AWEX National Wool Declaration review to welcome international retail submissions

Terry Sim June 28, 2016
AWEX CEO Mark Grave

AWEX CEO Mark Grave

AUSTRALIAN Wool Exchange will welcome international retailer and brand submissions to its latest review of the National Wool Declaration, AWEX chief executive officer Mark Grave said today.

AWEX has announced it is conducting a review of the NWD through the Industry Services Advisory Committee, with written or email submissions due by the close of business on Friday July 22, 2016.

The review will consider the following topics as well as any other aspect of the NWD and its Integrity Program:

  • The relevance of the current mulesing status declarations, viz. Ceased Mulesing (CM), Non Mulesed (NM), Mulesed with Pain Relief (PR) and Mulesed (M). The NWD definition of mulesing is sourced from the Australian Animal Welfare Standards and Guidelines.
  • The user-friendliness of the NWD form with respect to its correct completion by the owner/manager and data entry by wool broking staff.
  • The NWD adoption rate and compliance, and how it is being received by industry.

The last NWD review was in 2015, but AWEX said increased interest in the declarations by the wool supply chain predicated it should be reviewed to ensure it is fit for purpose and that the declarations can be substantiated through the NWD-Integrity Program (NWD-IP).

The NWD as the first declaration of the mulesing or pain relief status of raw Australian wool has attracted closer scrutiny from woollen clothing brands and retailers as demand for declared non-mulesed wool and its reliable traceability increases worldwide.

NWD only ‘partially trusted’ overseas

The European Outdoor Group’s head of corporate social responsibility and sustainability, Pamela Ravasio, said trust in the NWD among EOG members is “partial.”

“We recognize that the declaration is a very formal document in the Australian wool industry. “However, trust is good but control is better,” she said.

The EOG is the membership association of more than 90 internationally-operating outdoor brands, retailers and technology brands in Europe, with 10 national organisations as associate members.

Ms Ravasio said recognised best practice to create transparency required that all such claims are checked quite tightly by a credible third party to avoid any false claims.

“I have been informed that the NWD is only spot-checked and not all farms that declare their wool as unmulesed are indeed checked in a single year.”

Ms Ravasio said also mulesing is just one aspect of supply chain sustainability.

“Checks on the NWD do not necessarily pay attention to the health of the land the flock is raised on, or the general welfare of the flock as a whole.

“The NWD therefore only addresses one aspect,” she said.

“Looking further downstream into the processing stages of the whole supply chain, who guarantees that the wool declared as unmulesed is indeed not mixed with mulesed wool at any one processing stage (accidentally or purposely)?

“What could be a mere mistake for a processor – maybe with best intentions, i.e. to optimize the quality of the wool – for a brand at the retail front, could result in a rather disastrous back‐lash if some of the wool could be traced to a mulesed flock of sheep.”

Trust in the NWD is important

Mr Grave said there has been increased interest in the NWD, with 55 percent of first-hand bales offered at auction declared over the last 12 months, including more crossbred wool.

“We just want to make sure that it is still relevant – we know that we still have a way to go to increase the uptake.

“Now that we are above 50 per cent it is too easy to be complacent, so we want to make sure we are hitting the right marks, and particularly from a grower point of view, making sure that it is understood and the awareness is out there.”

Mr Grave said AWEX is the third party auditor for the NWD integrity Program, being independent of the grower, the broker and the wool buyer. AWEX annually did 1000 desk-top NWD audits, plus 225 property inspections, including any property that has declared NM and CM wool. Other audit inspections are done on behalf of other programs, he said.

AWEX also did 100 property audits on pain-relief declarations annually, following through on Tri-Solfen invoices to determine validity.

“But unless you are there ate the time the sheep are being handled you wouldn’t know or can’t say whether that is categorically true or not.”

Mr Grave said AWEX would welcome any enquiries or questions from the EOG or any other brands about the NWD Integrity Program.

“I think trust is a very big part of it – trust and confidence in the process is ultimately what the industry needs right from the grower right through to the processor, retailer and consumer.

“The feedback we’ve had is that the buyers and processors have confidence in the scheme, there is obviously significant costs involved in inspecting every property and that’s something that would be well and over above how it is currently funded and performed,” he said.

“The declaration at 55pc is a good sign — we want to make sure that the declaration and the information coming out it is relevant and trusted.”

AWEX is inviting all industry stakeholders to make a submission to the 2016 NWD review. The timeframe will ensure that any modifications to the NWD will be ready for inclusion in new shearing stationery printed from December 2016 forward, AWEX said.

All submissions must be in writing and include the name and address of the author/organisation and must be lodged with AWEX by close of business on Friday July 22, 2016. Emails are welcome. When making a submission, please include the topic(s) and the background to the topic(s) to be considered. ISAC will give due consideration to all submissions.

All submissions to the 2016 NWD Review should use the following contact: Dr Kerry Hansford, ISAC secretary, AWEX, Gate 4, Frederick Rd, Tottenham, Victoria, 3012. Email: [email protected] Fax: 03 9314 5392.


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  1. Edward Wymer., June 30, 2016

    Very considerate of Ms Ravasio to be concerned not only about mulesing, but also, “the health of the land the flock is raised on, or the general welfare of flock as a whole.” She wants all to be checked by a credible third party. Is Ms Ravasio going to pay for this? Of course not.

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