Sustainability claims for international markets

24 February 2025

Credentials and Digital Innovation
Department of Agriculture, Fisheries and Forestry
Agriculture House
70 Northbourne Avenue
Canberra ACT 2601

Via email: credentials.innovation@aff.gov.au

welcomes the opportunity to share feedback to the
Department of Agriculture, Fisheries and Forestry (department) on international market requirements for proof of sustainability claims.

is representing accredited cattle feedlots, with approximately
1.4 million cattle on feed. The feedlot industry makes up 47% of the cattle slaughtered in Australia and contributes to over 35% of Australia’s total beef exports. As a key contributor to a trade-exposed industry, up-stream supply chain operators, such as meat processors, retailers, and exporters, rely heavily on the feedlot industry for the supply and export of high quality, safe, grain-fed beef to feed families in Australia and abroad.

The Australian feedlot industry is committed to sustainability and the nourishment of cattle, land and communities. Quality beef comes from cattle that are healthy and productive. The feedlot industry knows that it is imperative that all livestock are well cared for from the time they arrive at the feedlot to when they leave. Every aspect of their welfare is planned and monitored by trained staff, including diet formulation, health program and social stimulation. Additionally, feedlots acknowledge that they have the responsibility to ensure the achievement of ecologically sustainable development, embracing sound environmental management of feedlot facilities and continual review environmental performance. Cattle on grain-based diets at feedlots reach their ideal weights efficiently resulting in a measurable reduction in carbon emissions.

Feedlots support over 49,000 people through direct and indirect employment opportunities. The industry values a workforce that is skilled and places importance on providing best practice education and training for feedlot employees. is proud to showcase the lot feeding industry’s commitment to innovation, sustainability, and animal welfare, highlighting the vital role our sector plays in the broader red meat industry.

has reviewed the discussion paper, making the following comments on the relevant consultation questions:
In addition to the regulatory requirements listed in Section 2.1, the European Union (EU) has prohibited the use of antimicrobials for growth promotion or increased yield in animals imported into their food system from September 2026. This will impact Australian beef exported to the EU.
Most Australian antimicrobial products are only labelled for preventing or controlling diseases, important factor for sustainable grain-fed beef production. These uses will not be restricted. For a small number of affected antimicrobial products, the new EU regulations will prohibit their use for growth promotion (but not for any labelled uses to prevent or control disease).

As you may be aware, the department is working with industry representatives to change the EUCAS rules to comply with the new requirements. The new EUCAS rule is expected to apply from May
2025. The department has recommended that EUCAS producers prepare for the change by reviewing all antimicrobial products used on property or included in feeds and supplements to ensure they are only used to control or prevent diseases.

It is important to acknowledge the important role that veterinary medicines such as antimicrobials play in animal welfare. In many cases there are limited options available, meaning that banning or limiting use can have a significant impact on health outcomes. It is important that veterinarians are able to appropriately prescribe and treat cattle in their care. Effective health management enables positive animal welfare outcomes and greater industry sustainability.

Other expectations required in addition to those listed in Section 2.2 include the following the EU
Deforestation Regulation (EUDR):
Human rights as protected by international law;
The principle of free, prior, and informed consent (FPIC) as outlined in the UN Declaration
on the Rights of Indigenous Peoples;
Taxation, anticorruption, trade and customs regulations.

Market access (including some sustainability claims outlined in Section 2.2) are evidenced through the National Feedlot Accreditation Scheme (NFAS). NFAS is an independently audited quality assurance program for the Australian lot feeding industry that is managed by AUS-MEAT through the Feedlot Industry Accreditation Committee (FLIAC). The NFAS underpins the integrity of the Australian lot feeding sector and includes a dedicated animal welfare and environment modules.

NFAS includes specific minimum requirements for the production and specification of grain fed beef. It enables cattle to be presented to the abattoir to be eligible for grading as ‘certified grain fed beef’. Under the Export Control Act 2020 and Export Control (Meat and Meat Products) Rules
2021, beef labelled as ‘grain fed’ must come from an NFAS accredited feedlot.

supports the statements regarding the industry sustainability frameworks, noting the important role the Australian Beef Sustainability Framework (ABSF) plays in highlighting sustainability within the beef industry. It is evidence of sustainability within the industry as a whole, and supplements claims made by individual businesses. It is a single point of truth, and provides a snapshot of key industry facts, figures and indicators.
Requirements as listed above and in consultation paper.

There is the opportunity to further evidence sustainability within the feedlot industry through the use of NFAS data. NFAS provides assurance that grain-fed cattle are managed in a way that goes above and beyond what is required within legal frameworks. The NFAS is a vehicle by which industry could demonstrate achievements and improvements through third party audit and accreditation.
NFAS data could be utilised through AUS-MEAT and the Australian Meat Industry Language in the context of the Standards Committee (AMILSC) and the review of the Beef and Sheep Animal Raising
Claims (ARC) Framework.

