Lead in shot, bullets and fishing weights

Lead in shot, bullets and fishing weights - lead text

Lead has been used in ammunition for hunting and sports shooting and in fishing tackle for centuries. It is estimated that around 44 000 tonnes of lead are dispersed into the EU environment from these uses each year: 57 % from sports shooting, 32 % from hunting and 11 % from fishing activities.

The use of 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 876 000 tonnes of lead would end up in the environment over the next 20 years. 

ECHA has proposed a restriction on lead use in hunting, sports shooting and in fishing.  The proposed restriction could reduce lead emissions by approximately 630 000 tonnes over 20 years following its introduction. This is a reduction of 72 % compared to a situation without the proposed restriction. 

 

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 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. A six-month consultation was held from 24 March until 24 September 2021. ECHA received 319 comments from individual people and organisations. As a result of ECHA’s analysis of these comments, some elements of the restriction proposal have been revised.

In summary, the proposed restriction is the following:

  1. Lead in hunting, sports shooting and other outdoor shooting:
    • sale and use of lead gunshot: ban after a five-year transition period. As current rules of international competitions specify the use of lead ammunition for certain disciplines, ECHA presents - as an option for the decision maker - a derogation for use of lead gunshot for sports shooting by licensed individuals only under strict conditions, i.e. when releases to the environment are minimised; and
    • use of lead in bullets and other projectiles:
      • for hunting: ban after a five-year transition period for small calibre bullets and 18 months for large calibre bullets. The technical feasibility of alternatives to small calibre lead bullets should be reviewed before the ban enters into force.
        Derogations are proposed for using lead in bullets for seal hunting and in full metal jacket bullets. For seal hunting, the user needs permission from the Member State to hunt seals. Use of full metal jacket bullets also needs to be allowed in the relevant Member State.
      • for sports shooting: use can continue if releases to the environment are minimised within a five-year transition period. This means that sports shooting ranges are equipped either with trap chambers or ‘best practice’ sand traps.
  2. Lead in fishing:
    • ban on the sale and use of lead sinkers and lures (with transition periods depending on weight: ≤ 50 g three years; > 50 g five years);
    • immediate ban on the sale and use of lead fishing wire; and
    • immediate ban on the use of lead sinkers when the sinker is deliberately released (lead ‘drop off’ techniques).
  3. The restriction proposal does not cover military or other non-civilian uses of lead ammunition, such as use by police and customs forces. Indoor uses are also excluded.

The proposed restriction is estimated to reduce lead emissions by approximately 630 000 tonnes over 20 years following its introduction. This is a reduction of 72 % compared to a situation without the proposed restriction. The restriction will significantly reduce the risk of wildlife poisoning, including endangered species.

Additionally, the proposed restriction would protect the children of households that very frequently eat game meat. It is assumed that banning large calibre bullets and lead gunshot in hunting could avoid IQ loss in about 7 000 children per year. 

The total cost of the restriction is estimated to be in the order of EUR 12 billion over 20 years following its entry into force. The cost to society of avoiding the release of one kilogram of lead to the environment ranges between EUR 1 and EUR 525 for the different uses assessed.

 

Committee opinions and decision by European Commission

ECHA’s Committee for Risk Assessment (RAC) adopted its opinion on the restriction proposal in its meeting in May/June 2022. It supported the proposal while recommending a shorter transition time to phase out lead gunshot for hunting. You can read more about RAC's opinion here.

The Committee for Socio-Economic Analysis (SEAC) adopted its opinion in its meeting in November/December 2022. At the same time, RAC adopted a supplementary opinion on the proposed restriction taking into account comments and supporting evidence submitted by interested parties on specific data concerning game meat intake and lead concentrations in game meat provided by the European Food Safety Authority (EFSA).

The opinions of both committees will be sent to the European Commission at the start of 2023.

Decision by the European Commission and EU Member States

Once the scientific evaluation of the proposal is completed, the Commission is expected to prepare its legislative proposal. 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.

 

What are the concerns?

Lead is 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 is released 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 digest their food. Ingestion of spent lead gunshot is well known in many species of birds leading to lead poisoning. Ingestion of a single lead gunshot pellet is enough to kill a small waterbird. This route of exposure is called primary ingestion.

Lead fishing tackle is also frequently lost during use and can poison birds in the same way as lead gunshot and bullets, if ingested. Some contemporary fishing practices encourage the deliberate release of lead sinkers to water (called ‘dropping the lead’).

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’ or where predatory animals eat animals that have been wounded with lead ammunition or those shot for pest control. This is called secondary ingestion and is also known to frequently cause lead poisoning in wildlife.

ECHA estimates that at least 135 million birds are currently at risk of lead poisoning each year from primary ingestion of lead gunshot. Additionally, 14 million birds (including birds of prey) are at risk of poisoning from secondary ingestion and 7 million from the ingestion of lead fishing tackle.

Furthermore, spent lead projectiles from sports shooting can contaminate the soil and water in and around the shooting ranges leading to different kinds of risks. One example is poisoning of cattle or poultry if the shooting area is used for agriculture. 


