Scottish Government

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Dear Sir/Madam

BSE: LIFTING THE EXPORT BAN AND HARMONISING UKSRM CONTROLS WITH THOSE IN OTHER MEMBER STATES

Purpose

The purpose of this letter is to invite your views on potential changes to UK legislation to:

• Give effect to the possible lifting of the EU ban on the export of live bovines and bovine products from the UK; and
• implement consequential changes to the rules for the removal of bovine vertebral column ( VC) and other controls on bovine Specified Risk Materials ( SRM).

Background

The export from the UK of live bovine animals and their products was banned by the European Union in March 1996 due to fears about the risk to human health from BSE in cattle. Since then the incidence of BSE in UK cattle has declined markedly and is now below the internationally agreed threshold for moderate BSE risk status. The food borne risk to human health is also reduced in line with the reduction in BSE cases. In addition, on 28 September the European Commission's Food and Veterinary Office published a satisfactory report on UKBSE controls. This means that the UK has met the two conditions set by the Commission for beginning discussions with Member States on lifting the export ban.

Subject to a positive outcome to those discussions, we expect the Commission to make a proposal to lift the ban in relation to live cattle born after July 1996 and products derived from them. Please note that cattle born before August 1996 - i.e. before the UK ban on feeding mammalian meat and bone meal to all farm livestock was fully enforced - will remain permanently excluded from the food and feed chain. From the time that the export ban was applied, it has been UK Government policy to seek its removal for products permitted for sale on our domestic market. If EU legislation to lift the export ban is adopted, we will need to amend our legislation, the Bovines and Bovine Products (Trade) Regulations 1999 and related controls, to bring UK law into line with EU law.

Timetable and Proposed Changes

At this stage we cannot be sure when or whether EU Member States and the Commission will agree to lift the export ban, nonetheless the purpose of this letter is to begin a formal consultation on the amendments to UK export controls which would be needed to allow the export of live cattle born after July 1996 and beef and bovine products derived from them. At the same time, the current Date-based Export Scheme ( DBES) for UK beef, and the export approved scheme ( XAP Scheme) for beef of foreign origin, would come to an end. The UK would apply all the provisions of EU law relevant to normal trade between Member States, including the rules to protect the welfare of cattle during transport.

As the UK will have attained the same moderate BSE risk status as other Member States we expect that the Commission will also propose bringing UK controls on SRM into line with those applicable in other Member States. In particular, the Standing Committee for the Food Chain and Animal Health agreed on 5 October a change to EU rules to require the removal of bovine vertebral column ( VC) from animals aged over 24 months at slaughter, rather than at 12 months as has been the requirement to date. Whilst the UK currently has a derogation to classify VC as SRM only in animals over 30 months of age, we anticipate that the 24 months limit would apply to the UK should the export ban be lifted. This would mean that the age for VC removal in the UK would change from 30 months to 24 months. This change would, of course, also apply to animals and carcases imported into the UK from other Member States. This letter also opens a formal consultation on the implementation of this potential change by an amendment to the TSE (Scotland) Regulations.

The application of the 24 month age limit in the UK would ensure the harmonisation of controls across the EU, rather than a response to any perceived increase in the level of risk. EU legislation requires that VC, deemed to be SRM, be removed in licensed cutting plants but allows Member States who wish to do so to permit the removal of VC in butcher shops "specifically authorised, monitored and registered for this purpose". Currently the Food Standards Agency ( FSA) requires removal at cutting plants to enable a more robust system of enforcement by the MHS. At present this system affects only a small number of grass reared Beef Assurance Scheme ( BAS) animals that are over thirty months at slaughter, and a larger number of imported animals and carcases slaughtered at over 12 months of age. With the expected introduction of the over thirty months testing regime in early November this system relating to VC removal will be applicable to those over thirty months animals that are allowed into the food chain after testing. The consequence of coming into line with a 24 month age limit, should beef export controls be lifted, is that a new sector of the UK cattle population, i.e. those 24-30 months of age, will require VC removal as SRM.

