Biosecurity Inspections: Who Pays for Unpacking and Repacking?

DAFF conducts the biosecurity inspection, but it does not automatically provide all the labour needed to move, open, unpack and repack the goods. A new national clarification makes the person in charge of the goods, or their representative, responsible for providing reasonable assistance and sufficient resources.

If the labour, equipment or access is not ready, the inspection may be cancelled. That can add cancellation, rebooking, storage and delivery-delay costs.

What DAFF clarified on 24 August

Import Industry Advice Notice 149-2026 applies to approved-arrangement operators, customs brokers and importers associated with goods entering Australia.

Under section 552 of the Biosecurity Act 2015, a biosecurity officer can direct the person in charge of the goods, or their representative, to provide reasonable assistance. DAFF says the responsible party must ensure sufficient resources are available to support the inspection.

Reasonable assistance can include:

• moving or repositioning goods;
• lifting cartons, bags or other packaging;
• opening cartons, bags or containers;
• unpacking goods for inspection;
• repacking after inspection; and
• closing and securing the packaging.

The exact work depends on the goods, the inspection environment and the officer's directions.

What remains the department's job

The notice separates manual handling from the regulatory inspection.

DAFF officers select cartons, inspect and sample goods, collect samples when needed, take photographs, issue directions and complete inspection records. The industry participant supplies the physical assistance needed to present the goods safely and restore the packaging afterwards.

That distinction matters when checking a depot or broker quote. A government inspection charge, depot attendance, forklift work, labour, unpacking, repacking, waste handling and storage can be different cost lines.

Who should arrange the labour

The legal responsibility described by DAFF rests with the person in charge or representative. The commercial task can still be performed by a depot, approved arrangement, broker, forwarder or contracted labour provider.

Do not leave the allocation implied. Before booking, record who will:

• place the goods in the inspection area;
• provide forklift or pallet-jack access;
• cut straps or open outer packaging;
• lift and present selected units;
• protect fragile or heavy goods;
• repack and reseal cartons;
• dispose of removed packing material; and
• provide evidence that the job is complete.

OPL's guide to customs brokers and freight forwarders can help assign the wider border and freight roles. The inspection-day manual-handling task still needs its own named owner.

The cost of arriving unprepared

DAFF says an officer may cancel the inspection if insufficient resources are available. The industry participant may then face a cancellation fee and need to request a new inspection.

The commercial effect can extend beyond that fee. Cargo may remain at the depot while a new slot is arranged. Storage can continue, delivery can move and equipment free time may expire. Those outcomes are shipment-specific, but the risk is controllable before the appointment.

Use the OPL guide to demurrage, detention and storage to keep the time-based charges separate from the inspection and handling lines.

A pre-inspection responsibility check

Confirm the goods and access

Send the depot or broker the package count, dimensions, weights, pallet configuration, access points and any safety or fragility limits. Identify whether selected cartons can be reached without unloading the whole consignment.

Confirm the equipment

Ask whether the location needs a forklift, lifting aid, tools, replacement straps, tape, bags, pallets or other repacking material. Confirm who supplies and charges for each item.

Confirm labour and timing

Record how many people will be available, the attendance window and what happens if the inspection runs longer than expected. Ask whether the quote includes unpacking and repacking or only depot attendance.

Confirm document control

Keep the inspection direction, booking, depot instruction, quote and completion evidence together. If packaging or product identification changes during repacking, ensure the consignment remains traceable.

Check BICON before the cargo ships

This notice explains assistance during an inspection; it does not replace the import conditions for the goods.

Use current BICON conditions for the exact commodity, country, pathway, end use, treatment and certification. OPL's BICON guide for importers explains how to preserve the pre-shipment evidence.

A well-prepared inspection cannot cure a missing permit, invalid treatment or incorrect certificate.

Questions to send the depot or broker

Before approving the booking, ask:

1. What work is included in the inspection attendance fee?
2. Who will move, open, unpack, repack and reseal the goods?
3. Which labour and equipment charges are fixed, hourly or conditional?
4. Can the selected goods be accessed safely at the booked time?
5. Who pays if the inspection is cancelled because resources are unavailable?
6. Which storage or equipment-free-time clocks continue while rebooking?
7. What completion evidence will be retained?

Bottom line

The regulatory inspection and the physical handling are separate jobs. DAFF's clarification makes it unsafe to assume that an inspection booking includes every person, tool and repacking material needed on the day.

Name the responsible party, confirm the resources and price the handling before the inspection slot. For help building the destination plan into a China-to-Australia shipment, contact Ocean Port Link.