New South Wales Supreme Court CITATION : CEO of Customs v Hui Min JING [2007] NSWSC 1354 HEARING DATE(S) : 16/03/2007, 01/11/2007 JUDGMENT DATE : 30 November 2007 JUDGMENT OF : Howie J at 1 DECISION : The following penalties are imposed: Import Charges:1. Entry 1 For the offence contrary to s 234(1) of the Customs Act and the offence contrary to s 9(1) of the CTD Act, applying s 4K(4): A fine of $1600. 2. Entries 2 and 5 applying s 4K(4): A fine of $3000. 3. Entries 3, 4 and 9 to 13 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $12,000. 4. Entries 14 to 20 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $12,000. 5. Entries 21 to 24 and 26 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $9000. 6. Entry 25 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $1600. Export Charges: 1. Clearance 1 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $4000. 2. Clearances 2 to 5 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $10,000. 3. Clearances 6 and 7 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $6000. 4. Clearances 8 to 13 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $17,000. 5. Clearance 14 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $4000. 6. Clearances 15 to 17 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $9000. 7. Clearances 18 to 30 for offences under s 12(1) of the CTD Act, applying s 4K(4); $25,000. 8. Clearances 31 to 39 for offences under s 12(1) of the CTD Act, applying s 4K(4): $15,000. The total fine for all offences is $129,200. CATCHWORDS : CUSTOMS PROSECUTION - Sentence following admission of guilt and assistance to the prosecutor. Customs Act 1901 - Part XIV, ss 234(1)(d)(i) and (ii), 236 LEGISLATION CITED : Commerce (Trade Descriptions) Act 1905 (Cth) - ss 9(1), 121(1) Crimes Act 1914 (Cth) - ss 4K(4), 16C CEO Customs v CHS Enterprises Pty Ltd [2007] NSWSC 1133 CASES CITED : CEO Customs v Labrador Liquor Wholesale Pty Ltd [2006] QCA 558; 63 ATR 1158 Pearce v The Queen [1998] HCA 57; 194 CLR 610 PARTIES : Chief Executive Officer of Customs v Hui Min Jing FILE NUMBER(S) : SC 20304/2004 COUNSEL : P Roberts SC - Plaintiff B Allas - 3rd Defendant SOLICITORS : Australian Government Solicitor - Plaintiff B Allas - 3rd Defendant IN THE SUPREME COURT OF NEW SOUTH WALES COMMON LAW DIVISION HOWIE J FRIDAY 30 NOVEMBER 2007 SC 20304/2004 CHIEF EXECUTIVE OFFICER OF CUSTOMS v HUI MIN JING JUDGMENT 1 HIS HONOUR: These are proceedings brought under Part XIV of the Customs Act 1901 (Cth) (the "Customs Act") by the plaintiff ("the prosecutor") whereby the third defendant (Ms Jing) has been charged with a number of offences in relation to the importation into, and exportation from, Australia of honey originating in China. There were 29 separate consignments of honey that took place over a period of about 11 months from August 2001. 2 The importation of the honey gives rise to 21 offences against s 234(1)(d)(i) or (ii) of the Customs Act and 19 offences in breach of s 9(1) of the Commerce (Trade Descriptions) Act 1905 (Cth) (the "CTD Act"). These are set out in a schedule to this judgment under the heading "Import Charges". The exportation of honey gave rise to 17 offences against s 234(1)(d)(i) of the Customs Act and 39 offences contrary to s 12(1) of the CTD Act. These are set out in a schedule to this judgment under the heading "Export Charges". 3 Offences under s 234 of the Customs Act concern misstatements intentionally or recklessly made to a Customs Officer. The maximum penalty for each offence is a fine of 100 penalty units. A penalty unit is $110 and hence the maximum fine that can be imposed is $11,000. As no duty was payable on the honey imported, the mandatory provisions relating to unpaid duty are not applicable. The offences under s 9 and s 12 of the CTD Act concern false or misleading statements made in relation to the importation or exportation of goods. The maximum penalty for each offence under the two sections is $10,000. None of the offences charged against Ms Jing is punishable by a term of imprisonment. 4 The proceedings commenced in this Court by the prosecutor involved five defendants including two companies and a person who was the former husband of Ms Jing. The statement of claim was filed on 27 July 2004. On 16 March 2007 Ms Jing pleaded guilty before me to each of the charges. She also indicated in sworn evidence that she was prepared to assist the prosecutor in the proceedings involving the other defendants. The proceedings involving Ms Jing were then adjourned to permit that assistance to be given. 5 By judgment dated 12 October 2007 Acting Justice Smart convicted the other defendants of various offences under the Customs Act and CTD Act arising from the shipments of the honey into and out of Australia: see CEO Customs v CHS Enterprises Pty Ltd [2007] NSWSC 1133. Ms Jing gave evidence during the proceedings before his Honour on 17 and 18 July 2007 and her evidence is referred to at paragraphs 68 to 103 of the judgment. She was described by his Honour as: "wily and manipulative and anxious to have her share of responsibility and wrong-doing reduced". 