A non-regulated analysis of existing policy
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Why is this non-regulated analysis of existing policy being undertaken?
The Department of Agriculture helps people and goods move in and out of Australia while keeping Australia safe and protecting our industries from pests and diseases that exist in many other parts of the world.
As part of this role, the department is responding to a market access request from Japan for fresh table grapes.
What is a non-regulated analysis of existing policy?
A non-regulated analysis of existing policy identifies and assesses the risks posed by the pests and diseases relevant to an import proposal.
If the risks associated with a proposed import exceed Australia’s appropriate level of protection, the analysis of existing policy specifies what measures should be taken to reduce those risks to an acceptable level.
These procedures are described in the Import Risk Analysis Handbook 2011, available on the department website.
How is a non-regulated analysis different from an import risk analysis under the regulated process?
A non-regulated analysis is undertaken when the identified, potential quarantine pests of concern are the same as, or similar to, quarantine pests for table grapes from other countries for which import policy exists.
Import policy already exists for table grapes from China, Korea, New Zealand, Chile and the United States of America (California). Australia allows the import of fresh table grapes from these countries subject to specific quarantine conditions.
A preliminary assessment of the pests and diseases of table grapes from Japan concluded that most of the potential quarantine pests of concern identified are the same as, or similar to, quarantine pests for table grapes from China, Korea, New Zealand, Chile and the United States (California).
Given the similarity of pests of concern, and the potential mitigation measures, the department determined that the market access request for table grapes from Japan would be conducted as a non-regulated analysis of existing policy, rather than a regulated import risk analysis.
This approach is consistent with the Import Risk Analysis Handbook 2011.
Unlike a regulated analysis, there is no specific timeframe required to complete a non-regulated analysis of existing policy.
What quarantine pests have been identified?
The draft report identifies 19 pests of quarantine concern that require phytosanitary measures. Out of these 19 pests, 14 are arthropods and five are fungal pathogens.
The 14 arthropods are: Harlequin ladybird (Harmonia axyridis), Japanese beetle (Popillia japonica), grape whitefly (Aleurolobus taonabae), four species of mealybugs (Crisicoccus matsumotoi, Planococcus kraunhiae, Planococcus lilanicus, Pseudococcus comstocki), two leafroller moths (Eupoecilia ambiguella, Sparganothis pilleriana), Kanzawa spider mite (Tetranychus kanzawai), two species of thrips (Drepanothrips reuteri, Frankliniella occidentalis), spotted wing drosophila (Drosophila suzukii), and grapevine phylloxera (Daktulosphaira vitifoliae).
The five fungal pathogens are: black rot (Guignardia bidwellii), grape cluster black rot (Physalospora baccae), brown rot (Monilinia fructigena), Asiatic brown rot (Monilia polystroma) and grape rust fungus (Phakopsora euvitis).
Import policy already exists for the same or similar pests.
What quarantine measures have been proposed for fresh table grapes from Japan?
The draft report proposes a range of risk management measures, combined with a system of operational procedures to ensure quarantine standards are met. These measures will reduce the risk posed by the 19 quarantine pests, and achieve Australia’s appropriate level of protection. These measures include:
- phytosanitary inspection and remedial action for the management of the ladybird, beetle, whitefly, mealybugs, leafroller moths, spider mite and thrips
- area freedom, a systems approach or fruit treatment known to be effective in managing all life stages of spotted wing drosophila
- area freedom or fruit treatment known to be effective in managing grapevine phylloxera
- area freedom or a systems approach for the management of black rot, grape cluster black rot, Asiatic brown rot, brown rot and grape rust fungus
- a supporting operational system to maintain and verify the phytosanitary status of exported table grapes. This includes the pre-export phytosanitary inspection and certification by the Japanese Ministry for Agriculture, Forestry and Fisheries and phytosanitary inspection, remedial action if required, and clearance by the Australian Department of Agriculture.
Are there any regional differences for Australian states?
Regional differences were identified for two pests. A spider mite species was identified as a quarantine pest for Western Australia and a thrips species was identified as a quarantine pest for the Northern Territory.
The proposed quarantine measures take account of these regional differences.
Will Australia be adequately protected from exotic pests?
A comprehensive risk assessment of pests of quarantine concern has been undertaken. The pest risk assessments conclude that a range of risk management measures, combined with a system of operational procedures to ensure quarantine standards are met, will provide an appropriate level of protection to address any risks of exotic pests or diseases entering Australia.
The assessment is based on the latest available scientific information and reflects Australia’s conservative approach to managing biosecurity risks.
Can Australia have zero risk?
A ‘zero risk’ stance is impractical, as it would place severe restrictions on Australia’s tourism industry, international travel and commodity imports. Nevertheless, Australia adopts a conservative approach to quarantine to ensure that risks are managed to a very low level.
Science-based risk analysis provides an important foundation for safe trade. Australia only accepts imports once we are confident that the risks of pests that could be associated with specific imports can be managed appropriately, in accordance with Australia’s appropriate level of protection.
Australia exports almost two thirds of its agricultural produce. The future of our agricultural and food industries, including their capacity to contribute to growth and jobs, depend on Australia’s capacity to maintain good animal and plant health status. Our future also depends on the conditions our industries face overseas.
Therefore, it is very important to Australia that fair and consistent trading rules are in place around the world, as provided by the World Trade Organization. Australia cannot expect trading partners to take our export produce if we are not prepared to apply consistent rules to imported products, nor could Australia be optimistic about opening up new export markets.
Consultation
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Have stakeholders been consulted during the development of the draft report?
The Department of Agriculture consulted with stakeholders prior to commencement and during the drafting of the report. Stakeholders were given the opportunity to raise any concerns, and kept aware of the progress.
The department provided the draft pest categorisation table to the state and territory agricultural departments for their consideration of regional pests. Their comments have been considered and, where relevant, included in the draft report.
Meeting Australia’s food standards
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Does imported produce need to comply with Australia’s food standards?
Imported food for human consumption must satisfy Australia’s food standards. Australian law requires that all food, including imported food, meets the standards set out in the Australia New Zealand Food Standards Code.
Food Standards Australia New Zealand (FSANZ) is responsible for developing and maintaining the Code, including Standard 1.4.2, maximum residue limits. The standards apply to all food in Australia, irrespective of whether it is grown domestically or imported.
Background information
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Does Australia currently allow any imports of fresh table grapes?
Yes. Australia allows the importation of table grapes for human consumption from China, Korea, New Zealand, Chile and the United States (California) provided they meet Australia’s quarantine requirements.
Does Australia export fresh table grapes?
Yes. Australia exports table grapes to various countries. Key markets for Australian table grapes include Hong Kong, Indonesia, Thailand, Singapore, Malaysia, Vietnam and the Middle East. Exports to all markets for table grapes during 2007–11 were 30 000–70 000 tonnes per year.
Japan is currently finalising import conditions for Australian table grapes.
How big is Japan’s total export of fresh table grapes?
Table grape production in Japan is relatively small and the production has been declining in recent years. During 2007–11, the total export volume of table grapes from Japan to all markets was only 200–400 tonnes per year.
What time of the year does Japan export table grapes?
Generally, Japanese fresh grapes are exported from June to December, with the peak volume exported during August to October. This export season is counter-seasonal with Australia’s domestic table grape production.