Sven Giegold
Member of the European Parliament – Greens/EFA Group

Speaker of the German Green Delegation

Lead in ammunition: No longer any good reasons for using lead in the open countryside

Hunting, munition

I received more than 400 emails about a possible ban on lead in ammunition. My response to these letters can be found below. 

Dear Sir or Madam,

Thank you for your email regarding a possible future ban on lead in ammunition. I took your letter and the letter from a good 400 other citizens as an opportunity to deal with the subject for the first time.

A good school friend of mine, Tim Taeger, has been running the Wilderness and Hunting School JAGWINA in Germany for twelve years. Based on your request, I asked him for his opinion as a practitioner, instructor and as a hunter and thus an expert of the subject. You can find his answer below.

But I would like to briefly go into the details of the European decision-making process. As you know, the European Commission asked the European Chemicals Agency (ECHA) on 16 July 2019 to prepare a proposal to restrict the marketing and use of lead in ammunition. This procedure does neither avoid nor exclude the European Parliament. On the contrary, it follows the regular process of the EU chemicals law REACH which was agreed in 2006 by the Council of the Member States and the European Parliament. ECHA takes this procedure very seriously and tries to collect as much information as possible and to exchange views with all relevant stakeholders. Therefore, a ten-week public consultation took place at the end of last year. Parliament will not be avoided in the further course. If the EU Commission presents a proposal for the restriction of lead in ammunition, the European Parliament has a right of veto and can reject the proposal. We made use of this right recently when we successfully voted against lead in recycled PVC. So you can be sure: as a member of the European Parliament, we will carefully examine the European Commission’s proposal for its correctness and proportionality.

I hope to be able to answer some of your questions and criticisms with Tim Taeger’s answer. In my opinion, the hunting instructor makes a very convincing case that there are no longer any good reasons for using lead in the open countryside for hunting purposes.

With European greetings,

Sven Giegold

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Here is my translation of Tim Taeger’s answer (Wilderness and Hunting School JAGWINA):

Dear Sven,

It is sad that this topic is still being discussed so controversially and emotionally. To my knowledge, the facts are clear: lead is a highly effective environmental poison, to which there are now sufficient alternatives to buckshot and rifle ammunition.

Indisputably lead has very good ballistic properties for projectiles and has therefore been used in buckshot and rifle ammunition for centuries. Since the mid-2000s, however, there is an increased awareness in the general public and in the hunting community of the potential danger of lead bullets for humans and the environment.

In Germany, the legislator reacted to this a few years ago by banning the use of lead shot near water bodies. The use of leaded rifle bullets has so far only been prohibited in some state forest administrations for their administrative hunts.

Lead is a dangerous environmental toxin

I myself became aware of the problem in 2004 through publications by the Institute for Zoo and Wildlife Research (IZW) on the threat to white-tailed eagles from the remainders of lead-containing hunting bullets in the innards of game. At the time, I was responsible for wildlife management in what is now the Buchenwald Grumsin UNESCO World Heritage Site in Northern Brandenburg.

During one of the hunts I did there, in December 2004 with about 80 hunters taking part, I asked Dr. Oliver Krone, from the IZW, to present his results to us. He did this very clearly by X-raying some of the deer that had been shot and shot with lead ammunition using a mobile X-ray machine. The deer had not yet been broken open, so they still had all of their innards in their bodies. The result was the visualization of a large number of lead splinters of various sizes in the entire body.

These lead particles were found primarily in the innards of the animals, which is desirable for the killing effect of the projectiles. Lead particles were also found in the muscle tissue. The innards usually remain in the forest or field when hunting for game.

Under the following link there is a descriptive publication of the German Hunting Association (DJV) from 2011 with similar images and results (in German): https://docplayer.org/22649062-Bleisplitter-im-wildkoerper-eine-exemplarische-untersendung.html

The disastrous thing about the lead residues in the innards is that scavengers, including the sea eagle, find them very quickly after the hunts and pick them up. Since birds of prey have a much more acidic stomach balance than other animals and us humans, the lead that is absorbed is released in a very short timeframe and gets directly into the blood of the eagle. This leads to signs of poisoning in the animals. These poisonings are often not directly fatal, but lead to drowsiness and reduced responsiveness of the eagles. This makes them easy prey for foxes and increases their chances of colliding with trains or wind turbines.

