Transcript: Irradiation of table grapes – the story so far.

Thank you everyone, and it's a great opportunity to present today. And I've been asked to just give an overview of the Australian table grape industry and how we've embraced irradiation. But firstly, just a general overview of the industry itself. Australian table grapes is the number one fresh fruit exported by value when it comes to our exports. We've had such a significant growth over the last couple of years, which I'll show you shortly. There are about 900 growers throughout Australia. We have about 25,000 hectares planted. We grow in six main mainland states and territories in Australia. And our harvest season runs from November through to May, which its increasing with expeditional plantings up north.  Yep. Okay. So if you look at our export growth, which you can see there is quite quite exceptional. In 2005, basically that's when the, ATGA was formed or one or two years earlier. We had about $50 million worth of exports. Five years later. We were up to $80 million worth of exports, 30,000 ton. From 2005, we, in earnest, we set about getting market access to various countries, such as China, Japan, Korea and so on. And we're able to only take about five or six years to gain access into those countries. We gained access to China in 2011, Japan and Korea maybe one or two years after that. But from 2010 to 2015, we went to $240 million worth of export. 84,000 ton. And then five years later, we reached our peak just prior to COVID at $623 million worth of exports, 152000 ton. And it's around about 75% of our national production is exported.

The other thing that they realize about the Australian table grape industry is that they are, nearly all our growers, are nearly all family farmers. And by being family farmers, their reputation themselves personally is based on their quality and through exports as an export registration number, and a lot of our importers take in consideration that export registration number, that CG number and the fruit that's produced in each of those boxes. And they know which is the best quality fruit coming from different growers and the better growers get rewarded with the better prices, and that's basically how it works. But the good thing about being a family farmer is that because they are, they make that they pick and pack their own fruit. They actually have their own facilities on their farm and cool room facilities, et cetera. And they make their own decisions about where they're going to market their fruit. So they don't send to one large packhouse. And all of a sudden that packhouse makes the decisions for them. Individual farmers make their own choice.

So just where we we grow our grapes, which a lot of people ask is ask me this all the time. But in Queensland we're even go up as far as Mareeba now. Mainly around Emerald and St. George in New South Wales. We are on the Riverina, but primarily on the Murray, on the other side of the Murray River. Sunraysia is our largest production area with 75% of our production grown in Sunraysia, but importantly, 99% of our exports come out of Sunraysia region, which is Victoria, basically. South Australia in the riverlands. In  Western Australia, we're down south down    in Bunbury. But we also mainly in the Swan Valley, the middle of WA in Western Australia, but we also now growing grapes up in Broom. And as well as that, we've got some farms in Ti Tree in the Northern territory.

So in terms of our exports, we need to have that point of difference. And that point of difference is quality. Obviously, we send a lot of fruit to Asia. It's 4.5 billion people there. It’s our closest neighbour. But when you look at Australia and compare that to the rest of the world, we are very small .We export out our maximum 152000 ton,  South American countries export over a million tons. And other competing countries such as South Africa do about three times as much as Australia, but a lot of the exports from, in table grapes come from the Northern hemisphere back to the Southern hemisphere countries. But again, if we are going to compete with these low cost countries, such as South Africa, Peru and Chile and so on, we need that point of difference. And that point of difference for us is quality. And I'll keep mentioning quality all the time. So let's have a look at the export overview. Here's a graph of where we've been in the last 10 years. And you can see that we've had that steady climb right through, but what's important about this steady increase over 300% in the last 10 years has also been that the price has increased as well. So the return to the grow has been there. And I give a lot of credit to our growers for this because they've realized when we first started, when we first gained access into China, they were very complacent. They basically thought they could just do what they used to do when they used to pack in the field. The boxes that were landing over in China. And we were the first country, by the way, to have China accept to have field packing for export to China, because every other country allegedly packs in the shed. And the first year that we sent grapes to China, we had one in three rejections. So one in three containers were rejected and China suspended us. So then basically there was a few meetings with growers, et cetera, a few harsh words were said to the growers, and then they started to realize, as I keep on saying to the growers, they're not farmers, they're business people, and they're in the business of growing grapes and they've took on that attitude, and from that day onwards, they've improved their practices to where there is basically very few rejections these days. We did have international inspectors coming out from China and Korea and so on. We've been able eliminate those inspectors because our compliance level is way below what the threshold is in terms of exporting out grapes and having them being received at the other end.

The last two years, you can see there's been a bit of a dip and that dip is obviously we might put it down as a result of COVID. And there's been a lot of challenges with COVID in particular of getting the fruit off the ground. There's challenges of input, labour costs, getting labour, to list logistical challenges and so on. So all that has resulted in a decrease. And the fact that we couldn't travel was the biggest thing. Asians like to see face to face connectivity. They like to see negotiations happening. While that wasn't happening over the last two years, our exports have decreased, but that's been the case for all commodities.

So let's look at Indonesia. We'll focus on just two countries that I want to, because primarily the two countries I'm gonna focus on now is Indonesia and Vietnam, because they're the ones that we can irradiate and send fruit to.

So with Indonesia, it's our second biggest market. And as you can see, from 2011 to 12, we've had a gradual increase, until 2019 20. And the reason behind that was political issues with Indonesia. When I say political issues, depending on who was the minister of trade, minister of agriculture at the time you need an export license and a quota. And in 2010 and 1920, there was a few a few political plays that in Indonesia that that prevented a number of importers getting their licenses and quotas. And as a result that sort of curtailed trade a fair bit. But since then, that has been sorted out. There was a lot of work done by the Australian government from that point of view, particularly the minister of trade at the time, we’re on basically having weekly phone calls, trying to resolve this and to their credit, they did resolve that. But since then, that trade, as you can see, there has increased the last two years dramatically and that's in the face of COVID. And I couldn't mention COVID because of that decrease. But one of the reasons why there was that increase in growth over the last two years is the fact that we've been able to use irradiation because Indonesia takes primarily one variety, which is Red Globe, but they're now getting used to a new proprietary varieties that we are growing, but we don't send them in bulk as we do with our, with red Globe. So we don't send container loads. We send maybe air freight loads and a lot of those air freight loads now are through irradiation.

Looking at Vietnam, Vietnam again is an interesting country. It's had a rapid, in the first three years there, you can see some decent growth. Vietnam telegraphed up to us in round about April of 2014, that they were going to suspend trade on the 31st of December, if Australia didn't get their act together. Australia was again, used the word complacent. They didn't and trade was suspended, not just for grapes, but for every commodity. And when we went over there to renegotiate, table grapes were fortunate. We gained access within three months of that trade suspension, but basically Vietnam just said to us, you haven't paid us due diligence. We've been trying to get their products, Vietnamese products into Australia, their dragon fruit, and so on and Australia hadn't paid due diligence to doing the work. So that was resolved. We were fortunate to be the first commodity back into Vietnam. And as you can see from then we've had steady growth, but in particular, last year, every country last year decreased in our exports, except for Vietnam.

