Agricultural Produce (Horticultural Industry) Regulations 2001

Charge. Defined in regulation 2 as a charge imposed under section 14 of the Act. This is a levy on horticultural produce, the amount and timing of which are set by the Commission in a notice published in accordance with regulation 7. The charge is not a tax in the strict sense but a statutory impost raised for the purposes of funding a producers’ committee’s prescribed services. The regulations do not cap or limit the charge; that is left to the Act and the Commission’s discretion, subject only to publication requirements. The producer bears the ultimate liability, but the collection burden falls on dealers and, in limited cases, local governments.

Dealer. A broad category: any person who purchases horticultural produce direct from a producer wholesale for resale, receives it on a producer’s behalf for wholesale sale, or receives it from a producer or wholesaler for processing. This captures wholesalers, agents, processors, and anyone in the supply chain who takes produce from a producer for onward sale or processing. The definition expressly excludes the original producer and also excludes retailers who buy from wholesalers (unless they also buy direct from producers wholesale). The breadth matters because the dealer is the primary collection agent: regulation 6A makes the dealer responsible for collecting the charge from the producer on the day of transaction, and for remitting it to the Commission. A dealer who fails to collect or remit faces a $2,000 fine per offence.

Horticultural produce. Defined expansively: fruit and vegetable juices (fresh or processed), nuts (including processed nuts), flowers (fresh or dried), and plants including grass and other herbaceous plants grown for sale as living plants. This is broader than the ordinary meaning of “horticultural” - it clearly includes processed goods (juices, processed nuts) and nursery stock. The broad definition means that many supply chains that involve processing (e.g., a juice manufacturer buying fruit direct from a grower) are caught: the manufacturer is a “dealer” under paragraph (e) of the definition because it receives produce for processing, and must collect charge from the producer. However, note that “sale” includes barter or exchange, so non-monetary transactions are covered.

Producer. A producer of horticultural produce in relation to which a producers’ committee is established under the Act. This means not every grower of horticultural produce is automatically a producer for these regulations - only those growing produce for which there is an active committee. The Act allows establishment of committees for specific kinds of horticultural produce (e.g., apples, potatoes, flowers). So a grower of a crop with no committee is not liable for charges under these regulations, but may still be subject to other regulations under the same Act. The regulations do not list which committees exist; that fluctuates.

Prescribed services. Regulation 3 simply states that the services in section 12(1)(a) to (m) of the Act are prescribed. Those services include research, development, extension, promotion, market development, quality assurance, education, and pest and disease control. No further specification is given; the effect is that a producers’ committee may spend levy funds on any of those activities. The regulation does not restrict the committees to a subset of services, nor does it require them to provide any particular service. This is a broad enabling provision that gives committees maximum flexibility, but also maximum potential for levy funds to be spent on activities with uncertain benefit to individual producers.

Returns and statistical information. There are two distinct reporting obligations. First, regulation 8 requires every dealer who has dealt in horticultural produce during a month to furnish a return to the Commission within 14 days after month end, showing all dealings. The form is approved by the Commission; the dealer does not know in advance what information will be required unless the form is published. On request, the dealer must also provide producer names, quantities, and types of produce. Second, regulation 4 empowers the Commission to require a producer to produce specified statistical information (not a standing monthly return, but on demand by written notice). That information includes quantity, land area, dealer names, and quantities sold to dealers and non-dealers. The distinction is important: dealers have an automatic monthly return obligation; producers have a potential obligation triggered by Commission request.

The regulations directly impose obligations on two main groups: producers of horticultural produce for which a producers’ committee exists, and dealers who purchase or receive such produce directly from producers.

Producers. A producer’s liability arises under regulation 5(1) to pay charges imposed under section 14(1) of the Act. The producer must pay the charge to the Commission if they sell to someone who is not a dealer (e.g., direct to a consumer, a retailer who is not a wholesale buyer, or via a farmers’ market). If they sell to a dealer, the dealer collects the charge at the point of transaction, so the producer does not need to remit separately, but they still bear the economic incidence. Producers may also be required by the Commission to provide detailed statistical information under regulation 4 - including the quantity of crop grown, the area of land cultivated, and the identities and quantities supplied to each dealer. This is a significant compliance burden, especially for smaller growers who may not keep records in the form the Commission wants. The producer must also file a monthly return if they sold any produce to a non-dealer during the month (regulation 8(3)). That return must show quantities and types of produce sold. Failure to do so attracts a $2,000 fine.

