Compared to EFTTA’s lead position from 2022 a couple of things has changed since then.
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Most importantly, the EFTTA board agreed to support not only a sales ban but also a use ban as the Chemical Agency (ECHA) has suggested in its advice to the EU Commission (link in footnote 1 below).
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EFTTA suggests 3% as the max. acceptable lead percentage in brass (previously 4%). This to get closer to ECHA’s proposed 1% limit, and to make an argument by referring to a 3% derogation suggested for some hunters’ ammo (see below). If the Commission will accept 3% for some ammo products, then they should also allow 3% for some angling products.
As a result, the current EFTTA position is the following:
EFTTA Position on the Pending EU Legislation to Restrict Lead in sinkers and lures
EFTTA supports the sales and use ban, import control and consumer information as proposed by the European Chemicals Agency (ECHA)
1 – EFTTA supports both a sale and a use ban
EFTTA previously has argued against a use ban, but the EFTTA board decided last year (Dec 2023) to support the use ban as proposed by ECHA. It is simply too easy for consumers to import leaded tackle from non-EU countries and via the Internet, which will do harm to the environment and the European fishing tackle industry. And, as informed in the ECHA opinion: “..a ban on placing on the market would not be sufficiently effective, because use of ‘home-casted’ sinkers and lures would still be possible.”
2 – Derogation for lead in copper or copper alloys
Previously EFTTA has argued in favour of a derogation for lead in brass of 4% (instead of ECHA’s proposed 1%). EFTTA members now accept 3% but warn that less than 3% would require new costly machinery and product design changes – but stamped products can be made lead free of course. We understand the intention of making things easy by setting 1% as a limit for all products. However, the ECHA proposal does suggest 3% for some ammo (2a). Concerning the mention that “SEAC points out that the threshold in the restriction of lead gunshot in or around wetlands is also 1 % w/w” (2b). We would like to stress that when that 1 % limitation was discussed and decided for ammo in wetlands, we were not part of that discussion as that piece of legislation concerns ammo only, not fishing tackle.
3 – Derogation for small dust shots of 0.06 grams or less [size 14 to size 8]
EFTTA requests a derogation for these small dust shots. Anglers inform us that there are no durable alternatives. Tungsten putty is not a prudent alternative EFTTA is told. The putty often falls of the line when used in such small quantities.
In this video an angler explains, to avoid putty falling of the line you should stick it onto the split shot (sic) => From time 2 min 10 sec
Dust shots 0.06 grams or less are derogated by the UK’s anglers’ lead legislation since 1986. See this => explanatory memorandum from 2015.
4 – The phasing in time of the restriction
EFTTA requests one transition period only for sinkers & lures of 5 years; instead of ECHA’s proposal ≤ 50 g (3 years) > 50 g (5 years).
Next:
The Commission is working on a legislative proposal. It was expected to be ready in April but it won’t be out before September at the earliest, EFTTA believes. Thereafter, the Council and the European Parliament have three months to consider if one or both institutions will vote against the text. If not – which is most likely – the legislative proposal will be law.
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Note: ECHA has two committees to work on restriction proposals like this one:
- the Committee for Risk Assessment (RAC)
- the Committee for Socio-economic Analysis (SEAC)
Read more about the restriction process => here
Footnotes:
1 - Compiled RAC and SEAC opinion (and minority positions). => LINK
2a - Opinion on an Annex XV dossier proposing restrictions on Lead and its compounds. => LINK
Cutting from page one (pdf page 8):
“e. in any other projectiles not defined as a gunshot for hunting (by way of derogation shall not be used in a concentration equal to or greater than 3 % w/w in copper or copper alloys – this derogation shall be subject to a review prior to entry into force to determine if a concentration less than 1 % can be achieved)”
“f. in any other projectiles not defined as a gunshot for sports shooting (by way of derogation shall not be used in a concentration equal to or greater than 3 % w/w in copper or copper alloys – this derogation shall be subject to a review prior to entry into force to determine if a concentration less than 1 % can be achieved)”
2b) Cutting from page 20 (pdf page 28):
“SEAC considers that the same concentration threshold of 1 % weight by weight (w/w) proposed for restricting the placing on the market and use of lead ammunition and fishing tackle should also apply to the labelling and information requirements to avoid confusion and to aid enforcement. SEAC points out that the threshold in the restriction of lead gunshot in or around wetlands is also 1 % w/w. SEAC also supports RAC’s proposal to apply the labelling requirements specified in paragraphs 5a and 5b for alternatives containing copper and copper alloys only when lead content is equal to or greater than 3 % w/w.”
