Policy paper

Government response to the Animal Sentience Committee report on the restriction of lead in ammunition

Published 31 July 2026

Summary

This is the government’s response to the Animal Sentience Committee’s (ASC) report of 12 March 2026 on the UK REACH Restriction on lead in ammunition.

The report summarises the ASC’s findings following assessment of the policy, and – where relevant – contains recommendations in relation to any further formulation or implementation of the policy.

We would like to thank the ASC for its thoughtful consideration of the UK REACH Restriction on lead in ammunition.

Introduction

The statutory process that led to the UK REACH Restriction on lead in ammunition began on 21 April 2021, when the Defra Secretary of State — supported by Welsh and Scottish Ministers — requested the Health Safety Executive (the HSE) to prepare a dossier relating to lead use in ammunition. A UK REACH Restriction Decision was subsequently made on 27 June 2025, when a Decision Report and draft amendment were published. This decision benefits the welfare of animals as sentient beings, including through reductions in the primary and secondary poisoning of birds and mammals, and through reductions in the secondary poisoning of wildlife and livestock (for example through contamination of feed or groundwater).

Following the Decision Report, the REACH (Amendment) Regulations 2026 came into force on 1 April 2026. They amend Annex 17 of UK REACH to include a new UK REACH Restriction on lead in ammunition. From 1 April 2028, lead bullets must not be used at outdoor shooting ranges unless those ranges have effective lead risk management measures in place and provide specific information requirements. From 1 April 2029, the placing on the market and use of lead shot will not be permitted. Provided certain conditions are met, elite athletes (as defined in the legislation) will be permitted to use lead shot. Also from 1 April 2029, the placing on the market and use of large calibre lead bullets for live quarry shooting will not be permitted. Lead in airgun ammunition is out of scope of the UK REACH Restriction.

Response to the ASC’s conclusions and recommendations

We note that the ASC welcomes this decision, which will reduce environmental lead contamination and improve animal health and welfare through reductions in direct and indirect lead poisoning.

We note the ASC’s consideration of how well the adverse effects on the welfare of animals as sentient beings were given all due regard, and we note the ASC’s recommendations in relation to implementation of the UK REACH Restriction. We acknowledge the ASC’s recognition of the extensive and thorough consultation carried out by the HSE to develop their proposal for this UK REACH Restriction, and also the ASC’s recognition of the HSE’s consideration of the scientific evidence, of similar experience in other countries, and of economic and social impacts.

In relation to implementation of the UK REACH Restriction, the ASC highlighted the importance of hunting practices changing. We note the ASC’s view that if new non-lead ammunition is adopted without the necessary accompanying changes in hunting practices, then there may be a reduction in lethality and in associated harm to the welfare of animals. We also note the ASC’s views about the provision of good practice guidance by the shooting and hunting sector on new shooting practices and on the modification of weapons. We further note that the ASC considers that paying all due regard to the welfare of animals as sentient beings includes considering the future monitoring of the UK REACH Restriction when it comes into effect. We note the ASC’s associated views about enforcement and about possible non-compliance by some shooters with the new regulations. We will be monitoring the development and dissemination of guidance by the sector.

In terms of facilitating the desired change in hunting practices, the government recognises that hunting techniques should adapt following the adoption of non-lead alternatives. The HSE concluded that reductions in lethality can be avoided if hunters follow best practice, as demonstrated by the Forestry Commission’s successful shift to non-lead ammunition. Denmark has also successfully applied a total ban on lead shot for all hunting since 1996.

We note that the ASC has concerns that a 3-year transition period may not be long enough for the change to using non-lead ammunition for the euthanasia of livestock. The HSE’s consultations collected views from the humane killing community, and the Lead Ammunition Group recommended to the HSE that a 3-year transition period was suitable. As a result, HSE extended the transition period for bullets from the original proposal of 18 months to 3 years. The Humane Slaughter Association also publicly welcomed the government’s decision to restrict lead ammunition, duly noting the 3-year transition period.

We note the ASC’s recommendation that officials and Ministers consider the potential benefits of licensing in order to facilitate a route to restricting lead in airgun ammunition. The ASC acknowledges that Defra cannot deliver these changes as licensing powers for firearms reside with the Home Office.

We would like to thank the ASC for its consideration of how well the government paid all due regard to the adverse effect on the welfare of animals as sentient beings when making the decision to place a UK REACH Restriction on lead in ammunition.