APL Submissions
Submissions are developed to express APL's opinion on industry related proposals such as reviews of legislation and regulation.
APL's submissions cover a wide range of policy matters that impact on the industry and producers viability, including food safety and quality, competitiveness, trade, labour, environment, quarantine, biosecurity, animal health and welfare.
For further details on submissions contact the APL Policy Division.
Title |
Date |
Submission brief |
Submission download |
| Carbon Farming Initiative |
February 2011
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APL addressed concerns regarding the operation of the CFI and the ability of the Australian pork industry to effectively participate. These concerns include the assessment of ‘additionality’ as a requirement to be an accredited carbon offset, practical on-farm issues, privacy, administrative burdens and the role of APL driving climate change research. |
APL’s Letter to the Department of Climate Change |
| Response to: Policy Discussion Paper - Better Regulation of Agricultural and Veterinary Chemicals |
February 2011 |
APL agrees with the intent of the reforms to improve the efficiency and effectiveness of the APVMA, to enable more effective regulation of AGVET chemicals. However, we have provided some recommendations for consideration by the review team which we believe may enhance the effect of the proposed reforms. | APL's response to: Policy Discussion Paper - Better Regulation of Agricultural and Veterinary Chemicals |
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Treasury: APL’s submission into the Excise Consultation – Implementation of alternative fuels taxation |
November 2010 | APL noted its support for the Australian Lot Feeders’ Association (ALFA) submission into the Treasury Inquiry on a delayed phase-out of ethanol subsidies to the industry. APL also emphasised its opposition to ethanol subsidies and its impact on the pork industry. | APL’s Submission to Treasury |
| Second Submission to the Productivity Commission (PC) Inquiry into the Rural Research and Development Corporations (RDC’s) |
November 2010 | APL believes that the establishment of a “public good” driven new RDC such as Rural Research Australia would not be the optimal way to address what may have been an area of under-delivery by the RDC model. Any reduction in the matching funding would reduce the amount of rural R&D and the spillovers that flow from it to the community, at a substantial net cost. |
APL’s Letter to the Productivity Commission |
| Submission to the Productivity Commission Inquiry into Bilateral and Regional Trade Agreements |
September 2010 | APL continues to support the government’s current approach to trade negotiations. It is in the future interests of Australia’s pork producers that no sector misses out on being part of a free trade agreement. | Submission Bilateral and Regional Trade Agreements |
| Australian Customs: Productivity Commission Final Report on Australia’s Anti-dumping and Countervailing System |
August 2010 | APL supports the continuation of the ‘close processed agricultural goods’ (CPAG) provisions for Australian agriculture. | Submission to Australian Customs |
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Ethanol and the impact on the NSW pork industry |
July 2010 | APL supports the need for Australia to reduce its greenhouse gas emissions and recognises that biofuels are an alternative energy source. However, APL is opposed to an ethanol mandate using grain as a primary input. | Letter to the Leader of the Nationals in the Senate, Fiona Nash |
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Productivity Commission (PC) Inquiry into Rural Research Development Corporations (RDC’s) |
June 2010 | APL’s submission to the PC Inquiry into the Rural RDC’s supported three positions: 1) taxpayers gain a competitive net value from investing in rural R&D; 2) the present RDC model is well placed to deliver this value with areas for improvement; and 3) the unique structure of APL enables a performance level unmatched by other structures, across a range of interlinked industry services and representation. |
PC Inquiry into RDC’s |
| SA - Draft for Public Consultation: Guidelines for Wastewater Lagoons | May 2010 | The draft Guidelines ignore that the nature, scale, management and risks of piggery effluent are not comparable to industrial wastewater systems. |
SA EPA Guidelines for Wastewater Lagoons Submission |
| Review of Food Labelling Law and Policy | May 2010 |
APL supports mandatory CoOL labelling for both packaged and unpackaged pork products to identify both the origin of ingredients of a product and also to identify the proportion of content in a product that is of domestic origin. While CoOL requirements for fresh pork are effective, we believe that current CoOL standards for processed pork products are inadequate to help consumers distinguish Australian from imported ham, bacon and smallgoods. |
Response to Issues Consultation Paper |
| QLD - State Planning Policy: Air, Noise and Hazardous Materials 2009 | March 2010 | APL is concerned that the State Planning Policy: Air, Noise and Hazardous Materials 2009 will add yet another layer of administrative process that will negatively impact on Queensland pig producers within five kilometres of land zoned primarily for a sensitive use. |
QLD State Planning Policy Submission |
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QLD - Letter to the Office of Clean Energy on the ethanol mandate |
March 2010 | APL is opposed to an ethanol mandate using grain as a primary input. In an environment where grain supply is tight, the mandate will artificially inflate grain and food prices, increase production costs for pig producers and increase cost of living for the public. | APL’s Letter to the Office of Clean Energy, QLD |
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Discussion Paper: A National Scheme for Assessment, Registration and Control of Use of Agricultural and Veterinary Chemicals |
