Here we go again.

About one year after the European Union's latest attempt to attack the civilian market of lead-based ammunition, the ECHA, the European Chemicals Agency is returning to the attack and trying once again to propose further restrictions on the use of lead-based ammunition for civilian uses.

The two attempts are indeed tightly linked: the ECHA document is indeed the Agency's response to the European Commission's request dated back to September 2017.

And despite what sources such as AFEMS told us last year, ECHA does not seem willing to limit to a new tightening of the screw on the use of lead shot in wetlands – which is anyway already heavily restricted or outright banned in many Countries both within and outside of Europe.
ECHA's report seems indeed aimed to propose heavy restrictions, if not an outright ban, on all civilian uses of lead-based ammunition, for both hunting and sport shooting.

ECHA's report on non-wetland uses of lead in ammunition  – published with the title of "ECHA identifies risks to terrestrial environment from lead ammunition", which immediately suggests its tone – states that the European Chemicals Agency has "found sufficient evidence of risk to justify additional measures" in order to reach three main goals: "limit additional pollution with lead and improve the quality of the environment"; "reduce the mortality of an estimated 1 to 2 million birds" that may inadvertently swallow the lead shot, or scavenge or prey on lead poisoned birds in the terrestrial environment; and "reduce health risks to a significant population of hunters and their families" who frequently eat game meat killed with lead shot or bullets.

It is now all too clear that the threat announced back in September 2017 was dismissed at a moment too soon, and it is now made even more paradoxal, as it's not just about ammunition: even fishing weights and home-casting would be limited by the proposed new regulations. 

And just as we stated back in 2017, there's no reason not to see the ECHA report as yet another attempt to impose sneaky gun control under the disguise of "environment protection". Despite what the European Chemicals Agency states, lead-free ammunition – and more specifically, steel-based ammunition – can not, by any means, used by "most" shotguns or rifles.

It's not a case if proofing houses following CIP standards use a special punch – the so-called "lilium" stamp – to mark the firearms that were built and tested to be used with steel shots.

Anybody with the slightest knowledge of firearms technology knows all too well that steel shots and bullets have a much different effect on barrels than steel shots in terms of tear and wear, and that steel-based ammunition often develop levels of pressures that older firearms – and some of the newer ones, particularly if subject to a particular level of usury – may not guarantee to sustain.

Using steel-based ammunition in firearms that weren't built, or tested, to be sufficiently reliable with them is by no means recommended and can be hazardous to the shooter. Should the restrictions proposed by ECHA be put in the books, a huge number of hunters all through Europe would need to spend enormous amounts of money to purchase new firearms – or even just new barrels – to keep practicing their sports. And should the new regulations also apply to sport shooting, the number of people affected would be exponentially larger.

As claimed many times before, it is safe to assume that the true reason behind the global push for an all-out ban on lead-based ammunition has very little to do with the protection of the environment and human health, and much more to do with the attempt to curb the number of individuals who own and use firearms for legitimate purposes. Imposing new and increasing costs for the de facto mandatory transition to a new technology is an excellent way to prompt those who don't have much money to spend to abandon altogether the practice hunting or sport shooting... and thus, due to the regulations in effect in many Countries, to forfeit gun ownership tout court.

The LEX paper certainly has the merit to highlight the highly paternalistic nature of ECHA's action proposal – protecti on of people from themselves, whether they like it or not and whether or not it's really a necessary thing to do! – but even more important is that LEX has so far been the only body to openly come out and oppose the ECHA's report and the proposed lead ammunition ban.

It is now up to the industry and hunting associations, and the representatives thereof, to use their political and economic means to avoid another round of restrictions whose impact would be outright disastrous for hunters, sport shooters, and the firearms and ammunition market in Europe.

The European Parliament itself will face a key decision: will they want to second ECHA and request a full impact assessment on the matter – which, no doubt, will result in a new waste of paper full of false, doctored and hand-picked data to justify yet another tightening of the screw over the people's rights in Europe? Or will it understand that gun owners Europe-wide are better left alone, since the community as a whole is already eagerly awaiting for the May 2019 European elections to provide its own kind of feedback on the amendment to the European firearms directive passed in 2017?

We would really like to see European lawmakers regain some common sense. But hoping for the best should always come in pair with expecting the worst. And that's what the so-called "EU Gun Ban" taught us to do when it comes to European lawmakers discussing all things gun-related.

Click here for the LEX paper rebutting ECHA's proposed lead ammo ban (English)