SG 84/24
The EU has informed the WTO of its intention to regulate 18 PAH in clay targets for shooting as a new entry under Annex XVII of REACH. If approved, the restrictions will become effective one year from the date of entry into force.
On May 27, 2024, the World Trade Organization (WTO) announced a draft regulation from the European Commission on its intention to regulate 18 polycyclic aromatic hydrocarbons (PAH) in clay targets (clay pigeons).
These disc-shaped objects used by sports shooters and small game hunters for (shooting) practice are manufactured using binders such as coal tar pitch, high temperature (‘CTPHT’), petroleum pitch or other types of resin.
The substance CTPHT is a substance of very high concern (SVHC) on the Authorization List under Annex XIV of Regulation (EC) No. 1907/2006 (entry 41 to Annex XIV of REACH, consolidated version to December 2023). Its carcinogenic, persistent, bio-accumulative and toxic (PBT) and very persistent and very bio-accumulative (vPvB) properties are due to the presence of PAH in the substance.
Applications for authorizing the use of CTPHT as a binder for the manufacture of clay targets have been rejected by the European Commission under Decisions C(2022)1510 and C(2022)1512. Although the authorization requirement does not apply to the placing onto the market of substances in articles, there are concerns about clay targets containing CTPHT being imported into the EU.
The draft regulation is planned for adoption in Q4 of 2024.
Highlights of the draft regulation are summarized in Table 1.
WTO Document Number 24-4026, May 27, 2024
Draft Commission Regulation amending Annex XVII to Regulation (EC) No. 1907/2006 as regards polycyclic aromatic hydrocarbons (PAHs) in clay targets
| Substance | Scope | Requirement | Proposed effective date |
| 18 PAH 1 |
| ≤ 50 mg/kg (sum of all PAH in dry mass of clay target)² | One year from date of entry into force |
Table 1
¹See Table 2 for full list
²Aligns with existing rules for clay targets in competitions under the International Sport Shooting Federation (ISSF)
| Item | PAH | CAS | Item | PAH | CAS |
| 1 | Acenaphthene | 83-32-9 | 10 | Benzo[k]fluoranthene | 207-08-9 |
| 2 | Acenaphthylene | 208-96-8 | 11 | Chrysene | 218-01-9 |
| 3 | Anthracene | 120-12-7 | 12 | Dibenzo[a,h]anthracene | 53-70-3 |
| 4 | Benzo[a]anthracene | 56-55-3 | 13 | Fluoranthene | 206-44-0 |
| 5 | Benzo[a]pyrene (Benzo[def]chrysene) | 50-32-8 | 14 | Fluorene | 86-73-7 |
| 6 | Benzo[b]fluoranthene (Benzo[e]acephenanthrylene) | 205-99-2 | 15 | Indeno[1,2,3cd]pyrene | 193-39-5 |
| 7 | Benzo[e]pyrene | 192-97-2 | 16 | Naphthalene | 91-20-3 |
| 8 | Benzo[ghi]perylene | 192-97-2 | 17 | Phenanthrene | 85-01-8 |
| 9 | Benzo[j]fluoranthene | 205-82-3 | 18 | Pyrene | 129-00-0 |
Table 2. 18 PAH
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