Crop groupings project – consolidated responses to phase one consultation

1. GPA (Grain Producers Australia)

GPA notes the proposed new APVMA crop groupings, particularly the specific cereals, pulse and oilseeds groups.  GPA supports the APVMA in proving clarity of appropriate groupings of crops and supports a pragmatic approach to alignment with current and proposed new international groupings, including CODEX and the United States. There are however some crop omissions, especially for pulses and further clarification required on the proposed groupings.

Pulses crop group additional inclusions required:

• navy bean and borlotti bean—phaseolus vulgaris
• vetch—vicia sativa and vicia villosa
• guar—cyamopsis tetragonoloba
• garbanzo beans added to description of chickpeas—cicer arietinum.

Oilseeds crop group:

• inclusion required of rapeseed with canola
• inclusion required of flax with linseed.

Cereals crop group:

• inclusion of barley max with barley
• clarification required on the approach to inclusion of varieties of popcorn and sweet.

Corn with maize/corn:

• clarification required on the approach to the various millet species included.

In addition, further clarification and discussion is requested on:

• nomination of proposed reference crops for each crop group
• how will minor crops included in each crop group be associated, ie could 2–3 reference crops for minor use to get a minor crop grouping as an alternate?

Summary comments

GPA is committed to further discussion with the Australian government and the APVMA to improve crop group classifications to reduce regulatory burden and improve delivery of new chemical technologies to industries, especially for emerging and minor crops. GPA recognises a key issue in that some of the appropriate crops in a crop group may include minor crops that are never likely to attract investment to support the group. Further discussion on potential APVMA mechanisms to address these investment challenges is required. GPA requests further discussion with the APVMA in response to the omitted crops noted and crop grouping issues raised in this response. There is commitment from GPA to also work cross industry and deliver productivity outcomes to agricultural industries and confidence of the Australian community.

2. Ausveg

AUSVEG welcomes the opportunity to provide comment to the Australian Pesticides and Veterinary Medicines Authority (APVMA) on the proposed Australian crop grouping list.

In particular we will focus our submission on:

• commodities that are not listed but are currently grown, or could be, grown in Australia
• the most appropriate delegation for which group a commodity should be
• the most appropriate common names to be used in the Australian crop grouping.

Crop group: brassica (cole or cabbage) vegetables

Brassica cole vegetables have been a constant basis for crosses and variety emergence. It is important to ensure that the cole vegetable crop group is not too heavily grounded in a limited number of designated varieties.

As a recent example broccolini a hybrid of brassica oleracea var. botrytis and brassica campestris var. albogalbra, has become a significantly more popular crop. Considering the parent commodities, this should fall into the cole vegetable crop group. In addition, there is romanesco broccoli (or broccoflower) that is another new hybrid of brassica oleracea, crossing var. italic and var. botrytis for a combination of flavour and visual aesthetic for use in culinary dishes, which may become another highly popular crop.

AUSVEG would note that kohlrabi is more similar to celeriac and fennel than broccoli or brussel’s sprouts, in that the above ground ‘swelling’ is the part of the plant consumed.

It is the view of AUSVEG that all chemistry that is safe and efficacious for use on currently recognised cole crops would also be safe and efficacious for new hybrids of these current varieties. As such, AUSVEG recommends the inclusion of a line stating 'and all future hybrids of these varieties' into the crop group listing. This will ensure crops that could be produced and grown in Australia are covered in the appropriate crop group.

AUSVEG recommends the inclusion of a line stating 'and all future hybrids of these varieties' into the crop group listing.

Crop group: bulb vegetables

AUSVEG draws attention to a major change from previously listed APVMA crop groups. Fennel was previously listed by the APVMA as a part of the leafy vegetables crop group.

From the APVMA webpage on residue trials to obtain permanent maximum residue limits for crops (residues), in table 3: codex commodity crop groupings, fennel was listed in 013 leafy vegetables (including brassica leafy vegetables) under subgroup 3 in the Important members of group grown in Australia column. In this listing it was documented as ‘fennel’ without any clarification if it meant the leaves, the bulb or the whole crop.

Due to the APVMA listing for fennel under subgroup 3 of 013 leafy vegetables (including brassica leafy vegetables) on that page, several growers have used approved chemistry for the Leafy vegetable crop group under the belief that they are using the correct approved chemistry with support from the APVMA website. With fennel effectively moving to the bulb vegetable crop group, approved chemistry will change for these growers. Current practices will have to be modified and this could adversely affect fennel growers across Australia.

This was the only time fennel was mentioned by the APVMA in relation to crop groups, and as a result it has created the understanding that fennel is in the leafy vegetable crop group. While the United States (US) codex crop groups separated fennel into two groups, group 027 herbs and group 009 bulb vegetables depending upon the end use of the crop, this was not clear or outlined in the Australian crop groups or what the APVMA has provided on their website. Furthermore, if a grower did have access to the US codex crop groups, fennel is not listed in the leafy vegetable crop group at all, and due to the APVMA listing it as subgroup 3 of the leafy vegetable crop group, this has led several growers to believe that it is listed in that crop group in Australia.