6 The proceedings against Ms Jing were resumed before me on 1 November 2007. Senior counsel representing the prosecutor stated the following: "It is Customs' view that Miss Jing's evidence in the proceedings before Acting Justice Smart was of importance to the prosecution case, particularly in relation to Mr Lam [the fifth defendant] and Unicargo [the fourth defendant]." 7 Although Mr Hu (the second defendant) and CHS Enterprises Pty Limited (the first defendant) were only convicted in respect of one of the transactions, I was advised that this was not as a result of any failing in the evidence of Ms Jing. 8 The facts can briefly be stated for present purposes. Between August 2001 and May 2002, 28 separate consignments, comprising 125 container loads of Chinese honey were imported from China into Australia. Each container held 68 drums and each drum contained 200 litres of honey. The total quantity of honey imported in the 28 consignments was 1.7 million litres having a total listed Customs value of $5,027,289. 9 In respect of most of the 28 consignments, false or misleading commercial and shipping documentation was presented to Australian Customs representing that the honey had been sourced from a fictitious Singaporean company and had been consigned from Singapore or Malaysia. The honey was imported into Australia by CHS Enterprises Pty Limited of which Ms Jing's husband was the sole director/secretary, and by JHM Trading Company which was a name used by Ms Jing for business purposes. 10 When the honey had been imported into Australia it was re-packaged and/or re-labelled as being produced in Australia. The honey was then shipped for export to the United States of America. There were 39 separate export consignments, comprising 125 container loads of honey. False and misleading shipping and commercial documentation was generated in relation to these export consignments, representing that the honey was a product of Australia. 11 The false and misleading statements concerning the origin of the honey did not result in the avoidance of Australian Customs duties, as none was payable on the imported honey, irrespective of whether it originated from China or Singapore. Nor were there any restrictions on the importation of honey from either country. 12 The exportation of the honey to the United States was carried out in the names of CHS Enterprises Pty Ltd and JW International Trading Pty Ltd or Jing Wei International Trading Pty Ltd or a similar name. At the time of the exportations, Chinese honey attracted anti-dumping duties in the United States of between 34 to 184 per cent. Honey produced in Australia was duty free. By falsely claiming that the honey was of Australian origin, the United States duties were avoided. This was no doubt the principal reason why the origin of the honey was misdescribed. The honey was also found to contain a particular carcinogenic antibiotic that has been linked to a certain rare blood disease. The particular antibiotic was banned in food products sold in the United States. 13 In regard to the 28 separate importations of Chinese honey the prosecutor charged as the principal, the person or entity on whose behalf the particular Customs entry was made. With the exception of importations 1 and 2, the Customs entries were made on behalf of Ms Jing using the business name JHM Trading Co. Each of the remaining defendants were charged with being directly concerned with the commission of the principal offence, pursuant to s 236 of the Customs Act. 14 Of the 28 separate importations 21 are the subject of a charge under the Customs Act for directly or indirectly representing, in Entry for Home Consumption documents presented to Customs, that the honey was either from an unknown origin or from Singapore, reckless as to the fact that the honey was from China. The same representations constitute offences under the CTD Act. 15 The offences under the Customs Act relating to the 39 instances of exportation arise from a representation in export clearance forms that the honey was Australian, reckless as to the fact that the honey was from China. The same representations are relied upon to establish the offences against the CTD Act. 16 The entity alleged to be the principal in all of the exportation offences is AK Unicargo Pty Ltd, with the offender being charged with being directly concerned with the commission of those offences pursuant to section 236 of the Customs Act. 17 The involvement of Ms Jing in what was obviously an ongoing enterprise of using Australia as a means of fraudulently importing Chinese honey in to the United States is described in an affidavit placed before me. A similar account was given in evidence before Smart AJ and is found in his judgment in those portions to which I have already referred. In effect she says that she was to receive $50 a day for her involvement in the venture that was organised through a company in China directly with the importers in the United States. She was in effect the facilitator in Australia on behalf of a government owned company in China. She said that she did not believe that what she was doing was unlawful. 