this exemption was available in 2014 so it was in enacted before Justin Trudeau
Source by wayback machine archived on October 4, 2014 https://web.archive.org/web/20141006223931/http://www.rcmp-grc.gc.ca/cfp-pcaf/online_en-ligne/firearms-licence-permis-armes-a-feu-eng.htm
Edit to add:
Now when you look at the actual act you will see it was enacted or amended in 2004 because at the end of this section it states SOR/2004-274, s. 13. SOR stands for Statutory Orders and Regulations
According to the Parliaments House publication (minutes) it states this
"In the matter of SOR/2004-274; Regulations Amending the Firearms Licences Regulations, it was agreed that the joint chairs correspond with the acting commissioner of the Royal Canadian Mounted Police with respect to certain comments made by the committee"
So sometime in 2004 this part of the act was amended or enacted. This exemption could even date back further as many Amish are avid hunters but believe photos are against the bible and considered a graven image.
https://thegunblog.ca/2017/05/25/rcmp-says-1182-gun-licences-dont-have-photos-ccfr-reports/
Related Faith Goldy & Jewish Defense League EXPOSED! - A Snub to The Alt Right
https://thegunblog.ca/2017/05/25/rcmp-says-1182-gun-licences-dont-have-photos-ccfr-reports/
Related Faith Goldy & Jewish Defense League EXPOSED! - A Snub to The Alt Right
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