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GRTU has today sent its comments after being consulted by the Food Safety Commission on the possible introduction of a Legal Notice regulating the Slaughtering of Rabbits for Human Use for Units Rearing 49 does or less.
After having analysed the proposed Legal Notice that the Food Safety Commission is in the process of advising to the relevant Ministers to issue, GRTU finds itself not in agreement with the changes being proposed in the Legal Notice.This Legal Notice proposes to regulate against slaughtering of rabbits on a very small scale. The operators affected are currently unregulated, for the precise reason of being small. Practices such as the slaughter in one’s shop will not be admissible unless the requirements have been met, in real terms however GRTU is not aware of any such practices.
It will however affect the cottage industry, leading to a total halt of this industry since the operators will not be able to sustain the costs involved to be in line with the requirements of the proposed Legal Notice. GRTU is not in agreement in this context and doubts the reasons the Legal Notice is being proposed.
GRTU is principally not in agreement since we do not see any requirement for this Legal Notice being imposed by a European Directive. Going beyond the Directive means that other Member States are not imposing such a burden and it is therefore unfair for these micro operators to carry a burden they cannot sustain, which their fellow operators in other Member States do not have to face. This proposal therefore goes against European principles within the Better Regulation Strategy and the Small Business Act, both of which the Government has endorsed during European Council Meetings. Within the principles endorsed is the “Think Small First” principle which means policies should be made with the micro and small operators in mind, a principle which this Legal Notice clearly lacks. As a conclusion GRTU therefore reiterated that it disagrees with the adoption of this Legal Notice and we invite the Food Safety Commission to withdraw such proposal for the reasons stated above. Should any members be interested in more information, please do not hesitate to contact Abigail Mamo.
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