An accredited property is a property approved by the department to carry out particular export operations for particular goods and, where relevant, for particular export markets. Accreditation provides assurance that activities carried out at the property meet applicable regulatory and importing country requirements. The accreditation will specify the export operations, products and destination markets it covers.
Accreditation may cover preparing goods prior to export including manufacturing, processing, packing, storing or handling.
For general products, accredited properties will be required where an importing country requires Australian Government assurance or oversight of the property where specified export activities occur, beyond the assurance provided through an export licence or government certificate.
When is property accreditation required
Accreditation of a property may be required where the importing country has specific requirements relating to the preparation of general products for export including manufacturing or processing, packing, storing and handling. The criteria for accreditation will depend on the relevant importing country requirements.
Reasons for the change
Under the existing non-prescribed goods administrative arrangements, some establishments are ‘listed’ where importing countries require government oversight or approval. Under the proposed general products framework, existing establishment listings will be replaced by accredited properties. This will place the current listing arrangements within a clearer legislative framework under the Export Control Act 2020 and the proposed Export Control (General Products) Rules.
The change is intended to provide government oversight of relevant properties and processes without requiring all premises involved in an export supply chain to be regulated in the same way. Accredited properties are proposed as a targeted regulatory tool linked to particular premises and specified export operations. This allows risks arising at property level, which may affect multiple exporters, consignments or broader market access, to be managed through appropriate government oversight.
In practice:
- existing listed establishments will need to transition to accredited properties
- new properties will need to apply where accreditation is required for their products, export operations and export markets
- exporters may source goods from an appropriately accredited property operated by another business, where a requirement for accreditation exists.
Properties that need accreditation
Not every property involved in preparing general products for export will require accreditation. Accreditation will be required only where the property, or an export operation undertaken at the property, requires Australian Government oversight in order to meet an import country requirement. Criteria to become accredited will depend on the assurance the Australian Government is required to provide to the importing country authority about each product and export operation.
The department is developing a list of the specific product, export operation and market combinations for which accreditation will be required. This list is expected to be published on the department’s website, with relevant information also available through the Manual of Importing Country Requirements (Micor).
Exporters will remain responsible for confirming the requirements applying to their goods and markets. Where accreditation is required, they will need to confirm that the relevant export operations were undertaken at a property with the appropriate scope of accreditation.
Scope of accreditation
An accredited property approval will specify the property, export operations, products and destination markets it covers. Accredited properties will not be linked to exporters or export licences. Where accreditation is required, the exporter is responsible for ensuring that the products they export have come from an appropriate accredited property.
Using an accredited property when exporting
Before exporting, confirm whether the goods require any manufacturing or processing, packing, storage and handling activity to occur at an accredited property. If so, the exporter will need to ensure the goods meet this requirement. The accreditation will need to be held by the manager of the property where the relevant export operation is conducted; this may or may not be the same person or entity as the exporter.
Using an accredited property does not, in itself, demonstrate that a consignment meets all importing country requirements. Exporters must also hold a valid export licence and obtain any required government certificate.
Comparison with other regulatory controls
| Regulatory control | What it does | When it applies |
|---|---|---|
| Accredited property | Provides assurance for specified export operations at a property, covering particular products and destination markets. | Where property-level government oversight is required to meet importing country requirements. |
| Export licence | Authorises a person or an entity to export prescribed general products and establishes exporter accountability. | For all exporters of prescribed general products. |
| Government certificate | Provides official assurance for a particular consignment, particular consignments or certification request. | Where required by an importing country or requested for market access purposes. |
These controls are separate. Operating or sourcing goods from an accredited property does not remove the exporter’s obligation to hold an export licence or obtain a government certificate where either is required.
Why accredited properties are proposed instead of registered establishments
Registered establishments are an established regulatory mechanism under the Export Control Act 2020. The legislative requirements applying to registered establishments are more extensive than those proposed for accredited properties. For general products, property-level oversight is expected to be required only for particular combinations of products, export operations and destination markets. Applying the registered establishment model could create a greater administrative and compliance burden than is needed for these export pathways.
The accredited property model is intended to provide a more targeted and proportionate mechanism. It allows the department to approve a property for the specific export operations, products and markets for which assurance is required, while maintaining appropriate regulatory oversight. This does not reduce the assurance provided to importing countries; it aligns the regulatory control with the scope and level of assurance required for the relevant export pathway.
If a property is already a registered establishment for another export commodity, that registration will not be affected by the introduction of regulation for general products. If an accredited property is required for general products prepared or produced at the same location, the two approvals would operate alongside each other.
Where possible and appropriate, the department would seek to use existing information and assurance evidence to streamline application processes and avoid unnecessary duplication, subject to final transition guidance.
Proposed commencement and transition
Applications are proposed to open through TradeClear from 1 July 2027. Managers of existing listed establishments will need to apply when their annual continuation of listing is due, or no later than four months before accreditation becomes mandatory on 1 July 2028.
These dates and transition arrangements remain subject to final policy, legislative and implementation decisions.
Proposed accreditation categories
Accredited property requirements are proposed to be grouped into Simple, Moderate and Complex categories to aid in setting appropriate charging. The categories reflect the different regulatory effort associated with the processes or evidence required to satisfy importing country requirements for the given products and export operations. It is intended to publish the complexity of each requirement on a list on the department’s website.
| Category | When it would apply | Typical assessment |
|---|---|---|
| Simple | Government oversight is required, but no detailed market-specific assessment or separate importing country approval is needed. | The department confirms the property details, management, scope and appropriate systems and controls. |
| Moderate | The department must assess detailed evidence against specific importing country requirements. A separate foreign approval would not ordinarily be required. | The department may assess checklists, audit reports, technical evidence and non-compliance reports. |
| Complex | The importing country authority must assess, approve or accept the property. | The department assesses and verifies the Australian submission, and coordinates with the importing country authority. The foreign approval process and timing remain outside the department’s control. |
Apply for accreditation
- Set up access to TradeClear. Manual forms will be available for businesses that cannot access the portal.
- Complete the application with details of the applicant, property, management and control, any overdue departmental fees or charges and repayment plans, fit and proper person information, proposed products, export operations and destination markets, and supporting evidence and declarations.
- The department will assess the application against regulatory and importing country requirements and may request further information. If approved, the accreditation will state the products, export operations and destination markets covered.
Accreditation period, renewal and variations
Under the current proposal, accreditation would be granted for three years. The accreditation period remains subject to final policy and legislative decisions. The accredited property manager will need to apply to renew the accreditation before it expires. If there are relevant changes to the property’s operations, products or export markets, the accredited property manager may need to apply to vary the accreditation before undertaking activities outside the approved scope.
Ongoing responsibilities of accredited property managers
While an accredited property is in force, the property manager will need to:
- meet accreditation conditions and maintain accurate records
- participate in audits or verification activities as required, and address any non-compliance reports
- notify the department of relevant changes and keep business and contact details current.
Where properties currently undergo audits by third party auditors engaged by industry bodies or other third-party auditors, these arrangements will not change. In some cases, the industry body will hold an approved arrangement with the department, formalising how these results may be used as evidence to support properties in gaining and maintaining accreditation. Managers of properties will not need to hold approved arrangements themselves.
The department remains responsible for assessing the information needed to grant and maintain accreditation, deciding whether requirements are met, and providing appropriate oversight, verification and compliance activities.
Assurance requirements
Existing assurance requirements for listed establishments are expected to inform the transition to accredited properties. Where a property currently undergoes an annual audit by an industry body or the department, that audit evidence may continue to be used where it remains relevant and is accepted by the department. The department will still assess the information needed to grant and maintain accreditation and decide whether further assurance activity is required.
The frequency and scope of assurance processes would be based on importing country requirements, the products and export operations covered, the accreditation category, the property’s compliance history and other relevant risks. Frequency may vary between properties and may change if requirements, export operations, products or risk settings change. For a property handling multiple products or commodities, the department would seek to coordinate assurance activity where practical while ensuring that each applicable regulatory and importing country requirement is addressed.
Audits may be undertaken by the department or by a third-party auditor engaged by the industry body under the approved arrangement where appropriate. The department will determine the appropriate audit pathway for each property.
Non-compliance and regulatory action
The department will take a proportionate and escalating approach to non-compliance that considers mitigating and aggravating factors. Depending on the circumstances, the department may consider education or guidance, additional conditions, increased monitoring, refusal or revocation of a government certificate, variation, suspension or revocation of an export licence, and civil or criminal enforcement action for serious breaches.
Regulatory action may be required if the manager has failed to meet accreditation conditions or importing country requirements, supplied false or misleading information, failed to pay relevant fees and charges, or failed to address non-compliance reports.
In these cases, additional conditions may be placed on the accreditation, or it may be varied, suspended or revoked if appropriate.
Key risks managed through accreditation
The accredited property framework is intended to manage risks that can extend beyond an individual exporter or consignment. A failure at property level could affect multiple exporters, consignments and broader market access. Accreditation supports:
- appropriate controls for manufacturing or processing, packing, storing and handling
- accurate records, traceability and evidence for export assurance
- compliance with accreditation conditions and importing country requirements
- management of importing country approvals and property eligibility
- consistent government oversight and regulatory action where required.
Practical steps
For exporters
- Check whether any export operations related to the product require an accredited property for the intended destination.
- Identify the properties where the relevant export operations occur.
- Confirm each required property is accredited for the relevant product, export operation and destination market.
- If the property is not appropriately accredited, contact the property manager. It is the manager’s responsibility to apply for, maintain and vary accreditation.
- Continue to monitor and follow departmental guidance as it is released.
For property managers
- Identify the products, export operations and destination markets that accreditation needs to cover.
- Ensure you satisfy the relevant requirements.
- Apply to accredit your property, or vary your existing accreditation, through TradeClear. If you cannot access TradeClear, a manual process is available.
- Complete assurance activities as required, and address any non-compliance reports.
- If approved, seek a variation before undertaking activities outside the approved scope. Ensure all necessary records are kept.
- Renew your accreditation when prompted to avoid trade interruptions.
- Continue to monitor and follow departmental guidance as it is released.