Specific Issues
140. The preceding section discussed issues which all parts of the infrastructure have in common. This section considers each area of the standards and conformance infrastructure in turn. It explains the current situation and relevant things to consider before identifying issues and options.
141. The topics discussed are:
- standards, including participation in domestic and international standards development;
- measurement;
- accreditation, including the accreditation of inspection bodies, the funding of participation in international activities, and the framework for the Testing Laboratory Registration Council's operations;
- conformity assessment, including supply of conformity assessment services and take up of certification services; and
- regulation.
Standards
142. Economic theory has identified that the purpose of standards is to overcome a range of market failures or inefficiencies which would result from leaving compatibility and risk management completely to the marketplace. The development of standards supports all three objectives identified: managing risks to health, safety, and the environment and facilitating both domestic economic development and international trade.
Current Situation
143. The review to date has found that the existing standards-development process meets many of the objectives described in the preceding section. The outstanding issues surround questions of strategic priority - which Standards get developed and how sustainable is the current role of SNZ?
144. A major issue identified concerns the future role of SNZ which provides Standards for domestic applications through a consensus process and provides a conduit for participation in the international Standards process. SNZ decides, with sector input, which Standards to develop or update depending on market demand and the availability of sponsors. SNZ is self-funded, relying principally on sales of publications (Standards) (45 per cent of its income in 2005), and contracts for services (25 per cent of its income in 2005).26
145. New Zealand and Australia have endorsed a framework which requires consideration of international (ISO) Standards, then joint trans-Tasman (Australia / New Zealand) Standards, before the development of a domestic-only Standard.
Things to Consider
146. It is probable that the following factors are changing the demand for Standards: changes in international and domestic regulatory structures, including the progression to performance based approaches, combined with the internationalisation of Standards, an increasing diversity of the coverage of Standards and the development of the Single Economic Market with Australia.
147. Requirements to sponsor the Standards development process may place a disincentive on the use of the process, particularly where the sponsor may be able to produce alternative "standards". Internationally, there is a trend by national standards development bodies to accredit regulators and industries to develop their own standards and guidelines. The accreditation process ensures that the resulting documents are "registered" into the Standards infrastructure but allows their development to be managed and funded.
148. There is also an increasing tension between regulatory objectives of making compliance guidelines available at a cost that does not impede uptake and the desire to obtain a commercial return on the intellectual property contained in Standards. This tension becomes an issue where a regulator is the major sponsor of the development process and where the Standard is a major potential income earner for the Standards development body.27 A similar situation exists for other sponsors.
Issues
149. How can the prioritisation of Standards activity be improved and directed at those projects which will return the best outcomes to the economy considering available knowledge and funding resources?
150. How might the tension between securing an appropriate return on the invested intellectual property contained in Standards be balanced against the compliance objectives of regulators and the economic benefits expected from the availability of Standards?
151. How are changes in the international and domestic regulatory structures, the internationalisation of Standards, increasing diversity of the coverage of Standards and evolving regulatory needs changing the demand for, and structure of, Standards?
152. How, if at all, are trends in this area challenging the sustainability of Standards New Zealand's current operating models and what should be done about it?
Options
153. In an enhanced status quo option, responsibility for funding the development of Standards primarily aimed at public interest outcomes should remain with the various regulators. Under this option, there may be scope to consider how regulators might be required to have a closer involvement with funding and prioritising the Standards development process.
OR
154. For domestic Standards development, it might be possible to develop a more centralised process for choosing which standards to develop and maintain. Such a process could seek to ensure that the most important standards to "New Zealand Inc." receive priority. This process might include an economic/regulatory impact assessment process.
AND/OR
155. The current business model for SNZ could be revised. Work could be done to consider if there is a business structure or model which could be more effective in the future environment, particularly where the price of a Standard provides a disincentive to the delivery of economic or regulatory outcomes sought through the application of the Standard. Such a model would need to be consistent with our international obligations.
AND/OR
156. The method of public funding may be revised. This could involve some public funding for SNZ, or filtering public funding through regulators for their sponsorship of standards in the public interest.
Participation in Standards Development
157. Involvement in the Standards development process is on a voluntary basis. SNZ promotes the individual and organisational benefits of such involvement. Industry commitment to participation in the process could be reducing, however, with competing resource pressures. This is particularly true for small to medium sized firms, as larger firms with more at stake can subsidise the participation of their staff on Standards development committees. This also risks the charge that some committees are "captured" by large firms' interests. Public participation, such as by consumer representatives or independent experts, is also becoming increasingly dependant on direct support from the Standards process.
