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Jurisdictions Surveyed: Angola | Argentina | Botswana | Bulgaria | Cambodia | China | Democratic Republic of the Congo | Côte d’Ivoire | Egypt | Gabon | Georgia | Ghana | Greenland | Guyana | India | Indonesia | Kazakhstan | Liberia | Nepal | Pakistan | Russia | Thailand | Turkey | Vietnam
Appendix: Mexico | Saudi Arabia | United Arab Emirates | United Kingdom
There do not appear to be any wet markets that sell live wild animals and slaughter them on site across the United Kingdom (UK). However, wild game meat may be lawfully sold across the UK through Approved Game Handling Establishments or privately, and this market is regulated through a combination of retained European Union (EU) law and the Food Safety Act 1990. These laws require compliance with general hygiene, consumer protection, and traceability provisions that are designed to ensure the safety of wild game meat for the final consumer.
There do not appear to be any wet markets that sell live wild animals and slaughter them on site across the UK. While the UK left the European Union (EU) on January 31, 2020, it created a new body of domestic law, known as retained EU law, transposing all EU law that applied to the UK immediately before its exit. Wild game may lawfully be sold by retailers and hunters in the UK under these laws and the Food Safety Act 1990.
II. Laws Regulating the Sale of Wild Game Meat
Wild game is defined as
wild ungulates and lagomorphs, as well as other land mammals that are hunted for human consumption and are considered to be wild under the applicable law in the Member State concerned. These include mammals living in enclosed territory under conditions of freedom similar to those of wild game . . . and wild birds that are hunted for human consumption.
Thus, the legislation extends to hooved animals such as wild deer and wild boar, rabbits, squirrels, and wild birds. Hunters or those who organize the shooting of wild game are considered to be primary producers under EU food hygiene regulations.
To ensure wild game that will be consumed by humans remains free of disease at least one person in a hunting party, or a hunter of wild game, must be a “trained person” and “have sufficient knowledge of the pathology of wild game, and of the production and handling of wild game and wild game meat after hunting, to undertake an initial examination of wild game on the spot.” A trained person must have received training in the anatomy, physiology, and behavior of wild game along with abnormal behavior and pathological changes in wild game caused by diseases, environmental contamination, and any other factors that could impact human health after eating wild game; hygiene rules and techniques to handle, transport, and field-dress wild game; and the laws relating to the sale of wild game.
For large wild game, the trained person must include a numbered declaration that indicates the date, time, and location of the killing and includes a statement that no abnormal characteristics were found during the examination of the animal and viscera and that no abnormal behavior was observed prior to killing the animal. This declaration must remain with the wild game until the animal is processed at the Approved Game Handling Establishment (AGHE). In cases where abnormal behavior or abnormal characteristics have been detected in small wild game, the trained person must inform the Official Veterinarian at the AGHE.
In England, training from the National Gamekeepers’ Organisation is sufficient to meet the requirements of Regulation 853/2004. In Scotland, the Scottish Gamekeepers Association or British Association for Shooting and Conversation provide training. A nationally recognized vocational qualification in Wild Game Meat Hygiene that meets these requirements has been introduced and is being offered across the UK, and the skills required have also been introduced within Deer Stalking Certificate level 1.
A. Hunters Supplying Small Quantities of Wild Game Directly to Consumers or Retailers
Hunters who shoot, process and supply small quantities of “in fur” or “in feather” wild game either directly to the final consumer, or to local retailers within 30 miles of the hunter’s county boundaries who then supply the wild game carcasses in fur or in feather directly to the final consumer, are exempt from the EU Food Hygiene Regulations.
While hunters operating in this manner are not covered by the aforementioned Regulations, they are considered to operate a food business and must register as such with the local authority. These hunters must meet the traceability requirements contained in EU Regulation 178/2002. A “one step forward one step back” approach has been adopted and means the food business operator must have information about their immediate supplier and immediate customer, unless the immediate customer is the final consumer. This means hunters and retailers must provide an accurate description, including the quantity of wild game and date of dispatch of the wild game, the name and address of the person sending and receiving the wild game, and a reference number that enables the identification of the wild game. The information “must be kept and be retrievable for at least until it can be reasonably assumed that the food has been consumed.”
