Australian Food and Grocery CouncilSUBMISSION

SEPTEMBER, 2012

TO:DEPARTMENT OF AGRICULTURE, FISHERIES AND FORESTRY (DAFF)

IN RESPONSE TO:FIRST PRINCIPLES REVIEW OF THE APVMA’s COST RECOVERY ARRANGEMENTS

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Australian Food and Grocery CouncilPREFACE

The Australian Food and Grocery Council (AFGC) is the leading national organisation representing Australia’s food, drink and grocery manufacturing industry.

The membership of AFGC comprises more than 150 companies, subsidiaries and associates which constitute in the order of 80 per cent of the gross dollar value of the processed food, beverage and grocery products sectors.

With an annual turnover of $108 billion, Australia’s food and grocery manufacturing industry makes a substantial contribution to the Australian economy and is vital to the nation’s future prosperity.

Manufacturing of food, beverages and groceries in the fast moving consumer goods sector1 is Australia’s largest and most important manufacturing industry. Representing 26 per cent of total manufacturing turnover, the sector is the second largest industry behind the Australian mining sector and accounts for over one quarter of the total manufacturing industry in Australia.

This growing and sustainable industry is made up of over 30,100 businesses and accounts for $46 billion of the nation’s international trade. The industry spends $368 million a year on research and development.

The food and grocery manufacturing sector employs more than 312,000 Australians, representing about 3 per cent of all employed people in Australia, paying around $13 billion a year in salaries and wages.

Many food manufacturing plants are located outside the metropolitan regions. The industry makes a large contribution to rural and regional Australia economies, with almost half of the total persons employed being in rural and regional Australia2. It is essential for the economic and social development of Australia, and particularly rural and regional Australia, that the magnitude, significance and contribution of this industry is recognised and factored into the Government’s economic, industrial and trade policies.

Australians and our political leaders overwhelmingly want a local, value-adding food and grocery manufacturing sector.

EXECUTIVE SUMMARY

1 Fast moving consumer goods includes all products bought almost daily by Australians through retail outlets including food, beverages, toiletries, cosmetics, household cleaning items etc.

2 About Australia: www.dfat.gov.au

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Australian Food and Grocery CouncilPREFACE

AFGC supports the Department of Agriculture, Fisheries and Forestry (DAFF) First Principles Review of the APVMA’s Cost Recovery Arrangement to ensure that agencies engaged in cost recovery activities conduct them in an effective and open manner.

AFGC member companies are not direct users of the agvet chemicals managed by the APVMA but are directly impacted downstream by decisions and costs within APVMA.

AFGC supports a comprehensive review of the APVMA’s cost recovery arrangements, in order to increase transparency and effectiveness of cost recovery activities.

The review must consider some fundamental issues with respect to the capacity of the food and grocery industry to support cost recovery arrangements as follows:

Impact of increased costs; Impediments to growth and profitability; Business certainty; and Impact of increasing regulatory burden.

AFGC has identified a number of key issues which must be given priority in the current review and makes the following recommendations:

AFGC note that there are other reviews currently in process that will impact on this review of APVMA cost recovery practices and urge DAFF to ensure that these higher level reviews are considered alongside this review to reduce the potential for overlap and duplication, especially for industry.

The APVMA review must ensure alignment with the Australian Government Cost Recovery Guidelines, recognizing these are currently under review by the Department of Finance and Deregulation.

AFGC urges the government to take action to ensure that cost recovery processes are carried out in a manner that does not introduce further cost burdens to industry or impact on industry’s ability to remain viable and competitive.

AFGC recommend that public funding of some APVMA activities must be given consideration in this review.

The review must include scrutiny of the APVMA’s approach to overall cost management, including measures to reduce spending and improve efficiency.

Innovation is key to industry remaining strong and competitive. Barriers to innovation, such as cost recovery increases are a further burden and disincentive to industry to invest. Cost recovery processes must be clear about the requirement not to “unduly stifle industry innovation.”

