Author: RaptorPersecutionUK

Two weeks ago Defra made it’s long-awaited announcement that a ban on the sale and use of toxic lead ammunition (with limited exceptions) would be coming in to force across England, Wales and Scotland in 2029 (see here).

Although the precise details of the ban have yet to be revealed, the news was welcomed across the board by conservation organisations, many of whom have spent decades campaigning against toxic lead ammunition because of the damage it causes to wildlife (especially waterbirds and raptors), the environment and human health.

An excellent summary article was published last week welcoming the ban and discussing its potential impact, published by The Conversation and written by two leading scientists who have been at the forefront of academic research into the use of toxic lead ammunition in the UK – Professor Rhys Green and Dr Debbie Pain. It’s well worth a read for a general overview for those new to this topic.

The government intends to introduce the new legislation by summer 2026 and a three-year transition period will follow (so effectively this is a four-year transition period from the date of Defra’s announcement). This is a shorter transition period than the five-year transition period proposed by the Health & Safety Executive and government sources tell me the shorter transition period was preferred by Defra and the devolved governments in Wales and Scotland ‘because the original five-year transition was proposed due to Covid-19 manufacturing delays, which have now returned to pre-pandemic levels‘.

I don’t know what evidence Defra used to decide that manufacturing levels have rebounded but it’s clear that a number of the game shooting organisations are intending to lobby for a return to the five-year transition period because they don’t think that non-toxic ammunition is ‘readily available’.

If it isn’t readily available, then what ammunition are the thousands of wildfowlers using, given that lead ammunition has been banned for killing waterfowl in England since 1999, in Wales since 2002, and banned for use over wetlands in Scotland since 2005?

Although a series of scientific studies have shown that compliance with those bans is poor (see here, here and here), it seems highly unlikely to be due to a lack of available non-toxic lead ammunition and more likely to be down to arrogance by those shooters who, by their own admission, don’t accept the justification for a lead ban and so carry on using it knowing that enforcement measures are mostly non-existent. There’s a clear lesson there for the English, Welsh and Scottish governments and the enforcement authorities when the wider ban is finally in force in 2029.

Since Defra’s announcement about the ban two weeks ago, apart from whining about the shortened transition period away from toxic lead ammunition, a number of the game-shooting organisations have been undertaking a gaslighting exercise with extraordinary claims about their environmental foresight.

It’s been interesting to watch because from what I’ve been reading online, many, many gamebird shooters still do not recognise the need to move away from toxic lead ammunition – they simply see it as a threat to their bird-killing hobby/industry – and they’re furious with their membership organisations for what is perceived as ‘rolling over’ to the pressure.

The gaslighting clearly hasn’t impressed the shooting organisations’ members, so I can only conclude it’s for the benefit of Ministers and civil servants.

Here are some examples.

The Moorland Association responded to Defra’s lead ban announcement by proclaiming:

“Grouse moors: Leading the transition. Our moors have already been paving the way. Sporting organisations, including the MA, GWCT, BASC and others, voluntarily endorsed a five-year lead-free target back in 2020“.

Ah, yes, the five-year so-called ‘voluntary transition’ away from using toxic lead ammunition (2020-2025) that failed spectacularly!

Peer-reviewed evidence produced by scientists at the University of Cambridge in 2025 at the end of the voluntary five-year transition period showed that of 171 Pheasants found to contain shot, 99% of them had been killed with lead ammunition.

And as for Red Grouse – the same study also analysed shotgun pellets found in Red Grouse carcasses shot in the 2024/25 shooting season and on sale through butchers’ shops and online retailers. In all 78 grouse carcasses from which any shot was recovered, the shot was lead.

Quite how these results translate to: ”Grouse moors: Leading the transition. Our moors have already been paving the way‘ is anyone’s guess.

Then there was the response by the Countryside Alliance:

“This is an important step for the future of shooting, which will benefit the countryside and rural economy. The Alliance has long advocated a move away from lead ammunition which is necessary and beneficial“.

I’m interested in the Countryside Alliance’s definition of “long“. Yes, it was one of the nine organisations that signed up to the (now failed) five-year ‘voluntary transition’ away from toxic lead ammunition in 2020 but what was the Countryside Alliance saying prior to that?

Oh, this –

And this –

And this –

That doesn’t look to me like evidence of the Countryside Alliance having “long advocated” for a move away from toxic lead ammunition – it looks like gaslighting.

And what about BASC? What has it had to say?

Apart from clapping itself on the back for participating in the (now failed) five year ‘voluntary transition’ from 2020-2025, BASC said:

“Today’s announcement confirms that the Government plans to introduce legislation to restrict lead ammunition by summer 2026, with a further three-year transition period running until 2029.

