COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive 2013/29/EU of the European Parliament and of the Council of 12 June 2013 on the harmonisation of the laws of the Member States relating to the making available on the market of pyrotechnic articles (recast)
Date: 2025-09-12
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EC conformity marking, approximation of laws, fireworks, free movement of goods, market approval, market supervision, marketing standard, product safety, safety standard, technical standard

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.9.2025  SWD(2025) 268 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of Directive 2013/29/EU of the European Parliament and of the Council of 12 June 2013 on the harmonisation of the laws of the Member States relating to the making available on the market of pyrotechnic articles (recast) {SWD(2025) 269 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 

EVALUATION 

of 

Directive 2013/29/EU of the European Parliament and of the Council of 
12 June 2013 

on the harmonisation of the laws of the Member States relating to the making 
available on the market of pyrotechnic articles (recast) 

Table of contents 

1. 

INTRODUCTION ........................................................................................... 1 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? . 3 

2.1.  Description of the intervention and its objectives .............................................. 3 

2.2. 

Points of comparison .......................................................................................... 7 

3.  HOW  HAS  THE  SITUATION  EVOLVED  OVER  THE  EVALUATION 
PERIOD? ....................................................................................................... 11 

Current state of play ...................................................................................................... 11 

3.1. 

The market for pyrotechnic articles .................................................................. 11 

3.2.  Human health and safety .................................................................................. 14 

3.3. 

3.4. 

Public security .................................................................................................. 16 

Environmental protection ................................................................................. 17 

3.5.  Harmonisation of laws and implementation ..................................................... 18 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ................................. 20 

4.1.  TO  WHAT  EXTENT  WAS  THE  INTERVENTION  SUCCESSFUL  AND 
WHY? ............................................................................................................ 20 

4.1.1. 

4.1.2. 

4.1.3. 

Effectiveness............................................................................................. 20 

Efficiency ................................................................................................. 28 

Coherence ................................................................................................. 41 

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE AND TO 
WHOM? ........................................................................................................ 46 

4.3.  IS THE INTERVENTION STILL RELEVANT? ........................................ 48 

4.3.1. 

4.3.2. 

Relevance of the objectives ...................................................................... 48 

Relevance with regard to other priorities/challenges ............................... 50 

 
 
 
 
 
 
4.3.3. 

Relevance of the scope ............................................................................. 51 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ........... 52 

5.1.  CONCLUSIONS ........................................................................................... 52 

5.2.  LESSONS LEARNED .................................................................................. 55 

ANNEX I: PROCEDURAL INFORMATION ..................................................... 57 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ........... 58 

ANNEX III. EVALUATION MATRIX ............................................................... 66 

ANNEX  IV.  OVERVIEW  OF  BENEFITS  AND  COSTS  AND  TABLE  ON 
SIMPLIFICATION AND BURDEN REDUCTION .................................... 96 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ... 111 

ANNEX VI. FUNCTIONING OF THE PYROTECHNICS DIRECTIVE ........ 137 

ANNEX  VII.  COMPLEMENTARY  INFORMATION  ON  THE  CURRENT 
STATE OF PLAY ....................................................................................... 142 

ANNEX VIII. CASE STUDIES .......................................................................... 147 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ADR 

ADN 

AdCo 
ATM 
CEN 
CLP Regulation  

DG 
EEA 
ESOs 
ESRs 

EU 

EUR 

ICSMS 

NACE 

NB 

NGO 

NLF 

Agreement Concerning the International Carriage of 
Dangerous Goods by Road 
Agreement concerning the International Carriage of 
Dangerous Goods by Inland Waterways 
Administrative Cooperation 
Automated teller machine 
European Committee on Standardization  
Regulation (EC) No 1272/2008 of the European 
Parliament and of the Council of 16 December 2008 on 
classification, labelling and packaging of substances 
and mixtures, amending and repealing Directives 
67/548/EEC and 1999/45/EC, and amending 
Regulation (EC) No 1907/2006 
Directorate-General 
European Economic Area 
European Standardisation Organisations 
Essential safety requirements 

European Union 

Euro 

Information and Communication System for Market 
Surveillance 

Acronym used to designate the various statistical 
classifications of economic activities developed since 
1970 in the European Union (EU) (Eurostat)  

Notified Body 

Non-governmental organisation 

New Legislative Framework, as established by 
Decision No 768/2008/EC of the European Parliament 
and of the Council of 9 July 2008 on a common 
framework for the marketing of products, and repealing 
Council Decision 93/465/EEC and Regulation (EC) 
No 765/2008 of the European Parliament and of the 
Council of 9 July 2008 setting out the requirements for 
accreditation and market surveillance relating to the 
marketing of products and repealing Regulation (EEC) 
No 339/93  

MSA 

PC 

Market surveillance authority 

Public consultation 

 
 
REACH Regulation 

RID 

SBS 

SITC 

Seveso-III Directive 

SMEs 

The Directive 

Regulation (EU) No 1907/2006 of the European 
Parliament and of the Council of 18 December 2006 
concerning the Registration, Evaluation, Authorisation 
and Restriction of Chemicals (REACH), establishing a 
European Chemicals Agency, amending Directive 
1999/45/EC and repealing Council Regulation (EEC) 
No 793/93 and Commission Regulation (EC) No 
1488/94 as well as Council Directive 76/769/EEC and 
Commission Directives 91/155/EEC, 93/67/EEC, 
93/105/EC and 2000/21/EC 

Regulations concerning the International Carriage of 
Dangerous Goods by Rail 

Eurostat Structural Business Statistics  

Eurostat Standard International Trade Classification 

Directive 2012/18/EU of the European Parliament and 
of the Council of 4 July 2012 on the control of major-
accident hazards involving dangerous substances, 
amending and subsequently repealing Council 
Directive 96/82/EC 

Small and medium-sized enterprises 

Directive 2013/29/EU of the European Parliament and 
of the Council of 12 June 2013 on the harmonisation of 
the laws of the Member States relating to the making 
available on the market of pyrotechnic articles (recast)  

UEFA  

US 

Union of European Football Associations 

United States of America 

 
 
1. 

INTRODUCTION 

Directive 2013/29/EU on the harmonisation of the laws of the Member States relating 
to  the  making  available  on  the  market  of  pyrotechnic  articles1  (hereinafter  ‘the 
Pyrotechnics  Directive’  or  ‘the  Directive’)  aims  to  achieve  the  free  movement  of 
pyrotechnic articles in the internal market while ensuring a high level of protection of 
human  health  and  safety  of  consumers  and  taking  into  account  the  relevant  aspects 
related  to  environmental  protection.  Hence  the  internal  market  legal  base  was  used 
(Article 114 TFEU, approximation of laws). The Pyrotechnics Directive was adopted as a 
recast of Directive 2007/23/EC of the European Parliament and of the Council of 23 May 
2007  on  the  placing  on  the  market  of  pyrotechnic  articles2  (hereinafter  ‘the  2007 
Directive’), aligning it to the New Legislative Framework (hereinafter ‘NLF’)3 but leaving 
the sector-specific rules introduced in 2007 essentially untouched. 

Commission  Implementing  Directive  2014/58/EU  complements 
Directive by setting up a system for the traceability of pyrotechnic articles4. 

the  Pyrotechnics 

Purpose and scope of the evaluation 

The Pyrotechnics Directive has been in force in its current form since 2013. Member States 
had to transpose the Directive into national law by 30 June 2015. Studies have been carried 
out on certain aspects of the Directive – notably on high-risk fireworks, illegal sales and 

1 Directive 2013/29/EU of the European Parliament and of the Council of 12 June 2013 on the harmonisation 
of the laws of the Member States relating to the making available on the market of pyrotechnic articles 
(recast) (OJ L 178, 28.6.2013, p. 27, ELI: http://data.europa.eu/eli/dir/2013/29/oj). 

2 Directive 2007/23/EC of the European Parliament and of the Council of 23 May 2007 on the placing on 
ELI: 

pyrotechnic 

14.6.2007, 

articles 

p. 1, 

154, 

(OJ 

L 

the  market 
of 
http://data.europa.eu/eli/dir/2007/23/oj). 

3 The New Legislative Approach consists of Decision No 768/2008/EC of the European Parliament and of 
the Council of 9 July 2008 on a common framework for the marketing of products, and repealing Council 
Decision  93/465/EEC  (OJ  L  218,  13.8.2008,  p. 82,  ELI:  http://data.europa.eu/eli/dec/2008/768(1)/oj) 
and Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting 
out the requirements for accreditation and market surveillance relating to the marketing of products and 
repealing 
ELI: 
http://data.europa.eu/eli/reg/2008/765/oj). 

(EEC)  No 339/93 

Regulation 

13.8.2008, 

p. 30, 

218, 

(OJ 

L 

4  Commission  Implementing  Directive  2014/58/EU  of  16 April  2014  setting  up,  pursuant  to  Directive 
2007/23/EC of the European Parliament and of the Council, a system for the traceability of pyrotechnic 
articles (OJ L 115, 17.4.2014, p. 28, ELI: http://data.europa.eu/eli/dir_impl/2014/58/oj). 

1 

 
 
 
criminal misuse5, and transposition by Member States6 – but no comprehensive evaluation 
of the Directive and Implementing Directive 2014/58/EU has yet been carried out. 

The environment in which EU pyrotechnics legislation operates has changed, not only 
since  the  introduction  of  the  substantive  provisions  in  2007  but  also  since  the  recast  in 
2013. Member States, stakeholders and citizens have drawn the Commission’s attention to 
several shortcomings and problems with the Directive and its implementation. 

Against this background it was necessary to assess the overall performance of the current 
Directive and whether it is still fit for purpose. In line with the Better Regulation Guideline 
and  Toolbox7,  the  evaluation  examined  the  relevance,  effectiveness,  coherence  and 
efficiency  of  EU  pyrotechnics  legislation,  and  its  EU  added  value.  Based  on  the 
evaluation criteria and taking into account the Directive’s objectives and experience with 
implementing it, the following aspects were looked at in particular: 

a)  the appropriateness of requirements, including essential safety requirements; 
b)  the safety of articles imported from non-EU countries, including the effectiveness 

of enforcement of rules for those products; 

c)  the effectiveness of the current system for the traceability of pyrotechnic articles; 
d)  the diversion of articles for use to criminal ends; 
e)  the effectiveness, proportionality and dissuasiveness of penalties; 
f)  the impact of national derogations and possible gold-plating; 
g)  internal coherence and potential gaps; 
h)  the  potential  for  simplification  or  burden  reduction  for  economic  operators  and 

authorities. 

The evaluation focuses on the sector-specific aspects of the Directive, bearing in mind 
that some horizontal issues are addressed by the evaluation of the NLF8. However, where 
appropriate, NLF-related aspects are also included. The evaluation covers the period from 
2015 (when the Directive became fully applicable) until the end of 2024 and covers the 
geographical scope of the EU pyrotechnics legislation, the European Economic Area.9 

Methodological approach 

This  Staff  Working  Document  builds  on  desk  research,  including  Commission  studies, 
academic  literature,  legal  texts  and  grey  literature,  and  on  various  stakeholder 

5  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public.  Final Report, Oxford Research A/S (Denmark), 2019; European 
Commission, F4 Flash Bangers in EU Member States, Study on production, import and use in the EU 
of  high  risk  pyrotechnic  articles  categorised  F4  according  to  Directive  2007/23/EC  and  Directive 
2013/29/EU. Final Report, DJS Research Ltd, 2016; European Commission, Reducing security risks of 
pyrotechnic articles in the EU A study on the security risks related to the handling of large amounts of 
pyrotechnic articles and on ways to mitigate these risks. Final Report, DHV B.V., 2012. 

6  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022. 

7  European  Commission,  Better  regulation  guidelines,  2021;  European  Commission,  Better  Regulation 

Toolbox 2023. 

8 European Commission, Evaluation of the New Legislative Framework, SWD(222) 365 final, 2022. 
9  Agreement  on  the  European  Economic  Area,  Annex  II  Technical  Regulations,  Standards,  Testing  and 

Certification, OJ No L 1, 3.1.1994, p. 3, pp. 352 et seq. 

2 

 
 
consultations, involving economic operators, authorities, notified bodies and citizens. The 
Commission started the evaluation process with a call for evidence, launched in May 2023, 
which aimed to inform the public and stakeholders about the evaluation and to gather their 
feedback on the initiative.  

The  evaluation  was  supported  by  a  study  carried  out  for  DG  GROW  by  Technopolis 
Group, supported by Milieu, Wavestone and Intellera, between October 2023 and February 
202510.  This  Staff  Working  Document  takes  into  account  the  study’s  findings,  but  also 
other relevant  information not  covered by the study. Due to  the  limited  amount of data 
available,  it  is  not  possible  to  substantiate  all  conclusions  quantitatively.  These 
shortcomings were mitigated to the extent possible by using qualitative information. As 
only limited information was available through desk research, the findings strongly rely 
on  the  stakeholder  consultations  that  reflect  participating  stakeholders’  experiences  and 
perspectives. 

For the market analysis, it was not possible to tailor the data from Eurostat’s Structural 
Business Statistics (SBS) to the scope of the evaluation. The statistics for the pyrotechnics 
and  civil  explosives  sectors  fall  under  the  same  NACE  division:  ‘Manufacture  of 
explosives’. This also includes gunpowder and match production. In addition, data was not 
available for every year covered by the evaluation. The cost assessment presented under 
the efficiency criterion is based on very limited data from cost templates, interviews and 
the  targeted  survey.  Although  the  assessment  was  validated  during  the  stakeholder 
workshop,  it  may  not  fully  represent  stakeholders’  costs  associated  with  the  Directive. 
Moreover,  stakeholders  encountered  difficulties  in  classifying  costs  into  adjustment, 
administrative and enforcement costs11. 

A  detailed  description  of  the  methodology  and  main  sources  of  information  for  this 
evaluation are provided in Annex II. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  Description of the intervention and its objectives 

The Directive sets out rules for the making available on the market of pyrotechnic articles, 
including  essential  safety  requirements,  rules  for  conformity  assessment  and  related 
obligations  for  economic  operators.  It  defines  pyrotechnic  articles  as  ‘any  article 
containing explosive substances or an explosive mixture of substances designed to produce 
heat, light, sound, gas or smoke or a combination of such effects through self-sustained 
exothermic chemical reactions’. This includes consumer and professional fireworks and 
emergency flares, but also other pyrotechnic articles that are often components of other 
products, particularly in the automotive industry, such as airbags and seatbelt fasteners in 

10  European  Commission,  Evaluation  study  of  Pyrotechnics  and  Civil  Explosives  Legislation  (Directive 
2013/29/EU,  Commission 
Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025. 

11 These cost categories are used in the Better Regulation (BR) approach and are defined in the BR Toolbox. 

3 

 
 
vehicles.  The  Directive  differentiates  between  eight  categories  of  pyrotechnic  articles, 
based on use and hazard: 

•  F1 to F4: fireworks for entertainment purposes;  
•  T1 and T2: theatrical fireworks for stage use;  
•  P1 and P2: other pyrotechnic articles, including for vehicles. 

Categories F4, T2 and P2 are only for users with specialist knowledge. 

Several kinds of articles are excluded from the scope of the Directive:  

those for use by the armed forces, the police or fire departments; 
those for use in the aerospace industry and as marine equipment; 

• 
• 
•  civil explosives;  
•  percussion caps intended for toys;  
•  ammunition; and 
• 

fireworks  built  and  approved  by  a  Member  State  for  use  exclusively  on  that 
Member State’s territory.  

The categorisation of pyrotechnic articles and related provisions are explained in more 
detail in Annex VI. 

2.1.1.  How did the intervention fit in the wider policy framework? 

As part of a package of proposals (‘the Goods Package’) for several product directives, 
the current Directive brought the rules on pyrotechnic articles into alignment with the New 
Legislative Framework (NLF)12. The NLF was a response to large-scale product recalls 
and product safety problems. The product recalls, particularly in the toys sector, revealed 
shortcomings  in  the  functioning  of  market  surveillance  and  raised  questions  about  the 
ability of EU legislation to protect the health and safety of consumers13. Other important 
policy considerations for the development of the NLF were the need to streamline the rights 
and obligations of economic operators in the single market and across sectors, in line with 
the Better Regulation agenda and the need to strengthen regulatory coherence across EU 
harmonisation legislation14. In the recast, the sector-specific rules established by the 2007 
Directive were essentially brought over into the current Pyrotechnics Directive. 

2.1.2.  Problems and needs that the intervention aimed to address 

Adopting the Directive was considered necessary to align the EU pyrotechnics rules to 
the NLF, which addressed the following horizontal weaknesses and inconsistencies in 
the implementation and enforcement of EU harmonisation legislation: 

12 Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common 
framework  for  the  marketing  of  products,  and  repealing  Council  Decision  93/465/EEC  (OJ  L  218, 
13.8.2008, p. 82, ELI: http://data.europa.eu/eli/dec/2008/768(1)/oj) and Regulation (EC) No 765/2008 
of  the  European  Parliament  and  of  the  Council  of  9 July  2008  setting  out  the  requirements  for 
accreditation and market surveillance relating to the marketing of products and repealing Regulation 
(EEC) No 339/93 (OJ L 218, 13.8.2008, p. 30, ELI: http://data.europa.eu/eli/reg/2008/765/oj). 

13 Impact Assessment accompanying the 10 proposals to align product harmonisation directives to Decision 
No 768/2008/EC, New Legislative Framework (NLF) Alignment Package (Implementation of Goods 
Package), SEC(2011) 1375 final, 2011, p. 7. 

14 European Commission, Evaluation of the New Legislative Framework, SWD(222) 365 final, 2022, p. 10. 

4 

 
 
• 

the  presence  of  non-compliant  or  dangerous  products  on  the  market  and 
consequently a lack of trust in CE marking;  

•  competitive disadvantages for economic operators complying with the legislation 

as opposed to those circumventing the rules;  

•  unequal  treatment  in  the  case  of  non-compliant  products  and  distortion  of 
competition  amongst  economic  operators  due  to  different  enforcement 
practices;  

•  differing  practices  in  the  designation  of  conformity  assessment  bodies  by 

national authorities;  

•  problems with the quality of certain notified bodies for the mandatory third-party 

conformity assessment of pyrotechnic articles15. 

Besides addressing these horizontal issues, the Directive was to continue to address the 
problems and needs that had motivated the adoption of its predecessor, the 2007 Directive: 

•  divergent  legal  frameworks  for  the  placing  on  the  market  and  the  use  of 
pyrotechnic articles in the Member States that created barriers to trade within 
the internal market; 
the  dangers  inherent  to  the  use  of  pyrotechnic  articles  and  different  safety 
requirements across Member States16. 

• 

2.1.3.  General and specific objectives of the intervention 

The  Directive  maintained  the  general  objectives  of  its  predecessor,  as  stipulated  in 
Article 1(1),  according  to  which  the  Directive  aims  to  achieve  the  free  movement  of 
pyrotechnic articles in the internal market while ensuring a high level of protection of 
human  health  and public  security  and  the  protection  and  safety  of  consumers  and 
taking into account the relevant aspects related to environmental protection. 

Linked to those general objectives, the Directive pursues the following specific objectives: 

• 

• 

the harmonisation of rules for the making available of pyrotechnic articles, and 
the strengthening of the single market17; 
the  improvement  of  the  traceability  of  sales  and  transactions  to  prevent  illicit 
possession, misuse and thefts18. 

In addition, the Directive, by implementing the NLF, aimed to: 

•  ensure the quality and credibility of the work of notified bodies; 
increase the effectiveness of market surveillance activities19. 
• 

15 The Directive does not contain the possibility of a self-declaration of conformity. European Commission, 
Proposal for a Directive of the European Parliament and of the Council on the harmonisation of the laws 
of the Member States relating to the making available on the market of pyrotechnic articles (Recast), 
Explanatory Memorandum, COM(2011) 764 final, 2011, p. 5. 

16 European Commission, Proposal for a Directive of the European Parliament and of the Council on the 
placing on the market of pyrotechnic articles (COM(2005) 457 final), Explanatory Memorandum, 2005, 
pp. 2 ff; recital 9 Directive 2007/23/EC; recital 15 of Directive 2013/29/EU. 

17 As already indicated in the title of the Directive. 
18 See Article 9 of the Directive. 
19 European Commission, Proposal for a Directive of the European Parliament and of the Council on the 
harmonisation  of  the  laws  of  the  Member  States  relating  to  the  making  available  on  the  market  of 
pyrotechnic articles (Recast), Explanatory Memorandum, COM(2011) 764 final, 2011, p. 5. 

5 

 
 
Commission  Implementing  Directive  2014/58/EU  aims  to  ensure  traceability  of 
pyrotechnic articles by introducing the requirement that such articles be labelled with a 
registration  number  based  on  a  uniform  numbering  system.  This  labelling  system  is  to 
guarantee  the  identification  of  pyrotechnic  articles  and  their  manufacturers 
throughout all stages of the supply chain.20 

2.1.4.  The intervention logic 

The intervention logic of the evaluation is to examine the inter-relationships between 1) 
the  problems  that  the  Directive  was  designed  to  address;  2)  the  general  and  specific 
objectives that it seeks to achieve; 3) the inputs (such as human and financial resources) 
required to achieve these objectives; 4) the activities and implementation processes; and 
5) the expected effects in terms of outputs (shorter-term outcomes), results (intermediate 
outcomes) and impacts (longer-term outcomes) through which the Directive’s general and 
specific objectives should be achieved. 

Essential  safety  requirements  (ESRs),  in  combination  with  rules  for  conformity 
assessments,  obligations  on  economic  operators  (including  in  relation  to  labelling  and 
traceability)  and  measures  on  market  surveillance  were  established  to  achieve  several 
outputs. It was expected that Member States would adapt their national laws, putting in 
place  measures  to  ensure  that  only  compliant  articles  are  placed  on  the  market.  The 
Directive  also  envisaged  systems  and  procedures  for conformity  assessments,  oversight 
over  notified  bodies,  and  effective  market  surveillance  mechanisms.  A  further  desired 
output  was  the  institutionalisation  of  information  exchange  and  cooperation  between 
market surveillance authorities, economic operators and the European Commission. 

Overall,  these  outputs  were  expected  to  result  in  1)  the  harmonisation  of  laws;  2)  the 
reduction of technical barriers and costs in the single market; 3) improved traceability of 
sales  and  transactions;  4)  higher  compliance  of  pyrotechnic  articles  with  safety 
requirements; and 5) increased quality and credibility of the work of notified bodies. The 
desired impacts of the Directive were: 1) increased intra-EU flows of pyrotechnics and 
enhanced  competitiveness  of  EU  companies;  2)  improved  safety  of  products  and  high 
levels of public security; and 3) the reduction of risks to the environment. 

20 See recital 2 of Commission Implementing Directive 2014/58/EU. 

6 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 1: Intervention Logic 

Source: own preparation 

2.2.  Points of comparison 

A proper assessment of the existing pyrotechnics legislation against the evaluation criteria 
requires a comparison between the current situation and the situation before the Directive 
was adopted. For this purpose, the following points of comparison were identified as the 
baseline. 

2.2.1.  The internal market for pyrotechnic articles 

In 2015, the production value of pyrotechnic articles was approximately EUR 260 million. 
The EU mostly produced signalling flares, rain rockets, fog signals and other pyrotechnic 
articles,  with  a  value  of  EUR 134.5 million,  followed  by  fireworks  at  around  EUR 76 
million. The production value of matches was approximately EUR 49.5 million21. The EU 
was  a  net-importer  of  pyrotechnic  articles,  with  imports  of  approximately  EUR 283 

21 As covered by the available Prodcom Data (INDICATORS: PRODVAL, PRCCODE: Fireworks, Matches 
(excluding Bengal matches and other pyrotechnic products), Signalling flares, rain rockets, fog signals 
and other pyrotechnic articles (excluding fireworks)). It should be noted that these statistics do not take 
into account the scope exemptions in the Pyrotechnics Directive, such as that for maritime equipment. 
Consequently, some articles covered by the figures presented in this section, e.g. signalling flares in the 
scope  of  Directive  2014/90/EU  on  maritime  equipment,  might  not  be  subject  to  the  Pyrotechnics 
Directive. 

7 

   
 
 
 
 
 
 
 
 
 
 
million,  exceeding  its  exports  of  around  EUR 110  million.  The  overall  negative  trade 
balance was due to the significant reliance on imports of fireworks. For matches, signalling 
flares, rain rockets, fog signals and other pyrotechnic articles, the EU was a net exporter22. 

Figure 3: Extra-EU trade in pyrotechnic articles in 2015 

)
s
o
r
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e
f
o
s
n
o

i
l
l
i

m

(
e
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V

l

300

250

200

150

100

50

0

Fireworks

Matches

Signalling flares,
rain rockets,
fog signals and
other pyrotechnic
articles

Export

Import

Source: own preparation  based on    Standard  International  Trade  Classification  (SITC)  Data  (Eurostat)  (INDICATORS: 
VALUE_IN_EUROS,  PRODUCT:  Fireworks,  Matches  (excluding  Bengal  matches  and  other  pyrotechnic  products), 
Signalling flares, rain rockets, fog signals and other pyrotechnic articles (excluding fireworks)) 

Trade between Member States was most pronounced for fireworks, but matches, signalling 
flares, rain rockets, fogs signals and other pyrotechnic articles were also actively traded. 
Overall,  intra-EU  trade  (using  Eurostat  intra-EU  export  figures)  amounted  to  EUR 165 
million23. 

Figure 4: Intra-EU export of pyrotechnic articles in 2015 

)
s
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r
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e
f
o
s
n
o

i
l
l
i

m
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l

80
70
60
50
40
30
20
10
0

Fireworks

Matches

Signalling flares,
rain rockets, fog
signals and other
pyrotechnic
articles

Source: own preparation based on SITC Data (Eurostat) (INDICATORS: VALUE_IN_EUROS, PRODUCT: Fireworks, Matches 
(excluding  Bengal  matches  and  other  pyrotechnic  products),  Signalling  flares,  rain  rockets,  fog  signals  and  other 
pyrotechnic articles (excluding fireworks)) 

22  SITC  Data  (Eurostat)  (INDICATORS:  VALUE_IN_EUROS,  PRODUCT:  Fireworks,  Matches 
(excluding Bengal matches and other pyrotechnic products), Signalling flares, rain rockets, fog signals 
and other pyrotechnic articles (excluding fireworks). 

23 Ibid. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
As regards the size and structure of the market, no data is available for 2015. However, at 
the time of the impact assessment for the Goods Package in 2011, the market size of the 
EU’s pyrotechnic sector was estimated at EUR 4.2 billion per year. The impact assessment 
differentiated between the two biggest sub-sectors – fireworks and pyrotechnic articles in 
vehicles. Of the overall EU pyrotechnics market, EUR 1.4 billion per year was attributable 
to the fireworks sector, with equal shares for sales to consumers (categories 1, 2 and 3) and 
sales to professionals (category 4). The fireworks industry in the EU was composed mainly 
of  SMEs,  employing  collectively  between  15 000  and  20 000  people  in  the  EU.  This 
estimate was made with the caveat that most companies were operating in more than just 
the field of fireworks and employed seasonal workers in the end-of-year period. Businesses 
were mostly active in distribution, storage and professional display of fireworks. The small 
EU  firework-manufacturing  sector  was  predominantly  engaged  in  the  production  of 
fireworks for professional use (F4) and was concentrated in Germany, Italy, France, Spain, 
Portugal and the UK24. 

In contrast, the size of the market in automotive pyrotechnic articles in 2011 was EUR 2.8 
billion,  including  airbag  systems  (EUR 1.8  billion)  and  seatbelts  (EUR 1  billion).  The 
market  for  automotive  pyrotechnic  articles  was  dominated  by  a  few  big  international 
automotive  supplier  companies  with  a  total  of  around  40 000  employees.  They  were 
responsible for approximately two thirds of pyrotechnic article sales in the EU25. 

2.2.2.  Human health and safety 

The safety situation was not comprehensively assessed for the recast of the Directive in 
2013. However, in  the  impact  assessment, a projection by the EU injury database from 
2010 was cited which revealed an annual average of 27 000 injuries due to fireworks in 
the EU, representing 0.07% of all injuries. Misuse was estimated to be the main cause of 
these accidents, but high product failure rates (up to 50%) were also reported26. A study 
carried out for the European Commission and published in 2019 estimated on the basis of 
data from  the European Injury Database27 that, between 2013 and 2015,  around 16 000 
fireworks accidents happened each year. This counted only those reported by hospitals28. 
Some  fragmented  accident  data  from  Member  States  is  also  available  from  the  period 
around the entry into application of the Directive. For instance29, the Romanian authorities 
reported to the Commission that 17 accidents with pyrotechnic articles were recorded in 
Romania  in  2013,  and  33  in  2014.  These  accidents  predominantly  led  to  hand  injuries, 

24  European  Commission,  Impact  Assessment  accompanying  the  10  proposals  to  align  product 
harmonisation directives to Decision No 768/2008/EC, New Legislative Framework (NLF) Alignment 
Package (Implementation of Goods Package), SEC(2011) 1375 final, 2011, p. 62. 

25 Ibid. 
26 Ibid., p. 63. 
27  The  European  Injury  Database  is  an  injury  surveillance  system  based  on  accident  and  emergency 

department data from selected hospitals in various EU member states. 

28  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, p. 64. 
29 Some other Member States also submitted accident data to the Commission for these years, but given the 
lack of data from  other Member States and the difficulty  in comparing the data available, only  some 
accident figures are presented here, for illustrative purposes. 

9 

 
 
followed  by  eye  injuries.  Portugal  reported  10  and  11  accidents  in  2013  and  2014 
respectively,  mostly  involving  F4  fireworks.  Denmark  recorded  233  accidents  at  New 
Year’s Eve 2013/2014 and 334 in 2014/2015, also mostly causing hands and eyes injuries. 

This fragmented data on accidents makes it difficult to draw a reliable picture of the safety 
of pyrotechnic articles at that time. Nevertheless, the high level of non-compliance in the 
sector observed at the time was clearly one of the reasons for the NLF alignment. In the 
public  consultation  for  the  impact  assessment  of  the  Goods  Package,  78%  of  the 
responding  authorities  and  50%  of  the  responding  notified  bodies  indicated  that  they 
considered the pyrotechnic sector to be affected by non-compliance30. For most sectors, 
the ineffective operation of market surveillance in the European Union, exacerbated by the 
limited  traceability  of  articles,  was  identified  as  the  main  reason  for  the  high  non-
compliance rates. Other factors included inadequate conformity assessments, in particular 
where  subcontractors  of  notified  bodies  were  located  outside  the  EU31.  This  issue  was 
particularly  acute  in  the  case  of  fireworks,  which  are  predominantly  produced  in  third 
countries and imported into the EU32. Insufficient coordination between notified bodies 
was also seen as contributing to the varying quality of conformity assessments33. 

2.2.3.  Public security 

The recast in 2013 was meant to address issues in conformity assessments and enforcement 
and did not assess or touch upon security. However, a study in 2012 commissioned by the 
European Commission analysed the misuse of pyrotechnic articles for terrorist purposes, 
criminal activities and to disturb public order. As regards terrorist activities, the study 
pointed to the fact that pyrotechnic  articles, more precisely flash bangers, were used as 
boosters to spread flammable liquids and gases in the New York Times Square bombing 
attempt in 2010. Moreover, high-energy pyrotechnic substances (like flash compositions) 
were identified as potential materials used for bombings, considering that terrorists could 
acquire large quantities of pyrotechnic shells, open them relatively easily and extract the 
flash composition in quantities of up to 300 grams. Lastly, according to the study, terrorists 
also sometimes used certain pyrotechnic articles, such as gas generators, as components of 
homemade improvised explosive devices34. 

Other criminal uses identified by the study were the use of pyrotechnic articles to enter 
buildings,  to  frighten  or  warn  people  or  to  build  pipe  bombs.  In  addition,  theft  of 
pyrotechnic articles, e.g. from a storage location, transport containers or from vehicles (e.g. 
airbags)  was  a  concern  raised.  In  terms  of  disturbances  of  public  order,  the  study 
highlighted  vandalism  and  hooliganism,  notably  around  New  Year’s  Eve,  but  also  in 

30  European  Commission,  Impact  Assessment  accompanying  the  10  proposals  to  align  product 
harmonisation directives to Decision No 768/2008/EC, New Legislative Framework (NLF) Alignment 
Package (Implementation of Goods Package), SEC(2011) 1375 final, 2011, p. 19. 

31 Ibid., pp. 19-25. 
32 Ibid., p. 61. 
33 Ibid., p. 26. 
34 European Commission, Reducing security risks of pyrotechnic articles in the EU: a study on the security 
risks related to the handling of large amounts of pyrotechnic articles and on ways to mitigate these risks. 
Final Report, DHV B.V., 2012, p. 57. 

10 

 
 
football stadia (with distress signals such as hand-held flares). Consumer and professional 
fireworks,  and  illegal  fireworks  obtained  online,  were  the  articles  most  associated  with 
criminal  misuse  by  stakeholders.  More  generally,  the  study  concluded  that  the  broad 
availability of pyrotechnic articles facilitated their misuse35. 

2.2.4.  Harmonisation of laws and implementation 

Member States were obliged to transpose the 2007 Directive by 2010, thereby harmonising 
their  laws,  which  had  previously  differed  significantly  in  terms  of  classification  and 
authorisation systems for pyrotechnic articles, labelling and sales restrictions36. Since the 
pyrotechnics-specific provisions were retained in the NLF alignment, Member States did 
not need to adapt their laws to these provisions when the current Pyrotechnics Directive 
was adopted in 2013. 

For  the  recast,  no  mapping  of  the  pyrotechnics-specific  rules  in  Member  States  was 
undertaken, as this was not the focus of the initiative. However, the absence of EU-wide 
obligations  for  importers  and  distributors,  which  led  to  differing  rules  in  the  Member 
States, was considered a problem. This contributed to different approaches to cases of non-
compliance by market surveillance authorities. For instance, measures taken against the 
non-compliant  product  concerned  varied  in  severity  depending  on  the  product  and  the 
authority  involved.  Different  approaches  were  applied  to  importers  and  distributors  to 
demonstrate compliance. Cases were reported in which non-compliant products had been 
withdrawn in one Member State but could still circulate in another Member State37. 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

Current state of play 

This section will outline the development of the legal and factual situation for pyrotechnic 
articles in the EU since the adoption of the current Directive, structured by the points of 
comparison described in the previous section. 

3.1.  The market for pyrotechnic articles 

There does not seem to have been any significant change in EU production of signalling 
flares,  rain  rockets,  fog  signals  and  other  pyrotechnic  articles,  matches  and  fireworks38 
since the adoption of the current Pyrotechnics Directive. Post-adoption production figures 
are generally in the same range as in the years before adoption (2009-2011), although there 

35 Ibid., pp. 57-59. 
36 European Commission, Proposal for a Directive of the European Parliament and of the Council on the 
placing on the market of pyrotechnic articles (COM(2005) 457 final), Explanatory Memorandum, 2005, 
p. 2 et seq. 

37  European  Commission,  Impact  Assessment  accompanying  the  10  proposals  to  align  product 
harmonisation directives to Decision No 768/2008/EC, New Legislative Framework (NLF) Alignment 
Package (Implementation of Goods Package), SEC(2011) 1375 final, 2011, p. 21. 

38 It must be noted that these statistics do not take into account the scope exemptions in the Pyrotechnics 
Directive, such as those for maritime equipment. Consequently, some articles covered by the figures 
presented  in  this  section,  e.g.  signalling  flares  in  the  scope  of  Directive  2014/90/EU  on  maritime 
equipment, might not be subject to the Pyrotechnics Directive. 

11 

 
 
were small temporary peaks in production in 2012 and 2018, and a minor decline in 202039. 
Low production volumes of fireworks during the COVID-19 pandemic seem to have been 
largely balanced by increased production of signalling flares, rain rockets, fog signals and 
other  pyrotechnic  articles.  After  the  pandemic,  the  production  of  fireworks  recovered 
quickly and exceeded pre-pandemic levels in 2022, with a value of EUR 90 million. There 
were also slight increases in post-COVID production of matches40. A slight decrease in 
production was recorded in 2023. At the time of the evaluation, data for 2024 was not yet 
available. 

Figure 5: EU production of pyrotechnic articles 2009-2023 

Production value of pyrotechnic articles 2009-2023

)
s
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r
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e
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s
n
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i
l
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(
e
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l

400
350
300
250
200
150
100
50
0

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Fireworks Matches

Signalling flares, rain rockets, fog signals and other pyrotechnic articles

Source: own preparation based on Prodcom Data (INDICATORS: PRODVAL, PRCCODE: Fireworks, Matches (excluding 
Bengal  matches  and  other  pyrotechnic  products),  Signalling  flares,  rain  rockets,  fog  signals  and  other  pyrotechnic 
articles (excluding fireworks)), not inflation-adjusted 

The  EU  continues  to  be  an  overall  net  importer  of  pyrotechnic  articles,  with  imports 
increasing  over  recent  years,  reaching  an  all-time  high  of  EUR 452  million  in  2024. 
Fireworks still represent the largest share of imports and affect the overall trade balance: 
while the EU continues to be a net importer of fireworks, it is a net exporter of signalling 
flares, rain rockets, fog signals and other pyrotechnic articles, and of matches. In the years 
following  the  adoption  of  the  Directive  exports  remained  relatively  stable  at  around 
EUR 110  million  annually,  but  in  recent  years  they  have  increased  slightly,  to 
approximately  EUR 150  million.  The  biggest  share  of  imports  still  comes  from  China, 
followed by the US41. The US is also the main destination for extra-EU exports42. 

39 Production value refers to the value of sold production of pyrotechnic products manufactured in the EU. 
Prodcom  Data  (INDICATORS:  PRODVAL,  PRCCODE:  Fireworks,  Matches  (excluding  Bengal 
matches  and  other  pyrotechnic  products),  Signalling  flares,  rain  rockets,  fog  signals  and  other 
pyrotechnic articles (excluding fireworks)), not inflation-adjusted. 

40 Ibid. 
41  SITC  Data  (Eurostat)  (INDICATORS:  VALUE_IN_EUROS,  PRODUCT:  Fireworks,  Matches 
(excluding Bengal matches and other pyrotechnic products), Signalling flares, rain rockets, fog signals 
and other pyrotechnic articles (excluding fireworks)). 

42 Ibid. 

12 

 
 
 
 
 
 
 
In 2024, the EU imported fireworks with a value of approximately EUR 407 million, and 
exported signalling flares, rain rockets, fog signals and other pyrotechnic articles with a 
value of about EUR 108 million43. 

Figure 6: Extra-EU trade in pyrotechnic articles 2014-2024 

Extra-EU trade in Pyrotechnics 2014-2024

)
s
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i
l
l
i

m

(
e
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V

l

500

400

300

200

100

0

Export

Import

Source: own preparation based on SITC Data (Eurostat) (INDICATORS: VALUE_IN_EURO, PRODUCT: Fireworks, Matches 
(excluding  Bengal  matches  and  other  pyrotechnic  products),  Signalling  flares,  rain  rockets,  fog  signals  and  other 
pyrotechnic articles (excluding fireworks)), not inflation-adjusted 

When examining the developments in intra-EU trade, it is worth looking at the data since 
1999. 

Figure 8: Intra-EU exports in pyrotechnic articles 1999-2024 

Intra-EU export in pyrotechnic articles 1999-2024

)
s
o
r
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e
f
o
s
n
o

i
l
l
i

m
n
i
(
e
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V

l

400

350

300

250

200

150

100

50

0

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

Source: Evaluation Study based on SITC Data (Eurostat)(INDICATORS: VALUE_IN_EUROS, PRODUCT: Fireworks, Matches 
(excluding  Bengal  matches  and  other  pyrotechnic  products),  Signalling  flares,  rain  rockets,  fog  signals  and  other 
pyrotechnic articles (excluding fireworks)), not inflation-adjusted 

An upward trend in intra-EU trade was already observed after the adoption of the 2007 
Directive  and  this  continued  after  the  adoption  of  the  current  Directive.  In  particular, 
exports from Member States to other Member States have increased at an accelerated pace 

43   Ibid. 

13 

 
 
 
 
 
 
 
 
 
 
since 2021, reaching a value of approximately EUR 376 million in 202344. This might be 
due to increased imports of fireworks from outside the EU in 2022, which were then traded 
within the EU. In 2024, intra-EU exports decreased slightly. 

Currently there are no public or private databases that can be used to conduct a market 
analysis of pyrotechnic devices for the automotive industry45. Case study 2 aimed to 
shed light on the state of this sector and revealed that the market has remained stable since 
the implementation of the Pyrotechnics Directive, with the EU industry generating 40% of 
the global market’s turnover from these products. Pyrotechnic automotive parts seem to be 
an  area  of  innovation,  with  the  development  of  new  products  that  aim  to  improve 
passengers’ safety46. 

Information  on  the  development  of  the  market  structure,  including  the  number  of 
businesses and employees and turnover, are presented in Annex VII.1. 

3.2.  Human health and safety 

Despite  the  obligation  imposed  on  Member  States  to  report  accident  statistics  to  the 
Commission, introduced by Commission Implementing Decision (EU) 2023/109647, it is 
still  difficult  to  identify  clear  trends  in  pyrotechnics-related  accidents  and  to  derive 
conclusions  on  the  safety  of  pyrotechnic  articles.  This  results  on  the  one  hand  from 
different reporting practices of Member States and, on the other hand, from the difficulty 
of identifying the cause of accidents due to the many factors that can cause such accidents 
and the fact that the article concerned is destroyed in the accident. While accident statistics 
submitted  by  Sweden  show  an  overall  decrease  in  the  number  of  accidents  related  to 
pyrotechnic articles between 2012/2013 and 2021/2022, but a strong increase from 2023, 
data from Ireland indicate more fluctuation during that period, with no identifiable trend48. 

Data from the EU rapid alert system Safety Gate is also useful to get an idea of the nature 
and  scale  of  safety  issues  occurring  in  Member  States.  In  2024,  60  unsafe  pyrotechnic 
articles were notified via Safety Gate, which is the highest number of incidents since 2015. 
The articles concerned were mainly fireworks imported from China that were withdrawn, 
recalled or destroyed because they were found to pose a risk of burns, damage to sight or 
hearing  or  other  injuries,  but  also  of  fires.  The  number  of  notifications  in  Safety  Gate 

44 Ibid. 
45  European  Commission,  Evaluation  study  of  Pyrotechnics  and  Civil  Explosives  Legislation  (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report,  Technopolis  Group  in  collaboration  with  Milieu,  Wavestone,  and  Intellera,  2025,  Annexes, 
2025, p. 250. 

46 CLEPA, New technologies for green and digital mobility take first prize at the CLEPA Innovation Awards 

2022, 14 October 2022. 

47 Commission Implementing Decision (EU) 2023/1096 of 2 June 2023 laying down rules for the application 
of Directive 2013/29/EU of the European Parliament and of the Council as regards the regular collection 
and updating of data on accidents related to the use of pyrotechnic articles (OJ L 146, 6.6.2023, p. 24, 
ELI: http://data.europa.eu/eli/dec_impl/2023/1096/oj). 

48 These two countries are taken as example because both submitted an overview of accident numbers over 

this period of time. 

14 

 
 
concerning pyrotechnic articles has significantly increased since the entry into application 
of the Directive49.  

Data from the Information and Communication System for Market Surveillance (ICSMS) 
shows that in 2024, 58.3% (233 out of 400) of the pyrotechnic articles tested by market 
surveillance  authorities  were  non-compliant,  of  which  68%  were  imported  from  China. 
Compared with 2015, when 86.5% (186 out of 215) of products tested were found non-
compliant, this seems to be an improvement, but the 2024 numbers are still dissatisfactory. 
Since 201050, non-compliances posing a risk have been detected in 77.1% (1 274 out of 
1 653)  of  all  completed  inspections  of  pyrotechnic  articles  reported  in  ICSMS.  In 
comparison, the non-compliance rate (with risk) over this period was 77.6% (7, 820 out of 
10, 082) for personal protective equipment, 91.5% (4, 313 out of 4, 713) for vehicles, and 
90.1% (3, 881 out of 4, 271) for radio equipment. This shows that non-compliances are an 
issue across different pieces of product legislation. It should be noted, however, that not 
all market surveillance authorities systematically report cases in  ICSMS and some only 
report cases where non-compliances were found. 

