EU ban on lead ammunition for airguns, shotguns and rifles

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It shouldn’t be difficult to collate your own statistics, you should be doing it already to monitor the progress of your voluntary transition.
If BASC and other shooting organisations aren’t , wont, or can’t do it, Wild Justice will do it for you.
After all, all the cartridge manufactures were consulted prior to the voluntary transition announcement so they should be happy to help as one would hope the importers would.

What measures did the shooting organisations have in place to monitor the success of the transition?
Thanks both for the suggestions. The latest BASC update on the voluntary transition is here:

 
Thanks both for the suggestions. The latest BASC update on the voluntary transition is here:

So all is good then 😂 do remember the US are not limited to CIP restrictions so any reference to Tom Roster is of limited consequence within the U.K.

However do agree that the jocker cardboard cup wads are the best alternative to traditional fibre.

If the EU push back on a lead ban by adopting a ten year transition period are the U.K. shooting organisation looking to support the HSE if they recommend a three or five year transition or will you (they) try to get the HSE to follow the EU?

Plus it’s all very well having the 150 sustainable cartridges but how many are actually available to buy and affordable an issue the EU appear more concerned about than the U.K. shooting organisation or HSE.

Words are all very woolly, support the success with data, like volume of sales of the sustainable cartridges year on year since 2020.
 
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So all is good then 😂 do remember the US are not limited to CIP restrictions so any reference to Tom Roster is of limited consequence within the U.K.

However do agree that the jocker cardboard cup wads are the best alternative to traditional fibre.

If the EU push back on a lead ban by adopting a ten year transition period are the U.K. shooting organisation looking to support the HSE if they recommend a three or five year transition or will you (they) try to get the HSE to follow the EU?

Plus it’s all very well having the 150 sustainable cartridges but how many are actually available to buy and affordable an issue the EU appear more concerned about than the U.K. shooting organisation or HSE.

Words are all very woolly, support the success with data, like volume of sales of the sustainable cartridges year on year since 2020.
If legislation is enacted for EU (+NI) or GB then I think that will prompt a look at CIP regulations. As regards transition periods before legislation is enacted this no longer sits with HSE, its a government decision - and the following PQ indicates a decision this summer (sometime between 2 June and 22 July when next session of parliament is)

 
Thanks both for the suggestions. The latest BASC update on the voluntary transition is here:

Conor,
That article provides absolutely zero information on the progress or success of the voluntary transition to non lead alternatives for game shooting.
I strongly suspect you knew that.
Your organisation is in the final year of a major project with the potential to impact virtually every aspect of shooting sports, we are coming to the end of the voluntary transition period, what progress has been achieved so far?
You should have some feedback by now, the transition period is almost over.
What were the annual incremental targets?
Have these intermediate goals been met or exceeded?
What criteria and parameters are you using to define the success or failure of the programme?
Given that this is the last year of the transition period, there should be measurable impacts. Lead cartridge use should be showing a measurable decline and that decline should be mirrored in an increase in manufacture, import, sales and use of alternatives.
Has that change, or lack of change, been measured?
If not, why not?
If you are not monitoring use of differing shot types, what parameters are you using to measure and define the programme’s success or failure?
How much has BASC spent on the transition plan so far?

Basic project management requires you to define your goal, strategy, implementation, monitoring and assessment.
You also define success or failure.
What is going on?
 
Conor,
That article provides absolutely zero information on the progress or success of the voluntary transition to non lead alternatives for game shooting.
I strongly suspect you knew that.
Your organisation is in the final year of a major project with the potential to impact virtually every aspect of shooting sports, we are coming to the end of the voluntary transition period, what progress has been achieved so far?
You should have some feedback by now, the transition period is almost over.
What were the annual incremental targets?
Have these intermediate goals been met or exceeded?
What criteria and parameters are you using to define the success or failure of the programme?
Given that this is the last year of the transition period, there should be measurable impacts. Lead cartridge use should be showing a measurable decline and that decline should be mirrored in an increase in manufacture, import, sales and use of alternatives.
Has that change, or lack of change, been measured?
If not, why not?
If you are not monitoring use of differing shot types, what parameters are you using to measure and define the programme’s success or failure?
How much has BASC spent on the transition plan so far?