If waterfowl is shot with lead and does not die instantly, these wounded birds will later become easy prey for sea eagles or they will be eaten as carrion after they have died. The lead shot in the birds eventually also gets into the stomachs and blood of the eagles.

Lead poisoning from hunting ammunition was and is therefore the most common cause of death when dead white-tailed eagles are found. There are similar findings on golden eagles from the Alpine region.

Danger to humans

In addition to the danger to birds of prey, the danger to humans by eating game meat contaminated with lead particles has been repeatedly discussed in recent years. The German Federal Institute for Risk Assessment (BfR) has researched and published a number of studies. The final report, from 2014, of a multi-year project on the topic can be found at: https://www.bfr.bund.de/cm/343/forschungsprojekt-lebensmittelsicherheit-von-jagdlich-gewonnenem-wildbret-lemisi.pdf

In summary, it can be said that the BfR has found an increased lead pollution in hunter households. So-called “extreme consumers”, people who eat more than 80 game meals a year, have been found to have a significantly higher lead exposure than normal or heavy game consumers. In hunter households, this lead exposure is sometimes ten times higher than what the general population intakes in lead through food.

“According to a new representative survey by the BfR, 10% of all game consumers are at risk of exceeding the health limit values ​​for lead determined by the European Food Safety Authority EFSA. According to the BfR, 5% of those questioned can ingest lead quantities of concern. This is especially true if they eat venison shot with lead projectiles” (BfR 2011).

The BfR therefore advises especially pregnant women and girls and women of childbearing age, as well as children under the age of seven, to avoid venison shot with lead-containing hunting projectiles. https://www.bfr.bund.de/cm/343/fragen-und-antworten-zum-verzehr-von-wild-das-mit-bleihaltiger-munition-geschossen-wurde.pdf

For me, these are all good reasons to use lead-free hunting bullets. I have been shooting lead-free hunting ammunition since 2004 because of the lead problems of the white-tailed eagle (my territory was home to a breeding pair at the time and up to ten white-tailed eagles were observed in the winter months). In the areas where I am responsible for hunting, this has since been mandatory for all hunting guests. With consistently good experiences.

Campaign against lead-free ammunition

I have heard from hunters for years that lead-free rifle bullets do not work as well and are supposedly more dangerous than lead bullets. But even the German hunting association DJV has now recognized that it is not the material of a projectile that is decisive for its effect, but its construction. https://www.jagdverband.de/welche-munition-funktioniert

However, a stubborn opinion among hunters is that lead-free bullets are no good. How does that come?

Unfortunately, according to my assessment, all common hunting magazine publishers and hunting officials in the middle of the 2000s were all too often accomplices of the German ammunition manufacturers lobby. With the advent of the discussion about the problem of lead-containing hunting bullets for health and the environment, there was a massive, well over ten-year campaign against lead-free hunting bullets in the popular media.

Why? Because no German ammunition manufacturer had lead-free ammunition in its product range, my guess and observation is from that time. When I switched in 2004, there was lead-free hunting ammunition from Finland, the Czech Republic and the USA. But not from Germany. Only when the German manufacturers had caught up with their development backlog and were able to offer lead-free hunting ammunition did the anti-lead-free wave in the German hunting magazines and forums slowly die down.

With the publication of the final report 2012, and its addition in 2014, a research project at the University of Sustainable Development Eberswalde on the killing effect of lead-free projectiles, the opponents of the lead-free hunting projectiles the wind was finally taken out of their sails. As already mentioned above, the report comes to the conclusion that it is not the material but the construction that is decisive for the killing effect of projectiles.

So there is a lot to be said against the use of leaded ammunition and much for the use of appropriately constructed lead-free hunting ammunition.

In my experience from over 20 years of hunting, the perseverance of the hunters is quite high and the anti-lead-free campaign mentioned has also left its desired traces in the minds of the hunters. Therefore, the majority of hunters in Germany – against better knowledge of science – continue to shoot with leaded bullets.

