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that lead-free shotgun cartridges be used for hunting nation-
wide in all habitats (Mateo 2009).
At the 11th Meeting of the Conference of the Parties to the
UNEP Convention on Migratory Species (CMS) in November,
2014, Resolution 11.15 on Preventing Poisoning of Migratory
Birds (UNEP-CMS 2014a) and its Guidelines (UNEP-CMS 2014b)
were adopted by the Parties. The guidelines include the
recommendation to phase out all lead ammunition (gunshot
and bullets) in all habitats (wetlands and terrestrial) within
three years. The Resolution agrees that “it is for each Party to
determine whether or how to implement the recommended
actions, considering the extent and type of poisoning risk,
whilst having regard to their international obligations and
commitments, including those under the Convention”. The
intention of this is clear, i.e. that countries that do not have
particular risks, or have only trivial risks from one of the
listed poisons within their territory (e.g. with respect to lead
ammunition this may apply to countries where all hunting
is forbidden) need not act. In contrast, the expectation is
that countries that do have anything more than a trivial risk
from one of the poisons within their territory should follow
the recommendations in order meet their international
commitments – including under the CMS.
Lead poisoning has been shown to be a significant problem
for both welfare and survival in migratory birds in the UK
(Pain et al. 2015). The Resolution, which is politically binding
both at EU and individual signatory Member State levels,
requires that the UK responds to the proposed timing and
extent of the lead ammunition phase–out across the country,
while considering the devolved jurisdictional powers of
Wales, Scotland and Northern Ireland. Implementation of
the Resolution requires extension of lead-use bans beyond
what currently exist in the UK. The UK government has also
to consider its relation to the European Union in this manner
because of the sharing of the migratory bird flyways with
different European Union partners, and because the EU en
bloc is also a signatory to the CMS.
In addition to the requirements under the CMS, lead levels
in marketed shot game, whether national or imported, raise
concerns about national food standards and the need to
regulate human lead exposure in this manner (Knott et al.
2010, Green and Pain 2012). It is both desirable and possible
that constructive regulation to end the use of lead ammunition
could serve the interests of both human consumers and
wildlife, and ideally, be harmonised across regions of the UK, as
well as adjacent European countries.
CONCLUSIONS
Issues of availability
SHOT: The product availability of lead-free shot is assured in
the UK by two British companies (Gamebore and Eley) making
two proprietary brands, and all of the major British cartridge
makers producing steel shot cartridges. Additionally, foreign-
made steel shot ammunition is imported into the UK and
distributed through online and other retailers. This is to satisfy
current regulations requiring use of lead-free cartridges for
shooting waterfowl, but the same manufacturing, importing,
and distribution system could be used to supply lead-free
shot cartridges across all game shooting. The retail availability
of steel, bismuth, and tungsten-based shot cartridges is large,
especially from on-line dealers.
BULLETS: Lead-free rifle bullets are imported from either
American or European makers, and a growing number of
companies either make or produce assembled rifle cartridges
with lead-free bullets (Thomas 2013). The retail availability of
this type of ammunition is restricted for two reasons. The size
of this UK rifle shooting community is smaller than the shotgun
shooting community, and far fewer shots are used per shooting
season. The other main reason is that game shooting with rifles
and lead-core ammunition is still allowed in the UK.
The economic availability of lead-free rifle ammunition is not
a barrier to a transition away from lead bullet use in this sport.
Although lead-free bullets are approximately double the price of
lead-core bullets, few rifle shots are used in a typical deer hunt,
and then, their costs become a very small part of the total costs
of the hunt. A transition to lead-free shotgun cartridges carries
different economic costs. The cost is zero for steel shot, 5-6 times
more for bismuth-tin shot, and 10-11 times more for Tungsten
Matrix shot. However, relating these prices to the costs of game
shooting indicates that the costs of the target animals and other
related costs predominate, not the costs of the ammunition.
There is no strong economic barrier to the regulated transition
to lead-free shot for all game and pest shooting in the UK.
In considerations of availability, issues of regulation and
prices predominate. If regulations mandating use of lead-free
ammunition do not exist, there is little incentive for industry to
Availability and use of non-toxic ammunition: practicalities and regulations