To All Beekeepers
I sent a mail in mid-September addressing the confusion around our insurance and requirements for registration with the Department of Agriculture (DAFM), and I’d like to follow up with the current status. In particular, many beekeepers have recently received a letter from DAFM asking them to re-register and I want to address this too.
First, to reiterate about the insurance: our insurance has no explicit reference to registration and only has the generic requirement that we comply with the current legislation. This has, of course, always been the case, just like any other insurance.
However, we have a conflict with DAFM in that they appear to have changed the regulations with no consultation, in contradiction to EU legislation. To explain the problem, consider that there are three categories of beekeepers for the purpose of this discussion:
- Beekeepers who only produce honey for their own use or do not produce honey at all are completely exempt from this registration requirement – it simply does not apply. Our insurance covers this group of beekeepers as you might expect.
- Beekeepers with a larger number of hives who produce commercial levels of honey are definitely primary producers of honey and, as such, are required to register. I suspect most, if not all, beekeepers who fall into this category have already registered. In order to comply with the legislation, these beekeepers must register with DAFM in accordance with the law and consequently to ensure that their honey is covered by insurance.
- Beekeepers who only supply small amounts of honey direct to consumers or to local retail outlets that supply direct to consumers: up to recently, DAFM did not require this group of beekeepers to register, as allowed by the EU regulations (although the usual food hygiene requirements still apply). However, DAFM removed that exemption from their web site, and are now claiming that registration is required and the EU exemption does not apply. This is where we disagree with DAFM.
It is this third group of beekeepers, possibly the majority of our members, where the uncertainty arises. We have been trying to arrange a meeting with DAFM and it looks like this will happen on 8th December, although this has not been confirmed yet. We have very specific questions to ask them to try to understand why they believe that EU legislation should not apply here.
Until we have the complete response from DAFM and an agreement as to what registration is necessary, please hold off with returning the updated registration. We will probably have complete information in a few weeks so it’s not an undue delay.
Brendan Murray, Secretary, Federation of Irish Beekeepers Associations