Issues
158. What are the incentives for business and consumer representatives to contribute to standards development processes, and what, if anything, should be changed?
Options
159. The status quo situation is appropriate, as those who value taking part in the process enough to fund themselves should be the ones with a say.
OR
160. There may be arguments for more direct funding of participation in Standards development to ensure that committees get the best and widest representation. This would form one of the uses for the limited public funding mentioned above. Under this option, regulators could be made responsible for ensuring appropriate representational balance.
Participation in International Standards Development
Current Situation
161. The trend towards New Zealand becoming a "taker" of Standards developed internationally and for regulators to directly adopt international Standards may not only reduce traditional revenue sources for SNZ, but increase the need for New Zealand to participate more in the development of international Standards.
Issue
162. Is there currently sufficient participation in international Standards development (not just by infrastructure bodies but also by regulators and business) to meet New Zealand interests?
Options
163. The status quo situation is appropriate as firms or regulators choose to be involved in international standard development.
OR
164. Design a process to decide how New Zealand's interests can best be represented at international standards development. This might include increased links between trade policy and SNZ to assist and inform strategic choices. This option might logically be combined with the process adopted for domestic Standards projects.
AND/OR
165. The Memorandum of Understanding between the Minister of Commerce and the Standards Council could include more specific expectations on involvement in the international standards process.
Measurement
Objectives
166. All the outcomes which government requires from the infrastructure rely on measurement services being available for products and processes. The overall outcomes of the standards and conformance infrastructure described earlier require appropriate measurement services to be available, traceable and reliable.
Current Situation
167. Metrology is an area of exponential growth in new and complex technology. While these advances provide a platform for the development of new high technology products, they also pose problems for metrologists in small countries with limited resources. Increases in the scientific requirements for trade measurement28 also may challenge existing work divisions between legal and physical metrology.
168. An examination of measurement services provides an opportunity to consider how well-aligned the priorities of the different parts of the infrastructure are, with respect to overall economic development objectives. In the physical metrology area, the core funding for the Measurement Standards Laboratory comes from Vote: Research, Science and Technology. MSL is not a separate body, but a unit of IRL, and the Minister of Research, Science and Technology's output agreement for these services is with IRL.
169. In the 2006/2007 financial year, IRL will receive $6,192,000 to provide the services laid out in the output agreement on National Measurement Standards. This total includes the overhead charges which the Measurement Standards Laboratory must pay to IRL. MSL's capital expenditure and staffing decisions are subject to the IRL Board's priorities, rather than the MSL alone.
Things to Consider
170. The ability to measure new physical qualities and to measure to increasing degrees of precision, frequently requires expensive equipment and expertise that is in short supply. At the same time, failure to have access to new forms of measurement can inhibit new product development or access to overseas markets.
171. The main challenge identified in measurement services is the provision of chemical and biological measurement accuracy (a worldwide issue). This issue is being addressed temporarily in New Zealand by calling on the combined resources of private and public sector laboratories, but in the future additional capacity in the public sector may be required. There are also some specific measurement services, for example, in relation to high voltage equipment, which cannot be provided in New Zealand currently. These services need to be obtained overseas, where this is possible, which involves additional expense to producers. There are some services that require local measurement capacity such as trace soil elements.
172. Areas where increased demand is likely to occur over time include applications of nanotechnology in industry, as well as changing environmental standards and expectations. In a situation where there is rapidly increasing demand for measurement services, it is possible that neither the resources of MAPSS or MSL nor existing alliances within the region to facilitate access to services not provided in New Zealand, will be sufficient.
173. Decisions about priorities for investment in the MSL are made by the board of IRL, unless a client directly funds the necessary service development. Funding decisions and priorities are therefore made without formal input from other parts of the standards and conformance infrastructure or from MED.
174. The main issue for measurement in this review is the challenge of maintaining capacity in measurement services and extending this with our changing needs. This is both a potential problem of resourcing and also an issue which may be affected by alignment, or lack of it, in the infrastructure.
Issues
175. In a period of rapid technological advance in metrology, how can the capability of metrology services be maintained to meet New Zealand's strategic needs?
176. Is there sufficient co-ordination between government, other infrastructure bodies and metrology services to ensure that decisions on future resourcing and directions of such services meet the needs of their users?
Options
177. The options already proposed to improve alignment and information exchange for the standards and conformance infrastructure as whole would help to resolve the issues raised about priorities for measurement capacity.
