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Considering that that animal by-products from healthy wild animals, having died accidentally or naturally (so not as a consequence of an infectious disease) or through hunting, can not represent a threat to human or animal health, FACE - representing all national hunters’ organisations and some 7.000.000 hunters in Europe – is of the opinion that animal by-products from game, “produced” in direct connection to hunting or game management activities, should not be included in the new “Animal by-products” Regulation. 

Hunting in Europe is further an activity carried out in a natural or even wild environment, often in remote areas. It would therefore be practically unfeasible to apply EU rules to animal by-products from wild animals such as game. Such ABP should best be dealt with (and properly discarded or eliminated) in accordance with “good hunting practice”, both in terms of health requirements and environmental rules.
FACE welcomes therefore the position taken by the Commission in its Proposal, Article 2 “Scope”, stating that “this Regulation shall not apply to […] entire bodies or parts of wild animals […] in the case of wild terrestrial animals, which are not collected after killing, in accordance with good hunting practice” or “animal by-products from wild game and from wild game meat referred to in Article 1(3)(e) of Regulation (EC) No853/2004 [i.e. hunters who supply small quantities of wild game or wild game meat directly to the final consumer or to local retail establishments directly supplying the final consumer]”. Point 13 in the preamble corresponds to this provision. 
This is also in line with the opinion expressed by DG SANCO during the first exchange of views in the AGRI Committee, on the 10th September, namely that the objective behind the Proposal is to clarify existing provisions and make them compatible with other rules, not to create “new” rules. 
FACE, having the required expertise and knowledge, offers to assist the EU institutions in drafting some kind of Guidance document for “good hunting practice”, as a source of reference at Community level. 

Brussels, 28.11.2008
Dr. Yves LECOCQ, Secretary-General / Senior Policy Advisor