Dealers. The dealer is the linchpin of the collection system. Any person who buys horticultural produce direct from a producer wholesale for resale, receives it for wholesale sale on behalf of a producer, or receives it from a producer or wholesaler for processing, is a dealer. On the day the dealer purchases or receives the produce, they must collect from the producer any charge that relates to that produce (regulation 6A(2)). The dealer can deduct the charge from money owed to the producer or collect it as a separate transaction. If deducted, the dealer must give the producer a written statement within 28 days of the deduction. The dealer holds the charge on behalf of the Commission and must remit it within 14 days after the end of the month (or longer if the Commission allows). Additionally, every dealer must file a monthly return showing all dealings in horticultural produce (regulation 8(1)). That return is due 14 days after month end, and the Commission can demand additional details (producer names, quantities, types). Failure to collect the charge, failure to remit, or failure to file a return each carries a $2,000 fine.

Local governments. In a more limited context, local governments are required to collect charges that are imposed for the purpose of pest or disease control services (regulation 6). They must remit to the Commission within 14 days after month end. This adds an administrative function to local councils, who may not be set up for levy collection.

The Commission. The Agricultural Produce Commission itself is not a regulated entity but an administering body. It holds the power to specify statistical information, approve return forms, allow extensions of time for payment, and impose charges by notice. The regulations expand the Commission’s reach into the day-to-day operations of producers and dealers.

Indirectly affected: consumers and taxpayers. The charges collected are presumably used for industry services, but the cost of compliance - including time spent on record-keeping, returns, and dealing with collection paperwork - ultimately flows through supply chains. Dealers face a fixed per-transaction collection cost that may be passed back to producers in lower prices or forward to consumers. The $2,000 fines are a blunt enforcement tool; the Commission’s discretion to allow longer periods for payment or returns does not reduce the underlying compliance cost.

Duty of producer to pay charges. Regulation 5(1) states the producer is liable to pay charges imposed under section 14(1). This is a strict liability - no fault element appears. The duty is discharged either by the producer paying directly (if selling to a non-dealer) within 14 days after month end, or by the dealer collecting the charge at point of sale and remitting it, which then discharges the producer’s liability (regulation 6A(7)). The producer has no right to refuse collection by the dealer; the dealer is obliged to collect.

Duty of dealer to collect and remit charges. Regulation 6A(2) imposes a positive obligation on the dealer to collect the charge on the day of purchase or receipt. There is no exemption for small transactions, low value, or administrative difficulty. The dealer must hold the collected monies on behalf of the Commission (regulation 6A(5)) and remit within 14 days after month end (regulation 6A(6)). The dealer cannot decide to let the producer pay directly; the dealer must collect. This is a mandatory intermediary role.

Duty of dealer to provide written statement. If the dealer deducts the charge from money owed to the producer, the dealer must give a written statement of the amount deducted within 28 days (regulation 6A(4)). This is a transparency right for the producer to know that the charge has been deducted and remitted.

Duty to file monthly returns. Dealers must file a return showing all dealings in horticultural produce each month (regulation 8(1)). Producers must file a return only for months in which they sold to a non-dealer (regulation 8(3)). The return form is approved by the Commission; the producer or dealer has no right to use a different format. The Commission can also demand additional information from dealers (producer names, quantities, types) on request.

Right to request extension of time. Both producers and dealers can apply to the Commission for a longer period than 14 days after month end to pay charges (regulations 5(2), 6A(6), 8(1), 8(3)). The Commission has discretion to allow this. There is no stated criteria; it is a matter of administrative grace.

Duty of local government to collect and remit. For pest/disease control charges, local governments must collect and remit within 14 days after month end (regulation 6(2)). They have no discretion to refuse.

Right to notice of charge. Producers have a right (through regulation 7) that a notice of charge be published in a newspaper in their area at least 14 days before the charge takes effect. This is a limited form of advance notice, but the charge may still be imposed without individual notice. The regulation does not require the Commission to notify each producer directly.

Lack of choice or opt-out. Producers cannot opt out of paying charges if a committee is established. There is no individual right to challenge the level of charges or the services funded. Dealers cannot refuse to be collection agents. The regulations impose mandatory participation in a collectively run levy system with no direct link between the charge paid by a particular producer and the services they receive.

