Domestic Organic Regulatory 
Framework : Consultation 
regulation impact statement  
 
Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
ii © Commonwealth of Australia 202 2 
Ownership of intellectual property rights  
Unless otherwise noted, copyright (and any other intellectual property rights) in this publication is owned by the 
Commonwealth of Australia (referred to as the Commonwealth).  
Creative Commons licence  
All material in this publication is licensed under a Creative Commons Attribution 4.0 International Licence  except 
content supplied by third parties, logos and the Commonwealth Coat of Arms.  
Inquiries about the licence and any use of this document should be emailed to copyright@awe.gov.au . 
 
Cataloguing data  
This publication (and any material sourced from it) should be attributed as: Domestic Organic Regulatory Framework : 
Consultation regulation impact statement , Department of Agriculture, Water and the Environment , Canberra, 
February . CC BY 4.0. 
This publication is available at haveyoursay.awe.gov.au/organics.  
Department of Agriculture, Water and the Environment  
GPO Box 858 Canberra ACT 2601  
Telephone 1800 900 090  
Web awe.gov.au  
Disclaimer  
The Australian Government acting through the Department of Agriculture, Water and the Environment  has exercised 
due care and skill in preparing and compiling the infor mation and data in this publication. Notwithstanding, the 
Department of Agriculture, Water and the Environment , its employees and advisers disclaim all liability, including 
liability for negligence and for any loss, damage, injury, expense or cost incurred  by any person as a result of 
accessing, using or relying on any of the information or data in this publication to the maximum extent permitted by 
law.  
Acknowledgement of Country  
We acknowledge the Traditional Custodians of Australia and their continuing c onnection to land and sea, waters, 
environment and community. We pay our respects to the Traditional Custodians of the lands we live and work on, 
their culture, and their Elders past and present.  
  
Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
iii Contents  
Executive summary  ................................ ................................ ................................ ................................ .........  v 
Purpose  ................................ ................................ ................................ ................................ ................................ .........  v 
Scope and definitions  ................................ ................................ ................................ ................................ ..............  v 
Introduction  ................................ ................................ ................................ ................................ .......................  1 
Overview of the organics sector  ................................ ................................ ................................ .........................  1 
Current state of domestic organics regulation  ................................ ................................ .............................  1 
International regulation  ................................ ................................ ................................ ................................ .........  2 
1 What is the policy problem we are trying to solve?  ................................ ................................ .... 3 
1.1 Current regulation  ................................ ................................ ................................ ................................ ..... 3 
1.2 Barrier to trade and market access  ................................ ................................ ................................ .... 4 
1.3 Consumer confidence  ................................ ................................ ................................ ...............................  5 
2 Why is government action needed?  ................................ ................................ ................................ .. 7 
2.1 Overarching objective  ................................ ................................ ................................ ..............................  7 
3 What policy options are we considering?  ................................ ................................ .......................  9 
3.1 Status quo  ................................ ................................ ................................ ................................ ......................  9 
3.2 Non -regulatory approaches  ................................ ................................ ................................ ...................  9 
3.3 Mandatory domestic organics standard  ................................ ................................ ........................  11 
4 What is the likely net benefit of each option?  ................................ ................................ ............  15 
4.1 Status quo  ................................ ................................ ................................ ................................ ...................  15 
4.2 Non -regulatory  ................................ ................................ ................................ ................................ ........  16 
4.3 Mandatory domestic organics standard  ................................ ................................ ........................  17 
Appendix A: Process to date and next steps  ................................ ................................ ........................  20 
Appendix B: Organic Standards  ................................ ................................ ................................ ...............  21 
Appendix C: Regulatory systems of comparable trading partners  ................................ .............  22 
United States  ................................ ................................ ................................ ................................ ............................  22 
Canada  ................................ ................................ ................................ ................................ ................................ ........  22 
European Union ................................ ................................ ................................ ................................ ......................  22 
China  ................................ ................................ ................................ ................................ ................................ ...........  22 
New Zealand  ................................ ................................ ................................ ................................ ............................  22 
Appendix D: Comparison of options ................................ ................................ ................................ ....... 24 
References  ................................ ................................ ................................ ................................ .......................  25 
 
Table 1 Organic standards  ................................ ................................ ................................ ................................ ..........  21 
Table 2 Comparison of options  ................................ ................................ ................................ ................................ . 24 Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
iv  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
v Executive summary  
Purpose  
The Department of Agriculture, Water and the Environment (the department) is releasing this 
Consultation Regulation Impact Statement  (RIS) to seek comments on how Australia regulates 
organic products domestically, and supports industry growth and consumer confidence. It 
examines the policy problem with the current system, as well as potential regulatory and non -
regulatory options for r eform.  
The Consultation RIS includes several questions designed to prompt thinking and inform 
submissions. You are welcome to use the questions when framing your submission, but they are 
not mandatory.  
Together with other feedback received from stakeholder s, submissions on the Consultation RIS 
will be used to prepare a recommended policy option for Australian Government consideration. 
Submissions will be accepted during the consultation period, running from 18 February to close 
of business 17 March 2022.  Further information on the process to date and next steps is 
available at  Appendix A: Process to date and next steps . 
This RIS has been developed in accordance with The Australian Government Guide to Regulation  
and in consultation with the Office of Best Practice Regulation.  
 
Scope and definitions  
The department is aware there are a number of definitions and interpretatio ns of the term 
‘organic’.  Producers and processors who operate organically do not use artificial fertiliser or 
synthetic chemicals and may also choose to adopt practices that are complementary to not using 
synthetic chemicals, such as sustainable use of resources or conservation.  
Australia's organic export standard, t he National Standard for Organic and Bio -Dynamic 
Produce , defines the intent of organics as 'the application of practices that emphasise: the use of 
renewable resources; co nservation of energy, soil and water; recognition of livestock welfare 
needs; and environmental maintenance and enhancement, while producing optimum quantities 
of produce without the use of artificial fertiliser or synthetic chemicals '. 
This RIS covers the  domestic regulation of organic agriculture (crops and livestock), 
aquaculture, textiles, skin and beauty products, seed, and livestock feed, and seeks views on the 
application or scope of any potential regulatory framework.  
