ECHA’s new regulatory development on lead

Author: European Shooting Sports Forum (ESSF)

Including lead in the REACH Authorisation list, as proposed by the European Chemicals Agency (ECHA), would negatively impact many strategic sectors and successful value chains in Europe, including the European ammunition industry and its related businesses. The consequences for industry and society would be significant and, as you will see, potential impacts to environment and human health will not be controlled.

ECHA recently included lead metal in its draft recommendation for REACH authorisation – a process designed to facilitate the substitution of Substances of Very High Concern and ultimately establish an end date for its current use. On 2 February 2022, a 90-day public consultation period began in order to gather feedback on ECHA’s draft recommendation and on the possible socio-economic fallout of subjecting lead metal to the REACH authorisation requirement.

If adopted, the authorisation process would impact a broad range of important sectors. In fact, a wide variety of products and processes rely on lead metal, which is used anywhere from batteries to aerospace manufacturing and healthcare, from the recycling of valuable metals to high-speed machining and renewable energy technologies. These industries are essential to society, the economy, and the fulfilment of EU policy objectives, including the European Industrial Strategy, the European Green Deal, and the EU’s Circular Economy Action Plan.

Although lead in the ammunition industry represents only 4% of the total lead usage in the EU, the authorisation listing would have negative consequences not only for the ammunition industry and its related businesses, but also to the users of ammunition (e.g. hunters and sport shooters), which are already facing a near-total ban on lead ammunition as proposed in another “Restriction” procedure within ECHA. A recent study has shown that 1 in 4 hunters will stop hunting completely if a near-total ban on lead ammunition becomes a reality and at least 30% will hunt less frequently. Further, there would be a major economic loss of at least €5.7 billion because of reduced hunting activity.

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