As you should already know (read our article here), the European Chemicals Agency (ECHA) through its scientific Committees for Socio-Economic Analysis (SEAC) and Risk Assessment (RAC) is pushing forward its proposal to ban lead use for ammunition in hunting and sports shooting – oh, and don't forget: in fishing tackle too (!) – under the pretext of the “environmental risks” to wildlife and livestock resulting from the use of lead. All this in full disregard of scientific evidence, solid objections and reality as a whole. The above mentioned ECHA committees sent their technical advice to the European Commission for scrutiny and to allow the REACH Committee to start its drafting activity over the legislative proposal to restrict the use and placing on the market of lead ammunition in outdoor activities.
AFEMS: useful proposals for the use of lead in ammunition to ECHA and EU-Commission
Thanks to the lobbying activities of organizations such as AFEMS (the Association of European Manufacturers of Sporting Ammunition) some changes were made in the anticipated final proposals from ECHA . These changes include:
- Better requirements for non-shotshell ammunition for sports shooting: use can continue if releases of lead to the environment are minimized within a five-year transition period. This means that sports shooting ranges are equipped either with trap chambers or “best practice” sand traps. The 90% recovery rate is ruled out.
- Better provisions for labelling requirements: Committees recommend that the concentration threshold of 1 % weight by weight (w/w) that is used for restricting the use and placing on the market of lead ammunition should also apply to the labelling and information requirements. ECHA originally proposed a threshold of 0.3 % w/w as a trigger for the labelling obligation. RAC and SEAC also consider that a derogation allowing the use of copper or copper alloys containing lead up to 3 % in bullets is implemented.
- Expanded derogations for hunting: permanent derogation foreseen for fully jacketed bullets and open tipped ones. Seal hunting with lead ammunition will be derogated, where it is permitted.
Ban of lead in ammunition: more bad news to expect in the near future?
Unfortunately, there are now also worse provisions for the derogation for lead gun-shot in sports shooting: RAC considers that enforcement of the restriction would be simplified if this derogation was not implemented. However, if the decision maker decides that this derogation is needed, RAC suggests that it should be limited to shot sizes used in sports shooting (between 1.9 and 2.6 mm).
As AFEMS points out, you should remember that the proposal coming out of ECHA can be modified in many aspects by the European Commission. Which is not reassuring, if you consider the gross incompetence and ideological bias already shown by the Commission in the recent past.
Anyway, AFEMS also says that we can expect that the timeline will be influenced by the growing concerns related to the supply of military production and the upcoming political election in the European Union in Q2 2024. While a worst-case scenario could mean the restriction would be adopted by Q4 2023, a longer delay can be forecasted in case of extensive political discussions.
What ECHA and all the EU institutions are not taking in account, however, is the crazy situation this kind of restriction would lead to, and the total different interpretations and consequences country by country. It's not clear how the different EU countries, with different laws, contexts and traditions, could implement the restrictions in such a short time, even without taking into account the effects on the ammo and gun industry. But do you remember the foolish story of recently announced ban on the sale of new petrol and diesel cars in the European Union from 2035? The script is always the same: ideological poisoning, murky interests, sheer incompetence, and complete disregard for the ordinary citizen's interest.