18 Ms Jing's account was that Mr Hu both encouraged and assisted her in undertaking this enterprise. He put her in touch with a Customs agent, Mr Lam (the fifth defendant). Mr Lam supplied her with the storage deposits used and his company (the fourth defendant), a freight forwarding business, aided in the importing and exporting of the honey. Mr Hu allowed her to use his company (the first defendant) pending the registration of her own company, Jing Wei International Trading Pty Ltd. For some reason Mr Hu's company continued to be used by Mr Lam. She received instructions by FAX or telephone from China. Although it was proposed to blend Australian honey with that imported this never eventuated. Mr Lam organised Customs clearances, quarantine inspections and the exportation of the honey. 19 Ms Jing assisted by Mr Hu removed the "Made in China" labels from drums when they arrived and replaced them with labels indicating that the honey originated in Australia. She also occasionally cleaned leaking containers. Mr Hu and Ms Jing separated on 17 August 2004 a few weeks after the filing of the statement of claim in this matter. 20 Ms Jing was born in China and is aged 43 years. In 1998 she married Robin Hu (the second defendant) and in 1999 a child was born. Ms Jing came to Australia in the year 2000 and is an Australian citizen. She is now divorced. She has apparently a very poor understanding of English and can speak very little in that language. 21 Ms Jing has no prior criminal record in either China or Australia. She lives with, and cares for, her child in rented housing commission accommodation. She is unemployed, and in receipt of a single parent pension. She also receives a child support payment from her ex-husband of $45.00 per week ($180.00 per month). She does not own a car or any real estate and has limited means. She would no doubt have great difficulty in paying any pecuniary penalty. However, she is not at risk of being placed in prison for non-payment of any fine imposed upon her. 22 It is clear on the facts that Ms Jing was the prime offender in carrying out the scheme in Australia. It may be that she was acting as agent for Chinese principals, but so far as the offences before the Court are concerned she was a major, if not the major, offender. It is for Smart AJ to determine relativities between all the defendants as he has heard much more evidence than was placed before me. He made findings against Ms Jing as to her greater involvement in the enterprise than Mr Hu but that is not a matter that concerns me. Although the fourth defendant was the principal in the exporting offences, that company was engaged in the enterprise at the behest of Ms Jing. It is clear also that the first defendant, CHS Enterprises Pty Ltd, was acting on behalf of Ms Jing in the importation of the honey. 23 The offences are serious even though they may not have resulted in any loss to the revenue because none of the misdescriptions or false statements resulted in avoidance of duty. However they put at risk the confidence of foreign markets in both Australian produce and Australian Customs procedures. It was a highly organised enterprise that was in place for a not inconsiderable period of time and involved a large amount of produce being represented as what it was not. General deterrence is clearly required because of the importance of attempting to ensure that such a systematic fraud perpetrated on the Australian Customs is not attempted again for whatever purpose so significant is the risk posed by such conduct to Australian trade. It is important that Customs be able to rely upon statements made by importers and exporters of goods and it should be understood that it is a serious offence for which significant penalties will be imposed where persons intentionally or recklessly breach the duty of honesty imposed upon them when undertaking that type of activity. Although the purpose of the scheme may have been to avoid USA duties, that is not a matter warranting punishment in this Court. 24 It is difficult to know what Ms Jing financially made out of the venture, but even if one accepts that she was receiving $US50 a day over a period of about a year it was in excess of $US15,000. Of course that is a trifling sum having regard to the value of the goods. However, she was engaged in the venture as a business and for profit. It involved a considerable amount of effort on her part, even though she sought advice and was assisted by others. 25 I am to apply the provisions of the Crimes Act 1914(Cth). Section 16C of that Act requires the Court to take into account the ability of Ms Jing to pay any financial penalty imposed upon her. But that inability cannot result in the imposition of fines that do not reflect the objective seriousness of her conduct or seek to have a general deterrent effect: see generally CEO Customs v Labrador Liquor Wholesale Pty Ltd [2006] QCA 558; 63 ATR 1158 at [96]-[98]. It is important to have regard to the principle of totality that applies even though the Court cannot impose penalties that are concurrent as might be done if the Court were imposing custodial orders. 