The department is also seeking views on the alignment of potential domestic regulation wi th 
export arrangements. Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
1 Introduction  
Overview of the organics sector  
Australia has the largest organic agricultural area in the world at 35.7 million hectares ( Willer et 
al. 2021 ). According to IBIS World ( 2020 ), Australia’s organic industry revenue is fo recast to 
increase at an annualised 14.6 per cent over the 5 years through 2025 -26, to $3.9 billion.  
Industry reporting indicates that Australian organic exporters reached 62 international markets 
during 2020, with North America, Asia, and Oceania the lea ding export destinations ( AOL 2021 ).  
Industry reporting also suggests the number of certified organic operations in Australia has 
grown by 38 per cent since 2011 ( AOL 2021 ). 
These figures reflect the rise in consumer preferences for organic products over recent years. 
The COVID -19 health pandemic has catalysed this trend in consumer preferences, with 
37 per cent of Australian organic shoppers increasing their household food allocation to organic 
in 2020 ( AOL 2021 ). 
This is also reflected internationally, w ith the global market for organic food and drink sales 
reaching more than 106 billion euros in 2019 ( Willer et al. 2021 ). The largest single market was 
the United States with 42 per cent of the global market, followed by the European Union with 39 
per cent  (Willer et al. 2021 ). 2019 also saw a rise in organic producers with 3.1 million 
producers identified, 12.5 per cent more compared to 2018 ( Willer et al. 2021) . 
Current state of domestic organics regulation  
Businesses that make organic claims on goods in the Australian domestic market must be able to 
substantiate those claims, consistent with the whole -of-economy requirements under the 
Australian Consumer Law (ACL). There are protections against misleading, false and deceptive 
conduct, and consumers are ab le to make complaints to the Australian Competition and 
Consumer Commission (ACCC)  and state and territory fair trading regulators . 
There is no legislated, or government -endorsed definition of ‘organic’, no mandatory standard 
for domestic use, and no requirement for certification of organic products produced and sold 
domestically in Australia.  
Organic businesses can choose to be certified by an organic certification body to underpin truth 
in labelling and promote consumer confidence. For example, those  selling on the domestic 
market may choose to be certified against Australia’s organic export standard the National 
Standard for Organic and Biodynamic Produce  (National Standard), owned and managed by the 
department . Businesses can also be certified to the voluntary AS6000:2015 - Organic and 
biodynamic products (AS 6000) owned by Standards Australia. There are also a number of 
private standards that are similar to or based on the National Standard.  
There are 6 Government -approved certifying bodies in Aust ralia for export purposes and each 
body certifies to the National Standard. Some bodies have their own standard (equivalent to the 
National Standard) and all have their own organic certification labels. Industry reporting 
indicates there are around 4,000 c ertified organic operations in Australia. Further information 
on the different standards is at  Appendix B: Organic Standards . Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
2 Products for export that make an organic cl aim must be certified by an Australian Government 
approved certifying body against the National Standard. The 6 approved certifying bodies  are: 
• Australian Certified Organic Certification Ltd  
• AUS -QUAL Pty LTD  
• Bio-Dynamic Research Institute  
• NASAA Certified O rganic  
• Organic Food Chain  
• Southern Cross Certified Australia Pty Ltd  
Products certified to the National Standard can be sold anywhere in Australia and to 
non-regulated markets overseas. International markets which regulate the use of the word 
'organic ', such as the United States, China, and the European Union, require organic products 
that are imported to meet the requirements of their national regulatory system.  
International regulation  
Internationally, organic production is generally regulated through a s pecific regulatory system, 
which is often supported by a mandatory national standard and a certification scheme. The 
latest IFOAM survey on organic regulations found that 72 countries had fully implemented 
organics regulations as of 2020. 22 countries had regulations which were not fully implemented, 
and 14 unregulated countries were drafting legislation  (Willer et al. 2021) . New Zealand is in the 
process of introducing mandatory domestic organic regulation. More information on the 
regulatory systems of com parable trading partners is available at Appendix C: Regulatory 
systems of  comparable trading partners . Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
3 1 What is the policy problem we are 
trying to solve?  
We have heard feedback from the sector that there are several issues with the current system, 
including:  
1) Confusion and costs for some businesses in navigating current regulations  
2) Barriers to trade and market access may impede market growth  
3) A lack of clear and cons istent information may impact consumer confidence and 
protections.  
A key focus for the department is to gather evidence in these areas, identify those impacted, and 
gauge the extent of any failure in the market.  
There is potential for continued and acceler ated growth in Australia’s organics sector, but the 
right incentives, market signals, and information flows are required to facilitate this growth and 
remove potential barriers.  
It is also important that Australia is competitive globally . Other countries a re actively promoting 
growth in their organic sectors. For example, under the European Green Deal’s Farm to Fork 
strategy, the European Commission has set a target of ‘at least 25% of the EU’s agricultural land 
under organic farming and a significant incre ase in organic aquaculture by 2030’ ( European 
Commission 2021 ). 
1.1 Current regulation  
No domestic equivalent to export regulation  
At present, Australian organic businesses operate under different requirements for the domestic 
market and exports. While organic operators who export overseas are required to obtain 
certification from an approved certifying body under a mandatory standard, organic products 
intended for the domestic market (including imports) are not required to be certified or comply 
with a particular standard.  
The department is responsible for managing biosecurity and food safety risks with imported 
food. Under the Biosecurity Act 2015 , certain foods may be restricted from entry and other foods 
may require an import permit and compliance wit h specific conditions. Under the Imported Food 
Control Act 1992 , imported food must be safe and compliant with requirements in the Australia 
New Zealand Food Standards Code and the Country of Origin  Food  Labelling information 
standard . Neither Act places a ny obligation under importers to substantiate claims of organic 
goods or produce.  
