Freight & Trade Alliance (FTA) has received advice from the Department of Agriculture, Fisheries and Forestry (DAFF) on proposed reforms designed to address a longstanding anomaly in the management of imported sea containers moving through rural Australia. DAFF has now released an Import Industry Advice Notice and commenced a Have Your Say consultation on the proposed reforms. Members can access the notice HERE
Under existing arrangements, a container destined to be unpacked in a rural location is subject to a Rural Tailgate Inspection before leaving the metropolitan area of the port of discharge. DAFF publicly describes the existing requirement as applying to FCL containers destined for rural unpack, with containers required to meet applicable biosecurity clearance requirements before movement.
However, a container discharged in (for example) Melbourne and subsequently moved by road or rail through rural areas for unpacking at a metropolitan location in Sydney is not currently subject to an equivalent rural movement inspection.
DAFF is proposing to address this through a new Rural Transit Inspection requirement.
Proposed Rural Transit Inspection
Under the proposal, a container moving from a metropolitan location to another metropolitan location, but transiting through an area classified as rural, would require a five-sided external inspection before commencing the rural movement.
This differs from the existing Rural Tailgate Inspection applying to containers destined for rural unpack, which includes an internal tailgate inspection.
The proposed rural transit requirements are currently expected to commence from June 2027, subject to consultation, system changes and implementation readiness.
FTA concerns regarding responsibility and declaration requirements
Of particular concern to FTA is DAFF's proposal to use the Full Import Declaration (FID) and an amended Declaration Question in the Integrated Cargo System (ICS) to identify containers intended to transit through rural areas.
The proposal potentially places significant responsibility on customs brokers and accredited persons to identify whether a container will subsequently undertake a rural transit movement.
FTA has advocated that responsibility should rest with the party that has visibility and control of the physical landbridge movement, rather than placing an unreasonable obligation on a customs broker who may be far removed from the subsequent transport arrangements.
A customs broker may correctly lodge an FID based on the information available at the time, while the subsequent road or rail movement may be arranged or changed by an importer, freight forwarder, shipping line or transport provider without the customs broker's knowledge.
Importantly, DAFF itself acknowledges that customs brokers may not know the final route when lodging the declaration, with the proposal currently referring to information reasonably available at lodgement and reasonable due diligence.
FTA is particularly concerned that the draft policy also provides for compliance action against an Approved Arrangement where an accredited person fails to appropriately assess and declare rural transit movements.
FTA will continue to advocate for a model that appropriately manages the identified biosecurity risk without imposing compliance obligations on parties that do not have reliable visibility of, or control over, the physical container movement.
Changes to postcode classifications
Separately, DAFF is proposing changes to the way metropolitan and rural postcodes are classified.
A national review has assessed 2,644 postcodes, with 207 proposed for reclassification. DAFF is also proposing an interactive Postcode Classifications Map as the authoritative source for determining classifications and rural transit requirements.
The revised postcode classifications are currently proposed to commence from March 2027.
Consultation and member feedback
DAFF has now commenced its Have Your Say consultation process on the proposed reforms. FTA will provide members with consultation details and supporting material once available.
In the meantime, members are encouraged to review and consider how the proposed arrangements may affect their operations, particularly: - who currently has visibility of interstate or other landbridge movements;
- when those transport arrangements are known relative to FID lodgement;
- how changes to transport arrangements are communicated across the supply chain; and
- the practical implications for customs brokers and accredited persons operating under Approved Arrangement Class 19.1.
Members with concerns, practical examples or feedback are encouraged to contact the FTA team at support@ftalliance.com.au
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