Lead ban

Grizzly 45

And fixed!:)

Grizzly 45

Apprently while we have been distracted by the COVID drama,this has still been ongoing and via webinars of our dear leaders in brussels. So third reading the countries that support the new lead ban proposals are
According to the recent webinar, the countries supporting the lead ban are:

- Portugal
- Greece
- Romania
- Belgium
- France
- Sweden
- Austria
- Slovenia
- Italy
- Denmark
- Spain

This is the new annex document.Recommend stratgedy is to get our and other MEPs to abstain from voting on this . But this needs to be done in Brussels on the QT. So this is now in FACE domain ,but please keep your local shooting reps on their toes about this pressure.




In Annex XVII to Regulation (EC) No 1907/2006, in entry 63, the following paragraphs are added in the second column:

‘[20]. Doing either of the following acts after [Publications office - please fill in the date that is 24 months from date of entry into force of this amending Regulation] in or within 100 metres of wetlands is prohibited:
(a) discharging gunshot containing a concentration of lead (expressed as metal) equal to or greater than 1% by weight;
(b) carrying any such gunshot where this occurs while out wetland shooting or as part of going wetland shooting.
For the purposes of the first subparagraph:
(a) ‘within 100 metres of wetlands’ means within 100 metres outward from any outer boundary point of a wetland;
(b) ‘wetland shooting’ means shooting in or within 100 metres of wetlands;
(c) if a person is found carrying gunshot in or within 100 metres of wetlands while out shooting or as part of going shooting, the shooting concerned shall be presumed to be wetland shooting unless that person can demonstrate that it was some other type of shooting.
The restriction laid down in the first subparagraph shall not apply in a Member State if that Member State notifies the Commission in accordance with paragraph [21] that it intends to make use of the option granted by that paragraph.
[21]. If at least 20 % in total of the territory, excluding the territorial waters, of a Member State are wetlands, that Member State may, in place of the restriction laid down in the first subparagraph of paragraph [20], prohibit the following acts throughout the whole of its territory from [Publications office - please fill in the date that is 36 months from entry into force of this amending Regulation]:
(a) the placing on the market of gunshot containing a concentration of lead (expressed as metal) equal to or greater than 1% by weight;
(b) the discharging of any such gunshot;
(c) carrying any such gunshot while out shooting or as part of going shooting.
Any Member State intending to make use of the option granted by the first subparagraph shall notify the Commission of this intention by [Publications office - please fill in the date that is 6 months from entry into force of this amending Regulation]. The Member State shall communicate the text of the national measures adopted by it to the Commission without delay and in any event by [Publications office - please fill in the date that is 30 months from entry into force of this amending Regulation]. The Commission shall make publicly available without delay any such notices of intention and texts of national measures received by it.
[22]. For the purposes of paragraphs [20] and [21]:
(a) “wetlands” means 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;
(b) “gunshot” means pellets used or intended for use in a single charge or cartridge in a shotgun;
(c) “shotgun” means a smooth-bore gun, excluding airguns;
(d) “shooting” means any shooting with a shotgun;
(e) “carrying” means any carrying on the person or carrying or transporting by any other means;
(f) in determining whether a person found with gunshot is carrying gunshot “as part of going shooting”:
(i) regard shall be had to all the circumstances of the case;
(ii) the person found with the gunshot need not necessarily be the same person as the person shooting.’.
[23]. Member States may maintain national provisions for protection of the environment or human health in force on [Publications office - please fill in the date of entry into force of this amending Regulation] and restricting the use of lead gunshot more severely than provided for in paragraph [20].
The Member State shall communicate the text of those national provisions to the Commission without delay. The Commission shall make publicly available without delay any such texts of national provisions received by it.

LONG READ AHEAD


amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards lead in gunshot in or around wetlands
(Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC , and in particular Article 68(1) thereof,
Whereas:
(1) Annex XVII to Regulation (EC) No 1907/2006 lays down restrictions on the manufacture, placing on the market and use of certain dangerous substances, mixtures and articles. Entry 63 of that Annex contains restrictions with respect to lead (CAS No 7439-92-1, EC No 231-100-4) and lead compounds.
(2) The Union and 23 Member States are Contracting Parties to the Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA). Contracting Parties are required under paragraph 4.1.4 of the Action Plan annexed to AEWA to endeavour to phase out the use of lead shot for hunting in wetlands as soon as possible in accordance with self-imposed and published timetables.
(3) Article 4(2) of Directive 2009/147/EC of the European Parliament and of the Council requires Member States to pay particular attention to the protection of wetlands, and particularly to wetlands of international importance, in the taking of conservation measures with regard to regularly occurring migratory species.
(4) On 3 December 2015, the Commission asked the European Chemicals Agency (‘the Agency’) pursuant to Article 69(1) of Regulation (EC) No 1907/2006 to prepare a dossier with a view to extending the restriction on lead and lead compounds in Annex XVII to that Regulation in order to control the risk to the environment and human health posed by the use of lead or lead compounds in gunshot used for shooting in wetlands (‘the Annex XV dossier’). At the same time, the Commission also asked the Agency to start collecting information on other uses of lead ammunition, including hunting in terrains other than wetlands and target shooting, and on the use of lead weights for fishing.
(5) On 21 June 2017, the Agency published the Annex XV dossier proposing the introduction of a restriction on the use of lead and lead compounds in gunshot for shooting with a shotgun within a wetland or where spent gunshot would land within a wetland. The Agency also proposed introduction of a restriction on the possession of lead gunshot in wetlands in order to enhance enforceability of the proposed restriction on the use of lead gunshot for shooting. The Agency concluded that the use of lead gunshot in wetlands leads to a risk to waterbirds that ingest spent lead gunshot, leading to toxicological effects, including death.
(6) The number of waterbirds estimated to die in the Union from lead poisoning is in the order of one million every year. The use of lead gunshot also leads to a risk to species that feed on birds contaminated with lead gunshot, and a risk to humans from consuming waterbirds shot with lead gunshot, although the latter risk was assessed by the Agency only qualitatively. Exposure to lead by humans is associated with neurodevelopmental effects, impaired renal function and fertility, hypertension, adverse pregnancy outcomes and death.
(7) The Agency concluded that lead-free gunshot alternatives, such as steel and bismuth gunshot, are widely available, technically feasible and have better human health and environmental hazard and risk profiles than lead gunshot. Moreover, steel gunshot, the most likely alternative to be used, is available at a comparable price to that of lead gunshot.
(8) Provisions prohibiting or restricting the use of lead gunshot in wetlands exist in the majority of Member States, but the disparities between them result in different levels of risk reduction. Furthermore, the migration routes of migratory birds typically cross several Member States and therefore birds could ingest spent lead gunshot in Member States where no or more limited measures are in place. The Annex XV dossier demonstrated that Union-wide action is necessary to address the risks arising from the use of lead gunshot in wetlands in a harmonised manner. Harmonisation legislation should however be based on a high level of protection. The outcome of harmonisation should therefore not be to oblige the Member States that have stricter national provisions on lead in gunshot to abandon those provisions, as this would imply a reduction in the level of protection of environment and health in those Member States.
(9) The Agency suggested a period of three years for introduction of the restriction.
(10) On 9 March 2018, the Agency’s Committee for Risk Assessment (RAC) adopted an opinion pursuant to Article 70 of Regulation (EC) No 1907/2006 with respect to the Annex XV dossier. In that opinion, RAC concurred with the Agency’s conclusion that ingestion of spent lead gunshot by waterbirds causes toxicological effects, including death. As to human health, RAC concluded that lead is highly toxic and that no threshold has been established either for neurodevelopmental effects in children or for blood pressure or renal effects in adults, so any exposure to lead therefore constitutes a risk. RAC concluded that the proposed restriction is an appropriate Union-wide measure to address the identified risks.
(11) RAC strongly supported a shorter period than the three years proposed by the Agency. The reason given was that each year of delay would result in approximately 4 000 additional tonnes of lead being released into wetland areas, resulting in the death of somewhere in the order of 1 million birds.
(12) On 14 June 2018, the Agency’s Committee for Socio-economic Analysis (SEAC) adopted an opinion pursuant to Article 71(1) of Regulation (EC) No 1907/2006, concluding that the proposed restriction is an appropriate Union-wide measure to address the identified risks, taking into account the fact that the socio-economic benefits of the measure would be proportionate to the socio-economic costs. In addition, SEAC concluded that the cost of the proposed restriction would be borne mainly by hunters, and that the cost increase to hunters was reasonable.
