Please take the time to read this and use the link to have your say on protecting the private ownership of firearms:

EU Public Consultation on firearms
This EU Consultation Document on a common approach to reducing the harm caused by
criminal use of firearms in the EU can be found on
It is one part of a number of EU firearms-related initiatives, including the ratification by the
EU of the UN Vienna Firearms Protocol, the much-publicised comments by EU Home
Affairs Commissioner Cecilia Malmström suggesting a link between legal ownership of
firearms and illicit trafficking, the preparation of a report by the Commission on possible
further amendments to the EU Directive 91/477/EEC on control of the acquisition and
possession of weapons and of course the EU’s active role in the UN’s recent adoption of a
text for an Conventional Arms Trade Treaty.
The intention of this consultation is to obtain some appearance of legitimacy for further
restrictions on the legal ownership, use and acquisition of firearms by civilians. We may
anticipate that organisations opposed to recreational firearms use, hunting or gun collecting
will orchestrate large numbers of replies. It is therefore essential that shooting organisations
and their individual members complete and submit responses to provide an effective counterargument
and counter-weight. If the majority of responses are supportive of our interests, it
would be difficult for the Commission to use public opinion as a reason for seeking further
The deadline for replies is the 17th June 2013.
All the questions have at least some relevance to legal ownership. Most of the questions are
biased and are written in a way that seeks to pre-determine the response and push the
respondent into agreeing that some EU action is needed even though national legislation on
all issues addressed in the questions already exists.
Question C.2 suggests that the list of prohibited firearms should be extended (it is understood
that the Commission is referring to semiautomatic rifles and possibly also to semiautomatic
shotguns and handguns). Question C.4 pursues the mandatory use of locking devices in
firearms. Imagine the impact if this was made retrospective. Question C.7 would provide a
justification to introduce compulsory mental health tests and suppress the current derogation
that allows people under the age of 18 to hunt and sport-shoot if they have parental
permission or guidance. This derogation was hard-won with Britain taking a leading role in
negotiating it. If this were lost it would be a severe blow to the future of our sport. Question
C.8 aims at requiring that all firearms and ammunition be subject to authorisation, which
would have negative implications not only in countries where there is a formal distinction
between authorisation and declaration of firearms but also in countries where there are
flexible arrangements for certain hunting firearms. In Britain, it could result in the
introduction of tighter controls on shotguns and shotgun cartridges. Question D.2 could result
in a general requirement to store firearms in an approved safe. What would happen if the EU
specification for a gun cabinet exceeded the British Standard currently the norm in Britain?
It is not necessary to answe r the optional questions that request additional free-text
comments (questions B.4, C.11, D.5 and E.6). It is necessary to click on Option 1 in
response to all the multiple choice questions. While this may seem extreme in some
instances, the questions are biased and are designed to elicit your agreement that action
by the EU is necessary.
If you do decide to make further comments, you may wish to consider referring to the
EU principle of ‘subsidiarity’, enshrined in Article 5 of the Treaty on European Union.
This is the principle whereby the Union does not take action (except in the areas that fall
within its exclusive competence), unless it is more effective than action taken at national,
regional or local level. Civilian firearms control is most appropriately dealt with at national
level, given the variety of shooting and hunting traditions among the member states.
Please follow the following steps:
1. Go to
2. Choose your language in the icon that is in the upper right part of the screen.
3. Indicate your country, whether you are an individual or an organisation and your name or
the name of your organisation.
4. Answer the questions by clicking on option “1” for each one of them. You do not need to
answer the optional questions that request additional comments (questions B.4, C.11, D.5
and E.6).
5. After having answered the questions, as a security measure to avoid computer-generated
replies, you will have to type in the numbers and/or letters that will be displayed in your
screen and validate them.
6. Your answers will have been submitted by then. You can view them and/or save them as a
Thank you for taking the time to respond to this consultation.
David Penn
Secretary, British Shooting Sports Council

Thank you for your time, Simon.