AUSVEG recommends that if a change for fennel to the bulb vegetable crop group is continued, that growers must be informed of this through country-wide communication. (from APVMA listing for fennel under subgroup 3 of 013 leafy vegetables (including brassica leafy vegetables RE)

Crop group: cucurbits

AUSVEG has recognised that there are three issues that require comment on in the crop group: cucurbits section.

These are, errors in entries, different common names and additional commodities that are not yet included in the crop grouping list proposed by the APVMA:

• The pumpkin is incorrectly listed as cucurbita maxima, this is actually giant pumpkin in the US. Pumpkin is cucurbita pepo var. pepo. zucchini is cucurbita pepo var. cylindrica. It is unclear as to what the APVMA was intending with the marrow listing, it is referred to as cucurbita pepo, however vegetable marrow (or marrow) is cucurbita pepo var. fastigata. There are numerous varieties of cucurbita pepo that are listed in the additional commodities section. If it was the intention of the APVMA to include all current and all possible new varieties of pumpkin under one single entry in the crop group: cucurbits section, it would be more effective to list pumpkin, and all known varieties (cucurbita pepo varieties).
• Bottle gourd is more commonly referred to as long melon, chi qua (wax gourd) is more commonly known as hairy melon.

Additional commodities:

• spaghetti pumpkin (cucurbita pepo subsp. pepo), several varieties depending on colour and consistency
• butternut pumpkin (cucurbita moschata)
• acorn pumpkin (cucurbita pepo var. tubinata)
• cocozzelle (cucurbita pepo var. ionga)
• crookneck pumpkin (cucurbita pepo var. torticollia)
• scallop pumpkin (cucurbita pepo var. clypeata)
• straightneck pumpkin (cucurbita pepo var. recticollis).

Crop group: fruiting vegetables

AUSVEG has identified two sections for comment regarding crop group.

Fruiting vegetables:

• pepper, sweet is more commonly known as and referred to as capsicum. Peppers, chili is more commonly known as chili. AUSVEG recognises the importance of ‘peppers’ on label as this designation covers both capsicum and chili and would need to be outlined.

Additional:

• thai eggplant (solanum undatum)
• thai pea eggplant (solanum torvum).

Crop group: leafy vegetables

AUSVEG notes three areas for comment in the crop group: leafy vegetables, proposed by the APVMA. These are errors in scientific names, a possible relocation of a commodity listed and additional commodities for inclusion.

Regarding errors in scientific names, AUSVEG as identified several misspellings of brassica (e.g. brasssica, brasica and brassicca). It is imperative that any crop group list is free from unintended errors in scientific names of commodities.

AUSVEG has consulted with agronomists and growers regarding the proposed crop groups developed by the APVMA. It was noted that Wombok (brassica pekinensis) is a head cabbage, and may be best placed in the brassica (cole crop) crop group.

Additional:

• tatsoi (brassica narinosa)
• chinese spinach (arwranthus gangericus)
• japanese mustard spinach (brassica rapa var. perviridis)
• choi sum (brassica parachinenies)
• mustard sprouts (sinapis alba)
• salad rocket (eruca sativa)
• borage greens (borago officinalis)
• melokhia (corchorus oliorius and capsularis)
• zucchini flower (cucurbita pepo var. cylindrica)
• indian lettuce (claytonia perfoliata).

AUSVEG recommends that these additional commodities are included in the crop group: leafy vegetables.

Crop group: legume vegetables

Yard-long bean is more commonly known as snake bean, or long bean.

AUSVEG recommends that the more common name is considered, and has no additional comments regarding this crop group.

Crop group: root and tuber vegetables

AUSVEG recognises the changes in cultural eating practices in Australia that may impact crop grouping.

As an example, galangal is currently listed as both a root and tuber vegetable and a spice due to consumption patterns. Due to the significance of Asian inspired cooking, ginger and tumeric are also consumed in a similar manner as galangal, both as a spice and as an ingredient. AUSVEG recommends the APVMA considers changes in cultural practices, and as a result include ginger and tumeric in the root and tuber vegetable crop group as well as galangal

AUSVEG notes that agronomists have commented on celeriac, the fact that it grows more like fennel as an aboveground tuber and may be best placed in the bulb vegetable crop group. It is important for the APVMA to consider where celeriac and fennel are placed in the new crop groupings

AUSVEG also notes that there is there is only one radish entry, that of white radish. This is listed as raphanus sativus, however there are several radish varieties that are not listed, including red radish and winter radish (or daikon). The APVMA should consider listing radish (raphanus sativus), or separating out all varieties of radish for inclusion in the crop group.

Additional:

• root parsley (petroselinum crispum var. tuberosum).

Crop group: stalk and stem vegetables

AUSVEG has identified two comment areas in this crop group:

• this is in relation to witloof chicory (sprouts) that is more commonly known as Witlof in Australia.

Additional:

• wasabi (eutrema japonicum)
• fiddlehead fern (pteridium aquilinum and athyrium esculentum).

