OOA has provided to APVMA a submission on the internalisation of externalities from agricultural and veterinary chemicals, remediation, risk disclosure, and sustainable finance implications for Australia's organic sector.
APVMA (the Australian Pesticides and Veterinary Medicines Authority) has released its Regulatory Posture Statement 2026–30 and that the Assistant Minister for Agriculture, Fisheries and Forestry, Senator the Hon Anthony Chisholm, has issued a new Ministerial Statement of Expectations. OOA's proposals in this submission are directed at matters within the scope of both instruments. The Regulatory Posture Statement commits the APVMA to prioritising resources "toward the greatest risks to humans, animals, the environment, and to Australia's trade, applying streamlined, proportionate approaches where appropriate.”
OOA submits that the downstream risk to Australia's organic trade from AgVet chemical contamination—valued at approximately $1 billion AUD in organic exports annually—falls within this prioritisation framework. The Ministerial Statement of Expectations requires the APVMA to "take regulatory decisions and actions that are consistent, predictable and based on the best available science" and to "routinely and clearly communicate on its regulatory decisions and actions." OOA's proposals for standardised risk disclosure documents (Section 3.3), proactive exercise of chemical review powers (Section 3.4), and post-registration monitoring that accounts for downstream impacts on exclusion-based production systems (Section 3.4) are directed at these expectations. The Statement of Expectations further requires the APVMA to "actively contribute to the government's regulatory reform and productivity agenda" by "achieving its regulatory objectives efficiently and effectively, minimising the cost recovery burden on industry." OOA submits that the cost recovery burden on the organic sector—arising from contamination externalities the organic sector does not create—is a matter the APVMA's regulatory reform agenda should address (see Section 3.1).
This submission is one of three related submissions by OOA: a separate DAFF CRIS submission addresses organic export regulatory services and whole-of-DAFF cost recovery, and a separate OGTR submission addresses gene technology externalities. Each submission is directed to the regulatory body with the relevant jurisdiction. OOA notes that the APVMA sits within the Agriculture portfolio and is an independent statutory authority responsible for the regulation and control of agricultural and veterinary chemicals in Australia up to and including the point of retail sale.
OOA's submission addresses the environmental stewardship dimension of the organic sector's relationship to the APVMA's regulatory framework. All certified organic operators—whether exporting and/or selling domestically—are required by their certification standards to internalise environmental management obligations that the APVMA's statutory functions are designed to protect. These include the prohibition on synthetic chemical and synthetic nitrogen inputs, the maintenance of defined biodiversity conservation areas (a minimum of 5% of total farm area under the domestic standard AS 6000:2015 and the export National Standard, currently 2.65 million hectares and valued at a replacement cost of $273 million annually, see Section 4.2), and documented management of soil health, water resources, and ecological connectivity. These are auditable conditions of certification, not voluntary commitments. When AgVet chemical contamination—from spray drift, watercontamination, and legacy soil residues—degrades land managed under these environmental obligations, the consequence is both environmental (loss of a documented, auditable environmental management function) and commercial (loss of certification and market access).
OOA's submission also addresses the trade dimension. The APVMA's statutory criteria include the trade criteria under section 5C of the AgVet Code, which require that use of a registered chemical product does not, or would not, unduly prejudice trade or commerce between Australia and places outside Australia. AgVet chemical contamination that causes organic decertification and loss of organic export market access engages the trade criteria directly.
OOA's submission further addresses the sustainable finance dimension. The Australian Government's Sustainable Finance Roadmap (Treasury 2024) and the Australian Sustainable Finance Taxonomy (ASFI 2025) classify agriculture and land as one of six priority sectors for sustainable capital allocation, subject to a Do No Significant Harm (DNSH) framework that requires taxonomy-aligned activities to not undermine biodiversity, water resources, and/or pollution prevention objectives. AgVet chemical contamination threatens organic operators' taxonomy alignment and access to sustainable capital flows—a consequence that is distinct from, and additional to, the environmental, trade, and market access consequences addressed in this submission.
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