Packing declarations have been in operation since around 1998/1999 [the time when I became a licensed customs broker]. International sea freight trade into Australia has changed dramatically since that time; the increase of sea freight shipments to Australia has increased year on year. As we are aware – as sea freight trade increases so does the increase of issues at the border.
The Quarantine department has changed its legal name four times since 1999 and they have been known over recent years as the Australian Quarantine and Inspection Service [AQIS], Department of Agriculture and Water Resources [DAWAR] to now simply as the Department of Agriculture [DOA]; with these changes comes logo and marketing material changes as well as management changes.
In the past three years the department has changed the packing declaration three times – and let me say the changes were so minute it was not worth the fuss. I believe that new employees joined the department and wanted to place their mark on their entrance or departure.
The issue I have with the one packing declaration template approved and created by the department is that they fail to understand that the packing declaration is required to be completed by suppliers or packers in overseas countries who do not have English as their first language; the department expects suppliers and packers in Non English Speaking countries to complete a template by answering questions and signing-off on it.
If the Australian Border Force can create twelve B534 unaccompanied personal effects statements for persons who are required to declare the contents of their personal effects, why can’t the Department of Agriculture create various templates for international traders who are required to complete a form which is not in their first language? [B534s can be found in English, Arabic, Chinese, Farsi, French, Greek, Italian, Japanese, Russian, Spanish, and Turkish].
Over the past 21 years, I feel that the effectiveness of a packing declaration has become relied upon to an ineffective degree. As customs brokers, we do not see the packing of shipping containers in overseas countries and we also seldom see the goods that enter the country – we work on documents. If the correct box is crossed, the goods avoid an inspection and can be delivered to the importer. To be quite blunt, I refer to this practice that has been in practice for some 21 years to be “tick and flick”.
To show how ineffective a packing declaration is – imagine this scenario – you have travelled to France, you are asked to complete an immigration card in French or you travel to China and you are asked to complete an immigration card in Chinese? It just doesn’t make sense that international suppliers and packers are required to complete a document which in more cases than not – they don’t fully understand.
To add salt to the wound – if all of the boxes are crossed correctly – the Department of Agriculture does not check the accuracy of those crossed boxes by physically inspecting against what has been stated.
The Department of Agriculture has charged customs brokers approximately $3900 “Approved Arrangement” fees over the past three years – we do most of the import compliance work – we should be compensated in doing their work – not asked to pay them $3900.
In New Zealand, they do not require packing declarations for less than a container load shipments; the Ministry for Primary Industries requires that all LCL shipments are inspected as they are unpacked from the full container load.