Advantages and drawbacks of restricting the marketing and use of by ghkgkyyt

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									European Commission
Enterprise Directorate-General
CONTRACT NUMBER – ETD/FIF.20030756




Advantages and drawbacks
of restricting the marketing
and use of lead in
ammunition, fishing sinkers
and candle wicks

Final Report

November 2004
European Commission
Enterprise Directorate-General


Advantages and drawbacks of
restricting the marketing and
use of lead in ammunition,
fishing sinkers and candle
wicks
Final Report

November 2004
                                     Preface

Background                           While the effects and the emissions of lead used for lead ammunition, lead
                                     fishing sinkers and candle wicks are relatively well documented, little is known
                                     about the markets of the products and the impact of potential marketing and use
                                     restrictions.

                                     This study is therefore aimed at analysing the markets of lead ammunition, lead
                                     sinkers and lead candle wicks in the old and new Member States and to assess
                                     the economic, social and environmental consequences of potential marketing
                                     and use restrictions.

                                     All military use of lead ammunition is outside the scope of this study. However
                                     military experience regarding development of substitutes and remediation of
                                     shooting has to the extent relevant been presented.

Purpose                              The overall objective of the present project is to assess the impact of potential
                                     restrictions of lead ammunition, fishing sinkers and candle wicks containing
                                     lead on business and private users.

                                     More specific the objectives of the study are:

                                     •      To provide a quantitative up-to-date assessment of the various uses in the
                                            old and new Member States.

                                     •      To identify and analyse the regulation and rules on hunting, shooting and
                                            fishing at national or regional level which may have an influence on the
                                            use of products in question.

                                     •      To discuss to what extent a common market exist for the products in ques-
                                            tion and whether a community wide approach is adequate.

                                     •      To identify the alternatives available to lead for the various applications
                                            and assess potential drawbacks of substitutes.

                                     •      Finally, to estimate the costs related to restrictions on lead in the various
                                            applications and compare them to the emission reduction expected.

Study team                           The following team has contributed to the solving of this assignment: Erik
                                     Hansen (Project Manager), Carsten Lassen and Adam Elbæk-Jørgensen, COWI
                                     A/S.




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                                     Table of Contents

                                     Preface                                                                  3

                                     1              Executive summary                                         7
                                     1.1            Lead ammunition                                           7
                                     1.2            Lead fishing equipment                                   12
                                     1.3            Lead candle wicks                                        17

                                     2              Potential environmental and health impact of the
                                                    use of lead in shot and sinkers                          19
                                     2.1            Environmental impact                                     19
                                                    2.1.1 Effects on waterfowl and other birds by direct
                                                             ingestion                                       19
                                                    2.1.2 Secondary poisoning                                20
                                                    2.1.3 Effects of dissolved lead on the biota             20
                                     2.2            Health impact                                            24

                                     3              Ammunition                                               27
                                     3.1            Application of lead in cartridges                        27
                                     3.2            Markets of cartridges                                    28
                                                    3.2.1 Available information                              28
                                                    3.2.2 Lead consumption by shooters and hunters           29
                                                    3.2.3 Lead consumption by ammunitions
                                                              manufacturing                                  33
                                                    3.2.4 Structure of shooting and hunting ammunition
                                                              industry in Europe                             37
                                                    3.2.5 Ammunition trade patterns in Europe                41
                                     3.3            Legal or voluntary use restrictions on lead ammunition   43
                                     3.4            Rules on hunting and shooting which govern
                                                    consumers' access to and demand for lead
                                                    ammunition                                               46
                                     3.5            Available measures to recover used lead ammunition       47
                                     3.6            Availability of substitutes for lead cartridges          50
                                                    3.6.1 Technical issues                                   50
                                                    3.6.2 Environmental and health issues                    55
                                     3.7            Impact of potential marketing and use restrictions on
                                                    lead ammunition                                          59
                                                    3.7.1 Impact on business and users                       59
                                                    3.7.2 Impact on the environment and health               69
                                                    3.7.3 Discussion of the need for a community wide
                                                              approach                                       75
                                     3.8            Summary and conclusion                                   77



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                                     4              Fishing sinkers                                           84
                                     4.1            Application of lead in fishing sinkers                    84
                                     4.2            Markets of fishing sinkers                                86
                                                    4.2.1 Angling                                             86
                                                    4.2.2 Commercial fishing                                  97
                                     4.3            Legal or voluntary use restrictions on lead fishing
                                                    sinkers                                                  103
                                                    4.3.1 Effectiveness of the restrictions                  104
                                     4.4            Availability of substitutes for lead fishing equipment   106
                                     4.5            Impact of potential marketing and use restrictions on
                                                    lead fishing sinkers                                     109
                                                    4.5.1 Impact on business and users                       109
                                                    4.5.2 Impact on the environment and health               114
                                                    4.5.3 Discussion of the need for a community wide
                                                              approach                                       118
                                     4.6            Summary and conclusion                                   119

                                     5              Candle wicks                                             123
                                     5.1            Application of lead in candle wicks                      123
                                     5.2            Markets of candle wicks                                  123
                                     5.3            Legal or voluntary use restrictions on lead wicks        128
                                     5.4            Availability of substitutes for lead wicks               129
                                     5.5            Impact of potential marketing and use restrictions on
                                                    lead wicks                                               129
                                     5.6            Summary and conclusion                                   130

                                     References                                                              132

                                     Annex 1 Contacted European associations                                 141

                                     Annex 2 Other contacted associations and companies                      144

                                     Annex 3 Abbreviations                                                   146

                                     Annex 4 Questionnaires                                                  147

                                     Annex 5 Trade Statistics                                                159




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                                     1              Executive summary

                                     The aim of this report is to assess the impact of potential restrictions of lead
                                     ammunition, fishing sinkers and candle wicks containing lead on business and
                                     private users considering economic, social and environmental consequences.


                                     1.1            Lead ammunition
Applications                         Lead ammunition is covering lead shot, lead pellets and bullets. All military use
                                     of lead ammunition is, however, outside the scope of this study.

Market                               Detailed data on consumption of lead as ammunition or for manufacturing of
                                     ammunition in the EU old and new Member States are generally not available
                                     and it has been necessary to assess these data indirectly based on the total num-
                                     ber of cartridges used in the EU, the number of hunters and shooters registered
                                     in each country and the content of lead in cartridges combined with statistical
                                     information on import and export of ammunition to the individual countries.

                                     Based on this approach the total consumption of lead about 2003 as ammuni-
                                     tion in EU15 is estimated at approximately 38,600 tonnes of lead yearly. The
                                     dominant countries of consumption seem to be Germany, France, UK, Spain
                                     and Italy. Lead shot ammunition is estimated to account for about 34,600 ton-
                                     nes of lead while lead bullets and pellets count for about 4,000 tonnes of lead.
                                     The picture of manufacturing is somewhat similar, but Italy is presenting itself
                                     as clearly the largest country of manufacturing followed by Germany, Spain,
                                     UK and France. The total consumption for manufacturing is estimated at about
                                     53,000 tonnes of lead. The difference between manufacturing and consumption
                                     is export. Data for consumption and manufacturing has furthermore been esti-
                                     mated for Hungary, Lithuania and Poland as representatives of the new Mem-
                                     ber States.

                                     Apart from the countries in which restrictions have been introduced, the con-
                                     sumption of lead as ammunition as well as for manufacturing of ammunition
                                     should be taken as reasonable stable.

Existing restrictions                The African-Eurasian Migratory Waterbird Agreement calls for the phase out
and rules                            of lead shot for hunting in wetlands. The agreement has entered into force in 9
                                     EU Member States and has been signed by another 5 besides the EU. Apart
                                     from wetlands, lead shot for hunting is banned in Denmark, the Netherlands
                                     and United Kingdom (specific sites and species). Restrictions for hunting in
                                     forests and other areas will, furthermore, be introduced in Sweden from 2006
                                     and in Belgium (the Flemish region - in forests) from 2008.

                                     Generally no legal restrictions on the use of lead shot for sports shootings apply
                                     apart from Denmark, where the use of lead shot is only allowed on a few speci-
                                     fied shooting ranges. However, a ban on lead shot for several shooting disci-
                                     plines will take effect from January 2005. In the Netherlands a ban on the use
                                     of lead shoot on shooting ranges is expected shortly. Regarding lead bullets no


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                                     restrictions have been introduced neither for hunting nor sports shooting. How-
                                     ever, in Sweden a ban on lead for this purpose will take effect from 2008.

Options of substitu-                 Substitutes seem to be available for all types of lead ammunition. Most focus
tion                                 has been on substitutes for lead shot. The cheapest alternative is steel shot be-
                                     ing about 20% more expensive than lead shot. As the ballistic properties of
                                     steel shot differ from lead shot, steel shot requires some time of acquaintance.
                                     The drawbacks of steel shot may otherwise be summarised as follows:

                                     •      they cannot be used in old guns with thin barrels as the barrels may be
                                            damaged;
                                     •      they are often not allowed in forest from which trunks are sold for furniture
                                            and veneer making as the industrial cutting tools may be damaged;
                                     •      they should not be used in rocky and similar terrain due to the risks of
                                            ricochets.

                                     Other alternatives based on e.g. bismuth, tungsten and tin are available that do
                                     not suffer from the technical drawbacks of steel and may ballisticly be taken as
                                     rather similar to lead. These alternatives, however, suffer from the disadvantage
                                     of a price corresponding to 150 - 1000% of the price of lead.

                                     Regarding sports shooting, the general strategy of the International Sports
                                     Shooting Federation regarding the issue of minimizing the environmental con-
                                     sequences of the use of lead ammunition is to promote improved lead recovery
                                     at shooting ranges. However, due to restrictions on lead shot, steel shot is the
                                     type of shoot mainly used in Denmark. The Danish experiences consider steel
                                     shot to be an acceptable alternative to lead shot also for competitions. Experi-
                                     ences from other countries have not been available.

                                     Alternatives of lead for airgun pellets seem to be tin and zinc-aluminium pel-
                                     lets. While tin pellets are claimed to be as accurate and soft as lead pellets, the
                                     experience of zinc-aluminium pellets is not always positive. The major draw-
                                     back of tin pellets seems to be a price increase of 1.5-6 times compared to lead
                                     pellets.

                                     Substitutes for lead bullets are not as developed as alternatives for shot and pel-
                                     lets. Non-lead ammunition claimed to be appropriate is being marketed. Devel-
                                     opment efforts addressing non-lead bullet ammunition seem, however primarily
                                     to be related to military ammunition. It may be noted that lead-free bullets for
                                     military purposes fulfilling all NATO-standards today is available in Europe at
                                     a price about 20% higher than lead bullets.

Recovering of lead                   Several techniques are available for lead containment as well as lead recovery
from shooting ranges                 from shooting ranges. Regarding shooting ranges for riffle and pistol shooting
                                     containment measures may include earthen berms as well as bullets traps made
                                     of sand, steel or rubber. Regarding shooting ranges for clay pigeons high soil
                                     berms (up to 20 m) are being developed in order to minimize the shot fall zone.
                                     Such berms can be equipped with large nets placed vertically on top of the
                                     berms in order to intercept shot flying over the berms. Nets can also be placed
                                     horizontally in the shot fall zone to catch shot and prevent them from being


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                                     mixed with soil. A solid asphalt surface may be used as an alternative to hori-
                                     zontal nets. Generally, a process of developing an environmental friendly de-
                                     sign of shooting ranges seems to have been initiated.

                                     Once contained, lead ammunition can be recovered by a number of techniques
                                     including sifting, vacuuming and soil washing. Which technique to apply de-
                                     pends heavily on the site conditions, soil composition and level of lead deemed
                                     acceptable in the cleaned soil or bullet trap material utilised. The lead colleted
                                     (bullet and particles) can be directed to recycling.

                                     The international sports shooting association (ISSF) recommends that collec-
                                     tion and recycling of the lead from shooting ranges are promoted rather than
                                     substitutes for lead ammunition. It is believed that significant improvements in
                                     this field are possible, and that shooting ranges can be designed and operated in
                                     a way paying full respect to environmental concerns related to inter alia lead.
                                     However, a strategy of improving design and operation of shooting ranges will
                                     certainly imply higher cost and it remains to be seen whether this strategy is
                                     more or less cost-effective than a strategy of substitution of lead ammunition.

Environmental im-                    The potential environmental and health impact of lead compared to the substi-
pacts of lead com-                   tutes available may be summarised as follows:
pared to substitutes
                                     Extensive documentation exists of the toxicity of lead towards humans as well
                                     as towards plants, animals and micro-organisms. The actual effects, however
                                     depends on the actual concentrations and availability of lead in the environment
                                     and the sensitivity of the exposed species.

                                     Specific focus has been on the poisoning of waterfowl and other birds by
                                     ingestion of lead shot and sinkers and the following secondary poisoning of
                                     raptors. Lead shot and fragments of lead shot in muscle tissues in waterfowl
                                     and other game may in special cases form a health risk to humans consuming
                                     this game.

                                     In soil and other parts of the environment metallic lead as bullets and shot are,
                                     furthermore, slowly corroded and turned into toxic lead compounds (oxides,
                                     carbonates, sulphides etc.). In the environment effects are generally limited to
                                     specially contaminated areas. Shooting ranges may be regarded as a type of
                                     contaminated areas where remedial action can be required.

                                     Lead ammunition is today regarded as the major source of lead contamination
                                     of soils slowly causing the content of lead in topsoil to increase. No compre-
                                     hensive assessment of the effects of this increase exists. However, a continued
                                     increase will narrow the gap between the current lead content of soil and the
                                     levels for which effects may actually be observed and could eventually cause
                                     these levels to be exceeded. The actual rate of increase should be expected to
                                     vary between Member States depending on the present content of lead in soil
                                     and the actual load of lead from ammunition and other sources.




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                                     While the issue of poisoning of waterfowl and other birds is related to the use
                                     of lead shot in wetlands and upland areas the issue of soil contamination is re-
                                     lated to all types of lead ammunition.

                                     Substitutes based on steel, tin, bismuth and tungsten is approved as non-toxic to
                                     birds in either USA or Canada. Regarding other impacts only iron presents a
                                     clear improvement compared to lead, while other alternatives suffers from one
                                     or more drawbacks inclusive of lack of data. Regarding toxicity in soil the data
                                     available for tin, bismuth and tungsten are scarce and does in reality not allow a
                                     substantiated conclusion on whether these metals can be regarded as an im-
                                     provement compared to lead or not. It is recommended that research is initiated
                                     that can eliminate the current lack of data. This recommendation is supported
                                     by the fact that new data on tungsten has indicated effects towards humans (e.g.
                                     reproductive and development effects) as well as towards soil organisms and
                                     plants.

Business impacts of                  The impact of potential restrictions to business and users are assessed as fol-
restrictions on am-                  lows:
munition.
                                     The incremental cost of ammunition is estimated at 22€ - 46€ for the average
                                     European hunter if lead ammunition was to be completely banned for all hunt-
                                     ing. This estimate is based on an estimated 6.2 mill. hunters within EU15. To
                                     this cost should be added a one-time cost of 50€ per testing related to safety
                                     testing of a shotgun. Spread over 5 years this conversion cost corresponds to an
                                     annual incremental cost of 13€ per hunter. In this estimate lead shot is assumed
                                     to be replaced by a mix of steel, tin, bismuth and tungsten shot depending on
                                     the local conditions. To these costs may be added the costs of replacement of
                                     old shotguns not able to cope with steel or other shot of similar hardness. How-
                                     ever, the owners of these guns may have the option of choosing shot of tin,
                                     bismuth or tungsten polymer having softness similar to lead but being more
                                     expensive. On average non-lead shot gun ammunition for hunters are assumed
                                     to cost 3 times as much as lead shot ammunition.

                                     The incremental cost of ammunition to the average European shooter is esti-
                                     mated at 27 - 55€ for shotgun ammunition, 2 - 20€ for bullet ammunition, and 8
                                     -24€ for airgun ammunition, corresponding to a total of 37 - 99€, if lead am-
                                     munition was to be completely banned for all shooting. For shotgun ammuni-
                                     tion is assumed that lead is substituted by a mix of steel, tin, bismuth and tung-
                                     sten ammunition, while for airguns tin pellets is assumed to be an acceptable
                                     alternative. These figures indicated above describes the incremental cost to the
                                     average shooter, while a competitive shot gun shooter may have to face extra
                                     costs in the range of 500€ to 7500€ annually due to a significantly higher con-
                                     sumption of shot gun cartridges. The same picture applies to a competitive pis-
                                     tol, rifle or air gun shooter. To the ammunition cost for shotguns must be added
                                     the cost of gun testing, besides that for many shotguns new chokes will have to
                                     be installed. This one-time conversion cost of 50 -100€ pr shooter assumed
                                     relevant for 50% of all shooters will spread over 5 years correspond to an an-
                                     nual incremental cost of 6.5 - 13€ taken as an average for all shooters. Finally,
                                     competitive shooters with very high cartridge consumption may face increased
                                     barrel wear due to steel shot forcing frequent replacement of weapons. Assum-


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                                     ing that 3 - 5 % of all sport shooters will make an extra replacement of their
                                     weapon annually the costs incurred will correspond to an annual incremental
                                     cost of 30 -50€ as average for all sport shooters.

                                     The direct costs to the industry of a ban on lead shot ammunition in Europe is
                                     related to conversion of existing lead based production lines have been esti-
                                     mated at approximately 310 million €. These costs should be assumed to be
                                     included in the incremental costs of ammunition stated above.

                                     A ban on lead shot may hit hard on about 5-8 European companies specialised
                                     in manufacturing of lead shot or machinery for manufacturing of lead shot.
                                     Giving the appropriate time of adaptation the production of these companies
                                     may be taken over by other European companies thus minimizing the economic
                                     impact from the transition process. However, it is at the present stage not possi-
                                     ble to assess the social and other costs related to the transition process as these
                                     depends heavily on the local conditions in the regions of the companies. How-
                                     ever, as the companies in question to the best of knowledge are relatively small,
                                     the transition costs should be expected to be limited.

The need for a com-                  It is assessed that arguments exist for a community wide approach regarding
munity wide ap-                      the use of lead shot in wetlands, as in particularly waterfowl are migratory birds
proach                               and the actions of individual Member States may naturally influence other
                                     Member States.

                                     Regarding other hunting activities the picture is more complicated, as the pri-
                                     mary environmental problem in this context seems to be the issue of soil con-
                                     tamination, and it is unclear whether the substitutes available in all cases repre-
                                     sent an improvement in the soil environment compared to lead. Soil contamina-
                                     tion should generally be regarded as a local or national issue and despite the
                                     uncertainties mentioned regarding available substitutes to lead shot. Member
                                     States may for environmental reasons consider it justified to introduce local or
                                     national restrictions on the use of lead based on national conditions. The main
                                     argument in favour of a community wide approach in this context would thus
                                     be the implications of such restrictions towards the free trade across the EU.
                                     Assuming that appropriate time will be allowed for companies to adapt to re-
                                     strictions, it is difficult to believe that such restrictions will be critical to more
                                     than very few companies.

                                     Regarding shooting activities the environmental issue in focus again is the issue
                                     of soil contamination which should regarded as a local or national issue. As
                                     already stated ISSF has proposed a strategy of promoting improved design and
                                     operation of shooting ranges in order to ensure almost completely collection
                                     and recycling of lead. Behind this strategy lies the recognition of the fact that
                                     lead ammunition is the ammunition preferred for international sports shooting
                                     events and that a ban on lead ammunition in the EU naturally will be a draw-
                                     back for European shooters compared to their competitors outside the EU.




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                                       Table 1.1    Estimated costs of selected measures to reduce the load to the
                                       environment from lead containing ammunition, EU-15 area
                                                                                     Phase-out regime
                                 Lead shot for         Lead shot for        Lead bullets for   Lead shot and     Lead bullets for        Total
                                hunting in wet-        other hunting           hunting,        air gun pellets      shooting
                                   lands 1)             activities 2)                           for shooting



Total costs per tonne           12,200 - 20,600       12,200 - 20,600        1,200 - 10,300    10,100 - 19,700   1,850 - 18,500     10,500 - 19,900
lead substituted (€/t) 1)
Total costs in EU-15                 44 - 74              176 - 296            0.18 - 1.5        180 - 350           5 - 50           405 - 770
(mill.€/year) 1)
Reduced load to the              3,400 - 3,600        13,700 - 14,400           140 - 150        ? - 17,800          ? - 2700       17,240 - 38,600
environment in EU-15                                                                                  3)                3)                3)
(tonnes lead/year)
                                       1)             All costs are based on estimated retail prices and include for shot gun also the anticipated
                                                      costs of testing of weapons. Costs of reduced remedial actions related to shooting ranges
                                                      and other areas exposed to soil contamination are not included. Costs of transition incl. of
                                                      social costs for companies not able to adapt to restrictions are not included either.
                                       2)             For hunting in wetlands as well as other hunting activities has been assumed a mix of 50
                                                      steel, 20% bismuth, 20% tungsten and 10% tin. It is likely that the percentage of steel
                                                      could be higher in wetlands causing the average cost per ton of lead substituted to be less
                                                      than for other activities. It is assumed that 20% of all shotgun hunting takes place in wet-
                                                      lands areas.
                                       3)             Some collection and recycling is taking place already today. However, no exact data on
                                                      the amount of lead recycled is available.


                                       In case substitution turns out to be more cost-effective the option always re-
                                       mains to restrict the use of lead on the individual shooting ranges or nationally.
                                       Again Member States may for environmental reasons consider it justified to
                                       introduce local or national restrictions on the use on lead based on national
                                       conditions. Thus the only argument in favour of a community wide approach in
                                       this context would be the implications of such restrictions towards the free
                                       trade across the EU. Again, assuming that appropriate time will be allowed for
                                       companies to adapt to restrictions, it is difficult to believe that such restrictions
                                       will be critical to more than very few companies.

  Cost and conse-                      The cost and consequences in terms of reduced contribution of lead to the envi-
  quences of selected                  ronment in the EU related to the possible restriction options are presented in
  measures                             table 1.1.


                                       1.2            Lead fishing equipment
  Applications                         Lead fishing equipment is covering anglers' equipment as well as equipment for
                                       commercial fishing. Lead equipment for anglers can be divided in a number of
                                       different items like split shot, sinkers/weights, pirks, downriggers and to a mi-
                                       nor extent also wobblers and floats. Regarding commercial fishing it is relevant
                                       to distinguish between sinkers/weights, lead lines and seine ropes.

  Market                               The data available on consumption of lead for fishing equipment in the EU old
                                       or new Member States is rather scarce. Only few investigations have been car-



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                                     ried out in this field, and the companies active are generally small having little
                                     or no knowledge of the total market for lead equipment neither in Europe nor in
                                     their home countries.

                                     Based on the data available the total consumption of lead for angling equipment
                                     in EU15 and EU25 is estimated at 1,900 - 5,600 and 2,000 - 6,000 tonnes/year
                                     respectively, of which about 50% is used for fresh water fishing. The consump-
                                     tion of lead for commercial fishing in EU15 and EU25 is similar estimated at
                                     1,900 - 8,700 and 2,000 - 9,000 tonnes/year.

                                     As the data available on national consumption of lead for angling is highly
                                     varying it is deemed not reasonable to estimate consumption figures for coun-
                                     tries for which no data is available. As manufacturing of lead sinkers is rela-
                                     tively simple and may take place in small workshops no major manufacturers in
                                     Europe seem to exist, and the general picture emerging is that with respect to
                                     ordinary sinkers most countries are supplied by own manufacturers of which
                                     many are small or having sinker manufacturing as a minor activity besides
                                     manufacturing of other lead based products.

                                     Concerning equipment for commercial equipment national data are even
                                     scarcer than for angling. The estimates presented are based on data regarding
                                     the size and composition of the fishing fleet combined with estimates for size
                                     and quantity of typical fishing equipment for different vessels. It has not been
                                     possible to estimate figures for consumption for manufacturing in the different
                                     countries.

Existing restrictions                Denmark has established a total ban on the use of lead in fishing equipment.
and rules                            However, for commercial fishing the ban has been derogated to 1 December
                                     2004.

                                     UK has banned the use of lead split shot and lead sinkers above 0.06 g and be-
                                     low 28.35 in fresh waters.

                                     In Sweden voluntary restrictions on lead fishing sinkers exist in some rivers.

Options of substitu-                 Substitutes seem to be available for many but not all types of lead sinkers (e.g.
tion                                 substitutes do not exist for the so-called "dust shot"). Most development has
                                     taken place with respect to angler's equipment. The dominant substitutes are
                                     zinc alloys and iron/steel which is used for several types of equipment. For spe-
                                     cial equipment also tin, tungsten composites and bismuth are utilised. The de-
                                     velopment of substitutes is, however, somewhat limited by the fact that the
                                     most extensive ban on lead exist in Denmark, which is a little market not neces-
                                     sarily interesting for foreign manufacturers. The costs of substituting products
                                     are estimated to be in the range of extra +10% - 1000% of the price of lead
                                     products. The price differs with the products in question but also with the alter-
                                     native material used. Bismuth and tungsten substitutes are typical high end sub-
                                     stitutes, while zinc and iron are the cheap alternatives. For several types of
                                     sinkers the products formerly produced in Denmark from lead is now manufac-
                                     tured in China based on zinc or iron. This outsourcing has effectively reduced



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                                     the extra costs related to the change of raw materials as well as other costs of
                                     manufacturing.

                                     Regarding equipment for commercial fishing substitutes are only available for
                                     sinkers/weights for which substitutes based on iron or zinc are developed at a
                                     price equalling the price of lead products.

                                     With respect to lead lines and seine ropes no alternatives are commercially
                                     available today. Efforts to develop substitutes are, however, ongoing, and it is
                                     believed that substitutes based on iron or zinc can be realised at a price equal-
                                     ling or slightly exceeding the price level of lead equipment.

Environmental im-                    The potential environmental and health impact of lead compared to the substi-
pacts of lead com-                   tutes available may be summarised as follows:
pared to substitutes
                                     Extensive documentation exists of the toxicity of lead towards humans as well
                                     as towards plants, animals and micro-organisms. Specific focus has been on the
                                     poisoning of waterfowl and other birds by ingestion of lead split shot and small
                                     sinkers and the following secondary poisoning of raptors. Poisoning of water-
                                     fowl may in special cases form a health risk to humans consuming these birds.
                                     In this context the discussion of lead sinkers/weights are similar to lead ammu-
                                     nition.

                                     In the aquatic environment sinkers lost in fast running streams as well as in the
                                     wave zone and other erosion zones in the sea are likely to be slowly eroded and
                                     dissolved. Sinkers lost to the ground along streams and lakes may also be
                                     slowly corroded and turned into toxic lead compounds (e.g. lead oxides and
                                     lead sulphides). This way lead used for sinkers are dispersed into the environ-
                                     ment and is adding to the general concentration of lead in the environment.
                                     Other sinkers may directly end up in sediments and the overall picture is that
                                     lead will accumulate in sedimentation areas and by time be buried in the sedi-
                                     ments. Apart from poisoning of waterfowl no reported environmental effects
                                     have been ascribed to lead from fishing sinkers and weights.

                                     Other concerns related to the use of lead for sinkers is that they are often manu-
                                     factured by home-casting or small scale casting in small enterprises which is
                                     not likely to be equipped with adequate emission abatements technology and
                                     thus may result in relatively high emissions of lead to the environment. Lead in
                                     abandoned fishing equipment collected as waste may furthermore be a source
                                     of lead to waste incineration and thus add to lead emissions to air and the con-
                                     tent of lead in residual products recycled to civil works etc.

                                     Regarding substitutes to small sinkers and lead split shot based on tin, tungsten,
                                     bismuth, iron and zinc the discussion is similar to the discussion on substitutes
                                     for lead shot ammunition. However, zinc is not currently approved in the US as
                                     a non-toxic shot and is in reality also toxic to birds although the toxicity is
                                     lower than that of lead.

                                     Regarding other impacts only iron presents a clear improvement compared to
                                     lead, while other alternatives suffers from one or more drawbacks inclusive of


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                                     lack of data. Regarding toxicity in water zinc must be considered significantly
                                     less toxic than lead, while no water quality criterion or other comparative as-
                                     sessment covering toxicity in water environments have been identified for tin,
                                     bismuth or tungsten. While it is generally believed that neither tin, bismuth nor
                                     tungsten should be of concern regarding their environmental impact in water
                                     environments, this is in reality not documented, and it is recommended that re-
                                     search is initiated that can eliminate the current lack of data.

Business impacts of                  The impact of potential restrictions to business and users are assessed as fol-
restrictions on lead                 lows:
sinkers.
                                     Sinkers and other lead equipment for angling and commercial fishing are manu-
                                     facturers by several hundred companies in Europe. Many companies are small
                                     and dealing with other activities than sinker manufacturing. Lead sinkers are
                                     easy to cast and can be manufactured in a small workshop or even as home-
                                     casting. Lead wires/string of beads are estimated to be manufactured by 10-50
                                     companies in Europe.

                                     Lead casting may relatively easy be replaced by zinc casting by using other
                                     moulds while manufacturing of iron or steel is more complicated and requires
                                     different equipment and expertise. It has not been possible to quantify the direct
                                     and indirect costs of industry in case of restrictions on the use of lead as well as
                                     the social cost of transition for companies not able to adapt to a restriction. It is,
                                     however, deemed likely that a change from lead to other materials will result in
                                     a concentration of production and the close down of many small workshops and
                                     companies. Danish experience indicates that the market changes introduced by
                                     a ban may to some extent also speed up a process of outsourcing to Asia.

                                     Regarding the consequences for angling, it is roughly estimated that on average
                                     anglers annual expenses may increase by 1.5-10.4 €/year considering raw mate-
                                     rials as well as other elements included in the retail price. Other consequences
                                     are assessed to be small and without significance regarding the use of lead-free
                                     equipment.

                                     Regarding the consequences for commercial fishing, test fishing with lead-free
                                     equipment is first scheduled to take place in 2004 and no precise experience
                                     with lead-free sinkers and equipment is yet available. Concern is raised related
                                     to the extra volume of substitute metals and the extra noise coming from han-
                                     dling steel or zinc equipment as compared to lead equipment. Also the impacts
                                     on substitutes on net materials need to be clarified.

                                     Regarding the issue of a common market for fishing equipment, it is clear that a
                                     significant part of the production in particular of sinkers/weights is carried out
                                     by small companies for their home market. However, as the same types of sink-
                                     ers and lead lines are used all over Europe, a common market for these products
                                     to some extent also exists. For lead wires and lead bead strings used for lead
                                     line production - the main application of lead for commercial fishing - there
                                     seems to be a common European market.




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Restriction options                  The restriction options available differ from restricting lead sinkers for angling
and the need for a                   in inland waters to a total ban on the use lead large sinkers for angling and a
community wide ap-                   ban on the use of lead for commercial fishing. The costs of these measures are
proach                               roughly indicated in table 1.2 below.

                                     The environmental concerns as to the use of lead sinkers are mainly related to
                                     the use of lead split shot and small sinkers for fishing in inland waters as in par-
                                     ticularly waterfowl are migratory birds and the actions of individual Member
                                     States may naturally influence other Member States. From an environmental
                                     point of view a use restriction as the restriction implemented in the UK would
                                     be the most well-documented as reasonable solid arguments related to migra-
                                     tory birds exist for a community wide approach.

                                     It must be recognized that only iron presents a clear improvement compared to
                                     lead considering toxicity as well as other environmental issues, while other al-
                                     ternatives suffers from one or more drawbacks inclusive of lack of data. Fur-
                                     thermore, substitutes for "dust shot" seem not to be available, besides that their
                                     impact on birds has not been specifically documented.

                                     For larger sinkers and other lures used in the sea and in large lakes, a signifi-
                                     cant home casting takes place, and these activities may increase as a conse-
                                     quence of a ban on the sale of lead sinkers. It is deemed that a ban on the use of
                                     lead sinkers (like in the UK) more efficiently would reduce the load of lead to
                                     the environment than a ban on the sale (like in Denmark). In both cases a re-
                                     striction will reduce the amount of lead (estimated 850-2,520 tonnes yearly
                                     from EU15) emitted to waters covered by international sea conventions as the
                                     OSPAR Convention aimed at - among other issues - to reduce the emissions of
                                     lead to the marine environment.

                                     A phase-out of lead for commercial fishing has relatively small incremental
                                     costs to the fisheries and the costs per ton of lead phased out is considerably
                                     lower than for sinkers for angling. However, the environmental effect of the
                                     decreased load of lead to the sea by lead from commercial fishing is not well-
                                     documented apart from that a restriction will reduce the amount of lead emitted
                                     to marine waters covered by international sea conventions as the OSPAR Con-
                                     vention.

                                     The commitment of the EU related to sea conventions as the OSPAR Conven-
                                     tion could be used as an argument for a community wide approach for lead
                                     wires and lead bead strings for which a common market exist. Assuming that
                                     appropriate time will be allowed for companies to adapt to restrictions, it is not
                                     possible based on the knowledge available to assess whether restrictions may
                                     lead to market distortions.

                                     However, it is relevant to note that national concerns and restrictions regarding
                                     the use of large lead sinkers and commercial equipment may also be argued by
                                     other concerns as e.g. emissions from home casting of lead and waste disposal.
                                     Fishing equipment disposed of to landfills and waste incineration may contrib-
                                     ute significantly to total lead in waste and thus to the emissions caused by e.g.
                                     utilisation of incineration residues for civil works. The load of lead to the waste


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                                     streams may, however, be reduced by the use of other instruments requiring the
                                     discarded equipment to be collected separately and recycled, which however
                                     may be costly in particular for items like lead lines and seine robes.

                                     Table 1.2             Estimated costs of phase-out of lead sinkers and reduced lead load to
                                                           the environment

                                                           Phase-out of lead sinkers      Total phase-out of lead        Phase-out of lead sinkers
                                                            for angling in inland wa-       sinkers for angling           for commercial fishing
                                                                       ters
    Total costs to anglers/the fisheries per                     19,000-39,000                 12,000-34,500                     300-1,330
    tonne lead substituted (€/t) 1)
    Total costs to anglers/the fisheries in the                       19-117                       24-207                          0.6-12
    EU25 (million €/year) 1)
    Reduced lead load to the environment in                         900-2,700                   1,800-5,400                      100-1,800
    the EU25 (t lead/year)
    Total costs to anglers/the fisheries in the                       18-110                       23-198                        0.57-11.6
    EU15 (million €/year) 1)

    Reduced lead load to the environment in                         850-2,520                   1,700-5,040                       95-1,740
    the EU15 (t lead/year)
                                     1)             All costs are based on estimated retail prices. Costs of transition incl. of social costs for
                                                    companies not able to adapt to restrictions are not included.




                                     1.3            Lead candle wicks
Applications                         Lead candle wicks covers the type of wicks in which a thin lead wire is inserted
                                     into the wick in order to stiffen or support the wick.

Market                               Use of lead candle wicks is just one of a variety of known candle
                                     manufacturing technologies. No members of the European Association of Can-
                                     dle Makers (AECM) are known to be engaged in production or use of lead can-
                                     dle wicks and no production of lead containing candles in the EU15 area has
                                     been detected. There may reportedly be a small production in certain parts of
                                     Eastern Europe, notably the general Balkan area, but it has not been possible to
                                     document this assumption.

                                     It is, however, based on surveys from USA and Australia assumed that a certain
                                     share of the imported volume of candles from the Far East contains lead candle
                                     wicks, although no precise data is available to quantify this import. It is esti-
                                     mated that the import of lead to the EU in candle wicks in candles from the Far
                                     East most likely will be well below 100 tonnes per year and may not exceed a
                                     few tonnes per year.

Existing restrictions                Lead in candle wicks has been banned in Finland (indoor uses) from 2001 and
and rules                            in Denmark from 2002, while a voluntary restriction on the use of lead in can-
                                     dles in the UK has existed since the 1970's.

Options of substitu-                 Lead candle wicks can be substituted by wicks with cores based on tin or zinc
tion                                 or simply by using a thicker woven wick. In the EU, production of candles


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                                     seems to be based mainly or solely on wicks without a metal core, as there are
                                     no known manufacturer of zinc or tin wicks in Europe.

Environmental and                    When a lead wick based candle is burned in indoor conditions, considerable
health impacts of                    amounts of lead may be released to the indoor air and result in human exposure
lead and substitutes                 to lead by inhalation. The lead released may otherwise settle as dust on furni-
                                     ture and floors and thus be a source of human intake of lead for adults as well
                                     as for children. Besides, the released lead may be a source of lead to waste and
                                     waste water when the lead is removed from the indoor environment by clean-
                                     ing. For candles used outdoor, lead will similarly settle in the surroundings and
                                     thus add to the general level of lead in the surroundings. Regarding environ-
                                     mental and health impacts of substitutes no reports are available indicating con-
                                     cerns related to any of the substitutes in question.

Business impacts of                  It is assessed that an EU-wide restriction on marketing and use of lead wicks in
restrictions on lead.                and for candles will have no effects on the manufacturing industry in the EU. It
                                     is also not possible to identify any disadvantages to the European consumers of
                                     such a restriction, while the consumers certainly will benefit from such a re-
                                     striction. Although the import and consumption of lead candle wicks in Europe
                                     likely is small the risk exists that some consumers are exposed to lead fumes
                                     from lead wicks in candles and the lead dust generated by those fumes. A re-
                                     striction should - in principle - eliminate this risk completely.

Relevance of a                       To the best of knowledge a community wide approach may benefit all stake-
community wide ap-                   holders in all Member States of the EU apart from those companies importing
proach                               and selling candles with lead wicks on the European market.




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                                     2              Potential environmental and health impact
                                                    of the use of lead in shot and sinkers
                                     Potential environmental and health impact of the use of lead in shot and sinkers
                                     is shortly reviewed in the following. At the moment a risk assessment of lead
                                     financed by the industry is undertaken by Lead Development Association In-
                                     ternational (LDAI). In a comprehensive risk assessment the actual and pro-
                                     jected exposure of man and organisms in the environment is compared against
                                     the observed effect levels. It has been beyond the scope of the current study to
                                     undertake a risk assessment.


                                     2.1            Environmental impact
                                     The environmental issues related to the use of lead shot and fishing sinkers can
                                     roughly be divided into three aspects:

                                     •      Poisoning of waterfowl and other birds by ingestion of split-shot and small
                                            sinkers;
                                     •      Secondary poisoning of raptors;
                                     •      Short-term and long-term effects of dissolved lead on the biota.


                                     2.1.1 Effects on waterfowl and other birds by direct ingestion
Waterbirds                           Metallic lead is highly toxic to birds when given as lead shot; ingestion of a
                                     single pellet of lead shot can be fatal for some birds. Lead shot is typically
                                     trapped in the gizzard of birds where it is slowly ground down resulting in the
                                     release of lead, which causes severe lead contamination: in organs, high levels
                                     of lead are found in blood, kidney, liver and bone [WHO 1989]. The sensitivity
                                     varies between species and is dependent on the diet. Since birds have been
                                     found in the wild with large numbers of lead shot in the gizzard, this poses a
                                     major hazard to those species feeding on river margins and in fields where
                                     many shot have accumulated [WHO 1989].

                                     Lead shot ingestion and poisoning of waterfowl has now been documented in at
                                     least 21 countries, including Canada, Australia, Great Britain, France, Spain,
                                     The Netherlands, Japan, and the United States (referred in [Beintema 2001].
                                     Mortality of waterfowl from lead shot ingestion becomes manifest either as
                                     large-scale die-offs or as less conspicuous, day-to-day mortality. Many in-
                                     stances of die-offs have been recorded in the United States and Canada. Al-
                                     though spectacular cases of mortality have drawn public attention to the issue
                                     of lead poisoning, these occasions are probably less important than the largely
                                     invisible losses of small numbers of birds on a daily basis. Sick and dying birds
                                     generally become increasingly reclusive [Beintema 2001]. The effects of lead
                                     shot on waterfowl is the direct background for article 4.1.4 under the African-
                                     Eurasian Migratory Waterbird Agreement (AEWA) that states that Parties shall
                                     endeavour to phase out the use of lead shot for hunting in wetlands by the year
                                     2000.




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                                     Besides lead shot, waterfowl are also ingesting small sinkers. Because sinkers
                                     are generally much larger than shot pellets, a single lead sinker may induce
                                     acute poisoning. In an American study on the causes of mortality of 600 loons
                                     showed that fishing lures was responsible for about 10% of the deaths. The
                                     loons most often ingested weights of 1/4 - 1 ounce (28.35 g). The types of lures
                                     recovered from the loons could be split into sinkers (40%), split shot (16%),
                                     jigs (16%), pellets (2%), shot (2%) and miscellaneous (6%) [Tufts 2004].

Terrestrial birds                    Birds in the terrestrial system may also be exposed to spent lead shot. Evidence
                                     exist that upland birds, particularly mouring doves (Zenaida macroura) ingest
                                     spent lead shot [Kendall et al. 1996]. A review of the scientific data and an eco-
                                     logical risk assessment was performed by [Kendall et al. 1996]. The risk as-
                                     sessment did not clearly define a significant risk of lead exposure to upland
                                     game birds. However, Locke and Friend 1992 (as cited by [Scheuhammer and
                                     Norris 1995]) conclude that "lead poisoning has been documented in a suffi-
                                     ciently wide variety of birds to consider all birds as being susceptible to intoxi-
                                     cation after ingesting and retaining lead shot".


                                     2.1.2 Secondary poisoning
                                     Secondary lead shot poisoning can occur when a predator or scavenger
                                     consumes animals that have been shot with lead shot ammunition and conse-
                                     quently carry lead shot pellets embedded in their bodies, or consumes the giz-
                                     zard of a bird that has ingested lead shot. Research done in various countries
                                     over the past 5–10 years has demonstrated that secondary poisoning, particu-
                                     larly of raptors such as Bald Eagles (Haliaeetus leucocephalus), is a significant
                                     source of mortality in many places. In the United States and in Canada, for ex-
                                     ample, secondary lead poisoning accounts for 10-15% of the recorded post-
                                     fledging Bald Eagle mortality. Similar facts have now been documented in
                                     many locations in Europe and North America in various other raptor species as
                                     well, including Golden Eagles (Aquila chrysaetos), Northern Goshawks (Ac-
                                     cipiter gentilis), Peregrine Falcons (Falco peregrinus), White-tailed Eagles
                                     (Haliaeetus albicilla) and European Sparrowhawks (Accipiter nisus). Many
                                     free-living raptor species for which secondary poisoning has not yet been
                                     documented nevertheless risk this type of poisoning as a direct consequence of
                                     their preferred feeding habits. Also, sublethal lead exposure contributes to mor-
                                     tality from other causes. ([Beintema 2001] - whole paragraph)


                                     2.1.3 Effects of dissolved lead on the biota
                                     Besides the effects on birds and raptors in general no reported environmental
                                     effects has been ascribed to poisoning by lead from shot and sinkers. It can
                                     based on the present knowledge, however, not be excluded that some harmful
                                     effects could arise from the occurrence of lead in soil and water; in particular in
                                     combination with the effects of other chemical substances or other stress fac-
                                     tors. Of particular concern is clay target shooting ranges in which significant
                                     quantities of lead is deposited.




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Fate of lead shot and                When metallic lead in the form of spent shot is exposed to air or water, lead
sinkers in soil                      oxides, carbonates and other compounds are produced by weathering of the pel-
                                     lets. Analyses of spent lead shot pellets collected from target shooting ranges in
                                     Canada and Denmark have shown pellets to be visibly corroded and covered
                                     with a crust of white, grey or brown material [Scheuhammer and Norris 1995].
                                     The rates of erosion, oxidation, and dissolution of metallic lead pellets in the
                                     environment depend on various physical and chemical factors. Aerobic, acidic
                                     conditions enhance the rate of pellet breakdown, whereas anaerobic, alkaline
                                     conditions decrease it. Physical factors such as high water flow rates, soils or
                                     sediments dominated by the presence of coarse sand or gravel, and frequent
                                     disturbance of contaminated soils all serve to enhance the rate of lead pellet
                                     breakdown. Dependent on chemical and mechanical conditions the shot pellets
                                     will be totally corroded within tens to hundreds of years. This process can re-
                                     sult in local lead concentrations in soils and water far in excess of normal con-
                                     centrations, which can form a risk factor for all trophic levels: lead transferred
                                     to soil and sediment invertebrates and terrestrial and aquatic plants will ulti-
                                     mately affect entire food webs [Beintema 2001]. High local concentrations are
                                     mainly associated with shooting ranges with a high load of lead.

                                     Lead is in general not very mobile in soil. Soil pH, content of humic acids, and
                                     amount of organic matter influences the content and mobility of lead in soils.
                                     Only a very small portion of the lead in soil is present in the soil solution,
                                     which is the immediate source for lead for plant roots, but soil acidification will
                                     lead to increased mobility and bioavailability of lead. More acid conditions
                                     (lower pH) not only increase the solubility of lead, but also other heavy metals.
                                     In Europe major differences exist among regions as to soil acidity. In the north-
                                     ern Member States like Denmark, Sweden and Finland the soil in general have
                                     lower pH than in Member States with soils with a high alkalinity like France
                                     and the U.K. [Hansen et al. 2002]. This result in regional differences in heavy
                                     metals mobility in soils and influences the assessments of the environmental
                                     impact of heavy metal load to soil.

                                     Due to the binding capacity of the soil minerals and humus, groundwater usu-
                                     ally contains very low concentrations of lead, and the diffusion of lead from
                                     and the top soil layers to the groundwater must be expected to be a relatively
                                     slow process. This again results in that lead added to the top soil layers, e.g. as
                                     lead shot, generally will accumulate in the top soil layer.

                                     The significance of this accumulation depends on the actual load of lead to the
                                     soil as well as the content of lead already present. This issue in particular re-
                                     lates to ammunition (reference is made to section 3.7.2).

Effects in the ter-                  The tendency of inorganic lead, to form highly insoluble salts and complexes
restric environment                  with various anions together with its tight binding to soils, drastically reduces
                                     its availability to terrestrial plants via the roots. Lead is taken up by terrestrial
                                     plants through the roots and to a lesser extent through the shoots [WHO 1989].

                                     According to [Davies and Thornton 1989] a positive linear relationship exists
                                     between lead concentrations in plant and soil for a wide range of uncontami-
                                     nated and contaminated soils. At higher soil lead levels, however, plant uptake


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                                     has been found to decline with increasing soil lead concentrations and a curvi-
                                     linear relationship has been reported [Davies and Thornton 1989].

                                     Translocation of the ion in plants is limited and most bound lead stays at root or
                                     leaf surfaces. As a result, in most experimental studies on lead toxicity, high
                                     lead concentrations in the range of 100 to 1,000 mg/kg soil are needed to cause
                                     visible toxic effects on photo synthesis, growth, or other parameters. Thus, lead
                                     is only likely to affect plants at sites with very high environmental concentra-
                                     tions [WHO 1989].

                                     Ingestion of lead-contaminated bacteria and fungi by nematodes leads to im-
                                     paired reproduction. Caterpillars that are maintained on a diet containing lead
                                     salts show symptoms of toxicity leading to impaired development and repro-
                                     duction. The information available is too meagre to quantify the risks to inver-
                                     tebrates during the decomposition of lead-contaminated litter [WHO 1989].

                                     Effects on micro-organisms are reported from soil lead concentrations down to
                                     10 mg/kg, but for most organisms effects starts at 50-100 mg/kg [Scott-
                                     Fordsmand et al 1995].

Fate of lead shot and                Lead in the aquatic environment is strongly adsorbed onto sediment and soil
sinkers in the aquatic               particles reducing its availability to organisms. Because of the low solubility of
environments                         most of its salts, lead tends to precipitate out of complex solutions.

                                     Lead lost as shot and sinkers is in metallic form and, contrary to lead from at-
                                     mospheric deposition and waste water, not readily available to organisms. Over
                                     time the lead can be dissolved - probably e.g. as lead oxides - and therefore be
                                     available, but the extent and rate at which this occurs are not known in detail.

                                     The fate of lead shot and sinkers in the aquatic environments is highly depend-
                                     ent on the chemistry of the water and mechanical disturbances. Highest corro-
                                     sion rates are expected in rivers with acidic water and high velocity whereas
                                     low rates are expected in sedimentation areas in the marine environment. Rela-
                                     tively high corrosion rates of about 1% per year have e.g. been demonstrated on
                                     lead sinkers in Swedish rivers (pH 6.3-6.7) with a high velocity [Jacks & By-
                                     stöm 1995]. The study does not demonstrate to what extent the sinkers contrib-
                                     ute to the lead concentration of the river water. Lakes may be considered sinks
                                     in which the sinkers accumulate in the anoxic part of the sediment.

                                     In the marine environment lead sinkers in the wave zone and sinkers fixed to
                                     e.g. pound nets on low water is highly exposed to wear whereas the sinkers lost
                                     in sedimentation zones must be expected to move into the anoxic part of the
                                     sediment in which the corrosion is extremely slow.

                                     Lead will tend to accumulate in the anoxic zones of the sedimentation areas -
                                     probably e.g. as lead sulphides - and over time be buried and not be available
                                     for the bottom living biota. It means that the sediments act like a sink for the
                                     lead. At that point the fate of lead in the aquatic environment differs signifi-
                                     cantly from the fate of lead in soil. In the soil (or more widely in the terrestrial
                                     environment) the lead will accumulate and for hundreds or thousands of years


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                                     be available for the biota or be released to surface waters or ground water re-
                                     sources.

Effects of lead in the               Lead dissolved in water can be taken up by the organisms and some organisms
aquatic environment                  can concentrate lead compared to their surroundings, but magnification of lead
                                     through the food chains (bio magnification) have not been reported.

                                     The following information has largely been extracted from [WHO 1989] unless
                                     otherwise indicated.

                                     Lead is unlikely to affect aquatic plants at levels that might be found in the
                                     general environment.

                                     In communities of aquatic invertebrates, some populations are more sensitive
                                     than others and community structure may be adversely affected by lead con-
                                     tamination. However, populations of invertebrates from polluted areas can
                                     show more tolerance to lead than those from non-polluted areas. In other
                                     aquatic invertebrates, adaptation to low oxygen conditions can be hindered by
                                     high lead concentrations. Young stages of fish are more susceptible to lead than
                                     adults or eggs. Typical symptoms of lead toxicity include spinal deformity and
                                     blackening of the tail region. The maximum acceptable toxicant limit for solu-
                                     ble species of inorganic lead has been determined for several species under dif-
                                     ferent conditions and results ranging from 0.04 mg/litre to 0.198 mg/litre. Or-
                                     ganic compounds are more toxic to fish than inorganic lead salts. There is evi-
                                     dence that frog and toad eggs are sensitive to nominal lead concentrations of
                                     less than 1.0 mg/litre in standing water and 0.04 mg/litre in flow-through sys-
                                     tems; arrested development and delayed hatching have been observed. For adult
                                     frogs, there are no significant effects below 5 mg/litre in aqueous solution, but
                                     lead in the diet at 10 mg/kg food has some biochemical effects.

                                     Fish eggs show increasing lead levels with increased exposure concentration,
                                     and there are indications that lead is present on the egg surface but not accumu-
                                     lated in the embryo. In contrast to inorganic lead compounds, tetra alkyl-lead is
                                     rapidly taken up by fish and rapidly eliminated after the end of the exposure.

                                     In communities of aquatic invertebrates, some populations are more sensitive
                                     than others and community structure may be adversely affected by lead con-
                                     tamination. However, populations of invertebrates from polluted areas can
                                     show more tolerance to lead than those from non-polluted areas. In other
                                     aquatic invertebrates, adaptation to hypoxic conditions can be hindered by high
                                     lead concentrations.

                                     Young stages of fish are more susceptible to lead than adults or eggs. Typical
                                     symptoms of lead toxicity include spinal deformity and blackening of the cau-
                                     dal region. The maximum acceptable toxicant limit (MATC) for inorganic lead
                                     has been determined for several species under different conditions and results
                                     range from 0.04 mg/litre to 0.198 mg/litre. The acute toxicity of lead is highly
                                     dependent on the presence of other ions in solution, and the measurement of
                                     dissolved lead in toxicity tests is essential for a realistic result. Organic com-
                                     pounds are more toxic to fish than inorganic lead salts.


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                                     There is evidence that frog and toad eggs are sensitive to nominal lead concen-
                                     trations of less than 1.0 mg/litre in standing water and 0.04 mg/litre in flow-
                                     through systems; arrested development and delayed hatching have been ob-
                                     served. For adult frogs, there are no significant effects below 5 mg/litre in
                                     aqueous solution, but lead in the diet at 10 mg/kg food has some biochemical
                                     effects.


                                     2.2            Health impact
                                     Human health issues related to the use lead in shot and sinkers can be divided
                                     into two aspects:

                                     •      Secondary poisoning by consumption of game;
                                     •      Effects of a general increase of lead in the environment.

Effect of lead                       In humans, lead can result in a wide range of biological effects depending upon
                                     the level and duration of exposure. Effects may range from inhibition of en-
                                     zymes to the production of marked morphological changes and death. Such
                                     changes occur over a broad range of doses. For neurological, metabolic and be-
                                     havioral reasons, children are more vulnerable to the effects of lead than adults.
                                     Signs of serious lead intoxication include paralysis of the hands, anaemia, wast-
                                     ing of the upper chest muscles, weakness in limbs, and neurological signs

                                     Of particular concern for the general population is the effect of lead on the cen-
                                     tral nervous system. Epidemiological studies suggest that low level exposure of
                                     the foetus and developing child may lead to reprotoxic effects, i.e. damage to
                                     the learning capacity and the neuropsychological development. Studies of chil-
                                     dren indicate a correlation between higher lead contents in the blood and a
                                     lower IQ. Slowing of nerve conduction velocity has been found at low lead
                                     blood levels. Impairment of psychological and neurobehavioral functions has
                                     also been found after long-term lead exposure of workers.

                                     WHO has established a PTWI (Provisional Tolerable Weekly Intake) value for
                                     lead of 25 µg/kg bodyweight for both adults and children [WHO 1995]. The
                                     PTWI represents the average weekly intake of lead considered to be safe over a
                                     lifetime of exposure.

Lead in petrol                       Organic lead is more bioavailable and toxic than inorganic lead. The primary
                                     source of organic lead, and the primary source of the exposure of the general
                                     population, has been leaded petrol which is now phased out from the market in
                                     the EU.

Lead shot in game                    According to [Beintema 2001] and [Scheuhammer and Norris 1995] lead
                                     poisoning in waterfowl and other game animals can form a health risk to hu-
                                     mans. Consumption of game killed with lead shot can result in lead exposure
                                     and intoxication. This can happen either through ingestion of tissues from lead-
                                     exposed or lead-poisoned animals that have biologically accumulated higher
                                     than normal concentrations of lead, or through ingestion of tissues containing
                                     fragments of metallic lead or lead shot pellets themselves.



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                                     While lead concentrations in muscle tissue of wildfowl are generally
                                     considered harmless to human health when not exceeding 0.5 mg/kg, scientists
                                     from Canadian Wildlife Service scientists observed that 15% of 227 breast
                                     muscle samples from waterfowl killed with lead shot contained lead at concen-
                                     trations higher than 0.5 mg/kg. Lead concentrations in these muscle samples
                                     ranged as high as 759 mg/kg [Scheuhammer and Norris 1995].

                                     Increased lead exposure and intoxication in humans can also occur as a result
                                     from retention of lead shot pellets, most often in the appendix. A Danish study
                                     [Madsen et al 1988] quoted by [Scheuhammer and Norris 1995] reports in-
                                     creased blood level concentrations for persons having 1 or 2 lead shot in their
                                     appendices compared to a control group without shot retention (11.4 and 6.0
                                     µg/dL, respectively). In Canada, one study [Reddy 1985] quoted by [Scheu-
                                     hammer and Norris 1995] reported that 62 patients seen in a Newfoundland
                                     hospital had from 1 to over 200 retained lead shot in their appendices. [Hillman
                                     1967] quoted by [Scheuhammer and Norris 1995] discussed a woman having
                                     signs of serious lead intoxication prior to the discovery of more than a dozen
                                     lead shot pellets in her appendix, which was subsequently removed, leading to
                                     the gradually recovery of the patient over the cause of a year.

Lead in food                         In the general non-smoking adult population, the major exposure pathway for
                                     lead today is from food and water. The question is to what extent increased lead
                                     concentration in the terrestric and aquatic environments (e.g. by accumulation
                                     of spread lead shot) may increase the exposure to lead from food.

                                     In foods, lead may originate from atmospheric dust deposition on fruits, vege-
                                     tables grains and contamination via environmental origin of meat, seafood or
                                     fishes. Lead is present on plant surfaces as a result of atmospheric deposition.
                                     Traditionally the major source of lead on plant surfaces has been lead in the air
                                     originating from the use of leaded gasoline. Biological uptake from the soil or
                                     leaves may also occur as indicated by the presence of lead in internal tissues.
                                     However, a reduced atmospheric deposition will in the shorter time perspective
                                     be more significant than an increasing content of lead in soil. From the positive
                                     relationship between lead concentrations in plant and soil mentioned in section
                                     2.1.3 follows that increasing content of lead in agricultural soils by time may
                                     lead to increasing content of lead in plants used for food.

                                     Lead is not biomagnified in terrestrial and aquatic food chains. Biomagnifica-
                                     tion seems limited to phytoplancton or to filtering organisms such as mussels or
                                     oysters. In aquatic organisms, more lead is found in benthic organisms and al-
                                     gae than in upper trophic level predators.

                                     Concern about the potential environmental and health effects of a general in-
                                     crease of the lead concentration in the environment is one of the drivers behind
                                     the Danish ban on lead trade [Brønnum and Hansen 1998]. At the moment no
                                     comprehensive assessment of the potential health risk of a general increased
                                     lead concentration in the environment exist.

Lead intake from soil                A particular problem concerns children's intake of lead from soil and dust. For
and dust                             infants and young children lead in dust and soil often constitutes a major expo-


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                                     sure pathway and this exposure has been one of the main concerns as to the ex-
                                     posure of the general population. The intake of lead will be influenced by the
                                     age and behavioural characteristics of the child and the bioavailability of lead in
                                     the source material. It is, however, not likely that shot and sinkers in general
                                     will be used in areas, where children in present, and thus not likely that lead in
                                     shot and sinkers will add significantly to the lead content of soil and dust taken
                                     in by children.




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                                     3              Ammunition

                                     3.1            Application of lead in cartridges
Application                          Cartridges containing lead can be divided in:

                                     •      Lead shot;
                                     •      Airgun pellets;
                                     •      Bullets.

                                     The application of these types of cartridges may be briefly presented as follows.

                                     Shot is used in particular for hunting and competition. The same applies to bul-
                                     lets, for which military purposes, however, also is an important application.
                                     Pellets are used primarily for amusement and competition, but in a few coun-
                                     tries also for hunting. Pellets are not indicated separately in the EU statistics on
                                     production, import and export of cartridges, but are registered together with
                                     shotgun cartridges (reference is made to Annex 3).

