Below is the translation of an article recently published on Euractiv - the pan-European media network specializing in European Union policies - signed by the European Shooting Sports Forum (ESSF), of which ANPAM is a member through IEACS and holds its secretariat. The article deals with the REACH authorization procedure for metallic lead proposed by THROW and the impact this would have on the European industry in general, and the ammunition industry in particular. The inclusion of metallic lead in the REACH authorization list, as proposed by the European Chemicals Agency (ECHA), would have a negative impact on many strategic sectors and successful value chains in Europe, including the European chemicals industry. ammunition and related activities.
The consequences for industry and society would be significant and, as you will see, the potential impacts on the environment and human health would not be controlled. ECHA recently included lead in its draft Recommendation for the Authorization of REACH, a process established to facilitate the substitution of Substances of Very High Concern and to set a deadline for its current use. A 2-day public consultation period began on 2022 February 90 to gather feedback on ECHA's proposal for a recommendation and on the possible socio-economic implications of a possible subjection of metallic lead to the REACH authorization requirement. If adopted, the authorization process would impact a wide range of sectors. In fact, a wide variety of products and processes rely on metallic lead, which is used in everything from batteries to aerospace and healthcare manufacturing, from precious metal recycling to high-speed processing and renewable energy technologies.
These industries are essential for society, the economy and the achievement of EU policy goals, including the European Industrial Strategy, the European Green Deal and the EU Action Plan for the Circular Economy. Although lead in the ammunition industry accounts for only 4% of the total lead consumption in the EU, its inclusion in the permit list would have repercussions not only for the ammunition industry and its related activities, but also for the ammunition users (eg hunters and sport shooters), who are already facing a near-total ban on lead-based ammunition, as proposed in another ECHA 'restriction' procedure. A recent study showed that 1 in 4 hunters will completely stop hunting if the near-total ban on lead-based ammunition becomes a reality, and at least 30% of them will hunt less frequently.
Furthermore, there would be a serious economic loss of at least 5,7 billion euros due to the reduced hunting activity. According to ECHA's recommendation, this new regulatory development appears to be neither proportionate nor fully effective in reducing the risks to human health and the environment considering the work of the parallel procedure of "restriction" on lead in ammunition and existing rules . In fact, the EU already has a specific regulatory framework for lead designed to manage these potential risks. The industrial production, use and recycling of lead is carried out safely, under highly regulated conditions intended to reduce exposure, protect workers and control environmental emissions in facilities that operate under strict regulatory requirements and best practices at industry level.
In confirmation, emissions from industrial uses of lead in the EU have decreased in the recent past: air pollution from lead decreased by 88% and emissions to water decreased by 80% between 2007 and 2020. Most lead emissions in the EU are currently caused by activities outside the scope of the REACH authorization for metallic lead, such as thermal power plants, cast iron, steelmaking and waste management. The issue of waste management deserves particular attention, as lead plays a fundamental role in reducing environmental impacts. Even for the very few uses where lead exposure or emissions may pose a risk to human health and the environment, there are restrictive measures already in place or are under active review.
These include the current REACH regulation on the use of lead shot in wetlands, or the recent proposed "restriction" on lead in ammunition (and fishing gear), which would be more appropriate to assess and potentially reduce emissions. of lead compared to an inclusion of metallic lead in the list of substances subject to authorization. In conclusion, the REACH authorization procedure appears, in this specific case, to be an example of regulatory action that could bring very few new benefits in a proportionate way. Rather, it would create a good deal of uncertainty for many economic sectors, while reducing investment and competitiveness in Europe and potentially opening the door to non-EU competitors, such as Russia and China. Furthermore, this initiative comes at a time when there is a different mindset towards European security, where ammunition will be more in demand outside of hunting and sport shooting uses. Furthermore, for the ammunition sector, the inclusion of metallic lead in Annex XIV of REACH would result in an unjustified double regulation regime of “authorization” and “restriction”, raising many questions on the common thinking of the EU institutions.
Furthermore, it is sufficient to consider that ammunition is considered an "article" under the REACH Regulation and that the authorization schemes do not apply to substances contained in articles. This actually allows it to be placed on the market in the European Union (coming from non-EU markets), but not for its production in the EEA. This means that, in the case of lead ammunition, it would continue to pose health and environmental risks as it could still be used, while EEA manufacturers would be disadvantaged because their products would be subject to stricter requirements than goods from from other parts.
What is the European Shooting Sports Forum (ESSF)
The European Shooting Sports Forum (ESSF) is an informal platform where representatives of international bodies active at European level in the fields of sport shooting, hunting, firearms collection, trade and industry maintain an open dialogue on issues of common interest, in particular environmental, legal, political and socio-economic aspects of such activities.
The ESSF is composed of the Association Européenne de Commerce d'Armes civiles (AECAC), the Association des Fabricants européens de Munitions de Sport (AFEMS), the European Shooting Sports Council (ESSC), the Association of European Manufacturers of Sporting Firearms (ESFAM ), the Federation of Associations for Hunting and Conservation of the EU (FACE), the Foundation for European Societies of Arms Collectors (FESAC) and the Institut Européen des Armes de Chasse et de Sport (IEACS). These sectors employ more than 600.000 people in Europe for an annual turnover of around 40 billion euros, if we include the revenues generated by hunting and shooting activities. Overall, 14.000 retailers, 300.000 collectors and over 10 million hunters and sport shooters in Europe are represented by the ESSF.