Export Certification
27 September 2007
The 1st September deadline is drawing close and to our knowledge very few timber exporters have achieved compliance with the export certification procedures that must be implemented on that date.
We have noted our concerns to the Director-General of MAF pointing out that:
The requirement of the new regime are overly technical and sometimes ambiguous; i.e. too detailed and complicated.
The requirements of the new system are unnecessary for timber and therefore unjustifiably expensive.
Timber exporters are needing to employ consultants to draft and have approved, site manuals. This is a very expensive exercise that would cost the industry up to $1.0 million.
There are insufficient expert consultants to have all export sites compliant by due date.
The situation is exacerbated by requirements of service providers such as transport and port companies to implement their own approved systems. Timber exports could be frustrated if these service providers are not certified.
There is a shortage of qualified evaluators to allow IVAs to properly examine and approve systems for each individual site.
Our fear is that if a resolution is not found timber exports will be reduced to a trickle after 1 September 2007.
STOP PRESS
On 2 August 2007 the staff of the NZTIF held a meeting with MAF Biosecurity New Zealand to address concerns around the implementation and detail of the new export inspection standard.
Our chief issue was the large number of exporters unable to have compliant systems in place by the 1 September 2007 deadline.
The outcomes from the meeting on this points are as follows:
MAF BNZ have agreed that those companies who have submitted documents to their IVA by 1 September 2007 will be able to continue exporting as before until such time as full accreditation is achieved. This grace period will extend until at least the end of the year. MAF BNZ will communicate exact time frames within the next few days.
Those who have not submitted documentation to their IVA by 1 September 2007 will not be forced to perform costly and impractical end point inspection for export product but will have their audit frequency under current practice increased. The exact frequency will reflect each companies export inspection compliance history and the product type exported. This is a short term measure with the aim of making the shift to the new standard workable for those who will be unable to have compliant documentation drafted by 1 September 2007. MAF BNZ will communicate in the next few days the likely time period that this solution will be allowed.
The numerous issues and impracticalities in the new standard highlighted to us by exporting members were tabled at the meeting. The outcome is that MAF BNZ have undertaken to initiate a forum where these can be formally addressed and rectified if necessary.
It is extremely unlikely that any changes will be able to be implemented before 1 September 2007 or soon after that. Companies should therefore continue to base their documentation on the stipulations in the present standard.
The acceptance of current industry practice and the recognition of industry quality assurance schemes such as the WOODmark® and NZDri as acceptable phytosanitary treatment programmes was embraced by MAF BNZ.
We will be working closely with MAF BNZ to see if these systems can be integrated as soon as possible.
In spite of this relief we urge timber exporters to press on with progress to achieve compliance as soon as possible. The arrangements with MAF Biosecurity is not an excuse to stop work on implementing a compliant export inspection system at your site.