The Biosecurity Act 2015 was designed to safeguard Australia’s ecosystem and agricultural sector. However, recent events involving the khapra beetle (Trogoderma granarium) policies by the Department of Agriculture, Fisheries and Forestry (DAFF) highlight significant gaps in the system. These shortcomings complicate compliance and put customs brokers and importers at the mercy of inconsistent directives.
Here’s a detailed account of how Platinum® Freight encountered these gaps and why the current khapra beetle policies need urgent reform.
The Issue with DAFF’s Khapra Beetle Policies
DAFF has a dual responsibility to safeguard rural postcodes in Australia against invasive pests like the khapra beetle. Their policies specifically target Full Container Loads (FCLs) shipped from “khapra beetle risk countries” such as India, Pakistan, and Bangladesh. The guidelines are clear:
- FCLs from risk countries destined for rural postcodes must be fumigated before shipping.
- If not fumigated offshore, these containers must be:
- Fully unpacked at a metropolitan location.
- Transported as loose cargo to rural addresses (in separate containers or trucks).
This policy aims to minimise the spread of pests by preventing poorly managed containers from entering rural locations. On paper, this approach makes sense. However, when applied in practice, it seems DAFF sometimes allows deviations, creating confusion for customs brokers like Platinum® and their clients.
A Case Study: When Policy Meets Loopholes
The Initial Scenario
On 5 May 2025, Platinum® Freight was contacted by an importer who had shipped machinery from India. Despite being aware of DAFF’s policies, the Indian supplier failed to fumigate the two containers (a 40-foot and a 20-foot) before shipping. The containers arrived at Port Botany on 3 May 2025.
On 9 May 2025, DAFF issued clear instructions:
- The containers must be unloaded at a metropolitan address.
- The goods could not be reloaded into the same containers for delivery to a rural postcode.
- Before the containers could be cleared in the Integrated Cargo System (ICS), the importer had to sign a declaration agreeing to these terms.
The importer complied, and DAFF cleared the containers in ICS. However, things quickly unravelled.
The Unravelling Begins
Behind the scenes, the importer disagreed with Platinum® Freight’s adherence to DAFF’s directive. They contacted a DAFF-approved depot, which transported the containers from Port Botany to a metropolitan site. Rather than unpacking the containers as required, the importer sought advice from DAFF personnel at the depot.
Shockingly, despite DAFF’s earlier directives, the depot’s DAFF officer provided conflicting advice. After recommending alternative fumigation and tailgate inspection procedures, they allowed the containers, still packed, to proceed to the rural postcode.
This directly contradicted the initial instructions Platinum® Freight received from DAFF and the clear policies outlined on the DAFF website.
Confusing Communications from DAFF
When Platinum® questioned DAFF about the contradiction, they were met with bureaucratic double-talk. An Acting Team Leader of Assessment admitted that advice from the Seasonal Pest Policy team had overruled earlier directives. The policy unit had permitted an alternative solution due to the high value and fragility of the cargo.
Although this resolution satisfied the importer, it left Platinum® Freight in an uncomfortable position. The inconsistency in DAFF’s guidance made Platinum® appear unreliable to their client, even though they had strictly followed the original directive.
Why Does This Matter?
DAFF’s shifting policies erode the trust between customs brokers, importers, and regulatory bodies. The purpose of the Biosecurity Act 2015 is to ensure consistent, clear, and enforceable biosecurity measures, protecting Australia’s agricultural regions. Yet, this case highlights how these standards can crumble under pressure:
- Unclear direction makes it nearly impossible for customs brokers to confidently advise clients.
- Case-by-case decision-making undermines DAFF’s published policies.
- Perception of bias arises when some importers receive more lenient solutions while others face costly compliance measures.
Case in point, other importers have adhered strictly to the rule of unpacking FCLs at metropolitan locations, incurring significant costs. Why was this particular shipment allowed a “workaround”?
If DAFF’s Seasonal Pest Policy unit permits alternate outcomes based on importer objections, then the existing khapra beetle policy is simply unfit for purpose.
How Khapra Beetle Policies Must Evolve
DAFF must address the inconsistencies in its khapra beetle policies to ensure fairness and transparency. Platinum® Freight suggests the following reforms:
1. Fumigation in Australia as Standard Practice
If offshore fumigation is not completed, DAFF should mandate fumigation upon arrival in metropolitan Australia before re-clearing goods for rural delivery.
2. Consistent and Standardised Processes
Policies outlined in BICON (Biosecurity Import Conditions) and on the DAFF website should be definitive and not open to interpretation based on individual complaints.
3. Immediate Reassessment of the Current Policy
The existing policy should be reviewed to eliminate the costly burden on compliant importers. Allowing local fumigation and rural tailgates as a streamlined process benefits importers and enforces biosecurity.
4. Transparent Decision-Making
DAFF must ensure that all parties receive uniform guidance. To avoid ambiguity, any deviations from policy should be transparently shared and justified.
5. Centralised Oversight of Seasonal Pest Policy
A dedicated oversight team should monitor how khapra beetle policies are applied in live scenarios, offering consistent enforcement across all cases.
Key Questions DAFF Must Answer
Cases like this raise critical questions:
Who is overseeing the Seasonal Pest Policy unit?
Lack of transparent leadership allows discretionary decisions that undermine importer trust and compliance.
How is policy enforcement monitored?
If DAFF staff at depots can contradict written policy, how are brokers and importers supposed to follow the rules?
Without clear answers, confidence in Australia’s biosecurity system will continue to erode, leaving room for pests like the khapra beetle to harm our agricultural heartland.
The Biosecurity Act 2015 was introduced to protect Australia’s unique environment, agricultural industries, and rural communities from biosecurity threats. However, inconsistent enforcement and unclear directives from DAFF risk undermining its purpose.
For customs brokers like Platinum® Freight, navigating these policies becomes an uphill battle when enforcement agencies fail to uphold their own standards. Whether you’re an importer or broker, transparency and consistency are essential to protect your interests and Australia’s agricultural future.
It’s time for DAFF to acknowledge the gaps in its seasonal pest policy and implement reforms that focus on clarity, fairness, and the shared goal of safeguarding Australia.
To learn how Platinum® Freight can help you manage imports with confidence, call us on 1300 882 877 or visit Platinum® Freight Management.