Submitted to Biosecurity Tasmania – Department of Natural Resources and Environment on the 30th July 2026.
The Agroecology and Food Sovereignty Alliance (AFSA) thanks Biosecurity Tasmania for the opportunity to provide feedback on the revised draft Primary Produce Safety (Horticulture Produce) Regulations 2026. As a First Peoples and farmer-led civil society organisation representing small-scale regenerative and agroecological producers, AFSA remains concerned about the potential for corporate capture of our food systems and the imposition of excessive regulatory burdens on smallholders. We appreciate that Phase 1 feedback has led to a tiered accreditation model, but we must ensure that the implementation is truly scale-appropriate and does not favour large-scale industrial models.
Proposed Regulatory Approach in Tasmania
AFSA supports the proposal to implement a tiered system that allows lower-risk or smaller producers to meet simpler requirements. However, we have specific concerns regarding the auditing requirements for Accredited Producer – Category 1 (1-5 ha).
- Department-Based Audits: For producers in the 1-5 ha range (Category 1), AFSA strongly advocates for Department-based audits conducted by Biosecurity Tasmania staff rather than external third-party or GFSI-standard audits. External audits are often designed for industrial monocultures and carry prohibitive costs that are not commensurate with the risk of small-scale production.
- Scale-Appropriate Compliance: Regulation should focus on education and facilitating compliance through Food Safety Management Statements (FSMS) that reflect the simplicity of short, direct supply chains. Small-scale farms, which often occupy between a quarter-acre and one hectare, present vastly reduced risk points compared to conventional industrial supply chains.
- Education-Led Transition: AFSA welcomes the planned twelve-month transition window following the approval of the regulations to help businesses adjust to their new legal obligations. We emphasise that this period must maintain a primary focus on education and facilitating compliance, providing smallholders with the necessary guidance documents and templates to meet standards without facing immediate or punitive regulatory barriers.
