17 months (& waiting) for NatureScot to make decision on General Licence restriction relating to ‘shooting & killing’ of sleeping Golden Eagle called Merrick

The Scottish Government’s nature advisory agency, NatureScot, has been now been procrastinating for 17 months on whether to impose a sanction on an estate in relation to the ‘shooting and killing’ of a sleeping Golden Eagle called Merrick.

Merrick was a young satellite-tagged Golden Eagle, released in south Scotland in 2022 as part of the South Scotland Golden Eagle Project, a lottery-funded conservation initiative which translocated young Golden Eagles from various sites across north Scotland to boost the tiny remnants of the Golden Eagle breeding population in south Scotland that had previously been decimated by illegal persecution and had become isolated by geographic barriers.

Camera trap photo of golden eagle Merrick in 2022, from South Scotland Golden Eagle Project

A year after her release, which had seen her fly around south Scotland and down into northern England and back, on 12 October 2023 Merrick’s satellite tag suddenly and inexplicably stopped transmitting from a roost site in the Moorfoot Hills in the Scottish Borders where she’d been sleeping overnight.

A project officer from the South Scotland Golden Eagle Project went to her last known location where he found Merrick’s feathers and blood directly below her roost tree. Police Scotland later determined from the evidence that she’d been ‘shot and killed’ and that someone had then ‘removed her body and destroyed her satellite tag’ (see here).

There was limited scope for anyone to be charged and prosecuted for killing this eagle unless someone in the know came forward with sufficient evidence to identify the individual(s) responsible. In addition, the prospect of an estate having its grouse-shooting licence withdrawn as a consequence of this crime was zero, given that this offence took place prior to the enactment of the Wildlife & Muirbun (Scotland) Act 2024.

That just left a General Licence restriction as a possible sanction. Not that I’d describe a GL restriction as an effective sanction, for reasons that have been explored previously on this blog (e.g. here and here). Nevertheless, it’s still something and, given the high-profile of Merrick’s death, you might think that making a decision on whether to impose a GL restriction would be a high priority for NatureScot.

I wrote about NatureScot’s procrastination on this case in August (see here), after receiving a response to a Freedom of Information request I’d lodged in June 2025. That response confirmed that NatureScot had received an information package from Police Scotland, on which it would base its GL restriction decision, in April 2024.

Seventeen months on and we’re now at the end of September 2025 and there’s still no sign of a decision from NatureScot.

What’s the hold up? Why hasn’t this decision been a priority for NatureScot?

What sort of message does NatureScot’s procrastination send out to others who might be thinking of ‘getting rid’ of a Golden Eagle in south Scotland, or any other part of Scotland for that matter?

The consequences became very clear yesterday when it was announced that two more satellite-tagged Golden Eagles from the South Scotland project had ‘disappeared’ in suspicious circumstances.

Two Golden Eagles ‘disappear’ in south Scotland – Police appeal for information

Press release from Police Scotland, 29 September 2025:

APPEAL FOR MISSING GOLDEN EAGLE

Detectives are appealing for information after a satellite-tagged golden eagle disappeared in the hills to the north of Langholm.

The tag on Tarras, a four-year-old male golden eagle, has displayed suspicious patterns and data reports, and officers are concerned he may have come to harm between Wednesday, 27 August, 2025 and Friday, 29 August, 2025.

A full search of the area where his tag last transmitted has been carried out using specialist resources, including dogs trained in tracing birds and their tags, however neither the bird nor the satellite tag have been recovered.

Tarras was translocated to the area in 2021 as part of the South of Scotland Golden Eagle Project.

Officers and wildlife partners have subsequently been unable to trace his mate, Wren. Although there is nothing to suggest she has come to harm, her disappearance coincides with that of Tarras and concerns are growing for her welfare.

Golden Eagles. Photo by Pete Walkden

Detective Sergeant David Lynn, National Wildlife Crime Coordinator, said: “The data received from Tarras’ tag suggests that he has come to harm to the north of Langholm and efforts remain ongoing to locate him and his tag.

We cannot say for certain that Wren has also come to harm, but her disappearance is worrying.

Our investigation remains ongoing, and we are working with a range of partner agencies to establish more details around the disappearance of both birds.

