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Submission to Australia – India Comprehensive Economic

Cooperation Agreement

July 2015

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Contents

Overview ............................................................................................................................... 3

Australia’s grain trade with India ........................................................................................... 5

India’s grain production ......................................................................................................... 9

Mutual benefits to enhanced grain trade to India ................................................................. 14

Exporting Australian grains to India ..................................................................................... 15

Summary ............................................................................................................................ 17

References ......................................................................................................................... 18

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Overview

GrainGrowers is an independent and technically resourced, grain farmer representative organisation

with 18,500 members across Australia. GrainGrowers’ goal is a more efficient, sustainable and

profitable grain production sector that benefits all Australia grain growers and the wider grains

industry. GrainGrowers has four divisions which work cooperatively to achieve improved grain

industry outcomes:

1) Milling, Baking and Analytical Food Industry Technical Services

2) Industry Capacity Building

3) On-farm Information Services

4) Policy and Advocacy

Trade & Market Access is a key focus within Policy and Advocacy and GrainGrowers has the specific

aim to:

Drive the development and implementation of positive international trade and market access

outcomes for the Australian grains industry and its customers.

On this basis, GrainGrowers makes this submission to Department of Foreign Affairs and Trade to

inform the renewed dialogue between Australia and India with regard to an Australia-India

Comprehensive Economic Cooperation Agreement.

GrainGrowers’ overarching priorities for all trade negotiations are:

1) Zero tariffs and removal of all quota barriers on all grains and all grain products;

2) For agreements to include measures to minimise the risk of non-tariff barriers being invoked

following removal of tariffs and quotas;

3) That agreements are living, both in terms of built in review clauses and built in mechanisms to

resolve SPS disputes;

4) Agreements do not compromise Australia’s own biosecurity processes; and

5) Trade partners recognise the benefits of, and actively pursue, removal of domestic policy

measures which distort resource allocation.

GrainGrowers is supportive of an enhanced trade environment between Australia and India because: India has a large and growing population, with increasingly Western diets; Indian grain supply can be variable so that imports are important for their food supply in some

years; There is a logistical advantage that can benefit both India and Australia, especially from

Australia’s west coast, but also Australia’s east coast, to southern India; India is the world’s largest pulse market, and improved access to it, can deliver not only increased

profitability to grain growers but also improved sustainability because including pulses in crop rotations increases performance, reduces cost and enhances sustainability; and

The greater the number of markets to which we can competitively sell Australian grain, the lower our industry’s market risk.

India has not traditionally been not among Australia’s larger grains markets, accounting for an average less than 2% of Australia’s grain exports by volume (2011- 2014). This is primarily because while India is a large consumer of grains, it is also one of the largest grain producing nations in the world, but also due to tariffs and other restrictions on trade.

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Currently accounting for the second largest population in the world, and with a growth rate putting it on track to be the largest beyond 2028 (UN, 2012), trends in consumption offer opportunities for Australian grains. There is also however the potential for RD&E and logistics developments in India which could dramatically enhance the Indian grain supply. All of these dynamics mean that India is undoubtedly a market that will have some influence on the future position of Australian agriculture and the Australian grains industry. This submission provides contextual data and commentary regarding India’s grain market and Australia’s trade with India, and then within this context, the key areas that an Australia-India Comprehensive Economic Cooperation Agreement, should address to benefit the Australian grains industry. In brief these areas are: High tariffs on some grains; Import clearance processes; Pre-import treatment requirements; and Highly distorting domestic wheat policies. Pursuit of a trade enhancing agreement with India is desirable however the priority of such is reduced for the Australian Grains industry due to: a) The relatively modest proportion of our current market that it currently accounts for; b) The volatility in its demand; and c) The apparent incapacity of India to reduce high levels of domestic support and market

intervention policy in Indian grains markets, especially that for wheat.

Further, if any agreement were to deliver any possibility of undermining the competitive position of

Australian grain production globally, the priority of engagement with the Indian market would fall

further. Examples of such would include the export of key production technologies and capacities, or

agreement provisions which undermine Australia’s biosecurity.

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Australia’s grain trade with India

In the context of Australia’s $16bn total value of annual exports to India, agriculture contributes a

relatively modest amount, just $0.5bn, or 3%. Of this, grain and grain products represent an average

of just 7% of Australian agricultural exports. In the context of total Australian grain exports, India

represents an average of less than 2% of Australia’s grain exports by volume.

Figure 1 shows the five year average value of Australia’s Grain and Grain Products exports to India.

It shows that on average wheat and wheat starches (and cereal preparations) are important grain and

grain product trade items. Figure 2 however demonstrates the variability in grain and grain product

exports to India in stark reality. India is a variable market for Australian grains and generally an

opportunistic market, based on pricing rather than developed trade relationships.

Figure 1: Average annual value of Australian Grain & Grain Product Exports to India, 2010-2014 ($’000)

Data source: DFAT, Composition of trade Australia, 2014

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Figure 2: Value of Australian Grain and Grain Products Exports to India, 2008 – 2014

Data source: DFAT, Composition of trade Australia, 2014

Australian grain exports to India are dominated by containerised grain, and in fact account for a not

insignificant proportion of Australia’s total containerised grain trade. On average, India accounted for

over 7.7 per cent of all Australian containerised grain trade over the period 2011-2014. Containerised

grain exports represent about 15% of total Australian grain exports, and this has trended upwards in

recent years1.

Table 1: Australian Grain Exports to India as a Proportion of all Grain Exports (by Volume)

Data source: ABS, 2015. a. July 2014 – January 2015

1 Deregulation of wheat export sales and historically cheap container freight are key drivers of this

recent trend.

2011-12 2012-13 2013-14 2014-15

a

Bulk 0.6% 1.0% 0.0% 0.0%

Container 3.7% 9.4% 10.0% 7.3%

Total (inc both modes)

1.2% 2.0% 2.0% 1.6%

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Figure 3: Composition of Australia’s Containerised Grain Exports to India, 2011-14

Data Source: ABS, 2015

Australian grain exports by container are dominated by exports of pulses, as shown in Figure 3.

These include chickpeas, mungbeans, black and other lentils, field peas, pigeon peas, with chickpeas

(including chana dal), lentils and mungbeans being the most important among pulse exports by

volume.

Table 2: Australian Exports of Pulses to India, 2011- 2013/14

Australian Pulse Exports to India Total Indian

Pulse Imports

(tonnes)

Australia’s share

of Indian Imports

(%)

Container Bulk Total

2011/12 126,130 89,418 215,548 3,495,000 6

2012/13 307,946 167,736 475,682 4,013,240 12

2013/14 174,153 4,706 178,859 3,654,780 5

Data Source: ABS, 2015

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The small volume of grains exported to India in bulk include, chickpeas, field peas, and lentils, with

bulk volumes of all grains averaging just 87,000 tonnes per annum in the period 2011-14. There were

no bulk exports of any grains to India from Australia in the first 6 months of financial year 2015.

Canada is the largest exporter of pulses internationally, accounting for around 30% of total world

pulse exports annually. Australia is the second largest exporter of pulses. Both Australia and

Canada feature prominently as import sources for Indian pulse imports as shown in Table 3, however

a range of other countries also feature for particular pulse types.

Table 3: India Import Sources for Major Pulses 2013-14

HS Code Pulses Top 5 Import Sources

07131000 Peas (Pisum Sativum) Canada (70.59%), Russia (11.06%),

USA (8.37%), Australia (6.19%),

France (1.74%)

07132000 Chickpeas (Garbanzos) Australia (61.43%), Russia (22.77%),

Tanzania (7.84%), Myanmar (6.40%),

USA (0.47%)

07133100 Moong2 /Urad

3 Myanmar (82.83%),

Tanzania (4.23%), Kenya (3.55%),

Australia (3.05%), Mozambique (1.61%)

07134000 Lentils (Mosur) Canada (79.33%), USA (10.70%),

Australia (9.85%), Uzbekistan (0.01%),

Turkey (0.01%)

07136000 Pigeon Peas (Tur) Myanmar (51.37%), Tanzania (27.44%),

Mozambique (14.69%), Malawi (4.53%), Kenya (1.79%)

Data source: Commodity Profile for Pulses-March2015, http://agricoop.nic.in/imagedefault/trade/PulsesNew29.pdf

2 moong : mung beans

3 urad dal = black lentil = black gram = kali dal Notes: These lentil-like beans have black skins covering

creamy white interiors. Whole urad dal derive their strong, earthy flavour from the black skins and are often used in curries. Split urad dal retain the skins and also have a strong flavour. Skinned and split urad dal are creamy white and somewhat bland.