The regulations create four penalty provisions, each specifying a fine of $2,000. No imprisonment or daily penalties are provided.

First penalty: Dealer fails to collect charge. Regulation 6A(2) requires a dealer to collect the charge from the producer on the day of purchase or receipt. Failure to collect incurs the $2,000 fine. Note that the dealer’s obligation is to collect, not just to remit. If a dealer receives produce but fails to collect the charge (e.g., because they forgot or the producer objected), the dealer is liable even if they later pay the charge themselves. The prosecution would need to prove the dealer purchased or received produce and did not collect; no mental element is specified, though the provision is likely strict liability.

Second penalty: Dealer fails to remit collected charges. Regulation 6A(6) requires the dealer to pay collected charges to the Commission within 14 days after month end (or longer if allowed). Failure to remit attracts a $2,000 fine. This is separate from the collection penalty; a dealer could be fined twice if they both fail to collect and fail to remit.

Third penalty: Dealer fails to furnish return. Regulation 8(1) requires a dealer to furnish a monthly return. Failure to do so within 14 days after month end (or longer if allowed) incurs a $2,000 fine. This is a continuing obligation each month.

Fourth penalty: Producer fails to furnish return. Regulation 8(3) requires a producer who has sold to a non-dealer to give a return. Failure incurs a $2,000 fine. This only applies when the producer has sold to a non-dealer; if the producer sells only to dealers, no return is required and no penalty risk.

Enforcement mechanism. The regulations do not specify who prosecutes these offences. Presumably, the Commission or the State can bring prosecutions in a court of summary jurisdiction. The $2,000 fine is a fixed maximum; there is no formula for escalation for repeated or serious breaches. The fine is relatively low compared to the value of transactions in commercial horticulture, which may reduce deterrence for larger dealers. There is no provision for interest on late payments so the Commission’s only remedy is prosecution, which is costly and slow.

No strict liability defence stated. The regulation does not include a defence of reasonable mistake or due diligence. However, any prosecution would need to prove the elements of the offence beyond reasonable doubt. For example, in a prosecution under regulation 6A(2), the prosecution must prove the defendant was a dealer (i.e., purchased or received produce from a producer), and that they failed to collect the charge. The charge must have been actually imposed; if no charge was in effect for that produce, the obligation does not arise. The defendant could argue that no charge applied to the specific produce or transaction.

Enforcement of local government collection. Regulation 6 does not impose a penalty on a local government for failing to collect or remit. The only remedy would be for the Commission to seek recovery of the money as a debt or through other administrative action. The absence of a penalty for local governments is notable given that they are also collectors.

Overall enforcement capacity. The regulations rely on a combination of self-reporting through returns and some possibility of audit. The Commission can require statistical information from producers, which may help cross-check dealer returns. But the information asymmetry is large: the Commission relies on dealers and producers to report accurately. A dealer who systematically fails to collect charges and does not report may avoid detection unless the Commission audits specific supply chains.

Agricultural Produce Commission Act 1988 (WA). These regulations are made under that Act. They give effect to sections 12, 13, 14, 19A, and other provisions. The Act creates the Commission, enables establishment of producers’ committees, and empowers the Commission to impose charges. The regulations provide the procedural framework. Section 14 of the Act requires that a notice of charge be published; regulation 7 specifies how and when. Section 13 allows the Commission to require producers to provide statistical information; regulation 4 specifies what information and the mechanism. The Act provides the enabling power for the regulations; the regulations cannot expand beyond the Act’s authority.

Other regulations under the same Act. The Agricultural Produce Commission Act 1988 may have other regulations for different commodities (e.g., eggs, livestock, grains). Each set of regulations will have its own definitions and collection arrangements. This regulation is specific to the horticultural industry. A person who deals in both horticultural produce and another regulated commodity may be subject to multiple sets of regulations with potentially different reporting periods and collection methods.

Local government legislation. Regulation 6 requires local governments to collect certain charges. This overrides or supplements local government’s general functions. Interaction with local government acts may affect how councils administer these collections, but the regulation is paramount within its scope. Local governments may need to amend their own procedures or seek reimbursement for collection costs from the Commission - the regulations are silent on costs.

