The poisoning of birds by lead ammunition is more common in waterfowls (where a restriction on the use of lead shot is already in place), rather than in birds in terrestrial areas, where it is almost impossible for lead shots to accumulate in large quantities, making the possibility of lead ingestion close to zero.
A literature review of population trends of potentially exposed terrestrial bird species suggests that most birds species reported to be potentially exposed to lead shot are not declining in Europe, proving that the poisoning by lead ammunition does not pose a threat to species extinction; and those that are, probably are declining due to other factors besides lead shot, such as exposure to herbicide and increased predation.
Moreover, the number of birds dying from lead poisoning provided by institution appears to be incorrect and based on wrongful assumptions. In 2018, ECHA stated that “1 to 2 million terrestrial birds die from lead poisoning annually”. This estimation was done through the upscaling of what they considered “known effects from lead shot ingestion in wetlands”. Such wrongful extrapolation was based on the incorrect assumption that water and terrestrial birds are similar and have equal habits.
In 2020, ECHA reviewed its estimations by stating that 135 429 204 birds are at risk of primary poisoning from lead shot, with the mortality of birds to direct ingestion of lead shot estimated as 1% of the total (1 354 292), and that 14 392 217 birds are at risk of secondary poisoning from lead bullet, without giving estimations on mortality rate. This very accurate estimates however are not based on scientific knowledge, as ECHA does not anyhow outline the exact scientific process used to derive that estimate and does not provide any valid source of information. Furthermore, the studies used to produce such estimates have been conducted on farm species and in intensive hunting reserves, scenarios which have nothing to do with the reality and, thus, lead to flawed results.
Mortality data are indeed not available in sufficient quality and quantity, nor are collected in the same and consistent across all habitats and species investigated.
Therefore, there is no valid scientific evidence or figure on the poisoning of birds caused by lead shot or bullets that can justify a restriction on lead ammunition in the EU. As defined in REACH, a restriction can only be adopted if it is demonstrated that the substances present “an unacceptable risk to human health or the environment (…) which needs to be addressed on a Community-wide basis”. An ‘unacceptable risk’ requires not only a demonstration of widespread and repeatable mortality but also data on long-term trends on populations of terrestrial birds.