The introduction of the controversial Biosecurity Protection Levy and its timing has "not fully considered" the operational and practical complexities of the sector, according to the nation's grain levy collectors.
In a Senate inquiry submission, Grain Trade Australia chief executive Pat O'Shannassy added that the creation of a new process for the levy would increase management and handling demands on traders, along with a "substantial" increase in costs, and that this should be considered part of the levy's "perceived value."
The levy legislation was referred to a Senate committee on March 21 after Coalition, Greens and other lower house crossbench MP's took aim at the policy, including calling for a container levy to be introduced to help fund the national biosecurity response.
The committee must report by May 10 with public hearings set for April 23.
However, Mr O'Shannassy said the scheduled July 1 introduction date for the levy remained "ambitious" given a range of design, process and collection issues remaining in the air.
"GTA members will require time. Systems updates and enhancements to support change will need to fit within current priorities and workloads of individual companies," he said.
It is believed that should the levy be delayed there would be no retrospective application once it became operational.
Mr O'Shannassy said the government also must avoid extra imposts on levy collectors by utilising existing systems, processes and collection mechanisms for the biosecurity levy.
"The collection and transmission of funds requires sophisticated systems and processes to ensure levies are correctly deducted from growers and paid to appropriate government agencies and other stakeholders, such as plant breeding companies," he said.
"The establishment and operation of these systems on behalf of government comes at a cost."
The comments follow Australian Livestock & Property Agents Association chief executive Peter Baldwin also raising issues with the levy and its collection.
DAFF acting first assistant secretary Bronwen Jaggers recently confirmed in Senate Estimates that commodity collection agents would be used to collect the levy and, "as far as possible", using the same collection mechanisms already in place.
Mr O'Shannassy also said the commencement of levy collection must be managed appropriately to ensure commodities with established industry levy systems, such as grains and livestock, do not start paying the new fee prior to those commodities without existing levies, which are overwhelmingly from within horticulture.
"Inequity will create discord and the need for ongoing review and analysis by Government. Management of this process will be costly," the GTA submission said.
The design of the levy was changed by Mr Watt earlier this year from a percentage of industry rates covering most commodities to a sector proportionate share of total gross value of production to cover nearly all commodities after equity issues were raised during a period of public consultation last year.
The DAFF submission also said that while the government had increased cost recovery from importers with increases to full import declaration charges introduced last year, "Australia is a strong supporter of the multilateral trading system " and must ensure a container levy "would be consistent with Australia's international trade law obligations and the Commonwealth charging framework."
Meanwhile, individual commodity calculations farmers will pay towards the levy have been revealed.