Have your say
This discussion paper seeks submissions on proposed exporter licence fees and recognised product group levies to be paid to the New Zealand Horticulture Export Authority (HEA).
HEA fees regulations need updating because:
- the HEA has new functions and funding tools (introduced last year when the HEA Act 1987 was amended)
- exporter licence fees were last reviewed in 2002.
Your feedback is sought on 3 options for exporter licence fees and 2 options for recognised product group levies.
Submissions open on 19 April and close at 5pm on 15 May 2017.
The Ministry for Primary Industries (MPI) is reviewing the fees and levies charged by the HEA for 3 reasons:
- The Act provides new funding tools – the 2016 amendments to the Act provides for the HEA to collect levies from recognised product groups, enabling the HEA to replace its contractual fees with a product group levy. Given the statutory nature of the HEA and the services it delivers to the recognised product groups, it is more appropriate that the charges it makes on recognised product groups be set out in regulations rather than through private contracts
- The HEA has new functions – the 2016 amendments to the Act enable product groups to target grade standards for exports to specific markets, and to create up to 5 tiers of licences with varying access to specific markets. The fees in the current Fees Regulations do not envisage different tiers of licence
- Income is not covering the HEA's expenditure – the current exporter licence fees in the Fees Regulations were set 15 years ago. The HEA's expenditure has exceeded its revenue since 2009. That shortfall is being financed from the HEA's dwindling reserves. This is not sustainable, and limits the HEA's ability to promote the structure and assist the development of the sectors consistent with its functions in its Act.
What we're proposing
This paper seeks submissions on proposed exporter licence fees and recognised product group levies to be paid to the HEA.
The 3 exporter licence fee options in the discussion paper are:
- Option 1: Maximum fees in the regulations for each of the services, for up to 5 tiers of markets, with the HEA Board setting fees for each of those services within the prescribed maximum.
- Option 2: This builds on option 1, but provides for a discounted licensing fee for experienced exporters, to reflect that it costs less for the HEA to licence exporters who have some exporting experience, particularly exporting horticultural products.
- Option 3 (MPI's preferred option): This builds on option 2, but provides for a flat fee for all applications for export licence exemptions, regardless of the tier of market.
The 2 options for recognised product group levy in the discussion paper are:
- Option 1: This has one levy rate applied on FOB export earnings to all recognised product groups regardless of their size, and is largely based on the current HEA product group fees.
- Option 2 (MPI's preferred option): This has variable levy rates applied on FOB export earnings, with declining rates for higher FOB export earnings to reflect reducing HEA costs from economies of scale.
It is also proposed that the updated fees and levies regulations be reviewed within 4 years of the new regulations coming into force. This will give some time to assess the impact of multi-tier export marketing with targeted grade standards on the HEA's costs, and ensure that the fees remain up to date.
Meetings on request
MPI officials are available should any individual or a group wants to meet with MPI to discuss the proposals in the discussion paper. Email Jason.Frick@mpi.govt.nz to seek a meeting.
Making your submission
All submissions must be received by MPI no later than 5pm on 15 May 2017. Make sure you include in your submission:
- the title of the consultation document in the subject line of your email
- your name and title (if applicable)
- your organisation's name (if applicable)
- your address.
Email your feedback to Jason.Frick@mpi.govt.nz
While electronic submissions are preferred, you can post your submission to:
Sector Policy Directorate,
Ministry for Primary Industries,
PO Box 2526,
After close of submissions, MPI will analyse the feedback and make recommendations to the Minister for Primary Industries. New fees and levies regulations will be drafted once the Minister and Cabinet has approved the proposals.
Submissions are public information
Any submission you make becomes public information. Anyone can ask for copies of all submissions under the Official Information Act 1982 (OIA). The OIA says we must make the information available unless we have a good reason for withholding it. You can find those grounds in sections 6 and 9 of the OIA. Tell us if you think there are grounds to withhold specific information in your submission. Reasons might include, it's commercially sensitive or it's personal information. However, any decision MPI makes to withhold information can be reviewed by the Ombudsman, who may require the information be released.