AND/OR
178. Better linkages between funding decisions for MSL and MAPSS and the standards and conformance needs of the economy may be sought at the portfolio level. Responsible Ministers could be encouraged or required to consult with the Minister of Commerce on their performance agreements with the measurement bodies.
AND/OR
179. Initially other improvements in alignment and information sharing should improve measurement outcomes. Alignment with overseas bodies and adequacy of total funding may need to be reconsidered in the future if these options prove insufficient.
Accreditation
180. The activities of the accreditation bodies successfully support all the outcomes of the infrastructure for the most part. The more that conformity assessment competence and results are accepted both locally and internationally, the better for both risk management and domestic and international trade. International recognition is an ongoing process through government-to-government activities as well as international liaison by the infrastructure bodies themselves.
181. The existing accreditation bodies have a wide and positive involvement in the economy. Three specific issues are identified here: the accreditation of inspection bodies, the funding of participation in international activities, and the framework for the Testing Laboratory Registration Council's operations.
Accreditation of Inspection Bodies
Current Situation
182. Conformity assessment bodies, whether testing laboratories, certification bodies or inspection bodies, are required to be accredited for much of the work they carry out. This accreditation plays an important function within the domestic economy and is also essential for the acceptance by overseas markets of many New Zealand exports.
183. In New Zealand, IANZ provides accreditation of testing laboratories and JAS-ANZ provides accreditation of certification bodies.29 One area in which there remains an overlap in the mandated functions of the two bodies is the accreditation of inspection bodies. Until recently IANZ has been the prime provider of inspection body accreditation. JAS-ANZ, however, is now providing these services in New Zealand.
184. The ability of two peak bodies to provide this service is not widely replicated in other jurisdictions reflecting the fact that, usually, the equivalent activities of JAS-ANZ and IANZ are contained within one national accreditation agency. A general principle in other jurisdictions is also that accreditation activity should not be the subject of competition in the market place.
Things to Consider
185. In reflecting on the merits, or otherwise, of the New Zealand approach consideration needs to be given to the following:
- the benefits to businesses, other consumers, and regulators, associated with having a choice in accreditation provider;
- whether a competitive model puts at risk the integrity and quality of the accreditation services and how this might be managed;
- the scope for developing a complementary rather than competitive model between JAS-ANZ and IANZ that would serve business and regulator interests;
- the potential risks to New Zealand trade associated with maintaining a dual approach which is becoming increasingly at variance with developments in other jurisdictions;
- developments of international MLAs between accreditation agencies in the inspection area. Unlike the widespread network of MLAs that underpin international recognition for certification services and laboratory test reports, MLAs in the inspection area are still developing. Of the four international bodies relevant to New Zealand only Asia Pacific Laboratory Accreditation Cooperation (APLAC) has developed an MLA (although IANZ was also evaluated in April 2006 for entry into the MLA operated by European Cooperation for Accreditation for Accreditation of inspection bodies).
- the long-run implications of the current efforts between the International Accreditation Forum (IAF) and the International Laboratory Accreditation Cooperation (ILAC) to adopt the same standards and guidelines for peer reviewing peak agencies and the standards for accreditation of inspection bodies;
- the reasons the Australian government, under their Memorandum of Understanding between the Department of Industry of Tourism and Resources and the National Association of Testing Authorities (NATA), identified the latter as Australia's "peak authority for the accreditation of inspection bodies" despite JAS-ANZ's mandate allowing it to undertake this work.
Issues
186. Is the current model for accreditation of inspection bodies appropriate for New Zealand's current and future needs? If not, how could it be improved?
Options
187. The status quo situation could be retained. If there is a risk stemming from current arrangements, New Zealand could make more effort to promote our model to our trading partners.
OR
188. Divide up responsibility for accrediting inspection bodies according to the alignment with other accreditation, such that where certification and inspection exist, but not testing, JAS-ANZ could undertake accreditation. This option would require transitional or grandparenting provisions.
OR
189. Accept that the risks associated with the complementary model may be greater than the benefits and move to a single provider of accreditation for inspection bodies. Such a change would also require transitional arrangements for current clients.
Funding of Participation in International Activities
Current Situation
190. IANZ and JAS-ANZ participate in a range of international activities. They have played active roles in their international affiliations, special regional bodies, and CASCO (ISO's policy development committee on conformity assessment). Many of these activities are core activities required to establish and maintain their international credibility. The cost of participating in these activities has been met from revenues from accreditation services as both IANZ and JAS-ANZ are usually expected to finance their activities on a user pays basis. The policy rationale for this is to ensure services are demand driven and costs are met by the organisations that profit from them.
