FACE representative David Scallan explained the potential consequences and spoke about the main issues that remain unresolved in the European Commission's 3rd proposal.
Main issues:
- no socio-economic assessment has been carried out with regard to shooting ranges, shops and the industry
- it is impossible to determine the location of a wetland in practice because the definition is too broad
- it is impossible to determine the 100-metre distance to a wetland in practice
- the European Commission has excluded an exemption for military and police purposes, in principle without informing the relevant authorities
FACE points out that the existing proposal is flawed, unenforceable and discriminatory towards hunters. FACE emphasises that lead should be phased out of use in hunting, but the current proposal will not solve the problems and will instead create additional issues for the sector.
LATMA also emphasises that lead as a material for ammunition should be phased out, but through proportionate and enforceable requirements, taking into account many of the conditions mentioned in the initial ECHA report, such as abandoning buffer zones and extending the transition period. Furthermore, an impact assessment of the ban on the operation of shooting ranges and hunting shops should be carried out, as well as a more in-depth evaluation regarding ammunition manufacturers.



