Lead ammunition consultation

As you will likely be aware, following on from the HSE consultation of 2022 in respect of lead ammunition, a second consultation was published in October 2023.  This consultation closes on 10 December 2023.  The overview of the consultation was published in the newsletter of 26 October 2023. 

At that time, we asked that you read the document as its impacts were potentially significant, not only for the types of ammunition we use but also the long-term sustainability of shooting.  The most impactful statement I have heard over the years of listening to the views on this matter was from an influential representative of the game dealing industry who quite simply said ‘Game dealers aren’t going to fill their freezers full of stock they can’t sell’.  If markets close due the non-acceptance of prime foodstuffs shot with lead what is the future of shooting?  Together, our community needs to look to the future and understand the importance of this consultation for the future of shooting – not just for ourselves but for the generations to come.

We are pleased that the wind seems to be favourable towards not stopping the use of lead and lead-core rifle ammunition.  That said, we are aware that large forestry management companies require the use of non-lead ammunition.  Similarly, we are aware of game dealers moving towards only accepting deer carcases shot with non-lead ammunition.  Importantly though, the second consultation seems to indicate that there is comfort about the legislative status quo, dependent on the results of the second consultation.  That is positive and reflects a great deal of advocacy work and common-sense consideration.

Similarly, in respect of lead ammunition for target shooting, it is proposed (subject to the second consultation) that this will be allowed where mitigation measures are in place, with a two-year grace period for measures to be installed, if not already there.  The majority of established formal ranges already have mitigation measures in place.

In respect of shotgun ammunition, we believe that a minimum five-year transition period is required.  We are of the view that a number of external factors will perhaps impact upon the viability of the transition period of five years for lead shot, namely the availability of component cartridge parts – higher energy double base propellant and steel shot for example, which are imported.  The military conflicts in Europe and the Middle East have impacted upon the availability of components parts, a situation compounded by massive civil stockpiling in the USA and countries elsewhere in the world looking at their own supplies.  Our view is that there should be a transition period of not less than five years for lead shot. 

We are aware that the legislation relevant to the control of deer in GB allows for the use of heavy shotgun shot to control deer in certain circumstances.  We are concerned that there is no readily available non-lead factory ammunition which would be a substitution.  This may require the relevant deer legislation to be amended.

We are also strongly of the view that it should be a period of not less than five years for lead shot given the supply factors impacting smaller calibre shotguns such as 16 and 28 bores and .410s.  We respectfully refer to the shotgun ammunition manufacturers for their views.

The consultation document contains the background to the initial conclusions and it is important that you read this.  The document can be found here UK REACH - Public Consultation on Lead in Ammunition - Health and Safety Executive - Citizen Space (hse.gov.uk).

You can respond to the consultation via this link.  UK REACH - Public Consultation on Lead in Ammunition - About you - Health and Safety Executive - Citizen Space (hse.gov.uk)

Should you have any queries about the report or the consultation, please don’t hesitate to ‘phone the office and Alex and I will do our best to help you.

Overall, the situation is more positive than it could have been, though despite a longer transition the end-state for lead shot looks inevitable.

Thank you to the many members we have engaged with on this matter. Your feedback informs our work.

Best wishes,

Fraser