No hands…and no heads: An argument to end heading in soccer at all levels

Football header
Published 11 March 2019 | Authored by: Jeremi Duru

Soccer sits at a troubling crossroads. With each passing year, the damage the game poses to its players’ brains becomes increasingly evident.1 The sport’s governing bodies, however, have in the author’s view reacted slowly and ineffectually, instituting weak concussion protocols – such as those revealed during the 2018 FIFA World Cup to be nothing more than “eye candy2 – and altering some rules for children playing the game.

For the good of soccer and its participants, far more must be done. In this author’s opinion, and based on research set out below, the act of heading, which presents the risk of both concussive and sub-concussive blows, must be eliminated from soccer at all levels. Anything less exposes soccer and its institutions to the litigation and public relations consequences the United States of America’s National Football League (the NFL) has endured.

The National Football League’s Cautionary Tale

American football is a violent game, and the NFL has suffered from its long-standing stubborn refusal to acknowledge the connection between playing the game and suffering brain trauma. It has suffered in the court of law and in the court of public opinion. In 2011, seventy-five former NFL players with brain injuries sued the NFL,3 and in the ensuing months an avalanche of plaintiffs followed them. Within a year, the various suits, involving 18,000 players, were consolidated into one enormous class action.4 The allegation was simple and straightforward: “[The NFL] failed to take reasonable actions to protect players from the chronic risks created by concussive and sub-concussive head injuries and fraudulently concealed those risks from players.5 Ultimately the parties signed a settlement agreement that would result in the NFL paying out up to $1 billion dollars.6

The settlement amount is certainly substantial, but with annual revenues topping $14 billion,7 the NFL can overcome it. The public relations consequences are much more severe. The neurological risks of playing American football are driving people away from the game. Year over year, youth American football participation rates drop as fearful parents direct their children toward other athletic endeavors. In 2015, the year in which the settlement was initially reached, 22% of the roughly 1,000 parents surveyed on the matter said they would not let their children play American football,8 and the percentage has increased substantially every year since, nearing 50% in 2018.9 Moreover, and perhaps more damaging, some of the NFL’s greatest ever players and most committed ambassadors have publicly lamented the dangers of American football. They have expressed concerns about their own brain health and about the future of the game, and many have indicated reluctance to let their children and grandchildren play.10

The concerns seem warranted, as American football’s inherent violence seems to unavoidably present a brain trauma risk.11 For the NFL, there may be no solution.

Soccer’s Path Forward

For soccer, however, there is a solution. A solitary rule change – the elimination of heading – will drastically reduce brain trauma in the game. Many in the soccer community have resisted calls to ban heading from the game, and their protests generally fall along one of two lines:

  1. heading is not conclusively injurious to the brain;12 and

  2. heading is too fundamental to the game to be abandoned.13

As detailed below, neither argument is sufficiently compelling to retain heading as a part of soccer.

Science increasingly reveals that the act of heading inevitably puts the head directly in harm’s way, posing a dual threat to players’ brains. The first threat is the concussion risk that heading the ball or attempting to head the ball creates. Often, attempted headers result in two players’ heads clashing or one player’s head smashing against another’s shoulder, elbow or forearm, causing a concussion.14 Even casual soccer spectators have observed these collisions, and one need not be trained in medicine to intuit that damage has been done.

The second threat – the repeated subconcussive impact of actually heading the ball – is less evident to spectators and is often overlooked or downplayed in the soccer community. Over the past two decades, due in large part to the NFL’s widespread brain trauma crisis, the long term effects of concussive blows have been well-documented, but the consequences of repeated sub-concussive blows have drawn relatively little attention. The scientific community, though, has been sounding the alarm for years.

Three decades ago, Norwegian researchers who had previously studied cognitive impairments among boxers found that the impact of a head meeting a soccer ball is similar to the impact a head meeting a boxer’s jab and that retired Norwegian professional soccer players displayed neurocognitive deficits “with alarming frequency.15 In the years that followed, other studies exploring the impacts of heading emerged, but the soccer community dismissed those raising concern about brain health “in almost a knee-jerk reaction.16

Today, however, the danger of heading a soccer ball is virtually undeniable. Research reveals that repeated sub-concussive impacts can produce symptoms that mirror those of concussion, like headaches, confusion, and diminished memory.17 More frightening still, Dr. Robert Cantu – a leading expert on brain trauma – notes that sub-concussive blows can create brain abnormalities while producing no concussion symptoms and going unnoticed.18 He explains:

[T]here have been [thirteen] studies that I’m aware of – there might be more – that have shown that sub-concussive hits in sports . . . have shown abnormalities on DTI MRI, have shown abnormalities on functional MRIs . . . and [have] also [shown] breakdown of the blood-brain barrier . . . . And that’s happened without recognized concussion, just from repetitive trauma.19

Soccer governing bodies could conceivably take measures to reduce the frequency and violence of bodily collisions occurring when players attempt to head the ball, though it is difficult to imagine what those measures might involve. Eliminating heading from all forms of soccer at all levels, however, is the only reform that will protect players from the repetitive sub-concussive blows that we now know damage their brains.

