Managing deer for climate and nature: consultation

Theme 5: Venison

Overview

The proposals in this theme seek to address issues with the licensing of venison dealers and the barriers faced by venison processors by taking forward the following recommendations from the DWG:

Recommendation 19: The Licensing of Venison Dealers (Prescribed Forms etc.) (Scotland) Order 1984 should be replaced by a new Order that requires clearer and more robust information about the source of any purchases or receipts of wild venison.

Scottish Government Response: The Scottish Government accepts this recommendation in principle.

Rationale: The Scottish Government considered the DWG’s rationale alongside recent research published by Food Standards Scotland who previously recognised gaps in understanding of food related illnesses which can apply to wild deer. We recognise that the original intention of this legislation was to control poaching of wild deer. However, we are supportive of actions which will ensure increased transparency and a better understanding of venison origins.

Recommendation 20: Section 34 of the Deer (Scotland) Act 1996 should be amended to empower those with the authority under that section, to require a licensed venison dealer to submit a return summarising their throughput of wild deer carcasses during a period not exceeding three years and in a form to be described.

Scottish Government Response: The Scottish Government accepts this recommendation in principle.

Rationale: The Scottish Government believes that existing food hygiene regulations, in combination with the proposed changes to the licensing of venison dealers ensures good levels of traceability. However, including additional powers to gather further information could further improve this and allow for a better understanding of the venison market.

Recommendation 21: Scottish Government should review sections 33-36 of the Deer (Scotland) Act 1996 that cover the licensing of dealing in venison, with a view to making changes in addition to the related recommendations in this Report, so that the arrangements are fit for purpose in contemporary circumstances.

Scottish Government Response: The Scottish Government accepts this recommendation in principle.

Rationale: As outlined above, we accept the rationale behind these recommendations but the complex nature of the legislation requires further discussion with stakeholders before legislative changes are made.

Background

Over 117,000 wild deer are reported culled in Scotland annually producing around 3,500 tonnes of venison. Venison provides an income from the overall management of wild deer in Scotland. However, as outlined by the DWG, we do not currently collate data on the total number of deer which go to venison dealers.

The DWG commented that:

“There is, however, no information available on the number of wild deer carcases processed each year by venison dealers and, as discussed further below, NatureScot experienced difficulty in trying to obtain this throughput data from some of the main dealers. The most recent information on throughput is therefore from 2009.”

‘Venison Dealers Licence (VDL)’ means the licence required by the 1996 Act for the sale, offer or exposure for sale of venison meat. This licence is not required where venison is sold to or bought from the holder of a VDL, meaning only one party in the transaction must possess a VDL. VDLs are issued by local authorities.

The DWG also recommended that -

“The Licensing of Venison Dealers (Prescribed Forms etc.) (Scotland) Order 1984 should be replaced by a new Order that requires clearer and more robust information on the prescribed form about the source of any purchases or receipts of wild venison.”

Since the publication of our response to the DWG report we have given consideration to the recommendations made by the DWG with regard to venison, and with the existing regulations under both food standards legislation and venison specific legislation. Venison, like any other meat which enters the food chain, is regulated by Food Standards Scotland.

The DWG recommends amending legislation to enable the gathering of more information on wild venison, including the use of deer carcases and requiring venison dealers to provide up to three years of data. However, we have been considering the need for Venison Dealers Licences more generally. Venison is regulated by Food Standards Scotland in the same way as other wild meat and game products, which means it must meet acceptable standards of food safety.

We want to ensure that as we increase deer management in Scotland, we are maximising the benefits wild venison can bring through. That means that the venison market has a key role to play in underpinning the annual cull of deer required in Scotland each year, and that we want to ensure the process for. However, we are aware that in some circumstances the requirement for a VDL may act as a barrier for existing wild meat and game handlers. So although the Deer Working Group recommendations were around increasing information about venison through the Venison Dealers Licence, NatureScot have proposed that consideration should be given to removing the requirement for a VDL altogether.

Scottish Government Proposals

We are therefore proposing an amendment which would remove the requirement for Venison Dealers Licences. This would mean that venison would be regulated in the same way as those other products.

We think this would make the processing of venison more accessible for smaller, local establishments, including those that are processing other wild meat and game products at the moment but have not sought an additional venison dealers licence. This would support more venison products making their way into the food chain.

In doing so we would not proceed with recommendations 19 to 21 set out by the DWG in relation to the information which could be gathered in relation to venison and the proposed review into Venison Dealers Licensing by Food Standards Scotland.

We would like your views on the existing Venison Dealers Licence, and whether you support our proposal to remove the requirement for a VDL and allow venison to be regulated in the same manner as other wild meat and game or if you support the DWG recommendations to amend the existing VDL scheme.

Consultation Questions

Question: 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?

Answer options:

• Yes
• No
• Don’t know

Question: If no, do you agree that NatureScot should be able to gather more information from venison dealers on deer carcases and their use? For example, this could be used to help understand if there are areas of Scotland where there are insufficient facilities for processing venison or if there are other barriers.

Answer options:

• Yes
• No
• Don’t know

Free text box: Please provide any further comments on the questions in this section here.