Consumption of lead                  Information on the use of lead for production of shot and ammunition in
                                     France, Germany, Italy, Spain and the U.K. is shown in Table 3.1 and illus-
                                     trated in Figure 3.1. Lead is formed into spherical lead shot to be used as am-
                                     munition, or added to certain steel alloys to improve the steel machinability
                                     (steelmaking shot). According to [OECD 1993] shot for steel alloys in 1990
                                     accounted for 20% of the total used for ammunition and shot with a declining
                                     trend. Is has not been possible to obtain specific data on lead use in the other
                                     EU countries. As indicated the market of lead for production of shot and am-
                                     munition in the EU should be considered rather stable. The total consumption
                                     of lead for ammunitions manufacturing in EU15 including all countries is in
                                     table 2.8 estimated at approximately 53,000 tonnes/year (average of 2000-
                                     2003).

                                     Table 3.1             Consumption of lead for production of shot and ammunition in France,
                                                           Germany, Italy, Spain and the UK. 1993-2001[ILZSG 2004]

                                                                                   Consumption (1000 t)
                             1992          1993         1994          1995           1996      1997       1998   1999   2000   2001
France                         7.0          7.9           8.0          6.5            8.0       7.0       7.5    7.3    7.0    7.0
Germany                       11.9         13.2          14.4         14.7            14.       14.6      13.6   13.4   13.3   13.3
Italy                         19.1         23.5          21.9         23.7           23.6       24.6      26.4   23.1   21.6   16.3
Spain                          5.0          4.5           4.0          5.0            5.0       5.0       5.5    5.5    5.5    5.5
UnitedKingdom                 3.2           3.5           3.5          5.5            5.2       5.3       5.6    5.3    6.5    5.7
Total 5 countries             45.7         52.6          51.8         55.4           55.8       56.5      58.6   54.6   53.9   47.8




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                                     Figure 3.1                             Consumption of lead for production of shot and ammunition in France,
                                                                            Germany, Italy, Spain and the UK. 1993-2001

                                                                   70000                                                              UK



                                       Lead consumption (t/year)
                                                                   60000                                                              Spain
                                                                                                                                      Italy
                                                                   50000
                                                                                                                                      Germany
                                                                   40000                                                              France
                                                                   30000

                                                                   20000

                                                                   10000

                                                                      0
                                                                           1992 1993 1994 1995 1996 1997 1998 1999 2000 2001




                                     3.2                               Markets of cartridges

                                     3.2.1 Available information
No detailed records                  The statistical data available for the EU regarding production, export and im-
available                            port of ammunition by Member States is presented in Annex 3 (table A3.1-
                                     A3.17). The data does not indicate the amount of lead used in production of
                                     sporting and hunting ammunition or the amount of lead consumed by sports
                                     shooters and hunters.

                                     It is noted that the PRODCOM commodity code 29.60.14.30 (reference is made
                                     to table A3.1) records "production, import and export of cartridges and parts
                                     hereof for shotguns, revolvers, pistols, rifles, carbines and military firearms,
                                     slugs, pellets and darts". The fact that this database includes ammunition for
                                     military firearms implies that the database is not an appropriate source of in-
                                     formation, as the share of military to civilian ammunitions production is not
                                     known. Furthermore, the commodity code is too aggregated to be of any use in
                                     this respect.

                                     No other statistical data directly covering these issues seems to be available.

                                     The Association of European Manufacturers of Sporting Ammunition
                                     (AFEMS) - reference is made to section 3.2.4 - has been contacted and has
                                     kindly provided a significant part of the information presented and utilised in
                                     the following sections inclusive figures on the total consumption of ammuni-
                                     tion for sporting and hunting in Europe. However, the Association has not been
                                     able to provide information on the amount of lead used and the number of car-
                                     tridges produced by the individual members of the Association as this informa-
                                     tion is considered confidential. As the Association among its members includes
                                     the dominant part of European manufacturers of ammunition - the list of mem-
                                     bers is presented in table 3.10 while the estimated coverage of manufacturing
                                     activities in Europe is indicated in table 3.11 - it has been deemed as not realis-




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                                     tic to obtain figures on the consumption and production of lead ammunition for
                                     sporting and hunting in the various Member States by direct contact to industry.

                                     In stead the choice has been made to estimate these data indirectly based on the
                                     total number of cartridges used in the EU, the number of hunters and shooters
                                     registered in each country and the content of lead in cartridges combined with
                                     statistical information on import and export of lead data to the individual coun-
                                     tries.


                                     3.2.2 Lead consumption by shooters and hunters
Aggregate consump-                   The Association of European Manufacturers of Sporting Ammunition
tion                                 (AFEMS) has provided aggregate data on the annual consumption of ammuni-
                                     tion in the EU15 area. These data that is assumed to describe the consumption
                                     pattern about 2003 have been summarised in the table below.

                                     Table 3.2             Number of cartridges/rounds consumed by sports shooters and hunters
                                                           in the EU15 area annually [AFEMS 2004a]

                                     Cartridge type                                         Shooters                             Hunters
                                     Shotgun 1)                                          640,000,000                         560,000,000
                                     Rim fire                                            500,000,000                                    0
                                     Centre fire rifle                                    33,000,000                          22,000,000
                                     Pistol/revolver                                     178,200,000                                    0
                                     Total cartridges                                  1,351,000,000                         582,000,000
                                     Air gun pellets                                   2,400,000,000                                    0
                                     1)             According to AFEMS hunters and shooters consume an equal amount of shotgun car-
                                                    tridges annually. Some 6% of the total consumption is based on substitute metals (non-
                                                    lead alternatives), and it is assumed that these 6% are used entirely by hunters. Hence the
                                                    difference between hunters and shooters for this particular item.


Lead content, shot-                  According to the International Shooting Sport Federation (ISSF) [ISSF 2004b]
gun cartridges                       rules for skeet and trap shooting the lead content of a cartridge used for interna-
                                     tional competitions must not exceed 24 grams. A survey of European manufac-
                                     turers however indicates that gauge 12 cartridges (the most commonly used
                                     shotgun calibre) is widely marketed in 28 grams and 32 grams versions as well,
                                     with the 28 grams version being the most strongly marketed. The metal used
                                     for this purpose may contain 95%-100% lead, as certain hardeners are some-
                                     times added (up to 5% antimony or similar). 26 grams as an average is the
                                     AFEMS estimate [AFEMS 2004a].

                                     Shotgun cartridges used for hunting normally contains relatively more lead,
                                     although the variation in the marketed products is considerably higher as com-
                                     pared to sports shooting cartridges. For gauge 12 the lead content ranges
                                     roughly between 25 grams up to 50 grams or even more, as hunting cartridges
                                     tend to be marketed for dedicated purposes (different kinds of game). 32 grams
                                     as an average for all hunting shotgun cartridges is the AFEMS estimate
                                     [AFEMS 2004a].




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Lead content, rim                    Rim fire cartridges are, according to [AFEMS 2004a], only used for sporting
fire cartridges                      purposes and mainly cover ammunition for calibre .22 (5.6 mm) guns. Accord-
                                     ing to ISSF rules, rim fire calibre .22 ammunition is used within the disciplines
                                     of rapid fire pistol, 25 m pistol and standard pistol, 50 m pistol and 50 m rifle
                                     (including running target).

                                     A survey of European manufacturers indicates that the weight of the bullet of a
                                     calibre .22 cartridge generally ranges between 30 and 40 grains1. The AFEMS
                                     estimate [AFEMS 2004a] of the lead content of an average rim fire cartridge is
                                     2.4 grams.

Lead content, centre                 Centre fire rifle cartridges for sports shooting are used in the ISSF-discipline of
fire cartridges                      300 m rifle (calibres of up to 8 mm)

                                     The AFEMS estimate [AFEMS 2004a] of the average lead content of a car-
                                     tridge in this category is 7 grams (125-185 grains) and is based on weight dis-
                                     tributions of 6.5 mm, 7.65 mm and WIN 308 rifle cartridges. A similar estimate
                                     is made for centre fire cartridges used for hunting.

Lead content, pis-                   Cartridges for pistol and revolver are according to AFEMS almost entirely used
tol/revolver car-                    for sporting purposes. The relevant ISSF-discipline is centre fire pistol (calibres
tridges                              between 7.62 and 9.65 mm)

                                     The category may, however, also cover a number of shooting disciplines that
                                     are not Olympic disciplines. Furthermore, most ISSF pistol disciplines uses .22
                                     rim fire ammunition (described above) and it is therefore for practical reasons
                                     assumed that consumption for these purposes is covered separately under the
                                     rim fire cartridge category. The AFEMS estimate [AFEMS 2004a] of the aver-
                                     age lead content of a cartridge within the pistol/revolver category is 7 grams.

                                     Table 3.3             Estimated lead content of an average cartridge [AFEMS 2004a]

                                     Cartridge type (user type)                             Lead content (grams) per cartridge
                                     Shotgun (shooting)                                                    26
                                     Shotgun (hunting)                                                     32
                                     Rim fire (shooting)                                                   2.4
                                     Centre fire rifle (shooting)                                           7
                                     Centre fire rifle (hunting)                                            7
                                     Pistol/revolver (shooting)                                             7
                                     Air gun pellets (shooting)                                            0.5




Lead content, air gun                Air gun pellets are according to AFEMS used solely for sports shooting, and
pellets                              covers various sports disciplines. The prevailing calibre is .177, and a market
                                     survey indicates that pellets for this calibre ranges between 5 and 10 grains.
                                     Hence the AFEMS estimate [AFEMS 2004a]of the lead content is 0.5 grams

                                     1
                                         1 grain (gr) = 0.00006479891 kilogram (kg) according to [EX 2004]


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                                     per pellet. It may be noted that air gun pellets according to [Lecocq 2004] to
                                     some extent also is used for hunting, in particular, in the UK. However, as the
                                     quantity used for hunting cannot be quantified and likely is small, the choice is
                                     made in this study to assume that air gun pellets only are used for sports shoot-
                                     ing. The estimates are summarised in table 3.3 above.

Number of users                      The number of ammunition users (sports shooters and hunters) has been quoted
                                     from an inventory prepared in 1995 (see table 3.4 below).

                                     Table 3.4             Estimated number of shooters and hunters in the EU15 area and in se-
                                                           lected new Member States (1995)

                                                                                              Shooters                          Hunters
                                     Austria                                                    60,000                          110,000
                                     Belgium                                                    25,000                           29,000
                                     Denmark 1)                                                 50,000                          177,000
                                     Finland                                                    40,000                          300,000
                                     France                                                    150,000                        1,650,000
                                     Germany                                                 1,450,000                          326,000
                                     Greece                                                       7,000                         293,000
                                     Italy                                                      40,000                          925,000
                                     Ireland 2)                                                 10,000                          120,000
                                     Luxembourg                                                   4,000                            2,200
                                     Netherlands                                                33,000                            33,500
                                     Portugal                                                   13,500                          300,000
                                     Spain                                                     100,000                        1,000,000
                                     Sweden                                                     70,000                          320,000
                                     UK                                                        550,000                          625,000
                                     EU15 total                                              2,602,500                        6,210,700
                                     Hungary                                                      2,000                          50,000
                                     Lithuania                                                  10,000                           27,000
                                     Poland                                                     20,000                          107,000
                                     Source         [AFEMS 2004a] quoting 1995 data from the Federation of Associations for Hunting and
                                                    Conservation of the EU (FACE) and European Shooting Confederation (ESC); [Rinkevicius
                                                    2004; Andruszkiewicz et al 2004; Varkonyi 2004 ]
                                     1)             According to the original 1995 ESC inventory of shooters, no shooters are registered in
                                                    Denmark and Ireland. Number of shooters in Denmark is therefore based on information
                                                    from [Danmarks Skytteunion 2004]. It has not been possible to obtain similar information
                                                    for Ireland, so the number of shooters is estimated (very roughly) based on the number of
                                                    inhabitants (3.9 million).


Estimated consump-                   The consumption of lead for EU15 in total as well as the individual Member
tion of lead                         States is estimated in table 3.5 based on the data presented in table 3.2 - 3.4.
                                     The total consumption for EU15 for each type of cartridge is calculated by
                                     combining table 3.2 and table 3.3, while the distribution on the Member States
                                     finally is calculated by distributing the totals on the Member States according
                                     to the estimated number of shooters and hunters. As this distribution assumes



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                                     identical use patters for shooters and hunters across countries - an assumption
                                     that is probably not correct - the figures for Member States should be regarded
                                     as less reliable than the figures for EU15 in total.

                                     Table 3.5             Estimated consumption of lead about 2003 in ammunition for sports
                                                           shooting and hunting in EU15 and selected new Member States, all
                                                           numbers indicated in tonnes




                                                               shooting
                                                               Shotgun


                                                                            hunting
                                                                            Shotgun


                                                                                          shooting
                                                                                          Rim fire


                                                                                                         shooting
                                                                                                         Centre fire


                                                                                                                           hunting
                                                                                                                           Centre fire


                                                                                                                                             ing
                                                                                                                                             Pistol shoot-


                                                                                                                                                                 shooting
                                                                                                                                                                 Air gun


                                                                                                                                                                                Total 4)
                                       Austria                     384             343          28                     5                 3             29              28                  800
                                       Belgium 2)                  160              72          12                     2                 1             12              12                  250
                                       Denmark 1)                  320                0         23                     4                 4             24              23                  400
                                       Finland 2)                  256             749          18                     4                 7             19              18           1,100
                                       France                      959        5,146             69               13                41                  72              69           6,400
                                       Germany                   9,271        1,017           669              129                       8          695              669        12,500
                                       Greece                        45            914               3                 1                 7                   3              3       1,000
                                       Ireland                       64            374               5                 1                 3                   5              5              450
                                       Italy                       256        2,885             18                     4           23                  19              18           3,200
                                       Luxembourg                    26               7              2                 0                 0                   2              2               50
                                       Netherlands 1)               211               0         15                     3                 1             16              15                  250
                                       Portugal                      86            936               6                 1                 7                   6              6       1,000
                                       Spain                       639        3,119             46                     9           25                  48              46           3,900
                                       Sweden 2)                   448             798          32                     6                 8             34              32           1,400
                                       UK 2)                     3,517        1,560           254                49                15               264              254            5,900
                                       EU15 total               16,640      17,920          1,200              231               154            1,247              1,200        38,600
                                       Hungary 3)                    13            156               1                 0                 1                   1              1              150
                                       Lithuania 3)                  64            84                5                 1                 1                   5              5              150
                                       Poland 3)                   128             334               9                 2                 3             10                   9              500
                                     Source         Own calculations - reference is made to the text
                                     1)             Denmark and the Netherlands have applied full ban on the use of lead containing shotgun
                                                    ammunition for hunting since mid 90'ies, and consumption of lead for shotgun hunting
                                                    therefore has been set at 0 for these two countries.
                                     2)             A number of countries apply a partial ban on the use of lead containing shotgun ammuni-
                                                    tion for hunting (wetlands areas, national reserves or other especially dedicated areas). In-
                                                    formation on this has been provided through the questionnaires. For these countries it has
                                                    therefore been estimated that the consumption of lead is some 20% lower than average
                                                    EU level.
                                     3)             Consumption of lead for sports shooting and hunting in Hungary, Lithuania and Poland has
                                                    been estimated assuming use patterns similar to the EU15 average
                                     4)             All figures are rounded.


                                     The assessment of the assumption of identical use patterns as probably not cor-
                                     rect is based on it is likely for example that certain sporting disciplines are
                                     more popular in some countries as compared to other countries. Hunting tradi-


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                                     tions may also differ quite substantially from one country to the other. National
                                     and regional variations in use patterns throughout Europe have thus not been
                                     accounted for, as no information on this topic has been available.

                                     Despite these limitations the estimated figures for the Members States still indi-
                                     cate a likely order of magnitude of the consumption in each country. It may be
                                     noted that AFEMS deems the consumption figure for Germany as to high
                                     which may be caused by that most of the registered sports shooters in Germany
                                     actually are air gun shooters [AFEMS 2004a].


                                     3.2.3 Lead consumption by ammunitions manufacturing
Model calculations                   In lack of direct data from the industry on the amount of lead used for
                                     manufacturing of ammunition the choice has been made to estimate these fig-
                                     ures based on the figures estimated in table 3.5 for consumption of lead in
                                     EU15 in total and in the Member States combined with statistical data from the
                                     EU COMEXT database on export and import to and from the Member States
                                     (reference is made to Annex 3).

                                     Basically, the amount of lead used in domestic ammunitions manufacturing can
                                     be estimated using the following equation:

                                     [Consumption for manufacturing] = [domestic consumption by users] + [export
                                     (intra+extra EU)] - [import (intra+extra EU)].

COMEXT data                          The relevant COMEXT nomenclature for civilian ammunitions manufacturing
                                     includes three separate listings:

                                     •      9306 21 00: Cartridges for smooth-barrelled shotguns including air gun
                                            pellets;
                                     •      9306 30 91: Centre fire cartridges;
                                     •      9306 30 93: Rim fire cartridges.

                                     Table 3.6             Transition from AFEMS to general COMEXT nomenclature

                                     AFEMS nomenclature               Corresponding nomenclature of COMEXT            Weight distribution,
                                                                                                                      lead component to
                                                                                                                       overall cartridge 1)
                                     Shotgun, shooters                Smooth-barrelled shotguns and air gun pellets           72.50%
                                     Shotgun, hunters                 Smooth-barrelled shotguns and air gun pellets           72.50%
                                     Air gun pellets                  Smooth-barrelled shotguns and air gun pellets          100.00%
                                     Centre fire, shooting            Centre fire                                             70.00%
                                     Centre fire, hunting             Centre fire                                             70.00%
                                     Pistol/revolver shooting         Centre fire                                             65.00%
                                     Rim fire shooting                Rim fire                                                70.00%
                                     1)             [AFEMS 2004a]




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                                     As the calculations use the estimated consumption by users as its basis, it is
                                     necessary to harmonise the classification schemes of the AFEMS nomenclature
                                     (see Table 3.2) and the relevant COMEXT nomenclature. Table 3.6 above out-
                                     lines the correspondence between the two systems that has been applied in the
                                     subsequent calculations.

Weight components                    The COMEXT databases provide data in tonnes import/export of the relevant
                                     items. The weights applied under this system, however, incorporates the weight
                                     of the complete, finished product (the cartridge) including packaging. The
                                     weight component of the lead content in an average cartridge relative to the
                                     weight of the entire cartridge has been provided by AFEMS and is indicated in
                                     the right-most column in the table above.

                                     This information has been combined so as to yield a weighted average of the
                                     lead contents in the import/export figures recorded in the COMEXT database.
                                     A further 5% deduction has been made for the additional weight of the packag-
                                     ing.

                                     Table 3.7             Estimated relative weight of lead content in items covered by the rele-
                                                           vant COMEXT classifications

                                       EU nomenclature                             Estimated lead to cartridge     Adjusted incl. 5% packaging
                                                                                         distribution 1)
                                       Smooth barrelled shotguns and air                    73.38%                            69.71%
                                       gun pellets (9306 21 00)
                                       Centre fire (9306 30 91)                             66.53%                            63.20%
                                       Rim fire (9306 30 93)                                70.00%                            66.50%
                                     1)             The distribution is based on the weight distribution for cartridges indicated in table 3.6
                                                    weighted according to the calculated consumption patterns in EU15 stated in table 3.5.


Adjustments for                      The COMEXT database classification on cartridges for smooth-barrelled shot-
hunting shotgun                      guns and air gun pellets includes lead as well as non-lead shot. According to
ammunition                           AFEMS, some 6% of the shotgun ammunition used in the EU is based on a
                                     non-lead alternative [AFEMS 2004a]. It has been assumed that the same rela-
                                     tive share can be applied to the import/export figures (the part, which specifi-
                                     cally covers shotgun ammunition for hunting), and the COMEXT data has been
                                     adjusted accordingly.

                                     Furthermore, from the country questionnaires it has been established that two
                                     (Denmark and Netherlands) out of the 15 EU countries apply a full ban on lead
                                     containing shotgun ammunition for hunting. Similarly, is has been established
                                     that another 4 countries (Belgium, Finland, Sweden and UK) applied a partial
                                     ban, typically in wetland areas or other areas of particular interest.

                                     It must be assumed that Denmark and Netherlands do not import or export lead
                                     containing shotgun ammunition for hunting purposes at all, and similarly that
                                     Hungary, Finland, Sweden and UK import and export an amount of shotgun
                                     ammunition for hunting, which is below the EU average. The COMEXT data
                                     has been adjusted accordingly.



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Use of lead for am-                  The above information and assumptions have been combined so as to yield in
munitions manufac-                   overall estimate of the amount of lead used in the 15 EU countries for sports
turing                               shooting and hunting ammunitions manufacturing. Specifically, two break-
                                     downs have been provided as presented in table 3.8 and 3.9.

                                     Table 3.8             Estimated use of lead for ammunitions manufacturing in EU15 and se-
                                                           lected new Member States, average for 2000-2003, breakdown by
                                                           COMEXT nomenclature, all figures in tonnes lead per year

                                     Country                Shotgun and air               Centre fire             Rim fire                Total 1)
                                                                      gun
                                     Austria                              490                     48                   24                 550 2)
                                     Belgium                              311                    -26                     6                    300
                                     Denmark                             -113                    -43                   -27                -200 2)
                                     Finland                              606                    127                   51                     800
                                     France                             5,859                   -177                   -91                  5,600
                                     Germany                           10,440                    616                  776                  11,900
                                     Greece                               712                      9                    -7                    750
                                     Ireland                              195                      8                     4                200 2)
                                     Italy                             13,098                  1,097                   -24                 14,150
                                     Luxembourg                             24                    -2                    -9                   0 2)
                                     Netherlands                          211                    -18                     6                200 2)
                                     Portugal                             204                      1                     0                    150
                                     Spain                              7,901              2,262 4)                     -2                 10,100
                                     Sweden                             1,573                     48                   32                   1,700
                                     UK                                 5,768                    318                  417                   6,500
                                     Total EU15                        47,281                  4,269                1,156                  52,700
                                     Hungary 3)                         1,167                      3                    -3                  1,150
                                     Lithuania 3)                         134                      1                     3                    100
                                     Poland 3)                            397                    -21                    -8                    400
                                     Source         Calculated as described in the text
                                     1)             Figures are rounded
                                     2)             According to AFEMS [AFEMS 2004a] no production are known to take place in Austria,
                                                    Denmark, Ireland, Luxemburg and the Netherlands. It is thus likely that the calculated fig-
                                                    ures in reality represents calculation "noise" and statistical "errors" more than actual manu-
                                                    facturing.
                                     3)             Import and export figures for Hungary, Lithuania and Poland to and from countries outside
                                                    the EU15 area have been estimated based on statistical data available in annex 3.
                                     4)             According to AFEMS there is no production in Spain of centre fire ammunition [Grodzki
                                                    2004]. The observation must be assumed to be an error based on statistical registration
                                                    shortcomings.




                                     Similar to the statement made for consumption, it is emphasized that the figures
                                     for Member States should be regarded as less reliable than the figures for EU15
                                     in total.




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                                                                                                                                              36



                                     Calculations like this are naturally subject to calculation "noise" caused by
                                     partly incorrect assumptions and statistical "errors" caused by incorrect report-
                                     ing from companies to the statistical institutions. No matter the actual cause it
                                     is noted that for Austria, Denmark, Ireland, Luxemburg and the Netherlands the
                                     calculation results does not correspond with the AFEMS statement that no pro-
                                     duction of sporting ammunition is known to take place in these countries
                                     [AFEMS 2004a].

                                     Table 3.9             Estimated use of lead for ammunitions manufacturing in EU15 and se-
                                                           lected new Member States, average for 2000-2003, breakdown by totals
                                                           for all COMEXT classifications, all figures in tonnes lead per year

                                     Country                Total consumption             Total export         Total import       Estimated total
                                                                            1)                                                     production 1)
                                     Austria                                  800                  96                  353                550 2)
                                     Belgium                                  250               1,599                1,577                    300
                                     Denmark                                  400                  30                  612                -200 2)
                                     Finland                               1,100                  217                  504                    800
                                     France                                6,400                1,075                1,856                  5,600
                                     Germany                              12,500                1,223                1,849                11,900
                                     Greece                                1,000                   54                  316                    750
                                     Ireland                                  450                   0                  248                200 2)
                                     Italy                                 3,200               11,975                1,022                14,150
                                     Luxembourg                                50                   1                   26                   0 2)
                                     Netherlands                              250                   5                   67                200 2)
                                     Portugal                              1,000                  108                  952                    150
                                     Spain                                 3,900                7,053                  813                10,100
                                     Sweden                                1,400                  401                  106                  1,700
                                     UK                                    5,900                1,897                1,305                  6,500
                                     Total EU15                           38,600               25,733               11,606                52,700
                                     Hungary 3)                               150               1,116                  122                  1,150
                                     Lithuania 3)                             150                   0                   26                    100
                                     Poland 3)                                500                  10                  136                    400
                                     Source         Calculated as described in the text
                                     1)             Figures are rounded
                                     2)             According to AFEMS [AFEMS 2004a] no production are known to take place in Austria,
                                                    Denmark, Ireland, Luxemburg and the Netherlands. It is thus likely that the calculated fig-
                                                    ures in reality represents calculation "noise" and statistical errors more than actual manu-
                                                    facturing.
                                     3)             Import and export figures for Hungary, Lithuania and Poland to and from countries outside
                                                    the EU15 area have been estimated based on statistical data available in annex 3.


                                     No matter the "noise" attached to the calculation results a picture is emerging,
                                     which corresponds well to the other data available in e.g. table 3.1, table 3.10
                                     and 3.11:




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                                                                                                                    37



                                     !     The total consumption of lead for manufacturing of ammunition for shoot-
                                           ing and hunting in EU15 comes up to about 50,000 tonnes of lead yearly.

                                     !     Shotgun ammunition is the dominant type of shooting and hunting ammuni-
                                           tion manufactured and consumed in EU15 (follows from table 3.5 com-
                                           bined with table 3.8).

                                     !     The dominant countries of manufacturing are Italy and Germany followed
                                           by France, Spain and the UK. Italy and Germany seems to the dominant
                                           countries of manufacturing regarding shotgun and air gun ammunition.
                                           While Germany dominates concerning rim fire ammunition, Spain is seem-
                                           ingly a dominant country of manufacturing with respect to centre fire am-
                                           munition. However, according to AFEMS there is no production in Spain of
                                           centre fire ammunition [Grodzki 2004], and the observation must be as-
                                           sumed to be an error based on statistical registration shortcomings. AFEMS
                                           informs that on centre fire ammunition the Czech Republic is the major
                                           manufacturer in Europe [Grodzki 2004].

                                     !     Manufacturing also takes place in countries like Sweden, Finland, Greece
                                           and Portugal (confirmed by AFEMS [AFEMS 2004a]) and in Belgium (by
                                           the large company of Groupe Herstal, which is not a member of AFEMS
                                           [KOMPASS 2004]).

                                     !     To the best of knowledge no manufacturing is taking place in Austria,
                                           Denmark, Ireland, Luxemburg and the Netherlands [AFEMS 2004a].


                                     3.2.4    Structure of shooting and hunting ammunition industry in
                                              Europe
Overview of the                      The Association of European Manufacturers of Sporting Ammunition
European manufac-                    (AFEMS) represents companies that are somehow engaged in the manufactur-
turing industry                      ing of ammunition and related products for sports and hunting purposes in
                                     Europe. These companies include:

                                     •      Manufacturers of ammunition components (primers, cases, propellants,
                                            wads, lead and alternative shot, lead and alternative bullets);
                                     •      Manufacturers of ammunition (assembling of components into final car-
                                            tridges);
                                     •      Manufacturers of machinery used in ammunitions manufacturing (incl.
                                            testing equipment);
                                     •      Distributors of ammunition and components;
                                     •      Manufacturers of clay targets.

                                     There are 45 entries in the AFEMS members list, of which some are owned by
                                     the same holding/parent companies. 16 of the companies listed are engaged in
                                     two or more manufacturing activities (typically manufacturing of selected am-
                                     munition components and assembling of the final cartridges). The overall pic-
                                     ture is, however, rather complex (see table 3.10 below).




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                                                                                                                                                                                                          38

Table 3.10          AFEMS member list by activities


Name of manufacturer                      Coun                         Components                                                                Ma-     Dis-     Clay      Company        Number of




                                                                                                                            Bullets ammunition
                                                                                                          Shotgun Ammuni-
                                          try                                                                                                    chin-   tribu-   targets   turn-over      Employees
                                                                                                                                                 ery     tors                   4)            4)




                                                                                                          tion loaders



                                                                                                                            loaders
                                                 pro-     pri   bul-   wad   case   lead   steel   zinc                                                                     mill. EUR
                                                 pel-     mer   lets                shot   shot    shot
                                                 lant



Browning International                    BEL                                                                                                               X                53       3)    60       3)
Indusys Technologies                      BEL                                                                                                      X                              ?              ?
New Lachaussée                            BEL                                                                                                      X                              ?           68
P. B. Clermont                            BEL         X                                                                                                                        16            123
G&L Calibers                              CYP                                 x                                  X                                                             22             22
Explosia                                  CZE         X                                                                                                                           ?              ?
Sellier&Bellot                            CZE              x      x     x     x      x                           x                 X                                         35       3)   1420 3)
Nammo Lapua                               FIN                     x           x                                                    X                                           23            250
Nastakiekko                               FIN                                                                                                                       X             ?              ?
Eurenco Vihtavuori                        FIN         X                                                                                                                           ?              ?
Cheddite France 2)                        FRA              X                  X                                  x                                                             36            200
Decathlon                                 FRA                                                                                                               X                     ?              ?
Laporte Ball Trap                         FRA                                                                                                                       X             ?              ?
ETS Colombi Sarl                          FRA                                        X                                                                                            ?           14
MR Equipment                              FRA                                                                                                      X                              ?              ?
Nobelsport S. A. 2)                       FRA         X                                                          X                                                                ?          190




                                                                                                                                                                                                           .
                                                                                                                                                                                          39

Name of manufacturer               Coun                       Components                                                                Ma-     Dis-     Clay      Company     Number of




                                                                                                                   Bullets ammunition
                                                                                                 Shotgun Ammuni-
                                   try                                                                                                  chin-   tribu-   targets   turn-over   Employees
                                                                                                                                        ery     tors                   4)         4)




                                                                                                 tion loaders



                                                                                                                   loaders
                                          pro-   pri   bul-   wad   case   lead   steel   zinc                                                                     mill. EUR
                                          pel-   mer   lets                shot   shot    shot
                                          lant



RUAG Ammotec 1)                    DEU            X      x           X                                  X                 X                                           ?           ?
FROHN                              DEU                                              X                                                                                 ?           40
GRILLO                             DEU                                                      X                                                                         ?        >1000 3)
Metallwerk Elisenhütte             DEU                   x           X                                                    X                                           16        101-250
Metplast                           GRE                                      X                                                                      x                  11          60
Sotirios Nafpliotis ABEE           GRE                                                                  x                                          x                  ?           ?
Nike-Fiocchi Sporting ammunition   HUN            x            x     X                                  x                                                             6           86
Baschieri & Pellagri               ITA      X                  X     X                                  X                                                             15          86
BSN International                  ITA                                                                                                    X                           ?           ?
Cheddite S.r.I. 2)                 ITA                                                                  X                                          x                  18          25
Eurotarget                         ITA                                                                                                                     X          ?           ?
Fiocchi Munizioni                  ITA            X      x           X      x                           x                 X                                           56         430
Locatelli                          ITA                                      X                                                                                         5           5
Nobelsport Martignoni 2)           ITA            X            x     X                                  X                                          x                  25         151
STAS                               ITA                                                                                                    X                           ?           ?
Team Italia                        ITA                                      X                                                                                         ?           ?
Norma AS                           NOR                                                                                                             X                  6           12
Fabicaca LDA                       POR                                      x                           x                                                             ?           ?
Corsivia                           SPA                                                                                                                     X          1.5         10




                                                                                                                                                                                           .
                                                                                                                                                                                                                 40

Name of manufacturer                         Coun                             Components                                                                    Ma-     Dis-     Clay      Company        Number of




                                                                                                                                       Bullets ammunition
                                                                                                                     Shotgun Ammuni-
                                             try                                                                                                            chin-   tribu-   targets   turn-over      Employees
                                                                                                                                                            ery     tors                   4)            4)




                                                                                                                     tion loaders



                                                                                                                                       loaders
                                                     pro-     pri     bul-    wad     case   lead    steel   zinc                                                                      mill. EUR
                                                     pel-     mer     lets                   shot    shot    shot
                                                     lant



Montorretas                                  SPA                                                 X                                                                                           6          11-20
Nobel Sport Espana 2)                        SPA                                                                            X                                           x                    ?            ?
UEE Cartucheria Deportiva                    SPA         X        X                    X                                    X                                                                ?           ?
Gyttorp                                      SWE                                                                            X                                                                1           10
Eurenco Bofors                               SWE         X                                                                                                                              22       3)    190 3)
Norma Precision AB                           SWE                          x            X                                                      X                                           17            140
RUAG Ammotec 1)                              SWI                  X                    X                                                      X                                          8 3)          300 3)
CCI International                            UK                                                                                                                                  X       3-7            21-50
ELEY Limited                                 UK                           x            X                                                      X                                          7-15          101-250
Lyalvale Express                             UK                                   x                                         X                                                            5-15           21-50

Total number EU15                                    7        8       7       5       15     8       1       1      16                 8                    5       8        5

Source: Company list and information on activities is provided by AFEMS [AFEMS 2004a, AFEMS 2004b].
?           No data
1)          The company RUAG Ammunition in Switzerland is owner by RUAG Ammunition in Germany [AFEMS 2004a].
2)          The Nobel companies in Italy, France and Spain together with Cheddite companies in France and Italy are owned by SOFISPORT in France [AFEMS 2004a].
3)          The company undertakes many other activities than shooting and hunting ammunition manufacturing and distribution etc.
4)          Data from KOMPASS International Business to Business Search Engine [KOMPASS 2004], Turn over in other currencies than € has been converted to € by exchange rates of 30 September
            2004.




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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             41



AFEMS representa-              AFEMS represents individual companies rather than national associations. The
tion                           organisation estimates that about 70% of all shotgun cartridge manufacturers
                               (loaders shotgun) in Europe are members of AFEMS, whereas all bullet car-
                               tridge manufacturers (loaders bullets) are members. Similar information on the
                               component manufacturers have been provided in the table below.

                               Table 3.11         AFEMS representation of European industry

                                                       Percentage of production by AFEMS       Specific characteristics to the indus-
                                                         members to production by total             try sector outside AFEMS
                                                                    EU15, %
                               Comp: Propellant                         95
                               Comp: Primer                             100
                               Comp: Wad                                60                      Typically small family-owned busi-
                                                                                                   nesses (e.g. Gualandi Italy)
                               Comp: Lead shot                          90
                               Comp: Steel shot                         50
                               Comp: Zink/bismuth                       50
                               shot
                               Loaders bullets                          100
                               Loaders shotgun                          70
                               Machinery                                75




                               The brands that are known to end users (sport shooters and hunters) are typi-
                               cally the names of the loading companies. The same companies may, however,
                               also be engaged in supplying specific components for other loading companies.
                               Non AFEMS members are normally medium or small companies spread eve-
                               rywhere, in particular in Italy, France, Greece, Portugal, Spain and UK. These
                               companies typically are just loaders and use 100% components produced by
                               AFEMS members [AFEMS 2004a].

                               Based on table 3.10 and 3.11 the total number of manufacturing companies in
                               Europe dealing with sporting and hunting ammunition should be expected to be
                               in the range of 50 to 100 companies.


                               3.2.5 Ammunition trade patterns in Europe
Cartridges                     Based on the statistical data presented in annex 3 it can be calculated that there
                               is a substantial trade with ammunition across borders in Europe. Overall, the
                               import amounts to 21% of total ammunitions production. 17% of production is
                               on average imported from other EU15 member countries. Similarly, 47% of
                               total production is exported, of which 18% (of total production) is exported to
                               other EU15 member countries. The ammunitions market is assessed to be worth
                               of roughly 300 million euros annually (worth of production based on average
                               import/export prices for 2003).




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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                 42



                               As can be seen from the table 3.12 below, substantial regional variations exist.
                               Italy is by far the largest exporter of shotgun ammunition and Germany is the
                               largest exporter of rim fire ammunition. According to table 3.12 Spain is seem-
                               ingly the most prominent exporter of centre fire ammunition. However, as
                               AFEMS informs that there is no production in Spain of that type of ammunition
                               [Grodzki 2004], the observation must be assumed to be an error based on statis-
                               tical registration shortcomings.

                               Table 3.12        Import and export (intra and extra EU) measured in tonnes lead used in
                                                 ammunitions manufacturing, average of 2000-2003

                                                    Shotgun and air gun                Centre fire                   Rim fire
                                                       export        import         export           import      export         import
                               Austria                     26           290             54              43           16                20
                               Belgium                 1,406          1,339             85             126          107               112
                               Denmark                     14           470              6              83           10                60
                               Finland                      2           419            125              28           90                57
                               France                  1,059          1,374              6             311           10               171
                               Germany                   613          1,129            223             440          387               280
                               Greece                      54           303              0               2            0                10
                               Ireland                      0           247              0               0            0                 1
                               Italy                  10,835            897          1,122              66           17                59
                               Luxembourg                   1             11             0               4            0                11
                               Netherlands                  4             20             0              38            0                 9
                               Portugal                  108            932              0              14            0                 6
                               Spain                   4,703            606       2,350 1)             158            0                48
                               Sweden                    401            106              0               0            0                 0
                               UK                      1,610          1,172             29              39          258                94
                               Total EU15             20,836          9,315          4,002           1,351          895               939
                               Hungary                 1,100            103             15              14            1                5
                               Lithuania                    0             19             0               5            0                 2
                               Poland                      10             84             0              35            0                17
                               Source       COMEXT, adjusted
                               1)           According to AFEMS there is no production in Spain of centre fire ammunition [Grodzki
                                            2004]. The observation must be assumed to be an error based on statistical registration
                                            shortcomings.


                               For a comprehensive picture on the ammunition trade patterns in EU15 refer-
                               ence is made to table A3.12-A3.17 in Annex 3.

Ammunition compo-              AFEMS has informed that there is a widespread trade across borders of ammu-
nents                          nitions components, although no detailed data in this issue has been provided.
                               This is apparent when browsing websites of manufacturers (cartridge loaders).




                                                                                                                                        .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   43



                               3.3        Legal or voluntary use restrictions on lead
                                          ammunition
International agree-           The African-Eurasian Migratory Waterbird Agreement AEWA, the largest
ments                          agreement developed so far under the UN Convention of Migratory Species
                               (CMS), came into force on 1 November 1999. According to article 4.1.4 of the
                               agreement 'Parties shall endeavour to phase out the use of lead shot for hunting
                               in wetlands by the year 2000'. Per September 2004 the agreement has entered
                               into force in Denmark, Finland, Germany, the Netherlands, Spain, Sweden, UK
                               besides also in Hungary and Slovakia, and has furthermore been signed by EU,
                               Belgium, France, Greece, Ireland and Luxemburg [UNEP 2004].

Use restrictions in            Information on legal use restrictions on lead shot and other ammunition at na-
old and new Member             tional level was collected by a questionnaire to the national environmental au-
States                         thorities in all old and new Member States and Candidate Countries. The ques-
                               tionnaire was prepared in English. The questionnaire was addressed to contact
                               persons in the Member States attending the Commission's Working Group on
                               the Limitation of Marketing and Use Directive. For countries without contact
                               persons in the working group, the questionnaire was addressed to the ministries
                               responsible for environmental issues in each country. For countries not answer-
                               ing, questionnaires were further addressed to the ministry responsible for envi-
                               ronmental issues. Twenty-five of the 28 countries answered the questionnaire.

                               Further information on legal and voluntary use restrictions were collected by
                               questionnaires in English, French and German sent to hunters' associations in
                               26 old and new Member States and Candidate Countries based on a list of asso-
                               ciations obtained from FACE (Federation of Associations for Hunting and
                               Conservation of the EU). 13 of the associations answered the questionnaire.
                               The combined result of the questionnaires is shown in table 3.13.

                               The survey shows that the use of lead shot in wetlands (or specified sites and
                               species) are regulated by legal instruments in Cyprus, Denmark, Finland,
                               France, Hungary, Latvia, the Netherlands, Sweden, Flanders, UK and 7 of 16
                               federal states of Germany (reference is made to table 3.13). In France the regu-
                               lation is still not in force. Use of lead shot in forests and other terrestrial envi-
                               ronments are or will be regulated in the Flemish region of Belgium, Denmark,
                               The Netherlands, Sweden and the UK (specified sites and species) only.

                               Further a voluntary agreement on the restriction of the use of lead in wetlands
                               has been entered into between the German Deutscher Jagdschutz-Verband e.V.
                               and Bundesministerium für Verbraucherschutz, Ernährung und Landwirtschaft
                               in 1993. In Slovenia the Slovenian Hunters Association recommends not to use
                               lead shot over wetlands.

Use restriction on             Only Denmark and Sweden have a general restriction on the use of lead shot
lead-shot for shoot-           for clay target shooting.
ing




                                                                                                                         .
    Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                 44



                                    Table 3.13         Restrictions on the use of lead-shot for hunting in the EU old and new
                                                       Member States and Candidate Countries

Country               Legal or voluntary use restrictions (year of entry into   Type of instrument
                      force)
                      Wetlands or        Hunting in          Other hunting
                      waterfowl          forests
                      hunting
Austria               no                 no                  no
Belgium
- Brussels            no                 no                  no
- Federal             reg. by regions    reg. by regions     no info *

- Flemish region      yes (2003)         yes (2008)          no info * 1)       Decision of the Flemish Government
Cyprus                yes (2003)         potentially         potentially        Legislation for Protection and Management of Wild Birds
                                                                                and Game Species. According to the regulation type of
                                                                                shot used in forest and other areas may be specified by
                                                                                the Director of the Game Fund Service
Czech Rep.            no                 no                  no
Denmark               yes (1994)         yes (1996)          yes (1994)         Statutory Order no 41 (1994) and no 39 of Jan 1996
                                                                                (First regulation: Statutory Order no 784 of Nov 1986)
Estonia               no                 no                  no
Finland               yes (1996)         no                  no                 Hunting act
France                yes (2005)         no                  no                 Arreté du 21 mars 2002
Germany               yes                no                  no                 Acts in 7 of 16 Federal States) (Jagdgesetze und
                                                                                Verordnungen der Länder)
                                                                                Voluntary agreement between Deutcher Jagdshutz-
                                                                                Verband e.V. and Bundesministerium für
                                                                                Verbrauchershutz, Ernährung und Landwirtschaft from
                                                                                1993
Greece                no                 no                  no
Hungary               yes (2002)         no                  no                 Parliament Resolution 55/2002 and Law XXXIII of 2003
Ireland               no                 no                  no
Italy                 no                 no                  no
Latvia                partly (in na-     no                  no                 Regulations of the Cabinet of the Ministers No 415 of July
                      ture reserves)                                            22, 2003
Lithuania             no                 no                  no
Luxembourg            no                 no                  no
Malta                 no                 no                  no
Netherlands           yes (1995)         yes (1995)          yes (1995)         Flora and Fauna Act
Poland                no                 no                  no
Portugal              no                 no                  no
Slovakia              no                 no                  no
Slovenia              no / yes           no                  no                 Slovenian Hunters Association recommend not to use
                                                                                lead shot over wetlands
Spain
Sweden                yes (1998)         yes (2006)          yes (2006)         SFS 1998:944




                                                                                                                                             .
     Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                45



Country                Legal or voluntary use restrictions (year of entry into   Type of instrument
                       force)
                       Wetlands or         Hunting in         Other hunting
                       waterfowl           forests
                       hunting
UK                     partly              partly             partly             The Environmental Protection (Restriction of Use of Lead
                                                                                 Shot). The regulations detail a site list and species. Any
                                                                                 activity on a listed site cannot use lead.

Bulgaria
Romania                no                  no                 no
Turkey                 no                  no                 no
                                     * "no info" indicated in questionnaire response
                                     1) According to Mr. Lecocq [Lecocq 2004] use of lead shot is restricted in the Flemish region of Bel-
                                     gium for other hunting from 2008 parallel to the restrictions for wetlands and forests.


                                     Denmark has a general ban which entered into force in 1994 on the use of lead
                                     shot for shooting, with an exception for 10 specified shooting ranges for the
                                     Olympic disciplines 'trap', 'double trap', 'skeet' and 'automatic trap'.

                                     Sweden has a ban on the use of lead shot for shooting which entered into force
                                     in 2002. Lead shoot may be used until 1 January 2005 for the disciplines 'trap',
                                     'double trap', 'skeet' and 'automatic trap' and until 1 January 2006 for competi-
                                     tion in 'jaktstigskytte' (a Swedish training exercise simulating hunting with tar-
                                     gets of different sizes on different distances).

     The Netherlands                 In the Netherlands a ban on the use of lead shoot on shooting ranges (clay
                                     pigeon shooting) is expected shortly.

                                     The UK has a regulation detailing a site list. Any activity on the listed sites
                                     cannot use lead shot, but most shooting ranges are probably outside these sites.

                                     According to the questionnaire response, Poland has some specific regulation
                                     on the construction and use of shooting ranges (Regulation of Ministry of Envi-
                                     ronment of 4 April 2000 on special requirements concerning construction and
                                     use of riffle-ranges in regard to protection of the environment). The question-
                                     naire did not include specific questions regarding the regulation of shooting
                                     ranges, and other Member States may similarly have requirements as to the
                                     construction of shooting ranges.

     Use restriction on              Sweden is the only country with a use restriction on the use of lead for rifle
     lead in rifle car-              ammunition entering into force January 1 2008. The regulation concerns rifle
     tridges                         cartridges for both hunting and shooting, but lead-containing bullets may be
                                     used on shooting ranges if the spent bullets are managed properly from an envi-
                                     ronmental and health perspective. In Greece the use of rifles for hunting is ac-
                                     cording to Hellenic Hunters Confederation not allowed (questionnaire re-
                                     sponse). In Cyprus hunting may be carried out only with shotguns (question-
                                     naire response).




                                                                                                                                              .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   46



                               3.4        Rules on hunting and shooting which govern
                                          consumers' access to and demand for lead
                                          ammunition
Rules of hunting               In many Member States specific requirements to the ammunition for hunting of
                               specific game exist. Cyprus, Denmark, Estonia, France, Slovenia, Sweden,
                               Hungary and UK have answered the questionnaire that such regulation exist,
                               but regulation may exist in other Member States as well as many countries have
                               left the question blank. The regulation specifies e.g. a specific bullet weight or
                               striking energy. As an example, to illustrate the type of regulation, for hunting
                               moose, red deer, wild boar and brown bear in Estonia the minimum calibre of
                               barrel should be 6.5 mm and minimum weight of bullet 9.0 g.

                               The requirements first of all concern the weight and striking energy of bullets
                               and by replacement of lead by other metals in the bullets it is critical that the
                               alternative bullets meet these requirements. According to [Lecocq 2004] some
                               Member States - Netherlands, the Flemish region of Belgium - has legally es-
                               tablished legal requirements for the maximum size of shotgun pellets for hunted
                               species. It is not known whether these requirements are critical with respect to
                               the use of non-lead alternatives, such as steel, for which it is recommended to
                               use a larger size shot than for lead (reference is made to section 3.6).

Rules of shooting              The European Shooting Confederation (ESC) is the European branch of the
                               global shooters' association, International Sports Shooting Federation (ISSF).
                               The ISSF is responsible for the organisation of official international sports
                               shooting events, such as the world championships and notably the Olympics.
                               The organisation formulates and regulates the rules applied in international
                               sport shooting competitions.

                               There may be special rules for sport shooting competitions applied in individual
                               countries or even in sub-regional contexts. It must be recognised, however, that
                               the structure of sports shooting is highly hierarchical, as are most other sports.
                               Hence, only the best of competitors at the local level makes it through to the
                               national level; only the best at the national level makes it through to the sub-
                               regional or regional level; only the best at the regional level makes it through to
                               the international level, and only the best of the international competitors makes
                               it through to the Olympics.

                               Therefore, there are strong incentives for competitors even at lower levels (lo-
                               cal and national levels) to compete under the same rules that are applied for up-
                               per-level competitions. The successful shooter would eventually be competing
                               directly under the ISSF regulations (e.g. the Olympics) and therefore there
                               would be little or no sense in training for these events under other conditions.
                               There are only few countries in which the use of lead ammunition is banned,
                               and in these countries range shooting for competitions is typically specifically
                               exempted in order to maintain the competitiveness of the national sportsmen
                               when training for international competitions.

                               The rules by the International Shooting Federation [ISSF 2004] requires for all
                               competitions expect 300 m riffle that ammunition are based on lead or similar



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   47



                               soft material. For 300 m riffle the ammunition may be based on any material
                               that does not imply any danger to the shooters, spectators or range personnel.
                               According to the best of knowledge of ISSF lead bullets is the only ammunition
                               used. Also for 300 m riffle, close to 100% of all bullets used for the last 10
                               years are based on lead.

                               Regarding shot or pellets used for clay pigeon competitions this types of am-
                               munition should be made of lead, lead alloy or alternative material decided by
                               the ISSF [ISSF 2004]. In practice only the lead option is used in international
                               competitions. However, in Denmark the use of lead shot is limited to a few
                               shooting ranges. On other shooting ranges in Denmark the alternative accepted
                               is steel [Winther 2004]. As stated in section 3.3, a ban on the use of lead shoot
                               on shooting ranges is expected shortly in the Netherlands.

                               According to the ISSF, all new ranges may only be constructed with a back-
                               ground created in such a way that a complete collection of lead pellets is guar-
                               anteed. Existing ranges have been modified in order to make it possible to col-
                               lect the lead. In practically all cases where existing ranges have been located in
                               particularly vulnerable areas (wetlands for example) or where modification has
                               not been deemed feasible, facilities have been shut down.


                               3.5        Available measures to recover used lead
                                          ammunition
                               Measures to recover used lead ammunition are relevant mainly for shooting
                               ranges. Certain measures - e.g. sifting of earth to separate bullets and shot -
                               could in principle be applied to all shooting areas inclusive of hunting areas,
                               but would certainly be considered not economically realistic for almost all areas
                               apart from shooting ranges. For this reason the following presentation is fo-
                               cused on shooting ranges only. In this discussion it is relevant to distinguish
                               between shooting ranges for bullets, i.e. riffle and pistol shooting, and shooting
                               ranges for clay pigeons, i.e. use of shot for trap and skeet shooting.

                               The measures to recover used lead ammunition may be divided in measures for
                               containment of used ammunition and measures for recovering of lead from the
                               materials in which the have been contained.

Containment meas-              Focusing on shooting ranges for bullets containment measures may include
ures - ranges for bul-         (based on [USEPA 2001] and [AFEMS 2002] unless otherwise noted):
let shooting
                               •     Earthen berms and backstops;
                               •     Sand traps;
                               •     Steel traps;
                               •     Rubber traps.

                               Earthen banks and backstops are a common kind of bullet stops employed at
                               shooting ranges. The earthen backstop is generally between 5 - 7 meters high
                               with a slope as steep as possible. It may be constructed of any material avail-
                               able free of stones, rocks, debris and other items, that could cause ricochet and



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   48



                               bullet fragmentation. From time to time it is necessary to remove bullets from
                               the earthen backstop - at least from the top layer - to avoid build up of bullets
                               increasing the risk of ricochet and bullet fragmentation. Bullets may be re-
                               moved by simple sifting of the earth. The earthen backstops may be underlined
                               by a plastic membrane in order to control the extent to which penetrating rain
                               water are contaminated by lead or other bullets materials.

                               Sand traps are a variation of earthen backstop. A sandbank is placed in front of
                               e.g. a concrete wall behind the shooting targets to allow the bullets to become
                               embedded in the sand. Occasional removal of bullets is required as for the
                               earthen backstop. Again sifting is an appropriate method.

                               Traps based on wood chips but otherwise similar to sand traps are used by the
                               Danish army. In this case the wood chips is not sifted, but disposed of as haz-
                               ardous waste due to the content of lead dust generated on impact [Fredslund
                               2004]. Similar generation of lead dust should be expected to occur for earthen
                               backstops and sand traps.

                               Steel traps are designed so that used bullets are directed into some form of de-
                               celeration chamber and finally into a collection tray/box. Several different de-
                               signs of steel traps are available.

                               Rubber traps include tight hanging vertical strips of rubber before a solid wall
                               of steel or concrete or shredded rubber granules covered by a solid rubber front
                               placed as a bank in front of a solid wall [Fredslund 2004]. From both types of
                               traps the bullets may be removed by either sifting or centrifugal treatment.

Containment meas-              Regarding clay pigeon shooting ranges containment measures include (based
ures - ranges for clay         on [Ceccarelli & Rosi 2004; Streitberger 2004 ] unless otherwise noted):
pigeon shooting
                               •    Earthen berms;
                               •    Net and similar traps;

                               Earthen berms is a measure introduced primarily in order to reduce the shot fall
                               zone. In Germany soil berms up to about 20 m high are being developed. Such
                               berms can be equipped with large nets placed vertically on top of the berms in
                               order to intercept shot flying over the berms.

                               In the shot fall zone the single shot will typical remain on the soil surface or
                               close to the surface. However, nets can also be placed horizontally in the shot
                               fall zone to catch shot and prevent them from being mixed with soil. A solid
                               asphalt surface may be used as an alternative to horizontal nets. Generally, a
                               process of developing an environmental friendly design of shooting ranges
                               seems to been initiated.

                               It may, however, be noted that Danish experience indicates that soil berms on
                               windy places, may cause wind turbulence again causing uncontrolled and un-
                               predictable movements of clay pigeons [Winther 2004].




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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   49



Recovery measures              Measures for recovering of lead includes [USEPA 2001; AFEMS 2002]
                               excavation (or simply raking in case of shooting ranges for clay pigeons) of the
                               contaminated material followed by either:

                               •    Sifting (manually or mechanically);
                               •    Vacuuming;
                               •    Soil washing.

                               While manually sifting may be employed for small ranges mechanical sifting
                               using e.g. soil shaking or gravel sizing, machinery may by relevant for larger
                               ranges.

                               Vacuuming is mainly relevant for clay pigeon ranges.

                               Soil washing is a technique aimed at separating the sand and gravel fraction
                               from the clay fraction. The soil is mixed with a water-based wash solution and
                               then exposed to either screening or gravity separation techniques.

                               Which technique to apply depends heavily on the site conditions, soil composi-
                               tion and level of lead deemed acceptable in the cleaned soil or bullet trap mate-
                               rial utilised. The lead colleted (bullet and particles) can be directed to recycling.

Experience of the US           The US Army ([Lillie et al 2002]) has summarised their experience regarding
Army                           lead removal from impact berms on outdoor shooting ranges as follows:

                               'The cost of removing lead from ranges varies depending on the method used
                               and site conditions. Mining industry technologies such as dry screening, wet
                               screening and acid washing have been shown to be effective in removing lead
                               from range soils and allowing for recycling of the lead. Dry screening costs
                               about US$30 per tonne of soil, but only recovers between 50 percent and 75
                               percent of the lead. Wet screening costs from US$40 to US$60 per tonne of
                               range soil and recover 74 percent to 95 percent of the lead. Acid washing costs
                               about US$170 per tonne and has a 95 percent recovery rate. A method of last
                               resort is the removal of both the lead and the soil without separating the lead,
                               which means the soil will have to be disposed of as a hazardous waste. This
                               method has no recycling capability, can cost up to US$200 per tonne and is the
                               least preferred method.'

                               An interesting conclusion of the US Army experiences with lead recovery from
                               berms on outdoor shooting ranges is that considering the costs of lead recovery
                               and soil cleaning, lead-free ammunition e.g. based on tungsten would probably
                               be cheaper than lead ammunition [Lillie et al 2002].

UK experience                  A calculation of remediation costs related to a clay pigeon shooting range in the
                               UK involving soil washing (only by water) of approx. 28,000 m3 soil and
                               screening of an extra 10,000 m3 soil resulted in unit costs for the soil washing
                               operation of approximately 105€ (US$130) per tonne of soil and 50€ (US$60)
                               per tonne for the soil screening operation [McAllister 2004]. The calculation is
                               based on an assumed soil density of approximately 2.7 t/m3.



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                50



                               It is noted by [Streitberger 2004] that contaminated soil from existing shooting
                               ranges may be used for constructing earthen berms when renovating and im-
                               proving ranges, thereby minimizing remediation costs in the first round.

                               No studies indicating the cost of lead recovery from shooting ranges, using
                               other types of bullet containment than earthen berms, seem to have been pub-
                               lished.


                               3.6           Availability of substitutes for lead cartridges
                               Several substitutes for lead are available based e.g. on the materials steel, bis-
                               muth, tungsten, tin, copper and zinc/aluminium. Basic characteristics of these
                               substitutes compared to lead are presented below.


                               3.6.1 Technical issues
Substitutes for lead           The substitutes generally available for lead shot for hunting includes steel, bis-
shot for hunting               muth/tin alloy, pure tin and tungsten mixed with a polymer giving a resulting
                               density of about 10 g/cm3. Other metals and composite materials like zinc and
                               molybdenum/polymer or tungsten/bismuth/polymer have also been developed,
                               but seem so far not to have entered the market significantly. Specifically re-
                               garding zinc shot this type of shot is promoted in e.g. Germany and prohibited
                               in e.g. the Flemish region of Belgium [Lecocq 2004]. Here the choice is made
                               to focus on steel, bismuth/tin alloy, pure tin and tungsten shot.

                               Steel shot seems to have obtained a position as the dominant substitute for lead
                               shot whereas bismuth-tin and the tungsten alloys/polymer are lacking behind
                               presumably due to the price level.

                               Table 3.1410 Substitutes for lead in shot - alternative materials and price indication
                                            relative to lead of products marketed 1).

                                Material                           Density                  Hardness            Price of shot relative
                                                                            3                                      to lead shot 1)
                                                                    g/cm                  HV (Vickers) 2)
                                Lead                                 11.3                       20                      100%
                                Iron/Steel                            7.9                      100                      120%
                                Bismuth                            9.6 - 9.8                    20                   300-500%
                                Tungsten al-                      ~10 - 12.5                    ~8                   300-1000%
                                loy/polymer 3)
                                Tin                                   7.3                       15                   150-250%
                                      1)   [Hartmann 2001; Bjælkehytten 2004] - the price of 1 lead shot cartridge is assumed to be in
                                           the range of 0.13 - 0.27 € depending on the size, quality, discount offers etc.
                                      2)   [AFEMS 2004a]
                                      3)   Includes alloys as tungsten-iron, tungsten-nickel-iron and tungsten-nickel-iron-tin just as
                                           heavy and even heavier than lead and having hardness typical higher than iron/steel. Fur-
                                           thermore includes tungsten-nylon composites with a density almost similar to lead and a
                                           hardness equalling bismuth and tin. Tungsten is a metal with a density of 19.3 g/cm3 and a
                                           hardness above steel.




