GrainGrowers welcomes the opportunity to comment on the Assuring Sustainability Claims discussion paper. GrainGrowers has provided detailed responses to questions relating to current and emerging regulatory requirements (Question 1), common forms of evidence (Question 3), material topics (Question 6), challenges facing the grains industry (Question 8), and data (Questions 9, 10 and 11).
GrainGrowers is a national organisation working to enhance the profitability and sustainability of Australian grain growers. GrainGrowers achieves this through focus areas of policy and advocacy, grower engagement, thought leadership and active investment in future focused activities for all growers. Australian growers are at the heart of all that GrainGrowers does and the focus of its work.
Sustainability credentials are growing in importance for accessing certain markets for Australian grains. Increased focused is evidenced through new programs such as the US Renewable Fuel Standard and the EU’s Union Database for Biofuels. Sustainability assurance should be driven by the market and must focus on what value it provides supply chains, avoiding perverse outcomes such as exclusion from key grain export markets or regulatory fragmentation. Sustainability assurance mechanisms cannot be a one-size-fits-all approach and will need to reflect the unique requirements of the Australian grains industry.
It is critical to ensure that the costs and efforts required by growers align with tangible benefits, such as improved market access or price premiums. Implementing complex sustainability assurance systems without a clear understanding of market demand could result in an imbalance, with growers bearing the burden without a commensurate return on investment.
GrainGrowers looks forward to working with the Department of Agriculture, Fisheries and Forestry on this topic. Should we be able to provide further assistance or if there are any enquiries relating to this submission please contact Rebecca Hurst - Policy Officer, Sustainability and Natural Resource Management at rebecca.hurst@graingrowers.com.au.