Lack of a legal definition  
The absence of a legislated definition of ‘organic’ in the Australian domestic market may add 
further uncertainty to businesses. The department has  heard from stakeholders that without 
clarity on what constitutes organic, businesses can lack the understanding and confidence 
needed to make organic claims.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
4 The lack of a single definition may also cause confusion, or transfer risk between parties when 
products move along the supply chain, i.e., from farmer to processor to distributor or 
transporter. For example, there may be confusion if operators or processors operate on different 
understandings about what constitutes ‘organic’, and where certified products become non -
compliant with their standard, operators may be de -certified (even if the non -compliance was 
introduced further along in the supply chain) and this carries financial risk and burden.  
Market integrity  
While the ACL protects aga inst misleading, false or deceptive conduct, products not verified as 
meeting an agreed standard can still be sold with the suggestion they are ‘organic’ and at similar 
price points to certified products, noting organic products tend to command a price pre mium. 
The current arrangements do not ensure all ingredients or materials used to create an organic 
product are genuinely organic.  
As a result, a range of products can make it to market with unsubstantiated organic claims, 
which could risk the integrity of  Australia’s organics sector and organic producers. This may 
result in an uneven playing field, with businesses that invest time and resources maintaining the 
integrity of organic products disadvantaged by those who may not follow the same rigor.  
A purpose  of this consultation is to determine whether and how much this may be happening.  
1.2 Barrier to trade and market access  
Some of Australia’s major trading partners, including the USA and South Korea, require a more 
robust domestic regulatory regime as a prereq uisite to entering negotiations on preferential 
trade arrangements (equivalency). In the absence of greater assurance and integrity around the 
domestic production, imports and sale of organic goods, Australian producers face greater costs 
to access export markets as well as potential opportunity costs arounds limits to market access.  
Equivalency arrangements can reduce the cost burden on Australian exporters, removing the 
need for additional certifications. While not all domestic producers will want to acce ss 
international markets, greater consistency across domestic and export regulation could lower 
the cost of doing so and broaden options for future growth. It would also provide added 
protection from a downturn in either a domestic or international market.  
For markets where there is organic regulation of imports, exports and their domestic market, 
and where Australia has not negotiated equivalence arrangements (e.g., the US and South 
Korea), operators can only access these markets through conformity assessm ents. This is where 
an approved certifying body enters an arrangement with an overseas government to certify 
goods to the overseas standards. The costs to certification bodies of maintaining such overseas 
arrangements add up and are passed onto businesses requesting this certification – typically as 
an add -on fee, charged per export market. This may create a disincentive to organic businesses 
interested in exporting to those markets under private arrangements due to the upfront and 
ongoing costs associated with maintaining export market access.  
It also results in cost duplication for industry as exporters need to comply with both Australia’s 
export requirements and separately meet the costs to partake in conformity assessment 
arrangements to meet the export market’s requirements.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
5 1.3 Consumer confidence  
A key challenge of 'organic' products is the products' credence characteristics – that is, you 
cannot necessarily look at a product and know if it is 'organic'. It is reasonable to expect 
businesses to disclose de scriptive information about their product to consumers voluntarily and 
accurately (e.g., that they are providing an 'organic' product), particularly where organic 
products typically command a price premium. However, potential market failures may arise 
from : 
• information asymmetries (i.e., producers have greater knowledge regarding the quality of 
goods or classes of goods than the consumer)  
• possible negative social externalities (i.e., incorrect descriptors may cause 'harm' to the 
public interest, as well as to the reputation of Australian manufacturers of similar goods).  
There may also be a perception of a market failure due to negative externalities where the 
actions of producers that make dubious claims are exposed, resulting in a general loss of 
confidence  in the sector.  A purpose of this consultation is to determine whether and how much 
this may be happening.  
Consumer surveys suggest that the lack of a single legal definition of organic, along with the use 
of several standards, inconsistent labels, differi ng certifying body logos, and multiple terms on 
product packaging can cause consumer confusion and undermine shopper confidence.  
The current domestic regulatory environment may also have drawbacks for Australian 
consumers - Australian consumers may be vuln erable to being misled, and operators could gain 
financial benefits from selling products as ‘organic’ without substantiating their claims (as 
organic products generally command a price premium). International consumers of Australian 
certified products are  less likely to experience this concern as all products claiming organic that 
are exported into international markets are required by Commonwealth Export Rules to comply 
with the National Standard.  
There is a risk that if consumer awareness of regulatory g aps were to grow, the incentive to buy 
organic products could diminish which has the potential to impact the organics supply chain. 
Organic businesses may face the threat of losing their consumer base due to the wrongdoing of 
other businesses. This could a lso deny consumers access to products they desire and for which 
they would be prepared to pay a premium.  
A purpose of this consultation is to determine whether and how much this may be happening.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
6 Questions  
• Do you agree with the problems listed above?  
• How do they impact you or your business, or you as a consumer?  
• Do the current regulatory settings incur costs, or make it difficult on your business?  
• If you export organic goods, how user friendly is the curren t process?  
• Do you think the current process for certifying exports should be extended to organic products for 
sale within Australia?  
• What are the current barriers to seeking certification (if any)?  
• Do you think there is enough information for consumers to make informed purchases?  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
7 2 Why is government action needed?  
The government’s role in an open market is to correct market failures (including information 
asymmetries or anti -competitive behaviour along the supply chain) to ensure the market 
remains open.  
Gove rnment also plays a role in working with industry to support growth, reduce regulatory 
burden, and facilitate trade. This includes the delivery of effective and efficient regulatory 
frameworks that are suitably tailored and proportionate to sector needs. I t also includes 
removing barriers to trade, bolstering supply chains, and supporting product diversification.  
A further role is in competition policy, aimed at ensuring competition is not restricted or 
undermined. For organics regulation, this may include an exploration of existing power 
dynamics between certifiers and producers  and between certifiers themselves , how potential 
changes might impact this relationship, and any barriers to entry  to the certification industry or 
the organics industry . 