(13) SEAC considered that a shorter period than the three years suggested in the Annex XV dossier could pose a challenge in terms of implementation for those Member States that currently have only a limited or no ban on the use of lead gunshot in wetlands, although SEAC did also acknowledge that a shorter transitional period might be feasible, having regard to the fact that lead-free gunshot is already available on the market and that, in terms of increased costs for early replacement of guns, a shorter period would have only a minor impact.
(14) The Forum for Exchange of Information on Enforcement was consulted during the restrictions process in accordance with Article 77(4)(h) of Regulation (EC) No 1907/2006 and its recommendations were taken into account.
(15) On 17 August 2018, the Agency submitted the opinions of RAC and SEAC to the Commission.
(16) Taking into account the Annex XV dossier, the opinions of RAC and SEAC, the socio-economic impact and the availability of alternatives, the Commission considers that there is an unacceptable risk to the environment and a potential risk to human health stemming from the discharge of lead gunshot in or around wetlands, which needs to be addressed on a Union-wide basis. It is therefore appropriate to introduce a restriction on the act of discharging lead gunshot in or around wetlands.
(17) Given the difficulty for enforcement authorities in catching hunters in the act of actually discharging gunshot, the restriction should also include the carrying of lead gunshot whilst shooting. This will make it possible to enforce the restriction on discharging gunshot far more effectively and will therefore ensure the effectiveness of the restriction in addressing the risks identified to the environment and human health. The restriction should not be linked to ownership rights. The term “carrying” should therefore be used instead of ‘possession’ which was the term suggested by the Agency.
(18) A restriction on carrying lead gunshot should, however, apply specifically to carrying whilst shooting, as opposed to carrying in some other context, for example when transporting gunshot across wetlands for delivery elsewhere. The Commission considers, moreover, that the restriction on carrying should be directly linked to the particular type of shooting within the scope of the restriction (shooting in or around wetlands). This is in view of the fact that comments submitted during the public consultation on the Annex XV dossier indicated that, in some Member States, hunters involved in other types of shooting are quite likely to walk through different types of terrain, wetlands as well as other terrains, on a typical day’s shooting. The Commission also considers that, in order to aid enforcement, the restriction on carrying should cover not only carrying while out wetland shooting, but also carrying as part of going wetland shooting, in other words where there is a close connection with the actual shooting. This would cover, for example, carrying while heading out on, or returning home from, a day’s wetland shooting or carrying by someone helping hunters on a shooting expedition.
(19) Given the practical difficulties in proving the particular type of shooting that a person found carrying lead gunshot is intending to do, it is appropriate to establish a legal presumption that anyone found in or around wetlands carrying lead gunshot while out shooting, or as part of going shooting, is presumed to be carrying that gunshot while out wetland shooting, or as part of going wetland shooting. In other words, it would be for that person to show that he or she was actually intending to go shooting elsewhere and was merely passing through the wetland area in order to go shooting elsewhere.
(20) As regards geographical scope, the Agency proposed that the restriction on discharging lead gunshot should apply not only in wetlands but also in areas where “spent gunshot would land within a wetland”. The Commission notes that there was some support in RAC for quantitatively defining a fixed buffer zone around wetlands rather than relying on a test based on where spent gunshot would land. The Commission agrees that a fixed buffer zone is likely to make it easier to comply with the restriction and to enforce it. The restriction should therefore apply to discharging lead gunshot not only in wetlands but also in a fixed buffer zone around wetlands, defined quantitatively. Taking into account the need to ensure proportionality, the size of the fixed buffer zone should be set at 100 metres around wetlands.
(21) In view of the enforcement advantages and effectiveness of the restriction as a result of not having to catch hunters in the actual act of discharging lead gunshot, the Commission considers it appropriate to apply the restriction on carrying lead gunshot not only to carrying in wetlands but also to carrying in the fixed buffer zone around wetlands.
(22) As gunshot is generally not designed or placed on the market specifically or exclusively for use in or around wetlands, a restriction on the placing on the market of lead gunshot would affect shooting in all terrains. Therefore, the restriction should be limited to the discharge of and carrying lead gunshot.
(23) The restriction should apply to gunshot containing a concentration of lead equal to or greater than 1%. 1% is the concentration limit applied for the purposes of the “non-toxic” gunshot approval process in the United States of America in order to avoid a significant toxicity danger to migratory birds and other wildlife, or their habitats. Moreover, a 1% concentration threshold for the restriction is considered to be sufficient to address the risks posed by lead-containing gunshot material whilst also being readily achievable by producers of alternative gunshot, given that some of those alternatives are likely to contain lead as an impurity.
