Ustavimo prepoved EU pri prepovedi uporabe svinca v strelivu in ribištvu

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Danes sem prejel posredovano tole sporočilo, ki ga pošilja Vitaly Kryuchin, predsednik zveze IPSC. Gre za nov pritisk EU za prenehanje uporabe svinca v strelivu in ribiških utežeh.
Spodaj je širše pojasnilo in opis korakov kako to preprečiti.

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Stop EU ban on lead ammunition and fishing loads. Follow the attached international Declaration and join to organisations of shooters, hunters and fishermen representing 1 000 000 people

Dear colleagues,
 
we encourage your organization to follow and join the attached Declaration to prevent from EU lead ban. Simply, send us your approval, send your address, logo and one sentence description who you represent and how many people you represent. Originally this declaration served only for Czech republic, where it has been very successful. In the Czech Republic, shooting, hunting and fishing organizations representing 1 million people joined and made such a pressure on politics that Czech parliament adopted a resolution against lead ban and Czech Ministry of Environment became one of very noisy advocates against lead ban in recent meetings of REACH committee.
 
We are very pleased that we see the interest from other countries, e.g. Slovak hunting chamber joined too, so we internationalized our declaration and translated it in English to get as many organizations from different countries as possible to join our declaration, so that our voice reaches the European Commission and other EU institutions. As you can see, the declaration contains many relevant arguments.
 
The European Commission has officially stated that 2020 should be the year of the ban on lead in wetlands, and by 2022 lead should be banned everywhere even outside wetlands for all types of ammunition (gunshot and rifle) and in fishing weights. This is an important thing, for many people it is a very restrictive matter.
 
At the EU level, two processes are currently running in parallel to ban lead ammunition and fishing weights:
1) lead ban on wetlands. This lead ban, which the European Commission is already planning for 2020, is declared a "ban on wetlands", but in fact this ban is supposed to be much broader due to vague legal definitions. Last week, February 4, 2020, a key meeting of REACH committee was held in Brussels on the ban on lead ammunition on wetlands. REACH is a 15 year old EU regulation containing over 500 pages of annexes on registration, evaluation, authorization and restriction of chemicals. It was success that representatives of the EU Member States (mostly officials of the Ministries of the Environment or Health) by a narrow blocking minority rejected the technically and legally bad draft of the European Commission 's, so EC will have to come with the revision by next meeting on April 29th 2020. It is worth noting that, as early as 19 November 2019, several states already opposed the previous version, so the European Commission had to revise the proposal to ban on wetlands, but the changes were only cosmetic. The problem is that the EC has proposed to introduce a protection buffer zones around wetlands of 300 meters, while it is not clearly defined what a wetland is. A wetland can therefore be any ditch, every brook, and it can also be a puddle after the rain. Another problem is that the EC is proposing a ban on possession, not just a ban on the use of lead shot. Basically, it means if that someone lives 300 meters from the ditch, and someone has lead shot at home, so it might be illegal. And, when you go to buy lead ammunition in the store and when go home or at the shooting range on the road through or around some water, according to extensive legal interpretation it will again be illegal.
 
2) total lead ban. At the end of last year, the European Commission determined that 2022 should be the year of a total ban on lead ammunition and fishing weight everywhere. This week, on 10 and 11 February 2020, the European Chemicals Agency ECHA in Helsinki has already negotiated this total ban with representatives of EU Member State ministries and the stakeholders - representatives of selected shooting, sporting and hunting organizations, as well as firearms and ammunition manufacturers. Unfortunately, both ECHA and the EC emphasize the so-called "precaution principle", which basically reverses the burden of proof - ie. that it is necessary to demonstrate that lead is not harmful in order not to be prohibited. ECHA will discuss the ban in 2 of its committees that give opinions to the EC, which will ultimately decide: the Committee for Risk Assessment (RAC) and the Committee for Socio-Economic Analysis (SEAC).
 
According to information from the participants, the situation looks bad for both prohibition processes on and off wetlands, because the lead ban is politically motivated and stakeholder expert's and security arguments are neglected. However, the situation is not completely lost and does not mean that we can do nothing. On the contrary, Member States have already twice returned the EC proposal for recasting.
 
So what else can be done?
1) Join our international challenge (in attachment), while you can reuse it in your country - just translate it into your language and deliver it to your Parliament, the government and responsible ministries (environment, agriculture) in your country, and ask politicians to oppose the ban on lead with the arguments set out in the Declaration - i.e. (un)safety of shooting with substitutes, (not)ecology of substitutes etc.
2) ask the politicians and officials responsible for the meetings of the REACH committees (list of ministries concerned here), ECHA RAC and ECHA SEAC to vote against or at least abstain (which has the same effect as  to be against).
3) ask promptly your Members of European parliament to help and get involved. MEPs can help with advice or political pressure. On Tuesday, February 18th 2020, European Parliament’s Committee on Environment (ENVI) has requested a discussion with the European Commission on lead in ammunition (see agenda point 19, list of its members are here).
.
 