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India’s grain production

In approaching a trade negotiation with India including grains, it must be noted that India is a major

grain producer. In particular, India is:

the third largest single grain producer in the world. On average Indian grain production

accounts for 7% of international grain production (2010- 2014), after the United States (22%) and

China (17%) and ahead of Russia (4%), Brazil (4%), France (4%), Ukraine (3.5%), Argentina

(3%) and Australia (2%);

the second largest single wheat producing country in the world averaging 13% of annual

world production, behind China (17%) and ahead of the United States (9%), France (6%) Canada

(4%), Australia (4%), Germany (3.5%), Pakistan (3.5%) and Kazakhstan (2%) (see Figure 5); and

the single largest pulse producer in the world, accounting for an average of 24% of annual

world production, followed distantly by China (7%), Canada (7%), Burma (7%), Brazil (5%),

Nigeria (4%), Australia (3%), Russia (3%) and the United States (3%).

The size of the Indian grain production base means that changes in it have the potential to impact on

world markets. For example a drought that reduces Indian pulse production will have a massively

positive impact on world pulse prices, and vis a vie. Further, India has a large production base and

cheap labour, so that into the future even small positive changes in production if adopted widely

enough, have the potential to lead to an even greater impact on world grain markets.

The following sections provide an overview of wheat, coarse grain and pulse production in India.

Figure 4: Average Annual Wheat Production, 2010-14

Data Source: IGC, 2015

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Wheat Indian wheat is grown

primarily in northern

India and is mostly

winter wheat varieties.

As shown by the shaded

yellow areas in Figure 5,

the bulk of production is

in the states of Uttar

Pradesh, Punjab and

Haryana.

Figure 5: Wheat production regions of India

Source: www.mapsofindia.com

In terms of wheat, Australia’s number one agricultural commodity export, India well exceeds

Australia’s area planted and harvest, production and yield. India’s total annual wheat production is

more than 4 times greater than Australia’s. Yields in India are higher, sometimes as much as two

times greater than Australia’s average wheat yield. As shown in Figure 6, India has greater per

hectare yields and a significantly greater number of hectares harvested but considerably lower

potential to export wheat than Australia due to India’s high domestic consumption.

Wheat production in India has a high level of policy intervention, including:

a Wheat Procurement program, including Minimum Procurement Prices, which procures

between 22-37 million tonnes per annum (2011-2014);

a Public Distribution System;

subsidies on inputs to wheat production (especially fertiliser); and

additional wheat bonuses to farmers in some states.

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Figure 6: Wheat Production and Consumption, India and Australia, 2004 – 2014

Data source: USDA PSD, 2015

There are no applied tariffs on the import of wheat to India, however due the highly distorted prices of

locally produced wheat, imported wheat is generally uncompetitive as a bulk commodity. Current

expectations are for significantly increased exports of wheat to India this year due to India’s rain

damaged domestic wheat production. It has been 5 years since such large imports have been seen,

and as with 2010, it is anticipated to be higher quality milling wheat to blend with downgraded

domestic wheat. Further, international shipping rates are currently historically low meaning that

export to Southern India is relatively cheap compared to domestic transport.

Given the high level of distortion in the Indian wheat market, the landing of Indian wheat in some of

Australia’s key wheat markets, including Malaysia and Indonesia, is of great concern. It is also

understood that there is potential for the use of Indian wheat in some of Australia’s traditional Middle

Eastern markets. This is of concern again because of the high level of distortionary support for wheat

production in India, but even more so because of the freight advantage that India has to the Middle

East.

