Managing Deer for Climate and Nature: Analysis of consultation responses

7 Venison (Q24–Q26)

7.1 Part 5 of the consultation paper set out proposals for responding to recommendations from the DWG report concerning the regulation of venison. It was suggested that venison should be regulated in the same way as other wild meat and game, with the specific requirement for a Venison Dealers Licence (VDL) discontinued, and that NatureScot should be able to gather more information from venison dealers on how deer carcasses are used. The consultation asked three questions on this issue.

Question 24: Do you agree that venison specific regulations should be repealed and venison should simply follow the same regulatory procedure as other wild meat and game products without the additional requirement of a Venison Dealers Licence? [Yes | No | Don’t know]

Question 25: If no, do you agree that NatureScot should be able to gather more information from venison dealers on deer carcasses and their use? [Yes | No | Don’t know]

Question 26: Please provide any further comments on the questions in this section here.

Regulatory procedures for venison (Q24)

7.2 Question 24 asked whether respondents agreed that venison should follow the same regulatory procedures as other wild meat and game products.

7.3 Table 7.1 shows that, overall, 75% of respondents agreed, 15% disagreed, and 10% said ‘don’t know’. Individuals were more likely than organisations to agree (76% versus 62%). Most conservation and animal welfare organisations (87%) agreed. However, other organisational respondents were divided in their views. Among land management, deer and sporting organisations, 50% agreed and 46% disagreed. Among organisations in the ‘other organisation types’ category, 47% agreed, 27% disagreed and 27% said ‘don’t know’.

Percentages may not total 100% due to rounding

A more detailed breakdown of responses by organisation type is shown in Annex 3, Table A3.22.

Information provided by venison dealers (Q25)

7.4 Question 25 was aimed at those who had answered ‘no’ at Question 24. It asked whether (in the context of a continuing VDL system) NatureScot should be able to gather more information from venison dealers on deer carcasses and their use. (Note that 241 respondents answered ‘no’ at Question 24, all but two of whom answered Question 25.)

7.5 Table 7.2 shows that, overall, 75% of the respondents who answered this question agreed and 23% disagreed. The remaining 2% said ‘don’t know’. Organisations were more likely than individuals to agree (93% versus 73%). There was general agreement with this proposal among all organisational groups.

This table includes only those respondents who answered ‘no’ at Question 24.

Percentages may not total 100% due to rounding.

A more detailed breakdown of responses by organisation type is shown in Annex 3 – Tables A3.23 (all respondents) and A3.24 (respondents who answered ‘no’ at Question 24).

Comments on the proposals related to venison (Q26)

7.6 Question 26 asked respondents for any comments they had in relation to the proposals on venison. Altogether, 347 respondents – 62 organisations and 285 individuals – provided comments.

7.7 The sections below present views on the two issues addressed in the closed questions in Part 5 of the consultation: (i) regulation and the proposal to remove the requirement for a VDL and (ii) information gathering. A third section presents views on the venison market – a key theme in respondents’ comments. A final section covers any other comments.

7.8 It should be noted that, irrespective of how respondents answered the closed questions, there was a general consensus that traceability and high standards were crucial to the venison market.

Regulation and the proposal to move away from venison specific regulation

7.9 As shown in Table 7.1, most respondents agreed with the proposal to move away from venison specific regulation, although land management, deer and sporting organisations and those in the ‘other organisation types’ category offered more of a mix of views on this issue.

7.10 Those who agreed with the proposal highlighted both shortcomings with the current system and anticipated benefits of the proposed system based on other existing food standard regulations. They said that:

• There was a lack of consistency in the way the VDL system was administered by local authorities and that the information provided by the system did not give an accurate picture of venison dealing across the country.
• Existing food standard regulations (along with deer traceability requirements) were sufficient and that additional measures were not required for venison in particular – some respondents (including individuals) noted the importance of enforcement of regulations and tough penalties for failure to meet requirements.
• Removing the need for a VDL would reduce the financial and administrative burden on venison dealers, and help open up the venison market, particularly at local level.
• A regulatory shift in emphasis from dealers who buy venison to those who sell venison would help improve data on deer culling.

7.11 Additionally, individuals in particular stressed that hunters had the knowledge and expertise to ensure that a carcass was safe for consumption and/or suggested that this could be assured via deer stalker training and/or registration. It was also pointed out that Scotland was the only part of the UK to operate a separate licensing system for venison.

7.12 Those who disagreed with the proposal emphasised the importance of food safety and protecting the food chain. They thought that licensing was an important measure in ensuring good practice and maintaining consumer confidence, given the particular risks associated with wild venison, and were keen that this requirement was not removed without robust alternative arrangements being in place. Food sector organisations were among those giving such views.

7.13 Additionally, there was some concern expressed that not all hunters would comply with a system relying on more generic food safety regulations, and that such a system might be more easily exploited by poachers.

7.14 However, respondents in this group often also acknowledged that the VDL system was ‘far from perfect’, with some saying it had ‘broken down’. Respondents referred to inconsistencies and varying levels of uptake across different local authority areas, as well as funding issues. There were calls for the current regulatory system to be modernised and streamlined by tightening the current local authority-led system and/or by introducing a digital app-based data system for gathering data from deer managers and stalkers. This would improve cull data and traceability – it was noted by some respondents that NatureScot was already pursuing the development of such a system. The issue of improved data is discussed further below (see paragraphs 7.16 to 7.21).

7.15 Among those who neither agreed nor disagreed with the proposal, one respondent in the ‘other organisational type’ category sought clarity on the interaction between current food hygiene regulations and traceability arrangements for wild venison, and between requirements for wild and farmed venison.

Information gathering on venison

7.16 Information gathering and data quality were issues of concern for a range of respondents, irrespective of their views on the overall regime for regulating venison.

7.17 As shown in Table 7.2, most respondents who did not agree with the repeal of venison specific regulation as proposed at Question 24 said they supported gathering additional information from venison dealers. These respondents (both organisations and individuals) stressed the need for good quality data to support traceability and food hygiene standards and safety, and to better understand the venison market in Scotland. Respondents highlighted the need for improved information from deer managers and deer stalkers, as well as from venison dealers.

7.18 Some respondents (including land management organisations and deer groups) specifically noted support for amending Section 34 of the Deer (Scotland) Act 1996 to empower authorities to require venison dealers to submit throughput summaries. However, others stated a more general wish to see the introduction of a national-level digital system for gathering information about the disposal and use of deer carcasses. Respondents said that any system:

• Should cover all stalkers and producers, including those operating at small-scale or ‘vocational’ levels in all areas of the country
• Should be easy to use for deer managers and stalkers inputting data as well as those administering the system and interrogating the data
• Could be linked up with existing agricultural and Police administrative systems.

7.19 Those who supported the repeal of venison specific regulations made similar points about the importance of good information and the potential for introducing a digital data collection system.

7.20 Those respondents who did not think that more information should be gathered from venison dealers generally thought that sufficient information was already collected. Individuals characterised further data collection as ‘unnecessary bureaucracy’ and intrusive.

7.21 In addition to the views presented above, some respondents (irrespective of how they answered the closed questions in this section) expressed concern about how additional information would be used and NatureScot’s capability or capacity to gather and use additional data, or they said NatureScot should pay for any information gathered.

The venison market

7.22 A common theme in the comments from respondents on Part 5 of the consultation was the need to support and stimulate the venison market. There was a broad view that the market for venison was integral to the success of the proposed package of reforms to deer management, and that not addressing this issue was a shortcoming of the current consultation.

7.23 Respondents said that without a successful venison market there was no end-use for an increased number of culled deer, and no incentive for deer managers, landowners and stalkers to cull deer; others argued slightly differently that there should be no culling unless there was an end-use for the carcass. Respondents noted the need to increase capacity in the venison processing system to cope with any increased throughput of carcasses; they also noted the need to stimulate demand for venison products at national level and support the availability and consumption of affordable venison at a local level.

7.24 There was a great deal of consensus among respondents about the type of action they thought was required to address this issue. Respondents commonly called for:

• A government-led strategy to promote wild venison as a healthy, ethical, locally sourced, low-carbon food – respondents suggested the establishment of a venison marketing board and collaborative work with retailers and advertisers
• Greater use of venison across the public sector – in schools, hospitals, prisons, etc.
• Action to facilitate the use of venison in the pet food market
• Funding (grants and/or subsidies) for infrastructure (e.g. local venison larders and storage facilities on ferries) and business development activities to support the venison industry – respondents thought this was particularly important in supporting small-scale local venison production by individual stalkers and those operating in more remote areas and lowland areas where the deer sector was less developed
• Funding for training and apprenticeships for those working in the venison industry.

7.25 Respondents drew attention to already established successful schemes (e.g. the introduction of community larders) in some areas which could be replicated elsewhere.

7.26 Some respondents saw such measures as not only good for the venison market but good also for local areas and economies – some characterised this as being part of a ‘just transition’ for the deer sector and rural communities affected by changes in the approach to deer management.

7.27 Less often, respondents mentioned (i) subsidies to allow venison to be sold at an economic price while also giving stalkers and processers an acceptable financial return, and (ii) bans on venison imports and farmed venison.

7.28 Respondents (individuals in particular) also called for a ban on the use of lead ammunition in deer hunting (for deer intended for human consumption) as this was seen as an important factor in improving food safety and consumer confidence in venison products.

7.29 Less commonly, and in contrast to the views above, some respondents (mainly individuals) expressed opposition to the consumption of venison, and the culling of deer more generally.