Hunters operating as such a food business must also comply with general hygiene requirements contained in Regulation 852/2004. This Regulation specifies the way primary products are to be stored and transported, and how meat should be prepared from the primary products. More specifically, individuals who handle wild game and game meat must be in good health and trained about the health risks of wild game.
The provisions of the Food Safety Act 1990 must also be complied with. The provisions in this Act set out basic food safety standards, prohibit individuals from placing unsafe food on the market or falsely describing food, and provide for the inspection and seizure of any food that is suspected of being unsafe. It also sets forth consumer protections and the requirement for individuals to register as food business with the local authority.
Regulations further provide that operators of game larders must ensure that the larder has sufficient capacity to hygienically handle wild game; that only potable water is used; that the larder is ventilated, protected from pests and contamination from pests and animals, and kept clean and disinfected appropriately when necessary; and that steps are taken to prevent the introduction and spread of any contagious diseases that can be transmitted to humans through food. Any cases of suspected diseases should be reported to the competent authority. Any waste and hazardous substances on the premises should be handled appropriately to prevent the contamination of the wild game.
Individuals involved in processing wild game must have a food safety management procedure in place based on Hazard Analysis and Critical Control Point (HACCP) principles to prevent, eliminate, or reduce the safety hazards and meet food traceability requirements. Records must be kept to demonstrate that these procedures have been established and are being followed.
B. Hunters Obtaining Wild Game from Shoots and Supplying It to Retailers
Hunters who obtain in fur or in feather wild game from shoots that they do not participate in and who supply these to retailers, even in small quantities, must register as food businesses with the local authority and are subject to the hygiene requirements of Regulation 853/2004. As a result, any wild game obtained in this manner cannot be directly supplied to the public or to local retailers and may only be provided to an AGHE. To sell wild game to an AGHE, these individuals must comply with
- the traceability requirements of Regulation 178/2002,
- general food business operators’ obligations under Regulation 852/2004, and
- wild game handling requirements to supply to an AGHE under Regulation 853/2004.
The hunter must also ensure that a declaration from a trained person accompanies the bodies of large wild game to the AGHE. In order to prevent confusion over game hunted for personal use and game purchased from elsewhere for the supply of others, the Food Standards Agency recommends that this game be clearly identified and kept separately from any game the individual has personally hunted.
It is an offense for a person to consign wild game purchased through this process directly to a retailer. If this occurs, both the middleman and the buyer may be prosecuted for the transaction.
C. Hunters Supplying Wild Game to Approved Game Handling Establishments
Hunters who supply in fur and in feather game, or individuals who collect and transport this wild game to a middleman or to an AGHE must register with the local authority as a food business and comply with the hygiene requirements for primary producers.
An AGHE may only place large wild game meat on the market if the body was transported to it as soon as a trained person examined the body. In cases where a trained person was unavailable to inspect large wild game, the AGHE may accept the body if the head and viscera are labelled and remain with the body of the large wild game. The diaphragm of wild boars must always remain with the body to provide suitable samples for testing for trichinella.
Large wild game must be cooled and maintained to a temperate of 7 degrees Celsius or below and small wild game to 4 degrees Celsius or below within a reasonable time after the wild game has been killed. To achieve these temperatures the Food Standards agency recommends that game larders have an efficient chiller installed and has stated that the chiller should never be overfilled, or skinned and unskinned wild game carcasses should be separated from one another, even if the carcasses are wrapped in plastic.
D. Businesses Processing and Supplying Wild Game Meat to Wholesale or Retail Customers
Businesses that purchase in fur and/or in feather wild game and process and supply unlimited quantities of this meat directly to retail or wholesale customers are considered to be food business operators and must be approved as an AGHE by the Food Standards Agency in England and Wales, Food Standards Scotland if located in Scotland, or the Department of Agriculture and Rural Development in Northern Ireland.
An AGHE must comply with traceability requirements, as discussed above, have a food safety management procedure based on the principles of HACCP in place, meet the hygiene requirements, and comply with official veterinary controls. It is an offense for persons to process wild game if they are not exempt from the requirements of the Regulations or are not an approved AGHE.
E. Hunters Supplying Wild Game for Private Domestic Consumption
Those who hunt wild game for private domestic consumption, or to provide to family and friends, are considered primary producers for domestic use and, provided the wild game is not sold or supplied to any other person as part of a food business, are not considered to be a food business operator. Thus, these individuals are exempt from the requirements of the Regulations.