(24) It is appropriate to mirror the definition of “wetlands” used in the Convention on Wetlands of International Importance (Ramsar Convention) signed in Ramsar on 2 February 1971 for the purposes of the restriction, as was proposed by the Agency and confirmed in the opinions of RAC and SEAC, since that definition is comprehensive, covering all types of wetlands (including peatlands, where many waterbirds are also found), and since the Ramsar Convention has also developed a classification system for wetland types to help in the identification of wetlands.
(25) Stakeholders should be allowed sufficient time to take appropriate measures to comply with the restriction and Member States should be allowed sufficient time to prepare for its enforcement. Taking into account the views expressed by RAC and SEAC regarding the feasibility and appropriateness of a shorter period than the three years proposed by the Agency, and taking account particularly of the estimated impact each year of introducing more lead into wetlands through the use of lead gunshot, application of the restriction should be deferred for 24 months.
(26) In September 2018, the Agency published the results of an investigation report reviewing the available information on various uses of lead including, among other things, in gunshot used in terrestrial environments. Since the investigation report found, inter alia, that the available information suggested that the use of lead gunshot in terrestrial areas posed a risk to both human health and the environment, the Commission requested the Agency in 2019 to prepare an Annex XV dossier with a view to a possible restriction on the placing on the market and use of lead in ammunition and in fishing tackle .
(27) Moreover, in their opinions on the Annex XV dossier on the use of lead gunshot for shooting in wetlands, RAC and SEAC indicated their agreement with the Agency’s view that a ban on the placing on the market and use of lead gunshot in all terrains would result in a higher level of environmental protection and would be more effective from the point of view of practicality and enforceability.
(28) In some Member States, the restriction introduced by this Regulation may give rise to particular difficulties due to the specific geographical conditions in those Member States. For Member States with a significant proportion of wetlands in their territory, a ban on discharging and being in possession of lead gunshot in and around wetlands could in practice have a similar effect to a total ban on all shooting across the whole territory since hunters of all kinds would almost inevitably find themselves frequently in or near wetlands. Moreover, the resources that would have to be devoted to the enforcement of a restriction targeted only at areas in and around wetlands may not be much smaller, and may indeed be greater, than the resources needed to enforce a restriction covering their territory as a whole.
(29) Given the difficulties described, the need for the measure to be not only effective, but also simple and fair on the hunting community as a whole, and also the results of the Agency’s investigation report and the views of RAC and SEAC, the Commission considers that those Member States where such difficulties are likely to arise should be given the option to impose a different restriction in their territory which would prohibit both the placing on the market of lead gunshot, and also the discharging of and carrying lead gunshot throughout their territory, whether in wetlands or elsewhere, in connection with any type of shooting.
(30) In the interests of legal certainty, it is important to identify clearly the Members States who are to be eligible to make use of that option. The option should be available to those Member States where at least 20% of their territory is made up of wetland areas. A 20% threshold should cover those Member States who are likely to experience the difficulties due to the specific geographical conditions.
(31) Since the restriction that could be imposed by those Member States would be more stringent than the one limited to areas in and around wetlands, it is appropriate to set a longer period for the introduction of that restriction. That period should be set at 36 months, which corresponds to the period originally suggested by the Agency in the Annex XV dossier.
(32) For reasons of transparency and legal certainty, the Member States making use of the option should be required to notify the Commission of their intention and to communicate the measures adopted by them to give effect to it within certain deadlines, and the Commission should make the notices of intention as well as texts of the adopted national measures publicly available without delay.
(33) A number of Member States have in place national provisions prohibiting or restricting the use of lead gunshot for the protection of the environment or human health in a more severe manner than laid down in this Regulation. Forcing those Member States to reduce the existing level of protection in order to comply with this Regulation might lead to the increase of use of lead in gunshot in those Member States. Such a result would not be compatible with the high level of protection required by Article 114(3) of the Treaty. Member States should therefore be allowed to maintain such stricter provisions.
(34) Regulation (EC) No 1907/2006 should therefore be amended accordingly.
(35) The measures provided for in this Regulation are in accordance with the opinion of the Committee established by Article 133 of Regulation (EC) No 1907/2006,
HAS ADOPTED THIS REGULATION:
Article 1
Annex XVII to Regulation (EC) No 1907/2006 is amended in accordance with the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels,
For the Commission
The President
Ursula von der Leyen