With Regards                                                                                                                                                                                                                             


   
Dr. Bohumil Straka
vice-president
LIGA LIBE, z.s.
Křižovnická 86/6 • 110 00 Praha 1 - Staré Město
e-mail straka@ligalibe.cz
www.ligalibe.cz
www.facebook.com/LIGA.LIBE
www.twitter.com/libeliga
www.instagram.com/ligalibe
   
Bohumil Straka
International committee
Czech-Moravian Hunting Union (ČMMJ)
 
   
www.cmmj.cz
Bohumil Straka
hunter, shooter, fisherman, falconer
tel. +420 777 071 722
e-mai: b@straka.eu

www.straka.eu
www.facebook.com/straka.bohumil
www.facebook.com/straka.bohous
www.twitter.com/BohumilStraka
www.instagram.com/bohumil.straka

 

 

 

Country

Organisation

Austria
Federal Ministry for Sustainability and Tourism
Bulgaria
Ministry of Environment and Water
Finland
Ministry of Social Affairs and Health
France
Ministry for an Ecological and Solidarity Transition;
Ministry of Environment
Germany
Federal  Ministry of Labour and Social Affairs (BMAS)
Federal Ministry for Economic Affairs and Energy (BMWI)
Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU)
Greece
General Chemical State Laboratory of Independent Authority for Public Revenue
Hungary
National Public Health Centre
Ireland
Health and Safety Authority
Italy
Ministry of the Environment, Land and Sea
Lithuania
Environmental Protection Agency
Malta
MCCAA
Poland
Ministry of Entrepreneurship and Technology;
Bureau for Chemical Substances
Slovakia
Ministry of Economy
Slovenia
Chemicals Office
 
 
Next very important addresses:
 
European Chemicals
Agency Committee for Risk Assessment RAC
P.O. Box 400 FI-00121
Helsinki Finland 
 
European Chemicals
Agency Committee for Socio-Economic Analysis SEAC
P.O. Box 400 FI-00121
Helsinki Finland
 
European Chemicals Agency
P.O. Box 400 FI-00121
Helsinki Finland 
 
 
REACH Committee
Directorate-General for Internal Market,
Industry, Entrepreneurship and SMEs
European Commission 
1049 Bruxelles/Brussel Belgium 
(email grow-general-information@ec.europa.eu )
 
 
REACH Committee Directorate-General 
for Environment European Commission 
1049 Bruxelles/Brussel Belgium

Some other information sources:

 

Information on the successful declaration of 1 000 000 Czech citizens against the lead ban:

https://ligalibe.cz/2019/01/15/protestni...kazu-olova

(English translation here)

 

Registry of restriction intentions until outcome:

https://echa.europa.eu/registry-of-restr...e1840159e6

 

EU Public consultation on lead ban 3rd October to 16th December 2019:

https://echa.europa.eu/previous-calls-fo...24001/term

 

EC/ECHA official timetable for the ban on lead in and outside wetlands in 2020/2022

https://echa.europa.eu/hot-topics/lead-i...ng-weights

 

                                           

 
 
One successful example to be followed:

Resolution of the Chamber of Deputies of the Parliament of the Czech Republic adopted on 24 September 2019 regarding lead.

Chamber of Deputies:
I. continues to ensure that the European Union institutions interfere disproportionately in the functioning system of control, registration, acquisition and possession of weapons and ammunition set up by the legislation of the Czech Republic;

II. Calls on the European Commission, when drafting and submitting any EU legislation, to pay due attention to the principle of proportionality and non-discrimination of EU Member States and not to abuse its right to issue implementing regulations with the so-called direct effect; EU;

III. calls on all EU institutions to take due account of the principle of proportionality and non-discrimination of EU Member States when drawing up and approving any EU legislation;

IV. calls on the Government to be active in negotiations with other EU members in the event of further steps in the regulation of lead in ammunition and fishing lead and the legal possession of weapons, thus ensuring the necessary support and allies to stop unjustified restrictions on citizens' rights;

V. Authorize the President of the Chamber of Deputies to inform the Prime Minister of the Czech Republic, the President of the European Commission, the President of the European Parliament and other representatives of the EU institutions and the parliaments of the Member States of the European Union.

 

 

--
Vitaly Kryuchin
IPSC President
ipsc.org