IFN 04-18 – IFIS Importer declarations and IFIS Community Protection profile questions for cheese

​Issued: 10 July 2018

Purpose

The purpose of this notice is to advise brokers and importers that from 8 August 2018, Imported Food Inspection Scheme (IFIS) Importer declarations will be introduced for cheese made from unpasteurised milk, and for cheese that does not support the growth of Listeria monocytogenes.

The importer declaration for cheese made from unpasteurised milk, enables importers to demonstrate that the cheese being imported is permitted, because it has received a heat treatment during production.

Note, the importer declaration for cheese made from unpasteurised milk is not required for Roquefort imported from France. Roquefort from France, is currently the only raw milk cheese permitted to be imported into Australia, provided it meets certification requirements. RMC 07-2018 specifies the requirements to import raw milk cheese into Australia.

The importer declaration for cheese that does not support the growth of Listeria monocytogenes, enables importers to demonstrate that the cheese being imported is a surveillance food because it does not support the growth of Listeria monocytogenes.

CHE 07-2018 specifies the kinds of cheese that do not support growth of Listeria monocytogenes. Different Listeria monocytogenes microbiological limits apply to cheese, depending on whether it supports, or does not support, the growth of this bacteria. Cheeses that support the growth of Listeria monocytogenes are classified as ‘risk food’ and those that do not, are classified as ‘surveillance food’.

These changes do not apply to:

What is changing?

Community Protection (CP) questions

From 8 August 2018, the department will replace the existing CP questions for cheese with the following questions:

‘IFIS: Is the cheese made from unpasteurised milk? If yes, complete the ‘Imported Food Inspection Scheme–importer declaration for cheese made from unpasteurised milk’. Search ‘Importer declarations’ at www.agriculture.gov.au for more information.’

‘IFIS: Is the cheese covered by an ‘Imported Food Inspection Scheme–importer declaration for cheese that does not support the growth of Listeria monocytogenes’? Search ‘Importer declarations’ at www.agriculture.gov.au for more information.’

The department will monitor the answers to the CP questions. Consistent with the department’s minimum document requirements policy, the department expects that importers and brokers will maintain records of the information used to substantiate answers to CP questions. The department may require brokers and importers to present this information upon request for compliance or verification activities. Giving false or misleading information is a serious offence.

IFIS Importer declarations

From 8 August 2018, the department will introduce two IFIS Importer declarations for cheese:

  1. Imported Food Inspection Scheme–importer declaration for cheese made from unpasteurised milk: A mandatory declaration for cheese made from unpasteurised milk that must accompany the goods.

    This declaration demonstrates that the cheese does not require government certification because it has undergone a heat treatment step during production.

    NOTE: If the cheese is Roquefort cheese from France and it meets certification requirements, an ‘Importer declaration for cheese made from unpasteurised milk’ is not required. RMC 07-2018 specifies the requirements to import raw milk cheese into Australia.

  2. Imported Food Inspection Scheme–importer declaration for cheese that does not support the growth of Listeria monocytogenes: A voluntary declaration that enables importers to provide information on why the cheese does not support the growth of Listeria monocytogenes.

    Cheese lodged with this declaration is classified as a ‘surveillance cheese’ and is randomly referred for inspection and analysis at a rate of 5%. If referred for inspection and analysis, this cheese will be analysed against the standard of no more than 100 colony forming units of Listeria monocytogenes per gram. Surveillance cheese is released after inspection before results of analysis have been reported to the department.

    CHE 07-2018 specifies the kinds of cheese that do not support growth of Listeria monocytogenes.

IFIS Importer declarations are available from the ‘Lodging declarations and documentation for imported food’ webpage.

Importer declarations are valid for a year from the date they are signed by the importer. Giving false or misleading information in an importer declaration is a serious offence.

Clearance

The table below provides the tests applied and permitted results for cheese based on the answer combination to the CP questions.

CP questions

Test applied

Permitted result

IFIS: Is the cheese made from unpasteurised milk? If yes, complete the ‘Imported Food Inspection Scheme–importer declaration for cheese made from unpasteurised milk’. Search ‘Importer declarations’ at www.agriculture.gov.au for more information.’

IFIS: Is the cheese covered by an ‘Imported Food Inspection Scheme–importer declaration for cheese that does not support the growth of Listeria monocytogenes’? Search ‘Importer declarations’ at www.agriculture.gov.au for more information.

Yes1

Yes2

Listeria monocytogenes

n = 5, c = 0, m = 100 cfu/g

Yes1

No

Listeria monocytogenes

n = 5, c = 0, m = not detected3 in 25g

No

Yes2

Listeria monocytogenes

n = 5, c = 0, m = 100 cfu/g

No

No

Listeria monocytogenes

n = 5, c = 0, m = not detected3 in 25g

n = the minimum number of sample units which must be examined from a lot of food.
c = the maximum allowable number of defective sample units.
m = the acceptable microbiological level in a sample unit.

1 If the cheese is not accompanied by an ‘Importer declaration for cheese made from unpasteurised milk’, it will fail.

2 If the cheese is not accompanied by an ‘Importer declaration for cheese that does not support the growth of Listeria monocytogenes’, the cheese will be analysed and must not contain any detectable Listeria monocytogenes in five 25 gram samples.

3 The department allows appointed analysts to composite the five cheese samples when the ‘not detected’ standard applies. This may result in reduced testing costs for importers.

Importers may request a review of a decision within the legislated timeframe for such reviews. If such a review requires re-sampling and re-analysis of samples (for example, for assessment against the other of the two standards) then this will occur at the importer’s expense. A non-compliant result, on its own, is not justification for a review or re-analysis.

How are the changes being implemented?

The changes do not apply until 8 August 2018. From 8 August 2018, the new CP questions apply and importers and brokers can lodge the IFIS Importer declarations.

IFIS Importer declarations are available from the ‘Lodging declarations and documentation for imported food’ webpage.

The department has updated the risk food web pages for ‘Raw milk cheese’ and ‘Cheese in which the growth of Listeria monocytogenes can occur’.

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Last reviewed: 4 November 2019
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