                                                                                                                                         .
       Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks               51



       Steel shot                     Steel is hard, relatively cheap and lighter than lead. In Denmark it has been
                                      used as substitute to lead shot since 1985. Significant experience from several
                                      other countries like the USA, Canada, Sweden, etc. is also available.

                                      It may be noted that CIP (Permanent International Commission for the Proof of
                                      Small Arms) to which several European Countries are a member, have estab-
                                      lished regulations related to steel shot cartridges and the proof requirements of
                                      guns used to fire steel shot ammunition - it is e.g. required that the Vickers
                                      hardness of steel shot are below 110 at the surface and below 100 in the core
                                      [BASC 2004].

                                      Table 3.15 Weight, price, mine production and reserve base of lead and po-
                                      tential substitutes

                    Chemical     Weight          Price              Price           Price,    Mine production 2002             Reserve base
                    formula                                         metal : lead    source                                             2002
                                 g/cm3           US$ /t                                                 1000 t    5)
                                                                                    date
                                                                                                                                 1000 t    5)
Lead                    Pb           11.34                888             1           1)                      2,910                 140,000
Iron                    Fe           7.87                 330            0.4          4)                 504,000 6)             150,000,000
Tin                     Sn           7.31                6,668            8           1)                         249                 11,000
Nickel                  Ni           8.90             15,145             17           1)                      1,340                 140,000
Zinc                    Zn           7.14                1,087           1.2          1)                      8,360                 460,000
Copper                  Cu           8.92                2,759           3.1          1)                     13,600                 940,000
Molybdenum             Mo            10.28            40,840            43,5          2)                         128                 19,000
Bismuth                 Bi           9.87                6,834            8           2)                           4                      680
Tungsten                W            19.25            10,857             12           3)                          59                  6,200
                                      1)         London Metal Exchange, cash mean prises for the month February 2004.
                                                 http://www.lme.co.uk/dataprices_monthlyaverages.asp
                                      2)         Metalprices.com, average price of 20 Feb 2004.
                                                 http://www.metalprices.com/subscription/metals/w/w.asp - price indication for molybde-
                                                 num from 29.Sep. 2004 (price covers molybdenumoxide with min. 57% Mo)
                                      3)         Metalprices.com, average price for "pure Chinese bar", 31 Jan 2004.
                                      4)         Metalprices.com, Pig iron prices , Midwest USA - FOB delivered 9 Feb 2004.
                                      5)         USGS. 2004. Mineral Commodity Summaries. U.S. Geological Survey,
                                                 http://minerals.usgs.gov
                                      6)         Estimated assuming an average iron content of ore of 47% (same content as for the re-
                                                 serves).




       Different ballistic            The hunters experience with steel shot may be summarised into the statement
       properties                     that some time of acquaintance seems to be needed, as the ballistic properties of
                                      lead and steel shot differ due to the lower weight and higher hardness of steel
                                      shot compared to lead shot. The consequences of these differences are less pel-
                                      let deformation, denser pattering, shorter shot strings and lower retained energy
                                      at long ranges for steel shot compared to lead shot [Scheuhammer & Norris
                                      1995]. Practical solutions for hunters to remedy these consequences have been
                                      to use larger size steel shot and shortening the shooting distance thereby in-



                                                                                                                                                .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   52



                               creasing the efficiency of the shot. According to the Danish Hunters Associa-
                               tion [Kanstrup 2004a], all predictions related to exploding guns, increased
                               number of crippled game etc. caused by the use of steel shot instead of lead has
                               turned out to be "really only rumours".

Old guns                       However, older guns with thin-walled barrels may not be able to use steel shot
                               and may be damaged if trying. The experience from Denmark on this issue may
                               be summarised into the statement that about 10-20% of the shotguns in use in
                               Denmark, when the first ban was introduced, was deemed not suitable for steel
                               shot. This figure should be regarded as a rough estimate as no statistical records
                               on the issue are available [Korsholm 2004]. At that time testing facilities for
                               guns was established by major dealers in order to ensure that all hunters could
                               feel safe regarding whether steel shot could be used in their weapon. It is an-
                               ticipated that all guns not being completely new at that time were actually
                               tested. Also today old weapons are being tested. The price of testing is about 50
                               € [Korsholm 2004]. As a consequence of this effort, no explosions of guns
                               caused by the use of new ammunition and no cases of personal damage due to
                               exploding guns have been recorded in Denmark [Kanstrup 2004b].

                               In several countries in Europe the authorities responsible for gun testing is the
                               CIP Proof Houses. According to AFEMS [AFEMS 2004a] it is estimated that
                               in the whole Europe no more than 2% of the shotgun in circulation has been
                               submitted to CIP steel shot proof.

                               It is similar noted by the European Federation of Hunters [Lecocq 2004] that
                               the extent to which older guns not suitable for steel shot is still in use may de-
                               pend strongly on local habits and in reality differ between the European coun-
                               tries. Thus, the number of old guns may well be relatively higher in countries
                               like e.g. France and Italy than in Scandinavia.

                               It is difficult on this stage to judge on, whether hunters in e.g. France and Italy
                               may be less aware of having their gun tested than hunters in Denmark. Fur-
                               thermore, it is beyond the scope of this project to assess the potential organisa-
                               tional problems - if any - in the different Member States related to a large scale
                               testing of older guns.

                               Besides the risk of damaging old guns not suitable for steel shot, other practical
                               disadvantages related to steel shot include increased wear of guns, the conse-
                               quences for the wood industry and the increased risks related to ricochets.

Wear of guns                   An issue presented by AFEMS [AFEMS 2004c] after discussion with the
                               Italian Association of Sporting Firearms Manufacturers and so far not con-
                               firmed by other sources and not covered by existing CIP regulations (reference
                               is made to [BASC 2004]) is the issue of increased wear of shot guns using steel
                               shot as compared to shot guns using lead shot. It is the opinion of Italian ex-
                               perts on this issue that while the expected average lifetime for a shotgun barrel
                               using lead shot ammunition is between 20,000 and 30,000 rounds, a shotgun
                               barrel exposed to high performance steel shot will only have an average life-
                               time of 3,000 to 10,000 rounds. This assessment is based on investigations dis-
                               covering micro-cracks inside the barrel surface - micro-cracks that in the long


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   53



                               term could lead to serious damage. It is assumed that the increased wear of bar-
                               rels due to steel shot is due to higher acceleration of the shot column increasing
                               the radial pressure, which together with inter alia the higher hardness of steel
                               shot are causing some steel shot pellets to penetrate the plastic wad and thus
                               damaging the barrel [AFEMS 2004c].

Impact on wood in-             Steel shot ending in wood in forests is causing discoloration of wood besides
dustry                         being a cause of breaking down of cutting tools used in the veneer industry. It
                               has been tried to solve the last problem by developing "soft iron" shot in Den-
                               mark, but without success, as the iron hardens in the process of entering the
                               trees. The general solution adopted is that forest owners do not allow the use of
                               steel shot in a forest from which trunks are sold for industrial purposes like fur-
                               niture and veneer making [Hartmann 2001].

Richochets                     The hardness of steel increases the risk of ricochets, when steel shot is used in
                               areas where hard surfaces (stones, rocks) might be hit. In such cases other al-
                               ternatives than steel shot should be preferred. However, it must be recognised
                               that all hunters, no matter the type of shot used, may face and should be able to
                               handle situations where risk of ricochets are present. Among the situations giv-
                               ing risk of ricochets for all types of ammunition may be mentioned shooting
                               animals close to the ground, e.g. rabbits, hunting in wintertime when the
                               ground is frozen and hitting a water surface at a low angle [Kanstrup 2004b].

Crippled game                  The issue of increased number of crippled game mentioned above is based on
                               the belief that the lower density of e.g. steel shot results in less strike energy on
                               impact making the shot less lethal. While this in principle is correct, the prob-
                               lem, as also stated above, is solved by changing shooting habits and use larger
                               size steel shot besides shortening the shooting distance, thereby increasing the
                               efficiency of the shot. Hunters accustomed to steel shot often polemically
                               brings forward the question of how many birds are suffering from lead shot in
                               their body due to an optimistic hunter hoping to bring down the bird with a shot
                               even if the distance is a bit too long. As stated above the Danish experience
                               shows that the ban on lead shot has not increased the amount of crippled game
                               [Kanstrup 2004a]. In reality the issue of cripple game can be reduced to that
                               this is a matter of hunter's habits and not a matter of ammunition.

Bismuth shot                   Bismuth/tin shot contains about 3-6% tin and obtains a resulting density of
                               approx. 9.6 g/cm3 and are almost as soft as lead. Bismuth shot are taken as very
                               close to lead, and they can be used in all guns with risk for ricochets similar to
                               lead shot. The major disadvantage is the price. The early generations of bis-
                               muth shot had a disadvantage of pulverising easily on impact. This problem has
                               been reduced by the addition of tin.

Tungsten shot                  Tungsten alloy/polymer shot are manufactured with densities rather close to the
                               density of lead. For some alloys even densities above lead are obtained by vary-
                               ing the alloy composition. Tungsten/polymer shot is based on the polymer ny-
                               lon and has softness at the level as bismuth and tin and consequently they can
                               easily be used in all guns with risk of ricochets similar to lead shot. Again, the
                               price is a major disadvantage.



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   54



Tin shot                       Tin shot may be characterised as an in-between compared to other substitutes.
                               The low density is causing behaviour quite similar to steel shot requiring larger
                               size shot. The softness allows it to be used in forest areas similar to bismuth
                               and tungsten shot and eliminates damage to old guns. The risk of ricochets is
                               similar to lead shot.

Zinc shot                      Zinc shot is also a kind of in-between compared to other substitutes. It has a
                               density close to tin and hardness slightly above bismuth. However, as tin it is
                               relatively expensive compared with either steel or lead [Scheuhammer & Norris
                               1995].

                               In summary it can be concluded that several alternatives are available. No al-
                               ternative can be described as the perfect substitute recognising that all alterna-
                               tives in their characteristics represent some kind of trade-off compared to lead
                               shot.

Substitutes for lead           It is the opinion of ISSF that lead shot is beyond discussion the best option for
shot for shooting of           clay pigeon shooting and that steel shot suffers from being ballistic inferior and
clay pigeons                   not reliable to the same extent as lead shot [ISSF 2004a]. In Denmark use of
                               lead shot is restricted to a few shooting ranges and steel shot is actual the domi-
                               nant ammunition used for clay pigeon shooting. The Danish experiences with
                               steel shot for clay pigeon can be summarised as follows [Winther 2004]:

                               While steel shot a decade ago to some extent was unreliable, the quality has
                               improved considerably and is today at a level similar to lead shot. Thus, steel
                               shot today should be regarded as fully qualified for competition shooting as-
                               suming that all competitors are using steel shot . Furthermore, there are no
                               problems related to the use of steel shot in modern guns. Focusing on weak-
                               nesses of steel shot compared to lead shot the following issues could be noted:

                               •    While a single lead shot typically will cause the clay pigeon to break, this
                                    is not the case for steel shot. Typically the pigeon must be hit by a number
                                    of steel shot before it breaks. A single steel shot may due to its hardness
                                    simply penetrate the clay pigeon without causing other damage than just a
                                    hole in the pigeon. Danish experience from shooting ranges where steel
                                    shot are used shows that clay pigeons frequently can be found on the
                                    ground penetrated by one or two holes but otherwise undamaged [Winther
                                    2004].

                               •    For several brands of steel cartridges a problem of delayed ignition (2-3
                                    seconds) seem to be occurring frequently and the Danish Shooting Federa-
                                    tion has decided to warn its members of this problem.

                               •    Cartridges should generally be stored at a temperature of 10-25 ûC. Car-
                                    tridges stored at temperatures outside this interval may behave differently.
                                    This problem is more important for steel shot than for lead shot.

Substitutes for airgun         Non-lead airgun pellets available on the market include pellets based on zinc-
lead pellets                   aluminium alloys and tin based pellets. Tin based pellets are claimed to be as
                               accurate as lead pellets [Airgun 2004; Airgunpellets 2004] and possess softness


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   55



                               similar to lead, while the experience with zinc-aluminium pellets is not always
                               positive (reference is made to [Geocities 2004b]). It is relevant to note that pel-
                               let uniformity is essential for accuracy and may well depend on the price of the
                               pellets [Holzer 2004]. According to information available on the internet the
                               price of lead pellets is assumed to be in the range of 0.005 - 0.017 € per pellet
                               depending on the size, quality, discount offers etc. while the cost of tin-based
                               pellets to the consumer must is about 0.029 € or 1.5 - 6 times the cost of lead
                               pellets, while zinc-aluminium alloy pellets seem to be slightly more expensive
                               than tin pellets [Shootinggear 2004; UK gun 2004; Skenco 2004].

Substitutes for lead           The substitutes available for lead bullets can - rather simplified - be said to be
bullets                        numerous, as in principle all materials able to be cast in a form or as a powder
                               able to be put inside a jacket may be used as bullets. However, the ballistic
                               characteristics will differ with the materials employed and the design of the car-
                               tridge and very few final cartridge alternatives to lead bullets are actually mar-
                               keted. Cupper seems today the most widely used alternative [Lecocq 2004].
                               Bullet density equalling lead bullets is obtained by using materials like tungsten
                               as composites with polymers or as an alloy with other metals like tin, nickel,
                               iron etc. Powder-based materials may pulverize or fragmentize on impact,
                               while soft materials like tin is more likely to resemble the behaviour of lead on
                               impact. Using materials with lower density than lead is partly compensated by
                               increasing the length of the bullets. However, the extent to which the length of
                               bullets can be increased is covered by CIP-regulations [Grodzki 2004].

Substitutes for mili-          Inter alia motivated by the costs of cleaning up shooting ranges for lead pollu-
tary and hunting               tion, considerable efforts have been invested in developing lead free ammuni-
ammunition                     tion for military purposes. It may e.g. be noted that a Nordic ammunition com-
                               pany today is supplying Swedish, Norwegian and Finnish defence forces with
                               non-lead ammunition. The company has furthermore recently established a li-
                               censing agreement with the Danish Army Material Command regarding local
                               manufacturing in Denmark [Nammo 2004]. The ammunition in question fulfils
                               all requirements of NATO and is roughly estimated to cost about 20% more
                               than lead ammunition [Rasmussen 2004].

                               The company in question has also developed non-lead ammunition for hunting.
                               The ammunition is according to the company able to create a "mushrooming"
                               effect similar to lead bullets and the ammunition is considered suitable for all
                               game inclusive of e.g. of boar and moose [Nammo 2004].

                               According to information available on the internet etc. the price of bullets for
                               small arms is assumed to be in the range of 0.04 - 0.35€ per cartridge depend-
                               ing on the size, quality, discount offers etc. [Shootinggear 2004; Globalnet
                               2004, Bille 2004].


                         3.6.2 Environmental and health issues
Toxicity of alternatives The evaluation of the environmental toxicity of alternatives can be divided into
                         three aspects:




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   56



                               •    Toxicity to birds when ingested;
                               •    Toxicity of shot in the tissue of wounded animals;
                               •    General environmental toxicity of the substances.

Toxicity to birds              In some countries specific systems for certification/approval of non-toxic shot,
when ingested                  based on the toxicity of the shot to birds, have been developed. None of the EU
                               Member States have such systems. In Member States with legal restrictions on
                               the use of lead in shot, the regulation in general concerns the use of lead only.
                               However, zinc shot is prohibited in the Flemish region of Belgium [Lecocq
                               2004a]

- USA                          The United States Fish and Wildlife Service (USFWS) implemented a ban on
                               the use of lead shot for migratory waterfowl hunting which was finalized in
                               1991. They have also developed a review/certification process to evaluate the
                               safety of other alternative shot materials i.e. that the spent shot material does
                               not impose a significant danger to migratory birds and other wildlife or their
                               habitats. The certification concerns thus primarily the toxicity of the materials
                               to birds when ingested. Most U.S. ammunition manufacturers produce lead-free
                               ammunition. The following shot types have received non-toxic approval for the
                               2003-2004 season: Steel Shot, bismuth-tin shot, tungsten-iron shot, tungsten-
                               polymer shot, tungsten-matrix shot (in reality also tungsten-polymer), and tung-
                               sten-nickel-iron [Nevada 2004].

- Canada                       Bismuth shot, steel shot, tin shot, tungsten-iron shot, tungsten-matrix shot (in
                               reality also tungsten-polymer), tungsten-nickel-iron shot and tungsten-polymer
                               shot have been approved as non-toxic alternatives for use in Canada in accor-
                               dance with the Toxicity Test Guidelines of the Canadian Wildlife Service
                               (CWS) of Environment Canada [Canada Gazette 2004]

- zinc shot                    Zinc has been demonstrated to be toxic to birds when ingested although its
                               toxicity is lower than that of lead [Scheuhammer and Norris 1995]. Zinc shot
                               are not currently approved for use as non-toxic shot in the USA or Canada.

- molybdenum                   Chronic oral ingestion of molecular molybdenum can be toxic [Scheuhammer
                               and Norris 1995]. Molybdenum shot are not currently approved for use as non-
                               toxic shot in the USA or Canada

Toxicity of shot in            For many species of waterfowl sampled in many locations it is common for 20-
the tissue of                  30% of apparently healthy individuals to be carrying one or more shot pellets
wounded animals                [Scheuhammer and Norris 1995]. The embedded pellets may be the source of
                               secondary poisoning of raptors but lead released from the pellets may also in-
                               fluence the health of the wounded animal.

                               The potential effects on wounded animals of embedded shot pellets of alterna-
                               tive materials have still not been investigated in detail.

General environ-               Comparison of the general environmental toxicity of substances implies a re-
mental toxicity of             view of a large range of effects to different organisms in different media. It has
alternatives                   been beyond the scope of this study to carry out a comprehensive comparative
                               review of environmental toxicity of all alternatives and it has not been possible


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   57



                               to identify a comparative review. Furthermore, it is noted, that the assessment
                               presented in the following is focused on the dominant material available - e.g.
                               iron in steel shot - and will not detail on the fact that all materials will contain
                               traces and fractions of other substances - e.g. steel shot will besides iron contain
                               small amounts of heavy metals.

                               Within the context of the EU Water Framework Directive environmental qual-
                               ity standards are being developed for priority substances. However, of the nine
                               substances included in table 3.16 only lead and nickel is included in the list of
                               priority substances [Lepper 2002]. For this reason the choice has been made to
                               consider water and soil quality criteria as aggregated indicators of the toxicity
                               of the substances. Danish ecotoxicological soil quality criteria and water quality
                               criteria for the substances together with soil target values for the Netherlands
                               are shown in the table below. It is noted that similar criteria are also available
                               for Canada (reference is made to [Canada 2003]).

Soil quality criteria          The Danish ecotoxicological soil quality criteria are considered as a level,
and target values              where no harmful effects on soil organisms or processes can be expected
                               [Scott-Fordsmand and Pedersen 1995]. The Dutch target values indicates the
                               level corresponding to fully functional properties of the soil for humans and
                               plant and animal life besides giving an indication of the benchmark for envi-
                               ronmental quality in the long time on the assumption of negligible risk to the
                               ecosystem [Netherlands 2000].

                               As shown in the table the soil criteria and target values for molybdenum, nickel
                               and copper is lower than the criteria for lead (i.e. the substances are considered
                               more problematic than lead). In particular molybdenum is considered much
                               more problematic than lead. Regarding tin it should be noted that no target
                               value is established in the Netherlands for the present and that the ecotoxi-
                               cological data underlying the Danish criterion is rather scarce and a re-
                               evaluation of the criteria when new knowledge is available was specifically
                               recommended [Jensen et al 1997]. It is the opinion of the authors of this report
                               that it may well be discussed whether the data available for tin compared to the
                               data available for lead does justify tin to be assessed as more problematic than
                               lead (reference is made to [Jensen et al 1997] and [Scott-Fordsmand and Peder-
                               sen 1995]). Inorganic tin is considered low-toxic to humans, for which reason
                               WHO has decided not to recommend a specific guideline value for drinking-
                               water [WHO 1993].

                               Regarding tungsten and bismuth no criteria and target values been identified
                               neither in Denmark and the Netherlands nor in other countries and the problem
                               of scarce data may likely also apply to these metals. Lack of criterion and target
                               value for iron is justified with the fact that iron in general are considered non-
                               toxic in soil besides that iron normally are present in abundant quantities in
                               natural soils.

Water quality criteria         Regarding water quality criteria, the criteria for copper are at the same level as
                               lead, whereas the criteria for zinc and nickel are significantly higher than the
                               criterion for lead (i.e. the substances are considered less problematic than lead).
                               Again as for the soil environment it is generally believed that neither tin, bis-


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks            58



                               muth nor tungsten should be of concern with respect to the water environment.
                               However, this assumption has actually not been documented and no water qual-
                               ity criteria for tin, bismuth and bismuth have been identified. The same applies
                               to molybdenum. Lack of criterion for iron is justified with the fact that iron in
                               general are considered low- toxic in natural water environments.

New data on tungsten           Recent studies on tungsten has created concern about possible links between
                               tungsten and leukaemia and animal data suggesting reproductive and develop-
                               ments effects as well as possible neurological effects has caused tungsten and
                               several tungsten compounds to be nominated to the US Toxic Substances Con-
                               trol Act Priority list [Begley 2004; Federal Register 2004]. Research has further
                               shown uptake of tungsten by plants and invertebrates besides that tungsten in
                               pure and ammunition grade forms was found to produce a strong impact on soil
                               microbial community, soil microfauna and plant growth ([Dermatas et al. 2004]
                               and [Strigul et al. 2004a,b] quoted by [Begley 2004]).

                               Table 3.16        Danish ecotoxicological soil and water quality criteria and soil target
                                                 values from the Netherlands

                                                   Soil quality crite-    Target values          Water quality criteria     4)
                                                          ria              Netherlands                    µg/l
                                                       Denmark                  3)
                                                  mg/kg dry weight       mg/kg dry weight
                                                                                              Saltwater            Freshwater
                                Lead                       50 2)               85                5.6                      3.2
                                Zinc                    100 2)                 140                86                      110
                                Molybdenum                 2 1)                 3                n.a.                     n.a.
                                Tin                        20 1)               n.a.              n.a.                     n.a.
                                Nickel                     10 2)               35                8.3                      160
                                Copper                     30 2)               36                2.9                      12
                                Tungsten                    n.a.               n.a.              n.a.                     n.a.
                                Bismuth                     n.a.               n.a.              n.a.                     n.a.
                                Iron                        n.a.               n.a.              n.a                      n.a.
                               n.a:        Not available
                               1)          [Jensen et al. 1997].
                               2)          [Scott-Fordsmand and Pedersen 1995].
                               3)          [Netherlands 2004]
                               4)          [Danish Ministry of Environment 1996] - The proposed criteria are based on US EPA water
                                           quality criteria.




Other environmental            As stated in table 3.15 bismuth, tungsten, molybdenum and tin are relatively
aspects                        scarce metals with a limited reserve base and based on the knowledge available
                               seemingly significantly more scarce than lead. Metals as zinc, cupper and in
                               particular iron are, however, more abundant and less critical than lead.




                                                                                                                                     .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   59



Summary                        While iron presents an clear improvement compared to lead considering
                               toxicity as well as other environmental issues (although steel shot besides iron
                               contain small amounts of heavy metals), other alternatives suffers from one or
                               more disadvantages inclusive of lack of data.

                               Tin, bismuth and tungsten are all characterised by being more scarce than lead.
                               Regarding toxicity tin, bismuth and tungsten are considered non-toxic to birds
                               and tin are generally considered low-toxic to humans. However, regarding tox-
                               icity in soil and water the data available are for all 3 metals scarce and does in
                               reality not allow a substantiated conclusion on whether these metals can be re-
                               garded as an improvement compared to lead or not. It is recommended that re-
                               search is initiated that can eliminate the current lack of data. This recommenda-
                               tion is supported by the fact that new data on tungsten has indicated effects to-
                               wards humans as well as soil organisms and plants. Whether these effects are
                               serious enough, to disqualify tungsten as a substitute to lead in ammunition,
                               remains to be clarified.

                               Zinc and cupper are both more abundant than lead although not as plentiful as
                               iron. However, neither of these materials are approved as non-toxic in USA and
                               Canada and zinc is also prohibited in the Flemish region. Zinc is toxic to birds,
                               but less toxic than lead considering birds as well as soil and water. Cupper are
                               more toxic than lead in soil and on the same level as lead in water.

                               Molybdenum is scarcer than zinc. It is not approved as non-toxic shot in the
                               USA and Canada and far more toxic than lead in the soil environment.

                               Nickel, which is only used in combination with tungsten, is more toxic in the
                               soil environment but less toxic in water. The reserve-base is similar to lead.


                               3.7        Impact of potential marketing and use restrictions
                                          on lead ammunition

                               3.7.1 Impact on business and users
Fundamentals of car-           A shotgun or bullet cartridge is made from five main components:
tridge manufacturing
                               •     The primer, which is probably the most sophisticated part of the cartridge
                                     due to the safety risks involved;
                               •     The propellant;
                               •     The wad, which is made of plastic or other similar material;
                               •     The shot or projectile, which is typically made of lead but can also be bis-
                                     muth, steel, zinc, alloys or similar; this part typically makes up 60%-75%
                                     of the entire weight of the cartridge;
                               •     The case.

Consequences for               In general the cases, the propellants, the primers and the wadding system of the
manufacturing proc-            cartridge (that is primer, propellant and wad) must be reconfigured when lead is
ess                            substituted by another metal in the bullet/pellets (reference is made to table
                               3.17).



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                   60



                               Table 3.17 Consequences for processes in ammunitions manufacturing
                               [AFEMS 2004a]

                                Type of manu-      Description
                                facturer
                                Comp: Propel-      Use of a different metal for the shot/projectile will require development of new
                                lant               propellants (geometric configuration and composition). The propellant is uniquely
                                                   designed for each single product type (different calibres, different pellet sizes,
                                                   different purposes).
                                                   Cost of the raw materials will be approximately the same regardless of the metal
                                                   used for the shot/projectiles. New installation process could be necessary to pro-
                                                   duce the required propellant. Otherwise, incremental costs relate to research and
                                                   development in addition to new propellants.
                                Comp: Primer       The primer is developed so as to match the specific type of propellant used in the
                                                   cartridge. As new propellants are to be developed if lead is being substituted, so
                                                   could also the corresponding primers.
                                                   Cost of the raw materials will be approximately the same regardless of the metal
                                                   used for the shot/projectiles. Machinery for the manufacturing process will be un-
                                                   changed. Hence, incremental costs relate only to research and development
                                Comp: Wad          The wad is uniquely designed for each single product type (different calibres, dif-
                                                   ferent pellet sizes, different purposes).
                                                   The wad will have to be redesigned if a different metal is used. Lower density of
                                                   the alternatives implies that less space is available inside the cartridge for the wad,
                                                   and also different metals behave differently with respect to the passage in the
                                                   barrel of the firearm.
                                                   Cost of the raw materials will be approximately the same regardless of the metal
                                                   used for the shot/projectiles. Machinery for the manufacturing process will be un-
                                                   changed. Incremental costs relate to research and development and to new injec-
                                                   tion moulders. Cost of new material will increase accordingly to new design.
                                Comp: Shot         The manufacturing process of steel shot is distinctly different from lead shot. The
                                (pellets)          machinery needed is generally more complex and in entirely different from lead
                                                   manufacturing machinery.
                                                   In general neither machinery nor know how of lead manufacturing processes can
                                                   be transferred to manufacturing of substitute metals. Any extensive regulation on
                                                   the use of lead in ammunition on the EU level may therefore have substantive con-
                                                   sequences for this particular category of manufacturers.
                                Loaders            Assembling of components into final cartridges is done on a separate piece of
                                                   machinery.
                                                   New type of pellets will require modification of some sections of the present ma-
                                                   chines with costs which varies from machine to machine, so to allow them to work
                                                   with other alternative metals as well.
                                Machinery for      Only producers of machinery for lead shot manufacturing (the machine that actu-
                                pellets, bullets   ally makes the pellets) will be affected by a potential restriction on the use of lead
                                                   in ammunition. However, it seems likely that the demand for machines for manu-
                                                   facturing of other types of pellets will increase accordingly to the request of lead
                                                   alternatives.
                                Distributors       No consequences.
                                Cases              New cases with different lengths would be required to accept higher volume of
                                                   pellets. Consequently this would require adaptation to the existing machines.
                                Clay targets       No consequences.




                                                                                                                                             .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                 61



                               General costs for the industry in case the use of lead in ammunition is com-
                               pletely restricted relate mainly to research and development of new products as
                               well as adaptation of existing machinery. The consequences for the existing
                               producers of lead shot (cartridge component) may, however, be more severe.

                               The technology used for lead shot manufacturing cannot be adapted to alterna-
                               tive metals. The companies in question are typically specialised in lead process-
                               ing, and therefore would have no basis for entering new markets (e.g. produc-
                               tion of steel shot).According to the AFEMS registry -reference is made to table
                               3.10 - approximately 5 companies in Europe are sole producers of lead shot
                               (i.e. neither engaged in production of other cartridge components nor assem-
                               bling of cartridges). Based on the data presented in table 3.10 it can be assumed
                               that these 5 companies most likely represent a total staff of employees of less
                               than 200 and a total turnover of less than 100 mill.€/year. 3 other lead shot
                               manufacturers exist, but these are engaged in other activities related to ammuni-
                               tions manufacturing parallel to the production of lead shot. Together these 8
                               manufacturers according to table 3.11 are covering 90% of the production of
                               lead shot in EU15, indicating that the number of employees and the turnover of
                               other companies active in this field is limited.

                               There exists in Europe today 3 companies (that has been identified during this
                               survey) that manufacture machines for lead shot production. These companies
                               would obviously be affected also in case of a stricter regulation in Europe for
                               the use of lead ammunition (as for example a ban). The number of employees
                               and the turnover of these companies are not either.

Costs for research             Estimated costs for research and development in accordance with the needs in-
and development                dicated in table 3.17 above have been outlined in table 3.18 below.

                               Table 3.18         Estimated costs for research and development [AFEMS 2004a]

                               Item                            Unit costs in €               Applies to                  Total 1)
                               Propellant                          400,000             60 types of propellant               17,700,000 €
                                                                                        of which 70% would
                                                                                         need reformulation
                               Primers                             400,000              10 types of primers                   4,000,000 €
                               Wads (including new             100,000 per die              150 moulds                      25,000,000 €
                               moulds)
                               New cartridges with          10,000 per cartridge         10,000 articles 2)                142,900,000 €
                               lead alternatives (inte-            type
                               grated cartridge de-
                               sign)
                               New packaging                         150                 10,000 articles 2)                   2,100,000 €
                               Total R&D (rounded)                                                                         190,000,000 €
                               1)           Totals have been adjusted to account for non AFEMS members in accordance with table
                                            2.11.
                               2)           The high number of articles indicated comes from that several companies besides their
                                            main product lines also have a significant production of speciality products for individual
                                            customers [AFEMS 2004a].




                                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             62



Costs for machinery              Estimated costs for adaptation of existing machinery in accordance with the
adaptation                       needs indicated in table 3.17 above have been outlined in table 3.19 below.

Costs of a complete              In summary, the estimated costs for the European ammunitions manufacturing
or partial industry              industry of completely converting the existing lead based production lines to
conversion                       alternative metals are approximately 310 mill.€. This amount mainly covers
                                 costs for development of new products as well as costs for adapting existing
                                 machinery.

                                 In case a more selective regulation is put forward for the use of lead ammuni-
                                 tion in Europe it is likely that conversion costs for the industry will decrease
                                 accordingly. It is assessed that approximately 50% of the entire lead shot am-
                                 munitions production is used for sports shooting purposes, and similarly 50%
                                 for hunting purposes. Assuming that about 20% of all hunting takes place in
                                 wetlands, conversion costs for the industry could be down at about 30-40
                                 mill.€, in case the regulation only concerns hunting in such areas.

                                 Table 3.19         Estimated costs for machinery adaptation [AFEMS 2004a]

 Item                                                          Unit costs in €           Applies to              Total (note 1)
 Assembling machines (cartridge cases): The use of                500,000               25 machines               17,900,000 €
 steel shot requires in some cases longer shells (up to
 89 mm long). Most of the shell assembling machines
 are designed for only 3" (76 mm) long shells. This
 means that those assembling machines have to be
 modified for this new length by changing the cams
 and the slides when it is possible
 Loading machines: The extra length of the shell would            20,000               1,200 machines             34,300,000 €
 also require a modification (change of the stroke of
 the machine) of all loading machines (most are de-
 signed for 3" shells).
 Loading machines: Increased hardness of alternative              15,000               1,200 machines             25,700,000 €
 materials will require alterations of the volumetrical
 pellet dosing devices and for the larger diameters the
 use of counting (instead of volumetrical) systems
 Printing machines: The use of steel shot (or other               75,000               400 machines               42,900,000 €
 alternative materials) will also require for safety rea-
 sons a clear and resistant print of that information on
 the shell tubes. New printing machines would be
 required
 Total machinery adaptation (rounded)                                                                             120,000,000 €
                                 Note 1      Totals have been adjusted to account for non AFEMS members in accordance with table
                                             3.11.




                                 It is impossible at this stage to quantify the general effects for the markets of a
                                 complete or partial ban on lead ammunition in Europe. Producers of ammuni-
                                 tion based on alternative metals and alloys certainly do exist in Europe already
                                 (supplying the markets in Denmark and elsewhere) and they would obviously
                                 benefit from such a ban, as would also the import to Europe of such ammuni-
                                 tion. To the extent manufacturing activity is taken over by other European
                                 companies, the economic impact is minimized, but social costs related to the


                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   63



                               transition process remains. It is, however, at the present stage not possible to
                               assess the social costs related to the transition process. Generally such transi-
                               tion costs depend heavily on the conditions in the region in which the com-
                               pany is located and is thus generally very difficult to assess.

                               Other elements that are difficult to quantify at this stage include:

                                !    A change in the overall activity (amount of ammunition sold and used) in
                                     hunting and sport shooting following a restriction on the use of lead in
                                     ammunition. It is difficult to predict with certainty whether the outcome of
                                     a restriction might be a decrease in activity caused by increased ammuni-
                                     tion costs or a status quo. The possibility of an increase following the
                                     status of being a more environmentally friendly sport may not be ex-
                                     cluded, either.

                                !    A restriction on the use of lead in the EU may result in that companies
                                     have to maintain two lines of production to the extent they are serving cus-
                                     tomers outside the EU still requesting lead ammunition.

Consequences for               The end users - sports shooters and hunters - will eventually pay for any in-
hunters and shooters           creased costs in manufacturing through increased price levels for the individual
                               cartridges. Increased costs not only cover higher prices for the raw materials
                               used (the stock quotes are certainly higher for a number of the alloys used, and
                               also for tungsten and bismuth), but also covers the costs of more complex pro-
                               duction techniques (more energy is required to cast steel pellets as compared to
                               lead pellets) as well as the conversion costs of the industry described above.
                               However, the transition costs related to companies not able to adapt to non-lead
                               products incl. of social costs related to the transition process is not included in
                               the increased price level for cartridges.

Incremental costs for          The Netherlands and Denmark are the only European countries to have banned
hunters                        all use of shotgun ammunition as of today. Therefore, it has been deemed the
                               most appropriate way of estimating the costs to users to assess the retail prices
                               for ammunition in one of these countries, where it should be safe to assume that
                               the market for non-lead alternatives is relatively mature. Based on the informa-
                               tion in table 3.14 it has been estimated that the average European hunter would
                               face annual expenses for ammunition of approximately 290% as compared with
                               today corresponding to an increase of 190%. This estimate is based on the as-
                               sumption that lead shot would be substituted by a basket of alternatives - 50%
                               steel, 20% tungsten alloy, 20% bismuth and 10% tin. This basket should be re-
                               garded as the authors' estimate of a reasonable mix of the alternatives available
                               - an estimate that pays respect to the advantages and drawbacks of each alterna-
                               tive (reference is made to section 3.6.1).

                               On average it is assessed that the prices of cartridges based on alternative met-
                               als would range from a factor 1.2 to a factor 6.5 to the comparable price of a
                               lead based cartridge, depending on the actual substitute metals used.

                               As stated in table 3.4, there was about 6.2 mill. hunters within the EU15 area in
                               1995. According to industry estimates approximately 560 mill. shotgun car-


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   64



                               tridges and 22 mill. centre rifle cartridges are annually consumed in Europe for
                               hunting purposes, so each hunter on average consumes approximately 90 lead
                               shot cartridges and 4 rifle cartridges per year. With a retail price of a lead shot
                               cartridge of 0.13 - 0.27 € (reference is made to table 3.14), this implies that the
                               average European hunter would be subject for annual extra costs in the range of
                               22€ to 46€ for ammunition if lead ammunition was to be completely banned for
                               all shotgun hunting.

                               Parallel to this and assuming a retail price of a rifle cartridge of 0.04 - 0.35€
                               and a cost of non-lead rifle cartridges of 120% compared to lead cartridges
                               (reference is made to section 3.6.1), a ban on lead in rifle cartridges would im-
                               ply annual, incremental costs to the average European hunter in the range of
                               0.03€ to 0.3€.

                               The experience from Denmark and other places, where lead ammunition has
                               been subject to a stricter regulation than in the EU average, shows increased
                               specialisation in the market. The very expensive bismuth or tungsten based al-
                               ternative shotgun cartridges would typically not be used for small game hunting
                               (e.g. game birds) in upland areas. For this purpose a cheaper steel or tin based
                               alternative is adequate. Bismuth and tungsten based cartridges are sold for
                               hunting of fur game (hare, roe deer and similar) and together with tin shot for
                               use in forest areas or when risks of ricochets are present. In the US the tungsten
                               alloy cartridges are marketed specifically for turkey hunting.

                               Finally, as stated in section 3.7 some old guns may be replaced in case use of
                               lead shot is restricted. The number of guns being replaced could considering
                               Danish experiences (reference is made to section 3.7) be as high as 20% and
                               even higher. Assuming a cost of a new gun of 1,000€, the total costs could be
                               significant. However, each hunter having an old gun actually has the choice of
                               whether to replace the gun in order to benefit from the relatively cheap steel
                               shot or to continue using the gun with the more expensive cartridges based on
                               e.g. tin, bismuth or tungsten. Furthermore, the problem is likely to diminish
                               over time (long term), as all guns eventually at some point will be renewed due
                               to general wear and tear. All new guns are reportedly capable of using non-lead
                               ammunition, and the estimate stated above of an increase in annual expenses
                               for ammunition of approximately 190% actually has included about 50% soft
                               ammunition suitably for old guns.

                               These considerations also partly apply to the issue of increased wear on barrels
                               due to the use of steel shot. With a consumption of 90 shot gun cartridges
                               yearly the average hunter may face an average life of the shotgun or the barrel
                               to be reduced from 200-300 years to 30 - 100 years. Therefore this is an issue
                               only relevant for hunters with cartridge consumption considerably above aver-
                               age and paying attention to the many other factors influencing the practical life
                               of shotguns the economic consequences should in general be considered small.

                               It should, however, be noted, that owners of old guns will need to have their
                               gun tested for use with steel shot in case they decide to use this type of shot.
                               This could be relevant for most owners of shotguns in Europe and imply a cost
                               of 50€ per gun. Assuming that each hunter on average owns 2-3 guns and that


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   65



                               on average 1gun per hunter will be tested, each hunter will face an one and for
                               all expenditure of 50€. Spread over 5 years this conversion cost corresponds to
                               an annual incremental cost of 13€.

                               In summary, a very rough estimate of the costs incurred on the European hunt-
                               ers would be approximately 220 - 370 mill.€ annually.

Other consequences             Most ammunition used for sports shooting in Europe today is lead based. The
for shooters                   main arguments from the point of view of the sport shooters are somewhat par-
                               allel to hunters [ISSF 2004a]:

                               •    Alternatives to lead, most notably steel, imply higher safety risks at shoot-
                                    ing ranges due to ricocheting pellets; a ban on the use of lead based shot-
                                    gun ammunition could require reengineering of many existing shooting
                                    ranges;

                               •    A ban on the use of lead based ammunition for sporting purposes will im-
                                    ply that European shooters must compete on unfair terms when participat-
                                    ing in international sporting events;

                               •    The financial impact on the average sports shooter would be more severe
                                    than for the average hunter because sports shooters generally use more car-
                                    tridges (several thousands per competitive shooter [AFEMS 2004a]).

Available alternatives         Even though alternatives to lead ammunition are being used or tested for
                               competition purposes, it appears that the sports shooters within the ISSF and
                               associated organisations are focussing their efforts on reclaiming and recycling
                               lead pellets and bullets from the shooting ranges rather than on identifying sub-
                               stitute metals. According to the ISSF [ISSF 2004a; Nicolaysen 2004], all new
                               ranges may only be constructed with a background created in such a way that a
                               complete collection of lead pellets is guaranteed. Existing ranges have been
                               modified in order to make it possible to collect the lead. In practically all cases
                               where existing ranges have been located in particularly vulnerable areas (wet-
                               lands for example) or where modification has not been deemed feasible, facili-
                               ties have been shut down.

Incremental costs for          Retail prices for sporting ammunition in principle will follow the market for
sports shooters                hunting ammunition. As the average sports shooter annually consumes 5-6
                               times the amount of ammunition consumed by the average hunter, it seems fair
                               to assume, however, that quantity discounts will be available for the sports
                               shooter. Based on the information in table 3.14 it has been estimated that the
                               average European sports shooter would face annual expenses for ammunition
                               of approximately 180% for shotgun ammunition as compared with today corre-
                               sponding to an increase of 80%. This estimate is based on the assumption that
                               lead shot would be substituted by a basket of alternatives - 80% steel, 7% tung-
                               sten alloy, 7% bismuth and 7% tin. This basket should be regarded as the au-
                               thors' estimate of a reasonable mix of the alternatives available - an estimate
                               that pays respect to the advantages and drawbacks of each alternative (reference
                               is made to section 3.6.1). Similarly, a 20% increase for bullet ammunition
                               could be expected, while the increase for airgun pellets probably is in the range


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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             66



                               of 50% - 500% (reference is made to section 3.6.1). The substitutes for bullet
                               ammunition and the price increase to be expected is, however, difficult to as-
                               sess in detail at this stage because a market for full range of high-performance
                               cartridges for sports shooting has not been developed (or has not matured) yet.

                               As stated in table 3.2 approximately 640 million shotgun cartridges (total for
                               various sports shooting disciplines) along with some 711 million bullet car-
                               tridges and 2.4 billion air gun pellets are being consumed by European sports
                               shooters annually.

                               Table 3.20       Number of sport shooters in Europe in 1995

                               Country                         Number of sport shooters            Overlapping (shooters also
                                                                                                            listed as hunters)
                               AUSTRIA                                            60,000
                               BELGIUM                                            25,000
                               DANEMARK
                               FINLAND                                            40,000                                 40,000
                               FRANCE                                           150,000                                 100,000
                               GERMANY                                        1,450,000                                  50,000
                               GREECE                                              7,000
                               HUNGARY                                             2,000
                               ITALY                                              40,000                                 10,000
                               IRELAND
                               LUXEMBOURG                                          4,000
                               NETHERLAND                                         33,000                                 30,000
                               NORWAY                                             33,000                                 10,000
                               POLAND                                              1,500
                               PORTUGAL                                           13,500                                  6,000
                               SLOVENIA                                            2,700
                               SPAIN                                            100,000                                  50,000
                               SWEDEN                                             70,000                                 40,000
                               SWITZERLAND                                      552,000
                               UNITED KINGDOM                                   550,000                                 300,000
                               Total                                          3,133,700                                 636,000
                               Source     [AFEMS 2004a] quoting 1995 data from the European Shooting Confederation (ESC)


                               According to the ESC registry made in 1995 (see table 3.20), there are some 2.5
                               mill. sports shooters within the EU15 area. On average this implies that a Euro-
                               pean sports shooter consumes 256 shotgun cartridges, 284 bullet cartridges and
                               944 air gun pellets. It should be noted, however, that these average numbers
                               cover large geographical variations. Major users of ammunition for clay target
                               shooting (shotgun cartridges) are Italy, France, Spain and UK. Major users of
                               bullet cartridges for sports shooting purposes are Germany, Austria, Sweden
                               and UK. The major user of air gun pellets is Germany.




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   67



                               With a retail price of lead shot cartridges of 0.13 - 0.27 €/piece, bullet car-
                               tridges of 0.04 - 0.35€/piece and airgun lead pellets of 0.005 - 0.017€/piece
                               (reference is made to section 3.6.1), and extra costs of non-lead ammunition of
                               80%, 20% and 50-500% respectively, this implies that the average European
                               shooter would be subject for annual extra costs in the range of 27€ to 55€ for
                               shotgun ammunition, 2€ to 20€ for bullet ammunition, and 8€ to 24€ for airgun
                               ammunition, if lead ammunition was to be completely banned for all shooting.

                               All in all the average European sports shooter would thus in principle have to
                               face annual extra costs in the range of 37€ and 99€ for ammunition if lead am-
                               munition was to be completely banned for all sports shooting purposes.

                               It is emphasized that these estimates addresses the average shooter, while a
                               competitive shooter using e.g. 5,000 - 35,000 shot gun cartridges yearly may
                               have to face extra costs in the range of 500€ to 7500€ annually, which have to
                               be added to the existing costs of 650€ - 9500€ that a shooter with this cartridge
                               consumption is paying already today for lead shot.

                               Also a competitive pistol, rifle or air gun shooter will have consumption far
                               above average and the general picture emerging is that the group of shooters is
                               composed of a little subgroup (the competitive shooters) with consumption
                               high above and a large subgroup close to or below average.

                               It is assessed that guns used currently by sports shooters generally will be easier
                               to adapt to the use of non-lead ammunition, at least as seen from a safety point
                               of view as the average age of gun used for sports shooting generally is lower
                               and sports shooters may be better informed of the risks related to shift of am-
                               munition. For many shotguns new chokes will have to be installed in order to
                               adjust for the changed shot characteristics of non-lead ammunition, but the risk
                               of gun explosions is likely very small assuming that proper testing of all weap-
                               ons are carried out before shift of ammunition. Assuming that approx. 50% of
                               the shooters are using shotguns and each shooter on average will need testing of
                               one weapon about 1.250.000 shotguns need to be tested. It may, furthermore,
                               be assumed that the testing together with replacement of chokes may add up to
                               between 50€ and 100€ pr shooter as a one-time conversion cost. Spread over 5
                               years this conversion cost will correspond to an annual incremental cost of 13 -
                               25€ for each shooter using a shotgun and 6.5 - 13€ taken as an average for all
                               shooters.

                               Furthermore, the issue of increased wear of shotguns using steel shot (reference
                               is made to section 3.6) with a high consumption could be relevant for competi-
                               tive shooters, as their cartridge consumption may be so high that they even with
                               lead shot have to replace their weapon as often as every year or every second
                               year. The economic consequences of an increased replacement may be roughly
                               estimated by assuming that about 3 - 5% of the sport shooters will have to face
                               the extra costs of replacing their weapon once per year. With a cost of a new
                               gun of 1000€ this would lead to total extra cost of 75 - 125 mill.€ per year cor-
                               responding to an annual incremental cost of 30 -50€ as average for all sport
                               shooters.



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   68



                               It is assumed that there will be no need for testing of pistols and rifles changing
                               to non-lead ammunition. However, as non-lead ammunition still is in the proc-
                               ess of being developed this assumption may well be discussed.

                               In summary, a very rough estimate of the extra costs incurred on the European
                               sports shooters would be approximately 185 - 400 mill.€ annually.

Manufacturing costs            In principle as described earlier the ammunition users would cover the indus-
versus hunters and             try's increased manufacturing costs. More specifically this would include costs
shooters costs                 for industry conversion (development of new products and machinery adapta-
                               tion) and the incremental costs of manufacturing a substitute metal shot
                               (changed prices for the raw material and for the detailed pellet/shot manufactur-
                               ing process). It is assessed that all subsequent steps in the manufacturing proc-
                               ess (manufacturing and handling of other ammunitions components as well as
                               loading, packaging etc) would be similar to a regular lead ammunition produc-
                               tion line - at least in terms of costs involved.

                               Stock quotes for the substitute raw materials have been provided in table 3.15.
                               It is roughly assessed that the price of lead (not as manufactured pellets/bullets
                               but as a raw material) to the final cartridge is at about 7-15% of a shotgun car-
                               tridge and 3-10% of other types of cartridges. Based in this information it can
                               be estimated that the price of an average hunting non-lead shotgun cartridge
                               (assuming the same mix as above - 50% steel, 20% tungsten alloy, 20% bis-
                               muth and 10% tin) as an example would increase 25-50% due to increased
                               costs for raw materials alone. On top of this would come additional costs for
                               the more costly pellet/shot manufacturing process (for example steel requires
                               more energy to process than lead). It has not been possible to estimate this par-
                               ticular individual cost component, however. And finally, would come the one-
                               time conversion cost for the industry, which could amount to additional 10-
                               20% of final retail price for the cartridge, provided that conversion costs are
                               spread evenly over a period of - say - five years.

                               So, all in all, the 190% increase in hunters' annual expenses for shotgun ammu-
                               nition estimated above (which is mainly driven by price developments for shot-
                               gun ammunition) and which is based on the experience from Denmark, seems
                               like a fair estimate, although maybe on the high side. This may reflect that
                               Denmark in itself is only a small market, which for the non-lead ammunition
                               alternatives relies on specialist suppliers and import from outside the EU15
                               area. These market conditions would expectedly change in case the entire
                               European industry is forced by regulation into converting from lead to substi-
                               tute metals, thereby over time probably lowering average prices somewhat be-
                               low the 190% mark.

Timing                         In case an EU-wide regulation on the use of lead ammunition is introduced suf-
                               ficient time for transition activities should be allowed for.

                               The industry will need time practically to convert production lines and develop
                               new product ranges (including the required know-how). At the same time it
                               should be emphasised that at least for shotgun ammunition full ranges of non-
                               lead cartridges already exist on the market (of which some are imported from


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   69



                               outside the EU15 area). A regulation, which is being implemented too hastily
                               could therefore skew the market quite extensively and redistribute market
                               shares among ammunition manufacturers inside and outside of the general EU-
                               area.

                               Also users will need time to adapt properly to new types of ammunition, in par-
                               ticular in order to have testing and adjustments of weapons carried out and to
                               obtain instruction and training in new safety routines to the extent relevant.


                               3.7.2 Impact on the environment and health
                               The potential environment and health effects of the environmental load of lead
                               by the use of lead shot and sinkers are reviewed in chapter 2.

                               A restriction of the use of lead for shot and bullets may result in reduced re-
                               leases from the following activities:

                               •    Primary and secondary production of lead and manufacturing of lead shot
                                    and bullets;
                               •    Hunting and shooting;
                               •    Waste disposal, e.g. incineration.

                               It is beyond the scope of this study to review the impact of the releases from the
                               production of lead, manufacturing of lead shot and bullets and the disposal of
                               lead shot and bullets that are not spread in the environment. However, it should
                               be kept in mind that a restriction of the use of lead for ammunition also would
                               reduce the releases from these activities.

                               The impact on the environment and health of a restriction of the use of lead for
                               hunting and shooting will depend on which materials are used to substitute for
                               the lead. As reviewed in section 3.6.2 iron presents a clear improvement com-
                               pared to lead considering toxicity as well as other environmental issues, while
                               other alternatives suffers from one or more drawbacks inclusive of lack of data.

Resource perspective           Lead is a relatively scarce metal with a limited reserve base even though raw
                               material deficiency is not expected for the next decades. The same is true for all
                               the alternatives except iron. Replacement of lead by bismuth and tungsten
                               would imply a very important increase in the total global demand for those
                               metals (reference is made to table 3.15). A significant increase in demand may
                               also be observed for the metals of tin and molybdenum. From a resource per-
                               spective only substitution of lead by iron (steel) can be considered advanta-
                               geous.

                               The impact of a restriction of the use of lead will in the following be estimated
                               on terms of reduced load of lead to the environment without considering the
                               impact of the increased load of the alternative materials.

Use of lead shot for           The effects of lead shot on waterfowl are well-documented and generally rec-
hunting in wetlands            ognised.



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   70



                               It is anticipated that lead shot by time generally will be buried in sediments and
                               disappear out of reach for waterfowl and that the risks related to lead shot gen-
                               erally are limited to 1-2 years after the shot has been discharged [Brønnum &
                               Hansen 1998]. However, investigations in the UK indicate that waterfowl poi-
                               soned by lead can be found many years after the use of lead shot has been pro-
                               hibited [Perrins et al 2003]. The cause is not known for sure, but several expla-
                               nations have been proposed including the following [Perrins et al 2003]:

                                  !   The birds are finding long-lost lead or lead shot used illegally.

                                  !   Waterfowl are generally migratory birds that may move from areas
                                      where the use of lead shots is allowed to areas where it is prohibited.

                                  !   The birds may find other lead products not banned but having an effect
                                      similar to lead shot like the so called "dust" shot (sizes 8 and smaller -
                                      not prohibited in the UK) and lead shot for fishing (banned in UK but al-
                                      lowed in many other countries - authors comment).

                                  !   An unidentified source of lead - it has, however, not been possible to
                                      bring forward any reasonable suggestions.

                               According to [AFEMS 2004a] shotgun cartridges are approximately used 50%
                               for hunting and 50% for shooting. According to table 2.5 approximately 18,000
                               tonnes of lead is used annually in the EU for shotgun hunting. It is not known
                               how much of this is used for hunting in wetlands. In Denmark before the ban of
                               the use of lead shot in wetlands, approximately half of the lead shot was used in
                               wetlands, but it must be assumed that the share of hunting in wetlands in EU as
                               a whole is lower. In addition hunting in wetlands is restricted in some countries.
                               It has thus for a first estimate been assumed in this report that 20% of the lead
                               shot is used in wetlands corresponding to 3,600 tonnes. It is further assumed
                               that more than 95% of this is released directly to the environment by the use.
                               The amount of lead shot not directly released to the environment must be as-
                               sumed sooner or later to end up as waste or be collected for recycling. Besides
                               the effects on the waterfowl, the release of lead contributes to the general load
                               of lead to the environment. Although it is more common that agricultural soil
                               are converted to wetlands than the opposite, it happens that wetlands are con-
                               verted to agricultural soil. In such agricultural soils the content of lead will
                               surely be above the average. However, it is not documented that the content of
                               lead in plants grown in such soils can be measured to exceed the average.

Use of lead shot for           Effects of the use of lead shot for other hunting activities on upland birds have
other hunting activi-          been reported, but it has not been demonstrated that the use of lead shot consti-
ties                           tute a significant risk.

                               Lead for hunting may contribute to a general increase of the lead content of
                               soils. To what extent the use of lead shot may contribute significantly to an in-
                               crease of lead in the soils will depend on the amount of lead used in the specific
                               region or area and the actual content of lead in soils in this region or area.




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   71



                               Based on an assessment of the loss of lead shot in the environment and the cor-
                               rosion rate of lead shot is soil, [TNO 2001] estimates that lead shot/ammunition
                               will be responsible for 80 % of total anthropogenic lead releases to soil in 2030
                               (EU15 countries). The report estimates that the lead releases on average may
                               result in an annual enrichment of the upper 25 cm of the soil of 0.2-0.5 % per
                               year (0.048 mg/kg/year) which implies on average a doubling of the lead con-
                               centration of European soils in 200 to 500 years. For the estimate, an average
                               natural background concentration of 10-30 mg/kg is applied. For grasslands, in
                               which the accumulation mainly takes place in the upper 5 cm, the report con-
                               cludes that the lead content of the 5 cm top layer may double in 40 years if a
                               "clean" soil concentration of 10 mg/kg is assumed. In the calculations it has
                               been assumed that 50% of the total consumption of lead for ammunition is col-
                               lected and thus not emitted to the environment. This assumption corresponds to
                               an almost complete collection of lead from shooting ranges. As pointed out by
                               the Scientific Committee on Toxicity, Ecotoxicity and the Environment,
                               [CSTEE 2003b] in their comments to the report, the estimates are based on
                               very uncertain assumptions that should be further examined and analysed. In
                               any case the study indicates that lead shot today is the major source of lead con-
                               tamination of soils, and that the resulting doubling times (except for permanent
                               grasslands) on average are in the order of magnitude of hundreds of years.

                               The lead content of soils varies considerably between Member States, e.g. the
                               geometric mean of soils in England and Wales are shown to be 42 mg/kg
                               [Thornton et al. 2001] whereas it in Danish agricultural soils (upper 30 cm) is
                               11.3 mg/kg [Brønnum and Hansen 1998]. The differences in background con-
                               centration to some extent reflect differences in mobility (and thus bioavailabil-
                               ity) of lead in the soils. In soils with low pH, and consequently high mobility of
                               lead, and relatively low background lead content, a load of 0.048 mg/kg/year
                               would have much more significant impacts in the content of bioavailable lead
                               in the soil than in soils with high pH and high background lead content.

                               For Norway it has been estimated assuming a background concentration of lead
                               in soil of 10 - 42 ppm that the time to double the lead concentration in soil will
                               be in the range of 10,000 to 42,000 years [Nicolaysen 2004]. This estimate is
                               however based on an assumed consumption of lead shot for hunting in Norway
                               of 50 tonnes only [Nicolaysen 2004], which is far below the consumption esti-
                               mated in table 3.5 for the neighbouring countries of Sweden and Finland and
                               furthermore may illustrate the fact, that Norway is a relatively large country
                               compared to the number of inhabitants and thus may show a relatively small
                               consumption per unit of area.

                               Generally should be expected that the actual load (consumption per unit of
                               area) of lead on soil from ammunition will vary between countries and also be-
                               tween regions in the individual countries.

                               So far no documented environmental or health impacts related to a general in-
                               crease of the lead content of the agricultural soils have been reported. It is,
                               however, obvious that an continued increase will narrow the gab between the
                               current lead content of soil and the levels for which effects may actually be ob-
                               served (reference is made to table 3.16) and could eventually cause these levels


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   72



                               to be exceeded. It may also be argued that new knowledge often tend to lower
                               the concentrations for which effects are observed - e.g. by focusing on effects
                               not previously studied - for which reason increasing concentrations in the envi-
                               ronment of hazardous substances like lead should be avoided to the extent pos-
                               sible.

                               Of the 18,000 tonnes lead used annually in the EU for shotgun hunting, ap-
                               proximately 14,400 tonnes are roughly assumed to be used for other hunting
                               activities (excluding wetlands) and it is estimated that more than 95 % of this
                               lead is released to the environment by the use. Please note the mutual depend-
                               ence between the estimated amount used for hunting in wetlands and the
                               amount used for other hunting activities, respectively. The amount of lead shot
                               not directly released to the environment must be assumed sooner or later to end
                               up as waste or be collected for recycling.

Use of lead rifle bul-         Rifle projectiles are in general too large to be ingested by birds, but the bullets
lets for hunting               may fragment when striking hard surfaces. Ingestion of fragments of lead pro-
                               jectile parts found in animal carcasses by birds have been reported from USA
                               [CCRT 2003], but to the knowledge of the authors ingestion of lead from pro-
                               jectiles by birds are in general not considered a significant problem.

