Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA welcome the opportunity to provide feedback on the proposed remaking of four biosecurity legislative instruments scheduled to sunset on 1 October 2026. These instruments form a critical part of Australia's biosecurity and border management framework and have direct, day-to-day impacts on international trade and supply chain operations.
FTA / APSA support the department's objective to modernise the biosecurity regulatory framework through a risk-based approach that narrows or removes outdated requirements, strengthens regulatory capability where genuinely required, and improves the clarity and usability of the instruments. Our membership strongly supports robust biosecurity outcomes and recognises the importance of maintaining Australia's high biosecurity standards.
At the same time, members consistently emphasise that the effectiveness of the remade instruments will depend as much on practical implementation as on legislative drafting. Issues such as permit processing delays, inconsistent interpretation across regions, workforce capability, and the reliability and integration of digital systems materially affect compliance outcomes, supply chain efficiency and cost.
The submission highlights the need for nationally consistent application of the new instruments, transparent service standards, and proportionate regulatory responses that distinguish between isolated human error and systemic risk. Particular emphasis is placed on the role of Approved Arrangements, the importance of clear and practical reporting obligations, and the need for tiered, risk-based controls for low-risk goods, movements and conveyances.
FTA / APSA also stress the importance of aligning the remade instruments with modern supply chain practices, supported by reliable and integrated digital systems and clear operational guidance. Ongoing industry engagement, early access to exposure drafts, and a structured implementation roadmap will be essential to achieving effective and enduring outcomes.
FTA / APSA remain committed to working collaboratively with the department to ensure the 2026 biosecurity framework is practical, efficient, risk-based and capable of supporting both strong biosecurity protection and Australia's international trade competitiveness.