+++ UPDATE +++ Ban of lead in ammunition: EU stakeholders are now invited by ECHA to submit information – But is this a real consultation? Or are hunting and shooting under attack?

 +++ UPDATE +++ ECHA's "Questions and Answers"

ECHA released a document complementary to the webinar that was organised on 15 April 2021 to clarify aspects of the proposed restriction on lead in outdoor shooting and fishing. Presented in the form of “questions and answers”, the document “is intended to support respondents to the consultation on the proposal, which is open from 24 March 2021 until 24 September 2021and is based on the questions received from stakeholders before and during the webinar.

As we already pointed out, reading the ECHA answers the perception – something more than a perception, actually – is that this is already a done deal, regardless of EU citizens' opinion, reasoned objections and scientific data. But we leave you to judge.

You can download the document here.

The webinar of April 15, 2021

The European Chemicals Agency (ECHA) invited stakeholders to send in scientific and technical information on the use of lead in ammunition for hunting and sports shooting. A six-month consultation was launched on March 24, 2021 and the deadline is on September 24, 2021 – but only info submitted by May 5, 2021, will be able to be considered in the first meeting of RAC (Risk Assessment Committee) and SEAC (Socio-Econmic Analysis Committee).

An online information session on the proposed restriction (what we more aptly dub “lead ban”, for short) was held on April 15, 2021. During the webinar, ECHA’s experts explained the specific questions posed in the consultation and clarified how to submit comments. As all4shooters.com readers already know, ECHA has in fact already published its proposal to restrict the use of lead in ammunition for hunting and outdoor sports shooting as well as in fishing tackle. Basically they are now asking EU stakeholders to submit any information they consider relevant on the topics that RAC, SEAC or ECHA – as the dossier submitter – have identified. All information must be provided with supporting evidence, of course, and all comments and info must be submitted via the ECHA website at this link

In the video below, you can watch the full ECHA webinar and learn more about the consultation steps and the specific questions.

Video of the ECHA webinar on April 15, 2021: Consultation on the restriction proposal of lead in outdoor shooting and fishing tackle

A comment by Piergiorgio Molinari, all4shooters.com, on the ban of lead in ammunition and ECHA's 6 months consultation period

They want no lead ammunition in the EU
They want no lead ammunition in the EU. But the alternative materials for shot and bullets could be worse even for the environment and human health.

A public consultation about what ECHA calls “Sustainable outdoor shooting”: that's sound fine, very politically correct, and profoundly democratic. Unfortunately, it's not quite like that. The Q&A page, that was made available for an hour after the webinar, offers a glimpse of the critical issues of the consultation process and, above all, of the proposed restrictions. First of all, evidence, data and sources on which the EU's anti-lead crusade is based, are vague and controversial at best. They repeatedly state that “the proposal does not seek to stop hunting, shooting or fishing but to protect people and the environment”. Sure, lead is toxic. But no one asks, “At what quantities? Or in what particle sizes? Do people really ingest enough lead to endanger their health?”. And what's the evidence about lead exposure of sports shooters? We already addressed these issues on all4shooters.com. Suffice here to say that all the scientific studies proof, that there is no particular food pollution coming from lead used in hunting/fishing and evidence proves that metallic lead in ammunition does not have any significant effect on human health.

They also say that “135 million birds” are at risk of lead contamination every year, but they then admit that this is not real data – just a “reasonable assumption”. Which means that they are proposing an EU wide restriction of lead based on “guesstimates”. About the alternatives to lead in shotshells, ECHA proposed steel, bismuth and tungsten. But ricochet of steel pellets could be a potential source of severe injuries to athletes and hunters, while scientific studies show that tungsten is toxic to soil microbes and plants, and bismuth is a human toxicant.

Literally nobody is currently talking about a reasonable alternative to lead bullets in centerfire cartridges. The opposite is going on: ECHA also has copper and zinc on the watchlist of critical materials. Knowing that almost all lead free deformation bullets are based on copper. And then? Does this mean that after lead, sooner or later the EU will ban all these materials too? And what about the consequences of a lead ban on Olympic sports shooting, on hunting in general, and the costs for the ammunition industry as well as hunters and sport shooters? There are no clear answers – just “assumptions”. Or is there a clear, but hidden goal in the air: To come up with a total ban of sports shooting and hunting? We don’t know – we just “assume”.

Besides these and many more doubts, isn't it weird that ECHA is asking stakeholders for information on essential issues after drawing up a restriction proposal, instead than before drawing it? An anonymous webinar participant wrote, “This does not seem like an actual discussion. Your arguments are manipulated, lack sourcing, based on guesses ("estimates"), lacking hard facts. You actually don't ask for other opinions, you are already decided and all this charade is only to further restrict legal civilian weapon owners.” It sounds a bit rude. But there seems to be some truth in that.

All comments and info must be submitted via the ECHA website at this link. The public consultation deadline is on September 24, 2021.

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