                               The same considerations regarding a general increase of lead in the environ-
                               ment as discussed above may apply to the use of lead in rifle bullets.

                               According to table 2.5 approximately 150 tonnes lead is annually used in EU15
                               for hunting with centre fire cartridges and it is estimated that more than 95% of
                               this is released to the environment by the use corresponding to more than 135
                               tonnes lead. The amount of lead not directly released to the environment must
                               be assumed sooner or later to end up as waste or be collected for recycling.

Use of lead shot for           Lead shot for clay pigeon shooting is mainly used on out-door shooting ranges.
shooting                       The potential environmental impact of the activities is highly dependent on the
                               measures applied for recovery of the used lead and for preventing releases from
                               the ranges to the surroundings (via drain, surface water and ground water).

                               Traditionally the lead applied for clay pigeon shooting have been left of the
                               ground and have accumulated over time at the shooting ranges. As the lead shot
                               corrodes very slowly and the corrosion products have a low solubility in water
                               and a slow mobility in most soils, leaching of lead from the ranges to the sur-
                               roundings is a very slow process.

                               A comprehensive survey of the present situation of soil contamination of shoot-
                               ing ranges in Germany from 1998 [Working Group 1998] demonstrated only a
                               few cases of ground water contamination at the areas of shooting ranges, but
                               the report concludes that: "Especially the lead, accumulated in the soil, contains
                               - in the long term and depending on the conditions at the site (long detention
                               period, high acidity of the soil) - a considerable danger potential for different
                               protected resources and may - without measures taken - also give reason for
                               limitations on follow-up uses". The extension of the lead contamination of the
                               ranges is indicated by a calculation showing that 137 ranges in Lower Saxony


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   73



                               in total were contaminated with 2,722 tonnes lead (as of 1990). In the six
                               ranges with the highest activity the area on average was contaminated with
                               1,011 kg lead/ha per year and the author of the ranges in Lower Saxony "con-
                               siders approx. two thirds of the shooting ranges in Lower Saxony as areas,
                               which - at least partial areas - need to be remediated" [Working Group 1998].

                               The mobility of lead in the soil may be reduced by changing the chemistry of
                               the soils by addition of e.g. lime or phosphates thereby delaying the leaching of
                               the lead, but the addition do not remove the lead from the ranges or the need for
                               remediation.

                               The risk of contamination of the surroundings with lead leaching from shooting
                               ranges is today in general recognised, and methods for recovery of lead is de-
                               veloped and promoted by e.g. shooters organisations and the Association of
                               European Manufacturers of Sporting Ammunition. Methods for recovery of
                               lead are reviewed in section 3.5. Besides, the recovery is promoted by the
                               shooter's organisation by demanding the ranges to recover the lead and the Sec-
                               retary General of IFFS and the President of ESC express "that we will do eve-
                               rything possible to only permit competitions on shooting ranges which guaran-
                               tee the collection of the lead ammunition used" [ISSF 2004a].

                               To what extent lead shot is actually recovered today is presumably very varying
                               between the Member States and it has not been possible to identify any com-
                               prehensive surveys of the actual recovery rates. An estimate of the amount of
                               lead released to the environment from the actual clay pigeon shooting activities
                               is consequently not possible.

                               According to [AFEMS 2004a] shotgun cartridges are approximately used 50%
                               for hunting and 50% for shooting. According to table 3.5 about 16,600 tonnes
                               of lead is used annually in the EU15 for shotgun shooting. As mentioned above,
                               surveys of actual recovery rates are a prerequisite for an assessment of the
                               amount of lead released to shooting ranges today.

                               Besides approximately 1,200 tonnes is used for air-gun pellets. The air-pellets
                               are dominantly used for shooting and expected mainly to be disposed of for re-
                               cycling, though a minor part used in households may be released to the envi-
                               ronment.

                               A significant part of this is assumed to be recovered for recycling, but as men-
                               tioned above no actual data on recovery rates has been obtained.

Lead rifle and pistol          It is relatively simple to collect bullets from rifle and pistol shooting and the
shooting                       release of lead to the environment from these activities is considered small and
                               consists mainly of dust transported to the surrounding by the air and dust cre-
                               ated on impact e.g. when bullets are hitting earthen berms or traps etc.

                               According to table 3.5 approximately 2,700 tonnes lead is used annually in the
                               EU15 for rifle and pistol shooting. While it should be possible to collect a
                               dominant part of this lead for recycling no actual data on recovery rates has
                               been obtained.


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   74



                               The estimated impacts of different use restrictions on the release of lead to the
                               environment is summarised in table 3.21.

Cross-national per-            The environmental issues discussed in this section can in principle be divided
spectives within the           into the following:
EU
                               !   The resource issue which basically is a global issue and of concern to all
                                   countries in the world. The issue is hardly relevant in a discussion of cross-
                                   national perspectives within the EU.

                               !   The issue of poisoning of birds and in particular of waterfowl. To the extent
                                   the birds exposed to lead shots by ingestion - direct ingestion as well as
                                   secondary ingestion - are migratory birds the actions of individual Member
                                   States may naturally influence other Member States, as birds naturally be-
                                   longing to the environment in some Member States may be poisoned during
                                   their travel through and temporary stay in other Member states. This per-
                                   spective is certainly relevant for many species of waterfowl and will to a
                                   limited extent be relevant for upland birds as well. The issue may thus jus-
                                   tify a coordinated effort within the EU related to the use of lead shot in wet-
                                   lands and to a limited extent also to the use of lead shot for hunting in gen-
                                   eral.

                               !   The issue of soil contamination which fundamentally is a local and thus na-
                                   tional issue apart from contamination taking place in border zones. The is-
                                   sue of soil contamination is the environmental issue in focus considering
                                   use of lead bullets and pellets for hunting as well as lead ammunition for
                                   shooting in general.

                               To these issues may be added the general issues of emissions caused by
                               primary and secondary production of lead and waste disposal. As stated earlier
                               a review of these emissions is beyond the scope of this study, but a restriction
                               of the use of lead for ammunition would naturally also reduce the releases from
                               these activities.




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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              75



                               Table 3.21        Reduced lead consumption and release to the environment by restrict-
                                                 ing the use of lead in EU15

                                Application for which lead is re-       Reduced lead consumption       Reduced release of lead to the
                                stricted                                                                      environment
                                                                              Tonnes/year                      Tonnes/year
                                Lead shot for hunting in wetlands              3,600 1)                         3,400-3,600
                                Lead shot for other hunting activi-            14,400 1)                      13,700-14,400
                                ties
                                Rifle bullets for hunting                         150                            140-150
                                Lead shot for clay target shooting               17,800                            ? 2)
                                and air gun pellets
                                Rifle and pistol bullets for shooting            2,700                             ? 2)
                               1)   The precise amount used in wetlands is not known. The figures should be regarded as a first es-
                                    timate and are mutually interdependent. The total is estimated at 18,000 t.
                               2)   Released on shooting ranges, no data on recovery rates available




Alternatives to lead           While iron presents an clear improvement compared to lead considering
                               toxicity as well as other environmental issues, other alternatives suffers from
                               one or more drawbacks inclusive of lack of data. All main alternatives to lead -
                               steel, tungsten, bismuth and tin - have the advantage of being non toxic to birds.

                               Regarding shooting it is relevant to emphasize that the potential benefits related
                               to substitution of lead ammunition is highly depending on the management of
                               the shooting ranges. Shooting performed on shooting ranges designed and man-
                               aged in a way allowing almost complete collection and recycling of lead - as
                               well as other metals - does not for environmental reasons call strongly for a
                               substitution of lead.


                               3.7.3 Discussion of the need for a community wide approach
                               Regarding the need for a common approach related to restrictions on the mar-
                               keting and use of lead in ammunition, the following arguments calling for a
                               common approach have been identified:

                               1) Lead shot is an important source of poisoning of birds and in particular of
                                  waterfowl. As many birds and in particularly waterfowl are migratory birds
                                  the actions of individual Member States may naturally influence other
                                  Member States, as birds naturally belonging to the environment in some
                                  Member States may be poisoned during their travel through and temporary
                                  stay in other Member states.

                               2) National restrictions could hamper the free trade in EU, as substantial trade
                                  of cartridges and components between Member States is taking place mean-
                                  ing that in reality a common market for hunting and sports shooting ammu-
                                  nition exist in EU. It is obvious that any restriction introduced in a member
                                  state will have some effect on companies in other member states consider-
                                  ing the extensive trade across EU (reference is made to section3.2.5). As-



                                                                                                                                        .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   76



                                   suming that appropriate time will be allowed for companies to adapt to re-
                                   strictions, it is, however, difficult to believe that such restrictions will be
                                   critical to more than very few companies.

                               However, attention may also be paid to the following argument partly opposing
                               the need for a common approach:

                               3) To the extent the main environmental impact is soil contamination condi-
                                  tions may differ between the Member States with respect to e.g. the content
                                  of lead in soil, the mobility of lead in soil, the lead load on soil from ammu-
                                  nition and other sources etc. These differences may motivate Member
                                  States to establish individual local or national restrictions regarding the use
                                  of lead ammunition for hunting and shooting as well as for design and op-
                                  eration of shooting ranges, as some Member States naturally may feel a
                                  need to be more restrictive on lead than other Member States.

Discussion of restric-         Compared to the restriction options presented in table 3.21 it is obvious that
tion options available         arguments related to migratory birds exist for a community wide approach re-
                               garding the use of lead shot for hunting in wetlands inclusive of the fact that
                               several non-lead substitutes deemed non-toxic to birds are easily available on
                               the market.

                               Considering lead shot for other hunting activities the picture is more compli-
                               cated, as it is debatable to what extent the risk of lead shot is significant to birds
                               and a restriction may also be argued by the general impact of lead shot on the
                               soil environment. In this context it is relevant to note that while steel shot is a
                               favourite alternative to lead shot other alternatives should be preferred in areas
                               with hard surfaces like rocks due to the risk of ricochets. Steel shot may, fur-
                               thermore, not be allowed in forest areas where the wood is utilised for indus-
                               trial production. However, the data available on soil toxicity for other substi-
                               tutes with a softness similar to lead as tin, bismuth and tungsten are scarce and
                               does in reality not allow a substantiated conclusion on whether these metals can
                               be regarded as an improvement in the soil environment compared to lead or
                               not. It is recommended that research is initiated that can eliminate the current
                               lack of data. This recommendation is supported by the fact that new data on
                               tungsten has indicated effects towards humans as well as soil organisms and
                               plants.

                               However, despite these uncertainties regarding available substitutes to lead shot
                               Member States may for environmental reasons consider it justified to introduce
                               national restrictions on the use on lead based on national conditions. The only
                               argument in favour of a community wide approach in this context would be the
                               trade argument stated above as (2).

                               Considering riffle bullets for hunting the discussion is very similar to the dis-
                               cussion above for lead shot for other hunting activities apart from that substi-
                               tutes for lead riffle bullets are less developed and tested than substitutes for lead
                               shot.




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   77



                               Considering lead shot and air gun pellets for shooting the environmental issue
                               in focus is generally the issue of soil contamination which is a local or national
                               issue not calling for a community-wide approach. This conclusion is also sup-
                               ported by the fact that the potential benefits related to substitution of lead am-
                               munition are highly depending on the management of the shooting ranges and
                               that it should be possible to design and operate shooting ranges in a way allow-
                               ing almost complete collection and recycling of lead. A strategy of collection
                               and recycling of lead is strongly supported by ISSF. It remains, however, to be
                               seen whether this strategy is more or less cost-effective than a strategy of sub-
                               stitution of lead ammunition. In case substitution turns out to be more cost-
                               effective the option always remains to restrict the use of lead on the individual
                               shooting ranges or nationally. Thus the only argument in favour of a commu-
                               nity wide approach in this context would be the trade argument stated above as
                               (2). It may be noted that also with respect to shooting ranges Member States
                               may for environmental reasons consider it justified to introduce restrictions on
                               the use on lead based on national conditions.

                               Considering riffle and pistol bullets for shooting the discussion is similar to the
                               discussion above for lead shot and air gun pellets for shooting.


                               3.8        Summary and conclusion
Existing market                The European (EU15 area) market for sporting and hunting ammunition can be
overview                       characterised by the following key figures:

                               •     6.2 million hunters
                               •     2.5 million sports shooters
                               •     Hunters and shooters use roughly 39,000 tonnes of lead annually
                               •     Approximately 50-100 companies are involved in ammunitions manufac-
                                     turing and the general industry structure is quite complex
                               •     The manufacturing industry annually produces ammunition representing a
                                     load of 53,000 tonnes of lead
                               •     The EU15 as a whole is a net exporter of ammunition (the net export
                                     comes up to about 14,000 tonnes of lead annually)
                               •     17-18% of total ammunitions production is exchanged across borders
                                     within the EU15 area annually - hence there appears to be a well-
                                     developed common internal market; this is even more evident for the sepa-
                                     rate market of ammunition components (i.e. not finished cartridges)
                               •     The ammunitions market is assessed to be worth of roughly 300 million
                                     euros annually (worth of production based on average import/export prices
                                     for 2003); measured in terms of retail prices (what hunters and shooters
                                     pay in retail stores) the market could be assessed to be worth of some 400-
                                     500 million euros
                               •     Approximately 70% of the market (measured in monetary terms) is for
                                     shotgun ammunition; similarly, approximately 90% of the lead annually
                                     consumed (measured in tonnes lead) is for shotgun ammunition.

Existing regulation            The existing regulation within the EU15 area on the use of sporting and hunting
overview                       ammunition can be summarised as follows:



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   78



                               •    Full bans on the use of lead shotgun ammunition are applied in the Nether-
                                    lands and in Denmark.
                               •    Partial bans on the use of lead shotgun ammunition are applied in Belgium,
                                    Finland, Sweden and UK (use in wetland areas or other special protected
                                    resorts).
                               •    Use of lead shotgun ammunition for sports shooting is restricted in Den-
                                    mark and Netherlands; selected shooting ranges are exempted for interna-
                                    tional competition purposes and training for such competitions, however.
                               •    The internationally applied rules for sport shooting do not require the use
                                    of lead ammunition in any sporting disciplines (typically the provision is
                                    "lead or other soft material"); practically, lead ammunition is used in al-
                                    most all shooting disciplines, reportedly due to attractive performance
                                    characteristics of such ammunition.
                               •    Use of lead centre fire or lead rim fire ammunition is not restricted for
                                    hunting or for sporting purposes (with few exemptions, notably in Swe-
                                    den).



Impact on industry,            Direct costs cover required investments for conversion of lead based ammuni-
direct costs                   tions production lines into production lines based on substitute metals, as well
                               as operating and administrative costs and consist of two separately identified
                               cost components: costs for development of new products (research and devel-
                               opment) and cost for adaptation of existing machinery, thus allowing the ma-
                               chinery to work properly with substitute metals. Conversion costs (costs of a
                               full conversion of existing lead based production lines) have been estimated at
                               approximately 310 million € based on information provided by the European
                               ammunitions manufacturing industry.

                               Incremental costs of a full ban on the use of lead ammunition - apart from con-
                               version costs described above - relate in principle solely to increased costs for
                               the detailed manufacturing of pellets/shots/bullets (seen as a separate cartridge
                               component). For a number of the available substitute metals the major part of
                               these costs would be incurred by the substantially higher price of the raw mate-
                               rials. An exemplary calculation indicates that retail prices of an average hunting
                               shotgun cartridge may increase by 25-50% due to higher expenses for raw ma-
                               terials alone. To this will be added additional costs for more costly manufactur-
                               ing processes.

                               All subsequent downstream steps in the manufacturing process of a cartridge is
                               assessed to be similar (at least in cost terms) to that of a lead based production
                               line. Thus costs for other ammunition components - propellant, case, wad and
                               primer - as well as costs for loading, printing, packaging and distribution would
                               remain unchanged once the industry conversion has been completed.

                               Additional costs could be foreseen in case parallel production lines of lead and
                               non-lead ammunition are established and maintained (this could be relevant for
                               example in order to serve export markets even in case of a full ban on the use of
                               lead ammunition in Europe).



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   79



Impact on industry,            Indirect costs cover consequences for the manufacturers regarding competitive-
indirect costs                 ness and their decisions to invest and innovate due to the proposed regulation.
                               Focus in this respect is on the existing manufacturers of lead shot/pellets/bullets
                               as the sub-sector of the entire ammunitions industry, which is likely to be hit
                               hardest by any new regulation on the use of lead ammunition. For this particu-
                               lar sub-sector the barriers involved in converting production lines as well as in
                               acquiring new know-how could be severe.

                               Of the AFEMS-members 5 companies (1 French, 1 Greek, 2 Italian and 1 Span-
                               ish) have been identified as specialist suppliers of lead shots/pellets, implying
                               that these five are not engaged in manufacturing of other ammunition compo-
                               nents or loading of final cartridges. The consequences of a ban on the use of
                               lead shot/pellets must be expected to be particularly hard felt for these 5 com-
                               panies. It is assumed that these 5 companies most likely represent a total staff
                               of employees of less than 200 and a total turnover of less than 100 mill.€/year.
                               3 other lead shot manufacturers exist, but these are engaged in other activities
                               related to ammunitions manufacturing parallel to the production of lead shot.
                               Together these 8 manufacturers are covering 90% of the production of lead shot
                               in EU15, indicating that the number of employees and the turnover of other
                               companies active in this field is limited.

                               Also 3 companies, which reportedly are engaged in manufacturing of machines
                               for lead shot production may face severe consequences. The know-how used in
                               lead processing cannot be transferred directly to for example steel processing.
                               Those companies that are not engaged in other types of lead processing (for
                               example produces lead sheets for roofing or similar parallel to the production of
                               lead shot for ammunition) may simply be pushed out of the market in case of a
                               full ban on the use of lead ammunition. It is noted that the number of employ-
                               ees and the turnover of these companies are not known.

                               Other lead shot manufacturers will probably to a varying extent be able to di-
                               versify their activities into some of the other manufacturing processes, in which
                               they are also engaged apart from the lead shot manufacturing. At least in a tran-
                               sitional period until production lines have been fully converted as described
                               above.

Social costs of tran-          To the extent manufacturing activity is taken over by other European compa-
sition                         nies, the economic impact is minimized, but social costs related to the transition
                               process remains. It is, however, at the present stage not possible to assess the
                               social costs related to the transition process. Generally such transition costs de-
                               pend heavily on the conditions in the region in which the company is located
                               and is thus generally difficult to assess. However, as the number of employees
                               affected seems to be relatively small the social costs of transition are likely lim-
                               ited.

Impact on hunters              The end users - sports shooters and hunters - will eventually pay for any in-
                               creased costs in manufacturing of ammunition through increased price levels
                               for the individual cartridges. Increased costs not only cover higher prices for
                               the raw materials used, but also cover the costs of more complex production
                               techniques as well as the conversion costs of the industry described above.


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   80



                               The incremental cost of ammunition is estimated at 22€ - 46€ for the average
                               European hunter if lead ammunition was to be completely banned for all hunt-
                               ing. To this should be added a one-time cost of 50€ per testing related to safety
                               testing of a shotgun. Spread over 5 years this conversion cost corresponds to an
                               annual incremental cost of 13€ per hunter.

                               The safety testing relates to the fact that the cheapest alternative available to
                               lead shot is steel shot, which however cannot be used in some old guns with
                               thin-walled barrels as these guns may explode or be damaged if trying. For a
                               number of other alternatives as shot made of tin, bismuth or tungsten, this prob-
                               lem does not exist. These other alternatives are however significantly more ex-
                               pensive than steel shot. The incremental cost of ammunition is calculated based
                               on a mix of alternatives giving each hunter having an old gun the choice of
                               whether to have the gun tested - and replaced if it does not pass the test - in or-
                               der to benefit from the relatively cheap steel shot or to use the gun with the
                               more expensive cartridges based on e.g. tin, bismuth or tungsten.

                               Other consequences to the hunter will vary with the alternative preferred.
                               Bismuth and tungsten-polymer shot will behave very similar to lead shot hav-
                               ing a significant higher price as their main disadvantage. Steel shot is the
                               cheapest alternative but will behave ballistic differently requiring the shooter to
                               shorten the shooting distance and generally get accustomed to this type of shot.
                               Furthermore, the shooter must be more careful as the risks of ricochets are
                               higher with steel shot. For this reason steel shot cannot be recommended in ar-
                               eas with hard surfaces like rocks. Finally steel shot may be not recommended in
                               forests in which the trees are utilised by the wood industry. Tin shot is like an
                               in-between being as light as steel and as soft as lead, bismuth and tungsten-
                               polymer.

                               Alternatives for other types of hunting ammunition like in particular bullets are
                               not as developed as alternatives for lead shotgun cartridges. Non-lead ammuni-
                               tion claimed to be appropriate is being marketed. Development efforts address-
                               ing non-lead bullet ammunition seem, however primarily to be related to mili-
                               tary ammunition.

Impact on sports               The incremental cost of ammunition to the average European shooter is esti-
shooters                       mated at 27 - 55€ for shotgun ammunition, 2 - 20€ for bullet ammunition, and 8
                               -24€ for airgun ammunition, corresponding to a total of 37 - 99€, if lead am-
                               munition was to be completely banned for all shooting. For shotgun ammuni-
                               tion is assumed that lead is substituted by a mix of steel, tin, bismuth and tung-
                               sten ammunition, while for airguns tin pellets is assumed to be an acceptable
                               alternative. The alternatives regarding bullets are not that developed, and de-
                               velopments efforts seem primarily to be focused on military ammunition.

                               These figures indicated above describes the incremental cost to the average
                               shooter, while a competitive shot gun shooter may have to face extra costs in
                               the range of 500€ to 7500€ annually due to a significantly higher consumption
                               of shot gun cartridges. The same picture applies to a competitive pistol, rifle or
                               air gun shooter.



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   81



                               As the dominant alternative for shotgun shooters also is assumed to be steel
                               shot again the issue of gun testing is relevant besides that for many shotguns
                               new chokes will have to be installed. This one-time conversion cost of 50 -100€
                               pr shooter assumed relevant for 50% of all shooters will spread over 5 years
                               correspond to an annual incremental cost of 6.5 - 13€ taken as an average for all
                               shooters.

                               Finally, competitive shooters with very high cartridge consumption may face
                               increased barrel wear due to steel shot forcing frequent replacement of weap-
                               ons. Assuming that 3 - 5 % of all sport shooters will make an extra replace-
                               ment of their weapon annually the costs incurred will correspond to an annual
                               incremental cost of 30 -50€ as average for all sport shooters.

                               Other consequences of a restriction on the use of lead ammunition to sports
                               shooters include the following:

                               •    Steel, a likely alternative to lead for shotguns, imply higher safety risks at
                                    shooting ranges due to the risks of ricocheting shot and a ban on the use of
                                    lead based shotgun ammunition could require reengineering of many exist-
                                    ing shooting ranges;

                               •    As lead ammunition is the ammunition normally used at international sport
                                    shooting events, European shooters may have to compete on unfair terms.

                               The international sports shooting association (ISSF) recommends that collec-
                               tion and recycling of the lead from shooting ranges are promoted rather than
                               substitutes for lead ammunition. It is believed that significant improvements in
                               this field are possible, and that shooting ranges can be designed and operated in
                               a way paying full respect to environmental concerns related to inter alia lead.

                               It must be recognised that measures for effective collection of lead ammunition
                               at shooting ranges and remediation of range areas exist and is being further de-
                               veloped. However, a strategy of improving design and operation of shooting
                               ranges will certainly imply higher cost and it remains to be seen whether this
                               strategy is more cost-effective than a strategy of substitution of lead ammuni-
                               tion.

Impact of lead and             The main environmental and health issues related to lead ammunition is as fol-
substitutes on envi-           lows:
ronment and health
                               !   Poisoning of waterfowl and other birds by ingestion of lead split shot and
                                   sinkers and the following secondary poisoning of raptors. Poisoning of wa-
                                   terfowl may in special cases form a health risk to humans consuming these
                                   birds.

                               !   Lead contamination of soil taking place on agricultural areas, in forests and
                                   other areas used as hunting grounds as well as on shooting ranges. Metallic
                                   lead is in soil slowly corroded and turned into toxic lead compounds. Lead
                                   ammunition is today regarded as the major source of lead contamination of
                                   soils slowly causing the content of lead in topsoil to increase. No compre-


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   82



                                   hensive assessment of the effects of this increase exists. However, a contin-
                                   ued increase will narrow the gab between the current lead content of soil
                                   and the levels for which effects may actually be observed and could eventu-
                                   ally cause these levels to be exceeded. The effects of lead to be expected
                                   cover toxicity of lead towards humans as well as towards plants, animals
                                   and micro-organisms.

                               While the issue of poisoning of waterfowl and other birds is related to the use
                               of lead shot in wetlands and upland areas the issue of soil contamination is re-
                               lated to all types of lead ammunition.

                               Substitutes based on steel, tin, bismuth and tungsten is approved as non-toxic to
                               birds in either USA or Canada. Regarding other impacts only iron presents a
                               clear improvement compared to lead, while other alternatives suffers from one
                               or more drawbacks inclusive of lack of data. Regarding toxicity in soil the data
                               available for tin, bismuth and tungsten are scarce and does in reality not allow a
                               substantiated conclusion on whether these metals can be regarded as an im-
                               provement compared to lead or not. It is recommended that research is initiated
                               that can eliminate the current lack of data. This recommendation is supported
                               by the fact that new data on tungsten has indicated effects towards humans as
                               well as soil organisms and plants.

The need for a com-            It is assessed that arguments exist for a community wide approach regarding
munity wide ap-                the use of lead shot in wetlands, as in particularly waterfowl are migratory birds
proach                         and the actions of individual Member States may naturally influence other
                               Member States.

                               Regarding other hunting activities the picture is more complicated, as the pri-
                               mary environmental problem in this context seems to be the issue of soil con-
                               tamination, and it is unclear whether the substitutes available in all cases repre-
                               sent an improvement in the soil environment compared to lead. Soil contamina-
                               tion should generally be regarded as a local or national issue and despite the
                               uncertainties mentioned regarding available substitutes to lead shot Member
                               States may for environmental reasons consider it justified to introduce restric-
                               tions on the use on lead based on national environmental conditions. The only
                               argument in favour of a community wide approach in this context would thus
                               be the implications of such restrictions towards the free trade across the EU.
                               Assuming that appropriate time will be allowed for companies to adapt to re-
                               strictions, it is difficult to believe that such restrictions will be critical to more
                               than very few companies.

                               Regarding shooting activities the environmental issue in focus again is the issue
                               of soil contamination which should regarded as a local or national issue. As
                               already stated ISSF has proposed a strategy of promoting improved the design
                               and operation of shooting ranges in order to ensure almost completely collec-
                               tion and recycling of lead. In case substitution turns out to be more cost-
                               effective the option always remains to restrict the use of lead on the individual
                               shooting ranges or nationally. Also for shooting ranges specific national restric-
                               tions may be considered justified by national environmental conditions. Thus
                               the only argument in favour for a community wide approach in this context


                                                                                                                         .
  Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                 83



                                 would be the implications of such restrictions towards the free trade across EU
                                 and again assuming that appropriate time will be allowed for companies to
                                 adapt to restrictions, it is difficult to believe that such restrictions will be criti-
                                 cal to more than very few companies.

  Cost and conse-                The cost and consequences in terms of reduced contribution of lead to the envi-
  quences of selected            ronment in the EU related to the possible restriction options are presented in
  measures                       table 3.22.




                                 Table 3.22        Estimated costs of selected measures to reduce the load to the environ-
                                                   ment from lead containing ammunition, EU-15 area

                                                                        Phase-out regime
                            Lead shot for     Lead shot for     Lead bullets for   Lead shot and      Lead bullets for        Total
                           hunting in wet-    other hunting        hunting,        air gun pellets       shooting
                                lands           activities                          for shooting
                                  1)                2)

Total costs per ton lead   12,200 - 20,600   12,200 - 20,600    1,200 - 10,300     10,100 - 19,700    1,850 - 18,500     10,500 - 19,900
substituted (€/t)
1)
Total costs in EU-15           44 - 74          176 - 296          0.18 - 1.5         180 - 350            5 - 50           405 - 770
(mill.€/year) 1)
Reduced load to the         3,400 - 3,600    13,700 - 14,400       140 - 150         ? - 17,800          ? - 2,700       17,240 - 38,600
environment in EU-15                                                                      3)                 3)
(tonnes lead/year)
                                 Source      Own calculations
                                 1)          All costs are based on estimated retail prices and includes for shot gun also the anticipated
                                             costs of testing of weapons. Costs of reduced remedial actions related to shooting ranges
                                             and other areas exposed to soil contamination are not included. Costs of transition incl. of
                                             social costs for companies not able to adapt to restrictions are not included either.
                                 2)          For hunting in wetlands as well as other hunting activities has been assumed a mix of 50
                                             steel, 20% bismuth, 20% tungsten and 10% tin. It is likely that the percentage of steel
                                             could be higher in wetlands causing the average cost per ton of lead substituted to be less
                                             than for other activities. It is assumed that 20% of all shotgun hunting takes place in wet-
                                             lands areas.
                                 3)          Some collection and recycling is taking place already today. However, no exact data on
                                             the amount of lead recycled is available.




                                                                                                                                            .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   84



                                  4          Fishing sinkers

                                  4.1        Application of lead in fishing sinkers
                                  Fishing sinkers are uses for both angling (recreational fishing) and commercial
                                  fishing. In this context the term sinkers is used as anonymous for all applica-
                                  tions of lead for lures and fishing equipment.

   Angling                        Lead is used for angling in a number of lures: Sinkers/weights, jigs, wobblers,
                                  downrigger weights, split shot, pirks, etc. (See Figure 4.1). In this study the
                                  term 'sinkers' is used for all these applications.

                                  Figure 4.1       Fishing lures that typically contain lead
Sinkers/weights                                                                  Jigs




Split shot                              Downrigger weight                        Pirks




Sources: Grejbiksen Albæk, http://gbab.dk/catalog; Cabelas Inc., http://www.cabelas.com




                                  The weight of split shot range from fractions of a gram to about 50 gram. The
                                  weight of sinkers, which consists of a lead body with one or more eyelets to
                                  fasten the fishing line with a knot, range from a couple of grams to several
                                  hundred grams. Downriggers may weight up to 5 kg whereas the weight of




                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   85



                               pirks typically ranges from 100-600 g. Wobblers are mainly made of wood or
                               plastics but contain often a small part of lead.

                               Split shot, small sinkers/weights, and wobblers are mainly used in fresh water,
                               whereas larger sinkers/weights, downrigger weights and pirks are used in the
                               sea.

Commercial and ar-             For commercial and artisanal fishing (small-scale semi-commercial and recrea-
tisanal fishing                tional fishing using nets), lead is used in at least three different ways dependent
                               on the specific fishing nets:

                               Seine ropes are used for large seines (nets), mainly used for fishing benthic
                               fish on relatively shallow water as in the North Sea. The seine rope is typi-
                               cally designed as a woven rope with a thin lead wire woven into the fila-
                               ments of polypropylene or polyester, which is sewn to the net. Benthic seine
                               nets are mainly used in Denmark, Scotland, Norway and Iceland. Seine
                               ropes are produced in different diameters and the weight of the ropes range
                               from about 23 to 85 kg per 100 m.




                               Lead lines are used all over Europe for pound nets (or set nets). A line is
                               made of small pieces of lead beads threaded on a plastic rope. The string of
                               lead beads is covered by a woven plastic stocking of polypropylene,
                               polyester or other plastics and the stocking is sewn or woven on the net.
                               Lead lines are produced in different diameters and the weight range from
                               about 2 to 20 kg per 100 m.




                               Sinkers/weights are used all over Europe for large ring nets or seines for pe-
                               lagic fish, some type of trawls, fykes, hoop nets and other types of net fishing.
                               The size and design of the weights may differ considerably and the weights
                               shown below represent a few examples only. Lead weight for fishing nets
                               ranges from about 50 g to several kg per weight.




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   86




                               Lead is in general not used for trawl. The trawls are in general equipped with
                               steel wires, but lead sinkers may in some cases be used in addition.


                               4.2        Markets of fishing sinkers

                               4.2.1 Angling
                               Manufacturers of tackle for angling are organised in the European Fishing
                               Tackle Trade Association (EFTTA) located in London. The organisation has
                               currently more than 250 members and represents about 80% of the producers
                               and wholesalers in the EU in terms of turnover. The organisation provides sta-
                               tistics on export/import by country obtained from national statistical bureaus.

                               In the nomenclature of production and trade statistics lead-containing tackle is
                               included in a commodity group including all fishing tackle exclusive rods, reels
                               and hooks. EFFTA does not hold any statistics specifically on sinkers and no
                               specific information on the use of lead for sinker production in the EU.

Production and trade           Statistics on production and trade of tackle for angling is shown in Annex 3.
statistics                     Lead-containing lures are included under a commodity code covering all lures,
                               landing nets and other equipment exclusive rods, reels and hooks. The total re-
                               ported production for EU15 according to the PRODCOM statistics add up to
                               about 80 million €/year (table A3.18). However, the production statistics seems
                               not to include production figures for all Member States. Import and export sta-
                               tistics are more complete. In total the export from the Member States totalled
                               about 65 million €/year.

                               The import/export statistics from the COMEXT database (table A3.19-A3.23)
                               average of 2000-2002) seems to use a slightly different delimitation of the
                               commodity code and the import/export data from PRODCOM and COMEXT,
                               respectively, are not immediately comparable. According to the COMEXT sta-
                               tistics (table A3.22) intra-community export from the Member States totalled
                               86 million € with Finland, France, Italy and UK as the main export countries.
                               The extra-community export totalled 65 million € with Finland, Ireland and
                               Italy as the main export countries.

                               EU15 is net-importer of the equipment concerned (table A3.23). The total ex-
                               tra-community import totalled 85 million €.

                               The total import to EU15 countries of line fishing tackle n.e.s. in tonnes in-
                               creased from 4,700 tonnes in 1993 to 14,000 tonnes in 2003 (Figure 4.2). Pro-



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                     87



                               duction data are only available in monetary units and only for some of the
                               member States.

                               Figure 4.2                        Total import of line fishing tackle n.e.s; fish landing nets, butterfly nets
                                                                 and similar nets; decoys and similar hunting or shooting requisites (ex-
                                                                 clusive rods, reels and hooks) (CN 95.07.90.00) to EU15 Member States
                                                                 1993-2003

                                                        16,000

                                                                        Extra EU15
                                                        14,000
                                                                        Intra EU15
                                                        12,000
                                 Import (tonnes/year)




                                                        10,000

                                                         8,000

                                                         6,000

                                                         4,000

                                                         2,000

                                                           -
                                                                 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003



                               According to a leading European wholesaler of fishing tackle, the lead-
                               containing lures account for about 10-15% of the total market for lures and for
                               less than 3% of the total fishing tackle market in monetary terms. Assuming
                               that sinkers and other lead-containing lures account for 10-20 % of the products
                               covered by CN 95.07.90.00 (figure 4.2) and that import account for 2/3 of the
                               total consumption, the weight of the lead-containing lures can be estimated at
                               2,000-4,000 t/year in accordance with the estimates of the total consumption
                               presented below.

Fishing tackle com-            Turnover of the major European fishing tackle companies based on information
panies                         from EFTTA is shown in table 4.1 (turnover off all types of tackle and fishing
                               equipment). It has not been possible to obtain information on the turnover of
                               the remaining companies, but it is estimated by EFTTA that the 20 largest
                               companies account for at least 50% of the total turnover.

                               Names of specific companies are considered confidential by EFFTA and will
                               not be reported here.




                                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           88



                               Table 4.1        Turnover of European fishing tackle companies in 2001 (EFTTA 2004)

                                                                           Total domestic turnover           Total export turnover
                                                                                 Million US$                      Million US$
                               5 biggest companies                                    86                                125
                               15 following companies                                128                                74




                               It must be expected that the production is concentrated on fewer companies for
                               high-tech products like rods and reels, whereas manufacturing of sinkers is
                               relatively simple and may take place in many smaller companies. According to
                               the database of EFTTA, 159 European members of EFTTA are registered as
                               manufacturers of weights/sinkers. In total, inclusive non-members, the database
                               holds information on 1,637 European manufacturers of weights/sinkers. A spot
                               check of the manufacturers of the latter list indicates that this list includes
                               manufacturers of equipment for professional fishing and manufacturers no
                               longer in operation or not producing sinkers. The lists are considered confiden-
                               tial.

                               The manufacturers of weights/sinkers are spread over most of Europe with
                               most producers (organised in EFTTA) in France, Germany, Italy and the UK
                               and Poland. Sinkers and other lead-containing lures are to a large extent sold on
                               the domestic market. As an example two Danish producers of lead-containing
                               lures ceased the production following the Danish ban on lead in sinkers.

                               It is relatively simple to manufacture sinkers and it can easily be done in a
                               small workshop. There seems not to be any "major" manufacturers in Europe.
                               At the international trade fair for fishing tackle, EFTTEX, in 2003, 10 manufac-
                               turers were registered in the catalogue as manufacturers of weights and sinkers.
                               All of these have been contacted as part of this study.

                               Most of the contacted manufacturers are either manufacturing different tackle
                               with sinkers as a minor part of their supply of products or they are lead foun-
                               dries, with sinkers as a small part of their supply of products besides batteries,
                               keels, and other lead products. The only identified companies of a certain size
                               (>20 employees) which have manufacturing of sinkers as their main activity are
                               situated in Eastern Europe. Among the contacted companies who provided spe-
                               cific information one company used about 150 t lead/year for sinkers.

                               Most of the contacted manufacturers are either manufacturing different tackle
                               with sinkers as a minor part of their supply of products or they are lead foun-
                               dries, with sinkers as a small part of their supply of products besides batteries,
                               keels, and other lead products. The only identified companies of a certain size
                               (>20 employees) which have manufacturing of sinkers as their main activity are
                               situated in Eastern Europe. As production volumes are considered confidential
                               actual figures on the use of lead for production has only been obtained from a
                               few manufacturers.




                                                                                                                                     .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   89



Common market                  The statistical data shows that there is an extensive trade of lures (and other
                               fishing tackle other than rods, reels and hooks) between the Member States
                               (Table A3.22 in Annex 3) and a common market seems to exist for lures in
                               general. Contact to a large number of manufacturers of sinkers, however, indi-
                               cate that for the simple sinkers the manufacturers mainly supply to the lo-
                               cal/national markets, but it actually difficult to trace where the products end up.
                               Only some manufacturers in the Czech Republic and Hungary have reported
                               that the major part of their production is exported.

                               A thorough assessment of the sinkers market in Europe would imply a compre-
                               hensive market survey and the positive participation of several hundreds of
                               manufacturers and wholesalers.

                               Table 4.2        European members of EFTTA recorded as manufacturers of
                                                weights/sinkers by country

                                                               Manufacturers of
                                                                Weights/sinkers
                               Austria                                        1
                               Belgium                                        4
                               Denmark                                        3
                               Finland                                        4
                               France                                        26
                               Germany                                       20
                               Greece                                         0
                               Ireland                                        0
                               Italy                                         35
                               Luxembourg                                     0
                               Netherlands                                    0
                               Portugal                                       2
                               Spain                                          5
                               Sweden                                         4
                               United Kingdom                                25
                               Czech Republic                                 3
                               Hungary                                        6
                               Latvia                                         1
                               Norway                                         3
                               Poland                                        14
                               Switzerland                                    3
                               Total                                        159




Lead consumption               In general only limited information is available on the consumption of lead for
                               fishing tackle in Europe. The European Fishing Tackle Trade Association
                               (EFTTA), European Anglers´ Alliance (EAA), the International Lead and Zinc
                               Study Group (ILZSG) and Lead Development Association International



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   90



                               (LDAI) have been contacted, but none of the organisations hold any informa-
                               tion on the use of lead for fishing sinkers at a European level.

                               In the statistics prepared by ILZSG, sinkers are included in 'miscellaneous
                               products' which also include yacht keels, curtain weights, counter balances, etc.
                               The total consumption for 'miscellaneous products' in EU15 is about 65,000
                               tonnes [TNO 2001].

                               A questionnaire and follow-up enquiries to environmental authorities in the old
                               and new Member States did except for Denmark not reveal any studies of the
                               use of lead for sinkers in the countries. The following information is obtained
                               by combining information from the literature with information from national
                               associations of manufacturers (identified through information obtained from
                               EFTTA) and from manufacturers of lead sinkers for angling.

                               As described in the next chapter, fishing sinkers are manufactured by a large
                               number of small manufacturers and the manufacturers mainly supplies to the
                               domestic markets. This makes it very difficult to identify 'major' manufacturers
                               and to obtain overall data on the use of lead in each country. It has for the data
                               retrieval been assumed that manufacturers exhibiting on the international fish-
                               ing tackle trade fair EFTTEX and registered in the catalogue as manufacturers
                               of sinkers could be regarded major manufacturers potentially supplying an in-
                               ternational market. However several of the manufacturers were actually not
                               producing lead sinkers.

- Denmark                      Denmark is the only country for which a detailed study of the use of lead for
                               fishing sinkers exists. The total content of lead in lures sold in Denmark in
                               2000 before the lead ban came into force is estimated at 97-170 t [Lassen et. al
                               2003], corresponding to 18-32 g/capita/year. The consumption can be broken
                               down into 30-51 t with general sinkers, 3-3.5 t with split shot, 4-12 t large troll-
                               ing sinkers, and 50-70 t with pirks, jigs, wobblers, etc. The consumption is ex-
                               pected to be decreasing because of the current Danish ban on the sale of lead
                               sinkers. The manufacturing of sinkers and pirks in Denmark has ceased the last
                               year because of the disappearance of a domestic market.

- Czech Republic               Manufacturers of fishing tackle in the Czech Republic are not organised in an
                               association Four to five manufacturers of sinkers are operating in the Czech
                               Republic and three of the Czech members of EFTTA are registered as manufac-
                               turers of sinkers. Three manufacturers of lead sinkers, members of EFTTA and
                               exhibiting on the EFTTEX and registered in the catalogue as manufacturers
                               were contacted. One of the manufacturers declined to participate in the study,
                               one informed that they were actually not producing sinkers and one provided
                               specific information. Based on information from manufacturer, that account for
                               a significant part of the domestic market, the domestic Czech market for fishing
                               sinkers is estimated at 40-100 t. The sinkers are mainly used for carp fishing.
                               Besides, there may be a significant home casting of lead sinkers. The consump-
                               tion of lead for production of sinkers in the Czech Republic is estimated to be
                               several thousand tonnes; the main part of the produced sinkers is exported.




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   91



- France                       The national association of manufacturers and wholesalers of fishing tackle,
                               GIFAB and a major manufacturer of sinkers were contacted. GIFAB has in-
                               formed that they are in the process of collecting information from manufactur-
                               ers, but no information has been received yet.

- Hungary                      Information about the Hungarian market for fishing sinkers have been collected
                               by COWI Hungary Ltd. [Varkonyi 2004]. Manufacturers of fishing tackle in
                               Hungary are not organised in an association. Besides four market leaders a
                               large number of small manufacturers (workshops) exist. The 4 leading manu-
                               facturers of lead sinkers, members of EFTTA and exhibiting on the EFTTEX
                               and registered in the catalogue as manufacturers (3 of the 4) were contacted.
                               Based on information from the manufacturers the domestic market of sinkers in
                               Hungary is estimated at 80-100 t lead. Some of the manufacturers report that up
                               to 90% of their production is exported to Western Europe, and the amount of
                               lead used for manufacturing of sinkers in Hungary is considerably higher than
                               the 80-100 t.

- Lithuania                    Information on the Lithuanian market of sinkers has been collected by UAB
                               COWI Baltic [Rinkevicius 2004]. Manufacturers of sinkers are not organised in
                               an association, and the list of manufacturers of sinkers from EFFTA do not in-
                               clude any Lithuanian manufacturers. Sinkers are only produced in small work-
                               shops and by home casting, and it has not been possible to obtain any estimate
                               of the sinker market in Lithuania.

- Italy                        The Italian association of manufacturers and wholesalers of fishing tackle,
                               FIPO, and two manufacturers of lead sinkers, members of EFFTA and exhibit-
                               ing on EFTTEX, were contacted. The contacted manufacturers confirm that
                               lead is used for manufacturing of sinkers in Italy, but that sinkers based on al-
                               ternatives to lead were manufactured as well. It has not been possible to obtain
                               an estimate of the Italian market. The difficulties in obtaining an estimate is
                               illustrated by the answer from the association of manufacturers, FIBO: "It is
                               true that are not many foundries in Italy which manufacture lead articles for
                               sports fishing, but there are small companies which manufacture the same arti-
                               cles for a limited market. A large part of the lead sinkers are imported from
                               abroad directly by the retailers, so it will be difficult to discover the market val-
                               ues" [FIPO 2004].

- Poland                       As regards the consumption of lead with sinkers, The Ministry of Environment,
                               describe the situation in their questionnaire response: "As far as sinkers and
                               candle wicks are concerned, these are mainly produced from micro and small
                               sized enterprises which are under the authorization of the Local Environmental
                               Authorities and it is extremely difficult to collect relevant data from them."

                               The Polish Association of Angling, manufacturers of sinkers and a fishing
                               tackle retailer have been contacted for collection of additional information.

                               About 20 manufacturers of sinkers operate in Poland and 14 of the Polish
                               members of EFTTA are registered as manufacturers of s inkers. The manufac-
                               turers produce mainly for the domestic market. The consumption of lead with
                               sinkers in Poland is, based on information from the Polish Angling Association,


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                 92



                               estimated at 1,000-1,500 t/year in inland waters and 20-40 t/year in marine wa-
                               ter (Baltic Sea). The estimate is based on information from the Polish Associa-
                               tion of Angling using an approach of multiplying the number of anglers with
                               the average amount of lead lost each time the go fishing and the number of fish-
                               ing expeditions as follows [Andruszkiewicz et al 2004]:

                    Technique                        Number of        Lost per expedition    Numbers of fish-           Total lost
                                                      anglers        (weight per sinkers x   ing expeditions
                                                                                                                        (t Pb/year)
                                                                       number of sinkers
                                                                              lost
                    Base techniques (float and         400,000             30 g x 1                 30                     360
                    similar)
                    Spinning                           500,000             10 g x 5                 30                     750
                    Carp fishing                       100,000             50 g x 1                 30                     150
                    Marine angling                     10,000              100 g x 1                30                      30
                    Total                                                                                                 1,290




                                It has not been possible to confirm the consumption estimate by actual infor-
                               mation on the Polish market from the contacted manufacturers. In countries
                               with many small manufacturers it seems to be a common problem that each
                               manufacturer does not know the volume of the whole market. Compared to
                               information from other countries the estimated amount of lead sinkers per an-
                               gler appears to be very high.

- The Netherlands              A Dutch survey estimate a load of lead from fishing sinkers in surface waters in
                               1993 of 28 tonnes, corresponding to 1.84 g/capita/year [Annema et al. 1995].
                               For the risk assessment, which is currently undertaken by LDAI, data from this
                               Dutch national emissions inventory is used to extrapolate the total releases from
                               fishing sinkers [Bush 2004].

- Spain and Portugal           Five Spanish companies and two Portuguese registered as members of EFTTA
                               and registered in the EFTTA database as manufacturers of fishing tackle were
                               contacted. The contacted Portuguese companies turned out not to manufacture
                               sinkers. No association of manufacturers of fishing tackle exist in Spain. The
                               contacted Spanish companies confirm the use of lead for sinkers in Spain and it
                               is informed that sinkers are produced by a large number of small enterprises
                               and that a significant part of the sinkers are manufactured by "home produc-
                               tion". It is not possible on the basis of the obtained information to estimate the
                               use of lead for production of sinkers in Spain or the volume of the domestic
                               market.

- Sweden                       In Sweden about 200 t lead was used for lures in 1992 [Gustafsson et al. 1993],
                               corresponding to 22 g/capita. Swedish manufacturers and wholesalers of fish-
                               ing tackle is organised in the association, Spofa Spöfiske. The association has
                               for the present study collected information from its members. The recent as-
                               sessment shows that lures sold on the Swedish market in total contained only
                               about 3.5 t lead. All lead-containing equipment is imported and lead is to an
                               increasing extent being replaced by other materials.



                                                                                                                                       .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   93



- UK                           In the UK zinc and tin is used for split shot and small sinkers, whereas lead is
                               still used for large sinkers, pirks and other tackle used in the sea. According to a
                               leading producer of small sinkers in the UK, the UK market for split-shot and
                               non-toxic sinkers (<1 ounce) is about 40 t and 100 t, respectively corresponding
                               to 2.3 g/capita/year in total for these applications.

                               The consumption of lead for large sinkers and pirks is considerably higher and
                               is according to information from one manufacturer probably in the order of
                               magnitude of 500-1000 t, giving a per capita consumption at the same level as
                               reported for Denmark and Sweden.

                               The UK Angling Trades Association Ltd has been contacted for information on
                               the UK market of lead sinkers for this study, but holds no statistics on the pro-
                               duction or consumption of lead in angling equipment [Broughton 2004].

USA and Canada                 Considering the scarce data on the use of lead sinkers in Europe, data on the
                               consumption of lead sinkers in Canada is included here. Split shot sinkers are
                               estimated to account for almost half of total U.S. sinker production; and the ma-
                               jority of lead sinkers of all types are less than 2 cm in any direction [Scheu-
                               hammer and Norris 1995]. Canadian experts estimate that the mass of lead sold
                               as fishing sinkers annually in Canada is in the range of 388–559 t (12-17
                               g/capita). The main part of the sinkers is manufactured by so-called 'cottage
                               industries' [Scheuhammer and Norris 1995]. An undetermined additional
                               amount of lead is sold in the form of jigs. Virtually all of this lead is according
                               to the authors destined to be deposited into the environment [Scheuhammer and
                               Norris 1995].

Summary                        The obtained data are summarised in table 3.4. Based on information on total
                               population and the number of active anglers, per-capita and per-angler con-
                               sumption for each country is estimated.

General considerations According to a leading European wholesaler, the consumption per capita in
                       Denmark and other Scandinavian Countries is significantly higher than in most
                       other Western European countries because of a large consumption of pirks and
                       large sinkers used at sea. In Scandinavia a significant part is used for angling in
                       the sea using large sinkers, pirks and downriggers with a relatively high lead
                       content. In the rest of Europe angling in streams and lakes is more widespread
                       and split-shot and smaller sinkers seem to make up a major part of the con-
                       sumption. However, a major French manufacturer indicates that the lead con-
                       sumption for angling in the sea may be higher than the consumption in fresh
                       water in France, because the significantly higher weight of each sinker.

                               The information obtained from Eastern Europe indicates that the consumption
                               of lead may be higher in those countries which may be due to general differ-
                               ences in the lures used for the fishing (lead account only for a small part of the
                               total use of lures). Further it is indicated that there is a significant export of lead
                               sinkers from Czech Republic and Hungary to Western Europe.

                               The obtained data shows very large variations, in particular if consumption is
                               estimated in terms of consumption per angler per year. The per-angler con-


                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                    94



                                 sumption varies from 0.002 kg/year in Sweden to 1.7 kg/year (maximum in the
                                 range) in Poland. It should be noted that the data from the Poland is considered
                                 quite uncertain and may be an overestimation. The reported consumption in
                                 Sweden and the Netherlands is considerably lower than the reported consump-
                                 tion in the other countries.

                                 Considering the large variation is seems not to be feasible to try to estimate the
                                 consumption of lead for sinkers in the countries for which no data is available,
                                 neither on the basis of number of anglers nor total population.

                                 The total consumption of lead for sinkers for angling will here be roughly esti-
                                 mated on the basis of the available data. For the estimate it is assumed that the
                                 per-capita consumption is 10-30 g/capita/year whereas the per-angler consump-
                                 tion is assumed to be 0.1-0.3 kg/angler/year. The total number of angler in
                                 EU15 and EU25 is shown in table 4.4.

                                 Using the per-capita figures the total consumption in EU15 and EU25 can be
                                 estimated at 3,800-11,300 and 4,500-13,500 t/year respectively. Using the per-
                                 angler figures (table 4.4) the total consumption can be estimated at 1,900-5,600
                                 and 2,000-6,000 t/year for EU15 and EU25 respectively.

                                 As the number of anglers in percentage of the total population varies consid-
                                 erably, the per-angler estimate is considered most appropriate.

                                 Table 4.3          Annual consumption of lead for fishing sinkers for angling in

Country           Consumption           Total       Number of       Consumption         Consumption       Year of    Source
                                      Population    active an-                                             study
                    t Pb/year                                      g Pb/capita/year   kg Pb/angler/year
                                        Million    glers Million
                                                        1)
Czech republic       40-100             10.3           0.23             4-10               0.2-0.4         2004      This study

Denmark              97-170              5.3           0.45             18-32              0.2-0.4         2000      Lassen et al. 2003

France                  -               59.2            4                                                            This study
Hungary              80-100             10.2          0.325             8-10               0.2-0.3                   This study

Netherlands            28               15.9            1.5               2                 0.02           1993      Annema et al. 1995

Poland             1,020-1,530          38.6            0.6             26-40              1.7-2.6                   This study

Sweden                 200               9.0           2.02              22                  0.1           1992      Gustafsson et al.
                                                                                                                     1993

Sweden                 3.5               9.0           2.02              0.4               0.002           2004      This Study

UK                 500-1,000            59.6            4               8-17               0.1-0.3         2004      This study

Canada              388-559             32.5             0              12-17                 -            1995      Scheuhammer and
                                                                                                                     Norris 1995
                                 1)            Source: Website of European Anglers´ Alliance, 2004. See the source for details regarding
                                               the basis of the estimates: http://www.eaa-europe.org/2003/PFAbout/About-EAA-EN.htm




                                 For the impact assessment it will be assumed that the annual consumption in
                                 EU25 is 2,000-6,000 t lead (EU15: 1,900-5,600 t). It is not known how much of
                                 this is used in inland waters (fresh water). Data from the UK and Denmark in-


                                                                                                                                           .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   95



                               dicate that it is a minor part, whereas it seems to be a major part in Poland and
                               100% in countries like the Czech Republic. It will here be assumed that half of
                               the sinkers are used in fresh water; the remaining part used in the sea. It gives
                               an estimated consumption for fishing in inland waters in EU25 of 1,000-3,000
                               t. The loss of lead with fishing sinkers to inland waters in EU15 have previ-
                               ously based on the Dutch and Danish data been estimated at 1,000-3,000 t
                               [TNO 2001].




                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                   96



                               Table 4.4          Numbers of anglers in EU15 and EU25

                                                                     Active recreational an-    % of popu-         Total population
                                                                             glers 1)             lation

                               Austria                                           410,000            5.1                 8,100,000
                               Belgium                                           300,000             3                 10,000,000
                               Denmark                                           451,000            8.5                 5,300,000
                               Finland 2)                                      1,390,000            26.7                5,200,000
                               France                                          4,000,000            6.8                59,200,000
                               Germany                                         3,300,000             4                 82,200,000
                               Greece                                            no data              -                10,500,000
                               Ireland                                           200,000            5.3                 3,800,000
                               Italy                                             900,000            1.6                57,700,000
                               Luxembourg                                          4,000             1                    400,000
                               Netherlands                                     1,500,000            9.4                15,900,000
                               Portugal                                          230,000            2.3                10,000,000
                               Spain                                             no data              -                39,400,000
                               Sweden                                          2,020,000            22.7                8,900,000
                               UK                                              4,000,000            6.7                59,600,000
                               Total EU15                                    18,705,000                               376,200,000
                               Cyprus                                              3,000            0.4                   800,000
                               Czech Republic                                    263 000            2.6                10,300,000
                               Estonia                                            50,000            3.6                 1,400,000
                               Hungary                                           325,000            3.2                10,200,000
                               Latvia                                            200,000            8.3                 2,400,000
                               Lithuania                                         no data              -                 3,500,000
                               Malta                                             no data              -                   400,000
                               Poland                                            600,000            1.6                38,600,000
                               Slovakia                                           69,000            1.3                 5,400,000
                               Slovenia                                          no data              -                 2,000,000
                               Total EU25                                    19,952,000             6.2               451,200,000

                               Rumania                                           200,000            0.9                22,318,000
                               Bulgaria                                          180,000            2.2                 8,283,000
                               1)           Source: Website of European Anglers´ Alliance, 2004: http://www.eaa-
                                            europe.org/2003/PFAbout/About-EAA-EN.htm
                               2)           According to [Salonen 2004] the correct figure for Finland is probably 1,9 mill. anglers.


                               Based on the experience from the UK and Denmark it is roughly estimated that
                               split shot (used in inland waters) account for about 10% of the total consump-
                               tion corresponding to 200-600 t/year and it is consequently estimated that 800-
                               2,400 t is the uses for other lures (small sinkers, jigs, etc.) used in inland waters
                               in EU25.




                                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   97



                               4.2.2 Commercial fishing
                               Manufacturers of nets for commercial fishing are not organised in a common
                               European association.

Data collection                A request was March 2004 circulated to national industry confederations which
                               are members of the Union des Industries de la Communauté Européenne,
                               UNICE (one in each Member State and Candidate Country) in order to identify
                               national associations of manufacturers of fishing equipment for commercial
                               fishing. The request was only answered by a few of the confederations and no
                               national associations of manufacturers of fishing nets have been identified.

                               In order to obtain more information on the application and consumption of lead
                               for commercial fishing in the different countries a questionnaire was prepared
                               and the association representing professionals in the fisheries sector in the EU,
                               Europêche, was contacted. The questionnaire was via Europêche circulated to
                               all member associations in the Member States. Only one association (Dutch
                               Fish Product Board) has until now responded to the questionnaire.

                               The questionnaire and follow-up enquiries to environmental authorities in the
                               old and new Member States did except for Denmark, not reveal any studies of
                               the use of lead for sinkers in the countries.

                               The experience with studies in Denmark is that it is necessary to contact a large
                               number of manufacturers and wholesalers just to obtain a rough overview, be-
                               cause of the many different applications, and import/export at different levels
                               of the product chains. The use of trade statistics is further complicated by the
                               fact that the fishermen often directly buy the equipment in other countries when
                               visiting the harbours.

                               It is beyond the scope of the present study to undertake a comprehensive mar-
                               ket research for all applications in all Member States.

Product chain                  The use of lead-lines for fishing nets involve three links of manufacturers in the
                               product chain as described below in figure 4.3 (excluding wholesalers, retailers,
                               etc.). The use of seine ropes involves similarly three links, but with other actors
                               except for the manufacturing of lead-wire. The product chain for lead sinkers
                               involves usually the manufacturers of the sinkers and manufacturing of made
                               up nets/fykes, but often the weights are applied directly be the fishermen.

                               A large number of companies are involved in the production of lead weights,
                               extruded lead wire, lead-lines, made-up fishing nets, etc. As an example more
                               than 20 companies are involved in Denmark alone.

