Lead in shot, bullets and fishing weights

Lead has been commonly used in ammunition for hunting and sports shooting and in fishing tackle for centuries. It is estimated that each year around 100 000 tonnes of lead is dispersed into the EU environment from these uses: 79 % from sports shooting, 14 % from hunting and 7 % from fishing activities.

The use of lead ammunition or fishing tackle containing lead is known to cause lead poisoning of wildlife, such as birds. People’s health may also be affected by the residual lead present in game killed using lead ammunition, or when making lead ammunition or fishing sinkers or lures at home.

If the current releases of lead from these activities continue, approximately 1.9 million tonnes of lead would be released to the environment over the next 20 years.

What are the concerns?

Lead is a substance toxic to people and wildlife.

Only a very small proportion of lead gunshot fired will hit its target. The remainder of this ‘spent’ lead gunshot spreads into the environment where it can be ingested by birds that mistake it for food or for small stones that they eat to help them grind food in their gizzards. Ingestion of spent lead gunshot is well known in many species of waterbirds, for example, ducks, geese and swans. Lead fishing tackle is also frequently lost during use and affects birds in the same way as lead gunshot and bullets, if ingested. In addition, some contemporary fishing practices encourage the deliberate release of lead sinkers to water (called ‘dropping the lead’).

After ingestion, lead gunshot, sinker or lure is rapidly ground down into small particles, which speeds up the absorption of lead in the birds’ bloodstream. In some cases, this can result in death or in sublethal effects. Ingestion of a single lead gunshot is enough to kill a small waterbird. This route of exposure is called primary poisoning.

In addition, scavenging or predatory animals (including birds) inadvertently eat fragments of lead that are in the tissues of their food. This includes cases where lead fragments are present in the discarded internal organs of large game left behind by hunters after ‘field dressing’. This is called secondary poisoning and is also known to frequently cause lead poisoning in wildlife.

ECHA estimates that at least 135 million birds are at risk of lead poisoning throughout the EU.

Health risks to people

Exposure to lead is associated with a wide range of negative health effects, including reduced fertility, cardiovascular diseases, developmental effects in babies and children, damage to organs through prolonged or repeated exposure and cancer. Lead is especially harmful to children's neurological development. ECHA estimates that in any given year about one million children are vulnerable to the toxic effects of lead due to game meat consumption.

People are exposed to lead mainly through two routes: inhalation and ingestion. Hunters and sports shooters can breathe in lead fumes and dust while shooting. Hunters and fishers can also inhale toxic fumes if they melt lead to prepare homemade bullets and fishing tackle. Such activity may also put other members of the household at risk.

Exposure to lead through ingestion happens while eating game meat hunted with lead ammunition. Recent research suggests that game hunted with lead ammunition can contain microscopic fragments of lead, which cannot be removed during the preparation of meat. The practice of ‘cutting away’ and discarding meat from around the wound channel, or removing visible lead fragments, is not sufficient to remove all lead. Ingestion may also happen through hand-to-mouth exposure when manipulating lead gunshot, projectiles or fishing sinkers and lures.

Based on the clinical evidence of risks to children and pregnant women, the European Food Safety Authority (EFSA) has recommended that exposure to lead from both dietary and non-dietary sources should be reduced.

Any reduction of lead exposure through food will reduce risks to people’s health, particularly for children and adults who regularly eat game meat. Several food agencies in EU Member States already advise their citizens to eat game hunted with lead in moderation. For example, the French Agency for Food, Environmental and Occupational Health and Safety (ANSES) advises the general public not to eat game killed with lead ammunition more than three times a year and that children and pregnant women should not eat game meat hunted with lead ammunition at all.

There is no evidence that eating fish caught with lead tackle will result in exposure to lead.

 

Alternatives to lead

Restricting lead-based ammunition is nothing new. Many EU Member States, or regions within Member States, already have bans for certain kinds of ammunition in place. Experience from those countries has shown that hunters and sports shooters have been able to adapt to using alternatives without significant problems in relation to ricochet or safety.

Studies show that the effectiveness of non-lead bullets (in large calibres) is the same as for lead bullets and that ethical hunting can be ensured with lead-free alternatives.

Steel gunshot

The effectiveness of steel 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 typical range used for hunting. 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.

