8 August 2012
The European Chemicals Agency (ECHA), the EU’s regulatory authority on chemicals, has commissioned a study on the use of lead shot. This is significant because the study was initiated through the EU's REACH regulations, which could be used to enforce new restrictions on the manufacturing, placing on the market, or use of lead shot across the EU. The outcome of this process could range from doing nothing to the enforcement of a total ban on the use of lead shot.
The UK’s shooting, trade and countryside management organisations have been working closely together to help address the threat. Through FACE UK they have helped FACE (The Federation of Associations for Hunting and Conservation of the EU) make a case for protecting lead shot from any unwarranted restrictions that might otherwise be proposed as a result of the study.
Whilst this study represents a very real threat to the continued use of lead shot in the UK, the regulations require 15 main steps to be followed before any restrictions can be adopted.
We are currently at step one – preparatory work. Earlier this year Amec Environment & Infrastructure UK Limited (Amec) was contracted by ECHA to gather information on the manufacture, cost and use of lead shot and alternatives in the EU.
The results of this study have now been submitted in a report to ECHA. However, the Amec report has not yet been published. On the basis of the Amec report, ECHA will consult with Sweden (which initiated the REACH process on lead shot) and the European Commission on whether to proceed to step two in the process. No timetable has been set for publication of the Amec report nor when ECHA will begin its consultation with Sweden and the European Commission. Enquiries are being made and this webpage will be updated as soon as we find out more.
We would reach step two if Sweden or the European Commission decided to proceed with a restriction. In doing so they would first have to give notification of their intention to prepare a restriction dossier. ECHA maintains a Registry of Intentions which is publicly available on its website. That enables stakeholders to prepare their contributions to the process.
When FACE was alerted to the Amec study it called on the assistance of all its members to help ensure that any decisions arising from the study would be based on facts and not speculation. The UK’s shooting, trade and countryside management organisations assisted FACE UK with the submission of scientifically valid evidence and relevant information to FACE.
FACE UK believes that ECHA's focus should be on wetlands given that some member states have yet to implement restrictions and many others have only recently done so.
FACE collated all the information received from its members and submitted these in a report to Amec. The FACE report ends by stating that a total ban on the use of lead shot would have a disproportionate negative impact on the greater majority of hunters.
FACE UK, which was founded in 1978, brings together 17 organisations with an interest in existing and potential EU policies and legislation affecting country sports anywhere in the United Kingdom. As a federation it supports the work of FACE both financially and in the provision of expertise.
The FACE UK members are the Association of Masters of Harriers & Beagles; Atlantic Salmon Trust; British Association for Shooting and Conservation; British Deer Society; British Falconers' Club; Countryside Alliance; Game and Wildlife Conservation Trust; Game Farmers’ Association; Hawk Board; Masters of Deer Hounds’ Association; Masters of Fox Hounds’ Association; Masters of Mink Hounds’ Association; National Gamekeepers’ Organisation; Scottish Land and Estates; St Hubert Club; Union of Country Sports Workers and the Welsh Woodcock Club.
In developing its submission to FACE on the Amec study, FACE UK worked closely with representatives of the British Shooting Sports Council, Clay Pigeon Shooting Association, Country Land and Business Association, Deer Initiative, Gun Trade Association, National Game Dealers’ Association and the National Small-Bore Rifle Association.
The secretary of FACE UK is Dr Conor O’Gorman.
Click here to email Conor