Some 50% of UK cattle are slaughtered before they are aged over 24 months, smaller abattoirs without a linked cutting plant or with only a small cutting plant and butchers will, therefore, have continued unrestricted access to a significant supply of UK cattle. However, the FSA recognise that a requirement to remove VC from 24 - 30 months animals in cutting plants could have an adverse impact on those who produce extensively reared cattle, particularly from traditional breeds, and on small abattoirs as well as craft butchers. The FSA is therefore exploring whether it should take up the derogation to remove VC from this age group of animals in butchers' shops. As a contribution to this debate the FSA would welcome detailed comments providing the comparative costs and benefits of removal of VC as SRM at cutting plants only or at a combination of butchers' shops and cutting plants. It is probable that if butchers' shops were allowed to remove VC from 24 - 30 month animals the authorisation, inspection and enforcement regime would be the responsibility of local authorities. In line with procedures at slaughterhouses and cutting plants, once the SRM is removed, butchers will be required to stain it and arrange for its collection and disposal as a category 1 animal by-product.

Harmonisation with other Member States would also involve a number of other changes to UK bovine SRM controls. These are set out in Annex to this letter. Therefore this letter also opens the formal consultation required by law on the implementation of these changes to SRM controls by amendments to the TSE (Scotland) Regulations.

We would also welcome your comments on the potential benefits and drawbacks of the other probable SRM changes set out in the Annex to this letter. In particular your views are sought on the harvesting of head meat and whether removal should be confined to slaughterhouses or the potential derogation to also allow its removal in cutting plants should be applied. At present the FSA is minded to allow removal only in slaughterhouses to avoid the risks associated with transportation of heads containing SRM and the stringent regulation of the process that would necessarily be required.

Also enclosed is a draft Regulatory Impact Assessment ( RIA) which addresses the potential changes described above. This RIA is still at an early stage of development and any comments you may have, particularly with regard to costs and benefits, especially in relation to options for dealing with SRM controls, would be very welcome.

Consultation Responses

Any change to EU law will be applicable in the UK as soon as it comes into force and this could be as early as the beginning of next year. With apologies for the short dead line, please provide comments on the expected lifting of the export ban on live bovine and bovine products, on anticipated amended controls on VC and other probable SRM changes, if at all possible by 12 December 2005. Although the consultation period will not end until 3 January 2006 the sooner responses are received the more time we will have to analyse all the points being made.

If you wish to make comments on this proposed change, then please submit them together with the attached permissions form to my colleague Bob Sutherland at the above address. Your response cannot be made public until the respondee information form is returned to us and we are obligated to write again to those who do not complete it.

As with other consultations, the Executive intends to make comments received available at the end of the consultation period. It is assumed, therefore, that your reply can be made publicly available unless you indicate clearly that you wish part or all of it to be excluded from this arrangement. For those wishing to obtain copies of comments, an administrative charge to cover copying and postage will be made. To enable requests to be dealt with efficiently and to avoid delay for those calling at the Library in person, it would be appreciated if personal callers could given the Library at least 24 hours notice of their requirements (see the attached forms for details).

Yours sincerely

Martin Morgan
Beef Exports, BSE & Animal Waste Branch

Annex

OTHER PROBABLE CHANGES TO UK BOVINE SRM CONTROLS

• The entire head will no longer be SRM from 6 months of age. Instead skull, excluding the mandible but including the brain and eyes will be SRM from 12 months of age.
• This means it will once again be possible to harvest head meat from animals over 12 months of age. The Community Regulations require that head meat be removed in the slaughterhouse. However by way of derogation Member States my decide to allow removal of head meat in specifically authorised cutting plants. Both slaughterhouses and cutting plants must harvest in accordance with the strict conditions laid down in Annex XI Paras 7 and 10 (c) of the Community TSE Regulation. EC 999/2001 (as amended). (A copy is available at the following web address; http://europa.eu.int/eur-lex/en/consleg/index.1.html and enter the Regulation number.) If you would like a printed copy please get in touch with FSA at the address given in the cover letter.
• Spinal cord will be SRM in animals over 12 months of age (currently SRM in animals over 6 months)
• Trigeminal ganglia, thymus and spleen will no longer be classified as SRM.
• Tonsils, intestine from the duodenum to the rectum, and the mesentary will remain SRM in animals of ALL ages

PARTIAL REGULATORY IMPACT ASSESSMENT

1. Title of proposal

BSE: lifting the export ban and harmonising Specified Risk Material ( SRM) controls applicable in the UK with those in other EU member states.