It went up by 100%. All right. Now, one of the reasons behind that is because they got the taste of the new varieties that we're growing, in particular, as I've mentioned with those new varieties, we don't send container loads of them. We send air freight loads of them. And when that new protocol was negotiated back in 2015, 14 - 15, it accepted a irradiation as well as methyl bromide and our growers opted for irradiation. So that's a big plus there.

So we've had used irradiation for a number of years now. We first started using, as I mentioned, Vietnam in 2016, it's mainly used for air freight. But prior to the Melbourne facility being developed or built, I remember Steritech, having conversations with them. They were trying to promote the use of irradiation. We were sending our grapes to Brisbane under the old cobalt system at probably at additional $10 a box. And I've basically said to Steritech, the only way you're going to get increase in irradiation use is to build a facility in Melbourne because grapes of 99%, as who's grown from Sunraysia, we all come to Melbourne to export, and we'll go from there. So to their credit, they went off and built this brand new, state of the art x-ray facility. And the use of our irradiation has increased enormously and has also helped our small consignment exports. And obviously grapes are one of the biggest users.

So when we look at the purpose of irradiation protocols and what's the strategic purpose behind that. So irradiation is a generic treatment that ensures an alternative use to chemicals. There's a lot of chemicals these days that are been taken away by APVMA. Growers are perhaps using some chemicals they shouldn't be, some harsh chemicals. There may be, those chemicals might be killing beneficial and so on. And there might be new pests that have been arising that we need to be prepared to manage.  Irradiation is a way of eliminating MRL issues, and it makes it simple for compliance going forward. But again, it's probably more so for small quantities. The new facility in Melbourne has the capability of just putting pallet through after pallet. So we could do container load after container load, but that would take time, but it's certainly available for our new proprietary varieties. And it is a way of overcoming MRL issues, which we had some this year.

So when it comes to competing with other Southern hemisphere countries, again, we need that point of difference. All right, we are the fastest to the market when you compare us to our competitors, Chile, Peru, South Africa. the use of the irradiation plant is cold chain friendly. So therefore it maintains its quality. We can rapidly react to demanding changes from various countries and by getting the fruit into the market quicker, there's an expectation that our growers get paid a lot quicker also. So it's going to improve our cash flow for our growers.

Going back to Vietnam is another example, the market opened in 2016, as I mentioned with irradiation and cold treatment. In fact, the, if you look at the Vietnam protocol for grapes is probably the best protocol that you'll ever see written. That doesn't equate to the import permit that comes out, but it's still one of the best protocols that we've received. So 15 to 25% of our exports are irradiated for air freight to Vietnam. And by doing so, we're getting the fruit into their market quicker. We are delivering greater quality and freshness and some of the Vietnamese importers believe that it's a safe fruit, and we're providing a greater service.

So we're beating our competitors from that point of view and Vietnam realized that, and our footprint in Vietnam is the biggest of all the competing countries. So we've really got a strong foothold in terms of exports to Vietnam and irradiation has helped that enormously.

So when we look at future trade needs, the current market as a strategy must consider all the challenges that we've got on play in the moment. And it's, this is very worrying for a lot of growers. Again, we've got increased competition. MRLs you see with chemicals being taken away and a lot of countries are reviewing the MRLs for a lot of chemicals, it's getting tighter and harder to maintain that and maintain pest control. There is that expectation of quality, is the main thing in terms of exports. And you've got all these other challenges, such as freight disruptions, staff shortages, weather challenges, asset changes, that had a major impact on our quality of fruit last year and also our exports. So again, the use of irradiation can overcome some of those issues.

So where is table grapes now with the market access priorities? Right now we have access to basically nearly every country in the world. So we're looking at improving our market access. In particular, we're looking at improved access to the USA. At the moment we do have a protocol to the US, but the conditions of that protocol just make it basically unviable to send fruit there.

We've been promised for five or six years that they will amend the protocol to accept in-transit cold treatment. And obviously irradiation would be put on the table. If we do, we can see our export to the US increasing minimum overnight by maybe another five to 10,000 ton in the next two to three years. We've all we've been advised by some major retailers in the US that they're waiting for that determination to happen because they're clearing their shelves to put Australian table grapes on their, in their stores.

Acceptance of other additional varieties in Japan, fortunately, after the last pilot meetings with Japan, the MAF have come out and have basically said that Australian grapes are their, the next priority in terms of improving market access. So Japan is the only country in the world that accepts access by varietal. We've requested a grape as a grape. Let's have vitus vinifera accepted into Japan and Japan that is on the table to hopefully be negotiated with the next 18 months. As well as that, we're talking to a lot of other countries, such as Thailand, Philippines, Japan, South Korea, China, as an alternative to methyl bromide to accept irradiation.

It's interesting that a lot of these countries use irradiation themselves, and yet they're not willing to accept it this day. So it's my belief. It's only just a matter of time before your Thailand’s, your Philippines, Japan, and Korea will accept it. Japan's an interesting one, where we did market, I do market seminars to each of those countries every year. About three or four years ago when I did one, I spoke to the Ag counsellor there and I said, I've got irradiation in my presentation, and they said no, take it out because it's too sensitive. The following year I ignored that advice. I put irradiation in and I had a number of MAF people come up and talk to me and say, I want to talk to you more about irradiation.

So it is gaining acceptance worldwide.

Transcript: Export of mangos to New Zealand and beyond.

Good morning everyone. Yes, my name's Ry Collins. I'm the CEO of Bowen Gumlu Growers Association. Apologies, Ben couldn't be here today. But we work together quite closely in our region. And yeah, look, I guess a lot of our experiences mirror with some of the things he would have to say as well.

Look, I think that the presentation today is a, ultimately a story of experience for Ben, but also, I guess the mango industry generally. And I think that the heading of his presentation there I guess covers a period of time, challenges, persistence and reward, because that's ultimately what it has been for him.

Just talking to Ben. So he's a second generation mango farmer from the Bowen region in north Queensland. His business Marto's Mangoes has been exporting by irradiation for 11 years, and seven of them has been direct export.  I guess talking mangoes generally where our region's well known for our mango produce along with the Mareeba area and Northern territory, we're probably the three major mango producing regions in Australia.

And as far as quantity of mangoes coming out of our region, it's around about 36,000 tons per annum. I guess talking to my general role, Bowen Gumlu Growers Association, we're an industry group supporting horticultural producers in north Queensland. We have a variety of of vegetable and tropical fruit produce that comes out of our region. But also I guess from irradiation perspective, some of the other commodities that, that we focus on are tomatoes, melons, and zucchinis.