“In doing this, the Government has shortened the expected timeframe for shotgun ammunition from five years to three years on the assumption that the ammunition is readily available – that is not the case for commercial and supply reasons beyond our sector’s control, and we urge government to adhere to a five-year timescale proposed by the Health and Safety Executive“.

Hang on a minute! Wasn’t it BASC that proclaimed “significant progress” had been made at the end of the so-called voluntary transition period in 2025? And wasn’t it BASC who said:

“Market-led solutions have emerged, with more than 150 sustainable cartridge options now available, and many shooters have successfully transitioned to lead-free ammunition” (see here).

Surely BASC wasn’t lying when it made these claims in March 2025?

We already know how consuming toxic lead ammunition can lead to a wide range of health risks in humans (e.g. see here). It seems to me there’s scope for examining its effect on short and long-term memory loss, too.

Press release from Defra (10 July 2025):

TOXIC LEAD AMMUNITION BANNED TO PROTECT BRITAIN’S COUNTRYSIDE

• New ban on use of lead in ammunition to protect iconic wildlife and clean up the nation’s waterways
• Restrictions will help prevent release of an estimated 7,000 tonnes of lead into the environment each year
• Aim to legislate the ban by summer 2026, with three-year transition period to give shooting and hunting sectors time to shift to more environmentally friendly alternatives

Red kites and white-tailed eagles will receive greater protection thanks to new restrictions on the use of lead in ammunition, Environment Minister Emma Hardy announced today.

To protect iconic British wildlife and clean up the nation’s waterways, new measures will ban shot containing more than 1% lead and bullets with a lead content of more than 3%. Beyond limited exemptions, these types of ammunition will no longer be sold to the public.

The ban will prevent the release of an estimated 7,000 tonnes of the toxic metal into fields, forests and wetlands each year. Up to 100,000 wildfowl, including ducks, swans and waders, die from lead poisoning annually, with birds often confusing the scattered shot for grit and consuming it.

Evidence from the Health and Safety Executive shows lead poses a risk to at least 1 million birds over the coming decades if usage continues at its current rate, while around 40,000 birds of prey such as red kites and white-tailed eagles are at risk from ingesting lead through carrion.

Introducing restrictions will also stop lead from contaminating soil and leaching into rivers when guns are discharged and spread the harmful metal, ensuring ecosystems thrive for both wildlife and people alike.

Environment Minister Emma Hardy said:

“Britain is a proud nation of nature lovers, but our rivers are heavily polluted, and majestic birds are declining at an alarming rate.

“This new ban on lead in ammunition for most uses will help reverse this – rejuvenating pride in our countryside by protecting precious birdlife and cleaning up rivers.

“Non-lead alternatives are readily available, and we’ll continue to work closely with the shooting sector throughout this transition.” 

Following extensive public engagement, a three-year transition period will support the shooting and hunting sectors to shift to more environmentally friendly alternatives. There will also be a two-year period for outdoor shooting ranges where lead is used to implement measures that prevent pollution from entering the environment.

Alternatives to lead shot have become more efficient and widely available in recent years, with steel and tungsten-based shot being two popular options. The government will continue to engage with the shooting industry to support the transition to alternative ammunition types.

In December 2024, the Health and Safety Executive published their Final Opinion proposing restrictions on the supply and outdoor uses of lead in ammunition – and the Government has now taken action to reduce toxic substances from entering the environment.

As part of the restrictions, there will be exemptions in place for the military, police, elite athletes, outdoor target shooting ranges with risk management measures in place, museum collections and other minor uses. Small calibre bullets for live quarry shooting – the outdoor shooting of live animals – and airguns are not in scope of the restriction.

 ENDS

This announcement has been a long, long time coming. Way too long, as various previous governments have been more interested in appeasing the selfish, idiotic game shooting industry instead of acting on reams of scientific evidence, produced over many decades, and doing the right thing for the environment, wildlife and human health.

Well done to Defra Ministers Reed and Hardy, as well as their counterparts in the devolved nations. This is an historic decision and is very welcome indeed.

I could quibble about the long lead-in time – the press release says there’ll be a three-year transition period but actually it’ll be at least four years before the ban becomes real, given that it’ll take at least a year for the new legislation to arrive and the 3-year transition will begin from then. But in the big scheme of things, this seems trivial. The decision to ban toxic lead ammunition will be one of those that future generations look back upon in 25, 50, 75 years time and wonder why the hell it took so long to implement what has been blindingly obvious for decades.

