EU, ECHA and restrictions on lead: a serious issue for industry and society – not just for hunters and shooters using lead ammunition. We’ll tell you why and what to do

The fight on lead in ammo goes on, with the European Union campaigning through the European Chemicals Agency (ECHA) for a total “lead ban”. In an article published on the Euractiv website, the European Shooting Sports Forum (ESSF) describes their latest moves. ECHA in fact recently included lead metal in its draft recommendation for REACH (Registration, Evaluation, Authorization and restriction of Chemicals) authorization – a process designed to facilitate the substitution of “Substances of Very High Concern” and ultimately establish an end date for its current use. On 2 February 2022, a 90-day public consultation period began in order to gather feedback on ECHA’s draft recommendation and on the possible socio-economic fallout of subjecting lead metal to the REACH authorization requirement.

What's the problem with the ban of lead in ammunition?

ESSF explains: “Including lead in the REACH Authorization list, as proposed by the European Chemicals Agency (ECHA), would negatively impact many strategic sectors and successful value chains in Europe, including the European ammunition industry and its related businesses. The consequences for industry and society would be significant and, as you will see, potential impacts to environment and human health will not be controlled.”

Ban of lead - a problem for industry and society

Serious consequences for industry and society
Including lead in the REACH Authorization list would impact a broad range of important sectors, with serious consequences for industry and society. (Image: ESSF).

It's not just a problem for hunters and shooters, or the ammo/firearms industry (see here our article on the consequences for ammo and firearms manufacturers): “If adopted, the authorization process would impact a broad range of important sectors. In fact, a wide variety of products and processes rely on lead metal, which is used anywhere from batteries to aerospace manufacturing and healthcare, from the recycling of valuable metals to high-speed machining and renewable energy technologies. These industries are essential to society, the economy, and the fulfilment of EU policy objectives, including the European Industrial Strategy, the European Green Deal, and the EU’s Circular Economy Action Plan.”

But the old saying "trouble shared is trouble halved" does not apply here. As we at already reported, if a near-total ban on lead ammunition becomes a reality it is estimated that 1 of 4 hunters will stop hunting entirely, and at least 30% to hunt less frequently. The economic loss to EU 27 because of the ceased and reduced hunting activity would be at least 5.7 billion Euros.

Moreover, in terms of the ECHA’s recommendation, “this new regulatory development seems to be neither proportionate, nor at all effective if its aim is to reduce the risks to human health and the environment considering the work of the parallel “Restriction” procedure on lead in ammunition and existing rules.” 

As a side note, most lead emissions in the EU are caused by activities which are not even within the scope of the REACH Authorization for lead, e.g., from thermal power stations, pig iron, steel production, and waste management, and in any case even for the very few uses where lead exposure or emissions may pose a risk to human health and the environment, restrictive measures are already in place or being actively reviewed. 

As we have been stressing over and over again, public health and environment have very little, if any, to do with what actually is an ideological crusade against hunters, shooters, and ultimately all legal gun owners across EU. As ESSF concludes, “the REACH authorization procedure seems, in this specific case, to be an example of a regulatory action that could deliver very few additional benefits in a proportionate way. Rather, it would create a good deal of uncertainty for many economic sectors, whilst reducing investment and competitiveness in Europe, thereby potentially opening the door to non-EU competitors including from Russia and China. This move also comes at a time when there is a different mindset towards European security where ammunition will be in greater demand outside of hunting and sports shooting uses.” 

It must be said, however, that lately this regime of “authorizations” and “restrictions” in every sphere of people's life seems to be the prevailing pattern of thought and action within the EU institutions. Especially when it comes to make European citizens bear the costs of questionable ideological choices. 

And three most relevant aspects are totally neglected by ECHA and the EU commission: 

  1. There is no better alternative to lead in ammunition
  2. For many uses such as sport shooting there is no alternative at all (rimfire ammo and airgun pellets)
  3. Copper – used currently as lead-free alternative for hunting cartridges – is already on the “watchlist” of ECHA

What can you do? Tell ECHA why lead should not be forbidden. No matter if you are a private person or from a company / organization:

We kindly ask you to participate in the current consultation for lead metal, which will run until May 2, 2022. You can give comments on the draft recommendation of lead metal for inclusion in Annex XIV. Please continue to support us in making the use of lead metal possible without authorisation at ECHA.

ECHA prioritises the substances on the Candidate List to determine which substances should be included in the Authorisation List (Annex XIV of REACH) and thus be subject to authorisation. ECHA regularly adopts recommendations for the European Commission, which ultimately decides on the inclusion of substances in the list of substances subject to authorisation.

Comments on the draft recommendation can be submitted within three months of the publication date. In our current case until May 2, 2022. The Member State Committee formulates its opinion on the draft recommendation, taking into account the comments received. The opinion of the Committee and the comments received during the public consultation will help ECHA to adopt a final recommendation to the European Commission to decide on the substances to be included in the list of substances subject to authorisation.

Link for your comments to ECHA in the public consultation on the ban of lead in ammunition:

This article is also available in this language: