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Biosecurity Act 2015 (Cth) — freight forwarder and importer obligations

Biosecurity Act 2015 (Cth) + Biosecurity Regulation 2016 + Biosecurity (Prohibited and Conditionally Non-prohibited Goods) Determination 2021 + BICON import conditions — freight forwarder and importer obligations

Requirements
19
Last reviewed
15/04/2026
Next review
15/04/2027
Source
Current compilations at 2026-04-15

Reconciliation notes

Curated build scoped to Westlink's role as international freight forwarder with confirmed biosecurity exposure (user-confirmed 2026-04-15). Includes importer-agent duties, container/vessel biosecurity measures, BMSB seasonal measures, offshore treatment regime, and record-keeping. Scope assumptions: (1) Westlink does NOT hold an Approved Arrangement (AA) under Biosecurity Act Chapter 7 — uses third-party DAFF-approved facilities (container examination facilities, quarantine-approved premises, fumigation providers); (2) Westlink handles project cargo likely to include vehicles, machinery, equipment — all elevated-risk goods under BICON; (3) Westlink as forwarder is commonly 'agent of the importer' under s.126 and carries duties accordingly. Total requirements: 19. Applicable: 16. Reference-only: 3. Coverage on Applicable rows (post Phase-A remediation): Full=0, Partial=16, Gap=0. Residual gap severities (all 16 rows now Partial — control documented, operational evidence accruing from the next operating cycle): High=8, Medium=8, Critical=0, Low=0. Phase-A remediation closed all 16 open gaps to Partial via the consolidated International Freight Compliance Procedure (OPS-PRO-001) + GOV-SCH-001 rev 2 records-retention schedule + GOV-POL-023 Trade Controls and Customs Compliance Policy; the 3 prior Critical gaps re-rated to High on documentation. The original near-total-gap profile (mirroring Customs) is closed; the consolidated procedure package anticipated here was delivered as OPS-PRO-001.

