EU REACH Adds PAH Restrictions on Clay Targets

 EU REACH Adds PAH Restrictions on Clay Targets



The EU REACH regulation has added restrictions on PAHs in clay targets, effective April 22nd.


The European Commission's Regulation (EU) 2025/660 adds clause 50a to Annex XVII of the REACH regulation, setting concentration limits for 18 polycyclic aromatic hydrocarbons (PAHs) in clay targets used in shooting sports.


Key Information:


- Regulation Number: (EU) 2025/660


- Publication Date: April 2, 2025 (Official Journal of the European Union)


- Effective Date: April 22, 2025


- Implementation Date: April 22, 2026


Scope of Impact: Primarily affects manufacturers of shooting sports equipment and manufacturers of clay targets exporting to Europe. Although this regulation targets a relatively specific product category, it signals that the EU is continuously tightening its control over PAHs and may subsequently expand to more consumer product categories. Recommendations: If your product involves plastic/rubber materials and is targeted at the EU market, it is recommended to continuously monitor updates to REACH Annex XVII.


Q: What are the main sources of PAHs in clay targets?


A: They mainly originate from bitumen binders, carbon black fillers, and rubber/plastic additives. Traditional clay targets often use bitumen or tar as binders, which naturally contain polycyclic aromatic hydrocarbons (PAHs). Recycled rubber or certain plasticizers used in some synthetic target materials may also introduce PAH contamination.


Q: How can companies verify that their products comply with the new PAH limits?


A: Companies should commission a laboratory with ISO 17025 accreditation to use GC-MS (Gas Chromatography-Mass Spectrometry) or HPLC-FLD (High Performance Liquid Chromatography-Fluorescence Detection) methods to test the total amount and individual concentrations of the 18 controlled PAHs, ensuring compliance with the limits specified in Section 50a of REACH Annex XVII, and retain the test report for verification by market regulatory agencies.


Q: Will this regulation affect other types of shooting sports equipment? A: Current regulations explicitly limit the use to "clay targets," but given the EU's continued expansion of PAHs controls, it is recommended that shooting sports equipment manufacturers (such as stock rubber pads, cartridge case plastic components, etc.) proactively assess product risks and pay attention to subsequent revisions to REACH Annex XVII.

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