Unfortunately, there are now also worse provisions for the derogation for lead gun-shot in sports shooting: RAC considers that enforcement of the restriction would be simplified if this derogation was not implemented. However, if the decision maker decides that this derogation is needed, RAC suggests that it should be limited to shot sizes used in sports shooting (between 1.9 and 2.6 mm).
As AFEMS points out, you should remember that the proposal coming out of ECHA can be modified in many aspects by the European Commission. Which is not reassuring, if you consider the gross incompetence and ideological bias already shown by the Commission in the recent past.
Anyway, AFEMS also says that we can expect that the timeline will be influenced by the growing concerns related to the supply of military production and the upcoming political election in the European Union in Q2 2024. While a worst-case scenario could mean the restriction would be adopted by Q4 2023, a longer delay can be forecasted in case of extensive political discussions.
What ECHA and all the EU institutions are not taking in account, however, is the crazy situation this kind of restriction would lead to, and the total different interpretations and consequences country by country. It’s not clear how the different EU countries, with different laws, contexts and traditions, could implement the restrictions in such a short time, even without taking into account the effects on the ammo and gun industry. But do you remember the foolish story of recently announced ban on the sale of new petrol and diesel cars in the European Union from 2035? The script is always the same: ideological poisoning, murky interests, sheer incompetence, and complete disregard for the ordinary citizen’s interest.