26 Clearly her lack of criminal record is a relevant factor but it loses much of its significance having regard to the nature of the offences committed by her and the number of them. There is a limited degree of remorse apparent: she was found by Smart AJ to have not told the complete truth and to have sought to downplay the extent of her criminality. She is entitled to a reduction of the otherwise appropriate sentence by reason of her pleas of guilty even though they came at a fairly late stage in the proceedings. 27 She is also entitled to a benefit by reason of the assistance she has given, but that cannot be of the same extent that would flow had she to serve a period of imprisonment in more onerous conditions. There is nothing to suggest she has been, or will be, at risk by reason of the assistance she offered and has given to the prosecutor. Still the policy of encouragement to offenders to facilitate the administration of justice by a plea of guilty and assistance should be applied even where the penalty to be imposed is only a monetary one. She should receive a combined discount of about one third. 28 I know little about Ms Jing's prospects of reoffending but I am willing to treat this as an isolated venture of criminal conduct on her part, notwithstanding that it went on over a period of about 10 months and involved many acts of fraudulent conduct. 29 There is a degree of double charging in the offences in that the same conduct resulted in breach of two statutes. This is not meant to be a criticism as there is nothing wrong or oppressive in the prosecutor charging more than one offence arising from the single act of an offender: see generally Pearce v The Queen [1998] HCA 57; 194 CLR 610. But the principle of totality has a very significant role to play when sentencing in that situation. Full rein can be given to the principle where, as here, the minimum penalty provisions do not apply because there was no evasion of duty. 30 It is clear that the purpose of the importations, which were not themselves illegal, were designed to facilitate the exportation of the honey to the USA. The exportation offences were the more serious because it was those that had the potential to adversely affect overseas confidence in Australian exports and this country's Customs controls. However, because the offences were not aimed at the revenue and were at most reckless as to any deleterious effect they may have on the Australian economy, they were not in the most serious category. Each offence itself was not particularly grave but it was the course of conduct that the offences represented that calls for significant punishment to denounce that activity for its routine fraud on Customs officers and the jeopardy in which it placed Australian exports. 31 Section 4K(4) of the Crimes Act applies and permits me to impose one penalty for more than one charge. It seems to me to be appropriate to take that course in relation to some of the offences. 32 The overall fines imposed have been decreased by about a third. The individual fines are not intended to be subject to close mathematical analysis. I have tried to take into account totality by moderating some of the sentences imposed for groups of offences that have been chosen largely because they approximate in time. Little has been added by reason of the CTD offences because of the element of double punishment. I have taken into account the relatively little income Ms Jing received by way of payment and her limited ability to pay a fine given her personal circumstances. 33 The following penalties are imposed: Import Charges 1. Entry 1 For the offence contrary to s 234(1) of the Customs Act and the offence contrary to s 9(1) of the CTD Act, applying s 4K(4): A fine of $1600. 2. Entries 2 and 5 applying s 4K(4): A fine of $3000. 3. Entries 3, 4 and 9 to 13 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $12,000. 4. Entries 14 to 20 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $12,000. 5. Entries 21 to 24 and 26 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $9000. 6. Entry 25 for offences both under s 234(1) of the Customs Act and s 9(1) of the CTD Act, applying s 4K(4): a fine of $1600. Export Charges 1. Clearance 1 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $4000. 2. Clearances 2 to 5 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $10,000. 3. Clearances 6 and 7 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $6000. 4. Clearances 8 to 13 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $17,000. 5. Clearance 14 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $4000. 6. Clearances 15 to 17 for offences both under s 234(1) of the Customs Act and s 12(1) of the CTD Act, applying s 4K(4): a fine of $9000. 