[Update] Phasing out lead gunshot over wetlands: Why the EC proposal is unworkable

The European Commission (EC) recently published its fourth proposal on the lead shot over wetlands restriction, which will be “discussed and voted” by EU Member States
on 3 September 2020 in the EU REACH Committee.

The EC’s revised proposal remains highly ambiguous, disproportionate and discriminatory.
It has not addressed in any way the major problems introduced in the first, second and third draft proposals. Importantly, it is liable to unintentionally cause a number of serious legal problems not only for European hunters but also for enforcement agencies.


  • FACE supports phasing out the use of lead shot for hunting over wetlands, and could have supported the proposal had the EC respected the Better Regulation guidelines, in particular achieving the goal of legal certainty.
  • Thus far, 23 Member States have phased out the use of lead shot for hunting over wetlands in line with the African-Eurasian Migratory Waterbird Agreement (AEWA). Member States have designed their regulations in a way that is proportionate to the risk as well as being practical and understandable for hunters and enforcement officers in line with national conditions.
  • FACE does not support the current EC proposal because of the excessive scope of the proposed restriction (i.e. ‘wetland’), the introduction of fixed buffer zones around wetlands (which were not recommended by ECHA), a short transition period (even shorter than what ECHA recommended), a vague ban on possession of lead shot, which automatically criminalises hunters, and a very broad definition of wetlands posing nearly unresolvable situations for hunters and enforcement officers.

For a summary of some of the main problems, watch this short video.

See ECHA’s restriction proposal (Annex XV dossier) opinion.
For a non-confidential version of ECHA’s Enforcement Forum’s advice on the enforceability of a proposed Annex XVII restriction, see here.

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