The game shooting industry will be furious. They’ve resisted this move for such a long time, denying the scientific evidence and maintaining there’s no issue here (gosh, sound familiar?!).

That was until February 2020.

After seeing the writing on the wall in parts of the US and Europe where more progressive, enlightened Governments had made huge strides to get rid of toxic lead ammunition, nine of the UK’s shooting organisations, including the National Gamekeepers Organisation, suddenly made a massive U-turn and announced they were introducing a ‘five year voluntary transition away from toxic lead shot’, presumably to deter legislation – the industry hates being forced to do anything because it goes against its ingrained sense of entitlement.

Notably, the dinosaurs at the Scottish Gamekeepers Association refused to sign up to a voluntary transition because they didn’t think there was sufficient evidence to support a move away from the use of toxic lead ammunition (yes, really).

To be fair, some shooting organisations, particularly BASC, made genuine efforts to encourage members to undertake the transition, but many of their members simply refused and a lot of them ditched their membership and wrote angry letters to the shooting press.

BASC tried to save face (and its falling membership) by slurring the scientific credentials of a research team from the University of Cambridge that was monitoring the (non)effectiveness of the five-year transition away from the use of toxic lead ammunition (see here). It wasn’t a good look.

Scientific results published earlier this year demonstrated that the industry’s voluntary five-year transition had failed spectacularly (see here), although the industry hilariously pretended to have made ‘significant progress’ (see here).

Now they’ve got another four years, in addition to the five they’ve already had, to drag themselves into the 21st century.

Will they do it? There’ll be some change, I’m sure, but I’m also sure that there’ll be high levels of non-compliance. Scientific evidence has shown that even though there is already legislation banning the use of toxic lead ammunition in some sensitive environments, non-compliance remains high in England (here and here) and in Scotland (here).

Monitoring and robust enforcement will be key, as ever.

There are many, many people who have worked hard for today’s decision, some of them dedicating their whole careers to this issue. We owe them all a debt of gratitude.

A couple of weeks ago I blogged about the Scottish Government’s and NatureScot’s decision to delay the introduction of muirburn licensing, which was due to begin on 15 September 2025 but now won’t start until 1 January 2026 thanks to lobbying by the grouse shooting industry (see here).

I wrote that as a result of this delay, we can expect to see an increase in the intensification of muirburn between 1 October – 31 December 2025 as grouse moor managers take full advantage of the opportunity to burn on deep peat until restrictions begin.

Intensification of grouse moor management looks like it’s already begun on some grouse moors.

Have a look at this satellite imagery from part of the moorland on the Raeshaw Estate in the Scottish Borders (image captured 13 May 2025, after the close of the 2024/25 muirburn season).

Look at the state of this!

According to the peat depth map that NatureScot has provided to help grouse moor managers determine peat depth for licensing purposes, this area is bang in the middle of an area defined in Scottish legislation as ‘deep peat’ (peat depth of 40cm+).

Using the timelapse function on Google Earth, it’s possible to look back at the ‘management’ of this area over the years:

Given the driven grouse shooting industry’s general rejection of cutting instead of burning (they claim it’s labour intensive, logistically difficult and doesn’t get rid of the ‘fuel load’ because it’s just dropped where it’s been cut), I’m guessing that this is muirburn. But it’s hard to differentiate between muirburn and cutting from satellite imagery so it really needs ground-truthing to know for sure. If any blog readers fancy a walk over to ‘The Sole’ on Raeshaw Estate to check, I’d be interested in seeing photographs.

But whether it’s cutting or burning, there’s no denying the intensification of grouse moor management here.

In 2020, Wild Justice won a significant legal challenge against Defra, forcing it to introduce a licensing scheme for the release of gamebirds (Pheasants & Red-legged Partridges) on or near Natura 2000 sites (see here).

In March this year, Defra announced that it would not be issuing General Licence 45 (GL45 – the licence under which restricted numbers of gamebirds can be released on or within 500m of Special Protection Areas) in 2025 because:

“It is currently not possible to rule out the risk of highly pathogenic avian influenza (HPAI) (which is currently very high) spreading to the bird features present on SPAs”.

That was a very sensible, precautionary decision by Defra. Protecting internationally significant bird populations is of far greater national importance than the unsustainable release of ~60 million non-native Pheasants and Red-legged Partridges by those who want to get their kicks from shooting them.

Natural England (now responsible for individual licences) went further, and on 14 April 2025 it advised the gamebird shooting industry that although they could still apply for individual licences for 2025 gamebird releases on or close to SPAs, some licences would only be permitted with a delayed release date for the poults, whereas licences for many other SPAs would be unlikely to be issued at all:

Natural England told the shooting industry that applications for individual licences could be made from 22 April 2025 and that NE aimed to determine applications within 15 working days.

