Promoting the Transition to Non-Lead Hunting Ammunition in the European Union Through Regulation and Policy Options

1Introduction

Lead poisoning in waterfowl resulting from the ingestion of spent lead gunshot, mistakenly for grit or food, has been recognised for more than a century¹. At an international workshop on lead poisoning in waterfowl in Brussels in 1991² it was concluded that solving this problem required the replacement of lead gunshot with non-toxic alternatives, and that suitable alternatives were already available and in use. This stimulated new policy initiatives, and the Contracting Parties to the intergovernmental treaty, the African-Eurasian Migratory Waterbirds Agreement (AEWA) agreed to endeavour to phase out the use of lead shot in wetlands by 2000. The European Union (EU) en bloc is an AEWA Party, as are most EU countries individually except Austria, Greece, Malta, and Poland³. However, some EU Member States (Ireland, Greece, Poland, Slovenia, and Romania) still have not taken action, and some others have not met their AEWA obligations by not fully enacting restrictions over wetlands (i.e. member states that restrict only within designated sites)⁴. Limited progress by 2008 resulted in AEWA further calling on Contracting Parties to phase out the use of lead gunshot over wetlands as soon as possible, whilst obligations made in 2014 by the EU and its member states under the Convention on Migratory Species recommended a full phase out of all lead ammunition^5,6.

Given limited and inconsistent progress under AEWA, in 2015, the European Commission (EC) initiated a process to evaluate and, if necessary, restrict the use of lead gunshot in wetlands under the REACH Regulation (Regulation for the Registration, Evaluation, Authorisation and Restriction of Chemicals). The process is outlined in Table 1. The EC requested the European Chemicals Agency (ECHA) to propose a restriction on the use of lead gunshot over wetlands. Following calls for and scrutiny of evidence, in April 2017, ECHA completed an Annex XV dossier proposing a restriction on the use of lead gunshot in and over wetlands⁷. Following a wide public consultation, the dossier was passed to the two ECHA technical committees, the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC), for assessment. The RAC commented particularly on the relevance of the proposed restriction for reducing risks to human health and the environment. After further consultation, in June, 2018, both technical committees adopted ECHA’s proposal that lead gunshot requires restriction in wetlands.

The usual EU procedure is for there to be a period of about three months after receipt of the compiled RAC and SEAC opinions during which the EC can consider and, if necessary, amend the proposal before it is voted upon by the EU REACH Committee (representing EU member states). The EC amended several aspects of the wetland restriction to ensure its enforceability and maximise the health protection of the proposal. The restriction was subject to considerable national lobbying from hunting and ammunition interests and many delays. Consequently, the REACH Committee vote did not take place until September 3, 2020, when it approved the restriction, with 18 of the 27 member states voting for the restriction, 5 against, and 4 abstentions⁸. The 18 States that voted in favour hold c.90% of the EU population, surpassing the required 65% population threshold (i.e. qualified majority) by a considerable margin (Table 1). On November 29, 2020, the European Parliament voted to accept the restriction, and on January 25, 2021, the Members of the European Council ratified European Commission Regulation (EU) 2021/57⁹ which is due to take effect on February 15, 2023. This Regulation will satisfy the EU’s obligation to the AEWA, but requires individual member states and Schengen states to enforce the ban at their national level.

With this restriction, the EU has adopted a regulatory, as opposed to a non-regulatory, approach to the lead ammunition issue¹⁰ which is similar to the regulative approaches taken by other jurisdictions, both within and outside the EU. The EU Regulation also parallels the regulative approaches taken by the EU to restrict the use of lead in other anthropogenic uses (e.g. gasolines, paints, and solders). In all these cases, regulation is possible because effective and available lead substitutes exist. The same applies to lead gunshot substitutes which are already made by leading European companies¹¹.

