ECHA’s efforts to reduce lead exposure from outdoor shooting and fishing.
ECHA’s Committees for Socio-Economic Analysis and Risk Assessment support the proposed restriction on the use of lead in ammunition for hunting, outdoor sports shooting and in fishing. The restriction could prevent over 600 000 tonnes of lead from being released into the environment, save millions of birds from lead poisoning and protect children in hunter families.
In June 2022, the Committee for Socio-Economic Analysis (SEAC) and the Committee for Risk Assessment (RAC) both adopted their final opinions on a proposed restriction which would cover the use of lead projectiles for hunting and outdoor sports shooting, as well as lead used in fishing sinkers and lures.
The RAC concluded that the use of lead in these activities poses risks to wildlife, people, and the environment that are not adequately controlled and that a restriction under the REACH Regulation is the most appropriate EU-wide measure to address these risks. The SEAC agreed with this conclusion and added that the proposed restriction can be considered proportionate after evaluating the costs and benefits to society. It also highlighted that some of the benefits were not quantified but are likely to be significant – for example, the benefits of avoiding the poisoning of predatory birds.
The final opinion of the Committee for Socio-Economic Analysis (SEAC) on the proposed restriction of lead projectiles for hunting and outdoor sports shooting, as well as lead used in fishing sinkers and lures has been adopted. In June 2022, the opinion of the Committee for Risk Assessment (RAC) was also adopted on the same proposal. It is considered that risks to wildlife, people, and the environment from these activities are not adequately controlled and that a restriction under the REACH Regulation would be the most appropriate EU-wide measure to address these risks. SEAC has concluded that after evaluating the costs and benefits to society, the proposed restriction can be considered proportionate. Additionally, some of the benefits that were not quantified are likely to be significant—for example, avoiding poisoning of predatory birds.
The Chair of SEAC, María Ottati, stated that they have examined the implications of the proposed restriction from multiple perspectives, not just the potential costs for shooters and fishers. They have analyzed whether hunting as an activity will be impacted in the long term and believe there will be no decline. Additionally, they have considered the availability of shooting ranges for military training, the supply of lead ammunition for non-civilian use, and the economic impacts of installing lead containment measures at shooting ranges. Based on the available information, Ottati believes that the proposed restriction is appropriate and proportionate to addressing the risks involved.
The RAC has also released a supplementary opinion on the risks to human health from lead in game meat. This opinion is based on an evaluation of comments and evidence submitted by the public to the ECHA during a consultation period from July to October 2022. The consultation focused on data from the European Food Safety Authority (EFSA) that was used in the risk assessment underpinning the proposal. The RAC’s supplementary opinion confirms the conclusions of the original opinion.
“We have thoroughly looked at EFSA’s data again and all the consultation input, and we believe there is a moderate to high risk from eating lead-contaminated game meat for children in hunter families. The risks for adults are likely to be low. Overall, RAC supports a transition to more sustainable outdoor shooting and fishing to protect the environment and people’s health,” says Tim Bowmer, Chair of RAC.
Both committees have recommended modifying the proposed restriction, suggesting a shorter transition period for lead gunshot in hunting, for example. The main recommendations of the committees are available in the Q&A. The combined RAC and SEAC opinion and the RAC’s supplementary opinion will be published in early 2023.
Once ECHA receives SEAC’s opinion and RAC’s supplementary opinion, they will send both opinions and the proposed restriction to the European Commission. This will occur in early 2023. The Commission will then decide if a restriction is necessary. If so, they will make a proposal to amend the list of restrictions (Annex XVII to the REACH Regulation). The proposal will be voted on by the EU Member States in the REACH Committee and scrutinised by the European Parliament and Council before being adopted into law.
At the request of the Commission, ECHA has proposed a European-wide restriction on the use of lead in outdoor shooting and fishing. The proposed restriction would phase out the use of most types of lead ammunition for hunting and sports shooting, as well as lead sinkers and lures for fishing, over a period of up to five years. However, the proposal allows for the continued use of lead ammunition for outdoor sports shooting with rifles and pistols where risks are appropriately managed.
If adopted, this restriction is estimated to reduce lead emissions to the environment by 630 000 tonnes over 20 years – a 72% reduction compared to if no such restriction was in place. This would prevent wildlife poisoning – including many endangered species – as well as exposure to lead among children and pregnant women in hunter families.
An regulation on lead in military activities would be consistent with the EU’s Green Deal, its Chemicals Strategy for Sustainability, and the Biodiversity 2030 Strategy. This would expand an existing restriction on lead ammunition in wetlands to include other non-civilian uses, such as by police, security, and customs forces. Indoor uses of lead ammunition would still be excluded.
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