Crop group: herbs

AUSVEG has been contacted by herb growers as well as vegetable growers regarding the proposed crop groupings, and as such will make comment in the crop group: herbs.

There has been one error noted, and several additional commodities for inclusion in the crop group:

• oregano is listed as origanum majorana in the crop grouping, which is incorrect. Marjoram is origanum majorana and oregano is origanum vulgare. Also, marjoram should be included in the crop group.

Additional:

• japanese wild parsley (cryptotaenia japonica)
• asian basil (ocimum basilicum var. thyrsiflora)
• thai coriander (eryngium foetidum)
• vietnamese mint (persicaria odorata)
• stevia (stevia rebaudiana).

Miscellaneous vegetable commodities

AUSVEG has identified two additional vegetable commodities that are not yet included in any crop group, however due to how they are grown, the leaf architecture and overall structure of the vegetables it is difficult to identify an appropriate group for these commodities to be listed in.

Additional:

• water chestnut (eleocharis dulcis, and trapa natans)
• lotus root (nelumbo nusifera).

AUSVEG recommends that the APVMA carefully consider these two commodities, and determines their best placement, or if they will be listed as miscellaneous vegetable commodities that do not adhere to a crop group.

Recommendations

AUSVEG accepts that these crop groups need to be developed to be inclusive of all currently grown commodities and possible future commodities, and we must congratulate the APVMA for this step. It is important to have the crop groupings be flexible enough for further inclusions, as additional commodities have entered the market that were not considered during this round of consultations.

AUSVEG supports the inclusion of the commodities that have been highlighted in this submission, and appreciates the efforts of the APVMA to better develop a comprehensive Australian crop grouping list.

As a final note, AUSVEG recommends that the APVMA review each of the listed crop groups, and actively seeks feedback from ‘bush tucker’ grower and representative groups across Australia for inclusion of native commodities that have not yet been considered or included.

3. Tasmanian Farmers and Graziers Association (TFGA) 

The majority of crop groups and associated individual listings are fine, with the only exceptions are to add the crops pyrethrum and industrial hemp.

Pyrethrum is a natural plant product that is produced by the pyrethrum daisy, tanacetum cinerariifolium, a member of the asteraceae family. Australia grows approximately 60% of the world’s pyrethrum, the majority within Tasmania.

Pyrethrum is concentrated in the flower, with the key part being the seed. The crop is collected using a windrower that is typically used to harvest canola, and then the seed and straw is gathered using a combine harvester.

We would recommend pyrethrum sit within the crop group, oilseed. As it is similar to other crops within Tasmania that are in the same group, where the seed is used, namely canola and poppies.

Industrial hemp (cannabis sativa L), also known as ‘indian hemp’. Industrial hemp is commercially grown to harvest for its fibre or for its seed. Hemp is a tall, annual herbaceous plant which produces fibre and hurd (woody core) from the stem as well as oil from seed.

Harvesting of hemp for fibre occurs as soon as the last pollen is shed but before seed sets, which is normally about 70–90 days after planting. Harvesting for seed would occur 4–6 weeks later than fibre harvest, when 60–70% of the seed has ripened.

Industrial hemp is potentially a crop that will see more hectares grown in the future. Because of its dual purpose it could fit in the crop group oilseed or cereal grains.

Add the crops pyrethrum and industrial hemp.

4. NSW Department of Primary Industries

The consultation paper on the crop groupings project was sent to over 100 professional agronomists, entomologists, pathologists and horticulturalists in the NSW Department of Primary Industries, many responded. Overwhelmingly they supported simplification of the registration process. One respondent said 'the APVMA's proposal to broaden crop groupings to all products is sound and economically sensible as it has already been tested and approved for pesticide labels for generic fruit fly hosts'.

Many minor crops rely heavily on the permit system as there are few products registered for minor crops. The process of renewing permits and acquiring new permits is expensive. Often a number of small industry groups pay for a permit for individual crops that could be covered by a commodity group such as berries.

Many respondents expressed the hope that overseas data from the same or a similar commodity could be used to support applications and that all states could be on the label as a matter of course.

Additional—there appears to be a significant number of crops which are currently grown or could be grown in Australia which are not listed in the consultation paper:

• temperate pasture legumes including biserrula (biserrula pelecinus), clovers (trifoliumspp.), medics (medicago spp.), serradella (ornithopus spp.) and vetches (vicia spp.), lotus (lotus spp.) and sulla (hedysarum coronarium)
• temperate pasture grasses including brome grasses (bromus spp.), cocksfoot (dacytlis glomerata), tall fescue (festuca arundinacea), phalaris (phalaris aquatica), puccinellia (puccinellia ciliate), ryegrass (lolium spp.), tall wheat grass (thinopyrus ponticum), timothy (phleum prantense)
• tropical legumes including American jointvetch (aeschynomene americana), carribbean stylo (stylosanthes hamata), siratro (macroptilium atropurpureum), axillaris (macrotyloma axillare), burgundy bean (macroptilium bracteatum), butterfly pea (clitoria ernatea), creeping vigna (vigna spp.) desmanthus (desmanthus virgatus), forage peanut (arachis pitoi), glycine (neonotonia wightii), desmodium (desmodium intortum), roundleaf cassia (chamaecrista rotundifolia)
• tropical grasses include paspalum (paspalum spp.), bluegrass (bothriochloa spp), floren bluegrass (dichanthium aristatum), buffel grass (cenchrus ciliaris), couch grass (cynodon dactylon), digit grass (didgitaria spp.), kikuyu (pennisetum spp.), lovegrass (eragrostis spp.), molasses grass (melinis minutiflora), panic grasses (panicum spp. and megathyrsus spp.), pigeon grass (setaria spp.), rhodes grass (chloris gayana), sabi grass (urochloa mosambicensis), setaria (setaria sphaceiata)
• pasture herbs include chicory (chicorium intybus) and plantain (plantago lanceolate).
• fodder brassicas include forage rape, leafy turnips and forage brassica hybrids, kale, turnips and swedes (brassica spp.)
• other crops include hops, poppies, sugar cane, hemp, tea and tobacco.

Allocation of particular commodities to certain crop groups:

• cotton appears as an oilseed (for cottonseed) and not under any separate category for fiber crops
• species within a cropping group should be botanically or taxonomically related eg bulb vegetables would be better described as allium (onion/shallot/garlic type vegetables)
• buckwheat, canihua and quinoa are not true cereals as they are not grasses. Uptake and tolerance of these species to pesticides is likely to be quite different to that of true cereals
• many of the crop groups include both summer and winter growing or tropical and temperate species. It is likely that pest, disease and weed issues vary greatly between similar species with different growing seasons
• rice is the only cereal grown completely under water. It has an entirely different pest and disease profile to most other dryland and irrigated crops
• jambolan is syzigium cumini has an edible peel so maybe should be in that grouping
• tonka bean dipteryx odorata may be better placed in spices
• chinese mushroom is probably more commonly called straw mushroom.

Agreed common names which should be used in the Australian crop grouping system. The names used in latest revision pesticide tolerance crop grouping from the international crop grouping consulting committee. While some American names for fruit and vegetables differ, such as rock melon/cantaloupe, they are generally universally understood.

Legislative considerations—states and territories are responsible for control of use legislation and regulation. In NSW the Pesticides Act 1999 and the Pesticides Regulation 2009 are likely to require significant review and amendments to accommodate changes to labelling resulting from crop groups being applied to labels.

General comments

Crop groups would appear to work well for insecticides and fungicides as the incidence of phytotoxicity issues are low. However extreme caution is recommended in applying crop grouping to herbicides as there is a wide range of tolerance or sensitivity between varieties within a species and even greater differences between species:

• some of the risks associated with establishing crop grouping may include
• unexpected phytotoxicity in crops that are not assessed
• poor efficacy in crops that are not assessed
• unexpected residue issues in crops that are not assessed
• producers experimenting with pesticides that are unfamiliar
• resistance due to growers applying a single product to a wide range of crops over prolonged periods.

Suggested changes in naming:

• mushrooms
  • king brown mushroom is pleurotus eryngii not boletus edulis
• tropical and subtropical fruits—edible peel
  • jaboticaba is now classified as plinia cauliflora
  • otaheite gooseberry is spelled phyllanthus distichus
• tropical and subtropical fruits—inedible peel
  • naranjilla is solanum quitoensis.

5. Australian Herb and Spice Industry Association Ltd

Comments have been provided from the Australian Herb and Spice Industry Association Ltd of herbs and spices traded in  Australia as fresh or dried, and tried to categorise them in terms  of value of trade, and possible crop groupings. As this is an entirely voluntary contribution I trust that you will forgive any errors or omissions. I am happy to discuss offline and participate in the Crop Grouping process going forward. I understand that there has been a Codex project, managed out of India re dried herb and spice grouping.

6. Kevin Bodnaruk—on behalf of industry groups

Citrus

A few typo corrections for citrus, plus the addition of kumquats c. japonica

Crop name	Scientific name
Citron	Citrus medica
Grapefruit	Citrus paradisi
Lemon	Citrus limon
Limes	Citrus aurantifolia, citrus limetta, citrus latifolia, citrus australiasica, citrus australis, citrus glauca, citrus papuana, citrus garrowayi, citrus warburgiana and citrus inodora
Mandarins	Citrus reticulata, citrus nobilis, citrus deliciosa, citrus tangerina, citrus mitis and citrus unshiu
Oranges	Citrus aurantium and citrus sinensis
Shaddocks or pomelos	Citrus grandis and citrus paradisi
Kumpuats	C.japonica

Stonefruit

Additions to consider for stone fruit

Crop name	Scientific name	Additional crops
Apricot	Prunus armeniaca	Japanese apricot (p.mume)
Cherry	Prunus cerasus, prunus avium and prunus cerasifera
Nectarine	Prunus persica var. nectarine (alternative p. persica var. nucipersica)
Peach	Prunus persica	Doughnut peach (p.persica var. platycarpa)
Plum	Prunus domestica, prunus insititia, prunus angustifolia, prunus salicina, prunus spinosa	Interspecific plums (addition of category to cover hybirds of the different (prunus species) eg plumcot, pluot etc)

Edible fungi

I don’t believe the two additions at the bottom are commercially cultivated but actively foraged in forests. However, I have seen saffron milk caps being sold at harris rarm so I thought I’d include them given they have been traded.

Crop name	Scientific name
Blewitt	Lepista nuda
Bunashimeji	Hypsizygus marmoreus
Chinese mushroom	Volvariella volvacea
Enoki	Flammulina velutipes
Hime-matsutake	Agaricus blazei
Hirmeola	Auriculari auricula
King brown mushroom	Bolteus edulis
Maitake	Grifola frondosa
Morel	Morchella spp.
Nameko	Pholiota nameko
Net bearing dictyophora	Dictyophora indusiata
Oyster mushroom	Pleurotus spp.
Pom pom	Hericium erinaceus
Reishi mushroom	Ganoderma lucidum
Rodman's agaricus	Agaricus bitorquis
Shiitake mushroom	Lentinula edodes
Shimeji	Tricholoma conglobatum
Stropharia	Stropharia spp.
Truffle	Tuber spp.
White buttom mushroom (synonyms portobello mushroom, swiss brown)	Agaricus bisporus
White jelly fungi	Tremella fuciformis
Wood ear mushroom	Auricularia suricularia-judae
Additional crops
Saffron milk cap	Lactarius deliciosus
Slippery jack	Boletus portentosus

7. Tree Nuts—Australian Walnut Industry association Inc. (AWIA), Chestnuts Australia Inc. (CAI), Hazelnut Growers of Australia Inc. (HGA), Pistachio Growers’ Association Inc. (PGAI)

Note:

• there is a specific and separate crop grouping list for ‘tree nuts’
• chestnuts, hazelnuts, pistachios and walnuts are included in the ‘tree nut’ crop list.

As such the relevant industry organisations are comfortable with the proposed ‘tree nut’ grouping. The industry organisations agree with the common crop names as listed being utilised within the crop grouping system.

Representatives of the Australian Walnut Industry Association Inc, Chestnuts Australia Inc, Hazelnut Growers of Australia Inc and Pistachio Growers’ Association Inc, collectively or individually, would be pleased to expand on these and other issues at any time in the near future.

8. Cotton Australia

Recommendation 

In regards to the public consultation for the crop grouping project, Cotton Australia advises that the common name for all gossypium spp. should be changed to 'cotton' in preference to the current listing of 'cottonseed'.

Rationale

In common usage, 'cottonseed' refers to a very specific plant fraction and is only one of several marketable products to be derived from the cotton plant (lint, seed, oil and vegetative biomass).

For example, the term 'cottonseed' is not inclusive of the lint (fibre) fraction of the plant, which constitutes the bulk of the Australian cotton market.

Alternately, the common name 'cotton' refers to the whole plant and all marketable products derived from the plant, which is consistent with common names for all other crops listed as part of the crop grouping project.

9. Grains Industries—new genes for new environments, Department of Agriculture and Food, Western Australia

Looked at the listings and contents for the proposed crop grouping, and I have not been able to find the pasture spp used in agriculture. ie the trifolium (clover) and medicago (medic) spp. Could you please acknowledge that they are listed, and in which group please.

10. National Working Party on Grain Protection (NWPGP)

The NWPGP submission has provided their comments which:

• is relatively self-explanatory
• relates to grain commodities only
• includes changes as outlined in our submission for the crop groups outlined by APVMA in the call for submissions.
• includes commentary under each crop group where further consideration may be required, potentially in the second phase of the review.
• notes that given the current discussion/review of crop groups and commodities within those crop groups at CCPR, we request APVMA consider future CCPR changes and their impacts on the crop groups developed for Australia.

As the grain industry members who are part of this submission have an interest in the outcomes of this APVMA review, we plan to provide input into the second stage of the review. Therefore please keep me informed of developments.

11. Crop Care Australasia Pty Ltd

A number of comments in relation to the proposed Australian crop grouping list out for public consultation:

• berries—youngberry—does this need to be added or is it covered by dewberry?
• citrus—clementine—does this need to be added or is it included within the mandarin group?
• cucurbits—kiwano—does this need to the added?
• fruiting veg—bush tomato, cherry tomato, goji berry—should these be listed  individually (they have different scientific name to tomato)
• herbs marjoram—does this need to be added? Aniseed myrtle—does this need to be added? Chia, hops—are these part of herbs (dried) and need to be added? Lemon grass, kaffir lime leaves—do these need to be added under herbs or somewhere else?
• legume veg—lupins—should they be included in this group as well as pulses (are they ever consumed fresh?) Snow peas and sugar snap peas—should they be individually listed or are  they covered by 'peas (pods and succulent = immature seeds)'
• oilseed—soybean—has it be decided that soybeans will no longer also be considered an oilseed (as well as a pulse and leg veg)?
• pulses—navy bean—should this be listed separately?
• root and tuber veg—white radish—can this just be listed as 'radish'
• spices—saffron—should this be added
• tropical and sub trop fruit (inedible peel)—pitaya (dragon fruit)—should this be added?