A key purpose of this Consultation RIS is to help identify the extent of any market failure, and to 
explore whether current settings are consistent with the above aims. Building from this premise, 
we have prepared the below policy objectives to measure opt ions against, noting not all policy 
options will solve all problems to the same extent:  
2.1 Overarching objective  
• Correct market failures (to the extent this is identified)  
What we're trying to achieve for businesses  
• Mitigate barriers to trade and allow fo r market access  
• Provide regulatory clarity around organic claims and certification  
• Prevent operations from making false and misleading claims  
• Ensure a level playing field  
What we’re trying to achieve for consumers  
• Give consumers access to clear and transparent information  
• Ensure consumers can choose from a range of quality organic products  
• Protect against harmful behaviour such as false and misleading claims  
With agriculture making up a substantial proportion of all organic output, this RIS is also l inked 
to the government’s commitment to help the agriculture industry reach its goal of $100 billion in 
production by 2030 (Ag2030). This will not be achieved unless the government puts in place the 
right foundations for industry to harness emerging opport unities and increase efficiencies. This 
means listening to industry, ensuring our policy settings and frameworks adequately support 
them, and making it easy to do business.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
8 COVID -19 has compounded these challenges, changing the way we live and work. The or ganics 
sector has a role to play in Australia’s recovery, economic prosperity, and food security but 
needs the right settings in place to support this.  
Questions  
• Is there evidence of market failure with the current system that would justify government 
inte rvention?  
• Are you aware of any precedent (domestic or overseas) with lessons around government intervention 
in similar markets?  
• What should a domestic regulatory framework aim to achieve?  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
9 3 What policy options are we 
considering?  
In addition to seeking furth er evidence about whether there is a problem, this Consultation RIS 
canvasses a range of potential regulatory and non -regulatory options for consideration. The 
options span from retaining the status quo through to implementing a mandatory domestic 
organics standard.  
Each option needs to be considered within existing regulatory frameworks, including the food 
regulation system requirements, to avoid duplication and undue regulatory burden. All options 
also need to be consistent with Australia’s intern ational trade obligations under the World 
Trade Organization.  
The options are intended to generate feedback on different ways to address the policy problem 
and objectives, with views on alternative approaches also encouraged. This will inform the final 
decision on whether the way organic products are regulated in Australia needs to change.  
For the purposes of this document, the options are described at a high level, with more detailed 
design considerations to follow should any option be agreed by government . 
3.1 Status quo  
Under this option, the existing approach to domestic regulation would be maintained. The ACL 
would continue to provide general protections against false and misleading claims and 
certification of organic products for the domestic market would remain voluntary. Current 
settings and market forces would be left to determine any changes to business and consumer 
behaviour.  
Questions  
• Are there other factors to consider when describing the status quo?  
3.2 Non -regulatory approaches  
Education campaign  
The f irst non -regulatory option identified in this RIS is an education and awareness raising 
campaign, noting the status quo could also be characterised as non/co -regulatory. The nature of 
the campaign would depend on the target problem (i.e., businesses not kn owing how to claim, 
consumers confusion, or both).  
If focused on consumers, this would involve united and consistent messaging to improve the 
general public’s awareness and understanding of the term organic. This could extend to 
guidance around existing vo luntary processes and branding, helping consumers to identify logos 
and distinguish between certified and non-certified  goods.  
If aimed at industry, the focus could be on industry benchmarks regarding what constitutes 
organic, how to achieve certification,  or business responsibilities under the ACL.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
10 Campaigns could be funded and delivered by industry (with standard messaging across 
representative bodies), government, or progressed as a joint effort.  
The campaign could include multiple communication mechanis ms. This could include a 
dedicated website platform, social media, television, radio, and newspapers as well as 
advertising on consumer and industry focused websites. In addition to general messaging, the 
industry and/or government could work with major re tailers and industry associations to 
deliver more targeted messaging to consumers and industry. This could include, f or example, 
working with major retailers to supply brochures or postcards with organic labelling 
information at the point -of-sale and direc t mail -outs targeting relevant operators.  
Industry -led approach  
An alternative non -regulatory option is for organic industry representatives to take incremental 
steps towards more unified voluntary settings. Industry -led codes can help address specific 
market failures that cannot be addressed by individual industry participants.  
Under this approach, industry would first come together to develop a common understanding of 
the term organic and agreement on a single, voluntary standard . Breaches of the voluntary 
standard would be enforceable only to the extent that the industry includes an enforcement or 
compliance mechanism.  
This could be followed by further steps, such as agreement on unified branding around certified 
organic goods (transitioning f rom differing certifying body marks to a single logo). Depending on 
progress, the agreed upon standard and logo could also be endorsed by government, adding a 
further layer of assurance and confidence to businesses and consumers.  
Any industry -led approach would need to incorporate the interests of consumers and involve 
consultation with consumer representatives.  
Depending on the coverage or scope of an industry -led, voluntary standard, there could be fees 
for industry participants, or costs in establishing such a standard.  
Any competition implications of an industry -led approach would also need to be considered. 
Where conduct may contravene competition laws, but is likely to have an overall public benefit, 
there may be exemptions or authorisations available from the ACCC.  
Health Star Rating system case study  
The Health Star Rating (HSR) system is a front -of-pack labelling system that rates the overall nutritional 
profile of packaged food and assigns it a rating from ½ a star to 5 stars. It is designed to prov ide 
consumers with a quick, easy, standard way to compare similar packaged foods.  
The HSR system was developed by the Australian, state and territory governments in collaboration with 
industry, public health and consumer groups. The HSR system has been imp lemented on a voluntary basis 
by the food industry since June 2014, meaning that food manufacturers can choose to display or not to 
display a HSR on their product.  
The number of stars that can be displayed on a product is determined by the Health Star Rati ng Calculator, 
underpinned by an algorithm that was developed in consultation with  the HSR Technical Advisory 
Committee.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
11 Food manufacturers that display HSRs on their products are responsible for the correct and accurate use 
of the Health Star Rating syste m. This includes correctly calculating the HSR, accurately displaying 
nutrient information, ensuring consistency of information between the HSR and the Nutrition Information 
Panel, and complying with all relevant legislation and regulations.  
Responsibility  for HSR policy, including monitoring and compliance sits with states and territories and the 
Australia and New Zealand governments through the Food Ministers’ Meeting (FMM). While there is no 
specific enforcement legislation for the HSR system, Australian  Consumer Law protects consumers from 
false or misleading product representations, including those made through the HSR system.  
