Labor's proposed new levy on farmers is inconsistent with the agreed principles of the National Biosecurity Strategy and hides a range of potential unintended negative consequences for both agricultural and biosecurity systems.
The National Farmers Federation also said in a submission to a Senate inquiry formed to investigate the Agriculture (Biosecurity Protection) Levies Bill 2024 and related bills that inadequate time was provided for policy development and implementation of new legislative frameworks destined to heavily impact the majority of Australia's 85,000 producers and agricultural supply chain participants.
The levy is scheduled to begin on July 1.
In the submission, NFF chief executive Tony Mahar also expressed concerns that funds raised through the Levy, to be directed into Consolidated Revenue instead of the government's dedicated biosecurity account, will be used to bridge "existing cost recovery shortfalls" instead of frontline biosecurity services.
He added that while farmers were open to "sensible opportunities" to invest in additional biosecurity measures, despite primary producers already contributing heavily through on-farm management and existing industry levies, the NFF remained unequivocally opposed to the BPL due to "serious, principle-based concerns with the construct of the policy."
"Unfortunately, this policy lacks the sensible component," Mr Mahar wrote.
The NFF also believe that a late change in the basis of the BPL, from a flat fee based on existing commodity levies to a gross value of production model, would result in smaller farm businesses being asked to more pay more, particularly within horticulture.
"There has been no industry consultation on the GVP model. While this change claims to create a more equitable and fairer model, it ultimately fails to address the NFF's wide-ranging concerns," Mr Mahar wrote.
The NFF also amplified a chorus that began with lower house crossbenchers last month calling for a container levy to be included in the package of Bills, it also demanded that the government outline the purported trade impediments that stopped it from progressing a container levy.
The submission said the NFF's key objections to the levy included the "likelihood" of its distortionary presence denting the confidence and support of producers in the critical rural research and development system.
Along with a lack of recognition of existing producer contributions to the biosecurity system, the need for increased contributions from risk creators and inconsistency with the NBS, particularly in relation to sustainable investment prioritisation and concerns around equitability, transparency and accountability.
Mr Mahar also called on the inquiry, which must report by May 10, to not let "an arbitrary implementation deadline" allow issues with a "significant" policy change for the sector proceed unresolved.
"The lack of certain and clear information available to industry this close to the proposed implementation date... is both a consequence and perfect example of the impact of a rushed and poor process," he said.
Mr Mahar also asked the inquiry to not misconstrue its support for the Sustainable Biosecurity Funding Advisory Panel, announced as the BPL legislation was introduced to Parliament in February to facilitate industry oversight over collected revenue, as support for the levy.
"The government's opportunistic timing has made it incredibly difficult for the NFF to publicly and politically separate our positions on the two measures," he said.
He added that panel members were still to receive formal terms of reference, fuelling concerns it was "an eleventh-hour token to dilute and confuse industry's opposition to the levy".
The submission also noted independent reports into the levy had highlighted a string of design issues.
