Compliance Review Report 23: Sheept exported to the United Arab Emirates

​1. Summary

On 25 October 2013 the Department of Agriculture received a report, including photographs and video, from a third party alleging non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in the United Arab Emirates (UAE). The report alleged that Australian sheep were purchased in Abu Dhabi at the Al-Ain market and were transported across the border for private sale in Oman.

The report also alleged that thousands of sheep were transported across the UAE and Oman border and the source of those sheep was the Livestock Shipping Services’ (LSS) UAE supply chain. There was no evidence provided to support this claim.

The department’s review assessed information provided by the complainant, the exporter, departmental records and information from the National Livestock Identification System (NLIS) database.

The review could not confirm if any of the sheep shown in the photographs and videos were exported under ESCAS or which exporter was responsible. However, the review concluded it was highly likely that many of the sheep depicted in the photographs were Australian, based on the presence of ear tags and other physical characteristics.

During the independent audit of the LSS supply chain in the UAE, for the Eid Al-Adha period, it was discovered that a number of sheep were unaccounted for. Records indicate that 114 sheep were moved from an approved supply chain feedlot but did not arrive at an approved supply chain abattoir.

The review found there was a loss of control in relation to the 114 sheep, leading to unauthorised movement outside the approved supply chain. A major non-compliance was recorded against the LSS supply chain in the UAE.

Since January 2014, the department has required LSS to provide a monthly reconciliation of the supply chain. The department has monitored the monthly reports and no major issues have been noted in the supply chain.

2. Introduction

On 25 October 2013 the Department of Agriculture received a report from a third party alleging non-compliance with Exporter Supply Chain Assurance System (ESCAS) requirements in the United Arab Emirates (UAE), during the Eid al-Adha period. The report alleged that Australian sheep were purchased in Abu Dhabi at the Al-Ain market and were transported across the border to Oman. Photographs and video were provided in support of this allegation, which were reportedly taken on 13 October 2013 in the UAE.

The report also alleged that thousands of sheep were transported across the UAE and Oman border and the source of those sheep was the Livestock Shipping Services’ (LSS) UAE supply chain. There was no supporting evidence supplied to support this claim.

The focus of the review was to determine the following

  • if the photographs and video were taken in the location and on the date alleged
  • if Australian sheep were transported outside the approved supply chain to Oman
  • to establish if any other non-compliance with ESCAS requirements occurred.

3. Review Findings

The review accepted that the photographs and video were taken on the date and in the location alleged by the report. The department reviewed records of slaughter sheep exported to the UAE since ESCAS requirements took effect on 1 September 2012. Three exporters; Emanuel Exports Pty Ltd, EMS Rural Exports Pty Ltd and LSS had exported nine consignments of slaughter sheep to the UAE between 1 September 2012 and 13 October 2013.

The photographs and video provided to the department show sheep with Australian merino characteristics, in a market and in the back of a utility vehicle with Omani registration plates. A number of sheep in the photographs had ear tags and ear notches consistent with Australian identification systems however; insufficient information existed to identify who exported the sheep.

One sheep had a National Livestock Identification System (NLIS) tag with a property identification code (PIC) from New South Wales. Property of origin lists for consignments to the UAE were reviewed however, the PIC was not found. There are a number of possible explanations for this; the sheep was not exported in the consignments reviewed, the tag lists were incomplete or the sheep had a second tag that was included in the consignment list, but was not visible in the photograph. It was not clear which exporter or supply chain facility(s) was associated with the sheep.

The report also alleged that thousands of sheep were transported across the border out of the LSS UAE supply chain into Oman during the Eid al-Adha festival. It was not possible from the information provided to establish how many sheep had been transported across the border or if these claims were accurate. In response to the department’s request for information in relation to this allegation, LSS reported that during the independent audit of the LSS supply chain in the UAE for the Eid al-Adha period, it was discovered that a number of sheep were unaccounted for. Records indicate that 114 sheep were moved from an approved supply chain feedlot but did not arrive at an approved supply chain abattoir.

ESCAS requires the importer and exporter to ensure that sheep remain in the approved supply chain until they are slaughtered. Within this system, ownership of the animals may change at any time provided the sheep remain within the approved supply chain facilities until they are slaughtered. The importer claims the buyer of the missing 114 sheep was a new client (which is common during the Eid al-adha festival) who was made aware that sheep must be slaughtered at the approved abattoir. After it was discovered that the sheep were unaccounted for, the importer claims they made efforts to contact the buyer and recover the sheep however, no response was received.

4. Review Conclusions

The review was unable to confirm if the sheep in the photographs provided to the department were exported under ESCAS to the UAE or which exporter or supply chain was responsible. It is highly likely many of the sheep shown in the photographs and video were of Australian origin and more likely than not, the sheep were exported from Australia under ESCAS requirements. As the department was unable to conclude which exporter or supply chain was responsible, there was no finding of non-compliance made in relation to the sheep in the photographs.

The department also considered the report from LSS of 114 missing sheep. The review found there was a loss of control in relation to the 114 sheep, leading to unauthorised movement outside the approved supply chain. A major non-compliance was recorded against the LSS supply chain in the UAE.

This decision was made in line with the Guideline – Management of Non-Compliance.

5. Actions taken by the Exporter

The exporter has advised the department that a number of corrective actions have been implemented at the feedlot and abattoir involved, in an effort to prevent sheep moving outside the supply chain. Including:

  • signage at the abattoir instructing buyers that Australian sheep are to be slaughtered at the facility and are not to be removed from the abattoir
  • where possible, sheep are kept at a purpose built secure facility to minimise the risk of movement outside the supply chain
  • limiting sales at the feedlot and advising abattoirs of the expected time of arrival and number of livestock
  • from December 2013, transport between that feedlot and the abattoir has been arranged by the feedlot as part of the sale, or truck carrying Australian animals have been accompanied by a representative from the feedlot to ensure delivery to the correct abattoir.

6. Regulatory Actions

Since January 2014, the department has applied the following additional conditions to consignments of sheep exported by LSS to the UAE:

No later than the 10th day of each month, the export licence holder must provide the department with the following in relation to the supply chain:

  1. A declaration from a person in management or control for the exporter stating:
    1. Whether or not sheep exported from Australia remained within the supply chain based on a monthly reconciliation from the supply chain of all stock movements for the previous month up to the point of slaughter provided to the exporter.
  2. The department may also request the provision of information upon which the above declaration is based.

The department has monitored the monthly reports, and no major issues have been noted in the supply chain.

Last reviewed: 4 November 2019
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