The review must include processes for ongoing monitoring of cost recovery arrangements.

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Australian Food and Grocery CouncilPREFACE

AFGC supports the current review and urges the department to take action to ensure that cost recovery processes are carried out in a manner that does not impact on industry’s ability to remain viable and competitive.

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Australian Food and Grocery CouncilSUBMISSION

EXECUTIVE SUMMARY 3

1. INTRODUCTION 5

2. AFGC OVERALL POSITION 5

3. GENERAL COMMENTS 7

4. KEY ISSUES 8

5. SPECIFIC COMMENTS 13

6. CONCLUSION 15

AFGC Member List 16

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Australian Food and Grocery CouncilSUBMISSION

1. INTRODUCTION

The Australian Food and Grocery Council (AFGC) welcome the opportunity to provide a written submission to the Department of Agriculture, Fisheries and Forestry (DAFF) in response to the “First Principles Review of the APVMA’s Cost Recovery Arrangements.”

This submission is in four parts:

1. Overall position and key recommendations;

2. General comment;

3. Key issues identified by AFGC; and

4. Specific comment on the matters raised by the department.

2. AFGC OVERALL POSITION

AFGC supports the principle of cost recovery on the provision that it is justifiable, appropriate and proportionate.

AFGC supports the finding of the 2001 Productivity Commission (PC) review of cost recovery by Commonwealth government agencies, that well-designed cost recovery arrangements could promote economic efficiency and equity by instilling cost-consciousness among agencies and users.

AFGC supports a comprehensive review of the APVMA’s cost recovery arrangements, in order to increase transparency and effectiveness of cost recovery activities.

2.1. Key Recommendations

2.2. Related Reviews

AFGC note that there are other reviews currently in process that will impact on this review of APVMA cost recovery practices:

Better Regulation of Agriculture and Veterinary Chemicals reforms, which seek, among other objectives, to improve the efficiency and function of the APVMA; and

Review of the Australian Government Cost Recovery Guidelines.

AFGC urge DAFF to ensure that these higher level reviews are considered alongside this review to reduce the potential for overlap and duplication, especially for industry.

3. The Australian Government Cost Recovery Guidelines should be followed without exception

AFGC supports the current review of the Australian Government Cost Recovery Guidelines3 to ensure that agencies engaged in cost recovery conduct these activities in an effective and open manner.

3 http://www.finance.gov.au/publications/finance-circulars/2005/09.html#FMG_4

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Australian Food and Grocery CouncilSUBMISSION

AFGC supports a mandate that departments, agencies, statutory authorities and boards responsible for cost recovery processes must adhere to these Guidelines without exception or omission.

The APVMA review must ensure alignment with the Australian Government Cost Recovery Guidelines, recognizing these are currently under review by the Department of Finance and Deregulation.

4. Cost Recovery Impact Statement (CRIS)

The requirement for a CRIS is critical to ensure the impact of cost recovery arrangements are fully explored and evaluated.

Once the CRIS is released, industry must be given adequate time to consider it in the light of this review and outcomes.

5. Industry capacity to support cost recovery

AFGC urges the government to take action to ensure that cost recovery processes are carried out in a manner that does not introduce further cost burdens to industry or impact on industry’s ability to remain viable and competitive.

The first principles review must consider the capacity of the food and grocery industry to support cost recovery – there must be a balance between the charges and the ability of industry to pay without impacting on viability and long term ability to stay in the market.

6. Public Funding of APVMA activities

AFGC supports for a more equitable balance between cost recovery and government funding of APVMA. AFGC recommend that public funding of some APVMA activities must be given consideration in this review.

AFGC encourage DAFF to give consideration to funding of post market activities by government – it is acknowledged that this issue has previously been rejected by government. AFGC suggest that DAFF look to the FSANZ model where there is a significant level of government funding to support industry on the basis that there is an overall ‘societal good’ to do so.