So just having a look at the, I guess the history of this and particularly the mango, industry’s history, I guess there's essentially two phases of development. First was getting the protocols established and that's taken a period of time essentially from 2004 to 2015, obviously establishing food standards, those protocols, and also to prove the benefits of of the technology.

And then I guess the second phase, which has been around that, that in market development and really gaining that acceptance around the quality gains that can be made forming those, essential customer relationships and doing what needs to be done to, to fill out the supply chain and make it all work for us.

Aussie mangoes are world first. So just a bit more on the history there. Australian mangoes have been world leaders. Mangoes were the first ever international shipment of irradiated produce. That was into New Zealand in 2005. At that point in time, obviously no retail chains and it was quite limited. 2005 also saw the the market access request into the USA put forward. And I guess just moving through there 2007 and Countdown in New Zealand started stocking mangoes and started to see the growth from there really. There's been a lot of challenges along the way. Initially only fruit shops sold those mangoes in New Zealand. But because of the success, it's obviously continued to grow. So yeah, moving forward 10 years later, 2015 the USA protocol was announced which I think was a major mark of success for the industry.  I guess the probable key takeaway point there is that developing these protocols takes some time and planning and there needs to be a level of collaboration across industry and government to really see this through, across different terms of government and different people coming and going throughout the years.

I guess probably a, another question there is which markets will allow irradiation 10 years from now, where do we need to focus our energies? And how do we continue to tell that story.

The USA has been a super premium market. It's also had its challenges. Importer education, like many countries has been a challenge and many flights and time spent doing business development. And also, the training to, to be able to handle that particular fruit differently.

I guess, second big takeaway is really focusing on quality as our point of difference.  That, that focus on quality's obviously been allowed to, you know, improved relationships between the grower and the importer ripening to optimize the treatment. And also I guess with mangoes making that transition from sea freight to air freight. There's a good, (I think it's on the next slide), picture here. This is from our Supermarket somewhere in New Zealand. Obviously got a product on the left-hand side, Peruvian mangoes, $1.69. Australian Bowen mangoes $6.90. That's been something that, that I believe a lot of work's been put into to, to get it to that point. From not only getting the product in, but also the education and business development that's required to really identify that product as being a premium product. Ultimately, we feel that delivers consumers a better experience and also allows growers that are exporting to take more control of, of their process and ultimately better outcomes for their business.

I guess coming back to a key challenge, is obviously preparing for the unpredictable. Think things were very much traveling along well until the pandemic came along and the industry saw quite a decline in export volumes and challenge getting into those new markets.

It was a good lesson ultimately to, that you need to prepare and maintain diversity in your business to, to keep a, an eye on the unexpected and how you may be able to adjust to that. The industry needs new protocols to support the next generations of trade. And ultimately those protocols are important for market access, security, flexibility, and simple compliance.

So talking to the rewards: moving through this sort of challenging period, New Zealand's become Australia's largest protocol market for mango. And Australia's market share for mangoes has continued to grow. There's just a graph here on historic mango exports by irradiation. As you can see it's significantly improved over, over recent times. USA, which is this component on the end there in, in red is obviously very promising. Few key, obviously retailers there, Walmart, Sam's club has been a big opportunity for mangoes, and I guess the goals moving forward are, really to continue this growth pattern and extend forward. We need irradiation protocols to deliver the volume and quantity to really meet these larger markets.

Talking to ongoing efforts: priorities for the industry are protocols for India and Vietnam. Getting into those markets, continuing the improvement of the USA market. And the challenges around Seed Weevil. Japan, that's seen as I guess the next big opportunity to really grow again, similar challenges to address particularly around consumer understanding. I, I guess talking to the business development side, some of the initiatives we've looked at as an association we, we've got a project going at the moment around Japanese agricultural exchange students that are working in our region. And lot of people say to me why do you take this on, what's the benefit for you? But, but for us it's ultimately about trade relationships. It's about being able to start up a dialogue with the relevant people that, that are going to support this process in country, and recognize that we're working with them. We want to work with their, them from a cultural perspective and really it's about enhancing that, that bond. So ultimately when we want to get something across the line, there are those established relationships to make it happen.

Just summarizing. I guess lessons from Ben's experience, but what we've seen generally, as I mentioned before, must have a long term strategy. These things don't happen quickly, but through good planning and execution, it can happen. There will always be challenges. I think we need to just because something's not, doesn't look like it's going to happen now, doesn't mean it's not going to happen in the future. So we need to keep our eye on what that plan is and really focus in on it. Compete on quality, not price. That is our competitive advantage. And lastly, probably Ben's point, buy more mangoes and I'll say tomatoes and veggies as well.

So, thank you.

Transcript: The benefits of irradiation for plant protection organisations.

So my name's Mirianne and I'm the Assistant Director in the Market Coordination and Strategy team in our Biosecurity Plant Division. I was to be joined today by my colleague Tash who works in the Hort Exports Team. She was meant to provide a presentation on irradiation and Hort exports. Unfortunately, she's unwell. So I'll read through her presentation, but I've got a colleague here Narelle who can answer any specific question on irradiation and exports.

I'll provide a short presentation on irradiation and technical market access. So Australia's renowned for growing and exporting high quality food plants and plant products to a range of overseas markets with approximately 72% of what we produce exported. The department of Agriculture, Fisheries and Forestry is responsible for negotiating new and improved trade conditions with trading partners. This is known as technical market access. It is specifically the negotiation of biosecurity import conditions that support two way trade. Trading partners like us have finite resources and will often do work when work is being done for them.

What we import is really important to the process, and that is why we really emphasize two-way trade. Like Australia however, our trading partners are increasingly imposing stronger biosecurity measures, which has made new improved technical market access, more difficult to achieve. And although that we are free from many pests and diseases, we have unique pests such as Queensland Fruit Fly, which are not present in other countries.

So when negotiating technical market access, we try and include a range of phytosanitary export pathways to provide flexibility to industry. One of these pathways being irradiation. It is also however important to recognize that some of our trading partners do have sensitivities with irradiation and we can't demand irradiation as an export pathway, but it is genuinely accepted in Southeast Asia. Trading partners like Vietnam very receptive and encourage the use of irradiation. However, in contrast North Asia training partners, such as China and Japan have lesser acceptance of this pathway. And in short, our access is based on the research and science that underpins risk assessments and that they underpin those market access negotiations. There is also noticeable lag in acceptance of new treatment pathways, such as irradiation for some trading partners.