Notwithstanding the science, there has, to date, been no seminal lawsuit to force change in the soccer community. The most notable relevant suit was a 2015 action in which a group of American youth soccer players sued FIFA along with several national and regional soccer governing bodies alleging that the organizations had failed to implement rules to protect the players from brain trauma. The case, Mehr v. Fédération Internationale de Football Association, however, never reached the merits, as FIFA secured dismal on jurisdictional grounds,20 and the other defendants reached a settlement agreement with the plaintiffs.21 Had the case reached the merits, the litigation and outcome might have been groundbreaking. The settlement, however, was non-monetary, so exerted no financial pressure. And even the programmatic aspects of the settlement were extremely limited. Although the settlement restricted heading for players within U.S. Soccer’s Youth National Team and Development Academy and recommended such restrictions for non-National Team and Development Academy players, the guidelines only apply to children under thirteen years old, and for eleven and twelve year olds, they only apply during practices.22

Other soccer governing bodies around the world, such as UEFA, England’s Football Association (The FA), and the Professional Footballers’ Association (PFA) have taken notice of these restrictions, and have launched studies to explore the connection between heading and diminished brain health. In 2017, UEFA commissioned two independent studies regarding heading in youth soccer.23 The first explores heading instruction for youth and the manner in which in-game heading differs from heading practice.2425 The second is designed to measure heading’s impact on brain structure.26 That same year, The FA and the PFA jointly commissioned a study intended to determine the long-term brain effects of playing soccer.27 None of these studies are as of yet complete. While the PFA had, prior to initiating its study, issued a call for the elimination of heading for children under eleven, the other regulatory bodies are, for the time being, content to “research[] and examine[]” the issue.28

No governing body, in any region of the world, has moved to eliminate heading from the adult game even though the bulk of research revealing the damage heading causes the brain – such as the studies Dr. Cantu references – involved adult subjects.

This stalwart resistance seems to channel the second of the two principal reasons many in the soccer community cling to heading: that heading is too fundamental to the game to be abandoned. Indeed, the prospect of eliminating heading from the game at all levels seems a laughable non-starter through much of the soccer community, as if eliminating heading would not merely change the game, but instead destroy it. 29 History teaches us, however, that this need not be so. In fact, although heading is currently a significant aspect of soccer, in the sport’s early days, it was devoid of heading.

None of the original rules systems developed in the nineteenth century and which serve as soccer’s foundation even mention players using their heads.30 Nor do the International Football Association Board’s (IFAB) 7 Laws of the Game, which the IFAB has altered over the years, and which FIFA has adopted as the official rules of soccer.31 The rules’ lack of references to heading indicates heading was not a fundamental part of the game early on, and the practicalities of heading a soccer ball confirm it. Indeed, soccer balls of the late 1800’s and early 1900’s were heavy orbs “prone to becoming water-logged,” which when headed, “led to frequent head and neck injuries.32 By the mid-twentieth century, though soccer balls had become lighter, heading remained painful.33 Only since technological advances have produced increasingly light and bouncy balls has heading become a fundamental part of the game. Now that research reveals these light and bouncy balls to be, like the heavy balls of old, dangerous to brain health, heading should cease to be a fundamental part of the game.

Such an alteration would, of course, substantially disadvantage some styles of play, which is perhaps another reason that some resist the change. Tall, attacking players who operate more effectively with the ball in the air than at their feet would become less impactful and may eventually be phased out of the game. On the other hand, players who excel in a “tiki-taka” short passing style would become more sought after. For that matter, the balance of power among national soccer teams could shift, as nations with soccer cultures less reliant on technical ability and short passes would struggle to adjust to a game played principally on the ground.

Analysis of the manner in which heading-less soccer would shift the balance of power among players and nations, however, is beside the point. A well-placed head ball is certainly a beauty to behold, but romantic notions of heading’s role on a soccer pitch should not trump well-documented concerns for player health. Science teaches that repeatedly heading a soccer ball can damage the brain, at any age. Placing the act of heading above players’ health, and above the game of soccer itself, threatens to drive concerned players and concerned parents of players away from the game. The exodus from American football has begun, and the consequences on the game will bear out over the course of the coming years and decades. By acting now, the soccer establishment can avoid this fate. Soccer sans heading will still be soccer, just with healthier people playing it.


1G. Bunc et al., ‘May Heading in Soccer Result in Traumatic Brain Injury. A Review of Literature’, Medical Archives, vol. 71, no. 5, 2017, pp. 356-359., (last accessed 25 February 2019).

2Jeremy Wilson, ‘Why Won’t Football Follow Other Sports and Introduce Concussion Subs?’,, 18 June 2018, last accessed 1 September 2018,

3Michael Sokolove, ‘How One Lawyer’s Crusade Could Change Football Forever’,, 6 November 2014, last accessed 1 September 2018,

4See: In re Nat’l Football League Players’ Concussion Injury Litig., 307 F.R.D. 351, 361 (E.D. Pa. 2015), aff’d by 821 F.3d 410 (3d Cir. 2016); Associated Press, ‘NFL, Ex-Players Agree to $765M Settlement in Concussions Suit’,, 29 August 2013, last accessed 1 September 2018,

5Nat’l Football League Players’ Concussion Injury Litig. (2015), op. cit., p. 361.