In May 2019 an independent review was conducted to examine its effectiveness of the HSR system in 
providing information to consu mers to help them to make more informed food purchases and healthier 
eating choices. The review examined the system after five full years of implementation.  
The review found that the HSR system was generally progressing well with uptake by food businesses 
increasing and consumer use and understanding improving. The review also found that there was 
evidence that the voluntary system was effective in changing consumer behaviour, and in some instances 
led to healthier product reformulation by food manufacturer s. Compliance with the HSR system was also 
found to be high.  
The review also recommended that the HSR System remain voluntary, but with clear uptake targets and a 
view to mandate if these are not achieved.  
The findings of the review were supported or suppo rted in -principle by the Australia and New Zealand 
Ministerial Forum on Food Regulation (now called the Food Ministers’ Meeting) in December 2019.  
 
Questions  
• Are there other non -regulatory options which should be considered which address the policy 
problem s? 
3.3 Mandatory domestic organics standard  
The main regulatory option identified is the introduction of a mandatory domestic organics 
standard through new standalone Commonwealth legislation. To understand the potential 
impacts of this approach, this sub -sect ion covers several design issues for public consideration 
including:  
• what products, processes, and businesses are within scope  
• how the standard could be implemented  
• how to check if businesses meet the standard  
• how to fund the standard, and  
• when/over what period it could be implemented.  
3.3.1 Coverage and scope  
Comprehensive coverage across the supply chain  
Adopting a defined organics standard  both exports and domestic systems could simplify the 
existing system by ensuring the same requirements app ly to all exported, imported and 
domestically sold organic products. Consistent with existing standards, coverage would extend Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
12 to the production, processing, transportation, labelling and importation of all organic agriculture 
(crops and livestock), aquacu lture, textiles, skin and beauty products, seed, and livestock feed.  
Split coverage across the supply chain  
An alternative option would be to split the production/manufacturing aspect of organics and the 
labelling aspect. For example, the production/manufa cturing could be regulated by government, 
with the labelling aspect captured under existing ACL  requirements.  
Partial/incremental coverage  
Another option is to limit or transition the kind of products the mandatory standard applies to. 
For example, it may be possible to start with fresh fruit and vegetables only or to exempt non -
food products when the standard is first introduced. Coverage could then be adjusted over time, 
using the initial phase as a pilot.  
Coverage by business size  
A further consideration  is whether to limit coverage by  the size of  a business. For example, the 
standard could be mandatory for larger businesses but voluntary or take a longer transition 
period for small or low risk businesses.  Small businesses could also be exempt from certif ication 
(see below at section 3.3.3).  
Questions  
• What organic products should be captured by a mandatory domestic organic standard (for example, 
fresh food, all food products, fibre, pet food, cosmetics or other non -prescribed goods)?  
• Which definition of or ganic ( National Standard, AS 6000 , or alternative) should be adopted as a 
suitable definition of organic?  
• Do you support a domestic organic standard covering the whole supply chain process, or splitting 
production/manufacturing and labelling aspects?  
• Are there parts of the sector (e.g., non -food, or small operators) that should be exempt from a new 
regulatory framework for domestic organics?  
3.3.2 Implementation  
The primary implementation option being considered is through new standalone 
Commonwealt h legislation.  
The Commonwealth would enact new legislation requiring organic operators to comply with a 
defined standard. This could proceed with or without a mandatory certification mechanism 
(refer sub section 3.3.3).  
Using a co -regulatory model, this c ould see certifiers responsible for monitoring and enforcing 
compliance of operators they certify, and the Commonwealth government responsible for 
monitoring and enforcing compliance in the marketplace to prevent misleading or false labelling 
claims for un certified projects.  
3.3.3 Certification  
Industry feedback indicates that being certified organic and displaying a certification label has a 
direct impact on the perceived benefits of organic food.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
13 Mandatory certification  
One option is to require all products tha t make an organic claim to be certified by an Australian 
Government approved certifying body against the mandatory standard. This could mirror the 
certification process currently used for organic exports under the National Standard, which 
includes regulati ng, investigating and enforcing compliance through regular checks, ongoing 
monitoring and enforcing compliance.  Under this arrangement, approved certifying bodies 
approve, conduct routine auditing, issue certification and carry out enforcement against 
oper ators they certify. The department is responsible for approving, auditing, and investigating 
compliance of certifiers.  
Mandatory certification could alternatively  be enforced on a more risk-based  model, with a 
sample of businesses audited periodically with frequency adjusted based on risk.  
Voluntary certification  
Independent certification could be voluntary for organic products intended for the domestic 
market. Businesses would still be subject to  enforcement action if it was shown that they were 
not meeting the mandatory standard.  
Exemptions  
If all businesses are included with in the  scope of a mandatory standard (see section 3.3.1), small 
businesses could be exempt from mandatory certification  but still required to comply with the 
definition of organic set out in a mandatory standard . This would account for business capacity 
to absorb associated compliance costs, noting all businesses would still be subject to 
enforcement action if they fail to mee t the mandatory standard. This approach has overseas 
precedent, with the United States and European Union allowing exemptions from verification 
based on annual turnover and whether the business sells direct to consumers respectively.  
Questions  
• If a mandato ry standard was to be progressed, how essential is certification?  
• If exemptions were introduced, how might these work in practice?  
• What exemptions should be in place for certification?  
3.3.4 Timing  
Experience with previous government reforms demonstrates the val ue of transition periods. For 
example, the Country of Origin Labelling reforms came into effect following a 2-year transition 
period, minimising implementation costs and allowing businesses to implement the reforms in 
an efficient manner.  
Australian busine sses have also experienced a multitude of hardships following recent bushfires, 
droughts, and the COVID -19 pandemic, making it impractical (and unaffordable) for some to 
consider additional costs in the near term.  
Questions  
• Is there value in a transition p eriod for business?  
• If so, how long?  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
14 3.3.5 Funding  
Any regulatory option will be developed consistent with the requirements of the Australian 
Government Charging Framework, noting the beneficiaries are likely to be organic businesses 
and consumers. The Framework  supports the government’s role in delivering quality public 
programs to Australian citizens, communities, and the economy more broadly, by assisting to 
improve program funding decisions.  