Going forward there is understood to be a number of issues facing Indian wheat production:

increasing salinization of cropping lands as water tables increase;

increasing budgetary pressure due to the high cost of domestic support policies for wheat.

The cost of the Government Wheat procurement and Public Distribution System is estimated

to be $1,150 billion rupees in 2014/15, having increased an average of 20 per cent per annum

over the past 5 years; and

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ageing wheat varieties and slow development of new more resilient varieties.

However, given the size of the Indian industry, even a small change in production practices if

implemented across the country, or the adoption of genetically modified varieties at some stage in the

future, has the potential to massively increase production potential.

Coarse Grains Production of coarse grains such as barley, sorghum, millet and corn in India is about 35-40 million

tonnes per annum, based primarily on demand from poultry, starch, commercial animal feed

industries and some export demand. Barley is a very small crop in India, comprising about 1.8 million

tonnes annually mostly in recent years for malting and brewing with some new varieties being

adopted to meet this market need (in the north of India under direct contract to domestic breweries).

There is significantly less government intervention in the domestic Indian coarse grain market, with

public procurement and distribution limited.

However, until September 2014, most coarse grains could only be imported by state trading agencies

such as the Food Corporation of India. This restriction was removed and now private traders may

import coarse grains. There remains a 50% import tariff on sorghum and millet, while barley

continues to be imported tariff free. Corn/Maize is imported under a zero per cent tariff rate quota of

500,000 tonnes per annum, with the rate being 50 per cent outside of the quota.

Pulses India is easily the world’s largest producer of pulses producing an average of 18 million tonnes per

annum and accounting for 25 per cent of global production over the 5 years to 2012 (see Figure 7 of

the following page). This is supplemented by net imports of around 3.4 million tonnes to allow total

annual domestic consumption of around 22 million tonnes.

Exports of pulses have been restricted since 2006 when it was implemented as a short-term food

security measure. The restrictions, which have remained as a result of multiple extensions, are to all

pulses with the exception of organic pulses and lentils to a limit of 10,000 tonnes and Kabuli variety

chickpeas.

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Figure 7: Average Proportion of World Pulse Production, by Country, 2008-12

Chick pea production accounts for almost half of all Indian pulse production (over 48%), with lentils (15%), mungbeans (8%) and black gram/black lentils (9%) also important pulse crops. The import of pulses to India is subject to tariffs of 15 – 30%, while India does offer a tariff of 0% to Less Developed Countries (LDCs).

Data source: ABARES, 2015

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Mutual benefits to enhanced grain trade to India

Indian Consumption

India has the production base on which to be a significant player in the international grain trade

market, however with such a large and growing population production is likely to continue to be

consumed domestically. There are a number of trends to be aware of in Indian consumption that do

suggest benefits to the Indian economy from increased grain trade with Australia:

Wheat consumption in India exceeds 80 million tonnes per annum, and this is growing. In

India, it is mostly used as 'atta' (whole wheat flour) in the form of rotis, chapatis, and similar

flat breads;

There is a significant growing trend towards western foods such as burgers, pizza and breads

that do not favour the performance of the vast majority of locally produced wheat;

The increasingly affluent middle class are seeking expanded access to pulses and whole

grain products due to health benefits;

The increasingly affluent middle class has concerns about food safety;

The population is growing significantly and is expected to be have the largest country

population beyond 2028; and

There is good demand for the Desi chickpea variety, which dominates Australian chickpea

production, because it has markedly higher fibre content than other varieties.

Freight advantages reduce costs International ship freight rates are currently at very low levels. The Baltic Dry Index is currently at its

lowest level in 30 years. Combined with the relatively high costs of internal freight movements in

India due to infrastructure constraints, this means that exporting bulk or containerised grain from

Australia to southern India can be cheaper than moving a grain such as wheat from northern India to

southern India. Even in times when freight rates have been higher, movement of grains to India from

Australia can be more competitive compared with Indian grain that must be moved domestically.

Production and export of pulses is great for Australia’s grain industry

India is the world’s largest pulse market, and improved access to it, can deliver:

Increased returns to grain farmers due to the higher value of pulses.

