---
title: "ExplD — Civil Explosives Directive"
description: "The Civil Explosives Directive requires explosives for civil uses to meet the essential safety requirements of Annex II, notified-body assessment, CE marking and a unique identification, while manufacturers, importers, distributors and every operator handling explosives must hold a licence or authorisation. It has applied since 20 April 2016, replacing Directive 93/15/EEC, and is unamended."
type: "guide"
url: "https://www.conphora.com/regulations/expld/"
markdown: "https://www.conphora.com/regulations/expld.md"
locale: "en"
language: "en"
published: "2014-04-18"
updated: "2026-09-12"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Directive 2014/28/EU"
celex: "32014L0028"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0028"
tags: ["ExplD", "CE / Product Safety"]
license: "Free to quote with attribution and a link to the page"
---

# ExplD — Civil Explosives Directive

The Civil Explosives Directive requires explosives for civil uses to meet the essential safety requirements of Annex II, notified-body assessment, CE marking and a unique identification, while manufacturers, importers, distributors and every operator handling explosives must hold a licence or authorisation. It has applied since 20 April 2016, replacing Directive 93/15/EEC, and is unamended.

## Key facts

- **Official title:** Directive 2014/28/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to the making available on the market and supervision of explosives for civil uses (recast)
- **Reference:** Directive 2014/28/EU
- **CELEX:** 32014L0028
- **Act type:** Directive
- **In force:** 2014-04-18
- **Applies from:** 2016-04-20
- **Enforced by:** National market surveillance authorities enforce the national laws transposing the directive with the powers of Regulation (EU) 2019/1020 (the directive still cites Articles 16 to 29 of Regulation (EC) No 765/2008, read as Regulation (EU) 2019/1020 since 16 July 2021), and the competent authorities named for transfers, licences and seizures apply the security chapter; in Denmark the directive is implemented by Justitsministeriet's executive order nr. 1251 of 29 October 2025 on explosives under the weapons and explosives act, permits to trade, store, transfer, acquire and use explosives are issued by the police (politidirektøren i Midt- og Vestjyllands Politi), which the order makes the supervisory authority for the permits it provides for (§ 13(4)), and Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, has controlled explosives for civil uses on behalf of Justitsministeriet since 1 August 2018. The toolkit is corrective action within a set period, prohibition or restriction of the making available, withdrawal or recall, orders to end formal non-compliance such as missing CE marking, notified-body number, declaration or identification, seizure of explosives that will be illicitly acquired, used or dealt in, and national penalties that must be effective, proportionate and dissuasive and may include criminal penalties for serious infringements.
- **Category:** CE / Product Safety

## Who it applies to

**Covered by the act:** Explosives for civil uses: the materials and articles considered to be explosives in the United Nations recommendations on the transport of dangerous goods and falling within Class 1 of those recommendations; Blasting explosives, detonating cords, safety fuses, other fuses and shock tubes, detonators and relays, and propellants and rocket propellants, the four groups given special requirements in Annex II; Explosives made available on the Union market in the course of a commercial activity, whether in return for payment or free of charge, and explosives a manufacturer uses for his own purposes; Explosives transferred within the Union, meaning any physical movement except movements within one and the same site, which need the approval of the competent authority of the Member State of the consignee; The economic operators: manufacturers, authorised representatives, importers, distributors and any natural or legal person who engages in the storage, use, transfer, import, export or trade of explosives

**Derived and downstream products:** Ammunition is outside the directive except for the transfer procedure, the security derogations and the information-exchange networks of Articles 12 to 14 (Art. 1(2)(c)); Explosives that conform to harmonised standards, or parts of them, whose references are published in the Official Journal are presumed to conform to the Annex II essential safety requirements those standards cover (Art. 19); An importer or distributor that places an explosive on the market under its own name or trade mark, or modifies an explosive in a way that may affect compliance, is treated as the manufacturer (Art. 9); The unique identification and traceability system does not apply to explosives transported and delivered unpackaged or in pump trucks for direct unloading into the blast-hole, or to explosives manufactured at blasting sites and loaded immediately (in situ production); for those, and for explosives manufactured for own use, the CE marking goes on the accompanying documents (Art. 15(1) and Art. 23(5)); Until the Commission adopts implementing acts under Article 15, Directive 2008/43/EC as amended by Directive 2012/4/EU continues to set the format of the unique identification and the record-keeping duties (Art. 51(3)); Where an explosive is also subject to other Union acts requiring an EU declaration of conformity, a single declaration covering all of them is drawn up (Art. 21(3)); Member States may designate substances not covered by the directive as explosives under national law (Art. 1(3))

**Roles under the act:**

- **Manufacturer (including brand owners and own-use manufacturers)** — Any natural or legal person who manufactures an explosive or has an explosive designed or manufactured, and markets that explosive under his name or trade mark or uses it for his own purposes; an importer or distributor that sells under its own name or trade mark or modifies an explosive in a way that may affect compliance is treated as the manufacturer.
- **Authorised representative** — Any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specified tasks; the mandate cannot cover the duty to design and manufacture to the essential safety requirements or to draw up the technical documentation.
- **Importer** — Any natural or legal person established within the Union who places an explosive from a third country on the Union market.
- **Distributor (wholesaler or retailer of explosives)** — Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes an explosive available on the market. The separately defined 'dealer' is a person whose occupation consists wholly or partly in the manufacture, trade, exchange, hiring out, repair or conversion of firearms and ammunition, and appears only in the ammunition transfer procedure.
- **Other economic operator (storage, use, transfer, import, export or trade of explosives)** — Besides the manufacturer, authorised representative, importer and distributor, the directive's economic operators include any natural or legal person who engages in the storage, use, transfer, import, export or trade of explosives, such as blasting contractors, quarries and mines; they must hold a licence or authorisation, obtain transfer approvals and take part in the unique identification and traceability system.

## Key dates

- 2014-02-26: Directive 2014/28/EU adopted by the European Parliament and the Council as a recast of Directive 93/15/EEC aligned with the New Legislative Framework
- 2014-04-18: Entry into force, the twentieth day after publication in OJ L 96 of 29 March 2014; the delegation of power to update Annex I runs from this date
- 2015-04-05: The data-collection and record-keeping duties of the unique identification and traceability system of Directive 2008/43/EC (Article 3(6) and Articles 13 and 14) apply; the marking duties had applied since 5 April 2013
- 2016-04-19: Deadline for Member States to adopt and publish the laws transposing the operative provisions listed in Article 52(1), including Articles 3 to 10, Articles 15 and 16, Articles 21 to 27, Articles 29 to 45, Articles 50 and 51 and Annexes III and IV
- 2016-04-20: National measures apply; Article 1, points 1, 3 to 6 and 14 of Article 2, Articles 11, 12 and 13, Article 14(2), Articles 17 to 19, the Module D, E, F and G references in Article 20, Article 28(5), (8) and (9), Articles 46 to 49 and Annexes I, II, V and VI apply directly; Directive 93/15/EEC and Directive 2004/57/EC repealed; explosives conforming to Directive 93/15/EEC and placed on the market before this date may still be made available and certificates issued under it stay valid
- 2021-07-16: Regulation (EU) 2019/1020 applies: it deletes Chapter III, Articles 15 to 29, of Regulation (EC) No 765/2008, of which Article 41 of the directive applies Articles 16 to 29 to explosives, and it lists Directive 2014/28/EU as point 47 of its Annex I

## What you must do

### Manufacturer (including brand owners and own-use manufacturers)

- Design and manufacture the explosive, whether you place it on the market or use it for your own purposes, in accordance with the Annex II essential safety requirements: minimal risk to life, health, property and the environment under normal foreseeable conditions, the performance characteristics you specify, safe disposal, the tested properties listed in Annex II part II (composition, stability, sensitiveness to impact and friction, purity, water and temperature resistance, safety features against untimely initiation, instructions and markings) and the special requirements for blasting explosives, cords and fuses, detonators and propellants.
- Draw up the technical documentation, including an analysis and assessment of the risks, a general description, design and manufacturing drawings, the harmonised standards applied or the solutions adopted instead, design calculations and test reports, and have a notified body carry out EU-type examination (Module B) followed by Module C2, D, E or F, or conformity based on unit verification (Module G).
- Draw up the technical documentation, including an analysis and assessment of the risks, a general description, design and manufacturing drawings, the harmonised standards applied or the solutions adopted instead, design calculations and test reports.
- Have a notified body carry out EU-type examination (Module B) followed by Module C2, D, E or F, or conformity based on unit verification (Module G).
- Draw up the EU declaration of conformity per Annex IV once the procedure has demonstrated compliance, keep it continuously updated and translated into the languages the Member State requires, combine it with the declarations other Union acts require into a single declaration, and affix the CE marking followed by the identification number of the notified body involved in the production control phase.
- Draw up the EU declaration of conformity per Annex IV once the procedure has demonstrated compliance, keep it continuously updated and translated into the languages the Member State requires, and combine it with the declarations other Union acts require into a single declaration.
- Affix the CE marking to the explosive, followed by the identification number of the notified body involved in the production control phase.
- Keep the technical documentation and the EU declaration of conformity, together with the EU-type examination certificate and its additions, at the disposal of the national authorities for 10 years after the explosive was placed on the market.
- Keep series production in conformity, taking account of changes in design or characteristics and in the harmonised standards or technical specifications by reference to which conformity is declared, and inform the notified body that holds the type certificate of any modification to the approved type that may affect conformity or the certificate's validity.
- Keep series production in conformity, taking account of changes in design or characteristics and in the harmonised standards or technical specifications by reference to which conformity is declared.
- Inform the notified body that holds the EU-type examination certificate of any modification to the approved type that may affect conformity with the essential safety requirements or the validity of the certificate.
- Mark each explosive you place on the market with a unique identification under the Article 15 system, which under Directive 2008/43/EC means a human-readable part (manufacturer name, a two-letter Member State code, a three-digit manufacturing-site code attributed by the national authority, and your product and logistical code) plus a barcode or matrix code, on the explosive and each smallest packaging unit; where the explosive is excluded from the system, mark it with a type, batch or serial number and your name, registered trade name or trade mark and a single postal contact address, or put that information on the packaging or an accompanying document.
- Mark each explosive you place on the market, and each smallest packaging unit, with a unique identification under the Article 15 system: a human-readable part (manufacturer name, a two-letter Member State code, a three-digit manufacturing-site code attributed by the national authority, and your product and logistical code) plus a barcode or matrix code.
- Where the explosive is excluded from the unique identification system, mark it with a type, batch or serial number and your name, registered trade name or trade mark and a single postal contact address, or put that information on the packaging or an accompanying document.
- Supply instructions and safety information in a language easily understood by end-users as determined by the Member State, clear, understandable and intelligible, together with any labelling.
- If you consider or have reason to believe that an explosive you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States where you made it available; on reasoned request provide all conformity information and documentation in a language the authority understands and cooperate on risk-elimination measures.
- If you consider or have reason to believe that an explosive you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States where you made it available.
- On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you placed on the market.

### Authorised representative

- Act under a written mandate that at least lets you keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the explosive was placed on the market.
- Act as authorised representative only under a written mandate from the manufacturer that sets out the tasks you perform.
- Keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the explosive was placed on the market.
- On reasoned request, provide the competent national authority with all the information and documentation necessary to demonstrate the conformity of the explosive, and cooperate with the authorities on any action taken to eliminate the risks posed by the explosives covered by your mandate.
- Do not take over the manufacturer's duty to design and manufacture to the essential safety requirements or to draw up the technical documentation; those cannot form part of the mandate, although the mandate may let you lodge the EU-type examination application and keep the certificate and documentation on the manufacturer's behalf.
- For explosives outside the unique identification system, be able to identify to the market surveillance authorities the operators that supplied you and that you supplied for 10 years after the supply.

### Importer

- Place only compliant explosives on the market, and before doing so ensure that the manufacturer has carried out the appropriate Article 20 conformity assessment procedure, drawn up the technical documentation, affixed the CE marking, supplied the required documents and applied the unique identification or the identification and address markings; hold back an explosive you have reason to believe does not meet Annex II and, where it presents a risk, inform the manufacturer and the market surveillance authorities.
- Indicate your name, registered trade name or registered trade mark and a postal contact address on the explosive or, where that is not possible, on its packaging or in an accompanying document, in a language easily understood by end-users and market surveillance authorities.
- Ensure the explosive is accompanied by instructions and safety information in a language easily understood by end-users as determined by the Member State concerned.
- Keep storage and transport conditions while the explosive is under your responsibility from jeopardising compliance with the Annex II essential safety requirements.
- If an explosive you placed on the market does not conform, immediately take corrective measures, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned with details of the non-compliance and the corrective measures.
- Keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 10 years after the explosive was placed on the market, ensure the technical documentation can be made available on request, provide conformity information on reasoned request in a language the authority understands and cooperate on risk-elimination measures.
- Keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 10 years after the explosive was placed on the market, and ensure the technical documentation can be made available to them on request.
- On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you placed on the market.
- Where the manufacturing site is outside the Union and the manufacturer is not established in the Union, contact a national authority of the Member State of import so that the site is attributed the three-digit code used in the unique identification; where the manufacturer is established in the Union, it is the manufacturer who must do so. If you place explosives on the market under your own name or trade mark, or modify an explosive already placed on the market in a way that may affect compliance, you carry the manufacturer's obligations under Article 5.
- Where the manufacturing site is outside the Union and the manufacturer is not established in the Union, contact a national authority of the Member State of import so that the site is attributed the three-digit code used in the unique identification.
- If you place explosives on the market under your own name or trade mark, or modify an explosive already placed on the market in a way that may affect compliance, you carry the manufacturer's obligations under Article 5.

### Distributor (wholesaler or retailer of explosives)

- Act with due care and, before making an explosive available, verify that it bears the CE marking, is accompanied by the required documents and by instructions and safety information in a language easily understood by end-users in the Member State where it is sold, and that the manufacturer and the importer have applied the unique identification or the identification and address markings; hold back an explosive you have reason to believe does not meet Annex II and, where it presents a risk, inform the manufacturer or importer and the market surveillance authorities.
- Keep storage and transport conditions while the explosive is under your responsibility from jeopardising compliance with the Annex II essential safety requirements, and if you repackage explosives make sure the unique identification is affixed to the explosive and the smallest packaging unit.
- While an explosive is under your responsibility, keep its storage and transport conditions from jeopardising its compliance with the Annex II essential safety requirements.
- If you repackage explosives, make sure the unique identification is affixed to the explosive and to the smallest packaging unit.
- If an explosive you made available does not conform, make sure corrective measures are taken to bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned.
- On reasoned request, provide the information and documentation demonstrating conformity and cooperate on risk-elimination measures; for explosives outside the unique identification system, identify your suppliers and customers for 10 years.
- On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you made available.
- For explosives outside the unique identification system, be able to identify to the market surveillance authorities, for 10 years after the supply, every economic operator that supplied you and every economic operator you supplied.
- If you sell under your own name or trade mark or modify an explosive in a way that may affect compliance, you take on the manufacturer's obligations under Article 5.

### Other economic operator (storage, use, transfer, import, export or trade of explosives)

- Hold a licence or authorisation entitling you to engage in the manufacture, storage, use, import, export, transfer or trade of explosives; employees of a licensed operator do not need their own, and a manufacturing licence is issued only after the Member State has checked that you can comply with the technical commitments you assume.
- Transfer explosives only after the consignee has obtained approval from the competent authority of its Member State and, for movements through another Member State, after you have notified and obtained the prior approval of the transit Member State; carry the approval document with the explosives to their destination, produce it on request and keep a copy as consignee.
- Where a Member State requires special supervision, provide before the transfer the names and addresses of the operators, the number and quantity of explosives, their full description and identification including the UN number, the compliance information for explosives to be placed on the market, the means of transfer and itinerary, the expected dates and where necessary the points of entry and exit; where no special security requirements apply, the authority may instead grant a fixed-period approval.
- Adhere to the uniform system for the unique identification and traceability of explosives: collect and store the data identifying each explosive, its location while in your possession and the identity of the operators, test and protect the data, keep it for 10 years after the transaction or, where the explosive was used or disposed of, 10 years after use or disposal even if you cease trading, and make it immediately available to the competent authorities.
- Keep a record of all identifications of the explosives you hold with the type and the person to whose custody each was given, record the location of each explosive until it is transferred or used, name a person who can supply that information outside normal business hours, and forward on request all relevant transfer information to the authorities of the Member States of departure and transit.

## Requirements

Each duty above as an identified requirement (39); ids are permanent and shared with the compliance engine.

### evidence

- `expld-mfr-design-manufacture-explosive` (Manufacturer (including brand owners and own-use manufacturers), product, before-market) — Design and manufacture the explosive, whether you place it on the market or use it for your own purposes, in accordance with the Annex II essential safety requirements: minimal risk to life, health, property and the environment under normal foreseeable conditions, the performance characteristics you specify, safe disposal, the tested properties listed in Annex II part II (composition, stability, sensitiveness to impact and friction, purity, water and temperature resistance, safety features against untimely initiation, instructions and markings) and the special requirements for blasting explosives, cords and fuses, detonators and propellants. [Art. 5(1) and Annex II]
- `expld-mfr-compile-technical-documentation` (Manufacturer (including brand owners and own-use manufacturers), product, before-market) — Draw up the technical documentation, including an analysis and assessment of the risks, a general description, design and manufacturing drawings, the harmonised standards applied or the solutions adopted instead, design calculations and test reports. [Art. 5(2) and Annex III, Module B, point 3]
- `expld-mfr-draw-eu-declaration` (Manufacturer (including brand owners and own-use manufacturers), product-market, before-market) — Draw up the EU declaration of conformity per Annex IV once the procedure has demonstrated compliance, keep it continuously updated and translated into the languages the Member State requires, and combine it with the declarations other Union acts require into a single declaration. [Art. 5(2), Art. 21 and Annex IV]
- `expld-mfr-supply-instructions-safety` (Manufacturer (including brand owners and own-use manufacturers), product-market, before-market) — Supply instructions and safety information in a language easily understood by end-users as determined by the Member State, clear, understandable and intelligible, together with any labelling. [Art. 5(6)]
- `expld-oth-hold-written-mandate` (Authorised representative, company, before-market) — Act as authorised representative only under a written mandate from the manufacturer that sets out the tasks you perform. [Art. 6(1) and Art. 6(2)]

### mark

- `expld-mfr-affix-ce-marking` (Manufacturer (including brand owners and own-use manufacturers), product, before-market) — Affix the CE marking to the explosive, followed by the identification number of the notified body involved in the production control phase. [Art. 5(2) and Art. 23(3)]
- `expld-mfr-mark-unique-identification` (Manufacturer (including brand owners and own-use manufacturers), unit, before-market) — Mark each explosive you place on the market, and each smallest packaging unit, with a unique identification under the Article 15 system: a human-readable part (manufacturer name, a two-letter Member State code, a three-digit manufacturing-site code attributed by the national authority, and your product and logistical code) plus a barcode or matrix code. [Art. 5(5) and Art. 15; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0043-20120314 · Art. 3, Art. 4 and Annex]
- `expld-mfr-mark-type-name-address` (Manufacturer (including brand owners and own-use manufacturers), product, before-market) — Where the explosive is excluded from the unique identification system, mark it with a type, batch or serial number and your name, registered trade name or trade mark and a single postal contact address, or put that information on the packaging or an accompanying document. [Art. 5(5)(a) and (b)]
- `expld-imp-indicate-name-registered` (Importer, product, before-market) — Indicate your name, registered trade name or registered trade mark and a postal contact address on the explosive or, where that is not possible, on its packaging or in an accompanying document, in a language easily understood by end-users and market surveillance authorities. [Art. 7(3)]
- `expld-dist-mark-repackaged-explosives` (Distributor (wholesaler or retailer of explosives), unit, on-event) — If you repackage explosives, make sure the unique identification is affixed to the explosive and to the smallest packaging unit. [Art. 3(6)]

### procedure

- `expld-mfr-carry-out-conformity-assessment` (Manufacturer (including brand owners and own-use manufacturers), product, before-market) — Have a notified body carry out EU-type examination (Module B) followed by Module C2, D, E or F, or conformity based on unit verification (Module G). [Art. 5(2) and Art. 20]

### submission

- `expld-mfr-inform-notified-body-changes` (Manufacturer (including brand owners and own-use manufacturers), product, on-event) — Inform the notified body that holds the EU-type examination certificate of any modification to the approved type that may affect conformity with the essential safety requirements or the validity of the certificate. [Annex III, Module B, point 7]
- `expld-mfr-correct-withdraw-recall` (Manufacturer (including brand owners and own-use manufacturers), product, on-event) — If you consider or have reason to believe that an explosive you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States where you made it available. [Art. 5(7)]
- `expld-imp-immediately-take-corrective` (Importer, product, on-event) — If an explosive you placed on the market does not conform, immediately take corrective measures, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned with details of the non-compliance and the corrective measures. [Art. 7(6)]
- `expld-imp-request-site-code` (Importer, company, before-market) — Where the manufacturing site is outside the Union and the manufacturer is not established in the Union, contact a national authority of the Member State of import so that the site is attributed the three-digit code used in the unique identification. [Art. 3(5)]
- `expld-dist-make-sure-corrective` (Distributor (wholesaler or retailer of explosives), product, on-event) — If an explosive you made available does not conform, make sure corrective measures are taken to bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned. [Art. 8(4)]
- `expld-op-hold-licence-authorisation` (Other economic operator (storage, use, transfer, import, export or trade of explosives), company, before-market) — Hold a licence or authorisation entitling you to engage in the manufacture, storage, use, import, export, transfer or trade of explosives; employees of a licensed operator do not need their own, and a manufacturing licence is issued only after the Member State has checked that you can comply with the technical commitments you assume. [Art. 16 and Art. 17]
- `expld-op-transfer-explosives-consignee` (Other economic operator (storage, use, transfer, import, export or trade of explosives), lot, per-lot) — Transfer explosives only after the consignee has obtained approval from the competent authority of its Member State and, for movements through another Member State, after you have notified and obtained the prior approval of the transit Member State; carry the approval document with the explosives to their destination, produce it on request and keep a copy as consignee. [Art. 11(2), Art. 11(4) and Art. 11(8)]
- `expld-op-provide-transfer-names` (Other economic operator (storage, use, transfer, import, export or trade of explosives), lot, per-lot) — Where a Member State requires special supervision, provide before the transfer the names and addresses of the operators, the number and quantity of explosives, their full description and identification including the UN number, the compliance information for explosives to be placed on the market, the means of transfer and itinerary, the expected dates and where necessary the points of entry and exit; where no special security requirements apply, the authority may instead grant a fixed-period approval. [Art. 11(5) and Art. 11(6)]

### verification

- `expld-imp-place-compliant-explosives` (Importer, product, before-market) — Place only compliant explosives on the market, and before doing so ensure that the manufacturer has carried out the appropriate Article 20 conformity assessment procedure, drawn up the technical documentation, affixed the CE marking, supplied the required documents and applied the unique identification or the identification and address markings; hold back an explosive you have reason to believe does not meet Annex II and, where it presents a risk, inform the manufacturer and the market surveillance authorities. [Art. 7(1) and Art. 7(2)]
- `expld-imp-ensure-explosive-accompanied` (Importer, product-market, before-market) — Ensure the explosive is accompanied by instructions and safety information in a language easily understood by end-users as determined by the Member State concerned. [Art. 7(4)]
- `expld-dist-act-due-care` (Distributor (wholesaler or retailer of explosives), product-market, before-market) — Act with due care and, before making an explosive available, verify that it bears the CE marking, is accompanied by the required documents and by instructions and safety information in a language easily understood by end-users in the Member State where it is sold, and that the manufacturer and the importer have applied the unique identification or the identification and address markings; hold back an explosive you have reason to believe does not meet Annex II and, where it presents a risk, inform the manufacturer or importer and the market surveillance authorities. [Art. 8(1) and Art. 8(2)]

### standing

- `expld-mfr-keep-technical-documentation` (Manufacturer (including brand owners and own-use manufacturers), product, ongoing) — Keep the technical documentation and the EU declaration of conformity, together with the EU-type examination certificate and its additions, at the disposal of the national authorities for 10 years after the explosive was placed on the market. [Art. 5(3) and Annex III, Module B, point 9]
- `expld-mfr-keep-series-conformity` (Manufacturer (including brand owners and own-use manufacturers), product, ongoing) — Keep series production in conformity, taking account of changes in design or characteristics and in the harmonised standards or technical specifications by reference to which conformity is declared. [Art. 5(4)]
- `expld-mfr-provide-information-request` (Manufacturer (including brand owners and own-use manufacturers), company, ongoing) — On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you placed on the market. [Art. 5(8)]
- `expld-oth-keep-documentation-10-years` (Authorised representative, product, ongoing) — Keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the explosive was placed on the market. [Art. 6(2)(a)]
- `expld-oth-provide-competent-national` (Authorised representative, company, ongoing) — On reasoned request, provide the competent national authority with all the information and documentation necessary to demonstrate the conformity of the explosive, and cooperate with the authorities on any action taken to eliminate the risks posed by the explosives covered by your mandate. [Art. 6(2)(b) and Art. 6(2)(c)]
- `expld-oth-able-identify-market` (Authorised representative, company, ongoing) — For explosives outside the unique identification system, be able to identify to the market surveillance authorities the operators that supplied you and that you supplied for 10 years after the supply. [Art. 10]
- `expld-imp-keep-storage-transport` (Importer, company, ongoing) — Keep storage and transport conditions while the explosive is under your responsibility from jeopardising compliance with the Annex II essential safety requirements. [Art. 7(5)]
- `expld-imp-keep-declaration-copy` (Importer, product, ongoing) — Keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 10 years after the explosive was placed on the market, and ensure the technical documentation can be made available to them on request. [Art. 7(7)]
- `expld-imp-provide-information-request` (Importer, company, ongoing) — On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you placed on the market. [Art. 7(8)]
- `expld-dist-keep-storage-conditions` (Distributor (wholesaler or retailer of explosives), company, ongoing) — While an explosive is under your responsibility, keep its storage and transport conditions from jeopardising its compliance with the Annex II essential safety requirements. [Art. 8(3)]
- `expld-dist-provide-information-request` (Distributor (wholesaler or retailer of explosives), company, ongoing) — On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the explosive, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by explosives you made available. [Art. 8(5)]
- `expld-dist-identify-supply-chain` (Distributor (wholesaler or retailer of explosives), company, ongoing) — For explosives outside the unique identification system, be able to identify to the market surveillance authorities, for 10 years after the supply, every economic operator that supplied you and every economic operator you supplied. [Art. 10]
- `expld-op-adhere-uniform-system` (Other economic operator (storage, use, transfer, import, export or trade of explosives), company, ongoing) — Adhere to the uniform system for the unique identification and traceability of explosives: collect and store the data identifying each explosive, its location while in your possession and the identity of the operators, test and protect the data, keep it for 10 years after the transaction or, where the explosive was used or disposed of, 10 years after use or disposal even if you cease trading, and make it immediately available to the competent authorities. [Art. 15(1) to Art. 15(3)]
- `expld-op-keep-record-identifications` (Other economic operator (storage, use, transfer, import, export or trade of explosives), company, ongoing) — Keep a record of all identifications of the explosives you hold with the type and the person to whose custody each was given, record the location of each explosive until it is transferred or used, name a person who can supply that information outside normal business hours, and forward on request all relevant transfer information to the authorities of the Member States of departure and transit. [Art. 11(7); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0043-20120314 · Art. 13 and Art. 14]

## Penalties

Member States lay down the rules on penalties for infringements of their national transposing laws by economic operators and enforce them; the penalties must be effective, proportionate and dissuasive and may include criminal penalties for serious infringements. Market surveillance authorities evaluate explosives that present a risk to the health or safety of persons, property or the environment, require corrective action, withdrawal or recall within a reasonable period commensurate with the risk, inform the notified body, and if the operator fails to act prohibit or restrict the making available, withdraw or recall the explosive and notify the Commission and the other Member States; compliant explosives that still present a risk can be treated the same way, and the competent authorities may seize any explosive where there is sufficient evidence that it will be illicitly acquired, used or dealt in. Formal non-compliance, such as CE marking missing or wrongly affixed, the notified body's identification number missing, a missing or incorrect EU declaration of conformity, incomplete technical documentation or absent, false or incomplete identification and address information, must be ended and otherwise leads to restriction, prohibition, withdrawal or recall. In Denmark, executive order nr. 1251 of 29 October 2025 on explosives (Justitsministeriet, in force 1 November 2025) makes the directive and Directive 2008/43/EC apply in Denmark, limits permits to trade and market explosives to products meeting Articles 3 to 4, 5(1), 19 and 22 to 23 and Annexes II to IV of the directive and the 2008/43/EC marking rules, requires police permits to trade, store, transfer, acquire and use explosives, and punishes breaches of its sections 2 to 11 and of section 12(4), and breaches of the conditions attached to a permit, with a fine or imprisonment of up to 4 months, or up to 2 years under aggravating circumstances, with companies liable under chapter 5 of the criminal code. The order names only the police as supervisory authority for the permits it provides for (§ 13(4)), and the Danish product act (lov om produkter og markedsovervågning, consolidated as LBK nr. 22 of 8 January 2026) does not list Directive 2014/28/EU among the acts it covers, so the market surveillance of explosives for civil uses rests on the control authority's own published statement that it performs it on behalf of Justitsministeriet, not on a published delegating order. Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, controls explosives for civil uses on behalf of Justitsministeriet and can ask the police to investigate breaches.

## Checklist

1. Confirm the article is an explosive in UN Class 1 for civil use and not a pyrotechnic article under Directive 2013/29/EU, ammunition, an explosive for the armed forces or the police, or a precursor chemical (Article 1, Article 2 and Annex I).
2. Decide your role for each product, remembering that selling under your own name or trade mark, modifying an explosive or using explosives for your own purposes makes you the manufacturer (Article 2, point (9), and Article 9).
3. Obtain the licence or authorisation for manufacturing, storing, using, importing, exporting, transferring or trading explosives before you start; in Denmark the permits come from the police under executive order nr. 1251 of 2025 (Article 16 and Article 17).
4. Identify the harmonised standards for explosives published in the Official Journal and test the product against the Annex II essential safety requirements, including the group requirements for blasting explosives, cords and fuses, detonators or propellants (Article 19 and Annex II).
5. Compile the technical documentation with the risk analysis, drawings, standards applied, calculations and test reports, and apply to a single notified body for EU-type examination, then choose Module C2, D, E or F for production, or use unit verification (Article 20 and Annex III).
6. Draw up the Annex IV EU declaration of conformity, as a single declaration where other Union acts also apply, and keep it and the documentation for 10 years (Article 5(3) and Article 21).
7. Affix the CE marking with the notified body's identification number to the explosive, or to the packaging and documents where the explosive does not allow it, and to the accompanying documents for own-use, MEMU-delivered and in situ explosives (Article 23).
8. Apply the unique identification (site code, product code, barcode or matrix code) to each explosive and smallest packaging unit, or the type or serial number and your name and address where the system does not apply, and add instructions and safety information in the required language (Article 5(5), Article 5(6), Article 7(3) and Directive 2008/43/EC).
9. Set up the traceability records that keep each explosive's identification, custody and location for 10 years, the corrective-action and notification procedure, and the transfer approvals and accompanying document for every movement between Member States (Article 11, Article 15 and Article 5(7)).

## Questions

### When did the Civil Explosives Directive 2014/28/EU start to apply?

The recast directive was adopted on 26 February 2014, published in the Official Journal on 29 March 2014 and entered into force on 18 April 2014. Member States had to transpose the operative provisions by 19 April 2016 and apply them from 20 April 2016, when Directive 93/15/EEC and Directive 2004/57/EC were repealed; the security chapter, the presumption of conformity, the Module D to G references and the annexes apply directly from the same date. Explosives conforming to Directive 93/15/EEC and placed on the market before 20 April 2016 may still be made available, and certificates issued under it remain valid.

### Which products count as explosives for civil uses?

The materials and articles considered to be explosives in the United Nations recommendations on the transport of dangerous goods and falling within Class 1 of those recommendations, such as blasting explosives, detonating cords, safety fuses, shock tubes, detonators, relays, boosters and propellants for civil use. Excluded are explosives, including ammunition, intended for the armed forces or the police, pyrotechnic articles under Directive 2013/29/EU and ammunition, except that the transfer, derogation and information-exchange rules of Articles 12 to 14 also cover ammunition; Annex I lists the UN Class 1 entries treated as pyrotechnic articles or ammunition.

### Do I need a notified body for civil explosives?

Yes. The manufacturer must follow one of the Annex III procedures: EU-type examination (Module B) by a notified body followed, at the manufacturer's choice, by conformity to type based on internal production control plus supervised product checks at random intervals (Module C2), quality assurance of the production process (Module D), product quality assurance (Module E) or product verification (Module F); or conformity based on unit verification (Module G). There is no self-declaration route, and the CE marking is followed by the identification number of the notified body involved in the production control phase.

### What is the unique identification of explosives and who must apply it?

Manufacturers must ensure that explosives they place on the market bear a unique identification under the uniform identification and traceability system of Article 15, and importers and distributors must check it is there. Until the Commission replaces it by implementing acts, the system is the one of Directive 2008/43/EC as amended by Directive 2012/4/EU: undertakings that manufacture or import explosives or assemble detonators mark each explosive and each smallest packaging unit with the manufacturer's name, a two-letter Member State code, a three-digit manufacturing-site code attributed by the national authority and the manufacturer's product and logistical code, plus a barcode or matrix code. The system does not apply to explosives delivered unpackaged or in pump trucks for direct unloading into the blast-hole, explosives produced in situ, ammunition, fuses, safety fuses and cap-type primers.

### How does the approval of transfers of explosives between Member States work?

The consignee obtains approval from the competent authority of its own Member State, which verifies that the consignee is legally authorised to acquire explosives and holds the necessary licences or authorisations; the operator responsible for the transfer notifies each transit Member State and obtains its prior approval. The authority issues a document that accompanies the explosives to their destination and is produced on request, and where special security requirements apply the consignee first supplies the operators' names and addresses, the number, quantity and description of the explosives with their UN number, the means of transfer, itinerary and dates. No operator may transfer explosives unless the consignee holds the necessary authorisations, and Member States may take extra measures against transfers during serious threats to public security.

### How long must records and documents be kept?

Manufacturers keep the technical documentation, the EU declaration of conformity and the EU-type examination certificate for 10 years after the explosive was placed on the market, authorised representatives keep the declaration and documentation at the authorities' disposal for the same period, and importers keep a copy of the declaration for 10 years. The identification and traceability data must be stored for 10 years after the transaction or, where the explosives were used or disposed of, 10 years after their use or disposal, even if the operator has ceased trading; for explosives outside that system, operators identify their suppliers and customers for 10 years.

### Who enforces the Civil Explosives Directive in Denmark and what are the penalties?

Executive order nr. 1251 of 29 October 2025 on explosives, issued by Justitsministeriet under the weapons and explosives act and in force since 1 November 2025, makes Directive 2014/28/EU and Directive 2008/43/EC apply in Denmark and requires police permits to trade, store, transfer, acquire and use explosives, issued by politidirektøren i Midt- og Vestjyllands Politi; permits to trade cover only explosives that meet the directive's Articles 3 to 4, 5(1), 19 and 22 to 23 and Annexes II to IV. Breaches of its sections 2 to 11, of section 12(4), which makes a legal person name a natural person jointly responsible for compliance, or of the conditions attached to a permit are punished with a fine or imprisonment of up to 4 months, or up to 2 years under aggravating circumstances, and companies can be held liable under chapter 5 of the criminal code. Sikkerhedsstyrelsen, since January 2026 the Markedsovervågning department of Erhvervsstyrelsen, has controlled explosives for civil uses on behalf of Justitsministeriet since 1 August 2018 and can ask the police to investigate breaches; suspected non-compliant products are reported to Erhvervsstyrelsen.

### Is the Civil Explosives Directive being revised?

The Commission published its evaluation of the directive on 19 September 2025 (SWD(2025) 266). It found that the directive is performing well on the whole but that some of its provisions are outdated and not fit for the digital age, and said it would reflect on the results and decide whether to launch a revision in line with the ProtectEU internal security strategy. No amending act has been adopted; the directive has not been amended since 2014, and Directive (EU) 2024/2749 on internal market emergency procedures does not cover it.

## What changed

- 2026-09-12 (guidance): **Guide rewritten from the directive text on the SPEC-62 model** — The body was rewritten from the Official Journal text of Directive 2014/28/EU and the consolidated Directive 2008/43/EC: the article numbering now follows the directive (transfers Article 11, unique identification Article 15, licensing Article 16, conformity assessment Article 20, market surveillance Articles 41 to 45, penalties Article 50, transposition Article 52), the exact Annex III module choice and the exclusions are quoted, and the Danish implementation now cites executive order nr. 1251 of 29 October 2025 and the police as permit authority instead of unnamed authorities.
- 2026-02-01 (amendment): **Denmark: the explosives register is widened to every holder of explosives** — Executive order nr. 231 of 29 January 2026 rewords § 10(1) of executive order nr. 1251 of 29 October 2025 on explosives with effect from 1 February 2026. The duty to keep a register of receipts and issues of explosives, with their type, unique identification and storage place and the persons holding them at any time, now falls on any natural or legal person and no longer only on manufacturers and those marketing explosives under their own name or trade mark; only natural persons holding a permit to manufacture, including to reload ammunition, are exempt.
- 2025-09-19 (guidance): **Commission evaluation of the Civil Explosives Directive published** — The Commission staff working document SWD(2025) 266 finds that the directive is performing well on the whole but that some provisions are outdated and not fit for the digital age; the Commission will reflect on the results and decide whether to launch a revision in line with the ProtectEU strategy. No amendment has been adopted.
- 2021-07-16 (applies): **Regulation (EU) 2019/1020 replaces the market surveillance articles of Regulation (EC) No 765/2008** — Chapter III, Articles 15 to 29, of Regulation (EC) No 765/2008 is deleted and replaced by the market surveillance framework of Regulation (EU) 2019/1020, which lists Directive 2014/28/EU as point 47 of its Annex I. Article 41 of the directive applies Articles 16 to 29 of Regulation (EC) No 765/2008 to explosives, so that reference is read as Regulation (EU) 2019/1020 from 16 July 2021, while the CE marking principles of Article 30 of Regulation (EC) No 765/2008 are untouched and continue to apply.
- 2016-04-20 (applies): **Directive 2014/28/EU applies; Directives 93/15/EEC and 2004/57/EC repealed** — Member States apply their transposing measures from 20 April 2016, the directly applicable provisions and Annexes I, II, V and VI apply from the same date, and Directive 93/15/EEC as amended and Directive 2004/57/EC are repealed; explosives conforming to Directive 93/15/EEC and placed on the market before 20 April 2016 may still be made available, certificates issued under it stay valid, and Directive 2008/43/EC continues to apply until replaced by implementing acts under Article 15.
- 2014-04-18 (in-force): **Directive 2014/28/EU enters into force** — Adopted on 26 February 2014 as a recast of Directive 93/15/EEC aligned with the New Legislative Framework and published in OJ L 96 on 29 March 2014, the directive entered into force on the twentieth day after publication; Member States had until 19 April 2016 to transpose it.

## ExplD in plain terms

The Civil Explosives Directive (ExplD), formally Directive 2014/28/EU, is the EU's safety and security law for explosives used outside the military and police sphere: blasting explosives, detonators, detonating cords, fuses, shock tubes, boosters and propellants for civil use. It applies to explosives for civil uses, defined as the materials and articles considered to be explosives in the United Nations recommendations on the transport of dangerous goods and falling within Class 1 of those recommendations (Art. 1(1) and Art. 2, point (1)). Explosives may be made available on the market only if they comply with the directive, and Member States may not prohibit, restrict or hinder explosives that do (Art. 3 and Art. 4).

The directive does two things at once. Its product chapters follow the New Legislative Framework: essential safety requirements in Annex II, notified-body conformity assessment, an EU declaration of conformity and the CE marking (Chapters 2, 4 and 5). Its security chapter adds what other CE directives lack: approvals for every transfer of explosives within the Union, a uniform system of unique identification and traceability, a licence or authorisation for anyone who manufactures, stores, uses, imports, exports, transfers or trades explosives, and the power to seize explosives that will be illicitly acquired, used or dealt in (Chapter 3, Art. 11 to Art. 18). The 2014 text is a recast of Directive 93/15/EEC; Member States had to transpose it by 19 April 2016 and apply it from 20 April 2016 (Art. 52), and it has not been amended since.

> **Official text**
> Read the directive on EUR-Lex: [Directive 2014/28/EU (CELEX 32014L0028)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0028). The unique identification system is set out in [Commission Directive 2008/43/EC, consolidated text of 14 March 2012](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0043-20120314).

## Scope

Three groups are outside the directive: explosives, including ammunition, intended for use, in accordance with national law, by the armed forces or the police; pyrotechnic articles falling within the scope of Directive 2013/29/EU; and ammunition, save as provided for in Articles 12, 13 and 14 on ammunition transfers, security derogations and information exchange (Art. 1(2)). Annex I contains a non-exhaustive list of the UN Class 1 entries that are considered pyrotechnic articles or ammunition, which the Commission may update by delegated act to follow the UN recommendations (Art. 1(2), Art. 46 and Annex I). Member States remain free to designate other substances as explosives under national law (Art. 1(3)). Precursor chemicals are not Class 1 explosives and fall under the separate EU regulation on explosives precursors, which applies since 1 February 2021.

The duties fall on the economic operators. A manufacturer is whoever manufactures an explosive or has it designed or manufactured and markets it under his name or trade mark or uses it for his own purposes (Art. 2, point (9)); the authorised representative, importer and distributor are defined as in the other CE directives (Art. 2, points (10) to (12)). Uniquely, the directive's economic operators also include any natural or legal person who engages in the storage, use, transfer, import, export or trade of explosives (Art. 2, point (13)), which brings blasting contractors, quarries and mines under the licensing, transfer and traceability rules. A separately defined 'dealer' in firearms and ammunition appears only in the ammunition transfer procedure (Art. 2, point (14), and Art. 12). An importer or distributor that sells under its own name or trade mark, or modifies an explosive in a way that may affect compliance, takes on the manufacturer's obligations (Art. 9).

## What you must do

### Essential safety requirements

Annex II requires each explosive to be designed, manufactured and supplied so as to present a minimal risk to the safety of human life and health and to prevent damage to property and the environment under normal, foreseeable conditions, to attain the performance characteristics specified by the manufacturer, and to be disposable in a manner that minimises effects on the environment (Annex II, part I). Part II lists the information and properties that must be considered or tested, among them design and chemical composition, physical and chemical stability, sensitiveness to impact and friction, compatibility of components, chemical purity, resistance to water and to low and high temperatures, suitability for hazardous environments such as firedamp atmospheres, safety features against untimely or inadvertent initiation, correct loading and functioning, instructions and markings for safe handling, storage, use and disposal, and shelf life until the use-by date; each explosive must be tested under realistic conditions (Annex II, part II, points 1 and 2). Special requirements follow for four groups: blasting explosives, detonating cords, safety fuses, other fuses and shock tubes, detonators (including delay detonators) and relays, and propellants and rocket propellants (Annex II, part II, point 3).

### Harmonised standards

Explosives that conform to harmonised standards, or parts of them, whose references are published in the Official Journal are presumed to conform to the essential safety requirements those standards cover (Art. 19). The Commission's page on harmonised standards for explosives for civil uses lists the standards under the communication published in OJ C 118 of 12 April 2017.

### Conformity assessment, declaration and CE marking

The manufacturer must follow one of the Annex III procedures: EU-type examination (Module B) by a notified body followed, at the manufacturer's choice, by conformity to type based on internal production control plus supervised product checks at random intervals (Module C2), conformity to type based on quality assurance of the production process (Module D), conformity to type based on product quality assurance (Module E) or conformity to type based on product verification (Module F); or conformity based on unit verification (Module G) (Art. 20). There is no self-declaration route. For EU-type examination the manufacturer lodges an application with a single notified body, with the technical documentation (a risk analysis and assessment, general description, drawings, the harmonised standards applied or the solutions adopted instead, design calculations and test reports) and specimens representative of production; the body examines the documentation, tests the specimens and issues an EU-type examination certificate, which the manufacturer keeps with the documentation for 10 years and must have supplemented for any modification affecting conformity (Annex III, Module B, points 3 to 9).

Once compliance is demonstrated the manufacturer draws up the EU declaration of conformity per Annex IV, keeps it continuously updated, translates it into the languages the Member State requires and, where several Union acts apply, issues a single declaration; by drawing it up the manufacturer assumes responsibility for compliance (Art. 21). The CE marking follows the general principles of Article 30 of Regulation (EC) No 765/2008 and is affixed visibly, legibly and indelibly to the explosive before it is placed on the market, or to the packaging and accompanying documents where the nature of the explosive does not allow it, followed by the identification number of the notified body involved in the production control phase (Art. 22 and Art. 23(1) to (3)). For explosives manufactured for own use, explosives delivered unpackaged or in Mobile Explosives Manufacturing Units for direct unloading into the blast-hole, and explosives produced in situ at the blasting site, the CE marking goes on the accompanying documents (Art. 23(5)).

### Unique identification and traceability

Economic operators must adhere to a uniform system for the unique identification and traceability of explosives that takes account of their size, shape or design, except where a unique identification is unnecessary because of an explosive's low level of hazard; the system does not apply to explosives transported and delivered unpackaged or in pump trucks for direct unloading into the blast-hole, or to explosives manufactured at blasting sites and loaded immediately (Art. 15(1)). It provides for the collection and storage of data identifying each explosive, its location while in the possession of economic operators and the identity of those operators; the data must be tested regularly, protected against damage, stored for 10 years after the transaction or, where the explosives were used or disposed of, 10 years after their use or disposal, even if the operator has ceased trading, and made immediately available to the competent authorities (Art. 15(2) and (3)). The Commission may adopt implementing acts on the format and structure of the identification and on the low-hazard exemptions (Art. 15(4)); until it does, Directive 2008/43/EC continues to apply (Art. 51(3)).

Under Directive 2008/43/EC as amended by Directive 2012/4/EU, undertakings that manufacture or import explosives or assemble detonators mark each explosive and each smallest packaging unit with a unique identification consisting of a human-readable part (the manufacturer's name and an alphanumerical code with two letters for the Member State of production or import, three digits for the manufacturing site attributed by the national authority, and the manufacturer's unique product code and logistical information) and a barcode or matrix code (Directive 2008/43/EC, Art. 3 and Annex). The directive sets the marking method per product type, from labels or printing on cartridges and sacks to stamping on detonator shells and marking every 5 metres of detonating cord (Art. 5 to Art. 11), excludes ammunition, fuses, safety fuses and cap-type primers (Art. 2), and requires undertakings to record all identifications with the custody and location of each explosive, keep the data for 10 years, protect it and name a contact person available outside business hours (Art. 13 and Art. 14). Manufacturers of explosives outside the system instead mark a type, batch or serial number or another element allowing identification, together with their name, registered trade name or registered trade mark and a single postal contact address, or put that information on the packaging or in an accompanying document (Art. 5(5)). The importer's own name and postal address are not tied to that exception: importers must indicate them on every explosive they place on the market, or on its packaging or in an accompanying document where that is not possible (Art. 7(3)).

### Transfers, licences and seizures

Explosives may be transferred within the Union only under Article 11: the consignee obtains approval from the competent authority of its Member State, which verifies that the consignee is legally authorised to acquire explosives and holds the necessary licences or authorisations, and the operator responsible for the transfer notifies and obtains prior approval from each transit Member State (Art. 11(2)). The authority issues a document that accompanies the explosives to their destination and is produced on request; where special security requirements apply, the consignee first supplies the names and addresses of the operators, the number, quantity, description and identification of the explosives including the UN number, the compliance information, the means of transfer, itinerary, dates and points of entry and exit, and where no such requirements apply the authority may grant a fixed-period approval instead (Art. 11(4) to (6)). No operator may transfer explosives unless the consignee holds the necessary authorisations (Art. 11(8)). Ammunition transfers follow the separate licence procedure of Article 12, Member States may take proportionate emergency measures against transfers during serious threats to public security (Art. 13), and they run information-exchange networks for the purpose (Art. 14).

Economic operators must hold a licence or authorisation entitling them to manufacture, store, use, import, export, transfer or trade explosives; employees of a licensed operator do not need their own (Art. 16). A manufacturing licence is granted only after the Member State has checked that the operator can comply with the technical commitments it assumes (Art. 17), and the competent authorities may seize any explosive where there is sufficient evidence that it will be illicitly acquired, used or dealt in (Art. 18).

### Obligations by role

Manufacturers design and manufacture to Annex II, draw up the documentation and have the Article 20 procedure carried out, draw up the declaration and affix the CE marking, keep both for 10 years, keep series production in conformity, apply the unique identification or the fallback markings, supply instructions and safety information in the required language, take corrective action and inform the authorities of risks, and cooperate on request (Art. 5). Authorised representatives act under a mandate that must at least cover keeping the documents and cooperating with the authorities and cannot take over design or documentation duties (Art. 6). Importers place only compliant explosives on the market, verify the manufacturer's work, add their own name and address, ensure the language of the instructions, protect the explosives in storage and transport, take corrective action and keep the declaration for 10 years (Art. 7). Distributors verify the CE marking, documents, language and identification before making explosives available, protect them in storage and transport and see that corrective action is taken (Art. 8). Importers and distributors that sell under their own brand or modify explosives become manufacturers (Art. 9), and for explosives outside the identification system every operator identifies its suppliers and customers for 10 years (Art. 10).

## Enforcement and penalties

Market surveillance follows Articles 16 to 29 of Regulation (EC) No 765/2008 as applied to explosives by Article 41; those articles were deleted by Regulation (EU) 2019/1020, which applies from 16 July 2021 and lists Directive 2014/28/EU in its Annex I, so the reference is read as Regulation (EU) 2019/1020 (Art. 41; Regulation (EU) 2019/1020, Art. 39, Art. 44 and Annex I). Where an authority has sufficient reason to believe that an explosive presents a risk to the health or safety of persons, property or the environment, it evaluates the explosive, requires corrective action, withdrawal or recall within a reasonable period commensurate with the risk, informs the notified body and, if the operator does not act, prohibits or restricts the making available, withdraws or recalls the explosive and informs the Commission and the other Member States (Art. 42). Compliant explosives that still present a risk can be treated the same way (Art. 44), and the Commission decides disputed national measures through the Union safeguard procedure (Art. 43). Formal non-compliance, such as CE marking missing or wrongly affixed, the notified body's number missing, a missing or incorrect declaration, incomplete technical documentation or absent, false or incomplete identification and address information, must be ended and otherwise leads to restriction, prohibition, withdrawal or recall (Art. 45).

Penalties are set nationally: Member States lay down effective, proportionate and dissuasive penalties for infringements of their transposing laws, which may include criminal penalties for serious infringements (Art. 50). In Denmark, executive order nr. 1251 of 29 October 2025 on explosives, issued by Justitsministeriet under the weapons and explosives act (LBK nr. 1736 of 26 August 2021) and in force since 1 November 2025, makes Directive 2014/28/EU and Directive 2008/43/EC apply in Denmark and prints them as annexes; permits to trade and market explosives cover only products that meet the directive's Articles 3 to 4, 5(1), 19 and 22 to 23 and Annexes II to IV and the 2008/43/EC marking rules, and trading, storing, transferring within Denmark, acquiring and using explosives each need a police permit, issued by politidirektøren i Midt- og Vestjyllands Politi, with the police as supervisory authority for permits. Breaches of its sections 2 to 11, of section 12(4) — under which a legal person must name a natural person who is responsible together with it for compliance with the explosives rules — and of the conditions attached to a permit are punished with a fine or imprisonment of up to 4 months, or up to 2 years under aggravating circumstances, and companies can be held liable; the duty to keep a register of receipts and issues of explosives was widened by executive order nr. 231 of 29 January 2026, in force 1 February 2026: § 10(1) now binds any natural or legal person, not only manufacturers and those marketing explosives under their own name or trade mark, and exempts only natural persons holding a permit to manufacture, including to reload ammunition. The register must show the type, the unique identification and the storage place of the explosives and who holds them at any time, be kept for at least 10 years from the end of the calendar year of the transaction or, where known, from the end of the explosives' life cycle, be handed to the police at once if the business closes, and a copy for the year must be sent to the police at the end of each calendar year, together with the name and contact details of a person reachable outside normal working hours (§ 10(2) to (4)). Sikkerhedsstyrelsen, which since January 2026 is a department of Erhvervsstyrelsen named Markedsovervågning, has controlled explosives for civil uses on behalf of Justitsministeriet since 1 August 2018 and can ask the police to investigate breaches; suspected non-compliant products are reported to Erhvervsstyrelsen.

## What is changing

The Commission published its evaluation of the directive on 19 September 2025 (SWD(2025) 266). It found that the directive is performing well on the whole but that some of its provisions are outdated and not fit for the digital age, and said it would reflect on the results and decide whether to launch a revision in line with the ProtectEU internal security strategy. No amending act has been adopted, and the internal market emergency procedures of Directive (EU) 2024/2749 do not extend to this directive.

## How Conphora helps

Conphora monitors the Civil Explosives Directive, its harmonised standards and the Danish executive orders and maps your products against the essential safety requirements, flagging gaps in the EU-type examination, the production module, the declaration of conformity, the CE marking and the unique identification before they become enforcement problems. The platform helps you build and keep the technical documentation and the 10-year traceability records, tracks the transfer approvals and licences each operation needs, and alerts you when a standard, the directive or the identification rules change.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Directive 2014/28/EU on the making available on the market and supervision of explosives for civil uses, OJ L 96, 29 March 2014 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0028)
- [Document information, dates and relationships for CELEX 32014L0028 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32014L0028)
- [Commission Directive 2008/43/EC setting up a system for the identification and traceability of explosives for civil uses, consolidated text of 14 March 2012 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0043-20120314)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EC) No 765/2008 on accreditation and market surveillance, Article 30 on the CE marking (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0765)
- [Explosives for civil uses, harmonised standards (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards/explosives-civil-uses_en)
- [Commission publishes evaluations of EU rules on pyrotechnics and civil explosives, 19 September 2025 (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/news/commission-publishes-evaluations-eu-rules-pyrotechnics-and-civil-explosives-2025-09-19_en)
- [Bekendtgørelse nr. 1251 af 29. oktober 2025 om eksplosivstoffer (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1251)
- [Bekendtgørelse nr. 231 af 29. januar 2026 om ændring af bekendtgørelse om eksplosivstoffer (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/231)
- [Bekendtgørelse af lov om våben og eksplosivstoffer m.v., LBK nr. 1736 af 26. august 2021 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1736)
- [Eksplosivstoffer til civil brug, vi fører kontrol (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eksplosivstoffer-civil-brug/eksplosivstoffer-civil-brug-vi-foerer-kontrol)
- [Kontrol med udgangsstoffer til eksplosivstoffer (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/udgangsstoffer-eksplosivstoffer/kontrol-udgangsstoffer-eksplosivstoffer)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Sikkerhedsstyrelsen)](https://www.sik.dk/sikkerhedsstyrelsen-del-erhvervsstyrelsen)

*This guide is for general information and is not legal advice.*

## Sources

- [Directive 2014/28/EU on the making available on the market and supervision of explosives for civil uses, OJ L 96, 29 March 2014 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0028)
- [Document information, dates and relationships for CELEX 32014L0028 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32014L0028)
- [Commission Directive 2008/43/EC setting up a system for the identification and traceability of explosives for civil uses, consolidated text of 14 March 2012 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008L0043-20120314)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EC) No 765/2008 on accreditation and market surveillance, Article 30 on the CE marking (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0765)
- [Explosives for civil uses, harmonised standards (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards/explosives-civil-uses_en)
- [Commission publishes evaluations of EU rules on pyrotechnics and civil explosives, 19 September 2025 (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/news/commission-publishes-evaluations-eu-rules-pyrotechnics-and-civil-explosives-2025-09-19_en)
- [Bekendtgørelse nr. 1251 af 29. oktober 2025 om eksplosivstoffer (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1251)
- [Bekendtgørelse nr. 231 af 29. januar 2026 om ændring af bekendtgørelse om eksplosivstoffer (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/231)
- [Bekendtgørelse af lov om våben og eksplosivstoffer m.v., LBK nr. 1736 af 26. august 2021 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1736)
- [Eksplosivstoffer til civil brug, vi fører kontrol (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/eksplosivstoffer-civil-brug/eksplosivstoffer-civil-brug-vi-foerer-kontrol)
- [Kontrol med udgangsstoffer til eksplosivstoffer (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/udgangsstoffer-eksplosivstoffer/kontrol-udgangsstoffer-eksplosivstoffer)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Sikkerhedsstyrelsen)](https://www.sik.dk/sikkerhedsstyrelsen-del-erhvervsstyrelsen)

_Reviewed 2026-09-24 by Conphora compliance team_