Lead Ammunition

Where are we now?

The Heath and Safety Executive published the UK REACH restriction dossier for lead ammunition on 6 May. The document outlines wide-reaching proposals for the restriction of many forms of lead ammunition. In response to the publication, BASC issued the following statement:

“The proposed restrictions would see a ban on the sale and use of many forms of lead ammunition outdoors in England, Scotland and Wales. Limited exemptions have been outlined in the dossier for the continued use of lead ammunition in some licensed settings.

“The wide-ranging proposed restrictions, which closely reflect EU REACH proposals, would apply to shotgun, rifle and airgun ammunition. The dossier will now undergo a high level of scrutiny and BASC will be playing a full role in that process.

“Through a six-month consultation also launched today by the HSE, we will challenge proposed restrictions where there are no viable alternatives to lead, where socio-economic factors mean a transition isn’t appropriate, and where lead can continue to be used in settings that present negligible or no risk.

“We have significant concerns about the short timeframes outlined in the dossier for transition away from the use of lead ammunition, which could be as short as 18 months. This is particularly alarming in light of current global supply chain issues. We will fight for timelines that are realistic and guided by the sector to ensure that the range of lead-free products and their supply can meet market demands.

“BASC will be engaging with the regulator to ensure that proposals are robustly scrutinised and that any future restrictions are based on evidence and proportionate to identified risks. We will not accept disproportionate restrictions that unfairly disadvantage shooting activities.

“Shooting is worth £2 billion to the UK economy, employing the equivalent of 74,000 full time jobs. The proposed restrictions stand to impact all 600,000 live quarry shooters and the estimated four million target and air rifle shooters in Great Britain. The regulator must be able to show its working and acknowledge the monumental challenge that restrictions will bring to the shooting community and market.

“BASC remains fully committed to the five-year voluntary transition away from using lead shot for live quarry shooting that has made such significant progress under challenging conditions.

“Given the severity of the proposed restrictions, the voluntary transition has afforded the sector a head-start in the move away from lead ammunition.”

Read more on the proposed restrictions and what they mean for shooting in our blog here.

FAQs

UK REACH – General

We are carefully analysing the restrictions proposed in the dossier alongside the supporting evidence. There are over 450 pages of information, and it will take time for BASC and the other shooting organisations to prepare their response to the regulator

Our response will come through public consultation and accredited stakeholder engagement. This will allow us to comment during the ‘scientific scrutiny’ and ‘challenge panel’ elements of the process.

Shotgun ammunition:

  • Ban on the sale and use of lead shotgun ammunition.
    • 18-month transition period.
    • Optional derogation (exemption), allowing sale and use for clay pigeon shooting by licensed athletes at licensed shooting grounds. A shooting ground licence would require annual recovery of 90%+ of spent lead shot, containment and treatment of run-off, and a ban on agricultural activity within the site boundary.
    • Note: If the optional derogation is taken forward, the transition period for all uses of lead shot would be extended to five years.

Lead bullets (including centrefire, rimfire, airgun and any other projectiles containing lead):

  • Ban on use of all lead bullets (centrefire, rimfire, airgun pellets and other projectiles containing lead)
    • An 18-month transition period for large calibre (5.6mm or larger) or 5 years for small calibre (smaller than 5.6mm) including rimfires and airguns and any lead projectiles not defined as gunshot
    • Optional derogation allowing continued use of lead bullets at licensed ranges with appropriate environmental protection measures. A licence would require regular recovery of >90% of lead from bullet traps, and a ban on agricultural activity within  the site boundary.
Sector of UseUse #Use titleMain risks identifiedEstimated release to the environment (tonner per year)
Hunting1Hunting with shot shell ammunitionPrimary and secondary poisoning of wildlife (birds)   Human via consumption of game meat6,537
2aHunting with bullets – small calibre, including airgunsSecondary poisoning of wildlife (birds)   Humans via consumption of game meat14.5
2bHunting with bullets – large calibreSecondary poisoning of wildlife (birds)   Humans via consumption of game meat 
Sports shooting3Outdoor sports shooting with shot shell ammunitionPrimary and secondary poisoning of wildlife (birds)   Secondary poisoning of livestock (ruminants) via silage grown on shooting ranges/ areas used as agricultural land Ingestion of contaminated soil or vegetation by livestock (ruminants) on shooting ranges/ areas used as agricultural land   Risks to soil compartment1,680
4Outdoor sports shooting with bulletsIngestion of contaminated soil or vegetation by livestock (ruminants) on shooting ranges/areas used as agricultural land   Risks to soil compartment26.8
5Outdoor shooting with air rifle/pistolNo data
Shooting with historical weapons6Other outdoor shooting activities including muzzleloaders, historical re-enactment, etc.No data

The HSE have indicated in the restriction dossier that legislation could come into effect in 2024.

The restriction dossier proposes transition periods between 18 months and five years. Any transition periods would only start from the date any new law is passed.

