A copy of the European and other concerned global scientists’ Open Letter on the Risks of Lead Ammunition published in October 2023 can be found below.
Alternatively, you can download a PDF copy here.
An Open Letter from Global Scientists on the Restriction on the placing on the market and use of lead in outdoor shooting and fishing proposed by ECHA under REACH Regulations1
October 2023
Dear Madam or Sir,
We, the undersigned European and other concerned global scientists, have expertise in quantifying the risks from the toxic effects of lead ammunition to human, wildlife or domestic animal health, and the effectiveness of measures to mitigate them. We are writing to you to express our concern about the continuing risks posed by lead ammunition use, and to highlight recent evidence. Moreover, we:
- Welcome Commission Regulation (EU) 2021/57 restricting the use of lead in gunshot in or around wetlands;
- Applaud the European Commission’s initiative and the substantial body of work, including extensive stakeholder consultations, undertaken by the European Chemicals Agency (ECHA) to produce their Opinion on an Annex XV dossier proposing Restrictions on Lead in Outdoor Shooting and Fishing;
- Agree with the Opinionthat the use of lead in outdoor shooting and fishing requires restriction and that EU-wide action is justified, as proposed by ECHA and adopted by its scientific committees;
- Urge the European Commission, Member States, REACH Committee, European Parliament and European Council and to support this important restriction proposal in the form of the preferred option proposed by ECHA (i.e., without optional derogations);
- Encourage the European Commission to respond to RAC2s recommendations/strong recommendations, especially that:
a) A further analysis of the feasibility for organisations such as the International Olympics Committee, FITASC (Fédération Internationale de Tir aux Armes Sportives de Chasse) and ISSF (International Sports Shooting Federation) to change their requirements regarding the use of lead gunshot in international competitions be conducted.
b) A regulatory maximum level be set for lead in game meat, similar to the maximum levels of lead for meat other than game meat already defined by Commission Regulation (EC) 1881/20063. - Encourage the European Commission to respond to SEAC4s recommendations, especially that:
a) The text of the restriction entry includes the ban of ‘carrying’ of lead ammunition in the field, in line with the restriction on lead gunshot in wetlands.
b) Education, particular if supported by influential groups (peers, associations or clubs) can be an effective tool to convince users to switch to lead-free alternatives, as complementary awareness-raising measure accompanying a ban. - Urge the International Olympics Committee (IOC), FITASC and ISSF to require the use of non-lead ammunition for Olympic shooting disciplines to ensure reduced exposures of lead to athletes and the environment and to meet the IOC’s strategic intent of ensuring that the Olympic Games are at the forefront of sustainability.
Our concerns result from the risks posed to human, animal and environmental health by lead from ammunition as documented by an overwhelming body of scientific evidence and highlighted in several Scientific Consensus Statements (A Consensus Statement of Scientists 2013; Scientific Consensus Statement 2014) and Special Issues of Journals (e.g., Kanstrup et al. 2019) in addition to the ECHA Background Document. Since the date of intention of the restriction proposal (03-Oct-2019) considerable additional research on risks from lead ammunition use for outdoor shooting and associated mitigation measures has been published. While some will have been incorporated in the restriction dossier, much will supplement it. This recent evidence is reviewed in summary in the appended document. It highlights that, in Europe:
- risks exist for a yet wider range of wild avian and mammalian species;
- risks extend not only to livestock but also to companion animals;
- negative effects are seen at ever lower levels of exposure;
- populations of some protected species are likely to be substantially suppressed by secondary ingestion of lead from ammunition.
Additionally, the range of suitable non-lead ammunition has increased including shot and both large and small calibre bullets, and most constraints on the use of non-lead ammunition have been, or could readily be, overcome. This is highlighted by the Danish government’s decision, supported by The Danish Hunters’ Association, to ban lead bullets for hunting by April 2024, as a supplement to their 1996 ban on all use of lead shotgun ammunition. Only the replacement of all lead ammunition with non-toxic alternatives will adequately control the risks.
We, the undersigned scientists, are a group of 81 professionals from 14 European Countries (11 EU countries) and seven countries beyond Europe across six continents. We work in various relevant disciplines, and include scientists and other professionals with expertise in this issue who are hunters, veterinarians, conservationists, human health specialists and social scientists. We urge relevant bodies from across the European Union to support this restriction proposal on the use and placing on the market of lead in outdoor shooting and fishing to protect the health of people, wildlife and the environment. This is also an important step towards meeting the European Commission’s zero pollution ambition under the European Green Deal, and will contribute to the pollution reduction commitment under Target 7 of the Kunming-Montreal Global Biodiversity Framework, with positive ramifications for people and wildlife globally.
