The Printing Industries Association of Australia (Printing Industries) has strongly advocated the retention of the 30-day rule in its final submission to the Productivity Commission's current inquiry into restrictions on the parallel importation of books.

Printing Industries submission raises the prospects of job losses and negative economic impacts on both metropolitan as well as regional areas of Australia if changes are made to the existing arrangements.

The submission argues that limiting parallel import restriction protection for books to just 12 months as advocated by the Productivity Commission in its Discussion Draft will impact on domestic reprints of books. Based on industry feedback this market segment represents some 40 per cent of total book printing turnover.

Printing Industries National Manager for Policy and Government Affairs, Hagop Tchamkertenian said that if the Productivity Commission's recommendations are implemented, overseas remainders will replace domestic reprints.

"This could place in jeopardy up to $95 million in local book printing activity and about $35 million in paper production. Taking into account historical input-output as well as industry multiplier analysis, the estimated output losses could result in the loss of 1,900 jobs throughout the Australian economy, including several hundred jobs in the book production sector".

"A contracting local book printing market is likely to result in the significant lessening of competition amongst book printers as pressures for consolidation increase at the top end," he said.

Following are Printing Industries specific recommendations:

1. Printing Industries opposes the recommendation by the Productivity Commission to limit parallel import restriction protection to a period of 12 months and abolishing the 7/90 day rule on the basis that the implementation of such recommendations will result in reduced local publishing and printing activity.

2.  Printing Industries supports modification of the existing 90 day rule provisions that apply to existing book titles to reflect technological advancements. As such, the 90 day provision should be shortened to 30 days.

3. The recommendation that booksellers should be allowed to overtly offer an aggregation service for individual import orders under the single use provisions is not opposed by Printing Industries. 

4. The recommendation by the Productivity Commission that a further review should be held five years after implementation of the changes arising from this study will be made somewhat redundant if the proposed changes are not implemented as is being advocated by Printing Industries. The book production stakeholders during these times of economic uncertainty need to harmonise their collective energy to help maintain a viable and sustainable book production industry in Australia. The last thing they want is to be distracted by another study/inquiry into copyright restrictions on the parallel importation of books.

5. This is why it is critical that the current study/inquiry settles the issue once and for all by providing certainty to book production stakeholders so that they can invest and commit to the local book production industry with confidence and certainty.

6. Policy recommendations concerning parallel import restriction protection need to give proper consideration to environmental issues especially the carbon impact associated with imported books.

7. To address the data challenge issue which arises due to the absence of current data on the Australian book industry, the ABS should be given the necessary resources to undertake regular surveys of the book industry.

8. Given that the Productivity Commission is interested in evaluating the impact of a particular measure(s) on Australia as an entity, then all relevant factors including the role of parallel import restrictions as a regional development/support

Mr Tchamkertenian said that the Productivity Commission is now considering the various submissions and plans to issue its final report and recommendations to the Federal Government on 13 May 2009.

"Printing Industries will be continuing its' representative efforts until this critical industry issue is resolved in a manner that is satisfactory to book printers," he said.