Stakeholders that responded in the targeted survey did not confirm the trend derived from 
Safety Gate and ICSMS and generally seem to be uncertain about the trends in accidents 
and  health  and  safety  issues,  with  about  40%  (29  out  of  73)  choosing  the  ‘Do  not 
know/prefer not to say’ option. However, 31.5% (23 out of 73) indicated that the number 
of accidents and health issues involving pyrotechnic articles has remained the same since 
the start of application of the current Directive in 2016, while 24.7% (18 out of 73) reported 
a  decrease.  The  overall  perception  of  stakeholders  in  the  public  consultation  was  that 
pyrotechnic articles in the single market are safe51. 

Besides the risk of accidents, which comes mainly from illegal or improper handling by 
individuals52, the harmful effects of the chemical substances released during fireworks 
displays  have  become  a  point  of  concern  in  recent  years.  A  study  published  in  2020 
suggests that significant amounts of toxic metal are released from both private fireworks 
and  larger  commercial  pyrotechnic  displays,  with  potential  adverse  cardiopulmonary 
effects53. Also, the awareness of the risks of noise exposure during fireworks seems to 
have increased54. 

49 One notification in 2015, nine in 2016 and 22 in 2017. 
50 This year was chosen because there is comparative data available for several sectors for the period from 

2010 to 2025. 

51 64.9% (24 out of 37) of respondents answered ‘Yes’ to the question whether pyrotechnic articles are safe, 
while 27% (10 out of 37) answered ‘No’. 8.1% (3 out of 37) responded ‘Do not know/prefer not to say’. 
52 Ulbricht, J., Doberentz, E. & Madea, B., Death on New Year’s Eve caused by illegal fireworks—a firework 

shell, Forensic Sci Med Pathol 20, 2024, 205-211, p. 205. 

53  Hickey,  C.,  Gordon,  C.,  Galdanes,  K.  et  al.,  Toxicity  of  particles  emitted  by  fireworks.  Part  Fibre 

Toxicology 17:28, 2020, 7-11, p. 8. 

54 Kukulsky, B., Wszolek, T., Mleczko, D., The Impact of Fireworks Noise on the Acoustic Climate in Urban 
areas, Archives of Acoustics 43:4, 2018, 697-705, Purdue University, Fireworks are fun for the eyes, 
dangerous  for  the  ears,  says  Purdue  audiology  expert,  26 June  2018;  American  Speech-Language-

15 

 
 
 
The misuse of pyrotechnic articles in sports stadia has also become a safety and security 
concern over the last two decades,  as described  in  a study carried out  on behalf of  the 
European  Football  Associations  (UEFA)  and  as  noted  more  recently  in  Council 
Conclusions  13370/2022  on  the  use  of  fireworks  in  football  stadia55.  The  UEFA  study 
identified several health and safety  risks, including burns and other wounds, vision and 
hearing impairments, effects of smoke, and panic56. 

3.3.  Public security 

The security situation related to pyrotechnic articles has become more severe in recent 
years.  35.3%  (24  out  of  68)  of  respondents  to  the  targeted  survey  believe  that  illicit 
activities have increased or strongly increased, while 19.1% (13 out of 68) indicated that 
the number has remained constant57. The most prevalent types of illicit activity, according 
to  stakeholders,  include  black  market  sales/illegal  trade  (including  through  online 
shopping), misuse for criminal  activities and diversion  of the product  (e.g. use by non-
professionals)58. Besides the recurrent misuse in football stadia and in riots (see Case Study 
1), the use by criminals to  break into automated teller machines (ATMs) has  become a 
frequently  observed  phenomenon  in  the  past  years,  especially  in  Germany59.  A  study 
carried  out  for  the  European  Commission  in  2019  found  that,  while  the  misuse  of  F4 
fireworks by the public on New Year’s Eve is much more common than criminal activities 
to harm persons and damage property, there is a significant black market for the illegal 
sale of F4 category pyrotechnics online used by organised crime groups. An investigation 
in Poland in December 2018 resulted in the seizure of 80 tonnes of F4 pyrotechnics, and 
the assessment of the evidence revealed that organised crime groups ship an estimated 
1 000 kg of F1-F3 fireworks and 500 kg of F4 pyrotechnics to different Member States 
every day60. Based on a sample, the study estimated that around 73% of online retailers 
sell  F4  pyrotechnic  articles  without  checking  the  buyers’  specialist  knowledge61. 
Moreover, the Terrorism Situation and Trend Report of 2019 reported an increased use of 
pyrotechnics products in planned or plotted terrorist attacks in Europe62. 

Hearing  Association,  Fireworks  Can  Cause  Permanent  Hearing  Loss,  But  Simple  Steps Can  Prevent 
Harm This July 4th, 24 June 2024. 

55 Council of the European Union, Council Conclusions concerning the need to prevent and counter the use 
of pyrotechnics in spectator areas of football stadia and other sports venues, 13 October 2022, 13370/22. 
56 UEFA, Pyrotechnics in Stadia: Health and Safety issues relating to the use of pyrotechnics in football 

stadia, 2016. 

57 When asked how the number of cases of illicit activities linked to products covered by the Directive had 
changed  since  the  entry  into  application  of  the  Directive  in  2015,  20.06%  (15  out  of  68)  selected 
‘increased’, 13.24 (9 out of 68) ‘strongly increased’ and 19.12% (12 out of 68) ‘remained unchanged’. 

58 Targeted survey: replies to open question. 
59 See Europol,  350 tonnes of dangerous fireworks seized in Germany and the Netherlands, 9 November 
2022; Matussek, K., Germany Is Europe’s Prime Target for Audacious ATM Bombings, Bloomberg, 
12 August 2024. 

60  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, pp. 82 et seq. 

61 Ibid. p. 47. 
62 Europol, European Union Terrorism Situation and Trend Report 2019, 2019, p. 18. 

16 

 
 
However, obtaining an EU-wide picture of the security problem is difficult as the channels 
used for such criminal activities are often hidden from the authorities, for instance by the 
use  of  non-compliant  web-shops  to  sell  pyrotechnics  to  non-authorised  users  and  by 
shipping products in unlabelled parcels. Postal and courier companies are unable to prevent 
the misuse of their services for illegal trade and are exposed to serious risks from unmarked 
parcels  containing  pyrotechnic  articles63.  As  most  fireworks  are  imported  from  third 
countries, effective customs controls are essential to discover illegal trade flows but the 
number  of  parcels  flooding  the  EU  market  as  a  consequence  of  e-commerce  poses 
challenges for customs authorities64. 

As  this  evaluation  was  being  finalised,  a  feasibility  study  on  the  criminal  misuse  of 
pyrotechnic articles  was  being  carried out  for the Directorate-General  of  Migration and 
Home Affairs, aiming to provide a broader and more in-depth analysis of security issues 
involving pyrotechnic articles. 

3.4.  Environmental protection 

Finally, the negative impact of fireworks on the environment, including on domestic and 
wild animals, has in recent years been the focus of many academic articles and calls from 
environmental non-governmental organisations (NGOs)65. Concerns include disturbance 
of migratory or reproductive behaviour of wildlife and animal welfare more generally, as 
well as chemical pollution of soil, water and air66. 

Fireworks release substances that contaminate water bodies or are taken up by plants and 
end up in insects, mammals, amphibians and fishes67. Heavy metals are also emitted by 
fireworks, some of them inhalable and/or bioaccumulative68. As regards animal welfare, a 
study from 2024 carried out by the Faculty of Veterinary Medicine at Utrecht University 
in the Netherlands found that almost 80% of cats and dogs experience stress and fear as a 

63  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, pp. 82 et seq. 
64 In the targeted survey, 58,3%, (14 out of 24) of respondents attributed high importance (4 or 5 out of 5) 
to the challenge of e-commerce and the related difficulty to control transport and parcel deliveries and 
54.1% (13 out of 24) recognised the high importance (4 or 5 out of 5) of the challenge of global supply 
chains. 

65  See  e.g.  Bateman  et  al.,  Not  just  a  flash  in  the  pan:  short  and  long  term  impacts  of  fireworks  on  the 
environment,  Pacific  Conservation  Biology  29:5,  2023;  396-401;  Camilleri,  R.,  Vella  J.,  Emission 
Factors for Aerial Pyrotechnics and Use in Assessing Environmental Impact of Firework Displays: Case 
Study  from  Malta,  Propellants,  Explosives,  Pyrotechnics,  41:2,  2015,  273-280;  Collins,  M.,  The 
Environmental Impact of Fireworks: Celebrations and Consequences, E+E Leader, 2 July 2024; Han, J., 
Crowd-Pleasing Fireworks Are Not So Pleasing to the Planet, Earth.org, 19 April 2023. 

66 Bateman et al., Not just a flash in the pan: short and long term impacts of fireworks on the environment, 
Pacific Conservation Biology 29:5, 2023, 396-401, p. 396; Collins, M., The Environmental Impact of 
Fireworks: Celebrations and Consequences, E+E Leader, 2 July 2024. 

67 Such as sulphur dioxide, carbon dioxide, carbon monoxide, suspended particles, aluminium, manganese, 
potassium nitrate, charcoal and sulphur. Inorganic anion perchlorates (such as potassium perchlorate and 
ammonium  perchlorate)  are  particularly  concerning  since  perchlorates  are  water-soluble  and  stable. 
Reviewed in Sijimol, M.R./Mohan, M., Environmental impacts of perchlorate with special reference to 
fireworks—a review, Environmental Monitoring and Assessment 186, 2014, 7203-7210, pp. 7203-7204. 
68 Reviewed in Bateman et al., Not just a flash in the pan: short and long term impacts of fireworks on the 

environment, Pacific Conservation Biology 29:5, 2023, 396-401, p. 398. 

17 

 
 
consequence of hearing fireworks; for more than a third of cats and dogs the fear lasts for 
more than half an hour after the firework noise69. There have even been reports of deaths 
of pets during or following fireworks, presumably due to stress70. The effect of fireworks 
on wildlife is more difficult to study, but strong flight responses have been observed in 
studies on the impact of fireworks on birds71. 

3.5.  Harmonisation of laws and implementation 

A study carried out in 2022 concluded that the transposition of the Directive is generally 
satisfactory,  although  the  transposition  in  most  Member  States  showed  several 
shortcomings72. 

The Directive leaves Member States a certain degree of discretion in the transposition of 
the harmonised EU rules, and this has led to national laws that differ considerably in some 
aspects. Article 4(2) of the Directive allows Member States  to prohibit or restrict the 
possession, use and/or the sale to the general public of categories F2 and F3 fireworks, 
theatrical  pyrotechnic  articles  and  other  pyrotechnic  articles  on  grounds  of  public 
order, security, health and safety, or environmental protection. In 2022, ten Member States 
had introduced prohibitions or restrictions under Article 4(2) of the Pyrotechnics Directive, 
including the prohibition of mail order/online sales, limits on net explosives mass and the 
prohibition of sales of F3 and certain F2 fireworks to the general public73. 

Some  Member  States  impose  certain  licensing  obligations,  while  others  do  not.  Those 
with  licensing requirements generally exempt category F1,  and some also  exempt  F274. 
Moreover, the majority of Member States have made use of the option under Article 7 to 
increase the required minimum age, changing the age limits for sales of F1 fireworks from 
12 to 14, 15, 16 or 18, and/or the age limits for F2 fireworks from 16 to 18. Two Member 
States have also increased the minimum age for F3 fireworks from 18 to 2175. 

Significant  differences  between  Member  States’  laws  also  exist  with  regard  to  the 
definition of a ‘person with specialist knowledge’ and the requirements for acquiring this 
status76.  The  definitions  in  ten  Member  States  only  refer  to  certifications  and/or 

69 Herwijnen et al., Firework aversion in cats and dogs as reported by Dutch animal owners, Veterinary and 

Animal Science 26:100402, 2024, pp. 1, 4. 

70 See for instance Magliocco, S., ‘Distraught’ family makes heartfelt Halloween plea after death of cat due 
to firework fright, RSVP Live, 29 October 2024; Hartmann, I., Silvester war Nacht der Panik für Hunde 
in Bad Kreuznach, SWR, 1 January 2025. 

71 Hoekstra et al., Fireworks disturbance across bird communities, Frontiers in Ecology and the Environment 
22:1,  2024,  e2694;  Shamoun-Baranes  et  al.,  Birds  flee  en  mass  from  New  Year’s  Eve  fireworks, 
Behavioural Ecology 22:6, 2011, 1173-1177. 

72  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022, p. 34. 

73 Ibid., pp. 51-55. 
74 Ibid., pp. 70-73. 
75 Ibid., pp. 65-68. 
76  For  instance,  one  Member  State  requires  certification  in  accordance  with  EN  ISO/IEC  17024,  while 
another Member State presupposes (i) the successful participation in a state or state-recognised course 

18 

 
 
 
authorisations  delivered  by  their  own  national  authorities.  This  raises  questions  about 
mutual  recognition  of  specialist  knowledge  between  Member  States.  Moreover,  the 
Directive  leaves  it  to  the  discretion  of  the  Member  States  to  lay  down  rules  for  the 
authentication  and  verification  of  persons  with  specialist  knowledge.  Belgium,  the 
Netherlands and Luxemburg have jointly decided to introduce a uniform control document 
in the Benelux area – the so-called Pyro-pass77. 

The Pyro-pass in the Benelux countries 

The Benelux Union, with the adoption of Benelux Decision 2020(14), introduced a 
‘Pyro-pass’  which  aims  to  facilitate  the  verification  of  specialist  knowledge  by 
economic  operators  and  thereby  prevent  pyrotechnic  articles  from  ending  up  in  the 
hands of unauthorised persons. The Pyro-pass  is a uniform  identification document 
issued  to  persons  recognised  by  the  authorities  as  having  specialist  knowledge.  A 
register is used to keep track of all issued and active Pyro-passes. Economic operators 
must  consult  this  register  before  supplying  pyrotechnic  articles  requiring  specialist 
knowledge and keep a  copy of the Pyro-pass,  the related invoice  and any transport 
documents required under Directive 2008/68/EC. 

Moreover,  there  are  significant  differences  in  the  transposition  of  the  obligation  to 
establish  effective,  proportionate  and  dissuasive  penalties  under  Article 45.  The 
amounts  of  the  fines  range  from  a  minimum  of  EUR 600  in  one  Member  State  to  a 
maximum (criminal) fine of EUR 10.8 million in another Member State. Imprisonment is 
a possibility in only half of the Member States, with prison terms ranging from 60 days to 
seven  years.  Other  penalties  introduced  by  Member  States  include  forfeiture  and 
confiscation,  market  restrictions  and  prohibitions,  and  the  relocation  and  suspension  of 
licences78. 

In seven Member States, restrictions on the free movement (Article 4(1)) of pyrotechnic 
articles  have  been  observed.  These  come  in  two  categories:  (1)  the  introduction  of  an 
obligation to register or notify pyrotechnic articles to national authorities before they are 
placed  on  the  market,  and  (2)  the  introduction  of  restrictions  on  the  sale  and/or  use  of 
pyrotechnic articles beyond those in the Pyrotechnics Directive79. 

of  instruction  for  the  intended  activity,  (ii)  practical  experience  of  at  least  three  years,  or  (iii)  the 
completion  of  a  course  of  study  at  a  university/university  of  applied  sciences/technical  school  and 
practical experience of at least one year. European Commission, Study of conformity in all EU countries 
on EU pyrotechnics and explosives legislation. Final Report, EY Law, 2022, pp. 56-62, p. 64. 

77 Decision du Comité de Ministres Benelux relative à l’introduction d’un pyro-pass du 7 décembre 2020, 

M (2020) 14. 

78  European  Commission,  Evaluation  study  of  Pyrotechnics  and  Civil  Explosives  Legislation  (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025, p. 47. 
79  Restrictions  of  the  latter  kind  include  the  prohibition  of  mail  order  sales,  maximum  limits  for  the 
availability, possession, transport and storage of pyrotechnic articles and limiting the sale of consumer 

19 

 
 
 
 
 
 
 
 
 
 
 
Annex VII.2 provides a more detailed overview of transposition and implementation of the 
Directive in Member States. 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

4.1.  To what extent was the intervention successful and why? 

This  chapter  summarises  the  evaluation  findings  in  terms  of  effectiveness  (fulfilling 
expectations and meeting objectives), efficiency (proportionality of its costs and benefits) 
and coherence (internal and external). The evaluation matrix included in Annex III lists 
the specific evaluation questions as well as the judgement criteria, indicators and sources 
of information used to answer the questions. They include desk research and the various 
consultation activities carried out in the context of the evaluation. 

Overall, satisfaction of stakeholders with the Directive is moderate to high, with 47.4% 
(27 out of 57) of respondents in the targeted survey rating it at 3 out of 5, and 28.1% (16 
out of 57) at 4 out of 5. In the public consultation, 29.7% (11 out of 37) responded that 
they were satisfied to a large or moderate extent with the rules established by the Directive. 

Where the findings below do not specify the category of article, it is assumed that they are 
valid  for  all  categories.  The  evaluation  questions  mostly  did  not  differentiate  between 
pyrotechnic  articles  for  vehicles  and  other  pyrotechnic  articles.  The  feedback  received 
from stakeholders was largely related to pyrotechnic articles other than those for vehicles 
– in particular to fireworks. This suggests that the Directive is performing well in relation 
to those articles. 

4.1.1.  Effectiveness 

a)  Free movement of pyrotechnic articles in the internal market 

Member  States  have  largely  aligned  their  legislation  to  the  Directive’s  requirements, 
leading  to  an  approximation  of  laws  on  pyrotechnic  articles  (see  section  3.5.). 
According to 45.9% (17 out of 37) of the participants to the public consultation (17 of 37), 
the  Directive  contributed  to  the  harmonisation  of  rules  on  the  making  available  of 
pyrotechnic articles to a large extent. 16.2% (6 out of 37) believe it has contributed to a 
moderate extent. Although it is not possible to establish causality, this harmonisation of 
national rules might have facilitated the free movement of pyrotechnic articles in the 
internal  market.  As  shown  in  section  3.1.,  intra-EU  trade  in  pyrotechnic  articles  has 
generally increased since the adoption of the current Directive. This suggests that it has 
enhanced  the  free  movement  of  pyrotechnic  articles  within  the  EU  and  thereby 
strengthened the internal market. The findings of the public consultation reveal that almost 
60% of respondents believe that the Directive’s objective of guaranteeing the functioning 

fireworks to the end-of-year period, applying to all fireworks, including F1 articles. Article 4(2) only 
provides  for  national  restrictions  for  categories  F2  and  F3,  theatrical  pyrotechnic  articles  and  other 
pyrotechnic articles. European Commission, Study of conformity in all EU countries on EU pyrotechnics 
and explosives legislation. Final Report, EY Law, 2022, pp. 48-51. 

20 

 
 
of  the  internal  market  has  been  achieved  to  a  large  (35.1%,  13  out  of  37)  or  moderate 
(24.3%, 9 out of 37) extent. 

However,  as  outlined  in  section  3.5.,  the  discretion  of  Member  States  in  some  areas  to 
prohibit  or  restrict  access  to  pyrotechnics80  has  resulted  in  differences  between  the 
Member States’ laws which might have impeded further integration. In that regard, the 
differences in the certification of specialist knowledge and the mutual recognition of such 
certificates were highlighted in the targeted survey. Moreover, different formats of licenses 
and  language  barriers  pose  practical  challenges  for  distributors  who  want  to  verify  the 
specialist knowledge of citizens from other Member States81. 

b)  Health and Safety 

As shown in section 3.2, information on trends in accidents and other health related issues 
is inconclusive. Although more than two thirds of stakeholders (64.9%, 24 out of 37) in 
the public consultation consider that pyrotechnic articles in the single market are safe, data 
from Safety Gate and ICSMS, the fragmented statistics reported from Member States to 
the Commission in accordance with Commission Implementing Decision (EU) 2023/1096, 
and also stakeholders’ impressions in the public consultation82, show that the Directive has 
not succeeded in eliminating unsafe pyrotechnic articles from the internal market. 

Essential safety requirements 

Compliance  with  the  essential  safety  requirements  (ESRs)  set  out  in  the  Directive  is 
supposed to ensure the safety of pyrotechnic articles. In the targeted survey, the Directive’s 
contribution to a high level of protection of human health and safety and higher compliance 
of pyrotechnics was recognised by more than half of respondents83. Nevertheless, certain 
shortcomings which limit the ESRs’ effectiveness were identified. 

The applicable ESRs depends on the category of pyrotechnic article. However, two market 
surveillance authorities and a notified body indicated in interviews that the current criteria 
for  classification  in  the  Directive  seem  to  allow  for  unintentional  and  intentional 
misclassification of products into categories with less stringent safety requirements. This 
concerns, in particular, fireworks that are miscategorised as other pyrotechnic articles of 
category  P1.  A  Commission  guidance  document  on  the  categorisation  of  pyrotechnic 

80 Articles 4(2) and 7 and the lack of harmonised licensing requirements. 
81  Reported  by  a  market  surveillance  authority  at  the  Administrative  Cooperation  Group  meeting  in 

November 2024. 

82 The majority (54.1%, 20 out of 37) consider that unsafe pyrotechnics articles on the market are a persistent 

concern that should be further addressed by the Directive in the future. 

83  Stakeholders  were  asked  ‘To  what  extent  were  the  following  main  benefits  of  harmonising  different 
national rules on pyrotechnic articles achieved in your member state since the entry into application in 
2015 of the current Directive 2013/29/EU?’. For ‘high level of protection of human health and safety, 
34.78%  (24  out  of 65)  selected  ‘to  a  high  extent’  and 11.59%  (8  out  of 65) ‘to  a  very  high  extent’. 
20.29%  (14  out  of  65)  replied  ‘to  a  moderate  extent’.  Note,  however,  that  14.49%  (10  out  of  65) 
responded ‘to no extent’. For ‘higher compliance of pyrotechnics available on the EU market with the 
requirements’, 28.99% (20 out of 65) selected ‘to a high extent’ and 13.04% (9 out of 65) ‘to a very high 
extent’. 21.74% (15 out of 65) responded ‘to a moderate extent’. 

21 

 
 
articles intended for entertainment purposes84 is considered of limited use due to its non-
binding nature and the vague reference to ‘entertainment purposes’ to qualify category F 
fireworks. Therefore, there is a considerable risk that products are not assessed against the 
appropriate ESRs. 

Moreover,  for  some  categories  of  fireworks,  the  ESRs  do  not  seem  adequate  to  ensure 
safety. In the public consultation and the call for evidence, several stakeholders pointed 
out that the one-metre safety distance for F1 fireworks was not sufficient as it does not 
adequately account for external circumstances, such as wind or improper usage. 

The Directive does not set out any specific safety requirements for F4 fireworks, apart 
from safeguards against inadvertent ignition, as this category of firework is supposed to be 
manufactured for use by professionals only. For the same reason, Member States are not 
allowed  to  impose  any  restrictions  on  the  manufacturing  and  sale  of  this  category  of 
firework.  This  has  led  to  a  situation  where  fireworks  with  an  exceedingly  high  net 
explosive content – higher than the needs of professional users85 – are made available on 
the market. 

According to the Directive, pyrotechnic articles which are in conformity with harmonised 
standards published in the Official Journal of the European Union must be presumed to 
be in conformity with the essential safety requirements. Harmonised standards are meant 
to translate the essential requirements into concrete technical specifications. Yet at present 
no harmonised standards are available for consumer fireworks or other pyrotechnic articles 
(category  P).  The  standards  proposed  by  the  European  Standardisation  Organisations 
(ESOs)  did  not  meet  the  essential  requirements  or  the  relevant  standardisation  request. 
While this is not a shortcoming of the Directive as such, it might hamper the effectiveness 
of the broadly formulated essential safety requirements86. 

84 European Commission, Group of Experts on Pyrotechnic Articles, Categorisation of pyrotechnic articles 

intended for entertainment purposes, 2021. 

85 Government of the Netherlands/République Francaise, Modify the Pyro Directive to Protect Public Order 

and Safety, A collaborative non-paper between the Netherlands and France, 2024. 

86 In 2017, the Commission rejected the publication of standards EN 16263 and 16265. No new version has 
been  submitted  to  the  Commission.  In  February  2025  the  Commission  withdrew  the  harmonised 
standards on consumer fireworks (the EN 15947 series) from the Official Journal as those standards had 
been  replaced  by  the  European  Committee  for  Standardization  (CEN)  with  new  standards  series, 
published  by  CEN  in  October  2022.  The  Commission  did not  cite  the  new  standards  in  the  Official 
Journal as they did not satisfy the requirements set out in the standardisation request and the relevant 
essential safety requirements laid down in the Directive. And while CEN was asked by the Commission 
to provide revised standards for pyrotechnic articles, including for fireworks, it will take several years 
for these to be finalised and cited in the Official Journal. See also: Commission Implementing Decision 
(EU)  2025/337  of  20 February  2025  on  the  harmonised  standards  for  pyrotechnic  articles  drafted  in 
support  of  Directive  2013/29/EU  of  the  European  Parliament  and  of  the  Council  (OJ  L,  2025/337, 
24.2.2025,  ELI:  http://data.europa.eu/eli/dec_impl/2025/337/oj)  and  Commission  Implementing 
Decision of 12.5.2022 on a standardisation request to the European Committee for Standardization as 
regards pyrotechnic articles in support of Directive 2013/29/EU of the European Parliament and of the 
Council, C(2022) 3011 final. 

22 

 
 
 
Compliance and quality of conformity assessments 

For the assessment of conformity of pyrotechnic articles, the manufacturer must follow 
one of the procedures according to the modules further explained in Annex VI. Third-party 
conformity assessment by a notified body is mandatory. Member States have notified 12 
bodies, and ten of these are accredited87. 

The alignment of the Directive to the NLF aimed to enhance the credibility and quality 
of  the  mandatory  conformity  assessment  procedures  and  to  increase  compliance. 
Indeed,  many  respondents  in  the  public  consultation  indicated  that  the  Directive  had 
contributed to a large extent (40.5%, 15 out of 37) or a moderate extent (16.2%, 6 out of 
37)  to  higher  compliance  of  pyrotechnic  articles  on  the  market  with  essential  safety 
requirements.  Nevertheless,  non-compliance  and  unsafe  products  are  still  a  concern88. 
Fireworks imported from third countries in particular – and especially those from China 
– often do not meet EU essential safety requirements89. 

The high number of instances of non-compliance presented in section 3.2.  raises questions 
about  the  quality  of  conformity  assessments.  According  to  54.1%  (20  out  of  37)  of 
stakeholders  in  the  public  consultation,  the  Directive  has  contributed  to  an  increased 
quality  and  credibility  of  conformity  assessments90.  Similarly,  30.4%  (21  out  of  69)  of 
respondents to the targeted survey are very satisfied and 24.6% (17 out of 69) moderately 
satisfied  with  the  current  requirements  for  overseeing  and  assessing  notified  bodies91. 
However,  the  consultation  activities  also  revealed  doubts  about  the  quality  of  the 
conformity  assessment  undertaken  by  laboratories  subcontracted  by  notified  bodies, 
especially where subcontractors are based in non-EU countries92. This echoes a Dutch non-
paper from 2024 on ‘Improving the product conformity of pyrotechnic articles within the 
European Union’93. In the targeted survey, a market surveillance authority and two SMEs 
pointed out that economic considerations by notified bodies might impact the quality of 
conformity  assessments94.  Considering  the  shortcomings  observed  in  conformity 

87 See Single Market Compliance Space. 
88 54.1% (20 out of 37)  of respondents to the public consultation believe that the minimisation of unsafe 
pyrotechnic  articles  on  the  market  should  be  further  addressed  by  the  Directive  in  the  future.  Non-
compliant products imported from third countries were mentioned as safety risks by national authorities 
in the targeted survey. 

89 Five national authorities explained in interviews that many consumer fireworks in the categories F2 and 
F3 imported from China do not meet the EU’s safety requirements. One national government authority 
noted in the public consultation that many fireworks, particularly those imported from Asia, fail safety 
tests.  This  could  be  due  to  insufficient  oversight  of  testing  laboratories.  See  also  Rijksoverheid, 
Improving the product conformity of pyrotechnic articles within the European Union, 14/03/2024, p. 1. 
90 35.1% (13 out of 37) selected ‘to a large extent’, 18.9% (7 out of 37) ‘to a very large extent’. Notably, 

100% (4 out of 4) of business associations responded ‘to a large extent’. 

91 17.4% (12 out of 69) rated their satisfaction with 5 out of 5, 13% (9 out of 69) rated it with 4 out of 5 and 

24.6% (17 out of 69) with 3 out of 5. 

92  Inadequate  oversight  over  conformity  assessments  carried  out  in  third  countries  was  also  a  concern 
mentioned in the targeted survey (by market surveillance authorities and industry manufacturers) and in 
interviews with five national authorities. 

93  Rijksoverheid,  Improving  the  product  conformity  of  pyrotechnic  articles  within  the  European  Union, 

14/03/2024, p. 1. 

94 Responses to an open question. 

23 

 
 
assessments, several stakeholders in the targeted survey and interviews deplored a lack of 
oversight over notified bodies by notifying authorities and accreditation bodies. 

Market surveillance and enforcement  

Market surveillance should identify non-compliant products and then ensure their removal 
from the market. It is essential for the enforcement of the Directive. Besides the rules and 
procedures set out in the Pyrotechnics Directive, the overarching EU legal framework for 
market  surveillance,  including  Regulation  (EU)  2019/102095  and  certain  provisions  of 
Regulation (EC) No 765/200896 apply to the market surveillance for pyrotechnic articles, 
including the provisions on controls on imports.  

For pyrotechnic articles, the effectiveness of market surveillance increased thanks to the 
Pyrotechnics  Directive,  according  to  most  stakeholders  participating  in  the  public 
consultation97.  However,  most  respondents  in  the  targeted  survey  reported  that  the 
frequency  of  product  controls  both  for  EU  manufactured  and  imported  products  has 
remained unchanged since the entry into application of the Directive.98 The controls carried 
out were in most cases documentary and physical checks (product testing) and, in some 
case, only documentary checks.99 Restrictions to the circulation of products for reasons of 
environmental,  safety  or  security  concerns  have  been  rather  rare  in  recent  years.100 
Moreover, according to the targeted survey101 and an interview with a market surveillance 
authority,  stakeholders  note  significant  differences  in  market  surveillance  practices 
between Member States, including in the use of ICSMS, which might be an obstacle to 
more effective market surveillance102. 

Cooperation and information sharing 

In general, cooperation and information sharing among market surveillance authorities and 
between  authorities  and  economic  operators  seem  to  be  effective  thanks  to  market 

95 Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market 
surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 
ELI: 
(OJ 
765/2008 
http://data.europa.eu/eli/reg/2019/1020/oj). 

(EU)  No 

25.6.2019, 

305/2011 

169, 

and 

1, 

p. 

L 

96 Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out 
the  requirements  for  accreditation  and market  surveillance  relating  to  the marketing  of products  and 
30, 
repealing 
ELI: http://data.europa.eu/eli/reg/2008/765/oj). 

(EEC)  No 

Regulation 

13.8.2008, 

339/93 

218, 

(OJ 

p. 

L 

97 Among the respondents, 29.7% (11 out of 37) stated it was effective ‘to a large extent,’ 18.9% (7 out of 
37) said ‘to a moderate extent,’ and 13.5% (5 out of 37) replied  ‘to a very large extent.’ Meanwhile, 
21.6% (8 out of 37) selected ‘Do not know/prefer not to say’. 

98 44% (11 out of 25) said the frequency of checks on imported products remained unchanged, 28% (7 out 
of 25) said it increased or strongly increased. As regards EU manufactured products, 52% (13 out of 25) 
said the frequency remained unchanged and 20% (5 out of 25) said it increased or strongly increased. 
99 In the targeted survey, ‘both’ (documentary and physical checks) was the most frequently given answer 
for most product categories, followed by documentary checks. For some product categories, ‘Do not 
know/prefer not to say’ was the most frequent answer. 

100 The most frequently given responses were no instances or 1-5 instances for all three concerns. 
101 52.8% (28 out of 53) respondents in the targeted survey chose ‘market surveillance’ as one of the areas 

where they observe the most pronounced differences across Member States. 
102 In fact, only approximately ten Member States report relatively regularly in ICSMS. 

24 

 
 
surveillance tools like ICSMS and Safety Gate103 and regular Administrative Cooperation 
(AdCo)  meetings.  The  same  seems  to  be  true  for  cooperation  between  notified  bodies. 
However,  when  asked  about  the  effectiveness  of  information  sharing  with  competent 
authorities from other Member States, 32.3% (21 out of 64) of respondents to the targeted 
survey considered it rather ineffective, especially in comparison with information sharing 
between authorities of their own Member State.104 Cooperation on concrete and specific 
cases, such as F4 fireworks, can be challenging105. In a non-paper, the Dutch authorities 
stressed  that  international  cooperation  and  information  sharing  among  European 
authorities  was  essential  for  effective  market  surveillance  and  suggested  that  a  joint 
European testing centre be set up to improve cost efficiency, facilitate information sharing 
and ensure a uniform approach to testing and interpreting results. Better cooperation and 
coordination in daily practice and on concrete cases would prevent non-compliant products 
withdrawn from one Member State’s market from being sold in another Member State106. 

Accessibility of high-risk pyrotechnics 

Lastly,  in  addition  to  the  issue  of  non-compliance,  the  accessibility  of  high-risk 
pyrotechnics  to  consumers,  including  those  intended  only  for  use  by  professionals,  is 
seen as a weakness of the Directive when it comes to the protection of health and safety107. 
While  some  Member  States  have  made  use  of  the  option  to  restrict  fireworks  under 
Article 4(2),  others  have  not  (see  section  3.5),  which  allows  consumers  to  circumvent 
national sales restrictions by buying restricted fireworks in other countries or online. As 
regards  (professional)  F4  fireworks,  Member  States  are  not  allowed  to  adopt  national 
restrictions going beyond the Directive. Internet sales are the main supply channel for this 
kind  of  firework108.  As  pointed  out  in  section  3.3,  buyers’  specialist  knowledge  is  not 

103 In the targeted survey, when asked about their satisfaction with digital and electronic tools for exchanging 
information about products governed by the Directive, ICSMS got mostly positive feedback, with 50% 
(12 out of 24) of the respondents rating it highly (4 or 5 out of 5). Dissatisfaction was minimal, with 
only 12.5% (3 out of 24) rating it at 2 out of 5 and no one rating it at 1 out 5. Similarly, Safety Gate, the 
EU rapid alert system for dangerous non-food products, was rated with moderate or high satisfaction 
levels, as 37.5% (9 out of 24) of respondents rated it moderately at 3 or 4 out of 4, and 8.3% (2 out of 
24) at 5 out of 5. Among the 14 Member State authorities that completed this survey question, only 3 
expressed dissatisfaction with Safety Gate, while dissatisfaction with ICSMS was reported by 2 Member 
State authorities. 

104 The  effectiveness of information sharing with competent authorities from another Member State was 
rated 2 out of 5 by 23.1% (15 out of 65), 4 out of 5 by 20% (13 out of 65), 3 out of 5 by 19.9% (11 out 
of 65), 1 out of 5 by 9.2% (6 out of 65) and 5 out of 5 by 1.5% (1 out of 65) respondents. In comparison, 
information sharing with competent authorities of the same Member State was rated 4 out of 5 by 26.1% 
(17 out of 65), 3 out of 5 by 24.6% (16 out of 65) and 5 out of 5 by 21.5% (14 out of 65). 

105 Pointed out by two market surveillance authorities in interviews. 
106  Rijksoverheid,  Improving  the  product  conformity  of  pyrotechnic  articles  within  the  European  Union, 

14/03/2024, p. 2. 

107 54.1% (20 out of 37) of respondents to the public consultation believe that the issues of controlled access 
to pyrotechnics not intended for the general public or to specific age groups, and safety and accessibility 
of the public to bigger and or powerful pyrotechnics, should be further addressed by the Directive in the 
future. Accidents with F4 fireworks were mentioned as a safety risk by national authorities in the targeted 
survey. 
108 Ibid., p. 3. 

25 

 
 
adequately checked109. In fact, some of the most serious accidents around New Year’s Eve 
involve F4 fireworks110. As mentioned above, some Member States, including Austria and 
Italy, have reacted to this problem by prohibiting mail order sales and/or  using the Benelux 
Pyro-pass. 

c)  Security 

Despite its declared objective, and given that it was conceived at a time when – contrary 
to today – the criminal misuse of pyrotechnic articles was not yet a serious concern, the 
Directive does not directly address public security issues111. As the 2019 study confirmed, 
the Directive was designed to enable the free movement of pyrotechnic articles in the 
internal  market,  not  to  prevent  cross-border  crime112.  Participants  in  the  public 
consultation were concerned about access to pyrotechnic articles by malicious actors, with 
54.1% (20 out of 37) of them considering that there were currently no effective controls 
on sales. 

Diversion and traceability 

It appears that legally produced articles are increasingly used for criminal purposes. This 
notably concerns F4 fireworks which, because of their explosive content (especially flash 
powder),  are  particularly  popular  among  criminals.  In  the  same  way  that  these  articles 
easily end up in the hands of consumers, they are also readily accessible to criminals. The 
2019 study found that the problem of the illegal sale of F4 pyrotechnics was hidden from 
the authorities, because the illegal transactions  were mainly taking place online and the 
products  were  shipped in unmarked parcels.113 The latter  presents  a risk also for  postal 
companies114. In the public consultation, several public authorities115 and a professional 
user shared their concern about the illegal online trade in pyrotechnic articles. This was 
echoed by market surveillance authorities in interviews, where they stressed the problem 
of increased accessibility of high-risk articles to unauthorised users. 

Contrary  to  explosives  for  civil  use,  pyrotechnic  articles  cannot  be  traced  on  an  item-
specific level, as the current system for traceability set up by Commission Implementing 
Directive 2014/58/EU only requires manufacturers to label their articles with a registration 
number issued by the notified body. This registration number belongs to all articles covered 
by  the  same  assessment.  When  asked  about  the  effectiveness  of  traceability  rules, 
stakeholder replies were divided in the public consultation and the targeted survey. In the 

109 Ibid., p. 2. 
110  See  for  instance  MDR  SACHSEN,  Zwei  Todesfälle  in  Sachsen:  Deshalb  sind  Kugelbomben  so 

gefährlich, 3 January 2025. 

111 Described in section Problems and needs that the intervention aimed to address 
112 Ibid., p. 4. 
113 Ibid., pp. 32, 46. 
114 European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025, p. 140. 
115 One market surveillance authority, a central administrative office  and a national and EU enforcement 

agency. 

26 

 
 
public consultation, 27% (10 out of 37) responded that the Directive contributed mostly to 
improved traceability and control of sales and transactions, 18.9% (7 out of 37) replied to 
a limited extent, and 13.5% (5 out of 37) to a moderate extent116. In the targeted survey, 
34% (18 out of 53) of respondents found that the Directive contributed to a moderate extent 
to the traceability of pyrotechnic articles, and 32.1% (17 out of 53) to a high or very high 
extent117. In interviews with three market surveillance authorities, the lack of an item-level 
traceability  system  was  identified  as  a  problem  for  tracing  back  the  movement  of 
pyrotechnic articles in the supply chain when used in criminal activities. 

Penalties 

Penalties aim to ensure compliance and deter illegal behaviour. In the context of diversion 
and criminal misuse of pyrotechnic articles, it is, however, necessary to bear in mind the 
nature of the Directive as a single market instrument based on Article 114 TFEU. While 
its safeguards against diversion may not be fully effective, the Directive’s remit does not 
govern the criminal misuse of pyrotechnic articles. Neither does it extend to harmonising 
criminal sanctions for their misuse. 

As shown in section 3.5, penalties for economic operators not respecting the provisions of 
the Directive differ between Member States. Among the stakeholders participating in the 
targeted survey, 30.5% (18 out of 59) of respondents indicated that current penalties were 
to a high extent effective in ensuring that pyrotechnic articles on the market fulfilled the 
existing requirement, while 25.4% (15 out of 59) replied that penalties were moderately 
effective.  However,  according  to  56.8%  (21  out  of  37)  of  respondents  to  the  public 
consultation, proportionate enforcement and penalties to prevent illicit possession, misuse, 
and thefts of pyrotechnic articles (i.e. penalties not mandated by the Directive, which only 
requires penalties for infringements of provisions of national law adopted pursuant to the 
Directive) should be further addressed in the future. Moreover, two market surveillance 
authorities  explained  during  interviews  that  the  current  penalties  imposed  by  Member 
States were not sufficient to deter serious infringements, such as organised crime, noting 
that illegal activities with pyrotechnics articles were generally subject to lighter penalties 
than those involving explosives or weapons. 

Illegal manufacturing 

It  is  important  to  note  that  not  all  security  issues  observed  are  linked  to  products 
manufactured  in  line  with  the  Pyrotechnics  Directive  that  are  diverted  for  criminal 
purposes. Illegal and counterfeit articles that were likely manufactured entirely outside of 
the legal supply chain have been detected in some Member States118. During the traditional 
celebrations called ‘Las Fallas’ in Valencia in 2024, the Spanish police seized pyrotechnic 
articles with a total of approximately 80 kg net explosive content. Investigations revealed 

116  Out of 37 respondents. 
117  28.3% (15 out of 53) selected ‘to a high extent’ and 3.8% (2 out of 53) ‘to a very high extent’. 
118  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 

(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, p. 3. 

27 

 
 
that a large share of the seized products were illegally manufactured counterfeits119. Black 
market sales, both online and on the streets, are a source of supply for criminals, such as 
organised crime groups120121. 

d)  Environmental protection 

As  explained  in  section  3.4,  awareness  about  the  negative  environmental  effects  of 
pyrotechnic articles has increased since the Directive was adopted. The results from the 
stakeholder consultations suggest that the Directive does not fully ensure the protection of 
the environment from pyrotechnic articles. In the targeted survey, while 44.1% (26 out of 
59)  of  respondents  said  the  Directive  had  a  positive  impact  on  the  protection  of  the 
environment,  33.1%  (20  out  of  59)  considered  the  Directive’s  effect  was  negative.  In 
interviews, stakeholders pointed to the Directive’s weak focus on environmental protection 
as  a  factor  limiting  its  environmental  effectiveness.  In  the  public  consultation, 
environmental  pollution  and  animal  welfare  were  also  concerns  highlighted  by 
stakeholders.  The  2022  standardisation  request  for  harmonised  standards122  aims  to 
translate the environmental essential requirements into concrete technical requirements for 
pyrotechnic articles. However, the results are not expected until 2027. It is therefore not 
yet possible to draw any conclusions from this workstream. Existing standards have only 
focused marginally on the environmental effects of pyrotechnic articles. 

4.1.2.  Efficiency 

To the extent that the Directive’s objectives have been attained, this seems to have been 
achieved in an overall efficient manner. While all stakeholder types, except notified bodies, 
reported cost increases due to compliance with the Directive’s requirements, there were 
also significant efficiency gains for most stakeholders. 

The  cost  estimations  presented  in  this  section  are  based  on  findings  from  the  study  in 
support of the evaluation123. The study relied on cost templates filled in by six companies 
(five SMEs and one large company), two market surveillance authorities and three notified 
bodies,  as  well  as  interviews  with  these  stakeholders.  This  data  was  complemented  by 
findings from the targeted survey. The assessment of the benefits is based on the findings 
from the effectiveness analysis. It is mostly qualitative, given the difficulty to monetise 
these positive effects of the Directive. Efficiency gains were identified on the basis of the 

119 Spanish Guardia Civil, Weapons and Explosives Central Inspectorate  Report on the seizure in public 

areas of counterfeit and illegally manufactured pyrotechnics, 2025. 

120  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, p. 3; Minutes 
– Meeting of the Pyrotechnics Working Group 2016_10_06. 