Basic project management requires you to define your goal, strategy, implementation, monitoring and assessment.
You also define success or failure.
What is going on?
The voluntary transition is ongoing and over the past five years have shown that shooting’s traditions and its adaptability can coexist. By choosing leadership, the shooting community is future-proofing the sport for the next generation. Any news from ROI shooting orgs on the latest EU policy developments?
 
Yes they were.
Like panto season this. OH NO THEY WERENT.

The following quoted from the article linked below:
Since then, representatives from four of the UK's leading cartridge manufacturers, Eley Hawk, Hull, Gamebore and Lyalvale Express, have responded to the call for a voluntary ban on lead and single use plastics in live quarry cartridges.

Their statement says that they were not consulted ahead of the announcement by the shooting organisations, reading:

Firstly, BASC and their fellow organisations had NO consultation with the UK cartridge manufacturers prior to the announcement being made.

 
Like panto season this. OH NO THEY WERENT.

The following quoted from the article linked below:
Since then, representatives from four of the UK's leading cartridge manufacturers, Eley Hawk, Hull, Gamebore and Lyalvale Express, have responded to the call for a voluntary ban on lead and single use plastics in live quarry cartridges.

Their statement says that they were not consulted ahead of the announcement by the shooting organisations, reading:



That's not true. If you don't believe me, ask them.
 
That's not true. If you don't believe me, ask them.
Inconvenient for your argument but yes unfortunately absolutely true.

Please read the below, especially the paragraph in bold.



JOINT STATEMENT FROM LEADING CARTRIDGE MANUFACTURERS​

Joint statement by the Directors of the UK’s leading shotgun cartridge manufacturers – 28th February 2020


From: Rodrigo Crespo of Eley Hawk, Paul James of Gamebore, David Bontoft of Hull Cartridge and Roger Hurley of Lyalvale Express.


We, the UK’s leading shotgun cartridge manufacturers, hereby address the announcement made by BASC and other organisations on Monday 24th February, stating their”wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years”.


Firstly, BASC and their fellow organisations had NO consultation with the UK cartridge manufacturers prior to the announcement being made.



The UK manufacturers have now discussed the matter collectively. We believe the organisations have looked at a limited amount of products and assumed that these are a viable answer to the issue at hand. Unfortunately, this is not the case.


This is a major concern to us for a number of reasons, reasons we would have explained to the organisations prior to the publication of their announcement, had we been given the opportunity to do so.


Europe is currently experiencing a steel shot shortage. A move from lead to steel shot for the majority of UK’s shotgun ammunition will inevitably put more pressure on the market for raw material. This would create further shortages in the short term and push up the price as the steel shot industry invests to increase capacity.



The examples of overseas markets successfully transitioned to steel shot such as Denmark and the USA water-fowling sector, should not be used as proof of a solution. This is because the steel loads used in these markets in any significant volume are loaded with plastic wads. In addition to this, the US and Danish regulations allow steel cartridges to be loaded to a much higher level of performance than here in the UK, to increase the lethality of the pellet.


Limitations to performance levels of steel ammunition currently allowed in the UK mean that we are already facing tougher challenges when developing an effective steel load compared to those used overseas. Couple this with the move away from plastic wads and we are even further limited on performance. We would like to see an increase in the performance levels allowed before we can begin to develop loads effective enough to produce clean, humane kills in the various types of shooting carried out in the UK.


There are indeed a handful of non-lead ammunition options with biodegradable wads currently on the market however, at this stage it is simply impossible to make these commercially viable. We cannot make a complete switch over to these products within a five year period without substantial investment into the industry. BASC and its fellow organisations do not have an understanding of the manufacturing processes involved and are therefore in no position to determine the length of time required to evolve.


Tungsten and Bismuth materials are very limited in their availability and significantly more costly to produce than steel. This will result in huge increases in costs, based on raw material prices, for smaller gauge shooters who cannot use steel. This may price many shooters out of the sport.


Right now, we need to decide which to eliminate- lead or plastic? We cannot avoid using both. At present the only commercially available options are lead shot with fibre wads, steel with plastic wads or unaffordable premium non-lead shot. Shooters and land owners will need to consider these options and then decide which option is preferable going forward.


We must be clear and educate the organisations as to what is realistic and achievable. Although the development of non-lead, non-plastic alternatives are in the early stages of development, it will be considerable time before a full range of options are available to shooters. This process is a long one that will require vast research, development and investment.


