STOCK FOOD SUPPLIER DECLARATION FORM - sfmca

14 September 2012Department of Agriculture, Fisheries and ForestryAgvet Chemicals (Domestic & International Policy)Agricultural Productivity DivisionGPO Box 858CANBERRA ACT 2601Re: FIRST-PRINCIPLES REVIEW OF THE APVMA'S COST RECOVERYARRANGEMENTSThe Stock Feed Manufacturers’ Council of Australia (SFMCA) is the peak industry bodyrepresenting Australian feed manufacturers. SFMCA members manufacture over 5.5MMT ofanimal feeds annually. The members of our organisation manufacture a wide range of feeds, withmany of these including veterinary chemical products. Some of our members also manufactureand supply veterinary chemical products.This letter relates to the First-principles review of the APVMA's cost recovery arrangements.From a global perspective Australia is a small market for veterinary chemical products. In termsof products for use within stockfeed, Australian feed manufacture represents approximately 1%of the global feed market volume. It is of note that the vast majority of feed additives andmedications are manufactured overseas and imported into Australia. Commentary from ourmembers, including distributors of veterinary chemical products, is that the cost of productregistration in Australia is already presenting a barrier for global companies to register newproducts within Australia.We believe any move to increase the upfront application fees (nominally 40%) will result in agreater barrier to new product entry. We would argue that the higher portion of cost recoverymust come from ongoing levy on product sales.The disincentive excessive registration costs place on new products is seen in Australianlivestock producers not having access to veterinary chemical products that are utilised in otherlarger countries. This situation places Australian livestock production at a major disadvantage tocompetitors in the global market for livestock products.Stock Feed Manufacturers’ Council of Australia Inc. ABN 84 816 063 155PO Box 383 Beaconsfield VIC 3807 Telephone: 03 9769 7170 Facsimile: 03 9769 7174 Website: www.sfmca.com.au

The SFMCA believes that the APVMA’s registration process is onerous and does not takeadequate account of low risk veterinary chemical products. This results in low risk productsrequiring extended and expensive registration. We believe there needs to be a lower costregistration mechanism for low risk feed additives. For example feed enzymes are widely usedand new product formulations should undergo minimal evaluation and carry a correspondingminimal registration fee.CONTACT DETAILSMr John SpraggStock Feed Manufacturers’ Council of AustraliaPO Box 383BEACONSFIELD VIC 3807Telephone: 03 9769 7170Email: jspragg@sfmca.com.auSFMCA Letter – First principles review cost recovery arrangements for APVMA, September 20122