AFIF
Thursday, 3 November 2011
AQIS related issue:
Proposed changes to the Container Packing Declaration

A small industry group has worked with the AQIS Entry Management staff to streamline the current requirements and layout of the container packing declarations and the project is now at a stage where wider industry feedback / comment is invited in line with the AQIS email below.

Whilst the changes appear to be minor they are important in that they a) align the packing declaration with that of the NZMAF and b) remove the need to make a bark statement on the packing declaration; in other words whilst Bark Requirements remain in the Non Commodity Requirements Policy there is no requirement to make a bark statement in the packing declaration.

It would be greatly appreciated if you would provide your comments and or suggestions on the issue under reference to ensure that the widest possible input into these planned changes is available. Please also refer to the attached proposed new Packing Declaration.

Would you please provide your comments to the AICCC Secretariat at the following email address packingdec@aiccc.com so that all information can be consolidated and made available to the AQIS Entry Management team.

Dear All

I am seeking your comments relating to the following proposal by Entry Management and Process Reform. This proposal relates to the current Bark Requirements and the subsequent Bark Statement that is provided to AQIS or the Broker by the packer or supplier on either a Packing Declaration or Packing List or Invoice. We are seeking your support to remove the current Bark statement from the packer's declaration and align our bark requirements on this document similar to New Zealand's Bark documentation requirements. As you may be aware at the time the Department began accepting the full ISPM 15 standard for timber packaging, including the bark tolerance, neither the policy nor the packing declaration were amended to reflect this. AQIS advised the regions and industry that they would review the packing declarations statements and CA's in consultation with industry within 6 months, thus allowing industry to obtain the benefits of the bark tolerance application from the 1 July 2010 implementation date.

We are therefore proposing to amend the current wording in the Non-Commodity Information Requirements Policy.

From:

BARK STATEMENT

Where timber packaging/dunnage has been declared, including ISPM 15, AQIS requires a statement indicating whether the timber packaging/dunnage is free from bark.

The bark statement should read as follows: "Is all timber packaging/dunnage used in this consignment free from bark?" Yes/No/Not Applicable

AQIS will accept bark statements on the following documents:

  • Packing declaration
  • Packing List or Invoice

To :

BARK REQUIREMENTS

Wood packaging material contaminated with bark, soil, or other extraneous organic material (e.g. leaves, twigs) shall have the contaminating material removed (if possible) or treated, re-shipped or destroyed. Small and clearly distinct pieces of bark may remain on ISPM 15 marked wood packaging material and to solid wood packaging treated with other AQIS approved treatments if they are:

  • less than 3cm in width (regardless of the length), or
  • greater than 3cm in width, provided that the total surface area of an individual piece of bark is less than 50cm2.

This change and the changes we propose to the packing declaration (attached) will still adhere to the Bark on Timber Packaging and Dunnage requirements on AQIS Plant's web page, however it will relieve the current confusion for our AQIS officers/ Brokers and Industry who are assessing the documentation whilst also aligning Australia with New Zealand's importing documentation requirements.

You will also note that we have changed the layout considerably for the Packing Declaration for Full Container Loads, it is our aim to ensure that the confusion that surrounds the current FCL/LCL packing declaration for our regional officers and industry is removed and shipments are not held unnecessarily because of this document. This layout is also consistent with New Zealand's documentation requirements and we believe it would be an ideal opportunity and good Government practice for both Australia's and New Zealand's border agencies to align the sea container Quarantine/packing declarations (QD) as much as possible, especially for industry.

In saying this we are also proposing to remove the requirement for a packing declaration for LCL containers or to at least remove the current differentiation between FCL and LCL's, given that LCL's are moved and held at QAP's until deconsolidation results in the quarantine risk being managed within a confined area (unlike FCL which can be moved directly to the importer's premise), however this is still in the initial discussion stage and it should be noted that there are nil requirements for packers decs for any air cargo (which is very similar to LCL shipments i.e. one or two air cans with multiple consignees) and mail air or sea.

Could you please provide your comments to me regarding the change to the Non-Commodity Information Policy and the proposed packing declaration by COB Wednesday 9th November 2011, please do not hesitate to contact me if you have any questions.

Thankyou & Regards

Robyn Fraser
Manager
Entry Management & Process Reform, Cargo Branch
Quarantine Operations Division
Biosecurity Service Group
Department of Agriculture, Fisheries and Forestry
Phone: (02) 6272 3390
Fax: (02) 6272 5888
Post: GPO Box 858 Canberra ACT 2601

Thanks and regards

Brian Lovell
Chief Executive Officer

Australian Federation of International Forwarders Ltd (AFIF)
Suite 403, Level 3
152 Bunnerong Road
Eastgardens NSW 2036
Tel: (61 2) 9314 3055
Fax: (61 2) 9314 3116