In September, 2018, ECHA published, at the Commission’s request, a report on the use of lead shot in terrestrial environments beyond wetlands, other types of ammunition (bullets), and fishing tackle¹². This report built on evidence gathered under the earlier restriction proposal for wetlands and concluded that there was sufficient evidence of risk from those other uses to justify additional regulatory measures. Consequently, in July, 2019 the Commission asked ECHA¹³ to prepare a restriction proposal on the placing on the market and use of lead in ammunition (gunshot and bullets) and of lead in fishing tackle conforming to the requirements of Annex XV to REACH. This restriction request covered both wetland and terrestrial habitats. Having assessed various risk management options, ECHA identified a preferred option to address the risks to the environment and human health in a proposal brought forward in February 2021. This option was summarised as¹⁴.

“1. Lead sold and used in hunting, sports shooting and other outdoor shooting:

Lead fishing tackle is also included within this restriction but not dealt with further in our analysis. The restriction process is ongoing (at the time of writing) with a provisional timetable as outlined in Table 1.

Lead from ammunition presents well-established risks, not only to waterfowl, but also to terrestrial birds, including scavengers and predators, that ingest lead fragments from ammunition when eating shot and injured or unretrieved game, or gralloch (discarded viscera of large game animals¹⁵). Because of the large body of peer-reviewed literature on the subject¹⁶, there is a consensus on the risks that lead ammunition poses to human and wildlife health which is supported by the scientific community in Europe and globally¹⁷. As well as publishing evidence-based consensus statements, scientists with expertise in this area have also recently produced open letters commending the European Commission for initiating the development of restriction proposals and encouraging a rapid transition away from all lead ammunition to non-toxic alternatives¹⁸.

There was considerable opposition to Regulation (EU) 2021/57 on the use of lead gunshot in and over wetlands, largely from the ammunition industry and the game hunting and shooting communities¹⁹, and this is also true of broader transitions to the use of all non-lead ammunition. The resistance to change occurs despite available European-made non-lead substitutes for both shotgun and rifle ammunition²⁰ and widespread acknowledgement that these perform well, and especially for rifle calibers over 0.243. Even bullet calibres of 0.243 and smaller, for which options were previously more restricted, are now produced more widely, partly due to stimulation of the market by enactment of a ban on all lead ammunition use for hunting in California State (USA) from July, 2019²¹. Nonetheless, restrictions on the use of lead gunshot were implemented decades ago in some countries, both within and beyond the EU. These include the USA (1991), and Canada (1999), where it is illegal to shoot migratory wildfowl while in possession of lead gunshot²², and also the Netherlands and Denmark where use of lead gunshot was banned for all types of shooting and in all habitats in 1993 and 1996, respectively²³. However, seven EU nations, Greece, Ireland, Lithuania, Malta, Poland, and Slovenia, had no restrictions on lead ammunition²⁴.

A comparison of the efficacy of the complete ban on lead gunshot in Denmark with that of the numerous partial bans (i.e. over some or all wetlands, and/or for shooting wildfowl) in other countries is informative. In some countries, measured compliance by hunters with partial bans is low. In England, measured compliance has remained at about only 30% since a ban on shooting wildfowl using lead gunshot was introduced in 1999, despite a campaign by shooting organisations to improve compliance and informing hunters that continued failure to comply increased chances of a complete ban²⁵. However, there has been little enforcement of this legislation in England. In Sweden, a third of people hunting in wetlands used lead gunshot despite its being banned 15 years ago²⁶. Where partial, site or species-based bans have been introduced, good compliance appears to have required a high level of monitoring and control of ammunition types used, as illustrated in the protected wetlands of Ebro Delta region of Spain²⁷. However, there has been high compliance with the complete ban on all lead gunshot use introduced in 1996 in Denmark, where possession and sale of lead shot cartridges is illegal²⁸. Much wetland hunting in Europe is conducted on private lands, and there is no government agency devoted to ensuring hunter compliance with shooting regulations in any EU member state. This contrasts with countries such as Canada and the USA where itinerant federal and provincial/state government conservation officers are required to meet hunters in the field and enforce prevailing laws²⁹. The financial resources required to enable the comprehensive monitoring and enforcement necessary were seldom made available even before the current pandemic-related economic impacts and are unlikely to be of increased priority to EU decision makers today.

