Lead restrictions — what happens next?

The Health and Safety Executive (HSE) has taken on board many of BASC’s concerns for its final lead ammunition restriction report (see p6). But there is much work ahead to ensure that any laws affecting ammo should be practical, easy to comply with and proportionate to evidenced risk. 

More than a year ago, the last in a series of HSE consultations concluded on a review into the outdoor recreational use of lead ammunition in England, Wales and Scotland. Due to the large number of responses — 8,159 — to that consultation, it has taken the HSE over 12 months to take these into account before reporting on its findings. 

The HSE report was published on 14 December 2024 and submitted to the Defra Secretary of State and the Scottish and Welsh Governments for consideration. The main recommendations are as follows: 

A restriction on the sale and use of lead shot for live quarry and target shooting with a timeline of five years. There will be a derogation for athletes to continue using lead shot. 

No restrictions for airgun pellets for live quarry or target shooting. 

No restrictions for small-calibre rifle ammunition for live quarry shooting. 

A restriction on the sale and use of large-calibre rifle ammunition — defined by HSE as .243 and above — for live quarry shooting with a timeline of three years. 

On target shooting with rifles, ranges that can de-lead — an estimated 95% of them — face no restrictions. The few that cannot have two years to adapt or move across to non-lead ammunition. 

Restrictions 

The timeline for a proposed restriction on the sale and use of lead shot has been extended from three to five years after extensive lobbying by BASC. The HSE has taken on board the evidence provided by BASC and other organisations relating to airguns and target shooting with rifles. No other restrictions have been proposed. 

No restrictions have been proposed on small-calibre rifle ammo after concerns were raised by BASC on accuracy and availability. Following our input, the timeline for a proposed restriction on the sale and use of large-calibre rifle ammo has been extended from 18 months to three years. 

While it’s positive that the HSE is not recommending restrictions on small-calibre rifle ammunition, BASC does not support the HSE definition of large calibre to include .243 for restriction proposals. 

There is sufficient evidence to show stabilisation issues with .243 calibres, supported by a technical report presented by BASC. As a result, potentially 60,000 people who use .243 for deer management will have to re-barrel their rifles — 80-gr .243 bullets do not stabilise in predominantly older rifles with a 1-in-12 twist because they need to be 1-in-8. BASC lobbied for large calibres to be set at 6.5mm and will continue to do so. We will be funding research and gathering evidence to underpin further lobbying of ministers and officials on this and other issues that arise as this policy issue moves into the political arena. 

Lead in ammo and some substances in tattoo inks and permanent makeup, were the first areas to be reviewed in 2021 under post- Brexit legislation called UK REACH on the control of hazardous chemicals. Northern Ireland is excluded due to the NI protocol and continues to be subject to European Union REACH regulations. 

Since 2021, many more substances have been subject to HSE reviews, again mirroring similar reviews for those substances in the EU, including lead ammunition. All of this is to ensure continued trade in chemicals with the EU post-Brexit. 

Defra and the Scottish and Welsh governments will review the report and decide whether to propose legislation. This could be the same for England, Wales and Scotland, or we could see different laws in different countries — as happened when the lead shot regulations for wildfowl and/or wetlands came into force over 20 years ago. 

There will also be people and various organisations lobbying for an immediate ban on all lead ammunition. So there is much work ahead.