The Government’s Charging Policy Statement notes:  
Where specific dem and for a government activity is created by identifiable 
individuals or groups, they should be charged for it unless the government has 
decided to fund that activity. Where it is appropriate for the Australian 
Government to participate in an activity, it s hould fully utilise and maintain public 
resources, through appropriate charging. The application of charging should not, 
however, adversely impact disadvantaged Australians.  
The total cost of the regulation and method of charging would depend on the regula tory model 
chosen and which party is being regulated (certifiers or operators.)  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
15 4 What is the likely net benefit of 
each option?  
In deciding final policy settings, the Australian Government will consider feedback and 
consultation findings to date, submission s to this  Consultation RIS and a cost -benefit analysis, 
quantifying the potential impact of different options. For the purposes of the Consultation RIS, 
this section aims to identify key types of benefits, costs, and risks likely to arise along with who 
may be impacted.  
At a high -level, the range of stakeholders most likely to be impacted include:  
• government (including Commonwealth and state and territory regulators depending on the 
level and type of change from status quo, if any)  
• businesses across the sup ply chain (including producers/farmers, transporters, storage 
operators, processors/manufacturers, wholesalers, retailers, farmers' markets, exporters, 
importers, and certifiers)  
• consumers.  
Potential impacts will be felt differently across and within these groups. For example, within the 
business grouping, business size and certification status will have a major role in determining 
costs and benefits. For consumers, factors such as social -economic status are likely to influence 
potential changes in their purchasing behaviour. This will be subject to further consideration 
and analysis in the advice to government . 
4.1 Status quo  
The key benefit of this option is the absence of additional costs and regulatory burden that may 
arise from further government intervention. The organics sector may continue to grow under 
the status quo, with market forces left to address the policy problems. Operators looking to 
export to countries without equivalency a greements could continue do so through conformity 
assessments (noting the regulatory burden involved). Depending on the extent of the problems, 
along with potential costs and benefits of other options, this may be an appropriate outcome.  
A further consider ation is that the current state is subject to change. Market forces and growing 
consumer awareness may see improvements over time and the market will correct the 
information asymmetry.  
Conversely, as this option does not directly address the issues of regu latory fragmentation, 
impediments to trade, or consumer confidence, it may result in increased costs over time. This 
includes a possible decrease in consumer confidence, lost opportunities for market growth, and 
a reduction in the Australia’s organic secto r’s competitive advantage as other countries look to 
grow their organic sectors.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
16 4.2 Non -regulatory  
Education campaign  
Education and awareness raising could target the problems of consumer and business confusion, 
depending on the aim of the campaigns.  
For cons umers, this option could increase the awareness and understanding of the term 
'organic ', clarify some common misconceptions, and help them to make more informed 
purchasing decisions. Consumers would also be better positioned to identify and report 
misleadi ng claims.  
For businesses, an education campaign based on current settings may reduce confusion, 
highlight the benefits of voluntary certification, and increase their confidence in the certification 
process. As a result, operators may be more likely to mak e organic claims  where they are 
substantiated , seek certification, and avoid non-compliance  with general ACL protections. More 
informed consumers could also help improve the integrity of the market and weed out operators 
that are not as stringent or do not  meet existing voluntary standards.  
As with the status quo, an education campaign is unlikely to impose significant additional 
regulatory burden on business. Depending on the funding model (industry -led, government -led, 
or co -funded and delivered), this is  also likely to be a lower cost option.  
There are limitations on how this option will address the identified problems (particularly 
around impediments to trade). While the education campaign may clarify meanings and increase 
information flows, the overarch ing framework would remain fragmented. Depending on the 
magnitude of such problems, this non regulatory response may be appropriate, including as an 
initial step before regulation.  
Industry -led approach  
As with the education campaign, this option primarily  targets the problems of consumer and 
business confusion. The key difference is that rather than educating consumer about the 
fragmented framework that currently exists, it would go some way to simplifying the 
fragmented regulatory system.  
For consumers, t he move towards a consistent and unified logo for certified organic goods may 
increase their awareness and understanding of what certified means and what to look for when 
shopping. They may have added confidence in their purchases should the logo have gove rnment 
backing.  
For businesses, the shift to a single, voluntary standard  may simplify the process, decreasing the 
time impost and regulatory burden of accessing and understanding different standards.  
Like the education campaign, the main disadvantage of this option is its limitations and 
associated opportunity costs. For example, the continued absence of mandatory domestic 
requirements would prevent negotiations on equivalency arrangements with key trading 
partners. However, this option can be built on ov er time, with policy problems revisited once 
initial steps are complete.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
17 Questions  
• Do you think an education and awareness raising campaign would be a cost -effective solution to 
address consumer and business concerns?  
• Do you think an industry -led, voluntar y, single standard is achievable, and would it be a solution to 
address consumer and business concerns?  
• Could the non -regulatory options presented be combined and implemented, either with each or other 
or a mandatory domestic organics standard? If so, whic h elements should be combined?  
4.3 Mandatory domestic organics standard  
Cross cutting considerations  
There are upfront and ongoing costs to implement and maintain a mandatory standard, 
including additional resources for education, compliance and enforcement , making this a higher 
cost option than the alternatives considered in this paper . Funding arrangements will need to be 
considered, including cost recovery options that are consistent with the Australian Government 
charging framework . 
Introducing a mandatory domestic organic standard could simplify the existing system by 
ensuring that the same requirements apply to all exported, imported and domestically sold 
organic products, creating a level playing field across the organics industry.  
This approach would also limit the ability of unscrupulous operators to claim ‘organic’ status 
without adhering to industry agreed requirements, supporting informed decision making and 
consumer confidence.  
A mandatory domestic organic standard could also be use d to negotiate equivalence 
arrangements with key trading partners and improve market access , some trading partners 
have expressed Australia’s lack of a mandatory regime as a key reason for not negotiating 
equivalence arrangements . Noting that equivalence a rrangements cannot be guaranteed and 
may take several years to establish, such an outcome could reduce regulatory burden, with 
exporters no longer required to meet each country’s individual standard and bear the associated 
cost.  