Irradiation does, however, present very clear opportunities, such as compliance, effectiveness, and sustainability. However, some challenges are seen as low consumer acceptance, slow domestic uptake and resistance from some trading partners to access irradiated imports regardless of their domestic use and regulation. We do see most of these challenges as opportunities. And today I'll touch on a few. Irradiation is simple, it's effective. It can be used across a range of commodities and pests. It allows for trade in fresher, high quality produce, uses less chemicals, and allows for an uninterrupted cold chain.

It's increasingly been used as an alternative to methylbromine in some commodities, especially for time crucial perishable commodities. A good example is the recent approval of table grapes from the Maryfield facility where grapes arrived within 72 hours to the Vietnam market.  And I think that's a really good example of the benefits of irradiation. Southeast Asia is increasingly becoming a hub for our premium produce, and the benefit of the irradiation supply chain provides greater opportunities to meet these demands. A key priority for the department is to promote the expanded acceptance within our region, and this is happening through our engagement with our trading partners, through capacity building activities, our active two way trade, Vietnam is the example here. And we're also developing a communication and education tool of videos, pamphlets to raise awareness and understanding of irradiation within the ASIAN region.  And we're expecting to launch this at the international irradiation forum in Bangkok, in November. And the purpose of this education package is to help raise awareness at that government official level. We also advocate in our bilateral meetings and in our multilateral forums. And we also hold information sharing workshops with our trading partner.

It would be remiss of me not to mention the ongoing topic of consumer acceptance, and I won't go into too much detail than mentioning that a broader domestic acceptance and consumption of irradiated produce is an important link to our technical market access and increasing our export. The department did take a high level research project that indicated that consumer acceptance can be supported at a lower level education. So it's not impossible. But don't underestimate the power of providing our trading partners, real examples of our domestic use to, to support those technical market access negotiations.

Moving on to sustainability. Sustainability has increasingly become a focal point for all industries, including the ag industry. Consumers, be they domestic or overseas are increasingly demanding or simply expecting that products are sustainable, and there is an expectation that we move towards a future that considers the environment. Our trading partners are introducing sustainability requirements and are moving away from traditionally used chemicals. Irradiation does provide a sustainable treatment for pests and diseases, but more than that, how do we keep our reputation and competitive advantage of being a premium producer and exporter of high quality produce, if we don't move towards sustainable practice?

Okay, moving on to Tasha's slide. So I'll move on to our operational exports. As we've mentioned, irradiation is an emerging treatment in the phytosanitary space, which means we only have limited access currently, but we are working towards access for more markets and commodities. You can see on these slides, the markets and commodities we have access for are currently listed in Micor, and these are Vietnam, New Zealand, the USA, Thailand, Indonesia, Fiji, and Malaysia. They're both protocol and non protocol markets. Noting that this is also for fruit and veg and doesn't reflect our uses for nursery stock or grains.

Depending on the market and commodity combinations, irradiation can be specified by the importing country to mitigate a range of pests, such as fruit flies, moths, and other insects, which I won't go into today. But Micor has a list if you are interested. And you can see on the slide that different trading partners accept irradiation for different commodities. The USA currently accepts irradiation for mangoes and lychees, but not yet for cherries. Even though we do have cherries for the USA, they currently have to be cold treated or fumigate. In the irradiation space, our work sits in the categories of getting trading partners to accept irradiation, getting trading partners to approve a specific commodity for irradiation, and getting trading partners to approve irradiation facilities, where the Brisbane facility has already been approved. For example, getting approval of the Maryfield facility. For irradiation in general, we're actively working to get access to two additional countries, those being India and the Philippines. Sometimes these can be long term goals. So for example in India, there isn't a lot of demand right now because a lot of commodities have high tariffs, but over the next seven years, some of those will be reduced, and when that time comes, we want to make sure that there are operationally feasible conditions to export. Hence the current irradiation request.

For specific commodities, this would be with seven markets that we already have approved irradiation for, and we are requesting consideration of irradiation for a range of different commodities. For example, Thailand accepts irradiation for persimmons, but we would also like Thailand to accept irradiation for cherries, strawberries, and table grapes. For specific facilities, such as Maryfield, some trading partners haven't had the chance to visit yet because of COVID travel restrictions. Hence why some facilities have not been approved.

From a regulatory perspective irradiation is very much the same as any other treatment, in that product for security, appropriate packaging, traceability, treatment certificates are still all required. The department has treatment standards for irradiation that the facilities must meet in order to export. And we will audit against those and any importing country requirements as needed. Though other export requirements include product security, under Australia's requirements and most MPPO requirements for Hort exports, once goods have attached a phytosanitary status, in this case, once they have been irradiated, phytosanitary security must be maintained at all times. That is the goods must be adequate, adequately protected to prevent reinfestation or contamination. Adequately protected in our policy means that goods either have to be securely packaged at either carton or pallet level or meet isolation requirements, be packaged in an insect proof space directly into a shipping container. When doing the inspection for export, authorized officers must confirm that packaging is suitable to meet those product security requirements. Traceability. So from the time goods have attained a phytosanitary status e.g. when irradiated or at farm in case of some protocol markets, all movements of goods need to be documented to be able to demonstrate that product has maintained that security and it hasn't been substituted. Treatment certificates - they must be completed by the irradiation operator and include things like date, dose, commodity, distinguishing features like lot numbers. And then of course the phytosanitary certificate. If it all goes well phytosanitary certificate will be issued stating the applied irradiation dose.

One of our biggest challenges that we have with trading partners is recognition of Australian systems and processes, not exclusive to irradiation, but it does apply a lot in this space. The irradiation pathway is regulated by the department and is audited by us against relevant requirements to ensure compliance. There are challenges in getting trading partners to recognize those systems, which can hinder timely approval processes for exports. Another challenge is that a irradiation does not necessarily kill insects. The required response may be that they end up sterile and unable to reproduce. So what happens if a trading partner opens a consignment and there is a live pest? Again, this comes back to recognition of Australia's processes and having faith that a phytosanitary certificate stating irradiation has occurred. Does that mean the consignment is safe to, to be released because the pest is sterile and holds no risk? A smaller challenge as we gain more access, is negotiating the required dose and having the efficacy data to support doses for specific pests and commodities. There are ISPMs for specific pests, which helps with this.

Transcript: Barriers to the use of phytosanitary irradiation: regulatory and technical

Good morning, ladies and gentlemen, and to those of you working from home, I'm that excited to be here! It's, there's been a few years talking about irradiation in a project which Marty is leading and to finally grab a number of people in the room and talk about what we can do going forward, for me, it's a great period of time. So thanks to Ag Vic, and for Marty for putting this on. My bias is in domestic trade. I'm a regulator that works out of New South Wales Department of Primary Industries, and I work with other regulators in other states. I see Tanya Jensen and Matt in the room, Matt Rogers from Queensland. So yeah, I'll give a more domestic spin on it, but it's good to see the first speakers talk about how much we can do domestically to lead the uptake of irradiation as a treatment.