Pulses typically range in the order of $400 - $600/tonne, compared to wheat which ranges in the order of $250 - $350/tonne (notwithstanding they have different risk profiles).

Decreased costs because including pulses in crop rotations increases plant available nitrogen to the next crop planted in that paddock.

A large cost in wheat and barley production is nitrogen application at sowing (via start up fertilisers) and during the growing season (top dressing). This cost is minimised when pulse crops are including in cropping rotations because of the process of nitrogen fixation that naturally occurs in the growth of pulses.

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Increased protein and higher wheat prices

Pulse crops can provide the equivalent up to 100kg/ha of urea to a soil profile if managed correctly. In such cases, a pulse crop cannot just increase potential yield of the following wheat crop, but also protein which translates to higher returns per tonne.

An addition approach to disease management.

The possibility of including a profitable pulse crop in your farm rotation also provides a biological

approach to disease management. Disease carrying wheat or barley stubble is often significantly

reduced or eliminated during a pulse crop rotation, because the disease cannot find a host. The

same applies for insect pests as many insect pests cannot be hosted on pulse crops.

Exporting Australian grains to India

There are a range of reasons why increased exports of Australian grains to India could benefit both

India and Australia. However, there a range of practical issues to consider in the import process.

Import Conditions

Indian import conditions are based on Plant Quarantine (Regulation of Import into India) Order, 2003.

India issues import permits for plants and plant products especially grains and seeds. For detailed

information on import conditions for various plants and plant products to India, refer to Schedule IV of

the Plant Quarantine (Regulation of Import into India) Order, 2003

(http://plantquarantineindia.nic.in/PQISPub/html/cannottake.htm#). A summary of these is provided

as Appendix 1.

To obtain market access for a grain which doesn’t have access India, the Australian Department Plant

Biosecurity develops a technical market access submission. India may then conduct a Pest Risk

Analysis and then provides the opportunity for review of their draft finding. Following negotiation,

market access may then be given with import conditions to manage the identified biosecurity risks.

Until it is published in India Gazette and become part of Quarantine Regulation, export the product is

not possible although technically market access has been granted.

Australian protocols for import have not been signed with India for any plant products. Indian import

conditions are solely based on Plant Quarantine (Regulation of Import into India) Order, 2003.

A summary of the current Indian import requirements for grains is included as Appendix 1 to this

document. The key concern relating to the import requirements is the stipulated use of Methyl

bromide fumigant. Since 1 January 2005, all uses of Methyl bromide, other than for certified

quarantine and pre-shipment (QPS), approved feedstock applications, or approved under critical use

exemptions, have been prohibited in Australia under the Ozone Protection and Synthetic Greenhouse

Gas Management Act 1989 (the Act). The manufacture, import and export of methyl bromide are

also controlled under the Act and associated regulations.

The consequence of phase out and regulation, is that it Methyl Bromide is expensive, adding around

$10 per tonne to the cost of grain. Cheaper alternatives such as phosphine or sulphuryl fluoride could

be investigated, and further the requirement for pre-export fumigation should be reviewed given the

uncommon requirement for pre-fumigation internationally. Another, also expensive requirement for

some grains, such as Canola, is Devitalisation. These pre-shipment requirements often make the

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Indian market an uneconomical market to pursue and limit the possibility of Indian consumers

accessing Australian grains.

Tariffs

As described in previous sections, Indian grains are generally subject to high levels of tariffs on

import. Of particular interest for Australia are the tariffs on pulses. These range from 15-30%, and

are summarized along with other grain tariffs in Table 4 below.