Our Open Letter can be found here and its appendix can be found here.
Yours faithfully,
Caroline Allen, MA VetMB CertSAM MRCVS
RSPCA Chief Veterinary Officer, RSPCA, ODI, 203 Blackfriars Rd, London, UK.
Dr Oddgeir Andersen, PhD
Senior Research Scientist, Norwegian Institute for Nature Research – NINA, Fakkelgården, NO-2624 Lillehammer, Norway.
Alessandro Andreotti, MS
Senior Researcher, Italian Institute for Environmental Protection and Research, Bird Migration Branch, Via Ca’ Fornacetta 9, 40064 Ozzano dell’Emilia (BO), Italy.
Professor Jon M. Arnemo, DVM, PhD
Professor, Wildlife Veterinarian, Inland Norway University of Applied Sciences, NO-2418 Elverum, Norway, and Swedish University of Agricultural Sciences, SE-901 83 Umeå, Sweden.
Enrico Bassi, MSc
Wildlife scientific consultant. Vulture Conservation Foundation Advisory Board Member, Chair of the Steering Committee of International Bearded Vulture Monitoring, Vice President of CISO – Centro Italiano Studi Ornitologici. Bergamo, Italy.
Nicola Bates, BSc (Brunel), BSc (Open), MSc, MA, SRCS
VPIS Research Lead, Veterinary Poisons Information Service (VPIS), London, UK.
Dr. Val Beasley, DVM, PhD, Diplomate, American Board of Veterinary Toxicology
Retired Professor, Veterinary, Wildlife and Ecological Toxicologist, 198 Blackberry Hill, Port Matilda, PA 16870, USA.
Dr Aksel Bernhoft, PhD
Senior Scientist, Veterinarian/Toxicologist, Feed Safety Expert, Norwegian Veterinary Institute, PO Box 64, NO-1431 Aas, Norway.
Associate Professor Łukasz J. Binkowski, PhD
Institute of Biology and Earth Sciences, Pedagogical University of Krakow, 30-084 Kraków, Podchorążych 2, Poland.
Professor Alan R. Boobis OBE PhD FBTS FBPhS
Emeritus Professor of Toxicology, Imperial College London, Ducane Road, London W12 0NN, UK.
Professor Asa Bradman, PhD
Professor, Department of Public Health, University of California, Merced, USA.
Associate Professor Scott Michael Brainerd, PhD
Inland Norway University of Applied Sciences, Faculty of Applied Ecology, Agricultural Sciences and Biotechnology, Anne Evenstadsvegen 80, NO-2480 Koppang, Norway.
Anne-Fleur Brand, DVM, MSc, MRCVS
PhD Candidate, Norwegian University of Science and Technology, Høgskoleringen 5, Trondheim, Norway, 7034 Trondheim, Norway.
Professor Eric Buenz, PhD, MBA, MAgr
Research Professor of Applied Industries, Nelson Marlborough Institute of Technology (NMIT), Te Whare Wananga o Te Tau Ihu o Te Waka a Maui, 322 Hardy St, Private Bag 19, Nelson 7042, New Zealand.
Professor Andrea Caselli, DMV
Director, Community-based Territory Conservation Program (PCCT), Faculty of Veterinary Sciences, National University of the Center of the Province of Buenos Aires, University Campus, 7000 Tandil, Argentina.
Dr Ruth Cromie, PhD
Research Fellow, Wildfowl & Wetlands Trust (WWT), Slimbridge, Glos. GL2 7BT, UK.
Sandra Cuadros
Researcher Affiliate, Hawk Mountain Sanctuary Kempton, Pennsylvania, USA /PhD candidate at UBCO Kelowna, Canada.
Professor José Antonio Donázar, PhD
Research Professor, Department of Conservation Biology, Estación Biológica de Doñana CSIC; Avenida de Americo Vespucio s/n, Isla de la Cartuja, E-41092 Sevilla, Spain.
Professor Alan Emond, MA, MD, MBB Chir(Cantab), FRCP, FRCPCH
Emeritus Professor of Child Health, Centre for Academic Child Health, Bristol Medical School, Canynge Hall, 39 Whatley Rd, Bristol BS8 2PS, UK.
