The CRIS encompasses the whole of DAFF's cost recovery framework. OOA's submission addresses the organic-specific component within that framework.
The CRIS cost base
1. Accept the proposed cost increments on organic certifiers within the current CRIS projections ($8,000 increasing to $9,480 by 2028, see Section 1.1, Escalating certifier fees); recover costs of certifier compliance audits from organic certifiers within these projections; and introduce no new fees to the organic sector during the implementation period.
2. Limit any additional cost recovery on the organic sector within the implementation period (2026–2028). DAFF-commissioned cost-benefit analyses—Cost benefit analysis for the implementation of a mandatory domestic organic standard (Deloitte, March 2021) and Cost benefit analysis of a new regulatory approach for domestic organics (PwC, March 2022)—found that additional regulatory costs on the organic sector would be significant and would likely be passed through the supply chain. The government's decision in March 2023 not to proceed with domestic regulation was based on these findings. Full cost recovery of existing services would impose cost burdens that would exceed the benefits—particularly for smaller operators, for whom including the cost of compliance outweighs the benefits (see Section 4.2).
3. Recognise that the primary transferable cost burden sits in standard administration and National Standard Advisory Committee (NSAC) management—functions that can transition to Standards Australia. Systems-level compliance auditing of Approved Certifying Bodies (ACBs) overlaps with accreditation body assessment and can be rationalised. Function auditing (witness audits, operator reviews) and OGC management oversight are sovereign Competent Authority functions that must remain with DAFF (see Section 2.2(c)).
4. Provide the functional cost breakdown of the Export Organic team, disaggregated by function, to enable industry assessment of cost efficiency and identification of transferable functions (see Section 1.1, Functional breakdown). OOA further requests that DAFF disclose the overhead allocation methodology applied to the organic program under the CRIS, including the cost driver used for apportionment, to enable industry to assess the full cost reduction from the structural reform and multilateral pathway proposals (see Section 2.8, Reduced shared overhead allocation).
5. Commit to a structural reform timeline aligned with the CRIS implementation period (2026–2028), encompassing the consolidation of the National Standard into AS 6000, the transfer of standard administration to Standards Australia, the rationalisation of the systems-level compliance audit, and program efficiency measures (see Section 2.2). Transitional considerations support this timeline (see Section 2.7). OOA commits to submitting a formal proposal for the ongoing co-regulatory governance of the organic standard to DAFF by no later than early-2028, to formalise the arrangements implemented during the structural reform period.
6. Extend the consultation period and commit to ongoing engagement with industry on implementation timing and methodology (see Section 4.1).
Structural reform enabling cost reduction
7. Confirm DAFF's role in providing: Competent Authority functions—the government body recognised by trading partners as having regulatory authority over organic certification and export—including function auditing of certifying bodies (witness audits, operator reviews), Organic Goods Certificate (OGC) management oversight, biosecurity and phytosanitary oversight, export certification issuance, and negotiation and maintenance of bilateral organic equivalency arrangements with trading partners (see Section 2.5).
8. Adopt a Canadian+ model of structural separation: Facilitate the consolidation of the National Standard and AS 6000 into a single AS 6000, with ownership resting with Standards Australia and given regulatory force through incorporation by reference into the Export Control (Organic Goods) Rules 2021 (see Section 2.2(b)). This model is validated by the Canadian CFIA/CGSB precedent, where the regulator maintains full equivalency with all major markets while a standards body manages the technical standard (see Section 2.1(a)). The "+" denotes an extension through a multilateral equivalence pathway via IFOAM Common Objectives and Requirements of Organic Standards (COROS) alignment, reducing per-market negotiation costs (see Section 2.1(b)). The only legislative change required for the structural reform is the amendment to the Rules to reference AS 6000 in place of the National Standard.
9. Support the AS 6000 consolidation proposed in Recommendation 8: Communicate technical requirements to Standards Australia by participating in the AS 6000 Standards Australia committee in an advisory capacity and ensuring the consolidated standard supports equivalency with all current and prospective trading partners (see Section 2.5(g)). OOA requests that DAFF provide all trading partner communications specifying requirements for Competent Authority standard ownership, to enable informed assessment of the structural separation proposal (see Section 2.1(a)).
10. Pursue multilateral equivalence recognition: Support OOA's engagement with IFOAM—Organics International to have the consolidated AS 6000 (incorporated by reference into the Export Control (Organic Goods) Rules 2021) assessed against COROS for inclusion in the IFOAM Family of Standards—the only existing global program for multilateral equivalence of organic standards and technical regulations. Inclusion provides a multilateral platform for equivalence recognition by current and prospective trading partners, reducing Australia's reliance on resource-intensive bilateral negotiations for each market (see Section 2.1(b)). OOA requests that DAFF provide technical input into the COROS alignment process.
11. Redirect resources toward US/Canada equivalency: Reallocate savings from transferred administrative functions toward negotiating equivalency arrangements (see Section 2.2(d)) to replace the costly conformity model currently imposed on Australian operators (see Section 2.3).
12. Expand the Manual of Importing Country Requirements (MICoR) by documenting organic protocols for non-equivalence markets, and ensure clear cross-referencing between organic integrity requirements and mandatory biosecurity treatments so that technical market access requirements are harmonised. As the multilateral equivalence pathway proposed in Recommendation 10 reduces the number of non-equivalence markets requiring detailed bilateral documentation, the scope of this function narrows over time (see Section 2.2(d)).
Minister’s discretion and broader policy
13. Include the biodiversity and environmental service value of organic certification as a policy consideration in setting the level of cost recovery, per the Minister's discretion under the Australian Government Charging Framework: charging policy may take account of broader government objectives. Over 2.65 million hectares of certified organic land is dedicated to biodiversity under the 5% set-aside requirement (National Standard; AS 6000), representing a replacement cost of approximately $273 million annually based on the NSW Biodiversity Conservation Trust's median conservation agreement payments. Over 3,000 organic operators deliver this audited environmental protection at a cost to the taxpayer of less than $2 million annually—compared with the Agriculture Stewardship Package's allocation of $32.1 million to trial a biodiversity certification scheme for 140 farmers, designed to incentivise biodiversity management that certified organic producers already deliver. The organic sector also avoids the environmental remediation and health costs that the CSIRO and One Basin CRC report, Towards a state of the food system report for Australia (2025), attributed to conventional agricultural inputs at up to $274 billion annually for the food system as a whole. OOA proposes that the organic sector’s contribution be reflected in the determination of cost recovery levels, whether through the cost allocation methodology or through the Minister's exercise of discretion under the Australian Government Charging Framework (see Section 3.3).
14. Engage with OOA to establish the proposed model of an organic R&D component within existing commodity levy instruments, with the R&D component for certified organic products directed to a dedicated Organic Program within AgriFutures Australia (see Section 3.2). The methodology and mechanisms are detailed in OOA's paper to DAFF Proposal for Organic R&D Levy Components and an AgriFutures Organic Program.
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