Lead ammunition
As you are aware, the future use of lead ammunition in the UK has been under scrutiny by the HSE and the UK REACH Agency for some time. The HSE published its opinion in December 2024, and a decision was due to be issued in March 2025. At the end of June, Scottish and Welsh Ministers gave consent to the Decision from the Under-Secretary of State, Emma Hardy MP, the responsible UK Government Minister for this decision. The decision was published yesterday.
In summary, the decision aligns with the majority of the recommendations outlined in the HSE Opinion. Under Article 73 of the UK REACH Regulation, any deviation from the recommendation given in the HSE Opinion is required to be well evidenced and reasoned. The major difference between the Opinion and the Decision is the transition period for lead shot, which has been reduced from 5 years to 3 years.
This change was made because the original 5-year transition period was recommended due to Covid-19-related manufacturing delays, which have since returned to pre-pandemic levels.
The UK and Devolved Governments will now work to lay a UK statutory instrument (SI) that will amend Annex 17 (the restriction list) of the UK REACH Regulation. Once this UKSI has been laid, the timelines for the transition periods will begin. The SI will likely be laid before Parliament in 2026 with a three-year transition period ending in 2029.
The proposals include:
A ban on shot containing more than one per cent lead;
A ban on bullets with more than three per cent lead;
A three-year transition period for most outdoor shooting, with two years for ranges to introduce pollution controls.
Exemptions will include airguns, small-calibre bullets for live quarry and managed outdoor ranges.
Realistically, given the delays to the report and the presentation of the legislation, the original five-year transition period was due to end in 2029, and this is what has happened.
This decision will be viewed with dismay by sections of the shooting community. Many will see no need for change. Others, who have transitioned away from lead, both for rifle ammunition and non-lead shot, report no significant difference in performance.
Despite this, the Government, which holds a significant majority, is planning to introduce this legislation and it will be implemented in 2029. The 1% of the population who possess firearms will not influence this decision. This is simply a fact, with a move from lead ammunition a certain outcome for many years.
The link to the decision and the proposed SI can be found here. UK REACH restriction for lead in ammunition, 27 June 2025 - GOV.UK
We would strongly urge you to read the decision. It affects you, and an understanding of the reasoning behind the decision is essential. It is the reality, and it may assist in reducing the excessive speculation that is prevalent on some social media platforms..
In the meantime, we will keep you updated with any further information as it becomes available.
If you have any queries regarding this, please don’t hesitate to contact the office, and we will do our best to assist you.