Associate Professor Ane Eriksen, PhD
Professor (Associate), Inland Norway University of Applied Sciences, Faculty of Applied Ecology, Agricultural Sciences and Biotechnology Campus, Evenstad N-2480 Koppang, Norway.
Professor Alina Evans, DVM, MPH, PhD
Professor in Wildlife Health, Institute of Forestry and Wildlife Management, Inland Norway University of Applied Sciences, Evenstad, Norway.
Dr William E Faber, PhD
Natural Resources Program Lead, Central Lakes College, Dept. of Natural Resources, 501 W. College Dr., Brainerd, MN, 56401, USA.
Professor Jerzy Falandysz, PhD, DSc
Professor in the Department of Toxicology, Faculty of Pharmacy, Medical University of Lodz, Poland.
Adjunct Professor Myra Finkelstein, PhD
Microbiology and Environmental Toxicology Department , University of California Santa Cruz, 1156 High St., Santa Cruz, CA 95064, USA.
Professor Anthony D Fox, PhD
Professor of Waterbird Ecology, Department of Ecoscience, Aarhus University, C.F. Møllers Allé 8, DK-8000 Aarhus, Denmark.
Dr Philippe Grandjean, MD, DMSc, dr.h.c.
Professor of Environmental Medicine, University of Southern Denmark, Odense, Denmark.
Dr Huw Golledge BSc (Hons), PhD
Chief Executive Officer and Scientific Director – Universities Federation for Animal Welfare, The Old School Brewhouse Hill Wheathampstead Hertfordshire AL4 8AN, UK.
Professor Andy Green, PhD
Research Professor, Estación Biológica de Doñana, Spanish Council for Scientific Research (CSIC), Spain.
Professor Rhys E Green, PhD
Emeritus Honorary Professor of Conservation Science, Department of Zoology, University of Cambridge, Downing Street, Cambridge, CB2 3EJ, UK.
Dr Jordan Hampton, BSc, BVMS, PhD
Research Fellow, Faculty of Science, University of Melbourne, Parkville, Victoria, Australia.
Dr Catherine Hauw, DVM MRCVS MSc Wild Animal Health
Veterinary surgeon, c/o Royal Veterinary College, UK, 6 Rue du Collège de l’Arc, 39100 Dole, France.
Dr Björn Helander, PhD
retired Senior Scientist, Environmental Research & Monitoring, Swedish Museum of Natural History, Box 50007, SE-104 05 Stockholm, Sweden.
Carrol L. Henderson
Minnesota Department of Natural Resources-Retired, State Nongame Wildlife Program supervisor, 1977-2018, Blaine, MN, USA. Frances K. Hutchinson Medal. Garden Clubs of America, 2017 – Top conservationist in America.
Professor Howard Hu, MD, MPH, ScD
Professor & Flora L. Thornton Chair, Department of Population and Public Health Sciences, Keck School of Medicine of USC, University of Southern California, Soto Street Building, Suite 330A, 2001 N Soto Street, MC 9239, Los Angeles, CA 90089-9239, USA.
Dr Helle Bernstorf Hydeskov, MSc, DVM, MVetMed, DipECZM (Wildlife Population Health), SFHEA, MRCVS, EBVS
European Veterinary Specialist in Wildlife Population Health, School of Animal, Rural and Environmental Sciences, Nottingham Trent University, Brackenhurst Campus, Southwell, NG25 0QF, UK.
Dr David E Jacobs, PhD
Chief Scientist, National Center for Healthy Housing, Adjunct Associate Professor, University of Illinois Chicago School of Public Health, Chicago, Illinois, USA.
Jean Jalbert, MSc, MSc Ag Eng
General Director, Fondation Tour du Valat, Research Institute for the Conservation of Mediterranean Wetlands, Le Sambuc, 13 200 Arles, France.
Professor Emeritus Lukas Jenni, PhD
Emeritus Scientific Director (retired), Swiss Ornithological Institute, Seerose 1, CH-6204 Sempach, Switzerland.
Dr Niels Kanstrup, DSc
Special Consultant, Wildlife Biologist, Department of Ecoscience, Campus, Aarhus University, Denmark.
Dr Terra Kelly, DVM, PhD, Dipl ACZM
Wildlife Epidemiologist, Director, EpiEcos, 3865 N Steves Blvd, Flagstaff, Arizona 86004 USA.
Jeff Knott
Director of Policy & Advocacy, RSPB, The Lodge, Sandy, UK.
