After years of intensive engagement, FACE considers the final restriction workable. An objection would send the entire file back to the European Commission, with a significant risk that it would return with a broader scope and less favourable conditions for hunters. The priority now must be to use the seven-year transition period effectively, so that Europe’s hunters are fully prepared for the change.

The EU restriction on lead shot is now in its final scrutiny phase. This is a difficult and significant file for Europe’s hunting community, but it is important to recognise how substantially the proposal has changed following sustained engagement.

Over 17 months of negotiations, Member States worked intensively to improve the proposal, while many Members of the European Parliament played an important role in bringing core issues to the table and supporting those efforts.

Most importantly, the transition period for lead shot has been extended to seven years. This is a considerable improvement on the 18-month transition period initially recommended by the European Chemicals Agency’s Risk Assessment Committee and the three-year period proposed by the European Commission.

The final restriction also entirely excludes bullets and slugs from its scope. This resolves serious technical and availability concerns about restrictions on certain types of rifle ammunition. Europe’s defence agenda was a major factor in this outcome.

Why seven years is workable
FACE has consistently argued that EU legislation must be practical, proportionate and capable of being implemented across Europe. We believe that a seven-year transition period meets that test, provided the time is used effectively. Considerable work will nevertheless be required from FACE Members in conjunction with regional and national authorities.

Experience from countries/regions that have already moved away from lead shot—including Denmark, the Netherlands and Flanders—shows that a transition within this timeframe can be achieved without causing a decline in hunter numbers or hunting bags.

More than 90% of the alternative ammunition required during the transition is expected to be steel shot. Currently, standard steel cartridges are already available at prices comparable to lead cartridges.

By the end of the seven-year transition, it is essential that hunters across Europe can enter their local hunting shop and purchase suitable non-lead shot for their firearms and specific hunting situations. The Association of European Manufacturers of Sporting Ammunition (AFEMS) position is therefore particularly significant in this regard. The European ammunition industry has confirmed it can deliver the necessary transition within seven years – See REACH lead gunshot restriction: the ammunition industry’s assessment on euractiv.com.

FACE’s assessment of the way forward
The restriction is currently subject to scrutiny by the European Parliament and the Council. An objection cannot selectively amend individual elements of the text. It can only reject the restriction in its entirety, thereby sending the file back to the European Commission.

In FACE’s assessment, this would create considerable uncertainty without guaranteeing a better result. The Commission would likely rework the restriction and bring forward a new proposal in a different geopolitical and institutional context. In our view, such a proposal would have a broader scope and be less favourable to hunters than the text currently on the table.

For this reason, FACE does not consider an objection to be the right course of action. Following the extensive improvements secured during the process—including the seven-year transition and the complete removal of bullets and slugs from the scope—the final proposal provides a workable basis for moving forward.

A process stretching back two decades
FACE has been following discussions on restricting lead at EU level for almost 20 years.

Throughout the process, our role has been to defend the interests of Europe’s hunting community, working closely with our Members and reflecting their positions, while seeking to ensure that any eventual legislation is realistic and implementable.

After several years of work on this file, the final text is fundamentally different from where the process began: from a complete ban covering lead-based bullets (including rimfire), lead shot and slugs to a restriction limited to lead shot, with a seven-year transition period. FACE considers the outcome workable and will now focus on ensuring that the seven-year transition is implemented successfully, with adequate ammunition availability, clear information and practical support for hunters across Europe.