Sale of Goods Act or contract law. The collection mechanism in regulation 6A operates by deduction from moneys owed. This overrides contractual terms that might otherwise apply to payment. A dealer has a statutory right to deduct the charge even if the contract with the producer is silent or prohibits deductions (subject to the regulation). The deduction gives the dealer a discharge of their obligation to pay that amount to the producer. This is a statutory modification of private contract rights.

Trade Practices / Competition laws. A producers’ committee using charge funds for services might affect competition in the market, e.g., by funding promotion that benefits all producers regardless of their contribution, or by imposing uniform quality standards. The Act and regulations do not provide any competition immunity; the committees must still comply with the Competition and Consumer Act 2010 (Cth). However, the regulations do not address this interaction.

Privacy and data protection. The return and statistical information requirements compel disclosure of producer names, quantities, and dealer identities. This information is collected by the Commission, a government body. There is no express protection against disclosure of this information under these regulations. The Privacy Act 1988 (Cth) may apply to the Commission’s handling of personal information (if the Commission is an agency subject to that Act). However, the regulations themselves do not limit use or disclosure of the collected data.

Criminal Code (WA). The offences under the regulations are summary offences; they may be subject to the general principles of criminal responsibility under the Criminal Code.

The regulations were originally made on 13 February 2001 and published in the Government Gazette on 13 February 2001. They came into operation on that day (the commencement day).

Amendment Regulations 2009. Gazetted 15 September 2009, operative 16 September 2009 (except for regulations 1 and 2 which commenced on 15 September 2009). This was a substantial amendment. It inserted the current regulation 6A (collection by dealer), which was previously absent. Before 2009, the collection mechanism was likely less explicit or different. The 2009 amendments also amended regulation 2 (definitions) to add or modify “dealer” and “horticultural produce” (see Gazette 15 Sep 2009 p. 3567-8). Regulation 4 was amended to update the statistical information provisions. Regulation 5 was amended to clarify producer liability. Regulation 6 was amended to change local government collection provisions? Actually, regulation 6 was amended at the same time (Gazette 15 Sep 2009 p. 3570). Regulation 7 was amended. Regulation 8 was completely replaced (new regulation 8 inserted by the 2009 amendments, see Gazette p. 3570-71). The original regulation 8 was presumably different; the new one imposes the dealer monthly return obligation and the producer return obligation with a $2,000 penalty. The 2009 amendments also omitted regulation 9 (which had been omitted under the Reprints Act). The transitional provisions in regulation 10 remained but may have been adjusted.

Reprint 1. As at 6 November 2009, a reprint of the regulations included the 2009 amendments.

Amendment Regulations 2016. Gazetted 14 June 2016, operative 15 June 2016 (regulations 1 and 2 on 14 June). This amendment was minor: it amended regulation 2 only, presumably to tidy definitions. The Gazette reference is 14 Jun 2016 p. 1819-20. The text of the amendment is not provided in the source, but it likely changed the definition of “dealer” or “horticultural produce” in a small way. The compilation table shows this as the most recent amendment.

Current version. The regulations as at the date of this deep dive are the compiled version including the 2016 amendments. No further amendments appear in the source.

Observations on pattern. The 2009 amendments were the most significant, creating the dealer collection and monthly return regime. Before 2009, the collection system was apparently different, likely with producer-paid charges and less formal enforcement. The 2009 changes shifted the compliance burden onto dealers, reflecting a policy choice to collect at source rather than rely on producer self-assessment. The 2016 amendments were minor.

The source materials provided do not mention any litigation history. No cases are cited in the regulations themselves, and the compilation table does not reference any judicial decisions. Western Australia’s State Reports and unreported judgments would need to be searched independently for cases interpreting these regulations or the parent Act. However, given that the regulations are procedural and subordinate, litigation is likely rare. The most probable grounds for challenge would be:

• Validity of a charge. A producer might argue that a particular charge imposed by the Commission was ultra vires because it was not published in accordance with regulation 7 (notice not in a newspaper, or less than 14 days before). Or that the charge relates to horticultural produce not covered by a producers’ committee.

• Non-compliance penalty. A dealer prosecuted for failing to collect or remit might argue that the person from whom they bought was not a “producer” (e.g., because no committee existed for that produce) or that the produce did not fall within the definition (e.g., processed product not within “horticultural produce”). A court would need to interpret the definitions.

