AusBiotech suggests FSANZ amend cost recovery plan
21 February 2017: AusBiotech has responded to Food Standards Australia New Zealand (FSANZ) call for comment on the draft Cost Recovery Implementation Statement (dCRIS), rejecting the proposed model to recover from industry direct and indirect costs of all FSANZ staff, and the total cost of the FSANZ Board, which are not directly involved in the specific activity in the Activity-Based Costing model used in the dCRIS.
The dCRIS provides information on how FSANZ applies cost recovery arrangements to certain applications to develop or amend food standards.
AusBiotech said it supports cost recovery where it is “justifiable, appropriate and proportionate to recovering the efficient costs of a specific government activity,” but noted that FSANZ do not have the legislative or policy authority to recover the full costs associated with all FSANZ staff.
AusBiotech said it could instead support a revised dCRIS in which overheads where correctly allocated in accordance with the Australian Government’s Cost Recovery Guidelines and only relating to the efficient costs of the specific activity undertaken, and not the overhead costs of the whole organisation.
AusBiotech said the increase in FSANZ’s fees for a food approval application, as described in the dCRIS, would elevate Australia to the top tier of fee-charging countries internationally. The cost of a FSANZ food approval application would be in-line with Russia (~$90,000), above China (~$60,000) and Argentina (~$20,000); and significantly more than regulatory agencies in jurisdictions charging no fee at all including the US FDA and countries such as Japan, Canada, EU, Switzerland, Singapore Brazil, Chile and Costa Rica.
AusBiotech recommended benchmarking FSANZ’s fees against other international regulatory agencies or regulatory frameworks to ensure that FSANZ’s fees are not adversely affecting Australia’s international competitiveness and access to innovative agricultural technology.
AusBiotech supported the thorough economic analysis provided by CropLife Australia in its submission.
AusBiotech acknowledged the critical role played by FSANZ in maintaining the integrity of Australia’s high level of food safety and said the cost, transparency and predictability of regulation are important considerations in the commercialisation of innovations in the agricultural sector.
“Any proposed increase to the cost of regulation has the potential to restrict or inhibit investment in agricultural innovations and/or reduce the commercial viability of technologies that could deliver benefits to the Australian farming sector. In addition, the relative cost of regulation in Australia compared to other jurisdictions is an important determinant for investment in and development of innovation in the Australian agricultural sector,” said AusBiotech CEO, Glenn Cross.
AusBiotech’s submission can be found here.