FREIGHT & Trade Alliance (FTA) sees significant merit in "approved arrangements" and is actively working with the Department of Agriculture and Water Resources in the co-design of processes and accredited training. The arrangements allow industry participants to manage biosecurity risk in accordance with the requirements, using their own premises, facilities, equipment and people, and/or perform the documentary assessment of goods without constant supervision by the Department.

The one area that has been a concern is the associated cost recovery arrangements with the introduction of a blanket $2900 fee across all businesses participating in the program.

The need for financial reform was supported by the many members, particularly small to medium enterprises, who assisted in our arguments to the Department throughout the year during our face-to-face forums and by making important contributions to our formal submissions.
 
During November 2017, FTA received a favourable response in the form of Industry Notices 108 – 2017 and 109 – 2017 outlining proposed changes including a $500 annual fee for businesses solely involved in customs clearance activities with a capped price for those with several non-broker approved arrangements sites remaining at $2900.

The proposed charges for broker class (19.1 and 19.2) approved arrangement participants include:

• Participants will pay an annual charge of $500 in addition to an Automatic Entry Processing (AEP) charge of $18 per entry.  The annual charge ensures brokers not participating in the AEP scheme still contribute to the cost of operating the broker class approved arrangements.
• Participants that also operate a non-broker class of approved arrangement will pay both the higher non-broker charge totalling $2,900 in addition to an Automatic Entry Processing (AEP) charge of $18 per entry.

The proposed new changes for non-broker approved arrangements include:

• Biosecurity industry participants with one approved arrangement site will continue to pay an annual charge per ABN, however, this will reduce from $2,900 down to $2500.
• Biosecurity industry participants that operate more than one approved arrangement site will be subject to the $2,500 charge but will also pay an additional annual charge of $400, no matter how many additional sites they operate (i.e. total annual charge will not exceed $2900 per ABN).
• Should a biosecurity industry participant operate both a non-broker class of approved arrangement and a broker class, in addition to the annual $2900 charge, they will also be required to pay an Automatic Entry Processing (AEP) charge of $18 per entry.

Preliminary feedback from members has suggested:

• Return to a historical Cost Recovery Model whereby costs are recovered on every "Customs Entry" i.e. removing all 19.1 and 19.2 fees and recover costs (projected to be $2,038,679 in the next financial year) with a marginal increase against ALL sea import declarations. This would encourage a greater uptake of approved arrangements to further support efficient departmental administration and would align to the Australian Border Force model whereby their container x-ray costs are spread across all import sea import declarations rather than a fee against targeted containers.
• Introducing a differential fee for non-broker approved arrangement fees reflecting the scale between SME establishments as against multi-site corporations.

As outlined in the official notices, the consultation process on these proposed approved arrangement charging reforms will conclude 5PM (AEDT) Friday 5 January 2018. Feedback can be sent direct to DAWR at costrecovery@agriculture.gov.au.

We again encourage members and DCN readers to send feedback to me at pzalai@FTAlliance.com.au for incorporation into the final FTA / Australian Peak Shippers Association (APSA) submission.

Paul Zalai is director at Freight & Trade Alliance (FTA) and an advocate of the freight and trade sectors.
www.FTAlliance.com.au