121 The study on the criminal misuse of pyrotechnic articles commissioned by the Directorate-General for 
Migration and Home Affairs is looking more closely into the criminal  misuse of pyrotechnic articles, 
including from the angle illicit manufacturing. 

122  Commission  Implementing  Decision  of  12.5.2022  on  a  standardisation  request  to  the  European 
Committee for Standardization as regards pyrotechnic articles in support of Directive 2013/29/EU of the 
European Parliament and of the Council, C(2022) 3011 final. 

123 European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025. 

28 

 
 
responses to the targeted survey. In view of the limited available data on costs and benefits, 
the analysis below can provide only an indication of how efficient the Directive is. 

a)  Costs 

Industry 
For  the  six  companies124  interviewed  in  the  context  of  the  study  in  support  of  this 
evaluation, costs arising from compliance with the Pyrotechnics Directive represent 0.9% 
of their annual turnover. For the large enterprise interviewed, the share is smaller (0.4%), 
while the SMEs spend an equivalent of 1.6% of their annual turnover on compliance with 
the  Directive.  This  is  comparable  to  the  regulatory  burden  of  other  directives  and 
regulations referred to in the evaluation of the New Legislative Framework125. The annual 
compliance costs have been calculated as the average (mean) over the period from 2015 to 
2022. 

Table 1: Average yearly (2015-2022) compliance costs attributed to compliance with the Pyrotechnics Directive as 
share of turnover 

Components 

Turnover 

Compliance costs 

All companies 

EUR 20 889.026 

EUR 196 048  

Share of compliance costs in turnover  0.9% 

Large 
enterprises 
EUR 85 859.154   EUR 12 091.667 

SMEs 

EUR 347 085  
0.4% 

EUR 194 044  
1.6% 

N=6 (1 large company, 5 SMEs), Source: Technopolis Group, based on cost templates 

For the SMEs, most costs are investments and expenses needed to adjust their activity to 
the  Directive’s  requirements  (adjustment  costs).  These  represent  87.6%  of  the  total 
compliance costs. Administrative costs account for only 8.3%. The large company reported 
inverse proportions, with administrative costs making up 63.5% of total compliance costs, 
and adjustment costs 36.5%. Hassle costs (i.e. costs resulting from inconveniences such as 
unnecessary waiting time, delays, redundant legal provisions, corruption, etc.) and costs 
only  indirectly  caused  by  the  Directive126  seem  to  be  negligible  and  are  not  further 
specified in this section. 

124 One large enterprise and five SMEs. 
125The  NLF  evaluation  for  industrial  products  assessed  the  efficiency  of  the  Toy  Safety  Directive,  the 
Restriction of Hazardous Substances Directive, the Electromagnetic Compatibility Directive, the Low 
Voltage Directive, and the Construction Products Regulation. European Commission, Supporting Study 
for the evaluation of certain aspects of the New Legislative Framework (Decision No 768/2008/EC and 
(EC)  No 765/2008),  2022,  https://ec.europa.eu/info/law/better-regulation/have-your-
Regulation 
say/initiatives/12654-Industrial-products-evaluation-of-the-new-legislative-framework_en. 
that 
evaluation study, the regulatory burden of some of the horizontal NLF provisions and the one-off costs 
ranged between 0.6% and 3% of the industry turnover. 

In 

126 In the cost templates stakeholders were asked to indicate any indirect costs, with  the explanation that 
such costs include: a) indirect compliance costs – costs related to the fact that other stakeholders have 
to  comply  with  legislation;  b)  offsetting/substitution  costs  –  for  example  costs  related  to  reliance on 
alternative experts; c) transaction costs – costs of renegotiating contracts; d) opportunity costs – the costs 
of foregone alternative investments/opportunities; e) negative impacts on market functioning such as 
reduced competition or market access, reduced innovation or investment. 

29 

 
 
Table 2: Average yearly costs for industry attributed only to the Pyrotechnics Directive 

Costs typology 
All companies 
Total yearly costs of the Directive  EUR 196 048  
Adjustment costs 

71.1% 

Administrative costs 

Hassle costs 

Indirect costs 

Other costs 

25.5% 

0.9% 

2.6% 

0.0% 

Large enterprises 

SMEs 

EUR 347 085  

EUR 194 044  

36.5% 

63.5% 

0.0% 

0.0% 

0.0% 

87.6% 

8.3% 

1.0% 

3.1% 

0.0% 

N=6 (1 large company, 5 SMEs), Source: Technopolis Group, based on cost templates 

Adjustment costs 

The interviewed SMEs spend, on average, EUR 170 020 on adjusting to the Directive’s 
requirements, but it varies considerably from EUR 9 903 to EUR 485 078, depending on 
the  company.  The  large  company  reported  average  annual  adjustment  costs  of 
EUR 126 735. While manufacturing in line with the essential safety requirements is the 
biggest adjustment cost factor for the SMEs, accounting for 58% of total adjustment costs, 
it represents only 7% of the large company’s adjustment costs. For the large company, the 
design, testing and categorisation of products  is the biggest adjustment cost, making up 
46% of the total adjustment costs. This is followed by costs for affixing the CE marking 
(16%), operational costs for traceability and labelling actions (equipment acquisition and 
implementation of activities) (13%), and adaptation of the design for compliance (11%). 
For  SMEs,  the  design,  testing  and  categorisation  of  products  is  the  second  biggest 
adjustment cost,  but  at  17%,  so  relatively low compared to  the large company.  Sample 
testing,  investigations  and  record-keeping  (complaints  and  non-conforming  articles) 
represent 10% of adjustment costs for SMEs. 

the  question127 

In the targeted survey, the responding large manufacturer allocated the largest share (40%) 
of  adjustment  costs  covered  by 
to  equipment  acquisition  and 
implementation of activities linked to CE marking, labelling and traceability128, while 30% 
of  the  adjustment  costs  were  attributed  to  the  design  and  manufacturing  of  products 
according to the Directive’s requirements, which was also a significant cost factor for most 
SMEs responding to the targeted survey. According to five out of seven, it represents 30-
40% of adjustment costs. For four of them, it is the largest adjustment cost. Costs for the 
acquisition  of  equipment  for  conformity  assessments  and  the  implementation  of  these 
assessments also represent a good share of SMEs’ adjustment costs – for five out of seven 

127  Economic  operators  were  asked  to  indicate  the  respective  shares  of  the  following  adjustment  costs: 
liability  insurance;  designing  and  manufacturing  products  according  to  the  Directive’s  requirements 
[manufacturers only]; product testing before and for conformity assessment; equipment acquisition for 
and 
the  conformity  assessment  process;  equipment  acquisition  for  and 
implementation of activities for affixing CE marking, labels, registration numbers, traceability systems 
or  devices  to  the  product;  taking  corrective  actions  on  identified  non-conforming  products  (e.g. 
recalls/withdrawals); other adjustment costs. 

implementation  of 

128 Costs for labelling and traceability could also have been categorised entirely as administrative costs. The 
supporting  study  had,  however,  collected  the  data  with  a  distinction  between  operational  tasks  for 
labelling and traceability and administrative tasks in that regard. Therefore, the distinction was kept for 
this SWD. 

30 

 
 
it accounts for 20-30%. Moreover, for four SMEs, the costs for equipment and activities 
linked to CE marking, labelling and traceability represent 20-40% of the adjustment costs 
covered by the question. 

Figure 11: Share of adjustment costs for companies by key drivers attributed only to the Pyrotechnics Directive as per 
cost templates 

7%

Manufacture per safety
requirements

36%

Design, test & categorise products

46%

58%

Affix CE marking

100%

90%

80%

70%

s
t
s
o
c

60%

t
n
e
m

j

t
s
u
d
a
f
o
)

%

(
e
r
a
h
S

50%

28%

40%

30%

12%

20%

10%

0%

8%

7%

6%

2%
1%
1%
Companies

16%

13%

4%

11%

2%
1%

Large Enterprises

17%

5%

5%

10%

1%
2%
1%
1%

SME

Traceability & labeling actions

Sample testing, investigations, and
record-keeping (complaints & non-
conforming articles)

Adapt design for compliance

Conformity assessment procedure

Corrective operational actions to
withdraw or recall non-conformant
articles

Other significant costs

N=6 (1 large company, 5 SMEs), Source: Technopolis Group, based on cost templates 

Administrative costs 

All  administrative  costs  linked  to  compliance  with  the  Pyrotechnics  Directive  together 
amount  to  an  average  of  EUR 16 023  per  year  for  the  five  SMEs  that  submitted  cost 
templates,  again  with  a  big  span  from  EUR 2 067  to  EUR 49 140.  The  large  company 
incurs on average EUR 220 350 for administrative activities linked to compliance with the 
Directive. 33% of the SME’s administrative costs result from labelling pyrotechnic articles 

31 

 
 
 
 
 
 
in accordance with the Directive’s requirements, collecting documentation for conformity 
assessments accounts for 14% and collaboration with surveillance authorities for 8%. For 
the large company, producing the technical documentation represents the most significant 
share of  administrative costs, representing 30% of all  administrative costs, followed by 
ensuring correct labelling (16%) and providing safety information in the language of the 
user (13%). 

Figure 12: Share of administrative costs for companies by key drivers attributed only to the Pyrotechnics Directive as 
per cost templates 

100%

Technical documentation (Annex II)

s
t
s
o
c
e
v
i
t
a
r
t
s
i
n
m
d
a
f
o
)

i

%

(
e
r
a
h
S

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

31%

30%

16%

16%

15%

9%

8%

5%

4%

3%
2%
2%
2%
1%
1%
1%
Companies

10%

12%

13%

7%

4%

4%
1%
1%
1%
1%
Large Enterprises

7%

33%

3%

14%

6%

7%

5%

4%

8%

2%
4%

5%
2%

SME

Ensure proper labeling (Art. 10/11)

EU declaration of conformity

Collect assessment documentation

Safety info in user language

Traceability & labeling actions

Conformity Assessment application

Record registration numbers

Collaborate with surveillance
authorities

Administrative actions to withdraw
or recall not conformant articles

Investigate & record non-
conforming pyrotechnics and recalls
(as requested)
Other admin activities

Notify authorities of risks

Maintain docs & declaration for 10
years

N=6 (1 large company, 5 SMEs), Source: Technopolis Group, based on cost templates 

In the targeted survey, ensuring correct labelling also emerged as an important driver of 
administrative costs for SMEs, with six out of eight indicating that it represents between 

32 

 
 
 
 
 
 
15-30%  of  the  administrative  costs  covered  by  the  question129130.  Similar  shares  were 
attributed to producing the technical documentation131 and documentary verification of the 
product’s conformity132. The responding large enterprise allocated the largest share (30%) 
of  the  administrative  costs  covered  by  the  question  to  documentary  verification  of  the 
product’s  conformity.  Ensuring  correct  labelling  was  also  found  to  be  a  significant 
administrative cost, with a 20% share of all administrative costs covered by the question. 
Only 10% of the large company’s administrative costs went on producing the technical 
documentation for conformity assessment procedures. 

Market surveillance authorities 
The two market surveillance authorities (MSAs) that provided cost data spend, on average, 
EUR 76 388 per year on compliance with the Directive. 73.9% of these costs are linked to 
enforcement,  while  adjustment  costs  represent  18.7%  and  administrative  costs  4.6%. 
Hassle costs and indirect costs represent 1.3% of total compliance costs, respectively. 

Table 3: Average yearly compliance cost for MSAs 

Public body 

Market surveillance authority 

Total yearly costs of the Directive 

EUR 76 388 

Enforcement costs 

Adjustment costs 

Administrative costs 

Hassle costs 

Indirect costs 

73.9% 

18.7% 

4.6% 

1.3% 

1.3% 

N= 2 (market surveillance =2), Source: Technopolis Group, based on cost template 

Enforcement costs 

The two MSAs incur average enforcement costs of EUR 21 516 and EUR 93 680 per year 
respectively.  Of  these  costs,  25%  are  linked  to  checks  and  risk  assessments  (excl. 
outsourced tests), while communicating non-conformance and market surveillance actions 

129 Economic operators were asked to indicate the respective shares of the following administrative costs: 
producing the technical documentation for conformity assessment procedures (referred to in Annex II 
to  the  Directive);  keeping  records  of  technical  documentation,  EU  declarations  of  conformity  and 
registration numbers of products for 10 years; ensuring the correct labelling, CE marking, identification 
and registration numbers, and traceability data of products; documentary verification of the product’s 
conformity (i.e. the validity of the certificate of conformity, verification of laboratory testing provided 
by  manufacturers,  verification  of  product  versus  safety  requirements,  correct  labelling,  CE  marking, 
registration number, etc.); handling paperwork for lodging applications for registrations, certifications, 
accreditations,  authorisations,  etc.;  information  sharing  and  cooperation  with  organisations  and 
authorities related to non-compliant products, their suppliers and buyers (supply chain). 

130  One  out  of  eight  responding  SMEs  allocated  30%  to  administrative  costs  linked  to  ensuring  correct 
labelling, CE marking and traceability of products, one 25%, two 20%, two 15% and two 10%. For four 
out of seven, it was one of the administrative tasks attributed the highest or second-highest shares of 
costs. 

131 For one out of eight SMEs, this represents 30% of all administrative costs, for four it represents 25%, 

and for one, 20%, another 15% and another 10%. 

132 For one out of eight SMEs, this represents 30% of all administrative costs, for six it represents 20% and 

for one 10%. 

33 

 
 
account for 23%. 17% of enforcement costs are attributed to the verification of reports and 
certificates. 

Figure 13: Share of enforcement costs for MSAs by key driver attributed only to the Pyrotechnics Directive as per cost 
templates 

s
t
s
o
c

t
n
e
m
e
c
r
o
f
n
e
f
o
)

%

(
e
r
a
h
S

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

25%

23%

17%

11%

8%

7%

3%
3%
1%1%

Checks & risk assessments (excl.
outsourced tests)

Communicating non-
conformance & market
surveillance actions
Verification of reports &
certificates

Coordination group meetings

Mapping non-conformant
supply chain

Corrective actions (e.g.,
destruction/disposal)

Monitoring accidents & harms

Market surveillance
recordkeeping

Other

N=2, Source : Technopolis Group, based on cost templates 

In the targeted survey, one MSA indicated that laboratory testing represented 30% of all 
costs covered by the question133, while the other two MSAs allocated no costs to this task. 
Coordination activities, including with expert groups within the Member State, competent 
authorities and regional authorities and external expert groups (e.g. standardisation bodies, 
Commission Expert Groups), account for approximately 30% of all presented costs for two 
out of three MSAs, while one did not provide complete information. Other significant cost 
factors reported in the survey were costs linked to record-keeping and the maintenance of 
registers, product recalls, and the training of inspectors134. 

133  MSAs  were  asked  to  indicate  the  respective  shares  of  the  following  costs:  administrative  costs  from 
receiving, storing and retrieving the records; coordination of expert groups within the Member State; 
coordination  between  and  with  competent  authorities  and  regional  authorities  (for  surveillance  and 
enforcement  purposes);  coordination  with  external  expert  groups  (standardisation  bodies,  EC  expert 
groups, for knowledge management purposes); the recall process; training of inspectors; maintenance of 
registers; laboratory  testing (incl.  safe  transportation and storage); legal  costs of transposition. These 
costs were not categorised in adjustment, administrative and enforcement costs. 

134 The three MSAs allocated 15%, 10% and 20% respectively to administrative costs from receiving, storing 
and retrieving the records, and 5%, 10% and 20% to the maintenance of registers. 5%, 10% and 20% 
were attributed to recall processes and 20%, 30% and 10% to inspector training. 

34 

 
 
 
 
 
 
 
Adjustment costs 

The yearly adjustment costs reported in the cost templates differ significantly between the 
two MSAs, with one indicating EUR 650 and the other EUR 27 953. As most costs for 
MSAs can be categorised as enforcement costs, there are only two adjustment cost factors. 
The  familiarisation  and  training  of  staff  accounts  for  75%  of  adjustment  costs,  while 
ensuring  that  personnel  are  informed  of  relevant  harmonisation  and  standardisation 
activities accounts for 25%. 

For the three MSAs participating in the  targeted survey, inspectors’ training represents, 
respectively, 10%, 20% and 30% of the costs covered by the question. 

Administrative costs 

The annual administrative costs incurred by the two MSAs that filled in the cost templates 
are  EUR 3 626  and  EUR 4 977.  These  are  split  between  record-keeping  of  surveillance 
activities (58%) and the collection of documents and evidence and reporting to authorities 
(42%). 

For the three MSAs responding to the targeted survey, administrative costs from receiving, 
storing and retrieving records account for 10%, 15% and 20%, respectively, of the costs 
covered by the question, while the maintenance of registers represents 5%, 10% and 20%. 

Notified bodies 
When looking at the costs for notified bodies (NBs), it needs to be borne in mind that NBs 
owe their income to the conformity assessment requirement in the Directive. They can also 
–  apart  from  considerations  of  competitiveness  and  proportionality  as  mandated  by  the 
Directive (Article 33(2)) – freely set the price for their assessments to cover their costs. 
Accordingly,  costs  directly  linked  to  carrying  out  conformity  assessments  are  not 
considered in this section135. 

On  average,  the  three  NBs  providing  cost  data  incur  EUR 34 895  to  comply  with  the 
Directive. Adjustment costs account for 64% and administrative costs for 36%. NBs also 
reported some indirect costs stemming from the Directive. Those notably included the use 
of external experts for audits and the training and monitoring of those experts to ensure 
compliance with the Directive. No hassle costs were reported. 

Table 4: Average yearly (2015-2022) compliance cost for notified bodies 

Cost categories 

Total yearly costs of the Directive 

Adjustment costs 

Administrative costs 

N=3, Source : own preparation, based on cost templates 

Costs in EUR 

EUR 34 895 

64% 

36% 

135  It  should  be  noted  that  the  supporting  study  included  them  in  the  efficiency  assessment.  This  cost 

calculation has been adjusted for this SWD. 

35 

 
 
 
Adjustment costs 

The NBs’ reported adjustment costs, on average, amount to EUR 22 192 per year. Most of 
these costs are linked to participation in coordination group meetings (49%). 41% relate to 
familiarising staff with the essential safety requirements and 10% to the liability insurance 

Administrative costs 

Administrative costs for the three consulted NBs are on average EUR 12 703 per year. Of 
these costs, 79% are attributed to (re)accreditation136. 

Figure 17: Share of administrative costs for NBs by key driver attributed only to the Pyrotechnics Directive as per cost 
templates 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

79%

7%
5%
5%
5%

Notified Bodies

(Re)accreditation cost

Independence cost (e.g., ethics committee)

Inform other Notified Bodies of test results

Notify authorities of compliance issues

Application cost for (re)notification

N=3, Source: own preparation, based on cost templates 

b)  Burden 

In  light  of  the  Commission’s  constant  objective  to  reduce  regulatory  burden  for 
stakeholders137,  the  efficiency  evaluation  should  also  include  an  assessment  of  the 
proportionality of the burden of legal obligations138. When asked in the public consultation 
to what extent certain operative tasks constituted a proportionate burden, one third (4 out 

136 It should be noted that accreditation is not mandatory under the Pyrotechnics Directive, but, if available, 

it facilitates the notification procedure. 

137  See,  for  instance,  European  Commission,  A  simpler  and  faster  Europe:  Communication  on 
implementation  and  simplification,  European  Commission  2024-2029,  2024;  Ursula  von  der  Leyen, 
Europe’s choice, Political Guidelines for the next European Commission 2024-2029, 2024; Ursula von 
der Leyen, Political Guidelines for the next European Commission 2019-2024, 2019. 

138  See European Commission, Better regulation toolbox, 2023 p. 407. 

36 

 
 
 
of  12)  of  stakeholders  indicated  that  designing  and  manufacturing  according  to  the 
essential  safety  requirements  constituted  a  proportionate  burden  to  a  very  large  extent, 
while this was a proportionate burden to a moderate extent for another third (4 out of 12). 
The  operational  tasks  linked  to  labelling,  CE marking  and  affixation  of  the  registration 
number were perceived as proportionate to a moderate extent by 23.1% (3 out of 13) of 
stakeholders and to a large extent by 15.4% (2 out of 13) and not at all proportionate by 
another  15.4%.  The  two  ‘not  at  all’  replies  were  submitted  by  companies.  Conducting 
investigations on non-conforming articles in response to requests from public authorities 
was considered proportionate to a moderate extent by 46.2% (6 out of 13) and to a limited 
extent by 7.7% (1 out of 13). 

Figure 18: Proportionality of the burden of operative tasks 

To what extent the following obligations and activities related to the 
compliance with the  Directive represent a proportionate burden for you 
and or your organisation (operative tasks)

Conduct investigations in response to requests
from public authorities

46%

8%

46%

Collaborating with audits and inspections

25%

5%

20%

15%

25%

10%

Take corrective actions to withdraw or recall non-
compliant articles

Labelling, CE marking, and coordinate notified 
body’s authorization to affix registration number 
to the pyrotechnic article

22%

6%

22%

17%

28%

6%

31%

15%

15%

8%

23%

8%

Implement traceability systems and operations

23%

8%

23%

8%

31%

8%

Carry out accreditation procedures

80%

20%

Carry out conformity assessment procedures

29%

6%

18%

12%

24%

12%

Designing and manufacturing according to the
essential safety requirements

17%

8%

8%

0%

33%

33%

Do not know/prefer not to say
To a large extent

0%

20%

60%

40%
Not at all
To a limited extent

80%

100%

N= 5-20 (depending on the task), Source: own preparation based on the public consultation 

Looking at the burden of the different administrative tasks, most stakeholders participating 
in  the  public  consultation  (58.3%,  7  out  of  12)  perceive  the  preparation  of  a  technical 
dossier for conformity assessment applications to be proportionate to a moderate extent. 
50% (3 out of 6) of companies shared this view, while 33.3% (2 out of 6) found this task 
to a large extent proportionate. When it comes to the burden of labelling, stakeholders were 
divided, with one third (4 out 12) considering it not at all proportionate, while 25% (3 out 
of 12) said it was to a large extent proportionate. 50% (3 out of 6) of companies selected 
‘not at all’; the other half was divided between ‘to a very large extent’ and ‘to a moderate 

37 

 
extent’  or  preferred  not  to  answer.  One  company  suggested  simplifying  labelling 
requirements, such as allowing the use of QR codes to convey safety information digitally, 
to  reduce  costs.  Supplying  the  technical  information  of  the  pyrotechnic  articles  to 
surveillance  authorities  and  economic  operators  constitutes  a  proportionate  burden  to  a 
large extent for 58.3% (7 out of 12) of stakeholders participating in the public consultation. 
Record-keeping  –  one  of  the  most  cost-intensive  administrative  tasks  for  market 
surveillance authorities – was considered moderately proportionate by 50% (5 out of 10) 
public authorities, whereas two rated it as proportionate only to a limited extent or not at 
all. 

Figure 19: Proportionality of the burden of administrative and office tasks 

To what extent do the following obligations and activities related to the 
compliance with the  Directive represent a proportionate burden for you 
and or your organisation (administrative and office)?

Recordkeeping information

32%

8%

14%

5%

32%

8%

Lodging applications for authorisations,
accreditations, certifications

Supplying technical information of the pyrotechnic
articles to surveillance authorities and economic
operators

23%

15%

38%

8%

15%

8%

58%

17%

17%

Information labelling

17%

33%

25%

0%

17%

8%

Submission of reports, data and statistics to
competent authorities

30%

3%

22%

11%

24%

11%

Notification of risk event (e.g. accidents)

17%

6%

39%

22%

17%

Elaborate technical dossier for conformity
assessment application

8%

8%

8%

58%

17%

0,00%

20,00% 40,00% 60,00% 80,00% 100,00%

Do not know/prefer not to say Not at all

To a large extent

To a limited extent

To a moderate extent

To a very large extent

N=12-37 (depending on the task), Source: own preparation based on the public consultation 

A separate question in the public consultation asked about the burden of the submission of 
accident  data,  as  required  by  Commission  Implementing  Decision  (EU)  2023/1096139. 
Three out of five authorities replied in the public consultation that the regular reporting of 
pyrotechnic-related accidents represented a significant burden to a moderate (1) or large 
(2)  extent140.  Moreover,  it  has  emerged  from  informal  discussions  with  MSAs  that  the 

139  Commission  Implementing  Decision  (EU)  2023/1096  of  2 June  2023  laying  down  rules  for  the 
application  of  Directive  2013/29/EU  of  the  European  Parliament  and  of  the  Council  as  regards  the 
regular collection and updating of data on accidents related to the use of pyrotechnic articles. 
140 For the remaining two authorities, it represents a significant burden to a limited or to no extent. 

38 

 
 
submission  of  accident  data  is  tying  up  resources  that  might  be  better  used  for  other 
purposes. 

Accident monitoring is important for taking appropriate policy decisions at Member-State 
and EU level. Without information about the product types involved, the victims and the 
causes of accidents, it is difficult to draw conclusions and take targeted and proportionate 
measures.  However,  considering  the  difficulty  of  producing  complete,  comparable  and 
meaningful accident statistics, due to the different recording practices between Member 
States and the often unclear causes of the accidents, the proportionality of the mandatory 
accident  reporting  in  its  current  form  is  questionable.  In  the  public  consultation,  when 
asked how accident reporting could be improved, multiple responses (4 companies and 2 
interest groups / civil societies / business organisations) suggested distinguishing between 
the use of legal and illegal items and whether they were used properly or improperly. A 
company highlighted the need for more detailed research into the behavioural aspects of 
accidents and the importance of collecting comprehensive statistics. A citizen/consumer 
also suggested an online reporting system for pyrotechnicians. 

c)  Trends in costs and efficiency gains 

Looking at how costs evolved during the evaluation period (i.e. from 2015) can provide an 
idea of the stakeholders’ financial burden linked to the Directive, but does not allow us to 
establish  a  causal  relationship  between  changes 
the  Directive’s 
implementation,  as  other  factors,  including  macro-economic  developments,  such  as 
increasing energy prices, might also have played a role. 

in  costs  and 

In the targeted survey, economic operators mostly reported that they had experienced cost 
increases  since  the  Directive  was  implemented141.  MSAs  and  enforcement  authorities 
mainly  experienced  cost  increases  or  no  change142.  For  the  participating  NBs  the  costs 
mainly remained unchanged143. 

At the same time, a large proportion of stakeholders experienced efficiency gains in their 
administrative and/or operational activities from complying with the Directive. 27.5% (14 
out of 51) of respondents in the targeted survey said that their administrative procedures 
became  more  or  much  more  efficient,  and  25.5%  (13  out  of  51)  reported  improved 
efficiency in their operative tasks144. Only a few stakeholders experienced a decline in their 

141  Between 50%-100% of SME manufacturers, large manufacturers, importers and industry organisations 

reported that their administrative, operative and hassle costs increased or strongly increased. 

142  33%  (3  out  of  9)  of  enforcement  authorities  reported  that  their  administrative  and  operative  costs 
increased, 11% (1 out of 9) said they remained the same. The reverse ratio applies to hassle costs. Among 
MSAs, 21.4% (3 out of 14) reported unchanged operative costs, but increased administrative costs, while 
14.3% (2 out of 14) experienced increased operative costs and unchanged administrative costs. 55.6% 
(5 out of 9) of enforcement authorities and 64.3% (9 out of 14) of MSAs did not know or preferred not 
to answer. 

143 50% (2 out of 4) of NBs reported that their adjustment and administrative costs remained unchanged, 
while 75% (3 out of 4) said this about their hassle costs. The remaining NBs did not know or preferred 
not to say. 

144 23.5% (12 out of 51) and 27.5% (14 out of 51) did not perceive any difference in their efficiency, while 

37.3% (19 out of 51) did not know or preferred not to say. 

39 

 
 
efficiency, including the two responding large manufacturers, one out of twelve SMEs and 
one out of fourteen MSAs. 

d)  Benefits 

As explained in Section 4.1.1, the Directive has in many respects achieved its objectives, 
in particular as regards contributing to increased health and safety and the free movement 
of pyrotechnic articles on the internal market. In doing so, it has generated a number of 
benefits for stakeholders and society. 

The  following  direct  benefits  have  been  identified  in  the  cost  interviews  on  the  cost 
templates: 

•  Sustained level of safety: The Directive seems to have contributed to a relatively 
stable safety level of the pyrotechnic articles on the market. This benefits not only 
users but also society at large145. 

•  Positive impact on public security: Although security issues remain, stakeholders 

mostly acknowledge the Directive’s positive impact on public security146. 

•  Improved  market  access:  Companies  and  NBs  report  improved  access  to  the 
single market  thanks to  the  harmonised rules  and the CE marking  system.  They 
have also experienced advantages on non-EU markets, as CE marking is widely 
accepted internationally as complying with other markets’ safety requirements147. 
•  Reduction  of  familiarisation  cost:  Although  the  Directive  has  not  entirely 
harmonised rules across Member States, adapting national laws to the Directive has 
reduced stakeholders’ costs for familiarisation with legal requirements. 

•  Cost  savings  in  conformity  assessment  activities:  The  harmonisation  of 
conformity assessment procedures has created cost savings for stakeholders. 

•  Coordination  and 

information  exchange:  The  Directive  has  facilitated 
coordination and information exchange between MSAs, NBs and the Commission. 
Fora like the Forum of Notified Bodies and the AdCo Group are appreciated for 
providing an opportunity to exchange views on issues encountered during market 
surveillance  and  conformity  assessments,  find  solutions  and  agree  on  common 
approaches. 

•  Traceability: Although it does not allow for item-level tracking, the traceability 
system for pyrotechnic articles, which requires pyrotechnic articles to be labelled 
with  registration  numbers  issued  by  the  notified  body  that  carried  out  the 
conformity assessment, has made it easier to track pyrotechnic articles throughout 
the supply chain148. 

145  Interviews with MSAs. See also Section Health and Safety. 
146  In the targeted survey, 34.8% (24 out of 69) of respondents indicated that this benefit was achieved to a 
high extent, 14.5% (10 out of 69) selected ‘to a moderate extent‘, and 11.6% (8 out of 69) ‘to a very 
high extent‘. 

147  Cost assessment interviews with industry stakeholders and NBs. 
148 In the targeted survey, 36.8% (25 out of 68) of respondents indicated that this benefit was achieved to a 
moderate extent, 19.1% (13 out of 68) selected ‘to a high extent’ and 4.4% (3 out of 68) selected ‘to a 
very high extent’. However, 14.7% (10 out of 68) considered that this benefit had not been achieved at 
all or to a low extent. 

40 

 
 
4.1.3.  Coherence 

The Directive is meant to integrate well into the overall legal and policy framework at EU 
level, but also at international and national level. Contradictions, overlaps or other tensions 
with  other  measures  should  be  avoided  and,  ideally,  synergies  created.  This  is  what  is 
understood  by  ‘external  coherence’.  At  the  same  time,  the  various  components  of  the 
Directive should build upon or complement each other in a logical and meaningful way – 
the  Directive  should  be  ‘internally  coherent’.  External  and  internal  coherence  of  the 
pyrotechnics  legislation  were  assessed  for  this  evaluation  and  no  major  points  of 
incoherence were identified. 

a)  External coherence 

The Pyrotechnics Directive operates alongside other EU legislation regulating explosive 
products  or  substances,  chemicals,  or  other  aspects  of  consumer  or  environmental 
protection. 

•  Explosives Precursors Regulation (Regulation (EU) 2019/1148)149 

The Explosives  Precursors Regulation  sets  harmonised rules  for substances or mixtures 
that could be misused for the illicit manufacture of explosives. It explicitly excludes from 
its scope pyrotechnic articles covered by the Pyrotechnics Directive. Before the Explosives 
Precursors Regulation was adopted in 2019, an impact assessment examined the coherence 
of the initiative with the existing legal framework, including the Pyrotechnics Directive. It 
was concluded that, given that they  had  a different  focus  in  terms of products, the two 
pieces  of  legislation  were  complementary.  No  major  inconsistencies  or  overlaps  were 
identified150.  Since  then,  no  coherence  issues  have  been  brought  to  the  attention  of  the 
Commission and of the 15 stakeholders sharing their opinion on this point in the public 
consultation, 12 perceived the Pyrotechnics Directive to be highly or moderately coherent 
with the Explosives Precursors Regulation151. 

•  Marine Equipment Directive (Directive 2014/90/EU)152 

The Marine Equipment Directive applies to equipment placed or to be placed on board an 
EU  ship  and  for  which  the  approval  of  the  flag  State  administration  is  required  by 
international instruments. Pyrotechnic articles, such as signal flares, that meet these criteria 

149  Regulation  (EU)  2019/1148  of  the  European  Parliament  and  of  the  Council  of  20 June  2019  on  the 
marketing and use of explosives precursors, amending Regulation (EC) No 1907/2006 and repealing 
Regulation 
ELI: 
http://data.europa.eu/eli/reg/2019/1148/oj). 

No 98/2013 

11.7.2019, 

(EU) 

p. 1, 

186, 

(OJ 

L 

150 European Commission, Impact Assessment accompanying the document proposal for a Regulation of the 
European Parliament and of the Council on the marketing and use of explosives precursors, amending 
Annex  XVII  to  Regulation  (EC)  No 1907/2006  and  repealing  Regulation  (EU)  No 98/2013  on  the 
marketing and use of explosives precursors, SWD(2018) 104 final, 2018, p. 106. 

151 18.9% (7 out of 37) responded that the Directive had ‘high coherence’, 13.5% (5 out of 37) responded 
‘moderate coherence’ and 8.1% (3 out of 37) ‘low coherence’. 59.5% (22 out of 37) chose the ‘Do not 
know/prefer not to say’ option. 

152  Directive  2014/90/EU  of  the  European  Parliament  and  of  the  Council  of  23 July  2014  on  marine 
equipment  and  repealing  Council  Directive  96/98/EC  (OJ  L  257,  28.8.2014,  p. 146,  ELI: 
http://data.europa.eu/eli/dir/2014/90/oj). 

41 

 
 
are excluded from the scope of the Pyrotechnics Directive and are exclusively subject to 
the Marine Equipment Directive. A stakeholder participating in the targeted survey pointed 
to difficulties encountered with the exclusion of marine equipment where national laws 
required  pyrotechnic  articles  on  ships  that  did  not  fall  under  the  Marine  Equipment 
Directive, such as small pleasure vessels or fishing boats. In such cases the same products 
would  be  considered  marine  equipment  when  placed  on  a  ship  subject  to  the  Marine 
Equipment Directive, but P1 or P2 pyrotechnic articles when placed on any other ship. In 
the case of P2 articles, the Pyrotechnics Directive would require specialist knowledge for 
people to buy them for their pleasure vessel or fishing boat, but this would not be required 
for articles intended for use on a ship under the Marine Equipment Directive. 

•  Civil Explosives Directive (Directive 2014/28/EU)153 

The Civil Explosives Directive regulates 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. Pyrotechnic articles falling within the scope of 
Directive 2013/29/EU are explicitly excluded from the Civil Explosives Directive’s scope. 
At the same time, the Pyrotechnics Directive does not apply to civil explosives under the 
scope of the Civil Explosives Directive. Legally, there are therefore no overlaps between 
the two directives. However, in practice, stakeholders report difficulties in distinguishing 
between the two kinds of products and, therefore, the applicable rules. For instance, high-
hazard pyrotechnic articles (e.g. category P2) are extensively used like civil explosives and 
could be considered as explosives due to their potential risks154. Primer caps are another 
example of products which, according to NBs, do not fit clearly into either category155. 

•  CLP  Regulation  (Regulation  (EC)  No  1272/2008)156  REACH  Regulation 

(Regulation (EU) 1907/2006)157 

The Classification, Labelling and Packaging (CLP) Regulation sets harmonised rules for 
the  classification  of  substances  and  mixtures  and  for  the  labelling  and  packaging  of 
hazardous substances and mixtures. Pyrotechnic articles, if classified as explosives under 

153  Directive  2014/28/EU  of  the  European  Parliament  and  of  the  Council  of  26 February  2014  on  the 
harmonisation of  the  laws  of the  Member  States  relating  to  the  making  available  on  the market  and 
supervision  of  explosives 
(OJ  L  96,  29.3.2014,  p. 1,  ELI: 
http://data.europa.eu/eli/dir/2014/28/oj). 

for  civil  uses 

(recast) 

154 Information from interviews with NBs and national enforcement authorities in the context of the study 

in support of the evaluation. 

155 Discussion at meeting of the Forum of Notified Bodies for pyrotechnic articles, 6 March 2025. Minutes 

not yet available. 

156 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on 
classification, labelling and packaging of substances and mixtures, amending and repealing Directives 
67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (OJ L 353, 31.12.2008, 
p. 1, ELI: http://data.europa.eu/eli/reg/2008/1272/oj). 

157 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 
concerning  the  Registration,  Evaluation,  Authorisation  and  Restriction  of  Chemicals  (REACH), 
establishing  a  European  Chemicals  Agency,  amending  Directive  1999/45/EC  and  repealing  Council 
Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 
76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC (OJ L 
396, 30.12.2006, p. 1, ELI: http://data.europa.eu/eli/reg/2006/1907/oj). 

42 

 
 
the  CLP  Regulation,  must  be  labelled  and  packaged  as  such  in  accordance  with  CLP. 
Accordingly,  pyrotechnic  articles  under  the  scope  of  the  Pyrotechnics  Directive  must 
comply with the labelling requirements both in the CLP Regulation and in the Directive. 
While the definition of ‘pyrotechnic article’ in the Directive is almost identical to that in 
the CLP Regulation, the non-detonative character of the chemical reactions referred to in 
the  CLP  definition  is  not  explicitly  required  by  the  definition  in  the  Directive158.  This, 
however, seems to be a negligible misalignment.  

The  REACH  (registration,  evaluation,  authorisation  and  restriction  of  chemicals) 
Regulation  regulates  the  manufacture,  placing  on  the  market  and  use  of  chemical 
substances, on their own, in mixtures or in articles to ensure a high level of protection of 
human health and the environment. REACH applies to substances and mixtures used for 
pyrotechnic articles.  

In the public consultation, out of the 17 stakeholders that shared their opinion, 9 perceived 
a high coherence between the EU chemicals legislation (CLP and REACH) (see below) 
and the Directive and 7 a moderate coherence. No concrete coherence issues between the 
two pieces of legislation and the Pyrotechnics Directive were identified. 

•  Waste Framework Directive (Directive 2008/98/EC)159 

The Waste Framework Directive (WFD) lays down measures to protect the environment 
and  human  health  from  waste,  including  rules  for  hazardous  waste.  It  applies  to 
pyrotechnic waste, which falls under the category of ‘explosive’, and therefore hazardous, 
waste160. The Pyrotechnics Directive itself is largely silent on the disposal of pyrotechnic 
articles.  The  essential  safety  requirements  only  very  broadly  stipulate  that  ‘each 
pyrotechnic  article  must  be  designed  and  manufactured  in  such  a  way  that  it  can  be 
disposed of safely by a suitable process with minimum effect on the environment’161. The 
WFD,  therefore,  complements  the  Pyrotechnics  Directive,  and  there  do  not  seem  to  be 
contradictions or overlaps between the two directives. It must be noted, however, that it is 
unclear  from  the  wording  in  the  WFD  whether  ‘pyrotechnic  waste’  only  refers  to  the 
residues of used pyrotechnic articles or also to expired articles. Expired articles could also 
be  excluded  from  the  scope  of  the  WFD  if  they  were  considered  ‘decommissioned 
explosives’ in accordance with Article 2(1)(e) of the WFD. 

158  Article 3(1)  of  the  Pyrotechnics  Directive  lays  down  that:  ‘‘pyrotechnic  article”  means  any  article 
containing explosive substances or an explosive mixture of substances designed to produce heat, light, 
sound,  gas  or  smoke  or  a  combination  of  such  effects  through  self-sustained  exothermic  chemical 
reactions.’ 

159 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and 
repealing certain Directives (OJ L 312, 22.11.2008, p. 3, ELI: http://data.europa.eu/eli/dir/2008/98/oj). 

160 See Annex III WFD. 
161  See Annex I, point 2, WFD. 

43 

 
 
 
•  Seveso-III Directive (Directive 2012/18/EU)162 

The Seveso-III Directive lays down rules for the prevention of major accidents involving 
dangerous substances in establishments where such substances are present. It also applies 
to economic operators in the pyrotechnics sector, if dangerous substances within the scope 
of  the  Seveso-III  Directive  are  present  in  their  establishments.  The  participants  in  the 
public  consultation  mainly  (62.2%,  23  out  of  37)  did  not  know  or  preferred  not  to  say 
whether the Seveso-III Directive and the Pyrotechnics Directive were coherent. However, 
of the 14 stakeholders that replied, 7 perceived a high coherence, 4 a moderate coherence 
and 3 a low coherence. No conflicting rules were identified. 

•  Product Liability Directive (Directive (EU) 2024/2853)163 

The Product Liability Directive sets rules on the liability of economic operators for damage 
suffered by natural persons and caused by defective products and on compensation for such 
damage. While it applies to pyrotechnic articles accessible to consumers under the scope 
of the Pyrotechnics Directive, the two directives regulate distinct aspects – safe products 
vs liability for defective products – and complement each other. The respondents to the 
public consultation mainly found the two pieces of legislation highly coherent (52.9%, 9 
out of 17, of those who expressed their opinion)164. 

•  Counter-Terrorism Agenda for the EU165 

The EU Counter-Terrorism Agenda seeks to support Member States in better anticipating, 
preventing,  protecting  and  responding  to  the  terrorist  threat.  Two  of  the  pillars  of  the 
agenda are (i) identifying vulnerabilities and building capacity to anticipate threats and (ii) 
promoting security by design and reducing vulnerabilities to protect cities and people166. 
The Directive’s stated objective of ensuring a high level of public security is in line with 
the EU Counter-Terrorism agenda. However, as explained in section 4.1.1.c), the Directive 
is  currently  not  sufficiently  effective  in  preventing  the  criminal  misuse  of  pyrotechnic 
articles. Most importantly, the fact that Member States cannot ban or restrict F4 fireworks 
seems to contradict the agenda’s objective of supporting Member States in anticipating, 
preventing,  protecting  and  responding  to  the  terrorist  threat.  The  study  on  the  criminal 

162 Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of 
major-accident hazards involving dangerous substances, amending and subsequently repealing Council 
Directive 96/82/EC (OJ L 197, 24.7.2012, p. 1, ELI: http://data.europa.eu/eli/dir/2012/18/oj). 

163 Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability 
for defective products and repealing Council Directive 85/374/EEC (OJ L, 2024/2853, 18.11.2024, ELI: 
http://data.europa.eu/eli/dir/2024/2853/oj).  The  same  applies  to  Council  Directive  85/374/EEC  of 
25 July 1985 on the approximation of the laws, regulations and administrative provisions of the Member 
States  concerning 
(OJ  L  210,  7.8.1985,  p. 29,  ELI: 
http://data.europa.eu/eli/dir/1985/374/oj). The latter will be repealed 9 December 2026. 

for  defective  products 

liability 

164 24.3% (9 out of 37) responded ‘high coherence’, 10.8% (4 out of 37) ‘moderate coherence’ and 10.8% 

‘low coherence’. 54.1% (20 out of 37) responded ‘Do not know/prefer not to say. 

165 European Commission, Communication from the Commission, A Counter-Terrorism Agenda for the EU: 

Anticipate, Prevent, Protect, Respond, COM(2020) 795 final, 2020. 

166 https://ec.europa.eu/commission/presscorner/detail/en/ip_20_2326 

44 

 
 
misuse of pyrotechnic articles commissioned by the Directorate-General for Migration and 
Home Affairs is looking more closely into EU pyrotechnics policy from a security angle. 

•  Agreement  concerning  the  International  Carriage  of  Dangerous  Goods  by 
Road  (ADR)167,  Regulations  concerning  the  International  Carriage  of 
Dangerous  Goods  by  Rail  (RID),  Agreement  concerning  the  International 
Carriage  of  Dangerous  Goods  by  Inland  Waterways  (ADN)  and  UN 
Recommendations on the Transport of Dangerous Goods168 

The  ADR,  RID,  ADN  and  the  UN  Recommendations  on  the  Transport  of  Dangerous 
Goods set out conditions or recommendations that should be met when dangerous goods 
are  transported.  The  EU  has  transposed  the  ADR,  RID  and  ADN  into  Directive 
2008/68/EC on the inland transport of dangerous goods, which makes them applicable to 
all transport in the EU, both within and across national borders169. Directive 2008/68/EC 
is complementary to the Pyrotechnics Directive, which does not regulate the transport of 
pyrotechnic articles. 