Current prices for steel and lead gunshot are comparable.

Bismuth and tungsten gunshot

Bismuth or tungsten-based gunshot can also be used as alternatives to lead gunshot. They can be used in any shotgun, including vintage shotguns that may not be suitable for use with steel gunshot.

Bismuth and tungsten-based gunshot cartridges are currently about four to five times more expensive than lead gunshot cartridges. They are also likely to remain more expensive than lead (and steel) gunshot cartridges as they are produced, sold and used in far lower volumes.

Rifle ammunition

Non-lead rifle ammunition is available on the European market in a wide range of calibres suitable for most European hunting situations. At least 13 major European companies make non-lead bullets for different rifle calibres.

To summarise, lead-free bullets can be purchased at slightly higher costs, but the price increase is not expected to restrict hunting or sports shooting activities.

Fishing sinkers and lures

Multiple alternatives are also available to lead sinkers and lures, such as those made with tin, tungsten, glass or various alloys.  

 

Will existing shotguns and rifles need to be replaced?

The available evidence, including from major shotgun manufacturers, suggests that standard steel shot can be used in most standard proofed shotguns. Bismuth and tungsten loads can 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 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.

Information from manufacturers and guidance from hunting associations have shown that hunters who want to switch to large calibre non-lead rifle ammunition do not need to purchase new guns.

 

ECHA's proposed restriction

In July 2019, the European Commission requested ECHA to investigate the use of lead in ammunition and in fishing and propose restrictions, where needed. The request is complementary to the restriction on the use of lead gunshot in wetlands. The scope of the investigation was the following:

Hunting:

  • Hunting with gunshot (outside of wetlands)
  • Hunting with small calibre bullets
  • Hunting with large calibre bullets

Sports shooting:

  • Outdoor sports shooting with gunshot (outside of wetlands)
  • Outdoor sports shooting with bullets
  • Other outdoor shooting using air rifles/guns/pistols

Shooting with historical weapons:

  • Other outdoor shooting activities incl. muzzle-loaders, historical re-enactments

Fishing

  • Lead in fishing sinkers and lures
  • Lead in fishing nets, ropes and lines (where lead is embedded)

Military uses of lead ammunition, along with other non-civilian uses of lead ammunition such as by police and customs forces, are outside of the scope of the investigation. Indoor uses of lead ammunition are also excluded.

The Agency collected information to support its investigation through a call for evidence, which ran from October to December 2019. ECHA submitted the proposal on 15 January 2021.

Restriction proposal

After assessing all the uses of lead within the scope of the Commission’s request, ECHA concluded that there are risks from these uses to wildlife, livestock, the environment and human health that are not adequately controlled and which need to be addressed at EU level. This conclusion is consistent with the restriction on the use of lead gunshot in wetlands and other restrictions on lead.

Various options to address the risks were assessed in terms of their effectiveness and impact to society. The following restriction is proposed – divided by sectors of use:

Sector of use Proposed restriction option
Hunting
Hunting with lead gunshot (outside of wetlands) Ban on placing on the market and using (with a five-year transition period)
+ Obligation to inform consumers about the risk of lead and availability of alternatives at the point of sale (information obligation)
Hunting with small calibre lead bullets (<5.6 mm centrefire) Ban on using (with a five-year transition)
+ Information obligation
+ Obligation to label the product to inform consumers of the risks of lead and available alternatives (labelling obligation)
Hunting with large calibre lead bullets (>5.6 mm) Ban on using (with an 18-month transition)
+ Information obligation
+ Labelling obligation
Outdoor sports shooting and shooting with historical weapons
Sports shooting with lead gunshot

PREFERRED OPTION: Ban on placing on the market and using (with a five-year transition)
+ Information obligation

COMPLEMENTARY OPTION: Conditional derogation under strict conditions
+ Labelling obligation
+ Reporting obligation for Member States to allow the Commission to monitor the use of lead gunshot

Sports shooting with lead bullets and with air rifles, guns or pistols
Ban on using unless there are bullet traps at the shooting location (with transition periods depending on the calibre size:
  • Small calibre: five years
  • Large calibre: 18 months)
+ Information obligation
+ Labelling obligation
Shooting with historical weapons e.g. muzzle-loaders and historical re-enactments
Fishing
Lead in fishing sinkers and lures
Ban on placing on the market and using (with transition periods depending on the type and weight:
  • Sinkers and lures ≤ 50 g: three years)
  • Sinkers and lures > 50 g: five years)
  • Wire: no transition period)
+ Ban on the use with drop off techniques (no transition period)
+ Information obligation
Lead in fishing nets, ropes and lines No restriction proposed


The aim of the proposed restriction is not to ban hunting, sports shooting or fishing.

