The European Commission (EC), in a letter to the European Chemicals Agency (ECHA) has requested the agency to prepare a proposal addressing the risk to wildlife and humans (via the consumption of game meat) from lead in all ammunition (shot and bullets) including target shooting. Lead in fishing weights is also included in the request. The EC’s letter to ECHA, which became public on 21 August 2019, also asks ECHA to assess issues linked to animal welfare, potential accidents to hunters using lead ammunition and its alternatives.
The CIC is particularly concerned by this move, especially with respect to animal welfare and the wider environmental impacts of lead-free alternatives. The matter cannot be boiled down simply to an issue surrounding the toxicity of lead. The matter is far more complex than this. It must be noted that ammunition manufacturers have been working on lead-free ammunition for decades and, whilst there are improvements in the performances of lead-free ammunition, more work is still required to address all of the environmental and animal welfare shortcomings.
The CIC is in close contact with FACE on this matter. The understanding of FACE is that “ECHA will publish the dossier on its ‘Registry of Intentions’ in the coming months. From there, ECHA is required to prepare a restriction proposal within 12 months. If ECHA’s proposal recommends that further action is necessary, the agency will begin preparing a restriction on all lead in ammunition with its Committee for Risk Assessment (RAC) and its Committee for Socio-Economic Analysis (SEAC). At that stage, there will be consultations with relevant stakeholders including FACE, which also sits on ECHA’s decision-making committees.”
It is clear that any further measures beyond the restriction of lead shot over wetlands must be proportionate to the demonstrated risks to wildlife populations (including welfare), human health via game consumption (taking into account risk management measures), and overall environmental impacts from the full life cycle of ammunition production and use.
The CIC will continue to follow this issue very closely, acting together with FACE and other relevant parties in the best interests of the environment, the safety of hunters, and the welfare of animals.