berettaman

Grizzly 45 wrote: »

Apprently while we have been distracted by the COVID drama,this has still been ongoing and via webinars of our dear leaders in brussels. So third reading the countries that support the new lead ban proposals are
According to the recent webinar, the countries supporting the lead ban are:

....
For the Commission
The President
Ursula von der Leyen

Guys:


This is relevant:


https://www.euractiv.com/section/energy-environment/opinion/restricting-lead-gunshot-over-wetlands-why-is-the-european-commission-proposal-so-problematic/


The upshot seems to be... we are bringing this in, here are the rules. If members states have an issue due to specific geography then work it out amongst yer selves...but comply.:mad:

tudderone

berettaman wrote: »

Guys:


This is relevant:


https://www.euractiv.com/section/energy-environment/opinion/restricting-lead-gunshot-over-wetlands-why-is-the-european-commission-proposal-so-problematic/


The upshot seems to be... we are bringing this in, here are the rules. If members states have an issue due to specific geography then work it out amongst yer selves...but comply.:mad:

Thats the way the eu/fourth reich operate.

solarwinds

tudderone wrote: »

Thats the way the eu/fourth reich operate.

With their predicted end result of countries just not bothering to tailor it to specific circumstances, it is just easier to ban outright. But the EU will just turn around and say well it was left to each country to amend to suit themselves but you did not bother.
Thereby giving the country the option but not really giving them an option either because it would be so convoluted as to be practically impossible.

tudderone

solarwinds wrote: »

With their predicted end result of countries just not bothering to tailor it to specific circumstances, it is just easier to ban outright. But the EU will just turn around and say well it was left to each country to amend to suit themselves but you did not bother.
Thereby giving the country the option but not really giving them an option either because it would be so convoluted as to be practically impossible.

Its only going to get worse, with the Uk going competely by the end of the year, any brakes on federalisation have gone. Guy Verhofstwat has said as much, they want much more "Harmonisation" of rules and laws :rolleyes:. Then we have the pox doctors clerk in charge here, and we all know what he said about "Outdated notions of sovereignty".

berettaman

My understanding is that this is what will be voted on shortly.


We need one of France or Germany to abstain. Then it does not go through. Hunting lobby is strong in Germany. Not a done deal...yet!

Grizzly 45

More importantly,whats OUR govts position on this?As well as that shower we elected to repersent us in Brussels?Seeng that half of them are Water melons these days,or suvscribe to that doctrine?

tudderone

Grizzly 45 wrote: »

More importantly,whats OUR govts position on this?As well as that shower we elected to repersent us in Brussels?Seeng that half of them are Water melons these days,or suvscribe to that doctrine?

They are waiting on the phone call from Brussels to be told :rolleyes:

meathstevie

Belgium ( Walloon regional government ) being one of the largest small arms and sporting arms manufacturers in the world backing this is disappointing. Than again that’s the Parti Socialiste for you, hunt with the dogs and run with the hares and pacifist until a helicopter manufacturer starts throwing the cash around.

tudderone

meathstevie wrote: »

Belgium ( Walloon regional government ) being one of the largest small arms and sporting arms manufacturers in the world backing this is disappointing. Than again that’s the Parti Socialiste for you, hunt with the dogs and run with the hares and pacifist until a helicopter manufacturer starts throwing the cash around.

I don't think they produce much in the firearms field anymore. Liege was a major producer, but last i heard it was somewhere suffering from unemployment and best avoided.

meathstevie

tudderone wrote: »

I don't think they produce much in the firearms field anymore. Liege was a major producer, but last i heard it was somewhere suffering from unemployment and best avoided.

