Letter submitted to ECHA by the Hungarian Blackpowder Shooters and Hunters Association regarding the inclusion of lead into Annex XIV of the REACH regulation

In the past year we dealt with the planned modification of Annex XVII of the REACH regulation, that is aiming to ban the outdoor use of lead. This Annex is solely targeting the outdoor use proposing a full ban in hunting, and strict regulations on outdoor ranges. The consultation was closed in September 2021, now the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC) shall create their own drafts based on the original document that will be used for further legislation. More info about the proposal and the timeline of legislation: https://echa.europa.eu/hu/hot-topics/lead-in-shot-bullets-and-fishing-weights

Now there is a new front in this war, where ECHA plans to include lead in the Authorisation List (Annex XIV) of the REACH regulation. This will set a sunset date for using lead, and import, export, use and production of lead will be subject of EU authorization – a highly bureaucratic, slow and expensive procedure. In each case when a substance is registered in Annex XIV it means that the authorized use of such material will be terminated sometime in the future. More info: https://echa.europa.eu/documents/10162/1cff5712-6e86-df7f-1e4c-f29559c80dd8

The consultation of the inclusion into Annex XIV is now open till 2nd May 2022.

How to participate in the consultation?

Governing and non-governing organizations and even private persons can submit their opinion about the linked draft through ECHA website till 24:00 2nd May 2022. The link to the ECHA consultation website: https://comments.echa.europa.eu/comments_cms/InclusionRecommendation.aspx?substancename=Lead&ecnumber=231-100-4

The letter submitted by Hungarian Blackpowder Shooters and Hunters Association:

Dear Madam/Sir,

On behalf of the Hungarian Blackpowder Shooters and Hunters Association we are submitting the following report on including lead in Annex XIV of the REACH regulation.

Any further regulation of lead is unacceptable. All the arguments we submitted for the consultation of Annex XVII are valid for Annex XIV as well. The sad happenings of today caused by the aggression of Russia in Ukraine raised the question from a health and environmental level to strategic defence and security levels.

Risks of further regulation of lead

Understanding the critical situation EU member states face today due to the Russian aggression in Ukraine, we consider any further regulations of using lead for manufacturing ammunition both for military, law enforcement and civil purposes a direct threat on both defence and security and security of food supply chain.

  1. Any further regulation of lead used for manufacturing ammunition or in any areas of civil industry producing products for military, law enforcement and civil purposes is considered a direct threat of reducing the productivity of critical infrastructure serving the defence and security sector or both Hungary and all other EU member states. Ammunition is manufactured in plants producing goods both for civil and military use. Any further regulation of the civil manufacture or use of lead bullets can drastically reduce the production capacities serving the military and law enforcement.
  2. A full ban on use of lead for manufacturing ammunition forces the industry to a manufacturing technology change with such short term, the industry will not be able to follow. We do not see any indication of plans for covering the cost of such transitions or covering the loss generated by losing the pay-off possibility of previous investments in lead bullet manufacturing machinery and procedures.
  3. Due to the insecurity of ammunition manufacturing within the EU, the industry will be willing to relocate the production capacities outside the geographical coverage of the REACH regulations, resulting loss of jobs, loss of tax revenues within the EU, while drastically reducing the potentials of the European defence industry.
  4. Any further regulation of lead as material for bullets for hunting will have a strong effect on the food supply chain security. Based on previous statistics, in case of a total ban on using lead projectiles for hunting 25% of the hunters will quit hunting, while the remaining hunters will hunt 30% less. This will necessarily increase the amount of damage caused by the game in the agriculture and forestry. (https://www.all4shooters.com/en/hunting/ammunition/eu-echa-and-restrictions-on-lead-public-consultation-is-still-open-until-may-2-2022/) In the light of the Ukrainian-Russian conflict, the importance of the security of the food supply chain became an increasingly important strategical question for all EU member states.
  5. Including lead in the Annex XIV of the REACH regulation will ban using lead bullets for the law enforcement organizations of the EU member states, as only defence purposes can be considered as exceptions according Article 2 3.: “Member States may allow for exemptions from this Regulation in specific cases for certain substances, on their own, in a preparation or in an article, where necessary in the interests of defence.”
  6. Inclusion of lead in Annex XIV shall have an effect of manufacturing batteries as vast majority of lead (84% in 2015) is used for this purpose. In light of the Ukrainian-Russian conflict the strategic importance of devices storing energy increased drastically.
  7. Inclusion of lead in Annex XIV shall nearly automatically render vast majority of firearms designed for lead bullets unserviceable, it will raise safety concerns in case of shotguns designed for lead shot, it will reduce accuracy of firearms and airguns used for target shooting and will reduce the effectivity of hunting rifles designed for lead core bullets.
  8. All Olympic and most ISSF international shooting events require lead bullets/shots to be competitive. After the ban no EU athletes can participate such events abroad, and no international competitions can be held in EU countries.
  9. All historical muzzleloaders and their replicas are safe only with lead bullets both for target shooting and hunting purpose. As there are millions of muzzleloader guns (mostly unregulated) in the hands of European citizens, it is potentially hazardous to force them to use alternative bullet materials. The lead ban also terminates the sport shooting and hunting with these guns.

Our proposals

  1. In light of the current defence and security situation faced by the EU member states due to the Russian aggression in Ukraine we are against any further regulation of lead by including it in Annex XIV.
  2. We find it necessary to interrupt the procedure of any further regulation of lead under Annex XVII and Annex XIV.
  3. It is essential to apply exclusion from the regulations of Annex XIV for manufacturing and using lead and lead core bullets to save the ammunition manufacturing capacity serving the defence and public security/law enforcement sector, and to maintain hunting at a level required to reduce damage to agricultural lands and forestry.


Balázs Németh, PhD

member of the board of HBSHA, defence and security advisor, doctor of military sciences

Hungarian Blackpowder Shooters and Hunters Association

HUNGARY, 1044 Budapest,