•  National laws and policies 

As explained previously, the Directive allows Member State to impose bans or restrictions 
on certain categories of fireworks and many Member States have made use of this option. 
The resulting variations between national laws seem to create barriers to the free movement 
of pyrotechnic articles, undermining the Directive’s objective of creating a single market 
for these articles. According to 36.8% (25 out of 68) of respondents in the targeted survey, 
current variations in national rules affect intra-EU flows of pyrotechnic articles negatively 
or very negatively170,while 32.4% (22 out of 68) observe a negative or very negative effect 
on  the  competitiveness  of  EU  companies171.  Moreover,  although  25%  (17  out  68)  of 
respondents  consider  that  national  rules  have  positive  effects  on  health  and  safety  and 
27.9% (19 out of 68) on public security172, the possibility of circumventing national rules 

167 United Nations Economic Commission for Europe, Agreement concerning the International Carriage of 

Dangerous Goods by Road, 2022. 

168 United Nations, Recommendations on the Transport of Dangerous Goods, Model Regulations, Volume 

I, Twenty-first revised edition, 2019. 

169 Directive 2008/68/EC of the European Parliament and of the Council of 24 September 2008 on the inland 
transport of dangerous goods (OJ L 260, 30.9.2008, p. 13, ELI: http://data.europa.eu/eli/dir/2008/68/oj); 
Directive (EU) 2022/1999 of the European Parliament and of the Council of 19 October 2022 on uniform 
procedures for checks on the transport of dangerous goods by road (OJ L 274, 24/10/2022, p. 1, ELI: 
http://data.europa.eu/eli/dir/2022/1999/oj); Directive 2010/35/EU of the European Parliament and of the 
Council  of  16 June  2010  on  transportable  pressure  equipment  and  repealing  Council  Directives 
76/767/EEC, 84/525/EEC, 84/526/EEC, 84/527/EEC and 1999/36/EC (OJ L 165, 30.6.2010, p. 1, ELI: 
http://data.europa.eu/eli/dir/2010/35/oj). 

170 In the targeted survey, 30.9% (21 out of 68) of respondents selected ‘unchanged/neutral’, 22.1% (15 out 
of 68) ‘negatively’, 14.7% (10 out of 68) ‘very negatively, 5.9% (4 out of 68) ‘positively’ and 4.4% (3 
out of 68) ‘very positively’. The remaining 22.1% (15 out of 68) did not know or preferred not to say. 
171 In the targeted survey, 32.4% (22 out of 68) of respondents selected ‘unchanged/neutral’, 25% (17 out of 
68) ‘negatively’, 7.4% (5 out of 68) ‘very negatively’ and ‘positively’, respectively, and 2.9% (2 out of 
68) ‘very positively’. The remaining 25% (17 out of 68) did not know or preferred not to say. 

172 In the targeted survey, for health and safety 29.4% (20 out of 68) selected ‘unchanged/neutral’, 19.1% 
(13 out of 68) ‘positively’, 11.8% (8 out of 68) ‘negatively’, 5.9% (4 out of 68) ‘very positively’ and 

45 

 
 
 
via  cross-border  sales  from  less-restrictive  Member  States  seems  to  undermine  the 
Directive’s objective of ensuring high levels of safety and security across the EU173. 

b)  Internal coherence 

Half of the 58 respondents to the targeted survey rated internal coherence as moderate and 
36.2% (21 out of 58) as high. In fact, only one minor issue was identified in the course of 
the  evaluation,  which  was  also  brought  up  by  several  stakeholders  in  the  validation 
workshop in the context of the Technopolis Group study. Articles 8(6) and 12(3) of the 
Directive stipulate that manufacturers and importers must indicate their name, registered 
trade name or registered trade mark and their postal address on the pyrotechnic article itself 
‘or,  where  that  is  not  possible,  on  its  packaging  or  in  a  document  accompanying  the 
pyrotechnic  article’.  Articles  10  and  11,  on  the  other  hand,  which  set  out  labelling 
requirements and reiterate the obligation to provide the information on the manufacturer 
and importer, do not refer to the possibility of providing this information in a document 
accompanying the article, but only to it being put on the article itself or its packaging. This 
creates  confusion  for  manufacturers  and  importers  that  are  unable  to  provide  the 
information on the article itself as to the options they have to provide that information in 
an alternative way. 

4.2.  How did the EU intervention make a difference and to whom? 

In  line  with  the  principle  of  subsidiarity,  it  is  important  to  evaluate  whether  the  EU 
pyrotechnics legislation has had a positive impact beyond what could have been achieved 
by the Member States acting alone. 

Overall, stakeholders acknowledge the added value of EU-wide rules on pyrotechnic 
articles. When asked about the expected consequences if the Directive were withdrawn, 
51.3% (19 out of 37) of respondents in the public consultation replied that the pyrotechnics 
sector would be affected negatively, or even very negatively174, although most business 
associations  (3  out  of  4)  considered  that  it  would  remain  unchanged.  The  stakeholders 
supplemented their reply saying that the withdrawal of the Directive would likely lead to 
more  accidents  (national  and  EU  enforcement  agency),  chaos  and  a  lack  of  control  (a 
professional user), and jeopardise safety and security (MSAs, company, citizen/consumer). 
At a meeting with the Commission on 19 February 2025, an animal welfare organisation 
stressed  that  the  fragmentation  of  national  laws  would  be  problematic  in  terms  of 
protection.  On  the  other  hand,  a  stakeholder  responding  to  the  public  consultation  and 
identifying as an interest group / civil society / business organisation sees also a positive 

2.9% (2 out of 68) ‘very negatively‘. 30.9% (21 out of 68) did not know or preferred not to say. In terms 
of security, 17.7% (12 out of 68) selected ‘negatively’ 14.7% (10 out of 68) ‘positively’, 13.2% (9 out 
of 68) ‘very positively’ and ‘very negatively’, respectively, and 20.6% (14 out of 68) did not know or 
preferred not to say. 

173 The circumvention of national rules was pointed out by two Member States’ authorities in a joint letter 

to the Commission. 

174 If the Directive were withdrawn, the largest share of the respondents would see the pyrotechnics sector 
affected very negatively (18.9%, 7 out of 37) or negatively (32.4%, 12 out of 37). 16.2% (6 out of 37) 
responded ‘remain unchanged’ and 24.3% (9 out of 37) chose ‘Do not know/prefer not to say’. 

46 

 
 
side  to  leaving  the  pyrotechnics  rules  to  the  Member  States,  suggesting  that  allowing 
Member States to introduce general bans on fireworks might benefit animal welfare. 

Looking  at  the  EU  added  value  of  the  Directive  in  relation  to  its  various  objectives, 
respondents to the targeted survey predominantly believe that these objectives could not 
have been achieved at all (20.7%, 12 out of 58) or only to a low extent (36.2%, 21 out of 
58) if Member States had acted alone. However, the public consultation reveals that the 
EU added value as perceived by stakeholders differs depending on the objective. While 
the  Directive  seems  to  be  essential  for  cross-border  trade  in  the  internal  market,  other 
objectives, notably the protection of safety and security were not sufficiently supported by 
the Directive. In fact, Member States acting individually might have achieved better levels 
of protection at national level, if allowed to take action on safety and security issues with 
regard to f4 fireworks, which may not be restricted by Member States under the current 
Directive, thereby limiting their ability to react to related safety and security threats175. In 
an interview, an industry stakeholder mentioned that, without the Directive, Member States 
could have made faster decisions at national level.  

About 45.9% (17 out of 37) of stakeholders in the public consultation believed that cross-
border facilitation related to the supply, trade, and use of pyrotechnics could only  have 
been achieved to a limited extent or could not have been achieved at all in the absence of 
the Directive. Companies especially expressed this view176. In the same vein, 48.6% (18 
out of 37) indicated that the reduction in trade barriers could have been achieved only to a 
limited  extent  or  not  at  all177.  The  EU  added  value  of  the  traceability  system  was  also 
recognised, with 27% (10 out of 37) responding that, in the absence of the Directive, it 
could have been achieved to a moderate extent, and 32.4% (12 out of 37) considering that 
it could only have been achieved to a limited extent or not at all178. 

In turn, as regards the protection of human health and safety, stakeholders said that it could 
have  been  achieved  to  a  large  (32.4%,  12  out  of  37)  or  moderate  (21.6%,  8  out  of  37) 
extent. Notably, 75% (3 out of 4) of business associations responded ‘to a large extent’ and 
25%  (1  out  of  4)  ‘to  a  very  large  extent’.  Similarly,  when  asked  about  public  security, 

175 See also European Commission, Study on illegal sales of pyrotechnic articles destined for professional 
users (category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, p. 69. 
176 For ‘Cross-border facilitation related to the supply, trade and use of pyrotechnics’, 27% (10 out of 37) 
responded that it could have been achieved only ‘to a limited extent’, 18.9% (7 out of 37) responded 
‘not  at  all’  and  13.5%  (5  out  of  37)  ‘to  a  moderate  extent’.  27%  (10  out  of  37)  responded  ‘Do  not 
know/prefer not to say’. Notably, 66.7% (4 out of 6) of companies/businesses chose ‘to a limited extent’ 
and 16.7% (1 out of 6) ‘to a moderate extent’. 

177 For ‘Reduction of the trade barriers and costs in the Single Market’, 27% (10 out of 37) responded that 
it could have been achieved only ‘to a limited extent’, 21.6% (8 out of 37) responded ‘not at all’ and 
13.5% (5 out of 37) ‘to a moderate extent’. 27% (10 out of 37) chose the ‘Do not know/prefer not to say’ 
option. 

178 For ‘Improved traceability of sales and transactions’, 27% (10 out of 37) responded that it could have 
been achieved ‘to a moderate extent’, 21.6% (8 out of 37) chose ‘to a limited extent’ and 10.8% (4 out 
of 37) ‘not at all’. 24.3% (9 out of 37) answered ‘Do not know/prefer not to say’. 

47 

 
 
24.3% (9 out of 37) answered that it could have been achieved to a large extent and another 
24.3% said  to a moderate extent179. 

Overall, these findings suggest that the Directive’s role in harmonising rules is beneficial 
to the free movement of pyrotechnic articles in the internal market, but, in its current form, 
impedes Member States from taking action on safety and security issues with regard to F4 
fireworks  at  national  level.  In  light  of  the  frequent  circumvention  of  national  rules  via 
cross-border (online) sales, a harmonised approach seems however preferable to individual 
national measures. 

4.3. 

Is the intervention still relevant? 

Under  the  criterion  of  relevance,  this  evaluation  looked  at  the  relationship  between  the 
scope and objectives of the Pyrotechnics Directive, on the one side, and the current and 
future needs and problems in relation to pyrotechnic articles in the EU, on the other. As 
explained in the Better Regulation Toolbox, if an intervention does not help address the 
current and likely future needs or problems, then it does not matter how effective, efficient 
or coherent it is, because it may no longer be appropriate180. 

4.3.1.  Relevance of the objectives 

In this section, the relevance of the Directive’s objectives in light of current problems and 
needs is  assessed.  Stakeholders in  the targeted  survey mostly  believe  that  the Directive 
addresses  current  needs  and  challenges  to  some  extent,  with  39.3%  (22  out  of  56) 
responding ‘to a high extent’ and 37.5% (21 out of 56) ‘to a moderate extent’. 

a)  Free movement of pyrotechnic articles in the internal market (incl. 

harmonisation of laws and implementation) 

As illustrated in section 4.1.1, Member States’ laws have significantly aligned following 
the adoption of the Directive, but there are still notable differences, which are not only 
considered to result in trade barriers, but also to hamper cooperation between MSAs. 

In the public consultation, when asked about the extent to which the guaranteeing of the 
functioning of the internal market is still relevant, 35.1% (13 out of 37) responded ‘to a 
large extent’, including all four responding business associations, and 24.3% (9 out of 37) 
said  ‘to  a  moderate  extent’.  Similarly,  in  the  targeted  survey,  38.9%  (21  out  of  54)  of 
stakeholders replied that the issue of differences between national laws, causing barriers 
to trade within the Union, was still to a high or very high extent relevant and continued to 
require action at EU level, while 22.2% (12 out of 54) chose ‘to a moderate extent.’ Here 
again, industry representatives generally attributed high relevance to this problem181. 

179 For ‘High level of protection of public security’, 24.3% (9 out of 37) answered that it could have been 
‘to a large extent’ achieved and 24.3% answered ‘to a moderate extent’ achieved. 18.9% (7 out of 37) 
responded ‘Do not know/prefer not to say’. 

180 European Commission, Better regulation toolbox 2023, p. 409. 
181  83.3%  (5  out of  6)  of  industry  associations  and  both  large  manufacturers  rated  it  as  to  a  high  extent 
relevant. Among the  twelve responding SMEs, five found it relevant to a moderate extent, three to a 
high extent and four to a very high extent. 

48 

 
 
The objective of ensuring the free movement of pyrotechnic articles in the internal market 
by means of the harmonisation of laws and practices can therefore be considered to be still 
relevant. 

b)  Health and Safety 

As mentioned in  section 3.2,  the numbers of  accidents with  pyrotechnic  articles  do not 
seem to have decreased and the negative impact of substances and noise emitted during 
explosions are an increasing concern. Moreover, as was explained in section 4.1.1.b), non-
compliant articles on the market, especially those imported from China, as well as the easy 
accessibility of high-risk fireworks by non-authorised persons, seem to compromise health 
and  safety.  In  line  with  these  observations,  the  respondents  to  the  public  consultation 
predominantly considered the Directive’s objective of ensuring the protection of human 
health and safety of consumers still relevant, with 32.4% (12 out of 37) responding ‘to a 
very large extent’ and 27% (10 out of 37) ‘to a large extent’. In the targeted survey, 27.8% 
(15  out  of  54)  of  respondents  said  that  they  consider  the  presence  of  non-compliant  or 
dangerous products on the market to be relevant to a low extent, including both responding 
large  manufacturers,  all  three  responding  importers  and  three  out  of  six  industry 
organisations182. However, 22.2% (12 out of 54) of all stakeholders considered the problem 
relevant to a high extent, 20.4% (11 out of 54) to a moderate extent and 18.5% (10 out of 
54) to a very high extent. 

Overall, health and safety risks linked to pyrotechnic articles are still a common concern 
for most stakeholders, and thus a relevant objective of the Directive. 54.1% (20 out of 37) 
of respondents  in  the public consultation  believe  that minimising  the number of  unsafe 
pyrotechnic  articles  on  the  market,  and  the  safety  and  accessibility  of  bigger  and  more 
powerful pyrotechnics to the public should be further addressed by the Directive in the 
future. 

c)  Security 

Security concerns linked to pyrotechnic articles such as illegal trade and criminal misuse, 
which were not of major relevance when the 2007 Directive was adopted, nor during the 
recast in 2013, have become more and more pressing in recent years, as shown in section 
3.3.  Accordingly,  the  majority  of  respondents  in  the  public  consultation  considered  the 
objective of ensuring public security still relevant to a large extent (37.8% (14 out of 37)) 
or very large extent (21.6% (8 out of 37)). In the open responses, an enforcement agency 
and  a  national  government  authority  shared  their  concern  that,  despite  progress  in 
restricting  pyrotechnics  access  to  non-authorised  individuals,  these  items  were  still 
misused in criminal activities due to inefficiencies in the current authorisation systems. A 
company and a market surveillance authority stated that they considered public security 
not adequately addressed by the Directive. 

In conclusion, it becomes apparent that the objective of public security has become even 
more relevant than it was when the Directive was adopted. Accordingly, controls to prevent 

182 The remaining industry organisations indicated ‘to a moderate extent’ (2 out of 6) and ‘to a high extent’ 

(1 out of 6). 

49 

 
 
access to pyrotechnic articles by malicious actors is a concern that, according to 54.1% (20 
out of 37) of stakeholders in the public consultation, should be further addressed in the 
future183.  Moreover,  56.8%  (21  out  of  37)  of  respondents  believe  that  proportionate 
enforcement and penalties to prevent illicit possession, misuse, and thefts of pyrotechnic 
articles should be further addressed by the Directive in the future. 

d)  Environmental protection 

As explained in section 3.4, the detrimental effects of pyrotechnic articles on wildlife and 
pets and the contamination of soil, air and water with chemical substances and plastics are 
concerns that have been expressed more and more vocally in recent years. In the public 
consultation,  35.1%  (13  out  of  37)  of  stakeholders  deem  the  consideration  of  aspects 
related  to  environmental  protection  to  a  large  or  very  large  extent  still  relevant,  while 
29.7% (11 out of 27) find it relevant to a moderate extent. Moreover, animal protection 
and  environmental  impacts  were  raised  by  two  non-governmental  organisations  and  a 
citizen, respectively, in their responses to the open question, as topics that are currently not 
sufficiently addressed. 

Against this background, the objective of environmental protection seems to be even more 
relevant than at the time when the Directive was adopted. In fact, only about a third of 
participants  to  the  public  consultation  considered  that  greener  and  more  sustainable 
chemical  compositions  for  pyrotechnic  articles  (including  compostability  and  plastic 
pollution) and animal welfare were currently addressed by the Directive, while almost half 
expressed their wish that these issues be further addressed in the future184. The relevance 
of environmental protection from the impacts of fireworks should also be considered in the 
light of new developments in the area of  entertainment, such as light and drone shows, 
which have been gaining popularity and seem to have less environmental impact. 

4.3.2.  Relevance with regard to other priorities/challenges 

In  the  public  consultation,  stakeholders  were  also  asked  to  what  extent  the  technical 
developments  were  currently  addressed  by  the  Directive.  In  that  regard,  online  trade 
emerged as a topic that is considered relevant to be further addressed for pyrotechnics in 
the future, with 51.4% (19 out of 37) stakeholders sharing this view, including seven out 
of ten public authorities. In relation to pyrotechnics containing digital components that 
are exposed to new risks (e.g. software malfunctioning, cyberattacks), 27% (10 out of 37) 
of stakeholders considered that this concern should be further addressed in the future, 2.7% 
(1 out of 37) said that it is currently addressed, while 70.3% (26 out of 37) responded ‘Do 
now know/prefer not to say’. 

Among other concerns, the need to increase the competitiveness of EU companies was 
considered to be currently addressed by 35.1% (13 out of 37) of respondents to the public 
consultation, while 27% (10 out of 37) responded that this should be further addressed in 

183  However,  83.3%  (5  out  of  6)  of  companies/businesses  responded  that  this  concern  was  currently 

addressed. 

184  For  ‘Addressing  greener  and  more  suitable  chemical  compositions  of  pyrotechnic  articles  (including 
compostability, plastic pollution)’, 48.7% (18 out of 37) responded that this concern should be further 
addressed in the future, while 35.1% (13 out of 37) responded that this concern was currently addressed. 

50 

 
 
the future. As regards, the Member States’ flexibility to authorise the use of pyrotechnics 
for traditional celebrations, processions, etc., 32.4% (12 out of 37) responded that this 
concern should be further addressed in the future, and 27% (10 out of 37) considered that 
it was currently addressed. 

4.3.3.  Relevance of the scope 

After having assessed the Directive’s relevance in terms of objectives, this sub-section will 
look more closely at the Directive’s current scope and whether it is still relevant. According 
to 64.8% (48 out of 74) of the respondents to the targeted survey, it is still relevant185. 

Relevance of product coverage 

Some issues were raised with regard to the delineation of scope set out in Article 2 of the 
Directive. According to paragraph 2(a) of that Article, pyrotechnic articles intended for 
non-commercial use by the armed forces, the police or  fire departments do not fall 
under the scope of the Directive. However, outside the context of the evaluation, Member 
States and industry have approached the Commission via email, in AdCo group meetings 
and meetings of the Forum of Notified Bodies to clarify from which point in the supply 
chain does the Directive not apply to a product that will eventually be used by the public 
security forces. The question was also raised in the targeted survey. It is especially relevant 
when  one  or  several  intermediate  companies  are  involved  that  manufacture  final 
pyrotechnic articles not only for use by public security forces, but also for commercial use. 
The  Commission  services  outlined  their  understanding  of  the  matter  in  a  document 
presented at the Commission Expert Group meeting on 18 March 2025, explaining that, 
while  the  exemption  is  not  limited  to  direct  sales  to  public  security  forces,  it  does  not 
necessarily apply to the whole supply chain and a case-by-case assessment of the situation 
is needed. 

Some stakeholders in the targeted survey, the public consultation and the interviews noted 
that some pyrotechnic articles, such as heavy flash bangers, posed similar risks to civil 
explosives and should therefore fall under the Civil Explosives Directive or be subject to 
similar  rules.  Moreover,  the  exclusion  of  pyrotechnic  articles  intended  for  use  in  the 
aerospace  industry  was  mentioned  as  problematic  by  two  stakeholders  in  the  targeted 
survey,  as  those  articles  were  not  excluded  from  the  Civil  Explosives  Directive  and, 
therefore, also low-risk explosive aviation components had to follow the strict traceability 
and transfer systems for civil explosives. When asked about products that were currently 
covered by the Directive but should rather be excluded from its scope, a professional user 
participating  in  the  public  consultation  suggested  excluding  smoke  devices.  In  turn, 
participants in the targeted survey proposed including equipment mimicking a pyrotechnic 
effect, ammunition-like articles, sparkle machines, maritime equipment and pyrotechnic 
substances. 

185 43.2% (32 out of 74) rated the relevance of the scope at 4 out of 5 and 21.6% (16 out of 74) at 5 out of 5. 

51 

 
 
 
Relevance of provisions 

The provisions of the Directive are still to a very high or high extent relevant across almost 
all areas of intervention, according to most stakeholders sharing their views in the public 
consultation186.  Nevertheless,  some  stakeholders  criticised  certain  provisions  or  made 
suggestions. 

As mentioned in section 4.1.1.b), the 1 m safety distance for F1 articles is not considered 
appropriate. Moreover, a small  number of stakeholders interviewed in  the Study on the 
illegal sales of F4 fireworks called for EU-wide limits to the net explosive content in F4 
fireworks187.  In  a  non-paper  addressed  to  the  Commission  in  late  2024,  France  and  the 
Netherlands went even further to consider an EU-wide limit on the amount of gunpowder 
and flash powder necessary also for F3, T1, T2, P1 and P2 articles, for which there was 
no maximum content defined in the Directive188. 

Stakeholders suggested that a number of aspects not currently covered by the provisions 
of the Directive should, in their view, be included. An enforcement agency, a professional 
user  and  two  interest  groups  /  civil  society  /  business  organisations  proposed  including 
common rules for storage. Animal welfare considerations should be covered according to 
two interest groups / civil society / business organisations. According to some respondents, 
the Directive should also regulate the transfer of articles (other, interest group / civil society 
/  business  organisation,  and  MSA),  and  harmonise  requirements  for  online  sales  and 
professional  certifications  (other).  Stricter  rules  on  emissions  (company)  and  better 
consumer awareness campaigns (interest group / civil society / business organisation and 
professional user) are also considered necessary. Finally, a mandatory authorisation system 
for the free movement of pyrotechnic articles within the EU was called for by a notifying 
authority189. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

Based on the above assessment and by drawing on different data sources and expertise, 
certain conclusions can be made on the overall performance of the Pyrotechnics Directive 
in terms of effectiveness, efficiency, coherence, relevance and EU added value. It should 
be remembered, however, that data available for the assessment of efficiency was limited 

186 ‘To a very large extent‘ and ‘to a large extent‘ were the most frequently given answers for the following 
areas:  ‘obligations  of  manufacturers’,  ‘obligations  of  importers’,  ‘obligations  of  distributors’, 
‘obligations  of  notified  bodies’,  ‘marking  and  labelling’,  ‘classification  of  pyrotechnic  articles’, 
‘traceability and record keeping’, ‘licences and authorisations’, ‘notification of conformity assessment 
bodies’, ‘seizures’, ‘sharing of information with authorities and operators’ and ‘conformity assessment 
procedures’. 

187  European  Commission,  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users 
(category F4) to the general public. Final Report, Oxford Research A/S (Denmark), 2019, p. 77. 
188 Government of the Netherlands/République Francaise, Modify the Pyro Directive to Protect Public Order 
and Safety, A collaborative non-paper between the Netherlands and France, 2024, not published. 
189 Other aspects were mentioned by stakeholders under the relevant open questions, but are not presented 

here as they do not relate to the relevance of the Directive’s provisions. 

52 

 
 
and rather difficult to correctly classify into the appropriate cost category and, as regards 
the benefits, impossible to quantify. 

Where  the  conclusions  do  not  differentiate  between  different  categories  of  pyrotechnic 
articles, they are valid for all, including for pyrotechnic articles for use in vehicles. With 
regard  to  pyrotechnic  articles  for  use  in  vehicles,  no  specific  concerns  or  shortcomings 
were identified in the course of the evaluation. 

5.1.1.  Effectiveness 

The Directive has to a large extent achieved its objectives. In particular, it contributed to 
the free movement of pyrotechnic articles in the internal market and the protection of health 
and safety.  However,  its positive effects on security and environmental protection have 
been more limited. 

Free  movement  of  pyrotechnic  articles  in  the  internal  market:  Despite  persistent 
differences  between  Member  States’  laws,  intra-EU  trade  in  pyrotechnic  articles  has 
increased since the Directive was adopted and a large share of stakeholders participating 
in the public consultation believe that the objective of guaranteeing the functioning of 
the internal market has been achieved. 

Health and safety: Although the lack of comprehensive and comparable data prevents us 
from drawing very clear conclusions on the Directive’s contribution to health and safety, 
it has become clear that there are persistent health and safety issues. The essential safety 
requirements, especially for categories F1, F4 and P1, do not seem sufficient to ensure 
the  safety  of  users,  bystanders  and,  in  the  event  of  criminal  misuse,  society  at  large. 
Moreover, non-compliance rates are still very high, despite a general perception among 
stakeholders that the quality of conformity assessments and market surveillance have 
improved thanks to the Directive. Concerns remain, in particular, with regard to imported 
fireworks  and  the  accessibility  of  high-risk  pyrotechnics  to  consumers.  Moreover, 
differences  in  market  surveillance  practices  and  difficulties  in  cross-border 
cooperation between market surveillance authorities seem to hamper the enforcement of 
safety requirements. 

Security:  The  Directive  has  not  effectively  prevented  security  threats  related  to 
pyrotechnic articles. Pyrotechnic articles are increasingly used for criminal purposes, e.g. 
to attack  first-responders and law enforcement personnel  and to  break open ATMs,  but 
also for organised crime. This is possible because the Directive does not effectively prevent 
the  diversion  of  legally  manufactured  pyrotechnic  articles.  Moreover,  the  traceability 
system set up by the Directive does not allow item-level tracking, making it difficult to 
trace back to which point in the supply chain an article was diverted. At the same time, 
illegally manufactured pyrotechnic articles are traded on the black market. Enforcement 
and  penalties  seem  insufficient  to  effectively  deter  illegal  behaviour,  especially 
considering that illegal behaviour involving pyrotechnic articles is often subject to lighter 
penalties than that committed with explosives or weapons. 

53 

 
Environmental  protection:  The  Pyrotechnics  Directive  does  not  fully  ensure  the 
protection  of  the  environment  from  the  negative  effects  of  pyrotechnic  articles. 
Environmental  pollution  and  animal  welfare  were  mentioned  by  stakeholders  as  not 
being adequately addressed by the Directive. 

5.1.2.  Efficiency 

Bearing in  mind the limited available cost  data, it can cautiously be concluded that the 
Directive is, overall, operating efficiently. 

Costs have increased for most stakeholders but, overall, still seem to be proportionate – 
they  are  equivalent  to  a  proportionate  share  of  companies’  turnover,  although  the 
burden for SMEs seems  to be bigger than for large companies. Most stakeholders have 
also  experienced  improved  efficiency  of  processes  and  tasks  thanks  to  the  Directive. 
Harmonised rules have reduced costs for familiarisation with legal requirements and for 
conformity assessments and facilitated market access. Stakeholders also benefit from 
improved  coordination  and  information  exchange  and  enhanced  traceability  of 
pyrotechnic  articles.  Costs  due  to  conformity  with  the  essential  safety  requirements, 
including design, manufacturing and assessment, seem proportionate, in particular in light 
of the safety benefit they bring. 

The Directive has  led  to  a  certain burden reduction,  as  tasks  and procedures  can be 
carried  out  more  efficiently.  Most  obligations  are  perceived  by  stakeholders  to  be 
proportionate and seem essential for achieving the Directive’s objectives. Some potential 
for  further  burden  reduction  could  be  identified  in  relation  to  the  labelling  of 
pyrotechnic  articles  and  record-keeping  obligations,  which  create  significant  costs  for 
stakeholders and are by some considered disproportionate. In the same vein, the mandatory 
accident  reporting  by  authorities,  in  its  current  form,  is  tying  up  authorities’  resources, 
while not bringing the expected benefits. 

5.1.3.  Coherence 

The Directive is coherent with other relevant EU legislation, but, with its limited focus 
on  security  and  environmental  protection,  the  Directive  does  not  seem  to  fully  support 
broader EU policies, in particular the EU Counter-Terrorism Agenda. Internationally, 
the Directive is complemented by international agreements and recommendations on the 
transport of dangerous goods. As regards coherence with national laws and policies, it 
must  be  noted  that  the  Directive  does  not  allow  Member  States  to  further  restrict  F4 
fireworks, which is not in line with some Member States’ security priorities. 

In terms of internal coherence, only a minor inconsistency between labelling provisions 
has been identified, potentially leading to confusion or misunderstandings as to whether 
certain information can be provided in a document accompanying the article. 

5.1.4.  EU added value 

The Directive has had an added value compared to what could have been achieved by the 
Member States acting alone. The results from the targeted survey suggest that, while the 
Directive seems to be essential for cross-border trade in the internal market, the objectives 

54 

 
of protecting safety and security were not sufficiently supported by the Directive, meaning 
that  Member  States  acting  individually  might  have  achieved  better  higher  levels  of 
protection at  national  level.  In light  of circumvention of national  rules via cross-border 
sales, a harmonised approach seems, however, preferable to individual national measures. 

5.1.5.  Relevance 

The Directive’s objectives of ensuring the free movement of pyrotechnic articles on the 
internal  market  via  the  harmonisation  of  laws  and  the  protection  of  health  and  safety, 
security and the environment are still relevant in light of current needs and problems. 
However, some of the objectives have become more relevant in recent years. Given the 
rise in illegal activities committed with pyrotechnic articles, the security objective seems 
even more important than ever. Similarly, environmental protection seems to have become 
more relevant since the Directive was adopted, also in light of emerging and possibly more 
environmentally-friendly alternatives, such as light and drone shows. The technological 
advancements made since the Directive was adopted are also not sufficiently addressed at 
present, notably online trade and pyrotechnics containing digital components. 

A few concerns about clarity and scope have emerged. These relate to the exemption of 
articles intended for use by public security forces, and the exclusion of articles for use in 
the aerospace industry. Moreover, in some cases, the delineation between civil explosives 
and pyrotechnic articles has proven to be challenging or inappropriate. Stakeholders are 
missing  provisions  on  storage,  animal  welfare,  transfer,  online  sales,  professional 
certifications, emissions and consumer awareness. 

5.2. 

 Lessons learned 

The evaluation shed light on those aspects of the Directive that are working well but also 
revealed problems and gaps. 

The main achievements of the Directive are: 

•  The  free  movement  of  pyrotechnic  articles  on  the  internal  market  through 
harmonised conformity assessment procedures and the alignment of national laws; 

•  Essential safety requirements for pyrotechnic articles across the EU; 
•  Increased  cooperation  and  information  sharing  between  and  among  market 

surveillance authorities, notified bodies and the Commission. 

However,  there  are  significant  shortcomings  which  compromise  the  Directive’s 
contribution to safety, security and environmental protection, as detailed below. 

•  Accessibility of dangerous fireworks: The Directive allows for the production of 
pyrotechnic articles with a net explosive content that exceeds even professional 
users’ needs. At the same time, it does not sufficiently prevent such articles from 
being used by unauthorised users, and even by criminals. Although this is also 
a  question  of  enforcing  existing  rules  properly,  a  harmonised  system  for  the 
verification of the required specialist knowledge would facilitate more effective 
checks  and  help  prevent  abuse,  notably  online.  Another  way  of  intentionally  or 

55 

 
unintentionally circumventing the strict rules for F4 fireworks is miscategorisation 
into the less stringent P1 or P2 categories. In addition to the risk from F4 fireworks, 
the broad availability of other dangerous consumer fireworks results in severe 
accidents and poses a security threat. 

•  National  restrictions:  Most Member States have made use of  the possibility  to 
introduce bans or restrictions on F2 and F3 fireworks, theatrical pyrotechnic 
articles and other pyrotechnic articles. While it is important to tackle risks that 
are  not  considered  to  be  sufficiently  addressed  by  the  Directive,  this  national 
discretion  prevents  laws  from  being  fully  harmonised  and  can  cause  trade 
barriers. At the same time, national restrictions can be easily circumvented by 
buying pyrotechnic articles across the border or online. On the other hand, because 
Member States cannot restrict F4 fireworks, the safety and security risks from 
such fireworks cannot be adequately addressed. 

•  Mail  order  sales:  The  existing  framework  is  not  designed  to  address  the  risks 
related  to  common  online  sales  practices,  mostly  taking  the  form  of  mail  order 
sales. The lack of physical contact between the distributor and the buyer means 
that the rules can be  circumvented, particularly  the  age verification  or specialist 
knowledge requirements, but also national restrictions. Moreover, the illegal postal 
shipment of pyrotechnic articles in regular parcels poses risks to postal services 
staff and other persons. 

•  Traceability:  The  lack  of  unique  identification  numbers,  as  required  for  civil 
explosives, makes it impossible to trace individual pyrotechnic articles throughout 
the supply chain, which could, however, be helpful for law enforcement and market 
surveillance. Moreover, even high-risk pyrotechnic articles, with risks similar to 
civil  explosives,  can  be  transferred  across  the  EU  without  any  procedural 
requirements, such as approval from the destination and transit states. 

•  Pollution  and  animal  welfare:  The  essential  safety  requirements  do  not 
sufficiently  account  for  environmental  protection.  Although  they  will  be 
supported by harmonised standards, a stronger focus  especially on pollution and 
animal welfare seems warranted in light of contemporary concerns and the EU’s 
environmental ambitions. 

56 

 
 
ANNEX I: PROCEDURAL INFORMATION 

Lead DG, Decide reference and, if relevant, Work Programme reference 

DG for Internal Market, Industry, Entrepreneurship and SMEs 

Agenda planning/ Work programme reference: PLAN/2022/1203 

Organisation and timing 

After it had been politically validated, the work on the evaluation started with the drafting 
of the terms of reference for the external study in support of the evaluation and the creation 
of the Interservice Steering Group (ISSG) in the last quarter of 2022. The first ISSG took 
place on 6 December 2022. The contract with the Economisti Associati SRL consortium 
for the external study was signed in October 2023 for an initially planned duration of ten 
months which, in May 2024, was extended by an additional three months. The ISSG was 
involved in all steps of the evaluation starting from the terms of reference, the consultation 
strategy and the call for evidence, and continuing throughout the duration of the public and 
targeted  surveys,  and  the  supporting  study  until  the  finalisation  of  the  Staff  Working 
Document. In total, the ISSG met seven times (06/12/22, 14/03/23, 12/12/23, 31/05/24, 
01/10/24, 18/11/24 and 05/05/25). 

Evidence used together with sources and any issues regarding its quality (i.e. has the 
information been quality assured?) 

The evaluation mainly used information gathered through various stakeholder consultation 
activities  but  also  studies,  reports,  academic  and  grey  literature  (e.g.  non-papers)  and 
statistical data from different databases, where available. Availability of cost data was very 
limited, and the market analysis was compromised by a lack of disaggregated data and data 
missing  for  some  years  within  the  evaluation  period.  Quality  was  assured  through 
triangulation  of  information  from  different  sources  and  validation  of  findings  in  the 
stakeholder validation workshop. A more detailed outline of the methodology can be found 
in Annex II. 

Use of external expertise 

Technopolis Group, supported by Milieu, Wavestone and Intellera, produced a supporting 
study. The study consulted external experts on Task 1 (Design of the methodology), Task 
2 (Collection of Information and data), and Task 4 (Answer to evaluation questions and 
conclusions).  The  external  experts  involved  in  the  study  were  Ineris  and  the  law  firm 
Kanzlei  Wübbe.  The  legal  expert  from  Kanzlei  Wübbe  primarily  contributed  to  the 
analysis  of  transposition  and  implementation,  as  well  as  the  coherence  aspect  of  the 
evaluation.  Ineris  provided  technical  guidance  and  feedback  to  the  evaluation  team  on 
multiple evaluation criteria across the study. 

57 

 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

The evaluation was supported by an external study carried out by Technopolis Group, 
supported by Milieu, Wavestone and Intellera. The contractor carried out most of the 
data  collection  activities  and  data  analysis  and  organised  a  stakeholder  workshop.  DG 
GROW and the ISSG closely monitored the contractor’s work from the inception phase 
until the final report. Consultation questionnaires were discussed and refined before their 
dissemination.  The  deliverables,  notably  the  final  report,  underwent  several  rounds  of 
commenting and revisions, to improve their quality.  

1.  Data collection activities 

The evaluation relied on information from a variety of sources:  

Desk research: Academic literature, grey literature (e.g. study reports, position papers, 
meeting  minutes,  contributions  and  documents  shared  by  stakeholders)  and  official 
documents  (e.g.  legislation,  Commission  Communications,  Council  decision)  were 
consulted to gather information, mainly on three areas of the evaluation: 

•  The transposition of the Directives by Member States and their implementation; 
•  The market structure analysis in the EU as well as trends in intra-EU and extra-EU 

trade; 

•  The key contextual developments and trends. 

All sources are listed in a bibliography at the end of this Annex. 

In  addition,  data  for  the  market  structure190  analysis  was  retrieved  from  the  Eurostat 
Structural Business Statistics (SBS). The market structure  analysis encompasses the entire 
European  ‘Manufacture  of  explosives’  sector,  which  includes  both  civil  explosives  and 
pyrotechnics, because they fall under the same NACE division. Data was available for the 
period from 2008 to 2022. Moreover, data is missing on some indicators for some years, 
which affects the continuity and completeness of the analysis. Data for the market size191 
analysis was taken from Prodcom, covering the period from 2003 to 2022, as records on 
pyrotechnic products for most Member States and the EU aggregate are missing from 1995 
to 2002 in the Prodcom dataset. Pyrotechnic articles in vehicles were not covered, because 
they  are  not  categorised  separately  in  the  Prodcom  data  base.  The  trade  analysis192  is 
based on data from the Eurostat Standard International Trade Classification (STIT) from 
1999 to 2024. However, some data from reporting countries was unavailable which may 
affect the completeness of analysis. 

190 Market structure is defined by the size, number, and distribution of businesses within a sector. 
191  The  market  size  of  the  European  pyrotechnics  industry  is  defined  as  the  value  of  sold  production of 

pyrotechnic products manufactured in the EU and placed on both EU and global markets. 

192 The  Trade Analysis analyses the trade value  of the  civil explosives industry, focusing on import and 
export  values  of  civil  explosives  products.  We  differentiate  between  intra-EU  trade  (transactions 
between EU member states) and extra-EU trade (transactions with countries outside the EU). 

58 

 
 
Call  for  evidence:  With  a  call  for  evidence,  published  in  all  EU  languages  on  the 
Commission  ‘Have  your  say’  from  4  May  to  1  June  2023,  the  Commission  gathered 
preliminary reactions  from  stakeholders on the main elements  of the  initiative.  In total, 
feedback  from  20  stakeholders  was  received:  nine  public  authorities,  four  EU  citizens, 
two  non-governmental  organisations,  one  business 
three  companies/businesses, 
organisation and one person. 

Targeted  survey:  A targeted survey, launched  on  15 March 2024 gathered specialists’ 
views across different categories of stakeholders on all evaluation questions. The survey 
consisted  of  110  questions  structured  in  five  sections:  1)  national  transposition  of  the 
Directive; 2) socio-economic context; 3) implementation of the Directive’s provisions; 4) 
overall assessment of the Directive; 5) suggestions for improvement. To take account of 
the  different  areas  of  competence  of  the  potential  respondents,  the  survey  included 
different  question  paths  adapted  to  the  different  respondent  types  (economic  operators, 
notified bodies, accreditation bodies, notifying authorities, etc.). 

The survey was deployed in English, using the tool Medalia193 and took approximately 45 
min  to  complete.  The  survey  was  distributed  to  all  stakeholders  identified  through  the 
mapping  process  (approx.  200  stakeholders).  Multipliers  were  employed  to  further 
disseminate  the  survey,  including  the  chair  of  the  Pyrotechnics  AdCO  and  industry 
organisations such as EuFias and SFEPA. The contractor aimed at balanced representation 
across  Member  States  and  stakeholder  types.  Tailored  reminders  were  sent  to  specific 
stakeholder  groups  as  corrective  measures.  Responses  were  closely  monitored  on  a  bi-
weekly basis to ensure diversity. Weekly reminders were also sent to selected stakeholders 
to boost response rates and encourage completion of the survey.  

Initially, the survey was set to be open for four weeks (i.e. mid April 2024). However, to 
accommodate  stakeholders’  needs  for  sufficient  time  to  collect  relevant  data,  often 
involving  coordination  across  various  departments  within  organisations  due  to  the 
extensive  nature  of  the  survey  and  the  large  number  of  questions,  the  deadline  was 
extended until the end of May 2024. In total, 80 answers were received, most of which 
from  market  surveillance  authorities  (24%).  For  many  questions,  a  high  percentage  of 
respondents  (sometimes  exceeding  40%  for  specific  questions)  selected  the  ‘Do  not 
know/prefer  not  to  answer’.  This  trend  was  particularly  evident  in  questions  related  to 
environmental  protection,  the  situation  before  the  implementation  of  the  previous 
directive,  and  questions  requiring  factual  information,  such  as  accident  frequency  and 
health and safety issue. Stakeholders cited the lack of available data or aggregated tracking 
systems in their Member States as reasons why they could not answer. Other factors might 
have been the historic focus of some questions and stakeholder fatigue due to the various 
consultation activities stakeholders were invited to. 

Public consultation: A public consultation was held from 8 April to 1 July 2024 on ‘Have 
your  Say’.  It  included  a  questionnaire  with  closed  and  open  questions,  which  the  wide 

193 For more information, please refer to the following website:  https://www.medallia.com/products/agile-

research/?utm_campaign=checkmarketmerger  

59 

 
 
public  was  invited  to  fill  in,  in  order  to  reach  a  broad  range  and  large  number  of 
stakeholders.  The  consultation  aimed  to  validate  the  topics  and  issues  covered  by  the 
evaluation,  gather  information,  data  and  experience  on  the  implementation  of  the 
Pyrotechnics Directive, solicit views and opinions of stakeholders on the extent to which 
this Directive has met its objectives, and gather views on the Directive’s relevance, taking 
into account social developments. In total, 37 answers were collected, most of them from 
EU citizens and public authorities (approx. 30 % each). 

Interviews:  The  contractor,  in  total,  conducted  48  interviews.  A  smaller  number  of 
‘scoping  interviews’  took  place  in  the  inception  phase  of  the  study  in  the  form  of 
exploratory  interviews.  This  allowed  the  study  team  to  obtain  necessary  and  relevant 
information at an early stage, so as to further develop the intervention logic, that ultimately 
also fed into the questionnaires and interview guides for the remaining stakeholders to be 
consulted.  In  addition,  some  key  sources  of  information  to  be  considered  in  the  desk 
research were identified and suggestions for potential topics to address via the case studies 
were collected. 

