Recommendations

Recommendations

¶203. The Inquiry’s Phase 1 hearings have been a deliberately focused and rapid examination of the circumstances of the attack itself, and the relevant agencies dealings with AR. While I have heard evidence in Phase 1 from online retailers, including in relation to knives/machetes and archery equipment/crossbows, I have not at this stage been able to consider wider arguments from interested groups including (for example) archery enthusiasts, or those for whom, for various reasons, online retail may be very important because of difficulties in accessing traditional physical retailers.

¶204. Accordingly, it is appropriate for me to draw a distinction between recommendations which I am confident in making now in Phase 1 and matters which I would wish to consider further as part of Phase 2.

Patterns of suspicious online purchases: recommendations

¶205. I will wish to consider wider evidence regarding the ability to spot suspicious patterns of online purchases.

Recommendation 12: Phase 2 should consider systems to detect and report concerning online behaviour and suspicious combinations of purchases. This should include consideration of:

1. Concerning patterns of online browsing and purchasing (e.g. change of names and addresses, use of Virtual Private Networks).

2. Concerning purchases of dangerous but legal items (e.g. sledgehammers, bow and arrows and smoke grenades).

3. Concerning combinations of purchases (e.g. castor beans, alcohol and laboratory equipment).

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Ricin: recommendations

¶206. Ricin is highly dangerous. If AR had decided to commit multiple murders using ricin rather than a knife, the death toll – depending on the method of distribution – could well have been even more extensive than the dreadful attack carried out on 29 July 2024. In my view, the Home Office is right to be carrying out a review of the sale of castor beans. Although there is an entirely valid horticultural use for castor beans, I consider that there is a case for tighter controls on their sale.

Recommendation 13: The Home Office’s ongoing review of the sale of castor beans should consider regulation of the number of castor beans that can be sold in a single transaction.

¶I wish to be kept apprised of the review and of the actions taken as a result of the review.

Archery equipment (conventional archery bows and crossbows): recommendations

Conventional archery bows

¶207. The evidence I have heard in relation to conventional archery bows has varied. This was exemplified in the difference of approach between Tactical Archery (who voluntarily age check conventional archery bow purchases, despite the lack of legal requirement) and Merlin Archery who do not see conventional bows as a particular risk.

¶208. I recognise that there are material differences between conventional archery bows and crossbows. The sporting (target) use of conventional archery bows is far more recognised and accepted. I note Mr Jones’ evidence as to the widespread youth interest in sporting archery, and the legitimate need for children to own/possess their own equipment. Ms Ellsmore of the Home Office explained in her statement that conventional bows are considered to be less attractive for potential misuse than crossbows, as they require a much greater degree of skill to use, are more cumbersome to carry, very difficult to conceal from sight, and are unlikely to have the same ability to fire as rapidly as crossbows. She has stated that this is reflected in the “very few (if any) offences that are committed by bows that are not crossbows”.⁵⁵⁸⁵⁵⁸ First Witness Statement of Ms Ellsmore HOM000078/§214. Mr Hunt of the Home Office expanded on this in his oral evidence noting that bows and arrows (compared to crossbows) had very rarely been used in crime, being relatively cumbersome and requiring a high degree of skill to use.⁵⁵⁹⁵⁵⁹ T/S: 23/127/10-128/10.

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¶209. Nevertheless, based on the Phase 1 evidence. I do have concerns about the almost complete lack of control over the sale of traditional archery bows:

¶a. AR’s own purchase of an archery bow and arrows, which he doubtless purchased as a weapon, shows their attractiveness as a weapon to violence fixated individuals. It is of note that AR bought a bow and arrows (which did not have age control) before moving on to seeking out the potential to buy, underage, a crossbow;

¶b. There is no doubt about the serious harm that could be inflicted by the kind of bow and arrows widely available online;

¶c. Some of the imagery and language around even conventional archery bows is, in my view, questionable. I have already touched on the very name of Tactical Archery (while recognising that MB Outdoors Limited are considering changing this trading name). I have no doubt that Merlin Archery Limited are at the more responsible end of the retailers in this area. But even they chose to use marketing imagery of someone in military-style camouflage kit holding an archery bow.⁵⁶⁰⁵⁶⁰ Merlin Archery website, (2025). Available at: www.merlinarchery.co.uk (last accessed 25 November 2025).

¶Given that it is illegal to use any bow or crossbow for the purposes of hunting any wild bird or wild animal, it is hard to see why camouflage gear is being used to market archery equipment.⁵⁶¹⁵⁶¹ Sections 5 and 11 Wildlife and Countryside Act 1981, available at www.legislation.gov.uk/ ukpga/1981/69/section/5; www.legislation.gov.uk/ukpga/1981/69/section/11

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¶Similarly, the online retailer PreppersShop.co.uk chooses to use a image for the page of its conventional archery sales.⁵⁶²⁵⁶² Preppers shop website, (2025). Available at: Preppersshop.co.uk/collections/archery (last accessed 25 November 2025). A sample image of how the crossbows are marketed with camouflage gear is shown below.⁵⁶³⁵⁶³ www.istockphoto.com/photo/bowman-with-bow-and-arrow-gm508650851-46094770

¶210. I will wish to consider wider evidence on this issue.

Recommendation 14: Phase 2 should consider whether conventional archery bows should be subject to age-verification prior to sale, delivery restrictions including ID checks, mandatory labelling for deliveries, and industry or trading standards to prevent the use of military-style imagery in marketing.

Crossbows

¶211. While I take into account that AR does not appear to have succeeded in buying a crossbow, I am confident that he was emailing both Tactical Archery and Merlin Archery to ‘test the waters’ on how strict the age verification was, and on what the packaging would be so he could try to evade his parents knowing if he bought one. While he did not place an order, AR’s well-evidenced interest in crossbows shows their attractiveness to violence fixated individuals.

¶212. As reflected in the current legislative distinction between conventional archery bows and crossbows, crossbows carry obvious risks that are much higher than conventional archery bows. As explained by Mr Jones, crossbows:⁵⁶⁴⁵⁶⁴ MERA000007/3-4.

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¶a. Are easy to become proficient with, requiring minimal instruction;

¶b. Can be cocked aimed and shot with relative ease and accuracy;

¶c. Can be fired one handed;

¶d. Are easier to conceal;

¶e. Can be held for long periods in the ready to fire position;

¶f. Are on average more powerful than conventional archery bows and cocking aids mean the crossbow can be used regardless of the user’s physical strength.

¶213. I welcome the government’s recently published response of 19 March 2026 to the crossbow call for evidence, which confirmed the intention to introduce significant new controls, including a licensing scheme for existing owners and a prohibition on the sale of crossbows, with further consultation planned on the detailed design of these measures. I am conscious that I have not heard detailed evidence of the extent of the legitimate use of crossbows and that this should be further explored in parallel with the government consultation before I make final recommendations in Phase 2.

¶214. I should record however my particular concern about the attractiveness of crossbows as a weapon, their design (which in the case of pistol crossbows, in particular, appears to gravitate towards making crossbows look like conventional firearms), and the imagery that is associated with their current marketing. Samples of readily accessible images from retailers advertising for UK crossbow online sales include online retailers PreppersShop.co.uk,⁵⁶⁵⁵⁶⁵ ’CROSSBOWS’ section picture at www.preppersshop.co.uk,⁵⁶⁶⁵⁶⁶ Picture 6 at www.preppersshop.co.uk/products/tenpoint-turbox-acuslide-compound-crossbow-rangefinder-package-in-vektra-camo Tacticalarchery.co.uk,⁵⁶⁷⁵⁶⁷ See shop by brand on the opening page at https://tacticalarchery.co.uk,⁵⁶⁸⁵⁶⁸ EK Archery Revo 7 Self-Repeating Crossbow 90lbs at https://tacticalarchery.co.uk/products/ ek-archery-revo-7-self-repeating-crossbow-90lbs,⁵⁶⁹⁵⁶⁹ EK Archery - Vlad Pistol Crossbow With 8-Bolt Magazine at https://tacticalarchery.co.uk/ products/ek-archery-vlad-pistol-crossbow-60lbs-90lbs Merlinarchery.co.uk,⁵⁷⁰⁵⁷⁰ Steambow AR-Series M10 Tactical Crossbow at www.merlinarchery.co.uk/steambow-ar-series-m10-tactical-crossbows.html Hattila.com.⁵⁷¹⁵⁷¹ 6 carbon hunting bolts for 50 and 80 pound mini crossbows at www.hattila.com/en/50-80-lb-shafts/2556-6-carbon-hunting-arrows-for-crossbows-80-lbs.html

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¶Similar examples of images are shown below.⁵⁷²⁵⁷² www.istockphoto.com/photo/tactical-jungle-military-hunter-camouflaged-gm1197769293-342082043,⁵⁷³⁵⁷³ www.istockphoto.com/photo/modern-crossbow-isolate-on-a-white-background-quiet-weapon-for-hunting-and-sports-gm1396754868-451404862

¶215. I will wish to consider wider evidence on the issue of crossbows. However, I make the following recommendation mindful of their lethal potential, their attractiveness as weapons to violence fixated individuals, their greater risks over conventional archery bows, and their more limited legitimate use.

Recommendation 15: Phase 2 should consider, in parallel with the government’s consultation where possible, a prohibition on the sale of crossbows, a licensing scheme similar to firearms, tighter controls on purchasing such as restricting sales to age-verified in-store transactions, and Trading Standards measures to prevent military-style marketing.

All archery bow retailers (conventional and crossbows)

Recommendation 16: The Home Office should provide clear guidance to all UK retailers of archery bows and crossbows on identifying and reporting suspicious behaviour, including underage purchasers or those who appear to be interested in criminal use of the equipment, and should consider placing retailers under defined obligations to report material suspicions.

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Knives and machetes: recommendations

Recommendations for immediate action

Recommendation 17: The Commissioner of Police of the Metropolis should consider an investigation, with input from the Crown Prosecution Service if appropriate, as to whether Ageo Wholesale UK Ltd committed criminal offences in relation to how it marketed knives/machetes or sold them without required age verification or labelling.

Recommendation 18: The Home Office should take immediate action to ensure that online knife retailers are complying with the Knives Act 1997, particularly regarding the marketing of knives, machetes, swords and similar bladed articles.

¶I am aware that following the Inquiry’s Phase 1 evidence, the Home Office has already raised this with the National Police Chiefs’ Council.

Recommendation 19: Amazon should:

1. Improve its measures to prevent children from making purchases, including making the conditions of use and sale more prominent.

2. Improve the labelling on packaging of bladed articles so that the warning is more prominent.

3. Ensure drivers inform recipients whenever deliveries contain a bladed article (I recognise the closing statement on behalf of Amazon that this is in train).

4. Review its systems for recording details of the recipient to ensure that an accurate record of the recipient is obtained.

5. Audit its training of age verified deliveries for drivers, in particular for Amazon Flex drivers. This should include training on the labelling of packaging so that, where appropriate, delivery drivers know what they are delivering.

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Recommendations for more detailed consideration in Phase 2 of this Inquiry

¶216. As a result of the evidence that I heard during the Inquiry regarding the online sale of knives and machetes, I wish to extend this further in Phase 2.

Recommendation 20: Phase 2 should consider further measures relating to knives/bladed items sales, including:

1. Restrictions on sharp-tipped knives.

2. Prohibiting some online sales (such as machetes).

3. Strengthening online age-verification and age verified delivery standards.

4. Mandatory reporting and information-sharing about suspicious behaviour.

5. The risks surrounding importation of bladed items.

6. The risks surrounding multiple sub-contractors in a supply chain delivering bladed articles.

¶The Inquiry notes that the Home Office has launched a public consultation, opened on 16 December 2025, on proposals to introduce a licensing system for the sale and importation of knives and bladed articles. The Inquiry welcomes this development and requests that it be kept updated on the progress and outcomes of this consultation, including any emerging proposals or legislative intentions arising from it.

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