Appendix A

Table 29 – Feedback from public Consultation for AICIS proposed charging arrangements for 2024-25

Industry feedback	AICIS response
Proposed registration levies for 2024-25
Proposed charges to registration levies for 2024-25 are supported. The new tiered approach to annual registrations, which brings a better and proportionate fee structure relevant to chemical introductions is welcomed. The proposal to modify registration tier 7 to reduce the registration fee for businesses under $15 million and also reduce the financial impact of the transition from $4,999,999 to $5 million is welcomed. Generally supportive of reducing registration levies	Stakeholder views noted.
Do not support the 8% increase for level 8 ($15M+), an increase from $32,405 to $35,000 which is significantly higher than the 3.1% index for fees for services. Changes to registration levels and levies appear to be ‘tweaking’ previous levels and levies and rational is absent.	Stakeholder views noted. The eight-tiered registration model, applied to determine the annual registration charge, is broadly informed by the effort required to undertake relevant leviable activities (e.g. compliance and enforcement, maintenance of the inventory, post-market evaluation and monitoring of chemicals, and regulatory support activities). Almost half of the 495 introducers previously register at level 8 (those with an introduction value from $5M to below $15M) will benefit from a levy reduction of approximately 24.5% ($32,405 to $24,500) a saving of $7,905.
Proposed fees for services for 2024-25
Proposed increase of 3.1% to all existing fees for services for 2024-25 is supported.	Stakeholder views noted.
Concerned by the proposed significant fee increase (above 3.1%) for applications to add a new certificate holder	AICIS acknowledges that the $6,695 fee for adding a new certificate holder, as stated in the consultation paper, was an error. The correct fee is $1,540, reflecting a 3.1% indexation increase for all fees for services.
This Consultation is an adjustment of existing fees and charges, and not a full review.	The CRIS is a rolling document that is updated annually to deliver AICIS’s ongoing commitment to appropriate charging of fees and levies consistent with the Australian Governments Cost Recovery Policy. AICIS has, and will continue, to monitor the maturation of the scheme and utilise new available data to refine effort drivers for both levy funded and fee for service activities and thus ensure that charging reflects the efficient cost of delivering regulatory activities and services.
Transparency of AICIS reserves Requesting continued transparency of AICIS’s financial position, including disclosure of reserves which was provided in previous consultations but not this discussion paper.	The cumulative balance of the Industrial Chemical Special account and the components for which the reserves are committed are provided in Table 24 and the balance management strategy respectively, under Section 6 Financial performance.

Keep informed with updates