Officially, the innards of game shot with leaded ammunition must be buried (at least in the Land of Brandenburg) in order to be out of reach of birds of prey like the sea eagle. For all of Germany there is a legal ban on the use of lead shot in water bodies. The fact is, however, that practically no hunter buries shot animals and that lead shot is still being used to hunt on water in Germany.

All hunters whom I speak to privately admit this. Everyone has a lead-free alibi shot or rifle cartridge in their jacket pocket, which they can show on request. But shooting continues with lead. When hunting, you are among yourself anyway, the buddies don’t give a whistle and there is no fear of official controls in the woods and fields. As long as lead-loaded ammunition is available, nothing will change in my opinion.

Alternatives are plentiful

There are now plenty of alternatives to lead bullets. Both for rifle ammunition and for shot. For the shot cartridges, shot made of soft iron, tungsten and bismuth have proven to be suitable and harmless. Their killing effect on more than 20,000 ducks, geese and pheasants in the United States, where lead ammunition has been banned near bodies of water since the mid-1990s, was found to be good. In terms of price, soft iron shot is now at the same level as lead. Up to now, it has been necessary to expect the price of lead-free hunting projectiles for rifle bullets to be at least one third more than the price of conventional lead bullets, if you want to stay with the same manufacturer. However, hunting lead bullets from premium German manufacturers sometimes cost more or about as much as cheap lead-free bullets from manufacturers in the Czech Republic or the USA. Lead-free ammunition for hunting shooting training can now also be obtained cheaply from several well-known manufacturers.

Switching from lead bullets to lead-free hunting bullets is generally possible with all hunting rifles. There are plenty of discussion forums for hunters on the Internet and the German DJV also has good tips at the following link: https://www.jagdverband.de/umstieg-auf-alternative-munition

On the other hand, there are often major discussions regarding the switch from lead shot to lead-free alternatives. It is usually argued here that old shotguns are not suitable for such shot. However, this is only partially true. Because modern soft iron shot cartridges are designed so that the shot grains no longer touch the inside of the barrel. They are surrounded by a bag until they leave the barrel. The higher pressure of the soft iron cartridges is more problematic. But in many cases this problem can also be solved with a little effort.

In 2004, an article by G. Schmidt-Colberg, a well-known professional in his field – hunter, target shooter and flint trainer – dealt with this very well and in detail. Quote: “I am not an outspoken supporter of soft iron shot, but given the necessities and the purpose of maintaining the hunt, I have to accept that the world needs a functional, lead-free shot material. And I think that in general for caliber 12 this is the soft iron shot. All previous tests have shown that with an adjustment of the chokes, the shot size and a little sense when removing the insert, soft iron can replace lead. The regulars’ table discussions about limited long-range shooting ability of the soft iron shot can also be silenced: Because with our average shot distance of 27 to 37 meters there are no problems.“ https://djz.de/neues-schrot-fuer-alte-flinten-13-626/

The article also invalidates the arguments of target shooters who, due to their habits, often appear even more inconvincible than hunters. There are also plenty of lead-free alternatives for their weapons. There could only be exceptions for historical muzzle-loading weapons. For all other weapons that have been manufactured since the end of the 19th century, there should now be usable lead-free ammunition.

It would be to be welcomed if, in the event of upcoming legislative changes, including at national level, it was noted that the kill effect of hunting rifle bullets – whether lead-free or leaded – was determined not by the 2,000 joules of impact energy at 100 meters (in the case of roe deer it is only 1,000 joules) but the bullet effectiveness in the target. In terms of animal welfare, it would be desirable if this criterion were taken into account in hunting legislation.

Conclusion

A Europe-wide ban on leaded ammunition would, in my opinion

– lead to no deterioration in the killing effect when shooting at wild animals, if lead-free alternatives are used appropriately

– lead to no deterioration of the hazards of hunting, if lead-free alternatives are used appropriately;

– make venison a recommended, high-quality and safe food for all population groups;

– stop the entry of the environmental toxin lead through rifle and shot projectiles into nature and the environment;

– end the excruciating death of birds of prey, especially those of strictly protected species such as sea and golden eagles from lead poisoning;

– mean additional financial expenditure of approx. 50 euros per year for the average hunter and sports shooter.