Explosives used in quarrying, mining, tunnelling, infrastructure construction and other civil applications require far more than ordinary product conformity controls. Their design, manufacture, distribution, transfer and traceability must all operate within a regulatory system capable of addressing both safety and security.
Directive 2014/28/EU establishes the European framework for the making available on the market and supervision of explosives for civil uses. It harmonises essential safety requirements, conformity assessment, CE marking and important obligations affecting manufacturers, importers, distributors and other economic operators.
Unlike many CE-marked products, explosives also operate within a particularly controlled supply chain. Economic operators may require appropriate licences or authorisations, transfers between Member States are subject to regulatory controls, and explosives are generally subject to a harmonised system of unique identification and traceability.
For manufacturers, conformity therefore begins with precise product classification and extends through design assessment, testing, manufacturing controls, Notified Body involvement, production conformity, CE marking and long-term traceability.
This GAR Insight explains the scope of Directive 2014/28/EU, Essential Safety Requirements, harmonised standards, conformity assessment modules, Notified Body involvement, technical documentation, CE marking, economic-operator obligations, identification and traceability.
Navigate This Article
Explore Directive 2014/28/EU scope, Essential Safety Requirements, standards, conformity assessment, CE marking, traceability and controlled movement of explosives for civil uses.
Understanding Directive 2014/28/EU
Directive 2014/28/EU establishes harmonised European requirements concerning the making available on the market and supervision of explosives intended for civil uses.
The Directive replaced the earlier Directive 93/15/EEC framework and has applied since 20 April 2016.
Which Explosives Fall Within the Directive?
Scope should be established from the legal definition and intended civil use rather than simply from the fact that a product contains an energetic material.
Directive 2014/28/EU does not apply to ammunition or to explosives intended for use by the armed forces or police in accordance with national law. Pyrotechnic articles are governed through their own European framework rather than this Directive.
Commercial Explosives
Explosive products intended for legitimate civil industrial applications may fall within the Directive.
Initiating Products
Certain detonators and initiating systems can fall within the harmonised civil-explosives framework.
Detonating Cord
Detonating cords used in civil blasting applications are among the products addressed by relevant harmonised standards.
Excluded or Separately Regulated Products
Ammunition, pyrotechnic articles and specified military or police applications should not be automatically treated as Directive 2014/28/EU products.
Essential Safety Requirements
Explosives placed on the EU market must satisfy the Essential Safety Requirements established in Annex II of Directive 2014/28/EU.
These requirements address both general safety characteristics and, where applicable, requirements specific to particular types of explosives.
Design Safety
The explosive should be designed so that foreseeable risks are minimised under normal and reasonably foreseeable conditions.
Physical & Chemical Stability
Relevant physical and chemical characteristics should remain appropriate during intended storage, transport and use.
Compatibility
Components and materials should remain compatible throughout the intended life of the product.
Sensitivity
Sensitivity to impact, friction, heat and other initiating influences should be controlled according to the product type.
Reliable Function
The explosive should function predictably when initiated under its intended operating conditions.
Safety in Handling
Design and construction should support safe handling, storage, transport and intended use.
Safety-Critical Product Characteristics
The specific characteristics requiring evaluation depend on the explosive product and its intended use.
Thermal Stability
The product should remain appropriately stable within its intended temperature and storage conditions.
Impact Sensitivity
Sensitivity to mechanical impact may require evaluation for relevant explosive types.
Friction Sensitivity
Susceptibility to initiation or hazardous reaction through friction can form part of the safety evaluation.
Water Resistance
Resistance to water or moisture may be relevant where exposure can affect performance or safety.
Initiation Reliability
Initiating devices and transmission systems must function consistently within their intended operational parameters.
Ageing & Storage
Performance and safety characteristics should remain suitable over the declared storage period.
Harmonised Standards
Explosives manufactured in conformity with relevant harmonised European standards whose references have been published in the Official Journal benefit from presumption of conformity with the Essential Safety Requirements covered by those standards.
Detonating Cords & Safety Fuses
The EN 13630 series includes requirements and test methods applicable to detonating cords and safety fuses.
High Explosives
Product-specific standards address relevant performance and safety characteristics for civil high explosives.
Detonators & Relays
Relevant standards address electrical and non-electrical initiation systems and related products.
Current OJEU Status
The legal effect of harmonisation depends on publication of the relevant standard reference in the Official Journal.
Testing & Technical Evaluation
Technical evaluation should demonstrate that the explosive satisfies the applicable Essential Safety Requirements and the requirements of the conformity route selected.
Define Product Type
Establish the exact product family, formulation, construction and intended application.
Identify Standards
Determine applicable harmonised standards and relevant technical specifications.
Select Representative Samples
Test specimens should adequately represent the design intended for manufacture.
Evaluate Safety Characteristics
Complete the relevant physical, chemical, mechanical, environmental and functional evaluations.
Document Results
Maintain traceable reports connecting testing to the product and conformity assessment.
Control Changes
Changes to formulation, construction or critical materials should be evaluated for their effect on approved conformity.