The majority of interviews were conducted in the main phase of the study, in the form of 
‘study interviews’,  which  covered some key trends and findings  that  emerged from  the 
desk research and the survey in more depth and/or filled some information gaps. These 
also comprised interviews on the eleven completed cost templates that were received. 

The  interviewees  were  identified  through  a  comprehensive  mapping  of  actors  in  each 
category, using existing contact information from the European Commission (e.g., notified 
bodies,  competent  authorities,  market  surveillance  authorities)  and  other  information 
available online. This process also included members of the Expert Group and contacts 
provided  following  pilot  interviews.  Additionally,  some  interviewees  were  identified 
through  the  survey,  which  included  a  question  allowing  respondents  to  indicate  their 
contact details for follow-up interviews. Lastly, some interviewees reached out directly to 
the contractor by email after learning about the study through the Expert Group. 

The interviews used semi-structured questionnaires covering the core  analytical  themes 
selected and issues of interest for deeper analysis, with flexibility to probe responses and 
to  explore  issues  that  emerge  during  discussion.  The  interviews  included  strategic 
questions and operational questions and were tailored to the different types of interviewees. 
The  interviews  were  conducted  via  MS-Teams.  The  interviews  were  undertaken  in 
English, and, where possible, in the national language (some interviews were conducted in 
French or Spanish upon request). 

Cost templates: Templates were circulated to administrations and economic operators for 
the quantification/monetisation of costs. Different cost templates were used for economic 
operators  (manufacturers),  notified  bodies  and  market  surveillance  authorities. 
Stakeholders were asked for estimations of costs and shares of costs across different cost 
categories (adjustment costs, administrative costs, indirect costs…) and whether those are 
one-off or recurrent as well as for information about the number of full-time equivalents 

60 

 
dedicated to compliance with the Directive. Despite the contractor’s efforts, only eleven 
cost templates were completed by stakeholders. 

Case studies: Two case studies were carried out in the context of the study with the aim 
to examine relevant aspects of the evaluation more in-depth. 

•  Case  Study  1:  Challenges  and  measures  to  tackle  the  illicit  use  of  pyrotechnic 

articles in the Netherlands and in France – hooliganism and riots   
•  Case study 2: The use of pyrotechnics in the automotive industry 

Summaries of these case studies can be found in Annex VIII. 

2.  Data analysis 

All collected data was analysed by the contractor using the indicators and judgment criteria 
from  the  evaluation  matrix  (see  Annex  III)  and  information  from  different  sources 
combined and compared (‘triangulation’).  

Responses from the public consultation and the targeted survey were statistically analysed 
to identify trends and patterns. Qualitative insights from interviews complemented these 
findings with context and details. More information on the methodology used to process 
consultation data can be found in the synopsis report in Annex V. 

For market structure analysis, the contractor used the following indicators: 

Table 5: Indicators for the market structure analysis 

Indicator 

Description 

Turnover 

Total  revenue  generated  from  operational  activities  within  a  specified  accounting 
period, including all amounts invoiced for goods and services sold during the reference 
period. Measures company size and market performance. 

Number of 
companies 

Number of 
employees 

Number of businesses whose primary activity is in the sector. 

Total human resources employed within the sector. 

Source : Structural Business Statistics glossary and metadata 

The market size of the European pyrotechnics industry is evaluated using the value of sold 
production of pyrotechnic products manufactured in the EU and placed on both EU and 
global markets. The analysis does not include pyrotechnic articles in vehicles, which are 
not categorised separately in the Prodcom dataset. 

For the trade analysis, the contractor used the following indicators: 

61 

 
Table 6: Indicators for the trade analysis 

Indicator  Description 

Extra-EU 
imports 

Intra-EU 
imports 

Extra-EU 
exports 

Value of goods entering the EU from non-EU countries under various customs procedures. 

Value of goods entering a Member State from another EU country. 

Value of goods leaving the EU for non-EU countries under various customs procedures. 

Intra-EU 
exports 

Value of goods destined for another Member State from a given Member State, including 
those in free circulation or under inward processing. 

Information and findings from the study were checked and complemented for the purpose 
of this Staff Working Document. 

3.  Bibliography 

Documents from public authorities 

Council of the European Union, Council Conclusions concerning the need to prevent and 
counter the use of pyrotechnics in spectator areas of football stadia and other sports 
venues, 13 October 2022, 13370/22 

European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation 
(Directive  2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and 
Directive  2014/28/EU,  Commission  Implementing  Directive  2008/43/EC  and 
in 
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62 

 
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Europol, 350 tonnes of dangerous fireworks seized in Germany and the Netherlands. The 
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the 

International Carriage of Dangerous Goods by Road, 2022 

63 

 
United  Nations,  Recommendations  on  the  Transport  of  Dangerous  Goods,  Model 

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65 

 
 
ANNEX III. EVALUATION MATRIX 

The table below presents the evaluation matrix. For each key evaluation question, it presents sub-questions, judgement criteria, and indicators, as well as 
relevant data and information sources and assessment methods. 

# 

Question 

Judgement criteria 

Indicators and descriptors 

Sources of 
information 

ECT-
01.1 

Do the existing 
requirements, including 
essential requirements as 
well as categories of 
pyrotechnics, continue to 
provide for an adequate level 
of protection of public 
interests and security, health 
and safety of users? 

•  Existing requirements adequately cover the 
needs, risks and recent developments in 
terms of health and safety; 

•  Existing requirements adequately cover the 
needs, risks, and recent developments in 
terms of security; 

•  Existing requirements adequately cover the 
needs, risks and recent developments in 
terms of environment  

•  Trend and type of accidents and health and safety issues 

•  Public 

involving products covered by the Directive  

consultation 
•  Targeted survey  
•  Interviews 
•  Desk research 
•  Safety Gate and 

ICSMS 

•  Trend and type of cases of illicit activities linked to the 

•  Public 

products covered by the Directive 

consultation 
•  Targeted survey  
•  Interviews 
•  Desk research 

•  Number and type of cases where Member States found that a 

•  Targeted survey 

product in compliance with the Directive presented a health & 
safety, security and/or environmental risk  

•  New products falling under the scope of the Directive for 

which requirements are not fully fit for purpose 

•  Stakeholders’ opinion on the level of protection in terms of 
health & safety, security and environment ensured by the 
current requirements and potential uncovered risks 

•  Desk research  
•  Interviews  

•  Public 

consultation 
•  Targeted survey 

66 

 
 
ECT-
01.2 

ECT-
02.1 

that 

To  what  extent  does  the 
Directive  ensure 
the 
articles  imported  from  third 
countries 
are 
equally 
those 
safe 
manufactured in the EU? 

(non-EEA) 

as 

•  Trend in the number of incidents adversely affecting the 

environment related to pyrotechnic articles  

•  Number and type of restrictions going beyond the minimum 

requirements adopted by Member States for health and safety 
reasons 

•  Targeted survey 
•  Desk research 

•  Targeted survey 
•  Desk research 

•  The enforcement of the existing requirements 
ensures an adequate level of protection of 
public interests and security, health and 
safety of their users practices 

•  Types and frequency of controls performed by MS to verify the 

•  Targeted survey 

compliance of products on the EU market 

•  Main differences in the controls performed nationally to ensure 

•  Targeted survey 

compliance of the products on the EU market  

•  Frequency, number and types of infringements of national rules 

•  Targeted survey 

on the compliance with essential safety requirements 

•  Most common difficulties faced in national and cross-border 

•  Targeted survey 

enforcement of rules  

•  Stakeholders’ opinion on the level of protection in terms of 
health & safety, security and environment ensured by the 
current enforcement practices 

•  Obligations on the economic operators 

involved in the import are clear and cover all 
possible areas of health & safety risks 

•  Type of obligations adopted at the national level on economic 
operators involved in the import of products covered by the 
Directive  

•  Targeted survey 
•  Public 

consultation 

•  Targeted survey  
•  Desk research 

•  Conformity assessment carried out in third 
countries is subject to the same level of 
controls and supervision and conformity 
assessment carried out in the EU 

•  Number and type of infringements of obligations on economic 
operators involved in the import of products covered by the 
Directives 

•  Targeted survey 
•  ICSMS 

•  Number and types of requests for clarification sent by MSs to 
the Commission on the obligations of economic operators 
involved in the import 

•  Desk research 
•  Interviews  

•  Share of products found not compliant out of the total number 
of products imported from third countries subject to controls 

•  Targeted survey 
•  Desk research 
•  ICSMS 

67 

 
 
 
 
 
 
 
ECT-
02.2 

ECT-
03.1 

•  Share of subcontracting to third country bodies by notified 

•  Targeted survey 

bodies 

•  List of possible health & safety issues identified during the 

controls of EU manufactured products and imported products 

•  Consistency in the application of conformity 

•  Types and frequency of conformity assessment performed by 

assessment: comparing conformity 
assessment levels between products 
manufactured within the EU and those 
imported from third countries 

MS on products manufactured in the EU and products 
imported into the EU to verify the compliance  

•  Types of controls performed to ensure the compliance of 

products coming from third countries and actors involved  

•  Consistency in Market Surveillance: 

comparing levels of control by market 
surveillance actors on articles entering the 
EU market through physical and online 
channels 

•  Types and frequency of controls performed nationally on 

physical and online incoming flows of goods  

•  Interviews 
•  Safety Gate 

•  Desk research 
•  Interviews 

•  Desk research 
•  Targeted survey 
•  Interviews 

•  Desk research 
•  Interviews 
•  Targeted survey 

•  Types and frequency of controls performed on  notified bodies 

•  Targeted survey 

•  Frequency, number and types of infringements of national rules 
requiring compliance with essential safety requirements for 
both products manufactured in the EU and products imported 
into the EU  

•  Targeted survey 
•  Public 

consultation 

•  ICSMS  

•  Most common difficulties to the implementation of controls on 
products manufactured in the EU and products imported into 
the EU 

•  Targeted survey  

•  Most common difficulties to the implementation of controls on 

•  Interviews   

physical and online incoming flows of goods 

Stakeholders’ opinion on the level of protection in terms of 
health & safety ensured by the current enforcement practices 

•  Severity of penalties per type of infringement per MS 

•  Public 

consultation 
•  Targeted survey  

•  Targeted survey 
•  Desk research 

68 

 
 
 
 
ECT-
03.2 

ECT-
04.1 

Are 
the  current  penalties 
effective,  proportionate  and 
dissuasive? 

The  level  of  penalties  for  infringements  of  the 
requirements set by the Directive is comparable 
across MS 

•  Main differences in the penalty systems implemented 

nationally 

•  Level of consistency/distortion across sanction regimes. 

•  Targeted survey 
•  Desk research 

•  Desk research 
•  Interviews 

•  Penalties defined at the national level allow 

•  Number and type of cases requiring cross- border cooperation  

•  Targeted survey 

for cross border cooperation 

•  The introduction of penalties at the national 
level is accompanied by a reduction in cases 
of non-compliance 

The current system ensures the traceability of the 
articles through all steps of the value chain 

69 

•  Enablers and challenges of cross-border cooperation 

•  Interviews 

•  Trend in the number of non-compliant products circulating in 

the EU market 

•  Trend in illicit activities involving the products covered by the 

Directive 

•  Targeted survey 
•  Public 

consultation 

•  Targeted survey 
•  Public 

consultation 

•  Frequency and trend in the number of infringements or cases of 
non-compliance by stakeholders concerned by the obligations 
of the Directive 

•  Targeted survey 
•  Public 

consultation 

•  Factors affecting the effectiveness of the penalties (eg. levels 
of awareness of health & safety, security and environmental 
risks of the public opinion, cultural traditions) 

•  Interviews  

•  Stakeholders’ opinion on the effectiveness of the system of 

penalties  

•  Targeted survey 
•  Public 

consultation 

•  Types of measures adopted at the national level to implement 

•  Targeted survey 

the traceability requirements set by the Directive ( eg. 
marking/labelling processes, digital vs ; online record keeping 
practices, type of information stored, exchange of information) 

•  Roles and responsibilities of the actors involved in the 
traceability of the products throughout the value chain 

•  Desk research 

Is 
the 
enabling 
articles effective?  

current 
traceability 

system 
of 

 
 
 
•  Main differences in national measures implementing the 

traceability system 

•  Targeted survey 
•  Desk research  

•  Type and frequency of controls on the respect of the 

•  Targeted survey 

traceability requirements 

•  Enablers and challenges in the implementation of controls on 

the traceability requirements 

•  Targeted survey 
•  Interviews  

•  Trend in the frequency of infringements related to traceability 

•  Interviews 

requirements 

•  Number of lost, stolen or diverted products covered by the 

Directive 

•  Number and key features of cases of trafficking of illegal 

pyrotechnics  

•  Types of mechanisms for sharing information among 

stakeholders and MS in case of security concerns in relation to 
the products covered by the Directive 

•  Stakeholders’ opinion on the effectiveness of the traceability 

system 

•  Ibid 

•  Information included in the licences and authorisations granted 
to economic operators to engage in the manufacture, storage, 
use, import, export, transfer or trade of pyrotechnics and 
challenges in checking the validity of licences granted by 
another MS 

•  Targeted survey 
•  Interview  

•  Targeted survey 
•  Interview  

•  Targeted survey 
•  Interview  

•  Targeted survey 
•  Public 

consultation 

•  Desk research  

ECT-
04.2 

Does 
the  current  system 
provide enough safeguards to 
combat  trafficking  of  illegal 
pyrotechnic articles? 

The current system ensures the traceability of the 
pyrotechnic articles  

ECT-
05.1 

Is the current framework for 
storage  and  or  transfer  or 
transit of articles effective?  

The framework for storage prevent pyrotechnics 
from being stolen 

•  Types of obligations and requirements concerning the storage 

•  Desk research 

and transit set by the Directive and other relevant EU 
legislation 

70 

 
 
•  Types of measures adopted nationally for the storage and 

•  Desk research 

transit of products covered by the Directive 

•  Types of security risks linked to the storage and transit 

•  Targeted survey 

•  Types and frequency of controls at the national level on the 
storage and transit of the products covered by the Directive 
(e.g. substantial  vs procedural) 

•  Targeted survey 

•  Trend in the n. of stolen/diverted products covered by the 

•  Targeted survey 

Directive (in the EU and outside) 

•  Stakeholders’ opinion on the effectiveness of the current 

•  Targeted survey 

framework for storage and transit 

The  current  rules  prevent  pyrotechnic  articles 
from being diverted  

•  ibid 

The  existing  monitoring  system  covers  all  the 
the  Directive,  Information 
key  aspects  of 
collected through the monitoring system allows 
well-informed EU decision-making processes 

•  List of key provisions of the Directive 

•  Level of compliance of MS with the monitoring requirements 

•  Targeted survey 

•  Desk research 

•  Desk research 
•  Interviews 

•  Level of involvement of MS in the expert groups on 

•  Desk research 

pyrotechnic articles 

•  Types of monitoring arrangements at the national level (besides 

those set by the Directive)  

•  Stakeholders’ opinion on the relevance of the existing 

monitoring provisions of the Directive, the usefulness of the 
information obtained and the potential areas for improvement 

•  Measures had economic effects on intra-EU 
flows and increased competitiveness of EU 
companies 

•  Level of harmonisation of national rules on the making 

available of products covered by the Directive on the EU 
market (provisions linked to the Single Market) 

•  Targeted survey 
•  Interviews 

•  Targeted survey 
•  Interviews 

•  Targeted survey 
•  Public 

consultation 
•  Desk research 

71 

ECT-
05.2 

ECT-
06 

ECT-
07.1 

extent 

To  what 
pyrotechnics  diverted 
terrorist 
purposes? 

are 
for 
criminal 

and 

the 

monitoring 
Are 
lack 
the 
provisions,  or 
thereof, 
in 
effective 
providing  data  that  allows 
well-informed 
conclusions 
about  the  functioning  of  the 
Directive? 

have 

been 

What 
the 
qualitative  and  quantitative 
effects  of  the  measures  on 
their  objectives?  How  have 

 
they 
evolved 
implementation 
measures 

since 
of 

the 
the 

•  The effects evolved over time since the 

•  Main differences in the current national implementation 

implementation of the measures 

practices and requirements perceived by stakeholders to have 
adverse impacts on the Single Market  

•  Trend in the production value and turnover of the EU industry 

for the products covered by the Directive 

•  Trend in the number and size of companies active in the sectors 

covered by the Directive, per sector 

•  Trend in volume and value of intra-EU flows of products 

covered by the Directive 

•  Trend in volume and value of extra-EU flows of products 

covered by the Directive 

•  Trend in the proportion of sales that EU businesses derive from 

national, intra-EU or extra-EU trade 

•  Desk research 
•  Interviews  

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Trend in the proportion of sales taking place online vs. offline  

•  Desk research  

•  Trend in the share of the EU industry in the total value of the 

market for the products covered by the Directive 

•  Trend in the trade competitiveness index  

•  Trend in the trade barriers affecting the Single market 

•  Level of trust of MSs and economic operators and mutual 
recognition of authorisations, compliance assessments and 
marking/labelling 

•  Desk research  
•  Interviews 

•  Desk research  

•  Targeted survey  
•  Desk research  

•  Interviews 

•  Stakeholders’ opinion on the positive and negative effects of 
the Directive on the strengthening of the Single Market and 
potential areas for improvement 

•  Targeted survey 
•  Public 

consultation 

•  Level of coverage of health and safety risks in the Directive 

•  Public 

consultation  
•  Targeted survey   

ECT-
07.2 

Measures  had  effects  in  terms  of  safety,  the 
effects 
the 
over 
implementation of the measures 

evolved 

since 

time 

72 

 
 
•  Level of harmonisation of national rules on the making 

available of products covered by the Directive on the EU 
market (provisions linked to the health and safety) 

•  Desk research 

•  Targeted survey 
•  Public 

consultation 
•  Desk research 

•  Main differences in the current national implementation 

•  Interviews 

practices and requirements perceived by stakeholders to have 
adverse impacts on health and safety  

•  Trend in the number of accidents and health & safety issues 

concerning the products covered by the Directive 

•  Targeted survey 
•  Safety Gate  
and ICSMS 

•  Data from 
accident 
reporting 

•  Key changes in the testing procedures adopted at the national 

•  Desk research  

level to verify the safety of the products  

•  Trend in the compliance to essential requirements of products 

available on the EU market 

•  Targeted survey 
•  Public 

consultation 

•  ICSMS 

•  Trends in the power/capacity of individual pyrotechnic 

•  Desk research  

products 

•  Stakeholders’ opinion on the positive and negative effects of 
the Directive on the health and safety of the products made 
available on the EU market 

•  Level of coverage of security risks in the Directive 

•  Targeted survey 
•  Public 

consultation 

•  Targeted survey 
•  Public 

consultation 
•  Desk research 

ECT-
07.3 

Measures had effects in terms of public security. 
The  effects  evolved  over 
the 
implementation of the measures 

time  since 

73 

 
 
 
 
•  Level of harmonisation of national rules on the making 

available of products covered by the Directive on the EU 
market (provisions linked to security) 

•  Targeted survey 
•  Public 

consultation 
•  Desk research 

•  Main differences in the current national implementation 

•  Interviews  

practices and requirements perceived by stakeholders to have 
adverse impacts negative effects in terms of security (eg, 
transfer procedures, requirements for authorisation, 
identification and traceability requirements) 

•  Trend in the number of security-related incidents and illicit 
activities concerning the products covered by the Directive 

•  Targeted survey 

•  Key changes in the national measures for the identification and 

•  Desk research  

traceability of the products covered by the Directive 

•  Stakeholders’ opinion on the positive and negative effects 

brought by the Directive in terms of overall public security 

•  Targeted survey 
•  Public 

consultation 

•  Level of coverage of environmental risks in the Directive 

•  Public 

•  Level of harmonisation of national rules on the making 

available of products covered by the Directive on the EU 
market (provisions linked to the protection of the environment) 

•  Main differences in the current national implementation 

practices and requirements that might have negative effects on 
the environment  

consultation  
•  Targeted survey 
•  Desk research 

•  Targeted survey 
•  Public 

consultation  
•  Desk research 

•  Desk research 
•  Interviews 

•  Trend in the number of incidents that negatively affected the 

•  Targeted survey 

environment concerning the products covered by the 
pyrotechnic Directive 

ECT-
07.4 

Measures had environmental effects. The effects 
evolved  over  time  since  the  implementation  of 
the measures 

74 

 
 
•  Key changes in the measures adopted nationally to assess the 

conformity of the products covered by the pyrotechnic 
Directive and extent to which environmental risks have been 
considered  

•  Desk research 
•  Interviews 

•  Stakeholders’ opinion on the positive and negative effects 

brought by the pyrotechnic Directive in terms of environmental 
risk protection 

•  Targeted survey 
•  Public 

consultation 

•  Level of coverage of the Directive of environmental aspects  
(environmental protection, biodiversity, animal well being, 
etc.) 

•  Public 

consultation  
•  Desk research 

ECT-
08 

ECT-
09.1 

Are  there  any  unintended 
effects of the measures? 

To  what  extent  has 
the 
different  implementation  in 
MSs 
the 
impacted 
effectiveness of the measures 
on the objectives?  

The measures had unintended effects  

•  Stakeholders’ opinion on the unintended effect of the Directive 

•  Interviews 

There  are  differences  in  the  implementation  of 
the measures, differences in the implementation 
have reduced the effectiveness of the measures, 
Member States have derogated to common rules 
and/or  have  adopted  more  restrictive  rules, 
derogations  and/or  restrictions  resulted  in  good 
practices, derogations and/or restrictions resulted 
in gold-plating 

•  Level of harmonisation of rules and practices adopted at the 

•  Targeted survey 

national level per area of intervention of the Directive 

•  Main differences in the national implementation practices and 
requirements that might have negative effects/create risks on 
the Single Market, on the health and safety of the users, on the 
public security and on the protection of the environment  

•  Desk research  
•  Interviews 

•  Number and rationale of cases where MSs adopted stricter 

rules for pyrotechnics intended to the general public 

•  Number and rationale of cases of gold plating 

•  Targeted survey 
•  Desk research 

•  Targeted survey 

•  Stakeholders’ opinion on the extent to which differences in 

•  Targeted survey 

national rules and practices affected the overall effectiveness of 
the Directive’s measures and on the effects generated 

•  Type of effects brought by differences in the national measures 

•  Targeted survey 

•  Number and type of national measures, derogations and/or 
additional restrictions that proved to be good practices 

•  Targeted survey 
•  Interviews 

75 

 
ECT-
09.2 

ECT-
09.3 

ECT-
10 

Is there national gold-plating 
that  hampers 
internal 
market? 

the 

is 

the 

impact  of 
What 
national  derogations 
and 
possible  gold-plating  on  the 
free movement of articles in 
the internal market? 

use 

traditional 

of 
The 
fireworks  differs  greatly 
between Member States, e.g. 
festivities. 
for 
Directive 
Does 
effectively  reflect  cultural 
differences for fireworks? 

traditional 

the 

ECT-11  Are 

there 

any 
aspects/means/actors 
that 
render  certain  aspects  of  the 
measures  more  or 
less 
effective than others, and – if 

Ibid 

Ibid 

National  rules  for  F2  and  F3  fireworks  are 
different  among  MSs,  differences  in  national 
rules  for  F2  and  F3  fireworks  reflect  different 
national traditions 

The allocation of roles and responsibilities in the 
implementation of the measures to specific actors 
affected  the  effectiveness  of  the  measures,  the 
use  of  digital  and  electronic  tools  affected  the 
effectiveness  of  the  measures,  the  means  of  of 

76 

•  Number and rationale of cases of gold plating 

•  Targeted survey 

•  Stakeholders’ opinion on the extent to which national 

•  Interviews 

derogations and possible gold-plating on the free movement of 
articles affected the free movement of articles in the internal 
market 

•  Type of effects brought by derogations and possible gold-

•  Targeted survey 

plating 

•  Number and type of national measures, derogations and/or 

•  Interviews 

additional restrictions that proved to be good practices for the 
internal market  

•  Level of harmonisation of national rules applicable to F2 and 

F3 fireworks 

•  Targeted survey 
•  Desk research 

•  Type and scale of the differences in the rules applicable to F2 

•  Desk research 

and F3  

•  List of MSs with historical traditions linked to the use of 

•  Desk research 

fireworks 

•  Level of correlation between MSs that adopt stricter rules for 
F2 and F3 and those that have strong traditions linked to the 
use of fireworks 

•  Targeted survey  

•  Stakeholders’ opinion on the extent to which the room left by 

the Pyrotechnic Directive to MSs allows them to safeguard and 
maintain their national traditions 

•  Targeted survey 
•  Public 

consultation 

•  Types of digital and electronic tools used at the national level 

•  Targeted survey  

for the implementation of obligations and requirements 
stemming from the various measures of the Directive 

•  Forms of transposition of the Directive adopted by MSs 

•  Desk research 

 
 
there  are  – what lessons can 
be drawn from this? 

(legal 

transposition 
administrative 
documents)  affected  the  effectiveness  of  the 
measures 

acts, 

•  Key challenges preventing the Directive from effectively 

•  Public 

achieving its intended objectives 

•  Trend in the number of accidents and health & safety issues 
related to the products covered by the Directive per MS 

consultation 
•  Targeted survey  
•  Interviews 

•  Targeted survey 
•  ICSMS 

and Safety Gate 

•  Data from 
accident 
reporting 

•  Trend in the number of security incidents related to the 

•  Targeted survey 

products covered by the Directive per MS 

•  Trend in the number of non-compliant products per MS 

•  Targeted survey 
•  Public 

consultation 

•  ICSMS 

•  Types of product-related controls and frequency per MS 

•  Targeted survey 

•  Stakeholders’ opinion on the effectiveness of the Directive at 

the national level and on key strengths and weaknesses per MS  

•  Targeted survey 
•  Public 

consultation 

•  Stakeholders’ opinion on aspects/means/actors that affect the 

•  Targeted survey 

effectiveness of the measures of the Directive 

ECT-
12.1 

To  what  extent  have  the 
specific 
general 
and 
objectives been achieved? 

The  directive  contributed  to  harmonising  rules: 
for making available pyrotechnics.  

•  Level of harmonisation of national rules and practices per area 

of intervention 

•  Main differences in national rules and practices per area of 

intervention 

77 

•  Targeted survey 
•  Public 

consultation 
•  Desk Research 

•  Desk research 
•  Targeted survey 

 
ECT-
12.2 

The directive improved the traceability of sales 
and  transactions  to  prevent  illicit  possession, 
misuse and thefts. 

•  Number and rationale of cases where MSs adopted stricter 

•  Targeted survey 

rules for pyrotechnics intended to the general public 

•  Number and rationale of cases of gold plating 

•  Areas of improvement 

•  Main differences in the national measures implementing the 

traceability requirements set by the Directive 

•  Targeted survey 

•  Targeted survey 
•  Interviews 
•  Public 

consultation 

•  Desk research 
•  Targeted survey 

•  Trend in the controls on the respect of the traceability 

•  Interviews 

requirements 

•  Trend in the n. of lost, stolen or diverted products covered by 

•  Targeted survey 

the Directive 

•  Trend in the n. of security incidents linked to the products 

•  Targeted survey 

covered by the Directive 

•  Trend in the ability of Law Enforcement Authorities and 

•  Targeted survey 

Market surveillance authorities to trace a product throughout 
all stages of the supply chain 

•  Stakeholders’ opinion on the contribution of the Directive’s 

measures to the traceability of pyrotechnics 

•  Areas of improvement 

•  Targeted survey 
•  Public 

consultation 

•  Targeted survey 
•  Interviews 
•  Public 

consultation 

ECT-
12.3 

The directive contributed to ensuring the quality 
and credibility of notified bodies’ work 

•  Trend in the type and number of controls over the notified 

•  Targeted survey 

bodies per MS 

78 

 
 
 
•  Trend in the number of cases where the competence of notified 

•  Desk research 

bodies has been challenged 

•  Trend in the number of appeal procedures against decisions of 

•  Desk research 

a notified body 

•  Trend in the number of non-compliant products covered by the 
Directive (as resulting from incidents, market surveillance 
evaluations or controls performed by EOs and notified bodies)  

•  Targeted survey 
•  Public 

consultation 

•  ICSMS 

•  Rules and topics of discussion of the working group of 

•  Desk research 

Notified Bodies organised by the EC 

•  Level of involvement of national authorities responsible for 

•  Desk research 

notification policy in the platform mentioned above 

•  Rules and topics of discussion in the sectoral group of notified 

•  Desk research 

bodies 

•  Level of involvement of the national notified bodies in the 

•  Desk research 

sectoral group mentioned above 

•  Stakeholders’ opinion on the contribution of the Directive’s 

•  Public 

measures to increasing the quality and credibility of the work 
of the notified bodies 

consultation 
•  Targeted survey 

•  Stakeholders’ opinion on the extent to which the lack of 
validity of the conformity certificates granted by notified 
bodies represents an obstacle to supervision 

•  Areas of improvement 

ECT-
12.4 

The  directive  increased  the  effectiveness  of 
market surveillance activities 

•  Channels and frequency of exchange of information between 
national market surveillance authorities (especially when the 
product’s non-compliance or risk affect other MSs) 

79 

•  Targeted survey 

•  Targeted survey 
•  Interviews 
•  Public 

consultation 

•  Targeted survey  

 
 
•  Trend in the number of incidents and health & safety issues 

related to the products covered by the Directive 

•  Trend in the number of prohibitions, withdrawals, recalls of 
products covered by the Directive and underlying rationale 
(non-compliance and/or risks)  

•  Trend in the n. of market surveillance evaluations launched in 

the MS 

•  Stakeholders’ opinion on the contribution of the Directive’s 
measures to the improvement of the effectiveness of market 
surveillance authorities 

•  Areas of improvement 

•  Targeted 
survey 
•  Public 

• 

consultation 
ICSMS 
and Safety 
Gate 
•  Data from 

accident 
reporting 

•  Targeted 
survey 

•  Targeted 
survey 

•  Targeted 
survey 
•  Public 

consultation  

•  Targeted 
survey 
Interviews 

• 
•  Public 

consultation 

ECT-
12.5 

that 
The  directive  contributed 
pyrotechnic articles on the EU market fulfil the 
requirements providing a high level of protection 
of  health  and  safety,  and  other  public  interests 

to  ensuring 

•  In addition to all indicators used to assess the achievement of 
the specific objectives (listed above) and those used to assess 
the overall qualitative and quantitative effects of the measures 
the analysis included: 

80 

 
 
 
 
 
 
 
 
(security  and  environment),  while  guaranteeing 
the functioning of the internal  market 

•  Comparison of the Directive’s impact on market, health & 

safety and security aspects  

•  Stakeholders’ opinion on the contribution of the Directive to 
ensuring that pyrotechnic articles on the EU market fulfil the 
requirements providing a high level of protection of health and 
safety, and other public interests, while guaranteeing the 
functioning of the internal market 

•  Areas for improvement 

•  Trend in the production value and turnover of the EU industry 

for the products covered by the Directive  

•  Targeted survey  
•  Public 
consultation  

•  Targeted survey  
•  Public 
consultation  

•  Targeted survey 
•  Public 
consultation 
•  Interviews 

•  Desk research  
•  Interview 

•  Trend in the number and size of companies active in the sectors 

covered by the Directive (with specific focus on SMEs) 

•  Desk research  
•  Interview  

•  Trend in volume and value of intra-EU flows of products 

covered by the Directive 

•  Trend in volume and value of extra-EU flows of products 

covered by the Directive 

•  Trend in the proportion of sales that EU businesses derive from 

national, intra-EU or extra-EU trade 

•  Trend in the share of the EU industry in the total value of the 

market for the products covered by the Directive 

•  Trend in the trade competitiveness index  

•  Desk research  
•  Interview 

•  Desk research  
•  Interview 

•  Desk research  
•  Interview 

•  Desk research  
•  Interview 

•  Desk research  

ECT-
13.1 

To  what  extent  has 
the 
directive  contributed  to  the 
achievement  of  Sustainable 
Development Goals?  

The  directive  positively  contributed  to  Goal  9 
(Build resilient infrastructure, promote inclusive 
and  sustainable 
industrialization  and  foster 
innovation) 

81 

 
 
 
 
 
•  Trend in the trade barriers affecting the Single Market (with a 

specific focus on SMEs) 

•  Evolution in the measures adopted by MS to reduce 

environmental risks when evaluating the conformity of 
pyrotechnic products to EU requirements 

• 

•  Stakeholders’ opinion on the contribution of the Directive to: 
Increasing the competitiveness of the EU sectors 
and raising the industry’s share of employment and 
GDP 
Integrating SMEs in the value chain 
Increasing the overall sustainability of the 
industrial sector  

• 
• 

•  Targeted survey 
•  Desk research  

•  Desk research  
•  Interviews  

•  Targeted survey 
•  Public 

consultation 

ECT-
13.2 

The  directive  positively  contributed  to  Goal  16 
(Peace, justice and strong institutions) 

•  Trend in the number of security-related incidents and illicit 
activities concerning the products covered by the Directive 

•  Targeted survey 

•  Key changes in the national measures for the identification and 

traceability of the products covered by the Directive 

•  Key changes in the national measures and requirements on 

exchange of information of products covered by the Directive 

•  Desk research 
•  Interviews  

•  Desk research 
•  Interviews 

•  Stakeholders’ opinion on the contribution of the Directive to: 

•  Targeted survey 

• 
• 
• 

reducing violence  
creating peace, security and stability 
ensuring stable enabling conditions for the global 
social and economic development of the EU SDG 16 

ECT-
14 

To  what  extent  has 
the 
directive  contributed  to  the 
new 
European  Growth 
Model?  

The  directive  enhanced  Europe’s  resilience  by 
strengthening the Single Market 

•  Trend in the production value and turnover of the EU industry 

for the products covered by the Directive  

•  Trend in the number and size of companies active in the sectors 

covered by the Directive 

•  Desk research  
•  Interviews  

•  Desk research 
•  Interviews 

82 

 
 
 
 
 
 
 
•  Trend in volume and value of intra-EU flows of products 

covered by the Directive 

•  Trend in volume and value of extra-EU flows of products 

covered by the Directive 

•  Trend in the proportion of sales that EU businesses derive from 

national, intra-EU or extra-EU trade 

•  Trend in the share of the EU industry in the total value of the 

market for the products covered by the Directive 

•  Trend in the trade competitiveness index  

•  Trend in the trade barriers affecting the Single Market  

•  Desk research  
•  Interviews 

•  Desk research 
•  Interviews  

•  Desk research 
•  Interviews  

•  Desk research 
•  Interviews 

•  Desk research  

•  Targeted survey 
•  Desk research  

•  Quantitative assessment for difference in current costs to the 

•  Public 

baseline per Directive  

•  Total administrative, adjustment and enforcement costs (min, 

max, average) by sub-category of costs and stakeholder 

•  Administrative, adjustment and enforcement costs broken 
down by sub-category of costs and stakeholder type  

consultation 
•  Targeted survey 
•  Cost templates 
and interviews 

•  Targeted survey 
•  Cost templates 
and interviews 

•  Targeted survey 
•  Cost templates 
and interviews 

•  Qualitative assessment for economic operators and 

•  Public 

administrations 

consultation 
•  Targeted survey 
•  Cost interviews 

EFF- 
01 

are 

What 
administrative 
burdens,  adjustment  costs 
and 
costs 
enforcement 
imposed  by  the  directive  to 
all  stakeholders  along  the 
value chain? 

Quantitative  assessment  of  the  cost  and  the 
administrative  burden  placed  on  competent 
authorities, notifying bodies, market surveillance 
and economic operators. Qualitative assessment 
of 
importers,  distributors, 
consignees, consumers, environment and cultural 
organisations, NGOs). 

the  costs  on 

83 

 
 
EFF-02  How  affordable  are 
regulatory/ 
costs 
stakeholders? 

the 
administrative 
all 
by 

borne 

•  What are the likely causes of change (Drivers) of 

administrative, adjustment and enforcement costs by 
stakeholder type and country 

Procedures  and  obligations  introduced  by  the 
Directive are achieved at a reasonable cost  

Economic operators 
•  Cost per unit (economic operators) (difference in current share 

of costs to the Baseline) 

•  Share of regulatory cost in total production (current share 

comparison with the Baseline). 

•  Share of regulatory cost in average yearly turnover (current 

share comparison with the Baseline) 

•  Public 

consultation 
•  Targeted survey 
•  Cost interviews 

•  Targeted survey 
•  Public 

consultation 

•  Targeted survey 
•  Cost templates 
and interviews 

•  Targeted survey 
•  Cost templates 
and interviews 

•  Share of survey respondents who express a strong increase to 

•  Public 

strong decrease of costs since the Baseline. 

Administrators 
•  Number of staff (FTEs)  

•  Number of personnel engaged in control and inspection. 

•  Number of personnel engaged in reporting obligations.  

•  Average labour cost  

84 

consultation 
•  Targeted survey 
•  Cost templates 
and interviews 

•  Targeted survey 
•  Cost templates 
and interviews  

•  Targeted survey 
•  Cost templates 
and interviews  

•  Targeted survey 
•  Cost templates 
and interviews 

•  Targeted survey 
•  Cost templates 
and interviews  

 
EFF-03  What aspects of the measures 
are  the  most  inefficient  in 
terms  of  resources  that  are 
mobilised  by  stakeholders 
during the different phases of 
the process? 

Quantitative  assessment  based  on  the  break-
down  of  administrative  costs,  adjustment  costs 
namely related to Product conformity assessment 
procedure and Product traceability and labelling 
and 
enforcement 
Qualitative assessment of the above categories 

costs 

of 

•  Targeted survey 
•  Cost templates 
and interviews  

•  Targeted survey 
•  Cost templates 
and interviews  

•  Targeted survey 
•  Cost templates 
and interviews  

•  Targeted survey 
•  Public 

consultation 
•  Cost templates 
and interviews  

•  Frequency of inspections per year 

•  Total cost per year  

•  Total cost per FTE 

Economic operators 

•  Average share of (particular sub-categories of) administrative 

costs in total regulatory costs (three year average) compared to 
the baseline 

•  Average share of (particular sub-categories of) adjustment 

costs in total regulatory costs (three year average) compared to 
the baseline  

•  Share of regulatory cost in total production cost compared to 

the baseline 

•  Share of regulatory cost in average yearly turnover  compared 

to the baseline  
Administrative costs 
•  Total cost per FTE compared to the baseline  

•  Total cost of reporting obligations compared to the baseline  

All 
•  Share of survey respondents who characterise the aspects of 

measures as highly inefficient to highly efficient compared to 
the baseline  

EFF-
04.1  

What  are  the  main  benefits 
for  stakeholders  and  civil 

Measures  had  economic  effects  on  intra-EU 
flows  and  Increased  competitiveness  of  EU 

•  Trend in the production value and turnover of the EU industry 

for the products covered by the Directive  

•  Desk research  
•  Interviews 

85 

 
 
society  that  derive  from  the 
directive? 

companies 
The  effects  evolved  over 
implementation of the measures 

time  since 

•  Trend in the number and size of companies active in the sectors 

the 

covered by the Directive 

•  Trend in volume and value of intra-EU flows of products 

covered by the Directive 

•  Trend in volume and value of extra-EU flows of products 

covered by the Directive 

•  Trend in the proportion of sales that EU businesses derive from 

national, intra-EU or extra-EU trade 

•  Trend in the share of the EU industry in the total value of the 

market for the products covered by the Directive 

•  Share of stakeholders with positive opinion on the  effects of 
the Directive on the strengthening of the Single Market and 
potential areas for improvement 

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Desk research  
Interviews 

•  Desk research  
•  Interviews 

•  Desk research  
•  Interviews 

•  Public 

consultation 

•  Targeted 

stakeholder 
consultation 

EFF-
04.1 bis 

What  are  the  main  benefits 
for  stakeholders  and  civil 
society  that  derive  from  the 
directive? 

Measures  had benefits  in  terms  of  safety  in  the 
industry  and  for  consumers.  Measures  had 
benefits in terms of public security. Measures had 
benefits in terms of environment 

•  Trend in number of accidents (injuries and safety issues)  

•  Public 

consultation 
•  Targeted survey 
•  Desk research, 
data from 
accident 
reporting 

•  Number and types of infringements of national rules requiring 

•  Public 

compliance with essential safety requirements 

consultation 
•  Targeted survey 
•  ICSMS 

•  Share of stakeholders with positive opinion on the level of 

•  Public 

protection in terms of health & safety, security and 
environment ensured by the current enforcement practices 

consultation 
•  Targeted survey 

86 

 
•  Trend in the number of security-related incidents and illicit 
activities concerning the products covered by the Directive  

•  Share of stakeholders with positive opinion on the effects 

brought by the Directive in terms of overall public security 

•  Desk research 
•  Public 

consultation 
•  Targeted survey 

•  Share of stakeholders with positive opinion on the effects 

•  Public 

brought by the pyrotechnic Directive in terms of environmental 
risk protection 

consultation 
•  Targeted survey 

REL-
01 

To  what  extent  do 
the 
objectives  of  the  Directive 
correspond to the needs? 

Degree  of  alignment  between  stakeholders’ 
perception of the needs and the objectives of the 
Directive.  The  objectives  are;  i)  achieving  free 
movement of articles in the Internal Market, ii) 
protecting human health and safety; iii) ensuring 
high level of public security and iv) considering 
environmental aspects. The alignment considers 
past, present and future needs.  

•  List of potential health & safety, security and environmental 

risks linked to pyrotechnics 

•  Level of coverage of potential risks by the measures included 

in the Directive 

•  Type of industrial accidents (and other accidents?) and health 
and safety issues involving products covered by the Directive 
(in the EU and outside) 

•  Type of cases of illicit activities linked to the products covered 

by the Directive (in the EU and outside) 

•  Type of environmental accidents linked to the products covered 

by the Directive 

•  Examples of products covered by the Directive that do not 

meet the essential safety requirements 

•  Main differences in the measures adopted by MS to implement 

common EU requirements 

87 

•  Desk research 
•  Interviews 

•  Interviews 
•  Targeted survey 
•  Public 

consultation 
•  Desk research 

•  Desk research 
•  Interviews 
•  ICSMS 
•  Safety Gate  

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 
•  ICSMS 

•  Desk research 
•  Interviews 

 
 
 
 
•  Type of restrictions going beyond the minimum requirements 

adopted by MSs for health and safety reasons  

•  Stakeholders’ opinion on the continuous need for protection in 
terms of health & safety, security and environment and the 
existence of potential uncovered risks 

•  List of main technological, scientific, and social developments 

relevant to pyrotechnics 

•  Level of coverage of the main developments by adaptations 

mechanisms foreseen by the Directive 

•  Examples of cases where Member States found that a product 
in compliance with the Directive presented a health & safety, 
security and/or environmental risk  

•  Desk research 
•  Interviews 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews  

•  Examples of cases where MSs identified shortcomings in the 

harmonised standards used to prove the conformity to essential 
safety requirement 

•  Desk research 
•  Interviews 

•  Type of restrictions going beyond the minimum requirements 

adopted by MSs for health and safety reasons  

•  Examples of good practices adopted nationally (besides EU 

requirements) to adequately follow technological, and 
scientific and social developments  

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Stakeholders’ opinion on the extent to which existing 

adaptation mechanisms allow to keep up with and adequately 
address technological, social and scientific developments 

•  Desk research 
•  Interviews 

•  List of pyrotechnics covered by the Directive 

•  Health & safety, security and environmental risks per type of 

product 

•  Desk research 

•  Desk research 
•  Interviews 

REL-
02 

To  what  extent  are  there 
adaptation  mechanisms 
in 
place 
follow 
to 
technological,  and  scientific 
and social developments? 

to 

all 

The  essential  safety  requirement  set  by  the 
Directive adequately protect the health and safety 
of  persons,  property  and  the  environment  in 
pyrotechnics.  
types 
relation 
The  harmonised  standards  used  to  demonstrate 
the 
safety 
requirements  ensure  an  adequate  protection  of 
the health and safety of persons, property and the 
environment. 
The Directive addresses new emerging trends. 

conformity 

essential 

the 

of 

to 

REL-
03 

To what extent is the current 
scope  of  application  of  the 
Directive adequate  and clear 
for  the  attainment  of  the 
objectives? 

