Every six months, the Australian Border Force publishes a Goods Compliance Update to industry. It covers both import and export declarations. It lists the errors most frequently identified across the clearances processed during that period.
The list is almost always the same.
Wrong classification. Wrong INCOTERMS. Wrong currency. These three categories of error appear so consistently across so many operators that the compliance report reads less like a finding and more like a standing reminder of a problem the industry has not solved.
Peter McRae has been reading these reports since before many of the operators currently making these errors entered the industry. He has a clear view of why the errors keep happening, who is responsible for fixing them, and what a large Australian multinational discovered when it asked him to audit its own export procedures.
“Why create a report every six months when the writing is on the wall about why these errors are happening? The answer is not more reports. The answer is who is allowed to submit the declarations in the first place.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
The Audit
When a Multinational Asked Peter to Review Their Export Declarations
A large multinational with significant export volumes had grown concerned about the accuracy of their own export data being submitted to the Australian Border Force by its export team. They were not facing an active compliance investigation. They simply understood that if the data was wrong, the consequences could be serious, and they wanted to know before the ABF told them.
Some of the goods being exported also required Department of Defence permits, which added a layer of regulatory sensitivity, making accuracy in the export documentation a matter of more than mere administrative tidiness.
They engaged Peter to review the current system and the data being submitted.
What he found was consistent with what the ABF compliance reports document repeatedly. The errors were not random or unusual. They were the predictable output of a structural problem that runs through the way Australian export declarations are currently handled.
“When I audited those export procedures, the errors were the same ones you see in every ABF compliance report. Classification wrong, INCOTERMS wrong, currency wrong. The same errors, every time, because the same structural problem produces them every time.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
The multinational made a significant investment to have a qualified customs broker review and assume responsibility for its export declarations going forward. It was a decision driven not by a specific incident, but by the recognition that the risk of getting it wrong with that particular customer was not one they could afford to carry.
The Structural Problem
The Rule That Creates the Risk
To understand why the same export errors appear in every compliance report, you need to understand one specific rule that governs who can submit what in Australia.
In Australia, a licensed customs broker is the only person who can submit an import declaration for goods with a customs value above $1,000 AUD. This threshold has been in place for some years. It reflects the view that import declarations above a certain threshold carry sufficient revenue and compliance implications to warrant a qualified professional.
There is no equivalent rule for export declarations.
Anyone, regardless of their training, experience, or qualifications, can submit an export declaration to the Australian Border Force for goods of any value. A company’s accounts payable officer can submit it. A junior logistics coordinator can submit it. An operator at a freight forwarding company who has never studied customs classification can submit it. There is no licence required and no minimum qualification specified.
Import declarations over $1,000 AUD: Must be lodged by a licensed customs broker.
Export declarations (any value): Can be lodged by anyone. No licence required.
Export Declaration Number (EDN) required: For goods valued over $2,000 AUD, or for any value when goods are regulated, require Defence permits, or are otherwise controlled.
“There is dysfunction in this system. You need to be a customs broker to submit import declarations over $1,000. You do not need to be a customs broker to submit export declarations of any value. So then you have people without the training and experience submitting export data, and there are going to be errors all over the place.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
The Recurring Errors
What Goes Wrong, and Why It Keeps Going Wrong
The three categories of error that appear in every ABF Goods Compliance Update are not complicated errors. They are not the kind of mistakes that require a novel regulatory scenario or an unusual product. They are fundamental, repeatable errors that occur because the person submitting the declaration lacks the training to get them right consistently.
“Classification is a skill that you develop every day. If you have got an export operator who does not have the history of a customs broker, they are going to keep making the same errors every day. The ABF Goods Compliance Update says so. Every time.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
The $1,000 Threshold Problem
Why Even Low-Value Export Declarations Carry Risk
The absence of a licence requirement for export declarations applies regardless of the value of the goods. An export declaration for a $500 consignment can be submitted by anyone. So can a declaration for a $500,000 consignment.
Peter raises a related concern about import declarations for goods under $1,000, which similarly do not require a licensed customs broker. The problem is not just that the threshold creates an opening for untrained operators. It is that the threshold can be manipulated.
