Licensing Review
While there have been some initial low level discussions between the DIBP and the CBFCA on the Licensing Review (whether it relates to licensed customs brokers, depots or warehouses), the lack of meaningful discussion between the parties worries the CBFCA. This Licensing Review, particularly in relation to its Terms of Reference, will impact on the regulatory/business interface for a significant future period, and in the CBFCA's opinion, to not devote the necessary time or resources to this process will have serious impacts and consequences not only for service providers in international trade logistics and supply chain management, but also for the DIBP, the Department of Agriculture and Water Resources, the Office of Transport Security, a variety of other governmental and non-governmental organisations and for importers and exporters (and other parties involved in international trade).
The timeline for the draft Recommendations was set as 14 April 2016 with a Review of submissions and Evaluation discussions to be completed by 4 May 2016 and Recommendations to be finalised by 30 June 2016. In the opinion of the CBFCA, this ambitious timetable is no longer realistic or appropriate. While it is understood that a request is being made for an extension of the Licensing Review timelines, this extension without appropriate interface with the industry association which represents, in particular, individual and corporate licensed customs brokerages, will, in the CBFCA’s opinion, not deliver the appropriate or desired outcome(s).
On this issue, the CBFCA would like to see a more coherent and coordinated approach to this Licensing Review with regular meetings between the parties.