Proposals to modernize Canada’s Migratory Birds Regulations: chapter 3

3. Hunting Methods and Equipment

3.1 New approach for authorizing non-toxic shot


The types of non-toxic shot that may be used for hunting migratory birds are listed in the Migratory Birds Regulations. There are currently eight definitions of approved shot types, and each type is specified by its elemental composition.

When a manufacturer wants to add a new type of non-toxic shot to the list, a comprehensive regulatory process must be followed. This process includes

  1. testing the toxicity of shot samples;
  2. having Environment Canada scientists evaluate and approve the samples; and
  3. formally amending the Regulations.

This entire process can take anywhere from three to five years, yet many new shot compositions comprise ingredients that have already been evaluated for toxicity.

The problem

The process of adding each new type of non-toxic shot presents a significant administrative burden in terms of time and resources. Also, it must be asked whether it is reasonable for the industry to expect to wait up to five years to register a new non-toxic shot.


Table 3.1: Options considered for certifying new non-toxic shots
Options Pros Cons
1. Status Quo - Testing all new shots is required, with subsequent regulatory process Hunters and enforcement officers refer to the Migratory Birds Regulations for a list of approved shots Administratively burdensome, lengthy process
2. Convert to a generic definition that would comprise the elements already tested for toxicity, and require manufacturers to label the box “non-toxic for birds”

Would automatically accommodate most new non-toxic shots being developed

Eliminates the current process for manufacturer submission and testing the toxicity of each new candidate shot

Testing and regulatory process would only be required for any proposed shot falling outside the boundaries of the general definition

Labelling requirement increases certainty for hunters, in absence of a regulatory list

No list of approved shots for hunters or enforcement officers to refer to

Recommended solution - Option 2

Key Messages

The main difference between the status quo and the recommended approach

Under the recommended approach, hunters would be certain that the shot they purchase is certified as non-toxic, and the approval process would be much quicker for manufacturers. The proposed definition would not completely eliminate the need for possible future amendments to the Migratory Birds Regulations, but it would likely reduce that need considerably.

Proposed new definition of “non-toxic shot”

"Any shot composed of up to 100% by weight of iron, tungsten, tin, or bismuth, or any combination of these four metals; and not more than 45% copper, and not more than 35% nickel, and not more than 1% of any other element, and any amount of Nylon 6 or 11 or ethylene methacrylic acid copolymer."

Labelling of shot

Manufacturers would be required to label the box "non-toxic for birds."

Objectives addressed

  • Clarity
  • Regulatory efficiency


The proposed option--which includes redefining non-toxic shot, along with labelling the box as "non-toxic for migratory birds"--reduces the administrative burden of unnecessary toxicity testing and makes it easier for hunters to know which shot types have been approved.

3.2 Option for ensuring that species taken can be identified


Regulations concerning the daily bag and possession limits and open season dates differ according to each species. This allows regulations to be designed specifically to ensure conservation of species that are at low levels, and also to permit more opportunity for hunting species that are at high levels. Because the Regulations vary by species, it is important that enforcement officers are able to identify the birds taken. That is why the current regulations require hunters to leave a fully feathered wing on each carcass, as species can be easily identified using the colour patterns on the wing.

The problem

Environment Canada has received numerous complaints about the current requirement. Many hunters have requested permission to leave the bird’s head--rather than a feathered wing--attached to the carcass, as the argument can be made that the species of migratory birds can be identified equally well from a fully feathered head as from feathers on a carcass.

In the United States, hunters are permitted the option of retaining a fully feathered head attached to the carcass, and there have been no problems reported with this practice.

The main argument relates to the size of feathered wings of geese and the difficulty this presents for transportation. Hunters are also concerned about contamination that might result from the difficulty of preventing the feathered wing from contacting the rest of the bird once it has been plucked and cleaned.


Table 3.2: Options considered for species identification
Options Pros Cons
1. Status quo - must retain a fully feathered wing attached to the carcass, until processing Species is readily identifiable Hunters continue to find wings too bulky to transport, especially for goose species
2. Add a hunter’s choice option to retain a fully feathered head attached to the carcass, instead of allowing only a wing
Hunters have been requesting the option to instead retain a fully feathered head May require new training for enforcement officers

Recommended solution - Option 2

Key Messages

The main difference between the status quo and the recommended option

The hunter would have the choice of retaining a fully feathered head or a wing attached to the carcasses.

The wing or head may be removed for processing

Birds that have been plucked and cleaned but not preserved in any other way (e.g. by freezing or cooking) are not considered processed, and so must retain the head or wing attached.

Once the bird is processed (see definition in Section 2.1), the head or wing may be removed.

Why not use DNA testing?

New techniques for field testing may become available in the future, but DNA testing is not feasible at this time.

Objectives achieved

  • Hunter preference is addressed


As requested by hunters, they could choose whether to retain a fully feathered wing or head attached to the carcass.

3.3 Using bows


Currently, the Regulations allow hunting of migratory birds with a long bow. A “long bow” includes a recurve bow and a compound bow.

The problem

Some hunters are requesting that the Canadian Wildlife Service add cross bows as a legal means of hunting. However, others believe that hunting with bows of any kind should be prohibited because insufficiently powerful equipment or inappropriate types of arrows or bolts can result in crippling of birds. Images posted across the Internet of birds still living with arrows stuck through their bodies do nothing to alleviate negative public perception of hunting.

If instances of crippling are to be reduced, it is important to ensure that requirements for bows--regardless of their type--are appropriate for hunting waterfowl.


Table 3.3: Options considered for a new concept of using bows
Options Pros Cons
1. Continue to allow use of long bows--but add cross bows Deals with the inconsistency of not allowing cross bows for no apparent reason Does not address crippling issues
2. Continue to allow use of long bow--but add cross bows AND specifications to ensure killing power for all bows
Addresses crippling issue None
3. Prohibit use of bows for hunting migratory birds Eliminate bows as a source of crippling Eliminate something hunters enjoy instead of fixing it

Recommended solution - Option 2

Key Messages

Ensure that bows are sufficiently powerful

Under Option 2, the Regulations would be amended to include a new description of allowable bows. The requirements are proposed as follows:

A bow (long, recurve or compound) must have a minimum draw weight of 18kg or 40lb and use an arrow with a broadhead with at least two sharp blades a minimum of 22mm or 7/8” wide. For cross bows, the requirement is for a minimum draw weight of 45kg or about 100lb, and a bolt with a broadhead a minimum of 22mm or 7/8” wide with at least two sharp blades.

Matching provincial requirements

Where provincial requirements for bows used for hunting game birds are different than those described above, we could consider an option to adopt provincial specifications. In general, the specifications in provincial regulations for hunting turkeys match very well with what would be needed to hunt geese.

Thus, the proposal (above) adopts the minimum of the provincial requirements, ensuring that hunters would not have to purchase new additional archery equipment to hunt migratory birds.

Objectives achieved

  • Addresses the issue of crippling
  • Deals with the current inconsistency of not allowing cross bows for no apparent reason
  • Meets the requests of hunters and increases their enjoyment of hunting


The proposed approach responds to the request from hunters to allow use of cross bows, and also reduces the potential for crippling.

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