Independent report

The Animal Sentience Committee's views on the restriction of lead in ammunition

Published 12 March 2026

The Animal Sentience Committee (ASC) is a statutory committee established by the Animal Welfare (Sentience) Act 2022 in May 2023. The ASC has a remit to assess whether, or to what extent, the government has given all due regard to the ways in which a policy might have an adverse effect on the welfare of animals, as sentient beings. This report summarises our findings following assessment of the associated policy, and – where relevant – contains recommendations in relation to any further formulation or implementation of the policy.

The policy

In accordance with UK REACH, a decision has been made by the UK government to restrict the use of certain types of lead ammunition, including lead shot and large calibre bullets. The ASC welcomes this policy, which will provide several benefits to both human and animal health and welfare through reductions in environmental contamination with lead. As highlighted by the Restriction Decision of 27 June 2025, such benefits to sentient animals will include reduction in the primary and secondary poisoning of birds and mammals, and secondary poisoning of wildlife and livestock (for example through contamination of feed or groundwater).

Within the policy and associated draft Statutory Instrument under certain conditions, obligations are suspended to allow the use of lead shot by elite athletes training for competitions. Small calibre bullets and air rifle pellets are not included in the restriction.

Policy team groundwork

The ASC was pleased that extensive consultation had taken place with a range of stakeholders including those members of the Lead Ammunition Group with expertise in conservation and animal welfare.

The policy team has clearly carefully considered the underlying scientific evidence, taken learnings from other jurisdictions where similar policies have been implemented, and considered policy impacts in both economic and social terms.

The implications of this policy

The policy offers clear and substantial benefits to animal welfare, including the prevention of thousands of animals being poisoned by lead every year, which is highly commendable. This provides clear evidence of due regard for animal welfare. Despite these clear benefits we identified some areas where there may also be potential negative impacts of the policy on the welfare of sentient animals. If not fully addressed, these effects could be very significant in terms of their overall welfare impact, given the large numbers of animals shot per year (for example, millions of pheasants). However, these potential negative impacts may be largely mitigated by appropriate implementation and monitoring plans.  

Reduced lethality

There is evidence that alternative metals to lead, used for bullets and shot, may have reduced lethality when used in identical circumstances. This is most significant for steel, which is a lighter metal with reduced fragmentation capacity. Alternative metals such as copper and bismuth typically offer better lethality but are more expensive and may not be as widely adopted. While changes to shooting practices can mitigate some of these effects, for example, increasing shot size, firing at closer range or with a narrower choke, these need to be communicated to gun users to ensure adaptations are made. Equally, for older firearms, there is a risk that the cost of adapting them to handle steel ammunition (if even possible) may see users instead change to narrower shot gauges to reduce barrel impacts, resulting in reduced lethality.

Provision of guidance

The ASC are concerned with the current proposition, which appears to indicate that guidance for necessary changes to the industry, both in terms of adaptation of existing weapons and changes in shooting practices (for example shot size, distance to quarry for lighter metals) will be left to shooting organisations. While the expertise and cooperation of these organisations is clearly vital, representation of other stakeholders, including ammunition manufacturers, animal welfare and wildlife charities, would likely result in guidance that both addresses the needs of the shooting community and better protects animals. In addition, it is unclear what the reach of the principal shooting organisations is across all firearms users, and whether they represent the best way of ensuring that the changes necessary to preserve welfare are communicated.     

The policy team could consider where gaps exist, and where further communication is needed to encourage the provision of appropriate guidance in parallel with a range of  organisations. Examples might be issuing standards which could be made available at point-of-sale for ammunition, and improved labelling of ammunition. Standards could include setting minimum energy or penetration criteria at typical ranges for species, at different metal and calibre/shot size (for example reference tables).  Ammunition box labelling or inserts could be either mandated or agreed under voluntary cooperation with the industry, with recommendations for inexperienced shooters who may be less familiar with technical specifications such as muzzle energy (for example “Suitable for pheasants to a range of 35m with full choke”).