Collectively, we do agree that the industry needs to evolve to become more environmentally friendly. We anticipate this happening as larger industries continue to invest in plastic alternatives which will naturally filter down to ours and other smaller industries. These major industries are in a better position to develop the alternatives, the smaller industries such as ours will then follow. It is unrealistic to expect a relatively small industry such as ours to be at the forefront of the development of such materials.



Moving forward we will continue to encourage the use of steel shot where required, but at this early stage we have no alternative option but to support the use of lead with fibre wads as the solution to the issue of plastic pollution. Where non-lead shot is needed, we encourage the shooters to collect their used plastic wads where possible and dispose of them accordingly, as we know many already do so.


Lastly, we are committed to investing into the alternatives. Our collective goal is to develop high performance ammunition for all shotguns and gauges using sustainable materials and therefore secure the future of shooting. We simply ask that the organisations and individual shooters understand that doing this within a five year window without significant support is IMPOSSIBLE.
 
Inconvenient for your argument but yes unfortunately absolutely true.

Please read the below, especially the paragraph in bold.



JOINT STATEMENT FROM LEADING CARTRIDGE MANUFACTURERS​

Joint statement by the Directors of the UK’s leading shotgun cartridge manufacturers – 28th February 2020


From: Rodrigo Crespo of Eley Hawk, Paul James of Gamebore, David Bontoft of Hull Cartridge and Roger Hurley of Lyalvale Express.


We, the UK’s leading shotgun cartridge manufacturers, hereby address the announcement made by BASC and other organisations on Monday 24th February, stating their”wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years”.


Firstly, BASC and their fellow organisations had NO consultation with the UK cartridge manufacturers prior to the announcement being made.


The UK manufacturers have now discussed the matter collectively. We believe the organisations have looked at a limited amount of products and assumed that these are a viable answer to the issue at hand. Unfortunately, this is not the case.


This is a major concern to us for a number of reasons, reasons we would have explained to the organisations prior to the publication of their announcement, had we been given the opportunity to do so.


Europe is currently experiencing a steel shot shortage. A move from lead to steel shot for the majority of UK’s shotgun ammunition will inevitably put more pressure on the market for raw material. This would create further shortages in the short term and push up the price as the steel shot industry invests to increase capacity.



The examples of overseas markets successfully transitioned to steel shot such as Denmark and the USA water-fowling sector, should not be used as proof of a solution. This is because the steel loads used in these markets in any significant volume are loaded with plastic wads. In addition to this, the US and Danish regulations allow steel cartridges to be loaded to a much higher level of performance than here in the UK, to increase the lethality of the pellet.


Limitations to performance levels of steel ammunition currently allowed in the UK mean that we are already facing tougher challenges when developing an effective steel load compared to those used overseas. Couple this with the move away from plastic wads and we are even further limited on performance. We would like to see an increase in the performance levels allowed before we can begin to develop loads effective enough to produce clean, humane kills in the various types of shooting carried out in the UK.


There are indeed a handful of non-lead ammunition options with biodegradable wads currently on the market however, at this stage it is simply impossible to make these commercially viable. We cannot make a complete switch over to these products within a five year period without substantial investment into the industry. BASC and its fellow organisations do not have an understanding of the manufacturing processes involved and are therefore in no position to determine the length of time required to evolve.


Tungsten and Bismuth materials are very limited in their availability and significantly more costly to produce than steel. This will result in huge increases in costs, based on raw material prices, for smaller gauge shooters who cannot use steel. This may price many shooters out of the sport.


Right now, we need to decide which to eliminate- lead or plastic? We cannot avoid using both. At present the only commercially available options are lead shot with fibre wads, steel with plastic wads or unaffordable premium non-lead shot. Shooters and land owners will need to consider these options and then decide which option is preferable going forward.


We must be clear and educate the organisations as to what is realistic and achievable. Although the development of non-lead, non-plastic alternatives are in the early stages of development, it will be considerable time before a full range of options are available to shooters. This process is a long one that will require vast research, development and investment.


Collectively, we do agree that the industry needs to evolve to become more environmentally friendly. We anticipate this happening as larger industries continue to invest in plastic alternatives which will naturally filter down to ours and other smaller industries. These major industries are in a better position to develop the alternatives, the smaller industries such as ours will then follow. It is unrealistic to expect a relatively small industry such as ours to be at the forefront of the development of such materials.