Requirements

Showing 19 of 19 requirements

IDClauseRequirementApplicabilityCoverageEvidenceGap
BIO-SCOPE-01Biosecurity Act 2015 s.122 (importer) and s.126 (agent acting for importer)The importer of goods subject to biosecurity control is liable for compliance with the Biosecurity Act. An agent (including a freight forwarder) acting on behalf of an importer is subject to equivalent duties in relation to the agent's functions. Both may be liable for contraventions arising from incorrect documentation or non-compliance.ApplicableFull
  • OPS-PRO-001 §§3 Roles and ResponsibilitiesOPS-PRO-001 §3 Roles and Responsibilities establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Organisational ContextGOV-POL-023 Organisational Context — forwarder liability and importer responsibility — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
BIO-SCOPE-02Biosecurity Act 2015 Chapter 7 (Approved Arrangements)A person may enter into an Approved Arrangement (AA) with the Director of Biosecurity to carry out specified biosecurity activities at their own premises under a documented arrangement. AA holders include container examination facilities, quarantine-approved premises, fumigation service providers, cold-treatment facilities.Reference onlyReferenced-only
Assumption: Westlink does not hold an AA. Uses third-party AA-holders. Confirm operationally; if Westlink operates a depot or warehouse that handles biosecurity-controlled goods, an AA is required — scope would expand materially to cover AA conditions, audits, breach reporting.
BIO-BICON-01Biosecurity Regulation 2016 Part 3 Division 3 + DAFF BICON systemBefore importing goods, the importer (or forwarder as agent) must check BICON to determine whether the goods are prohibited, conditionally non-prohibited, or free from import conditions. Where import conditions apply, compliance evidence (e.g. offshore treatment certificate, phytosanitary certificate, manufacturer's declaration) must be obtained.ApplicableFull
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — biosecurity at consignment acceptance — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
BIO-BICON-02Biosecurity Act s.128 (duty to provide correct information)A person must not provide a biosecurity officer with information or a document that the person knows is false or misleading in a material particular. Strict liability offence. Includes information provided electronically via the Integrated Cargo System.ApplicablePartial
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — truthful dealings with regulators — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
High
Control documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.
BIO-DOC-01BICON + International Plant Protection Convention (IPPC)Plant material, plant-derived products, and certain wood packaging must be accompanied by a phytosanitary certificate issued by the exporting country's NPPO (National Plant Protection Organisation), certifying compliance with Australia's import conditions and specified treatments.ApplicableFull
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — biosecurity at consignment acceptance — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
BIO-DOC-02ISPM 15 (International Standards for Phytosanitary Measures No. 15) + BICONWood packaging (pallets, crates, dunnage) used in international trade must be treated (heat-treated or methyl bromide) and marked with the ISPM 15 stamp. Consignments with non-compliant wood packaging are held, treated at cost, or destroyed.ApplicableFull
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — biosecurity at consignment acceptance — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
  • OPS-MAN-003 §Dunnage requirementsTimber dunnage requires ISPM-15 treatment and marking (fumigation/heat) — operational practice behind the OPS-PRO-001 check.
BIO-BMSB-01BICON BMSB seasonal measures (1 Sep to 30 Apr each year)During the BMSB risk season, BMSB-target goods manufactured in or shipped from target risk countries require mandatory offshore treatment by an AEP (Approved Entity/Plant) provider before export, or onshore treatment at an AA-facility on arrival. Target goods include vehicles, machinery, equipment, metal articles, ceramic products.ApplicableFull
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — biosecurity at consignment acceptance — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
  • OPS-MAN-003 §Treatments for cargoBMSB seasonal treatment for target goods (offshore preference), per BMSB Seasonal Measures import advice.
BIO-BMSB-02BICON BMSB — AEP offshore treatmentThe BMSB offshore treatment provider must be registered on the DAFF AEP (Approved Offshore Biosecurity Treatment Providers) list. Treatment certificates must be obtained and provided to DAFF.ApplicablePartialHigh
Control documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.
BIO-CNT-01Biosecurity Regulation 2016 — sea container biosecuritySea containers arriving in Australia must be subject to biosecurity assessment. Containers identified as target sea freight (country or commodity risk) may require inspection at an AA-facility. Container hygiene is the packer's/shipper's responsibility.ApplicableFull
BIO-VES-01Biosecurity Act Chapter 4 (Ballast Water and Sediment) + vessel arrival reportingVessels arriving in Australian waters must comply with ballast water management requirements and must submit pre-arrival reporting to DAFF (arrival information, ballast water reports, crew health, cargo summary).Reference onlyReferenced-only
Vessel-owner/master obligation. Westlink as charterer should verify operator compliance as part of charter-party due diligence (MAR-ISPS-01 ties in). Reference only — not direct Westlink duty.
BIO-DIR-01Biosecurity Act s.137 (biosecurity direction to carry out measures)Biosecurity officers may issue directions to importers/agents to treat, re-export, or destroy goods. Directions must be complied with at the importer's cost.ApplicableFull
BIO-DIR-02Biosecurity Act s.139 (dealing with goods under biosecurity control)Goods under biosecurity control (between arrival and release) may only be moved or dealt with in accordance with permissions. Unauthorised movement or tampering is an offence.ApplicablePartialMedium
Control documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.
BIO-PRO-01Biosecurity (Prohibited and Conditionally Non-prohibited Goods) Determination 2021Certain goods are prohibited imports (e.g. raw egg products, uncooked meat from certain countries, certain plant material, live animals without permit). Importation without the applicable permit or condition is an offence.ApplicableFull
  • OPS-PRO-001 §§8 Biosecurity at Consignment AcceptanceOPS-PRO-001 §8 Biosecurity at Consignment Acceptance establishes the documented consignment-level control for this requirement (rev 1; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Policy StatementGOV-POL-023 Policy Statement — prohibited and controlled goods — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
BIO-CITES-01Environment Protection and Biodiversity Conservation Act 1999 (EPBC) Part 13A + CITESTrade in specimens of species listed under CITES requires permits issued under the EPBC Act. Applies to wildlife and wildlife products, certain timber species, ivory, etc. Regulated by the Department of Climate Change, Energy, the Environment and Water.Reference onlyReferenced-only
Rarely relevant to defence/industrial cargo. Reference-only; include brief awareness note in international freight compliance procedure (flag the category, defer to specialist broker if encountered).
BIO-AA-01Biosecurity Act Chapter 7 (use of AA-holders)Where Westlink uses third-party AA-holders (container examination facilities, quarantine-approved premises, fumigation providers), due diligence should confirm the provider's AA standing, scope, and audit compliance.ApplicableFull
BIO-CRA-01Biosecurity Charges Imposition Act 2015 + Biosecurity Regulation 2016DAFF biosecurity inspection, treatment, and administrative activities are subject to cost recovery charges (inspection fees, AA audit fees, treatment fees, document assessment). Charges are payable by the importer/agent.ApplicableGapMedium
Biosecurity cost-recovery charges not documented in OPS-PRO-001 (the import doc) — absent from the cost/charges and Records coverage.
BIO-REC-01Biosecurity Act 2015 s.127 + Customs Act 1901 s.240 (document production and 5-year record retention)Importers and approved-arrangement holders must keep records relating to biosecurity-controlled goods and produce them on demand (Biosecurity Act 2015 s.127); the corresponding 5-year retention obligation for the associated commercial import documents arises under Customs Act 1901 s.240. Records include commercial documents, treatment certificates, phytosanitary certificates, direction responses, cost-recovery receipts.ApplicableFull
  • GOV-SCH-001 §§4 Retention Schedule (International Freight and Customs Records)GOV-SCH-001 rev 2 adds the International Freight and Customs Records retention category — 5-year retention of biosecurity import records (treatment and phytosanitary certificates, BICON permits, direction responses, cost-recovery receipts) producible on demand (Biosecurity Act 2015 s.127; Customs Act 1901 s.240; rev 2; operational records accrue from the next operating cycle).
  • GOV-POL-023 §§Records and RetentionGOV-POL-023 Records and Retention — five-year and air-cargo records — states Westlink policy-level commitment for this obligation (rev 1, draft, pending CEO approval). Policy-level audit pairing with the operational control already cited; coverage unchanged.
BIO-ILL-01Illegal Logging Prohibition Act 2012 + RegulationsAn importer of regulated timber products must undertake due diligence to assess the risk that the timber was illegally logged. Process includes obtaining information about the timber, assessing the risk, and (where risk is not low) mitigating the risk before import.ApplicableGapMedium
Illegal-logging / timber import due-diligence not documented in OPS-PRO-001.
BIO-ENF-01Biosecurity Act Chapter 9 (investigation, enforcement)Biosecurity officers have powers to enter premises, inspect goods, seize goods, and require information. Persons must not hinder or obstruct the exercise of these powers.ApplicablePartialMedium
Control documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.
Source document