Degree  of  alignment  between  stakeholders’ 
perception  on  the  clarity  of  the  scope  of  the 
Directive; coverage in terms  of products covered 
and  exempted;  stakeholders  role  within  their 
value chain.  

88 

 
 
 
•  Type of requests for clarifications sent by MSs to the 
Commission in relation to the scope of the Directive 

•  Examples of cases where products were wrongly categorised 

•  New products whose categorisation (within or without the 

scope of the Directive) appears not clear 

•  Stakeholders’ opinion on the clarity of the scope of application 

and definitions of the Directive 

REL-
04 

Which gaps exist (e.g. health 
&  safety,  security,  and/or 
environmental concerns)? 

The  relevance  of  the  Directive  to  address 
uncovered  health  &  safety,  security,  and/or 
environmental  concerns  in  terms  of  measures, 
definitions, scope 

•  Indicators listed in the previous questions 

•  Stakeholders’ opinion on the main gaps (if any) in terms of 

measures, definitions and scope of the Directive 

COH-
01 

Is there any issue of internal 
coherence  of  the  measures 
(i.e.,  between  the  various 
components 
the 
measures)?  

of 

Clarity  and  comprehensibility,  consistency  of 
terminology,  
logical structure and organization, legal certainty, 
objectives  and  policy  goals 
in 
provisions.  

reflected 

•  Clear and unambiguous language in provisions 

•  Avoidance of overly technical language 

•  Desk research 

•  Desk research 
•  Interviews 
•  Targeted survey 

•  Desk research 
•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Desk research 
•  Interviews 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Targeted survey 
•  Desk research  

•  Consistent use of terms and definitions throughout the document 

•  Interviews 

89 

 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research  

•  Specification of roles and responsibilities of involved parties 

•  Clear articulation of the objectives and policy goals 

•  Provisions directly linked to the achievement of objectives and 

policy goals. 

•  Adequate coverage of all relevant aspects of the objectives and 

policy goals  

•  Complaints from stakeholders related to internal coherence (e.g. 
complexity/  lack  of  clarity/lack  of  consistency)  to  the  EC 
Commission or via the survey and Open Public consultation 

•  No internal contradiction or overlaps 

90 

 
 
 
 
 
 
 
COH-
02 

there 

overlaps 

Are 
or 
complementarities  between 
the  measures  and  any  other 
Community  action  having 
similar objectives 

the  measures, 

Overlaps  between 
mechanism 
non- 
alignment 
provisions/objectives, synergies  

in 
and 

In-built 
place,  
contradictory 

•  Degree of alignment with other measures (high, medium, low)  

•  Synergies leading to positive impacts or with limited effects.  

•  Impacts of overlaps (e.g., administrative burden, cost on 
companies, legal uncertainties due to double regulation) 

•  Impact of in-built mechanisms (derogations, exemptions, legal 

references) to avoid overlaps  

•  Impact of non-alignment and contradictory 

provisions/objectives (e.g. administrative burden, legal clarity, 
barrier to achieve broader EU objectives) 

COH-
03 

there  any 

Are 
issues  of 
coherence,  alignment  with 
international laws?  

Non- 
alignment 
provisions/objectives 

and 

contradictory 

•  Degree of alignment with international measures (high, 

medium, low) 

•  Impact of non-alignment and contradictory 

provisions/objectives with international measures (e.g., non-
compliance) 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 
•  Desk research.  

•  Interviews 
•  Targeted survey 
•  Desk research 

•  Interviews 
•  Targeted survey 
•  Desk research 

•  Interviews 
•  Targeted survey 
•  Desk research 

•  Interviews 
•  Targeted survey 
•  Desk research 

•  Interviews 
•  Targeted survey 
•  Desk research 

•  Interviews 
•  Targeted survey 
•  Desk research 

EUAD-
01 

What  is  the  additional  value 
resulting 
the  EU 
from 
intervention compared to the 

Comparison (in relation to several indicators and 
descriptors)  between  the  situation  at  national 
level in relevant sectors before the introduction 

•  Trend in the production value and turnover of the EU industry 

for the products covered by the Directive  

•  Desk research 
•  Interviews 

91 

 
 
 
 
 
 
situation  in  which  Member 
State  would  act  at  national 
level? 

of  the  Directive  and  after  the  implementation, 
assessing the added value of the EU intervention.  

•  Trend in the number and size of companies active in the sectors 

covered by the Directive 

•  Desk research 
•  Interviews 

•  Trend in volume and value of intra-EU flows of products 

covered by the Directive 

•  Trend in volume and value of extra-EU flows of products 

covered by the Directive 

•  Trend in the number of incidents and infringements concerning 

the products falling under the scope of the two Directive. 

•  Types of measures in place before the entry into force of the 

Directive 

•  Stakeholders’ opinion on the added value brough by the 

Directive in relation to the current levels of health & safety, 
security, market and environment protection   

EUAD-
02 

To  what  extent  the  issues 
addressed  by  the  measures 
require a continuation of the 
EU action? 

The scale of the issues initially addressed by the 
Directive (or of their potential impacts on other 
MSs) requires a continuation of the EU action. 

•  Level of harmonization of national measures implementing the 

Directive 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Desk research 
•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Main differences in the rules and measures adopted nationally 

•  Desk research 

to implement the Directive  

•  Examples and geographical scope of cases of non-compliance  

•  Examples and geographical scope of cases of illicit use of 

products covered by the Directive 

•  Desk research 
•  Interviews 
•  ICSMS 

•  Desk research 
•  Interviews 

92 

 
 
 
 
EUAD-
03 

be 

What  would 
the 
consequence  of  stopping  or 
withdrawing the measures on 
pyrotechnics? 

Without  the  Directive  pyrotechnics  may  be 
subject  to  different  rules  and  restrictions  in 
different  MSs  thus  raising  health  &  safety, 
security and environmental risks and competition 
distortions among Economic operators. EU-wide 
rules  and  coordination  at  the  EU  level  is 
necessary  to  ensure  synergies  in  terms  of 
information-exchanges, controls, investigations.  
Measure adopted to implement the directive have 
brought  substantial  changes  in  the  national 
context that will likely remain unchanged. 

•  Stakeholders’ opinion on the need for EU action to address 

current issues 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

•  Types of measures in force before the introduction of the 

•  Desk research 

Directive 

•  Requirements and rules stemming from relevant EU and 

•  Desk research 

international law and policies (besides the Directive under 
investigation) 

•  Main technological, scientific and social developments 

relevant to pyrotechnics 

•  Type and scale of the changes occurred at the national level to 
Implement the Directive (eg. new institutions, changes in roles 
and responsibilities, new operational systems and procedures) 

•  Stakeholders’ opinion on the consequences of withdrawing the 

Directive 

•  Desk research 
•  Interviews 

•  Desk research 
•  Interviews 

•  Interviews 
•  Public 

consultation 
•  Targeted survey 

93 

 
 
 
 
 
 
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND TABLE ON SIMPLIFICATION AND BURDEN REDUCTION 

Table 1. Overview of costs and benefits identified in the evaluation194 

Citizens/Consumers  

Businesses 

Administrations 

Other… 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Administrative costs 

Draw up EU declaration of 
conformity 

Recurrent  N/A 

N/A 

Draw up the technical 
documentation referred to in 
Annex II 

Lodge application for 
Conformity Assessment (e.g. 
Module B, Module C2, Module 
D, Module E, Module F, 
Module G). 

Recurrent  N/A 

N/A 

N/A 

N/A 

Recurrent  

EUR 10 979 per 
year, per 
company 

EUR 23 153 per 
year, per 
company 

EUR 3 274 per 
year, per 
company 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

194  Cost data in this table is based on cost templates and related interviews, as reported in European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation 
(Directive 2013/29/EU, Commission Implementing Directive 2014/58/EU, and Directive 2014/28/EU, Commission Implementing Directive 2008/43/EC and Commission Decision 
2004/388/EC), Final Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025. 

94 

 
 
 
 
 
                        
 
 
Collect documentation related to 
carrying out conformity 
assessment procedure 

Recurrent 

N/A 

N/A 

Keep the technical 
documentation and the EU 
declaration of conformity for 10 
years after the pyrotechnic 
article has been placed on the 
market 

Inform national authorities of 
pyrotechnic articles that may 
represent a risk 

Recurrent 

Recurrent 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Ensure pyrotechnic articles are 
labelled according to articles 10 
(Fireworks and Theatrical 
pyrotechnics) or article 11 
(pyrotechnics for vehicles 
labelling and supply of safety 
data sheets to professional 
users) 

Ensure pyrotechnic articles are 
accompanied by instructions 
and safety information in the 
language of the consumer/user 

Administrative actions to ensure 
traceability, labelling 
pyrotechnic articles with the 
registration number assigned by 
the notified body 

Keep records of the registration 
numbers of the pyrotechnic 
articles 

Recurrent 

Recurrent  N/A 

N/A 

Recurrent  N/A 

N/A 

Recurrent  N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufactures 

N/A 

N/A 

N/A 

N/A 

Importers 

EUR 6 756 per 
year, per 
company 

EUR 537 per 
year, per 
company 

EUR 992 per 
year, per 
company 

EUR 11 755 per 
year, per 
company 

EUR 5 983 per 
year, per 
company 

EUR 3 785 per 
year, per 
company 

EUR 2 563 per 
year, per 
company 

95 

 
 
 
 
 
 
 
 
 
 
Recurrent  N/A 

N/A 

Recurrent  N/A 

N/A 

N/A 

N/A 

Recurrent 

EUR 1 869 per 
year, per 
company 

EUR 623 per 
year, per 
company 

EUR 660 per 
year, per 
company 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Recurrent  N/A 

N/A 

N/A 

N/A 

Recurrent  N/A 

N/A 

N/A 

N/A 

EUR 1 813 
per year, per 
MSA 

Market 
surveillance 
authorities 

EUR 2 489 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

EUR 587 per 
year, per NB 

Notified bodies  N/A 

N/A 

N/A 

N/A 

Recurrent 

Collaborate with market 
surveillance authorities to 
identify suppliers and 
distributors of their pyrotechnic 
articles. 

Investigate, and, if necessary, 
keep a register of non-
conforming pyrotechnic articles 
and pyrotechnic article recalls, 
upon duly justified requests of 
competent authorities 

Administrative actions to 
withdraw or recall not 
conformant articles 

Resources used to 
recordkeeping of the Market 
Surveillance Activities 

Resources used to documentary 
and evidence collection, and of 
information exchange with the 
EC on an annual basis of the 
Market Surveillance Activities 

Resources used to lodge 
application for (re)notification 
to the notifying authority of the 
Member State in which it is 
established. Includes costs of 
collecting document evidence of 
conformity assessment 
activities, the conformity 
assessment module or modules 
and the pyrotechnic article or 
articles for which that body 

96 

 
 
 
 
 
 
claims to be competent and 
accreditation certificates. 

Resources used to 
(re)accreditation procedure, 
(when applicable) issued by 
national accreditation body the 
competence and capacity of the 
conformity assessment body 

Resources used to ensure 
independence from notifying 
authorities, notified bodies, and 
so on (e.g ethics committee) 

Resources used to communicate 
the non-conformance of 
pyrotechnic articles to 
competent authorities (incl. 
third country authorities) 

Inform other notified bodies of 
negative or positive results 
(upon request) 

Designing, test, and categorise 
products according to their 
intended use (fireworks, 
theatrical, other), level of hazard 
(including their noise level) 

Manufacturing pyrotechnic 
articles according to the 
essential safety requirements set 
out in annex I 

Carry out a conformity 
assessment procedure 

Recurrent  N/A 

N/A 

EUR 10 062 per 
year, per NB 

Notified bodies  N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Recurrent 

EUR 880 per 
year, per NB 

Notified bodies  N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

EUR 587 per 
year, per NB 

Recurrent 

Notified bodies  N/A 

N/A 

N/A 

N/A 

 Recurrent 

N/A 

N/A 

EUR 587 per 
year, per NB 

Notified bodies  N/A 

N/A 

N/A 

N/A 

Adjustment costs 

N/A 

N/A 

 Recurrent 

N/A 

N/A 

 Recurrent 

Recurrent 

N/A 

N/A 

EUR 44 644 per 
year, per 
company 

EUR 56 960 per 
year, per 
company 

EUR 3 471 per 
year, per 
company 

97 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
Affix CE marking 

Recurrent 

N/A 

N/A 

Account for changes in 
pyrotechnic article design, 
characteristic, harmonised 
standards, or technical 
specifications to remain 
conformant to the Directive 

Operational actions to ensure 
traceability, labelling 
pyrotechnic articles with the 
registration number assigned by 
the notified body, and according 
to the uniform system 
determined by the Commission 

Upon a duly justified request of 
the competent authorities: 
• Carry out sample testing of 
pyrotechnic articles already 
made available on the market 
• Investigate, and, if necessary, 
keep a register of: 
     −Complaints 
     −Non-conforming articles 

Corrective operational actions to 
withdraw or recall non-
conformant articles 

Resources used to personnel 
familiarisation/training on 
pyrotechnics essential safety 
requirements set out in Annex I 

Recurrent 

N/A 

N/A 

Recurrent 

N/A 

N/A 

Recurrent 

N/A 

N/A 

Recurrent 

N/A 

N/A 

Recurrent 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Manufacturers 

N/A 

N/A 

N/A 

N/A 

Importers 

Distributors 

Notified bodies 

EUR 10 736 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

EUR 18 677 per 
year, per 
company 

EUR 8 816 per 
year, per 
company 

EUR 12 551 per 
year, per 
company 

EUR 9 874 per 
year, per 
company 

EUR 1 133 per 
year, per 
company 

EUR 9 150 per 
year, per NB 

98 

 
 
 
 
 
 
 
 
 
 
 
Recurrent 

N/A 

N/A 

N/A 

N/A 

EUR 3 656 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

Resources used to ensure that 
personnel responsible for 
carrying out the conformity 
assessment and risk assessment 
tasks are informed of the 
relevant standardisation and 
harmonisation activities 

Coordination and expert group 
meetings 

Recurrent 

N/A 

Liability insurance (if private)  Recurrent 

N/A 

N/A 

N/A 

EUR 10 942 per 
year, per NB 

EUR 2 100 per 
year, per NB 

Notified bodies  N/A 

Notified bodies  N/A 

Enforcement costs 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

EUR  5 866 
per year, per 
MSA 

Market 
surveillance 
authorities 

EUR 12 939 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

EUR 13 977 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

Participation of coordination 
groups meetings 

Resources used to communicate 
the non-conformance of 
pyrotechnic articles to economic 
operators, notified bodies, the 
EC, and competent authorities 
(incl. third country authorities) 

Resources used to performance 
of appropriate checks and risk 
assessments on the 
characteristics of the 
pyrotechnic article by means of 
documentary checks and, where 
appropriate, physical and 
laboratory checks (excludes 
outsourced laboratory tests) 
based on adequate samples 
(includes visit to premises of 
economic operators for 
sampling purposes) 

99 

 
 
 
 
 
 
 
Resources used to monitor 
accidents and harms in the 
Member State caused by 
pyrotechnic articles 

Resources used to take 
corrective actions when the 
Economic Operator does not 
(incl. Resources used to 
destruction/decommissioning/di
sposal) 

Resources used to map non-
conformant pyrotechnic articles’ 
supply chain 

Resources used to verification 
of reports and certificates 
presented by economic 
operators, notified bodies, etc. 
regarding the conformity 
assessment activities 

Resources used to alert users of 
pyrotechnic articles that may 
pose a risk of injury or damage 

Resources used to outsourced 
laboratory tests for conformity 
assessment and risk assessments 

‘Other’ enforcement costs 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Recurrent 

N/A 

N/A 

N/A 

N/A 

 Recurrent 

N/A 

N/A 

N/A 

N/A 

EUR 1 849 
per year, per 
MSA 

Market 
surveillance 
authorities 

EUR 3 780 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

N/A 

N/A 

EUR 762 per 
year, per 
MSA 

Market 
surveillance 
authorities 

EUR 9 527 
per year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

N/A 

N/A 

EUR 3 626 
per year, per 
MSA 

Market 
surveillance 
authorities 

EUR  762 
per year, per 
MSA 

Market 
surveillance 
authorities 

EUR 762 per 
year, per 
MSA 

Market 
surveillance 
authorities 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Sustained level of safety195 

Recurrent 

Not 
quantifiable 

The Directive 
seems to have 
contributed to a 

195 Interviews with market surveillance authorities. See also section 4.1.1.b). 

Direct benefits 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

100 

 
 
 
 
 
 
 
 
 
Positive impact on public 
security196 

Not 
quantifiable 

Recurrent 

relatively stable 
safety level of 
the pyrotechnic 
articles on the 
market. This 
benefits not only 
users but also 
society at large. 

Despite the 
persistent 
problems, 
stakeholders 
mostly 
acknowledge the 
Directive’s 
positive impact 
on public 
security. 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Improved market access197 

N/A 

N/A 

Recurrent 

Not quantifiable  Companies and 
notified bodies 
report improved 
access to the 
single market 
thanks to the 
harmonisation of 
rules and the CE 
marking system. 
They have also 
experienced 
advantages on 
non-EU markets, 
as CE marking is 
widely accepted 

N/A 

N/A 

N/A 

N/A 

196 In the Targeted survey, 34.78% (24 out of 69) of respondents indicated that this benefit was achieved to a high extent, 14.49% (10 out of 69)  selected ‘to a moderate extent’, and 

11.59% (8 out of 69)  ‘to a very high extent’. 

197 Cost assessment interviews with industry stakeholders and notified bodies. 

101 

 
 
internationally as 
complying with 
other markets’ 
safety 
requirements 

N/A 

N/A 

Not quantifiable  The Directive has 

Reduction of familiarisation 
costs198 

Recurrent 

Cost savings in conformity 
assessment activities199 

N/A 

N/A 

Recurrent 

198 Cost assessment interviews. 
199 Cost assessment interviews. 

resulted in an 
approximation of 
Member States’ 
legislation. 
Largely identical 
definitions and 
similar 
requirements 
have reduced 
businesses’ costs 
for 
familiarisation 
with legislation. 

Not quantifiable  The introduction 
of the horizontal 
NLF provisions 
for conformity 
assessments has 
brought cost 
savings for 
companies 
thanks to 
harmonised 
procedures. 

102 

N/A 

N/A 

Not 
quantifiable 

The Directive 
has resulted in 
an 
approximation 
of Member 
States’ 
legislation. 
Largely 
identical 
definitions and 
similar 
requirements 
have reduced 
businesses’ 
costs for 
familiarisation 
with 
legislation. 

N/A 

N/A 

N/A 

N/A 

 
 
Coordination and information 
exchange200 

Recurrent 

N/A 

N/A 

Not quantifiable  The Directive has 

facilitated 
coordination and 
information 
exchange 
between market 
surveillance 
authorities, 
notified bodies 
and the 
Commission. 
Fora like the 
Forum of 
Notified Bodies 
and the 
Administrative 
Cooperation 
Group (AdCo) 
provide an 
opportunity to 
exchange on 
issues 
encountered 
during market 
surveillance and 
conformity 
assessments, to 
find solutions 
and to agree on 
common 
approaches. 

N/A 

N/A 

Not 
quantifiable 

The Directive 
has facilitated 
coordination 
and 
information 
exchange 
between 
market 
surveillance 
authorities, 
notified bodies 
and the 
Commission. 
Fora like the 
Forum of  
Notified 
Bodies and the 
Administrative 
Cooperation 
Group (AdCo) 
provide an 
opportunity to 
exchange on 
issues 
encountered 
during market 
surveillance 
and conformity 
assessments, to 
find solutions 
and to agree on 
common 
approaches. 

Enhanced traceability of 
pyrotechnic articles201 

Recurrent 

Not quantifiable  The traceability 

system for 

Not 
quantifiable 

The 
traceability 

N/A 

N/A 

200 Cost assessment interviews. 
201 Cost assessment interviews. 

103 

 
 
 
 
pyrotechnic 
articles, which 
requires the 
labelling of 
pyrotechnic 
articles with 
registration 
numbers issued 
by the notified 
body that carried 
out the 
conformity 
assessment, 
although not 
allowing item-
level tracking, 
has enhanced the 
possibility to 
track pyrotechnic 
articles 
throughout the 
supply chain. 

system for 
pyrotechnic 
articles, which 
requires the 
labelling of 
pyrotechnic 
articles with 
registration 
numbers issued 
by the notified 
body that 
carried out the 
conformity 
assessment, 
although not 
allowing item-
level tracking, 
has enhanced 
the possibility 
to track 
pyrotechnic 
articles 
throughout the 
supply chain. 

104 

 
 
 
 
TABLE 2:  Simplification and burden reduction (savings already achieved)  
Report any simplification, burden reduction and cost savings achieved already by the intervention evaluated, including the points of comparison/ where available (e.g. REFIT savings 
predicted in the IA or other sources).  

Citizens/Consumers/Workers 

Businesses 

Administrations 

[Other…] _ specify 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative  Comment  

Quantitative  Comment 

N/A 

N/A 

Not 
quantifiable 

The Directive 
has resulted in 
an 
approximation 
of Member 
States’ 
legislation. 
Largely 
identical 
definitions and 
similar 
requirements 
have reduced 
businesses’ 
costs for 
familiarisation 
with 
legislation. 

N/A 

N/A 

N/A 

N/A 

Indirect compliance cost savings  

Recurrent 

N/A 

N/A 

Not quantifiable  The Directive has 

Reduction of 
familiarisation 
cost 

Recurrent 

N/A 

N/A 

Cost savings in 
conformity 
assessment 
activities 

resulted in an 
approximation of 
Member States’ 
legislation. 
Largely identical 
definitions and 
similar 
requirements 
have reduced 
businesses’ costs 
for 
familiarisation 
with legislation. 

Not quantifiable  The introduction 
of the horizontal 
NLF provisions 
for conformity 
assessments has 
brought cost 
savings for 
companies 
thanks to 
harmonised 
procedures. 

105 

 
               
 
Coordination and 
information 
exchange 

Recurrent 

N/A 

N/A 

Coordination 
and information 
exchange 

N/A 

N/A 

Coordination 
an 
information 
exchange 

The Directive has 
facilitated 
coordination and 
information 
exchange 
between market 
surveillance 
authorities, 
notified bodies 
and the 
Commission. 
Fora like the 
Forum of  
Notified Bodies 
and the 
Administrative 
Cooperation 
Group (AdCo) 
provide an 
opportunity to 
exchange on 
issues 
encountered 
during market 
surveillance and 
conformity 
assessments, to 
find solutions 
and to agree on 
common 
approaches. 

The Directive 
has facilitated 
coordination 
and 
information 
exchange 
between 
market 
surveillance 
authorities, 
notified bodies 
and the 
Commission. 
Fora like the 
Forum of  
Notified 
Bodies and the 
Administrative 
Cooperation 
Group (AdCo) 
provide an 
opportunity to 
exchange on 
issues 
encountered 
during market 
surveillance 
and conformity 
assessments, to 
find solutions 
and to agree on 
common 
approaches. 

106 

 
 
 
 
 
 
PART II: II Potential simplification and burden reduction (savings) 
Identify further potential simplification and savings that could be achieved with a view to make the initiative more effective and efficient without prejudice to its policy objectives202. 

Citizens/Consumers/Workers 

Businesses 

Administrations 

[Other…] _ specify 

Quantitative  

Comment 

Quantitative  

Comment 

Quantitative 

Comment   Quantitative 

Comment 

Simplification of labelling and record-keeping requirements 

Recurrent 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Not 
quantifiable 

Labelling and CE 
marking as well as 
record-keeping 
create significant 
costs for 
businesses. Further 
digitalisation could 
be explored.  

Remove accident reporting obligation 

Recurrent 

N/A 

N/A 

N/A 

N/A 

Not 
quantifiable 

N/A 

N/A 

The obligation 
for competent 
authorities to 
report accident 
data introduced 
via 
Commission 
Implementing 
Decision (EU) 
2023/1096203 
has not 
produced the 
expected 
reliable and 
comparable 

202 This assessment is without prejudice to a possible future Impact Assessment. 
203 Commission Implementing Decision (EU) 2023/1096 of 2 June 2023 laying down rules for the application of Directive 2013/29/EU of the European Parliament and of the Council as 
(OJ  L  146,  6.6.2023,  p.  24,  ELI: 
related 

regular  collection  and  updating  of  data  on  accidents 

the  use  of  pyrotechnic  articles 

to 

regards 
http://data.europa.eu/eli/dec_impl/2023/1096/oj).  

the 

107 

 
 
 
data on 
accidents with 
pyrotechnic 
articles. 
Removing this 
obligation 
would reduce 
burden for 
national 
authorities and 
the 
Commission. 

108 

 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

1.  Introduction  

This synopsis report provides a concise summary of the key findings and insights gathered 
during  the  evaluation  of  the  Pyrotechnics  Directive  (2013/29/EU  and  Implementing 
Directive  2014/58/EU).  The  report  supports  the  European  Commission  by  presenting 
evidence,  analysis,  and  conclusions  relevant  for  assessing  the  Directive’s  relevance, 
effectiveness,  coherence,  efficiency,  and  EU  added  value.  Engaging  a  diverse  range  of 
stakeholders,  this  report  incorporates  perspectives  from  national  authorities,  conformity 
assessment bodies, industry representatives, NGOs, logistics operators, and environmental 
and cultural organisations across all 27 EU Member States. 

2.  Consultation strategy 

2.1. Outline of the strategy  

The  consultations  conducted  as  part  of  the  evaluation  of  the  Pyrotechnics  legislation 
(Directive 2013/29/EU and Implementing Directive 2014/58/EU) were designed to assess 
whether the current EU rules remain effective, relevant, and fit for purpose in achieving 
their objective and addressing the needs and problems, including emerging challenges, in 
the sector. Their overall aim was to evaluate the success of the legislation in achieving its 
objectives, identify gaps or areas for improvement, and assess whether it remains aligned 
with evolving societal, technological, and environmental priorities. To achieve this, four 
types of consultations were carried out – a public consultation204, a call for evidence, an 
online survey and interviews. A summary of insights gathered during discussions at the 
validation workshop was also incorporated into this synopsis report. 

Each  consultation  tool  played  a  complementary  role  in  ensuring  a  comprehensive 
evaluation  of  the  Pyrotechnics  Directive.  The  public  consultation  provided  a  broad 
platform to gather diverse views from the general public and stakeholders, offering a wide 
range of perspectives on the legislation. The targeted online survey focused on collecting 
detailed,  structured  input,  enabling  a  more  technical  and  nuanced  assessment  of  the 
Directive’s  impact  and  challenges.  Meanwhile,  the  interviews  allowed  for  in-depth 
discussions with key stakeholders, providing qualitative insights and context that enriched 
the understanding of sector-specific issues. Together, these tools ensured a balanced mix 
of broad, focused, and detailed inputs to support a robust evaluation. 

204 Using European Commission’s dedicated Better Regulation online platform ‘Have Your Say’, Link 

109 

 
 
 
 
 
2.2. Overview of the consultation activities carried out 

Public consultation 

The public consultation (PC) was conducted from 8th of April to 1st of July 2024 on the 
European Commission’s dedicated Better Regulation online platform ‘Have Your Say’205.  

The consultation received 37 responses in total, with the stakeholder breakdown provided 
in  Table  8.  From  the  respondents,  11  (29.7%)  stakeholders  were  from  Germany,  11 
(29.7%) from Austria, 5 (13.5%) from the Netherlands, 3 (8.1%) from Belgium, 2 (5.4%) 
from  Czechia,  1  (2.7%)  from  Slovenia,  1  (2.7%)  from  Liechtenstein,  1  (2.7%)  from 
Sweden, 1 (2.7%) from Italy and 1 (2.7%) from France. 

Targeted survey 

The survey, launched on the 15th of March 2024, and closing on the 31st of May, consisted 
of 110 questions and was distributed online to key stakeholders in the field of European 
pyrotechnics.  Multipliers  were  employed  to  further  disseminate  the  survey  and  weekly 
reminders were sent to survey respondents who had not yet answered. 

The survey received 80 complete responses, representing various stakeholder groups. The 
largest  number  of  responses  has  been  provided  by  the  national  market  surveillance 
authorities  (23.8%)  and  industry  importers  and  national  enforcement  authorities  (15% 
each). The distribution of all responses is detailed in Table 8. Respondents came from 25 
Member  States.  Notably,  Spain  (14%)  and  the  Netherlands  (11%)  accounted  for  the 
majority of stakeholder responses.  

Interviews 

The  interview  process  engaged  a  diverse  range  of  stakeholders,  yielding  48  interviews 
from  key groups  involved in  the regulation,  oversight,  and use of pyrotechnics articles. 
National  enforcement  authorities  and  market  surveillance  authorities  accounted  for  the 
largest share, contributing for 23 interviews (47.9%). 10 interviews (20.8%) were carried 
out  with  individual  industry  stakeholders  and  an  additional  3  interviews  (6.3%)  with 
industry  organisations.  Notified  bodies  provided  7  responses  (14.6),  while  notifying 
authorities and the European Commission each contributed 2 responses (4.2%). Finally, 
one interview was conducted with an accreditation body (2.1%). This broad representation 
ensured  a  comprehensive  collection  of  insights,  capturing  the  views  of  both  public 
authorities and private entities affected by the Directive.  

It is important to note that in many instances, the same stakeholder was engaged multiple 
times  throughout  the  evaluation  process,  including  during  the  scoping  phase,  survey 
piloting, study phase, and for contributing to the cost templates. 

205

  European  Commission,  Have  Your  Say  ‘EU  rules  on  pyrotechnic  articles  –  evaluation’,  Link.  The 

summary report can be found here. 

110 

 
 
 
Table 8: Consulted stakeholders by consultation activity 

Public consultation 

Consulted stakeholders 

EU Citizens 

Public authorities 

Companies/businesses 

Business associations 

NGOs 

Other 

Non-EU citizen 

Targeted survey 

Consulted Stakeholders 

National market surveillance 

Industry - importer 

National enforcement Authority 

Industry: manufacturer (SME) 

Industry organisation  

Notified body 

Industry manufacturer (large enterprise) 

Notifying authority 

Accreditation body 

NGO - Animal welfare 

Regional authority 

Interviews 

Consulted stakeholders 

Industry organisations 

Accreditation body 

National enforcement Authority & market 
surveillance authority 

Responses 

11 (29.7%) 

10 (27%) 

6 (16.2%) 

4 (10.8%) 

3 (8.1%) 

2 (5.4%) 

1 (2.7%) 

Responses 

19 (23.8%) 

12 (15 %) 

12 (15 %) 

9 (11.3%) 

8 (10%) 

7 (8.8%) 

7 (8.8%) 

3 (3.8%) 

1 (1.3%) 

1 (1.3%) 

1 (1.3%) 

Responses 

3 (6.3%) 

1 (2.1%) 

23 (47.9%) 

111 

 
 
European Commission 

Industry 

Notified body 

Notifying authority 

Source: Technopolis Group 

2 (4.2%) 

10 (20.8%) 

7 (14.6%) 

2 (4.2%) 

2.3. Methodology used to process data  

The  data  and  information  collected  across  the  consultations  were  analysed  using  a 
combination of methods to ensure a balanced and robust evaluation. Responses from the 
public consultation and the targeted online survey were subjected to statistical analysis to 
identify trends and patterns, while qualitative insights from interviews provided context 
and depth to the findings. Triangulation was used to cross-validate information across the 
different consultation tools, as well as sources such as desk research, ensuring consistency 
and reliability. 

Due  to  limited  information  from  desk  research,  the  evaluation  depended  heavily  on 
stakeholder consultations. While valuable, stakeholder responses often reflected specific 
national  contexts  or  organisational  perspectives, 
introducing  subjective  biases. 
Additionally,  respondents  frequently  provided  fragmented  or  partial  views,  with 
occasional  inconsistencies  influenced  by  differences  in  stakeholder  type,  geographic 
location,  and  organisational  role.  These  factors  complicated  the  synthesis  of  a  unified 
perspective. To mitigate these limitations, the evaluation employed data triangulation, 
integrating insights from desk research (where available), public consultations, interviews, 
and survey data to enhance the robustness and reliability of findings. 

Low  response  rates,  particularly  for  the  online  survey  and  public  consultation,  further 
constrained  the  evaluation.  This  was  largely  attributed  to  respondent  fatigue,  as 
stakeholders  faced  multiple  concurrent  data  collection  exercises,  including  surveys  and 
interviews. Stakeholders reported difficulties allocating sufficient time to participate fully, 
particularly in the public consultation. A significant proportion of responses (sometimes 
exceeding  40%  for  specific  questions)  indicated  ‘Does  not  know/prefer  not  to  answer’. 
This trend was particularly evident in questions addressing: environmental protection, the 
situation  prior  to  the  implementation  of  the  Directive  and  Factual  information,  such  as 
accident  frequency  and  health and safety  issues. Stakeholders cited reasons such as the 
absence  of  aggregated  data  or  tracking  systems  in  their  Member  States.  Questions 
requiring a long-term perspective, such as trends since the adoption of the first Directive 
in  2007  (2007/23/EEC),  were  particularly  challenging  for  respondents  without  relevant 
historical insights. The prevalence of ‘Do not know’ responses was observed in the survey 
for pyrotechnics. This outcome was partly influenced by the evaluation team's inclusive 
approach,  which  encouraged  a  broad  range  of  stakeholder  types  to  respond.  While  this 
enhanced response rates, it also  led to instances  where respondents  lacked the requisite 
knowledge or experience to address certain questions. 

112 

 
Interviews  provided  qualitative  insights  but  were  subject  to  inherent  limitations. 
Stakeholders  often  shared  fragmented  or  incomplete  perspectives,  with  some  feedback 
proving contradictory. These inconsistencies were influenced by variations in stakeholder 
type, geographic location, and organisational role. Additionally, much of the information 
gathered  was  anecdotal  and  sometimes  conflicting,  making  it  challenging  to  derive 
definitive conclusions. As a result, the findings were constrained by the subjective nature 
of the evidence. 

To account for these limitations, the evaluation team implemented mitigation strategies, 
such  as  data  triangulation,  to  strengthen  the  robustness  of  the  findings.  However,  the 
reliance  on  subjective  stakeholder  input,  low  response  rates  especially  for  the  public 
consultation, and challenges in qualitative data interpretation must be taken into account 
when assessing the conclusions of this evaluation.  

3.   Results of the consultation activities 

2.1. Call for evidence 

The call for evidence for the Pyrotechnics Directive (Directive 2013/29/EU) received input 
from  23  stakeholders,  including  public  authorities,  companies,  NGOs,  business 
associations, and EU citizens. Feedback came from several Member States, with notable 
contributions  from  Germany,  France,  Portugal,  Croatia,  Norway,  and  the  Netherlands, 
highlighting a diverse range of perspectives. The key themes emerging from the feedback 
were  safety  and  risk  management,  security  and  misuse  prevention,  environmental 
consideration, market surveillance and regulatory consistency, and animal welfare. 

Safety and risk management 

Concerns  about  safety  dominated  the  feedback,  particularly  in  relation  to  the  current 
minimum safety distances specified in the Directive. Business stakeholders questioned the 
adequacy of the one-meter safety distance for F1 category fireworks, highlighting that it 
does not sufficiently account for practical risks such as wind or improper usage. Several 
contributors  recommended  increasing  these  distances,  suggesting  a  minimum  of  two 
meters for the spread of effects and three meters for user safety. Additionally, there were 
concerns about the lack of harmonisation in product labelling and design norms. Business 
associations  noted  that  inconsistent  or  unclear  labelling  can  mislead  users,  potentially 
increasing  safety  risks during use. Public authorities also  highlighted the importance of 
clear labelling and accurate safety instructions to ensure compliance and minimise risks 
during both professional and recreational use. 

Security and misuse prevention 

Security  concerns  focused  on  the  misuse  of  pyrotechnic  articles,  particularly  high-risk 
items  like  F4  fireworks.  Public  authorities  emphasised  the  recurring  issue  of  illegal 
trafficking, with fireworks often being used for criminal purposes such as vandalism or 
attacks  on  law  enforcement.  The  accessibility  of  such  products  through  online  sales 
platforms  was  a  prominent  concern,  with  stakeholders  urging  a  harmonised  EU-level 
approach to monitor and regulate digital markets. Suggestions included stricter online sales 

113 

 
restrictions,  traceability  mechanisms  for  high-risk  categories,  and  stronger  penalties  for 
illegal  transactions.  Moreover,  feedback  stressed  the  need  to  ensure  that  P1  and  P2 
technical pyrotechnics are only used for their intended purposes and not misclassified or 
mis-advertised as recreational fireworks. 

Environmental considerations 

The environmental impact of fireworks was raised by multiple stakeholders. NGOs and 
citizens  highlighted  the  use  of  harmful  materials  such  as  heavy  metals  and  plastics  in 
fireworks,  which  contribute  to  pollution  and  pose  long-term  risks  to  ecosystems. 
Stakeholders  called  for  updated  standards  that  promote  environmentally  sustainable 
alternatives,  including  the  use  of  biodegradable  materials.  Noise  pollution  was  another 
significant concern, with many contributors noting its detrimental effects on communities, 
particularly  vulnerable  groups  such  as  children,  the  elderly,  and  individuals  with 
sensitivities  to  loud  noises.  Recommendations  included  promoting  quieter  fireworks  or 
alternatives that reduce noise without compromising visual effects. 

Market surveillance and regulatory consistency 

Market surveillance and regulatory alignment emerged as critical areas for improvement. 
Public  authorities  pointed  out  deficiencies  in  the  CE  marking  system,  with  several 
instances of certified pyrotechnic articles failing to meet the required safety and quality 
standards.  Such  inconsistencies  undermine  consumer  trust  and  create  potential  safety 
hazards. Stakeholders emphasised the need for harmonised safety audits and compliance 
checks across Member States to ensure consistent enforcement. Business stakeholders also 
highlighted  inefficiencies  in  market  surveillance  mechanisms,  including  disparities  in 
technical  capacity  and  resource  allocation  among  national  authorities.  Suggestions 
included establishing an EU-level oversight body to coordinate enforcement efforts and 
ensure uniform application of the directive. 

Animal welfare 

Animal welfare concerns featured prominently in the feedback, particularly from NGOs 
and  public  authorities.  Fireworks  were  reported  to  cause  severe  stress  and  behavioural 
changes in animals, including fear, anxiety, and long-term health issues. Scientific studies 
cited by stakeholders indicated that a significant proportion of domestic animals, such as 
dogs and cats, exhibit adverse reactions to fireworks, with some requiring weeks or months 
to  recover  from  exposure.  Stakeholders  called  for  the  inclusion  of  animal  welfare  as  a 
legitimate  reason  for  restricting  or  prohibiting  fireworks  under  the  directive,  alongside 
existing  considerations  such  as  public  safety  and  environmental  protection.  Specific 
proposals  included  amending  the  Directive  to  allow  Member  States  to  implement 
restrictions based on animal welfare concerns. 

114 

 
 
 
2.2.Targeted survey  

Relevance 

Relevance of objectives 

A  majority  of  respondents,  particularly  national  enforcement  authorities,  consider  the 
Directive's objectives as highly (39%) or moderately (37.5%) relevant206. In particular, it 
is perceived as relevant to a high or very high extent for removing trade barriers within the 
EU market and addressing safety concerns by 39% of respondents207. However, a large 
share of industry representatives considered the Directive only to a moderate (55%) or low 
(10%) extent relevant,  thereby diverging  from  the general  perception of respondents208. 
The harmonisation  of  rules on the sales of goods across Member States209  and the free 
movement of goods210 are aspects for which the Directive is considered relevant by a large 
share  (73%  and  61%,  respectively)  of  stakeholders.  Moreover,  a  significant  share  of 
stakeholders  (40%), excluding however most industry actors211 rated the persistent issue 
of non-compliant or dangerous products on the market as highly or very highly relevant212. 
There  is  no  consensus  on  whether  the  still  to  a  certain  extent  heterogeneous  safety 
requirements in the Member States are a relevant issue213. 

206  ‘To  a  moderate  extent  was  answered  in  question  107  by  67%  (n=4)  of  6  respondents  for  industry 
organisations; 67% (n=2) of 3 respondents for importers; 50% (n=6) of 12 respondents for SMEs; and 
50% (n=1) of 2 respondents for large manufacturers. 

207  39% (n=21) of 54 respondents answered, ‘To a high extent’ or ‘To a very high extent’, and 22% (n=12) 

‘To a moderate extent’ in relation to the relevance of this problem in question 102. 

208 35% (n=19) of 54 respondents answered, ‘Not at all’ or ‘To a low extent’ in relation to the relevance of 
this problem in question 102, with 40% (n=22) replying ‘To a moderate extent’ or ‘To a high extent’. 
209 39% (n=21) of 54 respondents answered, ‘To a high extent’ or ‘To a very high extent’, and 22% (n=12) 

‘To a moderate extent” in relation to the relevance of this problem in question 102 

210 35% (n=19) of 54 respondents answered, ‘Not at all’ or ‘To a low extent’ in relation to the relevance of 
this problem in question 102, with 40% (n=22) replying ‘To a moderate extent’ or ‘To a high extent’. 
211 100% of large manufacturing entities (n=2) and importers (n=3) responding to question 102 consider that 
the problem has a low relevance. The same view is shared by 50% (n=3) of the 6 respondents for industry 
organisations and, to a lesser extent, 25% (n=3) of the 12 respondents for SMEs manufacturers. 
212  40% (n=22) of 54 respondents answered ‘To a high extent’ or ‘To a very high extent’ in relation to the 

relevance of this problem. 

213 35% (n=19) of 54 respondents answered, ‘Not at all’ or ‘To a low extent’ in relation to the relevance of 
this problem in question 102, with 40% (n=22) replying ‘To a moderate extent” or ‘To a high extent’. 

115 

 
 
Figure 22: Stakeholders' views on relevance of problems 

In your opinion, to what extent are the problems listed below still 
relevant and continue to require action at EU level?

Rules governing the sale of goods differ
considerably across EU countries

4%

30%

30%

13%

20%

Presence of non-compliant or dangerous
products on the market

Heterogeneous safety requirements hamper
the protection of human health and safety

and the protection of users and…
Differing practices in the designation of
conformity assessment bodies by national
authorities
Differences between national laws cause
barriers to trade within the Union, thus
impeding the free movement of goods…

28%

20%

22%

19%

11%

15%

20%

20%

20%

4%

20%

6%

7%

24%

15%

9%

39%

7%

13%

22%

28%

11%

19%

0%

20%

40%

60%

80% 100%

Not at all

To a low extent

To a moderate extent

To a high extent

To a very high extent

Do not know/prefer not say

 N=54, Source: Technopolis Group, based on targeted survey results 

Adoption of more stringent national rules 

Despite its relevance, many Member States have implemented stricter national rules than 
those outlined in the Directive214. Survey results reveal that these stricter rules commonly 
involve sales restrictions, additional requirements for licensing, or increased oversight of 
certain categories of products215. 

Scope of the Directive 

The scope of the Directive, including its categorisation framework under Article 6(1)216, is 
perceived as generally fit-for-purpose217. 55% of stakeholders, express satisfaction with its 
ability to accommodate newly emerging products218. However, concerns persist regarding 
potential misclassification of products, whether accidental or deliberate. For instance, the 

214 55% (n=21) of 30 respondents answered ‘Yes’ to ‘Adoption of measures or requirements in addition to 

those already included in the Directive’ in question 10. 

215 Based on responses to open question 11. 
216 55% (n=39) of 71 respondents answered ‘To a high extent’ or ‘To a very high extent’ in question 37. 
217  72%  (n=53)  of 74  respondents  provided  a  score  equal or  higher  to  4  in  a  relevance 5-point  scale  in 
question 35. 17% (n=13) of the respondents provided a score of 3, while scores of 2 and 1 were selected 
by11% (n=8) of the participants respectively. 

218 ‘To a very high extent’ or ‘To a high extent’ was answered in question 37 by 62% (n=5) of 8 respondents 
for industry organisations; 50% (n=3) of 6 respondents for importers; 64% (n=9) of 14 respondents for 
SMEs; and 100% (n=3) of large manufacturers. 

