2019-07 - Invoicing policy for Independent Observer charges where multiple exporters share the same vessel

13 August 2019


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Export Advisory Notice 2019-07 PDF  4 1.5 MB

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Species: All livestock

Country: All

For information:

  1. Livestock exporters
  2. ALEC


To inform all livestock exporters of the revised invoicing policy for Independent Observer (IO) services where multiple exporters share the same vessel.

Key points

  • To address industry feedback, the department has been investigating alternative charging options that would deliver an equitable split of costs for IO services.
  • Invoices for voyages with multiple exporters have not been issued for voyages since late December 2018, pending a decision regarding the implementation of a revised charging regime.
  • Prior to late December 2018, charges for IO services have been attributed equally to exporters sharing a vessel, regardless of the number of livestock exported by each exporter.
  • The department has amended the policy, so daily charges are split based on the number of livestock exported by each exporter which will be expressed as a percentage. These charges take into consideration audit activities undertaken throughout the voyage and any additional chargeable time prior to departure from Australia and post discharge overseas.
  • Costs associated with return international flights will continue to be split equally amongst the exporters irrespective of the size of their consignments.
  • The department has developed a scenario to help exporters understand the application of the new charging regime. (Attachment 1)
  • All completed voyages will be issued with an invoice consistent with this revised policy.


The IO program was introduced in 2018. Costs incurred by the department in placing an IO on board sea voyages are recoverable in accordance with section 1A.52 of the Export Control (Animals) Order 2004. The cost recovery component of the IO Program was implemented in October 2018. Export Advisory Notice (EAN) 2018-10 (Attachment 2) outlines the standard fees for each voyage, as set out in the Export Control (Fees) Orders 2015.

Sanjay Boothalingam
Live Animal Exports Division
Department of Agriculture

Attachment 1


Independent Observer on a voyage with 3 exporters

A voyage bound for Kuwait and Qatar is set to depart Fremantle on Thursday 25 April 2019. The departure is delayed by one day and the vessel departed on Friday 26 April, with 3 exporters utilising the vessel.

Exporter 1 has 1,223 cattle (22.5% of total load) discharging in Kuwait. Exporter 2 has 3,617 cattle (66.5% of total load) discharging in Kuwait. Exporter 3 has 599 cattle (11% of total load) discharging in Qatar.

The vessel arrived in port in Kuwait on Thursday 9 May and exporters 1 and 2 had consignments complete discharge in Kuwait on Friday 10 May.

The consignment belonging to Exporter number 3 continued to Qatar and arrived in port on Sunday 12 May at 5:00am. Discharge was completed at 3:00pm on Monday 13 May.

The IO provides the standard 7 ½ hour audit service each day. The IO also obtains audit support from Australia on a daily basis.

The IO departed for Fremantle on the next available flight at midday on Wednesday 15 May and arrived in Fremantle on Thursday 16 May.

25 April – 16 May
Fremantle to Qatar (via Kuwait)

Exporter 1, 2 and 3

22 days total – including travel time to return to Australia


Weekend days

Public Holiday

IO Support Weekdays

IO Support Weekends

IO Support Public Holidays

15 days x $ 1,290

6 days x $ 1,890

1 day x $ 1,890

12 days x $ 43

6 days x $ 126

1 day x $ 126

Sub Total 1

$ 19,350

$ 11,340

$ 1,890

$ 516

$ 756

$ 126

$ 33,978


International return flight

$ 5,250 divided by 3

Sub Total 2


$ 1,750

Exporter 1 with 22.5%

Sub Total 1  x 22.5%

Sub Total 2

$ 7,645.05

$ 1,750




$ 9,395.05

Exporter 2 with 66.5%

Sub Total 1  x 66.5%

Sub Total 2

$ 22,595.37

$ 1,750




$ 24,345.37

Exporter 3 with 11%

Sub Total 1  x 11%

Sub Total 2

$ 3,737.58

$ 1,750




$ 5,487.58



Total invoice for voyage

$ 39,228

Attachment 2

REVISED Charging for Live Animal Export Independent Observers


Last reviewed: 11 November 2019
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