                               The Business to Business Search Engine, KOMPASS, holds information on
                               184 manufacturers of 'fishing nets' in Europe, 44 manufacturers of 'fishing line
                               sinker', and 36 manufacturers of 'lead wire' [KOMPASS 2004]. The actual
                               number is presumably significantly higher. A spot check in Spain, in which all
                               four Spanish manufacturers of 'fishing nets' listed in KOMPASS were con-
                               tacted, revealed that none of them were actually manufacturing made-up fishing



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   98



                               nets or dealing with lead (they only made the netting). The relatively small
                               companies (often supplying a local market) which make up the fishing nets
                               were not listed in KOMPASS.



                               Figure 4.3       Product chain for lead lines

                               Manufacturing of                    The lead wire or lead string of beads (small
                               extrudes lead-wire                  pieces of lead threaded on a plastic rope) are
                                                                   manufactured by relatively few companies each
                                                                   supplying a number of manufacturers of lead lines
                                                                   and seine ropes

                               Manufacturing of                    By the production of lead-lines, the lead strings
                               lead-lines and seine                are covered by a woven plastic stocking of
                               ropes                               polypropylene, polyester or other plastics. Lead
                                                                   lines are typically manufactured by manufac-
                                                                   turers of made-up fishing nets who use the lines
                                                                   directly or sell the lines to minor manufacturers
                                                                   or fishermen

                               Manufacturing of made-              By manufacturing of the made-up nets, the lead-
                               up fishing nets                     lines are sewn onto the netting. The netting is
                                                                   usually manufactured by other companies special-
                                                                   ised on netting and ropes. The manufacturing of
                                                                   the made-up nets often takes place locally (e.g. by
                                                                   the fishermen themselves).

                               Fisheries                           The made-up nets are used for commercial or ar-
                                                                   tisanal fishery



                               From manufacturers of lead lines it was informed that a significant part of the
                               machinery used for production of the extruded lead-wire in Europe were pro-
                               vided by one German company. The company was contacted but declined to
                               participate in the study.

Production and trade           Lead wire, lead sinkers and lead lines for fishing nets do not have specific CN
statistics                     codes and it is not possible from the statistics to obtain specific information on
                               the production or trade of these products.

                               Statistics on production and trade of made-up fishing nets in EU15 is shown in
                               Annex 3. The value of the reported production totalled according to the
                               PRODCOM statistics142 million € in 2002, while the export from the individ-
                               ual countries totalled 40 million € (Table A3. 25, in Annex 3). The production
                               is not reported for some of the countries, but the data indicates that a major part
                               of the production is sold on the domestic markets. For the three main producer



                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   99



                               countries, Italy, Spain and the UK, export accounted for 10 %, 32 % and 15 %,
                               respectively.

                               The weight of the reported production (including all major export countries) is
                               in total 20,000-25,000 tonnes/year. As several types of nets (e.g. trawl) are not
                               equipped with lead, it is not possible to make an exact estimate of the consump-
                               tion of lead for production of the nets. If it is assumed that maximum 20% of
                               the made-up nets are lead, the lead content would be 5,000 t as a maximum.

                               It is not known to what extent the made-up nets are actually equipped with a
                               lead line or sinkers when traded. A spot-check in Denmark indicated that both
                               nets with and without lead-lines will be included in "made-up fishing nets".

                               According to the COMEXT statistics the intra-community export totalled 41
                               million € (average of 2000-2002) with Italy, Portugal and Spain as the main
                               export countries (Table A3. 30). Extra-community export totalled 39 million €
                               with Denmark, Italy, Portugal and Spain as main export countries. The total
                               extra-community export equalled the extra-community import.

Common market                  As mentioned above the export of made-up fishing nets in the three largest
                               producer countries only accounted for 10-15% of the total production. All
                               available information points at production of sinkers for fishing nets to take
                               place in many small enterprises mainly supplying to a local market. Contrary
                               to this there seems to be a more common market for the lead wires and lead-
                               bead treads used for lead line production, as well as for the lead lines used for
                               set-nets. It has however not been possible within the limits of the present pro-
                               ject to establish a comprehensive view of the market, and it is uncertain to what
                               extent a common market exists. The same type of sinkers and lead lines seems
                               to be used in the different Member Countries.

Estimating lead con-           In the absence of specific data from most Member States, a first rough estimate
sumption on the ba-            will be provided on the basis of information on European fishing fleets and an
sis of number of ves-          estimated average consumption of lead per vessel. Data on the European fish-
sels                           ing fleets are obtained from the concerted action "Economic performance of
                               selected European fishing fleets" [EAEF 2003]. The report provides very spe-
                               cific information on the number of large vessel types like trawlers and seiners,
                               whereas the segmentation of the rest of the fleet does not allow a detailed as-
                               sessment. The EU25 fleet consists of about 84,000 vessels (table 3.6) and em-
                               ploy 206,000 fishermen [EAEF 2003].

                               For a first estimate we will distinguish between three segments: trawlers, sein-
                               ers and 'other'.

                               It general trawl seem not contain lead (confirmed from Denmark, the Nether-
                               lands, Poland and Spain). Different information has been obtained regarding
                               seines; the term actually used for different nets. In 'Danish seine' used in the
                               North Sea, seine ropes with lead is used, but it is informed that seines in the
                               Netherlands do not contain lead, and in Spain some contain lead whereas some
                               do not. Set nets with lead lines are traded all over Europe and set nets seem in



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   100



                               general to include lead. Similarly, lead sinkers are traded all over Europe for
                               use in different types of pound nets, ring nets, fykes and other net types.

Consumption of lead            The only identified comprehensive studies of the use of lead for commercial
                               fishing in Europe is from Denmark. Information from Denmark, Spain and Po-
                               land will be used for estimating the average consumption per vessel.

- Denmark                      The background for the Danish studies is the considerations of the Danish
                               Ministry of Environment regarding a general regulation of the use and trade of
                               lead. The total content of lead in sinkers and ropes for fishing nets for commer-
                               cial and artisanal fishing sold in Denmark in 2000 is estimated at 430-740 t
                               [Lassen et al. 2003]. Artisanal fishing is in the study defined as recreational
                               fishing using nets and fykes. The brake down by applications is shown in table
                               4.5. It is estimated that the nets (or lead lines) on average have a life of 5 years,
                               i.e. about 3,000 t lead is in active use in the Danish fishery.

                               Table 4.5            Use of lead for commercial and artisanal fishing in Denmark, 2000
                                                    [Lassen et al. 2003]

                                   Application                                               Lead consumption
                                                                                                    t/year
                                   Commercial fishing:
                                   - Lead lines in set nets                                       200-300
                                   - Seine ropes in Danish seines                                   60-70
                                   - Sinkers in ring nets, pound nets, fykes, etc.                150-300
                                   Artisanal fishing (both sinkers and lead lines)                  21-72
                                   Total (round)                                                  430-740




                               The study was based on information from manufacturers and wholesalers and
                               detailed information on:

                               •       Danish fishing fleet segmentation (the number of fishing vessels by type);
                               •       The use of fishing net per vessel for each segment;
                               •       The content of lead in each type of fishing nets/fishing gear;
                               •       The average life of the fishing nets/gear.

                               The consumption of lead per vessel is highly variable dependent on the size of
                               the vessels, net types, etc.

                               Dividing the annual consumption of lead with seine ropes with the number of
                               vessels (95) gives an annual consumption of 600-700 kg per vessel.

                               The average consumption for all other boats than trawlers and seiners can be
                               estimated at 110-180 tonnes per vessel per year. There will be large variation
                               within the group. For example for gilnetters (>15 GRT) the average consump-
                               tion is thus 100-350 kg whereas the average for gilnetters (<15 GRT) is 30-180
                               kg (Lassen et al 2002, background information).



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   101



- Spain                        In order to obtain information on the application of lead in different equipment
                               and the typical lead consumption per vessel in Southern Europe it was decided
                               to concentrate the efforts on obtaining detailed information on Spanish fisheries
                               and market and use this information for the further assessment. The information
                               on Spanish fisheries was collected by Covitecma, S.A. Ingenieros Consultores,
                               Madrid. The experience from Spain illustrates the difficulties in obtaining in-
                               formation on lead consumption in fisheries if no studies of the subject have
                               been undertaken.

                               Besides the national Fishing Government Office, thee national association of
                               professionals in the fishery sector were contacted: Federación Española de Or-
                               ganizaciones pesqueras (FEOPE, member of Europêche), Federación Española
                               de Armadores de Buques de Pesca (FEABP, member of Europêche) and Aso-
                               ciación de Sociedades Pesqueras Españolas (ASPE). Further two regional asso-
                               ciations, Asociación de Productore de Ondario (Pais Vasco) and Organización
                               de Productores de Celeiro (Galicia) and University of Vigo (responsible of the
                               Spanish part of [EAEF 2003]) were contacted. None of the organisations could
                               provide information on the consumption of lead for commercial fishing in
                               Spain.

                               A number of manufacturers of fishing nets were contacted (see list in Annex 1)
                               for more detailed information on the use of lead in nets.

                               In general lead is not use in trawl, but small amount of lead have formerly been
                               used for this application.

                               Galician seines are large ring nets, about 1000 m. According to a report from
                               the Spanish Ministry of Science two examples of ring net of 385 m and 460 m
                               contain 300 kg and 900 kg lead respectively. A ring net of 1000 m would then
                               contain several tonnes of lead (Danish ring nets contain up to 7 tonnes). Each
                               vessel may carry up to 3-4 nets but only one is used at a time.

                               Set nets are produced in Spain but to a large extent imported from Portugal and
                               Italy (as confirmed by the COMEXT trade statistics). The nets are often bought
                               without floats and lead line and made up by the shoresmen. Set nets are both
                               used by larger vessels (gillnetters) and small boats for artisanal fishing. The
                               lead content of one set net range from 5 to 23 kg (Danish figures: 5-10 kg/net);
                               a typical net is 50 m long. The vessels are allowed to apply 2500 m nets, it
                               means each vessel carry about 50 nets (slightly less than the average for Danish
                               <15 BRT vessels). In total 250-1150 kg is in use per boat. According to Span-
                               ish producers 10-12% is lost or disposed of per year giving an annual consump-
                               tion per vessel of 25-138 kg per vessel. The 10% replacement per year is rela-
                               tively low; in Denmark about 20% is replaced per year.

                               The use of lead sinkers for other types of artisanal fishing (e.g. longlines) has
                               not been investigated, but the lead consumption is assumed to be lower than the
                               amount estimated above.

                               One producer estimates that about 2000 tonnes of lead is used for commercial
                               fishing annually in Spain, which is above the range calculated in table 4.6.


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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   102



- Poland                       Information on the use of lead in Poland was obtained by Polish speaking
                               experts of COWI A/S [Andruszkiewicz et al 2004]. According to information
                               from the Polish Anglers Association lead sinkers are not used for commercial
                               fishing in the sea. Sinkers of cast iron are used instead.

                               For commercial/artisanal fishing in inland water set nets including lead is used.
                               It is informed that in total about 200 cooperatives are dealing with inland wa-
                               ters. Each cooperative is estimated to annually use (loss or dispose of) 20 nets,
                               each containing 20-80 kg lead. In total about 200 t should accordingly be used
                               annually for inland commercial/artisanal fishing. Compared to information
                               from other countries the lead content of the nets is very high.

- Sweden                       According to [Gustafsson et al. 1993] 400 t lead was used for nets for
                               commercial fishing in Sweden in 1992. Lead lines accounted for about 2/3 of
                               the total consumption of lead for fishing purposes

- Finland                      The use of lead for fishing sinkers (for all applications) in Finland in 1992 is
                               estimated at 200 t (cited by [Ponsaing and Hansen 1995]).

- The Netherlands              The Dutch association of fishermen, Produktschap Vis, has responded to the
                               enquiry that the types of equipment used in the Netherlands are: trawl, seines
                               and beamtrawl nets. It is reported that lead is not used in any of the equipment.
                               It is further reported that there is no domestic production of lead weights and
                               lead-containing ropes or lines. The information is in accordance with the in-
                               formation on the European fishing fleets shown in table 4.6.

Model estimates of             In order to make a first estimate of the lead consumption for commercial fish-
lead consumption               ing it is assumed that trawlers/dredgers do not apply lead, seiners consume
                               200-800 kg lead per year (for replacement of lead/nets disposed of or lost). For
                               other vessels it is assumed that they on average consume 40-150 kg lead per
                               year in Northern Europa and 20-100 kg in the Mediterranean (Portugal, Spain,
                               Italy and Greece).

                               Based on these assumptions the total consumption of lead for commercial fish-
                               ing in the EU25 is estimated at about 2,000-9,000 t/year (EU15: 1,900-8.700 t).
                               Considering the statistical data on the production of made up fishing nets the
                               actual consumptions is most probably within the lowest half of the range. Of
                               this seines only account for about 150-600 t/year.

                               The calculated consumption for Denmark is below the actual consumption, be-
                               cause the report EAEF only includes the larger segment of the fleet as indicated
                               in the report. It is not specifically indicated for the other countries. The calcu-
                               lated values for Sweden and Finland are somewhat below the reported con-
                               sumption (discussed above). It might well be so that the calculated figures are
                               too low for countries in the Northern Europe and too high for countries in
                               Southern Europe. However, the actual consumption of lead for this application
                               area in the EU is considered to be within the calculated range.

                               The calculation indicates that the highest consumption is in France, Greece,
                               Italy, Portugal and Spain.


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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           103



                               Table 4.6          Fishing fleet of selected Member States (in 2002)* and calculated lead
                                                  consumption for commercial fishing
                  Total fishing fleet       Trawlers/dredgers         Seiners                 Other           Calculated lead con-
                                                                   Number of                                       sumption
                  Number of vessels         Number of vessels                          Number of vessels
                                                                     vessels                                       t Pb/year
Belgium                      130                      119                                          11                    0-2
Denmark                    1,409                      613            95                           701               47-181
Finland                      357                       86                                         271                   11-41
France                     5,712                     1,125                                      4,587               183-688
Germany                    2,199                      424                                       1,775               71-266
Greece                   19,546                        54                                      19,492              390-1,949
Ireland                    1,361                      244                                       1,117               45-168
Italy                    15,915                      3,193         180                         12,542              287-1,398
Netherlands                  410                      410                                          -                      -
Portugal                 10,548                       125          160                         10,263              237-1,154
Spain                    15,385                       338          240                         14,807              344-1,673
Sweden                     1,821                      360                                       1,461               58-219
UK                         7,033                     1,053           47                         5,933               247-928
Total EU15               81,826                      8,144         722                         72,960             1,921-8,666
Estonia                      736                      136                                         600                   24-90
Latvia                       191                      131                                          60                    2-9
Lithuania                    148                      124                                          24                    1-4
Poland                     1,426                       85                                       1,341               54-201
Total EU25               84,327                      8,620         722                         74,985             2,002-8,970
                               *        Source: [EAEF 2003]




                               4.3           Legal or voluntary use restrictions on lead fishing
                                             sinkers
                               Information on legal use restrictions on lead sinkers at national level was col-
                               lected by a questionnaire to the national environmental authorities in all old and
                               new Member States and Candidate Countries. The questionnaire was prepared
                               in English. The questionnaire was addressed to contact persons in the Member
                               States attending the Commission's Working Group on the Limitation of Mar-
                               keting and Use Directive. For countries without contact persons in the working
                               group, the questionnaire was addressed to the ministries responsible for envi-
                               ronmental issues in each country.

                               Twenty-five of the 28 countries answered the questionnaire.

                               Denmark is the only country with a general ban on the use of lead for fishing
                               sinkers which entered into force in 2002 with derogation for sinkers used for
                               commercial fishing until December 1, 2004.




                                                                                                                                     .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   104



                               In the UK the use of lead split shot and sinkers above 0.06 grams and below 1
                               ounce (28.35 grams) in fresh water has been prohibited by the Control of Pollu-
                               tion (Anglers' Lead Weights) Regulation since 1986.

                               In Sweden voluntary local prohibitions on the use of lead sinkers in some river
                               systems exist.


                               4.3.1 Effectiveness of the restrictions
Denmark                        The sale of lead-containing fishing sinkers has in Denmark been banned since 1
                               December 2002. For commercial fishing equipment an exemption until De-
                               cember 1 2004 has been granted.

                               According to the Danish Angler's Association (Danmarks Sportsfiskerforbund)
                               home casting of pilks has been widespread whereas home casting of sinkers
                               have been less common because of the low price of the sinkers. The exact lead
                               consumption for the activities is not known but could as an average quite well
                               be one kg or more per year per angler. According to a substance flow analysis
                               of lead, 14-40 t lead was used for home casting in Denmark in 2000 (Lassen et
                               al 2003).

                               In recent years the Danish Angler's Association has for environmental reasons
                               stopped courses in home casting. It should be noted that home casting of lead
                               and the use of lead sinkers is not prohibited by the Danish regulation on prod-
                               ucts containing lead.

                               According to a leading Danish wholesaler of fishing tackle, cross-frontier trade
                               of lead-containing lures is not considered to take place to any appreciable ex-
                               tent, whereas home casting of sinkers has increased significantly after the regu-
                               lation went into force. As home casting of sinkers is relatively simple it must be
                               expected that the activities increase if the price of sinkers increase.

U.K.                           Since January 1987 the use of lead split shot and sinkers above 0.06 grams and
                               below 1 ounce (28.35 grams) has been prohibited in the UK. According to a
                               leading UK manufacturer of split-shot and small sinkers, home casting and
                               cross-frontier trade is not taking place in any significant quantities.

                               Questions regarding the effectiveness of the restriction have been addressed to
                               the UK Department for Environment, Food and Rural Affairs (DEFRA),
                               Chemicals & GM Policy Division and European Wildlife Division, but no an-
                               swers have been obtained yet.




                                                                                                                          .
     Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                105



                                       Table 4.7         Restrictions on the use of lead in fishing sinkers in the old and new
                                                         Member States of the EU and Candidate Countries

                       Legal or voluntary use restrictions            Instrument
                       (Year of entry into force)
Austria                no
Belgium
- Federal              no info * (sea water)
- Flanders             no info (fresh water and commercial)
- Brussels             no (all applications)
- Walloon
Cyprus                 no
Czech Rep.             no
Denmark                yes (2002)                                     The sale on lead sinkers is prohibited by Statutory Order no 1012 on
                       derogation for commercial fishing until        prohibition of import and marketing of products containing lead
                       Dec 1 2004
Estonia                no
Finland                no
France                 no
Germany                no **
Greece                 no
Hungary                no
Ireland                no
Italy
Latvia                 no
Lithuania              no
Luxembourg             no
Malta                  no
Netherlands            no
Poland                 no                                             Restrictions may according to questionnaire response be applied by
                                                                      means of voluntary code of good conduct for sport fishing and pro-
                                                                      fessional fishing
Portugal               no
Slovakia               no
Slovenia               no
Spain
Sweden                 partly (year not informed)                     Voluntary restriction on the use of lead sinkers in some river systems
UK                     partly (1987)                                  The use of lead split shot and sinkers above 0.06 grams and below 1
                                                                      ounce (28.35 grams) in fresh water is prohibited by the Control of
                                                                      Pollution (Anglers' Lead Weights) Regulation 1986 as amended

Bulgaria
Romania                no
Turkey                 no
                                       * "no info" indicated in questionnaire response.
                                       ** Answers have been received from only 9 of 16 federal states.




                                                                                                                                               .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                    106



                               4.4           Availability of substitutes for lead fishing
                                             equipment
                               Several alternatives to lead fishing sinkers are available on the market or being
                               developed. The alternative materials utilised include iron, tin, tungsten and zinc
                               and likely also others depending on the individual applications.

Angling                        Regarding anglers equipment an overview of available alternatives and their
                               price at the retail level compared to lead based equipment is presented in table
                               table 4.8.

                               Table 4.8           Substitutes for lead in anglers' equipment - alternative materials and
                                                   price indication relative to lead of products marketed 1).

                                Type of equipment          Alternative material                                 Price indication
                                                                                                          (retail level in Denmark) 2)
                                Split shot                 Tin, tungsten composite/alloy                       + 200-300% 3)
                                Sinkers/weights            Zinc, iron/steel,                                    +10-100% 3)
                                                           Bismuth, tungsten composite/alloy                    + 400-1000%
                                Jigs                       Zinc alloy, steel                                            ~0%
                                Pirks                      Zinc alloy, iron/steel                                  + 10%-?
                                Downriggers                Zinc alloy, iron,                                       + 10%-?
                                Woblers                    Tungsten - zinc or tin alloys may likely                + 10%-?
                                                           be used
                                Floats                     No alternative - zinc, tin or tungsten                       +?
                                                           alloys may likely be used
                               1)            Based on [Toft 2004; Bjælkehytten 2004, Cabelas 2004; BulletWeights 2004]
                               2)            Price level varies with actual alternative and country of manufacturing.
                               3)            In the UK the price of spilt shot increased by approximately 300% by the shift from lead to
                                             tin. The price of small sinkers increased by approximately 100% by the shift from lead to
                                             zinc.


                               The picture presented in table 4.8 reflects Danish experiences mainly and illus-
                               trates a situation that cannot be regarded as fully stabilised, as the ban on sale
                               of lead based equipment for angling in Denmark in reality first have been in
                               full effect from 1. December 2003. Danish dealers of fishing equipment were
                               granted an extra year for sale of lead equipment in order to facilitate emptying
                               of lead equipment stocks [Danish EPA 2002b]. As the Danish market is small
                               and generally not important in an international context development of substi-
                               tutes make take time and should with respect to several types of equipment be
                               regarded as an ongoing process. The price indications should be treated with
                               caution.

                               Regarding the different types of equipment the situation may be presented as
                               follows:

- split shot                   Development of substitutes for lead split shot has in Europe in particular been
                               driven by the ban in UK from 1987 (reference is made to table 4.7) and should
                               be assumed to have reached a rather mature state. Tin seems to be the dominant
                               alternative marketed. The price of the substitutes compared to lead must be as-


                                                                                                                                           .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   107



                               sumed primarily to reflect the cost of raw materials (reference is made to table
                               3.15). Whereas tin shot is lighter than lead, tungsten composites/alloys are
                               manufactured with a density very similar to lead. The major disadvantage of the
                               substitutes seems to be the price difference.

                               However according to European Angles´ Alliance [Broughton 2004] no substi-
                               tutes are yet available for spilt shot below 0.06 g ("micro-shot" or "dust shot").

- small sinkers                Development of substitutes for small sinkers/weights up to 28 g/piece have
                               similarly been driven by the ban in UK from 1987, whereas for larger sizes a
                               legal requirement for substitutes was first established with the Danish ban in
                               2002. Iron is cheap but has a disadvantage of corrosion, besides being more
                               complicated to manufacture. Therefore zinc seems to be the preferred alterna-
                               tive at least for smaller sinkers. The lower density of zinc and iron versus lead
                               frequently requires the use of larger sinkers/weights (about 50% larger), which
                               in fast-flowing waters may be considered a disadvantage due to a different be-
                               haviour compared to lead sinkers. Regarding the price of lead equipment versus
                               substitutes the picture is complicated by the ongoing process of outsourcing
                               European production to China and other Asian countries. Whereas zinc and
                               iron substitutes a few years back represented a price increase at the retail level
                               of 100% compared to lead, outsourcing has today resulted in prices only 10-
                               20% higher than the former prices of lead equipment [Toft 2004]. It may be
                               noted that also steel sinkers today are available at a price almost at the level of
                               lead [Cabelas 2004]. The high-end substitutes are bismuth and tungsten sink-
                               ers/weights, which have a density similar to or above lead but have a price level
                               of 400-1000% of the level of lead [Cabelas 2004].

- jigs                         Regarding jigs only few substitutes seem to be available. A substitute based on
                               zinc is marketed in Denmark to a price equal to the former prices of lead
                               equipment [Toft 2004]. The substitute is, however, manufactured outside
                               Europe. Internationally also substitutes based on steel are marketed [Bullet-
                               Weights 2004].

- pirks and                    Considering pirks and downriggers, the situation of substitutes in many ways
  downriggers                  resemble the situation for sinkers and weights. The alternative materials in fa-
                               vour seem to be zinc/tin-alloys and iron/steel. In all cases the price increase has
                               been reduced significantly by outsourcing the manufacturing to outside Europe.
                               Stainless steel substitutes exist on the market but should be considered a high-
                               end and costly alternative.

                               Some wobblers and floats may contain a small quantity of lead in order to op-
                               timise the position of the equipment in water. Wobblers with tungsten or bis-
                               muth are available on the market. No substitutes have to the best of knowledge
                               been developed so far for floats, probably due to the limited size of the Danish
                               market [Toft 2004]. Tin must be regarded as an obvious alternative.

Commercial fishing             Regarding commercial fishing equipment an overview of available alternatives
                               and their price at the retail level compared to lead based equipment is presented
                               in table 4.9.



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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks          108



                               Table 4.9             Substitutes for lead in equipment for commercial fishing - alternative
                                                     materials and indication of expected price relative to lead of products
                                                     marketed [Heron 2004].

                                   Type of equipment                      Alternative material            Expected price
                                                                                                           (retail level) 2)
                                   Sinkers/weights                             Iron, zinc                       ~0%
                                   Lead lines                          Coated iron, iron?, zinc?             ~0-33% *
                                   Seine ropes                                   zinc                         ~0 % *
                               *       Alternatives are not available today.


                               Internationally only limited efforts have been invested in developing alterna-
                               tives, as a ban on import and sale of lead equipment for commercial fishing has
                               only been introduced in Denmark. Apart from sinkers/weights for which iron
                               has been an alternative for many years and e.g. utilised in trawls, no alterna-
                               tives to lead are so far actually marketed.

                               However, in Denmark a coordinated effort involving several Danish companies
                               and supported by the Danish Government have been invested since 1999 in de-
                               veloping substitutes to lead equipment. The effort is aimed at developing alter-
                               natives matching lead equipment in efficiency without implying extra costs.
                               The effort has not been finally evaluated yet, but is planned to be published in
                               autumn 2004. The delayed development of lead-free equipment has led the
                               Danish EPA to grant exemption until 1 December 2004 for import and sale of
                               commercial fishing equipment containing lead (EPA 2000).Status for develop-
                               ment of lead-free commercial fishing equipment can at this time only be briefly
                               summarised as follows [Heron 2004]:

- lead lines                   With respect to lead-lines substitutes based e.g. on coated iron have been
                               developed, successfully tested and a number of patents have been granted. Full
                               scale production has not yet been initiated, but it is estimated that these substi-
                               tutes would be about 33% more expensive than lead equipment. It is believed
                               that other substitutes based on iron or zinc, being cost neutral compared to lead
                               lines, could be developed, but manufacturing technologies are still not devel-
                               oped. A well-tested substitute being an efficient and cost neutral replacement
                               for lead lines cannot be expected to be available on the market before summer
                               2005 as the earliest. By the development of alternatives it has been a challenge
                               to overcome some problems arising when the lines are sewn on the made-up
                               nets, but these problems seems to have been solved by the developed alterna-
                               tives. Besides, it is unclear to what extent corrosion of zinc may have negative
                               influence on the life of the netting, in any case it is necessary to use corrosion
                               resistant zinc alloys.

- seine ropes                  Considering seine ropes the situation is not yet clarified. It is believed that a
                               substitute based on zinc wire could be developed, but the company in charge of
                               the development work has lately come into financial troubles and the future of
                               the company is thus unclear. It is, therefore, at present unclear when and how
                               the development work will be continued. To what extent extruded zinc wire
                               will be provided by the same companies that produce extruded lead wire has
                               not been assessed, but most likely some changes will take place.


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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   109



- sinkers                      Regarding sinkers/weights the most feasible alternatives seem to be iron and
                               zinc. 1 kg iron sinkers suitable for pound nets are manufactured in China at a
                               price equalling the former lead sinkers. These iron sinkers are the only alterna-
                               tive sinkers for commercial fishing that are actually being marketed in Den-
                               mark today. Zinc sinkers are being tested by Danish fishermen during summer
                               2004. The price of the zinc sinkers are expected to be comparable to the price
                               of lead sinkers, because the higher raw material price is offset by lower produc-
                               tion costs It is assumed that several fisher-men actually have developed their
                               own alternative solutions e.g. by using iron chains in stead of lead sinkers on
                               trawls.

                               It is the authors' assessment that for manufacturers with experience in lead cast-
                               ing it is relatively easy to change to zinc casting, whereas iron sinkers most
                               probably will be manufactured by other companies. A shift from lead to iron
                               sinkers may thus have a significant impact on the industry.




                               4.5        Impact of potential marketing and use restrictions
                                          on lead fishing sinkers

                               4.5.1 Impact on business and users
Consequences for               Compared to lead in ammunition, much less information has been available for
manufacturing indus-           the assessment of the impact of potential marketing and use restrictions on lead
try                            fishing sinkers. Fishing sinkers only account for a small part of the fishing
                               tackle trade and no investigations of the impact of a restriction on the use of
                               lead for sinkers has been done by EFFTA or national associations. As regards
                               sinkers for commercial fishing the development of alternatives is at a premature
                               stage, and the development has mainly taken place at individual companies, and
                               neither trade associations nor fisher's associations have carried out any assess-
                               ment of the consequences of a potential use restriction.

Sinkers and other              Sinkers, split shot and other lead-containing lures are manufactured by several
lures for angling              hundred companies in Europe. Many of the companies are small or sinker
                               manufacturing account only for a minor part of their activity. Lead sinkers are
                               relatively easy to cast and can be produced in a small workshop.

                               It is relatively easy for a foundry to replace lead with zinc for sinker casting,
                               but it is necessary to change the moulds. Large manufacturers may use up to
                               100 different moulds. The change of lead with tin has implied major changes in
                               design because the tin shot due to the hardness has to be fastened to the line in a
                               different way.

                               The manufacturing of sinkers of cast iron or steel is more complicated and will
                               typically take place in iron and steel foundries or the sinkers may be produced
                               by totally other methods (e.g. turning of steel rods).




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Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   110



                               It has not been possible based on the available information to estimate the need
                               for investment within the manufacturing industry as a consequence of a restric-
                               tion of the use of lead.

- experience from the          Since January 1987 the use of lead shot above 0.06 grams and lead sinkers be-
UK                             low 1 ounce (28.35 grams) has been prohibited in the UK. According to a lead-
                               ing UK producer, the volumes of the sale of lead shot and small sinkers
                               dropped dramatically before the ban went into force, and the sale of alternative
                               shot and sinkers boomed within the first three years following the ban, because
                               all anglers replaced their lead sinkers with the alternatives. After three year the
                               volume of sales was at the same level as before the ban, indicating that the de-
                               mand was unaffected by increases prices and that home casting and cross-
                               frontier trade was insignificant. It should be noted that the cost of split-shot and
                               small sinkers in any case is relatively small, and the experience may not be ex-
                               trapolated to larger lures of lead like pirks. The change from lead to alternatives
                               like tin and zinc required some development of technology and investment in
                               new tools (e.g. new moulds) and by the change over, the number of manufac-
                               turers of split-shot and small sinkers in the UK decreased from about 10 to 4.

- experience from              In Denmark at least two small manufacturers of lead-containing lures has
Denmark                        ceased production after the introduction of the Danish ban on lead. There seems
                               to be a tendency to outsource the manufacturing of lures to Eastern Asia and a
                               significant part of the lead alternatives sold in Danish angling shops are pro-
                               duced in Eastern Asia. The changes in the market introduced by the ban may
                               have speeded up a tendency already taking place.

Sinkers, commercial            Sinkers for commercial fishing is most probably produced by hundred to sev-
fishing                        eral hundred companies all over Europe, some of the companies also manufac-
                               turing sinkers for angling.

                               Based on the experience with development of substitutes for commercial fish-
                               ing equipment (reference is made to section 3.4) zinc and iron seems to be the
                               most obvious alternatives to lead in the relatively large sinkers used in equip-
                               ment for commercial fishing, and companies seem to be ready for manufactur-
                               ing of sinkers of iron and zinc at a price equal to the price of lead sinkers.

                               Zinc sinkers may be manufactured in the foundries casting lead sinkers by the
                               change of moulds, but for production of large lots it may be relevant to totally
                               change the machinery.

                               A significant part of sinkers for commercial fishing has traditionally been
                               manufactured is small workshops near the fishing ports. A shift from lead to
                               other materials most probably will result in a concentration of the production
                               on fewer enterprises and the close down of a number of small workshops.

                               A replacement of lead with other materials is not considered to influence the
                               next step in the product chain, the make-up of the fishing nets.




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   111



                               It has not been possible based on the available information to estimate the need
                               for investment within the manufacturing industry as a consequence of a restric-
                               tion of the use of lead.

Lead lines and seine           A replacement of lead with other materials in lead lines and seine ropes may
ropes                          influence three links of product chain: The manufacturing of the lead
                               wire/string of beads, the manufacturing of lead-lines and seine ropes, and the
                               making-up of the fishing nets. In some cases all three links takes place within
                               the same company, but it seems not to be the most common.

                               Lead wires/string of beads is estimated to be manufactured by 10-50 companies
                               all over Europe.

                               Regarding the manufacturing of lead lines, several of the developed alternatives
                               will imply a total change in machinery. The investment costs for machinery for
                               production of lines with polymer coated iron beads in one company is indicated
                               to be in the order of magnitude of 1.5 million € .

                               By the use of alternative material the volume of the string of lead beads will
                               increase, but as lead wires today are produced in many different thicknesses,
                               the changed volume most probably will not imply the need for changes in ma-
                               chinery for production of the textile stockings and the final lead lines.

                               The most probable alternative to lead in seine ropes is zinc wire. The total
                               amount of lead used for seine ropes is relatively small and it has not been as-
                               sessed whether the zinc wire will be manufactured by the same companies that
                               manufacture the lead wire today.

                               It has not been possible based on the available information to estimate the need
                               for investment within the manufacturing industry as a consequence of a restric-
                               tion of the use of lead, but it is estimated that the most significant investment
                               costs most probably would be related to the manufacturing of the string of
                               beads used for manufacturing of lead lines.

Consequences for               The consequences for anglers of a restriction of the use of lead, apart from the
anglers                        incremental costs discussed below, are generally estimated to be small apart
                               from the users of "dust shot", for which no alternatives so far are identified. For
                               shot above 0,06g tin split shot is available but somewhat harder than lead shot,
                               and should not be attached to the line by the use of the teeth, but split shot
                               which can attached without the use of teeth or other tools have been developed.
                               Sinkers and other lures will be slightly larger if made of zinc, and therefore act
                               differently in the water, but the changes are not considered to be of significance
                               for the application of the lures.

Incremental costs for          The alternative metals, except for iron, are more expensive that lead and other
anglers                        things being equal the price of the products at the retail stage will be more ex-
                               pensive than the lead products.

                               A spot check in an angling shop in Denmark showed that the price of small
                               sinkers and jigs of zinc equalled about 133 €/kg whereas the price of split shot


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   112



                               of tin equalled 333 €/kg. Comparing these prices with the price of the raw ma-
                               terials on the metal exchange (table 3.15) of about 1.5 €/kg and 5.5 €/kg for
                               zinc and tin, respectively, clearly demonstrate that the prices of lures in the an-
                               gling shop only to some extent reflect the prices of the raw materials.

                               The total lead consumption for angling in EU25 is estimated at 2,000-6,000
                               t/year (section 4.2.1) of which the half, 1,000-3000 t/yeas, is used in inland wa-
                               ters. A first estimate will be done by assuming that in split shot lead is replaced
                               by tin whereas zinc is replacing lead for all other lures.

                               Based on the experience from the UK and Denmark it is roughly estimated that
                               split shot account for about 10% of the consumption corresponding to 200-600
                               t/year. The price of split shot on the UK retail market is approximately 6 € for a
                               dispenser with about 60 g tin shot. It is informed that the price is approximately
                               4 times the price of lead shot giving an extra price of approximately 75 €/kg.
                               Using these figures the incremental costs to anglers of a phase out of lead for
                               split shot (at the retail level) would be approximately 15-45 mil.€ correspond-
                               ing to 0.75-2.3 € per angler per year (assuming a total of 20 million anglers).
                               The incremental costs may be smaller than estimated if the price of non-lead
                               split shot decreases with in increased European market.

                               The price of sinkers and other lures varies considerably and for many lead-
                               containing lures like pirks and wobblers the price of the metal account only for
                               a minor part of the price of the final product. The increase in price at the retail
                               level is roughly estimated to be between 10 and 100%.It is very difficult to es-
                               tablish an average price for these products. The typical price for lead sinkers in
                               bulk sold directly from manufacturers to fishermen in Denmark is 2-2.5 €/kg,
                               but the price paid by anglers in a shop may be up to 50 times more. For the first
                               estimate an average extra price of the alternatives of 5-30 €/kg will be assumed.

                               Using these figures, the incremental costs to anglers for sinkers used in inland
                               waters (800-2,400 t excluding split shot) can be estimated at 4-72 mil.€/year
                               corresponding to 0.2-3.6 € per angler per year. The incremental costs to angles
                               for sinkers used in the sea (1,050-3,000 t) can be estimated at 5-90 mil.€/year
                               corresponding to 0.25-4.5 € per angler per year.

                               In total the incremental costs to anglers (at the retail level) is estimated at 24-
                               207 mil.€ corresponding to approximately 1.2-10.4 €/year per angler.

                               In a Canadian assessment it was estimated that the incremental costs per an-
                               glers by replacement of lead in 1995 would be 0.6-10.1 CA$/year (0.4-6.3
                               €/year) [Scheuhammer and Norris1995].

Consequences for the           Besides the increased price of the equipment discussed below, the conse-
fisheries                      quences of a restriction on the use of lead concern increased volume of the
                               equipment, increased noise and maybe shorter life of the equipment.

                               The most realistic alternatives for lead in equipment for commercial fishing,
                               iron and zinc, both have a lower density than lead, and the volume of the sink-
                               ers will increase with about 60%. It means that the equipment will take up more


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   113



                               space in the fishing vessels and it will be more difficult to handle. To what ex-
                               tent the consequences of the increased volume of the equipment are of signifi-
                               cance for the fisheries need to be further investigated.

                               Replacement of lead sinkers by iron, e.g. on large ring nets, may have some
                               negative consequences on the working environment of the fishermen because
                               of increased noise when the nets hit the ship's side and the deck. The signifi-
                               cance of the increased noise by the use of different alternatives (iron, zinc, etc.)
                               needs a further investigation. Some experiments using equipment with zinc for
                               large ring-nets are planned to take place in Denmark during the summer 2004.

                               It is still unclear to what extent corrosion of zinc may have a negative conse-
                               quence on the netting (the textile) and by this shortening the life of equipment
                               (Gudum 2002). It has to be investigated to what extent these problems can be
                               overcome by using the right combinations of zinc alloy and netting material.

Incremental costs for          Incremental costs for the fisheries are a consequence of:
the fisheries
                               •    Increased price of equipment;
                               •    Increased volume of equipment;
                               •    Reduced life of equipment.

                               The consequences of increased volume of the equipment will be highly de-
                               pendent on the actual equipment, vessel type, etc. and in the absence of actual
                               investigations it is not possible to quantify the incremental costs. Similarly it
                               has to be further investigated to what extent the life of the equipment is influ-
                               enced by the replacement of lead with other metals.

                               In an assessment of the economic consequences of the Danish ban on lead
                               [Gudum 2002] it is estimated that the extra price at the retail level of both sink-
                               ers, lead lines and seine ropes using zinc as alternative will be about 5.5 DKK
                               (0.74 €) per kg lead replaced. Using iron as alternative to lead in sinkers de-
                               crease the price with 1 DKK (1.13 €) per kg lead. The extra price of lead-lines
                               and seine ropes with coated iron is estimated at 26 DKK (3.5 €) per kg lead re-
                               placed.

                               A new Danish investigation, are to the best of knowledge confirming the price
                               levels stated above. The investigation is, however, not yet ready for publication.

                               The actual prices at the retail level will obviously be different in the different
                               Member States and, considering the uncertainty on the increases in price, the
                               extra price of lead lines will for the present estimate be assumed to be in the
                               range of 0.5-2 € per kg lead replaced. It is assumed that lead alternative lead
                               sinkers and seine ropes can be manufactured at a price equal to products con-
                               taining lead.

                               The total consumption of lead with equipment for commercial fishing in EU25
                               is roughly estimated at 2,000-9,000 t/year (section 4.2.2). It is not known how
                               much is this is used in lead lines, but most probably it is the major part, and the
                               consumption for lead lines is here roughly estimated at 1,200-6,000 t/year.


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   114



                               If the extra price of the lines is assumed to be in the range of 0.5-2 € per kg
                               lead, the incremental costs to the fisheries, as a consequence of increased prices
                               of equipment, can be estimated at 0.6-12 million €/year.

Timing                         Due time should be given for an EU-wide regulation on the use of lead sinkers
                               to be implemented, either in terms of a due notification period or in terms of
                               gradual phase in of selected parts of the regulation (e.g. starting by regulating
                               the use in inland waters).

                               The industry will need time practically to convert production lines and develop
                               new product ranges (including the required know-how). At the same time it
                               should be emphasised that a full range of lead-free sinkers for angling already
                               exist on the market (of which some are imported from outside the EU25 area).
                               A regulation, which is being implemented too hastily could therefore skew the
                               market quite extensively and redistribute market shares among sinker manufac-
                               turers inside and outside of the EU-area.


                               4.5.2 Impact on the environment and health
                               A restriction of the use of lead for shot and bullets may result in reduced re-
                               leases from the following activities:

                               •    Primary and secondary production of lead and manufacturing of lead shot
                                    and bullets;
                               •    Angling and commercial fishing;
                               •    Waste disposal, e.g. incineration.

                               It is beyond the scope of this study to review the impact of the releases from the
                               production of lead, manufacturing of lead sinkers and the disposal of lead sink-
                               ers and bullets that are not spread in the environment. However, it should be
                               kept in mind, that a restriction of the use of lead for sinkers also would reduce
                               the releases from these activities (although they may as well be reduced by the
                               use of other instruments). Contrary to lead ammunition, sinkers are often pro-
                               duced by home casting and small-scale casting in small enterprises which may
                               result in relatively high emission of lead as the lead is cast with no or insuffi-
                               cient emission abatements technology. In addition the casting may have signifi-
                               cant health impact of the persons involved. The emission to air from home-
                               casting may be in the order of magnitude of 0.1-1% of the cast volume (Lassen
                               et al. 2003).

                               The impact on the environment and health of a restriction of the use of lead for
                               angling and commercial fishing will depend on which materials are used to
                               substitute for the lead. The most obvious (and used) alternatives are iron, zinc
                               and tin. From an environmental view, iron sinkers is certainly the most advan-
                               tageous alternative and the environmental impact of the use of iron sinkers
                               seems to be small compared to the impact of the use of lead. For this applica-
                               tion iron without heavy metals as alloying elements can be used. The data for
                               zinc indicate that zinc is significantly less problematic in the aquatic environ-
                               ments than lead (see section 3.6.2), while no water quality criterion or other



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   115



                               comparative assessment covering toxicity in water environments seems to be
                               available for tin. However, zinc is toxic to birds when ingested, although less
                               toxic than lead (reference is made to section 3.6.2).

Resource perspective           Lead is a scarce metal with a limited reserve base even though raw material
                               deficiency is not expected for the next decades. The same is true for zinc and
                               tin. From a resource perspective only substitution of lead by iron can be con-
                               sidered advantageous.

Use of split shot and          Direct effects of lead sinkers on waterfowl has been demonstrated for lead split
small lead sinkers in          shot of a size above 0.06 grams and sinkers below 1 ounce (28.35 grams) which
inland waters                  is the background for the ban of the use of lead sinkers of this size in the UK. A
                               study of lead poisoning of loons by sinkers is described in section 2.1.1, while a
                               recent article is suggesting that even "dust shot" could also be of importance
                               considering poisoning of mute swans (reference is made to [Perrins et al 2003]
                               and section 3.7.2.

                               Besides the direct effect on the birds, sinkers lost in rivers contribute to the
                               general contamination of the rivers by lead.

                               Based on section 4.2.1 the lead consumption for angling in inland waters in
                               EU25 is estimated at 1,000-3000 t/yeas. The major part is lost to the waters by
                               the application, but a minor part may be disposed of with municipal solid
                               waste. For some lures the amount disposed of with municipal solid waste may
                               be significant (lures which have been tried with no luck) but for simple lures as
                               sinkers it is estimated that approximately 90% of the sinkers are lost to the wa-
                               ters corresponding to 900-2,700 t.

Use of large sinkers           Based on section 4.2.1 the lead consumption for angling in the sea in EU25 is
for angling in the sea         estimated at 1,000-3000 t/yeas. The amount used in the sea vary of course with
or in large lakes              the differences in access to the sea, and in e.g. Denmark the consumption of
                               lead sinkers for fishing in sea is several times higher than the consumption for
                               fishing in inland waters. The major part is lost to the sea by the application, but
                               a minor part may be disposed of with municipal solid waste. For some lures the
                               amount disposed of with municipal solid waste may be significant, but for sim-
                               ple lures and sinkers it is estimated that approximately 90% of the sinkers are
                               lost to the sea corresponding to 900-2,700 t. As the conditions in large lakes are
                               very similar to the sea it is assumed reasonable to accept that consumption and
                               losses in large lakes is similar to consumption and losses in the sea.

Use of sinkers in              To the knowledge of the authors it has not been demonstrated that sinkers in the
equipment for com-             sea environment significantly contribute to the lead content of the water. As
mercial fishing                discussed in section 2.1.3, lead will tend to accumulate in the anoxic zones of
                               the sedimentation areas and over time be buried and not available for the bot-
                               tom living biota. It means that the sediments act like a sink for the lead.

                               The total consumption of lead for commercial fishing is in section 4.2.2 esti-
                               mated 2,000-9,000 t/year.




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   116



                               Only a part of this is lost at sea whereas the remaining part is disposed of to
                               landfills, recycling (mainly sinkers) or waste incineration. A Danish study indi-
                               cated that in total 5-20% of the lead applied for fishing equipment for commer-
                               cial fishing is lost to the sea either by loss of the equipment or by corrosion and
                               wear of sinkers [Lassen et al. 2003], and the same figures will be used here.
                               Assuming that 5-20% of the used lead is lost at sea the total release can be es-
                               timated with high uncertainty at 100-1,800 t per year.

                               The environmental issues discussed in this section can in principle be divided
                               into the following:

                               !   The resource issue which basically is a global issue and of concern to all
                                   countries in the world. The issue is hardly relevant in a discussion of cross-
                                   national perspectives within the EU.

                               !   The issue of poisoning of waterfowl. To the extent the birds exposed to lead
                                   shots by ingestion - direct ingestion as well as secondary ingestion - are
                                   migratory birds the actions of individual Member States may naturally in-
                                   fluence other Member States, as birds naturally belonging to the environ-
                                   ment in some Member States may be poisoned during their travel through
                                   and temporary stay in other Member states. This perspective is certainly
                                   relevant for many species of waterfowl and will to a limited extent be rele-
                                   vant for upland birds as well. The issue may thus justify a coordinated effort
                                   within the EU related to the use of lead sinkers in wetlands.

                               !   The issue of lead contamination of the water environment and in particular
                                   sediments. Regarding fresh water systems this is mainly a national issue but
                                   could for large river systems also be a cross-national issue. Concerning the
                                   marine environment, lead is covered by international sea conventions as e.g.
                                   the OSPAR Convention that has established binding commitments aimed at
                                   reducing lead emissions to marine environment.

                               To these issues may be added the general issues of emissions caused by pri-
                               mary and secondary production of lead inclusive of home casting and waste
                               disposal. As stated earlier a review of these emissions is beyond the scope of
                               this study, but a restriction of the use of lead for sinkers would naturally also
                               reduce the releases from these activities.

Alternatives to lead           Regarding substitutes to small sinkers and lead split shot based on tin, tungsten,
                               bismuth, iron and zinc the discussion is similar to the discussion on substitutes
                               for lead shot ammunition. Most main alternatives to lead - steel, tin, tungsten,
                               and bismuth - have the advantage of being non toxic to birds. Zinc, however, is
                               not currently approved in the US as a non-toxic shot and is in reality also toxic
                               to birds although the toxicity is lower than that of lead.

                               Regarding other impacts only iron presents a clear improvement compared to
                               lead, while other alternatives suffers from one or more drawbacks inclusive of
                               lack of data. Regarding toxicity in water zinc must be considered significantly
                               less toxic than lead, while no water quality criteria or other comparative as-
                               sessment covering toxicity in water environments have been established for tin,


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks         117



                               bismuth or tungsten. While it is generally believed that neither tin, bismuth nor
                               tungsten should be of concern regarding their environmental impact in water
                               environments, this is in reality not documented, and it is recommended that re-
                               search is initiated that can eliminate this deficiency.

Summary                        The estimated impacts of different use restrictions on the release of lead to the
                               environment is summarised in table 4.10 (EU25) and table 4.11 (EU15).

                               The only demonstrated effect of the use of lead lures is the effect of split shot
                               and small sinkers on waterfowl. These lures are mainly used in inland waters.

                               Table 4.10       Reduced lead consumption and release to the environment by restrict-
                                                ing the use of lead in EU25

                                Restriction option                   Reduced lead consumption       Reduced release of lead to the
                                                                                                           environment
                                                                             Tonnes/year
                                                                                                             Tonnes/year
                                Lead split shot and small sinkers            1,000-3,000                      900-2,700
                                used for angling in inland waters
                                Large lead sinkers used for an-              1,000-3,000                      900-2,700
                                gling in sea and large lakes
                                Lead in equipment for commercial             2,000-9,000                      100-1,800
                                fishing




                               Table 4.11       Reduced lead consumption and release to the environment by restrict-
                                                ing the use of lead in EU15

                                Restriction option                   Reduced lead consumption       Reduced release of lead to the
                                                                                                           environment
                                                                             Tonnes/year
                                                                                                             Tonnes/year
                                Lead split shot and small sinkers             950-2,800                       850-2,520
                                used for angling in inland waters
                                Large lead sinkers used for an-               950-2,800                       850-2,520
                                gling in sea and large lakes.
                                Lead in equipment for commercial             1,900-8,700                       95-1,740
                                fishing




                               While iron presents a clear improvement compared to lead considering toxicity
                               as well as other environmental issues, other alternatives suffers from one or
                               more drawbacks inclusive of lack of data. As regards the resource perspective
                               neither zinc nor tin is better than lead, but the general toxicity of zinc in water
                               is lower than the toxicity of lead. No water quality criterion or other compara-
                               tive assessment of toxicity in water environments is available for tin, bismuth
                               and tungsten.




                                                                                                                                     .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   118



                               4.5.3 Discussion of the need for a community wide approach
                               Regarding the need for a common approach related to restrictions on the mar-
                               keting and use of lead in fishing sinkers, the following arguments calling for a
                               common approach have been identified:

                               1) Lead split shot is a recognized source of poisoning of waterfowl. As many
                                  waterfowl are migratory birds the actions of individual Member States may
                                  naturally influence other Member States, as birds naturally belonging to the
                                  environment in some Member States may be poisoned during their travel
                                  through and temporary stay in other Member states.

                               2) National restrictions could hamper the free trade in the EU to the extent a
                                  common market exists. For lead wires and lead bead stings used for lead
                                  lines production a common market in Europe exist. For other types of
                                  equipment the production is highly national, but the same types of sinkers
                                  and lead lines are used all over Europe meaning that a common market for
                                  these products to some extent exists. When a common market exist, it is
                                  obvious that any restriction introduced in a member state will have some ef-
                                  fect on companies in other member states. Assuming that appropriate time
                                  will be allowed for companies to adapt to restrictions, it is, however, diffi-
                                  cult based on the knowledge available to assess the extent to which restric-
                                  tions may lead to market distortions.

                               Attention may also be paid to the following argument partly opposing the need
                               for a common approach:

                               3) Restrictions in local fresh water systems have been introduced based on lo-
                                  cal environmental conditions. To the extent the main environmental impact
                                  is contamination of local or national fresh water environments conditions
                                  may differ between the Member States with respect to e.g. the load and con-
                                  tent of lead in water and sediments, and the mobility and impact of lead on
                                  the local environment. Local conditions may thus justify that Member
                                  States or local authorities are establishing local or national restrictions re-
                                  garding the use of lead sinkers.

                               In principle a conflict could exist between arguments 2) and 3). However, ar-
                               gument 3 is mainly addressing fresh water systems and thereby mainly angling
                               equipment while the common market for angling equipment seems to be weak
                               and not relevant to consider in this context.

Discussion of restric-         Compared to the restriction options presented in table 4.10 and 4.11, it is obvi-
tion options available         ous that reasonable solid arguments related to migratory birds exist for a com-
                               munity wide approach regarding the use of lead split shot and small sinkers for
                               fishing in inland waters. However, it must be noted that substitutes for "dust
                               shot" seem not to be available, besides that their impact on birds have not been
                               specifically documented.

                               Considering large sinkers for angling in sea and in large lakes as well as lead
                               sinkers for commercial fishing the main argument in favour of a community



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   119



                               wide approach would be the commitments for the EU related to sea conven-
                               tions as the OSPAR Convention. It is noted that the EU is a party to this con-
                               vention and thus committed to work for reduced emissions of lead to the marine
                               environment [OSPAR 2004]. For lead wires and lead bead stings a common
                               market exist but it is not possible based on the knowledge available to assess
                               whether restrictions may lead to market distortions.

                               However, it is relevant to note that national concerns and restrictions regarding
                               the use of large lead sinkers and commercial equipment may also be argued by
                               other concerns as e.g. emissions from home casting of lead and waste disposal.
                               Lead sinkers combining lead and plastic materials may often end up as combus-
                               tible waste. While common rules exist in the EU regarding air emissions from
                               waste incineration national practices may differ considerably regarding disposal
                               of incineration residues like slag and clinker. Some countries as e.g. Denmark
                               are utilising such residues for civil works to the extent possible, and are thus
                               focused on reducing the content of hazardous substances like lead in waste for
                               incineration and may also for such reasons find restrictions on the use of lead in
                               fishing equipment for justified. The load of lead from fishing sinkers to the
                               waste streams may be reduced by the use of other instruments requiring the dis-
                               carded equipment to be collected separately and recycled. The costs of such a
                               separation and recycling operation could, however, be significant in particular
                               for lead lines and seine robes.


                               4.6        Summary and conclusion
Existing market                The EU25 market for lead fishing sinkers (lead-containing fishing equipment)
overview                       can be characterised by the following key figures:

                               •     More than 20 million anglers;
                               •     206,000 fishermen;
                               •     Detailed studies on the use of lead with sinkers are only available from a
                                     few countries;
                               •     Anglers use roughly 2,500-6,000 tonnes lead annually;
                               •     Approximately 2,000-9,000 tonnes lead is annually used for commercial
                                     fishing;
                               •     Manufacturers of lead sinkers and made-up fishing nets for commercial
                                     fishing are not organised in associations and limited information on the in-
                                     dustry is available;
                               •     Several hundred companies are involved in the manufacturing of lead
                                     sinkers, other lead-containing lures, lead wires and lead bead strings for
                                     lead-lines;
                               •     Further several hundred companies are involved in the manufacturing of
                                     made-up fishing nets;
                               •     Specific statistical information on the trade of fishing sinkers does not ex-
                                     ist;
                               •     Extra-community import of line fishing lures (including lead sinkers) and
                                     made-up fishing nets (including lead sinkers) to EU15 approximately equal
                                     the extra-community export;




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   120



                               •    Fishing sinkers for angling is to a large extent produced for the domestic
                                    markets hence there appears to be a well-developed common internal mar-
                                    ket for fishing lures;
                               •    Fishing sinkers and lead lines for fishing equipment for commercial fishing
                                    is to a large extent produced to the domestic markets, whereas there seems
                                    to be a common European market for lead wires and lead bead strings used
                                    for production lead-lines and ropes;

Existing regulation            The existing regulation within the EU25 area on the use of lead for sinkers can
overview                       be summarised as follows:

                               •    Full ban of the sale of lead sinkers in Denmark with a derogation for com-
                                    mercial fishing until December 1, 2004;
                               •    The use of lead shot above 0.06 grams and sinkers below 1 ounce (28.35
                                    grams) in fresh water is prohibited in the UK;
                               •    Local voluntary use restrictions in some river systems in Sweden.

Impact on industry,            Direct costs cover required investments for conversion of lead based sinkers
direct costs                   production lines into production lines based on substitute metals, as well as op-
                               erating and administrative costs. Investment costs relate to costs of converting
                               the industry (so-called conversion costs), and consist of two separate cost com-
                               ponents: costs for development of new products (research and development)
                               and cost for adaptation of existing machinery, thus allowing the machinery to
                               work properly with substitute metals.

                               It has for the present study not been possible to obtain specific information on
                               potential conversion costs. Change from lead casting to casting of other nonfer-
                               rous metals like zinc and tin is relatively simple, but involve investment in new
                               moulds. Change to a production based on steel and iron in general involves a
                               total change of machinery, and the production will most likely a shift from non-
                               ferrous foundries to industries based on ferrous metallurgy.

Impact on industry,            Indirect costs cover consequences for the manufacturers regarding competitive-
indirect costs                 ness and their decisions to invest and innovate due to the proposed regulation.
                               Lead sinkers are often manufactured for a local market by small workshops.
                               Based on the experience from UK and Denmark it is assessed that many small-
                               scale manufacturers are less for changes and may be pushed out of the market
                               in case of a ban on the use of lead for sinkers. There seems to be a tendency to
                               outsource the manufacturing of lures to Eastern Asia. The changes in the mar-
                               ket introduced by the ban may have speeded up a tendency already taking
                               place.

Social costs of tran-          It is at the present stage not possible to assess the social costs related to the
sition                         transition process for companies not able to adapt to restrictions on lead.

Impact on anglers              The only significant impact of a restriction of the use of lead sinkers on anglers
                               is increased prices of sinkers and other lead-containing lures. The incremental
                               cost are roughly estimated at 1.2-10.4 € per angler per year. It should be noted
                               that the price of lures only to a minor extent reflect the price of the raw materi-



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   121



                               als and the price may decrease as the market for lead-free alternatives mature
                               and the actual incremental costs may then be lower.

Impact on the fisher-          Three main consequences have been identified for commercial fishing: In-
ies                            creased volume of fishing equipment, increased noise by applying the equip-
                               ment and increased prices. The significance of the two first mentioned impacts
                               needs further investigations by actual testing of alternatives. The incremental
                               cost of a restriction on lead for sinkers to the fisheries due to increased prices is
                               estimated at 0.6-12 million €/year.

Impact on environ-             It has been demonstrated that split shot and small sinkers are ingested by water-
ment and health                fowl and similar effects as demonstrated for lead shot can be expected. Lead
                               sinkers lost in rivers is over time dissolved and may contribute to the total con-
                               tent of lead in the water and sediment. Lead sinkers lost in sea water will over
                               time be buried in the sediments and out of reach of the biota. Home casting of
                               sinkers may result in significant releases to the environment and exposure of
                               the persons involved.

