Elements of an Approved Arrangement

Transfer Documents and systems are used to accurately identify movements of dairy export products and ingredients, providing a check that export dairy products have been processed and stored only in dairy export sites. The document contains all traceability and identity information about export eligible dairy product, including the dispatching establishment name and number, the receiving establishment name and number, details about the product and a statement about complying with dairy export requirements. Where product seals are used, these seal numbers may also be recorded. This document demonstrates that when it arrives at the destination establishment, that it is still export eligible.

This system helps ensure that government Health Certificates are only issued for export eligible dairy product.

Details of information to be included in the Transfer Document are in Export Control Milk Rules 2021, Chapter 5 – 35 (1) (a) to (h) inclusive, and the attestation requirements are in Chapter 5 – 35 (1) (i) and (j). Further information about how a Transfer Document should be issued is in Milk Rules 2021, Chapter 5 – 35 (2),(3),(4) and (5).

Dispatch

If an export dairy product is made to meet particular processing requirements for the importing country, such as antibiotic test results for raw milk, then that country name should be identified in the Transfer Document. There are some importing country requirements that cannot be met until after the product has been processed. Examples are trade description (label) and product testing. The country name for these post processing requirements does not need to be included in a Transfer Document unless the finished packed product is being sent to a storage establishment. If the goods being sent with a transfer Document have been processed in a way that meets requirements for a specific country, the eligibility for that country should be indicated on the transfer. If it is an ingredient that requires further processing, then the requirement for further processing would also be identified.

There are certain exemptions to require a Transfer Document:

• When transferring product that will not be exported or used in export product
• When transferring export ingredients/products to another registered establishment that is occupied by the same company as the dispatching establishment
• when transferring export consignments directly to the wharf/airport for loading as freight (noting that if the consignment is stored before loading, then the storage must occur at a registered storage facility and a transfer doc is required)

An example of a Transfer Declaration Document depicting the minimum requirements can be found in the Department’s web site.

A system needs to be in place to ensure that correct information is included in the Transfer Document. If the dispatching site is not immediately able to issue a correct document, perhaps due to computer or communication problems, they should advise the receiving site.  If the dispatching site becomes aware that some information is incorrect or not included in the Transfer Document, they should contact the receiving site and provide them with a correct and complete Transfer Document and advise that the initial document is invalid. They should take appropriate corrective action to reduce the likelihood of this issue recurring. 

The procedure needs to ensure that all information on the Transfer Document can be verified and describe how this is done. As an example, there may be a step where the Transfer Document signatory checks that the product batch code on the Transfer Document matches the label and production records before they sign the Transfer Document.  In cases where an importing country is listed on the Transfer Document, the Transfer Document signatory may need to check Micor (manual of importing country requirements) dairy database for information regarding processing requirements for the particular importing country.  They may also need to liaise with the QA or production staff at the processing site.

Dispatching site export registration number, company name, site address and registered operations can be verified by contacting the dispatching site and asking them to send you a copy of their current (less than 12 months since issued) Export Registration Certificate. Alternatively, you may contact a department authorised officer.

Your site’s Transfer Document procedure should:

• Explain the responsibilities of staff involved in Transfer Documentation
• Explain the circumstances where a Transfer Document must be received or issued, and circumstances where a Transfer Document is not required                              
• Explain how data is sourced and included in Transfer Document
• Explain how to verify that dispatching and receiving site details, all product details and storage conditions, match the Transfer Document                                                 
• Include identifying label information on the Transfer Document. Examples may be use by date, best before date, batch number, lot number and any other codes, brands, or descriptions, which could be used to help accurately identify the product
• Include a check that identifying information on inner packages matches identifying information on outer packages
• How the dispatching establishment verifies that the receiving site is export registered for storing dairy product, chilled and/or frozen and/or unrefrigerated
• Explain how the dispatching establishment verifies the export site company name, export registration number and address
• Explain what steps the authorised signatory takes before they sign the Transfer Document
• Explain how the authorised signatory checks that importing country requirements have been met
• Explain how the authorised signatory checks that the dairy goods are export eligible
• Explain how the receiving site receives a copy of the signed Transfer Document
• Identify that only approved signatories can issue a Transfer Document
• List the approved signatories by name and explain any training and competencies that these individuals must have to issue Transfer Documents. 
• Include a copy of the Transfer Document template, with instructions for how to fill out each field
• Include what to do if an incomplete and/or incorrect Transfer Document is issued and provided to the receiving site or received from the dispatching site
• Include what to do if a Transfer Document is not provided to the receiving site or received from the dispatching site
• Ensure that domestic eligible only product (i.e., not export eligible), is not issued with a Transfer Document indicating that the product is export eligible
• Consider to include multiple signatories where required
• Consider to include a supervisor, with signatory status (or someone suitable) for administrative checking and counter-signing the issued Transfer Documents.

For occasions where mistakes are identified, a corrective action process should be initiated.

A compliant Transfer Document system, with a detailed procedure will ensure that accurate records are kept for all received and dispatched dairy export ingredients and finished products and provide assurance to the receiving site that they are receiving export dairy eligible product. This process ensures that the receiving site, if needed, can issue a Transfer Document, at dispatch, for this same dairy export product (or product made using the ingredient that continues to meet all relevant requirements).

Manufacturer’s Declarations of Compliance

A Manufacturer’s Declaration of Compliance is a statement from you, the dairy manufacturer, that advises that your dairy product is export eligible, fit for human consumption and meets importing country requirements. A Declaration of Compliance is required to be issued by you before an Export Permit can be approved. 

You may find out that you need to issue a Declaration of Compliance, after contact from an exporter who wants to export your product. An exporter who has bought your product may need to confirm from you that it meets importing country requirements.

Declarations of Compliance are used to verify that the product meets all relevant requirements before it is exported. The information required to be included in a Declaration of Compliance is described in Milk Rules 7 – 10 (1) , (2), (3), (4) and (5).

The aim of the system is to ensure that each dairy export shipment is covered by a document, in which you attest that your dairy product intended to be exported is export eligible, fit for human consumption and meets importing country requirements. It is the responsibility of the exporter to be in possession of a Declaration of Compliance before an Export Permit is issued and before your dairy product is exported.

The dairy processing site, if it intends to export products directly, needs to develop a procedure to cover issuing of Declarations of Compliance.

As a minimum, procedures will need to ensure:

• That a declaration will be issued for each export shipment
• The declaration must only be signed by a person nominated by name in the company’s approved arrangement as a person eligible to make such a declaration (electronic signatures are acceptable)
• Staff signing these documents understand on what basis the declaration is issued and are trained to issue declarations
• Records are kept of the relevant information to demonstrate that products are export eligible and meet importing country requirements
• Triggers for corrective action when requirements have not been met, or if a declaration of compliance is incomplete/inaccurate
  declarations of compliance and Transfer Documents will include a statement about country eligibility (i.e., China for liquid milk and the European Union)
• How non-export eligible product is identified in the system and identifies the circumstances when a declaration cannot be issued
• The minimum details to be included in the declaration.

Your nominated staff, who are authorised under Milk Rules 7 – 10 5 (b), can issue Declarations of Compliance. These staff should have access to data which allows them to decide if this dairy product is export eligible and meets importing country requirements.

A declaration of compliance template is available on the Department's webpage.

Corrective action should be included in the procedure.  For example, what to do if the signatory provides a signed Declaration of Compliance to an exporter stating a particular batch code, when later they discover that the batch code on the Declaration of Compliance was incorrect.  Corrective action should be recorded, and an improved system put in place to ensure that this error won’t occur again.  Accurate product identity is needed for product recall purposes.

Records must be kept of each Declaration of Compliance that you issue, and any substantiating documents, such as microbiological or chemical test results or copies of labels.  Records are required to be kept for a minimum of 3 years.