Game Handling Establishments
Guidance for Hunters and Operators
South Lakeland District Council has researched this issue and
has sought guidance through the Food Standards Agency.
1. If a person is selling game on an
occasional basis (once per week) locally and direct to the final
consumer or to local retail outlets either as game meat or as a
primary product then that person does not have to;
- be registered with the local authority;
- have a food safety management system based upon HACCP
- be a trained hunter;
- comply with the transport provisions of the 852/2004
- comply with the general and specific hygiene provisions of
Regulation EC No. 852/2004.
Compliance with general food law regulation, however, still
applies which makes it an offence to place unsafe food on
the market or to falsely describe that
food. As such it would be expected that hunters maintain a
basic record of what, when, quantities hunted and to whom and when
it was sold, this is particularly important for tracing
outbreaks relating to Tuberculosis (TB).
2. If small quantities of game are
supplied locally and direct on a regular basis i.e. more than once
per week the following apply:
Primary Product: The
hunter does have to be registered with the LA and comply with food
law regulations but does not have to put in place a food safety
management system based upon HACCP principles or comply with the
transport provisions or have to be a trained hunter.
The definition of a primary product is one
that is killed by hunters and is un-skinned and that have only
undergone any necessary gralloching in the field as a part of
normal hunting practice.
Game Meat: The hunter
does have to comply with the general food law regulations, register
with the LA, have a food safety management system in place and
comply with the specific hygiene provisions of EC Regulation No.
The definition of game meat is: edible
parts of the animal beyond primary production (e.g. skinned,
jointed, sliced etc.)
Both for both primary product and game meat, a separate
processing area for skinning and eviscerating carcasses is
The Primary Producer exemption may apply to the supply of
small quantities of in-fur/ carcasses either direct to the final
consumer and/or to local retailers that directly supply the final
The definition of local supply is within
the supplying establishment's own County plus the greater of either
the neighbouring county or counties or 50km/30 miles from the
boundary of the supplying establishment's county.
Direct supply to the final consumer is not
restricted by what is local. An individual or an estate can supply
final consumers who order from them via the internet/mail order as
well as those who collect themselves. Small quantities can also be
supplied to local retailers/caterers.
Members of hunting parties and individual hunters are exempt
from having to develop their premises into an approved
game-handling establishment (AGHE). All game must have been shot by
hunting party members (it cannot be sourced from others) and can be
prepared into meat by any one (or more) of the party.
The Game Act 1931, Game Licences Act 1860 and the Deer Act
1991 form part of a large body of law which controls killing,
taking and dealing in game. Game includes deer. Much of the law is
intended to prevent poaching. However, from 1st August 2007 the
requirements for licences to take kill or deal in game were
repealed by The Regulatory Reform (Game) Order
Although licences are no longer required for these activities,
restrictions on poaching and taking game out of season still apply
and the body that enforces this is DEFRA
. This means that those who
deal in game no longer have to hold a local authority licence or an
excise licence. Restrictions on dealing with game birds and venison
during the close season will no longer apply. This means that
anyone will be allowed to sell game and venison all year round
provided the animals in question were lawfully killed.
Record Keeping and Traceability
There is no longer a requirement to keep records under Section
11 of the Deer Act 1991, relating to the sale and purchase of
venison, BUT records to the level specified in EC Regulation
178/2002 must be kept if you sell game birds or venison. This
requirement applies to the hunter as well as game dealers and
retailers, caterers or wholesalers who sell game birds or venison.
The business must hold records with a level of detail commensurate
with the size and nature of the activities.
Game dealers must check the source before sale, offer or
exposure for sale or possess or transport for purposes for sale.
This is because it would be an offence if they knew or had reason
to believe that the game bird or venison offered for sale was
unlawfully killed, taken or poached during the close season.
The 2007 Regulatory Reform Regulations also remove the
requirement for a licence to kill or take game.