“Just because the invoice says the goods are under $1,000 Australian dollars, that is not always the true value. Sometimes people just do it to get it through and pay less duty. A customs broker would know the questions to ask to establish whether it is genuinely under $1,000 or not.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
This is not a theoretical concern. Deliberate undervaluation of customs declarations is a form of customs fraud. It reduces the duty payable, distorts official trade statistics, and in categories where import controls apply, can be used to avoid scrutiny that would otherwise apply to higher-value shipments.
The threshold designed to reduce the administrative burden on low-value trade has, in Peter’s view, become a vulnerability that the current system does not adequately address.
The Defence Permit Dimension
When Export Errors Become a National Security Matter
For most exporters, the consequences of a wrongly classified or incorrectly valued export declaration are administrative: potential penalties, correspondence from the ABF regarding compliance, and the reputational cost of appearing on a compliance report.
For exporters dealing in controlled or regulated goods, the stakes are higher.
Certain goods exported from Australia require permits from the Department of Defence under the Defence Export Controls framework. These include defence and strategic goods, dual-use items with both civilian and military applications, and goods listed on the Defence and Strategic Goods List (DSGL). For these goods, an Export Declaration Number is required regardless of the consignment value, and the accuracy of the declaration is a matter of national interest, not merely administrative compliance.
When Peter audited the multinational’s export procedures, the presence of Defence-controlled goods in the export mix was precisely what elevated the concern from an operational issue to a strategic one. An export operator who does not know how to identify goods that require Defence permits, or who does not understand the compliance pathway those permits require, is not just creating administrative problems.
Peter’s Position
A Direct View from Someone Who Has Seen the Evidence
Peter has been careful throughout his career to distinguish between what the current rules require and what he believes the rules should require. On this issue, his position is clear, and it is based on evidence he has accumulated across 28 years of practice, a formal audit engagement, and regular review of the ABF’s own compliance reporting.
In my view, licensed customs brokers should be the only people permitted to submit export declarations to the Australian Border Force, regardless of value. The same logic that requires a broker for import declarations over $1,000 applies equally to exports. The Goods Compliance Update issued by the ABF every six months proves the point. The same errors keep appearing because the same structural gap keeps producing them.
This is not a self-interested position in the narrow sense. A policy change of this kind would increase costs for exporters in the short term, as licensed brokerage services carry a professional premium over basic freight forwarding. Peter acknowledges that openly.
What he argues is that the cost of accurate export compliance — correctly classified goods, correctly recorded INCOTERMS, correctly declared values — is lower than the cost of the alternative: a compliance record, a regulatory investigation, or a major customer relationship ended because the export data that carries your name to the ABF cannot be trusted.
“In my mind, customs brokers who have a licence should be the only ones submitting export declarations to the ABF. The evidence is there every six months in the ABF’s Goods Compliance Updates. The writing is on the wall.”
— Peter McRae | Licensed Customs Broker, Platinum® Freight Management
What Exporters Should Do Now
Questions Every Australian Exporter Should Be Asking Their Freight Forwarder
Whether or not the regulatory framework changes, Australian exporters have a responsibility to understand how their export declarations are prepared and by whom. Here are the questions Peter recommends asking:
Speak with Platinum® Freight Management
Peter McRae has audited export compliance procedures for major Australian exporters and has a detailed understanding of the recurring errors documented in the ABF’s own compliance reports. If you want an honest assessment of your current export declaration process, call Platinum® Freight Management today.
Call 1300 882 877Every shipment has a number. Every person has a name. Platinum® knows the difference.
Platinum® Freight Management is a licensed customs brokerage operating Australia-wide since 2000. Peter McRae holds a Master of International Customs Law and a Master of International Revenue Administration (University of Canberra) and has been a licensed customs broker since 1998. Member: IFCBAA and Freight & Trade Alliance. ABN 58 095 228 934. The views expressed in the opinion section of this article are those of Peter McRae and represent his professional position based on industry experience and observation of ABF compliance reporting. They do not represent the position of the Australian Border Force or any government agency.