Coverage and scope  
The leve l of coverage has implications around the number of businesses likely to benefit and 
incur any regulatory costs.  
A key benefit of comprehensive coverage is regulatory simplicity, with businesses and 
consumers better positioned to understand a single set of  requirements and standardised scope. 
Limiting coverage by business size has the potential to mitigate disproportionate regulatory 
burdens but would need to be balanced against issues of operational complexity, consumer 
confusion, and limits on equivalency  negotiations.  
Separating  production from labelling requirements could improve consistency in production 
requirements for the export and domestic markets  and limit regulatory burden for producers 
and operators who no longer face a system with multiple requ irements.  Locating regulation of 
labelling requirements with a regulatory body with expertise in these matters , or regulated 
under the existing ACL  could also lower costs for government . However, any distinct labelling Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
18 standard would need to refer back to the production/supply chain standard.  In addition, having 
multiple regulators for different aspects of a single scheme may reduce the efficiency and 
effectiveness of that scheme.  
Starting out with partial coverage, such as fresh produce only, could ensure steps in right 
direction but – like other approaches to limiting coverage – may reduce the short to medium 
term chances of new equivalency arrangements.  
Implementation  
Standalone legislation has the benefit of full coverage, flexibility, and being tailored  to industry 
needs. For example, the legislation could initially cover food and/or other agricultural products 
(including livestock feed), with an option to cover textiles, skin care and other organic products 
later.  
The existence of a mandatory standard m ay benefit some existing organics businesses over their 
competitors, or may lead some (good faith) organics businesses to exit the industry for a variety 
of reasons. The move to a single standard may also have an impact the business model of 
existing certi fied businesses.  
As a new framework, this option would require new compliance and enforcement resources, 
with associated costs.  
The particular terms and scope of a Commonwealth legislative framework would require further 
consideration.  
However, the legisla tion would not apply to New Zealand imports. Under the Agreement 
between the Government of Australia and the Government of New Zealand concerning a Joint 
Food Standards System (the Treaty) and the Trans -Tasman Mutual Recognition Act 1997  (the 
Trans -Tasman  Mutual Recognition Act) it is assumed that the Food Standards Australia New 
Zealand Act 1991 will be the sole piece of Commonwealth legislation providing standards 
governing the labelling of food, its production and its packaging. The objective of the Tran s-
Tasman Mutual Recognition Act is to harmonise food standards between Australia and New 
Zealand and to provide mutual recognition for each other’s goods. If New Zealand were to 
implement its own standard (as is currently underway), this is unlikely to lea d to additional 
costs.  
Certification  
Mandatory certification would provide evidence to consumers and trading partners that 
integrity underpins Australia’s organic industry. This would come with added costs, as all 
businesses, including those currently not certified, would have to pay to be certified under a 
mandatory scheme.  
Mandatory certification may also have competition implications (for example, certifiers may 
have a power imbalance over operators), create barriers to market entry, and put upward 
press ure on prices for consumers. For example, some operators may choose to exit the market 
rather than become certified while others looking to enter the sector may find certification cost 
prohibitive. This could also have flow -on effects to organic suppliers.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
19 For consumers, mandatory certification may improve the transparency and consistency of 
information, increasing their trust in organic claims and supporting informed purchasing 
decisions. The impact on consumer choice is open to discussion. Under one scena rio, mandatory 
certification could drive producers out of the market, reducing the range of products on offer. 
This could mean a trade -off, with less choice but a higher quality product. Conversely, the added 
regulatory certainty could attract new competit ion to the market, resulting in more choice for 
consumers.  
Smaller uncertified operators may have limited capacity to absorb additional pressures should 
mandatory certification apply to them. While this can be reduced through possible exemptions, 
such approaches may decrease Australia’s ability to negotiate equivalency arrangements, with 
trading partners looking for stringent domestic compliance requirements.  
Timing  
The key advantage of a transition period would be to give businesses ti me to understand new 
requirements and adjust their business models, potentially decreasing regulatory burden. This 
could be particularly beneficial to smaller producers, who may need added time understand any 
changes and incorporate them into their busines s model.  
Funding  
The total cost of the regulation will vary based on whatever regulatory model is picked. Higher 
effort regulatory models will require more financial commitment from the organics sector under 
a cost recovery mechanism.  
Questions  
• What would be the positive and/or negative impacts of a mandatory domestic organic standard on 
you or your business?  
• What are the positive and/or negative impacts of a mandatory domestic organic standard for 
Australian consumers?  
• Are there positive or negative impacts of any options that are not described?  
• Is there any evidence you can provide to help quantify the impacts?  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
20 Appendix A: Process to date and next 
steps  
Parts of the organics industry have long called for regulatory changes, raising concerns about the 
integrity of the domestic market.  
When the National Standard was first implemented in 1992 as the Australian Export Standard, 
the sector pushed for regulation domestically as well, but this was not realised.  
In 2006, discussions began around the development of an Australian Standard for organic 
products. After consultation throughout the organics industry an application was made to 
Standards Australia to create an organics standard. As a result, the AS 6000 was published in 
October 2009 as a volun tary domestic standard. A review of the Organic Orders in 2018 and the 
drafting of the Organic Rules 2021 did not recommend one standard over the other.  
In late -2020, an Organics Industry Advisory Group was established to provide advice to the 
Minister for  Agriculture and Northern Australia, the Hon David Littleproud MP, on options to 
improve the current domestic organics regulatory framework. The Group convened over the 
first half of 2021, providing a report to Minister Littleproud on 29 June 2021.  
The Gov ernment determined that further work is required, and the department is now 
undertaking public consultation to better understand the sector, articulate the problem 
definition more clearly, and understand the impacts of any reform options on all parties alo ng 
the organics supply chain, including Australian consumers. As part of this process, the 
department has received:  
• over 100 submissions to an online business survey, used to gather industry insights on the 
organics sector  
• over 500 responses to a targeted phone survey, used to gauge the number and nature of 
organic operators in Australia (including uncertified and smaller producers)  
• over 1000 responses to the online consumer survey, used to collate existing consumer 
perspectives on organics, alongside their  appetite towards changes to the framework  
• and over 100 businesses invited to industry roundtables, with 6 industry roundtables 
completed, and ongoing 1:1 meetings continuing.  