The ABSF was initiated by industry in 2015. The ABSF is used by industry to guide and track performance on-farm and through the value chain to ensure that Australia continues to be recognised as a global leader in sustainable beef production. A focus on aligning environmental, welfare, social and economic practices with best evidence and community expectations, while growing profitability will help ensure continued access to markets and capital for Australian beef businesses. The ABSF provides consumers, customers, industry and other interested stakeholders with a clear snapshot of the beef industry’s performance across environmental, welfare, social and economic areas. The ABSF uses data from NFAS to demonstrate sustainable practices within the feedlot industry.

Further, the Livestock Production Assurance (LPA) program is proactively working with industry to develop a sustainability module that will leverage existing tools and systems. It is intended that the
LPA sustainability module won’t be mandatory however, will help producers strengthen their business practices and set themselves apart in an increasingly competitive market. The additional module is in recognition that Australia's sustainability credentials have the potential to be critical to future market access requirements.

Whilst the topics listed in section 3.2 are critical aspects of sustainability, and would support claims, it is important to consider how industry may practically demonstrate them in a way that is meaningful and not overly burdensome.

For example, the methodology for calculating GHG emissions within feedlots is currently under review. Meat and Livestock Australia (MLA) is working on a new equation for feedlot emissions, as
Australian feedlots emissions are likely overestimated by approximately 30%. This equation is still going through the process for acceptance by the National Inventory.

Further, modern slavery and labour conditions are currently not included in the NFAS or industry guidelines. This measure relies upon compliance with commonwealth and state and territory legislation, as well as individual business policies and practices.
are dedicated to preserving the effectiveness of antimicrobials, and to protecting human and animal health, by promoting responsible antimicrobial use. Antimicrobial stewardship describes practices and protocols designed to reduce the need for antimicrobial use and to ensure that when antimicrobials are required, they’re utilised in a way that maximises efficacy while minimising adverse effects – including the development of antimicrobial resistance. Antimicrobial stewardship is a key component of the animal health module in NFAS.

As above.

As above.

There are a number of challenges across the agricultural sector in providing the necessary evidence to satisfy international market demands. Challenges within the lot feeding sector include:

Lack of regulatory certainty: There is constant change and uncertainty in government
regulation and market requirements that are not necessarily science-based. Ongoing
communication and the establishment of relationships is essential, to enable industry to tell
their sustainability story and respond to early market indicators.
Complexity of regulatory requirements: As regulations and market requirements evolve,
different markets have developed their own distinct standards and regulations making it
difficult for producers to manage documentation and evidence requirements.
Data collection and management: There are high resourcing costs (labour, skills,
technology) associated with the collection and management of data. Data often must be
collated and verified from multiple sources.
Technology and infrastructure: Connectivity issues often impede the transfer of data in a
timely manner.
Transparency and traceability: International markets often require full traceability of
agricultural products, including detailed records of where and how a product was grown,
processed, and transported. This requires robust and transparent systems for tracking each
stage of the product’s journey.
Financial constraints: The costs associated with collecting and managing evidence can be
prohibitively, especially if there is no premium associated with providing additional data or
evidence.
Logistical challenges: Gathering evidence often requires coordination between multiple
parties along the supply chain. Due to the position of feedlots within the supply chain, there
is currently limited ability to access data pre and post feedlot entry. Lot feeders are reliant
on relationships to gather data. There are also challenges and costs with segregating animals
or feed or differentiated management practices based on market requirements, for example
use of palm oil in some rations but not others.
Data privacy and security: As the agricultural sector adopts more digital tools for data
collection and reporting, the risk of cyberattacks and data breaches increases, potentially
compromising evidence and harming the reputation of producers.
Inconsistent impact: Climate change impacts vary widely across different geographic
regions. What works as a sustainable practice in one area may not be applicable in another,
making the collection of standardized evidence difficult for international markets. These
geographical nuances are coupled with different definitions and interpretations of
sustainability and what in means in different contexts, for example the definition of
‘deforestation’.
Evolving science: As previously mentioned, MLA is working on a new equation for feedlot
emissions, as Australian feedlots emissions are likely overestimated by approximately 30%.
This equation is still going through the process for acceptance by the National Inventory.

The above challenges can be overcome through meaningful consultation with industry, and strong and united representation and advocacy by government and industry partners involved in trade negotiations. There must also be an understanding of the industry practicalities and limitations, for example the commercial viability and ability to adopt on a commercial scale technology such as methane inhibiting feed additives.

As previously discussed, ABSF has an important role to play in demonstrating sustainability within the beef industry. The ABSF is draws on existing NFAS and LPA datasets to highlight and support sustainability claims. This data can be further drawn upon to showcase that sustainability underpins the majority of practices and decisions within the Australian beef industry.

As above.

As above.

Nil.

International markets rely on the involvement of government to provide assurance through government operated systems or through endorsement of industry led frameworks (like ABSF) that are supported by quality data. There is an opportunity for government to work within industry to showcase the sustainable practices within the feedlot industry, and present data to back-up these claims.

As above.

Existing methods must be evaluated, to determine what enhancements can be made and how gaps can be addressed.
Thank you for the opportunity to provide feedback on international market requirements for proof of sustainability claims. Should you have any questions or require further information, please contact

Sincerely,