Import News from the Importers Institute
3 September 1999 - Border Review Submission
The government is conducting a review of Border Control. This is our submission to the review:
We agree that there should be a "whole-of-government" approach to border protection. There is a need to clearly separate
the functions of (1) policy formulation, (2) risk assessment, and (3) service delivery.
Policy should continue to be formulated in policy departments. For example, the Ministry of Commerce should continue to
have responsibility for tariff policy and MAF for biosecurity.
Risk-assessment should be science-based and independent from both policy formulation and service delivery. This function
should be delivered by a body of scientific experts and industry representatives, constituted as an advisory board to
the Minister of Border Control.
Service should be delivered by a new structure, essentially merging Customs with the border control functions of MAF. We
do not believe that it will be possible to achieve the objective of a "whole-of-government" approach without structural
The technical architecture for a service delivery agency would need to be redeveloped (the "green fields" option).
CusMod has the potential to become the core of a new system, but it is currently far from capable of meeting those
The Customs Service does not have the technical ability to develop such a system, at present. On the other hand, MAF has
considerably higher expertise in Internet development. Only structural integration will achieve the benefits of merging
those two core competencies.
Any decision to establish a new service delivery agency should be subject to a rigorous cost / benefit analysis. Such an
agency should not be established unless it is possible to demonstrate a net tangible national benefit. Only then should
the government reconsider proposals for user-pays funding for border services.