Results from these more recent consultation mechanisms are subject to further an alysis and will 
be used to inform the  advice to government . At a high -level, the culmination of all these 
processes informed the options detailed in this Consultation RIS.  
In late -2021, the department reconvened the Organics Industry Advisory Group to act as a 
sounding board for this project and facilitate broad consultation. Membership reflects a broad 
range of views across industry bodies, producers, manufacturers, farmers' markets, retailers, 
certifiers, consumers, importers and exporters.  
Next steps on this project are dependent on consultation feedback, outcomes of the CBA, and 
government consideration.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
21 Appendix B: Organic Standards  
Table 1 Organic standards  
National Standard for Organic and Bio -Dynam ic 
Produce  (National Standard)  AS6000:2015 - Organic and biodynamic products  
• Owned and managed by DAWE and with the 
National Standards Sub Committee (NSsC), an 
independent technical subcommittee.  
• Organic exporters must comply with the National 
Standard.  
• Provides the basis for equivalence arrangements 
with trading partners.  
• There are currently 6 approved certifying bodies.  
• The maintenance of the National S tandard  and 
oversight of the NSsC  will be funded by DAWE 
issued certifier accreditation fees  from FY 2022 -23. • Owned by Standards Australia.  
• Voluntary for domestic use.  
• Only one approved certifying body certifies to this 
standard.  
• Maintenance is funded through licence fees to access 
the standard.  
• Uses an associated control document (MP100).  
• Copyr ighted, with a fee required to purchase it.  
Note: Some of the larger certifying bodies maintain private standards based on the national standard. Some approved 
certifying bodies are also authorised to certify to the EU, US, Japanese, Korean and Chinese organic standards under a 
conformity assessment arrangement with those governments.  
 Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
22 Appendix C: Regulatory systems of  
comparable trading partners  
United States  
The United States National Organic Program (NOP) is a federal regulatory program that 
develops and enforces national standards for organically produced agricultural products sold in 
the United States. Third -party organisations are accredited to certify businesses meet the 
standard. The USDA and certifiers work together to enforce the standar ds. The NOP also 
authorises State Organic Programs, which provides the opportunity for a state to oversee 
organic production and handling operations within its state. California is currently the only state 
in the U.S. with a State Organic Program (SOP).  
Canada  
The Canadian Food and Inspection Agency (CFIA) regulates any food, seed, or animal feed that is 
labelled organic in Canada. All food sold in Canada must comply with Food and Drugs Act and 
Regulations and the Safe Food for Canadians Act and Regulations . Under the Safe Food for 
Canadians Regulations, products must be certified organic according to the Canadian Organic 
Standards. The CFIA oversees, monitors and enforces the requirements of the Canada Organic 
Regime using a third -party service delivery mod el that includes conformity verification bodies, 
certification bodies and organic operators.  
European Union  
EU Council Regulation 834/2007 previously set out the principles, aims and overarching rules of 
organic production and defined how organic products should be labelled. This regulation has 
recently been superseded by Regulation (EU) 2018/848 which came into effect on 1 January 
2022. Every country in the European Union appoints a 'competent authority' who is ultimately 
responsible for making su re that EU organics rules are followed. This competent authority can 
then chose whether this is managed ether publicly, privately or through a joint system. Each 
year EU countries report to the European Commission on the results of the controls carried out  
on organic operators and on the measures taken in case of non -compliance.  
China  
China's Organic Product Certification is a governmental program carried out according to the 
National Organic Standard GB/T19630 -2019. The standard is aimed at regulating the 
production and trade of organic products intended for the Chinese market. China classifies this 
standard and the accompanying certification regulations as voluntary. However, if products are 
to be marketed in China as organic, compliance with this standard  and accompanying 
regulations is mandatory.  
New Zealand  
New Zealand is in the process of introducing new legislation, Organic Products Bill 2020 (the 
Bill), to mandate organic standards for organic products. The Bill enables any relevant ministries 
to beco me responsible for the regulation of organic products relevant to their mandate, Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
23 including the development of organic production standards and the administration, monitoring, 
and enforcement of associated regulatory requirements.  Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
24 Appendix D: Comparison of options  
Table 2 Comparison of options  
Objectives   Regulation  Non -regulatory 
approaches   
 Status Quo  New mandatory 
legislation scheme  Education 
campaign  Industry -led, 
voluntary single 
standard  
Correct market 
failures (if any)  Potentially  Yes Potentially  Partially  
Regulatory clarity  No Yes No Partially  
Prevent false and 
misleading claims  No Yes Yes – Potentially, 
through better 
informed consumers  Partially  
Level playing field  No Yes No No 
Mitigate barriers 
to trade  No Yes No No – trading 
partners may 
continue to expect 
government, 
mandatory system  
Consumers access 
to better 
information  Potentially  Yes Yes Yes 
Consumer choice  No – No No 
Consumer 
protection  No Yes No No 
Cost  Low  High  Low  Medium  
 Domestic Organic Regulatory Fr amework : Consultation regulation impact statement  
Department of Agriculture, Water and the Environment  
25 References  
AOL 2021, The Australian Organic Market Report 2021 , Australian Organic Limited, Nundah , 
accessed 17 January 2022 . 
European Commission 2021, Organic action plan , Brussels, accessed  20 January 2022 . 
IBISWorld  2020 , Organic Farming in Australia , X0013 , Accessed 17 January 2022  
Willer, H, Meier, C, Schlatter, B, Dietemann, L, Kemper, L & Trávníček,  J 2021, 'The World of 
Organic Agriculture 2021: Summary' in H Willer, J Trávníček, C Meier & B Schlatter (eds), The 
World of Organic Agriculture Statistics and Emerging Trends 2021 . Research Institute of Organic 
Agriculture FiBL, Frick, and IFOAM, Organics International, Bonn, accessed 19 January 2022 .