Registering as a food business - direct supply

[75]

I thought I'd stick this up here as I know a few folk have either done this or are thinking of it but these posts are often tucked away in other threads.

So first off, this isn't a thread about do you / don't you need to register in order to take a carcass to the game dealer. That's been covered extensively elsewhere - see here for example: Registering as a food business

I registered with Manchester City Council about 3 years ago as a Food Business. By the inspectors own admission, my application sat on their desk for a few weeks as they didn't know what to do with it! They'd never come across this scenario before and are more used to dealing with restaurants and takeaways. They came out, gave me a quick inspection but to be honest, it was more of a fact finding mission as they didn't really understand the process, but were very friendly and genuinely curious. I've probably only taken a handful of carcasses to the dealers over the last 3 years, but I know I'm covered if asked and the whole process was free and took about an hour of my time (10 mins to fill in the online application, 45 mins for an inspection / chat).

I'm now in the process of changing my registration from simply supply of in-fur to AGHE to direct supply to the final consumer. I don't want to end up with a couple of reds in the chiller that the game dealer won't take this winter (I've already had a farmer tell me that his turnips are my responsibility and I better not let the bloody deer eat them ). We tend to eat most of what I shoot and give a load away to friends and family but I'd struggle to find freezer space for more than one red at a time so want to keep my options open.

Technically, I don't think there is any difference in requirement from a food business registration perspective, but as I'd previously only mentioned I'd be supplying carcasses to a game dealer I thought I'd drop them a note to let them know and make sure I was covered. The same inspector is dealing with me again this time and we've had a couple of chats by phone as she's sought clarity on a couple of points as I'm still the only person registered in Manchester on this basis. I've provided a HACCP (thanks @willie_gunn and @devon deer stalker who supplied the template), some photos of the area I'll use for butchery (an island in the kitchen - not a dedicated butchery area but they're happy with this as long as I follow the HACCP) and an example of the labels I'll use to ensure traceability. I also did the Level 2 Food Hygiene course online, which cost a tenner and took a couple of hours or so but seems to have been well received. All seems fine so far and just waiting final confirmation, which may take a week or two as the inspectors are pretty maxed out at the minute dealing with complaints about bars and restaurants not following social distancing regs apparently!

 

[paulbshooting]

Thanks for posting, just going through the same process as numbers need to be controlled and only so much u can eat. Have my inspection in a couple of weeks. Good advice and info provided from them so far. Great if I can just cover costs and get more people eating venison whilst protecting crops and keeping landowners happy.

 

[JMikeyH]

Thanks for the post. Would it be possible to put a copy of the HACCP up on this thread please?

 

[VIGILAIRE]

Interesting and informative post.

 

[paul dillon]

Thanks for posting

 

[slider]

I registered with my local authority a year or so ago and like you, they didn't really have a clue to start with. I had to point them in the direction of the FSA Wild Game Guide.

Once the EHO had done a bit of research it was a relatively easy process - I provided a HACCP and Risk Assessment, they inspect my premises and transport ( a domestic garage and a carcass tray in the back seat of my car and that was it.

Some have stated that a Venison Dealers Licence is also required and I discussed this specifically with the EHO, who reverted to the LA's lawyers and were adamant that it was not - I am simply selling my own produce not dealing in venison (defined as buying and selling).

Section 36 of the Deer Act (Scotland) (not sure if England is any different states
36Offences in connection with venison dealing.
(1)Subject to subsection (2) below, any person who—

(a)sells, offers or exposes for sale; or

(b)has in his possession, transports or causes to be transported for the purpose of sale at any premises,

any venison shall be guilty of an offence.

BUT the important word is "Dealing" and the definition of dealing is the activity of buying and selling. An individual hunter simply selling game they shot themselves in not dealing.

 

[@theroedeerguy]

I wouldn’t tend to agree with the local authority advice.

Broadly speaking in Scotland if you are processing deer from a carcass and then selling the venison, a Venison Dealers Licence is required.

The implementation of the legislation and potential offences is not on the basis of dealing but on the basis of selling venison.

Registering as a Licensed Venison Dealer is a relatively straightforward process especially given the steps you have already taken.

 

[slider]

I wouldn’t tend to agree with the local authority advice.

Broadly speaking in Scotland if you are processing deer from a carcass and then selling the venison, a Venison Dealers Licence is required.

The implementation of the legislation and potential offences is not on the basis of dealing but on the basis of selling venison.

Registering as a Licensed Venison Dealer is a relatively straightforward process especially given the steps you have already taken.

Thanks Ben, but who interpreted that particular implementation of the legislation? Has it been tested in the courts. The Deer Act specifically mentions dealing not selling.

Application for a VDL may not be a big step but is expensive if you only process a few carcasses a year.

I have summit a question on the requirement for a VDL to the Wild Game Guide consultation as it currently is not clear on this alleged requirement.
This is potentially another barrier to shortening the supply chain, although I acknowledge that food safety is paramount

 

[Freeforester]

Thanks Ben, but who interpreted that particular implementation of the legislation? Has it been tested in the courts. The Deer Act specifically mentions dealing not selling.

Application for a VDL may not be a big step but is expensive if you only process a few carcasses a year.

I have summit a question on the requirement for a VDL to the Wild Game Guide consultation as it currently is not clear on this alleged requirement.
This is potentially another barrier to shortening the supply chain, although I acknowledge that food safety is paramount

Presumably then it follows that if you are selling all your own shot stuff and not buying because you aren't a registered venison dealer, then you don't necessarily need to produce records of what you've shot to SNH? Seems like a bit of a potential loophole for unscrupulous trade?

 

[slider]

Presumably then it follows that if you are selling all your own shot stuff and not buying because you aren't a registered venison dealer, then you don't necessarily need to produce records of what you've shot to SNH? Seems like a bit of a potential loophole for unscrupulous trade?

Don't follow the logic not being a registered VDL does not absolve you from food safety and traceability requirements, this is all laid out in the FSA Wild Game Guide? I do produce records for SNH and scrupulously record all shot records, chiller records and can trace everything back to the spot it dropped,

 

[Freeforester]

I agree with all you say, but what I'm saying is that if there is no reason/requirement to be a registered venison dealer, then no venison dealer record book would be issued, which surely leaves a door wide open for the unscrupulous?

 

[VSS]

It all sounds very complicated in Scotland!

 

[slider]

It all sounds very complicated in Scotland!

anything to be different

 

[Freeforester]

It's not really Tim, but if say, someone wanted to process their own and sell to final consumer, but demand began to exceed their own gathered supply, they could theoretically fill the gap by unscrupulous means?

 

[slider]

It's not really Tim, but if say, someone wanted to process their own and sell to final consumer, but demand began to exceed their own gathered supply, they could theoretically fill the gap by unscrupulous means?

but then they would be dealing, so a VDL would be required

 

[slider]

One thing for sure is that it definitely need clarification

 

[Freeforester]

Exactly, but this would rely on the person owning up to buying in carcases - and 'remembering' they are required to register as a VDL - what happens if they 'forget' to do so in the meantime?

 

[VSS]

It's not really Tim, but if say, someone wanted to process their own and sell to final consumer, but demand began to exceed their own gathered supply, they could theoretically fill the gap by unscrupulous means?

Someone will always find a way to do something unscrupulous if it's in their nature to do so!
But even without the venison dealer requirement that you're talking about, we're still required to record all carcasses for traceability, from shot to sale.
Does being a venison dealer allow you to buy in carcasses to make up a shortfall? If so, then it's not so very different except we would need to be registered as an AGHE to do that.

 

[@theroedeerguy]

I am confused where you are getting the “dealing “ from

36 Offences in connection with venison dealing.

(1)Subject to subsection (2) below, any person who—

(a)sells, offers or exposes for sale; or

(b)has in his possession, transports or causes to be transported for the purpose of sale at any premises,

any venison shall be guilty of an offence.


The legislation states in Section 36 (1) (a) specifically mentions “sells” there is no dealing required....... sell venison without a VDL....offence complete.

In terms of guidance I would suggest making contact with your local Wildlife Liaison Officer who will be able to advise, as it will be the police and not the local authority that would report and/or investigate any potential offences to the PF.

From a personal point of view I would not be comfortable selling any venison without having a valid venison dealers license.

 

[slider]

Well the LA EHO regulate the sale of game meat by Registered Food Businesses and I have it in writing that I am a Registered Food Business and am not required to hold a VDL. I am content that that provides me with me with sufficient cover