Moving forward we will continue to encourage the use of steel shot where required, but at this early stage we have no alternative option but to support the use of lead with fibre wads as the solution to the issue of plastic pollution. Where non-lead shot is needed, we encourage the shooters to collect their used plastic wads where possible and dispose of them accordingly, as we know many already do so.


Lastly, we are committed to investing into the alternatives. Our collective goal is to develop high performance ammunition for all shotguns and gauges using sustainable materials and therefore secure the future of shooting. We simply ask that the organisations and individual shooters understand that doing this within a five year window without significant support is IMPOSSIBLE.
To repeat, that's not true. If you don't believe me, ask them.
 
To repeat, that's not true. If you don't believe me, ask them.
But it is true, are you asserting that they lied in their press release?
Or that the press release was a forgery (which they never came out publicly to disavow)?

At the time the press release came out I worked at an ammunition manufacturer that had dealings regularly with more than one of the authors of the above letter. They never mentioned the fact that it was a forgery.

So tell me again that it’s not true
 
The voluntary transition is ongoing and over the past five years have shown that shooting’s traditions and its adaptability can coexist. By choosing leadership, the shooting community is future-proofing the sport for the next generation.
Conor, I asked for information regarding the progress of the 5 year voluntary transition program, now in year 4 and rapidly approaching its end date. I understand and accept the principals guiding the introduction of the program.
I would like to know how successful it has been so far and how the success or failure of the program is being measured and how much it’s costing.

Any news from ROI shooting orgs on the latest EU policy developments?
Under the circumstances I regard this question as a bit of a red herring, however, just in case it’s not….
We have banned the use of lead shot over “ wetlands” using the EU definition. We have also banned it in the upland national parks and SSIA areas, this was achieved through a Ministerial order.
As yet our national organisations have not reacted to the rejection of the lead ban by other countries within the EU.
Enforcement of the regulations is virtually non existent and probably not possible due to the way they are worded.
For example, if I drive to my local clay ground, I cross 2 stream’s which are designated wetlands. Under the terms of the order, I cannot legally have lead shotted cartridges in my possession while crossing the wetlands, not even in the boot of my car.
No one has been charged with possession of lead shot cartridges anywhere so far.
 
After all, all the cartridge manufactures were consulted prior to the voluntary transition announcement so they should be happy to help as one would hope the importers would.
Which of course they were not and issued a rebuttal very soon after the BASC "round robin" of February 2020. Except of course "it's all not true". So we are now told. Next we will being told by BASC on here that it's not at all incorrect for whatever else they now deny as true as in fact it was "a big boy that did it and then he ran away".
 
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This was said tongue in cheek -

Liveonce said:
After all, all the cartridge manufactures were consulted prior to the voluntary transition announcement

given the statement from the cartridge manufacturer at the time.

The obvious conclusion is that the voluntary transition has been a complete failure and this leadership concept is just another way of hiding the failure.

Disappointing is that either no measures were put in place to determine progress of the transition or that they do not want to publicly acknowledge guns did not transition away from lead shot in any great way.

Yes we now have so called sustainable cartridges that did not exist five years ago. However filtering out the typical historic sale of non toxic shot sales by wild fowlers, by what volume are they selling that is I would say an important measure. After all what use are they if they are not being used?

If in the summer the government go along with all that the HSE propose we will have possibly five or even just three years remaining of lead shot, whilst the EU may have ten years. It will either see the U.K. lead the way or hit the players hard, be that shooters, manufactures, wholesaler, RFDs, clay grounds, farmers and game shoots.

Not long to wait now.
 
But it is true, are you asserting that they lied in their press release?
Or that the press release was a forgery (which they never came out publicly to disavow)?

At the time the press release came out I worked at an ammunition manufacturer that had dealings regularly with more than one of the authors of the above letter. They never mentioned the fact that it was a forgery.

So tell me again that it’s not true
At that time I worked for BASC and the cartridge manufacturers were consulted so we shall have to agree to disagree and maybe one day someone will write their memoirs covering that time and all the details will emerge. As for the voluntary transition, its ongoing and this continues to be a collaborative effort spanning cartridge manufacturers, estates, retailers, and thousands of shooters. BASC has supported this through Sustainable Ammunition Days, webinars, and close work with the gun trade to provide expert advice on compatibility and safety.
 
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