Implementation and effectiveness monitoring

The ASC consider good due regard to animal welfare to include monitoring of the policy in the post-implementation phase. Although the ASC was informed that the Health and Safety Executive (HSE) would consider enforcement action if illegal activity took place, this was indicated to depend on stakeholders reporting lead ammunition remaining on sale. It is unclear whether central follow-up is currently being considered, but monitoring changes in ammunition sales data would be beneficial, particularly trends in the types of metals adopted and the calibre of bullets or gauge of shot. For example, if an increase in sales of lower calibre bullets is seen at the expense of larger calibre, then this may suggest that either quarry type has changed (for example a move to smaller deer, with implications for their conservation and management) or reduced legal compliance.

The ASC understands that potential illegal responses to the new regulations, e.g. substituting smaller calibre lead bullets for non-lead large calibre bullets would be offences under existing regulations. However, good enforcement will require suitable reporting systems to be put in place. At present, enforcement is largely dependent on stakeholder reporting, as police involvement in this area remains limited. There is currently no established mechanism for reporting breaches of existing regulations, and proactive engagement from law enforcement is not a routine feature of the system (ASC Report on legislative compliance and enforcement). Further consideration should therefore be given to how any breaches might be detected.

Regarding use of ‘competition’ or legacy lead ammunition, the policy team highlighted the potential for gun license enforcement teams to check for evidence of lead ammunition at routine inspections. Ensuring that local authorities are made aware of this and update inspection protocols accordingly is therefore required in the implementation phase.

Airguns

Airguns are predominantly used for indoor sports shooting of non-live targets. However, a significant number are used to cull unwanted or pest animals, including small rodents (for example rats, grey squirrels) and some birds (for example pigeons). Within an agricultural setting, these animals are often shot around food stores, including grain stores and in livestock buildings. While it is difficult to provide a quantitative estimate, there is likely to be a limited risk of secondary poisoning of livestock or domestic pets (cats, dogs) via this route and, by extension, potential lead exposure for other wildlife and for humans. The decision to exclude airguns appears to be on the basis that non-lead alternatives would result in many airguns exceeding the limits on muzzle energy set out in England and Wales (12 ft·lbf for air rifles and 6 ft·lbf for air pistols), potentially leading to inadvertent breaches of the law. In addition, because low-energy airguns do not require a license, it was cited that ammunition is currently so accessible that enforcement would be extremely difficult.

While ASC understands and acknowledges the reasoning behind the policy decision, and that changes to airgun ownership and licensing are the responsibility of the Home Office rather than the REACH policy team, recognition of the animal welfare impacts associated with air gun use presents an opportunity  for interdepartmental cooperation on policy development. Aside from the potential for secondary lead poisoning of animals, airguns are frequently implicated in the injury of pets and other animals. The Air Weapons and Licensing (Scotland) Act, 2015 and Firearms (Northern Ireland) Order, 2004, provide examples of licensing and certification schemes which could be adapted into English and Welsh law and may provide a route towards lead restriction in airgun use outside of approved indoor shooting ranges.

Euthanasia of livestock

Euthanasia of larger livestock is undertaken using firearms by licensed slaughtermen, farmers and veterinarians, with the aim of immediate insensibility. While it is encouraging to hear that further research into the use of non-lead alternatives is planned, we are concerned that with a three-year lead-in time, research may not have been completed by the time the transition period is complete. There is also no guarantee that research will succeed in identifying a suitable non-lead alternative for this purpose. Thus, consideration should be given to the potential need to accelerate research or to provide a route for suitable exemptions.

Any changes to advice regarding calibre, energy etc. for a given material, shot placement and HSE considerations (potential for ricochet in more enclosed environments) will need to be communicated to users. Many of these individuals will not be connected to shooting organisations and may require different channels for information dissemination.

Recommendations

As discussed in the preceding section, the ASC recommends that officials and ministers consider:

• The potential benefits of licensing airguns as demonstrated in Scotland and Northern Ireland, with a view to reductions in lead poisoning, and protection of pets and wildlife.

The ASC recommends that policy teams consider ways to:

• Provide independent and comprehensive guidance during the transition that safeguards animal welfare.
• Monitor changes in sales of ammunition and practice in the field to monitor policy impacts.

Conclusion

At this juncture, the ASC considers that due regard for animal welfare has been given in almost all areas, however there are some points – particularly relating to the implementation phase – which would benefit from further consideration. We make suggestions on potential mitigation strategies.

Governance

Committee members who were responsible for developing this report:

• Richard Cooper
• Anna Meredith
• Christine Nicol

Date report was agreed: 25 November 2025