• Collection by local government. A local government might object to the obligation to collect charges, perhaps on constitutional grounds (e.g., is it a Commonwealth trading corporation? Unlikely). Or a producer might challenge the local government’s collection as improper.

• Interpretation of “dealer”. The definition in regulation 2 includes receiving produce for processing. There could be disputes about whether a facility that processes produce but also pays for it is a “dealer” or perhaps a “producer” if they also grow produce.

• Judicial review of Commission decisions. A refusal to allow a longer period for payment or return could be reviewed for procedural fairness.

• No known High Court or Court of Appeal decisions are referenced. The regulations have been in force since 2001 and amended twice without recorded litigation in the source materials.

Given the specialized nature, any litigation is likely in the Magistrates Court or the Supreme Court of Western Australia on judicial review. The fines are low enough that few defendants would appeal.

The term "gotchas" refers to tricky provisions that may catch out a practitioner, dealer, or producer. The following are notable.

Dealer defined broadly includes processors. A processor who buys fruit direct from a grower for juicing is a dealer under paragraph (e) of the definition. This means a juice manufacturer must collect the charge from the producer (the grower) on the day of purchase. If they fail to do so, they face a $2,000 fine. They also must file a monthly return showing all dealings. Many processors may not think of themselves as dealers and may not have systems for levy collection. The obligation arises regardless of whether the charge is for a service that benefits that processor directly.

Collection required even if the dealer does not know the charge amount. The dealer must collect the charge on the day of purchase or receipt. If the Commission has not yet published the charge notice, there may be no charge, but if the notice is in effect, the dealer must know the amount. The charge is not set by the regulations; it is set by Commission notice. A dealer must check each month whether a charge is in force for that produce. Ignorance of the charge amount is not a defence.

Deduction from moneys owed: written statement deadline is strict. If the dealer deducts the charge from money owed to the producer, they must give a written statement within 28 days of making the deduction (regulation 6A(4)). No grace period. Late statement is a breach (though no penalty specified - but the failure to comply with regulation is not penalised by a specific fine; the penalty provision in 6A only applies to failure to collect or failure to remit. The 28-day statement requirement is not backed by a penalty, but it is a legal duty. If breached, the producer could possibly take civil action for the failure to provide statement, but the regulations do not create a private right of action.

Monthly return for dealers is due 14 days after month end, regardless of whether any charge was collected. The return obligation applies to all dealers who dealt in horticultural produce during the month, even if no charge is in effect. The return shows “all dealings”. So a dealer must file every month they deal, even if they collected nothing. This is a recurring administrative cost.

Producer return only if sold to non-dealer. Many producers may sell only through dealers, so they never need to file a return. However, if a producer sells even a small amount at a farmers’ market or directly to a restaurant, that triggers the obligation to file a return for that month (regulation 8(3)). The producer must also remember to pay the charge directly to the Commission within 14 days after month end (regulation 5(2)). The direct-sale producer has both a payment and a return obligation.

Local government collection applies only to pest/disease control services. If a charge is imposed for a purpose other than pest/disease control, the normal dealer collection applies. But if the charge is for pest/disease control, the local government is the collector, not the dealer. This could cause confusion if a producer sells to a dealer who is uncertain whether the charge is pest/disease-related; the dealer might wrongly collect when they should not. The distinction turns on the notice published under section 19A(2)(a). Dealers need to know which charges are pest/disease charges and which are not.

No opt-out. A producer cannot avoid paying the charge by ceasing to sell to dealers who collect, because the liability attaches to the producer regardless of the channel. If they sell to a non-dealer, they must pay directly. There is no exemption for small producers, organic producers, or those who disagree with the committee’s spending.

The fine is $2,000 per offence, not per transaction. Could be modest for a large operator but still a disincentive.

Transitional confusion. The transitional regulation 10 provides that charges imposed before the 2000 amendment continue as if imposed under the new section 14(1). However, if a charge was imposed on a different basis that no longer applies, a producer might be liable for a charge that was originally valid but now may not be within the scope of the committee’s powers. The regulation attempts continuity but could lead to disputes about the validity of pre-2000 charges.

Compliance with these regulations requires a systematic approach from both dealers and producers. The following steps are practical guidance based on the regulations.