Dr Helle Katrine Knutsen, PhD
Senior Scientist, Department of Environment and Health, Norwegian Institute of Public Health, P.O. Box 222 Skøyen, N-0213 Oslo, Norway
Professor Michael J. Kosnett, MD, MPH
Associate Adjunct Professor, Department of Environmental and Occupational Health, Colorado School of Public Health, Aurora, CO, USA.
Dr med vet Oliver Krone
Veterinary specialist for Zoo-, Enclosure- and Wild Animals, Veterinary specialist for Parasitology, Eurasian Director Raptor Research Foundation, Assistant Editor Journal of Wildlife Research, Head of the parasitological and toxicological labs, Department of Wildlife Diseases Leibniz Institute for Zoo and Wildlife Research, Alfred-Kowalke-Str. 17, 10315 Berlin, Germany.
Professor Bruce P. Lanphear, MD, MPH
Professor of Children’s Environmental Health, Simon Fraser University, Vancouver, British Columbia, Canada.
Dr Maja Lazarus, PhD
Scientific Adviser, Analytical Toxicology and Mineral Metabolism Unit, Institute for Medical Research and Occupational Health, Ksaverska cesta 2, P.O. Box 291, HR-10001 Zagreb, Croatia.
Dr Catharina Ludolphy, PhD
Postdoc at the Department of Wildlife Sciences, Faculty of Forest Sciences and Forest Ecology, University of Goettingen, Buesgenweg 3, 37077 Goettingen, Germany.
Professor Rafael Mateo Soria, DVM, PhD
Group of Wildlife Toxicology, Instituto de Investigación en Recursos Cinegéticos (IREC) – Institute for Game and Wildlife Research, CSIC-UCLM-JCCM, Ronda de Toledo 12, 13005 Ciudad Real, Spain.
Professor Andrew E. McKechnie, PhD,
South African Research Chair in Conservation Physiology, University of Pretoria, Pretoria, South Africa.
Professor Andrew A. Meharg, FRSE, MRIA
School of Biological Sciences, University Road, Belfast BT7 1NN, UK.
Dr Erica A Miller, DVM
Senior Research Investigator and Field Operations Manager, University of Pennsylvania School of Veterinary Medicine, Wildlife Futures Program, Kennett Square, Pennsylvania, USA.
Professor Stein R Moe, PhD
Head of Section Ecology and Natural Resource Management, Norwegian University of Life Sciences, Faculty of Environmental Sciences and Natural Resource Management, P.O. Box 5003, NO-1432 Aas, Norway.
Dr Paola Movalli, PhD
Pharmacist, PhD Food & Environmental Toxicology, Ecotoxicologist, Research Group Prof Koos Biesmeijer, Naturalis Biodiversity Center, Darwinweg 2, 2333 CR Leiden, The Netherlands.
Prof Vinny Naidoo, PhD
Professor in Veterinary Pharmacology, Faculty of Veterinary Science, University of Pretoria, South Africa.
Dr Julia Newth, PhD
Ecosystem Health & Social Dimensions Manager, Wildfowl & Wetlands Trust (WWT) Slimbridge, Glos. GL2 7BT, UK.
Professor Ian Newton, DSc, OBE, FRS, FRSE
Emeritus Fellow, NERC Centre for Ecology & Hydrology, Benson Lane, Crowmarsh Gifford, Wallingford OX10 8BB, UK.
Professor Dan Osborn, BSc, PhD, CBiol, MRSB
Emeritus Professor of Earth Sciences, Editor-in-Chief, UCL Open: Environment, Department of Earth Sciences, UCL, London, UK.
Professor Deborah Pain, DPhil
Honorary Research Fellow, Department of Zoology, University of Cambridge, Downing Street, Cambridge, CB2 3EJ, UK.
Professor Christopher M. Perrins, LVO, FRS
Emeritus Professor, Edward Grey Institute of Field Ornithology, Department of Biology, University of Oxford, South Parks Road, Oxford OX1 3SZ, UK.
Dr Nikolai Petkov, PhD
Project Manager, Bulgarian Society for the Protection of Birds, PO Box 50, BG-1111 Sofia, Bulgaria.
Associate Professor Emeritus Mark A. Pokras, DVM
Wildlife Clinic & Center for Conservation Medicine, Tufts University, Cummings School of Veterinary Medicine, N. Grafton, MA, 01536, USA.
Dr Robert H. Poppenga, DVM, PhD, DABVT
Head, Toxicology Section, California Animal Health and Food Safety Laboratory, School of Veterinary Medicine, University of California, Davis, CA 95616, USA.
