In order to customs clear a typical sea freight shipment through Agriculture [Quarantine] where the goods are Manufactured Wooden Articles [MWA] from let’s say China, we would require:

1.            Commercial invoice

2.            Bill of lading

3.            Packing declaration and

4.            A fumigation certificate which has been photocopied on the darkest level to show the department that the water features “copy copy copy” are evident otherwise an inspection is required.

In September 2017, the Agriculture Department introduced an extra layer of paperwork to the tiresome process. All MWA goods that have been fumigated now need an extra layer of paperwork, a fifth document which typically is to be on the manufacturer’s or supplier’s letterhead, must be consignment linked, signed, dated and state:

“The [goods which have been fumigated] have been stored in an appropriate way to minimise the risk of infestation or contamination by pests of biosecurity concern between the date that the goods were treated and when the goods were exported.”

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Agriculture [Quarantine] stated that based on industry feedback and recommendations from the Import Conditions Review for timber and timber products, the department is increasing the time allowed between treatment and export for Manufactured Wooden Articles from 21 days to six months. This additional time between treatment and export is aimed at assisting manufacturers/suppliers to be able to effectively treat the goods at an appropriate time during their manufacture. However, to account for this increase in time between treatment and export, importers need to provide assurance that goods have not been infested with pests after treatment.

The storage certification provides the department with evidence that the goods have been stored in an appropriate way that limits the risk of infestation or contamination by pests of biosecurity concern for the entire length of time between the application of an appropriate treatment to the goods and export to Australia. [Bold is my emphasis]

In order to clear a typical sea freight shipment which contains MWA now requires five [5] documents and the cargo is not even checked or even verified that what is stated is actually true or accurate.

Customs brokers and other support staff would be aware that when Agriculture [Quarantine] introduced the Cargo Online Lodgement System [COLS] in 2017, that we are all now required to tick a box when we submit a shipment for processing that states: [bold is my emphasis]

By selecting the checkbox you declare that the information provided in this form is true and correct.

Providing false or misleading statements, information or documents to the Commonwealth, or to any other person in purported compliance with the law of the Commonwealth, is a serious offence under the Criminal Code Act 1995 (Cth) and is punishable by up to 12 months imprisonment.

Customs brokers and other support staff would not know if the information is correct or not, we are agents for the importers. This statement was never required from any person who submitted documents for processing to Agriculture [Quarantine]. In 2017, the Agriculture department placed the responsibility onto the persons submitting documents acting as agents for the importers.

Let’s not forget that during the past three [3] years the same department has changed the packing declaration three [3] times and still requires exporters / suppliers / manufacturers from Non-English Speaking Backgrounds to complete documents in English [for which they do not fully understand].

I think this is an approach of all risk covered but no responsibility on the part of Agriculture.

Peter McRae

CEO, Platinum Freight Management

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