Lead in shot, bullets and fishing weights

Lead has been widely used for decades in hunting, sports shooting and fishing. Yet, we know that it is a toxic substance for humans and wildlife. Hunting and shooting with lead gunshot or lead bullets, or fishing with lead sinkers has toxic effects on ecosystems and can result in lead poisoning in wildlife in all habitats.

When lead gunshot falls to the ground or in water (that which doesn’t hit its target), many species of waterbirds, like ducks and geese, and other birds ingest it. They get poisoned after mistaking it for food or small stones that they use to help digest food.

An estimated 5 000 tonnes of lead are released into wetlands in the EU due to hunting and sports shooting each year. These uses of lead shot are believed to result in the deaths of approximately one million waterbirds each year throughout the EU. Around
14 000 tonnes of lead shot are estimated to be dispersed into terrestrial environments per year from lead shot and lead bullets and another 2 000-6 000 tonnes from fishing weights in the aquatic environment. This dispersion is estimated to result in the unintentional deaths of one to two million birds each year.

Wildlife is further at risk as ammunition residue, in the remains of game left behind by hunters, forms another source of lead poisoning in wild animals, especially in scavengers, such as large birds of prey.


What are the health risks to humans?

Exposure to lead is associated with a wide range of negative health effects. It can damage fertility or the unborn child, cause cancer, harm breastfed children and cause damage to organs through prolonged or repeated exposure. It is also very toxic to aquatic life with long-lasting effects. There is no safe level of consumption.

Recent research suggests that lead gunshot can disperse as widely as microscopic or nanoparticles in tissues. Cutting away from the wound of game meat is not sufficient to remove all the lead that humans would consume.

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 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 advises not to consume game shot with lead more than three times per year, and for children and pregnant women not to consume game shot with lead at all.


What is being proposed?

At the request of the European Commission, ECHA has finalised one dossier and is working on another dossier for restricting lead in gunshot:

  • restricting the use of lead gunshot in wetlands (dossier finalised by ECHA); and
  • restricting the use of lead in gunshot in terrains outside of wetlands, in other ammunition in any terrain (i.e. in bullets) as well as restricting the use of lead in fishing tackle (dossier being worked on by ECHA).


Lead gunshot in wetlands

This proposed restriction suggests adopting a new EU-level measure to ban the use of lead gunshot in wetlands. EU-level measures would harmonise the effectiveness of national legislation already in place in various forms in 24 EU Member States.

The restriction dossier (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 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.


Lead in shot in terrains other than wetland, other ammunition and fishing tackle

In September 2018, ECHA published an investigation report recommending further measures to regulate the use of lead ammunition in terrestrial environments in addition to those proposed for wetlands.

The report concluded that further measures would be needed to:

  • limit additional lead pollution in the environment;
  • reduce the mortality of between one and two million birds that inadvertently swallow the gunshot;
  • reduce the mortality of predators and scavengers on lead-poisoned birds in the terrestrial environment; and
  • lower health risks to a significant population of hunters and their families who frequently eat game meat killed with lead shot or bullets.

The report also highlights that the costs to individual hunters would be limited as alternative steel shot is available, can be used in most shotguns, and is not significantly more expensive as assessed in the lead in shot in wetlands proposal.

Following the publication of this report, the Commission requested ECHA to develop a restriction proposal addressing the risk associated with the following uses of lead:

  • 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 sports shooting, including training (i.e. clay pigeons).
  • Lead used in bullets for hunting any animal.
  • Lead used in bullets for sports shooting, including training (i.e. targets).
  • Lead used in fishing tackle (weights, lures, jigs) for recreational fishing.
  • Lead used in commercial fishing gear.

ECHA is gathering more information on this initiative 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.


Why is an EU-wide restriction justified?

In the EU, all but three Member States – Poland, Austria and Slovenia – have signed up to the African-Eurasian Waterbird Agreement (AEWA), which has been in place since 2000 and proposes to phase out the use of lead gunshot in wetlands. Several Member States have legislation that completely prohibits the use of lead gunshot, including the Netherlands, Belgium and Denmark. In other countries, partial bans are in place.

However, four Member States – Ireland, Poland, Romania and Slovenia – have not implemented any restriction on the use of lead shot. Since measures are not harmonised across the EU, the risks posed by the use of lead shot is not adequately controlled.

Since many of the birds prone to ingesting the lead shot are migratory, they can cross several Member States during their flights, so addressing this issue at EU level is the best solution.


Are there alternatives to lead?

The restriction of lead-based ammunition is not a new thing. Many EU Member States already have a ban in place – some even more stringent than what is being proposed. 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 modern 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, however, hunters may need to develop new skills to hunt with steel. The effective shooting distance for modern steel gunshot is consistent with the range at which hunting for wildfowl is typically done. 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. However, experience from Denmark has shown no increase in ricochet after the introduction of the ban on lead shot.

Bismuth or tungsten-based gunshot can also be used as alternatives to lead and can be used in any shotgun, including vintage shotguns.

Studies show that the effectiveness of non-lead bullets is the same as for lead bullets. Furthermore, quick and ethical kills of animals in hunting activities can be ensured regardless of the bullet material.

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.

New developments in fishing tackle have also shown that there are alternatives to lead weights and sinkers and that they are now more available.


Are the alternatives more expensive?

Current prices for steel and lead gunshot are comparable. Research on the retail prices of loose shot for hand loaders found no large difference (lead shot approximately EUR 3/kg, steel shot approximately EUR 4/kg). It can be expected that once there is greater demand for steel gunshot cartridges, the price may go down.

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 as well, but this price increase is not expected to be prohibitive.


Will hunters need to replace their guns?

Evidence, confirmed by major gun manufacturers, suggests that while there may be limited cases where guns would need to be replaced, standard steel shot can be used in standard proofed guns.

Hunters would 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 the gun is compatible with high-performance steel gunshot cartridges.

Lead-free gunshot cartridges are suitable for all types of hunting and shooting and are widely available in the EU. If ‘high-performance’ steel cartridges are needed, for example when hunting larger waterfowl, older shotguns may need to be modified or replaced.

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

Planned timetable for restriction proposals on lead in shot used in wetlands and terrestrial environments


Future timings are tentative

  Lead in shot used in wetlands Lead in shot in terrains other than wetland, other ammunition and fishing tackle
Intention to prepare restriction dossier 12 April 2016 3 October 2019
Call for evidence 18 April 2016 –
18 June 2016
3 October 2019 –
16 December 2019
Submission of restriction dossier 12 April 2017 6 October 2020 (expected)
Public consultation of the Annex XV dossier (if conformity is passed) 21 June 2017 –
21 December 2017
December 2020
RAC opinion 9 March 2018 September 2021
Draft SEAC opinion 15 March 2018 September 2021
Public consultation on draft SEAC opinion 21 March 2018 –
21 May 2018
September 2021 –
November 2021
Combined final opinion submitted to the Commission 14 June 2018 January 2022
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions Within 3 months of receipt of opinions
Discussions with Member State authorities and vote 2018-2019 Spring/summer 2022
Scrutiny by Council and European Parliament Before adoption (3 months) Before adoption (3 months)
Restriction adopted (if agreed) 2020 End of 2022