Approved Arrangements

Approved Arrangement as a topic is very similar to talking about the weather – much spoken about but little option as to what can be done. This is however not the case in relation to cost recovery as it relates to Approved Arrangements and the Compliance Agreements with licensed customs brokerages, particularly as to FCL/FCX accreditation and AEP for commodities. When this change was first mooted by the Department of Agriculture and Water Resources (DAWR), the CBFCA put forward cogent commentary as to why such cost recovery should not occur in the format proposed. It argued strongly that there had been significant DAWR human resource re-allocation and cost benefit when these Compliance Agreements were introduced. Since the notification of cost recovery for Approved Arrangements in e-Bulletin Issue 1 27 January 2016 and Issue 16 25 August 2016, the CBFCA has project managed (in conjunction with the Australian Federation of International Forwarders Ltd) work with the DAWR to readdress, and reassess, the cost for the Approved Arrangements. To this end, the CBFCA wrote to the Minister for Agriculture and Water Resources on 5 January 2016 and 27 May 2016 to address the issue.

The CBFCA has always contended that the Compliance Agreement which related to licensed customs brokerages undertaking FCL/FCX and AEPCOMM were inherently linked and structured to the DAWR import clearance process, and if there were to be any cost recovery as to Approved Arrangements (which covered off previous Compliance Agreements) then these should be part of the import process and costs linked to the Import Processing Charge (IPC). The CBFCA contends this is the correct position and has continued to work with the DAWR in seeking to ensure that costs related to those activities are part of the IPC. Other Approved Arrangements, particularly as to the previous Quarantine Approved Premises (the processes and outcomes which occur being, in the main, not being directly linked to the import declaration process) should be considered separately in terms of cost recovery arrangements.

Notwithstanding the position put in other places, the CBFCA and AFIF have continued over the last 12 months (since this cost recovery position on Approved Arrangements was introduced by the DAWR) to work towards a more equity-based solution. The CBFCA is aware that there is considerable cross subsidisation within existing DAWR cost recovery arrangements and has raised this aspect with the DAWR and the Minister. It is hoped that there will be a reconsideration by the DAWR on cost recovery as it relates to Approved Arrangements on Compliance Agreements.

The CBFCA and AFIF will continue to work collaboratively on the resolution of this matter on behalf of all licensed corporate customs brokerages which, in the CBFCA/AFIF combined Association representation, is well over 90% of the industry.