Biosecurity Representation Update (NNF 2016/189)


As referenced in NNF 2016/096 AEP Reform Project Discussion Paper the CBFCA together with selected members who are high users of the Automatic Entry Processing (AEP) attended the AEP Project Reform Working Group meeting in Sydney on Tuesday, 29 November to discuss the industry feedback as to the reform of AEP and the process improvements which have been proposed by the Department of Agriculture and Waters Resources (DAWR).

The key topics discussed at the meeting include:
  • Commodity Expansion
  • New AEP model that is flexible for the management of commodity and non-commodity concerns
  • New simplified AEPCOMM codes and NCCC concern type to be included in BICON and possibly in third party software
  • Monitoring and assessing compliance – audit and sanction policy

The simplification of AEPCOMM codes and NCCC concern types was welcomed by industry and a recommendation for DAWR engagement with third party software providers to share reference files and possibly develop a drop down selection option in the software, which will eliminate manual entry and reduce human errors, resulting in improved AEP compliance.

The DAWR proposal to build a new AEP lodgement feature in COLS that requires minimal information to submit documents for each AEP transaction was not supported by industry as this will create additional work load, cost and disincentive for industry to use AEP. A post entry audit and request for documentation is the industry preferred option and this was strongly expressed by the CBFCA and members, users of the system at the meeting.

The DAWR project team was grateful for our feedback, which will enable them to take on board the industry feedback and recommendations as any system enhancements must meet the needs of the users.

This project is work in progress and we will keep you informed of any future developments as we work with the DAWR to reform AEP and increase the industry uptake.

Thank you to all the members that attended the working group meeting and your contribution to this reform project is much appreciated.

DCCC Meeting Update

On Wednesday 30 November the CBFCA as a member on the Department of Agriculture and Water Resources Cargo Consultative Committee (DCCC) attended the 75th DCCC meeting in Sydney.

Based on member feedback the two key issues that affect members are Service Delivery and Approved Arrangements Cost Recovery.

Service Delivery Operations

The CBFCA presented a position paper highlighting the key issues that affect members. Some of the recommendations in our position paper include:
  • Enhancement to COLS to prioritise entries in ETA order, provide cloning option of past entries and summary of entries submitted for visibility and traceability
  • Review COLS processing service standards as within 1 business day for urgent perishable airfreight cargo is not viable, industry preference is within 5 hours from receipt (or earlier)
  • Provide dedicated contact number for customs brokers to speak to senior assessment officer to address assessment and directions issues as the national numbers is not efficient for service providers that operate in fast moving and demanding industry 
     
Approved Arrangements Cost Recovery

As communicated to members in e-Bulletin Issue 22- 16 November 2016 – Approved Arrangements, the CBFCA has always opposed 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.

At the meeting the DAWR recognised the concerns raised by the CBFCA and is working with the Imports Industry Finance Consultative Committee (IIFCC), where CBFCA as your industry Association is represented to review the recovery mechanism for approved arrangements. DAWR will continue to work with the committee on ensuring a cost recovery model is developed for approved arrangements that will allow the costs of providing the approved arrangements systems to be recovered.

We will keep you informed of any further developments on this issue.

In summary individuals and businesses can still have an effect on regulators without belonging to an industry Association since regulators generally understand the value in preserving the single voice, but more often, it is the collective voice that speaks the loudest and for small and medium size business, it is your industry Association that often serve as the best opportunity to make your voice heard.