Hmmmm - not according to this -
2. How do I apply for or renew an APEC card?
From 1 July 2017, ABTC applications and renewals for Australian citizens must be lodged electronically through ImmiAccount. Please note, all applications received via mail and/or courier will not be accepted and will be returned to applicants.
The application process will prompt you to provide particular information depending on your individual circumstances. Incomplete applications could be delayed or, in some cases, refused.
Applications must include:
A copy of the bio-data page of your Australian passport;
Identity documentation;
Supporting evidence to demonstrate your business is engaged in trade or investment activities between APEC economies;
If you reside outside of Australia, evidence of authority to reside and work within this economy;
Evidence that you have made multiple trips to APEC economies within the last 12 months.