The Agency acknowledges that, for example, hunting provides significant social, cultural, economic and environmental benefits in different regions of the EU and recognises its role in nature conservation.

The proposed restriction is estimated to reduce lead emissions by approximately 1.5 million tonnes over 20 years following its introduction. This is a reduction of 78 % compared to a situation without the proposed restriction.

Additionally, restricting lead in the way suggested by ECHA would protect the children of households that very frequently eat game meat. It is assumed that banning large-calibre bullets and lead gunshot could avoid IQ loss in up to 7 000 children per year. 

According to ECHA’s analysis, the total cost of the restriction is estimated to be up to EUR 12 billion over 20 years following the entry into force. The cost to society of avoiding the release of one kilogram of lead to the environment ranges between EUR 0.5 and EUR 1 513.

A six-month consultation on the proposal started on 24 March 2021. During the consultation, all stakeholders can provide their arguments supporting or against the proposal. These third-party arguments can change the proposal if they are backed by robust scientific evidence. 

 

Committee opinions

ECHA’s Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) have 12 months to evaluate the strengths and weaknesses of the proposal and adopt their opinions. In their opinions, they take into account the comments received during the consultation. The draft opinion of SEAC will be subject to a further 60-day consultation before it is adopted.

The consolidated opinion of both RAC and SEAC on the restriction proposal is expected by mid-2022.

 

Decision by the European Commission and EU Member States

Once the scientific evaluation of the proposal is done, the Commission is expected to prepare its legislative proposal following ECHA’s report and the committees’ combined opinion. The Commission’s proposal to amend the list of substances restricted under Annex XVII to REACH will be submitted to a vote by the EU Member States in the REACH Committee.

Before any restriction can be adopted, it is scrutinised by the European Parliament and the Council.

 

Restriction on the use of lead gunshot in wetlands

In January 2021, the European Commission adopted a restriction on the use of lead gunshot in wetlands across the EU. It will apply from 15 February 2023 onwards in all 27 EU Member States. This restriction also allows Member States to ban lead gunshot in all areas if 20 % or more of the country’s territory is wetlands. In this case, the restriction applies from 15 February 2024.

This EU-wide restriction harmonises the national legislation already in place in various forms in 23 EU Member States and introduces new legislation in four EU Member States. It also implements the international agreement (AEWA) to protect wetland birds in the EU.

It is expected that restricting lead gunshot in wetland areas will protect the environment by significantly reducing lead pollution and will prevent the avoidable death by lead poisoning of around one million waterbirds every year.

The restriction is based on the scientific work of ECHA and its Committees for Risk Assessment and Socio-Economic Analysis. ECHA submitted its proposal (Annex XV dossier) for evaluation in April 2017. In August 2018, the opinions of ECHA’s scientific committees on the proposal were ready and sent to the European Commission.

Podcast interviews with stakeholders

We interviewed representatives from different organisations during an event organised by ECHA where stakeholders shared their views on a potential restriction on the use of lead in ammunition for hunting and sports shooting.

Ruth Cromie - Wildfowl and Wetlands Trust (WWT)
 

 

Niels Kanstrup - Danish Hunting Academy
 

 

Nina Mikander - African-Eurasian Migratory Waterbird Agreement (AEWA)
 

 

David Scallan - European Federation for Hunting and Conservation (FACE)
 

 

Hans Steinkellner - European Food Safety Authority (EFSA)
 

 

Philip Taylor - ELEY Limited (Ammunition manufacturer)
 

 

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 15 January 2021
Consultation of the Annex XV dossier (if conformity is passed) 24 March 2021 24 September 2021
RAC opinion, draft SEAC opinion March 2022
Consultation on draft SEAC opinion Q2 2022
Combined final opinion  June 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 Q1/Q2 2023
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) Q3/Q4 2023