National Wool Declaration must be mandated, but opinions divided over categories

It comes after AWEX called for industry feedback on the latest version of the NWD, with the review receiving 18 written submissions from producers, grower organisations, wool brokers, wool exporters and animal welfare groups.

The submissions vary broadly in terms of whether stakeholders think the current categories as they relate to mulesing should be retained or amended, though the theme of simplifying the document and making it compulsory came up numerous times.

The Ceased Mulesing category and Liquid Nitrogen category were particular points of contention.

WoolProducers Australia's submission reiterates its previous rejection of the current version of the NWD, advocating that the document return to the original intent of being a declaration regarding only mulesing status and Dark and Medullated Fibre Risk.

The submission argues that intent means the LN category has no place in the document, and further added that the low declaration rates of LN meant it was statistically insignificant

WoolProducers also called for the removal of the CM category "as the wool supply chain is more interested with the mulesing status of the wool on offer rather than what is or is not, occurring on-farm".

"The decline in CM declaration rates to below 3% nationally indicates that this is not a significant category of wool and WoolProducers believes that this status is now redundant and adds unnecessary confusion amongst growers," the submission said.

WoolProducers also recommended that AWEX not consider the inclusion of other animal welfare declaration and that AWEX pursues making the NWD a condition of sale.

Livestock SA's submission backed up the concerns and suggestions raised by WoolProducers, adding that decreasing use of the NWD was a sign it needed to be simplified.

"Livestock SA encourages and supports continual improvement in our industry, but in our experience often the parties wanting to make changes to declaration documents fail to grasp that certain documents were designed for certain functions," it said.

"So, while it may seem innocuous or like a good idea to add more elements to specifically designed forms, it is not that simple as it can change the purpose and relevance of the document."

Meanwhile the submission from NSW Farmers said while it supported WoolProducers' submission, they diverged on policy as they would like the NWD to include a status for alternative breech modification methods, such as sheep freeze branding and clips.

The NSW Farmers submission also called for the mandating of local anaesthetic or analgesic during mulesing through an industry led initiative.

A submission from wool trader Modiano, signed by managing director Stuart Clayton, said the company was disappointed by the proposal to discontinue CM during the previous review.

"With regard to the sale of wool tops, CM wool is accepted by all our European customers and is seen to be in line with the same ethical practices as Non Mulesed," he wrote.

"As such there is no distinction between CM and NM and are both acceptable components in the production and sale of Non Mulesed certified tops.

"The removal of CM from the NWD would deeply affect our business and further reduce our ability to buy Australian wool."

Mr Clayton further suggested that simplifying the document could be done by removing the AA category, defined as wool from a mob that has been mulesed with the use of an analgesic or anaesthetic product.

"Over the past 15 years we have not had one single customer ask for pain relief certified wool tops," he wrote.

Managing director of Endeavour Wool Exports Josh Lamb wrote that CM is an important tool for growers to transition their flock to NM.

"Exporters and processors also trade CM commercially and this advantage should not be taken away from growers," he wrote.

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Animal welfare groups have said they support the retention of the Ceased Mulesing and Liquid Nitrogen categories, and even the addition of further categories

Humane Society International Australia said a mandate would demonstrate that the Australian wool industry was committed to full transparency and integrity.

"The completion rate in some states still remains a concern, particularly in Western Australia at just 50.1pc in 2022, so there is a real need for improvement, " the submission read.

The National Council of Wool Selling Brokers submitted that the current NWD should remain the same, citing a "need for stability in the industry rather than continual change".

"For example, the definition of Ceased Mulesed (CM) has changed on many occasions as a result of each NWD review process," the submission read.

"NCWSBA preference is for CM to continue as an available option and for the current definition of CM to remain.

"The price premiums for CM justify the continuation of this category for a wool lot at auction."