7. Clearances 18 to 30 for offences under s 12(1) of the CTD Act, applying s 4K(4): $25,000. 8. Clearances 31 to 39 for offences under s 12(1) of the CTD Act, applying s 4K(4): $15,000. The total fine for all offences is $129,200. This is roughly a third less than $200,000 which was the amount I thought would be otherwise appropriate had there not been a plea of guilty and assistance. ********** SCHEDULE Import Charges: 1. Entry 1: 02.08.01 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 2. Entry 2: 10.10.01 - s 234(1)(d)(ii) Customs Act. 3. Entry 3: 15.11.01 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 4. Entry 4: 19.12.01 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 5. Entry 5: 31.12.01 - s 234(1)(d)(ii) Customs Act. 6. Entry 9: 17.01.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 7. Entry 10: 17.01.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 8. Entry 11: 08.02.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 9. Entry 12: 27.02.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 10. Entry 13: 27.02.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 11. Entry 14: 11.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 12. Entry 17: 11.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 13. Entry 18: 13.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 14. Entry 19: 13.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 15. Entry 20: 19.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 16. Entry 21: 26.03.02 - s 234 (1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 17. Entry 22: 26.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 18. Entry 23: 26.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 19. Entry 24: 26.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 20. Entry 25: 06.05.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. 21. Entry 26: 26.03.02 - s 234(1)(d)(i) Customs Act; s 9(1) Commerce (Trade Descriptions) Act. SCHEDULE Export Charges: 1. Clearance 1: 07.08.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 2. Clearance 2: 12.10.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 3. Clearance 3: 15.10.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 4. Clearance 4: 16.10.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 5. Clearance 5: 21.11.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 6. Clearance 6: 31.12.01 - s 234(1)(d)(i) Customs Act, s 12(1)(b) Commerce (Trade Descriptions) Act. 7. Clearance 7: 31.12.01 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 8. Clearance 8: 16.01.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 9. Clearance 9: 21.01.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 10. Clearance 10: 21.01.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 11. Clearance 11: 16.01.02 - s 234(1)(d)(i) Customs Act, s 12(1)(b) Commerce (Trade Descriptions) Act. 12. Clearance 12: 21.01.02 - s 234(1)(d)(i) Customs Act, s 12(1)(b) Commerce (Trade Descriptions) Act. 13. Clearance 13: 21.01.02 - s 234(1)(d)(i) Customs Act, s 12(1)(b) Commerce (Trade Descriptions) Act. 14. Clearance 14: 12.02.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 15. Clearance 15: 01.03.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 16. Clearance 16: 04.03.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 17. Clearance 17: 14.03.02 - s 234(1)(d)(i) Customs Act; s 12(1)(b) Commerce (Trade Descriptions) Act. 18. Clearance 18: 05.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 19. Clearance 19: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 20. Clearance 20: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 21. Clearance 21: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 22. Clearance 22: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 23. Clearance 23: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 24. Clearance 24: 02.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 25. Clearance 25: 16.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 26. Clearance 26: 16.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 27. Clearance 27: 12.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 28. Clearance 28: 10.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 29. Clearance 29: 12.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 30. Clearance 30: 12.04.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 31. Clearance 31: 31.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 32. Clearance 32: 31.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 33. Clearance 33: 24.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 34. Clearance 34: 24.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 35. Clearance 35: 24.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 36. Clearance 36: 24.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 37. Clearance 37: 31.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 38. Clearance 38: 31.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 39. Clearance 39: 31.05.02 - s 12(1)(b) Commerce (Trade Descriptions) Act. 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