BY MARK CRUDGINGTON

To: The Rt Hon Steve Reed MP
Secretary of State for Environment, Food and Rural Affairs
Department for Environment, Food & Rural Affairs
Seacole Building, 2 Marsham Street
London
SW1P 4DF

Subject: Concerns Regarding the Proposed Ban on Lead Ammunition

Dear Secretary of State,

I am writing to express deep concern regarding the Government’s proposal to ban the use of lead shot in shotguns and lead bullets in rifles exceeding .241 inches in bore diameter. While the intention to reduce environmental contamination is acknowledged, the current form of the proposed restrictions poses severe—and in many cases insurmountable—challenges for owners of heritage, traditional, and specialist firearms.

Several critical issues must be urgently addressed to prevent disproportionate harm to responsible gun owners, heritage shooting disciplines, and the conservation of historic firearms:

1. No Viable Alternatives for Historic and Traditional Firearms
   Many muzzle-loading and breech-loading black powder guns are incompatible with non-lead shot types. Steel and tungsten shot cannot be safely used due to the absence of protective wads in necessary bore sizes. Additionally, these firearms cannot propel lighter alternatives (e.g., Bismuth) to effective velocities, rendering humane dispatch of game or consistent clay target shooting unachievable. Similarly, black powder rifles cannot safely or accurately fire monolithic copper or other solid alternatives designed for nitro-powered rifles.
2. Proofing, Safety, and Legal Standing of Pre-1954 Firearms
   The UK Proof Houses do not recommend steel shot for firearms proofed prior to 1954. Most older guns lack the strength required for re-proofing to higher pressures demanded by steel ammunition. Even if technically safe, they may be deemed “out of proof,” making them uninsurable and effectively prohibited under the proposed regime—rendering them unusable despite being in working order.
3. No Alternative for Ball & Shot Guns
   “Ball and shot” guns, which fire a combination of round ball and shot, have no suitable non-lead projectiles available. Their unique design relies entirely on lead-based ammunition. A ban would criminalise their use and erode a historically important part of the UK’s sporting heritage.
4. Small-Bore Guns and Performance Limits
   Small-bore nitro shotguns (e.g., .410 and 28 bore) typically use sub-18 gram loads, which cannot be replicated effectively with steel or Bismuth. Their continued use with lead ammunition should be permitted—akin to the exemption for .22 rimfire rifles—given their similar practical and ballistic limitations.
5. Loss of Value and Lack of Compensation
   The proposed ban risks devaluing legally owned firearms worth hundreds of thousands of pounds, many of historical, cultural, or artisanal significance. These are not merely tools but heirlooms and investments. If rendered obsolete, will the Government compensate owners for these financial losses? Clarity on this point is essential.
6. Request for Proportionate and Evidence-Based Exemptions
   I urge DEFRA to adopt a nuanced approach, including exemptions for:
   • All muzzle-loading and breech-loading black powder firearms;
   • Pre-1954 proofed guns where no safe, viable non-lead alternatives exist;
   • Ball and shot guns;
   • Small-bore shotguns (.410, 28 bore) using lead loads ≤18 grams.

This issue intersects environmental policy, fairness, heritage conservation, and the rights of responsible firearm owners. I respectfully ask DEFRA to consult further with stakeholders—including the Gun Trade Association, muzzle-loading associations, the Proof Houses, and heritage shooting organisations—to ensure the final legislation is safe, proportionate, and practicable.

I welcome the opportunity to discuss these concerns further and look forward to your response.

Yours sincerely,
Mark D. Crudgington

Of George Gibbs Ltd
george.gibbsltd@btinternet.com