FTA / APSA SUBMISSION - Establishment of Committee for Depot and Warehouse Licensing Matters

Tuesday, March 24, 2026

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) have lodged a detailed submission to the Australian Border Force (ABF) in response to its consultation on the proposed establishment of a committee to consider depot and warehouse licensing matters.

The consultation explores whether a committee modelled on the National Customs Broker Licensing Advisory Committee (NCBLAC) should be introduced to strengthen fairness, consistency, transparency and integrity in licensing decisions for customs depots and warehouses.

FTA/APSA's submission draws on extensive member feedback from licensed depot and warehouse operators, customs brokers, freight forwarders and logistics providers, setting out where a committee may add value — and where it risks diverting attention from more pressing operational issues within the current licensing framework.

Why this matters to members

Depot and warehouse operators, and the supply chains that rely on them, are directly affected by licensing delays, inconsistent interpretation of requirements, fragmented communication and lengthy approval processes.
Member feedback provided to FTA/APSA consistently identified that the most significant operational challenges are not related to the absence of a review committee, but to:
  • prolonged and opaque application and variation processing;
  • inconsistent expectations between jurisdictions;
  • repeated and duplicative requests for information;
  • poor visibility over application status; and
  • fragmented and inconsistent coordination between national licensing teams and state-based inspection functions.
In several cases, members reported depot licence applications extending beyond 12 months for approval, creating uncertainty, delaying investment decisions and imposing material commercial costs.

FTA/APSA's submission stresses that while a committee may assist with genuinely complex or adverse matters, it must not become a substitute for addressing these systemic administrative failures.

Key positions advanced by FTA/APSA

FTA/APSA acknowledge merit in the principle of establishing a committee, provided it is carefully designed, clearly scoped and supported by broader administrative reform.
Key points include:
  • A committee may improve procedural fairness and decision-making for complex, adverse or integrity-related matters, including suspensions, cancellations, rejections and fit-and-proper-person issues.
  • Routine, low-risk applications and minor administrative variations must be expressly excluded from any committee process.
  • Expanding committee involvement into ordinary applications risks adding another layer of formality, cost and delay to an already cumbersome system.
  • The most urgent reform priority identified by members is improving licensing administration, not expanding governance structures.
  • Without parallel reform to application processing, communication and national consistency, a committee alone will not resolve the core issues faced by industry.
Formal Submission
FTA / APSA recommendations

The submission reiterates long-standing FTA/APSA advocacy for meaningful regulatory reform, including:

RECOMMENDATION 1 – Proceed with a committee model in principle.
RECOMMENDATION 2 – Adopt a structure that is proportionate, efficient and clearly limited to complex, adverse and integrity-related matters.
RECOMMENDATION 3 – Confine committee involvement to:
  • complex applications;
  • proposed rejections;
  • suspensions and cancellations;
  • fit and proper person matters;
  • integrity concerns; and
  • higher-risk variations.
RECOMMENDATION 4 – Expressly exclude routine low-risk applications and minor administrative variations from committee processes.
RECOMMENDATION 5 – Publish clear referral criteria, procedural rules and indicative timeframes.
RECOMMENDATION 6 – Ensure the committee includes an independent chair and a genuinely experienced industry member.
RECOMMENDATION 7 – Maintain strong procedural fairness safeguards.
RECOMMENDATION 8 – Clearly define "low risk", "medium risk" and "high risk" matters.
RECOMMENDATION 9 – Establish clear conflict-of-interest and recusal arrangements for committee members.
RECOMMENDATION 10 – Introduce a centralised online application and variation portal.
RECOMMENDATION 11 – Assign a named ABF case manager for each application.
RECOMMENDATION 12 – Update and consolidate depot and warehouse guidance materials nationally.
RECOMMENDATION 13 – Provide access to pre-lodgement education or advisory engagement.
RECOMMENDATION 14 – Implement nationally consistent approaches to inspections, training and audits.
RECOMMENDATION 15 – Establish a separate consultative forum with industry to address process, guidance and emerging operational issues.
Next steps

FTA/APSA will continue active engagement with ABF as consultation outcomes are considered and decisions are made on the future design of depot and warehouse licensing governance.
Member feedback and real-world operational experience remain central to this advocacy, ensuring any reform improves efficiency, fairness and national consistency rather than adding further complexity to an already challenging licensing environment.
Members with additional case studies or operational insights are encouraged to contact FTA/APSA via email to Tom Jensen.
Upcoming 2026 FTA Section 77G & Approved Arrangement Forums

FTA will host its 2026 Section 77G & Approved Arrangement Forums across Australia, providing members the opportunity to hear directly from DAFF, Department of Home Affairs and Australian Border Force (ABF) senior officers.

  • NSW – Wednesday, 17 June 2026
    St George Motor Boat Club – Waterfront Function Centre, Sans Souci
    ??? Register HERE.

  • VIC – Wednesday, 24 June 2026
    Mantra Melbourne Airport, Tullamarine
    ??? Register HERE.

  • WA – Wednesday, 1 July 2026
    Tompkins Park Functions – Canning Room, Alfred Cove
    ??? Register HERE.

  • QLD – Wednesday, 15 July 2026
    The Colmslie Hotel, Morningside
    ??? Register HERE.

Full details and all upcoming events:
?? https://www.ftalliance.com.au/upcoming-events 

Tom Jensen - General Manager Freight Policy & Operations -  FTA / APSA

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