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Over 130 scientists have signed a letter to the Spanish Ministry of Agriculture, Fisheries and Food urging a full ban on lead in hunting and fishing.
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They reject any delays or exceptions to the EU-wide restriction proposed by the European Chemicals Agency
Lead bullets and ammunition. | Rafael Mateo
In February 2025, ECHA published a report leading to a proposal for an EU-wide restriction on the use of lead in all forms of outdoor hunting and sport shooting ammunition, as well as in weights used for recreational fishing. However, several countries, including Spain, have submitted objections seeking to modify the proposal.
The Spanish Ministry of Agriculture, Fisheries and Food has submitted two key objections that have raised concerns among the scientific community. First, the Ministry argues that the timeline set out in the draft restriction for phasing out lead in hunting ammunition is too short and requests an extension of between five and ten years for full implementation. Secondly, the Ministry argues that due to high wild boar densities in certain regions and the associated health risks, population control of this species should continue to be carried out using lead ammunition, citing reasons of availability, cost, and safety.
The scientists behind the letter consider that while a short adaptation period may be reasonable, there is no justification for extending it beyond five years.
“Safe and effective alternatives are already available on the market and are being used by hunters worldwide, including in Spain”, explains Rafael Mateo, researcher at IDAEA and one of the signatories.
According to the scientific community, the second objection raised by the Ministry is “even more concerning and less justifiable”, as it would result in an inconsistency in the regulation of ammunition types – allowing the use of lead-free alternatives for sport hunting, but not for population control. This would greatly hinder the effective implementation of the restriction, and the authorities would face the difficult task of assessing and determining whether a hunting action qualifies as population control or regular sport hunting if hunters are allowed to carry out such controls.
Roe deer hunted with lead ammunition. | Oliver Krone
The letter, addressed to the Ministry of Agriculture and also shared with the Ministry for the Ecological Transition and the Demographic Challenge (MITECO), has been drafted by Dr Rafael Mateo, researcher at the Institute of Environmental Assessment and Water Research (IDAEA-CSIC); Dr Mónica Martínez-Haro, researcher with the Wildlife Toxicology Research Group at the Institute for Game and Wildlife Research (IREC – CSIC, UCLM, JCCM); and Dr José A. Donázar, researcher at the Doñana Biological Station (EBD-CSIC). All three are prominent scientists at the Spanish National Research Council (CSIC) with extensive experience studying the impacts of lead on the environment, wildlife and public health.
The toxicity of lead has long been recognised: it is considered “one of the most harmful metals for human, animal and environmental health”. It is now well established that “there is no safe level of exposure”, which has led to its removal from numerous applications and its replacement by less hazardous materials. Both the European Food Safety Authority (EFSA) and the Spanish Agency for Food Safety and Nutrition (AESAN) have issued clear warnings, stating that “children and pregnant women should not eat game meat due to the health risks posed by lead residues in ammunition”. Nonetheless, its use in hunting and sport shooting ammunition, as well as in fishing weights, continues.
The problem extends to the environment. The use of lead ammunition in terrestrial hunting results in the annual release of around 14,000 tonnes of this metal across “forests and agricultural lands in Europe”.
“This lead does not disappear; once pellets have disintegrated, they remain in the environment, polluting soils, waters and food webs”, concludes Rafael Mateo.
The impact on wildlife is also significant, particularly among birds. Lead poisoning from ingesting fragments has been diagnosed in at least 13 species of birds of prey in Spain – all of them strictly protected. The letter warns of the urgent need for a ban, stating that “the longer it takes to ban lead in hunting ammunition, the more polluted our environment will become”.
Slice of cured game meat containing a lead fragment. | Rafael Mateo
Given this overwhelming evidence – and the findings included in ECHA’s report on the risks posed to public and environmental health by the use of lead in hunting, sport shooting and recreational fishing – the three authors and more than 130 signatories, including the vast majority of experts in Spain on the effects of lead on biodiversity conservation, have expressed their “full support for the draft amendment to Annex XVII of Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards lead in ammunition and fishing weights”, as it currently stands. Their position is clear: “no moratoriums and, above all, no exceptions such as the use of lead for population control”.
The letter, available in full at this link, is an urgent call to protect public health, wildlife and the environment. It urges the Ministry of Agriculture to reconsider its objections and align itself with scientific evidence in order to ensure a truly effective and uncompromising ban on lead.
