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order the annulment and repeal of Commission Regulation (EU) 2021/57 of 25 January 2021 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards lead in gunshot in or around wetlands. (1)

1.

First plea in law, alleging infringement of the provisions of the Charter of Fundamental Rights of the European Union (2) (Article 16, Article 17(1), Article 21(1), Article 45(1) and Article 48(1)) through limitation of the freedom to take up and pursue a business connected with shooting; limitation of the right to property as well as the use and disposal of firearms, ammunition containing lead, and facilities constituting shooting ranges; discrimination against target shooters and hunters; limitation of the possibility of movement with ammunition containing lead; and introduction of a presumption that persons who move in ‘wetlands’ with ammunition containing lead are guilty of being persons who shoot in ‘wetlands’ using ammunition containing lead and, therefore, persons acting in breach of the prohibition.

2.

Second plea in law, alleging infringement of the provisions of the Treaty on European Union (3) (Article 2 and Article 3(2) and (3)) through disregard for the freedom and right to hunt and target shoot; failure to observe the rule of law through introduction of a presumption that persons who move in ‘wetlands’ with ammunition containing lead are guilty of being persons who shoot in ‘wetlands’ using ammunition containing lead; and infringement of the sense of security through introduction of provisions which make it impossible for a person to identify ‘wetlands’ and, therefore, the territorial scope of the prohibition and, accordingly, to tailor his or her conduct to the provisions in force.

3.

Third plea in law, alleging infringement of the provisions of the Treaty on European Union (Article 5(2), (3) and (4)) through infringement of the principle of conferral, consisting of the undertaking of actions which could have been satisfactorily undertaken by the Member States, and through extension of the form and content of those actions beyond what is necessary to achieve the objectives of the Treaties.

4.

Fourth plea in law, alleging abuse of power through the adoption of a regulation whose purpose was to significantly limit the practice of marksmanship by civilians in the territory of the European Union.