ECHA’s Committee for Risk Assessment (RAC) supports restricting the use of lead in ammunition for hunting, outdoor sports shooting and in fishing. However, it recommends a shorter transition time to phase out lead gunshot in hunting. The Committee for Socio-economic Analysis (SEAC) is expected to agree its draft opinion in early June before finalising its opinion in December.
RAC has adopted its opinion on ECHA’s proposal to restrict the use of lead projectiles for hunting and outdoor sports shooting, as well as lead used in fishing sinkers and lures.
The committee considered that the use of lead in these activities poses a risk that is not adequately controlled. The proposal was considered appropriate for reducing risks of lead to people, to wildlife (especially birds) and to the environment.
In its opinion, the committee highlighted the following:
- The proposed restriction, with minor modifications, is an effective, practical and monitorable measure to address the risks.
- Shorter transition period for using lead gunshot for hunting: RAC considers that a five-year transition period to ban lead in gunshot for hunting, as proposed by ECHA, is not necessary. This takes into account that the use of lead gunshot in wetlands is already regulated in the EU. The shorter the transition period, the less lead that will be released into the environment.
- Labelling of ammunition and fishing sinkers containing lead and information to consumers at point of sale: RAC recommends that the need to label products and inform consumers of their risks should be triggered at a concentration threshold of 1 % weight by weight (w/w). This is the same threshold as for restricting the use and placing on the market of lead ammunition and fishing sinkers. Having the same concentration would ease enforcement of the restriction. ECHA originally proposed a threshold of 0.3 % w/w.
- Derogation for lead gunshot in sports shooting: RAC considers that enforcement of the restriction would be simplified if this derogation was not implemented. This is in line with ECHA’s preferred restriction option. 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).
During opinion making, RAC members analysed the available scientific studies on the risks of lead to wildlife (e.g. birds, scavenging or predatory animals), on livestock and the environment (water, soil). They also assessed the health risks of eating game meat hunted with lead ammunition, for example, by evaluating the reliability and representativeness of data provided by the European Food Safety Authority (EFSA). The latter data presented some uncertainties but was still considered robust enough to demonstrate risks to vulnerable populations like children and pregnant women. Lead is harmful to children’s neurological development – even in the smallest quantities.
Following the normal process, ECHA has also updated its initial proposal to reflect the input received during the six-month consultation that ended on 24 September 2021. The key updates are explained in the Q&A document. The updated proposal, called a background document, will be available soon.
Before adopting its opinion, RAC held five plenary and five preparatory working group meetings over 15 months. The following organisations took part in these meetings as stakeholder observers: The European Chemical Industry Council (Cefic), ClientEarth, European Anglers Alliance (EEA), European Environmental Bureau (EEB), European non-ferrous metals association (Eurometaux), European Federation for Hunting and Conservation (FACE) and Fédération Internationale de Tir aux Armes Sportives de Chasse (FITASC)/International Shooting Sport Federation (ISSF) and their experts. The Secretariat of the Agreement on the Conservation of African-Eurasian Migratory Waterbirds (UNEP-AEWA) was present at the request of RAC’s secretariat.
SEAC is expected to agree its draft opinion in early June. A 60-day consultation on SEAC’s draft opinion will start soon after. The opinions of both committees are expected to be ready by the end of 2022. They will be sent to the European Commission at the start of 2023. The decisions on REACH restrictions are taken in the European Commission by the EU countries and scrutinised by the Council and the European Parliament.
In February 2021, ECHA made a proposal for EU-wide restrictions on the use of lead in ammunition for hunting and outdoor sports shooting, as well as in fishing. ECHA estimates that at least 135 million birds are currently at risk of lead poisoning each year from ingesting spent lead gunshot. Additionally, 14 million birds are at risk from eating animals shot with lead ammunition and 7 million from ingesting lead fishing tackle.
Spent lead ammunition from sports shooting can contaminate soil and water in and around the range. People are directly exposed to lead, for example, through eating game meat hunted with lead ammunition.
If adopted, the restriction could reduce lead emissions by 72 % compared to a situation without a restriction. This would prevent the poisoning of wildlife, including many endangered species, and reduce exposure of 1.1 million children as well as pregnant women.
The restriction proposal was developed at the request of the European Commission. A potential regulation on lead in these activities is in line with the EU’s Green Deal, its Chemicals Strategy for Sustainability and the action plan on Zero Pollution for water, air and soil.
Military uses of lead ammunition, along with other non-civilian uses of lead ammunition such as by police, security and customs forces, are outside of the scope of the restriction proposal. Indoor uses of lead ammunition are also excluded.