Again, setting aside the absurdity of the statutory nature advisor giving permission to release millions of non-native gamebirds in to the countryside, NE’s advice to the shooting industry about limitations to individual licences was all very sensible in light of the heightened Avian Flu risk, and it gave the shooting industry plenty of time to adjust its plans for the 2025/26 shooting season.

Predictably, the shooting industry went into meltdown, with BASC claiming on 15 April 2025:

“The approach taken by Natural England risks jobs and will have a huge impact on rural economies, not to mention the conservation benefits that sustainable shooting delivers for species and habitats.

“These new restrictions risk bringing large parts of the countryside to a standstill. While we recognise the need to manage the risk of avian influenza, the damage to the countryside could be irreparable. The government should commit to revisiting licensing decisions as the risk of AI dissipates“.

Two months later on 13 June 2025, BASC announced it had started legal proceedings against Defra’s decision not to issue GL45 for the 2025/26 shooting season.

BASC has submitted a Pre-Action Protocol (PAP) letter, apparently on the basis that “Defra has still not provided the formal reason behind it or published a detailed decision-making document“.

The timing of BASC’s PAP letter appears to be just within the three-month time limit for bringing judicial review proceedings, but it’s not clear to me what the specific legal basis of the claim is, nor the remedy BASC is seeking. It looks more like a grandstanding exercise to appease BASC members, but I guess time will tell.

Meanwhile, back in the real world, it turns out that Defra’s precautionary decision not to issue GL45 this year due to the high risk of avian influenza was absolutely spot on.

Since 11 June 2025, there have been five outbreaks of Highly Pathogenic Avian Influenza (H5N1) and protection zones have been established at all five premises, including one which is believed to be a commercial gamebird rearing facility.

The five current outbreaks are as follows:

11 June 2025 – near Ravensthorpe, Kirklees, West Yorkshire. Centred on grid ref: SE2206919016.

17 June 2025 – near Stanhope, Bishop Auckland, County Durham. Centred on grid ref: NZ0336936829.

20 June 2025 – near Linton-on-Ouse, Wetherby & Easingwold, North Yorkshire. Centred on grid ref: SE5024159461.

24 June 2025 – near Glyn Ceirlog, Wrexham. Centred on grid ref: SJ1591333699.

24 June 2025 – near Haverfordwest, Pembrokeshire. Centred on grid ref: SM8938621496.

Avian Influenza isn’t going away, and it’s not even peak season for outbreaks of this highly contagious notifiable disease (typically autumn/winter). As little faith as I have in Defra, I can’t see Ministers making a U-turn on its decision to withdraw GL45 this year, legal challenge or not.

UPDATE 31 July 2025: Four more Bird Flu outbreaks confirmed, including on a Pheasant shoot – yet selfish BASC starts another legal challenge against Govt restrictions on gamebird releases (here).

The RSPB did a fair bit of lobbying and campaigning on the back of the recent Wild Justice petition calling for a ban on driven grouse shooting.

Although agreeing with Wild Justice on the various problems associated with driven grouse moor management, the RSPB’s position was not to support a ban, but rather to push for a licensing scheme.

Calling for a licensing scheme has been RSPB policy since October 2020, after a period of internal review (see here).

It was good to see a couple of RSPB staff members attend the Westminster Hall debate last Monday, and on Friday it published the following statement (available on the RSPB website here but reproduced below because annoyingly, links to material on the RSPB website tend to break quite often).

On Monday 30 June Parliament debated the future of driven grouse shooting in England, and with it the future of vast swathes of our iconic upland landscapes. The debate was triggered by the petition launched by the campaign group Wild Justice, which was signed by over 104,000 people and called for a ban on driven grouse shooting. 

Our position on shooting

The RSPB is neutral on the ethics of shooting, and concerned only with preventing the harm caused to wildlife through the management of some grouse shoots. This is why, while we support efforts that bring this important issue into the spotlight, our focus has long been on achieving a system of licensing for grouse shooting. We believe this, rather than an outright ban, is the most pragmatic way to secure a positive outcome for nature.  

Licensing would raise environmental standards across the shooting industry and allow responsible shoots to continue to operate, while providing an effective deterrent for those who do harm, or worse, break the law.     

