SUBMISSIONS

Supporting market growth through submissions

Fighting for your voice to be heard

Freshmark is proud to submit applications and proposals on behalf of our members and market floor customers, ensuring industry standards are upheld across all chambers. Our submission process is designed to advocate for fairness, transparency, and consistency within the fresh produce industry. 

Latest submission

This submission represents Freshmark’s specific views and reflects our policy positions, as well as the input of our members and industry stakeholders across NSW. Freshmark has also contributed to and broadly supports the submission developed by Fresh Markets Australia (FMA), our national industry body.

Freshmark supports retaining the Horticulture Code of Conduct, with targeted reform to ensure it reflects the modern supply chain and remains practical, clear and fit for purpose. 

To achieve its stated purposes – improving transparency and clarity in transactions, and providing fair and equitable dispute resolution – the Code must reflect the full spectrum of the supply chain and support trade without imposing unnecessary burden.

 

Response to Horticulture Code of Conduct Review Consultation Paper

Our submission outlines a range of practical reforms to address key challenges with the Horticulture Code of Conduct. The Code plays an important role in regulating the sector, and we welcome the opportunity to provide recommendations to ensure it is workable, fit for purpose and aligned with the realities of trade.

To achieve its stated purposes, the Code must reflect the full supply chain and support trade without unnecessary burden.

This submission reflects valuable discussions between our members and the reviewer, and is broadly aligned with the submission of our peak national body, Fresh Markets Australia.

Response to National Food Security Strategy

Freshmark is calling on the Australian Government to formally recognise the independent fresh produce supply chain as critical national food security infrastructure.

In our submission to the Feeding Australia: A National Food Security Strategy discussion paper, we highlight how the independent sector consistently delivers fresh produce to Australian households — even in times of floods, pandemics, and global supply chain shocks.

These measures will ensure Australians can continue to access fresh, affordable fruit and vegetables every day.

Draft Food Regulation 2025

The Draft Food Regulation 2025 as it currently stands will have a severe negative impact on businesses operating across almost the full breadth of the berry, melon and leafy vegetables supply chains. The draft Food Regulation 2025 sets up a licensing scheme which differs significantly from those proposed by other states and appears to be misaligned with the intentions of the FSANZ.

Primary Production and Processing Standards relating to berry, melon, and leafy vegetable production and processing (FSANZ PPP Standards), which extends only to early-stage processors
and does not include wholesalers.

Mandatory Food and Grocery Code

Freshmark welcomes the Government’s commitment to strengthening the Food and Grocery Code to support a fair and sustainable fresh produce sector. We also urge ongoing flexibility for further updates following the ACCC’s supermarket inquiry.

ACCC Supermarkets Inquiry

The three major supermarket chains currently account for 75% of fresh produce sales in Australia.

Small retailers and independent grocers offer some competition to the large chains, and the central markets system is critical in maintaining this framework, but the supermarkets carry a disproportionate share of market power which impacts the competitive capacity of the rest of the sector.


It is critical that those retailers outside the major supermarket chain’s structure, are viable and sustainable to ensure consumer choice and competition.

Food and Grocery Code Review

Freshmark welcomes the opportunity to provide submissions to the independent review of the Food and Grocery Code.


Food, and especially fresh produce, is possibly the most important purchase for Australian consumers.

Our members play a critical role in the fresh produce supply chain. Compliance and red tape are among the biggest challenges our members and our industry face, and one of the sector’s biggest bugbears is that the codes under which supermarkets and other fresh produce industry participants operate are not equivalent in terms of the responsibilities they confer, the protections they offer or the deterrents they provide for breaches.

Unfair Trading Practices

Freshmark relied on the expert insights of our board and staff, relevant studies and research, and feedback from market participants.

This included a broad survey of members completed online and in-person on the market floor as well as one-on-one detailed interviews.

Independent Toll Review

Freshmark worked on this submission to highlight the significant impact of road tolls on the fresh produce sector, which operates on thin margins and plays a vital role in ensuring Australians have access to fresh, affordable food.

Given the essential nature of fresh produce distribution, Freshmark advocates for fair tolling policies, including exemptions or concessions for produce transport, a reevaluation of toll pricing structures, and greater recognition of the sector’s unique challenges.

The goal is to ensure a sustainable and competitive supply chain that does not pass unnecessary costs onto consumers.

Food Security in Australia

Freshmark’s submission to the inquiry into food security in Australia highlights key challenges facing the fresh produce sector, including unfair regulatory disparities, rising input costs, labour shortages, and the need for greater investment in regional communities.

The submission advocates for fairer industry regulations, sustainable labour policies, and increased support to ensure fresh produce remains accessible and affordable for Australian consumers.

Supporting the Fresh Produce Sector

Freshmark wrote this letter to the Treasurer to ask for support in moving away from highlighting rising fresh produce prices in cost-of-living discussions.

While weather events have impacted supply, broader inflation hasn’t had a disproportionate effect on produce.

Freshmark wants to emphasize that fresh, seasonal produce remains affordable and should stay a key part of consumers’ shopping lists.

Draft Food Regulation 2025

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Draft Food Regulation 2025

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Draft Food Regulation 2025

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Draft Food Regulation 2025

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Draft Food Regulation 2025

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Draft Food Regulation 2025

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Draft Food Regulation 2025

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Industry-backed policy positions

Freshmark’s policy agenda is focused on solutions that make working in our sector easier, more appealing and more sustainable.

Labour

Freshmark supports fair, equitable, and inclusive access to staff for businesses across the NSW fresh produce supply chain, and a safe, adequately remunerated work environment for workers.

Food security

Freshmark supports fair, equitable, and inclusive access to staff for businesses across the NSW fresh produce supply chain, and a safe, adequately remunerated work environment for workers.

Environment

Freshmark supports fair, equitable, and inclusive access to staff for businesses across the NSW fresh produce supply chain, and a safe, adequately remunerated work environment for workers.

Regulation and governance

Freshmark supports fair, equitable, and inclusive access to staff for businesses across the NSW fresh produce supply chain, and a safe, adequately remunerated work environment for workers.

Consumer education

Freshmark supports fair, equitable, and inclusive access to staff for businesses across the NSW fresh produce supply chain, and a safe, adequately remunerated work environment for workers.

Power in chamber unity

Freshmark has increased the amplification efforts of our advocacy by belonging to the Australian Chamber of Fruit and Vegetable Industries Limited, trading as Fresh Markets Australia (FMA).

FMA is the national organisation representing each of the five Market Chambers, which themselves are organisations that represent the fruit and vegetable wholesalers located in each of Australia’s six central Markets (Brisbane, Sydney, Melbourne, Adelaide, Perth and Newcastle).