7. Rationale and Process

The review must include scrutiny of the APVMA’s approach to overall cost management, including measures to reduce spending and improve efficiency. AFGC consider that the APVMA must demonstrate improvements in productivity and efficiency – benchmarks need to be set and reported and be held accountable for fiscal management.

8. Support for Innovation

Innovation is key to industry remaining strong and competitive. Barriers to innovation, such as cost recovery increases are a further burden and disincentive to industry to invest.

Cost recovery processes must be clear about the requirement not to “unduly stifle industry innovation.”

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Australian Food and Grocery CouncilSUBMISSION

9. Monitoring and Review

The review must include processes for ongoing monitoring of cost recovery arrangements. This is essential to ensure that the arrangements are appropriate and are not introducing additional, unnecessary burden to affected stakeholders. Monitoring ensure transparency and accountability by the cost recovering agency.

AFGC supports the requirement for periodic review of cost recovery arrangements; however, recommend that consideration be given to the frequency of no less than 5 years. Given the changing nature of the economy and markets, this may not be often enough.

10. GENERAL COMMENTS

10.1. The Current Climate

The past 12 months has seen the further erosion of trading conditions for the food and grocery industry in Australia. Food and grocery manufacturing, in common with other industries has suffered from the effects of the “two-speed” economy with profitability being undermined by rising input costs (raw materials, labour, power) and greater competition from imports as a result of the strong Australian dollar. Weak consumer sentiment has resulted in little or no growth in most major food and grocery categories.

Adding further stress to food and grocery manufacturing has been the aggressive behaviour of the highly concentrated retail sector. The two major supermarkets – Coles and Woolworths – have engaged in a prolonged price war across all major food and grocery categories with concomitant demands for lower prices from suppliers. This has resulted in effective retail price deflation in some categories.

The net result of these extremely adverse trading conditions for food and grocery manufacturing is:

plant closures with loss of jobs; movement of some production lines offshore; company restructuring with loss of jobs; and reduced investment in innovation and new plant.

Overall industry productivity is being undermined at a time when Australia needs to improve the productivity of major sectors of its economy. Food manufacturing is shifting to off-shore facilities threatening greater imports and fewer exports. If the pace of the current decline in manufacturing continues unabated, up to 120,000 jobs threaten to be lost from the industry by 2020, many from rural and regional Australia.

10.2. The Food and Grocery Industry – Cost Recovery

AFGC member companies are directly and indirectly impacted by the following agencies cost recovery activities:

FSANZ – partially cost recovered; NICNAS – fully cost recovered; TGA – fully cost recovered; APVMA – fully cost recovered; Biosecurity (AQIS Export / Import Audits) - transition to full cost recovery; and

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Australian Food and Grocery CouncilSUBMISSION

National Measurement Institute (NMI) – cost recovery for a limited range of services.

11.APVMA

AFGC member companies are not direct users of the agvet chemicals managed by the APVMA but are directly impacted downstream by decisions and costs within APVMA.

Any increased costs associated with reforms of agvet chemical regulation and cost recovery arrangements will be passed on to chemical users including those in industries that provide the ingredients that go into food products. This means that, the food industry has an important stake in ensuring cost recovery arrangements are not overly burdensome, and that costs are kept as low as possible.

AFGC has previously made a submission to DAFF on the Exposure Draft - Agriculture and Veterinary Chemicals Legislation Amendment Bill 20114 in which we did address some issues related to cost recovery.

Specifically, AFGC expressed concerned that increased costs associated with some of the proposals will be passed on to agvet chemical users and will, in turn, increase costs to food manufacturers. A direct cost impact at the front end of the food supply chain will have a flow on effect to food manufacturers as producers attempt to pass on these additional costs up the supply chain.