In Regulation (EU) 2021/57³⁰ the carrying of lead gunshot within 100m of a wetland is prohibited “where this occurs while out wetland shooting or as part of going wetland shooting” and this provides an enforcement mechanism. However, the examples above suggest that, in the absence of widespread and active enforcement, this ban on lead gunshot use in EU wetlands is unlikely to be as effective as needed to protect the environment and human health. In this paper we address further policy and regulative options that could be undertaken to complement and make more effective Regulation (EU) 2021/57 on lead gunshot in wetlands, and to facilitate a rapid transition to the use of non-lead ammunition across the EU. The paper also emphasizes the importance of further restrictions on lead ammunition use presently under consideration by the EU as both a critical adjunct to the 2021 EU Regulation and as further protection of wildlife, human, and environmental health. The inclusion of the UK (no longer an EU member state) in this paper derives from this country’s foremost involvement with this issue, its membership in AEWA, its large international ammunition industry, and its game meat sales to the EU.

2Discrete Components of European Hunting and Shooting

Waterbird hunting mainly involves migratory species whose flyways extend within and beyond the EU. The conservation interests of these species and their wetland habitats, which frequently span national boundaries, are covered by the Ramsar Convention (The Convention on Wetlands of International Importance Especially as Waterfowl Habitat)³¹, and AEWA, developed under the framework of the UN Convention on the Conservation of Migratory Species of Wild Animals (CMS)³². The CMS and the AEWA have provided strong focus for the use of non-lead ammunition to protect these and other migratory bird species from avoidable lead poisoning³³. The EU is a full Party to both AEWA and the CMS. Furthermore, legal acts of the EU address the subject indirectly including the Birds’ Directive ³⁴ requiring that hunting does not jeopardise conservation efforts in the distribution areas of huntable species (Articles 7). At the 25th anniversary conference of the Birds Directive in 2004, a stated intention was to “Aim to phase of the use of lead shot in wetlands as soon as possible and ultimately by 2009”³⁵ and this has been included in subsequent debates in the Directive’s ‘Ornis Committee’ that helps the Commission implement the Birds Directive³⁶.

The hunting of birds and smaller-sized mammals (e.g. rabbits (Oryctolagus cuniculus) and hares (Lepus europaeus)) in terrestrial habitats, including uplands, forest and grasslands is widespread across the EU, and mostly involves shotguns and lead-based ammunition. The many millions of animals shot annually are either consumed directly by hunters, sold into retail markets and the restaurant trade, or are killed as ‘pests’. Most ‘pest’ animals are not eaten by people but disposed of in the environment where they are likely to be scavenged. Hunting of larger mammals is also common practice in most EU nations. Lead rifle ammunition is used traditionally to hunt mainly four species of deer, wild boar (Sus scrofa), and several other mammal species. Germany is the leading nation in the transition to use of non-lead rifle ammunition, requiring its use in several regions³⁷. In addition, in several UK countries the agencies responsible for managing populations of deer and wild boar in the nation’s forests have required their staff to use non-lead bullets for hunting since 2016 (England) or are currently transitioning to non-lead bullets (Scotland)³⁸. In November, 2020, the Danish government announced a nation-wide ban on lead rifle hunting ammunition, effective from 2023³⁹.