For dealers:

1. Determine status. The first step is to confirm you are a “dealer” under regulation 2. If you purchase horticultural produce direct from a producer for wholesale resale, receive it for wholesale sale on behalf of a producer, or receive it from a producer or wholesaler for processing, you are a dealer. Note the broad scope: processors are included.

2. Know which charges apply. The Commission imposes charges by notice published in a newspaper circulating where producers are located. The notice must be published at least 14 days before the charge takes effect (regulation 7). A dealer must monitor these notices for each type of horticultural produce they handle. The charge may vary by commodity and time. The dealer should maintain a current schedule of applicable charges.

3. Collect charge on day of transaction. Regulation 6A(2) requires collection on the day you purchase or receive the produce. This means your invoicing or payment system must be set up to calculate and deduct the charge at the point of transaction, or to collect it as a separate payment from the producer. Do not delay collection; even a one-day delay arguably breaches the obligation.

4. Deduction and statement. You may deduct the charge from money owed to the producer. If you do, you must give the producer a written statement of the amount deducted within 28 days (regulation 6A(4)). The statement should be clear and timely.

5. Hold collected charges on behalf of Commission. The collected money belongs to the Commission from the moment you collect it. Do not use it for working capital. Keep it in a separate account or clearly record it.

6. Remit charges to Commission within 14 days after month end. Regulation 6A(6). Note that this is 14 days after the end of the month in which you collected the charge, not 14 days after each transaction. If you collect charges from multiple producers in a month, you must sum them and remit in one payment (subject to the Commission’s form). You can apply for a longer period if you can show cause.

7. File monthly return. Regulation 8(1): A dealer must furnish a return to the Commission within 14 days after the end of each month, covering all dealings in horticultural produce during that month. The form is approved by the Commission. If the Commission requests, you must include the names of producers you dealt with, quantities supplied by each, and the types of produce. Keep records sufficient to produce the return quickly.

8. Penalties for non-compliance. Failing to collect, failing to remit, or failing to file a return each carries a $2,000 fine. Ensure your system includes compliance checks.

For producers:

1. Confirm you are a producer. You are a producer if you grow horticultural produce for which a producers’ committee exists. If no committee exists for your crop, you likely have no obligations under these regulations.

2. Understand liability. You are liable for any charge imposed by the Commission (regulation 5(1)). The liability is discharged either by the dealer collecting and remitting, or by you paying directly.

3. If you sell to a dealer. Accept the dealer collecting the charge. Ensure the dealer gives you a written statement if they deduct from payment. Keep a record of the deduction for your own accounting.

4. If you sell to a non-dealer (e.g., direct to consumer, restaurant, farmers’ market). You must:

   • Pay the charge to the Commission within 14 days after the end of the month (regulation 5(2)). Calculate the amount based on the applicable charge per unit of produce.
   • Furnish a return to the Commission within 14 days after month end (regulation 8(3)). The return must show quantities and types of produce sold. The form is approved by the Commission.
   • Be careful: if you sell both through dealers and directly, you only need to report direct sales.

5. Respond to statistical information requests. If the Commission sends you a written notice specifying statistical information under regulation 4, you must provide that information. The notice will specify the period, date, and nature of information (quantity, land area, dealer details). Failure to comply is not directly penalised under these regulations, but the Act may provide penalties; ensure compliance.

6. Keep adequate records. You should record for each sale: date, buyer, quantity, type, whether buyer is a dealer, and amount of charge collected or paid. This will support your return and any statistical information requests.

7. Monitor notices. The Commission must publish notices of charge in a newspaper in your area at least 14 days before the charge takes effect. Monitor industry publications or the Commission’s website for these notices.

8. No opt-out. You cannot avoid the charge by changing your marketing channel; if you sell to a non-dealer you must pay directly. The only way to avoid the charge is to produce a crop for which no committee exists.

For local governments. If a charge is for pest/disease control, you must collect from producers in your district and remit within 14 days after month end. No penalty is specified for non-remittance, but the Commission could seek recovery. Ensure you have procedures to identify affected producers and collect the levy.

General best practice. Maintain an ongoing relationship with the Agricultural Produce Commission: check its website or contact it for current charge notices, approved return forms, and any extensions of time. Given the small penalty size, a system of monthly reminders for returns and payments is essential. For dealers, integrate charge calculation into point-of-sale or accounting software. For producers, consider selling exclusively through dealers to reduce compliance burden, but that may not suit all business models.