February 2010 | APL believes that agricultural producers have significant incentives to use AGVET chemicals responsibly and the results of NRS testing continue to show that pork producers have been using AGVET chemicals conscientiously. The Australian pork industry takes responsible use of AGVET chemicals seriously and administers and funds a variety of schemes including on-farm Quality Assurance to encourage and monitor safe chemical use. | Submission to the review of the framework for AGVET chemical regulation |
| Submission to the Review of Food Labelling Law and Policy | November 2009 | APL's submission provided information and views on country of origin labelling, method of production labelling, environmental labelling and genetically modified food labelling to the review panel for consideration in the first round of public consultation. |
Review of Food... |
| Inquiry into Australia's Anti-dumping and Countervailing System | October 2009 | APL maintains its view that Australia's current anti-dumping legislation does not favour primary production. Improved access to the Australian system is nessecery for pork producers and primary industry. |
Inquiry into... |
| Submission to the Food Standards Amendment (Truth in Labelling Law) Bill Inquriy 2009 | October 2009 | The Bill seeks to amend Country of Origin food labelling laws to only allow the word "Australian" if the food is 100% Australian, which would create difficulties for Australian processed pork made with imported brine. |
Food Standards Submission |
| Migration Occupations in Demand List (MODL) Review Submission | September 2009 | APL provided a submission to the MODL Review as a means of raising the concerns expressed by producers about difficulties maintaining access to skilled overseas workers. |
MODL Review Submission |
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Pacific Agreement on Closer Economic Relations (PACER) Plus |
July 2009 |
Australian pork producers are disadvantaged by tariffs in export markets of Fiji, Papua New Guinea and the Solomon Islands. |
PACER letter
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Victorian Competition & Efficiency Commission: Inquiry into environmental regulation in Victoria |
June 2009 |
Victorian government policy should encourage a nationally consistent, co-regulatory approach for the management of environmental outcomes related to Victorian pork production. |
APL VCEC Inquiry |
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Australia-ASEAN-NZ FTA |
February 2009 |
In February 2009, the Government finalised an FTA with the ASEAN nations. More information on tariff reductions for Indonesia, the Philippines, Vietnam and Malaysia can be found here. The agreement comes into effect from 1 January 2010. |
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Korea FTA |
February 2009 |
APL provided a submission into the Korea- Australia FTA negotiations. Import tariffs on pork in the Korean market are as high as 25%. |
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Joint Standing Commitee Inquiry of Foreign Affairs, Defence and Trade into Australia's Relationship with the ASEAN- Answers to Questions On Notice |
January 2009 |
APL provided Answers to Questions on Notice following on from APL's appearance before the Joint Standing Commitee in December 2008. |
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PC Inquiry into Government Drought Support- DRAFT Report Response
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December |
APL provided a response submission on the DRAFT Report developed by the PC Inquiry into Government Drought Support. The submission provides a response on the PC's findings and recommendations to improve current government drought assistance in a climate change environment. |
PC Inquiry into Government Drought Support- DRAFT Report Response |
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Trans-Pacific Strategic Economic Partnership (TPSEP) Agreement |
October 2008 |
The current grouping of Brunei, Chile, New Zealand and Singapore in the TPSEP does not provide the market access requirements Australian pork exporters need for larger and more valuable export markets such as Japan, Korea and China. |
TPP Submission |
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Carbon Pollution Reduction Scheme- CPRS Green Paper |
September 2008 |
APL provided a submission to the CPRS Green Paper describing past and current efforts to improve industry competitivness and reduce the environmental footprint; current sustainability challenges; expected immediate and long-term impacts of the CPRS; and recommendations for the Government to encourage industry uptake and environmental performance. A White Paper describing the final design of the CPRS will be released in December 2008. |
Carbon pollution Reduction Scheme- CPRS Green Paper |
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Joint Standing Commitee Inquiry of Foreign Affairs, Defence and Trade into Australia's Relationship with the ASEAN |
September 2008 |
APL provided the Joint Standing Commitee a submission into export opportunities for Australian pork in the ASEAN. Strong economic growth in many ASEAN countries for more than a decade has contributed to an increase in local meat consumption, especially pork. Australia already has a strong econmic and trade relationship with the ASEAN. |
Joint Standing Commitee Inquiry into Australia's relationship with the ASEAN. |
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PC Inquiry into Government Drought Support |
September 2008 |
APL provided a submission to the PC inquiry into Government Drought Support. The submission elaborates on the impact of current drought assistance on the competitiveness and sustainability of pork producers; and in particular on the need to incorporate measures to assist the industry's long-term adaption to climate change. |
PC inquriy into Government Drought Support |
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Senate Inquiry into Fuel and Energy |
August 2008 |
The Senate requested the Senate Select Committee on Fuel and Energy to undertake a inquiry into the fuel and energy sector. APL's submission covered the impact of higher fuel prices on pork producers and in particular the role of grain-based biofuels and potential impact of Australia's Carbon Pollution Reduction Scheme. |