116 

 
 
 
wide nature of the P1 and P2 categories of pyrotechnic articles outlined in Article 6 of the 
Pyrotechnics Directive might lead to a misclassification of articles by the manufacturer219. 

Emerging product coverage 

Stakeholders highlighted gaps in the Directive's scope concerning specific products, such 
as sparkle machines and pyrotechnic effect-mimicking equipment, which are currently not 
covered  by  the  Directive  but  are  considered  to  pose  risks  comparable  to  regulated 
pyrotechnic articles. Conversely, heavy flash bangers, currently in scope, were suggested 
for  exclusion  or  explicit  prohibition,  given  their  similarities  to  explosives  and  their 
associated risks220. 

Need for further harmonisation 

Misclassification  and  overlapping  or  grey  areas  regulations  between  the  Pyrotechnics 
Directive  and  other  legislation,  such  as  the  Marine  Equipment  Directive,  were  cited  as 
areas needing further harmonisation221. Stakeholders advocate for measures to ensure that 
dangerous goods do not fall into the hands of unqualified users222. 

Coherence 

External coherence 

Of the 57 respondents, 30% believe there is coherence between the Pyrotechnics Directive 
and other EU legislation to a moderate extent, while 23% rate it to a high extent. However, 
20% of participants chose ‘Do not know/prefer not to say’, reflecting some uncertainty or 
lack of opinion. Polarised views emerge as 13% rate coherence to a very high extent and 
another 13% to a low extent. 

Certain stakeholders expressed concerns that the Directive’s strong focus on facilitating 
the  free  movement  of  pyrotechnic  articles  contrasts  with  stricter  controls  under  other 
directives, such as the Civil Explosives Directive and the Firearms Directive. They called 
for more alignment with the Civil Explosives Directive security measures for at least the 
most  dangerous  pyrotechnic  articles  (e.g.  alignment  with  traceability  provisions),  to 
mitigate risks associated with the misuse of pyrotechnic articles. They flagged that they 
face classification issues with certain products that could also fall under other EU legal 
regimes such as they Civil Explosive Directive or the Marine Equipment Directive.   

Internal coherence 

The internal coherence of the Pyrotechnics Directive is widely viewed as unproblematic. 
Among  58  respondents,  the  vast  majority  found  no  significant  issues,  with  only  one 

219 More information available at: https://ec.europa.eu/docsroom/documents/45126  
220 This paragraph reports views shared by the 10 respondents to question 36. 
221 2 responders out of 10 mentioned maritime equipment in question 36. 
222This reports views shared by the 10 respondents to question 36. 

117 

 
 
respondent identifying low coherence. The single concern raised related to unclear text or 
inconsistent terminology, but no specific examples were provided. 

Figure 23: Stakeholders' views on internal coherence 

How would you qualify the internal coherence of the Directive? Explanatory 
note:Internal coherence means consistency and logical harmony of the 
directive's provisions, clauses, and requirements within itself

50%

36%

12%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Low internal coherence

Medium internal coherence

High internal coherence

Do not know/Prefer not say

N = 58, Source: Technopolis Group, based on targeted survey results 

Effectiveness 

National transposition 

Thirteen  Member  States  introduced  additional  measures  such  as  age  restrictions, 
prohibitions  on  certain  fireworks  categories,  and  custom  authorisation  procedures. 
Conversely,  nine  Member  States  imposed  restrictions  on  the  free  movement  of  goods, 
leveraging the directive’s optional provisions223. The need for enhanced safety and public 
protection is considered by respondents as the main factor behind the implementation of 
more  stringent  or  additional  rules  than  those  indicated  in  the  Directive224.  This  was 
followed by the fact of preventing illicit trade and misuse, selected by around one-fourth 
of the respondents. 

223 In total, stakeholders from 21 Member States (n=30) have answered the survey question on whether their 
Member State has adopted more stringent rules than those indicated in the Directive or added additional 
requirements. 

224 Stakeholders were asked to provide a rating on a scale of 1-5 for the relative importance of each factor. 
Out of the stakeholders who answered (n=19), ‘Enhanced Safety and Public Protection’ received a rating 
of 5 from 68.42% of respondents, with only 5.26% rating it as 1. 

118 

 
  
 
Figure 24: Stakeholders' views on reasons for more stringent or additional national requirements 

What factors or considerations drove your Member State to 
implement more stringent or additional requirements beyond the 
minimum requirements specified in the directive?

Environmental Considerations

37%

11%

21%

32%

Public Confidence and Perception

21%

11%

21%

21%

5%

21%

Other

5%

95%

Cultural or Historical Considerations

Addressing Unique National Risks

32%

32%

21%

16%

5%

5%

5%

16%

16%

26%

26%

Preventing Illicit Trade and Misuse

26%

16%

16%

16%

21%

5%

Enhanced Safety and Public Protection

5%

5%

21%

68%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

1

2

3

4

5

Do not know/Prefer not say

N = 19, Source: Technopolis Group, based on targeted survey results 

Differences in national rules appear to have mixed impacts. Stakeholders were divided on 
whether  and  how  (negatively  or  positively)  variations  affected  public  security, 
competitiveness, and intra-EU flows, with no clear consensus on their overall impact. 

Figure 25: Stakeholders' views on effect of variations in national rules 

How do you think that current variations in national rules affect:

Public security

13%

18%

21%

15%

13%

21%

Intra EU flows of pyrotechnic articles

15%

22%

31%

6%

4%

22%

Health and safety in the industry

12%

29%

19%

6%

31%

Competitiveness of EU companies

7%

25%

32%

7%

3%

25%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Very negatively

Negatively

Unchanged/neutral

Positively

Very positively

Do not know/prefer not say

N = 68, Source: Technopolis Group, based on targeted survey results 

Socio-economic context 

While  the  majority  of  stakeholders  did  not  know  or  preferred  not  to  give  an  answer  as 
regards the number of accidents and health issues involving pyrotechnics, 22% indicated 
that it has largely remained unchanged, 16% reported a decrease and 7% an increase in 
accidents225. However, stakeholders emphasised challenges such as illicit transportation, 

225 From the remaining stakeholders, 6.85% (5 out of 73) responded ‘Increased’, 16.44% (12 out of 37) 

responded ‘Decreased’, and 54.79% (40 out of 70) responded ‘Do not know/prefer not to say’.  

119 

 
  
  
 
storage issues, and the rise of online sales that evade regulatory oversight. Stakeholders 
highlighted the need for stricter controls over high-risk categories like F4 items, enhanced 
traceability  measures,  and  improved  collaboration  on  cross-border  challenges  like 
smuggling and terrorism. 

When  asked  about  the  prevalence  of  illicit  activities  related  to  pyrotechnic  articles, 
approximately  a  quarter  of  respondents  (out  of  the  68  that  responded  to  this  survey 
question) believe that instance of illicit activities had increased since the implementation 
of  both  the  initial  Directive  2007/23/EC  and  the  Directive  2013/29/EU.  Conversely, 
approximately a fifth of respondents felt the number of illicit activities remained constant.  

Figure 26: Stakeholders' views on trends in illicit activities 

How has the number of cases of illicit activities linked to products covered by the 
Directive evolved since:

The entry into application in 2015 of the current
Directive 2013/29/EU

6%

19%

22%

13%

37%

The adoption of the first Directive 2007/23/EC

9%

18%

26%

3%

43%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%

Strongly decreased

Decreased

Remained unchanged

Increased

Strongly increased

Do not know/Prefer not say

N = 68, Source: Technopolis Group, based on targeted survey results 

Furthermore, according to all stakeholder types, the most prevalent types of illicit activities 
include black market sales/illegal trade (including through online shopping), misuse for 
criminal activities and diversion of the product (e.g., use by non-professionals).   

120 

 
  
Figure 27: Stakeholders' views on most prevalent types of illicit activities since 2015 

Since the entry into force of the Directive in 2015, can you specify the most 
prevalent types of illicit activities encountered, choosing from the following options?
Please grade from a scale of 1-5 the relative importance of each (1 being the lowest 
and 5

Black market sales/illegal trade (including
through online shopping)

7%

6%

7%

28%

29%

22%

Misuse for criminal activities

15%

13%

9%

13%

18%

32%

Diversion of the product (ex: use by non
professionals

10%

9%

12%

25%

15%

29%

Terrorism and organised crime

32%

1%

7%

13%

4%

41%

Illicit manufacturing

26%

21%

13%

4%

1%

34%

Other

93%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

1

2

3

4

5

Do not know/Prefer not say

N = 68, Source: Technopolis Group, based on targeted survey results 

Implementation of provisions 

Most  Member  States  combine  physical  inspections  and  documentary  checks  for 
compliance.  Challenges  include  managing  cross-border  sales,  e-commerce  growth,  and 
complex  supply  chains.  While  traceability  systems  have  improved  since  the  directive's 
implementation, respondents highlighted difficulties in accessing data on product origins 
and testing certifications. Satisfaction with digital tools like ICSMS and Safety Gate was 
moderate 
information  sharing  remains  an  area  for 
improvement226. 

to  high,  but  cross-border 

Efficiency 

The  efficiency  analysis  examines  the  compliance  costs  and  obligations  stemming  from 
Directive  2013/29/EU  across  various  stakeholder  groups,  focusing  on  cost  drivers  and 
efficiency indicators.  

226 The  effectiveness of information sharing with competent authorities from another Member State was 
rated at 2 out of 5 by 23.1% (15 out of 65), at 4 out of 5 by 20% (13 out of 65), 3 out of 5 by 19.9% (11 
out of 65), at 1 out of 5 by 9.2% (6 out of 65) and at 5 out of 5 by 1.5% (1 out of 65) respondents. In 
comparison, information sharing with competent authorities of the same Member State was rated  at 4 
out of 5 by 26.1% (17 out of 65), at 3 out of 5 by 24.6% (16 out of 65) and at 5 out of 5 by 21.5% (14 
out of 65). 

121 

 
 
 
 
 
 
Yearly compliance costs227 

Yearly compliance costs vary significantly between stakeholders.228 

•  SMEs incur average costs of EUR 31 250, ranging from less than EUR 25 000 to 

EUR 100 000, while the single large company faces EUR 375 000. 

•  Notified bodies have the highest costs, averaging EUR 687 500, reflecting their 
specialised  roles  in  conformity  assessments  which  is  the  core  of  their  economic 
activity229. 

•  Market  surveillance  authorities  average  EUR  314 286,  and  enforcement 
authorities EUR 370 833, with labour costs constituting 65% and 54% of their total 
costs, respectively. 

Relative size of compliance costs230 

Compliance costs for industry represent, on average, 17% of production costs and 13% of 
turnover  per  pyrotechnic  article.  Large  companies  experience  higher  compliance  costs 
relative  to  production  costs  (30%)  than  SMEs  (18%),  indicating  differing  compliance 
strategies231. However, turnover-based costs  are comparable  for SMEs (16%) and large 
companies (15%). 

Adjustment costs232 

•  Large  manufacturers:  Focused  30%  of  costs  on  designing  and  manufacturing 
products to meet the Directive's requirements, with additional significant expenses 
allocated to equipment acquisition (40%) and smaller portions to product testing 
(15%), conformity assessments (5%), and corrective actions (10%). 

227 N = 21 (MSA = 3; SME = 10; notifying authority = 1; national enforcement authority = 3; NB = 2; LE = 

1; importer = 1). 

228  Respondents  were  asked  to  estimate  the  yearly  average  cost  attributable  to  the  directive  (including 
administrative costs, Operational and investment costs). The estimate is made with a simple average for 
each  type  of  stakeholder.  For  the  case  of  the  lower  bound  (Less  than  EUR  25 000),  the  value  per 
stakeholder is EUR 12 500. For the upper bound, the value per stakeholder was EUR 1 m. The middle 
value was given to each stakeholder for the rest of the ranges. 

229 The large variability in reported costs by notified bodies, to the extent of reporting up to EUR 1 m, may 
be explained by three factors: 1) the scale of the notified body’s operations, which is substantially larger 
in  some  countries;  2)  the  number  of  obligations  the  notified  body  has  (compliance  with  multiple 
Directives, national legislations, additional activities related to the sector such as training, certification, 
education, etc.; and 3) the ownership/governance structure of the  notified body (see figure 15 above), 
for instance, being a university, national institute, or military institution, may have an impact in the cost 
structure of the notified body. The analysis of the costs exclusively allocated to compliance with the 
Directive is part of another analysis, i.e.,  cost efficiency analysis, which will be included in the final 
report. 

230 N= 12 respondents (2 importers, 1 large company, 9 SMEs). 
231 SMEs, for instance, do not prioritise testing before conformity assessment processes but rely on notified 

bodies for knowledge at the design and manufacturing stages. 

232 N=8 (1 large company, 7 SMEs). 

122 

 
 
•  SMEs: Allocated the largest portion of costs (36%) to designing and manufacturing 
products,  followed  by  product  testing  (23%),  equipment  acquisition  (27%), 
conformity assessments (15%), and corrective actions (15%). 

Administrative costs233 

•  Manufacturers  (large):  Key costs are divided between handling paperwork for 
lodging  applications  (20%),  recordkeeping  and  technical  documentation  (22%), 
and ensuring correct labelling and markings (29%). Smaller shares are attributed to 
information sharing (10%) and product testing (10%). 

•  SMEs:  The  largest  share  of  costs  (33%)  goes  to  ensuring  correct  labelling  and 
markings,  followed  by  handling  paperwork  (28%)  and  recordkeeping  (20%). 
Information sharing (10%) and product testing (10%) are less significant. 

•  Importers: Predominantly invest in ensuring correct labelling and markings (40%) 
and handling paperwork (25%), with lower costs allocated to recordkeeping (18%), 
information sharing (10%), and product testing (7%). 

•  Notified  bodies:  Almost  entirely  focused  (97%)  on  conducting  conformity 
assessments,  with  marginal  contributions  (1-2%)  to  recordkeeping,  information 
sharing, and other administrative tasks. 

Regulatory charges 

Licensing  and  authorisation  fees  are  key  one-off  costs  for  SMEs,  while notified  bodies 
primarily incur administrative fees.  

Conformity assessment costs 

Costs for conformity assessments vary widely: 

•  Module B (EU-type examination) ranges from EUR 950 to EUR 60 000. 

•  Combined module conformity assessments, i.e. Module B plus Module C2, D or 
E, range from EUR 2 150 to EUR 190 000, with typical costs around EUR 5 000. 
Module G costs approx. EUR 2 700 and Module H costs approx. EUR 5 500 

Performance Indicators 

Market surveillance authorities conduct the highest number of inspections (47 per year), 
followed  by  enforcement  authorities  (38).  Labour  costs  per  intervention  average  EUR 
5 267 for enforcement authorities and EUR 4 858 for market surveillance authorities. Total 
intervention costs are EUR 9 759 and EUR 7 447, respectively.   

233 N=12 (importers=2, SMEs = 8, large companies=1, notified bodies=1). 

123 

 
 
 
EU added value 

The  Pyrotechnics  Directive  has  been  attributed  significant  EU-added  value  by 
stakeholders participating in  the survey. Stakeholders believe to  a very high  extent that 
those main benefits of harmonising different national rules, has ensured reduction of the 
trade  barriers  and  costs  in  the  single  Market  (15%),  higher  compliance  of  pyrotechnics 
available on the EU market with the requirements (13%), and harmonising rules on the 
making available and supervision of pyrotechnics (10%)234.  

Figure 28: Stakeholders' views on achievement of benefits from harmonising national rules 

To what extent were the following main benefits of harmonising 
different national rules on pyrotechnic articles achieved in your 
Member State

Improved traceability of sales and
transactions

10%

4%

37%

19%

4%

25%

High level of trust and confidence of users

3%

46%

16%

4%

28%

Cross-border coordination related to the
supply, trade, and use of pyrotechnics

19%

7%

19%

21%

4%

29%

High level of protection of public security

10%

7%

19%

32%

7%

24%

High level of protection of human health
and safety

Harmonizing rules on the making available
and supervision of pyrotechnics

6%

3%

22%

40%

7%

22%

7%

6%

26%

25%

10%

25%

Higher compliance of pyrotechnics
available on the EU market with the…

7%

3%

16%

34%

13%

26%

Reduction of the trade barriers and costs in
the Single Market

7%

6%

24%

13%

15%

35%

0%

20%

40%

60%

80% 100%

No extent

To a low extent

To a moderate extent

To a high extent

To a very high extent

Do not know/prefer not say

N = 68, Source: Technopolis Group, based on targeted survey results 

However,  when  asked  to  what  extent  they  believe  that  there  should  be  further 
harmonisation of national laws, 67% of respondents across all stakeholder groups selected 
‘to a very high extent’, ‘to a high extent’ and ‘to a moderate extent’. Stakeholders noted 
areas where further harmonisation is needed, particularly in the classification and labelling 

234 In question 17 (total respondents=68), ‘To a high extent’ and ‘To a very high extent’ in relation to the 
achievement of benefits was answered by: 47% (n=32) for High level of protection of human health and 
safety;  47%  (n=32)  for  higher  compliance  of  pyrotechnics  available  on  the  EU  market  with  the 
requirements;  40%  (n=27)  for  high  level  of  protection  of  public  security,  and  35%  (n=24)  for 
harmonising rules on the making available and supervision of pyrotechnics. 

124 

 
  
 
of products, rules governing public use, and the prohibition of certain articles235. Clearer 
regulations ensuring that testing and CE mark evaluations are conducted within the EU 
were also suggested. 

Figure 29: Stakeholders’ views on need of further harmonisation of rules 

To what extent do you think there is the need to further harmonise rules to 
ensure the free movement of the goods within the scope of the Directive 
within the EU market and ensure high level of protection of health and safety 
and of the environment?

11%

14%

33%

22%

12%

8%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Not at all

To a low extent

To a moderate extent

To a high extent

To a very high extent

Do not know/prefer not say

N = 73, Source: Technopolis Group, based on targeted survey results 

Significant shares of stakeholders considered the following issues relevant for continued 
EU action: the presence of non-compliant and dangerous products, barriers to trade arising 
from  differing  national  rules,  and  inconsistencies  in  the  designation  of  conformity 
assessment bodies236.  

Concerns  were  expressed  over  the  potential  withdrawal  of  the  Directive,  which, 
according to many stakeholders would impact the economic conditions within the sector 
strongly  negatively  (44%)  or  moderately  negatively  (28%)237.  Stakeholders  believe  the 
withdrawal  would lead to  market  fragmentation,  increased illegal  trade, and heightened 
security  risks.  Disparities  in  national  regulations  would  hinder  trade  and  result  in  the 
proliferation of dangerous goods in the market.  

2.3. Interviews  

Relevance 

Stakeholders across all groups generally viewed the Pyrotechnics Directive as relevant, 
noting that its core objectives and scope continue to address current needs and challenges. 
However,  interviewees  highlighted  that  the  Directive,  designed  to  meet  the  market 

235 67% (n=49) of 73 respondents answered,  ‘to a very high extent’, ‘to a high extent’ or ‘to a moderate 

extent’ to question 41. 

236 48% (n=26) of 54 respondents answered,  ‘to a moderate extent’, ‘to a high extent’ or ‘to a very high 

extent’ in relation to the relevance of this problem in question 102. 

237  44%  (n=14)  of  32  respondents  answered,  ‘strongly  negative’  and  28%  (n=9)  of  them  answered 

‘moderately negative’ in question 39. 

125 

 
  
 
conditions and safety concerns of its time, faces challenges in adapting to new risks and 
products. For instance,  one notified body pointed out  a lag in the  adoption of updated 
harmonised  standards,  leading  to  regulatory  gaps.  This  was  echoed  by  a  market 
surveillance  authority,  which  noted  inconsistencies  in  how  notified  bodies  assess  the 
conformity of new pyrotechnic articles. 

Nevertheless,  not  all  stakeholders  reported  significant  issues.  A  national  market 
surveillance  authority  indicated  that  they  had  not  yet  encountered  challenges  linked  to 
emerging  trends,  and  a  notified  body  experienced  no  difficulties  in  categorising  new 
products under the current framework. 

Security concerns emerged  as an area considered not  sufficiently addressed under the 
Directive,  particularly  regarding  online  sales  and  unauthorised  access  to  pyrotechnic 
products. Interviewees, especially national market surveillance authorities, raised concerns 
about the increasing volume of online sales, which has made pyrotechnics more accessible 
to  the public and increased the prevalence of dangerous goods in  the market.  Differing 
practices across Member States (such as insufficient age verification for online purchases 
or check regarding ‘specialist knowledge’) exacerbate these risks. Estonia was cited as an 
example of good practice, implementing ID verification for online purchases, while Spain 
allows online sales with additional safeguards, such as requiring collection from authorised 
stores, i.e. excluding mail orders, and recording purchaser details. 

The misuse of P1 articles, especially at football events, was flagged as a widespread issue. 
National  market  surveillance  authorities  identified  such  events  as  the  most  common 
context for misuse, echoing findings from the survey and public consultation. 

Concerns  were  also  raised  about  F3  and  F4  pyrotechnics,  particularly  regarding 
traceability. A national market surveillance authority suggested that the framework used 
for civil explosives, which includes strict controls and detailed tracking, could serve as a 
model. Stakeholders emphasised the importance of digital tracking tools to improve safety 
and  oversight.  Three  national  market  surveillance  authorities  recommended  leveraging 
existing initiatives, such as the Pyro-pass used in the Benelux region, and expanding these 
tools across the EU to enhance traceability and reduce illegal trade. 

Coherence 

Stakeholders’  views  on  the  coherence  of  the  Pyrotechnics  Directive  with  other  EU 
legislation were mixed. Among the 57 interview participants, 30% indicated coherence to 
a  moderate  extent,  while  23%  believed  coherence  exists  to  a  high  extent.  Responses 
suggesting  either  a  high  or  low  level  of  coherence  were  evenly  split  at  13%.  Regional 
authorities and accreditation bodies were more likely to report moderate or very high levels 
of coherence, whereas other stakeholder groups provided no clear conclusions. 

Ambiguities  in  the  classification  of  pyrotechnic  articles  were  a  recurring  theme. 
Stakeholders noted inconsistent classification practices across Member States, with some 
categorising  certain  articles  as  pyrotechnics  and  others  as  ammunition.  Additionally, 
stakeholders flagged the absence of transition frameworks for products that evolve from 

126 

 
heavy  firecrackers  to  explosives,  which  has  contributed  to  misuse,  particularly  in  the 
Netherlands. 

Gaps in traceability and market transparency were also highlighted, particularly  for 
F4,  P1,  and  P2  articles.  The  absence  of  robust  track-and-trace  systems  was  seen  as  a 
significant  shortcoming.  To  address  this,  stakeholders  recommended  aligning  the 
Pyrotechnics  Directive  with  the  Civil  Explosives  Directive  to  enhance  traceability, 
security, and public safety. 

Effectiveness 

The interviews highlighted several areas where the Pyrotechnics Directive is perceived as 
falling short in effectively addressing key issues, particularly those related to the misuse, 
safety, and enforcement of pyrotechnic articles. 

Misuse and safety risks 

Interviewees,  particularly  market  surveillance  authorities  (MSAs)  and  enforcement 
authorities, indicated that the Directive inadequately addresses the misuse of pyrotechnic 
articles.  While  products  are  assessed  for  the  intended  use,  their  misuse—such  as  use 
outside their intended purpose or by individuals lacking the necessary knowledge—poses 
significant safety risks. These concerns are compounded by the perceived ease of acquiring 
and  distributing  pyrotechnics  across  the  EU,  enabled  by  free  circulation  and  informal 
networks.  To  mitigate  these  risks,  stakeholders  emphasised  the  need  for  enhanced 
traceability  mechanisms  to  monitor  the  origins  and  movement  of  pyrotechnic  products 
more effectively. 

Deliberate misclassification 

Market  surveillance  authorities,  enforcement  authorities,  and  notified  bodies  raised 
concerns  about  the  deliberate  misclassification  of  pyrotechnic  products  (e.g.,  F4  being 
labelled  as  P1).  This  practice  enables  manufacturers  to  circumvent  stricter  regulatory 
standards, undermining the safety framework. Interviewees suggested stricter penalties for 
deliberate  misclassification,  alongside  clearer  definitions  of  regulatory  categories,  to 
enhance compliance and ensure the integrity of the Directive. 

Public security and high-risk categories 

The Directive’s failure to address public security risks related to high-risk pyrotechnics, 
particularly category F4, was another area of concern. Some stakeholders recommended 
stricter controls on the movement of these items, while others suggested banning specific 
high-risk  pyrotechnics  to  mitigate  emerging  threats.  The  lack  of  unique  identifiers  for 
individual products within the traceability system was flagged as a critical gap, making it 
difficult  for  enforcement  agencies  to  track  non-compliant  articles  or  articles  used  for 
criminal purposes. Additionally, monitoring online trade remains a significant challenge, 
as customs and enforcement authorities face barriers in regulating these goods effectively. 

127 

 
 
Regulatory disparities and fragmentation 

Stakeholders noted that regulatory variability across EU Member States complicates cross-
border trade and enforcement. For instance, differences in how Member States regulate 
online  sales  of  pyrotechnics  allow  products  to  bypass  national  restrictions,  further 
fragmenting  the market.  Interviewees  recommended addressing these inconsistencies to 
create a more harmonised and unified regulatory framework across the EU. 

Conformity assessments and testing 

Concerns were  also  raised about  the reliability of conformity  assessments conducted in 
non-EU  countries.  Stakeholders  identified  insufficient  oversight  of  subcontractors 
performing these assessments as a critical issue. Subcontracting to third countries is linked 
to  the  limited  availability  of  suitable  testing  sites  within  the  EU.  One  MSA  suggested 
establishing  European  testing  centres  to  ensure  more  reliable  assessments  and  reduce 
dependence on third-country facilities. 

Environmental considerations 

The  Directive’s  lack  of  explicit  focus  on  environmental  concerns  was  noted  by 
stakeholders,  including  two  MSAs  and  one  notified  body.  They  recommended  that  the 
Directive include clear objectives addressing environmental impact, supported by stricter 
incorporating  environmental 
product  requirements 
considerations could align the Directive with broader EU sustainability goals and enhance 
its effectiveness in this area. 

to  minimise  harm.  Explicitly 

Efficiency 

It is important to note that the cost estimates derived from this analysis are findings from 
the cost templates, with the interviews being largely based on the cost templates. 

The  companies  that  participated  in  the  cost  interviews,  indicated    average  annual 
compliance costs of EUR 196 048 due to the Directive. For the industry, the cost interview 
data shows that the administrative and adjustment costs during the period (2015 – 2022) 
were on average 71.1% and 25.5% of the total compliance costs, respectively. The single 
large enterprise reported annual average administrative costs of EUR 220 350. The five 
SMEs have average annual administrative costs of EUR 16 023 and a range from EUR 
2 067 to EUR 49 140. As regards adjustment costs, the single large enterprise has annual 
average costs of EUR 126 735. The five SMEs have average annual adjustment costs of 
EUR 170 020 and a wide range from EUR 9 903 to EUR 485 078.238 

For  notified  bodies  that  participated  in  costs  interviews,  data  shows239  that  regulatory 
compliance  costs  on  average  per  year  were  EUR  34 893,  with  the  administrative  and 
adjustment costs during the period (2015 – 2022) were on average 36% and 64% of the 

238  N = 6 (SMEs = 5; LEs = 1). 
239 To note that the cost classification for notified bodies has been adjusted compared to the supporting study 

to reflect that conformity assessments are notified bodies‘ usual business. 

128 

 
 
total compliance costs, respectively. The average administrative cost was EUR 12 703per 
year. The average adjustment cost for notified bodies was EUR 22 192240.  

The  market  surveillance  authorities  that  participated  in  the  cost  interviews  indicated 
compliance costs of EUR 76 388 due to the Directive. For these authorities, enforcement 
costs (73.9%) naturally constitute the largest portion of their average yearly cost associated 
to  the  Directive,  adjustment  costs  (18.7%)  account  for  the  second  most,  followed  by 
administrative (4.6%). Hassle costs and enforcement costs are both at 1.3%241. 

According to the majority of interviewed stakeholders, the Directive delivered substantial 
benefits,  including  enhanced  safety  and  compliance  through  harmonised  rules  and 
improved  supply  chain  transparency.  For  both  notified  bodies  and  MSAs,  recurring 
benefits  included  cost  savings  in  conformity  assessments  and  streamlined  traceability. 
Businesses reported improved single-market access and a 7.5% increase in turnover from 
extra-EU markets due to compliance with EU regulations. 

EU added value 

Interviewees generally agreed that the Pyrotechnics Directive provides clear EU added 
value  by  fostering  harmonisation  across  Member  States  and  reducing  barriers  to  trade. 
Two  national  market  surveillance  authorities  expressed  concerns  that  withdrawing  the 
Directive could lead to negative outcomes, including diverging national rules, increased 
costs, and an influx of cheaper, potentially unsafe products from non-EU markets. 

However, one industry stakeholder suggested that the overall impact of withdrawal might 
be relatively neutral, as it would entail both advantages and disadvantages. Advantages 
could  include  faster  decision-making  at  the  national  level,  while  disadvantages  might 
involve increased trade barriers and a loss of harmonised safety standards within the EU. 

2.4. Public consultation  

Relevance 

The  public  consultation  results  demonstrate  that  the  Pyrotechnics  Directive  remains 
relevant  across  its  key  objectives.  Ensuring  the  protection  of  human  health  and 
consumer safety was relevant either ‘to a very large extent’ or ‘to a large extent’ by 59.4% 
of stakeholders242. A 100% (4 out of 4) of Business Associations responded that it is still 
relevant  ‘to  a  large  extent’.  Additionally,  50%  of  Companies/businesses  said  that  the 
objective is relevant ‘to a very large extent’ and 50% (3 out of 6) that it is still relevant ‘to 
a large extent’. 

240 N = 3. 
241 N = 3. 
242 32.4% (n=12) out of 37 respondents rated it as relevant ‘to a very large extent’ and 27% (n=10) out of 37 
respondents rated it relevant ‘to a large extent’. From the remaining stakeholders, 10.8% (4 out of 37) 
responded  ‘not  at  all’,  10.8%  (4  out  of  37)  responded  ‘to  a  moderate  extent’,  10.8%  (4  out  of  37) 
responded ‘to a limited extent’, and 8.1% (3 out of 37) responded ‘Do not know/prefer not to say’. 

129 

 
 
Regarding security concerns, 37.8%243 agreed that the Directive remains  relevant  ‘to a 
large extent’, while 21.6%244 believed it is still relevant ‘to a very large extent’. Concerns 
were also raised about varying national rules affecting the retail market and illegal cross-
border trade. Notably, a 100% (4 out of 4) of business associations responded that it is still 
relevant ‘to a large extent’.  

For the issue of ‘Online trade’, 51.4% of the consulted stakeholders responded that this 
concern should be further addressed in the future by the Directive, while 32.4% chose the 
‘Do not know/prefer not to say’ option245. Notably, 70%246 of public authorities responded 
that this concern should be further addressed in the future by the Directive.  

On  environmental  protection,  64.8%  of  stakeholders  found  the  Directive  relevant  to 
some extent, with 29.7%247 rating it ‘to a moderate extent’ and a combined 35.1% viewing 
it as relevant ‘to a large’ or ‘very large extent’248.  

For the classification of pyrotechnic articles (e.g., F1-4, T1-2, P1-2), 51.4% viewed this 
aspect of the Directive as relevant ‘to a very large extent’, while 18.9% rated it relevant ‘to 
a large extent’249. Notably, 83.3% of companies/businesses responded that the Directive is 
relevant ‘to a very large extent’, and 16.7% that it is relevant ‘to a large extent’. 

Coherence 

When  asked  about  the  coherence  of  the  Pyrotechnics  Directive  with  other  EU 
interventions, many respondents selected the ‘Do not know/prefer not to say’ option. For 
those  who  did  respond,  the  strongest  coherence  was  observed  with  the  EU  chemicals 
legislation  (REACH  and  CLP  Regulations)  and  the  Product  Liability  Directive,  with 
24.3% (9 out of 37)250 indicating high coherence. 

Effectiveness 

The  public  consultation  revealed  mixed  views  on  the  effectiveness  of  the  Pyrotechnics 
Directive  in  meeting  its  objectives.  According  to  the  public  consultation,  64.9%  of 
respondents indicated that pyrotechnic articles in the single market are safe, while 27% 

243 37.8% (n=14) out of 37 respondents. From the remaining stakeholders, 13.5% (5 out of 37) responded 
‘not at all’, 10.8% (4 out of 37) responded ‘to a limited extent’, 8.1% (3 out of 37) responded ‘to a 
moderate extent’ and 8.1% (3 out of 37) responded ‘Do not know/prefer not to say’. 

244 21.6% (n=8) out of 37 respondents. 
245 From the remaining stakeholders, 16.2% (6 out of 37) responded that ‘this concern is currently addressed 

by the Directive’.  

246 From the remaining responses, 30% (3 out of 10) responded ‘Do not know/prefer not to say’.  
247 29.7% (n=11) out of 37 respondents. 
248 18.9% (n=7) out of 37 respondents considered it relevant ‘to a large extent,’ and 16.2% (n=6) out of 37 

rated it relevant ‘to a very large extent’. 

249  51.4% (n=19) out of 37 respondents rated it relevant to  ‘to a very large extent’ and 18.9% (n=7) out of 
37 respondents rated relevant to a ‘large extent’. From the remaining stakeholders, 10.8% (4 out of 37) 
responded ‘to a moderate extent’, 5.4% (2 out of 37) responded ‘to a limited extent’, 5.4% (2 out of 37) 
responded ‘not at all’, and 10.8% (4 out of 37) responded ‘Do not know/prefer not to say’. 

250 24.3% (n=9) out of 37 respondents. 

130 

 
 
disagreed251. At the same time, 54.1%252 of stakeholders stated that the ‘Minimisation of 
unsafe  pyrotechnic  articles  on  the  market’  remains  a  concern  that  should  be  further 
addressed by the Directive. Similarly, ‘controlled access to pyrotechnics not intended for 
the  general  public  or  specific  age  groups’  was  identified  as  a  concern  by  51.4%253  of 
stakeholders who believe this issue warrants further attention. 

In  terms  of  environmental  issues,  48.7%254  of  stakeholders  agreed  that  the  Directive 
should address ‘greener and more sustainable chemical compositions of pyrotechnic 
articles  (including  compostability  and  plastic  pollution)’  in  the  future.  Meanwhile, 
35.1%255 felt this issue is currently addressed by the Directive. 

Addressing  public  security,  54.1%256  of  respondents  supported  the  need  for  stronger 
‘controls to prevent access to pyrotechnic articles by malicious actors’ in future revisions 
of the Directive. Notably, 83.3% of Companies/businesses responded that this concern is 
currently addressed by the Directive257. 

In  the  area  of  ‘health  and  safety’,  regarding  the  minimisation  of  presence  of  unsafe 
pyrotechnics articles on the market’, 54.1% of the stakeholders answered that this concern 
should be further addressed in the future by the Directive.258 However, 75% of Business 
associations and 83.3% of Companies responded that this concern is currently addressed 
by the Directive259.   

Regarding  the  controlled  access  to  pyrotechnics  not  intended  for  general  public  or  to 
specific age groups 51.4% of the stakeholders answered that this concern should be further 
addressed in the future by the Directive and 37.8% responded that this concern is currently 
addressed  by  the  Directive.260  Notably,  100%  (6  out  of  6)  of  companies/businesses 
responded that this concern is currently addressed by the Directive.   

On the topic of harmonising rules for making pyrotechnic articles available on the market, 
46%261 of stakeholders stated that the Directive has contributed ‘to a large extent’, while 

251 64.9% (n=24) out of 37 respondents agreed and 27% (n=10) out of 37 respondents disagreed. From the 

remaining stakeholders, 8.1% (3 out of 37) responded ‘Do not know/prefer not to say’. 

252 54.1% (20 out of 37 respondents. From the remaining stakeholders, 43.2% (16 out of 37) responded ‘this 
concern is currently addressed by the Directive’, and 2.7% (1 out of 37) responded ‘Do not know/prefer 
not to say’. 

253  51.4%  (n=19)  out  of  37  respondents.  37.8%  (14  out  of  37)  responded  that  this  concern  is  currently 
addressed by the Directive. From the remaining stakeholders, 10.8% (4 out of 37) responded ‘Do not 
know/prefer not to say’. 

254  48.7% (n=18) out of 37 respondents. 
255 35.1% (n=13) out of 37 respondents. From the remaining stakeholders, 16.2% (6 out of 37) responded 

‘Do now know/prefer not to say’.  
256 54.1% (n=20) out of 37 respondents. 
257 83.3% (n=5) out of 6 respondents. 
258 54.1% (n=20) out of 37 respondents. 
259 75% (n=3) out of 4 respondents and 83.3% (n=5) out of 5 respondents. 
260 51..4% (n=19) and 37.8% (n=20) out of 37 respondents. 
261 46% (n=17) out of 37 respondents. 

131 

 
 
16.2%262 said it has contributed ‘to a moderate extent’. Notably, 83.4% of companies and 
businesses indicated that the Directive has contributed positively263. 

The effectiveness of traceability systems yielded limited responses, with 27% stating that 
the  Directive  has  contributed  ‘to  a  large  extent’  and  an  equal  proportion  was  not  in  a 
position  to  respond264.  Regarding  compliance  with  safety  requirements,  40.5%265  of 
stakeholders agreed that the Directive has contributed ‘to a large extent’ to ensuring ‘higher 
compliance with safety requirements of pyrotechnic articles available on the EU market’. 
Notably, 75% of business associations responded that the Directive has ‘to a large extent’ 
contributed to the objective, and 25% responded that it contributed ‘to a very large extent’. 

In the area of market surveillance activities, 29.7%266 of respondents said the Directive 
has contributed ‘to a large extent’ to ‘increased effectiveness of market surveillance’, while 
18.9%  rated  its  contribution  as  ‘moderate’267.  Business  associations  were  unanimously 
positive indicating contributions to a large or very large extent268. 

Efficiency 

Efficiency  analysis  based  on  data  collected  through  public  consultation revealed  mixed 
opinions. For the ‘submission of reports, data, and statistics to competent authorities’, 
almost a third of the stakeholders could not answer, showing stakeholders’ difficulty in 
estimating the associated burden.269 Among those who provided feedback, ca. 45% stated 
that  it  constitutes  a  proportional  burden  to  a  moderate  or  large  extent.270  For 
‘Recordkeeping  information’,  ca.  one-third  of  the  stakeholders  indicated  that  it 
constitutes a proportional burden to a moderate extent.271 A notable number of stakeholders 
frequently opted for the ‘Do not know/prefer not to say’ response. 

262 16.2% (n=6) out of 37 respondents. From the remaining stakeholders, 13.5% (5 out of 37) responded ‘to 
a very large extent’, 8.11% (3 out of 37) responded ‘to a limited extent’, 2.7% (1 out of 37) responded 
‘not at all’ and 13.5 (5 out of 37) responded ‘Do not know/prefer not to say’. 

263 66.7% (4 out of 6)263 of companies and businesses indicated that the Directive has contributed ‘to a large 

extent’, and 16.7% (1 out of 6) felt it contributed ‘to a very large extent’. 

264 27% (n=10) out of 37 respondents. From the remaining responses, 18.9% (7 out of 37) responded ‘to a 
limited extent’, 13.5% (5 out of 37) responded ‘to a moderate extent’, 10.8% (4 out of 37) responded ‘to 
a very large extent’, and 2.7% (1 out of 37) responded ‘not at all’.  

265 40.5% (n=15) out of 37 respondents. 18.9% (7 out of 37) responded with ‘Do not know/prefer not to 
say’. From the remaining responses, 16.2% (6 out of 37) responded ‘to a moderate extent’, 13.5% (5 out 
of 37) responded ‘to a very large extent’, 

266 29.7% (n=11) out of 37 respondents. 
267 18.9% (n=7) out of 37 selected ‘to a moderate extent’ and 21.6% (n=8) out of 37 respondents selected 
‘Do not know/prefer not to say’. From the remaining responses, 13.5% (5 out of 37) responded ‘to a 
very large extent’, 10.8% (4 out of 37) responded ‘to a limited extent’, and 5.4% (2 out of 37) responded 
‘not at all’. 

268 75% (n=3) out of 4 respondents indicated the Directive contributed ‘to a large extent’, and 25% (n=1) 

out of 4) respondents said it contributed ‘to a very large extent’. 

269 29.7% (n=11) out of 37 respondents selected the ‘Do not know/prefer not to say’ option. 
270 24.3% (n=9) out of 37 respondents stated that it constitutes a proportional burden to a moderate extent, 

while 21.6% (n=8) out of 37 respondents said it constitutes a burden to a large extent. 

271 32.4% (n=12) out of 37 respondents. 

132 

 
 
EU added value 

A  significant  proportion  of  stakeholders  underlined  the  role  of  the  Directive  and  EU 
intervention in achieving the harmonisation of rules for the availability and supervision 
of pyrotechnics. Specifically, more than half of the respondents (ca. 62.1%) stated that the 
result  could  not  have  been  achieved  at  all  or  only  to  a  limited  extent  without  the 
Directive272. 

When stakeholders  were asked  how  the pyrotechnics sector would be  affected if the 
Directive  was  withdrawn,  the  largest  share  of  the  respondents  answered  either  ‘very 
negatively’ or ‘negatively’273. Notably, 75% of business associations responded that the 
pyrotechnics  sector  would  ‘remain  unchanged’274.  On  the  other  hand,  40%  of  public 
authorities responded that it would be affected ‘very negatively’ and 40% responded that 
it would be affected ‘negatively’275. 

2.5. Validation workshop  

Stakeholders at the validation workshop highlighted several key points and perspectives. 
Subcontracting conformity assessments to third countries, particularly China, was noted as 
an issue in specific cases but not universally. Stakeholders identified diverging definitions 
of  ‘person  with  specialist  knowledge’  and  differing  enforcement  mechanisms  across 
Member States as problems requiring EU-level consistency. High-risk pyrotechnics, such 
as  certain  powerful  firecrackers  of  category  F4,  were  proposed  for  individual  tracking, 
while  concerns  about  online  sales  and  product  misclassification  were  emphasised. 
Participants stressed the importance of better enforcement and coordination at the Member 
State  level,  rather  than  increasing  categories  or  general  requirements.  Security  and 
environmental  issues,  including  animal  welfare,  were  raised,  though  some  stakeholders 
viewed these as outside the Directive's core scope.  

The  workshop  validated  regulatory  costs,  representing  around  7.2%  of  MSAs’  annual 
budgets and 11.2% of NBs’ turnover. MSAs confirmed that adjustment costs constituted 
the  largest  share  of  total  costs,  followed  by  administrative  costs,  with  their  main 
administrative  expenses  stemming  from  changes  to  documentary  verification  of 
certificates of conformity and adjustments focusing on procedure modifications for checks 
and risk assessments. For NBs, administrative costs were primarily driven by updates to 
their  Quality  Management  System,  while  adjustment  costs  were  associated  with 
establishing  or  modifying  conformity  assessment  procedures  and  training  personnel  to 
comply with the Directive. Despite these costs, participants acknowledged benefits such 

272 35.1% (n=13) out of 37 respondents of consulted stakeholders stated that the result could not have been 
achieved at all without the Directive, while 27% (n=10) out of 37 respondents indicated that it could 
have only been achieved ‘to a limited extent’. 

273  ‘very  negatively’  (18.9%,  7 out  of 37)  or  ‘negatively’  (32.4%,  12  out  of 37).273  From  the  remaining 
stakeholders, 24.3% (9 out of 37) responded with ‘Do not know/prefer not to say’. From the remaining 
stakeholders, 16.2% (6 out of 37) responded ‘remain unchanged’, 5.4% (2 out of 37) responded ‘very 
positively’, and 2.7% (1 out of 37) responded ‘positive’. 

274 From the remaining responses, 25% (1 out of 4) responded ‘negatively’.  
275 From the remaining responses, 20% (2 out of 10) responded ‘Do not know/prefer not to say’.  