Health risks to people

Exposure to lead is associated with a wide range of negative health effects, including neurodevelopmental effects in foetuses, babies and small children, cardiovascular diseases, impaired renal function (including chronic kidney disease), hypertension, impaired fertility and adverse pregnancy outcomes.

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. Game meat 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 the lead that is present. Ingestion may also happen through ‘hand-to-mouth’ exposure when manipulating lead 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 pregnant women who regularly eat game meat. Several food agencies in EU Member States already advise their citizens to only 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.

Frequently asked questions


>> Check also the Q&A document on the opinions of RAC and SEAC <<
 

1. Have you considered the effect of the proposed restriction on supply of lead ammunition for non-civilian (military) uses?

The restriction proposal does not cover military or other non-civilian uses of lead ammunition, such as use by police and customs forces. Nevertheless, comments received in the consultations indicate that there could be indirect impacts on the supply of lead ammunition for these uses. This is because lead ammunition production lines are reported to be shared between civilian and non-civilian uses, and civilian production lines capable of producing lead ammunition need to be available in case of sudden increases in demand (e.g. a conflict situation).

This aspect has been analysed by SEAC. It concluded that the proposed restriction is not expected to have an impact on the production of ammunition for military and other non-civilian uses.

Ammunition manufacturers already supply both non-lead and lead ammunition. The restriction would allow production lines for civilian uses of lead ammunition to continue, as, under the conditions of the proposed restriction, sports shooting with bullets (with an annual use volume of 42 000 tonnes) can continue. It can be expected that production of lead bullets will still be economically viable. The decrease in demand for lead bullets for hunting (with an annual use volume of 134 tonnes) will only lead to a small – if any – loss in profits generated from these lines.

Therefore, any surge in defence orders in times of crisis could be accommodated based on existing lines, and supply to the military would not be affected by the proposed restriction.

It should be noted that this conclusion is based on the assumption that the implementation of the proposed restriction will not cause a significant decrease in the volume of lead used for bullets in sports shooting.

It should also be noted that EU Member States may allow exemptions, when necessary, in the interest of national defence. This is based on Article 2(3) of the REACH Regulation, which states: “Member States may allow for exemptions from this Regulation in specific cases for certain substances, on their own, in a preparation or in an article, where necessary in the interests of defence.”

2. Are there alternatives to lead? What are those alternatives?

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. Lead-free alternatives are also available for fishing tackle.

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 larger species of birds, such as geese, shotguns compatible with ‘high-performance’ steel cartridges might be required.

Available evidence and experience from countries where restrictions on lead ammunition are already in place show that steel gunshot can also be used in clay target shooting.

Research shows that ricochet occurs when both steel and lead gunshot are used. 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.

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.

Even though non-lead alternatives exist, are being used and are commercially available throughout the EU for many uses, lead is currently difficult to replace in a number of applications, such as in rimfire ammunition (specifically .22 LR), airgun ammunition, ammunition for muzzle loading rifles, and certain non-expanding ammunition used for hunting (including full metal jacket and open tip match bullets). Therefore, the proposed restriction suggests a review of the technical feasibility of small calibre lead bullets before the ban on use in hunting enters into force and derogations for using lead in bullets for seal hunting and in full metal jacket bullets for hunting - where these uses are allowed by Member States.

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. 

3. If the restriction is adopted, will hunters need to replace their weapons? 

In the majority of cases, no. The available evidence, including from major shotgun manufacturers, suggests that the majority of existing shotguns will not need to be replaced. Standard steel shot can be used in most standard proofed shotguns. More energy per pellet is needed to hunt geese and birds of a similar or larger size, 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. Bismuth and tungsten loads can be used in any shotgun.

Individual hunters might have to invest in new equipment, although many hunters already own at least one shotgun that is suitable to use standard steel shot.

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. For small calibres, a switch to non-lead rifle ammunition may require replacing some guns or gun barrels to ensure a compatible ‘twist rate’, which is important for bullets to stay stable in-flight.    

4. What are the costs for hunters to switch from lead ammunition to non-lead ammunition?

According to available information, the extra cost for an individual hunter is less than EUR 30 per year for hunting with gunshot and less than EUR 10 per year for hunting with small or large calibre ammunition. These estimates include costs of switching to alternative ammunition and, where necessary, costs of testing, modification and premature replacement of guns.

5. What are the expected effects of the proposed restriction on hunting activity in general?

There could be a short-term drop in hunting activities as a result of the restriction, as hunters need to change their shooting practice and train with non-lead ammunition. SEAC reached this conclusion based on experience from the implementation of existing national regulations in place for lead ammunition.

6. When preparing game meat hunted with lead ammunition, why is it not enough to cut around the wound channel and remove the lead?

Game hunted with lead ammunition can contain microscopic fragments of lead, which cannot be removed. Concentrations of lead are greatest immediately surrounding the wound channel but can also be detected in a radius of up to 30 cm from the wound depending on the bullet type, resistance and velocity upon impact. The practice of ‘cutting away’ or removing visible lead fragments is not sufficient to remove all the lead.