12. KEY ISSUES

AFGC has recently made submissions on cost recovery to:

Food Standards Australia New Zealand (FSANZ) in relation to “Cost Recovery Arrangements for Applications”5; and

The Department of Finance and Regulation in relation to the “Review of the Australian Government Cost Recovery Guidelines”.6

In these submissions, AFGC identified the following key issues which we consider are highly relevant for consideration with respect to this current review by DAFF:

The Australian Government Cost Recovery Guidelines should be followed without exception; Conduct of Cost Recovery Impact Statements (CRIS); Capacity of industry to support cost recovery; Cost Recovery – rationale and process; Support for innovation; Monitoring and review; and Impact on trade.

4 http://www.afgc.org.au/tools-guides-.html#submissions

5 Copy of submission available on request from the AFGC secretariat6 Copy of submission available on request from the AFGC secretariat.

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Australian Food and Grocery CouncilSUBMISSION

12.1. Australian Government Cost Recovery Guidelines

It must be a fundamental requirement of any departments, agencies, statutory authorities and boards responsible for cost recovery processes that they must adhere to these Guidelines without exception or omission. It is the experience of the AFGC that this is not always the practice.

AFGC strongly support alignment of cost recovery arrangements for the APVMA with the Australian Government Cost Recovery Guidelines. Failure to do so will introduce unnecessary complexities and burdens which will impact industry.

Recommendation:

Cost recovery arrangements for the APVMA must align with the requirements of the Australian Government Cost Recovery Guidelines.

12.2. Cost Recovery Impact Statement (CRIS)

The Guidelines require that (amongst other requirements):

“All agencies with significant cost recovery arrangements will need to prepare Cost Recovery Impact Statements (CRIS). A CRIS will not be required where a Regulation Impact Statement (RIS) that also addresses cost recovery arrangements against these guidelines has been prepared.”

The requirement for a CRIS is critical to ensure the impact of cost recovery arrangements are fully explored and evaluated.

AFGC consider they should be mandatory with no option not to conduct (at least a very basic) assessment.

AFGC note that the APVMA advised the following in relation to the Consultation Response: Cost Recovery Discussion Paper:

A Cost Recovery Impact Statement (CRIS) will be published by the APVMA once approved by the Minister for Agriculture, Fisheries and Forestry. The publication of the CRIS is dependent on the passage of the exposure draft of the Agricultural and Veterinary Chemicals Amendment Bill 2011 through the Australian Parliament.7

AFGC note that the CRIS is yet to be released.

Recommendation:

Once the CRIS is released, industry must be given adequate time to consider it in the light of this review and outcomes.

7 http://www.apvma.gov.au/consultation/public/2012/interim_cost_recovery_report.php

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Australian Food and Grocery CouncilSUBMISSION

12.3. Capacity of Industry to support cost recovery

In the current economic environment, any increase in the costs applied to manufacturers’ places additional burden on industry. This is exacerbated in the current global financial environment, where economic growth is extremely low and where, in the best case, many businesses are struggling to remain competitive and, in the worst case, many are struggling for survival.

The review must consider some fundamental issues with respect to the capacity of the food and grocery industry to support cost recovery arrangements as follows:

Impact of increased costs; Impediments to growth and profitability and business certainty; and Impact of increasing regulatory burden.

13. Impact of increased costs

The review must address inefficiencies and costs in the current system, resulting in Australian manufacturers and suppliers being disadvantaged. This will, in turn, directly impact on the sustainability of Australian food and grocery manufacturers and suppliers through increased costs and lack of innovation.

Currently the international competitiveness of the Australian manufacturing sector is under pressure due to:

rising input costs – raw materials, energy, transport costs are all going up; exchange rate effects – the high Australian dollar makes manufacturers less competitive against

imports in the domestic market and competition in export markets; regulatory compliance costs; and retail sector concentration.

With respect to regulatory compliance costs – food and grocery manufacturers are faced with a slowly increasing regulatory burden. Compliance cost with government regulations at State and Territory, and Commonwealth level are high. These include food and grocery standards and regulations, environmental regulations, planning regulations, occupational health and safety and workplace relations requirements. The lack of uniformity across the Commonwealth, State and Territory jurisdictions is a problem in itself, as are the tortuous processes for changing regulations once they are in place. The importance of reducing this regulatory burden has been recognised by Government and action has been taken through the Council of Australian Government’s (COAG) regulatory reform agenda under the National Partnership to Deliver a Seamless National Economy. 8 AFGC considers there remains considerable scope for further regulatory reform in the food and grocery industry.

