United Kingdom Strengthens Ammunition and Projectile Controls via REACH Amendments

United Kingdom has introduced stricter chemical safety controls for ammunition and projectile products, including cartridges and explosives, through the REACH (Amendment) Regulations 2026.

UK – AMMUNITION

UK Tightens Chemical Rules for Ammunition

New REACH amendments set limits for shotgun cartridges and projectiles.

1 Apr 2028 Shooting range derogations
1 Apr 2029 Shot & bullet restrictions
930621 HS code for shotgun cartridges
930690 HS code for other projectiles

What changed

Restrictions on hazardous substances in shotgun cartridges (HS 930621).

Restrictions on hazardous substances in ammunition projectiles (HS 930690).

New chemical thresholds required before products can enter the market.

Updated REACH framework established under the REACH (Amendment) Regulations 2026.

Who it affects

Importers of shotgun cartridges (HS 930621) must meet new chemical limits by 1 April 2029.

Importers of other ammunition (HS 930690) must meet new chemical limits by 1 April 2029.

Shooting range operators must comply with derogation provisions from 1 April 2028.

Key dates

3 Mar 2026 — regulations formally adopted.
1 Apr 2028 — shooting range derogations take effect.
1 Apr 2029 — restrictions on shots and bullets take effect.
United Kingdom — REACH amendments for ammunition and projectiles

Compliance Overview: Stricter Chemical Safety Controls for Ammunition and Projectile Products under the REACH (Amendment) Regulations 2026

The REACH (Amendment) Regulations 2026 introduce targeted restrictions on lead and its compounds in ammunition and projectile products (e.g., cartridges, shot, and other projectiles) under UK REACH (Regulation (EC) No 1907/2006, as retained and amended in UK law). These measures take effect from 1 April 2026 and apply across England, Wales, and Scotland1, 2. Below is a structured breakdown of the key compliance requirements, exemptions, and enforcement provisions.

Regulation Analysis

1. Core Restrictions on Lead in Projectiles

The Regulations amend Annex XVII of UK REACH (Entry 63) to impose concentration limits and usage restrictions on lead in projectiles, with phased implementation:

RegulationKey RequirementDeadline/ThresholdAuthority
Lead in shot (pellets)Prohibits the use and placing on the market of lead shot (projectiles containing ≥1% lead by weight)2.1 April 2026Health and Safety Executive (HSE)1; local trading standards (enforcement)2.
Other projectilesProhibits the use and placing on the market of projectiles (other than shot) containing ≥3% lead by weight, with exceptions for specific uses (e.g., outdoor shooting ranges, elite athletes)2, 1.1 April 2026 (labelling from 2029)HSE (proposal); enforcing authorities (e.g., local councils, Border Force)2, 1.
LabellingFrom 1 April 2029, projectiles ≥6.17mm calibre containing ≥3% lead must be labelled: "Must not be used for live quarry shooting"2. Labels must be indelible, visible, and distinct2.1 April 2029Suppliers (manufacturers/importers)2; enforced by Secretary of State/local authorities.

2. Exemptions and Derogations

The Regulations carve out specific exemptions for public safety, military, and specialised uses, as well as temporary derogations for certain activities:

Full Exemptions (Paragraphs 25–26)2

  • Public sector uses:
    • Police, government security services, Border Force, and military purposes.
    • Forensic analysis and museum collections (licensed under the Firearms (Amendment) Act 1988).
  • Industrial/research uses:
    • Technical testing, proofing, and development by manufacturers or contracted test houses.
    • Historical/technical research by academic institutions.
  • Certificate-based exemptions:
    • Projectiles used by individuals whose firearms certificate conditions specify non-firing use2.

Conditional Derogations (Paragraphs 13–23)2

Use CaseConditionsCitation
Outdoor shooting ranges– Risk-reduction measures for ruminants/wildlife, soil, and water must be implemented.
– Documentation of actions must be maintained and submitted to the enforcing authority at least every 3 years2.
– Updated submissions required for changes (e.g., address, contact details).
2
Elite athletes– Applies to athletes recognised by National Olympic/Paralympic Committees.
– Athletes must provide information on their status to suppliers; suppliers must verify eligibility2.
2
Air weapons– Derogation for lead projectiles in air weapons (no concentration threshold specified)2.2
Indoor target shooting– Projectiles used in fully enclosed buildings (no emissions beyond the structure)2.2

3. Enforcement and Compliance Obligations

Enforcement Authorities

  • Secretary of State: Enforces supplier obligations (e.g., labelling, technical documentation, database registration).
  • Local authorities (e.g., trading standards in England/Wales, councils in Scotland): Enforce dealer obligations (e.g., promotional material, online sales).
  • Border Force/other agencies: Enforce exemptions for military/security purposes2.

Key Compliance Steps for Businesses

  1. Registration and Documentation:
    • Manufacturers/importers must maintain technical documentation proving compliance with lead concentration limits2.
    • Outdoor shooting ranges must submit risk-reduction documentation to enforcing authorities every 3 years2.
  2. Labelling (from 1 April 2029):
    • Projectiles ≥6.17mm calibre with ≥3% lead must display the mandatory warning label on packaging and online product pages2.
  3. Supply Chain Verification:
    • Suppliers must verify elite athlete status before supplying lead projectiles2.
    • Dealers must ensure promotional material (e.g., online listings) complies with labelling requirements.

Penalties and Enforcement Powers

  • Civil sanctions: Enforcing authorities may issue notices of intent for testing costs (e.g., if a product fails compliance tests).
  • Criminal offences: Failure to comply with restrictions may result in prosecution under UK REACH enforcement provisions2.
  • Powers of entry: Authorised persons may inspect premises (excluding private dwellings), seize non-compliant products, and require documentation.

4. Socio-Economic Impact and Stakeholder Consultation

  • The Secretary of State assessed alternatives and socio-economic impacts before drafting the Regulations, publishing a final opinion via the HSE1, 2.
  • Devolved administrations: Scottish and Welsh Ministers consented to the draft amendment and final Regulations2.

Summary Answer

The REACH (Amendment) Regulations 2026 impose stricter controls on lead in ammunition and projectiles, effective 1 April 2026, with phased labelling requirements from 2029. Key restrictions include:

  • Bans on lead shot (≥1% lead) and other projectiles (≥3% lead)2.
  • Exemptions for military, police, elite athletes, and outdoor shooting ranges (subject to risk-reduction measures)2.
  • Labelling obligations for projectiles ≥6.17mm calibre from 1 April 20292.
  • Enforcement by the Secretary of State, local authorities, and specialised agencies, with powers to inspect, test, and penalise non-compliance.

Businesses must verify compliance, maintain documentation, and adhere to labelling rules to avoid civil or criminal penalties. For full details, refer to the HSE’s socio-economic assessment and the Explanatory Note accompanying the Regulations1, 2.

Sources

  1. members.wto.org — modification / 26 03338 00 e https://members.wto.org/crnattachments/2026/TBT/GBR/modification/26_03338_00_e.pdf
  2. legislation.gov.uk — 195 / made https://www.legislation.gov.uk/uksi/2026/195/made

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