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Trade Council
Letter from the table: A threshold is not a landed cost
To the Trade Council
I am writing in English as a translation of what I hear from Mandarin-speaking small-business owners around Sydney. I do not mean that every owner has the same experience. I mean that the same question keeps coming up: how can we agree to a price and still not know what it will cost to get the goods through the door?
On 14 May, I confirmed an order with an overseas supplier. The goods were invoiced at AUD 3,780. The freight forwarder’s estimate was AUD 540, with import costs still to be confirmed. I asked what “to be confirmed” meant. I was told that the final amount would depend on the customs entry and assessment. That was a true answer, but it did not help me plan. I had no clear line-by-line estimate to use when deciding whether the order was affordable.
The shipment arrived in Australia on 1 July. The final request for payment was AUD 1,126.40 for import charges and services, rather than the roughly AUD 430 I had put aside for those costs. The statement separated some items, including import GST and duty, but did not explain the calculation in a way I could check: which customs value had been used, what exchange rate applied, or how the service charges were built up. I paid because the goods were held pending payment. The delivery was delayed by two business days while I found the money and tried to understand the statement.
I know the Australian rules are not a single flat fee. For a consignment above AUD 1,000, an import declaration is generally required, and the amount payable can depend on customs value, tariff classification and origin. GST and duty are not interchangeable, and different goods can
receive different treatment. A forwarder cannot promise a final assessment before the relevant details are known. I am not asking anyone to pretend otherwise.
What I tried was ordinary: I asked for an estimate before the order, asked again when the amount was still described as provisional, and checked the final statement against the information I had. I also asked whether the extra service charges were government charges or the forwarder’s own fees. I could not get a usable answer before I had to pay. For a small operator, the problem is not only that the amount changes. It is that the change arrives at the point when there is least room to respond.
In the language community I hear this expressed less as a demand for special treatment than as a demand to be able to see the whole cost. Translated, the recurring point is:
“Tell me what is known, tell me what is only an estimate, and show me what could make the final bill different.”
That is why I oppose making size-based thresholds or exemptions the centre of the proposed Small Importer Standard. I support plain-language guidance and a reasonable phase-in when new rules or tariffs take effect. I also strongly support landed-cost transparency from forwarders. But a threshold-led fix risks drawing a bright line where the real need is visibility. A small trader just above a threshold may still receive a complicated bill without an understandable explanation; a trader below one may still face charges or contractual costs that the threshold does not address. And where a threshold changes who must do what, owners will need clear guidance about the boundary, not just a new number.
I would ask the Council to put the practical information first. A forwarder’s quote should identify what is included and excluded, distinguish government taxes and duties from the forwarder’s own fees, and state the assumptions used for any estimate. If tariff classification, origin, customs
value, exchange rate or a later assessment could change the total, the quote should say so in plain language. When the final amount changes, the statement should show the basis for the change and how the customer can query it. Those steps would not guarantee a fixed bill. They would give a small operator a fair chance to understand and plan for a bill that may move.
For new rules, I would prefer accessible guidance and a transition period proportionate to the change, with small traders told in advance what records and decisions they need to make. That is different from assuming that smaller businesses should simply be exempt. Some of us need to comply; we need to know what compliance will involve before a shipment is already on its way.
Please treat this as opposition to a threshold-first approach, not opposition to the Trade Council taking up the problem. The Landed Cost Diary is useful because it records the gap between the quote, the arrival and the final payment. I hope the Council’s fix starts from that gap. Predictability is not the same as a promise that nothing will change. It is being able to see what may change, why, and what it may cost.
Emily HartCited · Trade CouncilSydney, Australia