CE marking for civil explosives done! With easyCE expert support.
Understand the regulatory requirements for explosives for civil uses. easyCE helps clarify product scope, conformity assessment and documentation responsibilities. We organise the evidence needed for the applicable notified-body procedure and distinguish CE marking from the separate rules on transfers, traceability, storage and use.
Willy Lebherz
Founder and Managing Director of easyCE GmbH
DoC ready to sign!
Receive the declaration for your review and signature once the required assessment and evidence are complete.
Risk assessment completed!
Identify product hazards, assess risks and document the necessary protective measures.
Applicable standards identified!
We identify the relevant harmonised standards and check their scope, current references and any restrictions for your product.
Technical documentation prepared!
Bring the assessment, supporting evidence and product instructions together in a structured technical file.
CE marking prepared!
Clarify the marking and information your product needs before it is placed on the market.
Explosives for civil uses. The essentials.
Requirements at a glance
Directive 2014/28/EU covers explosives for civil uses within its scope and has applied since 20 April 2016. It replaced Directive 93/15/EEC. Pyrotechnic articles and specified military, police and ammunition products are addressed by separate provisions or exclusions.
The manufacturer must meet the applicable essential safety requirements, complete the required conformity assessment and prepare the declaration and marking. CE conformity assessment does not replace the separate permissions and controls for transfer, transport, storage or use.
easyCE supports the regulatory scope review and the organisation of technical documentation for the designated assessment body. We help make responsibilities, evidence and outstanding actions clear, without presenting CE marking as a general authorisation to handle explosives.
Frequently asked questions
Which explosives does the directive cover?
The directive concerns materials and articles classified as explosives in Class 1 of the United Nations recommendations on the transport of dangerous goods, subject to its defined exclusions.
Explosives intended for the armed forces or police, pyrotechnic articles and ammunition require careful treatment under Article 1. Some transfer provisions apply to ammunition despite the general exclusion. Product classification should be confirmed with the relevant competent authority or assessment body.
Which conformity assessment routes apply?
Article 20 provides EU type-examination under Module B combined with Module C2, D, E or F, or unit verification under Module G.
The manufacturer arranges the applicable notified-body assessment and provides the technical documentation. A test report alone is not a complete conformity assessment, and the manufacturer cannot freely substitute an unrelated assessment module.
How do explosives differ from pyrotechnic articles?
Pyrotechnic articles are covered by Directive 2013/29/EU rather than the civil explosives product framework.
Examples include fireworks, theatrical pyrotechnics and specified technical pyrotechnic articles such as vehicle safety components. Qualification depends on the product and its intended purpose, not merely on whether it contains an energetic substance.
Why does the directive define supply-chain responsibilities?
The common EU framework gives manufacturers, importers and distributors defined duties and supports consistent market surveillance.
The aim is to make responsibility and traceability clear throughout the supply chain. CE marking must be supported by the applicable assessment and documents, not merely printed on the product.
Which authorities are responsible?
The competent authorities depend on the country and the regulatory activity, such as market surveillance, transfers, transport, storage or use.
HSE is relevant to specified explosives responsibilities in Great Britain, not an authority for the entire EU. For an EU project, identify the relevant national authorities and the appropriately designated notified body rather than relying on an old UK implementation consultation.
How is CE marking handled for in-situ or unpackaged explosives?
The directive provides specific arrangements for placing CE marking on accompanying documents for certain explosives manufactured for own use, delivered unpackaged, made in mobile manufacturing units or produced in situ.
These are marking arrangements, not exemptions from the applicable essential safety requirements or conformity assessment. The precise conditions in Article 23 must be checked for the supply and production arrangement.
Which legislation is the current basis for CE marking?
Directive 2014/28/EU is the current civil explosives directive. References to Directive 93/15/EEC describe the former framework, which was repealed from 20 April 2016.
The essential safety requirements are in Annex II to the current directive. The relevant conformity assessment procedures are in Annex III.
Who is responsible for affixing CE marking?
The manufacturer is responsible for conformity and affixes CE marking after completing the required procedure. The notified body performs the independent tasks specified by that procedure.
The identification number of the notified body involved in production control follows the CE marking. This does not transfer the manufacturer’s overall responsibility to the notified body.
How should shock tubes be classified?
The classification of a shock tube depends on the product supplied and its regulatory status, including whether it is supplied alone or as part of a detonator assembly.
The directive expressly addresses shock tubes within its essential safety requirements. Transport classification and product-conformity requirements should not be conflated. Obtain a product-specific classification assessment instead of relying on a generic claim that all shock tubes are either exempt or included.
What traceability rules apply to civil explosives?
Directive 2008/43/EC, as amended, establishes a system for the identification and traceability of civil explosives. Its identification and record-keeping requirements have been phased in since 2013 and 2015 respectively.
