FTA / APSA SUBMISSION - Submission to NTC on Landside Stevedore & Empty Container Park Charges

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) recently lodged a detailed submission to the National Transport Commission (NTC) in response to its consultation on updating the National Voluntary Guidelines for Landside Stevedore Charges and expanding their application to Empty Container Park (ECP) charges. The submission draws on extensive member feedback, ACCC monitoring data and Productivity Commission findings to demonstrate that while improved transparency and notice periods are welcome, voluntary guidelines alone have consistently failed to constrain the scale and frequency of landside charge increases. Why this matters to members Escalating landside and ancillary charges continue to be a systemic cost-of-doing-business issue for importers, exporters, freight forwarders, customs brokers and transport operators. These charges are unavoidable, non-negotiable, and imposed on parties with no direct commercial relationship with the charging entity, with costs ultimately compounded and passed through the supply chain to cargo owners. FTA/APSA's submission draws on extensive evidence, including ACCC monitoring reports, Productivity Commission findings, and direct member experience, demonstrating that voluntary frameworks have failed to restrain price escalation, despite improved notice periods and consultation processes. Key positions advanced by FTA/APSA In the submission, FTA/APSA acknowledge that the proposed national guidelines may deliver marginal transparency benefits and represent a constructive step compared to the absence of any national framework; however, voluntary guidelines alone are incapable of addressing the underlying market power imbalance. Key points include: Terminal Access Charges and ECP booking fees have increased by several hundred – and in some cases several thousand – per cent, despite stagnant or declining port productivity. Almost half of all stevedore revenue is now derived from landside charges, with cumulative Terminal Access Charge collections since 2017–18 exceeding total industry capital investment over the same period. The Victorian Voluntary Pricing Protocol, while improving process and notice, has explicitly failed to restrain price escalation, a position acknowledged by the Victorian Minister for Ports and Freight. Expanding a voluntary model nationally, and to ECPs, risks entrenching a framework that is procedural rather than protective. Formal Submission FTA / APSA recommendations The submission reiterates long-standing FTA/APSA advocacy for meaningful regulatory reform, including: RECOMMENDATION 1 - Ensuring any national framework includes enforceability, monitoring and consequences, not just transparency. RECOMMENDATION 2 - Rejecting reliance on voluntary guidelines as the primary policy response to landside charge escalation. RECOMMENDATION 3 - Implementing a mandatory national code, consistent with Productivity Commission recommendations, overseen by the ACCC. RECOMMENDATION 4 - Prohibiting the direct imposition of Terminal Access Charges and ECP booking fees on transport operators, requiring cost recovery from commercial clients (shipping lines) wherever feasible. RECOMMENDATION 5 - Where prohibition is not adopted, subjecting landside charges to regulatory oversight, including assessment of cost recovery, actual investment and reasonable returns. Next steps FTA/APSA will continue active engagement with the NTC as consideration of the consultation outcomes progresses, and will keep members informed of key developments. Member feedback and real-world case studies remain central to our advocacy, ensuring government decision-making is grounded in the practical cost and operational impacts of landside charging practices across the supply chain.

Tom Jensen - General Manager Freight Policy & Operations -  FTA / APSA Copyright © 2026 Freight & Trade Alliance (FTA) Pty Ltd, All rights reserved.