7 September 2026
With the APVMA’s consultation period on its proposed Cost Recovery Implementation Statement (CRIS) now closed, the national peak industry organisation for the plant science sector has warned the proposal in its current form poses a serious, direct threat to farming productivity and will put upward pressure on food prices for Australian families.
CropLife Australia has lodged a comprehensive submission outlining the significant problems with the cost recovery proposal and recommending better models to achieve the outcomes being sought. The submission is underpinned by independent analysis from leading economics, policy and advisory firm ACIL Allen.
“The APVMA’s new cost recovery model creates risks to the productivity and international competitiveness of Australia’s agricultural industries. It will limit the ability of our farmers to grow the fresh produce needed to lower cost-of-living pressures created by food inflation while also resulting in an overcollection of fees, charges and levies from industry,” said Mr Matthew Cossey, Chief Executive Officer of CropLife Australia.
“A properly resourced, well-functioning regulator that can turn around assessments in a reasonable timeframe is firmly in industry’s interest, and we support the APVMA being equipped to do that job well. Our concern is not that industry should pay its share, it’s that this model gets the balance wrong.
“ACIL Allen’s analysis confirms what industry has been saying since July: the proposed fee structure is not proportionate, not evidence-based, and not fit-for-purpose. Their final report found the shift to full upfront cost recovery for registration costs will deny farmers access to new products that, because of the size of the Australian market, were only marginally viable prior to the price hike.
“One of the most damaging outcomes identified by ACIL Allen is the creation of a ‘no-man’s land’, where registering a product, or a specific use, becomes uneconomical due to higher application fees, yet that same use is ineligible for access under a permit.
“Worse still, the impact will disproportionately affect productivity in smaller and specialty crops, especially in horticulture, where growing productivity is not only critical to Australian agriculture but essential for delivering cost-of-living relief.
“Last week’s Food for Thought analysis from ANZ brought to light the cost-of-living pressure that Australian families have been feeling at the checkout for years, with the price of vegetables rising almost 65 per cent since September 2017.
“This shows it is not just farmers who cannot afford this change but Australian families, from the cities to the bush,” Mr Cossey said.
The ACIL Allen analysis also pointed out that patents typically run for 20 years, but by the time a product is registered in Australia, nearly half that patent is already elapsed. With higher upfront fees proposed for that narrow window to recover costs, a real risk exists that some products or uses may not be economical to bring to Australia.
The analysis also provides a roadmap for developing a more informed approach to support cost recovery arrangements that provide greater resourcing to the APVMA without hobbling the farm productivity supporting all Australians.
“We look forward to working with Minister Chisholm, DAFF and the APVMA on proper engagement with industry and farmers before any final decision is made. There’s still time to get this right, and CropLife will keep offering practical suggestions to help get to a funding model that supports the APVMA, Australian farmers, and the competitiveness of the sector,” Mr Cossey concluded.
ENDS
Find the link to the ACIL Allen report here.
Find the link to CropLife Australia’s submission here.