Draft Cost Recovery Implementation Statements 2026-27
Download the PDF for the PGA’s complete analysis and recommendations to DAFF.
PGA submission - Draft Cost Recovery Implementation Statements 2026-27
PGA Submission
The PGA has lodged a submission strongly opposing the federal department’s proposed cost recovery model for agricultural export services. The position is unambiguous: the proposal is a rushed, poorly justified cost-shift that threatens the viability of Australian farm businesses and must be paused.
Submission Aim
The submission takes aim at five specific failures. First, the department has provided no evidence that its costs represent the “minimum efficient cost” of service delivery, a foundational requirement of any legitimate cost recovery framework.
Instead, the proposal focuses entirely on expanding revenue to cover growing expenditure, including a significant projected increase in departmental headcount, with no independent efficiency review.
Second, a 36-day consultation window was wholly inadequate for industry to analyse hundreds of pages of complex documents and model the financial impact on individual businesses.
The scale of the proposed increases is striking. Live animal export charges alone are proposed to rise from $12.8 million to $21.9 million, a near-doubling, on top of a 48% rise in meat sector charges over the preceding five years. No economic impact modelling was conducted. The submission also challenges the proposal to cost-recover market access activities, arguing that growing technical market access is a public good that underpins Australia’s entire export economy, not a service that should be billed to industry.
The PGA calls for an independent audit of departmental costs before any new fees are set, and urges the government to redirect its transition fund toward genuine efficiency improvements rather than temporarily masking a fee hike.
Read the full notice
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