Kudos to Peter Roberts from Rad Services in New Zealand as well, that he helped me conduct a review in the last several months. So I hope he's watching at home. I'm sure he'll send me a question.

Just to review the morning talks - world exports are increasing and 10% of 'em are Australian, and that seems to be a trend that's continued through. Over on the left hand side, there's a fair bit of detail in that, but you can see the mangoes down the bottom. That's the orange, it's continuing to slowly boil away. The light green is the table grapes, and you can see other commodities are getting on board as well, both internationally and domestically.

This is another breakdown, just looking in terms of pallets. Thank you to Ben Riley from Steritech for helping me put this together. So you can see again, the orange down the bottom, that's the mangoes, the greens, the cherries, but the little ones at the top, which I've drawn your attention to is domestic trade is increasing as well.

So what are the barriers? And what can we be doing domestically and internationally to increase the uptake? So a bit of a starter here is we operate under the world trade organization in a rules based trade order. You probably heard about the general agreement on tariffs of trade. That's a different thing, but the agreement on ag and particularly on biosecurity comes under the SPS agreement. And there are two bits that cover irradiation, which is quite different to say cold treatment as opposed harvest treatment on fresh produce. We only have to be concerned about what comes under the international plant protection convention. That is, does the treatment kill the pest? The difference with the irradiation is that we've also got to meet some requirements under the codex which my esteem colleague will be following me, talking about thinking Glen.

So I won't go into too much detail on that, but the codex talks about safe food. So it actually says there is international agreement in a general standard for irradiated foods that recommends its use, but also gives guidance about irradiation source, hygiene, packaging, which Maryanne went through, limits on re-irradiation. Evidently, we don't want that happening. Verification, which is the whole, where can you prove where it's from? And this certificate is for this product. And also labelling. Over on the other side of the regulatory requirement is all of the stuff that I'm more familiar with. And that's how the IPCC just sets the protocols for how we trade things like cold sterilization, chemical post-harvest treatment systems approaches. But particularly from irradiation, there are two things. One's ISPM 18, which basically says, this is what an irradiation facility should look like, and this is how the irradiation dose should be applied, and covers the auditing of those facilities as well. But then ISPM 28 actually gets right down in the weeds about what dose kills what pests. So there's a good ISPM 28 part seven, which includes the general treatments for all fruit flies, which is that to free to die word. So you got that in your head. We're gonna expand on that. So we, Australia's got many solutions to these barriers already, and they are being played out in the domestic scene. So where you see green, that's a good thing. And where you see yellow, that may be, an issue going forward. So we've got a good thing called Fsanz and the Australian standard about how irradiation, how irradiated fresh fruit and vegetables should be treated. And we want export marks to have something similar if they don't have it, because it eases negotiations.

In July, 2021 Fsanz actually just started stopped having a look at individual fruits and basically said all fresh fruit and vegetables can be treated with irradiation for domestic trade and international trade to New Zealand. And that was up from 26 fruit and vegetable in 2016. So in only the last 12 months, all of Australian domestic jurisdictions has changed their entry conditions to reflect that. And particularly for fruit fly, treat it with 150 gray, you can move it around Australia. We do talk about the requirement for labelling at point of sale, potentially as a problem. But we are seeing that diminish over time I believe. On the other side of the business, the treating the pest, like I said, all the jurisdictions are now harmonized, 150 gray for fruit fly and 400 gray for other insects. And that includes things like serpentine leaf minor, melon thrips and a few others, but none of them spring to mind. All jurisdictions except the irradiated produce may be certified with this generic protocol, ICA 55. That's a domestic certification protocol where it just goes into Steritech, comes out the other end. They write a certificate to say this consignment has been irradiated at the correct dose. Now Lois Ranson, who's a previous person on the, a previous delegate on the international plant protection convention committee, she did a presentation to Vic standards just last year about ICA 55, and she's basically saying we need to be concentrating on removing red tape. One of the things we could be looking at doing is just accepting a treatment certificate from an accredited facility that's also approved by ARPANZA. Now there's no reason domestically why we can't accept that and do away with double accreditation under ICA 55 entirely. So that's something that I reckon we can remove.

And then we talk about how do we improve international trade? Remembering that Australia is a world leader. There is some low hanging fruit. So there are countries that already have something similar to the Fsanz standard and that want reciprocal trade. This was focused on by Maryanne, just previously and by Jeff. We can draw on the success domestically using our generic protocol and expand into those markets, New Zealand, US, Vietnam, Malaysia, Indonesia, and Thailand. So if there are any industries who are interested in getting on board, think about what your potential markets could be in there and follow the example of mangoes and table grapes.

So a job for industry and the Australian government is to start that conversation and start reflecting on the domestic success we've already started gathering data on. So we, I think only a couple of years ago, or about a hundred tons domestically, and in the last 12 months, evidently there have been 1200 pallets traded domestically and therefore all sorts of things. And the interesting thing is an earlier question about what happens if we find a maggot in a fruit in Vietnam, what, does the world come to an end? That's already played out in the domestic space in the last 18 months and has been resolved numerous times. So we have good experience in the way that the underlying standard and the order and accreditation systems support the trade and irradiated produce. Let's start gathering that data and using that.

We've also got to start playing the long game. Now I won't presume to tell the Australian government how to do its business here, but we know that the easiest negotiating pathways aren't necessarily the ones that have been identified by industries, looking for high value markets, but you got to start somewhere. So what I'm suggesting or what Peter and I come up with is we already have a really good generic standard, the Fsanz standard. For those countries which don't have something that shows their regulators how to enforce the codex, we should be saying here's the Fsanz as an example, and get that discussion going, or keep that discussion going with Japan and South Korea. And reassure those markets that it is working domestically and the trade is increasing and that any of the problems that they can anticipate, we're already dealing with those in a mature way in the domestic market space.

And yeah, so that's pretty much what I'm saying on the right hand side as well. Obviously there's a bit of work still to be done on dosing against particular pests in particular fruit. There's still a bit of research to be done on that, but industry needs to help us identify what target market they need to be in, in the longer term so we can actually start setting those longer term research priorities. And then I can't leave you today without saying, we need to cultivate interest in emerging markets, which already have a food regulatory standard for irradiated food. And it was good to hear India came up in that discussion. They are deregulating their gap tariffs over time. And we want to be ready to start commencing those recipient trade negotiations with those industries, with those countries. So if industry's involved in any international horticultural export, get together, start talking to these fellows who already have those regulatory systems in place to see if they're interested in our products, which is what I said over there on the right hand side.