These factors combine to erode margins and reduce profitability thereby compromising long term competitiveness. The overall effect is a decline in margins and the profitability of the industry, limiting funds available (including from raising debt) for investment and reinvestment in new plant and new process i.e. in innovation. This limits the growth in productivity, i.e. becoming more efficient and effective, necessary to remain competitive in international markets.

The ultimate result is that the business case for companies to invest and re-invest in manufacturing in Australia is severely compromised. This leads to reduced levels of innovation, loss of competiveness and business closures or relocation offshore.

8 http://www.coagreformcouncil.gov.au/agenda/index.cfm

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Australian Food and Grocery CouncilSUBMISSION

AFGC seeks assurance this review will consider the impact of any changes with respect to the capacity of the food and grocery industry to support cost recovery arrangements and ensure they do not introduce further cost burdens to industry.

Recommendation

AFGC urges the government to take action to ensure that cost recovery processes are carried out in a manner that does not introduce further cost burdens to industry or impact on industry’s ability to remain viable and competitive.

14. Impediments to growth and profitability – business certainty

The current uncertain times are derived, to some extent, from the unprecedented events in financial markets and the lack of consensus regarding their implications in the longer term. This is unsettling for business considering investment options.

Against this backdrop, certainty in Government regarding their policies and programs is crucial. Certainty around the cost to do business, which is impacted by cost recovery arrangements, is critical to business planning over the long term.

15. Impact of increasing regulatory burden – Cost Benefit Analysis

There are many overlaps in responsibilities for regulators and enforcement agencies across Australia. This results in National, State and Territory and Local Governments with various regulatory responsibilities, and with this comes the “turf wars” between jurisdictions for influence over different sectors. This has been recognised to some degree through mutual recognition agreements allowing various arms of government to not require cost recovery activities for exactly the same functions. The various layers of government and the various cost recovery requirements remain particularly frustrating and difficult for industry to deal with. For large national companies operating across Australia and in a large number of local governments, the differences in approach and levels of cost recovery can be significant and bewildering.

15.1. Cost Recovery – Rationale and Process

The rational for cost recovery is that there must be some significant element of commercial benefit to the trading company in having government support, inspection or certification above and beyond the community benefit provided through government intervention, regulation and control of the marketplace. Cost recovery must be limited to that portion of the cost of government directly associated with a commercial benefit to the business, while government bears the costs of the ‘societal good’.

Cost recovery is seen as a ‘user-pays’ system where the needs of industry are met through a cost recovery process reducing the burden on the ‘public purse’ for a service that is largely for commercial gain. This in turn fosters a culture of external funding dependence to supplement budgetary shortfalls and cost-shifting from government to industry.

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Australian Food and Grocery CouncilSUBMISSION

16.Agency accountability for fiscal management

AFGC support the requirement for cost estimates to be based, wherever possible, on the efficient costs, not actual costs. Agencies must be held to account to adhere to the requirement for “minimum cost necessary”.

17.Magnitude and Timing of Cost Recovery

Where changes are made to cost recovery arrangements there must be a balance between the charges and the ability of industry to pay without impacting on viability and long term ability to stay in the market. Companies must be given adequate notice of any increase to fit in with budget planning cycles.

18.Transparency

The information on which cost recovery decisions are based should be publicly available and adequate time permitted for consultation with stakeholders built into the process, taking into account the time and resources required by stakeholders to assess the impacts of changes proposed.

Industry requires access to financial and operational data to ensure that cost recovered funds are being used in an appropriate manner by the agency.

18.1. Support for Innovation

Innovation underpinned by research and development (R&D) is a critical element in maintaining industry productivity growth, company profitability and therefore competitiveness. The food industry is no exception to this rule with investment in R&D by food companies generally running between 1-2% of sales.