Table 4: Tariffs on Australian Grain Imports to India

Tariffs faced by Australian Imports (%)

Other

Wheat Seed 50 MFN

Grain 0 MFN

Barley Seed 0 MFN

Grain 0 MFN

Sorghum Seed 50 MFN 0% LDC

Grain 50 MFN 0% LDC

Oats Seed 0 MFN

Grain 0 MFN

Maize Seed 50 MFN 0% LDC

Grain 50 MFN 0% LDC

Canola Seed 30 MFN 0% LDC

Grain 30 MFN 0% LDC

Pulses Australian

Lupins

15 MFN 0% LDC

Chickpeas 30 MFN 0% LDC

Lentils 30 MFN 0% LDC

Peas (various) 30 MFN 0% LDC

Beans

(Various)

30 MFN 0% LDC

Other Buckwheat,

millet, canary

seeds

Special categories at 50%, others 0%

LDC: Preferential duty scheme for least developed countries (LDC) Source: WTO, TAO

MFN: Most Favoured Nation under WTO

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Removal of these tariffs for Australian pulses, in particular, offers Indian consumers the opportunity to

increase consumption at lower cost and Australian grain producers enhanced profitability.

Import clearance process

One of the key risks exporting grains to India results from import clearance processes. In order to expedite cargo through ports, pre-clearance is undertaken. However, if receipt of goods is not subsequently undertaken and payment made, there is no mechanism for the re-export of grains from India. This results in distressed cargo and the need to quickly find an alternative Indian buyer, generally at a significantly lower price. Exporters to India cite this as a significant risk of trading grain to India, and only negated if you have a long standing relationship with a local agent, which itself comes at a cost. Such a cost and arrangement is generally not sustainable if the trade presents itself only opportunistically. Investigation of the process of clearance and potential to retain the right of re-export could be investigated as part of trade negotiations.

Summary

This submission provides contextual data and commentary regarding India’s grain market and Australia’s trade with India, and then within this context, the key areas that an Australia-India Comprehensive Economic Cooperation Agreement, should address to benefit the Australian grains industry. In brief these areas are: High tariffs on some grains. Removal of all tariffs on Australian pulses would be a minimum

outcome required of any agreement with India; Import clearance processes. Import clearance processes currently introduce additional risk to

Australian exporters and review of this system would be appropriate; Import requirements. Import requirements, including fumigation and devitalisation are costly so

that the market is less desirable despite underlying demand. Review of these requirements is desirable; and

Highly distorting domestic wheat policies, are creating long term resource allocation problems for India and mean that Australian wheat is uncompetitive despite demand for its high protein. Commitments to pursuance of reductions in distortionary domestic policies in Indian are sought.

Pursuit of a trade enhancing agreement with India is desirable however the priority of such is reduced for the Australian Grains industry due to: d) The relatively modest proportion of our current market that it currently accounts for; e) The volatility in its demand; and f) The apparent incapacity to reduce high levels of domestic support and market intervention policy

in Indian grains markets, especially that for wheat.

Further, if any agreement were to deliver any possibility of undermining the competitive position of

Australian grain production globally, the priority of engagement with the Indian market would fall

further. Examples of such would include the export of key production technologies and capacities, or

agreement provisions which undermined Australia’s biosecurity.

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References

ABS – data sourced directly

DFAT (2014) Composition of trade Australia 2014. www.dfat.gov.au

Hamshere, P, Sheng, Y., Moir, B., Gunning-Trant, C., and D. Mobsby (2014) What India wants,

Analysis of India's food demand to 2050,Research by the Australian Bureau of Agricultural

and Resource Economics and Sciences, Report No. 14.16 November 2014

Plant Quarantine (Regulation of Import into India) Order, 2003

(http://plantquarantineindia.nic.in/PQISPub/html/cannottake.htm#).

USDA PSD (2015) USDA Foreign Agricultural Service Production, Supply and Distribution Online,

https://apps.fas.usda.gov/psdonline/

UN (2012) World Population Prospects: The 2012 Revision, United Nations,

http://esa.un.org/unpd/wpp/index.htm

WTO (2015) Tariff Analysis On-line (TAO). tao.wto.org

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Appendix 1

Wheat (Triticum spp) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Dwarf bunt

(Tilletia controversa), Granary weevil (Sitophilus granarius), Rye ergot (Claviceps purpurpea), 31 Quarantine

weed seeds as per schedule VIII of PQ order 2003 and soil has to be endorsed on the phytosanitary certificate.

