Different metals have been proposed for the replacement of lead in ammunition. Among these, we can acknowledge bismuth, tungsten, tin, and steel. Related to these substances, different problems arise and constitute issues for a general substitution of lead metal in the sector, posing engineering challenges, non-negligible performance issues, increase in costs and non-availability of rough materials.
In terms of availability of raw materials, two of the proposed alternatives to lead in ammunition (bismuth and tungsten) are on the 2017 EU critical raw materials list, for which the EU relies heavily on the import mainly from China, Mexico and Japan. Also tin, which is the most widely reported substitute to lead for lead-free pellets used in air guns and air pistols, and steel, which is an alternative to lead shot and proposed as an alternative to lead in bullets, are largely imported from outside the EEA area, mainly from China.
The end of life and recycling of these alternatives should be also considered. For instance, even though the EU import reliance for bismuth is lower than tungsten, the former is more difficult to recycle. The same applies to tin, which has a very low recycling rate.
An additional consideration should be made in terms of supply. Tungsten and tin are two of four conflict minerals targeted by the EU Conflict Minerals Regulation. The EU regulation covers tin, tantalum, tungsten, and gold because these are the four metals that are most mined in areas affected by conflict or in mines that rely on forced labor. Substitution of lead with tungsten and tin will increase demand and further increase the due diligence requirements that the increased supply needed to fulfil the demand is not coming from conflict regions. Most importantly, tin is also around 8 times more expensive than lead.
A ban on the placing on the market and use of lead ammunition in terrestrial habitats in Europe would have severe consequences for the whole sector. Many individuals would be forced to abandon hunting and shooting due to higher safety risks, lack of suitable alternatives for many calibres, and to the expenses they would have to incur to replace the barrels or to purchase a new firearm. With a decrease in the number of sport shooters practicing their disciplines, many shooting ranges would be forced to close.
Ammunition and firearms manufacturers would have to face higher costs for the energy to make the projectiles, raw material, R&D to bring the new products on the market, redesign the firearms in terms of performance and safety. For each product, the technical and economic feasibility of a re-engineered lead-free unit of ammunition would need to be considered. This would impact the supply of lead ammunition for those uses that are still allowed, such as the military, police and law enforcement uses.
Switching to non-lead ammunition would inevitably increase the demand for the other raw materials and cause supply problems, as already mentioned, and more intensive use of energy would be required to source scarce alternatives.