2. Purpose and intended effect

• Objective

Legislative action to:

• • enable the resumption of exports of beef and live bovines born after July 1996 by repealing the Bovines and Bovine Products (Trade) Regulations 1999 ( SI 1999/1103); and
  • harmonise controls on Specified Risk Materials (including vertebral column and head meat) with the EU requirements that apply in other EU member states by amending the TSE (Scotland) Regulations 2002.
• Background

BSE was first identified in the UK in 1986. More than 183,000 cases have been confirmed in the UK to date, of which more than 95% were detected before 2000. In March 1996 the EU imposed a comprehensive, worldwide ban on the export of bovine and bovine products from the UK due to fears about the risks to human health posed by BSE. The GB legislation which currently implements the EU ban is the Bovines and Bovine Products (Trade) Regulations 1999 (S.I. No. 1103). This legislation applies to live cattle, beef, beef products, bovine by-products and mammalian meat and bone meal. Parallel legislation implements the ban in Northern Ireland.

Following the decline in the BSE epidemic in the UK and a positive assessment of our BSE related control measures by the Commission's Food and Veterinary Office inspectors, we hope that the Commission will present proposals to lift the EU ban. On a best case scenario such proposals would be approved by the Standing Committee for the Food Chain and Animal Health ( SCoFCAH) in December. The proposals would need to be translated into all EU languages and presented to the College of Commissioners for adoption. We estimate that this process could be completed early in 2006, possibly in February. However, the timing is dependent on the Commission and the views of other EU member states and we cannot be sure when or whether the ban will be lifted.

Some member states including France and Germany have domestic legislation which bans UK exports and the need to amend it could delay their ability to accept our exports. UK officials are investigating which countries have such national legislation.

When the ban is lifted, and thus the UK's move from high BSE risk status to moderate risk status is formally recognized, the UK will need to comply with SRM controls applicable in other Member States. Whilst the UK currently has a derogation to classify vertebral column as SRM only in cattle aged over 30 months at slaughter, we anticipate that the new EU limit of 24 months would apply from the time the ban is lifted. The current EU limit is 12 months but Member States agreed on 5 October that it should be increased to 24 months.

Harmonisation with other Member States would involve a number of other changes to UK bovine SRM controls as follows:

• The entire head would no longer be SRM from 6 months of age. Instead skull, excluding the mandible but including the brain and eyes would be SRM from 12 months of age.
• Spinal cord would be SRM in animals over 12 months of age (currently SRM in animals over 6 months)
• Trigeminal ganglia, thymus and spleen would no longer be classified as SRM.

EU legislation requires Member States to remove vertebral column in licensed cutting plants but includes a derogation permitting them to allow removal of vertebral column at specifically authorised, monitored and registered butcher's shops. Similarly, EU legislation requires removal of head meat at slaughterhouses but permits member states to allow removal at specifically authorised licensed cutting plants.

• Rationale for Government intervention

From the time that the export ban was applied, it has been Government policy to seek its removal for products permitted for sale on our domestic market. However, the Government has agreed that cattle born before August 1996 should remain permanently excluded from the food and feed chains. The objective is that, for cattle born after July 1996, the UK should be able to trade on the same basis as all other EU member states.

If the ban is lifted, UK legislation must be brought into line with EU legislation. If this is not done, the Bovines and Bovine Products (Trade) Regulations 1999 will remain on the statute book but will be open to legal challenge and judicial review. Unless the TSE (Scotland) Regulations 2002 are amended it will not be possible to enforce a 24 month age limit (as opposed to the current 30 months age limit) for the removal of vertebral column or, if this were to be agreed, to make use of the derogation allowing removal in specifically authorised butcher's shops. Similarly, it would be necessary to amend the TSE (Scotland) Regulations to enable the Executive to enforce the less restrictive list of SRM that would apply given the change in the UK's BSE risk status and, if this were to be agreed, to make use of the derogation allowing removal of head meat in specifically authorised licensed cutting plants as well as slaughterhouses.

3. Consultation

EU legislation to lift the export ban may come into effect early in 2006. The Executive would wish UK legislation to come into effect as soon as possible thereafter especially when, subject to Scottish Parliament's approval, additional supplies of UK beef are expected to be available on the UK market after the Over Thirty Months ( OTM) Rule is replaced by BSE testing from 7 November 2005. This consultation is therefore being initiated in advance of a specific EU proposal.

When the EU proposal is made, it is expected to affect those who keep and sell cattle, hauliers, abattoirs, cutting plants, the meat processing industry, independent butchers and other retailers, the catering industry, consumers, those who would wish to export or transport for export beef, bovine products and live cattle and port authorities. It will also be important to those concerned with the welfare of cattle and live exports. All these interest groups are being consulted.

4. Options for achieving the policy objective

Until the Commission has made a proposal and it has been agreed by member states, we cannot know the exact nature of EU legislation to lift the export ban and harmonise SRM controls. The options below are therefore provisional.

