Lead in shot, bullets and fishing tackle

Lead has been commonly used in ammunition and fishing tackle for decades. It is estimated that around 21 – 27 000 tonnes of lead is dispersed into the EU environment per year from these uses.

The use of lead gunshot and lead bullets or fishing tackle containing lead, is known to cause lead poisoning of wildlife, such as birds. Human health may also be affected by the residual lead present in game killed using lead ammunition. 

 

Restricting lead in ammunition and fishing tackle under REACH – previous and current activities
ECHA’s work on lead in ammunition and fishing tackle has been ongoing for several years and can be separated into three work packages. 
 

1. In December 2015, the European Commission requested ECHA to undertake an investigation into the risks posed by the use of lead gunshot in wetlands and, if needed, prepare a proposal for a restriction. 

  • April 2017 – ECHA concluded that the use of lead gunshot in wetlands posed a risk that was not adequately controlled and published its proposal for a restriction.
  • June 2018 – ECHA completed its work on the wetlands proposal with the adoption of the opinion of ECHA’s scientific committees for risk (RAC) and socio-economic analysis (SEAC) on the proposal. 
  • The proposal is now being considered for decision by the Commission.
 

2. In September 2018, ECHA published an investigation report recommending that further measures to regulate the use of lead in ammunition and fishing tackle should be taken.

 
3. In July 2019, the Commission requested ECHA to undertake an investigation with the following scope and propose restrictions, where needed:
  • Lead used in gunshot for hunting birds and other animals (e.g. rabbits) in terrestrial areas (i.e. outside of wetlands).
  • Lead used in gunshot for outdoor sports shooting, including training (i.e. clay pigeons).
  • Lead used in bullets for hunting any animal.
  • Lead used in bullets for outdoor sports shooting, including training (i.e. targets).
  • Lead used in fishing tackle (weights, lures, jigs) for recreational fishing.
  • Lead used in commercial fishing gear.
 
Military uses of lead ammunition, along with other non-civilian uses of lead ammunition such as by police, security and customs forces, are outside of the scope of the investigation. Indoor uses of lead ammunition are also excluded from the scope of the investigation.
 
ECHA is gathering information to support its investigation through a call for evidence, which runs from 3 October 2019 to 16 December 2019. Following ECHA’s investigation into the evidence, a possible restriction dossier can be expected in October 2020.

 

What is lead poisoning in wildlife and how does it occur?

Only a very small proportion of lead gunshot fired will hit its target. The remainder of this ‘spent’ lead gunshot is dispersed into the environment where it can be inadvertently ingested by birds who mistake it for food or for the small stones that they eat to help them to grind food in their gizzards. Ingestion of spent lead gunshot is well known in many species of waterbirds (e.g. ducks, geese and swans) and has also been reported in other species of birds. 

After ingestion, lead gunshot is rapidly ground down into small particles (by the gizzard), which increases its bioavailability. Absorption of lead in the digestive tract can result, in some cases, in death or in sublethal adverse effects. Ingestion of a single lead gunshot is sufficient to result in the death of a small waterbird.

In addition, scavenging or predatory species (such as birds of prey) inadvertently consume fragments of lead that are present in the tissues of prey (after previously being wounded with lead gunshot) or in the internal organs of large game (e.g. deer) that are discarded after the ‘field dressing’ of carcasses. This route of exposure is called ‘secondary poisoning’ and is also known to frequently result in lead poisoning of wildlife. 

5 000 tonnes of lead gunshot are currently estimated to be released into EU wetlands each year through hunting and sports shooting. This was estimated by ECHA to result in the unintentional deaths, through lead poisoning, of approximately one million waterbirds each year throughout the EU. 

In addition, around 14 000 tonnes of lead shot are estimated to be dispersed into terrestrial environments per year. This dispersion is currently estimated to result in the unintentional deaths of an additional one to two million birds each year. 

A further 2 000 to 6 000 tonnes of lead are released to the aquatic environment from fishing weights.

 

What are the health risks to humans?

Exposure to lead is associated with a wide range of negative health effects, including reduced fertility, developmental effects in babies and children, damage to organs through prolonged or repeated exposure and cancer. Lead is especially detrimental to children's neurological development. Current evidence suggests that there is no safe level of lead consumption.

Based on the risk of clinically important effects in infants, children and pregnant women, the European Food Safety Authority has previously (EFSA 2010) recommended that exposure to lead from both dietary and non-dietary sources should be reduced. 

Recent research suggests that game shot with lead ammunition can contain microscopic fragments of lead, which cannot be removed during preparation. The practice of ‘cutting away’ and discarding meat from around the wound channel, or removing embedded lead fragments, is not sufficient to remove all the lead present in the meat. 

Any reduction of dietary lead exposure will reduce the human health risks, particularly for children and adults who regularly eat game meat. Several food agencies in EU Member States advise citizens to consume game shot with lead in moderation, including the French Agency for Food, Environmental and Occupational Health and Safety (ANSES), who advise the general public not to consume game killed with lead ammunition more than three times per year, and for children and pregnant women not to consume game killed with lead at all.

There is no evidence that consuming fish caught with lead tackle will result in dietary exposure to lead. However, the practice of ‘home-casting’ lead-containing fishing tackle has recently gained popularity as a do-it-yourself activity among some fishers. If undertaken without the appropriate personal protective equipment or ventilation, it risks exposure to lead-containing fumes and dusts. Such activity may also result in a risk to other members of the household, for example due to insufficient ventilation or misplacement of the contaminated equipment.

 

Are there alternatives to lead in ammunition and fishing tackle?

The restriction of lead-based ammunition is not a new phenomenon. Many EU Member States, or regions within Member States, already have bans in place. Experience from those countries where a ban is already in place has shown that hunters and sports shooters have been able to adapt to using alternatives without significant problems in relation to ricochet and safety issues.
 
The effectiveness of steel (soft iron) gunshot has improved significantly since its introduction. Field studies have shown that hunters using steel gunshot can achieve the same results as with lead gunshot. The effective shooting distance for modern steel gunshot is consistent with the range at which hunting for wildfowl is typically undertaken. However, for some species of larger waterfowl, such as geese, shotguns compatible with high-performance steel cartridges might be required.
 
Research shows that ricochet occurs in both steel and lead gunshot. Experience from Denmark as well as research from Germany indicates that there is no increase in the risk of accidents or injuries from ricochet when using steel gunshot compared to lead.
 
Bismuth or tungsten based gunshot can also be used as alternatives to lead and have the advantage that they can be used in any shotgun, including vintage shotguns that may not be suitable for use with steel.
 
Studies show that the effectiveness of non-lead bullets is the same as for lead bullets. Furthermore, studies have shown that quick and ethical kills of animals in hunting activities can be ensured with lead-free alternatives alike.
 
Non-lead rifle ammunition is available on the European market in a wide range of calibres suitable for most European hunting situations. As indicated in ECHA’s investigation report, at least 13 major European companies make non-lead bullets for different rifle calibres. Field studies in Germany have demonstrated that using lead-free ammunition can be as effectives as hunting with ammunition that contains lead. 
 
New developments in fishing tackle have also shown that there are alternatives to lead weights and sinkers that are now more available.

 

Are the alternatives more expensive?

Lead-free gunshot cartridges are suitable for all types of hunting and shooting and are widely available in the EU. 

Current prices for steel and lead gunshot are comparable. Bismuth and tungsten-based gunshot cartridges, which are currently produced, sold and used in far lower volumes, are about four to five times more expensive than lead gunshot cartridges, and are likely to remain more expensive than lead (and steel) gunshot cartridges.
 
Research has shown that lead-free bullets can be purchased at slightly higher costs, but that this price increase is not expected to be prohibitive.

 

Will existing shotguns and rifles need to be replaced?

The available evidence, including from major shotgun manufacturers, suggests that while there may be limited cases where existing shotguns would need to be replaced, standard steel shot can be used in any standard proofed shotguns. Bismuth and tungsten loads, although more expensive, can feasibly be used in any shotgun.

Hunters using steel gunshot need to apply the ‘rule of two’ and select two shot sizes smaller to have the equivalent energy as to lead per pellet. For hunting geese and birds of similar or larger size, more energy per pellet is required and this may require the use of ‘high-performance’ steel gunshot cartridges. Unless marked with ‘fleur-de-lis’, it is recommended to check with a gunsmith whether a shotgun is compatible with high-performance steel gunshot cartridges.

Evidence suggests that, similar to shotguns, most modern rifles have suitable alternative ammunition available.

 

ECHA’s proposal to restrict the use of lead gunshot in wetlands

This proposed restriction is for a ban on the use of lead gunshot in wetlands across the EU. An EU-level measure would harmonise the national legislation that is already in place in various forms in 24 EU Member States and would introduce new legislation in four EU Member States.

The restriction proposal (Annex XV dossier) was submitted in April 2017 and in August 2018, ECHA sent the opinion of its scientific committees on the proposal to the European Commission.

The opinion recommended that a restriction is justified on lead in shot used in wetlands to reduce the large-scale exposure of numerous wetland dependent bird species to lead by ingestion of spent lead pellets. It estimated that approximately one million wetland birds die in the EU from lead poisoning every year despite existing legislation in many Member States and an international agreement (AEWA) to protect wetland birds.

AEWA also requires that use of lead gunshot should be phased out in wetlands. The restriction was needed to implement an existing AEWA commitment and harmonise legislation across the EU.

The Commission is preparing its proposal following ECHA committees’ opinion. The Commission proposal to amend Annex XVII to REACH will be submitted to a Member State vote in the REACH Committee, followed by a period of scrutiny by the European Parliament and the Council.

Planned timetable for restriction proposal for lead in shot in terrains other than wetland, other ammunition and fishing tackle

 

Future timings are tentative

  Lead in shot in terrains other than wetland, other ammunition and fishing tackle
Intention to prepare restriction dossier 3 October 2019
Call for evidence 3 October 2019 –
16 December 2019
Submission of restriction dossier 6 October 2020 (expected)
Public consultation of the Annex XV dossier (if conformity is passed) December 2020
RAC opinion September 2021
Draft SEAC opinion September 2021
Public consultation on draft SEAC opinion September 2021 –
November 2021
Combined final opinion submitted to the Commission January 2022
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions
Discussions with Member State authorities and vote Spring/summer 2022
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) End of 2022