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Table 1 Overview on REACH and CLP management measures for lead and lead compounds (CAS No 7439-92-1, EC No. 231-100-4)

From: An evaluation of the proposal to regulate lead in hunting ammunition through the European Union’s REACH regulation

REACH management measureScope and requirementsConcernSubmitted byYear of enforcement
Restriction (ANNEX XVII)
 Restriction of lead and its compounds in consumer articlesAnnex XVII, entry 30: Substances classified as toxic to reproduction, Cat 1A or 1B, may not be made placed on the market and made available to consumers, neither as pure substance or in preparations, at higher concentrations than the classification limit. This affects all lead compounds but not metallic lead. This means it is restricted as such and in mixtures placed on the market for sale to the general publicCMRSweden in 20122013
 Restriction of lead and its compounds in articles placed on the marketAnnex XVII, entry 63: Lead and its compounds shall not be placed on the market or used in articles supplied to the general public, if the concentration of lead (expressed as metal) in those articles or accessible parts thereof is equal to or greater than 0,05% by weight, and those articles or accessible parts thereof may, during normal or reasonably foreseeable conditions of use, be placed in the mouth by childrenCMRSweden 20152016
 Restriction of lead and its compounds in PVCAnnex XV Dossier submittedCMRECHA in 2017Not yet
 Restriction of lead and its compounds in gunshot in and over wetlandsAnnex XV Dossier submitted.
1. Shall not be used in gunshot for shooting with a shot gun within a wetland or where spent gunshot would land within a wetland.
2. Lead gunshot shall not be in the possession of persons in wetlands;
3. For the purposes of paragraphs 1 and 2:
   “shot gun” means a smooth-bore gun,
   “gunshot” means pellets used in quantity in a single charge or cartridge in a shotgun;
   “lead gunshot” means any gunshot made of lead, or any alloy or compound of lead with lead comprising more than 1% of that alloy or compound;
   “wetlands” are defined according to Article 1(1) of the Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar Convention).
4. Paragraphs 1 and 2 shall apply 36 months from entry into force of the restriction;
5. Member States may, on grounds of human health protection and environmental protection, impose more stringent measures than those set out in paragraphs 1 and 6. Member States shall inform the Commission of such measures
ENVECHA in 2017Not yet, presumably April 2020
Candidate listing and authorisation (annex xiv)
 Identification of lead and its compounds as SVHCProposal to identify lead and lead compounds as SVHC on the basis of the classification as being toxicity to reproduction category 1A in accordance with Article 57 (c) of REACHCMRSweden in 2018June 2018
Risk management option analysis (rmoa)
 Lead and lead compounds in certain consumer available articles and aviation gasoline CMRSweden in 2012x
 Lead and lead compounds in articles intended for consumer use CMRSweden in 2012x
 Lead and lead compounds CMRDenmark in 2015x
 Lead and lead compounds ENV, CMRECHA in 2015x
 Lead and lead compounds ENVECHA in 2016x
 Lead and lead compounds CMRSweden in 2017x
Classification and labeling (clp)
 Metallic leadHarmonized classification of lead metal (massive and powder, CAS: 7439-92-1) as toxic to reproduction (Repr. 1A-H360FD). The resulting new entries were included in Annex VI with the 9th ATP to CLP:
Lead powder; [particle diameter < 1 mm]:
Repr. 1A—H360FD; Lact.—H362; SCL Repr. 1A; H360D: C ≥ 0,03%
Lead massive; [particle diameter > 1 mm]:
Repr. 1A—H360FD; Lact. —H362
CMRSweden in 20132013
 Metallic leadProposal to classify metallic lead as aquatic acute 1; H400: Very toxic to aquatic life with an M-factor of 10 and as aquatic chronic 1: H410: Very toxic to aquatic life with long lasting effects with an M-factor of 10ENVDenmark in 20182018
  1. CMR carcinogenic, mutagenic or toxic to the reproduction system; ENV causes environmental harm