The European Federation for Hunting and Conservation (FACE) has criticised the European Commission?s (EC) justifications for wanting to review the European Firearms Directive. FACE has said that the evidence on which the EC?s concern that ?legal firearms feed the illegal market? is based, is confused, irrelevant or in some cases simply absent. The response concludes that ?FACE is convinced that the Commission is aiming at the wrong target, since legal firearms owners are not the problem. The EU should not divert public resources from actions specifi cally aimed at fighting illegal activities.?

The criticism appears in FACE?s response to a communication issued by commissioner Cecilia Malmström in October 2013, which sets out a list of legal and illegal firearms priorities with a view to reviewing the Firearms Directive and imposing greater restrictions on legal firearm ownership. In the communication, the Commission alleged that criminals were exploiting differences between firearms law in member states to obtain firearms for illegal use and cites this, along with public opinion, as a basis for a review and amendment of the EU Firearms Directive, which lays down current minimum standards for the acquisition and possession of legal firearms in member states.

While FACE says it welcomes action specifically to combat illegal activities, it contests the need for review and amendment of the directive in relation to legal fi rearms on the grounds that the Commission has not shown any evidence for the link between the legal and illegal firearms markets, that the data the Commission uses to support its other recommendations for action at an EU level is flawed, and that the public opinion cited was not fairly gathered.

The FACE response points to a number of errors and inaccuracies in statistics used by the Commission relating to legal firearms ownership and crime and to lost and stolen firearms. It goes on to address the Commission?s concerns over the illegal reactivation of deactivated firearms, pointing out that the Commission has not yet met its statutory duty to issue guidance on deactivation standards under the Firearms Directive.

Finally, the response highlights flaws in the public opinion cited by commissioner Malmström in support of further EU action. In particular, FACE criticises the omission of information on the results of FACE?s public consultation ? to which more than 81,000 EU citizens responded ? and instead cited a subsequent Eurobarometer survey, in which 26,555 respondents were interviewed by telephone.

FACE reports that commissioner Malmström made disparaging comments about the respondents to the public consultation and discounted their opposition to further EU action on the grounds that many of them had ?declared their membership of associations related to firearms use?.

FACE further notes that the questions in the consultation and subsequent Eurobarometer survey misleadingly suggested that there are not currently any European minimum standards for the legal acquisition and possession of firearms and that responses in favour of common standards cannot therefore be taken as support for further action at an EU level.