No. BASC is fighting to ensure that any future legal restrictions on lead ammunition are proportionate to the risk and necessary. Where restrictions are necessary, we will seek realistic transition periods that allow for the development of the full suite of required products – and at the necessary scale – to meet market demand.

It is also noted that the proposals include exemptions that would allow continued use of lead in some settings, such as clay ground and target ranges, where the necessary environmental protection measures are in place.

Lead is toxic and classified as a ‘substance of very high concern’. Its impacts on wildlife, the environment and human health are well documented. Taking a proportionate approach to the elimination of risk posed by lead ammunition would improve the sustainability of shooting in the future.

The regulator does not consider that voluntary or self-regulated transitions to lead-free ammunition will generate sufficient and broad enough change across the sector to eliminate the identified risks.

The regulator refers to the low compliance with existing environmental protection regulations on several occasions. They cite the high percentage of ducks continuing to be shot with lead as evidence to support the proposals for strict regulation that limits opportunities for non-compliance.

BASC will continue to pursue its voluntary transition away from lead shot and single-use plastics for live quarry shooting with shotguns.

The transition has been successful in starting change in the sector. We are supporting the community in making the transition to lead-free alternatives with advice, education, and opportunities to try new sustainable shotgun ammunition products.

Given the severity of the proposals from UK REACH, the voluntary transition has given the sector a head start on any future legal requirements to use non-lead ammunition.

The voluntary transition is only concerned with moving to lead-free alternatives for live quarry shooting with shotguns. At the time of the launch of the voluntary transition, UK REACH did not exist.

BASC has been fighting lead ammunition bans since they were first proposed in a 1983 Royal Commission on Environmental Pollution report. 

The European Chemicals Agency has been reviewing the use of lead ammunition since 2011 and BASC has been supporting the European Federation of Hunting Associations (FACE) in fighting these proposals. 

In 2016, after a lengthy campaign by BASC and other shooting organisations , the UK government rejected proposals for a lead ban, , with the Secretary of State noting that the findings of the Lead Ammunition Group did not show the impacts of lead ammunition were significant enough to justify changing government policy. 

In 2021, proposals to ban lead ammunition in the European Union were published along similar lines to what has recently been proposed by the UK Health and Safety Executive for England, Wales and Scotland.

UK Registration, Evaluation Authorisation and Restriction of Chemicals (UK REACH) is part of the UK’s independent chemicals regulatory framework but is essentially a copy of the European approach (EU REACH). UK REACH regulates the use of chemicals to protect human health and the environment and is led by the Health & Safety Executive (HSE). It will work with ministers of the devolved governments and devolved statutory environmental agencies to make regulatory decisions about substances and/or articles.

Although called UK REACH, the framework applies to England, Wales and Scotland (i.e. Great Britain) but not Northern Ireland. Due to the Northern Ireland Protocol, Northern Ireland remains under the EU REACH framework.

On 29 April 2021, the Health and Safety Executive (HSE), as the agency for UK REACH, received a request under Article 69(1) of UK REACH from the Secretary of State for Environment, Food & Rural Affairs, with the agreement of the Scottish Government and the Welsh Government, to prepare an Annex 15 restriction dossier assessing the risks from lead ammunition on the basis “that the use of lead in ammunition raises concerns related to both human health and the environment. The harm of lead ammunition to wildfowl is of particular concern – poisoning from ingesting lead ammunition causes long-term suffering and slow painful deaths for animals. The health of humans, particularly children, may also be adversely affected from eating meat killed using lead ammunition.”

Starting the process of regulating lead ammunition is one of five key objectives for UK REACH in 2021/22, with a target to produce an Annex XV restriction dossier no later than 29 April 2022.

A restriction dossier is a document prepared by the regulator that provides proposals for restrictions on a substance, chemical or article. The dossier must contain information on hazards and risks associated with that chemical, substance or article, available information on alternatives (substances and/or processes) and a justification for restrictions proposed.

The dossier needs to show that restriction is the most appropriate risk management instrument for addressing the identified risks. The restriction dossier may also include an analysis of the socio-economic impacts of the proposed restrictions.

No. The proposals in the restriction dossier are just that, proposals. They will be subject to scientific scrutiny by independent experts, agency consultation and full public consultation before a final restriction report is prepared.

The restriction report is the document from which legislation will be drafted. No restrictions will come into force until the end of the legislative process and the enactment of a new law.

Members can respond to the public consultation on the proposals, which is open until 6 November 2022. https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/

Over the coming weeks, BASC will be analysing the proposals and publishing detailed FAQs to assist members who respond to the consultation questions.

UK REACH – Shotgun

The proposals call for a ban on the sale and use of lead shot. As such the proposals would mean that non-lead alternatives would have to be used for live quarry shooting.

The proposals call for a ban on the sale and use of lead shot. Although there is a proposed derogation (exemption) for clay pigeon shooting under licence.

The proposed restrictions provide a derogation (exemption) which would allow the continued use of lead shot under a licensed system. The exemption would require the following:

  • a licence to sell shotgun cartridges containing lead shot
  • the individual will require a licence to shoot lead shot
  • the range/clay pigeon ground will require a licence. This will only be issued if the venue regularly recovers more than 90% of spent lead shot, has measurements in place to collect and treat water run-off, and bans agricultural use within the site boundary.

It should be noted that a derogation is optional and may not be taken forward.

There is currently no detail on how the licensing system might operate, who would run the licensing system, and the eligibility criteria to obtain a licence.

The restriction dossier is prepared on the assumption that legislation will come into effect in 2024.

Yes. The proposals are for an 18-month transition period for shotgun ammunition. That would allow the continued sale and use of lead shot for 18 months from the date any new law came into effect.

If the regulator takes forward a proposed derogation for the continued use of lead in clay pigeon shooting at licensed grounds, then a transition period of five years would apply. This extended transition period would apply to all use of lead shot; live quarry and clay pigeon.

No. The proposals provide no exemptions for using lead ammunition for live quarry shooting.

Based on the proposals, there would be at least 18 months in which to use up lead ammunition even after any law is passed. The transition could be up to five years if proposed derogations are taken forward in the current format.

The proposals also mention a buy-back scheme for lead ammunition, but there are no details of how this would operate. The regulator suggests that such a scheme will be considered during the consultation process.

UK REACH – Large Calibre Rifle

The proposals call for a ban on the use of lead bullets.

The restriction dossier is prepared on the assumption that legislation will come into effect in 2024.

Yes. The proposals are for an 18-month transition period for large calibre rifle ammunition. That would allow the continued use of lead bullets for 18 months from the date any new law came into effect.

No. The proposals provide no exemptions for using lead ammunition for live quarry shooting.

A derogation (exemption) is proposed that would allow the continued use of lead bullets for target shooting at licensed ranges.

To obtain a licence, the proposal is that ranges would have to regularly recover over 90% of spent lead bullets and would be required to ban any agricultural uses within the site boundary.

Based on the proposals, there would be at least 18 months in which to use up lead ammunition even after any law is passed.

The proposals also mention a buy-back scheme for lead ammunition, but there are no details of how this would operate at this time. The regulator suggests that such a scheme will be considered during the consultation process.

UK REACH – Other

The proposals call for a ban on the use of lead bullets, including those of small calibre rifles (i.e. with a bullet diameter less than 5.6mm).

The proposals call for a ban on the use of lead bullets, including those of small calibre rifles (i.e. with a bullet diameter less than 5.6mm). The ban is only for use outdoors and does not affect the use of lead ammunition on indoor ranges.

Yes. All lead ammunition including lead shot, lead bullets and other lead projectiles not defined as shot would be affected.

There are proposed derogations for the continued use of lead shot, lead bullets and other lead projectiles not defined as gunshot in target shooting. These derogations would be under a licensing system which licenses venues where appropriate environmental protection measures are in place.

A derogation (exemption) is proposed that would allow the continued use of small calibre lead bullets, airgun pellets and any other lead projectile not defined as gunshot at licensed ranges.

To obtain a licence, the proposal is that ranges would have to regularly recover over 90% of spent lead bullets, and would be required to ban any agricultural uses within the site boundary.

Yes. Lead airgun pellets are covered under restriction proposals for ‘small calibre rifle ammunition’.

The restriction dossier is prepared on the assumption that legislation will come into effect in 2024, although there is no indication of which month.

Yes. The proposals are for a five-year transition period for small calibre rifle ammunition. That would allow the continued use of lead bullets with a diameter below 5.6mm, lead airgun pellets and other lead projectiles not defined as gunshot for five years from the date any new law came in.

Based on the proposals, there would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as gunshot after any law is passed.

The proposals also mention a buy-back scheme for lead ammunition, but there are no details of how this would operate at this time. The regulator suggests that such a scheme will be considered during the consultation process.

Shooting and rural organisations take responsibility of move away from lead ammunition

Shooting and rural organisations announce five-year transition away from lead shot and single-use plastics for live quarry shooting.

Current restrictions on lead shot (only)

England and Wales

  • Don’t use lead shot for shooting ducks, geese, coot or moorhen anywhere.
  • Don’t use lead shot over the foreshore.
  • Don’t use lead shot over any of the listed SSSIs, even if they’re inland. The list can be found in the legislation below.

Scotland and Northern Ireland

  • Don’t use lead shot for shooting over the foreshore, or for shooting over wetlands including streams, rivers, ponds, marshes, wet fields and moorlands with visible standing water.

Specific legislation

England

Wales

Scotland

Northern Ireland

Using steel shot

What you need to know from a safety point of view

BASC guide to using non-lead shot for live quarry shooting

Sustainable ammunition articles

External publications and videos on sustainable ammunition.

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