4. Barriers and challenges to accessing the benefits of trade and FTAs

Overview

4.1The Committee received evidence identifying several major barriers and challenges that have a significant impact on the ability of Australian businesses to access the benefits of trade and free trade agreements (FTAs). These include a range of non-tariff barriers (NTBs), complexity and administration costs, FTAs that are not fit for purpose or up to date, and the impact of a changing global trade environment. An ongoing focus on addressing or mitigating the impact of these key barriers and challenges is important to ensuring that Australia can maintain and increase the benefits received from international trade and its FTAs.

4.2NTBs can prevent the potential benefits achieved through FTAs being realised by restricting market access, reducing competitiveness, and increasing costs. NTBs must be regularly identified and addressed through FTAs, collaboration with trading partners, and through other dedicated mechanisms. Complexity and costs associated with FTAs can be significant and prevent businesses from accessing trade opportunities, particularly those associated with overlapping agreements and rules of origin (RoO). Efforts to reduce administrative complexity and costs, including through streamlined processes and increased use of digitalisation would be highly beneficial.

4.3FTAs that are not fit for purpose can mean that Australian businesses face declining market advantages or miss out on new markets or trade opportunities from emerging areas of the economy. Regular efforts should be made to ensure FTAs maintain market access relative to competitors and reflect current opportunities for Australian businesses. The global trade environment has changed in recent years with geopolitical tensions, rising protectionist sentiment, supply chain disruptions and trade restrictions impacting on international trade. Australia must monitor these developments, and seek to mitigate their impact through diversification, maintaining strong bilateral ties, and continuing to promote the global-rules based trading system.

4.4This chapter considers broader challenges and barriers to accessing the benefits of trade and FTAs. The level of understanding and awareness of the benefits of trade including how it impacts on the ability of Australian businesses to access those benefits are discussed in Chapter 3. Issues and challenges relevant to the ability of small and medium sized enterprises (SMEs), First Nations, and diaspora communities to engage in trade are discussed in Chapter 5.

Non-tariff barriers to trade

4.5Most submitters to the inquiry raised the significant impact of NTBs in preventing greater uptake of FTAs and benefits from trade.[1] Submitters varied in referring to NTBs, with some using the term interchangeably with non-tariff measures (NTMs) and technical barriers to trade (TBTs) while others made a distinction between them.

4.6NTBs were similarly defined by the Department of Foreign Affairs and Trade (DFAT) as policy measures other than tariffs ‘that unjustifiably restrict trade’ and by the Department of Agriculture, Fisheries and Forestry (DAFF) as measures that ‘are more excessive than necessary to meet legitimate objectives.’[2]

4.7NTBs were commonly identified as having the effect of distorting trade, limiting market access, reducing competitiveness, increasing transaction costs and risks, and ultimately preventing Australian exporters from fully benefitting from FTAs.[3]

4.8The Red Meat Advisory Council (RMAC) reflected that: ‘NTBs imposed by trading partners create challenges, and in some cases, the complete inability for exporters to access certain markets… despite having a trade liberalising FTA in place.’[4] It further explained that common NTBs relate to stringent sanitary and phytosanitary (SPS) standards, technical regulations, and customs procedures.[5]

4.9Similarly, the National Farmer’s Federation (NFF) described key NTBs in the agriculture sector as overly burdensome administrative processes, undue animal and plant health requirements, and non-transparent or inconsistently applied standards.[6]

4.10AUSVEG designated NTBs as including a range of regulatory and administrative measures such as stringent phytosanitary regulations, import quotas, labelling requirements, and standards that differ from international norms.[7] Specifically, it elaborated that: ‘Phytosanitary regulations, which aim to prevent the spread of pests and diseases, often vary significantly between countries and can be particularly stringent. Compliance with these standards can be costly and time-consuming for Australian producers.’[8]

4.11The Australian Dairy Industry Council (ADIC) described NTBs as burdensome export establishment regulations and prescriptive food safety standards that can pose significant obstacles to trade despite the removal of tariffs.[9]

4.12The Northern Territory Department of Industry, Tourism and Trade (NTDITT) highlighted the impact of divergent regulatory standards and technical requirements between countries such as product standards, safety regulations, and certification processes.[10] It also noted that complex and lengthy customs procedures that delay the movement of goods lead to increased costs and reduced competitiveness.[11]

4.13The Australian Industry Group (Ai Group) referred to NTBs as hidden obstacles within the trading landscape that cover a wide range of issues from protection of domestic industries to public safety.[12]

4.14The Australian Information Industry Association (AIIA) suggested NTBs such as quotas, licensing requirements, and technical standards that impede market entry prevent greater trade in digital products and services.[13]

4.15Spirits & Cocktails Australia (SCA) explained that it is both foreign compliance and regulatory requirements being in addition to domestic requirements as well as the variance between them that can result in significant risks and compliance costs for Australian spirits producers seeking to export.[14]

4.16Several detailed examples provided in submissions to illustrate the impact of NTBs are contained below in Box 4.1.

4.17Barriers and challenges to greater trade in native foods and botanicals such as classification and quarantine requirements are discussed under the First Nations heading in Chapter 5.

4.18The NFF, SCA, and Australian Grape & Wine (AGW) all contended that while tariff reduction remains important, NTBs can often have a greater impact on the ability of businesses to utilise FTAs and benefit from trade.[18]

4.19Though the effect of NTBs is widely considered to be large, few submitters provided quantified measures of their impact. Of those that did, Standards Australia cited research estimating that NTBs reduce global trade by over 3 per cent[19] and RMAC referred to research it had undertaken that assessed the value of the adverse impact of NTBs on the red meat industry at around $4.3 billion per annum.[20]

4.20It was observed that the presence and impact of NTBs has been increasing over time, with some also noting that this has occurred at the same time as tariffs have decreased.[21]

4.21Dr Wei Li attributed the rise in NTBs to factors such as increasing geopolitical tensions, the adoption of more protectionist policies, as well as growing concerns in areas such as national security, public health, and environmental protection.[22]

4.22DAFF observed that FTAs are progressively expanding beyond requirements related to biosecurity and food safety to include areas such animal welfare, pesticide use, sustainability, carbon emissions, traceability and geographical indications which can increasingly result in barriers to trade.[23] It added that these changes have led governments, notably the EU, to increasingly place restrictions on imports that do not meet European standards.[24]

4.23DAFF acknowledged that many of the requirements in areas such as sustainability and the environment have legitimate policy objectives, however it also noted that: ‘… they are sometimes imposed to be intentionally more trade restrictive than necessary to achieve their objectives.’[25]

4.24DFAT made the point that: ‘All trading nations have the right to set regulations to ensure the health, safety and wellbeing of their citizens, and to protect animal and plant life. These rights are enshrined in the rules of the [WTO] and other international bodies.’[26]

4.25The Australian Chamber of Commerce and Industry (ACCI) drew attention to research indicating that those exporting products into Australia face comparatively more NTBs than in other countries on average and made the point that reducing NTBs for both exports and imports will assist in maximising the benefits of trade.[27]

Divergent regulations and standards

4.26Several submitters specifically raised the issue of divergent regulations and standards as a significant barrier to greater trade.[28] DFAT explained that even when FTAs reduce or remove tariffs, differing standards and conformance procedures can impose high costs and can make export markets undesirable or even inaccessible.[29]

4.27Standards Australia also outlined that differing standards in importing markets can have a substantial cost impact and reduce opportunities for Australian exporters.[30] It submitted that: ‘… more attention needs to be placed on the effect of standards in international trade, as well as their role in facilitating a level playing field for Australian business in international markets.’[31]

