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By E mail & Post


Mr Andy Spencer, Food Hygiene Implementation Division, 27 May 2005

Food Standards Agency,

Rm. 715b, Aviation House

125 Kingsway, London, WC2B 6NH


Dear Mr Spencer


Response to Food Standard Agency Consultation

'Implementing new EU food hygiene and official feed and food controls legislation'


I write in response to the Food Standard Agency's e-mail dated 10 May 2005.


Article 5, headed 'Amendments', of the draft Commission Regulation (EC) ... 'amending the Annexes of Regulations (EC) No ... 853/2004 ...' (ref: SANCO/55/2005 Rev. 3) reads:


1. Pursuant to Article 10 of Regulation (EC) No 853/2004, Annexes II and III to that Regulation are amended as follows:

(f) In Annex III Section I Chapter IV Point 8, the first sentence is replaced by the following:

8. Complete skinning of the carcase and other parts of the body intended for human consumption must be carried out, except for porcine animals, the heads of ovine and caprine animals and calves and the feet of bovine, ovine and caprine animals.


We make the following comments on Article 5.


The London Central Mosque Trust & the Islamic Cultural Centre recommends other exceptions to the requirement for complete skinning, namely except for porcine, ovine and caprine animals. The effect of this would be to permit sheep and goat carcasses with their skin on to be health marked and placed on the market.


Our justifications for this recommendation are:


1. There is a considerable market in UK for 'smokies' (singed carcasses of sheep or goat with their skin on). The main purchasers of smokies are the West African community, (Muslims and non Muslims).


2. There is a serious illegal trade in sheep and sheep carcasses in the U K to supply this market. You are doubtless aware of trade, and of the prosecutions taken by a number of Food Authorities, in the country.

We aware that amendments to other legislation may also be required, to permit the singeing of sheep or goat carcasses with their skin on.




Yours sincerely




Dr Ahmed Al Dubayan Dr Yunes Teinaz

Director General Advisor to the Director General