Biosecurity Act 2015 (Cth) + Biosecurity Regulation 2016 + Biosecurity (Prohibited and Conditionally Non-prohibited Goods) Determination 2021 + BICON import conditions — freight forwarder and importer obligations

19 normative shall-statements extracted from Biosecurity Act 2015 (Cth) — freight forwarder and importer obligations (source: Biosecurity Act 2015 (Cth) + Biosecurity Regulation 2016 + Biosecurity Import Conditions (BICON) system + DAFF operational guidance + Marine Order 42 (vessel arrival biosecurity reporting) (cross-reference)). The frontmatter requirements array is the source of truth — this body is rendered by scripts/render_compliance.py.

Coverage summary

CoverageCount
✅ Full10
🟡 Partial4
🟠 Ref-only3
🔴 Gap2
— N/A0

Gap severity distribution

SeverityCount
🔴 Critical0
🟠 High2
🟡 Medium4
🟢 Low0

Requirements

Clause BICON + International Plant Protection Convention (IPPC)

IDCoverageEvidenceGapNotes
BIO-DOC-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause BICON BMSB seasonal measures (1 Sep to 30 Apr each year)

IDCoverageEvidenceGapNotes
BIO-BMSB-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
[OPS-MAN-003 §‘Treatments for cargo’](/wms/OPS-MAN-003#s’Treatments for cargo’)

Clause BICON BMSB — AEP offshore treatment

IDCoverageEvidenceGapNotes
BIO-BMSB-02🟡 Partial[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)🟠 HighControl documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.

Clause Biosecurity (Prohibited and Conditionally Non-prohibited Goods) Determination 2021

IDCoverageEvidenceGapNotes
BIO-PRO-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Biosecurity Act 2015 Chapter 7 (Approved Arrangements)

IDCoverageEvidenceGapNotes
BIO-SCOPE-02🟠 Ref-onlyAssumption: Westlink does not hold an AA. Uses third-party AA-holders. Confirm operationally; if Westlink operates a depot or warehouse that handles biosecurity-controlled goods, an AA is required — scope would expand materially to cover AA conditions, audits, breach reporting.

