On May 27, 2024, the EU submitted notification G/TBT/N/EU/1065 to the WTO, proposing to add a new 50a clause to Annex XVII of REACH, which restricts the use of polycyclic aromatic hydrocarbons(PAH) in clay targets(clay pigeons) for shooting. The comment period will last for 60 days from the date of notification, and it is proposed to be adopted in the fourth quarter of 2024. If approved, the restrictions will become effective one year from the date of entry into force.
These disc-shaped objects used by sports shooters and small game hunters for (shooting) practice are manufactured using binders such as coal tar pitch, high temperature (‘CTPHT’), petroleum pitch or other types of resin.
The substance CTPHT is a substance of very high concern (SVHC) on the Authorization List under Annex XIV of Regulation (EC) No. 1907/2006 (entry 41 to Annex XIV of REACH, consolidated version to December 2023). Its carcinogenic, persistent, bio-accumulative and toxic (PBT) and very persistent and very bio-accumulative (vPvB) properties are due to the presence of PAH in the substance.
Applications for authorizing the use of CTPHT as a binder for the manufacture of clay targets have been rejected by the European Commission under Decisions C(2022)1510 and C(2022)1512. Although the authorization requirement does not apply to the placing onto the market of substances in articles, there are concerns about clay targets containing CTPHT being imported into the EU.
The attached is the specific limit requirements.
| Item | PAH | CAS | Limit Requirements |
| 1 | Acenaphthene | 83-32-9 |
One year after the entry into force of this provision, substances containing more than 50 mg/kg of the listed PAHs (0.005% of the dry weight of the clay target) shall not be placed on the market or used, alone or as a component of other substances, for shooting clay targets. |
| 2 | Acenaphthylene | 208-96-8 | |
| 3 | Anthracene | 120-12-7 | |
| 4 | Benzo[a]anthracene | 56-55-3 | |
| 5 | Benzo[a]pyrene (Benzo[def]chrysene) | 50-32-8 | |
| 6 | Benzo[b]fluoranthene (Benzo[e]acephenanthrylene) | 205-99-2 | |
| 7 | Benzo[e]pyrene | 192-97-2 | |
| 8 | Benzo[ghi]perylene | 192-97-2 | |
| 9 | Benzo[j]fluoranthene | 205-82-3 | |
| 10 | Benzo[k]fluoranthene | 207-08-9 | |
| 11 | Chrysene | 218-01-9 | |
| 12 | Dibenzo[a,h]anthracene | 53-70-3 | |
| 13 | Fluoranthene | 206-44-0 | |
| 14 | Fluorene | 86-73-7 | |
| 15 | Indeno[1,2,3cd]pyrene | 193-39-5 | |
| 16 | Naphthalene | 91-20-3 | |
| 17 | Phenanthrene | 85-01-8 | |
| 18 | Pyrene | 129-00-0 |
The PAHS listed in this draft are consistent with the 18 PAHS restricted in the German AfPS GS 2014:01 PAK, but the current 19th edition of the German G5 standard only restricts 15 PAHS. Therefore, it is recommended that companies producing clay targets for shooting control 18 PAHS instead of 15, in order to respond to the requirements of the draft regulation in advance.