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Importing country requirements
Are there documented procedures and training in place for ensuring compliance with identified importing country requirements being met?
The documented system will identify:
- How importing country requirements are identified.
- How the company checks that importing country requirements are met.
- What records are kept to ensure that these requirements have been met.
For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.
As an export registered establishment, you have a responsibility for meeting all of Australia’s export requirements (as outlined in the Export Control Act and Milk Rules) as well as any additional requirements imposed by the importing country.
Australia’s relationship with importing countries and our access to overseas markets relies heavily on our food export system and the assurances that we provide. Australia’s strong reputation relies on everyone playing their part and taking their responsibilities seriously.
Some things you might want to consider to ensure you meet your importing country requirements are:
- Meeting the Export Control Act importing countries sections,
- Meeting the Milk Rules importing countries sections,
- Advising your upcoming export shipments by issuing a ‘Notice of Intention to Export’ to the department, have an Export Permit issued by department and then have a Health Certificate issued by department.
- Ensuring that staff have access to relevant documents and sources of information, such department Micor, company records such as product testing and export shipment details, records showing that your product complies with importing country requirements and the department’s market access advices. When staff issue Declarations of Compliance they also need to check these sources of information to attest that importing country requirements have been met,
- Staff should have contact details (such as phone and email addresses) for dealing with problem importing country issues e.g. their NEXDOC computer software company, their export documentation company, their freight forwarder and the department’s Export Documentation team,
- Staff should be trained to ensure they are aware of importing country requirement procedures and the need to plan in advance when looking to export to a new country, including in your Approved Arrangement, details of how you will meet importing country requirements, for the countries you intend to export dairy product to, including in your Approved Arrangement details for the countries that you intend to be eligible to send dairy product to,
- You must update your Approved Arrangement when your list of importing countries changes, describe how you use Micor, how you receive updates to importing country changes for dairy product from depatment and how you update your Approved Arrangement when your importing country requirements change, how you will provide needed importing country requirement compliance details, to your export certification service (the company that organises your Notices of Intention to Export, Export Permits and Health Certificates, through a computer program called NEXDOC), such as microbiological or chemical tests or other information, that department Documentation Section requires before issuing a Health Certificate, note that not all importing country requirement verification documents need to be sent to department Documentation Section, this is detailed in Micor
- Updating your Approved Arrangement, if you intend to send dairy product to a country that requires sealing with a government seal,
- Updating your Approved Arrangement regarding keeping retrievable relevant records and
- If you need to issue a Corrective Action Request because of an issue regarding meeting an importing country requirement for a shipment, you need to check if you had covered all bases; Did you check Micor fully? Did you check the departments Market Access Advices? Did you provide correct information to your export documentation provider and freight forwarder? Was it a customer issue rather than an importing country issue? Once you have worked out where the problem was, you can take appropriate action, update your Approved Arrangement and hopefully be better prepared in the future.
The Export Control Act 2020 and Export Control (Milk and Milk Products) Rules 2021, detail requirements that you need to meet in order to meet the importing country requirements aspect of dairy export.
The following is a summary of these requirements, many of these linking back to needing information included in your approved arrangement:
Registration and Listing
Some countries require specific country listing to be included in your registration details, these may be approved by department or by the importing country authority and you may receive an annual copy of a Registration Certificate, showing that listing. You should include information in your approved arrangement regarding that country’s importing requirements and that you need to retain that listing in order to be able to export dairy product to that country.
Your approved arrangement:
- Must include details of how you will meet the requirements of countries you intend to export to (only if they have additional requirements above our export requirements. The details you should include are: country names, the processes needed to be actioned such as microbiological testing, chemical testing or specific labels needed, and what records of compliance should be kept for each shipment/batch of product for that country.
- Needs to be updated when you are notified that importing country requirements change, for countries that your dairy product is exported to.
- May need to be amended regarding importing country requirements, when for example, you are exporting dairy product to a new country, you are making and exporting a new dairy product or an importing country amends its requirements which require you to update your processes/procedure to meet its requirements.
- Should ensure that exported dairy product meets Food Standards Code requirements, except if an importing country authority has a different standard. You will need to update your Approved Arrangement for that country, to specify the different standard. Examples of Food Standards Code requirements are levels of metals, non metals, natural toxicants, agricultural or veterinary chemicals or food additives, microbiological standards, microbiological testing methods, gene technology and irradiation. You would need to have evidence that it’s an importing country requirement, not a customer request and be approved by the department prior to implementation.
- Should ensure that your approved supplier program includes details of and records of product specifications for particular importing countries, which indicate compliance with the relevant importing country’s requirements.
If you make dairy products to meet an importing country’s requirements, that country’s name must be included in the relevant transfer document when the dairy product is moved from your site to another dairy site.
Refer to ‘Transfers and Declarations of Compliance’ element for more details.
An importing country may require an Australian government seal to be applied to the Australian dairy product’s shipping or sea container, before it leaves Australia. A country may also require an Official Mark to be applied to the Australian dairy product, this mark indicates that it meets the importing country requirements. These requirements will be included in Micor.
Export Permit and Health Certificate
Your approved arrangement needs to link importing country requirements to issuing of your Export Permit and Health Certificate, so that the verifying documents proving that product meets importing country requirements are checked before requesting an Export Permit and/or Health Certificate.
Records need to be kept by the site showing compliance with importing country requirements, these should be detailed in your approved arrangement.
Records are more easily able to be retrieved if they are linked to Export Permit number and/or Health Certificate number, or other identifiable number, common to both the exporter and department.
If you are the exporter, you are required to keep a copy of the Health Certificate.
Some useful links from departments website relevant to importing country requirements are:
- Dairy Advices (includes Market Access Advices)
- Micor (Manual of Importing Country Requirements)
- European Union requirements (exporting to EU details)
- China requirements (exporting to China details)
Complying with your importing country is of the utmost importance, both for your company’s benefit, and also to help maintain market access for the Australian dairy industry.