Position and Comments from Svenskt Forum Concerning the European Chemical Agency’s

Working Paper

2019 – 01- 17

Christer Holmgren

Position and Comments from Svenskt Forum concerning the European Chemical Agency’s Annex XV Investigation Report

The Swedish Forum for Hunting, Shooting and Weapon Issues (Svenskt Forum) motes the failure to meet requirements for reasonable objectivity and the lack of technical insight into weapons and ammunition and solid scientific foundations for various standpoints in crucial parts of the European Chemical Agency’s (ECHA) Annex XV Investigation Report.

Svenskt Forum’s general understanding is that, to a large extent those activities undertake on issues regarding lead ammunition both in Sweden and Europe as a whole have a direct political agenda intended to support hastily concluded policy decisions in order to achieve a ‘non-toxic’ environment.

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