I would urge anyone with any information that may assist to contact us.”

Anyone with any information should call 101, quoting reference number 1987 of Friday, 26 September, 2025. Alternatively, please contact Crimestoppers though 0800 555 111, where anonymity can be maintained.

ENDS

There’s quite a bit of information missing from this press release, just as there was from the other recent press release about the poisoned Red Kite found in Perthshire.

This was a satellite-tagged territorial pair so the sudden disappearance of both of them at the same time is highly suspicious.

Why isn’t there any information provided about their last known positions according to their tag data? A police search has already taken place, so it’s not as though naming the location would provide a suspect with a chance of hiding or removing evidence.

It’d be very interesting to know the proximity of the nearest Red-legged Partridge release pen to the eagles’ last known locations…

Chick success after translocated Golden Eagle breeds with one of ‘our’ wild satellite-tagged birds in south Scotland

One of the translocated Golden Eagles in southern Scotland has bred with one of ‘our’ wild satellite-tagged eagles, resulting in the successful fledging of a male eaglet.

This is the first fledging event from a nest of one of the translocated eagles and marks a major milestone for the South Scotland Golden Eagle Project.

The chick has been named ‘Princeling’ by Sir David Attenborough.

Golden Eagle chick ‘Princeling’ having a satellite tag fitted (Photo copyright Ian Georgeson)

The breeding pair got together in 2024 and built up a nest but didn’t breed. That’s not unusual behaviour for young Golden Eagles who can take up to six years to mature, although in areas where there’s little competition for territories (e.g. through depletion of the population by persecution, as in south Scotland), breeding can happen much earlier.

Emma, the female, had been translocated to south Scotland in 2021 and was named by the Scottish Government’s then Biodiversity Minister, Lorna Slater MSP, in memory of the women’s rights and equality advocate, Emma Ritch.

Keith, the male, fledged from a wild nest in Dumfries & Galloway in 2018 and was named Keith after a member of the local Raptor Study Group. He was satellite-tagged as part of a project run by RPUK and Chris Packham in association with experts from the Scottish Raptor Study Group and we’ve been tracking his movements ever since.

Here he is prior to fledging in 2018 (Keith is on the right, one of his parents on the left). This is footage from a nest camera which are routinely installed (under licence) at nest sites to help researchers monitor young eagles after they’ve been fitted with a satellite tag to ensure the tag/harness is not causing any health or welfare issues.

Photo copyright Scottish Raptor Study Group

After dispersing from his natal territory in November 2018, Keith hung around in Dumfries & Galloway for a few months before then suddenly making a beeline for the border and in to England. He stayed in Northumberland for a while (and was joined by at least one other tagged Golden Eagle that had been translocated to south Scotland) before heading back in to Scotland and heading over to his old haunts in SW Scotland before eventually finding his own territory and settling there in October 2023.

After their unsuccessful breeding attempt in spring 2024, Keith and Emma were photographed together in October 2024 on a camera trap at a food platform provided by the South Scotland Golden Eagle Project. They looked to be in excellent condition:

Keith on the right, with the much larger female Emma. Photo copyright South Scotland Golden Eagle Project

The location of their successful breeding attempt this year has had to remain a secret because, as we’ve seen, (here and here) Golden Eagles, along with many other raptor species, still face the threat of illegal persecution in this region and beyond.

New BBC documentary provides shocking insight into appalling crimes on Auch Estate, Bridge of Orchy

A new BBC documentary aired last night that charts the police investigation into a missing charity cyclist, Tony Parsons, who vanished at the Bridge of Orchy in 2017 and whose remains were found three years later buried in a stink pit on the Auch Estate.

The programme follows the criminal trial of twin brothers Alexander (Sandy) and Robert McKellar from the Auch Estate, initially charged with murder but in 2023 Alexander was eventually convicted for the lesser offence of culpable homicide and Robert for attempting to defeat the ends of justice.

This case was of interest to me because the Auch Estate was at the centre of another criminal investigation in 2009 after walkers discovered a dead Golden Eagle. Tests revealed it had been illegally poisoned with the banned pesticide Carbofuran.