Option 1 - Do Nothing

If the EU legislates to allow the resumption of exports of UK cattle born after July 1996 and of beef and bovine products from bovines born or reared in the UK after this date, then the UK must make the necessary implementing legislation. If this is not done, existing UK legislation in relation to both exports and SRM controls will be open to legal challenge and judicial review.

Option 2 - Amend UK legislation to administer and enforce EU legislation without making use of EU derogations

This would involve repealing the Bovines and Bovine Products (Trade) Regulations 1999 and amending the TSE (Scotland) Regulations to reflect EU legislation. However, the UK would not allow either vertebral column from cattle aged 24 - 30 months to be removed in authorised butcher's shops or head meat to be removed in authorised licensed cutting plants. Instead, vertebral column from all cattle aged over 24 months would need to be removed in licensed cutting plants and head meat could be removed only at abattoirs.

Option 3 - Amend UK legislation to administer and enforce EU legislation, making use of EU derogations

This would involve repealing the Bovines and Bovine Products (Trade) Regulations 1999 and amending the TSE (Scotland) Regulations to reflect EU legislation to allow vertebral column from cattle aged 24 - 30 months to be removed in butcher's shops which are specifically authorised, monitored and registered for the purpose. It is not an option to allow vertebral column from cattle aged over 30 months to be removed in butcher's shops because the Food Standards Agency's Independent Advisory Group on replacing the OTM rule by testing recommended that vertebral column from OTM cattle should be removed in licensed cutting plants.

Similarly, the TSE (Scotland) Regulations would include provision for head meat to be removed at specifically authorised licensed cutting plants.

5. Costs and benefits

• Sectors and groups affected

When the EU proposal is made, it is expected to affect those who keep and sell cattle, hauliers, abattoirs, cutting plants, the meat processing industry, independent butchers and other retailers, the catering industry, consumers, those who would wish to export or transport for export beef, bovine products and live cattle and port authorities. It will also be important to those concerned with the welfare of cattle and live exports. There will also be implications for enforcement agencies dealing with the meat industry and exports.

There are implications for small businesses but the EU proposal will not have any race equality impacts.

• Analysis of Cost and Benefits

Option 1 - Do Nothing

Costs

Industry would be denied the opportunity to export beef, bovine products and live cattle and thus denied access to improved returns either directly from overseas markets or as a function of strengthening of the whole UK market because surplus domestic supplies can be exported. This may be particularly important following replacement of the OTM rule from 7 November which will mean that additional supplies of beef from older cattle can be sold on the UK market.

Those who currently export UK beef from eligible cattle aged 6 - 30 months under the Date-based Export Scheme ( DBES) or beef of foreign origin under the eXport Approved ( XAP) Scheme would continue to face the significant additional costs of exporting under these schemes.

UK Government continues to incur costs of enforcing export controls including portal surveillance.

Industry would be required to remove and destroy a longer list of SRM than necessary and more than other EU member States (except vertebral column - see below).

Benefits

The UK Government and the Executive prefer a meat trade to a live trade but recognise that the export of live cattle is a legal trade under EU rules.

UK would not apply new restrictions to vertebral column from cattle aged 24 - 30 months.

Option 2 - Amend UK legislation to administer and enforce EU legislation without making use of EU derogations

Costs

A limit of 24 months for vertebral column would be most unwelcome to farmers, abattoirs and butchers, but the industry has agreed that securing exports is the priority. However, industry has also pressed hard for the UK to make use of the EU derogation to allow removal of vertebral column in butchers' shops. With some 50% UK cattle likely to be finished by 24 months, there should be enough cattle of sufficient (if not ideal) quality to allow trade to continue. The main difficulty a 24 months limit is the impact it could have on;

• farmers producing slower maturing grass-fed cattle
• about 110 small slaughterhouses in GB without linked cutting plants or on about thirty further abattoirs with cutting plants that cannot accommodate all the cattle they slaughter
• traditional butchers

Although significant in presentational terms, sales of T-bone steaks account for only 0.2% retail sales and 0.5% catering sales. Rib roasts could still contain the rib. If the UK requires vertebral column to be removed in licensed cutting plants, small abattoirs will be unable to provide sides, quarters or primary cuts containing vertebral column direct to butchers for boning out unless these are derived from cattle aged under 24 months. These would need to be routed via the nearest cutting plant that might be some distance away. The impact will be greatest in the north and west where more meat is sold through traditional butchers.