Herstal Group; owner of FN Herstal, Winchester, Browning and Miroku is owned by the Walloon region. Every GPMG, Minimi, SCAR, P90, 5.7 pistol and maintenance and replacement bits makes their till go katching.

juice1304

berettaman wrote: »

My understanding is that this is what will be voted on shortly.


We need one of France or Germany to abstain. Then it does not go through. Hunting lobby is strong in Germany. Not a done deal...yet!

Most states in germany already have a lead ban

tudderone

meathstevie wrote: »

Herstal Group; owner of FN Herstal, Winchester, Browning and Miroku is owned by the Walloon region. Every GPMG, Minimi, SCAR, P90, 5.7 pistol and maintenance and replacement bits makes their till go katching.

Yes but they were only one of many companies in that city making guns. Winchester are making guns in the US and portugal, Browning and miroku are Japan apart from the high-end stuff.

Grizzly 45

https://www.all4shooters.com/en/shooting/ammunition/eu-lead-ban-time-to-act-together-and-vote-for-lead-in-ammo/

+++ July 15, 2020 Update +++ As AFEMS (Association of European Munitions Manufacturers) has just announced, today's vote to ban lead shot in wetlands has been "ended without result". The Czech Republic had opposed both the voting procedure and the Ramsar definition of wetlands.
The deadline was on July 15, 2020 – today. Yesterday, just one day before the expiry of the written voting procedure on the proposed EC restriction on the use of lead shot in wetlands (which, with the support of Germany, would certainly have passed), European authorities surprisingly decided to stop the whole process.
This was made possible thanks to the intervention of the Czech Republic, who opposed the use of the online written procedure to discuss the issue and, reportedly, also the overly broad and generic definition of wetlands.
It should be noted, however, that a few days ago Germany supported the proposed restriction with the promise by the EU Commission to extend the transitional period from two to three years.
The written voting procedure is therefore considered "concluded without a result". However, it is very likely that a new vote on a possible fourth revision will take place in September.

Unfortunately, the implications of a “lead ban” have not been understood, and instead attempts are being made to enforce that ban by all means. The fact that alternatives such as soft iron shot are highly problematic, that they require special shotguns and that many alternative materials are much more problematic than lead is swept under the carpet. "Green ammo" is the motto – no matter what the consequences are. From our point of view, this is irresponsible and without any vision. Without any tendency to exaggerate: in the long run this is the end of hunting and shooting. Apparently, some of the protagonists are interested in exactly that.

Stay tuned to all4shooters to find out more!

Background to the vote in the REACH Committee on 15.7.2020
We at all4shooters.com have been informing our readers about the restrictions proposed by Brussels since 2015, when the European Commission requested the European Chemicals Agency (ECHA) to prepare a restriction on lead shot over wetlands. We also already explained how these proposed restrictions are mostly ideologically-driven and why a complete ban would be a disaster for hunters, shooters, the industry and the environment alike (see here). In fact, the idea of the “poisonous lead ammo” is a myth per se.

Notwithstanding the many critics and the lack of both scientific data and support from governments (even if 23 Member States have already phased out lead gunshot for hunting over wetlands), the EC has always picked itself up and hurried off towards an EU-wide total ban as if nothing had happened. But there are some major problems in its proposal.

A (very) badly drafted proposal
To sum up some of the most compelling issues:

Wetland area
What is a “wetland”? The scope of the EC proposal is based on the Ramsar definition. Unfortunately, that definition is quite ambiguous since it includes expansive areas without visible water (“peatlands”).
The definition of “wetland”: the scope of the EC proposal is based on the full Ramsar definition, I.e. “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”. Unfortunately, the Ramsar definition is quite ambiguous since it includes expansive areas without visible water (“peatlands”). According to that definition, in fact, even a 1m² area of temporary water which appears in an otherwise dry field after a shower of rain could equate to “wetlands”. Add to this the so called 100 m “buffer zones” around wetlands and confusion is complete: no hunter, or officer, will ever be perfectly sure whether he/she is in a wetland or not. The stand-alone use of that definition (without designation) is not precise enough to be capable for legal application in the Member States. Here, the principle of legal certainty is gone.

Reversed burden of proof: the Commission proposes that “if a person is found carrying (lead) gunshot in or within 100 m of wetlands while out shooting or as part of going shooting, the shooting concerned shall be presumed to be wetland shooting unless that person can demonstrate that it was some other type of shooting”. This is a complete reversal of burden of proof, since it presumes that a hunter is noncomplying and the accused hunter must exonerate itself from accusation. The “presumption of guilt” takes the place of the presumption of innocence – a fundamental principle of Western legal traditions, by the way.

