RAC Backs Lead Restriction in Outdoor Shooting and Fishing

ECHA’s Committee for Risk Assessment (RAC) has expressed its support for restricting the use of lead in ammunition for hunting, outdoor sports shooting, and fishing by adopting its opinion on ECHA’s proposal to restrict the use of lead for relevant activities. The use of lead in these situations is reckoned as posing non-adequately controlled threats to people, wildlife, and the environment, especially for birds.

Once adopted, this restriction would reduce lead emissions by 72% compared to previously non-restricted situations, preventing the poisoning of wildlife, including many endangered species, and reducing exposure to vulnerable population groups.

The restriction proposal was developed at the request of the European Commission, in line with the EU’s Green Deal, its Chemicals Strategy for Sustainability, and the Zero Pollution Action Plan for water, air, and soil. However, military uses of lead ammunition and other non-civilian uses of lead ammunition such as by police, security and customs forces, are still beyond the scope of the restriction proposal as well as indoor uses of lead ammunition.

Despite RAC’s consent to the ECHA proposal, it nevertheless recommended a shorter transition time to phase out lead gunshots in hunting. The highlights of the Committee are listed below:

• The proposed restriction is effective, practical, and monitorable as a measure to address the risks without many modifications.
• A five-year transition period to phase out lead in gunshot for hunting as initially proposed is not necessary, seeing as the use of lead gunshot in wetlands is already regulated in the EU; the shorter the transition period means the less lead that would possibly be released into the environment.
• Labelling of ammunition and fishing sinkers containing lead and information to consumers at the point of sale is recommended, and the need to label products and inform consumers of products’ risks should be triggered at a concentration threshold of 1% (weight by weight), which is the same threshold as restricting the use and placing on the market of lead ammunition and fishing sinkers, which is different from what ECHA originally proposed (a threshold of 0.3% w/w);
• Abolishment of derogation for a lead gunshot in sports shooting is considered for the convenience of easier enforcement of the restriction, which is in line with ECHA’s preferred restriction option; in the case where the decision-maker deems this derogation needed, it is RAC’s suggestion to limit shot sizes used in sports shooting (between 1.9 and 2.6 mm).

RAC did the assessment by evaluating the reliability and representativeness of data provided by the European Food Safety Authority (EFSA) and the available scientific studies on the relevant risks. This assessment was done during opinion-making, where the former data presented somehow robustly demonstrated risks to vulnerable populations like children and pregnant women, especially to the children’s neurological development.

ECHA has also updated its initial proposal, where the key updates are explained in the Q&A document, and this updated proposal as a background document shall be available soon. The Committee for Socio-economic Analysis (SEAC) is expected to agree to the draft opinion in early June, where a 60-day consultation on SEAC’s draft opinion will soon start afterwards and it will be finalized in December.

The opinions of both committees are expected to be ready by the end of 2022, which will then be sent to the European Commission at the start of 2023, and at last, the decisions on REACH restrictions are taken by the European Commission along with the EU countries, scrutinized by the Council and the European Parliament.

You can also read about the EU's proposal to restrict lead and lead compounds in PVCs here.