And I guess in, in closing, the key challenge for us now is not how much work needs to be done, it's about simplifying what is already underway. We do have a brilliant generic agreement on how to trade irradiated produce for food safety concerns, and we do have a great generic trade protocol, domestically.

Transcript: Barriers to the use of phytosanitary irradiation: commercial and cultural

Today, I'm going to jump in and discuss the cultural and commercial barriers or more to the point, bring some clarity to the opportunities and dispel a couple of the myths there. But first of all, I'd like to say, I think it's really important when we have this conversation that we maintain perspective. Quite often there's a mix up of perception and opinions versus reality in science. So what we see playout, once products available, is very different to what we perceived would happen and certainly contradicts some of the research that's been put out there. We really need to separate biosecurity and consumer marketing. They are two very different things and we shouldn't get hung up on, one while we're focusing on a biosecurity matter, and we can certainly focus on benefits and purpose - our end goal of delivering better product to the market, as opposed to approaching it at times in a negative way, thinking of the challenges, so. Everyone's basically here today for two reasons. One to get consumers better produce. We certainly heard about the success of focusing on that from the table grape industry and the mango industry before. And also the second part is we're here to prevent the spread of pests that, that enable us to do that trade and grow this great fruit in Australia.

Now, if you look at the barriers, there's two easy ways to categorize them. And for me, there's the hard barriers. There's the brick walls. They're non-negotiable. You cannot trade without them. And this is where I think the previous presentation brought up from Lloyd brought a lot of attention to that. We need to ensure food standards are developed in our trading partner markets. Some already have them and we also need to focus on trade protocols with those markets that do have them.  And then finally, which is more on the commercial side than the regulatory side, is the treatment facility access.

So Australia is very lucky to have two of the leading irradiation facilities in the world for fresh produce. The first whole pallet irradiator for fresh produce was built in Brisbane in 2002. And again, Australia led the way with the first whole pallet x-ray facility for fresh produce in Melbourne here. So we're extremely lucky in Australia in that we have all three hard barriers addressed. Industry has developed facility, our government health departments have established food standards and the certification system, and our ag department has negotiated market access for import and export.

So I think it's at this point in time, it's important to pause and just think about why other countries may have been slower at up taking or applying irradiation? If you start with a commercial formula there, it's roughly $30 million to build a facility, it's a lot of money. And you need a solid business plan behind it. From start to finish, with all your contacts, you might be looking at a five year turnaround on that process. But who's going to build a facility if there isn't a food standard? So food standards in Australia - yes, we are leaders. We have got a great generic food standard. It's a little bit cumbersome with some of the operational requirements on labelling, particularly given the treatment occurs after the product has been packaged. And but we also look at some of our trading partners and their success in establishing the same food standards, where they jumped, leapt straight to generic approval, and that process took a lot of those countries between one and five years. So that's where we want to assist our trading partners, and I think Lloyd touched upon that very nicely. But, then who's going to develop a food standard, if there isn't a facility or a protocol to trade through? So it is a little bit of a chicken and an egg scenario for our trade partners. And this is where I think Australia can really focus our efforts to share what we've learned and help our trading partners move down the pathway, catch up to where we are and benefit from this, both for their consumers and their exports.

To touch upon consumer behaviour. This fits into that cultural factor, and I think consumer behaviour has really fallen into that confusion that I mentioned at the very start around perception and opinions versus science reality and access and behaviour and consumer decision making when the product is available.

Peter Roberts gets another mention here, as well as Yves Henon from the International Irradiation Association, have really taken a lot of their understanding with the irradiation industry and how it's played out around the world. So they've looked at a great, I guess a great assessment of irradiated food, a greater assessment than just fresh produce. And they've really hammered home, in this that piece, it was written in 2015. So we'll get the reference out if you would like it. But they've really focused in on purchasing behaviour versus perception. They've identified that the, a lot of the research out there and a lot of opinions are generated from market assessments and consumer research that was never conducted where a consumer had even experienced, eaten, purchased, heard of, seen irradiated product. Now, what we are seeing is commercial sales is directly answering that in, in a different way and saying, no, the demand is there. So consumers are buying a product. So a couple of pieces of advice that came out of that research is making people aware of the successful retailing around the world, not just of produce, but many other products that are treated.

Looking to engage stakeholders to advocate. Steritech as an irradiation provider, probably isn't the most effective mouthpiece for the Australian industry to pursue this in. I think the Australian industry, the growers, the producers, the biosecurity, it's a team effort. Focusing in our communications on the benefits of the treatment, not the treatment itself. So what are we trying to do? Deliver fresher produce to market through more sustainable pathways with fewer, fewer issues on the biosecurity side and providing easy access to information for the proactive consumers that are interested. So there still is going to be a small percentage of consumers interested. We need to make sure that there's science based effective materials available for them to access. And I would like to say that the graph before that we saw in Lloyd's presentation really emphasizes that we're seeing sales growth, and that sales growth would not happen without consumer acceptance and more the point consumer demand. So we're seeing real trade demonstrate or disprove the consumer resistance conversation.

And special kudos to a few people online and in the room here today, but we've got some leaders in sustainable biosecurity here in Australia and New Zealand that have seen the benefits focused on, on putting quality fruit on the shelf. And that's part of us being able to sit here today and tell that success story. This is very important to demonstrate to our export markets, I think as well, that we are utilizing irradiation domestically and that consumers are happy to purchase it. A tremendous example of where the labelling requirements, which is a commercial barrier in my mind, it's an operational challenge, has been flipped, where in the retail stores down in Tasmania, where they're now importing up to 55 different crops at any given time to fill independent retail shelves. And they've said rather than label every shelf or every piece of fruit, we can label our produce section. They're looking at it using technology and QR codes. They're focusing on a very positive message to address the needs and purpose for the and the interest of the audience. They're talking about what they're protecting. They're protecting Tasmania from fruit fly, while are they using a chemical free x-ray treatment. What is it used for? Fruit fly host crops growing on the mainland. To understand more, they've got access to information, but it's not an overload. It's a very positive spin. And it ensures their stories compliant without putting whole extra requirement of compliance and labelling on the producer themselves.

Now we look at, this is a screen grab from a retailer in Australia, and what I'd like to focus on here is purchasing policy of the retailer versus their sustainability goals, and quite often, this is in direct contradiction. So we've got a, we got a business here that's protecting forest, rivers, soils, and wildlife, but will not allow irradiation to be used as an endpoint treatment in their supply chain. So they're preventing their suppliers from utilizing this, which indirectly forces those producers to utilize chemical based treatments, ozone depleting gases. So I think, as more focus comes on the transparency of our sustainability, as an industry, and as supply chains, and delivering on, not just talking, but doing, I think these are the forces that will continue to reinforce the use of irradiation domestically.

Now to unpack a little bit of the sustainability side of things and put a little bit of focus on the facility that you'll be touring this afternoon, if you're joining us. The old way, and it served a very good purpose and continues in certain areas to facilitate trade. But the old way was largely chemicals and ozone depleting gases. Rather than get stuck into them, what I would like to focus on is the positive benefits of irradiation and the new modern alternative. We are seeing x-ray as a great new source that's been unlocked in the Melbourne facility. It Is the world's first whole pallet irradiator with x-ray source. So we're using renewable energy generated on site to offset those treatments. The only consumable of that treatment is electricity. I think given it's chemical free, cold chain friendly and rapid, and hasn't had any failures in the 15 years of a use in Australia and therefore avoided the recalls that we quite often see through other pathways, I think it's significant in reducing food waste. It's significant in reducing the carbon footprint and the ozone challenges with alternate pathways. And in my humble opinion, this is a critical part of Australia's industry, continuing to meet our sustainability goals. And as I think it was Jeff that 5 said earlier today, really lead and enhance our quality and clean green perception overseas.

So moving into commercial advantages, this is really why I think we're seeing success. This is why we're seeing volume move through the system. On the right, you can see what was Australia's first TV ad filled with irradiated produce. Again, hats off to the Tasmanians there. They've got a lot to lose down there if they end up with fruit fly and it's being approached by the retailers as a way to reliably treat their product and get a better product to the consumer. As we see other pathways disappear, and I think summer fruit's a great example. The challenges that's placing on distribution, we saw ICA 21 suspended and then removed for domestic trade of summer fruit last year. We are seeing a limited number of options for industry. We're seeing, I think, a lot of trade now basically weigh up methylbromide, or irradiation and quality is a key attribute to the advantages of our irradiation, so. We also look at the ability to supply Australian produce for a longer window of the season into markets like South Australia, and WA. If we're growing it in here in Australia, we should be sourcing it from Australia rather than switching to imports earlier, and it popped up a little bit in the presentations from the growers. We are facing as a production industry, a number of challenges around meeting the residue requirements in export markets. So irradiation's not going to solve all of those problems, but it gives industry another tool, a way to remove dimethoate from your domestic packing lines. Use irradiation for domestic distribution of say citrus to South Australia and Tazzie. So it's about flexibility. It's about simplicity of compliance. It's about a whole host of commercial advantages and that's what is driving, I think, the industry's uptake. So the commercial experience - proofs in the pudding, positive results moving forward.

Now moving towards to my last point. We have an opportunity - Australia is a leader. We have addressed all the hard barriers. Some of the trade partners that we do want to do business with in the future, still have some of those hard barriers in place. So it's really, that's our challenge. Once we open up those doors to trade, we can refine it and manage the softer barriers which are more of the commercial and cultural barriers. But what we've seen is Australia is doing a very effective job of managing that message domestically, and that many of our export markets have instantly taken hold of irradiated product and with great success. So Australia can choose to lead, and I think we are choosing to lead by being here today. What I also know being tapped into the irradiation, the global international world, is that other countries are nipping out our heels. Other countries have seen our facility in Melbourne and they've seen the new availability of certain technologies and they're ordering this stuff. So they're on our heels, and to Jeff's slides earlier about the competition from Chile, Peru, Australia does have a commercial advantage in being able to air freight to market greater than any other Southern hemisphere producing country. We can't deliver on that advantage unless we have the right protocols. And how do we get to that point of being able to trade and have those protocols in place? Well, Lloyd again, touched upon some great points there. There's a lot of shared roles involved and everyone has a role. So it's great to see the stakeholder diversity here today. You know, I break it down in my head, we've got industry. Yeah, that's the starting point for a lot of the relationships. That's the starting point for importers who want to, want more Australian mangoes in Korea or Japan. This is a pathway to be able to access that. We can help communicate in simple terms, what irradiation is and dispel their concerns and answer their questions. The research is a critical for that scientific collaboration, for that technical engagement and we see it time again where, through researchers in say Korea or Japan, are the starting point of a reference for the MAF department to understand more about our irradiation. So they there's an opportunity to trust internally there.

The Commonwealth government largely negotiates protocols. We wouldn't want another country coming to us to tell us to rewrite our food standards, because they want to export something to us. So, we have to understand that and factor that into our approach to foreign markets. The Commonwealth government does a great job of negotiating and drawing out the benefits of irradiation as a generic treatment. And we are very, I think that's another example of our leadership in Australia. And retail in Australia has an opportunity to lead with their purchasing policy. They have an opportunity to support Australian growers that protect them, to give them the full flexibility and access to utilize these new modern technologies, to deliver a better piece of fruit, to deliver better shelf life and more sustainable options.

Transcript: Interpreting and applying labelling requirements to fit your business

Good morning, everyone. Good morning, online people and Kia ora to the people, our colleagues in New Zealand. It's great to be here in person, not staring always into a computer, isn't it. And it's good to see some ex-colleagues that I came across this morning.

I've had a long passion with food irradiation. It goes back many years. I spent 25 years at Fsanz. I volunteered to do the project originally and people looked at me and thought, are you crazy? But it's been great. I've recognized this importance in food safety and biosecurity, and I got the privilege of managing every application at Fsanz except the last one. And the last one was the best one. Wasn't it? Because it got the generic approval. So I'm sorry I missed that. I even got to be at the minister's meeting when the standard was approved, so great. It's been great.

Right, now why did I put that image out? Most of you I suppose won't know what that is. It comes from a conference on quantum mechanics in Brussels Belgium in 1927. It has got a number of scientists there, 17 of the 29 or attendees were Nobel prize winners. Marie Curie, she seated two left of Einstein in that photo. It's an interesting one, isn't it? Because she's an amazing woman because she's the first woman to win a Nobel prize in both chemistry and physics. And she also, she accomplished this despite the fact that she wasn't allowed to enrol in higher education at all. She attended a clandestine organization called the Flying University. And why did I put that up? It sets a little bit of the theme of the day. Would we be satisfied how Madame Curie was treated or seek to change this? My parallel with this and labelling of irradiation is importantly, if you believe in this technology, don't get caught out in historical event like this. Be positive, be proud to label it and educate consumers of the real benefits to your business and the countries, Australia and New Zealand and other countries.

Just the presentation topics today: I'm just going to give a little bit of background on food or irradiation approvals, a crash course, go through some of the current labelling requirements, how you might interpret the code. And importantly, some examples which have been provided by Ben and some of the Steritech clients, and I'll thank them for that. Do a bit of a wrap up and have one last word, similar to what I said originally with the original slide.

