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). The unique identification system is set out in Commission Directive 2008/43/EC, consolidated text of 14 March 2012.
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.
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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)
- Document information, dates and relationships for CELEX 32014L0028 (EUR-Lex)
- 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)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Regulation (EC) No 765/2008 on accreditation and market surveillance, Article 30 on the CE marking (EUR-Lex)
- Explosives for civil uses, harmonised standards (European Commission, DG GROW)
- Commission publishes evaluations of EU rules on pyrotechnics and civil explosives, 19 September 2025 (European Commission, DG GROW)
- Bekendtgørelse nr. 1251 af 29. oktober 2025 om eksplosivstoffer (Retsinformation)
- Bekendtgørelse nr. 231 af 29. januar 2026 om ændring af bekendtgørelse om eksplosivstoffer (Retsinformation)
- Bekendtgørelse af lov om våben og eksplosivstoffer m.v., LBK nr. 1736 af 26. august 2021 (Retsinformation)
- Eksplosivstoffer til civil brug, vi fører kontrol (Sikkerhedsstyrelsen)
- Kontrol med udgangsstoffer til eksplosivstoffer (Sikkerhedsstyrelsen)
- Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Sikkerhedsstyrelsen)
This guide is for general information and is not legal advice.