In the current economic climate (previously discussed), innovation is key to industry remaining strong and competitive. Barriers to innovation are a further burden and disincentive to industry to invest.

Australian companies are the ones who suffer the most from unnecessary delays and costs in the system with inefficiencies slowing the introduction of innovative new products. This in turn impacts on Australian companies through increased costs or reduced capacity to innovate.

AFGC is concerned that a failure to implement effective cost recovery reforms will result in loss of existing products and discourage and delay introduction of new products for the following reasons:

Excessive and unnecessary cost burden reduces incentive for innovation by industry, with negative consequences for investment in new products;

Greater costs will remove products that have small markets.

The pressures of performance and increasing competition will continue to compel all manufacturers to improve the effectiveness of investment in innovation. Excessive and unnecessary cost reduces incentive for innovation by industry, with negative consequences for investment in new products. More importantly, Australian consumers are missing out on the innovation that other developed economies enjoy.

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Australian Food and Grocery CouncilSUBMISSION

18.2. Monitoring and Review

AFGC supports the requirement for ongoing monitoring of cost recovery arrangements. This is essential to ensure that the arrangements are appropriate and are not introducing additional, unnecessary burden to affected stakeholders.

AFGC supports the requirement for periodic review of cost recovery arrangements; however, recommend that consideration be given to the frequency of no less than 5 years. Given the changing nature of the economy and markets, this may not be often enough.

18.3. Impact on Trade

There is substantial international trade in processed food products and Australia imports food and grocery products from all over the world. Australia also exports processed food products to many countries around the world. It is clear therefore, that in common with food manufacturing industry around the world, Australia’s enjoys significant international trade in food and beverage products.

Reform which impacts on the food and grocery industry must include formal assessment of trade implications.

19. SPECIFIC COMMENTS

AFGC has reviewed the objectives, scope and expected outcomes of the review and provides the following comments for consideration.

19.1. Objectives and Scope

The comprehensive first-principles review of the cost recovery arrangements for the Australian Pesticides and Veterinary Medicines Authority (APVMA) will examine and recommend options to strengthen the financial sustainability, transparency and accountability of the APVMA’s cost recovery arrangements.

AFGC support this and urge DAFF to ensure that the review is aligned with the current review of the Australian Government Cost Recovery Guidelines.

The review is focused on the structure of the APVMA’s cost recovery framework. The review does not include consideration of the scope and level of the APVMA’s regulatory activities.

AFGC encourage DAFF to give consideration to funding of post market activities by government – it is acknowledged that this issue has previously been rejected by government. AFGC suggest that DAFF look to the FSANZ model where there is a significant level of government funding to support industry on the basis that there is an overall ‘societal good’ to do so.

AFGC consider that the APVMA must demonstrate improvements in productivity and efficiency – benchmarks need to be set and reported and be held accountable for fiscal management.

19.2. Expected Review Outcomes

A cost recovery approach that covers the cost of all APVMA regulatory obligations and services

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Australian Food and Grocery CouncilSUBMISSION

An evaluation of the alternative cost recovery arrangements that could be adopted by the APVMA, including an assessment of their advantages, disadvantages and compliance with Government’s policy and guidelines on cost recovery, such as:

AFGC support this and urge DAFF to ensure that the review is aligned with the current review of the Australian Government Cost Recovery Guidelines.

AFGC advocates for a more equitable balance between cost recovery and government funding:

Consideration of funding of “public good” activities – these should be budget funded by the taxpayer and not industry.

Industry should not fund reform and therefore the costs associated with the APVMA’s reform agenda should be funded by government.

All elements of public interest and industry assistance should be tax payer funded.

Industry funding should only seek to recover funds directly attributable to APVMA activity in connection with the registration of products. Compliance, adverse experience reporting and chemical review programs designed to confirm the integrity of the regulatory systems should be funded by the government.

Cost recovery should not exceed CPI and should not be used to “over recover” cost of underfunded activities.

