BASC has cautioned against poorly-targeted regulations in its response to a European-wide public consultation on the use of lead ammunition over wetlands.

The UK’s largest shooting organisation has warned that a wide-sweeping definition of a ‘wetland’ would risk criminalising those in possession of lead shot within close confines of field ditches and streams.

In its response to the consultation by ECHA (The European Chemicals Agency), BASC’s scientific advisor, Dr Matt Ellis, has also argued that the definition of a wetland should exclude peatlands without visible water.

Dr Ellis, chair of the FACE (European Federation of Associations for Hunting and Conservation) Ammunition Working Group, said: “BASC works to ensure that the law on lead shot is understood by those who shoot and is complied with.

“But we also continue to challenge those who make the laws to ensure that any changes are based on sound evidence and do not have unintended consequences. We are keen to work with ECHA to ensure they are fully appraised of how any decisions would affect the UK.

“We are aware that ECHA is recommending a ban on the possession of lead shot in wetlands. Most shooting in the UK involves walking between areas of woodland looking for game birds, often without any shooting over wetlands.

“However, the definition of a wetland is so broad that hunters would be criminalised for carrying lead cartridges over any wetland, including field ditches and streams, even if they were otherwise acting lawfully and not shooting lead shot over wetlands.

“Unenforceable and poorly targeted regulations will reduce the buy-in from hunters and ultimately reduce the effectiveness of the regulation itself.”

ECHA, an agency of the European Union, launched its consultation following a request from the European Commission, with the agency charged to develop an Annex XV restriction dossier on the use of lead shot over wetlands.

The consultation covers the impact of restrictions, the efficiency and safety of alternatives to lead ammunition, and calls for evidence on experiences and compliance with existing regulations and the effects on wildlife and water eco-systems.

BASC’s response emphasises that there are no direct substitutes for lead shot. It highlights that the current laws in the UK are in accordance with the country’s treaty obligations under the African Eurasian Waterbird Agreement (AEWA) and are targeted and proportionate.

BASC’s response emphasises that use of lead shot does not have a population level impact on birds.

BASC is working with other European shooting organisations, including FACE, to ensure that shooting’s interests are properly represented and protected.



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