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Departmental (Commonwealth) applied seals
If a sealing system is required, a documented program must be in place and include:
- How the company orders the seals from the department.
- Seals must be stored in a secure location with limited access to those staff responsible for the reconciling of them.
- A reconciliation process in place for identifying number of seals received and used.
- Staff allocated responsibilities for seal management are aware of the procedures and work instructions.
- Corrective actions and verification controls in place.
- Records available.
For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.
If your importing country requires departmental seals for your export product, then you must have a documented system in place for the seals and how they are managed and controlled as part of your approved arrangement. This information will be available for you in Micor.
Your establishment will need to have its self-sealing program approved by the department before it can be implemented. Alternatively, you can also opt to make an appointment with a departmental officer to apply the seal onsite. Once your system has received written approval from the department, you can carry out your seals procedures as per your approved arrangement.
Personnel responsible for the ordering, management and application of departmental seals must be suitably trained and identified in the approved arrangement.
Additional information on all official seals and marks and the legislative requirements are outlined in Chapter 8, Part 2 of the Export Control Milk Rules.
Departmental metal seals
Seals are used on shipping and air freight containers and each seal has a unique number. This number is included in documents such as transfer documents, export permits and health certificates allowing for you to check if the container was tampered with by checking the seal integrity and seal number.
To order container seals for the export of products the approved person will need to contact the department and complete a Dairy Container Security Seal Order form.
Metal seals, such as bolt seals and Tyden metal strap seals, are usually applied to sea freight containers. When correctly applied they will break when the container door is opened. A tamper-indicative metal strap seal, which is usually used for air freight containers, can be secured in a loop by inserting one end of the seal into a protected locking mechanism on the other end. Tamper evident metal strap seals and bolt seals are examples of official marks. They bear the words “Australian government” and a unique number, or a unique combination of letters and numbers, which are provided to the manufacturer by the department.
Departmental carton seals and paper seals
Some importing country requirements would need you to send your product with an official mark and this information can be found in Micor. Paper seals are applied to packages such as cardboard cartons. Paper seal or carton seal is an official mark with a certain design, including the Australian Coat of Arms, your establishment registration number, the manufacturer of the mark’s number and the unique serial number for the mark. They must be applied in such a way that the seal is broken if the package is opened. It should be noted that, in some cases, more than one paper seal may be required.
It is important to note that when an official mark or seal is applied, it must be placed on a specific container, package or product attached to the milk or milk products, but not on pallets or loose packaging material such as liners or any other item which is not connected to the product.
A person or a site may possess and apply official marks if they are in accordance with the legislation.
You can only alter, interfere or remove an official mark if, for example, the export product has deteriorated or is not fit for human consumption or it is no longer your intention to export the product. A person designated in an approved arrangement in accordance with the legislation may do this.
Official marks must be legible and securely attached to your milk products.
A false or misleading official mark must not be applied to goods intended for export or to documents which relate to these goods.
Your documented procedure should describe the official mark process and be amended when needed, such as when importing country requirements change, the countries you export to change or your products change.
Any significant variations in relation to your departmental seals control and the procedure in your approved arrangement must be approved by the department before the changes are implemented.
As a holder of an approved arrangement you must ensure records relating to seals and official marks are kept for at least 3 years.
Reconciliation of seals & official marks
Once you have received the seals and official marks from the department, you must have a system in place to ensure they are stored in a secure location, with authorised personnel responsible for reconciling them. Limiting access to the seals and official marks will assist in ensuring they are safeguarded during storage and not used inappropriately. A reconciliation process must be put in place to monitor the receival, usage and return of seals, including damaged seals.
The quantity and serial numbers of the departmental seals and official marks received must be checked against a copy of the processed order form and signed by an Authorised Signatory of the establishment and returned to the department Authorised Officer. Seals and official marks must only be used by the establishment specified on the Order Form. Seals and official marks must not be used at any other establishment or by any person who is not authorised.
Reconciliation controls must include:
- A register for the departmental seals and official marks detailing the date of receipt of the seals received by the establishment. Receipt dates can identify the sequential number range of the seals received (for example, numbers 501 to 600).
- Identifying when a seal or official mark has been used, on what date, what container it has been applied for and for what purpose. Every individual seal and official mark used must have a detailed record.
If a seal or official mark has been damaged, this must still be reconciled.
- Recording of any seals and official marks returned to the department.
- They should be stored in a secure and lockable cabinet or similar and accessed by trained staff who are responsible for their control.
- If an official mark has been applied to milk or milk products, the official mark must be removed or defaced if the products are no longer fit for human consumption or have deteriorated.
It is important to keep a record for all the checks you have conducted and ensure they meet the specified criteria. If checks fall outside the specifications, then appropriate corrective action must be taken and recorded.
Importing country requirements
If your importing country requires your product to contain departmental seals, as an establishment you can opt for a self-sealing program with departmental seals or make an appointment with a departmental officer to apply the seals on-site.
Check departmental Dairy export advice for information, especially regarding changes to countries that might require government seals to be applied to consignments.
For more information on specific importing country requirements, see Micor.
A compliant official mark system ensures that official marks are applied to all relevant dairy export products, according to export and importing country requirements.
Staff who are responsible for developing and implementing your official marks and seals procedure will need to be trained in the use of Micor and should receive and check Dairy export advice notices as they will need to know when there is a change in importing country requirements relating to official marks or seals.
Personnel responsible for checking official marks and seals should be appropriately trained.
Appropriate staff may need refresher training when importing country requirements change with regard to official marks, or if a seal type changes.
You should consider the following points when documenting your procedures relevant to this element;
- Have you clearly identified when a seal was received and used? Have you recorded the container number? The date of departure of the vessel or the flight details? The country of final destination? These details are important to ensure the identity of the product so it can be easily traced if needed.
- Have you recorded who applied the seal or mark?
- Do you need a particular type of mark or seal for your product, and how/where must this be applied?
- Do you know how to obtain the seals and marks you need?
- Will you be applying seals and marks yourself, or requesting an appointment with a departmental authorised officer?
- Have you described how you will document and manage this element in your approved arrangement?
How much do you know about Departmental (Commonwealth) applied seals?
Take this short assessment to find out.
Ali is employed as a warehouse assistant at a dairy facility and is responsible for managing departmental seals. He accidentally broke a seal when he tried to attach it to a sea freight container.
What should Ali do?
Click all that apply.
Neimi is the export assistant at a dairy establishment. She has been asked to organise a shipment of milk product overseas. Her company has sent product to the importing country earlier in the year and the requirements did not stipulate for a departmental seal to be applied. Product was received by the overseas customer who has now requested another shipment. As no departmental seal was required previously, Neimi is getting ready to export the new batch of product without seals yet again.
Should Neimi check to see if departmental seals are required for this delivery?
Zara works in the international sales department at a multinational dairy facility. The importing country has indicated all dairy products from Australia require a departmental seal. Zara knows that she must order seals for the dairy product she wishes to export to her overseas customer. Zara is unsure from where to buy the seals, but she knows a freight supplier who could possibly supply container seals at a reasonable price.
Can Zara use this supplier to purchase the container seals for her export shipment?