In 2012 Auch Estate farm manager Tom McKellar was convicted and fined £1,200 for possession of Carbofuran (not for poisoning the eagle, even though he had reportedly admitted during interview of putting out poisoned baits). He was also found to be in possession of two unlicensed handguns but instead of receiving a mandatory five-year custodial sentence he was given a 300-hour community service order.

From the Guardian, June 2009

The new BBC documentary provides a fascinating insight into the difficulties of investigating serious crime on a remote rural estate and the parallels with investigations into illegal raptor persecution in these glens will not be lost on blog readers. The ease with which the McKellar twins could hide their appalling crimes for so long is sobering.

The two-episode programme is available on BBC iPlayer (Murder Case: The Vanishing Cyclist).

16 months (& waiting) for NatureScot to make decision on General Licence restriction relating to ‘shooting & killing’ of sleeping Golden Eagle called Merrick

Documents released under a Freedom of Information request show that the Scottish Government’s nature advisory agency, NatureScot, has been procrastinating for 16 months on whether to impose a sanction on an estate in relation to the ‘shooting and killing’ of a sleeping Golden Eagle called Merrick.

Merrick was a young satellite-tagged Golden Eagle, released in south Scotland in 2022 as part of the South Scotland Golden Eagle Project, a lottery-funded conservation initiative which translocated young Golden Eagles from various sites across north Scotland to boost the tiny remnants of the Golden Eagle breeding population in south Scotland that had previously been decimated by illegal persecution and had become isolated by geographic barriers.

Camera trap photo of golden eagle Merrick in 2022, from South Scotland Golden Eagle Project

A year after her release, which had seen her fly around south Scotland and down into northern England and back, on 12 October 2023 Merrick’s satellite tag suddenly and inexplicably stopped transmitting from a roost site in the Moorfoot Hills in the Scottish Borders where she’d been sleeping overnight.

A project officer from the South Scotland Golden Eagle Project went to her last known location where he found Merrick’s feathers and blood directly below her roost tree. Police Scotland later determined from the evidence that she’d been ‘shot and killed’ and that someone had then ‘removed her body and destroyed her satellite tag’ (see here).

Evidence from the crime scene – photo via South Scotland Golden Eagle Project

As with every single other case of satellite-tagged Golden Eagles whose transmitters had suddenly stopped sending data and who seemingly vanished in to thin air (a Scottish Government-commissioned report in 2017 showed that almost one third of 131 satellite-tagged Golden Eagles had disappeared in such circumstances, most of them on or close to driven grouse moors), the person(s) responsible for ‘shooting and killing’ Merrick and then disposing of her body and her satellite tag was not arrested, charged or prosecuted.

It was this lack of enforcement, largely due to the difficulties of identifying the actual individuals responsible and securing sufficient evidence to meet the threshold for a criminal prosecution, that led to the Scottish Parliament voting to pass the Wildlife Management and Muirburn (Scotland) Act 2024, which introduced grouse moor licences that could be withdrawn by NatureScot if gamekeepers and/or estates were found, based on the lower burden of civil proof (the balance of probability), to have been involved in the illegal killing of birds of prey.

Grouse moor licensing hadn’t been introduced at the time Merrick was ‘shot and killed’ and can’t be applied retrospectively so in the absence of a grouse shoot licence withdrawal, and the absence of a prosecution, that leaves a General Licence restriction as the only possible sanction that NatureScot could impose.

Not that I’d describe a GL restriction as an effective sanction, for reasons that have been explored previously on this blog (e.g. here and here). Nevertheless, it’s still something and, given the high-profile of Merrick’s death, you might think that making a decision on whether to impose a GL restriction would be a high priority for NatureScot.

But apparently, it’s not.

In June this year, I submitted an FoI to NatureScot to find out what was happening in relation to this potential GL restriction, as we head towards the two-year anniversary of Merrick’s killing. NatureScot replied in July with this:

We have received an information package from Police Scotland to this case, and it is currently under consideration‘ (see here for earlier blog).

I submitted another FoI in July and asked Naturescot:

Please can you advise the date on which NatureScot received the information package from Police Scotland?‘.

NatureScot responded this month, as follows:

We can confirm that we received an initial information package from Police Scotland on 18 April 2024, then additional information on 3 May 2024‘.