Additional groupings/crops not covered:

• sugarcane, tea, coffee.

The individual industry groups will be best placed to nominate new crops recently introduced/now grown in Australia.

12. NT Farmers

Been through the proposed crop grouping lists and have a couple of tropical crops that are grown commercially in the top end or north Queensland, most on a small scale, that don’t appear to have made the lists:

• citrus: kumquot  'citrus japonica'
• herbs: vietnamese coriander(vietnamese mint) persicaria odorata
• tropical and sub-tropical fruit inedible peel: dragon fruit hylocereus * langsat  lansium parasiticum chempedak artocarpus integer.

I also have a query from a grower whether citrus maxima could be included in the scientific name for pomelo, along with citrus grandis.

13. The Chia Company

We are keen to have chia (salvia hispanica) included within the oilseed crop group.

I have also had a quick review of the other crop group lists and thought they covered all species that we currently produce, however we would also like to include grain amaranth (amaranthus spp.) in the oilseed crop group as well, which we possibly will work on in the future.

Chia is most similar to canola and quinoa in growth habit and it is a broadleaf (not a grass/cereal). Chia seed is also high in oil, although not quite as high in total oil content as canola.

In our previous/current APVMA permit applications and general discussions with APVMA, we typically compare with/to oil seed crops such as canola, cottonseed and others for residue comparisons and/ but we also compare with pulses, such as soybeans, in terms of comparatively similar chemistry application, residue activity and MRL work.

14. Growcom

Growcom have submitted the following table of comments:- 

Crop grouping	Commodities that are not listed but are currently grown or could be grown in Australia	Allocation of particular commodities to certain crop groups	Agreed common names which should be used in the Australian crop grouping system	Comments
Brassica (cole or cabbage) vegetables	Broccolini			Broccolini is a green vegetable similar to broccoli but with smaller florets and longer, thin stalks. Often misidentified as young broccoli, it is a hybrid of broccoli and kai-lan, both cultivar groups of brassica oleracea. It was originally developed by the Sakata Seed Company of Yokohama, Japan, in 1993 as 'aspabroc'. The entire vegetable is consumable, including the occasional yellow flower. In Australia Broccolini® is a registered trademark licensed to Perfection Fresh Australia by the Sakata Seed Company.
Citrus fruits	Kaffir lime		Kaffir lime The oxford companion to food recommends that the term 'makrut lime' be favoured over 'kaffir lime' because Kaffir is an offensive term in some cultures	Kaffir lime (citrus hystrix), sometimes referred to in English as the makrut lime or mauritius papeda, is a citrus fruit native to tropical Asia, including India, Nepal, Bangladesh, Thailand, Indonesia, Malaysia and the Philippines. The rind (peel) is commonly used in Lao and thai curry paste, adding an aromatic, astringent flavor. The zest of the fruit is used in creole cuisine to impart flavour in 'arranged' (infused) rums martinique réunion and Madagascar. In Cambodia, the entire fruit is crystallized/candied for eating. The juice is generally regarded as too acidic to use in food preparation (potentially, this also needs to have its leaves included as a herb).
Herbs	Kaffir lime		Kaffir lime The oxford companion to food recommends that the term 'makrut lime' be favoured over 'kaffir lime' because kaffir is an offensive term in some cultures	The kaffir lime (citrus hystrix), sometimes referred to in English as the makrut lime or mauritius papeda, is a citrus fruit native to tropical Asia, including India Nepal Bangladesh, Thailand, Indonesia, Malaysia Philippines. Its fruit and leaves are used in Southeast Asian cuisine essential oil is used in perfumery. The leaves are the most frequently used part of the plant, fresh, dried, or frozen. The leaves are widely used in Thai and Lao cuisine (for dishes such as tom yum), and Cambodian cuisine (for the base paste 'krueng'). Kaffir/makrut lime leaves are used in vietnamese cuisine to add fragrance to chicken dishes and to decrease the pungent odour when steaming snails. The leaves are used in indonesian cuisine balinese cuisine and javanese cuisine), for foods such as soto ayam, and are used along with indonesian bay leaf for chicken and fish. They are also found in malaysian and burmese cuisines.
Leafy vegetables	Beetroot leaves—beta vulgaris var. Conditiva
		Do sprouts such as alfalfa, mustard and snow pea come under this section?
Legume vegetables	Snow and sugar snap peas			Snow pea (Pisum sativum var. saccharatum) is a pea eaten whole in its pod while still unripe. The name mangetout french for 'eat all' can apply both to snow peas and to snap peas. Snow peas, along with sugar snap peas and unlike field and garden peas, are notable for having edible pods that lack inedible fibre (in the form of 'parchment', a fibrous layer found in the inner pod rich inlignin) in the pod walls. Snow peas have the thinner walls of the two edible pod variants. Two recessive genes known as p and v are responsible for this trait. p is responsible for reducing the schlerenchymatous membrane on the inner pod wall, while vreduces pod wall thickness (n is a gene that thickens pod walls in snap peas).
Root and tuber vegetables			White radish—should it just be radish?
Stonefruit	Are you including strange hybrids such as pluots, apriums, airplums or plumcots?			Pluots, apriums, apriplums, or plumcots, are some of the hybrids between different Prunus species that are also called interspecific (or IS) plums. In the United States and Canada, these fruits are known by most regulatory agencies as interspecific plums. Whereas plumcots and apriplums are first-generation hybrids between a plum parent (p. salicina or p. cerasifera or their hybrids), and an apricot (p. armeniaca), pluots and apriums are later-generations. Both names 'plumcot' and 'apriplum' have been used for trees derived from a plum seed parent, and are therefore equivalent.