F. Individuals Collecting and Transporting Wild Game
Individuals responsible for collecting and transporting in fur and/or in feather wild game carcasses to an AGHE must
- register with their local authority as a food business,
- comply with the traceability provisions of Regulation 178/2002,
- comply with the general hygiene provisions under Regulation 852/2004 relating to primary producers, and
- comply with the provisions of Regulation 853/2004 that apply to the handling of wild game supplied to an AGHE.
To prevent contamination of the wild game, the person transporting it must take measures to prevent contamination from other animals and pests, and keep any vehicles used for the transport of wild game clean and disinfected where necessary. The bodies of wild game must not be stacked on top of one another and the wild game must be chilled as soon as possible after it is killed and transported to an AGHE in a chilled vehicle.
In cases where the bodies of large wild game will be sold to an AGHE, a trained person must be present when the game is shot to examine the body of the game. This person must then complete documentation that must remain with the bodies of the large wild game transported to the AGHE. Any wild game bodies must be transported as soon as possible after they have been examined by a trained person, and a declaration from the trained person must accompany any large wild game body.
Unskinned bodies of large wild game animals may be consigned to other EU Members States but a certification by an official veterinarian along with the declaration from a trained person is required.
G. Farmed Game
There are instances in the UK where game is farmed, such as deer or boar. The law provides that “[a]ll meat from farmed game placed on the market must be produced in approved slaughterhouses.”
The laws are enforced by the Department of Agriculture and Rural Development in Northern Ireland, Food Standards Scotland in Scotland, and local authorities in England and Wales.
Prepared by Clare Feikert-Ahalt
Senior Foreign Law Specialist
 The following retained EU law as in force on the day the UK exited the EU (October 31, 2019) applies to the sale of wild game meat: Regulation (EC) No. 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin, https://perma.cc/E9K4-E267; Regulation (EC) No. 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs, https://perma.cc/C5Y6-VKCE; Regulation (EC) No. 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety, https://perma.cc/QT9D-9PAS; Commission Implementing Regulation (EU) No. 931/2011 of 19 September 2011 on the traceability requirements set by Regulation (EC) No. 178/2002 of the European Parliament and of the Council for food of animal origin, https://perma.cc/WSL9-VA24.
 Regulation (EC) No. 853/2004, Annex I, ¶ 1.5.
 Regulation 853/2004, § IV, ch. 1, art. 1.
 Id. § IV, ch. 1, art. 4.
 Id. An AGHE is defined in Annex II, ¶ 1.18 of this Regulation as “any establishment in which game and game meat obtained after hunting are prepared for placing on the market.”
 Id. ¶ 74.
 “In fur or in-feather game that has undergone no more than any necessary preparation that is part of normal hunting practice. Such preparation is usually the evisceration of large wild game animals, which is carried out either ‘in the field’ or in a game larder.” Id. ¶ 15, https://perma.cc/887W-XG65.
 Regulation 178/2002, art. 3(18) defines the final consumer as “the ultimate consumer of a foodstuff who will not use the food as part of any food business operation or activity.”
 Regulation 853/2004 art. 1(3)(c) &(e).
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 43.
 Commission Implementing Regulation (EU) No. 931/2011 of 19 September 2011 on the traceability requirements set by Regulation 178/2002 of the European Parliament and of the Council for food of animal origin, https://perma.cc/WSL9-VA24.
 Regulation 178/2002, art. 18; Commission Implementing Regulation 931/2011.
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 46.
 Id. art. 4.
 Id. ch. 1, arts. 1 & 5; Regulation 178/2002, ch. 2, arts. 6 & 18.
 Id. Regulation 852/2004, ch. 1, arts. 1 & 5.
 Regulation 853/2004, § IV, ch. 1, art. 4.
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 44.
 Id. ¶ 19.
 Regulation 853/2004, § IV, ch. II, art. 3.
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 37.
 Id. ¶ 39.
 Id. ¶ 14.
 Regulation 852/2004 ch. I. See also Food Standards Agency and Food Standards Scotland, supra note 7, ¶¶ 71-72.
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 22.
 Regulation 854/2004, § IV, ch. II, art. 6.
 Food Standards Agency and Food Standards Scotland, supra note 7, ¶ 7.
Last Updated: 12/31/2020