Association of Licensed Multiple Retailers
ALMR
National Trade Body representing licensed hospitality companies including pubs, bars, restaurants and accommodation providers.
ID: 514968420176-25
Lobbying Activity
7 Jul 2017
The ALMR represents the owners and operators of pubs, bars, nightclubs and restaurants amounting to over 23,000 outlets encompassing entrepreneurs, small, medium, branded restaurants & cafes, and PLC companies.
The ALMR supports the response from HOTREC its umbrella organisation but questions whether regulation is the best way to tackle this complex issue. Restaurants, pubs and bars are pre-predominately small businesses serving food in a traditional manner where quality and value for money are paramount and there is an overwhelming economic imperative to meet customers’ needs. We supported the voluntary approach taken in HOTREc's Code of Practice and still believe this would the best and most proportionate route to follow.
The Regulations as currently drafted raise the following particular concerns:
- we support HOTREC’s position on 'chains' that it should only apply to those businesses that offer standardised menus the ingredients of which are centrally sourced while the exemption “from the obligation to sample and analyse their production for the presence of acrylamide”
- The regulation instruction to use “lower sugar content” is in itself vague but we agree with HOTREC that the words “where possible” should be added.
-The inclusion of the instruction to wash and soak for 30 minutes or (we assume this should read as ‘for’) 2 hours before cooking, albeit preceded by ‘where possible’ should be removed.
- Cooking Oil should be defined so as to include animal fat.
- The draft includes a provision such that "Where possible, potatoes shall be blanched". This is simply not practical for most establishments and should be removed.
- colour guides should remain as guides rather than be something that should be strictly adhered to. If they remain as drafted the Commission should heed HOTREC’s call for a single unified and high quality chart that is reproducible and robust.
- The ALMR firmly believes that Colour Guides for toasting sandwiches are not remotely practical and disproportionate and should be removed as a requirement
- The ALMR believes that insufficient consideration has been given to the enforcement burden that the regulations will impose not just on businesses but on the enforcement community much of which is already over-stretched. We agree with other respondents that a voluntary approach would be much more likely to be produce a positive result.
The full response from the ALMR is attached below as a Word File.
Read full response