Non Toxic Shot Regulations 2018 - FAQ

Frequently Asked Questions

Fish & Game is taking further steps this year to phase out the present exemption for owners of sub-gauge shotguns ( such as 20 gauge) to use lead to hunt waterfowl within 200 metres of open water.

The decision, taken in 2016  by Fish & Game New Zealand’s Council, is being introduced over the next four game bird seasons, beginning this year, 2018.

By the 2021 season, all sub-gauge shotgun owners will have to use non-toxic shot for their open water waterfowl hunting. The only exception will be for .410 bore shotguns.

Waterfowl are defined as ducks, paradise shelduck, swan and pukeko.  If you are hunting them over or within 200 metres of open water, then you must use non-toxic shot.  At the moment, that requirement applies to 10 and 12 gauge shotgun users, but from 2021, it will apply to all waterfowl hunters except those with .410 shotguns.

Open water is defined as any stream, river, lake, wetland or tidal area more than three metres wide.  If you hunt in a harbour, foreshore, estuary or other tidal area, then the 200m rule applies from the Mean High Water Mark. 

A sub-gauge shotgun is one that uses 16 gauge, 20 gauge, 24, gauge, 28 gauge, 32 gauge or .410 shells.  The requirement to use non-toxic pellets for waterfowl hunting will apply to all these weapons except the .410 bore.  

Non-toxic shot does not contain lead and there is a wide range of alternative shotgun shells available for waterfowl hunting which are lead free.  The most common is steel, and this is already widely used in New Zealand.  Other products such as bismuth and a variety of tungsten mixes are less widely available but expected to become more common.  These are often more suitable to use in older shotguns which cannot be used with steel shot.

Because non-toxic shot has been mandatory in North America and Europe for a long time, the world’s major ammunition manufacturers have catered for the consumer demand for non-toxic shot in commonly-used shotgun gauges.  British and United States companies in particular make and sell bismuth and steel shotgun shells in 16, 20 and 28 gauges. 

The new requirement will be phased in over the next four game bird seasons, beginning with the 2018 season which begins Saturday, May 5. Technically, the non-toxic requirement came into effect last year after the 2017 season ended. However, the reality is that for most game bird hunters, the beginning of the new season this year (May 5) is the practical start. Owners of sub-gauge shotguns are encouraged to use up their lead shot then switch to non-toxic shot which is now available, for the sake of the environment – read on.  

In many parts of the world, hunters are not allowed to use lead shot for wildfowl hunting because it has been shown to poison ducks which accidentally eat it as grit. Lead is a toxic substance, so much so that there is no level of exposure which is considered safe. It is not only waterfowl which are affected.  Humans too can be poisoned and over the years, lead has been removed from widely used products like paint and petrol to protect human health.

New Zealand has already banned the use of lead in paint and petrol because of the health damage it was causing.  The decision to also phase out lead shot for waterfowl hunting was made in 2000 after the government decided to adopt Australian and New Zealand guidelines for fresh and marine water quality which identified issues with lead.  Scientific studies were then conducted into lead shot ingestion in New Zealand’s waterfowl.  More than 1,500 duck gizzards were examined during this research to see if they had ingested lead shot. The results of this peer-reviewed study showed New Zealand was no different from other countries where similar research had revealed lead being ingested by waterfowl.  The internationally acknowledged threshold for a change away from lead shot is when ingestion levels are five percent or higher. In New Zealand, it was found that ingestion levels were averaging eight percent across the whole country.  Further research is continuing and indicates contamination by heavy metals like lead remain a risk to wildfowl. 

In New Zealand, waterfowl hunters must use non-toxic shot if they are hunting over open water, or within 200 metres of open water.  In the United States and Canada, non-toxic shot must be used for all waterfowl hunting, and in some cases, also for hunting upland game such as pheasant and quail. Australia too requires non-toxic shot for waterfowl hunting.  In England, non-toxic shot must be used when hunting any waterfowl, even over land. Such tight restrictions are not presently being considered in New Zealand.

The requirement for sub-gauge shotgun hunters to begin using non-toxic shot comes down to two simple points – the detrimental environmental impact of lead shot and consistency and fairness for all Fish & Game game bird hunting licence holders.  Nine out of ten waterfowl hunters use 10 or 12 gauge shotguns and they have had to use non-toxic shot since 2004, or face prosecution.  Fish & Game feels it is only fair to ask the remaining small number of sub-gauge shotgun users to start doing their bit for the environment by also using non-toxic shot. Please note again that we are asking for voluntary compliance before this comes into force in 2021.  

The simple answer is for as long as you like.  If you hunt waterfowl over open water, you will have to use non-toxic shot from 2021. As we’ve noted, the new rules are being phased in over four years to give game bird licenceholders with sub-gauge shotguns like 20 gauges time to get accustomed to the changes and make the transition to non-toxic shot. For the first two seasons – 2018 and 2019 – hunters can use up their existing stocks of sub-gauge lead ammunition. In 2020, if they are hunting waterfowl on Department of Conservation or Fish & Game-controlled land, they must use non-toxic shot only - nothing else. From 2021, non-toxic shot will be required for waterfowl hunting over open water in all shotguns except the .410. This applies to all lands, public and private.

Fish & Game recognises the .410 shotgun is used by beginner hunters as a stepping stone into game bird hunting.  Its lighter weight gun, smaller shells and ease of handling make it suitable for younger and smaller stature hunters.  Because of this and the fact non-toxic shells for .410 are not readily available internationally, .410 shotgun users will be allowed to continue using lead for waterfowl hunting.   

Older shotguns may not be able to use steel shot but it is highly likely they will be able to use bismuth or tungsten polymer mixes such as Matrix.  If you are in doubt, get a competent gunsmith to check your shotgun.  There should be no reason why you can’t continue using your elegant English shotgun or treasured family heirloom for waterfowl hunting if you select the appropriate non-toxic shotgun shell.  

You can use lead shot to hunt ducks in grass paddocks or over stubble as long as you are more than 200 metres from open water.

No matter what gauge shotgun you are using, you can continue to hunt pheasant and quail with lead shotshells.  However, from 2021, if the waterfowl season is still open when you are upland game hunting, you will not be able to be in possession of lead shot to hunt both waterfowl and upland game at the same time.  This is the rule which already exists for 10 and 12 gauge shotgun owners and will simply be extended to sub-gauge users once the new restrictions come into force.