The European Chemicals Agency (ECHA) has tabled new proposals for a blanket ban on lead ammunition on wetlands. The proposal would restrict not only shooting with lead shot in wetland areas, but also carrying it. This has led to the suggestion that, due to the vague definition of ‘wetlands’ in the document, the proposed legislation could lead to a situation where shooters are criminalised for crossing a ditch or boggy area with ammunition in their pocket intended for legal shooting elsewhere.

The ECHA proposal identifies seven types of wetland based on a previous EC paper: marine and coastal wetlands, estuaries and deltas, rivers and floodplains, lakes, freshwater marshes, peatlands, and man-made wetlands such as reservoirs and former gravel-pits. It also volunteers a definition from the Ramsar convention that is already in use in some EU legislation: “areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres.”

The report’s discussion of lead’s toxicity mainly refers to birds ingesting spent shot. In the comparatively short section relating to toxicity in humans it notes, “Whilst there are some data available on the concentration of lead in waterfowl that are typically consumed, further additional data would be necessary to undertake a quantitative assessment of human populations to lead in the EU.”

Countryside groups cautioned against broadly targeted regulations. In response to a Europe-wide consultation by the ECHA Dr. Matt Ellis, BASC scientific advisor and chair of the European Federation of Associations for Hunting and Conservation (FACE) ammunition working group, argued that the definition of a wetland should exclude peatlands without visible water. “BASC works to ensure that the law on lead shot is understood by those who shoot and is complied with,” he said. “But we also continue to challenge those who make the laws to ensure that any changes are based on sound evidence and do not have unintended consequences. We are keen to work with ECHA to ensure they are fully appraised of how any decisions would affect the UK.

“We are aware that ECHA is recommending a ban on the possession of lead shot in wetlands. Most shooting in the UK involves walking between areas of woodland looking for game birds, often without any shooting over wetlands.”

FACE have launched their own consultation following a request by the European commission. Meanwhile BASC’s submission to the ECHA emphasises the lack of direct substitute for lead shot, and says that the use of lead does not have a population level impact on birds.


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