Placing on the market and use of lead in projectiles (for firearms and airguns), and in fishing sinkers and lures for outdoor activities. Outdoor activities include hunting, sports shooting, other outdoor shooting and fishing. Military uses of lead projectiles, along with other uses such as by police, security and customs forces, are outside the scope of the restriction proposal. Indoor uses of lead projectiles are also excluded from the scope of the restriction proposal.
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Alternatives to lead for rim calibres: As indicated in the Annex XV report, there is contradictory information on the accuracy of lead-free ammunition for rim calibres (such as .17 HMR, .22 LR, etc) for hunting. In some studies, lead-free ammunition for these calibres is claimed to be sufficiently accurate while in other studies it is disputed. Please provide information on the accuracy of lead-free ammunition for these calibres in the form of tests, field reports, or similar, as well as information on the development of lead-free alternatives for this type of ammunition in the future.
* Compulsory Fields
Alternatives to lead for certain types of hunting: The Annex XV report indicates that the suitability of lead-free ammunition for small game hunting with Full Metal Jacket bullets and for the population management of seals (where this is allowed) should be further explored in the consultation.
For the population management of seals, please provide information that helps ECHA’s Committees to better understand in how many EEA countries this takes place and whether lead-free alternatives are available and their technical performance/suitability for this type of hunting.
Distinction between large and small calibres: The current cut off between large and small calibres (5.6 mm) is based on a cut off for hunting roe deer found in hunting legislations throughout Europe. The smallest tested alternatives are in the calibre range of .222 and .223 (5.55 mm). Does the proposed cut off between small and large calibres adequately reflect the differences in the suitability and availability of alternatives?
Use of shooting ranges/areas for agricultural purposes:
Measures to limit releases to the environment at trap and/or skeet ranges:
Measures to limit releases to the environment at outdoor rifle/pistol ranges:
Measures to limit exposure of shooters:
Remediation of shooting ranges/areas:
Substitution of lead ammunition in outdoor sports shooting:
Home-casting of lead fishing sinkers and lures: The Dossier Submitter assumes that home-casting is a popular activity among fishers. Furthermore, it is assumed that if a restriction only applied to the placing on the market but not to the use of lead fishing tackle, home-casting would become more popular. Please provide any supporting information that would allow ECHA’s Committees to evaluate these assumptions, such as information on the proportion of fishers making their own lead fishing sinkers and lures or information on the proportion of home-cast lead fishing sinkers and lures compared to purchased ones.
Alternatives to lead in fishing tackle: Please provide information and supporting evidence on the availability of lead-free alternatives for the different types of lead fishing tackle (i.e. sinkers and lures ≤ 50 g and > 50 g, as well as lead wires). If no alternatives exist, please explain what analysis this conclusion is based on.
Impacts of the proposed restriction: The Annex XV report proposes a concentration limit of 1% w/w for placing on the market and use, as well as different transition periods for different types of hunting (gunshot / small calibre bullets / large calibre bullets), sports shooting (gunshot / bullets) and fishing tackle (lead wires and ‘intentional release weights’ / sinkers and lures ≤ 50 g / sinkers and lures > 50 g). Please provide information on the impacts of the proposed restriction (costs and benefits to society, including industry and SMEs) and consider how these impacts would vary dependent on the concentration limit and the duration of the proposed transition periods. Please refer to Annex XVI of REACH for an overview of the elements that should be included in an impact assessment.
Monitoring of environmental exposure: Please provide information on any organisations in Europe regularly monitoring the impacts related to the exposure of wildlife to lead ammunition and lead fishing tackle.
Voluntary military training: The Annex XV report describes the practice of ‘voluntary military training’ that is reported to take place in some EEA countries. Please provide further information on this practice including a justification for why lead ammunition is required and why a specific derogation for this activity is needed beyond the existing proposed scope and derogations.
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