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Opportunities and challenges for Australia's exports

Posted on 15th Mar 2023

Opportunities and challenges for Australia's exports


Exports generate hundreds of billions of dollars for the Australian economy, and a range of agencies and initiatives help facilitate this trade. These include Export Market Development Grants (EMDG), which provide financial assistance to exporters; the Australian Trusted Trader (ATT) initiative, to streamline border processes for exports; and support from federal, state and territory agencies both in Australia and internationally.


Free Trade Agreements (FTAs) create further opportunities for exporters. At the same time, the number of (and interaction between) bilateral and multilateral FTAs can lead to additional regulatory complexity. Non-tariff barriers (NTBs) are also potential impediments to export, particularly as tariff related barriers have been progressively reduced.


Australia’s export regulatory framework aims to maintain the quality and consistency of Australia’s exports while avoiding unnecessary costs and burden on business. Regulations differ based on sector requirements and risks, with agricultural products often being subject to a range of regulatory and biosecurity related processes.


The opportunities for future growth in Australia’s exports are immense and reflect changing global trends, expanded market access, new technology and innovative products. Taking advantage of these opportunities will require collaboration across industry and government; investment; and a continued commitment to open trade.

Government grants and support for exports

As was outlined in Chapter 1, a number of Australian Government agencies, as well as the state and territory governments, support Australia’s trade and investment growth. Inquiry participants drew particular attention to the EMDG and ATT initiatives, and the support provided to business through the Australian Trade and Investment Commission (Austrade) and the Department of Foreign Affairs and Trade (DFAT). These issues are outlined below.

Export Market Development Grants

The Australian Government’s EMDG scheme provides financial assistance for current and aspiring exporters, in order for them to ‘increase international marketing and promotion expenditure to achieve more sustainable international sales.’1 Austrade stated that the scheme:

‘encourages small- and medium-sized Australian businesses to develop export markets;

reimburses up to 50 per cent of eligible export promotion expenses above $5000 provided that the total expenses are at least $15 000; [and]

provides up to eight grants to each eligible applicant.’2


The Export Consultants Association (ECA) advised that the EMDG scheme had assisted over 100 000 small to medium sized enterprises (SMEs) since it began in 1974, and that some of these SMEs subsequently became the ‘biggest names in their industry sectors.’ The ECA consequently described the EMDG scheme as ‘the most successful economic stimulus initiative ever introduced into the federal parliament.’3


The ECA further explained that the EMDG scheme presented value for money, as the ‘export income derived by EMDG applicants per $1 of EMDG paid is over $40.’4 The Export Council of Australia (Export Council) was also supportive of the EMDG scheme and stated that it was ‘a vitally important program to give Australian businesses confidence to export.’5


In the 2019-20 Budget, the Australian Government announced a funding increase of $60 million over three years for the EMDG scheme. This brings the total annual spend on the EMDG scheme to $157.9 million.6 DFAT and Austrade explained that demand for EMDGs has been increasing in recent years, and as ‘the budget for the scheme is fixed every year … the rise in demand affects the final payment to businesses.’7


The ECA and the Export Council both welcomed the funding increase, but stated that it is insufficient to meet current and future business demand.8 The Export Council further noted that the low Australian dollar will increase demand for the EMDG, further widening the gap.9 The ECA estimated that by June 2020, the ‘deficiency will be in the region of $70 million to $80 million.’10


A funding shortfall may create uncertainty for businesses participating in the scheme, as they may not receive the amount of EMDG funding that they had expected. The ECA outlined this scenario further and stated that in the EMDG scheme:

… people put their hard-earned money on the line on an understanding that the government has offered a rebate of 50 per cent. They put in an annual application … to find out that when Austrade has assessed it virtually 12 months later there's not enough money to pay them. The upfront component is guaranteed—presently $40 000. The maximum benefit is $150 000. The grants above $40 000 last year were paid out at 24.6 per cent. A small business person at Airlie Beach with a tourism operation may have spent a lot of money on marketing and advertising to try to get people to come to Australia. They have an expectation in their cash flow of some level of recovery. If they find that they're going to get 24.6 per cent, it would be a pretty bitter pill to swallow.11


To address this, the ECA recommended funding for the EMDG be increased by an additional $60 million a year.12 The ECA further stated that the EMDG scheme had been shown to have a ‘multiplier of $7 to $1’, so it is estimated that the extra $60 million would generate a $420 million in economic activity. The ECA also highlighted that the business generated by the EMDG scheme, and the associated tax paid, lowers the overall cost to government. The ECA advised that:

… additional business generated by export grants almost covers the cost of the program through additional tax revenue. So the net cost to the government purse at the end of the day is negligible, and that's not taking into account the tax benefits that flow in subsequent years.13


Australian Performance Vehicles (APV) raised concerns that it was ineligible for EMDG funding due to its previous owners having already claimed under the EMDG scheme in the 1980s. The APV stated that this should be irrelevant as the company is under new ownership and would benefit from the EMDG scheme. APV explained:

As a result of purchasing the company from an international company—they were excluded after 11 EMDG claims … in 1987-88. That has got no relevance to my business today—none at all. Something which happened nearly two decades ago prevents me now, as an Australian company, from getting government support to put local resources on the ground overseas.14


To address this, APV recommended that the eligibility guidelines be amended to allow participation of companies such as APV. APV further outlined the benefits that the EMDG scheme could have to a small business, particularly through providing financial support for developing overseas relationships and contacts in new markets.15


In October 2019, the Government announced an independent review of the effectiveness of the EMDG scheme and government financial assistance to SME exporters, with a report due in March 2020.16


On 1 April 2020, the Australian Government announced a funding increase for the EMDG scheme of $49.8 million for the 2019-20 financial year. This will bring total EMDG funding for that period to $207.7 million, which the government stated was the highest EMDG funding level in over 20 years.17

Australian Trusted Trader

The ATT initiative is administered by the Department of Home Affairs and the Australian Border Force (ABF).18 The Department of Home Affairs stated that the ATT:

… accredits Australian businesses that demonstrate both secure supply chains and compliant trade practices, and rewards them with trade facilitation benefits. ATT is part of an internationally recognised network of Authorised Economic Operator programs and provides a mark of trust with customs administrations globally.19


Benefits of the ATT initiative include:

‘simplified access to market, such as priority treatment of goods at the border, or access to Mutual Recognition Arrangements with other economies;

streamlining red tape, including duty deferral, streamlined cargo reporting, and simpler access to the Temporary Skills Shortage visa or [Asia-Pacific Economic Cooperation] travel card; and

opportunities to work in partnership with Government.’20


As at 5 September 2019, there were 482 accredited trusted traders, with ‘many more coming forward through the application process.’21


BDO (East Coast Partnership) considered that the ATT initiative is ‘an excellent example of the kinds of initiatives that can improve the Australian trading system’ and described it as a ‘roadmap’ for broader regulatory reform to support and boost Australia’s international trade.22

Austrade and DFAT support

Austrade is Australia’s ‘official trade and investment promotion agency’, which provides services to Australian businesses looking to enter or expand into global markets, and assists in attracting foreign direct investment to Australia.23


The Australian Investment Council (AIC) considered that the role of Austrade could be expanded to provide a ‘tailor-made approach’ for large, mature and high-growth companies to expand into overseas markets. The AIC stated:

As companies grow, their capabilities and specific needs become more varied and complex. Enabling Austrade to provide a focused service approach to these companies, in terms of export know-how and investment readiness, would be one way of meeting those needs.24


DFAT and Austrade advised that Austrade was currently ‘developing a dedicated, longer-term support program for those exporters, customers and investors with the greatest potential to contribute to Australia’s economic prosperity.’ The first trials of this specialised approach, which was aimed at exporters expanding into new markets, began in May 2019.25


The Export Council stated that Austrade had experienced ‘declining resourcing for many years’, despite an increase in its responsibilities. The Export Council considered Austrade as ‘critical’ to Australian export businesses and stated that ‘any serious attempt to grow or diversify Australian exports must include better resourcing [of] Austrade.’26


APRA AMCOS commented that, while it had a positive relationship with DFAT and Austrade in key international posts, it found it ‘difficult … to get strategic priority overall from DFAT’ in relation to the music industry. APRA AMCOS stated this was in contrast to equivalent departments in other countries, such as the United Kingdom (UK), Canada, Korea and France, where there is greater investment in supporting music exports.27


To address this issue, APRA AMCOS recommended that DFAT (in consultation with government agencies and industry) develop a ‘Cultural Export Strategy’ to ‘ensure that the policy settings are right for Australia to fully realise our cultural export potential, particularly in music.’28

Free Trade Agreements
Benefits of FTAs

DFAT and Austrade advised that Australia’s FTAs have ‘high rates of business utilisation’29 and outlined that FTAs can benefit exporters by:

creating a competitive edge for their goods and services exports, including through e-commerce;

providing access to a wider range of more competitively priced imports;

deepening their engagement in global value chains;

safeguarding against protectionist tendencies in other countries;

improving access to overseas investment capital and new technologies; and

providing new growth and employment opportunities.30


Sectors such as medicines and agriculture outlined the importance of free trade to supporting their exports. Medicines Australia particularly supported FTAs with ‘high growth economies in the Asia region, which are major export destinations for medicines and vaccines.’31 The National Farmers’ Federation (NFF) described FTAs as critical to Australian agriculture, as many other countries have subsidies and protections for their domestic industries which FTAs can help address.32


Whilst highlighting the broad benefits of free trade, DFAT and Austrade acknowledged that it can be ‘difficult’ to assess the benefits of a single FTA due to the range of other factors in the international trading environment. DFAT stated:

It's very difficult to disaggregate the impact of an FTA from all of the other variables moving around—exchange rates, capacity to supply, whether there are non-tariff barriers, changes in income in the target country. … you can look at the impact of trade and investment as a whole on the economy, but to isolate the impact in a backward-looking sense from a particular agreement, or to compare the impact of two agreements, is very difficult.33


In contrast, the Australian Chamber of Commerce and Industry (ACCI) recommended that the Australian Government conduct economic assessments of existing and proposed trade agreements, to ‘ensure they are delivering (or likely to deliver) economic benefits to Australia.’34 The Productivity Commission (PC) similarly called for assessments of proposed trade deals during early stages of the negotiations.35


To further ensure that the business benefits of trade agreements are realised, ACCI encouraged the government to ‘provide greater access [for business] at an earlier stage to the negotiating process’.36

Challenges for businesses utilising FTAs

Australia currently has 13 FTAs in force with 20 partners, of both a bilateral and regional nature.37 ACCI stated that the ‘compounding development of bilateral and regional preferential trade agreements’ has led to a ‘build-up of “red tape”’ for business.38 Medicines Australia similarly stated that in some instances, Australia has ‘multiple agreements with the same country’, which can create a regulatory barrier for exporters.39


To reduce regulatory complexity, ACCI recommended that the government undertake a ‘stocktake’ in order ‘to consider the value of maintaining bilateral preferential trade agreements where the same nations are party to wider regional agreements.’40 ACCI also commented that ‘harmonising common elements in existing FTAs’ would help reduce NTBs.41


