FTA / APSA SUBMISSION - RESPONSE TO THE SIMPLIFED TRADE SYSTEM CONSULTATION PAPER

Friday, July 28, 2023

FTA_Submission_STS.pdf

The Federal Government in its most recent budget committed an additional $23.8 million in 2023–24 to continue initiatives to modernise and improve Australia's international trade system.
Supporting this outcome, the Simplified Trade System (STS) Taskforce released a Consultation Paper last month for industry feedback.

Building on our previous submission from January 2022, Freight & Trade Alliance (FTA) and Australian Peak Shippers Association (APSA) incorporated extensive additional member feedback in preparing a detailed submission providing the below twenty-eight (28) key recommendations.
FTA / APSA SUBMISSION AVAILABLE HERE

SUMMARY OF RECOMMENDATIONS

RECOMMENDATION 1 – to ensure continuity and long term implementation of reform, the Federal Government to engage in bi-partisan support to establish the STS as a permanent body.
RECOMMENDATION 2 – the STS Taskforce to complete mapping of current processes / systems and the establishment of an agreed future plan including incremental steps to avoid the "big bang" introduction of systems, processes and / or statutory reform.
RECOMMENDATION 3 – the STS Taskforce to clearly articulate the full scope (boundaries) of the reforms and the Federal Government's needs in terms of data requirements, physical screening of cargo and limitations (lifespan) of existing systems.
RECOMMENDATION 4 – the STS Taskforce to communicate the opportunities available via the Customs Legislation Amendment (Controlled Trials and Other Measures) Bill 2022 to facilitate time-limited trials of trade and customs practices and technologies, with approved entities, in a controlled regulatory environment.
RECOMMENDATION 5 – the Australian Border Force to revise licensing conditions to permit customs brokers to short term lodge import declarations from overseas under prescribed circumstances.
RECOMMENDATION 6 – the STS Taskforce to support government departments in engagement with industry to set pragmatic service standards.
RECOMMENDATION 7 – the Australian Border Force to provide online access of import / export reports to approved trade entities.
RECOMMENDATION 8 – the STS Taskforce to oversee trial statutory reporting of fully digitised messaging between Australia and New Zealand.
RECOMMENDATION 9 – the STS Taskforce to complete a review into all cross-border fees and examine opportunities for a streamlined collection methodology. 
RECOMMENDATION 10 – the STS Taskforce to engage with government departments and industry to establish and maintain standards for fair, consistent and informed compliance regimes.
RECOMMENDATION 11 – STS Taskforce to oversee standardisation of export messaging standards including the development as defined by the International Plant Protection Convention (IPPC) - ePhyto Solution.
RECOMMENDATION 12 – STS Taskforce to provide a "roadmap" of reform and timelines for initiatives where the status, updates, changes are linked directly to development pipelines - at minimum, focussed quarterly STS project status reports.
RECOMMENDATION 13 – the Department of Agriculture, Fisheries and Forestry to engage with industry on STEPS and how it ties in with the broader STS roadmap.
RECOMMENDATION 14 – the Department of Agriculture, Fisheries and Forestry to engage with industry on strategies to move away from reliance on documents / manual assessments to the use of data to automate / streamline risk assessment of import cargo.
RECOMMENDATION 15 – the STS Taskforce to engage with industry to: streamline and harmonise Fit and Proper Person (FPP) across government departments; explore the opportunity and benefits of a single government body to manage FPP; and establish parameters and safeguards for FPP sharing across whole of government.
RECOMMENDATION 16 – additional benefits to be provided to Australian Trusted Traders by enhancing Full Import Declaration functionality by removing "lock down" periods and the introduction of periodic declarations.
RECOMMENDATION 17 – the Australian Border Force to engage with industry to reform the tariff concession system (TCO) addressing TCO applications; late communication; Tariff classifications; concurrent TA and TCO applications; Tariff classifications of TCOs to operate as a Tariff Ruling; TCO wording; amendments of TCO wording by TARCON; strict compliance; objections to TCOs; information requirements in making a TCO objection; revocation of TCOs; impact of TCO revocation and reissue on refunds; and Tariff decisions by Refunds and Monitoring Officers.
RECOMMENDATION 18 – the Department of Agriculture, Fisheries and Forestry to engage with industry to change the access terms or potentially repeal the Cheese and Curd Quota System to ensure the importers operate on an even commercial basis.
RECOMMENDATION 19 – the STS Taskforce to conduct a focussed review to re-engineer process, legislative and systems functionality in dealing with cross-border clearances of personal effects.
RECOMMENDATION 20 – the STS Taskforce to assist peak industry bodies in obtaining government funding to promote the trade sector to the employment market to meet the supply of personnel in roles such as (but not limited to) licensed customs brokers.
RECOMMENDATION 21 - the STS Taskforce to facilitate a review of government department targeting to ensure that traders with a demonstrated high level of compliance receive greater relief from physical inspections or audits.
RECOMMENDATION 22 - the STS Taskforce to facilitate a review of Product Stewardship statutory requirements and collaborate with industry to mandate "best practice" arrangements across end-of-life waste products.
RECOMMENDATION 23 – the Australian Border Force to engage with industry on implementation of a pre-load cargo reporting regulatory model and systems implementation.
RECOMMENDATION 24 – the Australian Border Force to phase out and replace the use of Digital Certificates with a more contemporary, cost effective and a whole of government approach to data integrity.
RECOMMENDATION 25 – the Australian Border Force to limit the ability of customs brokerages in making EFT payments of duty and / or GST on behalf of client importers, forcing the cargo owner to provide financial banking data direct to the ABF, to reduce opportunities of identity theft and 'piggy-back' illegal imports consignments.
RECOMMENDATION 26 – associated costs for the streamlined cargo intervention model to be borne by the Federal Government and remove the onus on stevedores (and potentially intermodal terminals / depots) from using their own mechanisms to cost recover operational costs against transport operators.
RECOMMENDATION 27 – the STS Taskforce to work with government departments and industry to introduce differential import processing charge payments for Australian Trusted Traders and 'green lane' biosecurity participants.
RECOMMENDATION 28 – the STS Taskforce to establish regulatory reform to mandate: terminals and depots to provide a minimum of three days free storage for goods held by government departments; and shipping line detention clock on the return of empty containers to commence once the cargo hold is removed
.