Clay target shooting is common and widespread within the EU and occurs at both designated shooting grounds and itinerant sporting events. There are different target shooting disciplines (e.g. skeet and trap events) and lead shotgun ammunition is generally required, especially for international competitive events⁴⁰. Target shooting with rifles and handguns is common and popular in most European countries. Target shooting with rifles is often associated with hunting practice. Lead-core ammunition is most frequently used although comparable non-lead bullets are available for most applications. Bullets are normally fired into earth berms, from which spent bullet fragments can be recovered and recycled regardless of bullet material, hence the environmental impact can potentially be minimised. However, some rifle target shooting disciplines are located in natural environments with limited possibilities of retrieval of ammunition (“field shooting”).

Only 1.8% of the European population hunts, ranging from 0.2% in Belgium and The Netherlands, to 8% in Ireland⁴¹. However, a recent report found that each year, hunters from just 12 of the 27 EU countries for which data are available, and the UK, shoot over 6 million large game mammals, 12 million rabbits and hares and over 80 million birds. Collectively they support an international game meat market worth over 1.1 thousand million Euros⁴². Many game animals are consumed by individual hunters and their families and friends. In countries such as the UK and Denmark, where much hunting is done on estates with employees engaged to control predators and release captive-bred gamebirds, game may also be consumed by full-time and occasional employees⁴³. About 5 million people across the EU (largely associated with hunting) are estimated to be high level consumers of game, i.e. eating one meal or more of game meat per week, with many more consuming game meat less frequently. In a representative survey of 1000 people in Germany, >38% of respondents indicated consuming large game at some time throughout the year⁴⁴.

3Potential Non-Compliance with the EU Ban On Lead Gunshot Use in Wetlands

Regulation (EU) 2021/57 that restricts the use of lead gunshot in and over wetlands is made possible because an array of non-lead gunshot is already made by the leading European manufacturers and distributed throughout Europe⁴⁵. However, lead gunshot continues to be manufactured, and is used for game hunting in forests, farmland and uplands in all EU nations except Denmark and The Netherlands⁴⁶. Thus, hunters can still easily obtain lead gunshot suitable for shooting wetland bird species. For example, lead shot in sizes and cartridge loads suited for hunting hares could be used to hunt different species of geese and large-bodied ducks. Lead shot cartridges used for shooting pheasants could be used effectively to hunt ducks, and the lead-based shot cartridges marketed for clay target shooting could be effectively deployed to hunt small migratory wetland species such as teal (Anas crecca) and common snipe (Gallinago gallinago).

Potential non-compliance of hunters unwilling to forgo the use of lead ammunition, reinforced by widespread weak regulatory enforcement, would reduce the effectiveness of the EU lead gunshot ban over wetlands and the potential future ban on all lead-based ammunition (depending upon the conditions of such a ban). For migratory species, their protection across the entire flyway is essential⁴⁷. Conservation goals are not realised when birds migrate from a region where toxic risks from spent lead shot are reduced by high hunter compliance to regions where risks remain high due to non-compliance with regulations or lack of regulation. Individual nations within the EU have the right to enact further legislation to complement and enhance the effectiveness of a particular EU regulation (e.g. Birds Directive Article 14⁴⁸). An example would be the passing of a national regulation prohibiting the use of lead gunshot for all categories of hunting and clay target shooting as has been done in Denmark, where possession and trade of lead gunshot cartridges is illegal. Such legislation effectively prohibits the importation, sale, and use of lead gunshot and potentiates the national demand for non-toxic alternatives⁴⁹.

4Public Engagement and Awareness of the Societal and Environmental Impacts of Lead from Ammunition

European society has accepted the regulations removing or limiting the presence of lead in gasolines, paints, glass, and other anthropogenic uses because of its well-established risks to human and environmental health. As well as enabling lead’s removal from many products, modern technology has facilitated enhanced recovery and recycling in others. An estimated 39–40,000 tonnes of unreclaimed lead from spent hunting and shooting ammunition are released annually into EU wetland, forested, and upland environments⁵⁰. According to industry figures, annually approximately 21,000 tonnes of lead from shotgun cartridges used in hunting is dispersed into the environment in the EU (28), although some estimates indicate the tonnage is probably significantly higher⁵¹. While ammunition from target shooting is sometimes recovered, that dispersed in the environment from hunting is not and accumulates over time⁵². If these sports were classified as industries, it is likely that prevailing EU regulations would require an immediate halt to such lead release, especially in the absence of extensive lead reclamation.

As part of the EU REACH restriction process several opportunities exist for interested parties to give their views (Table 1). However, the vast majority of responses have involved hunting and shooting organisations, the arms and ammunition industries, conservation organisations, and scientists specialised in the risks lead-based ammunition poses to human and wildlife health. The non-hunting public is poorly represented in these consultations, probably largely due to lack of awareness of their existence. Pollution from lead ammunition has been regarded as a problem created by the hunting and shooting communities that the political process needs to address, with few attempts by public authorities to inform the public or engage people in debates around the issue, including its wider international and socio-economic implications⁵³. The social and economic costs of impaired human, wildlife and environmental health are externalized and paid for by the whole of European society⁵⁴, and the ‘polluter pays’ principle has been largely ignored, despite this being a tenet of the Treaty on the Functioning of the EU (Article 191, ex Article 174 TEC)⁵⁵.

Risks posed by lead gunshot to waterfowl have been documented for well over a century. Risks to predatory and scavenging birds from lead poisoning following ingestion of lead from gunshot or bullets in their prey have been acknowledged for at least forty years, particularly for Bald Eagles (Haliaeetus leucocephalus)⁵⁶, California Condors (Gymnogyps californianus) in the USA⁵⁷ and White-tailed Sea-Eagles (Haliaeetus albicilla) in Europe⁵⁸. However, the extent of this problem in these and other terrestrial birds and the wide range of species affected across the world has only become apparent in recent decades⁵⁹. What was formerly regarded as primarily a disease of waterfowl has become recognised as a disease of all animals that ingest fragments of spent lead-based ammunition, and this appears to include wild mammals⁶⁰ as well as birds. The substantial body of scientific literature that has appeared in the past 20 years⁶¹ also documents the risks to human health from frequent ingestion of game shot with lead ammunition⁶².

Chronic low level exposure to lead is associated with a range of critical effects in humans, including elevation of systolic blood pressure and kidney disease in adults, and reduced IQ in children⁶³. Children are particularly vulnerable to the effects of lead as they absorb a higher proportion of ingested lead than adults. Also, their developing nervous systems are particularly sensitive to its effects and there is currently no evidence for a threshold for critical lead induced effects⁶⁴. Even low blood lead concentrations have been associated with reduced Intelligence Quotient (IQ) in children and associated behavioural impacts⁶⁵ that may be irreversible⁶⁶. Green and Pain⁶⁷ estimated that least 83,000 children a year in the EU and Britain aged eight years or younger were at risk of suffering a 1 point reduction in IQ from the consumption of game killed with lead-based ammunition. This was linked to an ongoing potential yearly loss of at least 40 million to 104 million Euros to the EU economy for each year that game consumption continues⁶⁸. For those cohorts of children experiencing more than a 1 point IQ loss because of a greater than average consumption of game meats, the costs would be greater. At least 5 million adults across the EU are estimated to be frequent consumers of game⁶⁹ increasing their risks to negative effects on the cardiovascular and renal systems⁷⁰.

The direct loss of wildlife due to lead exposure also has a cost to society, for example through the loss of European species of predatory and scavenging birds that die following the ingestion of lead in contaminated game carcasses⁷¹. It is estimated that about 1 million European waterfowl die from lead poisoning, and three times that number suffer chronic sub-lethal effects⁷². The ingestion of lead shot may also be affecting the population trends of some European wildfowl, including the globally threatened (Vulnerable) Common Pochard (Aythya ferina)⁷³. This avoidable loss of avian biodiversity is of concern to society. Using a “willingness to pay” approach the societal value of wildfowl losses alone was estimated, broadly, to be 2.2 thousand million Euros⁷⁴. Where local governments are required to reclaim accumulated lead from long-abandoned shooting grounds, local authorities must pay for the recovery, which normally far exceeds the value of the lead removed from the ground⁷⁵.

