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EU REACH Restricts PAHs in Clay Targets for Shooting

EU REACH is restricting PAHs in clay targets for shooting with 0.05% of concentration limit from April 22, 2026.

On April 2, 2025, European Commission issued Regulation (EU) 2025/660 to regulate 18 polycyclic aromatic hydrocarbons (PAHs) in clay targets used for shooting under Annex XVII of the REACH Regulation (Regulation (EC) No 1907/2006). This regulation shall come into force on April 22, 2025. 

Clay targets are flying (saucer-shaped) targets used by sports shooters and small game hunters to practice. They are produced using binders such as coal tar pitch, high temperature ("CTPHT"), petroleum pitch or other types of resins.

CTPHT is identified as a substance of very high concern (SVHC) due to its carcinogenic, PBT and vPvB properties and it is included in Annex XIV to Regulation (EC) No 1907/2006.  Those properties are due to the presence of PAHs in CTPHT.

According to the regulation, a new entry of 50a for PAHs is inserted to the Annex XVII to Regulation (EC) No 1907/2006 (Restriction List). The restriction includes a one-year transitional period to allow producers to adapt to new binders with low or no PAH content, ensuring minimal disruption to supply chains. The details are as follows: 

Regulated substancesRestrictionConcentration limitEffective date 
18 PAHsshall not be placed on the the market or used, on their own or as constituents of other substances, in clay targets for shooting50 mg/kg (0,005 % by weight)2026.4.22

The details of 18 PAHs are shown below: 

Substances nameCAS number 
Acenaphthene83-32-9
Acenaphthylene208-96-8
Anthracene120-12-7
Benzo[a]anthracene56-55-3
Benzo[a]pyrene50-32-8
Benzo[b]fluoranthene205-99-2
Benzo[e]pyrene192-97-2
Benzo[ghi]perylene191-24-2
Benzo[j]fluoranthene205-82-3
Benzo[k]fluoranthene207-08-9
Chrysene218-01-9
Dibenzo[a,h]anthracene53-70-3
Fluoranthene206-44-0
Fluorene86-73-7
Indeno[1,2,3cd]pyrene193-39-5
Naphthalene91-20-3
Phenanthrene85-01-8
Pyrene129-00-0
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