Our concerns

We share the concerns of Wild Justice and all who signed the petition about the damaging and often illegal activities associated with the intensive management of land for grouse shooting: 

• Our latest report ‘Hen Harriers in the firing line’  highlights that there have been 102 confirmed cases of Hen Harrier persecution in the UK in the last five years, and these confirmed cases are just the tip of the iceberg when it comes to the true scale of this criminal activity, as many incidents happen in remote locations and go unreported. The report highlights that the average life expectancy of a young Hen Harrier in the UK is just 121 days, and that a Hen Harrier is 10 times more likely to die or disappear when on grouse moors.  Despite this, there has not been a single conviction for Hen Harrier persecution in England. 
• More broadly, our latest Birdcrime report reveals that, between 2009-2023, there were 1,529 confirmed bird of prey persecution incidents in the UK involving 1,344 individual birds of prey, including Peregrines, Buzzards and Red Kites, as well as rare and recovering Hen Harriers and White-tailed Eagles. The majority of raptor persecution incidents are associated with land managed for gamebirds, and of all individuals convicted of bird of prey persecution-related offences between 2009 and 2023, 75% were connected to the gamebird shooting industry.   
• Grouse shooting estates often use burning of peatland vegetation as a land management technique intended to encourage the growth of young heather shoots on which Red Grouse feed. This practice damages the UK’s globally rare peatlands, contributing to climate change by degrading these natural carbon sinks, increasing air pollution and associated health risks, and increasing the risks of flooding for nearby communities.  
• Research has highlighted the scale of the use of lead shot used in the grouse shooting industry. In 2024/25, 100% of the grouse purchased from UK food retailers, and from which shot could be recovered, had been killed with lead. This is toxic to both wildlife (including birds of prey) and to humans. 
• And then there are other impacts including the largely unregulated use of veterinary medicines, and the damage caused by the construction of hill tracks and other infrastructure for shoots. 

The Westminster debate

While there were some who spoke persuasively during the debate about the need for a robust regulatory framework if grouse shooting is to have a future, many spoke out against the calls for a ban. A wide range of arguments were given, from the socio-economic and cultural value of grouse shooting through to the often beneficial effects of legal predator control for some species of wading birds – most notably Curlews. 

Importantly, however, although the concerns raised are arguments against a ban – none of them are arguments against licensing.

Almost all of those who spoke were unanimous in their outright and unequivocal condemnation of the illegal killing of birds of prey.  But disappointingly few had suggestions for how this can be meaningfully addressed.

In summing up, Defra Minister Daniel Zeichner repeated the UK Government’s previous statements that they have no plans to ban grouse shooting, but acknowledged the strong opinions on both sides of the debate, and said that the Government would keep options under close review.

Licensing is urgently needed

Based on the growing body of evidence of the unacceptable and often illegal activities associated with grouse shooting, we believe grouse shoots should be licensed in England. Without change, there can be no sustainable future for our uplands. 

Licensing has already been introduced in Scotland, and, as pro-shooting and anti-ban MP John Lamont stated during the debate, “that system has its flaws, but works adequately in other respects”. 

We’re now calling on the UK Government to take swift action to introduce the licensing of grouse shooting in England, building on, and learning from the experience in Scotland.   

Our Hen Harriers and other wildlife can’t wait. Those who operate responsible shoots would have nothing to fear, and much to gain, from a system that would make the unanimous calls for effective action on the illegal persecution of birds of prey a reality. 

ENDS

I mentioned above that calling for a licensing scheme for driven grouse shooting has been the RSPB’s policy since October 2020 after the organisation undertook a comprehensive review of the evidence.

That policy was announced at the AGM in October 2020, and included the following statement:

‘Our focus is not on “walked up” grouse shooting, but we will re-double our efforts to secure effective licensing for “driven” grouse shooting, and we will learn from the developments anticipated soon on this issue in Scotland.  We will provide an annual assessment of progress and review our position within five years.  Failure to deliver effective reform will result in the RSPB calling for a ban on driven grouse shooting‘. [Emphasis is mine].

The findings of that five-year policy review are due to be announced in three month’s time at the RSPB’s October 2025 AGM.

It’ll be really interesting to hear what the RSPB says about the findings of it’s five-year review. I’d guess, given the RSPB’s response to the Westminster debate, that it will be sticking to its policy of calling for a licensing scheme rather than a ban, but if so, how will it justify that ‘effective reform‘ has been delivered since 2020? I don’t even know what measures it will use to assess ‘effective reform‘ but from what I’ve seen in the last five years, there hasn’t been a single bit of it.

Indeed, if you watch this (very good) RSPB video about the problems with driven grouse moor management in the Peak District National Park, which the RSPB published in January 2025, it’s quite clear that the RSPB recognises that ‘effective reform‘ has most definitely not been delivered: