Equivalence Assessment – Australian Primary Production and Processing Standard for Seafood: General Comments on Equivalence of Standard
All products produced under the Animal Products Act regime are subject to significantly greater controls than those proposed in the draft Australian Standard. Principal requirements relevant to seafood under the Animal Products regime are contained in the following legislation and specifications (Abbreviations used in text are in brackets):
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Animal Products Act 1999 (APA)
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Animal Products Regulations 2000 (APR)
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Animal Products (Regulated Control Scheme-Limited Processing Fishing Vessels) Regulations 2001 and specifications (FVRCS)
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Animal Products (Exemptions and Inclusions Order 2000) (APEIO)
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Animal Products (Definition of Primary Processor)Notice 2000 (APDOPP)
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Animal Products (Specifications for Products intended for Human Consumption) Notice 2004 (HC Specs)
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Animal Products (Risk Management Programmes Specifications) Notice 2003 (RMP Specs)
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Meat Act 1981 (To be fully revoked 1 July 2006)
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Fish Export Processing Regulations 1995 pursuant to the Meat Act 1981 (FEPR) (To be revoked 1 July 2006)
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Industry Agreed Implementation Standard 005.1 (IAIS005.1) issued pursuant to the Fish Export Processing Regulations 1995. (To be replaced by the Bivalve Molluscan Shellfish Regulated Control Scheme (BMSRCS) under the APA in 2005)
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Animal Products (Residue Specifications) Notice 2004
New Zealand is nearing the end of a transition phase with premises progressively coming under the ambit of the Animal Products Act 1999. The main products still covered by the superseded Meat Act 1981 and its subordinate legislation are the growing and harvesting of bivalve shellfish which will soon be under a prescribed Regulated Control Scheme under the APA. The shellfish Regulated Control Scheme is proposed to incorporate the previous IAIS requirements and include some new requirements. This scheme will be consulted on later in 2004.
For the purposes of this equivalence assessment the IAIS 005.1 has been considered as the current export shellfish standards as they are currently in force in New Zealand.
The equivalent controls in Australia for exported products only are applied through the Australian Quarantine Inspection Service Export Food Control Orders.
These are not considered further in this equivalence assessment because products exported to New Zealand may be permitted entry without restriction from Australia under the Trans-Tasman Mutual Recognition Agreement (TTMRA) unless risk listed.
The following classes of seafood products are risk listed:
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crustaceans (cooked and raw) including shrimps, prawns and canned product
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molluscs (cooked and raw shell fish) including clams, cockles, mussels, oysters, scallops
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shark and marlin (chilled and frozen)
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tuna (including canned)
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manufactured and minced fish (surimi and marinara mix)
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smoked and smoke flavoured vacuum packed fish
Virtually all primary production of seafood for export is covered under the Animal Products Act regime.
It is not clear to New Zealand how consistent implementation of national standards is undertaken in Australia, partly because each State retains its own primary legislation and regulatory resources are variable for jurisdiction to jurisdiction.
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