The ECHA's Committee for Risk Assessment (RAC) accepts the proposal to limit polycyclic aromatic hydrocarbons (PAHs) in shooting clay targets. The ban is intended to avoid future environmental emissions of these harmful and long-lasting chemicals that accumulate in humans and animals. Many PAHs are also recognized carcinogens.

RAC has issued an opinion on ECHA's proposal to ban the placement and use of PAH-containing chemicals in clay targets for shooting. After a one-year transition period with a 1% concentration limit, the proposed limitation sets a 0.005% weight-by-weight concentration limit for the total of 18 indicators PAHs. PAHs are found in the binders used to make clay targets.

The committee found the limitation request to be clear and well-justified. Although the European Commission earlier denied approval for one of the PAH-containing binders, coal tar pitch, high temperature (CTPHT), environmental damage from imported goods, and clay targets made with other PAH-containing binders, such as petroleum pitch, might continue. This reinforces the necessity for additional risk management.

"It is predicted that at least 270 tonnes of PAHs are discharged into the environment each year from PAH-containing clay targets." And these are broken by the bullet into the open environment, with little chance of risk management procedures being used. According to Tim Bowmer, Chair of the RAC, "the proposed limitation will minimize the assessed hazards by 99% in a reasonable timescale.

Aside from the environmental dangers, RAC believes that a ban is necessary since it would minimize exposure and related cancer risk for workers and the general public who handle and shoot clay targets.

In its draught opinion, the Committee for Socio-Economic Analysis (SEAC) likewise endorses the restriction. The committee believes that the proposal is the most suitable EU-wide response to the highlighted risks, taking into consideration the proportionality of its societal benefits and costs. The planned one-year transition period with a higher concentration limit, on the other hand, may not be essential. The draught opinion is open for 60 days until November 14, 2022.


Reach out to our regulation experts on product regulatory compliances