Butcher's shops would have to arrange and pay for disposal of the resultant SRM. This would vary according to local circumstance from nothing where waste is already incinerated to about £100 per week. Additional enforcement costs would depend on the regime agreed but could vary from about £20 - £300 per shop per week assuming a weekly visit by a local authority inspector.

There would be no increase in risk because current UK legislation allows butchers to handle and sell without restriction vertebral column from cattle aged under 30 months. However, enforcement cost could be considerable. It is estimated that about 1,000 of a total of about 7,000 UK butchers might wish to take advantage of a derogation.

Benefits

The export trade could resume.

The tables below show the tonnage and value of beef and live cattle exported during 1994 and 1995, the last two full years of trading before the export ban was imposed. Under the Date Based Export Scheme only small quantities of beef have been exported to several EU member states.

Beef and bovine products:

Live cattle:

Trading conditions, particularly exchange rates, are very different today and it would take time to rebuild the export trade which may never reach pre-1996 levels. The MLC estimate that in 2006 UK exports could be about 40,000 tonnes divided equally between prime beef and cow beef.

There is strong overseas interest in high quality breeding stock. There is also interest in calves, many of which are currently shot at birth. The UK would apply all the provisions of EU law relevant to normal trade between Member States, including rules to protect the welfare of cattle during transport.

Butcher's shops could apply for authorisation to remove vertebral column and could thus continue to beef in carcase form. More flexibility in removal of head meat.

UK would apply a more limited list of SRMs.

Industry would benefit being able to reclaim head meat albeit only in slaughterhouses.

Option 3 - Amend UK legislation to administer and enforce EU legislation making use of EU derogations

Costs

Additional costs associated with supervising removal of vertebral column in authorised butcher's shops and removal of head meat in authorised licensed cutting plants.

Additional enforcement costs associated with supervising exports of live cattle.

Benefits

For exports - as for Option 2 above.

For SRMs - butcher's shops could apply for authorisation to remove vertebral column and thus could continue to handle beef in carcase form. Cutting plants could apply for authorization to remove head meat and would no doubt welcome the flexibility and potential cost efficiency of being able to remove head meat in specifically authorised cutting plants.

• Summary of costs and benefits

[ Table - insert when figures are to hand]

• Costs and benefits checklist

Option 1 - Do Nothing

Economic impacts

• The proposal will not result in receipts or savings to the Executive or UK Government.
• The proposal will affect the availability of goods or services in that it will not be possible to export beef, beef products or live bovines from the UK.
• The proposal will not result in new technologies
• The proposal will not result in a change in the investment behaviour both into the UK and UK firms overseas and into particular industries.
• The proposal will not impact on levels of competition within the affected sector.
• The proposal will impact on the public sector, including the resources of front-line delivery staff, in that the Government will have to continue enforcing the Regulations.
• The proposal will not impact on business, charities and voluntary organisations.
• The proposal will impact on foreign consumers because the export of beef, beef products and live bovines from the UK will not resume.

Social impacts

The proposal will not have any social impacts or race equality impacts.

Environmental impacts

The proposal will not have any environmental impacts.

Options 2 and 3

Economic impacts

• UK Government will incur savings in enforcing the current export ban but will incur additonal costs in relation to the live export trade and in enforcing the removal of vertebral column in cattle aged 24 - 30 months.
• The proposal will affect the availability of goods or services in that it will enable the export of beef, beef products and live bovines from the UK. The extent of these benefits will depend on the nature and extent of the export trade.
• The proposal many result in new technologies related to the removal of vertebral column
• The proposal will not result in a change in the investment behaviour both into the UK and UK firms overseas and into particular industries.
• The proposal may impact on levels of competition within the affected sector in that some farmers, food companies and exporters may be able to take advantage of the lifting of the export bans before others are ready to do so.
• The proposal will impact on the public sector in relation to enforcement costs.
• The proposal will not impact on charities and voluntary organisations.
• The proposal will impact on foreign consumers because the export of beef, beef products and live bovines from the UK will resume.

Social impacts

The proposal will not have any social impacts or race equality impacts.

Environmental impacts

There may be environmental impacts if farmers are less inclined to rear cattle extensively because of the new rules on vertebral column.

6. Small Firms Impact Test

There could be implications for small businesses and we will contact the Small Business Service ( SBS).

7. Competition Assessment

The proposals are essentially deregulatory. They would affect a large number of small and mid-sized firms and a number of large firms, none of which dominate the marketplace. None of the measures prevent entry into the market by new firms and none would lead to higher ongoing costs compared to existing firms for new or potential entrants to the market.