April 2024?? That’s 16 months (and counting) that NatureScot has been procrastinating on this. It hardly inspires confidence, does it?

And the shooting and killing of a sleeping Golden Eagle isn’t the only raptor persecution case that’s awaiting a potential GL restriction decision. There are at least two others that I’m aware of – I’ll write about those in a separate blog because the cause of the delays in those two cases appears to lie at the feet of Police Scotland.

UPDATE 30 September 2025: 17 months (&waiting) for NatureScot to make decision on General Licence restriction relating to ‘shooting & killing’ of a sleeping Golden Eagle called Merrick (here)

General Licence restriction ‘under consideration’ in relation to shooting & killing of Golden Eagle ‘Merrick’ in south Scotland

I’m sure many of you remember the young, satellite-tagged Golden Eagle called ‘Merrick’.

She was part of the South Scotland Golden Eagle Project, a lottery-funded conservation initiative which translocated young Golden Eagles from various sites across north Scotland to boost the tiny remnants of the Golden Eagle breeding population in south Scotland that had previously been decimated by illegal persecution and become isolated by geographic barriers.

Camera trap photo of golden eagle Merrick in 2022, from South Scotland Golden Eagle Project

Merrick hit the headlines in autumn 2023 when her satellite tag suddenly and inexplicitly stopped transmitting on 12 October 2023 at a location in the area to the west of Fountainhall, between Heriot and Stow, close to the boundary of the Raeshaw Estate in the Scottish Borders.

Police Scotland issued an appeal for information in November 2023 in which they stated they believed Merrick ‘had come to harm’ but no further details were provided at that time.

We didn’t hear anything more for another six months but then in May 2024 the South Scotland Golden Eagle Project issued a press release that revealed evidence from the crime scene that led Police Scotland to believe that Merrick had been ‘shot and killed’, whilst she was sleeping in a tree, and that someone had then ‘removed her body and destroyed her satellite tag’ (see here).

The criminal who shot Merrick as she slept has not been arrested or charged. It’s the same old story – insufficient evidence to identify an individual and so whoever killed this eagle escapes without consequence, just like every single other eagle-killer in Scotland. Not one of them has ever been convicted.

New legislation was supposed to address this failure with the introduction of the Wildlife Management and Muirburn (Scotland) Act, whereby a grouse-shooting licence could be revoked in circumstances where, on the balance of probability, a crime was considered to have taken place where land was being managed for grouse shooting, but at the time of Merrick’s shooting this legislation wasn’t yet in place and can’t be applied retrospectively.

That just leaves a General Licence restriction as the only potential ‘sanction’ in this case, not that I’d describe a GL restriction as an effective sanction, for reasons that have been explored previously on this blog (e.g. here and here). Nevertheless, it’s still something.

As we head towards the two-year anniversary of Merrick being shot and killed, I wanted to know whether NatureScot had considered a General Licence restriction in this case, either on the land where Merrick was believed to have been shot or on land nearby. It was rumoured that this was under consideration over a year ago in June/July 2024 but I hadn’t seen any restriction notice so in June this year, I submitted an FoI to NatureScot to find out what the status was.

NatureScot replied to me on 21 July 2025 with this:

We have received an information package from Police Scotland to this case, and it is currently under consideration‘.

Tellingly, NatureScot didn’t elaborate on how long this decision had been under consideration so I’ve since submitted a further FoI request to find out on what date NatureScot received the ‘evidence package’ from Police Scotland which would allow NatureScot to begin its deliberations.

I await the response with interest.

UPDATE 11 August 2025: 16 months (& waiting) for NatureScot to make decision on General Licence restriction relating to ‘shooting and killing’ of sleeping Golden Eagle called Merrick (here).

DEFRA endorses Natural England’s recommendations for a presumption AGAINST the issuing of licences for taking wild birds of prey for falconry

Some good news for birds of prey! DEFRA has endorsed Natural England’s recommendations for a presumption AGAINST the issuing of licences for taking birds of prey from the wild for falconry and aviculture.

A licensing policy review was undertaken by Natural England following the furore in 2020 when NE issued licenses for the removal of young peregrines from the wild for a purported captive-breeding programme.

