I will be seeing my MP's "team" tomorrow in the Mid Leicestershire Constituency Office at 11.00am and will present my argument and the letter below. I hope that others may, if they also think they may have need to use shotguns on deer (or .22 Rimfire or 9mm Rimfire "Garden Guns" on anything else) may feel able to cut, copy, paste, paraphrase the letter if it helps them and contact their MP:
REACH (Amendment) Regulations 2026 (SI 2026/195)
Dear XXX
I am concerned of the unintended effects of a recent Westminster proposed Statutory Instrument laid before Parliament on 3 March 2026.
The REACH (Amendment) Regulations 2026 (SI 2026/195) is the Statutory Instrument (SI) that legalizes the ban on lead ammunition in England, Wales, and Scotland. It comes into force on 1 April 2026, initiating a phased transition period leading to full restrictions on the sale and use of most lead ammunition by 2029.
This SI is in fact not a "done deal" and can still be stopped coming into force if MPs object by what I am told is known a laying a prayer. There is thirty days to do this from when the SI is laid before Parliament.
The SI seems to have totally failed to take account of the needs of those owners and occupiers of enclosed land that rely on the one and only firearm that they might have...a 12 bore shotgun...to protect the crops, foodstuffs or plantings from damage by deer.
The law specifically allows them to do this and therefore recognises and permits exceptionally to them, and them only, the use of a 12 bore shotgun to kill derr because of that unique position. The law applying is as below.
In England and Wales it is the section 7 of the Deer Act 1991
On any cultivated land, pasture or enclosed woodland, deer may be shot during the close season and a shotgun can be used in certain circumstances [see below] in order to prevent damage. This action may be taken by the occupier of the land in person and with his written permission by:
Any member of the occupier’s household normally resident on the land;
Any person in ordinary service of the occupier of the land;
Any person having the right to take or kill deer on the land;
Any person acting with written authority of a person having that right.
If a shotgun is to be used, the following conditions apply
It must be not smaller than a 12 bore;
AAA shot ONLY may be used, or
A single non-spherical projectile weighing not less than 22.68 grammes (350 grains)
In Scotland it is The Deer (Firearms etc.) (Scotland) Order 1985.
This says as here below:
The Deer (Firearms etc.) (Scotland) Order 1985
4. Where an occupier of agricultural land or of enclosed woodlands has reasonable grounds for believing that serious damage will be caused to crops, pasture, trees or human or animal foodstuffs on that land if the deer are not killed, it shall be lawful for any of the persons described in paragraphs (c), (d) and (e) of section 33(3) of the Act to use a shot gun whose gauge is not less than 12 bore and which is loaded with the following lawful ammunition:-
(a) for shooting deer of any species, a single rifled non-spherical projectile weighing not less than 380 grains (24.62 grams); or
(b) for shooting deer of any species, a cartridge purporting to contain not less than 550 grains (35.64 grams) of shot, none of which is less than 0.268 inches (6.81 millimetres) in diameter, that is to say size SSG; or
(c) for shooting roe deer, a cartridge purporting to contain not less than 450 grains (29.16 grams) of shot, none of which is less than 0.203 inches (5.16 millimetres) in diameter, that is to say size AAA,
for the purpose of taking or killing any deer found on any arable land, garden grounds or land laid down in permanent grass (other than moorland and unenclosed land) and forming part of that land or on enclosed woodland, as the case may be.
There is no suitable non-lead ammunition available here in the United Kingdom of any of the types commonly referred to as "slug" ammunition after the often used "Brenneke slug" or "Forster slug" and of the types that are commonly referred to as "buckshot" or by older users the now archaic name "lettered shot" from those letters SSG or AAA in the relevant laws.
Some will say that there is in America, but it is not imported here, what is called “sabot” slug in non-lead in 12 bore. But this is specifically designed for use in rifled barrel, not smoothbore barrel, 12 bore pump-action or self-loading guns and so is unusable in our shotguns we have here that are by law defined as smoothbore. For under British Law a rifled barrel pump action 12 bore gun or a rifled barrel self-loading 12 bore gun is a Firearms Act s5 “prohibited weapon”.
Thus the SI if not modified by it being opposed by the threat of laying of a prayer will remove the ability of those in England, Wales and Scotland with enclosed land who own only 12 bore shotguns on Shotgun Certificates to control deer.
Creating, if not opposed, an otherwise unintended consequence that those then being unable to use 12 bore shotguns held on Shotgun Certificates past April 2029 will the seek authority to acquire rifles and ammunition for rifles on Firearm Certificates that otherwise they would not need to have and be burdened also with all the associated expense of such.
I note that the SI under paragraph 23(a) exempts a calibre of less than 6.17mm form this ban. I hope that this may be better made clear in regard to .22 Rimfire shotgun cartridges and perhaps also in relation to the AAA lead shot of the Deer Act and Deer (Scotland) Order as AAA lead shot is 5.16mm in diameter?
Can it be made clear if this paragraph 23(a) will permit the continued use and sale for all purposes on .22 Rimfire shotgun ammunition loaded in most cases with shot under “size #8” of 0.06 grams weight. Used in such guns as the .22 Rimfire Webley & Scott smoothbored bolt action “Garden Gun” shotgun and other makes?
And in connection with that there is also the 9mm Rimfire Webley & Scott smoothbored bolt action “Garden Gun” and other makes. This uses 9mm Rimfire shotgun ammunition loaded in most cases with shot under “size #8” of 0.06 grams weight.
There is no non lead ammunition anywhere for 9mm Rimfire or .22 Rimfire so again this will have an unintended consequence of owners possibly then purchasing other shotguns in more powerful calibres which will have non lead ammunition to use instead.
Statutory Instrument 1986 No. 1992 The Control of Pollution (Anglers' Lead Weights) Regulations 1986 which addressed freshwater anglers use of lead shot does not apply to lead weights of 0.06 grams and allows there continued use as it saw no danger to birds from lead shot of weight of or below 0.06 grams.
It is likely that the whole weight of lead shot fired throughout England, Wales and Scotland by each single individual user or .22 Rimfire and 9mm Rimfire “Garden Gun” shotguns is less that that fired by one single individual so called “elite athlete” in a full day’s practice.
Therefore I ask that the proposed regulations be re-worded to also exempt at paragraph 23 shotgun ammunition of .22 Rimfire or 9mm Rimfire calibre loaded with lead shot of 0.06 grams, or less, weight which would be “size #8”.
Thank you for accepting this correspondence which is not an attempt to create a smokescreen to allow the use past April 2029 of lead shot but a genuine expression of concern.
That the proposed regulations have overlooked the section 7 of the Deer Act 1991 and the Deer (Firearms etc.) (Scotland) Order 1985.
Nor is there clarity if its own paragraph 23 (a) apply to .22 Rimfire shotgun cartridges.
Nor is the commonsense of the Statutory Instrument 1986 No. 1992 The Control of Pollution (Anglers' Lead Weights) Regulations 1986 applied to exempting .22 Rimfire or 9mm Rimfire shotgun cartridges loaded with shot of “size #8” or smaller lead shot.
I hope that you might, please, be able to at this late stage raise a prayer against the intended SI unless it is looked at again in respect of what seem the overlooked matters I have raised?
With best wishes,
www.tds-us.com