The general public across the EU remain largely unaware of the risks associated with the use of lead ammunition and the related health, environmental and economic costs⁷⁶ incurred by society. On the contrary, there has been promotion by some hunting organisations of game meat as a healthy alternative to meat from domesticated species. This contrasts strongly with relatively high levels of public awareness of the risks associated with lead in petrol, paint, and water, which are all strictly regulated across the EU, as well as other highly recognized historical environmental toxicants, e.g. DDT and mercury. This may initially appear understandable, as societal exposure to lead from these and some other industrial sources was generally of greater magnitude and/or more widespread across the population, especially for lead in petrol. However, lead is unusual in that the dose-effect relationship between blood lead levels and IQ does not appear to be linear, but rather to reflect a greater relative impact at lower lead concentrations⁷⁷. Consequently, for health protection, exposure should be reduced to the minimum possible. Society needs to be aware of and understand the need for this, and that lead from ammunition is one dietary source of exposure that is technically straightforward to remove. High profile global campaigns and publications aimed at increasing lead awareness omit discussion of this remaining, largely unregulated, source of dietary lead exposure⁷⁸. Since 2011, food safety and standards organisations in a range of EU countries have published guidance on the risks to human health associated with the consumption of wild game shot with lead ammunition⁷⁹. These agencies advise pregnant women and children to limit their consumption or avoid eating game shot with lead ammunition. In the UK, the National Health Service (NHS) also advises pregnant women to avoid game meats such as goose, pheasant and partridge that may contain lead shot⁸⁰. However, finding advice from these agencies usually involves proactive searching on websites and it is unlikely that many people are aware of such advice. For example, in the UK, public awareness is more likely to have resulted from the actions of supermarket chain Waitrose than advice provided by the Food Standards Agency and NHS. The company Waitrose is the largest retailer of game meat in the UK and proactively initiated food labelling in 2018, highlighting the risks from lead ammunition to consumers. In 2019, Waitrose pledged that all of the game they sell would be harvested without the use of lead ammunition from the 2020-21 season⁸¹. This received public attention in several major daily newspapers⁸², reaching millions and possibly tens of millions of people.

There is a clear need for greater social awareness of and involvement in decisions relating to the use of lead-based ammunition in Europe, especially given the political influence of the European hunting and ammunition organisations⁸³. The evidence, collectively, warrants a wider adoption of lead substitutes in European hunting and shooting, and the decision by the European Commission to ban the use of lead shot over wetlands marks an important first step in this direction. It is notable though that this recent decision trails behind by three decades of comparable regulatory action taken in the USA (in 1991/92), a country with a broadly similar population size (c.75% of the EU) and double the land area of the EU.

5Complementary Actions to Enhance Compliance with EU Restrictions on the Use of Lead Ammunition and Better Manage Risks

6Conclusion

Lead exerts its toxic effects on humans, wildlife and the environment independent of source, whether from use in paints, gasolines, solders, or hunting ammunition¹¹⁵. In the interests of public and environmental health, EU regulations now restrict most uses, except for ammunition. This omission has been partly dealt with under Regulation (EU) 2021/57 banning the use of lead gunshot cartridges in wetlands. If adopted, the further, broader, restriction proposal covering all lead ammunition and fishing tackle (Table 1), currently under preparation, would correct this omission leading to a virtually complete transition to non-lead hunting ammunition in the EU.