SMEs may find it particularly difficult to navigate any regulatory complexity associated with exports and trade agreements. The Department of Industry, Innovation and Science (DIIS) stated that this is reflected in disproportionately low number of SMEs that engage in export. As such, DIIS stated that it was working across government to ensure these challenges were considered as part of FTA processes.42


The Export Council similarly highlighted that businesses require assistance to understand and utilise FTAs.43 ACCI agreed and recommended that:

The Australian Government continue to collaborate with industry representatives, including ACCI and its members, to develop and deliver resources for SMEs to capitalise on FTAs and boost exports.44


DFAT acknowledged that ‘FTAs are complicated instruments’ that can be difficult for SMEs to get across the detail. To assist, DFAT highlighted the FTA information seminars that it and Austrade deliver around the country.45 DFAT also drew attention to the FTA Portal, which is ‘designed to be a very easy-to-use online interface if you’re a small exporter wondering about what the different FTAs are.’46

Priority FTA negotiations

Broad multilateral trade agreements were described as the ‘best approach’ by the PC. Current global trade tensions, however, may make it difficult to achieve the broad consensus needed for multilateral agreement. In this context, the PC stated that ‘many countries are negotiating on a bilateral basis to make progress where they are able.’47


DFAT acknowledged that Australia has expanded its number of bilateral FTAs and highlighted that the benefits of these sometimes exceed that of multi-party negotiations, particularly on market access. At the same time, DFAT stated that it is also progressing multiregional agreements. Overall, DFAT concluded that there were ‘pros and cons’ to both approaches.48


Trade agreements that were put forward as priorities for Australia included:

Indonesia-Australia Comprehensive Economic Partnership Agreement49;

Regional Comprehensive Economic Partnership50;

Australia-European Union (EU) FTA51; and

Australia-UK FTA.52


The Australian Government aims to have 90 per cent of Australia’s two-way trade covered by FTAs by 2022.53 Medicines Australia questioned what the next steps for boosting Australia’s exports will be once this goal has been achieved. In particular, Medicines Australia stated that Australia’s FTAs may need to be updated and harmonised.54


DFAT advised that where possible, Australia ‘reviews FTAs in force with partner countries to upgrade the benefits Australian businesses obtain from these agreements.’55


Export-oriented industries put forward recommendations regarding FTAs that related to their industry. This included:

Sugar: The Australian Sugar Milling Council (ASMC) stated that the sugar industry had ‘missed out on some of the benefits obtained for Australian agriculture in agreements with the United States (US) and China.’ As such, the ASMC recommended that Australian raw sugar be a ‘beneficiary of future negotiations’ with these countries, the UK and the EU.56

Pharmaceuticals: Medicines Australia stated that any pharmaceutical chapter included in FTAs should ‘seek alignment with the recently implemented Medicines and Medical Devices Review reforms.’57

International education: Universities Australia recommended that bilateral negotiations be used to advocate for the ‘easing of impediments to transnational education.’58

Music: APRA AMCOS recommended that all trade agreements should ‘facilitate export of services and seek to remove potential barriers to cross border administration of copyright in digital services.’59


The New South Wales (NSW) Government provided in-principle support for increasing the number of Australian FTAs60, particularly those that:

remove or reduce tariffs and unnecessary regulatory and technical barriers;

‘require trading partners to be more transparent with regulatory and technical requirements to reduce risk of non-compliance and make trade easier’;

‘necessitate compliance with relevant product safety and sanitary and phytosanitary requirements’; and

‘balance certainty for investors and protections for governments with respect to dispute settlement mechanisms.’61


The Business Council of Australia (BCA) also supported the progression of FTAs that eliminate tariffs (as far as possible). The BCA further listed provisions that should not be included in FTAs and recommended that:

‘FTAs should not include provisions on geographic indicators that are contrary to free and open trade’; and

‘FTAs should not require Australia to observe foreign labour and environmental provisions.’62

World Trade Organization

The PC stated that the World Trade Organization (WTO) was facing ‘long‑standing and escalating challenges’ that needed to be resolved.63 The PC recommended that Australia continue to work with other countries on these challenges, and also suggested that:

There is a need to reinvigorate the negotiation function of the WTO, including plurilateral, sectoral and regional agreements that allow, or work towards ‘most favoured nation’ treatment and resolving the deadlock on ‘special and differential treatment’. There is also a need to strengthen compliance with notification procedures and review and refresh the rules to handle issues relating, inter alia, to state owned enterprises, regulatory cooperation, digital trade and intellectual property.64


The NFF was similarly ‘concerned about what’s happening in the WTO, particularly with the dispute settlement system.’65 The NSW Government recommended that the Australia ‘continue to work with [its] international partners to reinvigorate the negotiation function of the WTO.’66 The NFF also encouraged the government to ensure agricultural subsidies are on the agenda at the WTO.67

Co-production treaties

Screen Producers Australia (SPA) highlighted Australia’s co-production treaties as having a ‘vital role’ in the export of Australian screen content. SPA further outlined the importance of co-production treaties and stated that:

… the screen industry is increasingly a global business and requires access to global finance and global partners. Screen businesses require significant and often prohibitive sunk costs of time, resources and capital to build the skills, capabilities and overseas networks needed for export sales and co‑productions. Co-production treaties allow Australian producers to partner with producers from treaty-countries to access the benefits of each country’s regulatory and taxation environments.68


Australia currently has co-production arrangements with 12 countries. SPA compared this to other nations, noting that China has 16 treaties, France has over 30 treaties and Canada has over 60 treaties. SPA recommended that the government facilitate Australian co-productions, including pursuing a co‑production agreement with the EU.69


The Export Council described Australia’s exports as ‘too small and too concentrated.’ The Export Council elaborated that Australia is:

… well under the [Organisation for Economic Cooperation and Development (OECD)] average for export intensity. What we do export comes from a small number of businesses selling a small number of commodities, and those sales are disproportionately to one market. Too few Australian SMEs export. This needs to change.70


The Export Council recommended that the Australian Government ‘set a policy of diversifying Australia’s trade (the destinations, industries and the businesses) and develop an overarching strategy to achieve this diversification.’71


Australia’s infant formula industry provides an example of a concentrated export market, with 90 per cent of exports in this sector going to China.72 The Infant Nutrition Council (INC) stated that it can be difficult to convince exporters to look to other markets when they are ‘doing so well’ in this country. The costs and resources needed to enter other markets and understand their differing regulatory systems is also a potential barrier. The INC suggested the government could assist by continuing to smooth pathways into other markets, including through export assistance programs.73


A similar industry experience was put forward by Australian Grape and Wine (AGW), which stated that the Australian wine sector was currently ‘overexposed to China.’74 The AGW stated that this reliance was concerning as growth in the China market is ‘slowing’, as it is ‘reaching a developed market stage.’75


The AGW attributed this exposure to a range of factors, including:

Traditional markets for Australian wine (such as the UK and the US) ‘dropping off’, at the same time demand in China was increasing;

The Australia-China FTA increased awareness amongst Australian winemakers of the opportunities in China;

A large number of entrepreneurs have wine made under contract to export specifically to China;

China being a ‘high-value’ market for Australian wine; and

A global trend of exporting wine to China.76


To diversify the export markets for Australian wine, the AGW pointed to South-East Asia as a potential export opportunity. The US was another market with ‘enormous growth potential.’77 Factors inhibiting winemakers from diversifying included NTBs and ‘differing standards around the world.’ In addition, the AGW explained that the focus on China is in large part ‘self-inflicted’ by the industry, as ‘everyone’s making money there.’78


DFAT outlined that growing global trade tensions and protectionism have made it ‘even more important for Australia to expand and diversify market access.’79 To assist Australian businesses to access new markets, DFAT and Austrade pointed to the Government’s goal for FTAs to cover 90 per cent of Australia’s two-way trade by 2022.80 The NFF also emphasised the importance of FTAs to support diversification and stated that:

… exporters know we need to diversify our markets. When one shuts, we need to be able to pivot. That is why some people said, 'Why [are] you so worried about the Peru FTA? Why is that a priority?' While we don't do a lot of trade with Peru now, when one market closes or consumers change taste, we have to have access to these markets and we need access to as many markets as possible.81


India was put forward as a substantial opportunity to diversify Australia’s export markets, particularly for the education, tourism, resources and energy and agriculture sectors.82 Austrade also advised it was looking to increase its resources into Java, which it described as the ‘economic powerhouse of Indonesia.’83


To assist and motivate businesses to diversify their export markets, Austrade further stated that:

… one of the most powerful things [the government] can do is advocacy so people think about more than just one market—that market may be the US, China or Europe. We can actually play the role of supporting industry by advocating for them to genuinely diversify their business.84

Non-tariff barriers

As trade agreements have progressively reduced tariff-related barriers, NTBs have become a ‘higher concern’ for many industries.85 DFAT and Austrade defined NTBs as ‘any kind of “red tape” or trade rules that unjustifiably restrict the flow of goods and services’, and stated that they may cost industry up to ‘three times more than tariffs.’ 86


The Red Meat Advisory Council (RMAC) described the impact of NTBs and stated that they can:

… unreasonably and unjustifiably restrict or prevent trade, increase the cost of preparing a product, increase the cost of supplying a product, diminish product returns, require conditions which exceed commonly accepted standards, or add to administrative burden.87


DFAT and Austrade stated that ‘the Government is working to ensure that gains made through FTAs are not eroded by NTBs.’88 As such, in 2018 the Australian Government launched its NTB Action Plan, which outlined a ‘whole-of-government strategy to remove NTBs hampering our exports.’ DFAT and Austrade stated that the NTB Action Plan:

… was developed in close consultation between industry and government and provides Australian businesses with improved access to report barriers through the online NTB Gateway (at, better coordination between government agencies through a multi-agency NTB Coordination Team in DFAT, and greater transparency of government actions on NTBs.89


DFAT advised that since launching the NTB Action Plan and the NTB Gateway, over 300 potential NTBs affecting Australian exports had been identified. DFAT explained that it was working across government to use this information to ‘devise strategies, in partnership with industry, to reduce or remove NTBs.’90


RMAC stated that once NTBs have been identified, the government’s focus (and additional funding) should ‘be on how to find solutions to resolve’ identified NTBs, particularly those with ‘industry-wide implications.’91 The Export Council was also of the view that ‘government leadership is essential’ to reducing NTBs, as is partnership between government and industry.92


The Department of Agriculture highlighted that importing country requirements make up a large part of the ‘regulatory impost on agricultural exporters.’93 The Cooperative Bulk Handling (CBH) Group agreed and stated that over 50 NTBs had been identified in more than 15 importing countries that impact the grain sector. CBH Group suggested that ‘any inroads that the Australian government can make with those key importing countries can be very significant for the industry.’94


The NFF recommended industry work with the government to ‘establish globally accepted product certification processes.’ This would address NTBs that agricultural producers face when entering other markets, particularly when product certification processes are ‘changed in order to protect domestic producers.’95


The Department of Agriculture advised that addressing NTBs, particularly those related to biosecurity, food safety and technical barriers to trade, was ‘core business for the department’.96


ACCI was supportive of the government’s efforts to reduce NTBs for exports, but recommended that these efforts also be applied to imports. ACCI stated that it would like to see:

… a horizontal consolidation of NTB assessments in Australia, both for imports and exports, so that if you're an exporter or an importer or you're doing both you know that you have a one-stop shop to go to when you're reporting something that's going wrong at the border crossing that you didn't expect. There are always things that go wrong at the border crossing that we didn't expect. … Australia has an opportunity to capture that in a horizontal sense across all its departments.97


ACCI further proposed that states and territories be involved in the process of improving regulatory arrangements for imports and exports, to ensure the approach is harmonised.98

Regulation of exports

DFAT and Austrade highlighted that ‘Australia’s strong regulatory frameworks can be a competitive advantage for our exporters and they contribute to our attractiveness as an investment destination.’99 On the other hand, DIIS cautioned that ‘inefficient regulation can impose a significant cost burden on business.’100


DFAT stated that ultimately:

The challenge for any government is to deliver effective and efficient regulation and regulatory frameworks … that impose the least necessary burden on business, exporters and investors.101


The PC categorised key regulatory barriers to export as including: ‘nuisance elements to regulatory compliance’, such as being paper-based instead of digital; and ‘approaches that aren’t always … risk based’ and take a ’one size fits all approach’. The PC added that regulator ‘behaviour’ or ‘culture’ can also be a factor.102


The Export Council described Australia’s export regulations and administration as ‘inconvenient, complicated and costly’, which may impact on Australia’s competitiveness and the ability of businesses to enter export markets.103 The Export Council recommended export regulation be reviewed to ‘re-evaluate what is regulated, why it is regulated and how it is regulated.’104 In addition, the Export Council recommended that the Minister for Trade and DFAT be given ‘a mandate to coordinate and oversee all trade-related activities across government’, as this could help streamline regulations across departments and jurisdictions.105


DIIS stated that the Australian Government is focusing on regulatory reform and has set up a taskforce to identify and address regulatory barriers to investment for select industries. DIIS further explained that the Government:

… seeks to tackle the costs of regulatory compliance and processing of cumulative regulation, and disincentives to invest and innovate. An important element of this is working with business to identify and remove unnecessary barriers. The [deregulation] agenda aims to reduce barriers to business to enable them to grow and increase their productivity.106


DFAT highlighted that it, along with Austrade, conducts ‘regular outreach to business to better understand how Australia’s domestic regulatory settings affect our export competitiveness.’107 Business feedback provided to DFAT and Austrade included that there is ‘too much information from too many sources’, leading to ‘information overload.’ The online Global Business Support Finder was introduced for service exporters in response to this issue, as it ‘helps new or existing services exporters find the right information to make an export decision.’108


The Greater Whitsunday Alliance (GWA) and Regional Development Australia – Mackay Isaac Whitsunday (RDA-MIW) emphasised that any new regulation considered by government should be effective, proportional, and accompanied by a regulatory impact statement. This consideration may include conducting a risk analysis, cost-benefit analysis, the measuring of business compliance costs and assessment of the effects on competition.109


The importance of harmonising standards, both nationally and internationally, was highlighted by Standards Australia. Standards Australia stated that the ‘development and adoption of standards in Australia enables trade and growth’, and recommended the government consider ‘an integrated standards development roadmap.’110


DFAT and Austrade similarly advised that services exporters highlight a ‘lack of industry participation in setting international standards’ as a key impediment to export.111 In addition, service exporters identified that ‘multiple professional registration and licencing requirements vary between Australian jurisdictions’, which can add to business costs.112

Customs, borders and biosecurity
Border issues

Australia’s customs arrangements were described by the BCA as complex and antiquated.113 The Department of Home Affairs and the ABF highlighted similar feedback it had received from exporters regarding the export process, which related to:

complexity of processes;

multiple regulatory agencies with fragmented systems;

a lack of consolidated digital information on trade requirements;

complex legislative requirements, with approximately 200 pieces of legislation across multiple government agencies; and

manual and inconsistent data requirements across government.114


A 2019 World Bank report compared regulations related to business activity in 190 countries, including regulation related to trading across borders.115 DFAT and Austrade stated that this report:

… ranked Australia 18th overall, but Australia ranked 103rd in the ‘trading across borders’ measure. This was down from 27th position in 2010. The report found Australia’s ‘cost to export’ is six times higher than the OECD average and ‘cost to import’ is around five times the OECD average. Australia’s ‘time to export’ is about three times the OECD average and ‘time to import’ is around 3.5 times the OECD average.116


In response to exporter feedback, the ABF advised that it had undertaken a whole-of-government review of border permits.117 The Department of Home Affairs and the ABF stated that the resulting report will recommend opportunities for:

enabling better information sharing between border agencies to assist with removing barriers for international trade;

effective regulatory models that would simplify, reduce government intervention, and reduce regulatory burden associated with permits for prohibited goods;

simplifying and streamlining processes related to prohibited and licenced goods;

effective regulatory frameworks for introducing, updating or amending import and export prohibitions; and

effective outcome-based approaches to improve the process for evaluating import or export prohibitions.118


To reduce regulatory complexity, the BCA recommended a ‘single window’ be introduced, which would be ‘one online access point to provide all necessary information’. The BCA stated that a single window ‘would make exporting and importing simpler, eliminate duplication and reduce business costs.’119 ACCI recommended that the development of a single window should be done in consultation with peak bodies and industry.120


DFAT and Austrade highlighted that markets including Singapore, Hong Kong and New Zealand were implementing ‘single window’ initiatives. DFAT and Austrade noted that they would continue to work with the relevant agencies to ‘develop practical initiatives, such as a single window for digital trade documentation, to lower compliance costs for exporters.’121


DFAT and Austrade also pointed to Austrade’s development of a Trade Information Service, which is ‘an online platform to provide consolidated information for food exporters on how to export, including various regulatory and border compliance procedures.’ DFAT advised that this ‘prototype will build towards a “single-window for trade” that aims to streamline export processes.’122


RMAC highlighted the importance of Australia’s biosecurity framework for maintaining food safety and Australia’s security and stated:

Biosecurity is a core part of maintaining access and defending our borders; it is critically important for market access, productivity and food safety. Risks must be minimised and the integrity of our environments, livestock and crop health status must be protected through a robust and properly funded biosecurity protection regime.123


Australia’s biosecurity arrangements also support its international reputation as a ‘supplier of high quality agricultural exports.’124 The Department of Agriculture stated that it was ‘committed to protecting Australia’s biosecurity status which also provides an advantage in a global trading environment, particularly to premium protocol markets in Asia.’125


To enhance Australia’s biosecurity, RMAC recommended a biosecurity funding package be made available to ‘assist in the delivery of well-funded, science-based biosecurity and quarantine systems, involving stronger border protection protocols and effective disease outbreak response mechanisms.’ RMAC also recommended increased training for inspection officers at border ports and airports and an increase in the number of detector dogs.126


The GWA and RDA-MIW similarly recognised the importance of biosecurity, but stated that Australia ‘should also be evaluating new innovative technology and solutions which may allow for importation of products with lower risk and cost.’127


The Department of Agriculture explained that risk-based regulation balances risks with efficiency and highlighted that:

Investment in risk-based import regulation will continue to balance the need to protect Australia's biosecurity status while regulating trade in ever-increasing volumes and complexity. Contemporary and more responsive at-border screening processes are a key element of this risk management approach and validation of technological innovations will ensure timely and safe access to these critical business inputs for the sustainability and productivity of Australia's export sectors.128

Regulation of agricultural and food exports

The Department of Agriculture highlighted that Australia’s regulatory framework for agriculture provides trading partners and consumers with confidence that Australia’s products are safe and of a high quality, and also facilitate market access for exporters.129 At the same time, the Department of Agriculture stated that it was working to improve the regulatory environment by improving industry engagement, streamlining regulatory requirements where possible, and reviewing regulatory effectiveness.130


The costs associated with regulatory compliance were raised as a barrier to export in the agricultural sector. The Export Council put forward regulatory barriers as including:

‘the cost burden of becoming accredited for agricultural exports’, particularly for SMEs;

the regulation of composite goods, which have ‘lower risks’ than simple animal products but ‘are regulated in exactly the same way’; and

the cost of certificates required for shipments.131


The Export Council also considered that the Department of Agriculture is focused on cost recovery, which is an impediment to lowering costs and streamlining processes.132 RMAC similarly recommended that the government ‘ensure that its cost-recovery policy does not result in a self-imposed NTB on trade, by making Australian exports less competitive.’133 The NFF expanded on this concern:

… cost recovery is an issue … Many of our competitors don't pay those costs to government. Governments just provide the service. Those sorts of things undermine our competitiveness—the paperwork required to get all the biosecurity certifications and the rules of origin to comply with free trade agreements. All of that paperwork makes it difficult, particularly for small producers, to try and become exporters, which is something that we are trying to encourage.134


In contrast, the Department of Agriculture noted that ‘fees and charges for many of our export regulatory functions have not increased since 2011 and have not kept pace with the scale of exports, nor the increasing complexity of importing country requirements.’ The Department of Agriculture stated that it would be consulting industry on new cost recovery arrangements.135


The Department of Agriculture also stated that it was aware of ‘industry concerns around layers of current regulation at both the federal and state level increasing the burden on business.’ In response, the Department stated that it had:

… been tasked by the Minister for Agriculture to continue to engage with stakeholders and with our state and territory counterparts to provide advice to government as to the options available to address these situations where identified.136


The Insurance Council of Australia (ICA) recommended that the government consider supporting agriculture insurance schemes. The ICA stated that these have been used in the US, Canada and Europe, with positive results:

Crop insurance schemes in these markets have increased productivity across the agricultural sector, encouraging farmers to take additional actions to increase export yields, safe in the knowledge that if crop failure occurs they will at least be in a position to recoup input costs and begin again at the start of the next season.137


Industry and business perspectives on regulation in the agricultural and food sector included:

Red meat and livestock: RMAC stated that ‘Australian meat processors currently operate in the most expensive regulatory system in the world’, with ‘duplicate layers of legislation and regulation’. To address this, RMAC recommended a reduction in red tape and regulatory creep; harmonisation of regulations across local, state and federal jurisdictions, and incentives for cost efficiency and innovation amongst regulators.138

Sugar: ASMC outlined that the sugar industry faced a ‘growing regulatory burden and associated costs’139, with marketing, electricity, water, environmental management, port access and transport being particularly costly for the industry.140

Seafood: The Western Australia (WA) seafood industry was described as being ‘mired in … red tape’ and that the management of regulations was ‘outdated’. As such, a review of the regulatory framework for the seafood industry was recommended.141

The Queensland Seafood Industry Association (QSIA) similarly stated that its state regulator’s ‘sole focus … is the regulation of the industry, not the development of that industry.’ In particular, the QSIA stated that that stable and ongoing access to fisheries was needed before seafood businesses (particularly SMEs) could consider expanding into exports.142

Grains: CBH Group put forward that ‘unnecessary regulation in agricultural export supply chains invariably leads to increased costs, inefficiencies and market distortion.’ CBH Group recommended unnecessary regulation for the grains industry be removed, including a transition towards the repeal of the wheat port code and increased flexibility relating to environmental permits.143

Animal feed: Speciality Feeds, a manufacturer of feed for laboratory animals, stated that the annual cost of $3000 to become export registered was a ‘barrier to entering the export market.’144 The NSW Government also considered that ‘the cost of export accreditation for specific agricultural products’ was a regulatory barrier.145 Speciality Feeds recommended a lower cost registration be introduced, or that other accreditations be taken into account to reduce the registration cost.146

Infant formula: The INC explained that the Australian regulator prohibits ‘plain English’ terms such as ‘human milk identical oligosaccharide or HiMO’ being displayed on infant formula labels, despite this being allowed in other jurisdictions. The INC stated that this has impacted on Australia’s competitiveness in the global market.147

Authorised Officers


An Authorised Officer (AO) is a person authorised by the government to perform certain export inspection and certification functions. An AO may be a government or non-government individual.148


Premium Grain Handlers (PGH) stated that the AO training process was time consuming and costly, and also demands a ‘high level of computer literacy and an understanding of Australian legislation.’ PGH recommended a shorter, low-cost course be designed for front line operators who could support an on-site AO.149


The Department of Agriculture responded that it was ‘always looking at ways to improve training for [AOs].’150 At the same time, the Department of Agriculture highlighted that there are importing country requirements that needed to be met:

Australia’s trading partners require assurance that the strict import requirements specified within mutually accepted protocols are followed and they are comfortable that the current structure of the AO model provides them this.151


The Department of Agriculture also outlined that it was rolling out a regional assurance manager initiative, to assist businesses ‘understand what kind of [AOs] they need… [as] there are a number of registered establishments now that have [AOs] with job functions that they don’t use.’152 The Department of Agriculture concluded that:

… if we can better align the job functions that AOs hold to the work that they're doing, then the training burden will be less because they won't need to be being trained in jobs that they don't need.153

Regulations for defence industries

APV stated that government support provided to defence exporters, including by the Centre for Defence Industry Capability and the Australian Defence Export Controls Office (DEC), had been ‘instrumental in supporting [APV’s] growth.’154


In contrast, Geospatial Intelligence, Electro Optic Systems (EOS) and Barrett Communications advised that lengthy processing times by DEC had resulted in missed export business opportunities and financial losses.155 Barrett Communications added that it had experienced ‘inconsistency in the application of qualifying criteria and decision making’ by DEC.156


Geospatial Intelligence provided an example of its interaction with DEC, stating that it had pursued an export opportunity which was eventually lost due to a nine month wait for the finalisation of a DEC assessment. Geospatial Intelligence stated that:

This project was an opportunity to grow our company by exporting our skills and talent. However, the slow machinery of bureaucracy could not respond in time for us to get export approval.157


EOS described a similar experience and stated that the lengthy DEC processing times has meant that EOS no longer contends for business with delivery requirements of less than six months. EOS estimated that the loss associated with this was ’25 per cent of current turnover.’158


As such, EOS recommended a reduction in export application processing times, including by investing in additional processing staff.159 EOS also recommended the number of applications that DEC needs to process be reduced, by introducing ‘multi-year/multi-territorial permits.’160


The Export Council advised that the intersection of DFAT’s sanctions regime and DEC’s regime was ‘clunky’ and caused delays. These delays could lead to ‘adverse commercial consequences’ for defence export businesses.161 Barrett Communications expressed similar sentiments and explained that:

… in a number of our export contracts we were led to that business by DFAT coordinated trade promotion, yet after entering into subsequent contracts we have been prevented from finalising that trade by DEC rejecting our export permit. … [Also], the involvement of separate Departments in the export permit approval process creates a disconnected interface for the defence export industry in Australia. For example, an individual application may require a DFAT decision under the autonomous sanctions regime; or an individual application being processed by DEC may require input from other departments and agencies, resulting in that application being on a decision ‘carousel’ and contributing to significant processing delays.162


Another regulatory issue for defence exporters regarded the process for securing tenders for major defence projects. Geospatial Intelligence outlined how some Australian companies had been included in tender processes put forward by international businesses to secure defence contracts, only for the Australian company to never be used after the tender process is completed. Geospatial Intelligence outlined its experience and stated that it has:

… very good relationships with all the primes, both North American and European. If there is a capability that requires our services, they will normally always come to us. The problem we have is that we've [been] part of many tender responses, but once the tender is won we never hear anything else … Where is the accountability? Where is the follow-up? … We don't see that.163

Transport infrastructure

RMAC highlighted the importance of a streamlined and efficient transport supply chain to ensuring the international competitiveness of Australia’s exports.164 The Australian Logistics Council (ALC) agreed and stated that ‘the viability and strength of Australia’s export capacity is inextricably linked to the efficiency of supply chains across the country.’ In addition, the ALC noted that as Australia’s exports grow, so too will demands on freight and supply systems.165


The Queensland Government similarly highlighted the importance of infrastructure, and recommended that the Australian Government:

… commit to more efficient, transparent infrastructure funding models for delivery of productivity-enhancing infrastructure. Federal support for export ambitions could involve working with states and territories to identify critical export-related infrastructure requirements or greater engagement on ensuring adequacy and funding certainty.166


RMAC pointed to the government’s National Freight and Supply Chain Strategy and National Action Plan (Strategy and Action Plan), which was endorsed by the Transport and Infrastructure Council on 2 August 2019 and sets ‘an agenda for integrated national action across all freight modes over the next 20 years and beyond.’167 RMAC stated that the implementation of the Strategy and Action Plan should be accompanied by ‘meaningful actions, measures and investment.’168


The ALC put forward a range of transport and infrastructure priorities to support exports, including:

