The European Chemicals Agency’s (ECHA) consultation, directed by the European Commission, sought scientific evidence for and against its proposal to harmonise European legislation governing the use of lead shot over wetlands. In addition, the consultation requested feedback on proposals to add ‘peatlands’ to the current restrictions, the banning of possession of lead cartridges on or near to wetlands, and the addition of buffer zones around wetlands over which the legislation will apply.


You can read the Countryside Alliance’s full response to ECHA’s consultation here. In summary the Alliance concluded:

  • There is no scientific evidence to show that these proposals will reduce the risk of lead shot in wetland areas to waterbird and/or predatory and scavenging species;
  • It is paramount that any new restrictions to lead shot should be scientifically backed and fully costed;
  • Enhanced enforcement is required to improve compliance in the UK, not further restrictions;
  • EU legislation should not be brought into line through harmonisation as member states habitats and species are so varied and our hunting traditions diverse.


The responses to the ECHA consultation have now been published in full, and raise a number of interesting points:


Every single consultation response, including the Countryside Alliance’s, agrees that there are negative impacts on waterbirds resulting from the use of lead shot over certain wetland habitats. This has been proven on countless occasions and needs little expanding. The cause for disagreement is whether these new proposals will do anything to ameliorate those impacts.

There is significant disagreement regarding the addition of ‘peatlands’ to the legislation, with particular issues raised throughout the Scandinavian countries, as well as the UK. This proposal would restrict the use of lead shot over tens of millions of acres, including all grouse moors and upland shoots, but where is the evidence showing such restrictions would be of benefit to waterbirds?

All hunting organisations, including the Countryside Alliance, disagree with the implementation of buffer zones around wetlands where lead shot cannot be used, as it leads only to uncertainty and ambiguity. However, those backing the proposal wish to implement a 300m buffer zone resulting in a massive impact on shooting, leaving many areas across the UK, and Northern and Eastern Europe unable to use lead shot.

The banning of the possession of lead shot whilst on or near wetlands, leaves so many enforcement issues that it is simply unworkable. A ban on possession would not account for real-world hunting scenarios in which a hunter will be constantly moving towards and then away from wetland areas, creating an enforcement nightmare with no benefit to wetland birds.


Points of interest:

A hard or soft Brexit is irrelevant as any further restrictions of lead shot in the EU will impact the import of ammunition, and if these proposals are fully implemented they will have substantial implications for the politics surrounding lead ammunition in the UK.

The alleged non-compliance of the legislation by those shooting wildfowl in England and Wales with lead shot is being used by numerous EU organisations to call for further restrictions.

The harmonisation of legislation across the EU will disproportionately affect some regions more than other, whilst not actually targeting the risk to waterbirds.

There were only two consultation responses that requested even stronger restrictions to the use of lead shot; the RSPB and WWT.