Things to Consider
191. Some international activity by the accreditation bodies, such as taking part in free trade negotiations, generates positive externalities which accrue to a wider group than IANZ or JAS-ANZ clients. In addition, a substantial number of accreditation services are not for the commercial sector or export oriented firms. A question has been raised as to whether international activities have broadened beyond the role envisaged when the bodies and their self-funding model were set up.
192. Set against this, however, are a number of other factors. Cross subsidisation from Telarc Ltd to IANZ enables IANZ to remain a viable concern without direct government funding.30 If the funding arrangements for participation in international activities were to be reconsidered, it might also be necessary to look at current funding arrangements for IANZ.
Issue
193. What are the best means to fund participation in international activities by accreditation bodies?
Options
194. The status quo should remain, recognising that accreditation bodies are public bodies which generate revenue and international activities should be decided on by each board and funded out of the body's revenue. From the perspective of client fees, such international activities are an overhead cost.
OR
195. An option for increased recognition of the value of international activities could see the performance agreements made with the Minister (in the case of the Crown entity, IANZ) providing a stronger expectation of international activities. The Board and management would be able to refer to these expectations when deciding on what international activity to undertake, and could report against these expectations. For JAS-ANZ, the mechanisms provided in the Treaty could be used, depending on negotiation with the relevant Australian Minister.
OR
196. The complete funding model in this area could be re-examined. Participation in international activity is not the only public interest contribution of accreditation. A different funding model could be designed which accounted for all revenue and non-revenue raising activities such as participation in international activities. This could also involve any surpluses being returned to the Crown.
Framework for the Testing Laboratory Registration Council's Operations
197. The Testing Laboratory Registration Act 1972 gives the TLR Council undifferentiated powers and functions relating to both accreditation and certification. These services are on two different levels of the double audit system that underpins third party conformity assessment. It is important for the integrity of the system and for international acceptance that they are delivered separately. The TLR Council recognises the importance of providing accreditation and certification services and does so through two different operational arms, IANZ and Telarc Ltd (a subsidiary company providing certification services only). In meeting the growing demand for "packages" of testing, inspection and certification services, there is a risk that the distinctions between the two types of services may become blurred, intensifying the need to safeguard the distinction between accreditation and certification. There may be a need for an explicit clarification of these roles.
Issue
198. How can the government best ensure that the Testing Laboratory Registration Council's accreditation and certification functions remain separate as pressures on these functions increase?
Options
199. The status quo situation could continue, with the Council retaining the choice of how to separate its operational activities. The need to maintain separation could be underscored in performance agreements.
OR
200. The government could consider amending the Testing Laboratory Registration Act 1972 to differentiate the powers of the Council and clarify separation between its certification and accreditation activities.
Conformity Assessment
201. As is made clear in the objectives section of this paper, it is obviously not enough for standards to exist which describe how risks to health, safety, and the environment can be managed. There needs to be some way of telling whether a product or process is meeting those standards. The availability of conformity assessment services - for all products, processes and relevant standards - is necessary to achieve the management of risks. These services also need to be timely and cost-effective, as identified in the earlier section on outcomes.
202. For the most part, the private sector delivers these services, with a large number of conformity assessment bodies (CABs) operating across different areas of the economy. Public sector conformity assessment also exists in areas such as hospital laboratories. In the area of technical regulations, it is particularly desirable that compliance with regulations can be assessed and, if necessary, enforced. If conformity assessment services are not available for a particular standard or regulation, this is obviously a barrier to economic activity.
Current Situation
203. For the most part, the private and public sector CABs deliver on the desired outcomes. There are, however, some products or areas where conformity assessment is not provided. It may not be commercially viable for New Zealand conformity assessment bodies to meet all the potential demand for their services, but there is evidence that a single economic market with Australia is evolving in some areas. New Zealand laboratories are now testing overseas products for compliance with Australian and international requirements, demonstrating that New Zealand can provide competitive conformity assessment services where they are established.
204. On occasion New Zealand Trade and Enterprise have assisted in meeting the costs of equipment and/or conformity assessment fees. In other sectors, manufacturers are developing "in house" conformity assessment capabilities which give them a market advantage but risk duplication and limit market innovation by their competitors.
Things to Consider
205. While there are some gaps in the provision of conformity assessment, there may not be any case for government intervention. It can be argued that the market for conformity assessments in New Zealand is small, with high fixed set-up costs. At the same time, the type of products and processing requiring conformity assessment are broad and increasing, often requiring highly skilled, specialist expertise and, for laboratory testing, expensive equipment.