Fees should be capped at the top end.

Efficiency – cost recovery acts as an important mechanism to ensure the efficient delivery and consumption of government activities and services.

AFGC comment - agree

Development of draft funding/cost recovery proposal that can be released for public consultation.

AFGC comment – must be open and transparent and sufficient time allowed for input and feedback.

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Australian Food and Grocery CouncilSUBMISSION

20. CONCLUSION

The food and grocery manufacturing sector is Australia’s largest manufacturing sector. As such it, expects Government to be mindful of, and responsive to, the changing dynamics and the potential impacts on the industry – particularly in the context of Government’s overall policy agenda which should be to ensure Australians continue to have access to safe and affordable food and grocery products, manufactured by a competitive and wealth generating industry.

AFGC supports the current review and urges DAFF to take action to ensure that cost recovery processes are carried out in a manner that does not impact on industry’s ability to remain viable and competitive.

AFGC stands ready to provide further input into the review and would welcome the opportunity to meet with representatives of DAFF to discuss this submission further.

Level 2, Salvation Army House2–4 Brisbane AvenueBarton ACT 2600

Locked Bag 1Kingston ACT 2604

T: (02) 6273 1466F: (02) 6273 1477afgc@afgc.org.auwww.afgc.org.au

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1. AFGC MEMBER LIST

(as at 23 August 2012)

Full Members

• Arnott's Biscuits Ltd• Australian Blending Company Pty

Ltd• Barilla Australia Pty Ltd• Beak and Johnston Pty Ltd• Beechworth Honey Pty Ltd• Beerenberg Pty Ltd• Bickfords Australia Pty Ltd• Birch and Waite Foods Pty Ltd• Body Science International Pty Ltd• Bronte Industries Pty Ltd• Bulla Dairy Foods• Bundaberg Brewed Drinks Pty Ltd• Bundaberg Sugar Ltd• Byford Flour Mills/Millers Foods• Byron Food Science• Campbell's Soup Australia• Canon Foods• Cantarella Bros Pty Ltd• Carman's Fine Foods• Cerebos (Aust) Ltd• Cheetham Salt Limited• Christie Tea Pty Ltd• Church & Dwight (Australia) Pty Ltd• Clorox Australia Pty Ltd• Coca-Cola Amatil Ltd• Coca-Cola South Pacific Pty Ltd• Colgate-Palmolive Pty Ltd• Coopers Brewery Ltd• D.E Coffee & Tea Retail

Australia/Sara Lee Coffee & Tea Retail Australia

• Danisco Australia Pty Ltd• Devro Pty Ltd• DSM Food Specialties Australia Pty

Ltd• Eagle Boys Pizza• Earlee Products Pty Ltd• Ferrero Australia Pty Ltd• Fibrisol Service Australia Pty Ltd• Fonterra Australia Pty Ltd• Food Spectrum Group• FPM Cereal Milling Systems Pty Ltd• Freedom Foods Group• Frucor Beverages (Australia) Pty Ltd• General Mills Australia Pty Ltd• George Weston Foods Ltd• GlaxoSmithKline Consumer

Healthcare• Go Natural• Goodman Fielder Limited• H.J. Heinz Company Australia

Limited• Harvest FreshCuts Pty Ltd• Healthy Snacks Australia Pty Ltd• Hoyt Food Manufacturing Industries

Pty Ltd• Hungry Jack's Australia• Igea Group• Jalna Dairy Foods Pty Ltd

• JBS Australia Pty Limited• Jireh International Pty Ltd• Johnson & Johnson Pacific Pty Ltd• Kellogg (Aust) Pty Ltd• Kerry Ingredients Australia Pty Ltd• Kimberly-Clark Australia Pty Ltd• Kitchens of Sara Lee• Kraft Foods Limited• Laucke Flour Mills Pty Ltd• Lindt & Sprungli Australia• Lion Dairy and Drinks Pty Ltd• Madura Tea Estates• Manildra Harwood Sugars• Mars Chocolate• McCain Foods (Aust) Pty Ltd• McCormick Foods Australia Pty Ltd• McDonald's Australia Ltd• Merisant Australia Pty Ltd• Metarom Australia P/L• Mrs Mac's Pty Ltd• Murray Goulburn Co-operative Co