Considerations re-             Sinkers and made-up fishing nets are to a large extent produced for the domes-
garding a common               tic markets in the different countries. A reason is that lead sinkers are relatively
market                         easy to produce in small-scale for a local market and that slightly different
                               types of nets are used in different countries (e.g. dependent on water depth, cur-
                               rent, sea floor, etc.). However, the same types of sinkers and lead lines are used
                               all over Europe and a common market for these products to some extent exists.
                               For lead wires and lead bead stings used for lead lines production, the main ap-
                               plication of lead for commercial fishing, there seems to be a common European
                               market.

Summary                        The main findings of the analysis are summarised in table 4.12.

                               The environmental concerns as to the use of lead sinkers are mainly related to
                               the use of lead split shot and small sinkers for fishing in inland waters. From an
                               environmental point of view a use restriction as the restriction implemented in
                               the UK would be the most well-documented. Furthermore, reasonable solid ar-
                               guments related to migratory birds exist for a community wide approach. How-
                               ever, the incremental costs to the anglers of a total ban is only a little higher as
                               a significant part of the incremental costs are due to the increased price of split
                               shot used in inland waters. It must also be recognized that only iron presents a
                               clear improvement compared to lead considering toxicity as well as other envi-
                               ronmental issues, while other alternatives suffers from one or more drawbacks
                               inclusive of lack of data. While both tin, bismuth and tungsten is regarded as
                               non-toxic to birds no water quality criteria or other comparative assessment
                               covering toxicity in water environments have been identified for these metals.
                               Zinc is toxic to birds and in the water environment although less toxic than
                               lead. Furthermore, it must be noted that substitutes for "dust shot" seem not to
                               be available, besides that their impact on birds have not been specifically
                               documented.

                               For larger sinkers and other lures used in the sea and in large lakes, a signifi-
                               cant home casting takes place, and these activities may increase as a conse-


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                   122



                                 quence of a ban of the sale of lead sinkers. It is deemed that a ban on the use of
                                 lead sinkers (like in the UK) more efficiently will reduce the load of lead to the
                                 environment than a ban of the sale (like in Denmark). In both cases a restriction
                                 will reduce the amount of lead emitted to waters covered by international sea
                                 conventions as the OSPAR Convention aimed at - among other issues - to re-
                                 duce the emissions of lead to the marine environment.

                                 A phase-out of lead for commercial fishing has relatively small incremental
                                 costs to the fisheries and the costs per ton of lead phased out is considerably
                                 lower than for sinkers for angling. It should be noted that the differences be-
                                 tween the incremental costs to anglers and the fisheries are reflecting the high
                                 profits at wholesaler and retails level for angling equipment compared to
                                 equipment for commercial fishing. However, the environmental effect of the
                                 decreased load of lead to the sea by lead from commercial fishing is not well-
                                 documented apart from that a restriction will reduce the amount of lead emitted
                                 to waters covered by international sea conventions as the OSPAR Convention.

                                 However, it is relevant to note that national concerns and restrictions regarding
                                 the use of large lead sinkers and commercial equipment may also be argued by
                                 other concerns as e.g. emissions from home casting of lead and waste disposal.
                                 Fishing equipment disposed of to landfills and waste incineration may contrib-
                                 ute significantly to total lead in waste and thus to the emissions caused by e.g.
                                 utilisation of incineration residues for civil works. The load of lead to the waste
                                 streams may, however, be reduced by the use of other instruments requiring the
                                 discarded equipment to be collected separately and recycled, which however
                                 may be costly in particular for items like lead lines and seine robes.

                                 Table 4.12        Estimated costs of phase-out of lead sinkers and reduced lead load to
                                                   the environment

                                                    Phase-out of lead sinkers       Total phase-out of lead       Phase-out of lead sinkers
                                                   for angling in inland waters       sinkers for angling          for commercial fishing
   Total costs to anglers/the fisheries per ton           19,000-39,000                  12,000-34,500                    300-1,330
   lead substituted (€/t) 1)
   Total costs to anglers/the fisheries in the                19-117                         24-207                         0.6-12
   EU25 (million €/year) 1)

   Reduced lead load to the environment in                  900-2,700                      1,800-5,400                    100-1,800
   the EU25 (t lead/year)
   Total costs to anglers/the fisheries in the                18-110                         23-198                       0.57-11.6
   EU15 (million €/year) 1)
   Reduced lead load to the environment in                  850-2,530                      1,700-5,040                     95-1,740
   the EU15 (t lead/year)
                                 1)          All costs are based on estimated retail prices. Costs of transition incl. of social costs for
                                             companies not able to adapt to restrictions are not included.




                                                                                                                                              .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   123



                               5          Candle wicks

                               5.1        Application of lead in candle wicks
Technological ra-              Using lead containing wicks in candles is one of a variety of known candle
tionale                        manufacturing technologies. Practically, a thin lead wire is inserted into a
                               woven wick and thereby supports or stiffens the candle wick.

                               The lead wire is used to support the wick and keep it centred in the deeper wax
                               pools that develop in container candles. The wire is also used in sustaining the
                               position of the wick during the wax pouring process. Additionally, some candle
                               makers find that the metal wire transmits heat from the flame down into the
                               wax pool. This provides a larger wax pool for a given flame size and it is possi-
                               ble to use a smaller flame, that keeps the jar cooler, and still melt the wax to the
                               edge.

Environmental and              The technology has traditionally been applied for certain specific product types
health impacts                 (container candles, mostly outdoor applications). When a lead wick based can-
                               dle is burned in indoor conditions, considerable amounts of lead may be re-
                               leased into indoor air and result in human exposure to lead by inhalation
                               (CSTEE 2003a). The lead released may otherwise settle as dust on furniture
                               and floors and thus be a source of human intake of lead for adults as well as
                               children or be as source of lead to waste and waste water to the extent lead is
                               removed from the indoor environment by cleaning. For candles used outdoor,
                               lead will similarly settle in the surroundings and thus add to the general level of
                               lead in the surroundings.


                               5.2        Markets of candle wicks
Industry structure             The European Association of Candle Makers (AECM) represents the larger
                               share of the European candle manufacturing industry. Members of AECM are
                               national manufacturer associations. Member countries include the EU15 (ex-
                               cept for Portugal, Luxemburg and Greece) as well as Switzerland and Norway
                               (total of 14 member countries). A few countries of the EU15 are thus not repre-
                               sented by AECM, which according to the AECM is due to the fact that no na-
                               tional associations of candle makers are known to exist in these particular coun-
                               tries. AECM also covers Poland and is in discussion with associations in some
                               of the other new EU-25 countries.

                               By estimate, AECM represents approximately 80-90% of the entire candle pro-
                               duction in Europe [AECM 2004].

                               A simple count of manufacturer links on the website www.europecandles.com
                               yields a total of 188 companies being registered as member of one of the 14
                               constituent national manufacturer associations of AECM. Traditionally, the
                               candle industry consisted of a large number of manufacturers, each serving
                               their own country or region. A few larger manufacturers have grown up in
                               some countries, but still there exist a large number of manufacturers throughout
                               Europe.



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             124



                               Most wicks today are made by specialist companies, who then supply the regu-
                               lar candle makers.

Production and con-            The production of candles within the EU15 area is worth of approximately 650
sumption                       mill. € per year (measured as an average of the years 2000-2002), which repre-
                               sents an annual volume of about 350,000 tonnes. Germany is by far the largest
                               single producer covering approximately 40% of the entire EU15 production
                               measured in monetary terms.

                               The relevant PRODCOM commodity codes only record amounts in monetary
                               terms and not in weight terms. The relevant weight proportions have, however,
                               been estimated based on an assumption on price per ton, which has been ex-
                               trapolated using the relevant COMEXT figures (that record volumes in mone-
                               tary and in weight terms, but do not record production or consumption figures -
                               reference is made to Annex 3).

                               Table 5.1         Estimated production and consumption of candles, average of 2000-
                                                 2002, tonnes finished candles

                                                                                    Production                    Consumption
                               Austria                                                   8,567                           27,826
                               Belgium                                                       na                              na
                               Denmark                                                  17,879                           27,212
                               Finland                                                  11,371                           12,226
                               France                                                   48,421                           54,315
                               Germany                                                 176,617                          183,015
                               Greece                                                        na                              na
                               Ireland                                                   6,880                           11,196
                               Italy                                                    46,121                           48,947
                               Luxembourg                                                     0                           1,545
                               Netherlands                                                   na                              na
                               Portugal                                                 17,068                            8,698
                               Spain                                                    11,306                           13,935
                               Sweden                                                   21,603                           26,796
                               UK                                                       57,492                           51,182
                               Total EU15                                              423,325                          466,894
                               Hungary 1)                                               16,498                            6,444
                               Lithuania 1)                                                789                            2,612
                               Poland 1)                                                53,110                           26,318
                               Source       Annex 3 table A3.33 and table A3.34
                               1)           Production figures for Hungary, Lithuania and Poland is based on 2002 figures. For Lithua-
                                            nia only export to EU15 has been recorded. Poland and Hungary only export and import to
                                            and from EU15 has been recorded.




Experience with lead           Candles with lead cored wicks are not recorded in the available EU-databases
wicks                          on candle production and can therefore not be tracked separately. According to


                                                                                                                                         .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   125



                               the AECM none of its present members are known to be engaged in production
                               or use of lead cored wicks. Lead wicks has earlier been used in European can-
                               dle manufacturing, but has been gradually phased out during the 1970'ties and
                               1980'ties [AECM 2004].

                               Lead was in the USA commonly used as a core material until 1974 when the
                               US candle manufacturing industry voluntarily agreed to discontinue use of lead
                               in wicks. There are, however, still candles on the US market that contain lead
                               wick cores. In one study 3% of 285 purchased candles in 2000 contained lead
                               [Potera 2000]. In another study from 2000 the researchers found lead wicks in
                               fourteen brands of candles manufactured in the US, Mexico, and China (cited
                               in [Knight et. al 2001]. In Australian investigations, several large China candles
                               were releasing lead [Potera 2000].

                               In 1999 the Swedish Chemicals Inspectorate received information that lead had
                               been found in candles in Sweden (questionnaire response - reference is made to
                               section 5.3).

                               Based on inter alia this knowledge, there is growing concern in the European
                               industry about the risks associated with imported candles and in particular im-
                               port from the Far East. Hence, a certain share of the imported volume from the
                               Far East is believed to contain lead cored wicks, although it has not been possi-
                               ble to estimate the actual extent of the problem [AECM 2004].

                               Due to the reported health problems related to using lead cored wicks, stricter
                               regulation concerning the use of such candles has been put forward by the gov-
                               ernments of Australia, USA and Canada. This - emphasised by an increasingly
                               strong euro - could imply that candle manufacturers in the Far East will refocus
                               their marketing and sales of lead cored wicks in candles towards the EU mar-
                               kets. Use of lead cored wicks is presently not subject to EU-wide regulation,
                               and more such candles are therefore likely to appear on the EU markets in the
                               future, according to the AECM [AECM 2004].

Import/export                  On average, some 36% of total production is exchanged across borders within
                               the EU15 area, and another approximately 17% is exported to countries outside
                               the EU15 area, notably the US, Norway and Switzerland - reference is made to
                               table A3.33 and table A3.34 in annex 3.

                               Annually, candles worth of about 280 mill. € are imported into the EU15 area,
                               most notably from China (53% of total imports) and from Poland (16% of total
                               imports) - reference is made to table A3.34 in annex 3.

                               Candles with lead cored wicks are not recorded in the available import/export
                               EU-databases and can therefore not be tracked separately. The AECM has not
                               been able to supply any supplementing statistics on the subject.

Focus on the Far East          As described above, the import from the Far East into the EU15 area is
                               considerable. The share of the total import, which contains lead cored wicks, is
                               not recorded. Some calculated estimates can be provided, however, based on



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              126



                               the overall imported ton figures. For this purpose it is necessary to calculate the
                               relative lead content (by weight) in a candle.

                               Table 5.2            Assumptions for lead content estimation

                              Item                      Assumption           Comments
                              Density lead              11.34 grams/cm3      Table 3.15
                              Density wax               0.91 grams/cm3       [candletech 2004]
                              Lead core diameter        0.0381 cm            0.01-0.02 inches according to [VOSI 2000]. The arith-
                                                                             metic average of 0.015 inches (equalling 0.0381 cm) is
                                                                             used in the calculations.
                              Lead content core         55%                  Lead cores are practically typically lead alloys, with a
                                                                             lead content between 25%-85% according to [VOSI
                                                                             2000]. The arithmetic average of 55% is used in the
                                                                             calculations.




                               The relative weight of the lead in a candle depends on the diameter of the can-
                               dle. Estimated lead content of round candles with varying diameters have been
                               provided in the table below.

                               Table 5.3            Relative weight of lead content of a lead containing candle

                                     Candle diameter, cm                            Relative lead content by weight
                                                1                                                0.977%
                                                2                                                0.248%
                                                3                                                0.110%
                                                4                                                0.062%
                                                5                                                0.040%
                                                6                                                0.028%
                                                7                                                0.020%
                                                8                                                0.016%
                                                9                                                0.012%
                                                10                                               0.010%
                               Source        Own calculations


                               It is assumed that lead cored wicks are mainly used in container candles and the
                               like, which typically are of diameters between 3 to 8 centimetres. It has not
                               been possible to obtain any information about the share of the import from the
                               Far East, which contains lead cored wicks.

                               According to table A3.34 in annex 3 the total import of candles and the like
                               from the Far East comes up to approximately 80,000 tonnes annually.

                               Assuming as a hypothetical example that 100% of all candles imported from
                               the Far East contain lead wicks and that the size of these candles corresponds to
                               diameters between 3 to 8 cm, the amount of lead imported yearly to EU15 with




                                                                                                                                        .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   127



                               such lead candle wicks can be roughly estimated at (reference is made to table
                               5.3):

                               80,000 tonnes (0,016% - 0,11%) = 12.8 - 88 tonnes


                               The example illustrates the relevant order of magnitude of the import and con-
                               sumption of lead that might take place by import of candles with lead candle
                               wicks from the Far East. Most likely the consumption will be well below 100
                               tonnes per year and may not exceed a few tonnes per year. The quantities in-
                               volved should therefore be considered small comparing to e.g. a consumption
                               of 38,600 tonnes of lead yearly in sporting and hunting ammunition (reference
                               is made to table 3.5).

Eastern Europe                 Lead cored wicks are, reportedly, still being used in a few Eastern European
                               countries. The technology is specifically applied in the production of graveyard
                               candles according to information provided by the industry2. It has, however, not
                               been able to verify the extent of the production or of the consumption of such
                               candles, neither through official statistics nor through more thorough and spe-
                               cific investigations undertaken in Poland, Hungary and Lithuania.

                               Poland was the second largest exporter of candles to the EU15 area, and there-
                               fore of course also plays an important role on the newly enlarged internal mar-
                               ket. The National Association of Candle Producers in Poland reports that there
                               are some 27 companies involved in the business. None of these uses lead for
                               manufacturing of wicks or candles. The technology was phased out in the Pol-
                               ish industry for some 15 years ago. [Andrusszkiewicz et al 2004]

                               It has not been possible to identify a national industry association for candle
                               makers in Lithuania. General knowledge about the sector in Lithuania is there-
                               fore sparse and not readily available. In general, however, Lithuanian candle
                               producers are typically small, family-owned, individual enterprises. Some of
                               these may be using the lead wick technology, in particular for manufacturing of
                               graveyard candles, although it has not been possible to verify. Candles using
                               lead wicks are not recorded separately in national statistics databases or similar.
                               About 800 tonnes of candles were produced in 2002 in Lithuania. In the same
                               year almost 2,000 tonnes were imported, of which 80% came from Poland and
                               approximately 6% from China. So, the import accounts for the larger part of
                               candles used in Lithuania, and the main importer reportedly does not use the
                               lead wick technology [Rinkevicius 2004].

                               Attempts have been made at establishing a national manufacturers association
                               in Hungary. No such association, however, exists yet. It is reported that the us-
                               age of lead candlewicks is rather limited in the Hungarian market, all the mar-
                               ket leaders produce lead-free candles. The number of producers of lead candle-
                               wicks could not be estimated directly, however, their aggregate share of the


                               2
                                Telephone interview with the largest European wick manufacturer Wedo
                               (www.wedowick.de); 22 July 2004


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   128



                               market for candles is not deemed to be significant. Interviews made with repre-
                               sentatives of the Hungarian industry have revealed that some candles with lead
                               wicks are imported from Croatia into Hungary. The extent of that import, how-
                               ever, is unknown [Varkonyi 2004].

                               There are thus indications in the available information that production of can-
                               dles with lead wicks may take place in the Balkan Region, but neither the size
                               of the production nor the more detailed geographical dispersion is known.


                               5.3        Legal or voluntary use restrictions on lead wicks
AECM Voluntary                 The phasing-out of lead wicks in European candle manufacturing during the
agreement                      1970'ties and 1980'ties was supported by a number of voluntary agreements
                               made among manufacturers and their associations. Today, AECM as the main
                               European manufacturer association is formally recommending a European ban
                               on the production and use of candles with lead wicks (above the 0.06% thresh-
                               old). The minimum threshold is recommended because zink naturally may con-
                               tain up to 0.06% lead. Zink is one of the likely substitutes to lead cored wicks
                               [AECM 2004].

National regulation            Information on legal use restrictions on lead candle wicks at national level was
identified                     collected by a questionnaire to the national environmental authorities in all old
                               and new Member States and Candidate Countries. The questionnaire was pre-
                               pared in English. The questionnaire was addressed to contact persons in the
                               Member States attending the Commission's Working Group on the Limitation
                               of Marketing and Use Directive. For countries without contact persons in the
                               working group, the questionnaire was addressed to the ministries responsible
                               for environmental issues in each country.

                               Twenty-five of the 28 countries answered the questionnaire.

                               Lead in candle wicks has been prohibited in Denmark from 2002 (questionnaire
                               response). The Danish EPA did not find any candles with lead wicks in a cam-
                               paign in 2001 covering candles from six stores in Copenhagen [Danish EPA
                               2002].

                               The use of lead wicks is restricted in Finland for indoor use since 2001 by the
                               Consumer Agency's Guidelines on Safety Requirements for Candle Products
                               and Related Indications, while for outdoor uses it is recommended not to use
                               lead in candle wicks (questionnaire response).

                               Lead in candle wicks has been prohibited in Denmark from 2002 (questionnaire
                               response).

                               The Swedish Chemicals Inspectorate in 1999 reacted to the information that
                               lead had been found in candles in Sweden by asking the stores in a press notice
                               to remove candles with lead from the shelves (questionnaire response).




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   129



                               UK candle manufacturers have voluntarily agreed not to use lead and lead has
                               not been used in wicks since 1970's (questionnaire response).

                               It is assumed that no specific regulation on the use of production of lead cored
                               wicks exist elsewhere within the EU area. Specifically, no use restrictions have
                               been identified in Poland, Lithuania or Hungary.

Experience from                Lead was in the USA commonly used as a core material until 1974 when the
abroad                         US candle manufacturing industry voluntarily agreed to discontinue use of lead
                               in wicks.

                               Today lead candle wicks are banned in Australia, USA and Canada [AECM
                               2004].


                               5.4        Availability of substitutes for lead wicks
Alternative tech-              According to AECM [AECM 2004] lead supported wicks can in all cases be
nologies                       substituted simply by using thicker woven wicks or wicks with alternative
                               cores. Alternative cores may be made from either zinc or tin. Both alternatives
                               are considered complete substitutes to lead in the sense that all required per-
                               formance characteristics both in use as well as in manufacturing are maintained.

                               There are no significant barriers for a manufacturer in shifting technology (shift
                               to substitute metal cores) in terms of adaptation of machinery and adjustment of
                               production processes.

                               There are no known manufacturers of zinc or tin wicks in Europe, according to
                               the AECM. By far the larger share of candles used in Europe is based on wicks
                               without supporting metal wires [AECM 2004].

Experience from                Zinc is today commonly used in US produced candles as an alternative metal
abroad                         core for the wicks, since it provides the desired amount of stiffness and burns
                               off readily with the rest of the wick [Knight et. al 2001]. Tin is also commonly
                               used in the USA as a stiffener for candle wicks [NCA 2004].

Environmental and              Neither zinc nor tin wicks are considered to emit metals at concentrations caus-
health impacts                 ing health concerns [Knight et. al 2001]. No precise data regarding the impact
                               on environment of tin and zinc being burned as candle wicks are available. Re-
                               garding the other option of using thicker wicks, no studies are available indicat-
                               ing specific health or environmental problems related to this option.


                               5.5        Impact of potential marketing and use restrictions
                                          on lead wicks
Business impacts               It is assessed that an EU-wide restriction on marketing and use of lead wicks in
                               candles in the EU area will have no effects on the manufacturing industry in
                               EU, as no manufacturing companies in EU15 as well as the New Member
                               States to the best of knowledge is manufacturing candles with lead wicks. Indi-




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   130



                               cation exists of that such candles may be produced in the Balkan region e.g.
                               Croatia, but no certain knowledge on this issue is available.

                               It is assumed that candles with lead wicks to the extent such candles are avail-
                               able to consumers in the EU will originate from import from countries outside
                               the EU and in particular from the Far East.

                               Substitutes for lead wicks based on zinc and tin is available besides that thicker
                               woven wicks is the general solution adopted in Europe.

                               As it has not been possible to identify candles with lead wicks for sale in the
                               EU and thereby to be informed of retail prices for such candles as compared to
                               candles with substitute solutions it is not possible to estimate the costs to con-
                               sumers of a potential restriction on the use of lead wicks in Europe.

                               The data on prices on raw materials presented in table 3.15 makes it likely that
                               the manufacturing price for candles with lead wicks could be slightly lower
                               than for candles with substitute solutions. However, considering the amount of
                               lead used per candle and the likely very limited consumption of lead for this
                               purpose in Europe, the financial consequences to European consumers of a po-
                               tential restriction must be assumed marginal or in reality non-existing.

Environmental and              It is estimated that the amount of lead being imported to Europe as candle
health impacts                 wicks in candles - although not known - likely is small and may not exceed a
                               few tonnes per year. Still the risk exists that some consumers are exposed to
                               lead fumes from lead wicks in candles. When a lead wick based candle is
                               burned in indoor conditions, considerable amounts of lead may be released to
                               the indoor air and result in human exposure to lead by inhalation. The lead re-
                               leased may otherwise settle as dust on furniture and floors and thus be a source
                               of human intake of lead for adults as well as for children. Besides, the released
                               lead may be a source of lead to waste and waste water when the lead is re-
                               moved from the indoor environment by cleaning. For candles used outdoor,
                               lead will similarly settle in the surroundings and thus add to the general level of
                               lead in the surroundings.

Relevance of a                 To the best of knowledge a community wide approach may benefit all stake-
community wide ap-             holders in all Member States of the EU apart from those companies making a
proach                         profit out of importing and selling candles with lead wicks on the European
                               market. In particular the consumers of candles may benefit from a complete
                               elimination of the risk of being exposed to lead fumes from candles.


                               5.6        Summary and conclusion
Market overview                The total consumption of candles within EU15 is estimated at about 470,000
                               tonnes, while the production in EU15 reached about 420,000 tonnes. The dif-
                               ference is covered by a net import of candles, of which more than 50% is com-
                               ing from the Far East.




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   131



                               No production of lead containing candles in the EU15 area has been detected.
                               There may reportedly be a small production in certain parts of Eastern Europe,
                               notably the general Balkan area, but it has not been possible to document this
                               assumption.

                               Lead wicks are in Europe primarily substituted by thicker woven wicks. How-
                               ever zinc and tin wicks may be used as substitutes as well. The available substi-
                               tutes are fully satisfactory from a user as well as a manufacturing point of view,
                               and potential costs related to this substitution are assumed marginal or in reality
                               non-existing.

                               To the extent that lead containing candles can be found for retail sale within the
                               EU area, they are likely to be imported, mainly from the Far East. Actually this
                               issue is a main reason behind the focus on candle wicks, as it is known that lead
                               wicks is used in the Far East and imported to e.g. USA and Australia, and it is
                               feared that restrictions in inter alia these countries may motivate candle export-
                               ers in the Far East to increase their export to the EU.

Restriction on mar-            It is assessed that an EU-wide restriction on marketing and use of lead wicks in
keting and use of              and for candles will have no effects on the manufacturing industry in the EU. It
lead wicks                     is also not possible to identify any disadvantages to the European consumers of
                               such a restriction, while the consumers certainly will benefit from such a re-
                               striction. Although the import and consumption of lead candle wicks in Europe
                               likely is small the risk exists that some consumers are exposed to lead fumes
                               from lead wicks in candles and the lead dust generated by those fumes. A re-
                               striction should - in principle - eliminate this risk completely.

                               To the best of knowledge a community wide approach may benefit all
                               stakeholders in all Member States of the EU apart from those companies im-
                               porting and selling candles with lead wicks on the European market.




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   132



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                               Strigul, N., W.Braida, D. Dermatas, C.Chritodoulatos, and M.Los. 2004a.
                                    Tungsten effects on soil environments. Abstract submitted to the Univer-


                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   139



                                    sity of Massachusetts Annual International Conference on soils, sedi-
                                    manets and water.

                               Strigul, N., A. Koutsospyros, C.Chritodoulatos, D. Dermatas, and W.Braida.
                                    2004a. Effects of munitions grade tungsten environmental systems.
                                    Manuscript submitted to Chemosphere.

                               Thornton, I., R. Rautiu & S. Brush. 2001. Lead - the facts. IC Consultants Ltd,
                                   London.

                               TNO. 2001. Risks to health and the environment related to the use of lead in
                                  products. TNO report STB-01-39 for the European Commission, DG En-
                                  terprise. Available at:
                                  http://europa.eu.int/comm/enterprise/chemicals/markrestr/studies/studies.ht
                                  m)

                               Toft, O. 2004. Personal communication with Ole Toft, Grej Sport. Herning,
                                   Denmark, July 2004

                               Tufts. 2004. Loons and lead poisoning. Tufts University Scholl of Veterinary
                                   Medicine at: http://www.tufts.edu.

                               UNEP 2004. African-Eurasian Migratory Waterbird Agreement. at:
                                  http://www.unep-wcmc.org/AEWA/eng/intro.htm

                               UK gun 2004. Information available on www.ukgunproducts.com. September
                                  2004.

                               US EPA. 2001. Best management practices for lead at outdoor shooting
                                   ranges. United States EPA-902-B-01-001

                               USGS. 2001. Mineral commodity summaries. U.S. Geological Survey, Reston.
                                  http://minerals.usgs.gov/minerals/pubs/commodity/chromium/index.html.

                               Varkonyi, Z. 2004. Information collected in Hungary by Mr. Zoltan Varkonyi,
                                   COWI Hungary. July 2004.

                               VOSI. 2000. Information available on voicesofsafety.com/t1-ph-v50-1-
                                  standard.htm. Assessed by October 2004.

                               WHO. 1989. Lead - environmental aspects. Environmental Health Criteria 85.
                                 World Health Organisation, International Programme on Chemical Safety
                                 (IPCS), Geneva, Switzerland.

                               WHO 1993. Guidelines for drinking-water quality, 2nd ed. Vol. 1. Recom-
                                 mendations. Geneva, World Health Organization, 1993. p. 56.
                                 http://www.who.int/docstore/water_sanitation_health/GDWQ/Chemicals/ti
                                 nsum.htm




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   140



                               WHO 1995. Inorganic lead. Environmental Health Criteria 165. World Health
                                 Organisation, International Programme on Chemical Safety (IPCS), Ge-
                                 neva, Switzerland.

                               Winther, B. 2004. Personal communication with Mr. Bent Winther, Chairman
                                  of the clay pigeon section within the Danish Shooting Federation. Copen-
                                  hagen, July 2004.

                               Working Group. 1998. Soil contaminations at shooting ranges. Report by the
                                  Work Group of the Conference of the (Laender) Ministers for the Envi-
                                  ronment. Germany. Available at: http://www.wfsa.net/SoilReport.pdf




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   141




                               Annex 1
                               Contacted European associations

                               AMMUNITION

                               FACE
                               Federation of Associations for Hunting and Conservation of the E.U.
                               82, Rue F. Pelletier Street
                               1030 Brussels, Belgium
                               Phone: +32.2.732.69.00
                               Fax: +32.2.732.70.72
                               e-mail: info@face-europe.org
                               http://www.face-europe.org

                               A questionnaire has been circulated to national associations, members of
                               FACE, based on the FACE member list.

                               AFEMS
                               The Association of European Manufacturers of Sporting Ammunition
                               Av. Van Nieuwenhuyse, 4
                               B 1160 Brussels-Belgium
                               Tel. +32.2.676.7211 Fax +32.2.676.7203
                               Secretariat: AFEMS Via Flaminia 342/B
                               I-00196 Rome-Italy
                               Tel. +39.06.322.0016 Fax +39.06.322.0018
                               E-mail: afems@afems.org
                               Website: http://www.afems.org

                               ISSF
                               International Shooting Sport Federation
                               ISSF Headquarters:
                               Bavariaring 21D-80336 München, Germany
                               Phone: 49-89-5443550 - Fax: 49-89-54435544
                               Email: admin@issf-shooting.org
                               Website: http://www.issf-shooting.org

                               ESC
                               European Shooting Confederation
                               Unni Nicolaysen, President
                               Skadalsvn. 26 A
                               0781 Oslo, Norway
                               Norway Ph: +47 22920627
                               Phone: +22140481
                               Fax +47 22920827
                               Email: unic@powertech.no

                               FISHING SINKERS




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   142




                               EFTTA
                               The European Fishing Tackle Trade Association
                               73 St John Street
                               London EC1M 4NJ
                               Tel: +.44.20.7253.0777
                               Fax: +.44.20.7253.7779 (trade ony)
                               Email: info@eftta.com
                               Website: http://www.eftta.com

                               EAA
                               European Anglers Alliance
                               Rue du Parnasse, 42
                               B-1050 Brussels - Belgium
                               Tel/Fax : +32 (0)2 732 03 09
                               E-mail : email@eaa-europe.org
                               Website: http://www.eaa-europe.org

                               EUROPÊCHE
                               Association representing professionals in the fisheries sector in the EU
                               Rue de la Science 23/25, B
                               1040, Brussels
                               Tel: +32 2 230 4848
                               Fax: +32 2 230 26 80
                               Email: europeche@skynet.be

                               A questionnaire has been circulated by EUROPÊCHE to their national member
                               associations.

                               Further, a request regarding the presence of national associations of manufac-
                               turers of fishing equipment for commercial fishing has been circulated to na-
                               tional industry associations based on a member list at:
                               http://www.unice.org/content/default.asp?PageId=260

                               CANDLE WICKS

                               AECM
                               Association of European
                               Candle Manufacturers
                               118, Avenue Achille Peretti
                               F-92200 Neuilly-sur-Seine
                               Tel. 33 (0) 1 46 37 22 06
                               Fax 33 (0) 1 46 37 15 60
                               E-mail: bougies@fncg.fr
                               Website: http://www.europecandles.com

                               USE OF LEAD IN GENERAL

                               LDAI
                               Lead Development Association International



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   143




                               42 Weymouth Street
                               London W1G 6NP
                               Tel: +44 (0)20 7499 8422
                               Fax: +44 (0)20 7493 1555
                               Website: http://www.ldaint.org

                               ILZSG
                               International Lead and Zinc Study Group
                               1 Mill Street
                               London
                               SE1 2DF
                               United Kingdom
                               Telephone: + (44) 20 7740 2750
                               Facsimile: + (44) 20 7740 2983
                               E-mail: root@ilzsg.org
                               Website: http://www.ilzsg.org




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   144




                               Annex 2
                               Other contacted associations and companies

                               (contacted by phone eventually supplied with e-mail)

                               Contacted national fishing tackle trade associations
                               Angling Trades Association Ltd, UK
                               GIFAB, France
                               Spofa Spöfiske, Sweden
                               FIPO, Italy

                               Other contacted associations
                               Nordic Fishermen's Council, Denmark
                               Lithuanian Association of Hunters and Anglers, Lithuania
                               National Federation of Hungarian Anglers, Hungary
                               National Association of Fishermen, Hungary
                               Hungarian Hunters’ National Chamber, Hungary
                               Hungarian Dynamic Sport Shooting Federation, Hungary
                               Polish Association of Angling, Poland
                               National Association of Candle Producers, Poland
                               Polish Association of Sport Shooting, Poland
                               Polish Association of Hunters, Poland
                               Federación Española de Organizaciones pesqueras (FEOPE), Spain
                               Federación Española de Armadores de Buques de Pesca (FEABP), Spain
                               Asociación de Sociedades Pesqueras Españolas (ASPE) , Spain
                               Asociación de Productore de Ondario (Pais Vasco), Spain
                               Organización de Productores de Celeiro (Galicia), Spain

                               Contacted companies, fishing sinkers
                               Delta Plus, Czech Republic
                               Sema, Czech Republic
                               Lovy s.r.o, Czech Republic
                               Hvalpsund Net, Denmark
                               Svendsen Sport, Denmark
                               Randers Reb A/S, Denmark
                               Daconet A/S, Denmark
                               Iron Strand, Denmark
                               Kuusamon Uistin Oy, Finland
                               Lemer Fondarie, France
                               Collin Technology GmBH, Germany
                               Kamasaki Elnex, Hungary
                               Fisch KFT, Hungary
                               Deáky Fishing Tackle Manufacturing Ltd, Hungary
                               Q-tor Ltd., Hungary
                               Balaton Fishing Co., Hungary
                               JSC Elizija, Lithuania
                               Vedette di Viassone, Italy
                               Stoppioni Snc - STONFO, Italy



                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   145




                               KAMAX, Poland
                               Konger, Poland
                               Gamakatsu, Poland
                               Angel Sport, Poland
                               Kostal SC, Poland
                               Somsen & Poole Da Costa lda, Portugal
                               Dom Carlos Santos Miranda, Portugal
                               Cabos Y Redes, Spain
                               Efectos Navales de Celeiro, Spain
                               Calico SA, Spain
                               El Vilar, Spain
                               Grauvell Fishing SA, Spain
                               Lukris, S.L., Spain
                               Plumiratun, Spain
                               Talleres González y Fajardo, S.L., Spain
                               Redes Salinas S.L., Spain
                               Marina Hispanica S.L., Spain

                               Contacted companies, other applications
                               Eurocandle Ltd, Hungary
                               Candle Shop Ltd, Hungary
                               WEDO, Germany




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   146




                               Annex 3 Abbreviations
                               The following abbreviations are used in this report:

                               AECM                   Association of European Candle Manufacturers
                               AFEMS                  The Association of European Manufacturers of Sporting
                                                      Ammunition
                               ASPE                   Asociación de Sociedades Pesqueras Españolas
                               CA$                    Canadian dollars
                               CIP                    Permanent international Commission for the Proof of Small
                                                      Arms
                               CN                     Common Nomenclature (statistical commodity codes)
                               COMEXT                 An Eurostat database on commodities
                               CWS                    Canadian Wildlife service
                               DKK                    Danske kroner (Danish currency)
                               EAA                    European Anglers Alliance
                               EFTTA                  The European Fishing Tackle Trade Association
                               EFTTEX                 The European Fishing Tackle Trade Exhibition
                               EPA                    Environmental Protection Agency
                               ESC                    European Shooting Confederation
                               EU15                   The European Union with 15 Member States i.e. before 2004
                               EU25                   The European Union with 25 Member States i.e. from 2004
                               EUROPÊCHE              Association representing professionals in the fisheries sector
                                                      in the EU
                               EUROSTAT               The Statistical Agency of the European Union
                               FACE                   Federation of Associations for Hunting and Conservation of
                                                      the E.U.
                               FEABP                  Federación Española de Armadores de Buques de Pesca
                               FEOPE                  Federación Española de Organizaciones pesqueras
                               FIPO                   The Italian association of manufacturers and wholesalers of
                                                      fishing tackle.
                               GIFAB                  The French association of manufacturers and wholesalers of
                                                      fishing tackle.
                               GRT                    Gross Register Tonnage
                               ILZSG                  International Lead and Zinc Study Group
                               ISSF                   International Shooting Sport Federation
                               LDAI                   Lead Development Association International
                               Mill.                  Million
                               OSPAR                  The OSPAR Convention on the protection of the marine
                                                      environment of the North-East Atlantic.
                               Pb                     Lead
                               PRODCOM                An Eurostat database on commodities
                               t                      Tonne/tonnes
                               UNICE                  Union des Industries de la Communauté Européenne
                               USFWS                  The United States Fish and Wildlife Service
                               €                      Euro
                               US$                    US dollars




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   147




                               Annex 4 Questionnaires

                               The following questionnaires used for collection of data are presented in this
                               annex:

                               !   Questionnaire to national environmental authorities in Member States and
                                   Candidate Countries

                               !   Questionnaire to hunters associations in Member States and Candidate
                                   Countries

                               !   Questionnaire to fisheries associations in Member States and Candidate
                                   Countries

                               !   Questionnaire to associations of producers of fishing equipment in Member
                                   States and Candidate Countries




                                                                                                                          .
     Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           148



(To national environmental authorities)

Advantages and drawbacks of restricting the marketing and use of lead in ammuni-
tion, fishing sinkers and candle wicks
COWI A/S for the European Commission, DG ENT
Please return before March 30, 2004 to crl@cowi.dk or the address indicated below

Please indicate the names of legal instruments and agreements in both the original language and in English.


 COUNTRY
 INSTITUTION
 FILLED IN BY (NAME)
 DATE




Restrictions on the use of lead for fishing

Please mark with an X

                                No use re-                                            Use restriction
                                striction
                                                     Legal use restriction         Voluntary use restriction 2)   Date of entry into force
                                                              1)
 Use of lead for sport fish-
 ing in seawater
 Use of lead for sport fish-
 ing in fresh water
 Use of lead for profes-
 sional fishing
 Other (please specify un-
 der comments)




1)     Name of instrument for legal use restriction:




2)     Description of voluntary use restriction (name of agreement, partners, etc.):




Comments:




                                                                                                                                             .
     Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           149




Restrictions on the use of lead for candle wicks

Please mark with an X

                                No use re-                                            Use restriction
                                striction
                                                     Legal use restriction         Voluntary use restriction 2)   Date of entry into force
                                                              1)
 Use of lead for production
 of candle wicks
 Use of lead in marketed
 products


1)     Name of instrument for legal use restriction:



2)     Description of voluntary use restriction (name of agreement, partners, etc.):


Comments:


Restrictions on the use of lead for ammunition

Please mark with an X

                                No use re-                                            Use restriction
                                striction
                                                     Legal use restriction         Voluntary use restriction 2)   Date of entry into force
                                                              1)
 Use of lead shots over
 wetlands (or for waterfowl
 hunting)
 Use of lead shots in for-
 ests
 Use of lead shots for tar-
 get shooting and sporting
 Other uses of lead shots
 Use of lead for rifle ammu-
 nition
 (please specify under
 comments)
 Other


1)     Name of instrument for legal use restriction:



2)     Description of voluntary use restriction (name, partners, etc.):


                                                                                                                                             .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   150




Comments:




Legal requirements to ammunition for hunting

Is ammunition for hunting to some extent regulated by legal requirements (e.g. specific bullet weight or
striking energy for different types of game?

No legal requirements (mark with an X):

Legal requirements (name of instrument):




Please address questions regarding the questionnaire to:
Carsten Lassen, COWI A/S, Havneparken 1
DK-7100 Vejle, Denmark


E-mail: crl@cowi.dk
Tel: +45 7642 6412
Fax: +45 7642 6401




                                                                                                                             .
     Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks      151



(To hunters associations)

Rules, restrictions and measures for the use of hunting ammunition containing lead
COWI A/S for the European Commission, DG ENT
Please fill in and return before April 30, 2004 to COWI at crl@cowi.dk or fax +45 7642 6401

Please indicate the names of legal instruments and agreements in both the original language and in English.




 COUNTRY
 NAME OF ASSOCIATION
 FILLED IN BY (NAME)
 DATE




Legal or voluntary restrictions on the use of hunting ammunition containing lead


Please mark with an X:

                                   No restriction                                   Use restriction or ban
                                   or ban on the       Legal use        Voluntary use      Date of entry               Region
                                   use                 restriction      restriction 2)      into force
                                                           1)
 Use of lead shot over wet-
 lands (or for waterfowl
 hunting)
 Use of lead shot in forests
 Use of lead shot for target
 shooting and sporting
 Other uses of lead shot
 Use of lead for rifle am-
 munition
 Other (please specify un-
 der comments)




1)     Name of instrument for legal use restriction:

2)     Description of voluntary use restriction (name of agreement, partners, etc):



Comments:




                                                                                                                                  .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   152



Other rules or measures that regulate the use of hunting ammunition containing lead

Please indicate other rules or measures taken by competent authorities or organisations that regulate the use
of lead in hunting ammunition:




Please address questions regarding the questionnaire to:
Carsten Lassen
COWI A/S
Havneparken 1
DK-7100 Vejle
Denmark


E-mail: crl@cowi.dk
Tel: +45 7642 6412
Fax: +45 7642 6401




                                                                                                                             .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks        153



(To fisheries associations)

Use of lead in fishing sinkers - impact of restricting the use
COWI A/S for the European Commission, DG ENT
Please fill in electronically and return before July 20, 2004 to crl@cowi.dk




 COUNTRY
 NAME OF ASSOCIATION
 FILLED IN BY (NAME)
 TEL.
 E-mail
 DATE


Use of lead for fishing nets for commercial fishing



Which types of fishing equipment for commercial fishing are manufactured and used in the country and to
what extent is lead used for the equipment:


 Put a cross            Manufactured      Used in the                   Lead is used in the equipment in the form of:
                        in the country     country       Weights/ sinkers        Lead lines          Seine ropes           No lead
 Ring net
 Seines
 Trawl
 Pound nets
 Fyke or hoop
 nets
 Set net
 Lines for line
 fishing
 Other (describe
 in comments)
 Other (describe
 in comments)



Comments:



If any studies on the use of lead for fishing equipment in the country exist, please make a full reference to
the study:

How much lead is annually used for equipment for commercial fishing in the country (put a cross)?


                                                                                                                                     .
  Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             154



        <10                  10-50 t               50-200 t               200-800 t             800-2000 t                >2000 t




The estimate is based on (put a cross):

      Actual study             Expert judgement                 Guess




Manufacturing of fishing nets/gear in the country

If a national association of manufacturers of fishing nets/gear exists, please indicate contact coordinates:



How many manufacturers of made-up fishing nets/gear are operative in the country (indicate approximate
number):



Are lead weights and lead ropes/lines for production of made-up nets mainly produced domestically
(yes/no):



Are fishing nets/gear with lead-free alternatives produced in the country (yes/no):

(In case of "yes", please describe the types):



Effects of restricting the use of lead

How would a ban on the use of lead for fishing nets impact the fishery in the country:



How would a ban on the use of lead for fishing nets impact the manufacturing of fishing nets/gear in the
country:




                                                                                                                                      .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              155



Net terminology (according to Glossary of United Kingdom Fishing Gear Terms):
Ring net: A single-panelled multi-sectioned pelagic encircling net usually operated by two vessels. Seine: An encircling net sometimes
with ropes, e.g. purse seine, beach seine, Danish seine. Trawl: A fishing gear assembly incorporating a funnel-shaped net, ropes and
hardware to hold open the mouth of the net when towed. Pound net: General term for any moored and/or staked net comprising a leader
and one or more enclosures, e.g. bag net, stake net, kettle net. Fyke net: Anchored comprised of leader(s) and one or more small cham-
bers, each with an inner conical-shaped non-return 'valve' leading to the next chamber. Hoop net: Conical net attached to a hoop and
baited to catch lobsters, prawns, etc. Set net: General term for any simple net when it is held in fishing trim by anchors, sinkers and/or
stakes, e.g. trammel net, tangle net, gill net.

Seine ropes are used for large seines used e.g. for fishing benthic fish on relatively shallow water. The seine rope is typi-
cally designed as a woven rope with a thin lead woven into the filaments of polypropylene or polyester, which is sewn to the
net.




Lead lines are made of small pieces of lead threaded on a plastic rope. The leaded rope is covered by a woven plastic
stocking of polypropylene, polyester or other plastics and the stocking is sewn or woven on the net.




 Please address questions regarding the questionnaire to:
 Carsten Lassen
 COWI A/S
 Havneparken 1
 DK-7100 Vejle, Denmark
 E-mail: crl@cowi.dk
 Tel: +45 7642 6412




                                                                                                                                             .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks        156




(To associations of producers of fishing equipment)

Use of lead in fishing sinkers - impact of restricting the use
COWI A/S for the European Commission, DG ENT
Please fill in electronically and return before May 5, 2004 to crl@cowi.dk


 COUNTRY
 NAME OF ASSOCIATION
 FILLED IN BY (NAME)
 TEL.
 DATE




Use of lead for fishing nets for professional fishing

How many producers of fishing nets are operative in the country (indicate approximate number):



How many professional fishermen are operative in the country (indicate approximate number):



Which types of fishing tools for professional fishing are produced and used in the country (see terminology
below):


 Put a cross           Produced        Used in the                     lead is used in the equipment in the form of:
                         in the         country
                                                       Weights/ sinkers         Lead lines           Seine ropes           No lead
                        country
 Ring net
 Seines
 Trawl
 Pound nets
 Fyke or hoop
 nets
 Set net
 Lines for line
 fishing
 Other (describe
 in comments)



Comments:

How much lead is annually used for production of fishing equipment in the country (put a cross)?



                                                                                                                                     .
  Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             157



        <10                  10-50 t                50-200 t              200-800 t              800-2000 t               >2000 t




Are lead weights and lead ropes/lines for production of made-up nets mainly produced domestically
(yes/no): (In case "yes" please describe the types):



Are fishing nets with lead-free alternatives produced in the country (yes/no):

(In case "yes" please describe the types):



Effects of restricting the use of lead

How would a ban on the use of lead for fishing nets impact the fishing nets industry in the country (use the
categories below or prepare your own):

                                                                                  Put a cross
                                         All net/   Ring       Seines    Trawl        Pound     Fyke/    Set        Lines       Other
                                         equip-     net                               nets      hoop     nets
                                         ment                                                   nets
 No effects expected
 The production would be concen-
 trated on fewer enterprises
 A part of the domestic production
 would be replaced by imported
 products
 The production and export would
 increase
 A part of the domestic production
 would be replaced by domestic
 production at other companies.
 Domestic production may cease
 completely in favour of imported
 products




Comments:

How many years would be needed for the industry to shift to lead-free alternatives for production of fishing
nets (indicate number of years):




                                                                                                                                        .
   Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              158



Net terminology (according to Glossary of United Kingdom Fishing Gear Terms):
Ring net: A single-panelled multi-sectioned pelagic encircling net usually operated by two vessels. Seine: An encircling net sometimes
with ropes, e.g. purse seine, beach seine, Danish seine. Trawl: A fishing gear assembly incorporating a funnel-shaped net, ropes and
hardware to hold open the mouth of the net when towed. Pound net: General term for any moored and/or staked net comprising a leader
and one or more enclosures, e.g. bag net, stake net, kettle net. Fyke net: Anchored comprised of leader(s) and one or more small cham-
bers, each with an inner conical-shaped non-return 'valve' leading to the next chamber. Hoop net: Conical net attached to a hoop and
baited to catch lobsters, prawns, etc. Set net: General term for any simple net when it is held in fishing trim by anchors, sinkers and/or
stakes, e.g. trammel net, tangle net, gill net.

Seine ropes are used for large seines used e.g. for fishing benthic fish on relatively shallow water in the North Sea. The
seine rope is typically designed as a woven rope with a thin lead woven into the filaments of polypropylene or polyester,
which is sewn to the net.




Lead lines are used all over Europe for pound nets (or set nets). A line is made of small pieces of lead threaded on a plastic
rope. The leaded rope is covered by a woven plastic stocking of polypropylene, polyester or other plastics and the stocking
is sewn or woven on the net.




Sinkers/weights are used all over Europe for large ring nets for pelagic fish, trawls, fykes, hoop nets and
other types of net fishing. The size and design of the weights may differ considerably.


 Please address questions regarding the questionnaire to:
 Carsten Lassen
 COWI A/S
 Havneparken 1
 DK-7100 Vejle
 Denmark


 E-mail: crl@cowi.dk
 Tel: +45 7642 6412




                                                                                                                                             .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   159




                              Annex 5 Trade Statistics

                              Production and intra- and extra-community
                              trade of cartridges
                              Statistics on production, import and export by old and new Member States and
                              Candidate Countries was retrieved from the Europroms database of Eurostat.
                              According to the PRODCOM nomenclature (the nomenclature used for the da-
                              tabase), all ammunition is covered by one commodity code only: 29.60.14.30
                              'Cartridges and parts thereof for shotguns, revolvers, pistols, rifles, carbines and
                              military firearms, slugs, pellets and darts (excl. for captive-bolt humane killers)'
                              . The database thus does not provide detailed statistical data for the different
                              types of ammunition.

                              Statistics on intra- and extra-community export was retrieved from the
                              COMEXT database of Eurostat. Data was retrieved for the Combined Nomen-
                              clature (CN) codes:

                              9306 21 00 - Shotgun cartridges
                              9306 30 91 - Centrefire cartridges
                              9306 30 93 - Rimfire cartridges

                              The full CN classification regarding ammunition is shown below:

                              9306        Bombs, grenades, torpedoes, mines, missiles and similar munitions of war
                                          and parts thereof; cartridges and other ammunition and projectiles and
                                          parts thereof, including shot and cartridge wads :

                              9306 10 00 Cartridges for riveting or similar tools or for captive–bolt humane killers and
                                          parts thereof

                                          – Shotgun cartridges and parts thereof; air gun pellets :
                              9306 21 00 – – Cartridges
                              9306 29 00 – – Other :
                              9306 29 40 – – – Cases
                              9306 29 70 – – – Other

                              9306 30 – Other cartridges and parts thereof :
                              9306 30 10 – – For revolvers and pistols falling within heading 9302** and for sub–machine–
                                         guns falling within heading 9301
                                         – – Other
                              9306 30 30 – – – For military weapons
                                         – – – Other :
                              9306 30 91 – – – – Centrefire cartridges
                              9306 30 93 – – – – Rimfire cartridges
                              9306 30 98 – – – – Other
                              9306 90 – Other :
                              9306 90 10 – – For military purposes
                              9306 90 90 – – Other
                              note **
                              Heading 9302 Revolvers and pistols, other than those of heading 9303 (9303: Other
                                               firearms and similar devices which operate by the firing of an explosive



                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks   160




                                               charge) or 9304 (Other arms (for example, spring, air or gas guns and
                                               pistols, truncheons), excluding those of heading 9307( 9307: Swords,
                                               cutlasses, bayonets, lances and similar arms and parts thereof and
                                               scabbards and shealths therefor)).
                              9302 00 10 – 9 mm calibre and higher
                              9302 00 90 – Other




                                                                                                                          .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                       161




                               Table A5. 1          Production, import and export of cartridges and parts thereof for shot-
                                                    guns, revolvers, pistols, rifles, carbines and military firearms, slugs,
                                                    pellets and darts (excl. for captive-bolt humane killers) 2000-2002*
All figures in                              2000                                  2001                                  2002
Million €/year                Prod.        Import       Export       Prod.       Import       Export       Prod.       Import       Export
Austria                                -          5.9            3           -         8.7          5.3            -        10.5             4.5
Belgium                                -          9.4         11             -        12.0        14.9             -         4.9             9.2
Denmark                              0.0          7.8            0           -         9.6          0.8            -         9.4             0.0
Finland                              2.1          3.1            5        2.1          4.4        12.9          2.3          3.7             4.1
France                                 -         15.6         20             -        16.1        15.8             -        16.3            18.9
Germany                                -         17.6         13             -        13.0        13.9             -        15.0            29.7
Greece                               7.6          5.1            3       15.9          3.4          4.4            -            -              -
Ireland                              0.0          0.4            0        0.0          1.3          0.0         0.0          1.7             0.0
Italy                              102.2         15.7         36         88.0         13.2        32.6         93.3         16.9            36.1
Luxembourg                           0.0          1.1            0        0.0          1.6          0.0         0.0          0.0             0.0
Netherlands                          0.0          1.5            3        0.0          1.1          2.7         0.0          1.2             3.4
Portugal                            10.7          5.2            3        6.2          3.5          2.9         5.4          4.5             1.4
Spain                               65.0          9.6            9       72.2          9.9        10.1         81.0          9.6            10.0
Sweden                              40.8          3.1            1       37.9          2.8          0.6        33.9          3.9             1.4
UK                                  98.9         18.3         13         96.9         14.7        10.5        124.3         18.8            12.2
Total EU 15 **                         -         56.4      110.1             -        58.7       113.3             -        79.0       115.7
Bulgaria                               -            -            -           0            -            -           0            -              -
Croatia                                -            -            -           0            -            -           0            -              -
Czech Republic                         -            -            -           -            -            -           -            -              -
Estonia                               0             -            -           0            -            -           0            -              -
Hungary                                -            -            -        6.8             -            -           7            -              -
Latvia                                 -            -            -           -            -            -           -            -              -
Lituania                               -            -            -           0            -            -           0            -              -
Poland                                 -            -            -           -            -            -           -            -              -
Romania                               0             -            -           -            -            -           -            -              -
Slovakia                               -            -            -           -            -            -           -            -              -
Slovenia                               -            -            -           0            -            -           0            -              -
                               *       PRODCOM commodity code 29.60.14.30 "Cartridges and parts thereof for shotguns, revolvers,
                                       pistols, rifles, carbines and military firearms, slugs, pellets and darts (excl. for captive-bolt hu-
                                       mane killers)'
                               **      Total import/export from EU 15 to other countries
                               -       No data
                               Source: Europroms database. Commission of the European Communities (Statistical Office/Eurostat).




                                                                                                                                        .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                      162




All figures in                                2000                                  2001                                 2002
1000 p/st per year                    Prod.     Import   Export            Prod.      Import   Export            Prod.     Import    Export
Austria                                   -          -         -                -          -         -               -          -             -
Belgium                                   -          -         -                -          -         -               -          -             -
Denmark                                  0           -         -                -          -         -               -          -             -
Finland                             4863000          -         -       5847000             -         -       5498000            -             -
France                                    -          -         -                -          -         -               -          -             -
Germany                       370369000              -         -     386074000             -         -               -          -             -
Greece                        101536430              -         -     238435435             -         -               -          -             -
Ireland                                   0          -         -               0           -         -               0          -             -
Italy                        1506482000              -         -   1275652000              -         -   1261583000             -             -
Luxembourg                                0          -         -               0           -         -               -          -             -
Netherlands                               0          -         -               0           -         -               0          -             -
Portugal                           84135559          -         -      54679704             -         -      42440479            -             -
Spain                                     -          -         -   2070508000              -         -   1968172000             -             -
Sweden                             58220948          -         -      40509644             -         -      36135272            -             -
UK                           1111163867              -         -     959432077             -         -   1282108815             -             -


Bulgaria                                  -          -         -               0           -         -               0          -             -
Croatia                                   -          -         -               0           -         -               0          -             -
Czech Republic                            -          -         -                -          -         -               -          -             -
Estonia                                   0          -         -               0           -         -               0          -             -
Hungary                                   -          -         -     111632682             -         -      91698147            -             -
Latvia                                    -          -         -                -          -         -               -          -             -
Lituania                                  -          -         -               0           -         -               -          -             -
Poland                                    -          -         -                -          -         -               -          -             -
Romania                                   0          -         -                -          -         -               -          -             -
Slovakia                                  -          -         -                -          -         -               -          -             -
Slovenia                                  -          -         -               0           -         -               -          -             -



                               *      PRODCOM commodity code 29.60.14.30 "Cartridges and parts thereof for shotguns, revolvers,
                                      pistols, rifles, carbines and military firearms, slugs, pellets and darts (excl. for captive-bolt hu-
                                      mane killers)'
                               **     Total import/export from EU 15 to other countries
                               -      No data
                               Source: Europroms database. Commission of the European Communities (Statistical Office/Eurostat).




