ECHA’s Risk Assessment Committee (RAC) supports the restriction for the use of lead in ammunition for hunting, outdoor sport shooting and fishing. However, it recommends a shorter transition period for phasing out lead gunshot in hunting. The Socioeconomic Analysis Committee (SEAC) approved its draft opinion in early June and is expected to finalize it in December.


In February 2021, ECHA submitted a proposal for an EU-wide restriction on the use of lead in ammunition for hunting and outdoor sport shooting, as well as for fishing, given the worrying data on the impact on wildlife, the environment, and human health (particularly to the most fragile and exposed individuals, such as children and pregnant women).

Military uses of lead ammunition, along with other non-civilian uses of lead ammunition such as police, security, and customs, are outside the scope of the proposed restriction, as well as indoor uses.

RAC Opinion

The favorable opinion adopted by the RAC can be accessed at this link; however, the RAC made the following changes:

  • 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).

Following the normal process, ECHA also updated its initial proposal to reflect input received during the six-month consultation that ended on September 24, 2021. The main updates are outlined in the Q&A document. The updated proposal will be available soon. To keep updated consult the ECHA webpage related to this hot topic, where all the news are reported.

What will be the next step?

A 60-day consultation on the draft opinion has begun immediately after SEAC approval, on June 2, 2022. Opinions from both committees should be ready by the end of 2022.

They will then be sent to the European Commission in early 2023 for the final decision.

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