Barley (Hordeum spp) for consumption

It requires an import permit and freedom from Granary weevil (Sitophilus granarius), Rye ergot (Claviceps

purpurpea) are to be endorsed on the phytosanitary certificate. It has to be fumigated with Methyl bromide at 32

g/m3 for 24 hours at 21˚C or above, under NAP or equivalent or by any other fumigant/ substance in the manner

approved by the Indian Plant Protection Advisor. The details of the treatment are to be endorsed on a

phytosanitary certificate.

Sorghum (Sorghum spp) seed for sowing

We have market access for Sorghum seed for sowing which is not a big market. It requires an import permit and

freedom from (a) Bacterial blight (Burkholderia andropogoni), Bacterial leaf streak (Xanthomonas vasicola pv.

holcicola), Milo disease (Periconia circinata, Striga weed (Striga harmonthica) and Sorghum viruses viz. chlorotic

spot, mosaic has to be endorsed on the phytosanitary certificate.

No access for sorghum for consumption

Oats (Avena sativa) for consumption

It requires an import permit and treatment with Methyl bromide at 40g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Stem

nematode (Ditylenchus dipsaci), Culm rot: cereals (Fusarium culmorum), Foot rot: cereals (Monographella

nivalis) and Sharp eye spot of cereals (Ceratobasidium cereale), Flat grain beetle (Crytolestes ferrugineus),

Warehouse beetle (Trogoderma variabile), 31 Quarantine weed seeds as per schedule VIII of PQ order 2003 and

soil has to be endorsed on the phytosanitary certificate. However, kiln dried oats require a phytosanitary

certificate with no additional declarations and treatment.

Chickpeas (Cicer) for consumption

It requires an import permit and treatment with Methyl bromide at 40g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from 31

Quarantine weed seeds as per schedule VIII of PQ order 2003 and soil has to be endorsed on the phytosanitary

certificate.

Mung beans, Adzuki beans, cowpea (Vigna spp) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from 31

Quarantine weed seeds as per schedule VIII of PQ order 2003 and soil has to be endorsed on the phytosanitary

certificate.

Canola (Brassica napus; Brassica rapa)

Access required devitalisation of the seed.

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Lupins – splits (Lupinus spp) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Phomopsis

seed decay (Phomopsis longicolla), Stem blight of lupins (Phomopsis leptostromiform) and Phytophthora root,

stem rot (Phytophthora sojae),31 Quarantine weed seeds as per schedule VIII of PQ order 2003 and soil has to

be endorsed on the phytosanitary certificate.

Lentils (Lens culinaris) for consumption

Require an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Stem and

bulb nematode (Ditylenchus dipsaci), 31 Quarantine weed seeds as per schedule VIII of PQ order 2003 and soil

has to be endorsed on the phytosanitary certificate.

Millet

Australia does not have market access for millet to India.

Broad beans/Faba beans (Vicia faba) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Soybean

cyst nematode (Heterodera glycines), Stem and bulb nematode (Ditylenchus dipsaci), 31 Quarantine weed seeds

as per schedule VIII of PQ order 2003 and soil has to be endorsed on the phytosanitary certificate.

Maize (Zea mays) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Maize

ergot (Claviceps gigantean), Larger grain borer (Prostephanus truncatus), Maize weevil (Sitophilus zeamais) and

soil to be endorsed on a phytosanitary certificate.

Peas (Pisum spp) for consumption

It requires an import permit and treatment with Methyl bromide at 32 g/m3 for 24 hours at 21˚C or above, under

NAP or equivalent or by any other fumigant/ substance in the manner approved by the Indian Plant Protection

Advisor. The details of the treatment are to be endorsed on a phytosanitary certificate. Freedom from Pea cyst

nematode (Heterodera goettingiana), Stem and Bulb nematode (Ditylenchus dipsaci) and Bruchids (Bruchidius

spp Specularis impressithorax), 31 Quarantine weed seeds as per schedule VIII of PQ order 2003 and soil has to

be endorsed on the phytosanitary certificate.

Safflower (Carthamus tinctorius) for Processing

It requires an import permit and ffreedom from 31 Quarantine weed seeds as per schedule VIII of PQ order 2003

and soil has to be endorsed on the phytosanitary certificate OR seeds are to be devitalized by heat treatment at

120˚C for 15 minutes.