Dr Jannikke Räikkönen, PhD
Department of Environmental Research and Monitoring, Swedish Museum of Natural History, Box 50007, SE-104 05 Stockholm, Sweden.
Professor Patrick T. Redig, DVM, PhD
Professor of Avian Medicine and Surgery Emeritus, Founder and Director of The Raptor Center Emeritus, College of Veterinary Medicine, University of Minnesota, St. Paul, MN 55018, USA
Dr. Keisuke Saito, DVM
President of the Institute for Raptor Biomedicine Japan, Kushiro Hokkaido Japan.
Professor Emeritus Hans Martin Seip
Dept. of Chemistry, University of Oslo, Postboks 1033 Blindern, 0315 Oslo, Norway.
Alick Simmons, BVMS, MSc, DipAABAW
former UK Government Deputy Chief Veterinary Officer, Vinces, Barrington, Ilminster, Somerset, UK.
Dr Hanneline Smit-Robinson, PhD
Head of Conservation, BirdLife South Africa, Johannesburg, South Africa.
Professor Don Smith, PhD
Associate Dean of Graduate Studies and Postdoctoral Affairs, Distinguished Professor, Microbiology and Environmental Toxicology, University of California, Santa Cruz, CA 95064, USA.
Professor Christian Sonne, Veterinary Ecotoxicology and Wildlife Health DVM, PhD, dr.med.vet., Dipl. ECZM-EBVS (Wildlife Health)
Aarhus University, Faculty of Technical Sciences, Department of Bioscience, Arctic Research Centre (ARC), Danish Centre for Environment and Energy (DCE), Frederiksborgvej 399, POBox 358, DK-4000 Roskilde, Denmark.
Professor Chris J Spray, MBE, PhD, FCIEEM
Emeritus Professor of water science and policy, UNESCO Centre for Water Law, Policy & Science, University of Dundee, Dundee DD1 4HN, UK
Dr Brian Stollery, PhD
Senior Lecturer in Experimental Psychology, School of Psychological Science, Faculty of Life Sciences, University of Bristol, 12a Priory Road, Bristol BS8 1TU, UK.
Dr Mark Taggart, PhD
Senior Research Fellow, Group Leader: Pollution, Environmental Research Institute, University of the Highlands and Islands, Castle St, Thurso, KW14 7JD, UK.
Dr Patricia Mateo Tomás, PhD
Lecturer, Biodiversity Research Institute (IMIB, University of Oviedo-CSIC-Principality of Asturias), Spain.
Dr Caroline Taylor, BSc, PhD
Associate Professor, Centre for Academic Child Health, Bristol Medical School, University of Bristol, Canynge Hall, 39 Whatley Rd, Bristol BS8 2PS, UK.
Dr Vernon G. Thomas, PhD
Professor Emeritus, Department of Integrative Biology, College of Biological Science, University of Guelph, Guelph, Ontario N1G 2W1, Canada.
Dr Marcela Uhart, DVM
Director Latin America Program, One Health Institute, School of Veterinary Medicine, University of California, Davis, Member, OIE Working Group on Wildlife, South America Coordinator, IUCN Wildlife Health Specialist Group, Los Alerces 3376, Puerto Madryn Chubut (9120), Argentina.
Dr Antonio Uzal, PhD
Senior Lecturer in Wildlife Conservation, Nottingham Trent University, School of Animal, Rural and Environmental Sciences, Nottingham Trent University, Brackenhurst Campus, Southwell, NG25 0QF, UK.
Linda van den Heever
Species Conservation Programme Manager, BirdLife South Africa, Johannesburg, South Africa.
Dr Stefano Volponi, PhD
Ricercatore, Istituto Superiore Protezione e Ricerca Ambientale (ISPRA), Area CFN – Pareri tecnici e strategie di conservazione via Ca’ Fornacetta 9 – 40064 Ozzano Emilia, Bologna, Italy.
Professor Barbara Zimmermann, PhD
professor at the Department of Forestry and Wildlife Management, Inland Norway University of Applied Sciences, NO-2418 Elverum, Norway.
[1] REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation & restriction of Chemicals. ECHA is the European Chemicals Agency.
[2] ECHA’s Committee for Risk Assessment (RAC).
[3] According to Commission Regulation (EC) 1881/2006, the maximum levels of lead for meat (muscle) and for the offal of cows, sheep, pigs and poultry are 0.10 and 0.50 mg/kg wet weight respectively.