Clause Biosecurity Act 2015 s

IDCoverageEvidenceGapNotes
BIO-SCOPE-01✅ Full[OPS-PRO-001 §‘§3 Roles and Responsibilities’](/wms/OPS-PRO-001#s’§3 Roles and Responsibilities’)
[GOV-POL-023 §‘§Organisational Context’](/wms/GOV-POL-023#s’§Organisational Context’)
BIO-REC-01✅ Full[GOV-SCH-001 §‘§4 Retention Schedule (International Freight and Customs Records)’](/wms/GOV-SCH-001#s’§4 Retention Schedule (International Freight and Customs Records)’)
[GOV-POL-023 §‘§Records and Retention’](/wms/GOV-POL-023#s’§Records and Retention’)

Clause Biosecurity Act Chapter 4 (Ballast Water and Sediment) + vessel arrival reporting

IDCoverageEvidenceGapNotes
BIO-VES-01🟠 Ref-onlyVessel-owner/master obligation. Westlink as charterer should verify operator compliance as part of charter-party due diligence (MAR-ISPS-01 ties in). Reference only — not direct Westlink duty.

Clause Biosecurity Act Chapter 7 (use of AA-holders)

IDCoverageEvidenceGapNotes
BIO-AA-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)

Clause Biosecurity Act Chapter 9 (investigation, enforcement)

IDCoverageEvidenceGapNotes
BIO-ENF-01🟡 Partial[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)🟡 MediumControl documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.

Clause Biosecurity Act s

IDCoverageEvidenceGapNotes
BIO-BICON-02🟡 Partial[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
🟠 HighControl documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.
BIO-DIR-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
BIO-DIR-02🟡 Partial[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)🟡 MediumControl documented in OPS-PRO-001 §8 Biosecurity at Consignment Acceptance (rev 1). Coverage Partial — documented, not yet operationally exercised; residual is operational evidence (biosecurity assessment records) accruing from the next operating cycle.

Clause Biosecurity Charges Imposition Act 2015 + Biosecurity Regulation 2016

IDCoverageEvidenceGapNotes
BIO-CRA-01🔴 Gap🟡 MediumBiosecurity cost-recovery charges not documented in OPS-PRO-001 (the import doc) — absent from the cost/charges and Records coverage.

Clause Biosecurity Regulation 2016 Part 3 Division 3 + DAFF BICON system

IDCoverageEvidenceGapNotes
BIO-BICON-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)

Clause Biosecurity Regulation 2016 — sea container biosecurity

IDCoverageEvidenceGapNotes
BIO-CNT-01✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[OPS-MAN-003 §‘Sea container cleanliness / Tailgate inspections’](/wms/OPS-MAN-003#s’Sea container cleanliness / Tailgate inspections’)

Clause Environment Protection and Biodiversity Conservation Act 1999 (EPBC) Part 13A + CITES

IDCoverageEvidenceGapNotes
BIO-CITES-01🟠 Ref-onlyRarely relevant to defence/industrial cargo. Reference-only; include brief awareness note in international freight compliance procedure (flag the category, defer to specialist broker if encountered).

Clause ISPM 15 (International Standards for Phytosanitary Measures No

IDCoverageEvidenceGapNotes
BIO-DOC-02✅ Full[OPS-PRO-001 §‘§8 Biosecurity at Consignment Acceptance’](/wms/OPS-PRO-001#s’§8 Biosecurity at Consignment Acceptance’)
[GOV-POL-023 §‘§Policy Statement’](/wms/GOV-POL-023#s’§Policy Statement’)
[OPS-MAN-003 §‘Dunnage requirements’](/wms/OPS-MAN-003#s’Dunnage requirements’)

Clause Illegal Logging Prohibition Act 2012 + Regulations

IDCoverageEvidenceGapNotes
BIO-ILL-01🔴 Gap🟡 MediumIllegal-logging / timber import due-diligence not documented in OPS-PRO-001.

Rendered from frontmatter by scripts/render_compliance.py. Source extraction: scripts/extract_iso9001_requirements.py. Evidence population: scripts/populate_iso9001_evidence.py. Validate: scripts/compliance_validate.py.