15. CropLife Australia (CropLife)

CropLife has long advocated for the introduction of a comprehensive, publicly funded minor use and specialty crops program to alleviate the market failure resulting from the mandatory regulatory system. Crop protection products are only registered in circumstances where there is a direct financial incentive for registrants to do so. This is irrespective of the financial and economic benefits to the farming sector or the broader economy other uses of these products may be able to deliver. This problem is directly caused by the inability to recover the significant costs of the mandatory regulatory system in a relatively small market. It is important from a public policy perspective, to recognise that bringing a new crop protection product to market in Australia is the same on a dollar for dollar basis as it is in the United States, yet the market is one tenth the size.

CropLife notes that development of an official Australian crop grouping by the APVMA is being funded from the federal government’s allocation in its 2014 budget of $8 million over 4 years towards improving access to chemicals for Australian farmers. Crop grouping, if properly done, will enable formal recognition of data generated in a subset of crops to be extrapolated to other related crops of the same crop group, with little or no additional data or assessment by the APVMA required, and is as such supported by CropLife.

An effective official Australian crop grouping will provide Australian farmers better access to crop protection products for minor uses and specialty crops while reducing the cost to industry by reducing the need to generate data across multiple crops within the same crop group. CropLife contends, however, that the Australian crop grouping list must, where possible, align with the official list already developed by the Food and Agriculture Organization.

16. Department of Agriculture and Water Resources

Two teams within the plant biosecurity branch reviewed these listings and have provided comments against the commodities as grouped. We hope this provides some useful feedback into phase 2 of the crop grouping project.

The general comment from those staff that reviewed the listings was that some of the groupings seem not to be based solely on botanical criteria, which made the lists appear ‘clumsy’, or not based on botanical objective criteria. For future phases, would it be possible to clarify the criteria upon which the groupings were based?

The department seeks to be kept in touch with the progress of the crop grouping project, so that comments can be provided during future phases of the project. Please consider making available editable documents in the future, where track changes or comments can be added. 

Crop grouping	Commodities that are not listed but are currently grown or could be grown in Australia	Allocation of particular commodities to certain crop groups	Agreed common names which should be used in the Australian crop grouping system	Comments
Brassica (cole or cabbage) vegetables	Kale			In brassica or in leafy vegetables
Leafy vegetables			Chicory also known as radicchio
			New Zealand spinach also known as warragul greens
	Tatsoi, Brassica narinosa
Berry fruits	Goji berries
	Lingonberries  (Ikea)
	Table and wine grapes			Question inclusion in berries—but probably best spot for now
Bulb Vegetables		Chives		Should chives be considered a leafy vegetable?
Fruiting veg vegetables		Cape gooseberry		Should cape gooseberry be in berries?
			Pepper, sweet also known as capsicum
			Roselle—rosella?
		Sweet corn		Question its inclusion in fruiting veg as it is quite a different crop (grass)
Root and tuber vegetables	Coriander (root)
	Ginger
	Radish
	Turmeric (fresh)
			White raddish—daikon
Stonefruit	Plumcots/pluots
Pome fruits	Native Fruits? eg quandong, davidson plum, bush tomato, tasmanian pepper berry
Spice		Tonka bean		Also in trop fruits
				Basis for grouping? * dried ground material or crop itself. Some bark, some fleshy/tuber/root
Tropical fruits			Mangostan—mangosteen
		Tonka bean		In 2 groups, Also in spice

17. National Council of Pollination Associations (NCPA) and the Crop Pollination Association Inc (CPA)

THE NCPA and CPA oppose the establishment of an Australian crop grouping list for the purpose of streamlining the registration of agricultural chemicals on the following grounds:

• The establishment of a crop grouping list would mean abandoning the pre-cautionary principle.
• Extrapolation is a process of estimation. It is too inexact a methodology to be applied to any part of the human food chain and to any agricultural crop that the european honey bee or other pollinators are exposed when foraging.
• The practice of considering individual applications for agricultural chemical use on individual crops allows for the systematic review of the agricultural chemical in questions subject to contemporary risk assessment at the time of application.
• Crop grouping would only serve to further compound and confound the issue Australia already has with hundreds of agricultural chemicals that were 'grandfathered' into the national registration scheme that have never been subjected to contemporary risk assessment. This unquantified risk is further compounded by the large numbers of chemicals approved by the registration system of the states and territories prior to the formation of the APVMA which have never been reassessed against modern risk assessment principles. Such chemicals have not been subject to any reassessment of risk in over twenty years. In the past twenty years, there have been significant changes to our knowledge and understanding of risk and toxicity, and to the methods which are used to test and assess chemicals and to review the maximum residue levels that are to apply.
• Cost reduction is not a valid argument for increasing the risk that may ensue to the human food chain and pollinators by engaging in the practice 'desktop' extrapolation.
• Easier and greater (blanket) access to chemicals in the management of crops does not in itself translate to improved or better management of crops. It is far more likely to increase the volume of agricultural chemicals applied to crops thus increasing the potential for higher quantities and concentrations of chemicals to enter the human food chain and to which pollinators may be exposed, all under the guise of 'crop protection' management practices.
• The practice of considering individual applications for chemical use on individual crops also allows for the systematic review of the labelling hence bringing crop management techniques into line with the latest advances in research and safe usage principles.

In closing, it is the considered opinion of our associations and members who work at the coal face of the agricultural industry as apiarists, that the establishment of an Australian crop grouping list can only lead to the further erosion of testing standards applied to individual chemicals and application conditions in Australia. In doing so, this change would be detrimental to our industry, the Australian consumers and Australian agriculture across the board when one considers the wider ranging trade implications.

We oppose the establishment of an Australian crop grouping list.

18. Australian Olive Association Ltd

Submission from the Australian Olive Association Limited (AOA):

• it is proposed that olives form part of the tropical and sub-tropical fruits edible peel group
• according to Leandro Ravetti, Technical Manager of Australia's largest olive orchards, Boundary Bend Limited, due to its perennial nature and growing regions, citrus is the most compatible crop with olives (it should be called perennial temperate and subtropical crops)
• the problem with grouping olives with tropical and subtropical edible peel crops is that almost none of those crops are particularly big and we will continue to struggle for chemicals with off-label and on-label permits
• AOA position—recommend that olives form part of the citrus and/or stone fruit grouping.

19. Bayer CropScience Pty Ltd

Bayer CropScience has provided the following comments with the aim of helping to refine the final crop groupings

Berry fruits

Some Rubus hybrids have been mentioned but not all—I would suggest to list all or none?

• young berry—rubus spp.
• silvan berry—rubus spp.
• marion berry—rubus spp.
• add: jostaberry (ribes xnidigrolaria)

Cereal grains

• add: spelt (tritcum spelta), naked oats (avena nuda)
• correction: popcorn (zea mays—spelling of 'zea')

Citrus fruits

• add: bergamot (citrus bergamia), cumquat/citrus japonica and citrus margarita (decision whether these are more correctly listed as citrus spp. or fortunella spp.)
• remove: citrus australia from limes list?

Cucurbits

• add: pie melon (citron melon, citrullus caffer)

Fruiting vegetables

• add: kangaroo apple/black nightshade (solanum laciniatum) (or should we stay away from specialist plants like this?)

Herbs

• add: additional species of basil

Leafy vegetables

• add: beetroot leaves, bean sprouts, alfalfa (lucerne) sprouts, cereal sprouts, stinging nettle (urtica dioica), pandan (pandanus spp.) leaves, banana leaves, cos lettuce (correction—spelling of genus), box thorn (lycium chinense, licium barbarum)—is this the correct group for this plant. It appears leaves are used medicinally, and the berries (goji berries) are the main part eaten?
• dandelion (correction—spelling of species), spinach beet (correction—spelling of genus), lovage (correction—spelling of species)

Oilseeds

• add: jojoba (simmondsia chinensis)

Stone fruits

• add: almonds (immature)—whole fruit eaten fresh

Tree nuts

• add: more species of pine nuts

Tropical and subtropical fruits—edible peel

• add: strawberry guava (psidium cattleyanum)
• more persimmon species
• question: Is this the right category for carob—which appears to be eaten mainly dried and processed?

Crop Groups perhaps required for the following additional crops/presentations of crop parts:

• quandongs—santalum acuminatum (wild peach), and their seeds as well. Seeds may be able to be slotted into tree nuts
• other native fruits/plants grown commercially
  • water chestnut, coffee, tea, cacao
  • Indian hemp/marijuana (fibre crops—general) (also now grown for export pharmaceutical use), kenaf (hibiscus cannabinus) (fibre crops—general),  duboisia spp. (pharmaceutical alkaloids)
  • sugar cane (saccharum spp.) eucalypts for essential oils production, tea tree for essential oils production, sandalwood for essential oils production
  • other essential oils
  • echinacea purpurea, zucchini flowers, banana bells
  • baby versions of various crops—baby corn, baby carrots, baby beets etc.