SG 053/25
The European Union (EU) has restricted the use of 18 polycyclic aromatic hydrocarbons (PAH) in clay targets under REACH. The restrictions will apply from April 22, 2026.
On April 2, 2025, the EU issued Commission Regulation (EU) 2025/660 to regulate 18 PAH in clay targets (also known as clay pigeons) for shooting under new entry 50a to Annex XVII of Regulation (EC) No. 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals’ (Annex XVII of REACH, consolidated version to December 2024).
These flying saucer-shaped targets, used by sports shooters and small game hunters for practice, are produced using binders such as coal tar pitch, high temperature (CTPHT), petroleum pitch or other types of resin.
CTPHT is classified as 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). Its carcinogenic, persistent, bio-accumulative and toxic (PBT) and very persistent and very bio-accumulative (vPvB) properties are due to the presence of PAH within the substance.
Applications for authorization to use CTPHT as a binder for manufacturing 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 placement of substances in articles on the market, there are concerns over the release of PAH from clay targets containing CTPHT being imported into the EU.
Highlights of the new law on PAH in clay targets are summarized in Table 1.
| Substance | Scope | Requirement | Effective date |
|---|---|---|---|
| 18 PAH¹ |
| ≤ 50 mg/kg (sum of listed PAH in dry mass of clay target)² | April 22, 2026 |
| ¹ See Table 2 for the list of 18 PAH ² Aligns with existing rules for clay targets in competitions under the International Sport Shooting Federation (ISSF) | |||
Table 1
| 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 | 191-24-2 | 17 | Phenanthrene | 85-01-8 |
| 9 | Benzo[j]fluoranthene | 205-82-3 | 18 | Pyrene | 129-00-0 |
Table 2. 18 PAH listed under entry 50a to Annex XVII of REACH
Commission Regulation (EU) 2025/660 will enter into force on April 22, 2025, 20 days after its publication in the Official Journal of the EU (OJEU).
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