That news had generated heated arguments both for and against the licences, as reported on Mark Avery’s blog (e.g. see herehere and here). In 2022 NE said that although licences had been issued in 2020, ‘the licenses expired earlier this year with no chicks having been taken‘. It’s not clear why the licences weren’t used.

Young peregrines on a nest ledge. Photo by Ruth Tingay (taken under licence)

In 2022, licences to take birds of prey from the wild were temporarily suspended whilst NE began a fairly comprehensive licensing policy review which included a public consultation with wide stakeholder engagement from the falconry and non-falconry communities. Natural England has published links to various reports resulting from the consultation process, here.

The species most frequently mentioned by those wanting to take birds from the wild for falconry purposes were peregrine (58%), sparrowhawk (58%), merlin (22%) and goshawk (10%). One individual falconer respondent mentioned buzzard and golden eagle. However, many falconer and non-falconer respondents considered the latter two species to be unsuitable for inclusion in a future wild take licensing regime. In the case of golden eagles, it was stated that this was due to their rarity in England. Many falconers also considered merlin to be unsuitable for inclusion due to their rarity.

The consultation process included detailed evidence from the National Wildlife Crime Unit (NWCU) about the increase in the legal and illegal trade in peregrines, both for the domestic and international market, and how licensed ‘wild take’ may add to the problem.

Many of you will be familiar with Operation Tantallon, the recent successful multi-agency investigation leading to the subsequent prosecution and conviction of two peregrine launderers in south Scotland who were selling wild Scottish peregrines to wealthy falconers in the Middle East (see here).

The scale of their offending was considerable and I heard at a wildlife crime conference earlier this week that many more cases are currently under investigation as a result of Operation Tantallon.

In October 2023 Natural England’s ‘wild-take’ licensing review came to an end and drew the following conclusions:

  • Wild take is not integral to the present-day practice of falconry or aviculture in England. Few modern falconry texts define falconry as involving the use of ‘wild’ birds of prey and there are limited historical references to the cultural importance of wild take or of  wild-taken birds to British falconers. No clear consensus exists within the falconry community or in the available falconry literature regarding the cultural importance of wild take as a core aspect of falconry practice.
  • Despite rapid growth in the popularity of falconry in recent decades, the available evidence suggests that there are sufficient birds of the relevant species readily available – via captive populations – to meet current demand. There is no evidence of significant inbreeding risks in these captive populations and captive-bred birds are generally considered to perform to a similar standard as wild birds when used for falconry purposes.
  • Most non-falconers are opposed to licenced wild take on ethical grounds and have concerns regarding the potential impacts of falconry and wild take on the conservation and welfare of the species affected. Both falconers and non-falconers are supportive of additional measures to ensure that individuals keeping birds of prey have suitable experience in caring for such birds.
  • Few respondents to the public call for evidence expressed a desire to gain commercially from wild take. However, risks identified relating to the illegal trade in birds of prey nevertheless suggest a need for strict controls on commercial use of such birds alongside improved traceability and other measures to be taken forwards by the responsible agencies. Difficulties in tracing individual birds under current arrangements mean there is a credible risk that the offspring of a wild bird taken under licence could be illegally laundered via commercial breeding operations into the domestic and international trade.

On the basis of the above conclusions, Natural England put forward the following recommendations to DEFRA in late 2023 and advised that a clear policy statement should be published for England setting out the following:

  • That licences permitting the wild take of native birds of prey for falconry or avicultural purposes should not be issued other than in exceptional circumstances;
  • That the commercial use of native birds of prey taken from the wild under a licence issued for falconry or avicultural purposes – and any offspring of such birds –should not be permitted other than in exceptional circumstances; and,
  • That the power to grant licences remains on statute, with the adopted policy (as above) subject to future evidence-based review as required.

These are the recommendations that DEFRA has now endorsed and has implemented the policy of a presumption AGAINST issuing licences to take wild birds of prey for falconry and aviculture.

Natural England has stated that, ‘Whilst the power to grant licences will remain on statute, Defra ministers support the view that licences should not be issued, other than in exceptional circumstances. No evidence was provided during the review process that would support the issuing of licences for any specific exceptional circumstances at the present time‘.