It is important for any EU regulation to be effectively enforced across all member states. Given the highly traditional and locally organised nature of European hunting, weak enforcement of the wetland gunshot ban will be of concern. This is especially the case given low compliance levels with existing long-established regulations in countries such as the UK and Sweden, where a reasonably high level of awareness across the hunting community about the risks associated with lead-based ammunition exists, and alternative ammunition types are available for all applications. However, the ability to monitoring and enforce the wetland restriction will be facilitated by the inclusion of the restriction on carrying lead gunshot within 100 m of a wetland where this occurs while out wetland shooting.

More comprehensive restriction of the use of lead-based ammunition, and its replacement with non-toxic alternatives, as is currently being considered under the next phase of the REACH process, is essential to protect human health, the health of predatory, scavenging and other terrestrial birds and the environment. The introduction of such restrictions would greatly enhance compliance, especially if such restrictions include importation and carrying of lead ammunition in addition to placing on the market and use. This is because a large part of the burden of responsibility would shift from individual hunters to importers and retailers, making monitoring and enforcement straightforward and cost-effective. Comprehensive regulation is also required because ammunition manufacturers need a guaranteed market to innovate and scale up production. While lead ammunition can still be legally purchased and used for some types of shooting, it can also be obtained and used for illegal purposes.

Before such regulation exists, a range of interim measures would reduce risks from lead ammunition, help protect human and environmental health, and help pave the way for a lead-free future. Including wild game as a food for which MLs are set within Regulation (EC) 1881/2006 is an important step to promote healthy food and protect human health. Inclusion of lead from ammunition as a source of dietary exposure within revisions under consideration for the Codex code of practice for the prevention and reduction of lead contamination in foods¹¹⁶ may facilitate this. Establishing MLs of lead in game would also, incidentally, provide one monitoring mechanism for ammunition types used to shoot both wetland and other game species, and be a complementary adjunct to lead ammunition restrictions.

Beneficial policies and practices include adoption of non-lead gunshot types that have passed the stringent USA approval system. This would ensure that one toxic substance is not replaced with another. The rapid introduction of further national or sub-national restrictions with broader reach than the wetland restrictions, as has happened in Denmark and the Netherlands, would be highly beneficial and reduce environmental and human health risks. Measures taken by national agencies, organisations and individual landowners also help to reduce the cumulative and persistent effects of lead contamination, while enhancing awareness and shifting public opinion. Retail organisations can also be influential and effective, as markets are needed for the large amounts of game animals killed annually. Beyond the hunting and shooting communities, public awareness of this issue appears to be low, especially when compared to knowledge of the risks associated with other sources of lead contamination. Food labelling can help with this¹¹⁷, and national food standards and safety agencies should be encouraged to ensure that their advice is proactively publicised to ensure that it reaches those in society most vulnerable to the effects of lead.

The impacts of dietary exposure to lead from ammunition on wildlife have been communicated for far longer than risks to human health, but there remains limited public understanding of the issue, particularly beyond impacts on waterbirds. Public agencies have a responsibility to communicate these risks effectively to European citizens. Hunting organisations have been largely ambivalent about the use of non-lead ammunition but could play a key role in education and awareness, both at national level and across the EU via The European Federation for Hunting and Conservation (FACE). Non-toxic substitutes for lead ammunition are already available and used in the EU. They have been shown to be very effective in hunting all types of game¹¹⁸. The adoption of non-lead ammunition by the European hunting community would increase the sustainability of hunting¹¹⁹ and demonstrate a responsible approach regarding the safety of an important European food source. Economic benefits would also accrue from the adoption of non-lead ammunition for all hunting and shooting. These include benefits to human and environmental health and a reduction in sites where remediation for lead contamination is needed. The use of lead-based ammunition imposes substantial externalized costs to society. Minimum annual costs of a limited selection of the impacts on humans, wildlife, and the environment were estimated at 383–960 million Euros for the EU, and 444 million –1.3 thousand million Euros for Europe¹²⁰. All society, European and beyond, would benefit from the reduced toxic threats to avian biodiversity much of which is already under EU-wide legal protection¹²¹.