In this instance I am not guilty of "apparent skim reading". I have studied the Scottish WGG virtually since the day it came out, nevertheless I do not claim to be an expert on the legislation. I am just as capable of mis-interpretation as others posting on this thread.
Initially I contributed to the OP's request for information about the rules applying to disposal of deer waste, where I hope I provided a steer. Which then touched on the applicability of the Hunter/Primary Producer's exemption for supply of in-fur or feather unprocessed carcases
I drew everyone's attention to the most recent Scottish WGG, in my post #9 on Thursday, and recommended using that as the source, rather than the England/Wales version that everybody seems to like to quote. But it is well out of date, inconsistent, ambiguous and self contradictory in parts. And recognised as being long-overdue an update.
It was promised to have been updated some time ago, but hasn't happened yet. Whereas the Scots have done so, their new version is six years in advance of the old 2015 England/Wales version and I think gives greater clarity.
View attachment 258493
If you want to know where things stand on the consultation about the draft revised England/Wales guide, you can download the responses that consultation from
Supply of wild game for human consumption I do not have sight of that draft. The consultation closed in September 2020, same timescale as the Scottish one.
As yet no word of when the final document might be released, nor even a second draft yet.
Subsequently
@25 Sharps chipped in by saying that "Wrong, the Hunters’ bullet demotion doesn’t exist any more " Which is incorrect
Naturally , me being me, I felt the need to challenge him on that statement, which then escalated into the tiresome ding-dong between us. With him showing the flow chart in the old guide that in fact confirms exactly what I have been saying.
Now that you have had a day or so to skim it, you have discovered the key difference under Scottish legislation, which anyone shooting deer in Scotland knows about, it is not a new thing. I.e. the Venison Dealers License VDL.
Which I thought I had made clear when I said yesterday in post #29 "
take a look at the current modern Scottish Wild Game guide. (the rules are the same throughout GB), though the Scots have the added complication of Venison dealer licensing)"
But perhaps you skimmed over that nugget.
Simply put, Scotland has historically had a problem with poaching, where the VDL is intended to break that chain. By requiring at least one party in the transaction to hold a VDL, even for direct sale to the consumer. Not so in England/Wales. They also have anti-poaching legislation for Salmon tagging, see
The Salmon Carcass Tagging (Scotland) Regulations 2016
The Primary Producer's Exemption is enshrined in EU and UK law. Some countries such as Scotland may also impose their own restrictions over and above that such as the VDL. Just as, since Brexit, GB may now deviate from EU legislation (NI will still be held to it). But in reality I do not expect to see much change, in the future.
The intention of the Hunter's exemption is that hunters/hunting parties even estates, be allowed to sell their primary production direct to the consumer, or direct to local retailers without any restriction, other than to maintain safety and traceability, which I suggested is as simple as keeping larder records, accounts, invoices, receipts etc.
One may supply either directly to the consumer, or to a retailer. And of course not to an AGHE, that has to be a business to business transaction.
Below are direct quotes from the guide.
Primary wild game products are the products of hunting. This means in fur/feather game
that has undergone no more than any necessary preparation that is part of normal hunting
practice. Such preparation includes bleeding and evisceration (or ‘gralloching’), which is
the removal of green offal from large wild game, and is normally carried out either “in the
field” or in a game larder. Consequently, game larders, where preparation as part of
normal hunting practices takes place, are also defined as part of primary production.
Supply must be of small quantities of in fur/feather wild game Supply must be to direct to final consumers or local retail
Small quantities are regarded as self-defining in Scotland as the demand for in
fur/feather wild game from final consumers and local establishments is limited. Local is
defined as supply within one’s own Local Authority, a neighbouring Local Authority or 50
km/30 miles from the boundary of your Local Authority. Local in relation to Scotland’s
Island Local Authorities refers to the whole of Scotland. There is no local restriction
applied to direct sales to the final consumer, but the legal requirement remains to ensure
that any food supplied is safe.
In England/Wales much the same, except defined by county boundaries.
Trained Hunter status: Not required but encouraged
Registration as a food business is not required but you are encouraged to contact your Local Authority
You do not require a food safety management system based on HACCP principles.
Must maintain traceability records of supply
4.3 Direct supply of small quantities of in fur/feather wild game
carcases to the final consumer or local retail establishments
If you are a primary producer, estate or shoot that supplies all of your in fur/feather wild
game carcases, without any further processing (i.e. skinning, plucking etc.), directly
to the final consumer, or local retail establishments who directly supply the final consumer
(such as butchers or restaurants):
You must abide by the requirements of Retained Regulation 178/2002, including
the legal obligation to supply safe food and maintain traceability
You are exempt from the requirements of Retained Regulation 852/2004 and
Retained Regulation 853/2004 as set out in Article 1(2)(c) and Article 1(3)(c)
respectively.
This exemption only applies to the direct supply of small quantities of in fur/feather wild
game (i.e. primary products).
Examples of local retail establishments who may supply the final consumer are
restaurants, butchers and farm shops. These local retail establishments must be
registered as food businesses with their Local Authority.
Primary producers who wish to operate under this exemption are encouraged to contact
their Local Authority to ensure that the exemption does apply to their operations. Local
Authorities can also assist primary producers in understanding the food safety and
traceability requirements which apply to them under Retained Regulation 178/2002.
Primary producers operating under this exemption still need to demonstrate traceability in
their supply has been maintained in line with Article 18 of Retained Regulation 178/2002
and section 9 of this guide.
It is simple enough to understand. I, without needing any qualifications (though in fact I am a trained hunter with I think sufficient experience and mentoring by the Deer Keeper of a very large estate, who guided me whilst I shot twelve deer with him) may, for example, shoot a deer in Kent or West Sussex, gralloch it on the spot or in a nearby larder, take it home to East Sussex and sell it to a member of the public, or my local butcher, pub, restaurant, farm shop etc. (All of course being food businesses themselves) No unnecessary legislation applies. No trained Hunter, No food business, no HACCP, no inspection of my game larder (AKA chiller, in my case). No commercial waste disposal as long as its no more than 20kg/week.
Only traceability records.
Whereas if I shot it in North Norfolk I am not allowed to bring it home and do so. Not local. Must only be for my own personal consumption or that of family and friends.
Just as, say, my own freezer running low, I might call a contact, an individual or an estate, to ask whether they might have a carcase for me to purchase, or maybe go out and shoot one for me, ready for me to pick up when I was travelling through. They could also be operating under the primary producer exemption. Might even, once I'd paid for it, then ask them to help me skin and quarter it for for easier transportation, or at least let me use their larder to do so myself, even completely butcher it myself, which used to be a regular thing for me.
Nowadays this is how I obtain most of my venison, for me, my family and friends. Much less expensive for me than stalking it myself.
This is just how I like to operate, as uncomplicatedly as possible. Using the exemption. For others circumstances are different. If I were to be doing this on anything more than my hobby scale I would certainly contact my EHO for advice and support to carry on without the need to register as a food business. As I know several others are doing, with the approval of their EHO. It is allowed. And possibly less work for the pragmatic EHO.
Correct me if I am wrong, of course, I daresay some will continue to do so.
hole!
