5 October 2012
CropLife members recognise the need for a strong, adequately resourced and effective regulator for agricultural chemicals and their products. CropLife also recognises the need for the cost of some APVMA functions to be recovered from applicants and registrants. However, CropLife is concerned that current arrangements do not reflect existing government cost recovery policy and are based on out-dated and inaccurate presumptions about the Australian market.
To this end, CropLife has welcomed the First-Principles Review of the APVMA’s cost recovery arrangements and has previously asserted that such a review is essential to ensuring that the Authority’s cost recovery arrangements are equitable, consistent with government cost recovery policies and, if appropriate, encourage innovation in the development of new agricultural chemical tools. Furthermore, we are deeply concerned that rectification of this significant inconsistency is not addressed in the discussion paper.
The issue of cost recovery arrangements is of major significance to the industry and goes to the core of the efficiency of the registration system
With the Federal Government in the process of developing a National Food Plan, its current Better Regulation of Agricultural and Veterinary Chemicals proposals and its National Harmonisation of Agricultural and Veterinary Chemicals process, it is crucial to recognise that the plant science industry is a critical component to the productivity and competitiveness of Australian agriculture. A low cost, efficient registration system is essential to enable the industry to support the Australian farming sector. The consequences of an internationally uncompetitive and expensive registration system will be a loss of crucial products in the Australian market, a delay of new innovative products coming to the Australian market, as well as farmers paying more for existing registered products, all of which must be avoided and should be the focus of this review and the associated regulatory reform initiatives.