Ltd• Myosyn Industries Pty Ltd• Nerada Tea Pty Ltd• Nestle Australia Ltd• Nutricia Australia Pty Ltd• Ocean Spray International, Inc• Only Organic 2003 Pty Limited• Parmalat Australia Ltd• Patties Foods Ltd• Pfizer Consumer Healthcare• Popina (Vic) Pty Ltd• Procter & Gamble Australia Pty Ltd• QSR Holdings• Queen Fine Foods Pty Ltd• Reckitt Benckiser (Australia) Pty Ltd• Red Bull Australia Pty Limited• Rosella Foods Pty Ltd• Sandhurst Fine Foods Australia• Sanitarium Health and Wellbeing

Company• SC Johnson & Son Pty Ltd• SCA Hygiene Australasia Pty Ltd• Schweppes Australia Pty Ltd• Sensient Technologies (Australia)

Pty Ltd• Simplot Australia Pty Ltd• Solaris Paper Pty Ltd• Spicemasters Australia Pty Ltd• Steric Pty Ltd• Stuart Alexander & Co Pty Ltd• Subway Franchisee Advertising

Fund Australia/NZ• Sugar Australia Pty Ltd• SunRice• Swisse Vitamins Pty Ltd• Tasmanian Flour Mills Pty Ltd• Tate & Lyle ANZ Pty Ltd• The Smith's Snackfood Company• The Vege Chip Company• The Wrigley Company Pty Limited• Tixana Pty Limited• Unilever Australasia• Vital Health Foods (Australia) Pty

Ltd• Ward McKenzie Pty Ltd• Yakult Australia Pty Ltd• Yum! Restaurants Australia Pty Ltd

Associate Members

• A.T. Kearney Pty Ltd• ACI Operations Pty Ltd• Addisons• Allens Arthur Robinson• Amcor Australasia• Australian Pork Limited• Baker & McKenzie• Benchmarking for

Performance(B4P)• Bizcaps Pty Ltd• Brisbane Marketing• CHEP Asia - Pacific• CROSSMARK Asia Pacific• CSIRO Food and Nutritional

Sciences• Dairy Australia• Ettlin International Pty Ltd• Food Allergen Control Training

Analysis (FACTa)• Food Liaison Pty Ltd• Foodbank Australia Ltd• Grain Growers Ltd• Grant Thornton• GS1 Australia Ltd• Harris Smith• IBM Australia Ltd• innovations & solutions• Investment Attraction/trade and

Investment Queensland• King & Wood Mallesons• KPMG• Legal Finesse• Linfox Australia Pty Ltd• Logan City Council• Meat and Livestock Australia• Monsanto Australia Ltd• New Zealand Trade and Enterprise• Pacific Strategy Partners• Red Rock Consulting• Rentokil Initial Pty Ltd (Rentokil Pest

Control)• RQA Product Risk Institute• Simons Green Energy Pty Ltd• Six Degrees Executive Pty Ltd• Spectrum Automation• StayinFront Group Australia• Strikeforce Alliance Pty Ltd• Swire Cold Storage• Swisslog Australia Pty Ltd• Tetra Pak Marketing Pty Ltd• The Food Group Australia• The Nielsen Company• Touchstone Consulting Australia Pty

Ltd• Visy Pak• Wiley & Co Pty Ltd

Affiliate Members

• Australian Self-Medication Industry• Baking Associations Australia• CropLife Australia Limited• Food & Beverage Importers

Association• Food Industry Association Qld Inc• Food Q Inc• Foodservice Suppliers Association

of Australia• Grains & Legumes Nutrition Council• Private Label Manufacturers

Association Australia/New Zealand