206. As demands increase, the government may need to consider how conformity assessment services are developing, to guard against any risk of:
- products being marketed without being tested or certified with the associated risks for health, safety and the environment;
- products not being acceptable to export markets; and
- exports not being tested to acceptable standards, undermining New Zealand's reputation.
Issues
207. Are there inadequate conformity assessment services in the private sector to meet New Zealand's current and future conformity assessment needs? If so, what role can government play in working with the private sector to co-ordinate delivery of services and to address market gaps in the provision of conformity assessment services.
Options
208. Keeping the status quo assumes that there is no case for government intervention in the provision of conformity assessment services. Conformity assessment is a business cost, and if it is not profitable for a CAB to provide a particular service, producers should pay what it costs to obtain it (in New Zealand or offshore).
AND/OR
209. Accreditation agencies, CABs, business and regulators could be facilitated to communicate more. The earlier option of the infrastructure working together to develop information tools might have a role here. Information problems may exist in the market for some conformity assessment services. For example, CABs may not be aware of the total potential demand for a service.
AND/OR
210. If the conformity assessment required is related to regulatory requirements in New Zealand this could also be addressed by regulators themselves. The likely availability of conformity assessment services might be a consideration in the regulatory process. This option can be considered in the Regulatory Impact Analysis process which is currently under review.
Take-up Rates of Certification Services
Current Situation
211. The government currently has goals around improving business capability and productivity in the New Zealand economy. Intelligent implementation of management systems can improve business capability and is becoming essential for an increasing number of exports. The take up rates for certification of quality management systems and environmental management systems in New Zealand is at variance with overseas trends. Business practice surveys suggested a sharp fall in the number of manufacturers that have, or are seeking to have, a quality management system - from 58 per cent in 1997 to 38 per cent in 2001.31 Adoption of environmental management Standards is even lower with only ten per cent of firms certified, or planning to become certified. Only 15 certification bodies exist in New Zealand.
Things to Consider
212. A number of factors have been identified as contributing to this situation including:
- the cost of certification;
- the structure of accreditation fees which are claimed to be biased in favour of the bigger providers;
- a lack of appreciation of the benefits of certification by New Zealand businesses; and
- businesses appear to be unconcerned with the current take-up level.
213. It may also be possible that businesses have found more effective means of achieving those objectives. Another suggestion is that demand for certification in some New Zealand regulated sectors may be lower compared to other countries because the New Zealand economy is concentrated and regulation is enforced differently. For example, the Ministry of Agriculture and Forestry Biosecurity unit performs its own "certification" around food, and the Electrical Safety Service recognises suppliers' declarations of conformance.
Issues
214. Why is there a low take-up of certification services in New Zealand and is this impacting on New Zealand's economic performance? If so, what can be done to improve the uptake of such services?
Options
215. The option of information provision discussed above for other areas of conformity assessment might also increase the supply of certification services, if the problem is one of supply.
AND/OR
216. There may be a deficiency in demand rather than supply in this area. If certification is not required and the producer does not consider that its benefits outweigh the costs, the options for government are either to accept that business decision or promote certification or incentivise business to see the benefits of certification. This issue is being further investigated by the joint business/union/government Business Capability Partnership to better understand the causes.
Regulation
217. Some regulations aim directly at facilitating the functioning of the economy. These include competition policy and consumer protection such as the weights and measures and product safety legislation supported by MAPSS.
218. For regulations aimed at other non-economic outcomes such as health and safety, it is necessary to try to minimise unintended distorting side-effects on the economy, such as unnecessarily high costs of compliance. Thus the APEC information on good regulatory practice states that "regulatory measures should contain compliance strategies which ensure the greatest degree of compliance at the lowest level of government intervention." 32
219. Innovation is also relevant in this area. A report33 commissioned by the Ministry of Economic Development suggested that for domestically focused firms (or more precisely importing firms) the standards and conformance system can support innovation by keeping any product compliance costs to a minimum and integrating any new conformity or surveillance processes with existing processes.
220. The principles of high-quality regulation adopted by the Ministerial Review of Regulatory Frameworks are efficiency, effectiveness, transparency, clarity and equity. The standards and conformance infrastructure can support these principles. There are also specific interfaces between the infrastructure and regulators. A primary vehicle for dealing with regulatory issues currently is the Ministerial Review on Regulatory Frameworks. Some of the following options are, however, relevant to this issue, and may warrant consideration.
