Transfer of explosives
This page contains information on the controls that apply to the transfer of civil explosives within Great Britain (GB) under regulation 8 of the Explosives Regulations 2014. It outlines the responsibilities for those involved in the transfer of explosives, the documentation required and how to apply for it.
Parallel regulations apply in Northern Ireland.
What is a transfer of explosives?
A transfer means the physical movement of explosives from one place to another. Moving explosives within a site (such as a factory, mine, quarry or construction site) is exempt from the Regulations.
There are some prohibitions concerning the transfer of relevant explosives (those which require an explosives certificate to acquire or acquire and keep). These prohibitions are covered in regulation 31 of the Explosives Regulations 2014.
Before any civil explosives are transferred, the consignee must obtain approval for the transfer.
Many civil explosives will also be relevant explosives, which are explosives for which an explosives certificate is required. See authorisations for further information on explosives certificates.
Who does the regulation 8 apply to?
The regulation applies to anyone who transfers explosives, be they individuals or companies.
Does the regulation apply to all explosives?
Regulation 8 applies to the transfers of ALL explosives which have been, or would be classified in accordance with the UN recommendations as falling within class 1– except:
- ammunition, the acquisition of which is regulated or prohibited by virtue of the Firearms Act 1968-1997
- pyrotechnic articles, including explosives articles in airbags and seat belt pre-tensioners
- explosives intended for lawful use by the police or armed forces
- explosives seized by customs officers, police, local authority, HSE or ONR
- the components of small arms ammunition when being transferred for the recipient’s private use. (The commercial transfers of components of small arms ammunition are subject to the transfer controls.)
In relation to the exclusion for 'explosives intended for lawful use by the police or armed forces' this refers to the 'intended use'. In this context, a distinction needs to be drawn between the immediate use and possible eventual use for military purposes. A starting point for determining whether the explosive falls within the exclusion would be whether the explosive falls within the UK Military List. In principle, such explosives could be regarded as military explosives. However, the possibility of dual use cannot be excluded. If the immediate consignee is a commercial company, the rules of the Directive should apply up to the point it becomes clear the ultimate use is military.
If the explosive is not on the UK military list it should be regarded as a commercial explosive and treated accordingly unless the consignee is the armed forces or the police.
What transfer document do I need?
There are two types of transfer document which may be required for the transfer of explosives.
- For domestic transfers of civil explosives within the UK a Recipient Competent Authority document (RCA) is required.
- For transfers of civil explosives from outside the UK into GB you will require a GB transfer approval.
You may require both documents.
Domestic transfers covered by an RCA document
In England and Wales - All new explosives certificates (acquire and keep) issued by the police should include an RCA document. You should contact your local police explosives liaison officer if an RCA was not included with your explosives certificate.
In Scotland - Holders of explosives certificates from Police Scotland should apply to HSE for an RCA document.
Your RCA document will include the UN Numbers of the explosives shown on your explosives certificate. It will also include the UN Numbers for those explosives to which the transfer requirements apply but which do not require an explosives certificate to acquire and keep (eg smokeless powder) that you have indicated on your application form. The RCA document's expiry date will be the same as the expiry date on your explosives certificate.
If you require an RCA document but do not hold an explosives certificate, as you only acquire or keep explosives contained on Schedule 2 to ER2014, contact the HSE Explosives Inspectorate clearly stating which explosives you wish to transfer.
The Regulations require you to keep the RCA document or a certified copy for a period of three years from completion of the transfer. In practice, this normally means three years after expiry of the RCA document.
Transfers from outside the UK into GB
Transfers of civil explosives into GB from outside the UK require authorisation from HSE and a GB transfer approval. Applications can be made using the GB transfer approval form. This is in addition to any requirement for an RCA.
The GB transfer approval form includes a requirement for you to notify HSE of the manufacturers’ site codes (traceability codes) for explosives in the consignment.
If the explosives are being transferred through any EU member states before being transferred into GB then you will also need to obtain authorisation through an intra community transfer (ICT). You should apply to the competent authority of the EU member state on the itinerary immediately preceding entry into GB for the ICT.
Incomplete/inaccurate applications or failure to allow sufficient time for your application to be processed may result in delays to your consignment.
It is your duty to ensure that the explosives being transferred have been properly classified by a Competent Authority of a Contracting Party to the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR). The application of ADR in the UK is unaffected by the UK’s Exit from the EU. For information on classification of explosives see Classification of Explosives.
The documents must accompany the explosives at all times until they arrive at their destination.