Lead Ammunition

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.

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.

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 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.

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

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.

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.

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

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.

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.

Based on the proposals, there would be at least 18 months in which to use up shotgun and large calibre rifle lead ammunition even after any law is passed. There would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as lead shot 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 HSE suggests that such a scheme will be considered during the consultation process.

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.

The CIP (Permanent Proof Commission) is an international body which lays down standards to which the British Proof Authority must adhere when proofing guns in the UK.

Standard steel shot cartridges are safe for use in any post 1954 nitro proofed gun. As proof testing is mainly predicated on chamber pressure, it follows that pellet composition material is not relevant to the proof test. Consequently, any post 1954 nitro proofed gun is highly unlikely to become “out of proof” if lead shot were to be banned or otherwise restricted. NB Standard Steel cartridges may not contain pellets larger than 3.25mm diameter.

As the CIP is silent on the matter of choke constriction for Standard Steel cartridges, it follows that they may be fired through any degree of choke.

In the case of High-Performance steel shot cartridges, the CIP issues guidance on choke which varies according to the gun’s bore size.

In the transitional period before any ban on the use of lead shot in Great Britain is imposed, the British Proof Authority may revise its proof test procedure, taking into account any input from the CIP.

We accept that there is an evidenced risk of primary exposure to birds, and risks to human health from lead gunshot. These were part of the rationale for announcing the five-year voluntary transition away from lead gunshot for live quarry shooting back in February 2020.

We consider elements of HSE’s justification of restricting the use of lead gunshot for live quarry shooting to be valid.

However, through scrutiny and challenge panels and the ongoing public consultation for the proposal, we will seek to influence any restriction proposals to ensure they are proportionate to the identified risk and come with realistic transition periods.

We do not believe that the evidence presented by the HSE justifies the restriction proposals in their current form.

The evidence presented in the dossier of risk from lead gunshot to soil, soil organisms, plants and livestock is not conclusive. Furthermore, there are existing regulations and directives that are retained in UK law which address these factors, including:

• Regulation 1881/2006 that limits lead in food for human consumption (agricultural production),
• Regulation 1275/2013 that limits lead in animal feed, and
• DIRECTIVE 2002/32/EC on undesirable substances in animal feed

We therefore consider any further restrictions to be unnecessary and disproportionate.

Within proposals, HSE seeks to require containment and treatment of water run off on ranges where lead continues to be used, despite their report concluding that there is no risk within surface waters.

In addition, there are existing requirements in through the Water Framework Directive (Standards and Classification) Directions (England and Wales) 2015 and the Scotland River Basin District (Standards) Amendment Directions 2015.Further regulation that seeks to control this is not required.

There remains a risk of primary exposure to birds from consumption of spent lead gunshot. This risk would need to be managed; however, we argue that for many forms of clay pigeon/shotgun target shooting, this risk can be adequately controlled without the need for further legal restriction.

BASC will be making the case through scrutiny and challenge panels, and the ongoing public consultation, that the proposed restrictions are not justified by the evidence presented and are therefore unnecessary and disproportionate.

We will be seeking to avoid any unwarranted restriction and providing alternative proposals for how evidenced risks can be controlled without banning the use of lead gunshot for clay pigeon/target shooting.

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.

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.

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.

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

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 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 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.

Based on the proposals, there would be at least 18 months in which to use up shotgun and large calibre rifle lead ammunition even after any law is passed. There would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as lead shot 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 HSE suggests that such a scheme will be considered during the consultation process.

Within the restriction dossier, the Health and Safety Executive (HSE) has detailed a significant body of evidence of the lethal and sub-lethal effects of lead ammunition on birds.

The evidence relates to a ‘primary exposure pathway’ for birds who utilise a gizzard to grind up food as part of their digestive process. Usually these birds would consume grit, which would sit in the gizzard to aide the grinding of food items for digestion. In some cases, lead gunshot is mistakenly consumed.

Due to the grinding action and conditions within the gut, lead is taken up through the digestive tract. The lead uptake is proven to affect birds, from a range of sub-lethal impacts as well as ultimately causing their death if enough lead is ingested.

There is also a body of evidence presented in the restriction dossier about the impacts of lead on human health. Sub-lethal effects include neurotoxicity, kidney effects including renal disease and cardiovascular effects.

Although the evidence does not directly or solely attribute lead ammunition as a cause, either through primary or secondary exposure, lead is a ‘zero-threshold’ neurotoxin, which evidence shows has impacts on the IQ of children and ‘in-utero’ effects on a developing foetus.

Dietary exposure to lead in game meat is an means by which humans may consume lead, and it is clear from the evidence presented by HSE that existing meat processing practices cannot eliminate all lead contamination from game meat.

It is for these reasons that HSE are seeking to eliminate the risk of lead contamination in game meat reaching the human food chain.

We do not consider the evidence presented by HSE in the restriction dossier relating to secondary exposure to birds from lead ammunition to be conclusive. Based on the evidence presented, we do not consider restrictions related to this potential exposure pathway to be necessary or in line with the level of risk.

The CIP (Permanent Proof Commission) is an international body which lays down standards to which the British Proof Authority must adhere when proofing guns in the UK.

Standard steel shot cartridges are safe for use in any post 1954 nitro proofed gun. As proof testing is mainly predicated on chamber pressure, it follows that pellet composition material is not relevant to the proof test. Consequently, any post 1954 nitro proofed gun is highly unlikely to become “out of proof” if lead shot were to be banned or otherwise restricted. NB Standard Steel cartridges may not contain pellets larger than 3.25mm diameter.

As the CIP is silent on the matter of choke constriction for Standard Steel cartridges, it follows that they may be fired through any degree of choke.

In the case of High-Performance steel shot cartridges, the CIP issues guidance on choke which varies according to the gun’s bore size.

In the transitional period before any ban on the use of lead shot in Great Britain is imposed, the British Proof Authority may revise its proof test procedure, taking into account any input from the CIP.

We are opposed to current restriction proposals.

It is our view that lead ammunition can continue to be used for most forms of target shooting where risks are appropriately and proportionately controlled through the application of existing directives and regulations.

We do not believe that the evidence presented by the HSE justifies the restriction proposals as they stand.

The evidence presented in the dossier of risk from lead ammunition to soil, soil organisms, plants and livestock is not conclusive. Furthermore, there are existing regulations and directives that are retained in UK law which address these factors, including:

• Regulation 1881/2006 that limits lead in food for human consumption (agricultural production),
• Regulation 1275/2013 that limits lead in animal feed, and
• DIRECTIVE 2002/32/EC on undesirable substances in animal feed

We therefore consider further restriction unnecessary and disproportionate.

BASC will be making the case that the proposed restrictions are not justified by the evidence presented and are therefore not required through scrutiny and challenge panels, and the ongoing public consultation.

We will be seeking to avoid any unjustified restriction and providing alternative proposals for how evidenced risks can be controlled without banning the use of lead ammunition for target shooting.

We accept that there is an evidenced risk to human health. This, alongside consumer demand, is part of the reasoning behind a move to all game meat being sourced from lead-free supply chains.

We consider elements of HSE’s justification of restricting the use of lead ammunition for live quarry shooting as valid.

However, as with the use of lead shot for live quarry shooting, we will seek to influence any restriction proposals so that they are balanced against the identified risk and come with realistic transition periods. This will be done through scrutiny and challenge panels and the ongoing public consultation.

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.

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.

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

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.

There is a body of evidence presented in the restriction dossier about the impacts of lead on human health. Sub-lethal effects include neurotoxicity, kidney effects including renal disease and cardiovascular effects. Although the evidence does not directly or solely attribute lead ammunition as a cause, either through primary or secondary exposure. Lead is a ‘zero-threshold’ neurotoxin, which evidence show has impacts on the IQ of children and ‘in-utero’ impacts on the developing foetus.

Dietary exposure to lead in game meat is an exposure pathway for humans, and it is clear from the evidence presented by HSE that existing meat processing practices cannot eliminate all lead contamination from game meat. It is for these evidenced reasons that HSE are seeking to eliminate the risk of lead contamination in game meat reaching the human food chain.

The size of ammunition used means that HSE do not consider primary exposure of lead rifle ammunition to birds to be a risk.

We do not consider the evidence presented by HSE in the restriction dossier of secondary exposure to birds from lead ammunition to be conclusive. Based on the presented evidence, we do not consider restrictions related to this potential exposure pathway to be necessary or proportionate.

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 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.

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.

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 shotgun and large calibre rifle lead ammunition even after any law is passed. There would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as lead shot 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 HSE suggests that such a scheme will be considered during the consultation process.

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.

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

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.

Based on the proposals, there would be at least 18 months in which to use up shotgun and large calibre rifle lead ammunition even after any law is passed. There would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as lead shot 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 HSE suggests that such a scheme will be considered during the consultation process.

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.