Identification and traceability of explosives
The UK has left the EU, new rules from January 2021
The transition period after Brexit comes to an end this year.
Manufacturers or importers are required to mark most civil explosives with a unique identification code. Where it is required the unique identification code must be marked on (or in certain cases attached to) each individual item. Different marking requirements apply depending on the size of the explosive. This requirement applies to all civil use explosives, covered by Directive 2014/28/EU, manufactured or imported after 5 April 2013. It does not apply to civil use explosives manufactured or imported before 5 April 2013 which can be placed on the market and transported throughout the EU provided that all other requirements of the Directive are met.
European Directive 2008/43/EC introduced marking and record keeping requirements for civil use explosives across Europe and set in place a system for the identification and traceability of explosives at every point in the supply chain. This followed security issues raised by the Madrid train bombings in 2004, which killed 191 people, and injured over 1800 others.
In 2012, Directive 2008/43/EC was amended by Directive 2012/4/EU. The amendments removed some items from scope, delayed the coming into force date, and provided more certainty in relation to the marking requirements for small explosives items
Marking of items
The marking must be firmly affixed to the article in a durable and legible way.
The unique identification is described in Schedule 6 of ER2014 and is made up of:
- the name of the manufacturer
- an alphanumeric code detailing the state of manufacture or importation onto the market of the European Economic Area
- the manufacturing site code
- the unique product code and the logistical information designed by the manufacturer.
- the marking must include a machine readable barcode or matrix code, or both, which relate directly to the alphanumeric code and Schedule 7 of the regulations describe how the unique identification should be affixed to different types of civil explosives
Items too small to mark individually
If the explosive is too small to be marked with all of this information only some of the information will be required. Schedule 7 of the regulations details this information.
Exceptions to marking requirements
Manufacturers are not required to mark civil explosives that are manufactured for export providing that the civil explosives are marked in accordance with identification in accordance with the traceability requirements of the importing country.
Importers are not required to mark civil explosives if they are already marked with a unique identification compliant with Schedule 6 of the regulations.
The requirement to mark civil explosives does not apply to:
- an explosive which is transported and delivered without packaging or in a mobile explosives manufacturing unit for its direct unloading into the blast-hole
- fuses, which are cord-like non-detonating igniting devices
- safety fuses, which consist of a core of fine grained black powder surrounded by a flexible woven fabric with one or more protective outer coverings and which, when ignited, burn at a predetermined rate without any external explosive effect
- cap-type primers, which consist of a metal or plastic cap containing a small amount of primary explosive mixture that is readily ignited by impact and which serve as igniting elements in small arms cartridges or in percussion primers for propelling charges
L151 Explosives Regulations 2014 Guidance on Regulations – Security provisions provides further information on the marking of items.
Find out more about unique identification requirements.
The European commission have produced a set of questions and answers concerning the implementation of Directive 93/15/EEC which provides additional guidance on this topic.