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Re. use of Lead in ammunition and over wetlands

posted 31 Jan 2021, 06:23 by Tony Cattermole   [ updated 31 Jan 2021, 12:49 ]
Dear Members

Further to my post of 6th January please see the following communication from FACE Brussels, whose initial analysis is that while the EU Lead in Wetlands Regulation will not apply in Great Britain, it will apply in Northern Ireland. 

BSSC is currently attempting to have this confirmed by DEFRA, but the opinion from FACE seems clear enough. This also has implications for the Annex XV process for a total ban on lead in all ammunition which is about to kick off in Brussels.

The ECHA promised report is due in February and we will advise details as soon as available. Of course whilst reference is made to a total lead ban, as previously mentioned we have requested exemptions and given detailed explanations, especially in relation to historic arms and ranges, both in the consultation and direct with ECHA, and we await to see what we may have achieved . Indoor ranges are outside of ECHA’s remit although that may not affect the view of future use of lead by the EU.

Best wishes

Derek Stimpson


Dear FACE UK colleagues,

Please note the lead shot wetlands/restriction has been published in the official EU journal:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2021.024.01.0019.01.ENG&toc=OJ%3AL%3A2021%3A024%3ATOC

It will come into force in 20 days, and the application of the Regulation for EEA countries starts after 24 months (so in February 2023).

Please note an unforeseen development: Our initial analysis confirms that the REACH Regulation continues to apply to Northern Ireland. This is because Art 5.4 of the ‘Protocol on Ireland/Northern Ireland’ included in the EU-UK agreement stipulates that the ‘provisions of Union law listed in Annex 2 to this Protocol shall also apply, under the conditions set out in that Annex, to and in the United Kingdom in respect of Northern Ireland’ (emphasis added). Point 23 of Annex 2 includes REACH.

This will result in a change of the rules for game (and clay) shooters in Northern Ireland (e.g. see this article), and not just for lead shot over wetlands, but also for the future total lead ban, which will kick-off next week when ECHA’s proposal is published (due to come into law in approx. 3 years most likely with various transition periods).