Senate Inquiry into Fuel and Energy |
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Senate Inquiry into Food Production |
August 2008 |
The Senate Inquiry into Sustainable Food Production covered the consumer, producer and environmental perspective. APL's submission focused on the adverse effects of grain based ethanol production, which contributes to rising feedgrain prices and increasing food prices for consumers. |
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NZ Quarantine |
June 2008 |
NZ Govenment is in its second round of consultation concerning changes to the Import Health Standards for imported pork products. APL has provided a second submission to the NZ MAFF outlining its strong objection to the importance of 'high value ready to cook' pig meat cuts without treatment. |
NZ Quarantine submission
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Export Policies and Programs - Part I |
May 2008 |
The review is assessing Australia's export and investment performance. Research on FTAs is being undertaken as part of the review. APL has provided advice to asist the pork industry in accessing new markets. |
Export Polices submission PART I
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Export Policies and Programs - Part II |
May 2008 |
The review also includes a detailed examination of the Export Market Development Grants scheme (EMDG). APL has advised government on areas of improvement in the scheme. |
Export Polices submission PART II
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Transport Code Public Consultation |
May 2008 |
Animal Health Australia (AHA) conducted a public consultation relating to the development of the Land Transport of Livestock (Land Transport Standards), and the Regulatory Impact Statement (RIS). APL strongly supports a code which represents industry needs and practical measures to improve pig welfare. |
Transport Code submission to AHA
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Quarantine and Biosecurity |
May 2008 |
In February 2008 the Minister for Agriculture, Fisheries and Forestry, Tony Burke, announced a comprehensive independent review of Australia's quarantine and biosecurity systems. APL strongly supports science based IRAs which protect Australia's key competitive advantage in pig health. |
APL-DAFF Quarantine and Biosecurity Review
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Senate inquiry into Meat Marketing |
May 2008 |
The Government asked the Senate to conduct a public inquiry into concerns related to meat marketing. APL provided a submission and advocates for a national approach to assure compliance with labelling laws in geneeral through much more robust structures and systems than exist today.
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The Standing Committee on Rural and Regional Affairs and Transport Inquiry into Meat Marketing
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Review of the EP Regulation -QLD |
April 2008 |
The Queensland Government is currently reviewing the Environmental Protection (EP) Regulation and proposing to remake the regulations based on environmental emissions. APL and Pork Queensland Incorporated (PQI) strongly oppose the proposed EPA fee increase, which would discriminate against Queensland pork producers. |
Review of the Environmental Protection Regulation 1998
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Chile FTA |
April 2008 |
APL provided a submission into Chile FTA negotiations. A key tariff cut from 6% to 0% for pig meat products to Chile has been achived. Australia and Chile are aiming for entry into force of the Agreement on 1 January 2009. |
Chile FTA -DFAT Submission
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ACCC Grocery Inquiry |
March 2008 |
The Government requested the Australian Competition and Consumer Commission (ACCC) to hold a public inquiry into the competitveness of retail prices for standard groceries. APL's submission to the inquiry encouraged healthy levels of competition through the supply chain to enhance margins for pig producers. |
Grocery Inquiry into the Competitiveness of Retail Prices for Standard Groceries |
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India FTA Feasibility Study |
March 2008 |
Australia and India have agreed to undertake a joint feasibility study on the merits of an FTA. APL investigated the potential of this market and identified significant areas for reform. |
India FTA Feasibility DFAT Study
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Safeguards inquiry into the Import of Pigmeat |
February 2008 |
The Government commissioned the Productivity Commission (PC) to assess the case for safeguards against imports of fresh pork. APL made three submissions into the PC's Safeguard Inquiry (2007), pushing for safeguards on imports and requesting for industry assistance. The Final Report is available on the PC's website - www.pc.gov.au/__data/assets/pdf_file/0004/78457/pigmeatsafeguards.pdf |
Safeguards inquiry into the Import of Pigmeat 2007 - Final Submission |
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Japan FTA |
January 2008 |
APL has been in ongoing consultation with DFAT as to the progress of the FTA. APL strongly supports tariff liberalisation which significantly disadvantages market access. |
Japan FTA -DFAT Submission
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Safeguards Inquiry inot the Import of Pigmeat |
December 2007 |
This supplementary submission addresses the issues the Commission must consider in its recommendation as to any provisional safeguard remedy. This supplementary submission comments on submissions made to the Inquiry, the public hearings |
Submission 2
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Safeguards Inquiry into the Import of Pigmeat |
November 2007 |
The Government commissioned the Productivity Commission (PC) to assess the case for safeguards against imports of fresh pork. APL's first submission outlined the case for provisional safeguards and provided legal evidence, economic analysis of imports on domestic pigmeat prices and analysis into the economic impat of pork imports on domestic production. |
Attachment 3
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