On 21 June 2017, the European Chemicals Agency (ECHA) launched the 1st public consultation1 on the proposed restriction on lead and its compounds in gunshot under the REACH Annex XVII. The scope of this proposed restriction is limited to the shot used in wetlands.
Waterbirds, including waterfowl (e.g. ducks, geese and swans), are known to ingest the ‘spent’ lead gunshot through hunting and sports shooting. Further to direct ingestion, secondary poisoning may be caused by eating contaminated waterbirds that have lead gunshot embedded in their tissues or digestive tract. The ingestion of lead gunshot by waterbirds leads to a range of acute and chronic toxicological effects, including death. Taking risk into account in the use of lead gunshot in EU wetlands, the European Commission (EC) requested the ECHA to prepare a dossier2, to propose a restriction on lead in shot under the REACH Annex XVII.
All interested parties can comment on the proposal using the ECHA website until the end of the consultation period on 21 December 2017, but comments that are received by 21 August 2017 will assist in the first discussion of the ECHA committees on the proposal. Please refer to the Table 1 for the details of the proposed restriction.
Table 1. Proposed restriction on lead in shot
Proposed scope of restriction
Gunshot for shooting with a shot gun within a wetland or where spent gunshot would land within a wetland
Lead and lead compounds shall not be used in gunshot for shooting with a shot gun within a wetland or where spent gunshot would land within a wetland.
Lead shotgun (i.e. any gunshot made of lead, or any alloy or compound of lead with lead comprising more than 1% of that alloy or compound) shall not be in the possession of persons in wetlands.
“shot gun” means a smooth-bore gun;
“gunshot” means pellets used in quantity in a single charge or cartridge in a shotgun;
“wetlands” are defined according to Article 1(1) of the Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar Convention) as: “areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres”.