Transfer of explosives
Following the UK’s departure from the EU, some rules and procedures have changed since 1 January 2021.
This page contains information on the controls that apply to the transfer of civil explosives into and within Great Britain under regulation 8 of the Explosives Regulations 2014.
It outlines the responsibilities for those involved in the transfer of civil explosives, the documentation required and how to apply for it.
Parallel regulations apply in Northern Ireland.
What a transfer of civil explosives means
A transfer means the physical movement of civil explosives from one place to another. Moving explosives within a site (such as a factory, mine, quarry or construction site) is not a transfer of civil explosives.
The requirements
Before any civil explosives are transferred, the consignee must obtain approval for the transfer.
Many civil explosives will also be relevant explosives, which are those for which an explosives certificate is required.
HSE has guidance on authorisations and licensing[55] which includes further information on explosives certificates.
Who regulation 8 applies to
The regulation applies to anyone who transfers civil explosives, whether they are individuals or companies.
Explosives the regulation applies to
Regulation 8 applies to the transfer of civil explosives. This means all explosives in class 1, or which would be classified in accordance with the UN recommendations as falling within class 1, except:
- the acquisition of some ammunition which is regulated or prohibited by the Firearms Act 1968-1997)
- pyrotechnic articles, including explosives articles in airbags and seat belt pre-tensioners[56]
- explosives intended for lawful use by the police or armed forces
- explosives seized by customs officers, police, local authority, the Health and Safety Executive (HSE) or the Office of the Nuclear Regulator (ONR)
- the components of small arms ammunition when being transferred for the recipient's private use (the commercial transfers of components of small arms ammunition are subject to the transfer controls)
Exclusion for lawful use by the police or armed forces
In relation to the exclusion for 'explosives intended for lawful use by the police or armed forces' this refers to the 'intended use'.
There is a distinction between the immediate use and possible eventual use for military purposes. A starting point for determining whether the explosive falls within the exclusion would be whether the explosive falls within the UK Military List[57].
In principle, such explosives could be regarded as military explosives. However, the possibility of dual use cannot be excluded. If the immediate consignee is a commercial company, the requirement for a recipient competent authority document should apply up to the point it becomes clear the ultimate use is military.
If the explosive is not on the UK military list, it should be regarded as a civil explosive and treated accordingly unless the consignee is the armed forces or the police.
The transfer document you will need
There are 2 types of recipient competent authority documents which may be required for the transfer of civil explosives:
- a Recipient Competent Authority document (RCAD) for domestic transfers of civil explosives in Great Britain
- a Recipient Competent Authority Document: GB Transfer for transfers that involve the importation of civil explosives from outside the UK into Great Britain
You may require both documents.
RCAD for domestic transfers
In England, Scotland and Wales, all new explosives certificates (acquire and keep) issued by the police should include an RCAD. You should contact your local police explosives liaison officer if an RCAD was not included with your explosives certificate.
A RCAD issued by the police does not require a fee.
Your RCAD will include:
- the UN Numbers of the explosives shown on your explosives certificate
- the UN Numbers for those explosives the transfer requirements apply to but which (in certain circumstances) do not require an explosives certificate to acquire and keep (such as smokeless powder) that you have indicated on your application form
The RCAD’s expiry date will be the same as the expiry date on your explosives certificate.
If you require an RCAD but are not required to hold an explosives certificate (as you only acquire or keep civil explosives contained on Schedule 2 to ER2014[58]) contact HSE’s Explosives Inspectorate[59], clearly stating which explosives you wish to transfer. A RCAD issued by HSE costs £138.
The Regulations require you to keep the RCAD or a certified copy for a period of 3 years from completion of the transfer. In practice, this normally means 3 years after expiry of the RCAD.
RCAD for transfers from outside the UK into Great Britain (imports)
Transfers involving the importation of civil explosives into Great Britain from outside Great Britain require authorisation from HSE.
Applications can be made using the RCAD: GB transfer approval form (LP50) (.docx) [60]. This is in addition to any requirement for a RCAD for transfers within Great Britain. A RCAD involving the importation of civil explosives into Great Britain from outside Great Britain transfer has a fee of £138.
The RCAD: GB transfer approval form (.docx) (LP50) (.docx) [61] includes a requirement for you to notify HSE of the manufacturers' site codes (traceability codes[62]) for civil explosives in the consignment.
If the civil explosives are being transferred through more than one EU member state before being transferred into Great Britain, you will also need to obtain authorisation through an intra community transfer (ICT). You should apply to the competent authority of the EU member state on the itinerary immediately preceding entry into Great Britain for the ICT.
Incomplete or inaccurate applications or failure to allow sufficient time for your application to be processed may result in delays to your consignment.
It is your duty to ensure the civil explosives being transferred have been properly classified by a Competent Authority of a Contracting Party to the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR).
The application of ADR in the UK is unaffected by the UK's Exit from the EU. There is information on the classification of explosives[63].
The documents must accompany the explosives at all times until they arrive at their destination.
Summary of requirements
Approval to transfer civil explosives that are also relevant explosives domestically in Great Britain
Form
Explosives certificate application form
Who you should apply to
Police Force in England, Scotland and Wales
Fee
Nil
Approval to transfer civil explosives that are not relevant explosives domestically in Great Britain
Form
email cad.explosives@hse.gov.uk listing the explosives you want to transfer.
Who you should apply to
HSE
Fee
£138
Approval to import civil explosives from outside the UK into Great Britain
Form
Recipient Competent Authority Document: GB transfer – LP50
Who you should apply to
HSE
Fee
£138