Information concerning the sale and consumption of guga (young gannet) on the Isle of Lewis

Date published:

Request

Your request was about the following information:

I am particularly interested in understanding how the consumption and sale of Guga is permitted to continue, given it stands out with regulated food supply chains. I note that Comhairle nan Eilean Siar council has previously acknowledged in communications with Food Standards Scotland that the process is “not in full compliance with current food regulations.” I am aiming to understand how this is allowed to continue given the public health risks posed by pathogens that could arise from contact with Guga, such as avian flu, Salmonella, and Campylobacter. 

Please provide the following information: 

1. Handling and Food Safety Compliance 

- Details of any food safety requirements applicable to individuals involved in the handling, processing, or distribution of Guga.

- Whether individuals handling Guga are required to be registered food business operators, and if not, why. 

- Any inspections, audits, or oversight carried out in relation to the handling of Guga. 

2. Commercial Sale and Distribution  

- Clarification on whether the sale of Guga is permitted under current food safety law. 

- Details of how Guga is allowed to be sold or distributed. 

- Any exemptions, derogations, or informal arrangements that permit its sale or supply. 

3. Risk Assessment and Public Health 

- Any risk assessments conducted regarding the consumption of Guga, including risks from avian influenza, Salmonella, Campylobacter, or other pathogens. 

- Details of any testing, sampling, or monitoring of Guga meat for food safety risks. 

- Food Standards Scotland’s current position on whether the handling, sale, and consumption of Guga is compliant with food safety legislation. 

4. Internal Communications 

- All internal communications held by Food Standards Scotland relating to the Guga hunt and/or consumption of Guga, including emails, briefings, reports, and meeting notes. 

- Any communications with external bodies (including Comhairle nan Eilean Siar, Scottish Government, or other regulators) relating to the regulation, safety, or compliance of Guga.

Response

1. Handling and Food Safety Compliance 

As you are probably aware, the Guga hunt can only take place legally under a special licence issued by NatureScot under the Wildlife and Countryside Act 1981 (WCA 1981), and it is for NatureScot to advise on this. 

If the birds collected from the hunt are to be processed for human consumption, then the hygiene requirements for ensuring the safety of foodstuffs would apply. The various requirements are set out in Regulation 178/2002 (general principles and requirements of food law), Regulation 852/2004 (general hygiene requirements for food) and Regulation 853/2004 (specific hygiene requirements for foods). However, which requirements apply to any given individual or business is dependent on specific circumstances, as there are exemptions set out within the regulations which affect which requirements apply. We can also advise that the young gannets could be considered wild game, the definition of which is set out in Regulation 853/2004. 

There is a table within the Wild Game Guide (WGG) that explains the various exemptions, and this will be useful in explaining the regulations that apply to the Guga hunt. From the information provided, it appears that one of the primary producer exemptions may apply as the wild game or wild game meat is supplied directly to the final consumer or local retail establishment who directly supply the final consumer. Further information on the regulations that apply to them are set out on page 10-12 of the WGG. 

We would recommend that you contact the Local Environmental Health Department as it is responsible for enforcement of food safety and hygiene laws and will be able to provide you with specific advice. You may contact them directly on eh@cne-siar.gov.uk 

2. Commercial Sale or Distribution 

Queries regarding the permitted sale or distribution of Guga should be directed to the Local Authority (LA), as they are the Competent Authority for food safety matters. You may contact them directly at eh@cne-siar.gov.uk . 

3. Risk Assessment and Public Health 

Food Standards Scotland (FSS) has not undertaken any risk assessment regarding the consumption of Guga, or have carried out any testing, sampling or monitoring. 

4. Internal Communications 

FSS does not hold any internal communications, briefing, reports or meeting notes regarding the hunt and/or consumption of Guga. 

In September 2025 we received an enquiry regarding the possible health risk of consuming gannet meat that was subjected to Avian Flu/ Avian Influenza (AI). As FSS is not the Competent Authority, the LA and Scottish Government (SG) were engaged in the response. The following was provided as part of the response from SG/LA and FSS: 

- Confirmation that there was no case of AI in Lewis. 

- Link to NHS guidance on bird flu transmission - Bird flu - NHS 

- Link to the risk assessment for AI conducted by FSA in 2013 - Risk assessment of acquiring Avian Influenza from Poultry Products: Executive Summary | Food Standards Agency 

- Wild bird findings in avian influenza - Bird flu (avian influenza): cases in wild birds - GOV.UK 

- Map showing all the current cases - Wild Bird Reports 

- Instructions how to report for members of the public - Report dead wild birds - GOV.UK 

- Confirmation from LA they that they considered the risk of transmission of AI to be negligible as the meat is boiled for at least 45 minutes.

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