Okay. So irradiation's approved in 60 countries. Permissions vary in different parts. See either a case-by-case approval or the generic approach by codex. And so codex has that general standard which is approved up to 10 kilograms or higher if needed. We have a range of approvals, which I'll get to in the next slide, which I'll do very quickly. You all ought know that in the code in the Australia, New Zealand food standard code, is standard 1.5.3. We've had a case-by-case assessment as the intrinsic policy in place since 1997. Fsanz has dedicated application requirements as a handbook and specific guidelines. In the regulatory framework in Australia and New Zealand, obviously that's the code, but the state territory New Zealand food acts do the enforcement part of that.

So here's the success story. The track record has been excellent to date. Fsanz assessments have included that it's a safe technology, established as a technological need up to specified maximum doses. As I said, the big generic was the best, and left the last. Through that process, Fsanz also revised some of the data requirements, which made it a lot easier for industry to make applications. So there was a focus on one particular nutrient, which was vitamin C because a lot of during that time, the early days, the attention was lot on the toxicology of irradiated foods, but it changed to more of a nutritional impact. And certainly that was what the Fsanz board was concentrating on throughout the latter days of these approvals.

There's the current labelling requirements in front of you. Worldwide there's, you're required to identify irradiated foods. However, there are some differences in specific requirements. For example, Canada, Malaysia and South Africa provide an exemption for irradiated ingredients, if present in the final food in amounts below a threshold. For instance, Canada has a threshold of 10% where it does not need to be labelled. Our one, as I said is probably the most rigorous in the world. It's Ministerial endorsed policy. It's been in place since 1999. Any food that's irradiated must be labelled, no matter how minor the ingredient. It does preserve a consumer's right to know which came up as a barrier before in perceptions of that, but in fact, they got the right to know what they're eating, but it's not an advisory or warning statement. However, we can interpret the current standard and there's flexibility in location and wording and examples are coming up. Just to draw your attention to that. Fsanzs did a, quite a big review of labelling in 2016, under recommendation 34. It's on their website, and it's worth the read just to see what some of the issues are in the background with the labelling.

Some of the pros and cons of the current labelling. The advantages as have already said, there's full compliance in the code and it's consistent with the ministerial policy. It preserves the consumer's right to know that food, consistent with other countries up to a point, other than some of those thresholds I've said. The challenges still, we've heard that this morning, about consumer awareness and perception barriers. Operational impacts and challenges are product segregation for industry. If you've got to separate out an irradiated food line from a non-irradiated food line. And packing to order, if an order is placed and you have need to change that after it's packed, it makes the supply chain and interpretation and impacts an innovation sense.

However, even though you've got challenges, you've also got opportunities. You can consider how to interpret the labelling within the current supply chain and flexible options are out there and available. That will, that's good for growers and increases trade in retail and export markets.On that kind of controversy of food irradiation, there's a good point that came up because the original application, A413 had 3000 submissions. I remember them. Now a few applications later, it had dropped down as 75. It doesn't mean that necessarily they got better. They got better at making those submissions, but it showed you, I saw an acceptance as it went through the years to a certain degree.

Interpreting the code. I won't go into that because that's the black letter of the law that's in the code at this stage. You can find that online on the Fsanz website. The one I wanted to just pass to say was, you can use the Radura symbol. It is voluntary, it's optional, and you can indicate the benefit of food irradiation, provided it's not false, misleading or deceptive.

Something, some of you, just to note, when you're doing a label, consider some of the recent research. The Fsanz review found that consumers were willing to pay a bit more for irradiated food. Positive information really works. I'm going to see some examples in a minute. Watch your food technology overload. I haven't heard that term there, neophobia, but interesting paper. Information perceptions can change over time. Experts often wonder why consumers accept relatively high risks for unhealthy food choices, while at the same time they do not tolerate risks that we might find, some experts might find intrinsically low, such as GM foods, irradiated foods, or even residues of pesticides or additives. So it's interesting.

And the last one, the Conroy paper, which looked at New Zealand consumers, when choosing between x-rays or methyl bromide, 84 respondents chose irradiation. I didn't like the title of that I didn't put that one up, but it's a good paper to have a look at.

I thank Ben and Steritech clients for some of these examples. And so you've got a really nice example there of irradiated x-ray. It meets the ICA 55. It's irradiated to protect the Australian environment. Nice, good positive messages. The reasoning is to prevent fruit fly spread. It's got a bit of a sustainability element, chemical free, heat free, whatever. I like the choice of x-ray because being in the field myself a while ago, I think it's well recognized, x-rays as something consumers are familiar with and there's no false or misleading aspects to listing an x-ray on the label because it's listed as a source in the code. So good examples there of some positive labelling.

Similarly at the piece level, you've got some nice stickers there on the mangoes, on the melons and on the grape packages. The benefit there is there's actually no install merchandising needed. The challenge though, is if that product is not always packed to order and you need to change that order if someone needs irradiation treatment at a certain point in the supply chain. It can be a bit late and hard to change that, and costly.

On the master case, a nice example again, are treated by x-rays and irradiated to protect the Australian environment. Benefit there is, it's already part of an established protocol, the ICA 55. The challenge is that it is actually in that master case, but doesn't mean it doesn't work. I would've liked to, there was a really nice example out of New Zealand in a market years ago where tomatoes were labelled. I couldn't get hold of that photo to put in here, but it can be done even in the market sense as well.

This one in particular, the produce display has got a really nice generic produce section signage with some display labelling. Love the language, we protect Tasmanian from fruit fly using a chemical free x-ray treatment. And also love that other bit which is about the commitment to freshest sustainable stuff. The benefits are maximum supply flexibility, and it's got a positive consumer education message there as well.

Just in terms of some of the conclusions.

Australia is the leader in phytosanitary treatments for biosecurity. Australia and New Zealand, as I said, has the most rigorous requirements of the world to label irradiated food, but there are advantage. There's challenges, yes, and there's opportunities within the current labelling requirements. There's flexibility for the business to provide that, and you've seen some examples there. Your x-ray is quite a familiar term. It might be more successful than purely technical language such as ironizing radiation. There was another term that they used to list examples in the code called ironizing electrons. I thought that was even worse, actually. So I'm glad that went. Due to environmental and biosecurity issues, a positive message may influence consumers to purchase irradiated foods.

One last word, you can't go back and change the beginning, but you can start where you are and change the ending. Let's not go get caught out in history by some of the challenges with labelling, if you're proud of the technology, and it's actually working increasing trade in the domestic and export markets, be proud of it, label it and let's move forward with the technology.