6Ibid., p. 423.

7Ira Boudway and Eben Novy-Williams, ‘The NFL’s Very Profitable Existential Crisis’,, 13 September 2018, last accessed 16 January 2019,

8‘Ahead of Super Bowl, Nearly Three-in-Ten Americans Support Lifetime Ban for Football Players Convicted of Domestic Violence’,, 22 January 2015, last accessed 3 March 2019,

9Chelsea Howard, ‘Poll Shows Nearly 50 Percent of American Parents Don’t Want Their Children Playing Football’,, 3 February 2018, last accessed 1 September 2018,

10 N. Jeremi Duru, ‘In Search of the Final Head Ball’, Mo. L. Rev., vol. 83, no. 3, 2018, pp. 572-574.

11 For example, see: Jack Roger, ‘Traumatic Brain Injury and the NFL: A Study of the Confluences of Medicine, Ethics, and Social Mores in Professional Football’,, May 2017, last accessed 1 September 2018,

12 Peter Simpson, ‘Football must resist calls from scaremongers for heading ban after brain damage study’,, 20 July 2018, last accessed 25 February 2019,; Lindsey Barton Straus, ‘Heading in Youth Soccer: The Debate Continues’,, last accessed 25 February 2019,

13 Noah Davis, ‘What Happens When Soccer Bans Heading?’,, 25 April 2017, last accessed 25 February 2019,

14Mehr v. Féderation Internationale De Football Ass’n, 115 F. Supp. 3d 1035, 1062–63 (N.D. Cal. 2015); See also: Mike Woitalla, ‘Headgear Not Recommended in U.S. Soccer’s Concussion Prevention Campaign’,, 3 December 2015, last accessed 1 September 2018,

15Frank M. Webbe and Christine M. Salinas, ‘When Sciences and Politics Conflict: The Case of Soccer Heading in Adults and Children’, in Handbook of Sports Neuropsychology, F. Webbe (ed.), Springer Publishing Company, New York, 2001, pp. 275-294.

16Ibid., p. 282.

17Jessica Body, ‘With Concussion Risk in Soccer, Headers May Kick It Up a Notch’,, 1 February 2017, last accessed 1 September 2018,; Jeremy Wilson, ‘PFA Urges FA to Consider Ban on Heading for Children Under 10’,, 29 December 2016, last accessed 1 September 2018,; H. Ling et al., ‘Mixed pathologies including chronic traumatic encephalopathy account for dementia in retired association football (soccer) players’, Acta Neuropathologica, vol. 133, no. 3, pp. 337-352., (last accessed 25 February 2019).

18See: ‘Young Kids Should Stop Heading the Ball, Says Top Neurosurgeon’,, 25 October 2014, last accessed 1 September 2018,


20 Mehr, op. cit., pp. 1035, 1046.

21 Ben Strauss, ‘U.S. Soccer, Resolving Lawsuit, Will Limit Headers for Youth Players’,, 9 November 2015, last accessed 1 September 2018,

22 ‘U.S. Soccer Provides Additional Information About Upcoming Player Safety Campaign’,, 9 November 2015, last accessed 1 September 2018,

23 ‘UEFA launches research project into heading in youth football’,, 23 February 2018, last accessed 25 February 2019,

24 Ibid.

25 Ibid.

26 Ibid.

27 ‘The FA To Joint-Fund An Independent Research Study on Dementia For Ex-Footballers’,, 23 November 2017, last accessed 25 February 2019,

28 J. Wilson (2016), loc. cit.; Ben Rumsby, ‘Exclusive: Uefa Could Ban Heading in Youth Games’,, 27 January 2018, last accessed 1 September 2018,

29 Davis, loc. cit.; Paul Wilson, ‘Using Your Head: Why the Future of Football Should Still be Up in the Air’,, 11 November 2015, last accessed 16 January 2019,

30 See: ‘The Early Rules of Soccer’,, last accessed 1 September 2018, (listing the three main sets of rules in the nineteenth century that contributed to modern day soccer).

31 Webbe and Salinas, op. cit., pp. 277-278.

32 Davis, loc. cit.; ‘The History of the Soccer Ball’,, last accessed 1 September 2018,

33See: Webbe and Salinas, op. cit., pp. 282–283.

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About the Author

Jeremi Duru

Jeremi Duru

Professor of Law, Washington College of Law American University

Professor N. Jeremi Duru teaches sports law, civil procedure, and employment discrimination, and he is among the nation’s foremost sports law authorities. He is a co-author of one of the field’s premier casebooks, Sports Law and Regulation: Cases and Materials (4th edition) (Wolters Kluwer), as well as one of the field’s premier explorations of sports agency, The Business of Sports Agents (3rd edition) (U. of Penn Press). In addition, he is the sole author of Advancing the Ball: Race, Reformation, and the Quest for Equal Coaching Opportunity in the NFL (Oxford University Press), which examines the NFL’s movement toward increased equality of opportunity for coaches and front office personnel.

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