The transition period: a much shorter transition period (24 months) is proposed by the EC for the total transition from lead shot to “green ammo”. The transition period should be at least 36 months following ECHA’s socio-economic analysis and 60 months for countries that have no restriction in place (Ireland, Slovenia, Malta, Poland, Romania). Actually, it sounds like just a bad joke. It takes some research time to develop unleaded ammunition that ensures ethical killing and no environmental effects also in wetlands. Safety is an issue too: how many hunters/shooters have old firearms which would need replacement, adjustments and reproofing to fire unlead cartridges with different pressures?

The role of REACH and consumer products: this is the first time that the Commission proposes consumers (i.e. hunters) and not manufacturers, importers and distributors to be addressees of a restriction. The REACH regulation was originally intended for “industry” only. Can it legally apply to hunters as “consumers”? This would expand the scope of REACH far beyond its original remit, creating a dangerous precedent and further confusion. For example, ethanol is also a substance under REACH, and alcohol-related problems are well known. Could this demonstrate that EU-wide action is necessary to address the risk arising from the consumers’ use of alcohol in a harmonised manner?

All in all, to quote FACE/AFEMS's conclusion, “the draft restriction is so badly drafted that it is impossible to apply in practice. Everybody knows that something is wrong but politics prevent the Commission from making some fundamental (but basic) changes.”

What's at stake
Hunting shotgun and ammo
A complete lead ban would be a disaster for hunters, shooters, the industry and the environment alike.
According to FACE data, “the sector employs more than 580,000 people in Europe and the annual turnover is around €40 billion, when including the revenues generated by hunting and shooting activities, as a whole. All in all, this comprehends 200 distributors, 14,000 retailers, 300,000 collectors and over 10 million hunters and sport shooters in Europe.”

Not just manufacturers and hunters, but also sports and clay shooters should be worried about the “lead ban”. Most shooting ranges will be affected because most are within 100 m of a wetland (like dry peatland), and the rules of international shotgun competitions are based on lead ammunition.

What could/should we do?
What is needed is a close coordination between organization such as AFEMS–FACE–IEACS–SAAMI to develop, share and promote inputs for an integrated activity stimulating the national associations and companies to speak and coordinate a strategy.

The aim is to have a direct dialogue with a friendly government. Otherwise, when the national authority is hostile to the topic, use other instruments to be heard. A) Highlight the issue to those ministries that you have a link with; Create the preconditions for the hostile institution to justify its position or take responsibility; C) Involve a member of the parliament – part of the majority – to forward a parliamentary query to make pressure.

Publishing on generalist/economic newspapers and/or websites press agencies and/or social media what is happening, providing coherent and credible arguments, is also useful

BattleCorp

Grizzly 45 wrote: »

The fact that alternatives such as soft iron shot are highly problematic, that they require special shotguns and that many alternative materials are much more problematic than lead is swept under the carpet. "Green ammo" is the motto – no matter what the consequences are.

That 'Green ammo' can be very harmful to the environment too. Alternatives often consist of steel, copper, tungsten, bismuth and zinc or various alloys thereof.

I looked at studies while doing a literature review and found that leaching from copper and zinc has been shown to be far more harmful than lead to certain wetland organisms, one being Daphnia magna (a small planktonic crustacean found it many wetlands).

keith s

I seen a video on Facebook: https://m.facebook.com/SorcaClarkeSinnFein/

Deputies Matt Carthy and Sorca Clarke questioning minister Malcom Noonan over Irelands position on this.

He said (around 10:50)that his party has liaised directly with farmimg and hunting stakeholders, I wonder who these are and can he reveal who this was and the minutes of these discussions.


He also mentioned (around 5:50) a extension for countries with wetlands exceeding 20% of their territory to 3 years, with the condition that they completely ban the use and sale of lead ammo.

With an older shotgun and a few 22lr rifles, I think all of these will be rendered useless.
I mean even at the rifle range with proper catchment and collection for the lead, if I cannot buy or use lead, what ammo can I actually use!