                                                                                                                                       .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              163



                               Table A5. 2         Import and export of cartridges for smooth-barrelled shotguns
                                                   (93.06.21.00) to/from EU 15, 1993-2003, in tonnes


EXPORT,Intra EU15         1993        1994       1995     1996     1997     1998     1999      2000      2001      2002       2003
tonnes
Austria                                             1        1        1        6         1         3         4           0          1
Belg,-Luxbg              3,520       1,342       1,731    1,578    2,953    2,255
Belgium                                                                              2,016     2,600     3,461    1,945       1,074
Denmark                      31          1         41                                                                               -
Finland                                              -       0        0        0        17                   0           3
France                     207         324        296      146      487      149       174      152         93      119        757
Germany                    717         734        646      816      992      951       572      296       254       830        586
Greece                                                       0                                    25
Ireland                       6          2          5         -                 -                                                   -
Italy                    3,245       3,740       4,494    4,689    3,658    4,108    4,460     4,720     4,400    7,116       8,054
Luxembourg                                                                               -
Netherlands                  28          2          9                 0         -        -         -                                7
Portugal                     37         11         55       83       47       50        54        35        58          30         16
Spain                      161         572        202      263      369      295       417      805       982       986        872
Sweden                                            102       51      287      206       229      228       247       580        490
Utd,Kingdom              1,102         973       1,704    2,465    1,850    1,576    1,407     1,662     1,409    1,160       1,395


EXPORT,Extra EU15         1993        1994       1995     1996     1997     1998     1999      2000      2001      2002       2003
tonnes
Austria                                            21       16       34       17        15        31        46          42         25
Belg,-Luxbg                  69        121        135       25        8       74
Belgium                                                                                 54        45        83           4         23
Denmark                    155         151         73       71       55       74        65        73        32          50         10
Finland                                             2        2        4        7         6         5         2           3          3
France                     480         543       1,039     497      841      819       964      985      2,002    1,008       1,156
Germany                    563         496        337      316      323      324       272      348       352       629        338
Greece                        1         21         30       26       96      119        88        61        40          70     122
Ireland                                                                -
Italy                    3,257       3,722       4,529    6,743    8,225    9,623   10,113   11,493      9,170   10,240       9,005
Luxembourg                                                                                         3
Netherlands                              0          0        4        0        1         2        42         3           0
Portugal                     20         51         92       60       96      100       102      132       120       123        127
Spain                      316         503        860     2,387    3,811    2,375    4,163     5,290     4,535    7,376       7,018
Sweden                                            311      149      219      168       196      222       270       297        298
Utd,Kingdom              2,917       2,531       2,634    2,679    2,100    1,308    1,328     1,225     1,426    1,233       1,064
Total EU15               7,778       8,139      10,062   12,976   15,812   15,009   17,369   19,954    18,080    21,074      19,189


                                  **contimued




                                                                                                                               .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  164




IMPORT,Intra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                         422       499        513       527        467       419       362        292       341
Belg,-Luxbg              2,605      2,247     2,535     2,098      3,491     3,235
Belgium                                                                                 3,611     2,649     4,314        995       456
Denmark                    757         64       287       754      1,282     1,544      1,061     1,266     1,407      1,083     1,556
Finland                                         386       557        384       422        625       510       410        420       444
France                   1,782      2,418     2,450     2,220      2,678     2,591      2,145     1,912     2,289      1,892     1,741
Germany                  1,461      1,217     1,746     1,664      1,674     1,307      1,142     1,433       817      1,005     1,006
Greece                     259       234        344       428        555       413        552       598       349        389       294
Ireland                    409        358       449       377        323       300        221       131       442        493       363
Italy                        52        63        74         85       405       191         24        78         30       651       617
Luxembourg                                                                                123        21         17        10           16
Netherlands                214        211       268       423        152        95         53        65         30         6           54
Portugal                   164        281       147       122        108       254        232       462     3,724        567       702
Spain                      449       560        540       566        571       518        668       578       697      1,011     1,205
Sweden                                          243       203        386       246        248       203       121        146       142
Utd,Kingdom              1,975      1,439     1,472     1,131      1,644     1,170      1,121     2,373     1,337      1,505     1,501


IMPORT,Extra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                          50         74       135       142         46       105       104         77           19
Belg,-Luxbg                  43      103         21         18        56       111
Belgium                                                                                    99       151         37        98           94
Denmark                      33        57         2          8        18          2         5          3        46        19           72
Finland                                         204       325        300       291        190       279       272        224       195
France                     186        114       140         38        66        12         74        69         68        58       111
Germany                    531       475        407       605        813       653        746       668       621        675       466
Greece                     109         71        47         70        54        51         40        24         27        51           65
Ireland                       7         3         2          1         4          6        21        19          2         6           10
Italy                        38       110        96         58        15        75        103     1,036     1,412        838       651
Luxembourg                                                                                                                  -
Netherlands                   1        16         7          3          -       12         16        37          0         0           37
Portugal                      7        13        21          6        11          4        40          6        26         8           27
Spain                        67         8         2          9         8        12          7          1                  57           41
Sweden                                            2          3         2          1         3          2        46         6           32
Utd,Kingdom              1,258       857        624       352        366       202        168       198       254        277       250
TotalEU15                2,280      1,826     1,624     1,570      1,847     1,573      1,556     2,598     2,915      2,393     2,069
                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              165



                               Table A5. 3      Import and export of cartridges for smooth-barrelled shotguns
                                                (93.06.21.00) to/from EU 15, 1993-2003, in 1000 €
EXPORT,Intra EU15         1993      1994      1995      1996      1997     1998      1999      2000      2001      2002       2003
1000 €
Austria                                           6       17        11        28         5        12        17           2          5
Belg,-Luxbg              8,543     3,669      4,273    5,476     7,982     6,438
Belgium                                                                              5,631     7,363     9,816    5,483       3,077
Denmark                      87         5      138                                                                                  -
Finland                                           0        1         9         2       215                   3          13
France                   1,006     1,039       828     1,012     1,556       514       779      672       626       741       1,975
Germany                  3,160     2,893      2,571    3,032     3,403     3,730     1,880      986       995     3,231       2,046
Greece                                                     3                                      54
Ireland                      22       10        15        15                   1                                                    1
Italy                    7,149     9,001      9,579   10,840     9,123     9,653    10,609   11,810    11,141    18,059      19,529
Luxembourg                                                                               0
Netherlands                  68       12        41                   4         0         0         0                               36
Portugal                     96       24       138       184       113       147       155      129       132           77         81
Spain                      334     1,259       564       710       840       837       930     1,790     2,087    2,071       1,987
Sweden                                         252       137       711       520       531      547       633     1,404       1,179
Utd,Kingdom              4,602     3,604      4,154    8,886     7,147     5,541     4,774     5,310     4,885    3,880       4,580


EXPORT,Extra EU15         1993      1994      1995      1996      1997     1998      1999      2000      2001      2002       2003
tonnes
Austria                                        116       139       251        97        85      140       238       226        169
Belg,-Luxbg                262       254       317       313        65       218
Belgium                                                                                253      160       206           19     115
Denmark                    578       511       298       282       219       259       269      281       150       205            31
Finland                                         16         7        24        28        26        28        23          26         22
France                   1,855     2,033      2,139    1,667     2,586     2,576     2,525     2,609     4,814    2,688       3,226
Germany                  3,557     2,643      1,878    1,491     1,709     1,713     1,754     2,123     1,703    2,760       1,493
Greece                        3       72        37       229       235       278       361      188       100       181        269
Ireland                                                              1
Italy                    7,320     8,499      9,279   15,386    18,083    20,869    21,550   26,146    22,080    24,144      21,519
Luxembourg                                                                                        31
Netherlands                             1         1       65         5         6         5      106         12          26
Portugal                   103        31       302       196       288       337       263      385       429       552        664
Spain                      719     1,181      2,003    5,935     8,270     5,251     9,482   12,814    10,933    16,793      15,313
Sweden                                         756       364       553       461       544      722       747       860        951
Utd,Kingdom              7,205     6,677      8,478    6,976     6,869     4,527     4,589     4,613     6,232    5,413       3,644
TotalEU15               21,602    21,901     25,619   33,051    39,157    36,620    41,706   50,346    47,667    53,894      47,417
                               Continued




                                                                                                                               .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  166



IMPORT,Intra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                       1,994     1,764      1,894     2,084      2,941     1,381     1,294      1,051     1,238
Belg,-Luxbg              6,706      5,327     5,289     5,454      9,201     8,276
Belgium                                                                                 9,140     6,978     9,821      2,638     1,898
Denmark                  2,392      2,028     4,397     3,839      5,127     6,639      4,167     6,022     6,683      6,272     6,576
Finland                                       1,010     1,817      1,949     1,072      1,472     1,384     1,068      1,301     1,414
France                   5,222      8,453     6,312     6,190      7,386     7,139      5,641     5,990     6,263      5,199     4,976
Germany                  4,014      3,231     4,414     4,048      4,327     3,495      2,525     3,358     2,193      2,529     2,457
Greece                     721       595        993     1,342      1,597     1,306      1,682     1,616     1,010      1,044       943
Ireland                  1,055       837      1,011     1,003        900       870        558       399     1,264      1,746     1,271
Italy                      244       396        586       658      6,653     2,832        155     1,001       181      1,443     1,396
Luxembourg                                                                                453       186       255        152       231
Netherlands                640       676        664       909        597       500        392       240       214         59       241
Portugal                   487       452        395       370        340       815        763     1,379     1,197      1,333     1,667
Spain                    2,099      2,224     1,927     2,071      2,173     1,544      2,190     2,004     2,363      2,049     3,508
Sweden                                          758       647      1,204       827        800       628       364        583       344
Utd,Kingdom              4,907      3,401     3,438     3,279      4,838     3,443      3,067     3,535     2,883      4,071     4,519


IMPORT,Extra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                         161       237        316       351        147       294       297        290           64
Belg,-Luxbg                157       252         59         83       187       644
Belgium                                                                                   603     1,258       179        419       421
Denmark                    223       571         16         61       191        14         55        42       101        213       458
Finland                                         524       716        755       677        437       684       669        542       499
France                     970       655        540       262        437       139        348       291       563        334       353
Germany                  1,648      1,115     1,161     1,512      1,810     1,434      1,584     1,583     1,783      1,925     1,128
Greece                     429       273        206       319        314       261        168       249       182        290       350
Ireland                      11        28        18         20       105       111        103        37         69       160       167
Italy                      308       547        749       590        176       652        829     2,841     3,084      1,986     1,700
Luxembourg                                                                                                                 1
Netherlands                   5        82        40         17         1        84         59       135          3         8       272
Portugal                     45        86       106         48       162        49        408        87       252         44       271
Spain                      209         74        85       103        121       196        111        12                  139           86
Sweden                                           18         27        12        11         23        34       123         27       113
Utd,Kingdom              2,837      2,015     1,567       832        955       420        570       580       746      1,218       787
TotalEU15                6,844      5,697     5,250     4,828      5,540     5,043      5,446     8,129     8,051      7,599     6,669


                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             167



                               Table A5. 4        Import and export of centre fire cartridges (93.06.30.91) to/from EU 15,
                                                  1993-2003, in tonnes


EXPORT,Intra EU15         1993        1994      1995    1996      1997     1998      1999      2000      2001      2002      2003
tonnes
Austria                                           84      26         8        28         9         7         9          17         7
Belg,-Luxbg                  85         75        75     106       122       116
Belgium                                                                                111      143       165       102       122
Denmark                       2          2          -       -        0          -        0         -         -           4         2
Finland                                           90      95       112       121       139      113         96          64        88
France                        2          7         5      21         8         8         1         1         0           0         2
Germany                      92        110       155     182       200       179       136        80      151       253       197
Greece
Ireland
Italy                    3,905       4,031      4,516   3,830    4,860     4,717     3,991     3,341     2,605      204
Luxembourg                                                                                                                         -
Netherlands                   1          6         2       1         1         0         1         0
Portugal                                15                73          -        0                             -           1         0
Spain                      211                   343     696       794     1,211     1,264     1,301     1,718    2,438      2,741
Sweden
Utd,Kingdom                   0          0        13      11         8         8         1         4         2           0         0


EXPORT,Extra EU15         1993        1994      1995    1996      1997     1998      1999      2000      2001      2002      2003
tonnes
Austria                                           11      16        54        21        19        34        60          88    122
Belg,-Luxbg                  11          3         2       3         0         1
Belgium                                                                                  5         1         2           2         2
Denmark                      24         24        34      19        22        20        14        12         9           7         7
Finland                                          241     217       190        79        51        96        71      136       124
France                       60         53        35      48         7         8        10        12         6           7        12
Germany                    224         287       340     332       397       273     1,266      360       133       140           95
Greece                                                             149
Ireland
Italy                      392         370      1,467   1,498      986       396       438      318       465       144           27
Luxembourg
Netherlands                                                1         2         2                                         2
Portugal                                                                                 1         0         -                     -
Spain                      718       1,169      2,151   1,129    2,312     2,889     1,804     1,207     2,116    1,608      1,744
Sweden
Utd,Kingdom                  41         11         2       5         4        17       212         3        22           1    154
Total EU15               1,469       1,916      4,282   3,267    4,124     3,705     3,820     2,043     2,884    2,135      2,286


                                  **contimued




                                                                                                                              .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  168




IMPORT,Intra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                          21         25        85        16         14        18         22        80           29
Belg,-Luxbg                157       112         52         41        32        13
Belgium                                                                                    94       160         30        20           15
Denmark                       8        21        31         39        44        54         60        59         96       202       105
Finland                                          13         10        10          2        15          4        63        41           31
France                     460       152        269       367        142       161        161       407       176        168       901
Germany                    116       129        179       134        231       162        108       346       642        204       119
Greece                                            4          1         1          3         1          0         0         6            -
Ireland                       0         0         0          -         2          0         3          0         1                      1
Italy                        37        14        73         51       109        58         33        51         44        67           52
Luxembourg                                                                                 15          6         5         4            7
Netherlands                  11        30        30         30        15          6         9        11         53        39           24
Portugal                     36        69         3         18        10          8        22        14         21         6            5
Spain                        87        45        81         33        59       147         59       102         63        51       402
Sweden
Utd,Kingdom                  10        41        39         74        52        88         46        15         26        15           14


IMPORT,Extra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                          67         17        89        31         34        48         43        17           13
Belg,-Luxbg                  68        18        19         13        26        83
Belgium                                                                                   184       175         94       142       161
Denmark                      74        53        14         18        11          7        13        31          9        19            2
Finland                                          11         19        22        11         12          7         9         6           14
France                     116       122        101       133         67        80         75        69         82        80           87
Germany                    338       439        240       279      1,072       408        304       473       304        387       307
Greece                                                       1         8          4                              6         1
Ireland                       0         0         0                    1          3
Italy                        44        49        58         32        31        16          9        32         48        42           79
Luxembourg                                                                                             0         -         0            4
Netherlands                   5        12        10          2         1        13          2        26         39        24           23
Portugal                     21        17        22          5         6          2         4        13         14         9            8
Spain                        51        24         8         47        35        23        144        81         66        74       164
Sweden
Utd,Kingdom                  68        17        45         80        42       153        106        60         30        64           23
Total EU15                 784       751        593       645      1,412       833        886     1,014       744        864       883


                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks              169



                               Table A5. 5      Import and export of centre fire cartridges (93.06.30.91) to/from EU 15,
                                                1993-2003, in 1000 €
EXPORT,Intra EU15         1993      1994      1995      1996      1997     1998      1999      2000      2001      2002       2003
1000 €
Austria                                       2,868      537       225       233       268      275       346       435        198
Belg,-Luxbg                989       928       982     1,510     1,488     1,774
Belgium                                                                              1,688     2,316     3,072    2,220       2,550
Denmark                      14       13          1        0         3         0         3         1         0          16          7
Finland                                       1,481    1,491     2,087     1,929     2,720     1,910     3,896    1,446       1,915
France                       15       74        61        82        66        16         7        19         7           5         30
Germany                  2,312     2,863      3,765    4,228     4,524     3,929     2,914     1,524     2,061    4,918       4,429
Greece
Ireland
Italy                    9,166     9,467      9,394    9,845    12,383    11,689     9,959     8,319     6,493      471
Luxembourg                                                                                                                         16
Netherlands                   6       63        24        10        25         3        11        11
Portugal                              28                 646         1         5                             0          14          1
Spain                      459                 781     1,496     1,763     2,546     2,695     2,901     3,745    4,780       5,648
Sweden
Utd,Kingdom                  13       15       160       115        87        75        14        79        53           9          5


EXPORT,Extra EU15         1993      1994      1995      1996      1997     1998      1999      2000      2001      2002       2003
1000 €
Austria                                        280       350       736       377       493      953       956     1,772       2,282
Belg,-Luxbg                152        35        24        56         2        18
Belgium                                                                                155        18        29          44         62
Denmark                    474       434       701       415       610       451       388      303       240       221        214
Finland                                       2,198    2,168     3,365     1,425       925     1,764     1,481    2,709       2,765
France                     493       306       342       302        69       214        99      166       155       171        229
Germany                  2,339     3,227      2,321    2,303     3,021     2,321     5,765     2,506     2,035    2,747       2,059
Greece                                                             233
Ireland
Italy                      959       778      3,286    3,580     2,512     1,106     1,055      994      1,232      378        103
Luxembourg
Netherlands                                               10       105        18                                    368
Portugal                                                                                 2         0         0                      0
Spain                    1,660     2,331      4,343    2,582     5,869     6,598     4,063     2,896     5,363    3,234       3,821
Sweden
Utd,Kingdom                492       129        58       108       119       481       963      251       164           35     550
Total EU15               6,569     7,242     13,552   11,874    16,641    13,010    13,908     9,851   11,655    11,680      12,086
                               Continued




                                                                                                                               .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  170



IMPORT,Intra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                         420       426        562       325        336       421       481        630     1,017
Belg,-Luxbg                780       738        348       443        346       270
Belgium                                                                                   423     1,474       892        543       516
Denmark                    134       208        510       761        936     1,017        907       814     1,175      1,785     1,614
Finland                                         189       219        148        49        173        82     1,840        767       340
France                   2,756      1,727     2,829     3,556      2,528     2,898      2,776     4,070     3,445      3,962     4,558
Germany                    844      1,091     2,498     2,541      3,700     3,198      2,120     3,954     4,539      3,112     2,743
Greece                                           55         10         4        30         13          1         4       230            1
Ireland                       7         5        23          5        29          3        65          3        10                     14
Italy                      322       236      1,030       611        884       747        480       715       673      1,239     1,488
Luxembourg                                                                                148        95       109        135       174
Netherlands                122       266        263       305        183        63        148       145       334        424       329
Portugal                   163       222         75       155        143        32        186       121       129        151       133
Spain                      646       582        717       603        825     1,213        862     1,408     1,228      1,175     1,868
Sweden
Utd,Kingdom                104       431        519       988        722     1,541      1,394       395       588        792       529


IMPORT,Extra EU15         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                         567       187        858       455        359       396       332        338       282
Belg,-Luxbg                732       294        176       188        323     1,214
Belgium                                                                                 1,987     2,726     1,236      2,150     2,188
Denmark                    879       713         98       173        121       107        147       184       169        162           64
Finland                                          71       127        217       144         62        61       140        123       166
France                   1,282      1,611     1,507     1,080      1,079     1,105      1,204     1,074     1,437      1,452     1,385
Germany                  3,693      4,691     2,180     2,403      4,001     2,972      2,716     3,496     3,525      4,345     3,928
Greece                                                       5        71        22                            129         25
Ireland                       2         5         3                   13       330
Italy                      421       659        284       360        248       187        169       447       588        408       916
Luxembourg                                                                                             7         1        15           49
Netherlands                  46      114         76         18        16        87         13       102       141         91           93
Portugal                   231       212        271         74        85        28         78       234       329        147       174
Spain                      673       429        131       506        379       517        929       881       836      1,284     1,353
Sweden
Utd,Kingdom                582       357        466       502        416       872        979       828       443        929       413
Total EU15               8,542      9,083     5,830     5,623      7,826     8,038      8,643    10,436     9,304     11,470    11,012



                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks            171



                               Table A5. 6       Import and export of rimfire cartridges (93.06.30.93 to/from EU 15,
                                                 1993-2003, in tonnes
EXPORT,Intra EU15         1993        1994      1995    1996      1997     1998      1999      2000      2001      2002      2003
tonnes
Austria                                            5       6         0         0         0        28         1           2        2
Belg,-Luxbg                134         121        97      89       219       210
Belgium                                                                                173      185       195       131       112
Denmark                                            -                                                                     -        -
Finland                                           61      69        70        83       107        92        74          60       65
France                       31         13        15      32        10         4         1        10         7           0        0
Germany                    109         117       216     241       290       222       255      228       251       372       214
Greece
Ireland                       0                    0
Italy                      124          96                           7                             6         3          18       18
Luxembourg
Netherlands                   0          1        22                 1
Portugal
Spain                                                                           -        -         -         -           -
Sweden
Utd,Kingdom                270         252       343     324       308       291       257      270       192       229       162


EXPORT,Extra EU15         1993        1994      1995    1996      1997     1998      1999      2000      2001      2002      2003
tonnes
Austria                                            2      13        20        10         9        36        19           6        3
Belg,-Luxbg                   9         15        25      16                   0
Belgium                                                                                  0         1        11           5        5
Denmark                       9         15        13      13        16        15        19        23        14          11       10
Finland                                           21       3         2        46        48        73        54          61       62
France                       35         42        16      11         8        17         4        31         6           5        4
Germany                    179         260       232     185       314       279       179      294       276       316       378
Greece
Ireland
Italy                      977       1,629       189     327       134        89         0        15        12          11       19
Luxembourg
Netherlands                                                                                                  1
Portugal                                                                        -        -         -
Spain                         0                                                                    0                     -
Sweden
Utd,Kingdom                510         273       261     242       225       202       170      149       152       189       207
Total EU15                                         2      13        20        10         9        36        19           6        3


                                  **contimued




                                                                                                                             .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  172




IMPORT,IntraEU15          1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                          58         50        63        40         46        29         27        29           19
Belg,-Luxbg                  51        27        37         73        29        45
Belgium                                                                                    23        20         21        19           22
Denmark                      33        45        78       115        277       285         68        57       130         79           60
Finland                                         131         35        71        63         74        62         73        43           59
France                     137         87       108       124        110       125        153       143       146        211       155
Germany                    236       236        231       238        212       210        166       173       201        170       112
Greece                       30        58        34         24        18        22         13        28          7        11           17
Ireland                      10         9         7          6         5          5         0
Italy                         6        12        22         16        20        31         59       157         81        31           15
Luxembourg                                                                                  9        16         30         4           15
Netherlands                  17        19        72         26        14        10          8          5         7         9            8
Portugal                      2         3         1                    1          0         4          5        20         4            6
Spain                        25        41        71         89        47        22         22        42         99        63           85
Sweden
Utd,Kingdom                   9        50        21         38        82       122         25        47         38        23           20


IMPORT,ExtraEU15          1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                          19          5        15        12          8          5         2         2            8
Belg,-Luxbg                  36        32        66         68        31       137
Belgium                                                                                   138       187         99       184       124
Denmark                       9         5        11          1         5          5        11          7         9         9            7
Finland                                         103         63        22          7        14        30         22        39           17
France                     329       252        279       211         83        74        135        50         82       134       108
Germany                    245       219        364       412        305       262        333       355       232        254       188
Greece
Ireland                       1         0         0          2         2          1         1          3         1
Italy                        27        22        39         29         1          3         5        18         20        20           15
Luxembourg
Netherlands                   7        34        16          8        24          1         1          9         0         6           11
Portugal                      5                                        3          1         1
Spain                        11        11        32         33        24        21          2          0         1
Sweden
Utd,Kingdom                  47        96        37       123         42       105         64        69         71       153       145
Total EU15                 716       670        965       955        556       628        713       733       540        801       623


Total extra EU15,         1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Export                   1,719      2,234       758       810        718       657        429       622       544        603       688
Import                     716       670        965       955        556       628        713       733       540        801       623


                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks             173



                               Table A5. 7      Import and export of rimfire cartridges (93.06.30.93 to/from EU 15,
                                                1993-2003, in 1000 €
EXPORT,Intra EU15         1993      1994      1995      1996      1997     1998      1999      2000      2001      2002      2003
1000 €
Austria                                         54        96        33        37        43      264         36          51        80
Belg,-Luxbg                759       794       692       554     1,331     1,486
Belgium                                                                              1,230     1,328     1,567    1,171       941
Denmark                                           1                                                                      0         0
Finland                                        582       731       879       848     1,323     1,260     2,716    1,035      1,083
France                     194       112       137       140        90        37         3        95        64           2         1
Germany                    907       902     1,792     1,816     2,105     1,635     1,733     1,548     1,800    2,953      1,874
Greece
Ireland                                           1
Italy                      871       698                            21                            51        47      169       209
Luxembourg
Netherlands                   5         7       93                   3
Portugal
Spain                                   1                                      2         0         0         0           1
Sweden
Utd,Kingdom              2,477     2,311     3,212     3,149     2,948     2,802     2,427     2,195     2,075    2,676      1,944


EXPORT,ExtraEU15          1993      1994      1995      1996      1997     1998      1999      2000      2001      2002      2003
1000 €
Austria                                         47        84       191       138       168      223       237       100           49
Belg,-Luxbg                  84      328       637       446                   1
Belgium                                                                                  2         9        63          35        46
Denmark                    164       241       230       190       267       223       276      355       318       227       175
Finland                                        232        60        30       633       653     1,447     1,083    1,086       985
France                     390       510       161        80        43       132        43      136         61          41        47
Germany                  1,485     2,150     1,902     1,653     2,294     2,193     1,842     2,717     2,648    2,969      3,839
Greece
Ireland
Italy                    2,781     3,968       449       834       586       261         4      204       144       153       327
Luxembourg
Netherlands                                                                                                  9
Portugal                                                                       0         0         1
Spain                         4                                                                    4                     6
Sweden
Utd,Kingdom              4,789     3,629     3,442     3,534     3,250     2,757     2,349     2,381     2,764    3,177      3,367
Total EU15               9,697    10,825     7,100     6,881     6,660     6,338     5,338     7,477     7,326    7,794      8,835
                               Continued




                                                                                                                              .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  174



IMPORT,IntraEU15          1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                         760       637        838       682      1,002       394       443        499       302
Belg,-Luxbg                409       207        514       521        267       315
Belgium                                                                                   154       160       158        174       196
Denmark                    283       311        685       355        549       726        670       635     1,217        693       595
Finland                                         782       299        405       432        416       350       465        361       408
France                   1,435       969      1,014       990        937     1,061      1,015     1,076     1,143      1,607     1,450
Germany                  1,831      1,810     2,085     2,167      1,847     1,956      1,537     1,640     2,033      1,693     1,451
Greece                     194       286        263       184        137       173         99       207         51        93       148
Ireland                      72        96        97         98        77        94          3
Italy                        65      121        149       143        117       210        239       354     1,125        355       188
Luxembourg                                                                                 41        64       410         53           98
Netherlands                125       156        437       162        108        63         63        37         66        94       146
Portugal                     15        28         5                    2          1        15        20         41        29           27
Spain                      118       140        198       219        225       146         52       281       379        270       248
Sweden
Utd,Kingdom                  97      309        242       484        880     1,150        485       417       438        633       324


IMPORT,ExtraEU15          1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Austria                                         114         25       117        72         50        86         26        24           59
Belg,-Luxbg                199       149        297       281        148       791
Belgium                                                                                   948     1,211       727      1,290       789
Denmark                      47        37        67         17        26        58        105        97         90       104           82
Finland                                         437       252         94        37         80       166       112        226       116
France                   1,626      1,288     1,261       820        503       426        717       532       418        843       601
Germany                  1,271      1,400     1,686     1,855      1,342     1,336      1,625     1,939     1,480      1,760     1,139
Greece
Ireland                       7         9         7         23        17          8         8        48         19
Italy                      112       100        182         91        18        22         25       138       119        103       101
Luxembourg
Netherlands                  55      296         92         44       122          5        11        55          5        43           49
Portugal                     46                                       18          6        10
Spain                        70        57       138       153        101        70         16          2         9
Sweden
Utd,Kingdom                330       748        228       687        319       621        541       559       802      1,573     1,369
TotalEU15                3,762      4,083     4,509     4,248      2,823     3,451      4,136     4,832     3,806      5,965     4,306




Total ekstra EU 15,       1993      1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000 €
Export                   9,697    10,825      7,100     6,881      6,660     6,338      5,338     7,477     7,326      7,794     8,835
Import                   3,762      4,083     4,509     4,248      2,823     3,451      4,136     4,832     3,806      5,965     4,306



                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           175



                               Table A5. 8      Import and export of cartridges for smooth-barrelled shotguns
                                                (93.06.21.00) from new Member States and Candidate Countries.
                               EXPORT, EU 15, tonnes                        1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                        246          310         218          269          249
                               Czech Republic                                442          618         642          484          693
                               Estonia
                               Hungary                                                                                          792
                               Latvia
                               Lituania
                               Malta                                                         -
                               Poland                                          13          18           13          15           15
                               Rumania
                               Slovakia                                         0
                               Slovenia
                               Turkey                                           0           0
                               Total                                         701          946         874          768      1.749


                                EXPORT, NON-EU 15, tonnes                   1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                        381          331         498          455          289
                               Czech Republic                               1,658       1,393       1,355        1,339      1,211
                               Estonia                                          0
                               Hungary                                                                                          186
                               Latvia                                           3          10            3              2         1
                               Lituania                                         0                        1              3        2
                               Malta
                               Poland                                        377           92           69          65           44
                               Rumania
                               Slovakia                                         1                        1              4         1
                               Slovenia
                               Turkey                                                       0            2
                               Total                                        2,420       1,826       1,928        1,868      1,735


                                EXPORT, total , tonnes                      1999         2000        2001         2002      2003
                               Bulgaria                                         0           0            0              0         0
                               Cyprus                                        627          642         717          724          538
                               Czech Republic                               2,100       2,011       1,997        1,823      1,904
                               Estonia                                          0            -           -              -         -
                               Hungary                                          -            -           -              -       979
                               Latvia                                           3          10            3              2         1
                               Lituania                                         0            -           1              3         2
                               Malta                                            -            -           -              -         -
                               Poland                                        390          110           82          80           59
                               Rumania                                          -            -           -              -         -
                               Slovakia                                         1            -           1              4         1
                               Slovenia                                         -            -           -              -         -
                               Turkey                                           0           0            2              -         -
                               Total                                        3,120       2,773       2,801        2,636      3,484
                               Continued…




                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           176



                                IMPORT, EU 15, tonnes                       1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                        105          192       1,596          186      1,169
                               Czech Republic                                172           67         141          181          162
                               Estonia                                          8          34           31          26           53
                               Hungary                                         99         129         127          163          194
                               Latvia                                          30          31           32          27           29
                               Lituania                                        19          25           30          23           24
                               Malta                                            -            -           -              -         -
                               Poland                                        100           92         113          168          167
                               Rumania
                               Slovakia                                         9          16                           9        47
                               Slovenia
                               Turkey                                       6,406       7,101       2,269        4,655      2,625
                               Total                                        6,948       7,688       4,340        5,437      4,470


                                IMPORT, NON-EU 15, tonnes                   1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                          11           4         131           61           19
                               Czech Republic                                  35          17           39          23            2
                               Estonia                                          9          10            3          10            5
                               Hungary                                         34           1            4              2         2
                               Latvia                                           2                        5          14           33
                               Lituania                                        11           0            0              1         4
                               Malta                                            -
                               Poland                                        107           92           87          95           61
                               Rumania
                               Slovakia                                        66          98           88         119          129
                               Slovenia
                               Turkey                                        459                                    19          117
                               Total                                         733          221         357          343          371


                                IMPORT, total , tonnes                      1999         2000        2001         2002      2003
                               Bulgaria                                         0           0            0              0         0
                               Cyprus                                        116          196       1,727          247      1,189
                               Czech Republic                                206           84         180          203          163
                               Estonia                                         17          44           34          36           58
                               Hungary                                       132          130         131          164          197
                               Latvia                                          32          31           38          41           61
                               Lituania                                        31          25           31          24           28
                               Malta                                            -            -           -              -         -
                               Poland                                        207          185         200          263          228
                               Rumania                                          -            -           -              -         -
                               Slovakia                                        75         113           88         128          176
                               Slovenia                                         -            -           -              -         -
                               Turkey                                       6,864       7,101       2,269        4,674      2,742
                               Total                                        7,681       7,909       4,697        5,780      4,842
                               Continued…




                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks           177



                                EXPORT, EU 15, 1000 €                       1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                        554          685         482          576          498
                               Czech Republic                                886        1,357       1,412        1,112      1,649
                               Estonia
                               Hungary                                                                                      1,488
                               Latvia
                               Lituania
                               Malta                                                        0
                               Poland                                          31          56           37          40           29
                               Rumania
                               Slovakia                                         0
                               Slovenia
                               Turkey                                           0           0
                               Total                                        1,471       2,098       1,931        1,728      3,665


                                EXPORT, NON-EU 15, 1000 €                   1999         2000        2001         2002      2003
                               Bulgaria
                               Cyprus                                       1,043         835       1,260          777          648
                               Czech Republic                               3,402       3,424       3,196        2,985      2,642
                               Estonia                                          0
                               Hungary                                                                                      1,006
                               Latvia                                          24         180           10          10            3
                               Lituania                                         0                        3          13           12
                               Malta
                               Poland                                        863          256         204          227          105
                               Rumania
                               Slovakia                                         2                        3          11            2
                               Slovenia
                               Turkey                                                       0            6
                               Total                                        5,333       4,695       4,682        4,023      4,419


                                EXPORT, total , 1000 €                      1999         2000        2001         2002      2003
                               Bulgaria                                         0           0            0              0         0
                               Cyprus                                       1,597       1,520       1,742        1,354      1,146
                               Czech Republic                               4,288       4,781       4,608        4,096      4,291
                               Estonia                                          0            -           -              -         -
                               Hungary                                          -            -           -              -   2,495
                               Latvia                                          24         180           10          10            3
                               Lituania                                         0            -           3          13           12
                               Malta                                            -           0            -              -         -
                               Poland                                        893          312         241          267          134
                               Rumania                                          -            -           -              -         -
                               Slovakia                                         2            -           3          11            2
                               Slovenia                                         -            -           -              -         -
                               Turkey                                           0           1            6              -         -
                               Total                                        6,804       6,793       6,614        5,751      8,084
                               Continued…




                                                                                                                            .
Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  178



                                IMPORT, EU 15, 1000 €                          1999         2000         2001         2002         2003
                               Bulgaria
                               Cyprus                                           285          567          719          507             619
                               Czech Republic                                   366          171          337          495             470
                               Estonia                                           31          199           98            70            141
                               Hungary                                          214          305          308          393             482
                               Latvia                                            98          138          122            75            108
                               Lituania                                         156          141          114           84              94
                               Malta                                            265          449          538          263             434
                               Poland                                           275          201          283          408             511
                               Rumania
                               Slovakia                                          33           37                         21            111
                               Slovenia
                               Turkey                                        13,259       15,379        4,907       10,130        5,969
                               Total                                         14,984       17,588        7,425       12,445        8,939


                                IMPORT, NON-EU 15, 1000 €                      1999         2000         2001         2002         2003
                               Bulgaria
                               Cyprus                                            41           33           98            43             62
                               Czech Republic                                    69           41           71           45              13
                               Estonia                                           40           69           12            39             25
                               Hungary                                           71             5            8            6             12
                               Latvia                                            11                        23            46            157
                               Lituania                                          45             0            5          10              13
                               Malta                                             46
                               Poland                                           379          387          483          692             530
                               Rumania
                               Slovakia                                         133          185          190          289             320
                               Slovenia
                               Turkey                                           991                                    112             591
                               Total                                          1,825          719          888        1,282        1,722


                                IMPORT, total , 1000 €                         1999         2000         2001         2002         2003
                               Bulgaria                                           0             0            0            0               0
                               Cyprus                                           327          600          817          550             680
                               Czech Republic                                   435          212          408          539             483
                               Estonia                                           71          268          110          109             166
                               Hungary                                          285          310          316          399             494
                               Latvia                                           109          138          144          121             265
                               Lituania                                         201          141          119           94             107
                               Malta                                            311          449          538          263             434
                               Poland                                           654          589          766        1,100        1,041
                               Rumania                                             -            -            -            -               -
                               Slovakia                                         166          222          190          310             431
                               Slovenia                                            -            -            -            -               -
                               Turkey                                        14,250       15,379        4,907       10,242        6,560
                               Total                                         16,809       18,307        8,313       13,727       10,660
                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                   .
 Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  179



                                Table A5. 9       Import and export of cartridges for smooth-barrelled shotguns
                                                  (93.06.21.00) from EU 15, average of 2000, 2001 and 2002.
                                                      Import from:                                          Export to:
                                      1.000 €/year     tonnes/year       1000 €/ton**      1.000 €/year      tonnes/year      1000 €/ton**
New Member States and Candi-
date countries (NMSCC):
Bulgaria                                                                                            262                  93              2.8
Cyprus                                         495             207                 2.4              679              234                 2.9
Czech Rep.                                   1,177             469                 2.5              298              131                 2.3
Estonia                                         11                7                1.6               68                  27              2.5
Hungary                                      3,074            1,571                  2              348              147                 2.4
Latvia                                                                                              125                  42              2.9
Lithuania                                                                                            90                  28              3.2
Malta                                                                                               465              219                 2.1
Poland                                          39               14                2.7              271              120                 2.3
Romania                                                                                             398              183                 2.2
Slovakia                                                                                             34                  11              3.2
Slovenia                                        44                7                6.3              312              128                 2.4
Turkey                                                                                            8,948            4,476                 2.0
Total NMSCC                                  4,840            2,275                2.1           12,298            5,838                 2.1
Other:
USA                                          2,484             252                 9.9           11,883            4,152                 2.9
Japan                                           22               13                1.7            3,575            1,282                 2.8
Norway                                          77                2               36.3            1,808              573                 3.2
Venezuela                                                                                         1,721              541                 3.2
Ghana                                                                                             1,692              643                 2.6
Australia                                         1               0               21.7            1,377              647                 2.1
Argentina                                       17                7                2.5            1,232              522                 2.4
Kuwait                                                                                            1,132              408                 2.8
Peru                                                                                              1,019              348                 2.9
Morocco                                                                                             976              427                 2.3
Chile                                           38               17                2.2              965              394                 2.5
Guinea                                                                                              841              304                 2.8
Switzerland                                    279               21               13.6              775              198                 3.9
South Africa                                    29               10                  3              714              315                 2.3
South Korea                                                                                         691              265                 2.6
Senegal                                                                                             541              269                 2.0
Cameroon                                                                                            482              195                 2.5
Canada                                          12                1                8.5              462              162                 2.9
Russia                                            6               1               10.9              431              147                 2.9
New Zealand                                                                                         310              117                 2.6
Ukraine                                         14                7                2.1              276              113                 2.4
China                                           78               28                2.8               63                  23              2.8
Other                                           82               17                4.8            5,373            1,823                 2.9
Total non-NMSCC                              3,139             375                 8.4           38,124           13,865                 2.8
                                Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                                *           Export and import as registered by EU Member States
                                **         Calculated from non-round basic data
                                Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                                cret)




                                                                                                                                    .
 Advantages and drawbacks of restricting the marketing and use of lead in ammunition, fishing sinkers and candle wicks                  180



                                Table A5. 10 Import and export of centre fire cartridges (93.06.30.91) from EU 15,
                                             average of 2000, 2001 and 2002.
                                                      Import from:                                          Export to:
                                      1.000 €/year     tonnes/year       1000 €/ton**      1.000 €/year      tonnes/year      1000 €/ton**
New Member States and Candi-
date countries (NMSCC):
Bulgaria                                        55               24                2.3              174                  26              6.6
Cyprus                                                                                               21                   8              2.7
Czech Rep.                                   1,810             188                 9.6              227                  31              7.3
Estonia and Malta
Hungary                                        215               24                  9              257                  22             11.7
Latvia                                                                                              234                  16             14.8
Lithuania                                                                                           136                   8             16.9
Poland                                            2               0                6.7              525                  55              9.5
Romania                                                                                              47                   9              5.3
Slovakia                                       124               21                5.9               91                   3             28.9
Slovenia                                        79                5                17               108                   4             28.2
Turkey                                            9               0               18.9               49                  16              3.1
Total NMSCC                                  2,293             262                 8.7            1,867              198                 9.4
Other:
USA                                          6,279             378                16.6            1,496              475                 3.1
Ghana                                                                                             1,277              487                 2.6
Japan                                           26                9                2.8            1,063              351                 3.0
Norway                                            8               0               24.5              874                  56             15.7
Switzerland                                    470               21               22.5              680                  34             20.1
Guinea                                                                                              347              147                 2.4
Russia                                          74               16                4.6              320                  19             16.6
Equat.Guinea                                                                                        292              131                 2.2
Greenland                                                                                           263                  10             27.3
Brunei                                                                                              236                   7             31.8
South Korea                                       7               0               20.3              210                  29              7.2
U.A.Emirates                                                                                        162                   6             28.3
New Zealand                                                                                         147                  59              2.5
Ukraine                                           1               0                4.8              134                  36              3.7
Andorra                                                                                             132                   4             29.8
Canada                                          19                7                2.9               88                  14              6.3
Tunisia                                                                                              78                   4             18.6
Brazil                                          76                7               10.8               75                   4             20.9
Lebanon                                                                                              73                  23              3.2
Burkina Faso                                                                                         67                  26              2.5
Kuwait                                                                                               63                   8              7.8
Croatia                                                                                              62                   3              20
Saudi Arabia                                                                                         57                   2              26
Other                                        1,151             173                 6.6              524              193                 2.7
Total non-NMSCC                              8,111             612                13.3            8,720            2,129                 4.1
                                Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                                *           Export and import as registered by EU Member States
                                **         Calculated from non-round basic data
                                Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                                cret)




                                                                                                                                    .
                                                                                                                                    181



                               Table A5. 11 Import and export of rimfire cartridges (93.06.30.93) from EU 15, av-
                                            erage of 2000, 2001 and 2002.
                                                     Import from:                                          Export to:
                                     1.000 €/year     tonnes/year       1000 €/ton **     1.000 €/year      tonnes/year      1000 €/ton**
New Member States and Candi-
date countries (NMSCC):
Bulgaria                                                                                            48                   3          13.9
Cyprus
Czech Rep.                                    144               24                6.0              207                  26                8
Estonia                                                                                             38                   4            9.7
Hungary                                        10                2                4.0               87                  7           12.6
Latvia                                                                                              45                   6            7.8
Lithuania                                                                                           40                  3           12.4
Malta
Poland                                                                                             212                  25            8.6
Romania                                                                                             16                   1          15.1
Slovakia                                                                                            68                   8            8.6
Slovenia                                                                                            43                   4          10.4
Turkey                                                                                              27                  27                1
Total NMSCC                                   154               27                5.8              830              114               7.3
Other:
USA                                         3,321             471                 7.1            2,034              142             14.3
Switzerland                                      2             0.1               14.8              887                  79          11.2
Norway                                                                                             525                  60            8.8
Japan                                          22                1               20.2              450                  23          19.5
China                                                                                              433                  16          26.6
South Korea                                                                                        324                  12          28.1
Greenland                                                                                          305                  16          18.7
Yemen                                                                                              288                  46            6.3
Australia                                     815             109                 7.5              206                  19          10.7
New Zealand                                                                                        159                  13          12.6
Malaysia                                                                                            84                   4            22
India                                                                                               78                   4          18.8
Egypt                                                                                               65                   3          21.5
Canada                                                                                              63                   5          11.9
Brazil                                        153               23                6.7               42                   2          19.3
Vietnam                                                                                             41                  4             9.7
South Africa                                  191               18               10.8               39                   2          20.5
Qatar                                                                                               38                   2          20.5
Belarus                                                                                             33                   1          22.7
Other                                         210               43                4.9              610                  48          12.7
Total non-NMSCC                             4,714             665                 7.1            6,703              502             13.4
                               Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                               *           Export and import as registered by EU Member States
                               **         Calculated from non-round basic data
                               Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                               cret)




                                                                                                                                          .
                                                                                                                                                                                                                      182
Table A5. 12 Intra and extra community trade of cartridges for smooth-barrelled shotguns (93.06.21.00), average of 2000, 2001 and 2002


to *                                                                                              Export from (1000 €/year) *
                                                                                                                                                                                                  EU 15    NMS/
1000 €/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                    CC**
Austria                                237                                  6      188                                529                                           35                    13      1,009
Belgium                                                                    89         15                            1,583                                           46                 461        2,193         20
Denmark                                  23                                           1                               174                                           89      718      2,190        3,195          1
Finland                                184                                         261                                693                                        117           38      124        1,417        393
France                               2,821                                         775                              2,746                                        609                      88      7,039         74
Germany                        8       952                                 60                                       2,475                                        253            8      196        3,952        698
Greece                                   22                                25         45                              994                                           66                    5       1,157         56
Ireland                                                                                1                              435                                           32               1,077        1,545
Italy                          1       631                       4         31      228           18                                                                 59                 103        1,074
Luxembourg                               46                                            7                                43                                                                            96
Netherlands                 0,3        420                                            11                              242                                        220                   249        1,143
Portugal                    0,3          99                                42         11                              254                                        230                                637         12
Spain                          1       724                              215           58                            1,951                             113                                 8       3,068         28
Sweden                      0.3          65                      2                    43                              218                                           25                 176          529         49
United Kingdom                       1,330                              213           94                            1,334                                        200           98                 3,269        508
Total EU 15                   11     7,554                       5      680      1,737           18                13,670                             113      1,983        861      4,691       31,323      1,840
New Member                    93                                12      140        310           89                 8,255        10                            3,164                   226       12,298        235
States and Candi-
date Countries
Other countries             109        129        212           14    3,230      1,885           68                15,869                    48       455     10,349        776      5,194       38,337      1,667


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
**          As registered by the new Member States and Candidate Countries. For some countries export data are missing although import from the countries is registered by the EU15 countries.

Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                                                                                                                                                                      183
Table A5. 13 Intra and extra community trade of cartridges for smooth-barrelled shotguns (93.06.21.00), average of 2000, 2001 and 2002
to *                                                                                              Export from (tonnes/year) *
                                                                                                                                                                                                  EU 15    NMS/
Tonnes/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                  60                            <0.5           61                              223                                           14                     3        360
Belgium                                                                    21          4                              641                            <0.5           19                 168          854          7
Denmark                                   5                                       <0.5                                  64                                          33      291        572          965          0
Finland                                  54                                           46                              303                                           56         17         28        503        187
France                               1,062                                         208                              1,056                                        301                      34      2,661         38
Germany                        2       298                                 16                                         980                                        116           3          62      1,478        293
Greece                                   3                                  3         11                              374                                           34                     2        426         29
Ireland                                                                           <0.5                                178                                           16                 425          619
Italy                      <0.5        210                      1           2         50         8                                                                  23                    25        319
Luxembourg                               11                                            2                                18                                                                            31
Netherlands                <0.5        122                                             3                                96                                       105                      57        382
Portugal                   <0.5          33                                 3          3                                96                                          97                              232          3
Spain                                  245                                  7         21                              728                                41                                2      1,045         12
Sweden                     <0.5          19                 <0.5                      13                                98                                          15                    32        178         23
United Kingdom                         546                                 68         38                              559                                           95         41                 1,348        226
Total EU 15                    2     2,669                      1       121        460            8                 5,412                                41      924        352      1,410       11,400        819
New Member                    25                                3          70      100           23                 3,966          1                           1,589                      61      5,838        235
States and Candi-
date Countries
Other countries               14         44         52      <0.5      1,261        343           34                 6,335                    15       125      4,145        263      1,233       13,865      1,667


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                                                                                                                                                                      184
Table A5. 14 Intra and extra community trade of centre-fire cartridges (other than cases) (93.06.30.91), average of 2000, 2001 and 2002
to *                                                                                             Export from (1000 €/year) *
                                                                                                                                                                                                  EU 15    NMS/
1000 €/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                138                   143                   392                                  96                                       136                                905
Belgium                        5                                31         3       116                              2,981                                2          14                     6      3,158
Denmark                        5         12                  365                   102                               <0.5                                        409                                893
Finland                                  12                                           79                                 4                                       223                                318
France                        52       908                   251                 1,014                                456                                        723                              3,404
Germany                     149        545          6        299           1                                          104                    4                   383                              1,489
Greece                                                          19                     4                                16                                       107                                146
Ireland                        8                                22                    12                                41                                          94                    15        193
Italy                         49       327                   104                   422                                                                              41                    25        969
Luxembourg                    46         80                     64         1       136                                                                                                              327
Netherlands                    6         48                     22                 198                                                                           106                                379
Portugal                   <0.5          62                     4          1          25                             <0.5                                        674                                766
Spain                         29       264                      31     <0.5        113                                493                                3                             <0.5         934
Sweden                         2         38      <0.5        745           5          79                                 1                                       166                              1,036
United Kingdom                 2       103                   316       <0.5        142                                903                                        733                              2,199
Total EU 15                 352      2,536          6      2,417           10    2,834                              5,094                    4           5     3,809                      47     17,115
New Member                  387          10                  351           1       710                                  53                 123                   230                       4      1,867
States and Candi-
date Countries
Other countries             722          20       255      1,358           94    1,708                                815                            <0.5      3,602                   145        8,720


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                                                                                                                                                                      185
Table A5. 15 Intra and extra community trade of centre-fire cartridges (other than cases) (93.06.30.91), average of 2000, 2001 and 2002
to *                                                                                             Export from (tonnes/year) *
                                                                                                                                                                                                  EU 15    NMS/
tonnes/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                   7                      4                    20                                27                                          70                              128
Belgium                    <0.5                                  2     <0.5            5                            1,202                                            8                 <0.5       1,217
Denmark                    <0.5       <0.5                      18                     7                             <0.5                                        147                                172
Finland                                   1                                           10                                 1                                       111                                123
France                         2         53                      7                    41                              197                                        343                                642
Germany                       4          29         1            9     <0.5                                             50                <0.5                   177                                271
Greece                                                           1                <0.5                                   6                                          53                                60
Ireland                    <0.5                                  1                <0.5                                  20                                          45                    1           67
Italy                          1         17                      4                    33                                                                            28                    1           84
Luxembourg                    2          4                       3                    10                                                                                                              20
Netherlands                <0.5           2                      1                    15                                                                            51                                69
Portugal                                  3                 <0.5                       1                             <0.5                                        326                                330
Spain                          1         14                      1                     5                              177                            <0.5                                           199
Sweden                                    2                     32     <0.5            5                             <0.5                                           81                              120
United Kingdom             <0.5          4                      10                    9                               370                                        379                                771
Total EU 15                   11       137          1           91         1       161                              2,050                 <0.5       <0.5      1,819                      2       4,273
New Member
States and Candi-
date Countries                19          1                     16                    32                                22                   1                   106                      1         198
Other countries               35          1         9           71         3       178                                286                            <0.5      1,537                      8       2,129


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                                                                                                                                                                      186
Table A5. 16 Intra and extra community trade of rim-fire cartridges (other than cases) (93.06.30.93), average of 2000, 2001 and 2002
to *                                                                                             Export from (1000 €/year) *
                                                                                                                                                                                                  EU 15    NMS/
1000 €/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                  39                     57                 242                                   6                                                                11        355
Belgium                        2                                10         6          75                                15                                                                85        194
Denmark                                  73                  115       <0.5        327                                                                                                 225          741
Finland                                  44                                        290                                   3                                                                43        381
France                     <0.5        437                      31                 385                                   4                                                             212        1,068
Germany                     112        249                   829           36                                           28                                      <0.5                 1,200        2,454
Greece                                                          13         6           8                                                                                                   8          34
Ireland                        1                                36                    17                                                                                               124          179
Italy                      <0.5          76                  135       <0.5           78                                                                                                  81        370
Luxembourg                               32                     29                    61                                                                                                            123
Netherlands                <0.5        229                       6                 102                                                                                                    89        426
Portugal                       1         14                      3         1          32                                 1                                      <0.5                      29          81
Spain                                    70                     42          3         42                                27                                                             110          293
Sweden                     <0.5          22      <0.5           93                 307                                  5                                                                 99        527
United Kingdom                           68                  270            3      133                                                                                                              475
Total EU 15                 117      1,356       <0.5      1,670           54    2,100                                  89                                      <0.5                 2,315        7,701
New Member                    62         27                     83          9      497                                  34                                                             119          830
States and Candi-
date Countries
Other countries             125           8       300      1,122           70    2,282                                133                    3       <0.5           3                2,655        6,703


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                                                                                                                                                                      187
Table A5. 17 Intra and extra community trade of rim-fire cartridges (other than cases) (93.06.30.93), average of 2000, 2001 and 2002
to *                                                                                             Export from (tonnes/year) *
                                                                                                                                                                                                  EU 15    NMS/
tonnes/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                   4                      3                    27                             <0.5                                                                  1          34
Belgium                    <0.5                                  1     <0.5           12                                2                                                                  6          21
Denmark                                   7                      5                    48                                                                                                  25          85
Finland                                   4                                           45                             <0.5                                                                 6           55
France                                   56                      1                    50                             <0.5                                                                 20        128
Germany                       10         31                     34         4                                            3                                                              112          193
Greece                                                           1         1           1                                                                                               <0.5            3
Ireland                    <0.5                                  2                     1                                                                                                  18          21
Italy                                    10                      6                    10                                                                                                   7          33
Luxembourg                                4                      1                    10                                                                                                              15
Netherlands                              33                 <0.5                      15                                                                                                  11          59
Portugal                   <0.5           2                 <0.5       <0.5            4                             <0.5                                                                  3           9
Spain                                    10                      3     <0.5            5                                 3                                                                 9          31
Sweden                                    2                      5                    44                             <0.5                                                                 12          63
United Kingdom                           8                      14     <0.5           12                                                                                                              35
Total EU 15                   10       171                      75         6       284                                   9                                                             230          785
New Member
States and Candi-
date Countries                 4          5                      7         1          65                                3                                                                 30        114
Other countries               16          1         16          56         13      235                                  10                <0.5                  <0.5                   155          502


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




                                                                                                                                                                                                                             .
                                                                              188




Production and intra- and extra-community
trade of fishing tackle
Statistics on production, import and export by old and new Member States and
Candidate Countries retrieved from the Europroms database of Eurostat is
shown in Table A5.18. The PRODCOM data is for this commodity code only
available in monetary units (€). Data on intra and extra community trade from
the COMEXT database is shown in Table A5.19 - A5.24.

Data are shown for fishing tackle exclusive rods, wheels, and hooks. Sinkers
and other lead-containing tackle will account for a small part of this group of
fishing tackle.




                                                                                  .
                                                                                                                         189



                 Table A5. 18 Production, import and export of line fishing tackle n.e.s., fish landing
                              nets, butterfly and similar nets 2000-2002 (exclusive rods, wheels and
                              hooks)*
All figures in                2000                                 2001                                  2002
million €/year   Prod.       Import       Export       Prod.       Import       Export       Prod.       Import       Export
Austria                0.0          2.8       0.3          0.0         2.9          0.4          0.0         2.2          0.3
Belgium                0.0          6.7       3.6          0.0         6.7          4.9          0.0         5.4          3.2
Denmark                0.0          2.1       6.6              -       3.7          5.8              -       3.0          4.6
Finland               18.9          1.9      12.7         23.8         2.6          9.9         21.7         2.3         10.6
France                 26          15.4      11.5         21.6        13.5         15.3         22.6        11.9         11.5
Germany                  -          7.0       5.7          2.8         6.1          4.6          2.9         8.9          5.9
Greece                   -          1.5       0.0              -       0.9          0.0              -            -            -
Ireland                  -         12.1       2.5              -      10.2          4.8              -       9.2          5.3
Italy                 11.4          6.2      16.4          8.8         6.4         15.7          8.8         5.3         16.2
Luxembourg             0.0          0.4       1.2          0.0         0.5          0.0              -            -            -
Netherlands            0.0          3.1       3.9          0.0         2.9          3.7          0.0         4.0          7.6
Portugal                 -          3.4       0.1              -       2.7          0.1              -       3.1          0.1
Spain                    -          8.4       5.4              -       8.1          4.1              -       7.9          7.8
Sweden                 0.0          1.3       3.0          0.0         1.4          3.7          0.0         2.0          4.6
UK                     16           4.8      13.9         22.4         4.9           12         25.5         4.5         10.1
EU 15 **              75.4           80      57.1              -      83.6         70.5              -      90.1         65.6
Bulgaria                 -            -            -       0.0              -            -       0.0              -            -
Croatia                  -            -            -       0.0              -            -       0.0              -            -
Czech Republic           -            -            -           -            -            -           -            -            -
Estonia                0.0            -            -       0.0              -            -       0.0              -            -
Hungary                  -            -            -       0.7              -            -       0.7              -            -
Latvia                   -            -            -           -            -            -       0.0              -            -
Lituania               0.0            -            -           -            -            -           -            -            -
Poland                   -            -            -           -            -            -           -            -            -
Romania                0.0            -            -       0.0              -            -           -            -            -
Slovakia                 -            -            -           -            -            -           -            -            -
Slovenia                 -            -            -       0.0              -            -
                 *       PRODCOM commodity code 36.40.15.50, "Line fishing tackle, fish landing nets, butterfly and
                         similar nets .
                 **      Total import/export from EU 15 to other countries
                 -       No data
                 Source: Europroms database. Commission of the European Communities (Statistical Office/Eurostat).




                                                                                                                                   .
                                                                                                            190



                        Table A5. 19 Import/export of fishing line fishing tackle n.e.s (95.07.90.00) to/from
                                     to/from EU 15, 1993-2003, in tonnes


EXPORT,Intra EU15   1993        1994      1995    1996    1997    1998    1999    2000    2001    2002    2003
tonnes
Austria                                       -      0        -       -       -       -       -       -         -
Belg,-Luxbg           98           8        10      14      44      21
Belgium                                                                     11      12       5       5      21
Denmark              433         777       682     634     498     475     403     755     390     433     465
Finland                                     12      10      15       8      12       6       6       7          8
France               175         162       175     136     154     272     458     474     397     325     349
Germany               14           1          -      1       3       5       5       4       1
Greece                 1           3                 1       0       3       2      58       4      21      27
Ireland               76          97        85     182     145      89      46      82     124      11          5
Italy                508         582       602     674     736     920     986    1,303   1,040    906     761
Luxembourg                                                                           0
Netherlands          189         208       124     146     176     248     184     179     213     266     188
Portugal            1,369      1,313      1,391   1,565   1,813   1,867   2,367   2,471   2,855   2,408   2,361
Spain               1,247      1,436      1,648   1,662   1,917   2,146   1,926   2,187   2,571   2,449   1,612
Sweden                                       1       4       2       2       1       1       2       6          2
Utd,Kingdom          296         152       238     320     254      82      92      34      24      63      16


EXPORT,Extra EU15   1993        1994      1995    1996    1997    1998    1999    2000    2001    2002    2003
tonnes
Austria                                      0       3       2       1       4       0               2          1
Belg,-Luxbg            0           1         7       0
Belgium                                                                      1       2       0       0          1
Denmark              497         710       730    1,129   1,440   1,401   1,385   1,531   1,659   1,507   1,700
Finland                                     56      74      68      59      68      77      68      54      51
France               172         225       225     282     253     428     447     382     439     261     474
Germany              132         167       170     156     225     203      98     186     227     152     139
Greece                25          12        20      17      11      28      19      59      92      70      47
Ireland               22          41       108     152     204     114     143     174      80      23     113
Italy                173         198       274     347     399     259     496    1,058   1,242    582     840
Luxembourg
Netherlands           64          68       182     113     178     289     199     136     161     167     204
Portugal             532         617       869     915     986    1,124   1,257   1,331   1,380   1,349   1,524
Spain               1,545      1,468      1,946   1,741   1,210   1,524    735    1,041   1,053    935    1,231
Sweden                                      28      13      11      16      10       9      36      16      44
Utd,Kingdom          314         227       193     421     146     205     176     262      74     194     163
Total EU15          3,476      3,734      4,807   5,362   5,132   5,653   5,036   6,247   6,510   5,312   6,531


                            **contimued




                                                                                                                    .
                                                                                                                             191




IMPORT,Intra EU15   1993     1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                    2          3         3          1        34        38         37        19          1
Belg,-Luxbg          116      179        136         86       117       269
Belgium                                                                            121       158       142        177       153
Denmark              220      191        230       440        786       880      1,106     1,254     1,213      1,115       942
Finland                                    6          5         8        17          4        20          8        14          6
France               630      409        437       602        627       749        721       821       830      1,036     1,029
Germany               85      119        128       119        111        76         46       105         96        88        52
Greece               208      231        257       389        482       483        594       504       504        432       441
Ireland              112        87       133       244        257       351        207       270       272        204       245
Italy                 33        25        19         49        78        68         42       146         80        87        89
Luxembourg                                                                            -         0         1         2          0
Netherlands          260      250         46         44        56       229        224       185       335        393       249
Portugal             139        75        68         62        98       120        172       166       332        217       181
Spain                489      622        547       482        563       799        739     3,649     1,191      1,784     1,278
Sweden                                    60         73        78        16         36        58         39        46        58
Utd,Kingdom          486      832        844       897        866       669      1,177       832       599        556       490


IMPORT,Extra EU15   1993     1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                     -         -         0          0         0          6         1         1          1
Belg,-Luxbg           98                   9          4         1          2
Belgium                                                                             10          2         3         3          3
Denmark              513      729        963       987      1,257     1,068      1,184     1,530     1,622      1,585     1,876
Finland                                  128       114         90       113        121       124       172        167       181
France               622      427        535       582        492       619        837       719       695        782       903
Germany               74        71       104       167        112        99        131       142       122        139        90
Greece               463      507        504       587        609       422        470       413       448        851       541
Ireland              148      147        182       174        116       192        250       245       238        152       141
Italy                212      266        511       701        630       861        868       691       450        437       701
Luxembourg
Netherlands           46        29        52         76        74        48        142       151       204        212       223
Portugal              26         9        17          4        32        65         61        88         55        35        41
Spain                289      330        546       787      1,083     1,222      1,199       809     1,080      1,104     1,193
Sweden                                    90         79        64        59         58        53         35        54        59
Utd,Kingdom          186      237        340       274        313       274        259       381       311        305       342
Total EU15          2,679    2,750     3,981     4,536      4,874     5,046      5,588     5,353     5,434      5,826     6,293


Total extra EU15,   1993     1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Export              3,476    3,734     4,807     5,362      5,132     5,653      5,036     6,247     6,510      5,312     6,531
Import              2,679    2,750     3,981     4,536      4,874     5,046      5,588     5,353     5,434      5,826     6,293


                        Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                        Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                        cret)




                                                                                                                                   .
                                                                                                                                                    192



                            Table A5. 20 Import/export of fishing line fishing tackle n.e.s (95.07.90.00) to/from
                                         to/from EU 15, 1993-2003, in 1000 €


EXPORT,Intra EU15   1993         1994        1995        1996        1997        1998        1999        2000        2001        2002        2003
1000 €
Austria                                         140         143         128         772         429         304         398         282         254
Belg,-Luxbg           1,648        1,307       2,444       2,826       5,021      10,177
Belgium                                                                                        9,246       3,617       4,924       3,204       5,744
Denmark                    96      1,127        507         838         552         810        1,665       6,633       5,785       4,592       3,226
Finland                                        6,698       8,439       8,597       8,589       9,496      12,668       9,919      10,559       5,561
France                5,622        6,097       8,161       8,372       8,800       8,491       8,183      11,462      15,327      11,466      11,839
Germany               2,042        1,408       2,452       3,374       3,657       4,842       5,599       5,705       4,581       5,906       4,513
Greece                                   1                       9          22          56                       8           1          22          36
Ireland                725         1,637       3,345       4,466       5,016       4,628       4,474       2,537       4,783       5,285       6,299
Italy                 9,528       12,020      11,799      15,690      15,417      18,578      17,411      16,388      15,699      16,774      16,545
Luxembourg                                                                                     1,946       1,165             0           1           0
Netherlands           2,401        3,425       2,511       3,065       4,601       4,037       3,891       3,898       3,748       7,574      13,266
Portugal                    2           87          64          70      169             69          85          75      135             75      123
Spain                  883         1,110       1,479       2,741       2,287       2,345       2,868       5,358       4,060       7,819       5,859
Sweden                                         1,021       1,294       2,429       3,115       2,194       3,010       3,694       4,612       5,340
Utd,Kingdom           8,322       10,015      12,799      12,395      12,226      14,590      12,535      13,866      12,045      10,144      12,599


EXPORT,Extra EU15     1993          1994       1995        1996        1997        1998        1999        2000        2001        2002        2003
1000 €
Austria                                         285         773         600         720         764         924         852         560         692
Belg,-Luxbg                33           64          31          13          54      101
Belgium                                                                                             31          21          19          71      164
Denmark                879         1,046        343        1,186       1,204        803         909         978         595         476         517
Finland                                        9,768      11,280       7,963       7,972       6,719       9,678      15,456      12,799       6,310
France                3,836        4,210       3,782       4,103       4,335       4,807       4,329       4,433       5,523       7,924       4,763
Germany               2,550        3,498       2,237       2,716       3,640       3,579       2,702       3,655       3,359       3,255       2,914
Greece                     51           32          59          69          65      133             88          69      147         146             59
Ireland               4,974        4,340        419       10,487      22,096       6,930       2,485      10,689      16,360      13,671       7,288
Italy                 7,089        8,842       9,299      10,378      12,767      13,814      12,900      16,414      15,226      14,128      12,737
Luxembourg                                                                                           3           3           2           0           2
Netherlands            799         1,085        993        1,473        781        1,049        552        1,327       1,576       2,906       4,719
Portugal               962           146        114         133         155         813         359         281         649         361         279
Spain                 1,190        1,351       1,300       1,367        747         978        1,058       1,201       1,092       1,522       2,531
Sweden                                         1,663       1,753       1,895       2,330       2,326       2,154       3,443       2,872       1,901
Utd,Kingdom           6,913        7,030       6,318       4,900       6,075       4,256       4,057       5,312       6,196       4,877       4,345
Total EU15           29,276       31,643      36,611      50,629      62,378      48,285      39,283      57,138      70,497      65,567      49,221


                                **contimued




                                                                                                                                                         .
                                                                                                                 193




IMPORT,Intra EU15    1993     1994     1995     1996     1997     1998     1999     2000     2001     2002     2003
1000 €
Austria                                2,061    3,076    2,762    2,423    2,871    3,304    3,820    2,855    3,572
Belg,-Luxbg          6,073    6,596    7,768    8,079    7,784    7,926
Belgium                                                                    6,901    8,063    8,237    7,372   10,615
Denmark              3,525    3,842    4,173    6,080    5,648    6,154    4,625    4,151    5,841    5,320    5,774
Finland                                3,105    3,379    5,924    6,318    5,928    9,369   11,628   10,642    7,115
France              13,865   17,660   17,246   20,082   21,479   29,219   27,848   25,874   23,147   21,377   25,674
Germany             15,381   15,733   17,542   21,075   22,471   21,148   18,297   21,506   18,993   21,119   19,391
Greece               1,147    1,366    1,355    1,611    2,144    2,190    1,715    2,191    1,767    1,767    2,558
Ireland              1,551    1,816    4,850    6,837    7,069    7,800    8,157   12,379   10,735    9,778    7,568
Italy                8,009    9,653   10,423   10,997   12,023   11,973   14,407   17,223   17,053   17,455   17,006
Luxembourg                                                                  371      442      557      473      590
Netherlands          6,083    7,589    6,578    7,397    8,085    8,353    9,115    8,503    8,214   10,983   10,061
Portugal             2,525    1,798    1,925    2,413    2,892    3,409    3,645    3,959    3,111    3,635    3,331
Spain                5,970    6,193    7,413    9,452   10,395   12,543    9,720   13,858   14,011   14,520   16,014
Sweden                                 4,309    5,722    7,347    7,658    6,963    7,425    8,198    8,607    8,452
Utd,Kingdom          8,284   11,087   13,750   13,231   15,836   17,395   17,476   18,816   21,851   25,442   26,461


IMPORT,Extra EU15    1993     1994     1995     1996     1997     1998     1999     2000     2001     2002     2003
1000 €
Austria                                1,746    2,409    2,467    1,954    2,401    2,795    2,875    2,209    2,905
Belg,-Luxbg          5,227    5,448    6,485    6,793    6,523    6,406
Belgium                                                                    5,675    6,750    6,702    5,383    7,775
Denmark              1,443    1,505    2,408    3,956    4,399    4,481    2,961    2,107    3,745    3,025    2,001
Finland                                1,357    1,280    2,148    2,002    1,782    1,917    2,628    2,335    2,208
France               7,932   11,838   11,570   14,041   14,964   21,639   20,805   15,372   13,469   11,878   13,798
Germany              4,754    4,777    6,161    8,481    9,890    8,448    6,631    6,980    6,112    8,890    6,343
Greece                303      368      527      964     1,458    1,380    1,141    1,496     947      976     1,681
Ireland               733      802     4,646    6,563    6,815    7,457    7,674   12,106   10,158    9,167    7,146
Italy                2,692    2,751    3,384    3,879    4,692    3,936    5,296    6,162    6,352    5,455    4,075
Luxembourg                                                                  311      396      536      458      571
Netherlands          3,912    4,734    3,836    4,700    4,753    4,728    4,778    3,145    2,926    4,046    2,091
Portugal             2,047    1,426    1,555    2,176    2,482    2,800    3,131    3,379    2,721    3,081    2,619
Spain                2,655    3,686    4,729    6,636    6,245    8,748    5,857    8,402    8,140    7,890    9,420
Sweden                                 1,268    1,596    1,856    1,331    1,362    1,266    1,371    1,961    2,199
Utd,Kingdom          2,505    4,289    8,282    5,320    5,501    6,670    5,017    4,837    4,854    4,473    4,252
Total EU15          34,203   41,624   57,956   68,795   74,193   81,980   74,822   77,110   73,536   71,227   69,082


Total extra EU15,    1993     1994     1995     1996     1997     1998     1999     2000     2001     2002     2003
tonnes
Export              29,276   31,643   36,611   50,629   62,378   48,285   39,283   57,138   70,497   65,567   49,221
Import              34,203   41,624   57,956   68,795   74,193   81,980   74,822   77,110   73,536   71,227   69,082




                                                                                                                       .
                                                                                    194



Table A5. 21 Import/export of fishing line fishing tackle n.e.s (95.07.90.00) to/from
             New Member States and Candidate Countries 1999-2003
EXPORT, EU15, tonnes                   1999       2000       2001       2002       2003
Bulgaria                                 8.9        6.3        9.8        8.8      11.2
Cyprus                                   0.1                                -           -
CzechRepublic                          154.9      197.8     212.2      193.7      202.7
Estonia                                178.3      254.7     320.5      326.6      163.5
Hungary                                201.2      244.7     245.3      205.1      202.1
Latvia                                  50.8       30.6      30.5       35.1       42.6
Lituania                                 1.7        2.1        0.2        0.4        1.8
Malta                                    0.2        0.4        0.6
Poland                                 128.7      141.4     139.3      179.1      189.2
Rumania                                 45.8        0.1        1.1        3.0      19.1
Slovakia                                 2.5        0.1        0.0        0.0        0.1
Slovenia                                 1.7        0.3        0.5        0.4        0.5
Turkey                                   0.2        0.2        0.0        0.5        1.3
Total                                  774.8      878.7     960.1      952.7      834.1


EXPORT, NON-EU15, tonnes               1999       2000       2001       2002       2003
Bulgaria                                 2.8        1.2        0.9        6.9      10.9
Cyprus                                     -                     -          -           -
CzechRepublic                           62.0       21.0      29.9       18.6       21.7
Estonia                                  1.0        1.3        1.1        4.8     136.7
Hungary                                 52.9       70.6      68.9       78.9       51.3
Latvia                                  17.7       12.4      11.4       11.3       18.1
Lituania                                20.4        1.7      14.2       30.4       60.6
Malta                                                          0.3
Poland                                 105.4       94.4      89.3      131.2      131.1
Rumania                                  0.0        0.0        0.8        0.2        0.3
Slovakia                                 6.8       13.4      14.7       18.5       41.8
Slovenia                                 1.4        1.0        0.5        0.6        0.3
Turkey                                  24.1        0.4        2.9        2.7        1.0
Total                                  294.6      217.4     234.8      304.1      473.8


EXPORT, total, tonnes                  1999       2000       2001       2002       2003
Bulgaria                                11.7        7.6      10.7       15.7       22.0
Cyprus                                   0.1                     -          -           -
CzechRepublic                          216.9      218.8     242.2      212.3      224.4
Estonia                                179.3      256.0     321.6      331.5      300.2
Hungary                                254.1      315.3     314.2      284.0      253.4
Latvia                                  68.5       43.0      41.8       46.4       60.7
Lituania                                22.1        3.7      14.4       30.8       62.5
Malta                                    0.2        0.4        0.9
Poland                                 234.0      235.9     228.6      310.3      320.3
Rumania                                 45.8        0.2        1.9        3.2      19.3
Slovakia                                 9.3       13.5      14.8       18.5       41.9
Slovenia                                 3.1        1.3        0.9        0.9        0.8
Turkey                                  26.4        2.0        3.8        4.2        4.2
Total                                1,071.4    1,097.5    1,195.8    1,257.8    1,309.7
Continued…




                                                                                            .
                                                                    195



IMPORT, EU15, tonnes       1999      2000      2001      2002      2003
Bulgaria                    28.8     34.6      22.1      16.2      17.6
Cyprus                         -         -         -         -         -
CzechRepublic               33.1     39.5      26.8      25.0      19.3
Estonia                    147.0    212.0     173.8     139.4     134.6
Hungary                     26.7     43.3      59.1      36.6      37.7
Latvia                      12.1       9.0     14.2        8.3       9.3
Lituania                    26.7     19.0      13.2      34.0      10.6
Malta                       14.7     24.6      45.2     130.8      56.6
Poland                      72.5     72.1      66.5      56.7      61.2
Rumania                      3.1     15.0      15.4        8.4     15.4
Slovakia                    14.6     17.4      11.4      19.2      18.1
Slovenia                     9.2     10.2        9.6     12.4        9.6
Turkey                       5.0     10.3        1.5       6.5       6.5
Total                      393.5    506.9     459.0     493.5     396.6


IMPORT, NON-EU15, tonnes   1999      2000      2001      2002      2003
Bulgaria                    53.2     49.6      47.4      46.4      75.0
Cyprus                         -         -         -         -         -
CzechRepublic               32.1     44.5      49.4      78.8     104.8
Estonia                      6.2     11.0        9.8     17.6      15.5
Hungary                     48.6     43.0      63.6      75.2     113.5
Latvia                      22.5     17.1      21.8      32.3      46.5
Lituania                   143.8    140.5     126.1     279.7     301.0
Malta                        5.2       7.2       6.1       4.9     41.7
Poland                      81.5    191.4     166.3     147.1     238.4
Rumania                     25.5     27.0      37.5      46.9      84.8
Slovakia                    41.8     31.7      31.0      39.9      44.8
Slovenia                     4.5       5.3       6.8     11.7      11.9
Turkey                      32.7     35.9      12.9      15.9     965.6
Total                      497.4    604.2     578.7     796.4    2,043.4


IMPORT, total, tonnes      1999      2000      2001      2002      2003
Bulgaria                    82.0     84.2      69.6      62.6      92.6
Cyprus                         -         -         -         -         -
CzechRepublic               65.3     83.9      76.2     103.8     124.1
Estonia                    153.2    223.0     183.6     157.0     150.1
Hungary                     75.3     86.3     122.7     111.8     151.2
Latvia                      34.6     26.2      36.0      40.6      55.8
Lituania                   170.5    159.5     139.4     313.8     311.6
Malta                       20.0     31.8      51.2     135.7      98.3
Poland                     154.0    263.6     232.8     203.9     299.6
Rumania                     28.7     42.0      53.0      55.3     100.2
Slovakia                    56.4     49.2      42.4      59.1      62.9
Slovenia                    13.7     15.5      16.4      24.2      21.4
Turkey                      37.7     46.9      14.5      22.3     972.0
Total                      891.2   1,111.9   1,037.8   1,289.9   2,440.0
Continued…




                                                                           .
                                                                           196



EXPORT, EU15, 1000 €          1999       2000       2001       2002       2003
Bulgaria                     225.3      188.8      320.9      350.7      458.7
Cyprus                          4.7                              2.2        2.8
CzechRepublic                903.4     1,151.4    1,248.5    1,216.1    1,082.7
Estonia                     2,801.8    5,591.2    7,529.9    5,767.3    3,544.5
Hungary                     1,109.3    1,363.2    1,528.7    1,432.1    1,409.9
Latvia                       265.8      281.3      211.9      278.3      214.0
Lituania                      37.1       77.5         9.8       10.3       41.2
Malta                           3.1        4.5        1.1
Poland                      2,156.6    3,230.6    2,242.9    2,481.1    2,541.9
Rumania                       38.0       10.9       28.8         8.0       89.5
Slovakia                        7.0        3.6        1.6        0.2        1.0
Slovenia                      34.5       24.5        41.4       32.1       38.6
Turkey                          0.8        1.6        1.0        2.5       12.4
Total                       7,587.4   11,929.2   13,166.3   11,580.7    9,437.2


EXPORT, NON-EU15, 1000 €      1999       2000       2001       2002       2003
Bulgaria                      24.3       25.0       18.5        35.5     128.1
Cyprus                          6.1                   1.8        0.2        0.2
CzechRepublic                214.0      183.1      313.0      285.0      292.3
Estonia                        42.5       47.1       44.8       72.6    5,187.5
Hungary                      539.3      719.2      681.7      762.8      529.4
Latvia                       257.4      200.2      234.8      228.4      283.7
Lituania                      74.3       35.7      129.5      171.9      401.1
Malta                                                 0.8
Poland                      1,450.4    1,702.1    2,121.7    2,937.7    2,773.9
Rumania                         0.0        0.4        3.4        7.0        4.6
Slovakia                      34.9       31.7       24.3        28.5       60.2
Slovenia                      16.1       15.1        10.2       10.0       16.0
Turkey                        42.7         1.3        3.7       12.0        3.9
Total                       2,702.0    2,960.9    3,588.1    4,551.6    9,680.9


EXPORT, total, 1000 €         1999       2000       2001       2002       2003
Bulgaria                     249.5      213.7      339.4      386.2      586.8
Cyprus                        10.8                    1.8        2.4        3.0
CzechRepublic               1,117.4    1,334.5    1,561.5    1,501.1    1,375.0
Estonia                     2,844.4    5,638.3    7,575.7    5,839.8    8,732.0
Hungary                     1,648.7    2,082.4    2,210.4    2,194.9    1,939.3
Latvia                       523.2      481.5      446.7      507.3      497.7
Lituania                     111.4      113.2      139.3      182.2      442.4
Malta                           3.1        4.5        1.9
Poland                      3,607.0    4,932.8    4,364.7    5,419.7    5,315.8
Rumania                       38.1       11.4       32.1       15.0        94.0
Slovakia                      41.9       35.3       25.9        28.6       61.2
Slovenia                      50.6       39.6        51.6       42.0       54.7
Turkey                        51.4        13.4       11.6       20.2       28.9
Total                      10,297.5   14,900.6   16,762.4   16,139.5   19,130.7
Continued…




                                                                                  .
                                                                                                     197



IMPORT, EU15, 1000 €                            1999         2000         2001         2002         2003
Bulgaria                                       139.9        157.1        156.1        169.7        210.8
Cyprus                                         127.0         74.9        191.0        225.6        210.7
CzechRepublic                                  485.1        824.5        869.9        576.4        404.2
Estonia                                      2,526.7      5,277.7      5,803.7      4,242.0       3,915.1
Hungary                                        605.2        830.5        668.2        645.2        611.7
Latvia                                         226.8        250.9        311.8        260.5        288.2
Lituania                                       484.6        358.8        200.7        297.8        226.2
Malta                                          298.1        279.2        459.2        795.0        229.8
Poland                                         844.5      1,238.1        919.0        807.4       1,013.0
Rumania                                         39.7         36.4         84.3        114.0        178.5
Slovakia                                       148.4        177.7        223.4        217.3        230.0
Slovenia                                       123.9        169.1        147.7        181.3        162.5
Turkey                                         167.3        304.0         74.4        210.4        279.3
Total                                        6,217.1      9,979.0     10,109.5      8,742.7       7,959.9


IMPORT, NON-EU15, 1000€                         1999         2000         2001         2002         2003
Bulgaria                                        97.4        106.0        129.2        197.6        253.4
Cyprus                                          48.2         49.4        108.1        139.2        125.7
CzechRepublic                                  452.5        521.0        730.3        892.6        961.3
Estonia                                        122.5        243.1        213.0        193.0        212.4
Hungary                                        623.1        898.4        908.0      1,002.0       1,197.3
Latvia                                         163.5        255.5        283.6        357.0        487.2
Lituania                                       676.6        712.0        581.1        977.6        880.9
Malta                                          107.9        167.0         78.9          94.5       320.3
Poland                                       1,362.1      1,792.8      1,866.0      1,833.5       2,180.3
Rumania                                        154.4        195.9        237.7        268.2        329.1
Slovakia                                       253.7        378.8        421.1        448.3        466.6
Slovenia                                       111.7        109.8        131.2        193.3        211.3
Turkey                                         307.7        388.0        218.7        163.2        397.8
Total                                        4,481.1      5,817.8      5,906.9      6,760.2       8,023.6


IMPORT, total, 1000 €                           1999         2000         2001         2002         2003
Bulgaria                                       237.2        263.1        285.2        367.3        464.1
Cyprus                                         175.2        124.4        299.1        364.9        336.4
CzechRepublic                                  937.9      1,345.6      1,600.2      1,469.0       1,365.5
Estonia                                      2,649.2      5,520.7      6,016.7      4,435.1       4,127.5
Hungary                                      1,228.3      1,729.0      1,576.2      1,647.2       1,809.1
Latvia                                         390.3        506.4        595.4        617.6        775.4
Lituania                                     1,161.2      1,070.8        781.8      1,275.4       1,107.1
Malta                                          406.0        446.1        538.1        889.5        550.1
Poland                                       2,206.7      3,031.6      2,785.1      2,641.1       3,193.3
Rumania                                        198.0        232.4        322.1        382.2        507.6
Slovakia                                       402.1        556.6        644.5        665.6        696.6
Slovenia                                       235.5        279.0        278.9        374.7        373.7
Turkey                                         475.0        697.1        293.2        373.6        677.0
Total                                       10,702.6     15,802.7     16,016.4     15,503.0     15,983.4
Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
cret)




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                                                                                                                                                                                                                      198



Table A5. 22 Intra and extra community trade of line fishing tackle n.e.s; fish landing nets, butterfly nets and similar nets; decoys and similar hunting or shooting requisites ((ex-
             clusive rods, wheels and hooks) (95.07.90.00), average of 2000, 2001 and 2002
to *                                                                                              Export from (1000 €/year) *
                                                                                                                                                                                                  EU 15    NMS/
1000 €/year              AT         BE         DK          FI         FR         DE         GR         IE          IT         LU        NL          PT         ES         SE         UK                     CC
Austria                                  33       458           11      151      2,290                      44        302          3         45                      1         45      367        3,749        122
Belgium                                           426           31    1,810        180                      66      1,308        65      1,099                       1         32    1,388        6,406         65
Denmark                                   7                     74         98      152        <0.5          43        189          2         24                     1       981        229        1,800        110
Finland                               <0.5        264                   210           21               1,074          102      <0.5          11                     89    1,478           98      3,348      6,483
France                               2,712        237        226                 1,002        <0.5     1,189        5,470        67        379           5     3,653           97    2,634       17,674        436
Germany                     283          56     1,139           46    4,207                              661        1,858        27      2,352                   116        284      2,437       13,466      3,683
Greece                        3                     25           3      187           99                    61        592          9         21                      8                    14      1,021         17
Ireland                                   1         67     9,762        101           49                              117                    22                 <0.5            8      552       10,681         72
Italy                      <0.5           9       173            2    1,646        179           2          28                   43        211           18      104           53    1,622        4,091        177
Luxembourg                             125          23                     73         33                                68                   20                                 1         22        365          3
Netherlands                   28       728        272           99      680        553                   335          402        22                                  1         19    2,346        5,486        523
Portugal                      8          13         21          47      504           53                    86      1,200          2       284                 1,616            1         45      3,880         38
Spain                                    36       406        144      1,857        459            8      381        2,232        22          15          71                    44         95      5,771         57
Sweden                        2       <0.5      1,095        489        125           85                 127          159          2         22                     41                 169        2,317        141
United Kingdom                3        194        530        112      1,104        240                   104        2,288       123        570                      83      727                   6,079        299
Total EU 15                 328      3,915      5,137     11,048     12,752      5,397           10    4,200       16,287       389      5,073           95    5,715      3,772     12,018       86,136    12,225
New Member                  292          13         64     5,191      1,187      1,531           50         97      4,704                  729                      39         97      629       14,622
States and Candi-
date Countries
Other countries             488          24     1,153      7,454      4,773      1,893           70   13,478       10,551          2     1,208        431      1,263      2,726      4,832       50,345


Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
*           Registered export from the countries in the first rows to the countries in the first column (registered by the export country). The registered import (registered by the import countries) is for most figures
            slightly different.
Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept secret)




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                                                                                                                                          199



                                    Table A5. 23 Import and export of line fishing tackle n.e.s; fish landing nets, butterfly
                                                 nets and similar nets; decoys and similar hunting or shooting requisites
                                                 (exclusive rods, wheels and hooks) (95.07.90.00) to/from EU 15, aver-
                                                 age of 2000, 2001 and 2002
                                                                                         Import from:                        Export to:
                                                                          1.000 €/year           t/year           1.000 €/year       t/year
                                  New Member States and Candi-
                                  date Countries (NMSCC):
                                  Bulgaria                                           247                     8             450                  28
                                  Cyprus                                                  2                  0             327                  16
                                  Czech Rep.                                       1,504                   268           2,430                 115
                                  Estonia                                          6,450                   303           5,147                 178
                                  Hungary                                          1,301                   214           1,835                 103
                                  Latvia                                                 65                  2             231                  10
                                  Lithuania                                              23                  1             329                  26
                                  Malta                                                   2                  0             272                  13
                                  Poland                                           2,696                   203           1,897                 219
                                  Romania                                                23                  3             301                  30
                                  Slovakia                                               28                  8             556                  42
                                  Slovenia                                               20                  0             581                  62
                                  Turkey                                                 51                  7             267                 267
                                  Total NMSCC                                     12,411                  1,018         14,622            1,109
                                  Other:
                                  USA                                             15,006                   503          23,130                 819
                                  Russia                                                 47                  0           3,622                 102
                                  Norway                                           1,043                    71           3,400                 150
                                  Canada                                             804                    59           2,033                  54
                                  Tunisia                                          1,952                   169           2,029                 342
                                  Switzerland                                        215                    12           1,904                  86
                                  Croatia                                                 9                  0           1,775                 185
                                  Japan                                            6,130                    95           1,612                  63
                                  Serb. Monten.                                      237                    13             906                  73
                                  Algeria                                                 1                  0             688                  75
                                  Ivory Coast                                             -                   -            611                  75
                                  N. det.Intra                                           53                 14             566                  41
                                  Australia                                          178                     5             471                  20
                                  Singapore                                          377                     8             462                      7
                                  Andorra                                                50                  3             442                  13
                                  South Africa                                       198                    14             398                  14
                                  Madagascar                                         150                     4             383                  17
                                  Ukraine                                                 1                  0             373                  14
                                  Taiwan                                           4,707                   267             316                      4
                                  Cuba                                                   -                    -            282                  23
                                  Iceland                                                53                 10             257                  13
                                  China                                           23,129                  2,821             37                      2
                                  South Korea                                      8,573                   361              16                      1
                                  India                                            4,942                   471              98                  98
                                  Other                                            4,351                   235           4,535            4,288
                                  Total non-NMSCC                                 72,207                  5,132         50,345            6,578
                                    Source:      COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                                    *           Export and import as registered by EU Member States
                                    Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                                    cret)




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                                     Table A5. 24 Import and export of fishing tackle to/from EU 15 countries in 2001
All figures                                         Import                                                Export
in million €/year           Rods            Hooks    Reels     Other      Totals     Rods       Hooks       Reels     Other      Totals
Outside EU 15
Austria                        0.9            0.1      0.9       0.9         2.8       0.4         0.0        0.2       0.9          1.5
Belgium                       3.7             0.3      1.8       1.4         7.2       0.0         0.0        0.0       0.0          0.0
Denmark                       2.3             2.5      0.9       2.1         7.8       0.8         0.2        0.0       0.6          1.6
Finland                       1.2             0.5      1.4       9.0        12.2       0.2         0.7        0.5      15.5         16.8
France                       12.3             4.6      9.5       9.7        36.1       0.5         7.9        0.5       5.5         14.4
Germany                      11.4             2.8      9.3      12.9        36.5       2.8         0.5        2.8       3.4          9.4
Greece                        0.3             0.9      0.1       0.8         2.1       0.0         0.0        0.0       0.1          0.2
Ireland                        0.2            0.5      0.0       0.6         1.3       3.3         1.4        0.0      16.4          21
Italy                          9.5            2.7      4.1      10.7        26.9       1.4         1.7        0.5      15.2         18.8
Luxembourg                     0.0            0.0      0.0       0.0         0.0       0.0         0.0        0.0       0.0          0.0
Netherlands                    9.0            1.6      8.8       5.3        24.7       1.4         0.3        0.5       1.6          3.8
Portugal                         -              -        -         -            -      0.1         0.5        0.0       0.6          1.3
Spain                          6.2            1.6      4.9       6.0        18.7       0.3         0.5        0.2       1.1          2.1
Sweden                         5.0            1.5      5.3       6.8        18.7       1.0         0.2       19.1       3.4         23.8
United Kingdom               14.4             4.2      6.1        17        41.6       1.3         3.5        3.7       6.2         14.6
Total outside
EU 15                        76.5            23.8     53.0      83.3       236.6      13.4        17.3       28.1      70.5       129.3
Within EU 15
Austria                        1.5            0.4      1.0       2.9         5.7       0.4         0.0        0.5       0.4          1.3
Belgium                       1.7             0.2      0.5       5.6         7.9       7.0         0.1        1.3       4.0         12.4
Denmark                       0.7             0.1      0.8       4.1         5.7       2.6         0.6        1.2       5.3          9.6
Finland                       0.6             0.7      0.8       2.6         4.7       0.1         0.2        0.1       9.9         10.3
France                         8.1            1.3      3.1      13.5          26       6.8         3.6        4.7      14.4         29.5
Germany                       2.6             0.4      1.8       5.5        10.3       3.4         1.0        3.6       4.4         12.4
Greece                        0.0             1.1      0.0       0.9         2.1       0.0         0.0        0.0       0.0          0.0
Ireland                        0.6            0.2      0.3      10.2        11.2       0.0         0.0        0.0       4.8          4.8
Italy                          3.1            0.4      2.7       6.3        12.5      10.2         0.9        1.1      15.6         27.8
Luxembourg                     0.2            0.0      0.0       0.5         0.7       0.0         0.0        0.0       0.0          0.0
Netherlands                    0.2            0.0      0.0       2.3         2.5       7.3         0.1        2.9       3.4         13.7
Portugal                       1.4            0.4      1.0       0.4         3.2       0.1         0.8        0.2       0.1          1.3
Spain                          1.5            1.8      0.5       7.6        11.4       0.4         0.4        0.4       3.9          5.1
Sweden                         0.1            0.1      0.1       1.4         1.7       1.1         0.1        1.5       3.5          6.1
United Kingdom                7.2             0.3      2.0       5.9        15.4       4.5         1.2        3.8      12.7         22.2
Total within EU              29.3             7.2     14.8      69.6       120.9      43.8         9.1       21.2      82.4       156.5


                                     Source: European Fishing Tackle Trade Association EFTTA, London. Based on national statistics from
                                     each of the EU 15 countries.




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                 Production and intra- and extra-community
                 trade of made-up fishing nets
                 Statistics on production, import and export by Member State and Candidate
                 Country retrieved from the Europroms database of Eurostat is shown in Table
                 A5.25-A5.26. The table shows the total for made-up fishing nets. Data on intra
                 and extra community trade from the COMEXT database is shown in the tables
                 A5.27-A5.32.

                 Table A5. 25 Production, import and export of made-up fishing nets 2000-2002*
All figures in                2000                                 2001                                  2002
Million €/year   Prod.       Import       Export       Prod.       Import       Export       Prod.       Import       Export
Austria                  -         0.2         0.0             -       0.2          0.0              -       0.1          0.0
Belgium                  -         0.9         0.1             -       0.9          0.0              -       1.0          0.0
Denmark                9.1         6.3         5.6         7.1         6.0          3.1          8.4         5.5          3.4
Finland                0.8         0.1         0.1         0.9         0.1          0.1              -       0.1          0.1
France                   -         4.3         2.7        13.4         4.9          2.4         11.2         5.4          2.9
Germany                  -         0.8         0.1             -       0.7          0.0              -       0.8               -
Greece                   -         2.3         0.3             -       2.4          0.0              -            -            -
Ireland                6.1         2.0         0.9         6.3         1.9          1.5          3.1         1.5          0.1
Italy                 24.2         1.4         6.2        46.1         0.4          5.8         45.2         0.6          4.2
Luxembourg               -         0.0         0.0             -       0.0               -           -            -            -
Netherlands              -         1.1         2.0             -       1.8          2.0              -       1.9          2.8
Portugal              17.9         0.6       11.2          6.2         1.2         14.2         17.8         2.0         11.5
Spain                 35.6         4.6         9.9        35.2         5.5         13.1         40.8         7.1         13.2
Sweden                   -         0.8         0.0             -       0.6          0.0              -       0.7          0.0
UK                       -         4.3         0.3             -       2.9          1.1         15.7         2.7          1.7
EU 15 **                 -       34.8        36.5              -      30.6         38.4              -      28.8         30.1
Bulgaria                 -            -            -           -            -            -           -            -            -
Croatia                  -            -            -           -            -            -           -            -            -
Czech Republic           -            -            -           -            -            -           -            -            -
Estonia                0.1            -            -           -            -            -           -            -            -
Hungary                  -            -            -           -            -            -           -            -            -
Latvia                   -            -            -       0.6              -            -           -            -            -
Lituania                 -            -            -           -            -            -           -            -            -
Poland                   -            -            -           -            -            -           -            -            -
Romania                  -            -            -           -            -            -           -            -            -
Slovakia                 -            -            -           -            -            -           -            -            -
Slovenia                 -            -            -           -            -            -           -            -            -
                 *       Sum of PRODCOM commodity codes 17.52.12.33, 17.52.12.35: "Made up fishing nets…." (with
                         different codes for nets of different types).
                 **      Total reported mport/export from EU 15 to other countries (not identical with the sum of the indi-
                         vidual countries' export/import)
                 -       No data or insufficient data (the figure for reported commodity codes = 0)
                 Source: Europroms database. Commission of the European Communities (Statistical Office/Eurostat).




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                                                                                                                         202



                 Table A5. 26 Production, import and export of made-up fishing nets 2000-2002*
All figures in                2000                                 2001                                  2002
Tonnes/year      Prod.       Import       Export       Prod.       Import       Export       Prod.       Import       Export
Austria                  -           38            -           -          37             -           -          19             -
Belgium                  -        158          12              -       142               5           -       178               5
Denmark               763       1,254         755         556        1,213          390         633        1,115          433
Finland                  -           20            6           -            8            6           -          14             7
France                   -        821         474       1,058          830          397       1,058        1,036          325
Germany                  -        105              4           -          96             1           -          88             -
Greece                   -        504          58              -       504               4           -            -            -
Ireland               841         271          82       1,398          273          124         664          204           11
Italy                3,967        146       1,303       7,947             80      1,040       7,823             87        758
Luxembourg               -         0.1         0.1             -            1            -           -            -            -
Netherlands              -        185         179              -       335          213              -       393          266
Portugal             3,505        166       2,471         794          332        2,855       3,271          217        2,408
Spain                9,312      3,649       2,187       8,396        1,191        2,571       9,793        1,784        2,449
Sweden                   -           58            1           -          39             2           -          46             6
UK                       -        832          34              -       599           24       1,688          556           63
EU 15 **                 -      5,353       6,247              -     5,434        6,510              -     5,826        5,311
Bulgaria                 -            -            -           -            -            -           -            -            -
Croatia                  -            -            -           -            -            -           -            -            -
Czech Republic           -            -            -           -            -            -           -            -            -
Estonia               169             -            -           -            -            -           -            -            -
Hungary                  -            -            -           -            -            -           -            -            -
Latvia                   -            -            -       61               -            -           -            -            -
Lituania                 -            -            -           -            -            -           -            -            -
Poland                   -            -            -           -            -            -           -            -            -
Romania                  -            -            -           -            -            -           -            -            -
Slovakia                 -            -            -           -            -            -           -            -            -
Slovenia                 -            -            -           -            -            -           -            -            -
                 *       Sum of PRODCOM commodity codes 17.52.12.33, 17.52.12.35: "Made up fishing nets…." (with
                         different codes for nets of different types).
                 **      Total reported mport/export from EU 15 to other countries (not identical with the sum of the indi-
                         vidual countries' export/import)
                 -       No data or insufficient data (the figure for reported commodity codes = 0)
                 Source: Europroms database. Commission of the European Communities (Statistical Office/Eurostat).




                                                                                                                                   .
                                                                                                                                203



                          Table A5. 27 Import and export of made-up fishing nets (56.08.11) EU 15, 1993-
                                       2003, in tonnes
EXPORT,Intra EU15     1993        1994        1995      1996      1997      1998      1999      2000      2001      2002      2003
tonnes
Austria                                           -       0.1         -         -         -         -         -         -         -
Belg,-Luxbg           98.3          8.4       10.3      14.2      44.4      20.6
Belgium                                                                               10.6      12.3        4.7       4.9     21.2
Denmark              433.0       776.7       681.6     633.6     497.8     475.1     402.8     754.8     389.9     433.2     465.1
Finland                                       11.5        9.7     15.4        7.8     12.2        5.9       6.4       7.4       8.4
France               175.0       162.1       174.8     136.1     154.3     272.4     458.1     474.3     397.0     324.5     349.2
Germany               13.5          0.9           -       1.3       3.2       4.8       5.2       4.1       1.0
Greece                  1.0         2.8                   1.1       0.2       3.1       1.9     57.5        3.5     21.1      27.4
Ireland               75.7        96.8        84.6     181.6     145.1      88.8      45.9      81.9     123.8      10.8        5.3
Italy                507.7       581.6       601.6     673.5     736.1     920.1     986.1    1,302.7   1,039.9    906.1     761.2
Luxembourg                                                                                        0.1
Netherlands          188.9       207.9       123.5     145.8     175.9     247.7     183.9     178.7     212.8     265.5     187.5
Portugal            1,369.1     1,312.9     1,391.3   1,565.4   1,813.1   1,867.2   2,367.1   2,471.0   2,854.8   2,408.1   2,361.0
Spain               1,246.5     1,436.4     1,647.5   1,661.8   1,917.0   2,145.9   1,926.1   2,186.8   2,570.8   2,448.6   1,612.3
Sweden                                          0.8       3.9       2.3       1.9       0.5       0.9       1.7       5.7       1.9
Utd,Kingdom          296.0       151.8       237.8     319.9     254.4      81.8      91.8      34.1      24.4      62.9      15.8
Total EU15          4,404.7     4,738.3     4,965.3   5,348.0   5,759.2   6,137.2   6,492.2   7,565.1   7,630.7   6,898.8   5,816.3


EXPORT,Extra EU15     1993        1994        1995      1996      1997      1998      1999      2000      2001      2002      2003
tonnes
Austria                                         0.3       2.6       2.1       1.0       4.0       0.1                 1.7       0.7
Belg,-Luxbg             0.4         1.1         7.3       0.4
Belgium                                                                                 0.5       2.2       0.2       0.1       1.1
Denmark              496.7       709.9       729.7    1,128.8   1,440.3   1,400.5   1,385.1   1,531.0   1,659.0   1,507.2   1,699.8
Finland                                       55.5      73.6      68.0      59.4      67.7      76.6      67.7      54.3      51.4
France               172.4       224.7       225.0     282.0     253.0     428.3     446.7     382.0     438.9     260.6     474.1
Germany              132.4       167.1       170.2     156.0     224.9     203.2      97.6     186.2     226.5     151.5     138.6
Greece                24.8        11.7        19.9      16.8      11.4      28.4      18.6      59.2      91.6      70.2      47.2
Ireland               21.6        41.0       107.7     151.5     204.0     114.0     143.1     173.9      80.3      23.1     112.8
Italy                172.7       198.1       273.8     347.3     399.2     259.0     495.6    1,057.8   1,241.7    582.2     839.6
Luxembourg
Netherlands           63.6        68.4       181.7     112.8     177.5     289.4     198.7     135.9     161.1     166.8     204.1
Portugal             531.8       616.9       869.1     915.4     985.8    1,124.4   1,257.0   1,330.7   1,379.7   1,349.4   1,523.6
Spain               1,545.4     1,468.0     1,945.9   1,741.3   1,210.0   1,524.0    734.6    1,040.8   1,052.8    934.6    1,231.0
Sweden                                        28.3      13.3      10.7      15.9      10.4        9.3     36.3      15.8      43.7
Utd,Kingdom          313.7       226.9       192.6     420.5     145.5     205.3     176.2     261.7      74.0     194.0     163.2
Total EU15          3,475.5     3,733.8     4,807.0   5,362.3   5,132.4   5,652.8   5,035.8   6,247.4   6,509.8   5,311.5   6,530.9


                              **contimued




                                                                                                                                      .
                                                                                                                               204




IMPORT,Intra EU15     1993      1994      1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                     2.0       3.0       2.8        1.2      33.7      37.6       37.3      18.9        0.7
Belg,-Luxbg          116.3     178.8     135.6       85.8     117.0     268.5
Belgium                                                                            120.5     158.2     141.5      177.2     152.9
Denmark              220.2     191.4     229.9     439.6      786.0     880.4    1,106.3    1,253.5   1,212.8   1,114.5     942.4
Finland                                     5.9       4.8       8.3      17.3        3.7      19.7        7.5      14.2        5.7
France               630.2     408.9     437.4     601.6      627.4     749.2      720.7     821.1     830.3    1,036.1   1,028.5
Germany               84.7     118.8     128.4     119.3      111.2      75.6       46.1     105.2       96.0      87.9       52.3
Greece               208.2     230.7     256.5     389.2      482.0     483.3      593.9     503.8     503.9      432.1     441.0
Ireland              112.1      86.9     133.3     243.5      257.4     350.5      206.5     270.2     272.1      204.2     244.7
Italy                 33.1      25.2      19.1       49.3      78.1      67.7       42.4     146.3       80.2      87.3       88.9
Luxembourg                                                                              -       0.1       1.1       2.0        0.2
Netherlands          259.8     250.2      45.8       44.3      55.8     229.1      224.1     184.6     334.7      392.8     249.2
Portugal             138.5      74.6      68.3       61.5      97.6     119.9      172.4     165.7     331.9      216.7     181.4
Spain                488.8     622.3     546.7     481.7      562.9     799.2      738.9    3,649.4   1,190.6   1,784.1   1,277.9
Sweden                                    59.7       73.0      77.5      16.2       36.0      57.8       38.6      45.9       57.5
Utd,Kingdom          485.5     832.0     844.1     896.5      865.8     669.4    1,176.9     831.8     598.7      555.5     489.5
Total EU15          2,777.4   3,019.8   2,912.7   3,493.1   4,129.8   4,727.5    5,222.1    8,205.0   5,677.2   6,169.4   5,212.8


IMPORT,Extra EU15     1993      1994      1995      1996      1997       1998      1999       2000      2001       2002      2003
tonnes
Austria                                       -         -       0.2        0.3       0.3        6.1       0.5       1.1        0.6
Belg,-Luxbg           98.1                  9.3       3.7       0.6        2.3
Belgium                                                                             10.0        1.9       2.9       3.3        3.1
Denmark              513.1     728.7     963.0     986.6    1,257.3   1,068.0    1,184.1    1,529.9   1,622.2   1,584.7   1,875.8
Finland                                  127.7     114.2       89.9     112.9      120.5     123.5     171.9      166.6     181.0
France               622.0     426.9     535.2     582.0      492.3     619.2      837.0     719.3     694.8      782.3     902.9
Germany               74.4      70.5     104.2     166.7      112.2      99.0      131.2     141.5     122.2      139.0       89.9
Greece               463.4     506.8     503.9     587.3      609.1     421.8      469.6     412.9     448.2      850.7     540.6
Ireland              148.2     147.1     182.3     173.5      115.9     192.4      249.5     245.4     237.7      152.0     141.3
Italy                212.2     265.5     510.8     701.3      629.6     861.4      867.6     691.1     449.6      437.0     700.9
Luxembourg
Netherlands           46.4      29.1      51.7       76.2      73.9      48.1      141.8     151.1     203.8      211.7     222.8
Portugal              26.1        8.8     17.0        3.8      31.9      64.8       60.5      87.9       55.3      35.4       41.1
Spain                288.9     330.2     545.9     787.4    1,083.4   1,222.1    1,198.5     808.8    1,079.7   1,103.9   1,192.8
Sweden                                    90.3       79.3      64.3      59.3       58.3      52.7       34.5      53.6       58.6
Utd,Kingdom          186.1     236.6     339.8     274.0      312.9     274.1      258.9     380.5     310.7      304.9     341.5
Total EU15          2,678.9   2,750.2   3,981.1   4,536.0   4,873.5   5,045.7    5,587.8    5,352.6   5,434.0   5,826.2   6,292.9
                          Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                          Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                          cret)




                                                                                                                                     .
                                                                                                                205



                        Table A5. 28 Import and export of made-up fishing nets (56.08.11) EU 15, 1993-
                                     2003, in 1000 €
EXPORT,IntraEU15    1993     1994     1995     1996     1997     1998     1999     2000     2001     2002     2003
1000€
Austria                                  0        2        3        0        1        2        2        3        1
Belg,-Luxbg          148       64      117      107      164      312
Belgium                                                                     34       51       27       31       90
Denmark             3,197    4,670    6,607    6,446    5,110    4,745    3,625    5,614    3,102    3,362    3,315
Finland                                115      119      123      117      155       81      115       89      109
France               731      706      884      918     1,079    1,080    2,168    2,677    2,366    2,904    2,234
Germany               69       34       10       39       65       95      157      101       11
Greece                 9       22                 5        2       22       17      294       24      161       84
Ireland              523     1,118     960     2,462    2,115    1,112     559      929     1,542      99       49
Italy               3,319    3,509    3,691    4,553    4,598    5,580    5,478    6,225    5,756    5,081    4,461
Luxembourg                                                                            3
Netherlands         1,263    1,361     961     1,231    1,434    1,896    1,732    1,952    2,019    2,817    2,023
Portugal            6,700    5,921    6,171    7,143    7,715    8,502   10,614   11,224   14,211   11,489   11,300
Spain               3,969    4,604    8,323    8,846    9,658   10,486    9,064    9,898   13,127   13,197    7,743
Sweden                                  13       80       61       61        3        4       15       45       58
Utd,Kingdom         2,747    1,039    1,179    2,054    1,495     924      876      318     1,103    1,653     348
TotalEU15          22,675   23,048   29,032   34,006   33,623   34,934   34,483   39,375   43,420   40,932   31,816


EXPORT,ExtraEU15    1993     1994     1995     1996     1997     1998     1999     2000     2001     2002     2003
1000 €
Austria                                  4        7       13       11       21        1                19        9
Belg,-Luxbg            8        8       44        9
Belgium                                                                      4       15        2        2        8
Denmark             4,048    5,081    4,544    6,503    8,385    7,549    6,820    7,702    8,691    6,958    6,476
Finland                                506      568      645      522      539      566      543      490      407
France              1,525    2,102    1,387    1,814    1,343    3,156    3,389    2,959    3,491    1,806    3,300
Germany             1,404    1,674    1,793    1,464    1,860    1,759     831     2,042    2,610    1,543    1,258
Greece               160      101      139      149       99      216      173      825     1,009     669      400
Ireland              327      711     1,546    1,870    2,593    1,527    2,546    2,869     935      290     1,425
Italy               1,064     894     1,456    1,848    2,031    1,316    2,457    4,690    5,705    2,643    3,717
Luxembourg
Netherlands          521      478     1,116     956     1,386    2,044    1,332    1,054    1,454    1,642    1,706
Portugal            2,425    2,511    4,085    4,630    4,804    5,338    5,707    6,850    7,138    7,689    7,252
Spain               7,766    7,586    9,138    8,508    5,665    7,174    3,622    4,934    4,965    4,141    5,952
Sweden                                 231      172      133      166      126      151      241      261      435
Utd,Kingdom         3,255    1,870    1,534    2,518    1,355    2,020    1,423    1,866    1,598    1,925    1,369
TotalEU15          22,504   23,016   27,524   31,015   30,312   32,797   28,988   36,524   38,383   30,077   33,712
                        Continued




                                                                                                                      .
                                                                                                                              206



IMPORT,Intra EU15    1993     1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000€
Austria                                    72         46        70        30        177       190       211         74        21
Belg,-Luxbg           936      881        800       541        590     1,087
Belgium                                                                             676       870       854        958       875
Denmark              1,056     846      1,110     2,087      3,651     4,094      5,103     6,276     6,047      5,544     4,970
Finland                                    87         69       109       165         43       109         77        93        66
France               3,346    3,009     2,566     3,338      2,747     3,484      3,429     4,347     4,868      5,387     5,033
Germany               626      869        996       905        732       566        392       815       741        759       433
Greece               1,224    1,249     1,302     2,117      2,265     2,612      2,826     2,348     2,369      1,702     1,984
Ireland               872      543        989     1,942      2,112     2,729      1,523     2,006     1,907      1,464     1,750
Italy                 352      146        252       297        460       366        260     1,412       420        580       443
Luxembourg                                                                            1          4        32         5          5
Netherlands           996     1,032       214       278        199       916      1,116     1,118     1,810      1,903     1,411
Portugal              441      306        270       289        366       471        561       597     1,235      1,969     1,444
Spain                2,301    2,582     2,584     2,455      2,855     4,064      3,396     4,620     5,543      7,111     6,251
Sweden                                    673       713      1,091       314        412       754       619        670       929
Utd,Kingdom          2,260    3,672     3,267     3,738      4,442     3,008      6,170     4,293     2,852      2,652     2,357
TotalEU15           14,409   15,137    15,182    18,813     21,688    23,905    26,085     29,758    29,586     30,872    27,971


IMPORT,ExtraEU15     1993     1994       1995      1996      1997       1998      1999       2000      2001       2002      2003
1000€
Austria                                     7          3         5          8         6        28          8        12          7
Belg,-Luxbg           122         1        84         40         6        53
Belgium                                                                              39        18         29        55        17
Denmark              3,414    3,830     4,177     5,055      5,753     5,915      5,760     7,861     7,253      6,610     7,657
Finland                                   846       788        701       755        659       640       863        824       705
France               4,804    2,915     3,853     3,959      3,690     4,507      5,982     5,444     5,163      5,128     4,853
Germany               443      483        538       873        873       744        901     1,174       720        821       437
Greece               3,466    3,870     3,238     3,956      4,608     3,108      3,121     3,163     3,490      3,277     3,158
Ireland               822     1,055     1,303     1,285        778     1,123      1,562     1,703     1,765      1,037     1,154
Italy                1,448    1,683     1,891     2,330      2,476     2,966      2,765     2,248     2,635      2,283     2,735
Luxembourg
Netherlands           355      240        429       600        757       452        696       520       765        823       685
Portugal              111        43       112         45       345       460        364     4,744       476        248       214
Spain                1,575    1,599     2,485     4,170      4,537     5,994      5,754     4,612     5,473      5,540     5,903
Sweden                                    756       754        714       620        613       583       417        625       598
Utd,Kingdom          1,084    1,369     2,130     1,806      2,331     1,721      1,434     2,101     1,494      1,473     1,780
TotalEU15           17,644   17,089    21,849    25,666     27,573    28,425    29,655     34,838    30,551     28,757    29,904


                         Source:     COMEXT, Commission of the European Communities (Statistical Office/Eurostat)
                         Empty cells = no registered export or import, may indicate that the figure is 0 or the data are kept se-
                         cret)




                                                                                                                                    .
                                                                                 207



Table A5. 29 Import and export of made-up fishing nets (56.08.11) to/from New
             Member States and Candidate Countries 1999-2003
EXPORT to EU15, tonnes               1999      2000      2001       2002        2003
Bulgaria                              0.8        1.0       0.6        0.7         0.6
Cyprus                                  -                             1.6         0.2
CzechRepublic                         0.5        0.4       1.7        3.4         1.5
Estonia                             119.6      122.5     416.9     473.9        364.2
Hungary                               0.0                  0.3        0.0
Latvia                                                                0.7         1.9
Lituania                             26.0       22.5      32.8     150.2        348.1
Malta                                 0.0
Poland                              280.3      356.3     358.4     341.5        301.8
Rumania                               0.0                  0.0        0.0         1.2
Slovakia                              0.0                                         0.1
Slovenia
Turkey                                0.2        0.2       3.2        0.6         0.4
Total                               427.5      503.0     814.0     972.6    1,020.0


EXPORT to NON-EU15, tonnes           1999      2000      2001       2002        2003
Bulgaria                              0.4        0.1       0.0        0.0         0.2
Cyprus                                                                1.2         0.2
CzechRepublic                         3.4        6.7       5.0        6.0         4.2
Estonia                              13.6       20.0       8.4        6.3        30.9
Hungary                               0.2                  3.2        0.9
Latvia                                5.7       20.0       3.2        1.6         3.0
Lituania                             84.2       69.1      61.4      90.2         83.3
Malta                                                                 8.5         0.2
Poland                                2.2        1.9       4.9        6.6         1.9
Rumania                               5.8        4.9       2.6        5.5         5.0
Slovakia                              0.3                  0.1        0.2         0.1
Slovenia                              0.1        0.3                              0.1
Turkey                                5.5        3.4       1.5      22.1         15.7
Total                               121.3      126.3      90.4     149.1        144.7


EXPORT total, tonnes                 1999      2000      2001       2002        2003
Bulgaria                              1.1        1.1       0.6        0.7         0.8
Cyprus                                  -                             2.7         0.4
CzechRepublic                         3.9        7.1       6.8        9.4         5.7
Estonia                             133.2      142.5     425.3     480.2        395.2
Hungary                               0.2                  3.5        1.0
Latvia                                5.7       20.0       3.2        2.3         4.8
Lituania                            110.2      104.7      94.2     240.3        431.4
Malta                                 0.6        0.6                  8.5         0.2
Poland                              495.9      419.3     378.9     392.8        324.9
Rumania                               5.8        4.9       2.7        5.5         6.2
Slovakia                              0.4                  0.1        0.2         0.1
Slovenia                              0.1        0.3                              0.1
Turkey                               17.9        7.4       5.8      22.7         16.3
Total                               774.9      707.9     921.1    1,166.4   1,186.0
Continued…




                                                                                        .
                                                                      208



IMPORT from EU15, tonnes       1999    2000      2001      2002      2003
Bulgaria                         0.1    20.2     13.9      14.3        0.2
Cyprus                           9.5    12.2     12.9        6.6       6.9
CzechRepublic                    8.3    20.3     28.1      20.3      17.6
Estonia                         51.2    50.7    241.2     207.8     263.1
Hungary                          6.2     1.2     25.2      16.4        6.1
Latvia                           2.8     0.2       1.9       0.4       0.2
Lituania                         5.9    10.1       3.9     36.7      10.6
Malta                            2.2    11.6       2.2       2.8       2.7
Poland                          74.1   106.8    122.9     130.6     155.2
Rumania                          0.3     1.0       0.7       3.2       8.5
Slovakia                         0.4     0.7       0.7       0.5       1.9
Slovenia                         1.4     1.4       1.3       2.2       0.5
Turkey                          54.2    93.6    122.3     142.0     409.9
Total                          216.5   330.1    577.1     583.7     883.5


IMPORT from NON-EU15, tonnes   1999    2000      2001      2002      2003
Bulgaria                         8.1     5.9     11.5      21.7      13.5
Cyprus                          31.1    14.4     27.0      25.6      37.5
CzechRepublic                    1.2    17.7       0.3       1.6       0.9
Estonia                          7.2     7.8       7.3     12.6      11.9
Hungary                          0.1     0.0       0.7       0.9       1.0
Latvia                           9.1     7.4     79.6      83.0      37.4
Lituania                         3.2    75.6     73.0     106.9      17.0
Malta                            8.7    13.7     11.1      19.6      12.7
Poland                         136.6   121.3    147.7     160.7     152.9
Rumania                         25.3    54.8     62.8      71.3      52.1
Slovakia                         2.2     3.0       4.4       4.5       8.1
Slovenia                                 0.0       0.3       0.8       0.1
Turkey                          69.6    26.4     58.8     104.4     290.1
Total                          302.4   348.1    484.4     613.6     635.2


IMPORT, total, tonnes          1999    2000      2001      2002      2003
Bulgaria                         8.1    26.1     25.5      36.0      13.7
Cyprus                          40.5    26.6     39.8      32.1      44.4
CzechRepublic                    9.5    38.0     28.4      21.9      18.5
Estonia                         58.4    58.6    248.5     220.4     275.0
Hungary                          6.3     1.2     25.8      17.3        7.1
Latvia                          11.9     7.6     81.5      83.3      37.6
Lituania                         9.1    85.8     76.9     143.6      27.6
Malta                           10.9    25.3     13.3      22.5      15.4
Poland                         210.7   228.1    270.6     291.3     308.1
Rumania                         25.5    55.9     63.5      74.5      60.6
Slovakia                         2.6     3.6       5.0       4.9     10.0
Slovenia                         1.4     1.4       1.6       3.1       0.6
Turkey                         123.8   120.0    181.1     246.3     700.0
Total                          518.9   678.2   1,061.5   1,197.3   1,518.7
Continued…




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EXPORT to EU15, 1000 €         1999      2000      2001      2002      2003
Bulgaria                         3.5       5.5       2.8       2.9       2.5
Cyprus                           3.1                           0.9       0.5
CzechRepublic                  18.7        7.8     22.4      25.1      28.2
Estonia                       738.2     742.1    1,687.5   1,858.5   1,524.4
Hungary                          0.5                 3.2       0.2
Latvia                                                         4.3       7.6
Lituania                       77.4      87.5     204.3     789.9    2,192.0
Malta                            0.0
Poland                        840.1    1,165.4   1,034.2    966.4     965.3
Rumania                          0.0                 0.2       0.1       5.4
Slovakia                         0.5                                     2.0
Slovenia
Turkey                           0.5       1.8     30.3        3.9       2.1
Total                        1,682.4   2,010.2   2,984.8   3,652.2   4,730.1


EXPORT to NON-EU15, 1000 €     1999      2000      2001      2002      2003
Bulgaria                         1.1       0.7       0.1       0.1       0.4
Cyprus                                                         5.9       1.0
CzechRepublic                  34.1      68.0      50.9      68.1      43.6
Estonia                        41.4      27.0      59.7      20.1     121.4
Hungary                          4.2               20.5        6.3
Latvia                         25.5      33.2      16.2        7.4       5.1
Lituania                      311.4     337.4     358.9     453.6     464.8
Malta                                                        67.0        0.1
Poland                         18.7      21.7      65.2      72.8      19.4
Rumania                        26.4      31.5      18.5      51.6      25.8
Slovakia                         3.6                 2.3       1.2       0.4
Slovenia                         0.5       3.1                           0.2
Turkey                           6.9     12.2        6.2     27.0      47.5
Total                         473.9     534.8     598.3     780.9     729.6


EXPORT, total, 1000 €          1999      2000      2001      2002      2003
Bulgaria                         4.6       6.2       2.8       3.0       2.9
Cyprus                           3.1                           6.7       1.5
CzechRepublic                  52.8      75.8      73.3      93.2      71.8
Estonia                       779.7     769.1    1,747.2   1,878.6   1,645.8
Hungary                          4.6               23.6        6.5
Latvia                         25.5      33.2      16.2      11.7      12.7
Lituania                      388.8     480.2     563.1    1,243.5   2,656.8
Malta                            1.3       3.1               67.0        0.1
Poland                       1,669.0   1,494.8   1,228.6   1,475.6   1,182.8
Rumania                        26.4      31.5      18.7      51.6      31.2
Slovakia                         4.1                 2.3       1.2       2.5
Slovenia                         0.5       3.1                           0.2
Turkey                         17.4      18.1      37.3      30.9      51.4
Total                        2,977.8   2,915.2   3,713.1   4,869.6   5,659.6
Continued…




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IMPORT from EU15, 1000 €