If the near-total ban on the use of lead ammunition comes into force without a meaningful transition period, the socio-economic impact on the ammunition and firearms industry—and related sectors, would be severe: up to €4 billion and over 16,000 jobs could be lost, with associated welfare costs totaling €1.4 billion in the EEA.
When a radical reform that is set to change an entire industry is coming down the line, an accurate assessment of its impact and the setting of an appropriate time scale for its implementation are critical as to minimize any potential socio-economic fallout.
The impacts would also be felt on the 10 million users of ammunition which spend up to 20 billion euros annually.
Unfortunately, the European Chemicals Agency (ECHA) report has underestimated both of these aspects, meaning that if a lead ammunition ban becomes reality according to the existing terms and timelines in the current proposal, we can expect severe negative socio-economic repercussions for ammunition and firearm manufacturers, users, and European society as a whole.
According to a survey conducted by IEACS and ESFAM to collect data from firearms manufacturers in the EEA, up to half of the industry will face serious setbacks and even business closures if the restriction comes into force without longer transition periods.
To be compliant with the proposed restriction, in fact, years of extensive R&D will be required from industry players. The consensus between companies is that 10 years will be needed to fully transition their firearm portfolio impacted by the restriction, so that they can discharge lead-free ammunition if we want to avoid negative economic repercussions.
For an industry that annually records a revenue of nearly € 6 billion and employs nearly 22,000 people, implementing the restriction too early would endanger at least half (if not more) of the sector’s revenue and employees, and result in the closure of approximately 20% of related businesses: an annual monetary loss of up to €3 billion and over 11,000 jobs, with associated public assistance costs of around €800 million to be borne by taxpayers in the EEA.
Firearms manufacturers who mainly sell within the European market are most at risk, as they might be forced to a complete shutdown of their business. Large enterprises might be able to focus on exports and substitute lead in shorter term, but the small and medium size ones – SMEs, which are the true backbone of Europe’s economy, representing 99% of all businesses in the EU – will suffer once the core of their market vanishes.
That’s without even considering the significant indirect negative consequences of the ban on the industry’s supply chain and customers: there is an estimated number of 200 distributors, 14,000 retailers and over 300,000 collectors in Europe, whose business is entirely or largely dependent on the hunting or recreational shooting market.
As far as ammunition manufacturers are concerned, time is not the only factor at stake. As demonstrated by a survey that the AFEMS conducted among its members, the ECHA’s approach seems to ignore that the performance of ammunition is determined by all of its components and is engineered for specific ballistic and impact properties.
Changing any one component in that equation necessarily means re-engineering the whole unit. Therefore, an extended timescale is needed to design, develop and sell sufficient quantities of ammunition to meet current demand.
Very few manufacturers can substitute their leaded products in the short term (0-3 years), the majority can only substitute them in the longer term (10 years), and some are not able to substitute them at all, especially if we look at the absence of any accurate alternative for .22 rimfire.
It is clear from the survey that companies who are unable to immediately substitute products or sell to customers out of the EEA will have to stop their production lines. Consequently, the socio-economic impact of the proposed restriction would be harsh: annual monetary losses of up to €1 billion and over 5,000 jobs lost, with associated public assistance of €600 million in the EEA.
Adding up all the negative aspects that the proposed restriction would impose on firearms manufacturers and the ammunitions production industry, we get numbers that should make even the most enthusiastic supporters of the proposal think twice: annual monetary losses of up to €4 billion and over 16,000 jobs lost, with a public assistance tab of €1.4 billion in the EEA.
Despite the above, other complicating risk factors have been flagrantly ignored, including the availability (or shortage) of raw materials as direct alternatives to lead.
This is an issue for Bismuth and Tungsten in particular: while Annex D of the ECHA Report claims that both metals are ‘drop-in replacements’ for lead in gunshot, the 2020 critical raw materials factsheets of the European Commission conclude that the availability of both is already critical, and even look at substitution options to mitigate the risk.
Additionally, tin and steel, proposed as alternatives to lead in bullets and shots, are largely imported from outside the EEA, mainly from China. This would imply dependence for the EU market from the extra-EU, when it comes to the supply of such materials.
These kinds of inconsistencies unveil the umpteenth weak point of the ECHA report: if the proposed ban comes into force without the appropriate corrective actions, the price paid not only by the hunting (as previously demonstrated) and sports shooting communities, but also by European industry and society will be steep.