Identification and traceability of explosives

Manufacturers or importers are required to mark most civil explosives with a unique identification code. Where it is required the unique identification code must be marked on (or in certain cases attached to) each individual item. Different marking requirements apply depending on the size of the explosive. This requirement applies to all civil use explosives.

Further information on the record-keeping requirements of ER2014 are available.

Background

In 2004 a terrorist attack in Madrid which killed 191 people and injured over 1,800 others, raised a number of issues around the security of civil explosives.  This resulted in the development and adoption of an agreed system for the identification of civil explosives to assist traceability should the explosive be stolen or misplaced.

You must ensure that civil explosives are marked before they are imported into the UK. Applications can be made to HSE for GB identification codes for uncoded civil explosives manufactured in or imported into GB. GB also unilaterally recognises any existing codes issued by EU member states and does not require importers to add a new code. Importers must notify HSE of any existing codes issued by EU member states as part of the GB transfer approval process.

Manufacturers of civil explosives in Northern Ireland (NI) should apply to the Northern Ireland Office (NIO) for a manufacturer's site code. People who import uncoded civil explosives directly into NI should also apply to NIO for a site code. Importers wishing to transfer civil explosives from NI to GB do not need to apply to HSE for a new code as GB will unilaterally recognise manufacturer site codes issued by NIO.

Marking of items

All civil use explosives must be marked with a unique identification.  The marking must be firmly affixed to the article in a durable and legible way and must be as follows:

1. A human readable part detailing:

• the name of the manufacturer
• an alphanumeric code containing:
  • two letters identifying where in the UK (GB or NI) or EU member state the manufacturer or importer is based
  • three digits identifying the manufacturing site
  • the unique product code and the logistical information designed by the manufacturer

AND:

2. An electronic readable barcode and/or matrix code that relate directly to the alphanumeric code. Schedule 7 of the regulations describes how the unique identification should be affixed to different types of civil explosives.

Items too small to mark individually

If the explosive is too small to be marked with all of this information only some of the information will be required.

1. A human readable part detailing:

• the name of the manufacturer
• an alphanumeric code containing:
  • two letters identifying where in the UK (GB or NI) or EU Member State the manufacturer or importer is based
  • three digits identifying the manufacturing site

AND:

2. An electronic readable barcode and/or matrix code that relate directly to the alphanumeric code.

If the explosive is too small, or where it is technically impossible due to their shape or design, to mark the information outlined, the unique identification should be fixed on the smallest packaging unit (SPU). The SPU must be closed with a seal.

Schedule 7 of the regulations details this information.

Exceptions to marking requirements

Manufacturers are not required to mark civil explosives that are manufactured for export providing that the civil explosives are marked with the unique identification code in accordance with the traceability requirements of the importing country.

The requirement to mark civil explosives does not apply to:

• an explosive which is transported and delivered without packaging or in a mobile explosives manufacturing unit for its direct unloading into the blast-hole
• fuses, which are cord-like non-detonating igniting devices
• safety fuses, which consist of a core of fine-grained black powder surrounded by a flexible woven fabric with one or more protective outer coverings and which, when ignited, burn at a predetermined rate without any external explosive effect
• cap-type primers, which consist of a metal or plastic cap containing a small amount of primary explosive mixture that is readily ignited by impact, which serve as igniting elements in small arms cartridges or in percussion primers for propelling charges