Based on the assessment of EFSA’s data and the scientific literature, RAC concluded in line with ECHA (as the dossier submitter) that there is a moderate to high risk for infants and toddlers in hunter families that eat game meat hunted with lead ammunition. Risk of harm to the development of an unborn child’s nervous system during pregnancy is also considered relevant, since there is no safe threshold for the developmental neurotoxicity of lead. For adults, ECHA and RAC concluded that the risks from eating game meat are likely to be low.

RAC evaluated the representativeness and reliability of EFSA’s data as part of their scientific evaluation of the proposal. RAC noted that EFSA's dataset is likely to underestimate lead concentrations in small game meat and this may result in an underestimation of the total health impacts in children.

RAC also evaluated the influence of a small number of samples in EFSA's dataset for large game with very high lead concentrations, which stakeholders considered to be unrealistic. RAC agreed that as the risk assessment used the ‘distribution’ of all of the available data, rather than the mean value of the data, the conclusions of the risk assessment were not influenced by these high values and the conclusions of the assessment would not change if the high values were excluded. RAC agreed that the conclusions were also robust when different assumptions about the amount of game meat consumed by children and adults were made.     

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.

7. What are the measures proposed for shooting ranges to manage the risks of lead and to allow continued use of lead bullets?

The proposal allows shooting with lead bullets and air rifles to continue when the shooting range is equipped with minimum standard risk management measures including trap chambers or ‘best practice’ sand traps. The range location would also need to be notified to the national authorities and have no agricultural uses within the boundary of the site. Minimum standard risk management measures would have to be in place five years after the restriction enters into force.

A trap chamber is normally made of metal and is a fully enclosed structure preventing any lead emissions to soil. ‘Best practice’ sand traps have a roof and a water impermeable barrier between the base of the sand trap and the underlying ground to protect the soil, combined with a water management system for the containment, monitoring and, where necessary, treatment of run-off water or site drainage.

The conditions proposed have been evaluated by RAC to be effective in minimising the risks of lead pollution.

8. What are the expected impacts of the proposed risk management measures on the availability of shooting ranges?

SEAC considers that the need to upgrade the risk management measures at shooting ranges, and the impacts of such upgrading, may differ from region to region depending on existing regulations and standards already in place. For example, the existing rules in Germany seem to fulfill the standards of the proposed restriction to a large extent. However, shooting ranges in other regions, e.g. in the Nordic countries, could be more affected. It should be noted that the proposed restriction has a five-year transition period, which the committee considers appropriate for allowing shooting ranges to implement the required risk management measures.

Military ranges (those used by military only) are not included in the restriction proposal. However, local civilian ranges used by reserve soldiers to train are in scope and would need to fulfill the requirements.

In the interest of defence, individual Member States may use REACH Article 2(3) to exempt the activity from the scope of the proposed restriction. This article states: “Member States may allow for exemptions from this Regulation in specific cases for certain substances, on their own, in a preparation or in an article, where necessary in the interests of defence.

9. How can lead on outdoor shooting ranges contaminate groundwater?

Metallic lead can dissolve in water, e.g. during rain. The reaction is more severe if the water is acidic or low on minerals. Once dissolved, metal compounds can be transported from one location to another and, eventually, contaminate groundwater.

Dissolved lead is also bioavailable meaning that it can easily be absorbed by wildlife resulting in adverse effects. Dissolution of lead is similar to how table salt (sodium chloride) dissolves in water: When sodium and chlorine are ionised in water, the salt is no longer solid.

10. Can REACH restrictions apply to consumers?

It is possible for the REACH Regulation to limit uses of substances and mixtures by consumers. There are several examples of existing restrictions that impact consumer uses:

  • The discharge and carrying of lead gunshot in and around wetlands are restricted from February 2023 (entry 63 of the list of substances restricted under REACH).
  • Lead carbonate and sulphates must not be used in paint (entries 16 and 17)
  • Carcinogenic, mutagenic, reprotoxic substances must not be used in mixtures for supply to the general public. This example is similar to the situation in the proposed restriction where lead ammunition may be placed on the market legally but there are restrictions on its use (entries 28 to 30).
  • Nonylphenol and nonylphenol ethoxylates must not be used as substances or in mixtures for e.g. domestic cleaning (entry 46).   
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, which adopted the restriction in January 2021.

 
 

Planned timetable for restriction proposal for lead in outdoor shooting and fishing

 

Future timings are tentative

  Lead in outdoor shooting and fishing
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  24 March 2021 24 September 2021
RAC opinion, draft SEAC opinion May/June 2022
60-day consultation on draft SEAC opinion 29 June - 29 August 2022
Consultation on EFSA's data on game meat intake and lead concentrations in game meat 6 July - 6 October 2022
RAC supplementary opinion Nov/Dec 2022
SEAC opinion Nov/Dec 2022
Combined final opinion of both committees Q1 2023
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions
Discussions with Member State authorities and vote To be confirmed
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) To be confirmed