Current Situation
221. Regulators (government agencies) each have their own goals and operate within their specific statutory frameworks. From the perspective of the standards and conformance infrastructure, regulators can be characterised as creating demand for standards and conformance services. The creation or amendment of technical regulations can have flow on effects for the work of the infrastructure.
222. There are a range of options for how a regulator can use a Standard or set of Standards, ranging from Standards cited in a technical regulation, to Standards referred to as "deemed to comply" solutions to performance-based regulations. Conversely, a Standard may exist in an area, but the regulator may choose not to use it at all.34 Although many use the standards and conformance infrastructure, there is no formal or overall obligation on regulators to use the infrastructure to manage health, safety and environmental risks.
223. In the New Zealand model, each regulator may sign a contract for service with SNZ or a Memorandum of Understanding with an accreditation body. Regulators however can also institute their own conformity and approval processes separate from the infrastructure. In any case, regulators are bound by the TBT Agreement, which imposes certain requirements, including specifically, the obligation to notify WTO Members of regulatory changes. In New Zealand this is through the National TBT Enquiry Point (contracted to SNZ). Currently, there appears to be limited awareness among regulators of this obligation.
Things to Consider
224. The issue has been raised of whether regulators are making the best use of the standards and conformance infrastructure. In particular, the outcome of facilitating international trade depends on technical regulations meeting certain requirements. The question arises as to whether regulators are adequately ensuring that for Standards they cite, or apply, there is:
- adequate emphasis on international Standards;
- adequate emphasis on joint New Zealand and Australian Standards;
- appropriate Standards to support performance-based regulation;
- adequate participation of co-opted consumer representatives, experts and non-governmental organisations on Standards development committees; and
- adequate clarity of the compliance obligations applying to the technical requirements of Standards.
225. Some regulatory regimes do not provide adequate information on how compliance can be achieved. This is particularly the case with some performance-based regulation.
226. The Review of Regulatory Frameworks has identified that there is a need to ensure the enforcement of regulation is focused on the objectives, and proportionate to the risks, of non-compliance. In the area of technical regulation, it is important to enforce compliance sufficiently to facilitate fair competition and not distort the market. For example, a problem has been identified with compliance of some imports. If local producers comply with regulations at extra cost, but imported goods do not comply, local producers will be less competitive. This is particularly true if consumers are not aware of the difference in compliance.
227. The existence of a trans-Tasman market means that dissimilar enforcement levels between Australia and New Zealand have the potential to further disadvantage New Zealand manufacturers who service both markets. Likewise, New Zealand regulatory regimes that utilise the standards and conformance infrastructure are more likely to give foreign regulators the confidence needed to conclude trade-related arrangements (including MRAs).
228. The fact that New Zealand favours post market surveillance over pre-market surveillance can also create difficulties for exporters to countries that require pre-market surveillance. Addressing this issue may facilitate trade in some sectors.
Issues
229. Is there poor awareness among regulators of the services the standards and conformance infrastructure provides and how these can support and add value to the regulators' processes? Is this issue particularly acute around the development of Standards, conformity assessment requirements, and compliance with good regulatory practice?
230. How can awareness among regulators of their obligations under the WTO TBT Agreement be improved, and compliance monitored?
231. How can it be ensured that regulators take a closer interest in facilitating trade from New Zealand, in addition to undertaking their primary role?
232. As the sources of New Zealand's imports change, how can regulators ensure adequate regulatory enforcement and compliance with New Zealand standards?
Options
233. Information provision is the first step. The work on shared information tools already proposed could provide a place for regulators to discover the range of services available in standards and conformance.
AND/OR
234. More active education, coordination and peer review. The infrastructure, with MED in its coordinating role and the Ministry of Foreign Affairs in its trade facilitation role, could establish a forum for knowledge-sharing and problem-solving initiatives to promote the use of the infrastructure to regulators.
AND/OR
235. A formal process could be introduced to require regulators to consider using the standards and conformance infrastructure. Currently government agencies must undertake regulatory impact analysis and submit a Regulatory Impact Statement as part of the process of Cabinet approval for new or amended regulations. Additional requirements could cover the planned conformity assessment and monitoring process and resources for this. If this option is preferred it is likely to be progressed in conjunction with the Ministerial Review of Regulatory Frameworks.
AND/OR
236. The adequacy of the resources available for enforcement of regulations domestically, and for the participation of regulators in international processes, could be reviewed to ensure both compliance in New Zealand and trade facilitation.
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