There’s a useful Natural England blog on the subject, here.

For those interested in Natural England’s policy review, it can be read/downloaded here:

From my personal point of view, this is an excellent decision and is good news for birds of prey in England.

I’ve previously outlined my reasons, here.

50,000 people support the Northern Ireland Raptor Study Group’s petition to ban possession of dangerous, raptor-killing pesticides

Many, many thanks to all of you who signed the Northern Ireland Raptor Study Group’s (NIRSG) petition calling for a ban on the possession of dangerous, raptor-killing pesticides.

The petition has just passed its target of 50,000 signatures and the NIRSG has issued the following press release:

The NIRSG held a recent Raptor Conference which provided incredible insights into a range of topics locally and globally. Many of the talks raised a consistent theme of targeted persecution of birds of prey. Not least amongst these was the on-going issue in Northern Ireland of the Possession of Dangerous pesticides.

Some of the NIRSG 2025 conference attendees supporting the call for a ban on dangerous, raptor-killing pesticides. Photo by Marc Ruddock

The NIRSG highlighted that 63 raptors have been killed between 2009 and 2023 with a range of poisons, dominated by Carbofuran which has been banned for nearly 25 years. There have been at least 30 buzzards, 16 peregrine falcons, 13 red kites, 3 white tailed eagles and 1 golden eagle all poisoned in this time frame.

This evidence is collated by the Partnership for Action Against Wildlife Crime in Northern Ireland (PAW NI) and published in raptor persecution reports, which include ‘hotspots’ of illegal killing of our native birds of prey. These reports are publicly available on the PAWNI webpage available here and also aggregated in the RSPB Bird Crime reports available here.

In 2011, the wildlife legislation in Northern Ireland was strengthened, resulting in increased sentences of £5,000 fines (per offence) and up to 6 months imprisonment. The updated laws included a provision to ban the possession of prescribed ingredients under “Section 15B Possession of pesticides harmful to wildlife” of the Wildlife (Northern Ireland) Order 1985 as amended.

As part of that legislation there should have been an attached Order listing the banned chemicals. That list has never been created. Wildlife has continued to be poisoned by these dangerous and banned substances.

The legislation states in Section 15B Part 2: “A prescribed ingredient is one which is prescribed for the purposes of this Article by an order made by the Department; but the Department may not make an order under this Article unless it is satisfied that it is necessary or expedient to do so in the interests of protecting wild birds or wild animals from harm”. [Emphasis added by NIRSG]

There is significant evidence of continued harm from banned pesticides to birds of prey, based on robust post-mortem and laboratory results, which has been published in many reports. We believe it is indeed expedient for Minister Andrew to implement this Order to protect our birds of prey from harm. 50,000 people agree with us. Thank you to everyone who has supported the petition and helped give a voice to our wildlife.

The NIRSG will be seeking a meeting with Minister Andrew Muir to present the petition now that it has surpassed 50,000 signatures.   

ENDS

BBC rejects Scottish Gamekeepers Association’s complaint about programme that linked raptor persecution to land managed for gamebird shooting

Last November the BBC aired an episode of Highland Cops (Series 2, Episode 4) that featured a Police Scotland Wildlife Crime Officer, PC Dan Sutherland, investigating the suspicious disappearance of a satellite-tagged golden eagle on a grouse moor in the Highlands (available for next 9 months on iPlayer here, starts at 35.15 mins).

The programme followed PC Sutherland, along with an RSPB Investigations Officer, searching the moor for evidence of either the eagle or its tag.

PC Sutherland is an experienced WCO and he explained that this wasn’t the first time he’d been involved in an investigation into this type of incident and he gave a comprehensive commentary on the lengths that offenders will go to to hide the evidence of their crimes (e.g. tags being burned, tags being tied to rocks and dumped in lochs).

He also said: “So within Highlands & Islands, 100% of all birds of prey that are being killed happen on or near land that’s managed for gamebird shooting“.

The Scottish Gamekeepers Association (SGA) lodged a formal complaint to the BBC about what the SGA described in its quarterly members’ rag as having “caused unfair reputation [sic] damage” to the game-shooting industry and wanted the BBC to make “a prominent correction“.