Assess the current requirements, specific exclusions and the operator’s role. Do not infer a general exemption for old stock solely from its manufacturing date. Retention and traceability arrangements should be agreed against the applicable rules and competent-authority requirements.
What about explosives transiting the EU?
Transit under customs control is different from placing a product on the EU market. The route, customs status and roles of the operators determine which identification, transfer and transport rules apply.
Confirm the arrangement with the competent customs and explosives authorities. A general statement that transit is outside one directive does not establish that no other control or documentation is required.
What is the directive intended to achieve?
It harmonises the conditions for supplying civil explosives within the EU while addressing safety, supervision and traceability.
It is an EU product and supervision framework, not a description of the United Kingdom’s former obligation to transpose EU legislation. National rules for authorised activities remain relevant.
Does CE marking replace national permissions?
No. CE marking demonstrates conformity with the applicable EU product requirements. It does not replace permissions for explosives activities or the rules on transfer, transport, storage and use.
Clarify these separate requirements for each country and operator involved. Regulatory advice should identify which duty belongs to the manufacturer, supplier, transporter or end user.
Is an authorised representative mandatory?
Under this directive, a manufacturer may appoint an authorised representative by written mandate. Appointment is not a blanket prerequisite for every product.
The mandate defines the permitted tasks, such as keeping the declaration and documentation available and cooperating with authorities. The manufacturer’s design and manufacturing obligations cannot simply be transferred to the representative.
What evidence supports conformity assessment?
Prepare a technical file that identifies the product, its intended use, applicable requirements, design information and the evidence needed for the chosen procedure.
- Manufacturer and applicant identification.
- Product description and controlled design and manufacturing documentation.
- Risk assessment and identification of the applicable essential requirements.
- Relevant standards or alternative technical specifications and supporting assessment reports.
- Proposed product identification, marking and instructions.
Use a notified body designated for the product and procedure. No single body number is mandatory for every civil explosives project.
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Successful projects. Results that speak for themselves.
CE marking for a tunnel boring machine used in Australian copper mining
easyCE carries out the conformity assessment for a tunnel boring machine, including risk assessment across its lifecycle and preparation of a declaration of conformity ready to sign. The assessment focused on the new multi-arm cutting-head concept. The work also considered the applicable Australian safety and technical requirements, in close cooperation with the manufacturer and its Australian customer.
CE marking for control cabinets
easyCE supports the conformity assessment for control cabinets, including risk assessment and preparation of a declaration of conformity ready to sign. The assessment considered the Machinery, EMC and Low Voltage Directives, alongside DIN EN 60204-1:2019-06 and DIN EN IEC 61439-1:2021-10. The work also included a checklist to help select suppliers and components that meet the project's specific requirements.
CE marking for a mobile satellite communications system
easyCE supports the conformity assessment of a mobile satellite communications system, including risk assessment, EMC review and preparation of a declaration of conformity ready to sign. The system routes TCP/IP data redundantly through two or more satellite antennas. It is designed for rapid deployment where a mobile communications link is needed over long distances.
CE marking and declaration of conformity for a 2D laser cutting system
easyCE supports the full conformity assessment for a 2D laser cutting system with an automatic pallet changer. The work included coordinating the safety concept and two-beam light barrier, determining the performance level, analysing the product and carrying out a risk assessment in accordance with EN ISO 12100. Particular attention was needed for the cutting head's support structure and the movements of the pallet changer and cutting head. Laser protection screens, safety devices and a complete enclosure shield operators from the Class 4 laser cutting process inside the cabin, with Class 1 laser conditions outside the machine.
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Expert support in three clear steps
Step 1
Free initial advice
Describe your product and tell us where you need support. We clarify the applicable requirements and the next steps in a free initial discussion.
Step 2
A clear project proposal
Receive a proposal with a defined scope, deliverables and responsibilities. Your easyCE expert explains the assessment process and the evidence your project needs.
Step 3
Expert delivery
Your dedicated expert coordinates the agreed assessment, documentation and supporting tasks. You receive a structured handover, with any remaining actions clearly identified.
Your compliance project. Expertly handled.
Engineering expertise you can rely on
Willy Lebherz, Founder and Managing Director of easyCE
- Expert in product safety and compliance, since 1995
- Recipient of the "Medal of the Order of Merit of the Federal Republic of Germany", awarded in 1983 by the then Federal President Carl Carstens
- Meister qualification in measurement and control technology
- Captain (ret.), Project Officer for Technical Logistics in the Army Material Office and Chief of the Telecommunications Repair Company
easyCE specialises in product safety and conformity assessment. We combine engineering expertise with digital tools to help manufacturers, machinery users and distributors bring compliant products to market. From risk assessment and identifying relevant standards to technical documentation and test coordination, we carry out the work your project needs. You can choose support for the full process or individual tasks, with a dedicated CE expert as your point of contact. Founded in southern Germany, we work with customers worldwide.
We understand the requirements that apply to your product and can help you work through them.