I think a lot of people out there, still think it will either go away or that it will only affect hunting.

I think we need to first get the message out and make everyone aware of what it will mean and what we can do about it together.

Brontosaurus

What can be done about this realistically? Are there any organisations that actually have our best interest at heart who are actually fighting this? Can we fight this?

Most ranges I know are on or near wetlands, and I can't think of much lead-free ammunition that is A: available and B: not prohibitively expensive. I mean, what lead-free 22lr ammunition even is there?

J.R.

Brontosaurus wrote: »

what lead-free 22lr ammunition even is there?

CCI, Winchester, RWS & FedArm are some of the lead-free .22 LR bullets....but I have never seen them for sale here yet.

Brontosaurus

J.R. wrote: »

CCI, Winchester, RWS & FedArm are some of the lead-free .22 LR bullets....but I have never seen them for sale here yet.

So all-copper or copper-coated? Wouldn't that wear out your rifling quicker than using un-jacketed ammo? You're also then stuck with a handful of rounds to choose from, and your rifle may not shoot well with whatever is available, and it'll probably be expensive.

Most of it seems to be high-velocity/super-sonic too, so not only will we be polluting waterways with zinc/copper instead of lead, we'll be upping noise pollution too...

keith s

Yeah, we only use 22 sub sonic (or under that 1150 fps) on our range.
Keeping the noise levels down is one of the main concerns we have.

A complete ban on the sale of lead means, regardless of the range location or even with lead collection in place, we cannot use ammo that works, is affordable and always available.

tudderone

J.R. wrote: »

CCI, Winchester, RWS & FedArm are some of the lead-free .22 LR bullets....but I have never seen them for sale here yet.

Copper is very much more expensive than lead, so how much is this copper ammo a brick ?

Grizzly 45

Brontosaurus wrote: »

What can be done about this realistically? Are there any organisations that actually have our best interest at heart who are actually fighting this? Can we fight this?

Most ranges I know are on or near wetlands, and I can't think of much lead-free ammunition that is A: available and B: not prohibitively expensive. I mean, what lead-free 22lr ammunition even is there?

This is on EUROPEAN level not national level...Yes you do actually have some good EU operations fighting your corner,one whom we have direct involvement in,called FACE which seems to have got it's act together again.Fire Arms United Network is a recognised Brussels lobby group too.Your problem is not the groups,but your MEP's.
The majority are Red Greenies who dont really support shooting,and are of the opinion "Lead=Bad for the planet...Ban it".

There isnt much we can do on a local level except kicking our orgs and Td's in the reasr to keep pushing our MEP's that this is an unworkable proposition in a country like Ireland,wher under the EU proposals a puddle of water in a field after a rainstorm becomes a "wetland" and that the other phases of banning lead rifle ammo for hunting and reloading and casting of bullets,eventhough we dont have such here in muzzle loading or ammo reloading is not on either.and that we WILL challenge this EU directive thru our orgs for compensation for firearms that cannot use steel or alt shot.

Zxthinger

tudderone wrote: »

Copper is very much more expensive than lead, so how much is this copper ammo a brick ?

Isn't copper highly toxic to trees

Grizzly 45

Yup.A great way of safely poisioning off coppicing trees like willows or white thorns is to drive copper nails into the stumps. Nature does the rest.

Eddie B

Meanwhile

https://www.youtube.com/watch?v=f-pNA1BNVgk

tudderone

Eddie B wrote: »

Meanwhile

https://www.youtube.com/watch?v=f-pNA1BNVgk

Thanks for that Ed, very interesting. The whole thing looks unworkable, and hopefully common sense will prevail.

CJhaughey

A voice of reason, exactly how much reason the Commission will listen to is debatable.

keith s

If a country is deemed to have more than a 20% of its territory made up of wetlands, the perposal is to ban the sale or use of lead entirely.

So there will be no need to prove if any land (at any time) has a puddle or not, it will just be illegal to use lead at any time.
So even for target clubs for example, that have spent time and effort to make trapment for lead it could be a waste of time.

Hopefully the proposal gets shot down, but I heard Malcom Noonan, say that the Irish government plan to accept the proposal and phase out lead within 3 years.

The video is on "Sorca Clarke TD" Facebook page posted on 16th July.

minktrapper

Does this include bullets as well as shotgun cartridges.