8. Enforcement,sanctions and monitoring

The proposals are deregulatory except in relation to new controls on vertebral column from cattle aged 24 - 30 months.

9. Declaration and publication

I have read the regulatory impact assessment and I am satisfied that the benefits justify the costs.

Signed ………………………….

Date

Minister's name, title, department

See the Respondee Information Form for a contact point for enquiries and comments: name, address, telephone number and email address:

LIST OF CONSULTEES

Organisations

Advocates for Animals

Agriculture Industries Confederation

All Scottish Faith Groups

All Scottish Local Authorities

All Scottish Political Parties

All Divisional Veterinary Managers in Scotland

Animal Concern

Animal Health Distributors Association ( UK ) Ltd

Biobest Laboratories Ltd

Blackface Sheep Breeders Association

British Medical Association (Scottish Branch)

British Society of Animal Production

British Society of Animal Science

British Veterinary Association (Scottish Branch)

Business Gateway Aberdeen

CBI Scotland

Central Farmers Ltd

CJD Surveillance Unit

Compassion in World Farming

CoSLA

Crofters Commission

Devro (Scotland) Ltd

East of Scotland Farmers Ltd

European Committee of the Scottish Parliament

Federation of Small Businesses

Federation of Wholesale Distributors

Food Standards Agency (Scotland)

Hannah Research Institute

Health and Safety Executive

Highlands & Islands Enterprise

Highlands & Islands Livestock Ltd

Hospital Caterers Association

Independent Farming Group

Institute of Auctioneers & Appraisers in Scotland

LGC Penicuik

Meat and Livestock Commission

Meat Hygiene Service

Moredun Research Institute

National Cattle Association (Dairy)

National Farmers Union of Scotland

National Sheep Association (Scotland)

National Livestock Traders & Producers Association

North Country Cheviot Sheep Society

Pakistan Society of Edinburgh

Pet Food Manufacturers Association

Quality Meat Scotland

Roslin Institute

Rowatt Research Institute

Royal Dick Veterinary College

Royal Environmental Health Institute of Scotland

Royal Highland and Agric. Society of Scotland

Scottish Agricultural College ( SAC)

SAC Veterinary Science Division

SAC Veterinary Services

Scottish Agricultural Organisation Society Ltd

Scottish Association of Master Bakers

Scottish Association of Meat Wholesalers

Scottish Beef Council

Scottish Centre for Inspection & Environmental Health

Scottish Chamber of Commerce

Scottish Consumer Council

Scottish Co-operative Wholesale Society Ltd

Scottish Crofters Federation Head Office

Scottish Dairy Association

Scottish Enterprise

Scottish Environment Protection Agency

Scottish Environmental Services Association

Scottish Federation of Meat Traders Associations

Scottish Food Advisory Committee

Scottish Food & Drink Federation

Scottish Grocers' Federation

Scottish Meat Industry Liaison Group

Scottish Rural Property & Business Association Ltd

Scottish Society for the Prevention of Cruelty to Animals

Scottish Texel Sheep Breeders Club

Scottish Women's Rural Institute

Scrapie & Related Diseases Advisory Services

Shetland Agricultural Association

Shetland Flock Book Trust

Shetland Livestock Marketing Group Ltd

Shetland Sheep Society

Sheep Veterinary Society

The Independent Farming Group

Wholesale Grocers Association of Scotland

Women's Food & Farming Union

We require your permission to make your response available to the public, and therefore would be grateful if you could return the Respondee Information Form along with your reply to enable us to handle your response appropriately.

We intend making all non-confidential responses available to the public in the following ways:

We also intend to post a summary or analysis of responses received to the consultation on the Scottish Executive consultation web pages.

A new email alert system for SE consultations, SEconsult ( http://www.scotland.gov.uk/consultations/seconsult.aspx) now allows stakeholder individuals and organisations to register and receive a weekly email containing details of all new SE consultations (including web links). SEconsult complements, but in no way replaces SE distribution lists, and is designed to allow stakeholders to keep up to date with all SE consultations activity, and therefore be alerted at the earliest opportunity to those of most interest. We would encourage you to register.

This consultation, and all other SE consultation exercises, can be viewed online at http://www.scotland.gov.uk/consultations. You can telephone Freephone 0800 77 1234 to find out where your nearest public internet access point is.

Please return this form to:

Tel: 0131 244 5246
e-mail: robert.sutherland@scotland.gsi.gov.uk

RESPONDEE INFORMATION FORM