Here’s the response from the BBC’s Executive Complaints Unit, published 13 February 2025:

It shouldn’t come as a surprise to anyone, not least the SGA, that this complaint was not upheld. The Scottish Parliament voted overwhelmingly last year to introduce new legislation (Wildlife Management & Muirburn (Scotland) Act 2024) precisely because raptor persecution, and particularly the illegal killing of golden eagles, persists on many driven grouse moors.

Well done PC Sutherland for saying it as it is, and well done to the BBC for not pandering to the histrionics of the SGA.

UK Governments must decide on lead ammunition restrictions by March 2025 – you can have your say to help bring about a ban

In December 2024, long-delayed recommendations by the Health & Safety Executive (HSE) for restrictions to be placed on the use of lead ammunition in the UK were finally published.

Used shotgun cartridges. Photo by Ruth Tingay

A press release issued by the HSE at the time of publication stated that under the new proposals the use of lead shot for live quarry shooting and target shooting would be prohibited.

Dr Richard Daniels, HSE’s Director of Chemicals Regulation Division was quoted:

Following a comprehensive analysis of the evidence, we propose new restrictions to protect wildlife, particularly wildfowl and birds of prey, from lead poisoning. They would prevent an estimated 7,000 tonnes of lead entering the environment each year.

Golden eagles are particularly susceptible to lead poisoning. Photo by Pete Walkden

The final agency opinion follows significant responses to two public consultations. We worked through nearly 11,000 responses – dwarfing the recent exercise in the EU.

This detailed work, carried out under our UK REACH obligations, sets out the necessary balance we have struck to protect the environment and minimise disruption to those who shoot.

Currently, the risks of lead shot to the wider environment are not adequately controlled. While there are already legally binding measures in place to protect Britain’s wildlife in designated wetlands from the use of lead shot, our analysis has demonstrated the need for further restrictions.

People will still be able to continue to shoot, but we are proposing that for some outdoor uses in the future, alternatives to lead ammunition would need to be used.”

For those who want to read the detailed proposals, here’s the document:

This issue has dragged on for far too long in the UK (e.g. see here) but now the recommendations have been published, the Governments in England, Wales and Scotland have a limited time period to respond.

A consortium of wildlife and environmental organisations has now written an open letter to the Secretary of State at DEFRA and his colleagues in the devolved Governments, urging them to use this opportunity to finally bring an end to the use of toxic lead ammunition, removing this pollutant from our environment and protecting the health of wildlife and human populations alike. Here’s the letter:

The same campaigners have also set up an e-action that provides an opportunity for you to contact Minister Steve Reed MP at DEFRA, urging him to implement a swift and full ban on the use of lead ammunition. If you’d like to participate (it only takes a couple of minutes), please click here.

For blog readers in Scotland I’d encourage you to email Minister Gillian Martin MSP, the Acting Cabinet Secretary for Net Zero and Energy (contact details here).

For blog readers in Wales, I’d encourage you to email Minister Huw Irranca-Davies MS, Cabinet Secretary for Climate Change and Rural Affairs (and also Deputy First Minister), whose contact details are here.

Don’t be under any illusion that the shooting industry will be rolling over and taking this lying down. They won’t. They’ll be lobbying hard to introduce further delays and to minimise the impacts of the proposed restrictions. It’s what they’ve been doing for years (e.g. here), whilst simultaneously claiming to be undertaking a five-year so-called ‘voluntary transition’ to using non-lead ammunition but failing miserably (see here), and failing to comply with current regulations on using lead ammunition in sensitive environments in England (here) and Scotland (here).

It’s important that Ministers hear from a wider section of society than those with vested interests in maintaining the status quo. Please do make use of the e-action and/or email Ministers in Scotland and Wales. For blog readers with a special interest in birds of prey, this article and the linked scientific paper from researchers at the University of Cambridge should provide all the motivation you need.

To make sure the DEFRA Secretary of State meets the legal requirements for responding to the HSE recommendations within three months of receiving them, lawyers representing conservation campaign group Wild Justice have written to him with the intention of holding him to that deadline. You can read the letter here.

UPDATE 18 March 2025: UK Governments miss deadline for responding to recommendations for restrictions on use of toxic lead ammunition (here)