4.28AGW indicated that wine is a highly regulated product globally and that varying regulations relating to testing, certification, and labelling that diverge from Australia’s standards increase compliance costs and make exporting less viable.[32]

4.29Ai Group described that technical standards, most often related to quality and safety, can differ greatly between nations which requires exporters to make costly adjustments to their products.[33] Ai Group also drew attention to a number of areas of divergence between Australia and New Zealand (NZ) that create additional costs and complexities for businesses.[34] Some of these included areas such as different standards (e.g. toilet pans for the disabled have different size requirements), absence of shared standards (e.g. sizes of pallets differ between Australia and NZ), and different certification systems (e.g. gas appliance certification systems differentiate between products sold in Australia, NZ and Australia/NZ).[35]

4.30Standards Australia noted that the economic impact of divergent standards across markets can be difficult to determine because its often not easily measured and quantified.[36]

4.31In contrast to divergent standards, Standards Australia emphasised that when standards are harmonised, for example with internationally agreed standards such as under the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC), they are easier to meet and costs can be lower.[37]

Improving standards harmonisation

4.32Standards Australia suggested that Australia should focus on a systemic approach that involves the pursuit of standards harmonisation during FTA negotiations.[38] Doing so would encourage deeper economic integration between Australia and key trading partners and would enable quick resolution of barriers arising from technical regulations incorporating divergent product standards.[39] It added that the focus on standards harmonisation upfront would be more effective in the long-run than the current ad hoc approach to managing and addressing barriers to trade.[40]

4.33Standards Australia further highlighted the role of FTAs in standards harmonisation: ‘Our FTAs are a key opportunity to pursue our open and collaborate approach to standards harmonisation, by negotiating substantial provisions enshrining these approaches in the agreements and by putting focus on standards harmonisation and cooperation in implementation agendas.’[41]

4.34Ai Group recommended a focus on enhancing regulatory coherence and suggested that a concerted effort to unify standards and simplify regulatory requirements can facilitate easier integration of global markets and ensure NTBs do not outweigh the advantages of trade.[42]

4.35The Business Council for Sustainable Development Australia (BCSDA) suggested that the Australian Government should prioritise both bilateral and multilateral efforts to harmonise standards.[43]

4.36Standards Australia also emphasised that: ‘Australia needs to play a proactive role in advocating for cooperative global approaches on standards issues, under the umbrella of the ISO and IEC.’[44] It added that this is important because some countries, such as China and the EU, are pursuing adoption of their own standards including in emerging areas such as green technology, digital trade, critical minerals, quantum computing, and artificial intelligence (AI).[45] Attempts to impose certain standards in markets rather than cooperating to establish more widely shared standards can lock out new market entrants, or advantage regional or country specific suppliers of products to the detriment of Australian businesses.[46]

4.37DFAT also indicated that some countries are advocating for the adoption of their national or regional standards in other markets.[47]

4.38The AIIA focussed on the need to establish internationally agreed digital standards or mutual recognition agreements to reduce barriers to digital trade.[48] It elaborated that:

… Government can support domestic capabilities in a technology-driven economy through regulatory dialogue and diplomacy to harmonise regulations and standards with important trading partners for successful digital exports and/or joint innovation. Equalisation of standards is important for an open, accessible and secure digital environment and is necessary to ensure privacy, interoperability and efficiency.[49]

4.39Standards Australia noted that Australia’s engagement in such proactive efforts for cooperation at the international level will require ongoing effort from DFAT and greater support from the Australian Government.[50] It also advocated for greater funding and resources to be allocated to promote standards harmonisation with trading partners at the implementation stage once FTAs are in force, which would be of benefit to Australian exporters.[51]

4.40DFAT advised that its NTB Strategy: ‘… seeks to align standards and conformance procedures with trading partners and to ensure Australia’s influence in international standards setting.’[52] It also noted that it uses both specific international standards and conformance bodies as well as other forums such as the Asia-Pacific Economic Cooperation (APEC) to promote international and regional harmonisation.[53]

Addressing non-tariff barriers

4.41Given their significant impact, many stakeholders raised the importance of addressing NTBs to increase access to benefits of FTAs and trade.[54] For example, the NFF stated that: ‘The reduction in prohibitive NTBs is central to the ability of farmers to realise the opportunities presented by FTAs.’[55]

4.42DAFF outlined that addressing the impact of NTBs is crucial to ensuring that trade volumes are maintained and continue to grow, especially as the initial competitive advantages held by many Australian exporters declines over time (discussed further below).[56]

4.43DFAT advised that it leads a whole-of-government NTB Strategy that is focussed on ensuring trade facilitative provisions in FTAs and utilising multilateral forums to prevent and resolve NTBs.[57]

4.44Standards Australia contended that Australia has been highly successful in achieving tariff reductions to encourage exporters but much less effective in addressing NTBs.[58]

Within free trade agreements

4.45Some submitters referred to FTAs being an important and effective mechanism through which to address NTBs, at least in some cases.[59] For example, AUSVEG advocated for a greater focus on addressing NTBs in FTAs: ‘In the review of existing, and negotiation of new, FTAs, further consideration must also be given to reducing [NTBs] in tandem with tariff relief, to ensure the full benefits can be realised by the Australian vegetable industry.’[60]

4.46The NFF advised that it has taken a strong position on NTBs linked to market access that would result in an inability to utilise trading volumes offered under the agreements and that it supports the Australian Government taking a strong position on NTBs in FTA negotiations.[61]

4.47DAFF explained that in response to FTA provisions that may result in requirements that act as barriers to trade it: ‘… seeks to use FTAs to minimise the risk of [NTBs] limiting our ability to trade freely.’[62] It also underscored the importance of establishing mechanisms in FTAs to provide avenues to raise and cooperate to resolve NTBs.[63] For example, the Indonesia-Australia Comprehensive Economic Partnership Agreement (I-ACEPA), includes provisions that enable both nations to nominate barriers for review and seek to find alternatives.[64] Another example is the A-UKFTA that established the Committee on Sanitary and Phytosanitary Measures and the Joint Working Group on Animal Welfare.[65]

4.48Likewise, DFAT highlighted the importance of ensuring trade facilitative language in FTAs to assist in reducing NTBs: ‘This includes supporting the negotiation of chapter text and implementation of TBTs, [SPS] and other chapters that promote trade facilitative approaches to the regulation of international goods trade.’[66] For example, the Singapore-Australia Green Economy Agreement (S-AGEA) contains annexes on identifying and addressing NTBs and standards collaboration, and the Indo-Pacific Economic Framework (IPEF) includes provisions around the use of interoperable standards and reduction of NTBs.[67]

Other channels and forums

4.49DFAT noted that while FTAs can assist in discouraging barriers to trade, addressing an NTB often requires several channels.[68] As follows, submitters discussed a range of other mechanisms that are important for addressing NTBs.[69]

4.50Joint government and industry efforts were identified as being essential to identify and resolve NTBs.[70] For example, ACCI advocated for continued focus on resolving NTBs and stated that: ‘Close engagement between industry and government is needed to ensure that barriers that risk impeding Australian businesses from capitalising on trade opportunities abroad are removed and contested, particularly where they risk nullifying the commercial opportunities opened up through Australia’s network of trade agreements.’[71]

4.51RMAC advised that it closely engages with DAFF and DFAT on NTBs including providing detailed evidence of the impact on trade and advocating for their removal or reduction.[72] It elaborated on the establishment of the Market Access Prioritisation Tool (MAPT) framework, a collaborative approach to prioritising and alleviating NTBs between industry, DAFF, and DFAT that involves structured consultations through a MAPT Working Group and regular feedback sessions.[73]

4.52The NFF outlined that NTBs require continual addressing at a government-to-government level and that the Australian Government should actively seek reform to address NTBs through FTA review mechanisms to ensure the full benefits of FTAs can be realised.[74]

4.53DFAT emphasised the importance of multilateral forums and ongoing engagement as an avenue to address NTBs.[75] It explained that Australia’s ongoing engagement with the WTO increases information sharing on technical regulations, standards, and conformity procedures under TBT and SPS Agreements which improves understanding of the regulatory environment of FTA partners and assists in identifying and communicating concerns about potential NTBs.[76]

4.54DFAT added that WTO Committees are an important mechanism to escalate concerns about NTBs and to coordinate multilateral efforts to build pressure to remove them.[77] In the WTO TBT and SPS Committees, Australia raises NTBs as Specific Trade Concerns (STC) when it considers measures to be unnecessarily trade restrictive. Recent examples include Indonesia’s halal regulations, China’s cosmetics regulation, and the requirement by India for health certificates with each imported food consignment.[78]

4.55DAFF drew attention to its role in assisting to mitigate the risk of NTBs arising from areas such as sustainability measures being included in FTAs by undertaking initiatives, including in collaboration with industry stakeholders, to demonstrate the sustainability credentials of food and fibre production in Australia.[79] This includes supporting traceability verification and assurance on sustainably produced products and animal welfare.[80]

4.56It was also suggested that there is a need to actively educate and raise awareness of known NTBs amongst exporters and potential exporters so that they can make better informed decisions, as well as understand the processes for identifying and addressing them.[81]

Complexity and costs

4.57Stakeholders commonly identified complexity and associated administrative costs as a significant barrier to greater utilisation and effectiveness of FTAs, particularly for SMEs.[82]

4.58BCSDA noted the complexity and administrative burden associated with FTAs and observed that the uptake of FTAs is higher amongst businesses that are able to allocate dedicated resources to navigating engagement with international trade.[83]

4.59ACCI declared that while some businesses may be able to absorb administrative burdens, for others it will limit their use of FTAs or deter their engagement with international trade entirely.[84]

4.60ADIC elaborated on the complexities and costs faced when engaging with FTAs: ‘To qualify for FTA benefits, businesses must often provide extensive documentation proving that their goods meet the necessary criteria, which can be cumbersome and costly, particularly as different FTAs have different rules and certification requirements even for the same trading partner.’[85]

4.61The Productivity Commission explained that when businesses apply for preferential and concessional treatment under FTAs, they incur compliance costs which prevent them from accessing the full benefits of FTAs.[86] It added that where administrative costs of engaging with FTAs are not prohibitive but lead to increased costs for business, the costs are ultimately passed onto consumers.[87] The Productivity Commission also highlighted previous research that estimated compliance costs to be between $0.7-$2.2 billion in 2019-20.[88]

Overlapping free trade agreements

4.62Several submitters nominated the overlap between Australia’s FTAs as a source of additional complexity and a barrier to greater uptake.[89] For example, ADIC noted that the administrative burden associated with FTAs: ‘…is exacerbated by the complex network of overlapping and intersecting FTAs among countries particularly in the Asia-Pacific region…[90]

4.63ACCI submitted that while FTAs are effective in enhancing trade, the cumulative expansion of a network of complex agreements adds to the complexity of their use for businesses.[91] To illustrate, ACCI referred to the case of Singapore for which Australian businesses have the option to utilise the Singapore-Australia FTA (S-AFTA), the ASEAN-Australia-NZ FTA (A-A-NZFTA), the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), and the Regional Comprehensive Economic Partnership Agreement (RCEP).[92] It added that overlapping agreements that often contain divergent requirements make it more difficult for businesses to be aware of opportunities available and to understand the relative merits of each agreement for a particular product or transaction.[93] Overlap ultimately imposes significant compliance and administrative costs on Australian businesses.[94]

4.64Ai Group made a similar point using Malaysia as an example, emphasising the added difficulties in determining how multiple FTAs connect and in assessing eligibility for preferential treatment when goods transit through multiple countries in the value chain.[95]

4.65ACCI recommended that the Australia Government focus on harmonisation and rationalisation across overlapping agreements where possible.[96]

4.66Ai Group focussed on the need for clear and comprehensive direction and assistance for businesses to navigate the complexities of overlapping FTAs.[97]

Rules of origin

4.67A significant number of submitters specified RoO arrangements as a major contributor to the complexity and costs of engaging with FTAs.[98] ACCI explained that the purpose of RoO are to: ‘… assist governments in determining the eligibility of products for access to the preferential tariff concessions negotiated between governments through demonstrating that the products have sufficient connection to the territories that are parties to the agreement.’[99]

4.68Similarly, Ai Group outlined that RoO evaluate whether enough value has been generated in FTA partner markets to qualify for preferential tariff treatment. It added that the primary objective of RoO are to address trade deflection, where products from countries outside agreements are routed through an FTA partner to receive beneficial tariff treatment.[100]

4.69DFAT advised that exporters may need a certificate of origin (CoO) to access preferential tariff rates and explained that CoOs: ‘… ensure that only goods that 'originate' in the countries party to an FTA obtain preferential tariff treatment. This prevents exporters from other countries gaining the benefits of the FTA by simply transhipping goods through one of the FTA parties.’[101] Ai Group described CoO as documentation issued by an authority in the exporting country that verifies the origin of a product determine if it eligible for preferential treatment under an FTA.[102]

4.70While the intent of RoO were widely acknowledged, submitters remarked on the significant complexity and costs incurred by Australian importers to demonstrate that goods are compliant with RoO.[103] It was noted that businesses that engage in trade in multiple markets across multiple FTAs face an additional challenges.[104] For example, ADIC described RoO as adding a layer of complexity and noted that different FTAs have varying definitions for the conditions under which a product is considered to be produced within the FTA region and therefore eligible for preferential treatment.[105]

4.71On a similar note, the NTDITT reflected that there are multiple sets of RoO that have minor but potentially significant differences.[106]

4.72Ai Group indicated that: ‘A product that is eligible in for one FTA may, may not be eligible in another territory due [to] the unique criteria and standards of each agreement.’[107]

4.73ACCI underscored the impact of varying requirements for RoO on businesses:

… the proliferation of inconsistent and unharmonized [RoO], terminology, documentary requirements, compliance requirements and processes in each agreement further add to the challenges for traders. In addition to the administrative costs imposed on businesses in seeking to understand and meet those requirements, traders face administrative costs or liability in the event of non-compliance or where the validity of their origin claims is called into question.[108]

4.74According to Ai Group, importers have expressed concerns about administrative costs and delays related to obtaining CoOs or Origin Declarations.[109] It concluded that these obstacles: ‘… play a significant role in the choice to forgo FTA preferences, which result in increased expenses for products brought in from FTA partners, weakening the basic intent of these agreements.’[110]

4.75DFAT advised that it provides information to assist with understanding RoO via its FTA Portal and Austrade noted that a RoO Guide is available through its Go Global Toolkit digital service.[111]

4.76The Department of Home Affairs (DHA) explained that it provides advice on application at no charge that enables those importing goods into Australia to seek a binding ruling as to whether their goods meet the RoO of an agreement.[112]

4.77ACCI advised that, where permitted, it supports businesses to meet requirements by providing third party CoO that facilitate trade and provide support to traders in event that they confront challenges in crossing borders.[113]

4.78DFAT explained that modern RoO in regional FTAs provide for cumulation, which is: ‘…. the ability for value-adding activities along a supply chain to take place across several countries while still qualifying for preferential tariff treatment.’[114]

4.79Ai Group also made the point that Australian exports miss out when buyers do not request a CoO or Origin Declaration, forgoing savings that could be passed onto consumers and reducing the competitiveness of Australian products in overseas markets.[115]

Streamlining and digitisation

4.80Several submitters focussed on the need to reduce the complexity and costs of participating in international trade through efforts to streamline administration and increased digitisation.[116]

4.81Professor Richard Pomfret submitted that simplification of international trade will ensure continued benefits and that while the benefits of reduced complexity are difficult to measure, they are greater than specific market access benefits.[117]

4.82Ai Group emphasised the need for standardisation of RoO between FTAs and that businesses would benefit from clear and consistent rules.[118] Further, there are large efficiencies to be gained for business and government through simplified CoO application and automation, particularly for low risk or low value shipments.[119] It also suggested the development of additional training and resources on RoO for each FTA to assist business understanding.[120]

4.83BCSDA suggested the Australian Government should prioritise efforts to simplify customs procedures and referred to the EU's Single Window Environment for Customs, which streamlines customs processes across member states as informative.[121]

4.84The NTDITT also mentioned the need for the Australian Government to enhance support for streamlining customs procedures to reduce the burden on business.[122]

4.85DHA outlined its Australian Trusted Trade program, a partnership with accredited Australian businesses to streamline trade by reducing administration at the border, improving export market certainty, and expediting the flow of cargo in and out of Australia.[123] It further explained that the program includes the Origin Waiver Benefit that removes the requirement for importers to obtain a CoO or DoO under 13 FTAs making it easier to claim preferential rates of customs duty, as well as the Origin Advance Ruling that removes the requirement for a CoO under the China-Australia FTA (ChAFTA) by enabling importers to request a single advance ruling that refers to goods classified under multiple tariff classifications and consignments.[124]

4.86The NTDITT and AIIA both emphasised the benefits of enhanced digitisation of trade related documentation.[125] The AIIA detailed that digital or paperless trade can reduce costs, streamline customs procedures, and reduce barriers to digital goods and services trade.[126] It noted that online tools and platforms can help overcome barriers and described paperless trade as including acceptance of secure cross-border electronic signatures, e-certificates, e-payments, and e-invoicing.[127]

4.87DHA provided information on its Digital Verification Platform that: ‘… is designed to enable trade through high integrity verifiable digital documents between international parties who may not have an existing trust relationship.’[128] The concept involves exploring and trialling converting CoO into verifiable credentials to support authenticating CoOs to ensure appropriate application of preferential tariff rates.[129]

Fit for purpose and up to date free trade agreements

4.88The Committee received considerable evidence that broadly referred to the need to ensure that Australia’s FTAs remain fit for purpose and up to date if Australia is to maintain and expand the benefits received from trade.[130] This included maintaining relative market positions, establishing new FTAs, and expanding the coverage of existing FTAs including accounting for emerging products and technologies.

4.89It was suggested that the assessment of whether FTAs are fit for purpose and up to date should be a key focus of regular FTA review processes.[131] For example, the NTDITT stated that review mechanisms within FTAs should be utilised to assess their effectiveness and make necessary enhancements to ensure they remain relevant and beneficial in a changing global trade environment.[132] Likewise, AUSVEG considered that: ‘FTAs entered into years ago must be the focus of ongoing review and, where applicable, updating, to ensure they remain fit for purpose.’[133]

Maintaining market position relative to competitors

4.90The Committee heard that the benefits received from FTAs have declined over time as the advantages afforded to Australian exporters reduce relative to competitor nations.[134] As explained by the ADIC:

Over time, as other countries negotiate their own FTAs with the same trading partners, the competitive landscape can shift, potentially eroding the advantages previously gained. For instance, agreements like J-AEPA [Japan-Australia Economic Partnership Agreement] and the K-AFTA [Korea-Australia FTA] have demonstrated how competitors can negotiate similar or better terms, leveling the playing field for all participants or potentially putting Australia at a disadvantage.[135]

4.91DAFF similarly explained that Australia benefitted greatly as an early mover in establishing many FTAs that resulted in agricultural exporters facing low tariffs compared to many competitors.[136] However, as other countries have increasingly signed FTAs with those buying Australia’s agricultural exports, the initial competitive advantage has gradually decreased for certain products in some markets.[137]

4.92GrainGrowers also noted that the grain industry benefited significantly from signing FTAs with trading partners before other nations, resulting in lower tariffs for Australian exports than for many key competitors.[138]

4.93Several detailed examples provided in submissions to illustrate declining market advantages for Australia exports over time are contained below in Box 4.2.

4.94ADIC emphasised that it is critical to recognise that the uptake of economic benefits stemming from FTAs needs to be considered alongside the competitive advantage they afford Australian exporters compared to rival exporting countries.[143]

4.95The NTDITT stated that to maintain the competitiveness of Australian exporters, it is crucial to continuously evaluate and enhance FTAs including by: ‘… monitoring third-country agreements that may offer better market access terms to competitors and negotiating adjustments to Australian agreements to match or exceed these terms.’[144]

4.96Canegrowers similarly expressed that it is important for Australia to be competing on at least an equal footing to key competitors as the terms of Australia’s market access affects the profitability of both cane growers and sugar mills.[145] Subsequently, Canegrowers emphasised that ongoing effort is needed to: ‘Ensure market access gains are not eroded by third country agreements providing market access to competitors on better terms than are available to Australian exporters.’[146]

4.97AGW suggested that seeking MFN treatment to ensure Australian exporters receive at least the same benefits as competitors should be a priority for new and updated FTAs.[147] It elaborated on the benefits of the approach:

Australia included MFN clauses for wine in the Australia-India Economic Cooperation and Trade Agreement (A-IECTA), ensuring our wine cannot be undercut in that market. This provides valuable future security and certainty regarding market prospects. We recommend that, where complete tariff removal is not possible, MFN clauses for wine be included as much as possible in future Australian FTA negotiations.[148]

4.98The Productivity Commission submitted that its previous research has shown that Australia can be worse off when tariffs are reduced between Australia and the entrant to a regional agreement, because the acceding country is a competitor in Australia’s key export markets.[149] For example, when the US and all members of the CPTPP reduce their tariffs bilaterally, they compete directly with Australian exports of wheat and beef.[150]

4.99DAFF reflected that as the initial competitive advantage declines Australia must pursue the economic viability and competitiveness of its agriculture sector through the maintenance of open international markets, reducing NTBs and improving technical market access, negotiating new and updated FTAs, enhancing trade facilitation efforts, and responding to social concerns by improving sustainability and emissions credentials.[151]

Free trade agreement coverage

Products and emerging areas

4.100Submitters drew attention to a diverse range of products and emerging areas that may not be adequately covered by Australia’s existing FTAs and that could be sources of additional benefit from trade for Australia.

4.101Canegrowers suggested that market access provisions for Australian raw sugar should be revisited under both the Australia-US FTA (A-USFTA) and ChAFTA, with both having excluded new market access opportunities.[152] It added that both the US and China are significant global sugar importers and that there is excess demand to be met without effecting domestic producers.[153]

4.102The Australia China Business Council (ACBC) reflected that after 10-years of ChAFTA, there are new areas of trade that are not addressed in the agreement that should now be considered.[154] It nominated areas such as the growth in services exports for Australia, the green energy transition, and the economic activity arising from the digital transformation.[155]

4.103The AIIA emphasised that: ‘It is essential that older FTAs are updated to reflect the importance and growth in tech industries, E-commerce and digital trade.’[156] It highlighted S-AFTA and the A-UKFTA as effectively addressing digital trade, as well as the Australia-Singapore Digital Economy Agreement (A-SDEA) which establishes digital trade rules and provides for collaboration on the digital economy.[157]

4.104Cellular Agriculture Australia (CAA) explained the concept of cellular agriculture:

Cellular agriculture uses cells and innovative technologies to produce new ingredients, food and agricultural products… The technologies used include precision fermentation, cell cultivation, gas fermentation and molecular farming. The most common food and ingredients being created are meat, seafood, dairy proteins and fats, which are typically derived from animals.[158]

4.105CAA outlined the strong potential for the cellular agriculture industry and advised that as a predominantly pre-commercial industry the absence of institutional arrangements to support trade mean that it is effectively excluded from Australia’s FTAs.[159] It added that it aims to have cellular agriculture products incorporated into existing FTAs through scheduled review processes.[160]

4.106Following the inclusion of an innovation chapter in the A-UKFTA, Group of Eight Australia (Go8) recommended an innovation chapter be standard in all new and updated FTAs to recognise the centrality of research to innovation in emerging technologies that will drive future competitiveness in the global economy.[161] Go8 added that such chapters can provide opportunities to develop strategic alliances and collaboration, strengthen workforce skills and cultural ties, provide links for commercialisation, and reduce administrative burden through shared intellectual property (IP) and data sharing.[162]

New free trade agreements

4.107Several stakeholders contended that Australia would benefit from new FTAs covering additional markets. ADIC specifically stated that the absence of an FTA with Taiwan is a significant gap in Australia’s FTA framework and that: ‘… the Australian dairy industry asks the Australian Government to continue to explore and pursue avenues to complete a bilateral [FTA] with Taiwan. Such an agreement could significantly improve Australia's competitive advantage in the growing Taiwanese market.’[163] It noted that NZ has obtained substantial benefits from its agreement, including that since 2021 99.6 per cent of goods exported from NZ to Taiwan are tariff free.[164]

4.108AUSVEG also advised that not all key export destinations are covered by FTAs and that vegetable exports can be subject to high import duties which reduces their competitiveness.[165] To illustrate this it reflected on the impact of the stalled negotiations for the proposed Australia-EU FTA (A-EUFTA):

Australia was unable to finalise an FTA with the [EU] which now puts the Australian vegetable industry at a considerable disadvantage against key rival [NZ], a major vegetable producing country, which successfully negotiated an FTA with the EU, which came into force on the 1st May 2024.

[NZ] onion producers will now have a significant commercial advantage over Australian growers with their tariff dropping from 9.65% to zero.

Establishing commercially meaningful access to the EU for Australian growers via a matching of the tariff elimination afforded to [NZ] producers, has been identified as an urgent priority for our industry in the establishment of any FTA.[166]

4.109Several submitters noted the potential benefits of an A-EUFTA but also expressed support for the Australian Government in not finalising the agreement given the EU’s position in areas such as Australian beef, sheep meat, and sugar exports as well as geographical indications related to wine and dairy products.[167]

4.110ADIC emphasised the potential risk to the Australian dairy industry arising from the A-EUFTA in its current form and stated that it: ‘… underscores the need for careful, strategic negotiation to protect national interests while seeking beneficial trade opportunities.’[168]

4.111As outlined by DFAT, in addition to the 18 FTAs currently in force, Australia has two FTAs under negotiation in the A-EUFTA and the Australia-India Comprehensive Economic Cooperation Agreement (A-ICECA).[169] There are also two FTAs signed but not yet in force in the Second Protocol to upgrade A-A-NZFTA and the UK Accession Protocol to the CPTPP.[170]

4.112Some submitters acknowledged the strong benefits of bilateral and regional FTAs, particularly as trade liberalisation at the multilateral level has been increasingly difficult to achieve.[171] However, it was emphasised that Australia’s interests are best served by a multilateral approach that promotes a globally open trade, centred on the WTO and other international fora.[172]

4.113The Productivity Commission advised that based on modelling it has undertaken there may be limited benefit provided by further tariff reductions through FTAs and that: ‘… unilateral reduction of tariffs increased Australia’s economic output the most and is the most effective way to progress trade liberalisation in the absence of multilateral trade liberalisation.’[173]

Changing global trade environment

4.114The Committee received evidence that identified rising geopolitical tensions, protectionist sentiment, supply chain disruptions, and trade restrictions as factors contributing to a significantly changing global trade environment. Further, that these developments pose a significant challenge to the interconnected global economy and specifically for Australia in accessing the benefits of trade and FTAs.[174]

4.115DAFF stated that: ‘… some countries are increasingly turning towards protectionist economic policies, undermining the institutions and rules that govern international agricultural trade.’[175]

4.116It was observed that global supply chains are facing significant challenges with ongoing impacts from COVID-19, conflict in Europe and the Middle East, and adverse climatic conditions as key contributing factors.[176]

4.117Significant increases in freight costs and logistical challenges globally were also mentioned as factors affecting the competitiveness of Australian exports in international markets.[177]

4.118Trade and Investment Queensland (TIQ) denoted that another factor affecting the global economy is the rising preference for domestic brands amongst Chinese consumers due to growing nationalism and a weakening Chinese economy.[178]

4.119Some mentioned that it is important for Australia to strengthen its support and advocacy for the rules-based trading-system and multilateral approach to international trade in the face of growing challenges.[179]

Chinese trade restrictions on Australian exports

4.120Some submitters specifically raised the tariffs and trade restrictions imposed by China on a range of Australian exports such as barley, wine, lobster, and beef.[180]

4.121The ACBC described the recent trade situation with China:

Between April 2020 – March 2024, a number of Australian industries (wine, lobster, barley, coal and others) faced trade barriers to China due to the deterioration in bilateral relations, leading in some cases, to specific increased tariffs directed by the Chinese Government and, in other cases administrative policies that impacted the exporters’ ability to access the China market.[181]

4.122The ACBC outlined that the ban on live lobster exports to China resulted in a total loss of $420m per annum in total loss to lobster fishers, with $1.7b total lost revenue since 2020. This has had significant impact on coastal fishing communities from Western Australia to Tasmania.[182] ACBC added that two Australian abattoirs and the live lobster trade still face restrictions.[183]

4.123AGW outlined that in recent years there have been: ‘… profound and immediate impacts of broader geopolitical influences on trade. These influences have the potential to undermine the utilisation and benefits of Australia’s FTAs across all industries. For example, China’s imposition of anti-dumping duties on Australian bottled wine… completely nullified the positive benefits of ChAFTA.’[184]

4.124Canegrowers described the detrimental impact of ‘unofficial’ sanctions on Australia sugar exports to China, which had grown significantly since ChAFTA began in 2015.[185]

4.125The Bankwest Curtin Economics Centre (BCEC) advised that some sectors such as barley were able to pivot to alternative markets when facing trade restrictions whilst others such as wine and lobster faced difficulties in doing so.[186]

Market diversification

4.126The need for increased market access and diversification in export markets was presented as a key component in mitigating risk against the challenges arising from a changing global trade environment.[187] Several submitters made the point that export market diversification has been underpinned by Australia’s FTAs, and that greater diversification will be supported by new and upgraded FTAs, as discussed earlier in this chapter.[188]

4.127RMAC submitted that the enhanced level of market access provided by Australia’s FTAs over the last two decades has enabled strong diversification in red meat export markets which has assisted to cushion the industry from the negative impact of market and political disruptions.[189]

4.128In relation to global trade environment challenges and NTBs, DAFF stated that Australian farmers and industry groups are cognisant of developments in overseas markets and are supportive of new or upgraded FTAs to facilitate continued diversity in export markets.[190]

4.129Canegrowers elaborated on the advantages of market diversification:

With many economic, strategic and geopolitical uncertainties impacting the world economy and commodity markets, uncertainties about future disruptions to trade remain. In this environment, securing access to a wide range of markets is vitally important. The value of market diversity must not be understated. It provides export options and increases the competition amongst importers seeking cane sugar which is produced to the highest environmental and sustainability standards. This enables Australia to extract the full premium value of our sugar in all markets.[191]

4.130The NFF also outlined the need to continue focussing on growing export market options: ‘Farmers now more than ever are aware of the risks of an overreliance on a single trading partner, and the impact that protectionism can have directly on their business. Given this challenge, expanding and diversifying our trading partners, particularly within our immediate region, will be critical to mitigating this risk and ensuring farmers have stable and predictable markets to sell their produce.’[192]

4.131In response to adverse impacts of external factors on the wine export industry, AGW advised that: ‘Efforts have been concentrated on resourcing and promoting top markets to maximise their potential and further capitalise on Australia’s strong market position. However, this reliance on a small number of key markets increases vulnerability to adverse trade impacts. For these reasons, a broad range of meaningful and effective FTAs is vital for the sector’s future success.’[193]

Committee comment

4.132The Committee agrees that the barriers and challenges identified are major impediments on the ability of Australian businesses to maintain and expand the benefits received from trade and free trade agreements (FTAs). Australia has had remarkable success in negotiating substantial FTAs, however work does not end when an agreement is signed. Significant and ongoing work is required to make the potential benefits of an agreement a reality. Being cognisant of, and actively working to address these challenges, is essential for ongoing the success of many Australian businesses, industries, the national economy and the livelihoods of Australians.

4.133The Committee recognises non-tariff barriers (NTBs) that prevent access to expected trade opportunities are especially challenging for businesses. While many NTBs are in place to achieve legitimate policy goals, some are imposed to achieve domestic economic and social policy goals that may be designed to restrict trade. The Committee agrees that divergent regulations and standards can be a sizable obstacle to the uptake of trade opportunities and that greater standards harmonisation can reduce costs and improve access to export markets.

4.134The increase in NTBs across the global trading landscape is of significant concern for Australia. It appears that in some cases NTBs are undermining the favourable outcomes achieved through FTAs, which often take considerable resources to negotiate and implement over many years. The Department of Foreign Affairs and Trade (DFAT) and the other agencies involved, are well-aware of the significance of NTBs and are working to address them proactively through FTAs, collaboratively with trading partners, and through multilateral forums. However, an ongoing focus on addressing or mitigating the impact of NTBs is essential to ensuring that Australia can continue to realise the benefits of trade. As well as consideration up front in the development of new agreements, addressing NTBs should be a key focus in the review and update of FTAs.

4.135The Committee also recognises that Australia imposes NTBs on other countries and that these should be identified and removed where appropriate to provide greater access to the benefits of trade on the import side.

4.136The Committee agrees that participating in international trade can be complex and can incur substantial costs, sometimes to the point that it may discourage businesses from taking up trade opportunities. Differences in requirements between agreements is inevitable to some extent as each agreement is negotiated at a point in time, often with many parties. Government should provide support for businesses to make informed decisions when faced with choices between FTAs and should proactively seek to harmonise requirements between agreements where possible. Improving consistency between requirements around rules of origin (RoO) and certificates of origin (CoO) would provide particular benefit. While these have a valid intent, in many cases they may be unnecessarily adding to costs and even causing businesses to forgo trade opportunities.

4.137The Committee is encouraged by some of the initiatives referred to in evidence that are aimed at decreasing administrative burden through digitisation and streamlined processes. These types of initiatives that can lead to reduced complexity, lower costs, and efficiencies should be prioritised.

4.138The Committee agrees that it is essential for Australia’s FTAs to be fit for purpose and up to date. Regular reviews should evaluate whether FTAs are operating as intended and ensure that Australia is receiving the expected benefit. The Committee is concerned by the examples of Australia’s relative decline in market access over time. Where possible, proactive measures should be taken with trading partners to rectify this, and Australia should seek to have at least equal access to that of export competitors. It is also important for FTAs to be updated to revisit the coverage of certain products and services over time, and to include new and emerging areas of economic activity where Australia may have an advantage. The Australian Government should also continue to examine the potential for new bilateral FTAs, provided that they maintain Australia’s interests and result in genuine net benefit.

4.139The Committee acknowledges that several factors have combined in recent years to bring considerable changes to the global trade environment and that this poses a significant challenge to Australia as a trading nation. Since the conclusion of the evidence gathering phase of the inquiry, uncertainty in the global economy has grown further with the imposition of tariffs on some countries by the new United States (US) Administration and the potential for retaliation. The Australian Government must continue to monitor these developments for their impact on Australia and seek to mitigate them where possible. It must also continue to strongly emphasise the benefits of global rules-based trading system and multilateral approach to international trade.

4.140In relation to trade restrictions, the Committee notes that having an FTA in place fostering mutually beneficially trade outcomes is not enough on its own to preserve trade flows and that maintaining diplomatic relationships is critical. However, it is essential that the Australian Government continues to push back against unfair and unjustified trade restrictions imposed on Australia and uses mechanisms under the global trade architecture to defend its interests where appropriate.

4.141The Committee agrees that diversification of Australia’s exports is important for reducing the impact of both long-term and more acute changes in the global trade environment. Diversity across products and markets is important at the national level, for export markets within industries, and within bilateral trading relationships. That is, the number of markets should be expanded as well as the depth of trade with existing trading partners.

Recommendations

4.142The Committee recommends that the Australian Government continue to resource the Department of Foreign Affairs and Trade, and other relevant departments and agencies, to work proactively with industry to identify and resolve non-tariff barriers to trade.

4.143The Committee recommends that the Australian Government prioritise increased efforts to broaden and diversify trade relationships to mitigate the against future shocks in existing trade relationships. This should include:

• Working to develop bilateral, regional, and multilateral agreements with new trading partners; and
• Broadening existing relationships to cover additional goods and services, including emerging areas of economic activity.

4.144The Committee recommends that the Australian Government accelerate initiatives to improve consistency and streamline requirements involved in accessing benefits under free trade agreements, particularly relating to rules of origin and certificates of origin.

4.145The Committee recommends that the Australian Government give greater consideration to standards harmonisation during free trade agreement negotiations and continue to proactively engage in advocating for standards harmonisation at the multilateral level.

Footnotes

[1]See, for example: Standards Australia, Submission 1, pp. 1–2; National Farmer’s Federation, Submission 8, pp. 3–4; Australian Grape & Wine, Submission 9, p. 5; Australian Industry Group, Submission 11, pp. 3–4; Grain Trade Australia, Submission 13, p. 3; Red Meat Advisory Council, Submission 12, p. 9; Business Council for Sustainable Development Australia, Submission 17, p. 6; AUSVEG, Submission 15, p. 7; Australian Information Industry Association, Submission 18, p. 4; Australian Dairy Industry Council, Submission 21, p. 9; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 17; Spirits & Cocktails Australia, Submission 33, pp. 24–25; Department of Foreign Affairs and Trade, Submission 34, pp. 9–10; Australian Chamber of Commerce and Industry, Submission 35, p. 5.

[2]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 17; Department of Foreign Affairs and Trade, Submission 34, p. 9.

[3]GrainGrowers, Submission 4, p. 1; National Farmer’s Federation, Submission 8, p. 3; Grain Trade Australia, Submission 13, p. 3; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 17; Department of Foreign Affairs and Trade, Submission 34, p. 10.

[4]Red Meat Advisory Council, Submission 12, p. 9.

[5]Red Meat Advisory Council, Submission 12, p. 9.

[6]National Farmer’s Federation, Submission 8, p. 3.

[7]AUSVEG, Submission 15, p. 7.

[8]AUSVEG, Submission 15, p. 7.

[9]Australian Dairy Industry Council, Submission 21, p. 9.

[10]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7.

[11]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7.

[12]Australian Industry Group, Submission 11, p. 3.

[13]Australian Information Industry Association, Submission 18, p. 4.

[14]Spirits & Cocktails Australia Submission 33, pp. 24–25.

[15]Australian Dairy Industry Council, Submission 21, p. 9.

[16]AUSVEG, Submission 15, p. 7.

[17]Spirits & Cocktails Australia, Submission 33, pp. 24–25.

[18]National Farmer’s Federation, Submission 8, p. 3; Australian Grape & Wine, Submission 9, p. 5; Spirits & Cocktails Australia, Submission 33, p. 24.

[19]Standards Australia, Submission 1, p. 2, citation omitted.

[20]Red Meat Advisory Council, Submission 12, p. 9.

[21]National Farmer’s Federation, Submission 8, p. 3, citation omitted; Dr Wei Li, Submission 22, p. 3; Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 17–18.

[22]Dr Wei Li, Submission 22, p. 3.

[23]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 18

[24]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 18.

[25]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 18.

[26]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[27]Australian Chamber of Commerce and Industry, Submission 35, p. 5, citation omitted.

[28]See, for example: Standards Australia, Submission 1, p. 1; Australian Grape & Wine, Submission 9, pp. 5–6; Australian Industry Group, Submission 11, pp. 2–4; Business Council for Sustainable Development Australia, Submission 17, p. 8; Australian Information Industry Association, Submission 18, pp. 4–5; Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[29]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[30]Standards Australia, Submission 1, pp. 1–2.

[31]Standards Australia, Submission 1, pp. 1–2.

[32]Australian Grape & Wine, Submission 9, pp. 5–6.

[33]Australian Industry Group, Submission 11, pp. 3–4.

[34]Australian Industry Group, Submission 11, pp. 3–4.

[35]Australian Industry Group, Submission 11, pp. 3–4

[36]Standards Australia, Submission 1, p. 1.

[37]Standards Australia, Submission 1, p. 2.

[38]Standards Australia, Submission 1, p. 2.

[39]Standards Australia, Submission 1, p. 2.

[40]Standards Australia, Submission 1, p. 2.

[41]Standards Australia, Submission 1, p. 3.

[42]Australian Industry Group, Submission 11, p. 6.

[43]Business Council for Sustainable Development Australia, Submission 17, p. 8.

[44]Standards Australia, Submission 1, p. 2.

[45]Standards Australia, Submission 1, p. 3.

[46]Standards Australia, Submission 1, p. 3.

[47]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[48]Australian Information Industry Association, Submission 18, p. 5.

[49]Australian Information Industry Association, Submission 18, p. 5.

[50]Standards Australia, Submission 1, p. 3.

[51]Standards Australia, Submission 1, p. 3.

[52]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[53]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[54]See, for example: National Farmer’s Federation, Submission 8, p. 4; Red Meat Advisory Council, Submission 12, p. 9; AUSVEG, Submission 15, p. 7; Business Council for Sustainable Development Australia, Submission 17, p. 6; Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 14 and 15.

[55]National Farmer’s Federation, Submission 8, p. 4.

[56]Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 14 and 15.

[57]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[58]Standards Australia, Submission 1, p. 2.

[59]See, for example: Productivity Commission, Submission 10, p. 6; Red Meat Advisory Council, Submission 12, p. 6; Grain Trade Australia, Submission 13, p. 3; AUSVEG, Submission 15, p. 7; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 18; Spirits & Cocktails Australia, Submission 33, p. 24; Department of Foreign Affairs and Trade, Submission 34, p. 10.

[60]AUSVEG, Submission 15, p. 7.

[61]National Farmer’s Federation, Submission 8, pp. 3–4.

[62]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 18.

[63]Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 14, 15–16.

[64]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 17.

[65]Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 15–16, 18.

[66]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[67]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[68]Department of Foreign Affairs and Trade, Submission 34, pp. 9–10.

[69]See, for example: National Farmer’s Federation, Submission 8, p. 4; Red Meat Advisory Council, Submission 12, p. 9; Grain Trade Australia, Submission 13, p. 3; Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 3 and 18; Department of Foreign Affairs and Trade, Submission 34, p. 10; Australian Chamber of Commerce and Industry, Submission 35, p. 5.

[70]Red Meat Advisory Council, Submission 12, p. 9; Grain Trade Australia, Submission 13, p. 3; Australian Chamber of Commerce and Industry, Submission 35, p. 5.

[71]Australian Chamber of Commerce and Industry, Submission 35, p. 5.

[72]Red Meat Advisory Council, Submission 12, p. 9.

[73]Red Meat Advisory Council, Submission 12, p. 9.

[74]National Farmer’s Federation, Submission 8, p. 4.

[75]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[76]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[77]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[78]Department of Foreign Affairs and Trade, Submission 34, p. 10.

[79]Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 3 and 18.

[80]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3.

[81]National Farmer’s Federation, Submission 8, p. 4; Dr Wei Li, Submission 22, pp. 3 and 4.

[82]See, for example: Productivity Commission, Submission 10, p. 9;Business Council for Sustainable Development Australia, Submission 17, p. 7; Australian Dairy Industry Council, Submission 21, p. 8; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7; Australian Chamber of Commerce and Industry, Submission 35, pp. 1 and 4.

[83]Business Council for Sustainable Development Australia, Submission 17, p. 7.

[84]Australian Chamber of Commerce and Industry, Submission 25, p. 4.

[85]Australian Dairy Industry Council, Submission 21, p. 8.

[86]Productivity Commission, Submission 10, p. 9.

[87]Productivity Commission, Submission 10, p. 9.

[88]Productivity Commission, Submission 10, p. 9, citation omitted.

[89]Prof Richard Pomfret, Submission 3, p. 1; Australian Industry Group, Submission 11, pp. 5–6; Australian Dairy Industry Council, Submission 21, p. 8; Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[90]Australian Dairy Industry Council, Submission 21, p. 8.

[91]Australian Chamber of Commerce and Industry, Submission 25, p. 1.

[92]Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[93]Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[94]Australian Chamber of Commerce and Industry, Submission 35, p. 9.

[95]Australian Industry Group, Submission 11, pp. 5–6.

[96]Australian Chamber of Commerce and Industry, Submission 25, p. 4.

[97]Australian Industry Group, Submission 11, pp. 5–6.

[98]See, for example: Productivity Commission, Submission 10, p. 9; Australian Industry Group, Submission 11, pp. 2 and 4–6; Australian Dairy Industry Council, Submission 21, p. 8; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7; Department of Foreign Affairs and Trade, Submission 34, p. 7; Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[99]Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[100]Australian Industry Group, Submission 11, p. 5.

[101]Department of Foreign Affairs and Trade, Submission 34, p. 7.

[102]Australian Industry Group, Submission 11, p. 5.

[103]Productivity Commission, Submission 10, p. 9; Australian Industry Group, Submission 11, pp. 4–5; Australian Dairy Industry Council, Submission 21, p. 8; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 4; Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[104]Australian Industry Group, Submission 11, pp. 4–5; Australian Dairy Industry Council, Submission 21, p. 8; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 4; Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[105]Australian Dairy Industry Council, Submission 21, p. 8.

[106]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 4.

[107]Australian Industry Group, Submission 11, p. 5.

[108]Australian Chamber of Commerce and Industry, Submission 35, p. 4. See also: Australian Industry Group, Submission 11, pp. 4–5.

[109]Australian Industry Group, Submission 11, p. 5.

[110]Australian Industry Group, Submission 11, p. 5.

[111]Department of Foreign Affairs and Trade, Submission 34, p. 8; Austrade, Submission 29, p. 2.

[112]Department of Home Affairs, Submission 6, p. 6.

[113]Australian Chamber of Commerce and Industry, Submission 35, p. 4.

[114]Department of Foreign Affairs and Trade, Submission 34, pp. 6–7.

[115]Australian Industry Group, Submission 11, p. 5.

[116]See, for example: Prof Richard Pomfret, Submission 3, p. 1; Australian Industry Group, Submission 11, pp. 6–7; Business Council for Sustainable Development Australia, Submission 17, p. 7; Northern Territory Department of Industry, Tourism and Trade, Submission 27, pp. 7–8.

[117]Professor Richard Pomfret, Submission 3, p. 1.

[118]Australian Industry Group, Submission 11, pp. 6–7.

[119]Australian Industry Group, Submission 11, pp. 6–7.

[120]Australian Industry Group, Submission 11, pp. 6–7.

[121]Business Council for Sustainable Development Australia, Submission 17, p. 7.

[122]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7.

[123]Department of Home Affairs, Submission 6, p. 6.

[124]Department of Home Affairs, Submission 6, p. 6.

[125]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 8.

[126]Australian Information Industry Association, Submission 18, p. 3.

[127]Australian Information Industry Association, Submission 18, p. 3.

[128]Department of Home Affairs, Submission 6, p. 6.

[129]Department of Home Affairs, Submission 6, p. 6.

[130]See, for example: Standards Australia, Submission 1, p. 3; AUSVEG, Submission 15, p. 6; Australian Dairy Industry Council, Submission 21, p. 3; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 9; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3.

[131]Standards Australia, Submission 1, p. 3; AUSVEG, Submission 15, p. 6; Australian Dairy Industry Council, Submission 21, p. 3; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 9.

[132]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 9.

[133]AUSVEG, Submission 15, p. 6.

[134]Canegrowers, Submission 2, pp. 2 and 5; GrainGrowers, Submission 4, pp. 2–3; Australian Grape & Wine, Submission 9, p. 5; Australian Dairy Industry Council, Submission 21, pp. 7–8; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 9; Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 14 and 15.

[135]Australian Dairy Industry Council, Submission 21, p. 8.

[136]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 13.

[137]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 13.

[138]GrainGrowers, Submission 4, p. 2.

[139]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 13.

[140]GrainGrowers, Submission 4, p. 3. See also: Department of Agriculture, Fisheries and Forestry, Submission 28, p. 13.

[141]Australian Dairy Industry Council, Submission 21, p. 8.

[142]Australian Dairy Industry Council, Submission 21, p. 8.

[143]Australian Dairy Industry Council, Submission 21, p. 8.

[144]Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 9

[145]Canegrowers, Submission 2, p. 2.

[146]Canegrowers, Submission 2, p. 5.

[147]Australian Grape & Wine, Submission 9, p. 5.

[148]Australian Grape & Wine, Submission 9, p. 5.

[149]Productivity Commission, Submission 10, p. 6.

[150]Productivity Commission, Submission 10, p. 6.

[151]Department of Agriculture, Fisheries and Forestry, Submission 28, pp. 3; 14 and 15.

[152]Canegrowers, Submission 2, p. 5.

[153]Canegrowers, Submission 2, p. 5.

[154]Australia China Business Council, Submission 32, p. 5.

[155]Australia China Business Council, Submission 32, p. 5.

[156]Australian Information Industry Association, Submission 18, p. 2.

[157]Australian Information Industry Association, Submission 18, p. 2.

[158]Cellular Agriculture Australia, Submission 30, p. 2.

[159]Cellular Agriculture Australia, Submission 30, p. 4.

[160]Cellular Agriculture Australia, Submission 30, p. 3.

[161]Group of Eight Australia, Submission 19, p. 2.

[162]Group of Eight Australia, Submission 19, p. 2. See also: Australian Information Industry Association, Submission 18, p. 4.

[163]Australian Dairy Industry Council, Submission 21, p. 8.

[164]Australian Dairy Industry Council, Submission 21, p. 8.

[165]AUSVEG, Submission 15, p. 6.

[166]AUSVEG, Submission 15, pp. 6–7.

[167]Canegrowers, Submission 2, p. 3; Prof Richard Pomfret, Submission 3, p. 2; Australian Dairy Industry Council, Submission 21, p. 7.

[168]Australian Dairy Industry Council, Submission 21, p. 7.

[169]Department of Foreign Affairs and Trade, Submission 34, p. 13.

[170]Department of Foreign Affairs and Trade, Submission 34, p. 13.

[171]Red Meat Advisory Council, Submission 12, p. 4; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 6; Australian Chamber of Commerce and Industry, Submission 35, p. 2.

[172]Australian Grape & Wine, Submission 9, p. 7; Red Meat Advisory Council, Submission 12, p. 4; Grain Trade Australia, Submission 13, p. 3; Australia China Business Council, Submission 32, p. 5; Department of Foreign Affairs and Trade, Submission 34, p. 4.

[173]Productivity Commission, Submission 10, p. 6.

[174]See, for example: GrainGrowers, Submission 4, p. 2; Red Meat Advisory Council, Submission 12, p. 9; Bankwest Curtin Economics Centre, Submission 16, p. 3; Dr Wei Li, Submission 22, p. 3; Australian Business in Europe, Submission 25, p. 2; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3; Australia China Business Council, Submission 32, p. 2.

[175]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3.

[176]National Farmer’s Federation, Submission 8, p. 2; Australian Grape & Wine, Submission 9, p. 4; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3; Australia China Business Council, Submission 32, p. 5.

[177]Trade and Investment Queensland, Submission 24, p. 4; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 7.

[178]Trade and Investment Queensland, Submission 24, p. 4.

[179]Australian Grape & Wine, Submission 9, p. 7; Red Meat Advisory Council, Submission 12, p. 4; Grain Trade Australia, Submission 13, p. 3; Australia China Business Council, Submission 32, p. 5; Department of Foreign Affairs and Trade, Submission 34, p. 4.

[180]Canegrowers, Submission 2, p. 5; National Farmer’s Federation, Submission 8, p. 2; Australian Grape & Wine, Submission 9, p. 7; Bankwest Curtin Economics Centre, Submission 16, p. 8; Australia China Business Council, Submission 32, pp. 4–5.

[181]Australia China Business Council, Submission 32, pp. 4–5.

[182]Australia China Business Council, Submission 32, pp. 4–5.

[183]Australia China Business Council, Submission 32, pp. 4–5.

[184]Australian Grape & Wine, Submission 9, p. 7.

[185]Canegrowers, Submission 2, p. 5.

[186]Bankwest Curtin Economics Centre, Submission 16, p. 8.

[187]See, for example: Canegrowers, Submission 2, pp. 5–6; National Farmer’s Federation, Submission 8, p. 2; Australian Grape & Wine, Submission 9, p. 4; Bankwest Curtin Economics Centre, Submission 16, p. 8; Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3; Department of Foreign Affairs and Trade, Submission 34, p. 6.

[188]See, for example: Canegrowers, Submission 2, p. 4; National Farmer’s Federation, Submission 8, p. 2; Australian Grape & Wine, Submission 9, p. 4; Red Meat Advisory Council, Submission 12, p. 7; Australian Dairy Industry Council, Submission 21, p. 2; Trade and Investment Queensland, Submission 22, p. 2; Northern Territory Department of Industry, Tourism and Trade, Submission 27, p. 3.

[189]Red Meat Advisory Council, Submission 12, p. 7.

[190]Department of Agriculture, Fisheries and Forestry, Submission 28, p. 3.

[191]Canegrowers, Submission 2, pp. 5–6.

[192]National Farmer’s Federation, Submission 8, p. 2.

[193]Australian Grape & Wine, Submission 9, p. 4.