Prioritising road infrastructure projects that were ‘identified by Infrastructure Australia in the 2019 Infrastructure Priority List as critical to the freight and logistics sector.’169

Establishing a High Productivity Vehicle infrastructure and education fund, which ‘would allow local governments and/or road managers to apply for funding to upgrade infrastructure or commence community education campaigns to facilitate the movement of high productivity vehicles across key freight routes.’170

Prioritising the development of a national rail plan.171


Tourism Australia advised that aviation access was a critical factor in bringing international tourists to Australia, as 99 per cent of visitors arrive by aeroplane. Tourism Australia further stated that there is a ‘direct correlation between aviation capacity increases and increases in international visitation’ and as such it was important for Australia to maintain sufficient aviation capacity to meet ongoing demand.172


The Victorian Government agreed and stated that air service agreement capacity constraints were impeding the attraction of new international flight services. In particular, the Victorian Government recommended that air service arrangements, including with Qatar, South Korea and Hong Kong, ‘reflect the need for increased direct flights between Victoria and key destination markets.’173

Digitising regulations

The PC explained that government information, particularly for businesses looking to export, is ‘often piecemeal and delivered by multiple agencies’. The PC considered that the use of digital technologies may resolve this issue.174 The Export Council agreed and called on the government for global leadership in digitising trade processes.175 The Export Council stated:

… there are going to be huge efficiencies once we can move to a more efficient digital [trading] system, but it's going to take some leadership from governments in general … there's a real opportunity for Australia to be a leader in this area … The countries that move first, in terms of digitising supply chains, are going to have a huge first mover advantage, and that is something that I've really been encouraging the Australian government to take seriously.176


DFAT and Austrade advised that Austrade is working to digitise its services and stated:

Austrade is trialling digital technologies to enable businesses to access services when and where they need them, and to enable service delivery at cost-effective scale and so be able to service more exporters. … these new online services will include help to find the right market and opportunities, and advice for those businesses considering exporting.177


The ABF identified that there was a need to modernise customs and border processes, and stated that it was leading the development of an agenda to address these issues over the next decade.178 The ABF further stated that this long timeframe was needed as it was working towards ‘incremental changes’ over time, to ‘transform [the trade system] piece by piece.’179


The NSW Government called for a ‘“21st century-standard” searchable database of products, export markets, requirements and tariffs’ for agricultural exporters to use. It stated that current arrangements do ‘not adequately function in this way’, and a ‘modernised alternative’ is needed.180


The Department of Agriculture advised that it was implementing a ‘multiyear reform program aimed at modernising the agricultural trade system’, which includes the modernisation of digital systems that regulate agricultural trade.181 DFAT and Austrade further stated that:

In November 2019 the Prime Minister announced the introduction of a modern export documents system. This will replace the existing paper based system with a new online system, allowing food exporters to get their product to market faster and more simply with more secure certification.182


The INC highlighted the importance of continued government support for the growth of ‘cross border e-commerce channels’ (CBEC). The INC explained that consumers prefer online shopping, and that CBEC also ‘provides a lower cost and more streamlined market entry channel for SMEs and new exporters.’ The INC stated that ‘there is an important role for the Australian Government to play in supporting CBEC into China and other Asian markets and maintaining an open dialogue with regulators about future management of CBEC.’ 183

Emerging and growing areas of export

Inquiry participants from a range of sectors highlighted future opportunities for their sector, as well as potential challenges. This included opportunities for Australia in technology; space; education; entertainment; agriculture, food and beverages; resources and energy; and health. While this list does not encapsulate every export sector with future growth opportunities, it provides an insight into the diversity of Australia’s export strengths and possible areas of future focus.


Australia’s technology sector was described as ‘a crucial aspect of Australia’s future economic growth and securing jobs for the future.’184 Atlassian agreed and highlighted that technological manufacturing was a growing global need185 and that this sector in Australia needed ‘to be enhanced and grown.’186


DIIS stated that it was working to support the development of the technology sector, including through supporting the development of emerging technologies such as blockchain.187 DIIS further highlighted that in the 2018-19 Federal Budget, $29.9 million was allocated over four years to strengthening Australia’s artificial intelligence capability.188


Enhancing Science, Technology, Engineering and Mathematics (STEM) skills among the current and future workforce was described as essential to maintaining Australia’s future competitiveness and driving innovation.189 DIIS pointed to initiatives under the National Innovation and Science Agenda that promote STEM and STEM skills development.190


Atlassian expressed similar sentiments and stated:

If we are to be truly competitive globally, we need the right skills to manufacture the products the world demands. There is a gap at the moment, between what talent in STEM is home grown and what we need to import. We should focus financially and culturally on prioritising education in STEM to fill this gap.191


In addition to enhancing STEM education, to address immediate workforce shortages the AIC stated that the government should fund ‘institutions that can develop and deliver courses for tertiary students aimed at fostering entrepreneurship and teaching digital STEM skills.’192


Other recommendations put forward by Atlassian to support the development of the technology manufacturing sector included: clarifying legislation related to encryption; investment in research and development; and skilled migration.193


The global space industry is currently worth US$350 billion, and this is forecast to grow to more than US$1 trillion by 2040. To ensure Australia can be a part of this growth, in 2018 the government established the Australian Space Agency (ASA), which is tasked with ‘tripling the size of the space sector to $12 billion’ by 2030.194


The ASA stated that Australia’s space sector is ‘growing strongly and outperforming the broader economy.’195 Areas of the space industry that the ASA considered Australia could contribute to included: positioning navigation and timing (including Global Positioning System (GPS) technology); earth observation; and adapting technology already being utilised in Australia (such as autonomous transport in the mining sector) for space.19

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