Conformity Assessment Procedures
Directive 2014/28/EU requires the manufacturer to use one of the conformity assessment procedures established in Annex III.
| Module | Conformity Function | General Purpose |
|---|---|---|
| B | EU-Type Examination | A Notified Body examines the technical design and verifies that the type meets applicable requirements. |
| C2 | Conformity to Type Based on Internal Production Control Plus Supervised Product Checks at Random Intervals | Production conformity is supported by manufacturer control and supervised product checks. |
| D | Production Process Quality Assurance | An approved production quality system supports conformity with the examined type. |
| E | Product Quality Assurance | An approved quality system covers final product inspection and testing. |
| F | Product Verification | Products are examined and tested to verify conformity with the approved type. |
| G | Unit Verification | An individual explosive product is independently assessed for conformity. |
The Role of the Notified Body
Independent conformity assessment is integral to the Directive’s certification system.
Type Examination
The Notified Body evaluates product design and supporting technical evidence under Module B.
Product Verification
Where Module F or G is used, independent examination and testing support the conformity decision.
Quality-System Assessment
Modules D and E involve assessment and surveillance of manufacturer quality systems.
Production Checks
Module C2 incorporates supervised product checks at random intervals.
Maintaining Production Conformity
An approved explosive type must remain technically connected to the product subsequently manufactured.
Formulation Control
Composition and safety-critical raw materials should remain within the approved design.
Supplier Control
Critical materials and components should be purchased against controlled specifications.
Process Control
Manufacturing processes affecting safety or performance should be appropriately monitored.
Inspection & Testing
Appropriate production testing should verify continuing conformity.
Change Control
Product and process changes should be assessed before implementation.
Traceability
Production and identification records should remain connected to individual products or batches as required.
Technical Documentation
Technical documentation should allow conformity of the explosive with the applicable requirements to be assessed.
EU Declaration of Conformity & CE Marking
Once conformity with the Essential Safety Requirements has been demonstrated, the manufacturer draws up the EU Declaration of Conformity and applies CE marking before the explosive is placed on the market.
EU Declaration
The declaration confirms conformity with the Annex II Essential Safety Requirements and follows the structure required by the Directive.
Manufacturer Responsibility
By issuing the declaration, the manufacturer assumes responsibility for conformity of the explosive.
CE Marking
CE marking must be affixed before the explosive is placed on the market.
Notified Body Number
Where a Notified Body is involved in the production-control phase, its identification number follows the CE marking.
Unique Identification & Traceability
Traceability is one of the defining differences between civil explosives conformity and ordinary CE-marked product compliance.
Economic operators must participate in a harmonised identification and traceability system, subject to the exemptions established by the applicable legislation.
Unique Identification
Explosives and/or their packaging are identified so that regulated supply-chain information can be linked to the product.
Location
Traceability data include information allowing the location of explosives while held by economic operators to be established.
Economic Operator Identity
Records connect explosives with the economic operators possessing them through the supply chain.
Long-Term Records
The Directive requires relevant traceability data to be retained for 10 years after the applicable transaction, use or disposal.
Transfers, Licences & Economic Operators
CE marking does not give unrestricted permission to transfer or possess explosives throughout the European Union.
The Directive includes additional controls relating to the movement of explosives and requires Member States to ensure that economic operators possess appropriate licences or authorisations where required.
Manufacturer
Responsible for product conformity, technical documentation, declaration, marking and applicable identification requirements.
Importer
Must verify required conformity elements before introducing third-country explosives onto the EU market.
Distributor
Must exercise due care and verify applicable product and traceability requirements.
Transfers
Movement of explosives between Member States is subject to specific regulatory transfer controls.
Licences
Undertakings in the explosives sector may need licences or authorisations under the applicable national system.
Competent Authorities
Authorities supervise transfers, possession, traceability and market conformity within the framework established by EU and national law.
From Explosive Classification to EU Market Placement
A structured conformity strategy should establish the regulatory and technical route before significant testing or certification activity begins.
Define Product
Establish explosive type, design, composition and intended civil use.
Confirm Scope
Determine whether Directive 2014/28/EU applies.
Map Safety Requirements
Identify applicable Annex II Essential Safety Requirements.
Select Standards
Identify applicable harmonised standards and test methods.
Plan Testing
Establish the product-specific technical assessment programme.
Select Conformity Route
Determine the applicable Module B combination or Module G.
Select Notified Body
Verify notification for the required Directive activities.
Complete Assessment
Perform testing and independent conformity assessment.
Control Production
Implement the applicable C2, D, E or F controls.
Establish Traceability
Apply identification and record-keeping requirements.
Declare & Mark
Issue the EU Declaration of Conformity and apply CE marking.
Control Supply
Meet applicable transfer, licensing and supply-chain obligations.
From Explosive Product Design to Demonstrable European Conformity
Conformity of explosives for civil uses begins with precise regulatory classification. Manufacturers must establish that Directive 2014/28/EU applies and identify the Essential Safety Requirements and harmonised technical specifications relevant to the particular product.
Technical assessment then needs to demonstrate that the explosive behaves safely and predictably throughout its intended storage, handling and use conditions. Depending on the product, this may involve evaluation of thermal stability, mechanical sensitivity, environmental resistance, initiation reliability and other safety-critical characteristics.
The conformity architecture also requires independent assessment. Manufacturers normally combine EU-type examination under Module B with an appropriate production-conformity route, or use unit verification under Module G where applicable.
After conformity has been established, the manufacturer’s responsibilities continue through CE marking, controlled production, unique identification, supply-chain traceability and applicable transfer and licensing requirements.
The Product Safety Question
Does the explosive satisfy the safety, stability, sensitivity and functional requirements applicable to its intended civil use?
The Conformity Question
Can the manufacturer demonstrate that each CE-marked explosive remains connected to the design, testing, Notified Body assessment, production controls and traceability system on which its conformity is based?