133 

 
 
as improved safety standards, reduced accidents, and enhanced market access. Compliance 
costs, varying by company size and country, were generally seen as proportionate. Several 
participants  emphasized  that  the  Directive  has  greatly  improved  the  quality  of  safety 
standards, resulting in improved safety and health outcomes. Furthermore, mandatory CE 
certification was recognised as a key factor in preventing accidents. One participant also 
highlighted that the potential savings from avoiding accident investigations illustrate the 
Directive's cost-effectiveness. 

134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX VI. FUNCTIONING OF THE PYROTECHNICS DIRECTIVE  

The  Pyrotechnics  Directive  sets  out  rules  for  the  making  available  on  the  market  of 
pyrotechnic  articles,  including  essential  safety  requirements  and  rules  for  conformity 
assessment and related obligations for economic operators. It defines pyrotechnic articles 
as  ‘any  article  containing  explosive  substances  or  an  explosive  mixture  of  substances 
designed  to  produce  heat,  light,  sound,  gas  or  smoke  or  a  combination  of  such  effects 
through  self-sustained  exothermic  chemical  reactions’.  This  includes  consumer  and 
professional fireworks, emergency flares but also other pyrotechnic articles that are often 
components of other products such as airbags or seatbelt fasteners in vehicles. Pyrotechnic 
articles intended for use by the armed forces, the police or fire departments and for use in 
the  aerospace  industry  as  well  as  marine  equipment,  civil  explosives,  percussion  caps 
intended for toys, ammunition and fireworks built and approved for the use exclusively on 
the manufacturer’s territory are excluded from the scope. 

1.  Categories of pyrotechnic articles and essential safety requirements 

The Pyrotechnics Directive differentiates between three categories of pyrotechnic articles: 
fireworks (F), theatrical pyrotechnic articles (T) and other pyrotechnic articles (P). Each 
of these categories is divided into sub-categories, depending on the hazard and noise level. 
The  categorisation  of  a  pyrotechnic  articles  determines  which  essential  safety 
requirements,  age  and  knowledge  requirements  apply  and  whether  Member  States  can 
introduce  national  bans  or  restrictions.  The  table  below  provides  an  overview  of  the 
different categories and the way they are regulated by the Directive. 

Figure 21: Categories of pyrotechnic articles 

Category  Use  

Hazard  

F1  

F2  

For 
entertainment  

For 
entertainment  

Very low, 
negligible noise 
level, including 
for indoor use, 
1m safety 
distance  

Low hazard and 
low noise, 
outdoor use in 
confined areas, 
8m safety 
distance  

Age  Examples  

Professional/ 
consumer  
Consumer    12   Sparklers, 
christmas 
crackers, 
crackling 
granules, party 
poppers, 
serpents, etc.  
16   Bangers, flash 
bangers, 
battery,  bengal 
flames, 
fountains, mini 
rockets, jumping 
ground spinners, 
rockets, wheels  

Consumer / 
professional  

Possibility for 
national restrictions  
No possibility for 
national restrictions, 
apart from increasing 
age levels for public 
order, security or 
health and safety  

•  Possibility  to 
increase  age 
levels   

•  Possibility  to 
restrict sale to 
general public 
for 
public 
order, 
security, 
and 
health 
safety, 
or 
environmental 
protection   

135 

 
  
levels 
be 
for 

•  Age 
may 
lowered 
persons 
vocationally 
trained 
undergoing 
such training  

or 

Consumer / 
professional  

As for F2 

18   Banger, flash 
banger, aerial 
wheel, battery, 
compound 
firework, mines, 
report rocket, 
rocket, shot 
tubes  

Professional   N/A  Flash bangers 
(little known 
legal use), 
rockets, brocade 
crowns 
chrysanthemum  

No national 
restrictions are 
foreseen as these are 
professional articles.  

F3  

F4  

For 
entertainment  

For 
entertainment  

Medium 
hazard, for 
outdoor use in 
large open 
areas, noise 
level not 
harmful to 
human health, 
25 m safety 
distance  
High hazard, 
noise level not 
harmful to 
human health, 
safety distance 
to be 
determined by 
professional  
Low hazard  

T1  

Stage use  

Consumer  

18  

•  Possibility  to 
change age   
restrictions 
•  Possibility  to 
restrict sale to 
general 
public   
Possibility to restrict 
sale to general 
public   

•  Possibility  to 
increase  age 
levels   

•  Possibility  to 
restrict sale to 
general 
public   

N/A  

Possibility to restrict 
sale to general 
public   

T2  

Stage use  

Professional   N/A    

P1  

Other uses   Low hazard  

Consumer  

18   Signalling: some 

P1   

automotive 
use  

P2  

Other uses  

Low hazard   Not general 

flares to put on 
recreational 
crafts (if not 
marine 
equipment), fire 
extinguishers, 
machine tools  
N/A  Components of 
other products 
such as airbags, 
seat-belt 
tensioners  

public unless 
incorporated 
into vehicle 
or part.  
Professional   N/A  Same as P1 but 
for professional 
use  

136 

 
 
 
  
  
 
  
The essential safety requirements in Annex I concern, in particular, the following aspects: 

•  Correct functioning when used for intended purpose 
•  Use instructions 
•  Materials/(chemical) composition 
•  Physical and chemical stability 
•  Sensitivity to handling and transportation 
•  Resistance to moisture, low and high temperatures and other conditions 
•  Movement during use 
•  Safety distances 
•  Noise levels 

2.  Conformity assessment of pyrotechnic articles  

The  Pyrotechnics  Directive  is  part  of  the  New  Legislative  Framework  (NLF)  which 
introduced harmonised rules on conformity assessments across 29 pieces of EU product 
legislation. The purpose of conformity assessments is that products are assessed against all 
legislative requirements before they are placed on the market. The NLF introduced several 
model  conformity  assessment  procedures  (‘Modules’)  which  are  included  in  sectoral 
legislation, as appropriate for the product concerned.276 

For the purpose of assessing the conformity of pyrotechnic articles in accordance with the 
Pyrotechnics Directive,  manufacturers have the  choice between different  (combinations 
of) Modules:  

•  EU-type examination (Module B), and, at the choice of the manufacturer, one of 

the following procedures: 

(i)  conformity  to  type  based  on  internal  production  control  plus  supervised 

product checks at random intervals (Module C2); 

(ii) conformity  to  type  based  on  quality  assurance  of  the  production  process 

(Module D); 

(iii)conformity to type based on product quality assurance (Module E); or 

•  conformity based on unit verification (Module G);or 
•  conformity  based  on  full  quality  assurance  (Module  H),  insofar  as  it  concerns 

fireworks of category F4. 

Table 7: Overview of conformity assessment Modules 

Module 
B: EU-type examination 

Description 
Covers  design.  It  is  always  followed  by  other 
modules  by  which  the  conformity  of  the 
products 
is 
demonstrated.  A  notified  body  examines  the 
technical design and or the specimen of a type 

the  approved  EU-type 

to 

276  See  Decision  No  768/2008/EC  of  the  European  Parliament  and  of  the  Council  of  9  July  2008  on  a 
common framework for the marketing of products, and repealing Council Decision 93/465/EEC (OJ L 
218, 13.8.2008, p. 82, ELI: http://data.europa.eu/eli/dec/2008/768(1)/oj).  

137 

 
 
C2: Conformity to EU-type based on internal 
production  control  plus  supervised  product 
checks at random intervals 

D:  Conformity  to  EU-type  based  on  quality 
assurance of the production process 

G: Conformity based on unit verification 

in  order 

internally  control 

and  verifies  and  attests  that  it  meets  the 
requirements of the legislative instrument that 
apply to it by issuing an EU-type examination 
certificate. There are 3 ways to carry out EU-
type  examination:  1)  production  type,  2) 
combination of production type and design type 
and 3) design type. The  Pyrotechnics Directive 
applies the combination of production type and 
design type. 
Covers  production  and  follows  module  B. 
its 
Manufacturer  must 
production 
to  ensure  product 
conformity against the EU-type approved under 
module  B.  C  +  product  checks  at  random 
intervals tests on specific aspects of the product 
carried  out  by  a  notified  body  or  in-house 
accredited body. 
Covers production and follows module B. The 
manufacturer 
production 
(manufacturing  part  and  inspection  of  final 
product)  quality  assurance  system  in  order  to 
ensure  conformity  to  EU-type.  The  notified 
body assesses the quality system. 
Covers  both  design  and  production.  The 
the 
manufacturer  ensures  compliance  of 
legislative 
manufactured  products 
requirements. The notified body verifies every 
individual  product 
to  ensure 
conformity to legislative requirements (no EU-
type). 

in  order 

operates 

the 

to 

a 

H: Conformity based on full quality assurance  Covers  both  design  and  production.  The 
manufacturer operates a full quality assurance 
system  in  order  to  ensure  conformity  to 
legislative  requirements  (no  EU-type).  The 
notified body assesses the quality system. 

Source : Based on the Blue Guide

277

3.  Labelling and traceability system for pyrotechnic articles 

Pyrotechnic  articles  need  to  be  labelled  in  accordance  with  the  Directive  which  sets 
different rules for pyrotechnic articles for vehicles and other pyrotechnic articles (Article 
10 and 11). 

All labelling of pyrotechnic articles needs to include information about the manufacturer, 
the name and type of the article and a registration number. Where necessary, pyrotechnic 
articles  for  vehicles  shall  also  be  labelled  with  safety  instructions  and  they  have  to  be 
accompanied  by  a  safety  data  sheet  compiled  in  accordance  with  Regulation  (EC) 
No 1907/2006. Other pyrotechnic articles, depending on the category, need to be labelled 
with the relevant category and instructions for use, the year of production, age limits, safety 

277  European Commission, Commission Notice. The ‘Blue Guide’ on the implementation of EU product 

rules 2022, (2022/C 247/01). 

138 

 
 
 
distances, the net explosive content and, where appropriate, ‘for outdoor use only’ or ‘for 
use only by persons with specialist knowledge’. 

The registration number shall have the following format278: 

XXXX — YY — ZZZZ 

4-digit identification number of 
the notified body 

Category of the pyrotechnic 
article, e.g. F1, T2, P1 

Processing number 
used by the notified 
body for the 
pyrotechnic article 

Manufacturers,  importers  and  notified  bodies  need  to  keep  record  of  the  registration 
numbers. The registration number is not item-specific but is the same for all pyrotechnic 
articles covered by the same conformity assessment (i.e. type or batch). 

278 Commission Implementing Directive 2014/58/EU. 

139 

 
 
 
 
 
 
 
ANNEX VII. COMPLEMENTARY INFORMATION ON THE CURRENT STATE OF PLAY 

1.  Market structure 

As  regards  the  market  structure,  data  could  not  be  differentiated  between  pyrotechnic 
articles  and  explosives,  as  they  fall  under  the  same  NACE  code279  ‘Manufacture  of 
explosives’. The trends in turnover, number of companies and number of employees in the 
entire ‘manufacture of explosives’ sector does not seem to correspond to the rather stable, 
and recently increasing, production of pyrotechnics values shown above. As some data for 
the years around the adoption and entry into application is missing, the overall trend since 
2008 is illustrated below.280  

Figure 9: Turnover, number of companies and number of employees of the EU 'Manufacture of explosives' sector 

l

s
e
e
y
o
p
m
e
f
o
r
e
b
m
u
N

Number of employees over time

Number of companies over time

20000
17500
15000
12500
10000
7500
5000
2500
0

600

400

200

0

i

s
e
n
a
p
m
o
c

f
o
r
e
b
m
u
N

2008 2011 2014 2017 2020

EU turnover over time

3000

2000

1000

0

2008 2010 2012 2014 2016 2018 2020 2022

)
s
o
r
u
e
f
o
n
o

i
l
l
i

m

(

r
e
v
o
r
u
T

Source: own preparation of SBS data (Economical indicator for structural business statistics: V12110 Turnover or gross 
premiums written - million euros, V11110 Enterprises number, V16130 Employees – number, Statistical classification 
of economic activity: C2051 Manufacture of explosives) 

279  ‘NACE  is  the  acronym  used  to  designate  the  various  statistical  classifications  of  economic  activities 
developed since 1970 in the European Union (EU). NACE provides the framework for collecting and 
presenting  a  large  range  of  statistical  data  according  to  economic  activity  in  the  fields  of  economic 
statistics  (e.g. business  statistics,  labour  market,  national  accounts)  and  in other  statistical  domains.” 
Eurostat. 

280 Data is missing for the number of companies for the years 2011, 2014, 2015, for the number of employees 
for the years 2011, 2012, 2015, 2016 and 2019, and for the turnover for the years 2009, 2011-2015 and 
2019. No data was yet available for 2023 and 2024. 

140 

 
 
 
 
 
 
 
 
 
 
 
2.  Harmonisation of laws 

The Directive leaves Member States a certain degree of discretion in the transposition of 
the harmonised EU rules. A study carried out in 2022 concluded that the transposition of 
the Directive is generally satisfactory, although the transposition in most Member States 
showed several shortcomings.281  

Definitions 

Definitions (Article 2) have mainly been taken over with only some minor variation in a 
few Member States for ‘pyrotechnic article’ and ‘ammunition’- Due to the ambiguity of 
the  definition  of  ‘pyrotechnic  article’  in  the  English  version  of  the  Directive,  where 
‘designed  to  produce  heat,  light,  sound,  gas  or smoke  or  a  combination  of  such  effects 
through self-sustained exothermic chemical reactions’ could refer both to the pyrotechnic 
article itself or to the explosive substances or explosive mixture of substances contained in 
the pyrotechnic article, in several language versions of the Directive, the definition was 
translated with the latter meaning. These language versions were  subsequently corrected 
by the Commission.282 However, 16 Member States still use the latter definition in their 
laws.283  

The definitions of ‘ammunition’ in eight Member States are not a direct transposition of 
the Directive’s definition, mainly because they either require the presence of a projectile 
or do not cover blank ammunition, with the consequence that some articles that do not fall 
under the Pyrotechnics Directive are considered ‘pyrotechnic articles’ under those Member 
States’ legislation to which the rules spelled out in the Directive apply. 284 

According to the Directive, F4, T2 and P2 pyrotechnic articles may only be sold to ‘persons 
with  specialist  knowledge’.  While  the  definitions  of  a  ‘person  with  specialist 
knowledge’ (Article 3(6)) in most Member States laws are in line with the definition in 
the  Directive,  the  concrete  wordings  vary  between  Member  States.  Moreover,  the 
definitions in ten Member States only refer to certifications and/or authorisations delivered 
by their own national authorities, posing questions about mutual recognition of specialist 
knowledge between Member States.285  

National prohibitions, restrictions and age limits 

Article 4(2) of the Directive allows Member States to prohibit or restrict the possession, 
use  and/or  the  sale  to  the  public  of  categories  F2  and  F3  fireworks,  theatrical 

281  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022, p. 34. 

282 Corrigendum to Directive 2013/29/EU of the European Parliament and of the Council of 12 June 2013 
on the harmonisation of the laws of the Member States relating to the making available on the market of 
ELI: 
(OJ 
pyrotechnic 
http://data.europa.eu/eli/dir/2013/29/corrigendum/2021-03-18/oj). 

articles 

March 

2021, 

94 

18 

of 

L 

283  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022, p. 36. 

284 Ibid., pp. 36 et seq. 
285 Ibid., pp. 56-62. 

141 

 
 
pyrotechnic articles and other pyrotechnic articles on grounds of public order, security, 
health and safety, or environmental protection. In 2022, ten Member States had introduced 
prohibitions or restrictions pursuant to Article 4(2) of the Pyrotechnics Directive. Among 
the restrictions adopted are: 

-  Prohibition of mail order/online sales  
-  Prohibition of the sale of fireworks of which the pyrotechnic composition exceeds 

1 kg to consumers that do not hold the necessary permit 

-  Prohibition of F3 and certain F2 fireworks for the general public 
-  License requirements or requirements of specialist knowledge for certain fireworks 

and other pyrotechnic articles other than F4, T2 and P2 

-  Requirements for sales rooms 
-  Sales and use restrictions to the end of year period 
-  Maximum weight limits for the availability, possession, transport and storage 
-  Maximum net explosive mass for articles sold to the general public 

In addition, five Member States allow competent authorities to adopt restrictive measures 
by administrative decisions.286 

Besides the possibility to prohibit and restrict certain categories of pyrotechnic articles, 
Member States  also  have the discretion to  increase the  age limits set out in Article 7, 
where justified on grounds of public order, security or health and safety. They may also 
set  lower  age  limits  for  persons  vocationally  trained  or  undergoing  such  training.  The 
majority of Member States have made use of this option, increasing the age limits for F1 
fireworks from 12 to 14, 15, 16 or 18 and/or the age limits for F2 fireworks from 16 to 18. 
Two Member States have also increased the minimum age for F3 fireworks from 18 to 
21.287 

In seven Member States, restrictions on the free movement (Article 4(1)) of pyrotechnic 
articles related to notification obligations were observed, which can be subsumed under 
two  categories:  (1)  the  introduction  of  an  obligation  to  register  or  notify  pyrotechnic 
articles to national authorities before they are placed on the market and (2) the introduction 
of  restrictions  to  the  sale  and/or  use  of  pyrotechnic  articles  beyond  the  Pyrotechnics 
Directive.288  Restrictions  of  the  latter  kind  include  the  prohibition  of  mail  order  sales, 
maximum  limits  for  the  availability,  possession,  transport  and  storage  of  pyrotechnic 
articles and limiting the sale of consumer fireworks to the end of year period, applying to 
all  fireworks,  including  F1  articles,  although  Article  4(2)  only  provides  for  national 
restrictions for categories F2 and F3, theatrical pyrotechnic articles and other pyrotechnic 
articles.289 

286 Ibid., pp. 51-55. 
287 Ibid., pp. 65-68. 
288 Ibid., p. 48. 
289  Ibid., pp. 48-51. 

142 

 
 
 
Licensing requirements for economic operators 

The  Pyrotechnics  Directive  applies  without  prejudice  to  national  legislation  on  the 
licensing  of  manufacturers,  distributors  and  importers  by  the  Member  States.290 
Accordingly, the Directive does not  mandate any specific licensing requirements, nor a 
licensing  system  in  general.  In  2022,  15  Member  States  imposed  certain  licensing 
obligations,  while  12  did  not.  Those  with  licensing  requirements  generally  exempt 
category F1, some also F2.291  

Requirements for persons with specialist knowledge 

Besides  the  differences  in  the  definitions  of  a  ‘person  with  specialist  knowledge’ 
mentioned above, Member States also set out different requirements to be met in order to 
acquire  this  status.  For  instance,  one  Member  State  requires  certification  in  accordance 
with  the  norm  EN  ISO/IEC  17024,  while  another  Member  State  presupposes  (i)  the 
successful participation in a state or state-recognised course of instruction for the intended 
activity,  (ii) practical experience of at least three years, or (iii) the completion of a course 
of  study  at  a  university/university  of  applied  sciences/technical  school  and  practical 
experience of at least one year.292 Moreover, the Directive leaves it to the discretion of the 
Member States to lay down rules for the authentication and verification of persons with 
specialist knowledge. Belgium, the Netherlands and Luxemburg have jointly decided to 
introduce a uniform control document in the Benelux area – the so-called Pyro-pass.293 

The Pyro-pass in the Benelux countries 

The Benelux Union, with the adoption of Benelux Decision 2020(14), introduced a 
Pyro-pass  which  aims  to  facilitate  the  verification  of  specialist  knowledge  by 
economic  operators  and  thereby  prevent  pyrotechnic  articles  from  ending  up  in  the 
hands of unauthorised persons. The Pyro-pass  is a uniform  identification document 
issued  to  persons  recognised  by  the  authorities  as  having  specialist  knowledge.  A 
register is used to keep track of all issued and active Pyro-passes. Economic operators 
must  consult  this  register  before  supplying  pyrotechnic  articles  requiring  specialist 
knowledge and keep a  copy of the Pyro-pass,  the related invoice  and any transport 
documents required under Directive 2008/68/EC. 

Traceability 

In  terms  of  traceability,  some  Member  States  went  beyond  the  requirements  of  the 
Pyrotechnics  Directive  and  Commission  Implementing  Directive  2014/58/EU.  One 

290  See recital 12. 
291  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022, pp. 70-73. 

292 Ibid., p. 64. 
293 Decision du Comité de Ministres Benelux relative à l’introduction d’un pyro-pass du 7 décembre 2020,  

M (2020) 14. 

143 

 
 
 
 
 
 
 
 
 
 
 
Member  State,  for  instance,  requires  importers  and  dealers  to  report  all  movements  of 
fireworks to competent authorities. Moreover, in some Member States, economic operators 
must  inform  the  authorities  when  they  import  or  export  pyrotechnic  articles  or  before 
placing  a  pyrotechnic  article  on  the  market,  with  some  Member  States  entering  such 
information  into  a  register.  In  another  Member  State  distributors  are  obliged  to  record 
transactions  and  the  identity  of  purchasers  when  selling  certain  category  F2  and  F3 
pyrotechnic articles.294  

Environmental protection and animal welfare 

The  Directive’s  objective  to  ensure,  among  others,  environmental  protection  has  been 
included  in  provisions  of  18  Member  States.  While  most  Member  Sates  only  mention 
environmental  protection  as  ground  for  restriction  and  prohibitions,  thus  implementing 
Article 4(2), some also link other consequences to environmental concerns. For instance, 
in one Member State, damage to the environment caused by a violation of pyrotechnics 
legislation may lead to an increased imprisonment time of up to 2 years. Other Member 
States require pyrotechnic articles to be designed and manufactured in such a way as to 
have the least possible impact on the environment, transposing one of the essential safety 
requirements  of  the  Directive  explicitly  in  national  law.  Collection,  disposal  and 
destruction of explosive products and waste are regulated with the purpose of protecting 
the  environment  in  at  least  one  Member  State.  Finally,  one  Member  State  takes  into 
account the risk for the environment for the classification of pyrotechnic articles, where 
F1 fireworks are characterised by a low risk and F4 fireworks with a high risk. By 2022, 
no Member State had introduced the objective of ensuring animal welfare in their laws 
transposing the Pyrotechnics Directive.295 

Penalties 

In  transposition  of  the  obligation  to  establish  effective,  proportionate  and  dissuasive 
penalties (Article 45), most Member States have opted for fines. The amounts of the fines 
vary between a maximum fine of EUR 600 in one Member State to a maximum (criminal) 
fine of EUR 10.8 million in another Member State. Imprisonment is only provided for by 
half of the Member States, with imprisonment terms ranging from 60 days to 7 years. Other 
penalties  introduced  by  Member  States  include  forfeiture  and  confiscation,  market 
restrictions and prohibitions, and the relocation and suspension of licenses.296 

294  European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025, p. 46. 
295  European  Commission,  Study  of  conformity  in  all  EU  countries  on  EU  pyrotechnics  and  explosives 

legislation. Final Report, EY Law, 2022, pp. 79-82. 

296  European Commission, Evaluation study of Pyrotechnics and Civil Explosives Legislation (Directive 
2013/29/EU,  Commission  Implementing  Directive  2014/58/EU,  and  Directive  2014/28/EU, 
Commission  Implementing  Directive  2008/43/EC  and  Commission  Decision  2004/388/EC),  Final 
Report, Technopolis Group in collaboration with Milieu, Wavestone, and Intellera, 2025, p. 47. 

144 

 
 
ANNEX VIII. CASE STUDIES 

The below case studies were carried out by the Technopolis Group in the context of the 
study in support of the evaluation. 

1.  Case Study 1: Challenges and measures to tackle the illicit use of pyrotechnic 

articles in the Netherlands and in France- hooliganism and riots   

Objective and rationale of the case study   

Both France and the Netherlands are facing significant challenges related to the illicit use 
of  pyrotechnic  articles,  primarily  during  riots  in  France  and  football  events  involving 
hooligans in the Netherlands. This case study details how and to what extent these groups 
employ illicit pyrotechnic articles as well as the responses of public authorities, including 
police forces and market surveillance authorities, to such threats. Furthermore, it aims to 
highlight the challenges these authorities face in enforcing the measures transposed from 
Directive 2013/29/EU in such contexts. 

This case study is linked to the following evaluation questions:   

• 

Is the current system enabling traceability of pyrotechnic articles effective?  

•  Does the current system provide enough safeguards to combat trafficking of illegal 

pyrotechnic articles? 

•  Does national law impose sanctions on individuals selling F4 pyrotechnic articles 

to persons that do not demonstrate the required specialist knowledge?  

•  Are the current penalties effective, proportionate, and dissuasive? 

The case study can contribute to several types of lessons learned and in particular to assess 
if  there  are  shortcomings  in  the  monitoring,  control,  and  traceability  of  pyrotechnics 
articles to tackle their illicit use at EU level.    

Methodology   

This case study was built based on the following sources:  

- 

- 

Interviews with market surveillance authorities in FR and the NL 

Interviews with national enforcement authorities FR and the NL 

-  Desk research on French and Dutch data bases and related grey literature   

The research and interviews were carried out by respectively French and Dutch native legal 
experts.   

Types of pyrotechnic articles commonly used illicitly by hooligans and by protesters 

In France, pyrotechnic articles have been continuously used against security forces since 
the  early  2000s.  However,  between  27  June  and  7  July  2023,  France  experienced 
significant  riots  where  pyrotechnic  articles  were  illicitly  deployed  on  an unprecedented 
scale against security forces and public buildings. This marked the first instance of such a 

145 

 
 
massive, coordinated, and prolonged use of pyrotechnics in this manner. The articles used 
ranged from F2 to F4 category fireworks, with a particularly heavy use of firework rockets, 
Roman candles and high-capacity flash bangers. They were occasionally deployed in rapid, 
concentrated actions as rioters charged at security forces and also used to create barriers 
that impeded the progress of law enforcement forces. 

In the Netherlands, the types of pyrotechnics most often used illegally by hooligans are 
mainly  certain  brands  of  powerful  firecrackers  and  shells.297  Certain  brands  of 
firecrackers are known for their enormous explosive power and considered one of the most 
dangerous types of fireworks. Shells, a type of F4 fireworks, are small bombs often used 
in fireworks shows, for example during Kings Day and New Year's Eve, because of their 
large effects.  

Shells are not allowed to be stored in the Netherlands. These items are usually obtained 
illegally through other countries, such as Italy, or through storage in Germany, and then 
transported  to  the  Netherlands.  Under  the  Dutch  Fireworks  Decree,  anyone  bringing 
fireworks or theatrical pyrotechnic articles into or out of the Netherlands for commercial 
purposes must notify the Minister electronically at least 48 hours in advance. An exception 
applies if it can be demonstrated to the Minister that the articles will leave the Netherlands 
within 48 hours. If pyrotechnic articles are stored for a short period with an environmental 
permit, pending transport to a specific recipient, at seaports in Amsterdam, Eemshaven, 
Rotterdam, or Vlissingen, the 48-hour limit extends to two weeks.  

Additional  fireworks used by hooligans  are  avalanche rockets  (P2), that are originally 
F3/F4 bangers (extremely loud and powerful fireworks) refitted for controlled avalanche 
setting off in mountainous areas. Also, bengal flames (F1-F3), brightly burning fireworks, 
are often used to create atmosphere in stadiums, as well as to intimidate opponents and the 
police.  

Methods of acquisition and distribution among these groups  

In France, stocks of pyrotechnic articles were gathered in advance. At least two supply 
networks were identified: one through the internet and the other through well-organised 
networks  bringing  stocks  from  Belgium  and  Poland.  Social  media  platforms  were  also 
widely used to exchange information about potential supply sources that offered products 
for delivery, most often via express freight or postal services298.   

In the Netherlands, hooligans use various methods and channels to obtain and distribute 
these fireworks: 

-  Online  marketplaces  and  dark  web:  Illegal  fireworks  are  often  sold  through 
anonymous online platforms and marketplaces on the dark web, where payments 
are often made in cryptocurrency to ensure anonymity. 

297 Reinier Auwema (Inspectie Leefomgeving en Transport), ‘Interview on illegal use of fireworks by Dutch 

hooligans’ taken on 7 August 2024.  

298 Information collected from representatives of the French Ministry of the Interior via e-mail exchanges.   

146 

 
 
-  Smuggling:  Many  illegal  fireworks  are  illegally  brought  into  the  country  from 
countries  with  less  stringent  regulations,  such  as  Belgium,  Poland  and  Eastern 
European countries. 

-  Networks  and  middlemen:  Hooligans  often  have  a  well  organised  network  of 
contacts  and  intermediaries  specialising  in  the  trade  and  distribution  of  illegal 
fireworks. This network uses hidden warehouses and changing locations to avoid 
detection by the authorities. 

-  Anonymous orders and deliveries: Tactics such as placing anonymous orders and 
using  pick-up  points  or  fictitious  addresses  to  deliver  fireworks  are  common  to 
avoid detection. 

Between  2020  and  2023,  6%  of  football  hooligan-related  incidents  involved  the  use  of 
fireworks.299  

Measures to tackle this illicit use of pyrotechnic articles 

France  has  adopted  several  measures  to  tackle  the  illicit  use  of  pyrotechnic  articles  in 
France.   

The Environmental Code was amended by a 2021 law  300 to enhance the control on the 
sale of pyrotechnic articles. It requires distributors and sellers to record transactions and 
the identity of purchasers when selling pyrotechnic articles for entertainment, as defined 
by  the  Interior  Ministry  in  a  2021  Order301(i.e.  bangers  (F3),  batteries  (F3),  batteries 
requiring  external  support  (F3),  combinations  (F3),  combinations  requiring  external 
support (F3), double bangers (F2 and F3), flash bangers (F3), rockets (F2 and F3), roman 
candles  (F2  and  F3),  and  shot  tubes  (F2  and  F3)).  Sellers  have  the  right  to  refuse 
transactions deemed suspicious and must report such attempts to designated authorities. 
They face penalties for providing pyrotechnic articles to ineligible individuals, including 
imprisonment  and  fines.  Individuals  face  similar  penalties  for  acquiring  or  using 
pyrotechnic  articles  without  the  required  technical  knowledge  or  not  meeting  age 
requirements.  Carrying  out  such  illicit  conduct  online  is  considered  an  aggravating 
circumstance leading to more stringent penalties.  

Furthermore,  as  a  reaction  to  the  riots,  that  occurred  close  to  the  national  day,  the 
Government adopted a Decree302 temporarily prohibiting the sale, carrying, transport, and 
use of all pyrotechnic articles sold to the general public throughout the country until July 
15, to avoid serious public order disturbances. Pyrotechnic article producers challenged 
this Decree before the Council of State, arguing that it was overly broad as it also covered 
very low-risk pyrotechnic articles. The Council of State in its decision No. 475817 dated 

299  Wolsink,  J.  et  al.,  Van  voetbalrellen  leren:  Een  onderzoek  naar  modern  voetbalgeweld  en  de 

tekortkomingen van en kansen voor de aanpak, Bureau Beke, 2023.  

300 Article 70 and Article 71 of Law No. 2021-646 of May 25, 2021, for comprehensive security preserving 

freedoms. 

301 Order of December 17, 2021, Implementing Articles L. 557-10-1 and R. 557-6-14-1 of the Environmental 

Code concerning pyrotechnic articles intended for entertainment. 

302 Décret n° 2023-576 du 8 juillet 2023 portant interdiction de la vente, du port et du transport d'engins 

pyrotechniques et d'artifices de divertissement. 

147 

 
 
July 13, 2023303, determined that, while certain categories of pyrotechnic articles (i.e., F3 
bangers, rockets, and other items specifically listed in the 2021 Order) posed a higher risk 
of misuse and could be justifiably restricted, the prohibition was excessive concerning F1, 
T1  and  P1  as  well  as  F2  and  F3  pyrotechnic  articles  not  listed  in  the  2021  Order. 
Consequently, the Council of State partially suspended the Decree regarding these latter 
categories, concluding that a blanket prohibition exceeded what was strictly necessary to 
preserve public order. 

More  generally,  local  orders  issued  by  French  territorial  administrative  authorities  (the 
departmental prefects) are enacted each summer and for the end-of-year holidays to ban 
the use of certain categories of fireworks for the public to ensure public order as a legal 
basis. These orders are becoming increasingly robust from a legal standpoint and are less 
and less contested.  

Note  that  with  regard  to  the  misuse  of  pyrotechnic  articles  in  sport  events,  the  French 
Ministry of Sports launched a pilot program to regulate the use of pyrotechnic articles in 
designated  areas  within  sports  venues.  This  concerns  pyrotechnic  articles  of  moderate 
power, with a limited list of authorised items.  

In the Netherlands, the Fireworks Decree304 requires importers and dealers to report all 
movements of fireworks to the competent authorities. This system has been developed to 
monitor the transport of fireworks by car, ship or train, keeping a record of all fireworks 
movements within the Netherlands. The competent authorities randomly check the quality 
of fireworks.  On average, 20% of tested fireworks are destroyed because they are non-
compliant 305.  

The  Fireworks  Decree  also  regulates  fireworks  inspections  providing  comprehensive 
power  to  inspectors  (e.g.  access  to  locations  where  fireworks  are  stored,  sold  or  used 
without the owner's permission including business premises, means of transport and event 
venues  where  fireworks  may  be  present,  samples  of  fireworks  products,  and  request 
documents relevant to regulatory compliance.) and setting a stringent sanctioning regime.    

Furthermore, some due diligence requirements on postal package companies were adopted 
to prevent fireworks from entering their systems, enhancing preventive controls. 

In the football sector, additional measures are in place to combat hooligans. Mayors have 
extensive powers to better prevent abuses around football matches, set out in the Measures 
to Combat Football Hooliganism and Serious Nuisance Act306.  

Mayors can impose long-term area bans or group bans on hooligans (maximum 2 years). 
An area ban, reporting obligation or group ban around a home match can be extended to 

303 See Council State Decision N° 475817 of 13 July 2023.  
304 Vuurwerkbesluit, BWBR0013360.  
305 

See: 

https://www.rijksoverheid.nl/onderwerpen/vuurwerk/regels-
vuurwerk#:~:text=Sinds%202022%20geldt%20tijdens%20oud,hebben%20en%20ook%20niet%20afst
eken. 

306  Wijzigingswet  Gemeentewet,  Wetboek  van  Strafvordering  en  Wetboek  van  Strafrecht  (maatregelen 

bestrijding voetbalvandalisme en ernstige overlast), BWBR0028120. 

148 

 
 
non-home matches. Additionally, a football club can ban rioters from their own stadium307. 
The Royal Dutch Football Association (KNVB) can ban rioters from entering all stadiums 
in the Netherlands. This can be based on camera images from the club or on information 
obtained  from  the  club,  the  municipality,  the  police  or  the  public  prosecutor.  A  civil 
stadium ban lasts a minimum of three months. There is a guideline with  the terms of a 
stadium ban308. 

The  police  register  records  hooligans  and  disturbances  involving  football  violence  in  a 
central  database.  This  database  is  called  the  Football  and  Safety  Chain  System309. 
Municipalities, police, football clubs and the Public Prosecution Service use the data from 
this system and can put information into it themselves. In this way, parties exchange data. 
They  estimate  safety  risks  for  each  match.  But  they  also  determine  the  deployment  of 
police, stewards and private security guards with the help of this data.  

Strict enforcement measures have recently been applied during football matches, using a 
zero-tolerance policy. This means that if someone is caught setting off fireworks, they are 
immediately detained310. 

Recommendations for improvement and lessons learned  

In  France,  as  outlined  by  representatives  of  French  authorities311,  there  is  an  ongoing 
debate about how to enhance security measures and control access to fireworks to prevent 
their  increasing  illegal  misuse.  These  representatives  pointed  out  that  the  limited 
traceability  requirements  for  fireworks  across  the  EU  deriving  from  the  Pyrotechnic 
Directive  hinder  the  ability  to  track  the  movement  and  storage  of  pyrotechnic  articles 
within the Union despite national enforcement efforts. They suggested that the EU civil 
explosives traceability regime could serve as a model for the most dangerous categories 
of pyrotechnic articles, advocating for the adoption of similar requirements for pyrotechnic 
articles,  allowing  detailed  tracking  and  documentation  measures  for  the  Pyrotechnic 
Articles Directive. They also stressed that it is becoming increasingly necessary to hold 
transport  and  freight  operators  accountable  for  their  duty  of  vigilance  regarding 
explosive materials that may pass  through their  services, particularly  in  relation  to  the 
safety  of  their  own  employees,  who  may  sometimes  handle  dangerous  packages 
unknowingly. 

A  2023  Senate  Report  also  suggested  banning  the  online  and  postal  sales  of  mortar 
fireworks  requiring  individuals  to  physically  purchase  these  items  from  authorized 

307  For  more  information,  see.  https://www.rijksoverheid.nl/onderwerpen/voetbalvandalisme/aanpak-

hooligans. 

308 Koninklijke Nederlandse Voetbalbond, Richtlijn Termijn Stadionverbod Seizoen 2023/’24. 
309  https://www.rijksoverheid.nl/contact/contactgids/auditteam-voetbal-en-veiligheid.  
310  Politie  (Police)  Rotterdam  representative,  ‘Interview  on  illegal  use  of  fireworks  by  Dutch  hooligans’ 

carried out  on 9 September 2024.  

311 Interview held in July 2024 with representatives of the Ministry of Ecological Transition of the Ministry 

of the Interior, of police forces and customs.    

149 

 
 
dealers, who are better equipped to identify suspicious transactions as it is already the case 
in Spain 312 .  

It is proposed to lower the powder weights for professional fireworks, especially for 
dangerous popping fireworks, to reduce illegal use and enhance safety. The extension of 
the pyro-pass system313 used in BENELUX to all EU Member States was suggested to 
enhance  traceability  and  control  over  the  purchase  and  use  of  professional  fireworks, 
ensuring they are only accessible to authorised and trained individuals314. 

Both Member States also suggest further enforcement cooperation between Member 
States  based  on  lessons  learned  from  cooperation  between  the  two  countries.  Illegal 
fireworks  were  entering  the  Netherlands  through  postal  shipments  from  France.  The 
Netherlands established a mechanism in 2015 to address this issue and included France in 
the Dutch surveillance process. As part of this effort, both countries trained personnel and 
deployed  specially  trained  fireworks  detection  dogs  to  intercept  illegal  shipments.  This 
collaboration has resulted in a noticeable decrease in the number of fireworks smuggled 
through postal packages. However, smugglers have since shifted to alternative routes, such 
as through Belgium, to continue their activities. 

Conclusion   

France  and  the  Netherlands  have  taken  important  steps  to  address  the  illegal  use  of 
pyrotechnic  articles.  Their  efforts  demonstrate  that  robust  legal  frameworks,  strong 
enforcement mechanisms, and cooperation amongst Member States are key to tackling the 
illegal misuse of pyrotechnic articles. Both countries, however, advocate for further action 
at  the  EU  level  to  improve  traceability  and  security  of  the  most  dangerous  pyrotechnic 
articles  under  the  Pyrotechnic  Directive,  ensuring  that  all  Member  States,  working 
together, have the relevant tools to address this growing concern.   

2.  Case study 2: The use of pyrotechnics in the automotive industry  

INTRODUCTION 

Purpose & scope of the Case Study  

The integration of pyrotechnics in automotive safety systems, such as airbags and seat belt 
pretensioners, has become a crucial aspect of vehicle safety technology. As a consequence, 

312  Buffet,  F.-N.,  Rapport  d’information  fait  au  nom  de  la  commission  des  lois  constitutionnelles,  de 
législation,  du  suffrage  universel,  du  Règlement  et  d’administration  générale,  investie  des  pouvoirs 
d’une commission d’enquête, sur les émeutes survenues à compter du 27 juin 2023, 2024. 

313  The  Pyro-pass  initiative,  formalised  through  Benelux  Decision  2020(14)  and  amended  by  Decision 
2022(9),  is  a  standardised,  trilingual  permit  recognised  across  Belgium,  the  Netherlands,  and 
Luxembourg,  allowing  qualified  individuals  to  purchase  and  handle  professional-grade  fireworks.  It 
includes a harmonised documentation process and digital verification portals for real-time authorisation 
checks,  enhancing  cross-border  compliance,  preventing  unauthorised  access,  and  promoting  public 
safety by reducing illegal trade and misuse of high-risk pyrotechnic articles. 

314 Reinier Auwema (Inspectie Leefomgeving en Transport), ‘Interview on illegal use of fireworks by Dutch 

hooligans’ taken on 7 August 2024. 

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the automotive industry represents a large market for pyrotechnic devices. This case study 
aims to delve deeper into their use within this sector.  

Methodology 

This case study provides additional evidence to feed the following research questions: 

•   ECT-01.1: Do the existing requirements, including essential requirements as well as 
categories (especially  of pyrotechnics), continue  to  provide for  an adequate level  of 
protection of public interests and security, health, and safety of their users? 

•   ECT-07.1: What have been the qualitative and quantitative effects of the measures on 
their objectives? How have they evolved since the implementation of the measures? 

This  analysis  is  based  on  secondary  data  sources,  including  data  on  accidents,  industry 
reports, regulatory documents, and academic studies. The review of evidence revealed a 
scarcity of data on this issue; consequently, although a substantial number of sources were 
analysed, many were ultimately deemed irrelevant to the study. In addition, it integrates 
findings from an interview with one manufacturer of automotive devices315. 

Context and Background 

Use of pyrotechnic devices in the automotive industry 

Pyrotechnic devices are integral components in modern automotive safety systems. They 
are primarily used in: 

•  Airbag systems: these include actuators, inflators, and gas generators that rapidly 

inflate airbags during a collision to protect passengers316. 

•  Seat  belt  pretensioners:  pyrotechnic  mechanisms  that  tighten  the  seatbelt  in  the 

event of a crash to restrain the passenger more securely317. 

•  Pyrotechnic actuators: these are used in applications such as active bumpers, pop-
up hoods for pedestrian protection, and systems that automatically open car doors 
after a crash to facilitate occupant rescue318. 

The EU market of pyrotechnic devices for the automotive industry 

The  analysis  of  the  market  has  been  carried  out  using  a  single  interview  with  a 
manufacturer of pyrotechnic devices for the automotive industry. It must be noted that six 
manufacturers were contacted as part of this case study. However, only one agreed to be 

315 Despite efforts to engage a broader range of stakeholders for interviews, there was a lack of response 
from several key parties, which limited the scope of stakeholder perspectives included in this study. 
316  Aufauvre,  L.  (2006),  New  Trends  for  Pyrotechnic  Automotive  Safety  in  the  European  Union,  33. 

International Pyrotechnics Seminar (IPS 2006), 2006, 509-512. 

317 Górniak et al., The Numerical Simulation of the Pyrotechnic Actuator for the Active Bumper, Journal of 

KONES Powertrain and Transport 19, 2012, 141-147. 

318  Deutschmann,  C.W.,  Pyromechanic  actuators  increase  safety  for  passengers  and  pedestrians,  ATZ 

Worldwide 109, 7-8.  

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interviewed.  Findings  from  the  interview  have  been  integrated  with  data  from  market 
reports. Due to the absence of quantitative data and the single interview conducted, caution 
must be applied when interpreting the market analysis. 

Currently,  there  are  no  public  or  private  databases  that  can  be used  to  conduct  a 
market  analysis  of  pyrotechnic  devices  for  the  automotive  industry.  In  addition, 
primary  data  is  limited  because  manufacturers  do  not  make  the  price  of  their  products 
publicly available. Moreover, there are no online marketplaces for pyrotechnic devices for 
the automotive industry. Therefore, an ad-hoc study employing both bottom-up and top-
down market analysis would be needed to estimate the size and structure of this market. 

According to the manufacturer consulted, the market for pyrotechnic products in the 
automotive sector has remained stable since the implementation of the EU directive 
in 2013. The industry stakeholder provided estimates on market data indicating that the 
annual sales of inflators in Europe amount to approximately 50 million units, generating a 
turnover of about EUR 400 million, which represents around 40% of the global market. 
This  stability  reflects  the  continued demand for pyrotechnic safety systems,  such as 
airbags and seat belts, despite the overall declining trend in the wider pyrotechnics 
industry. 

The manufacturer indicated that Europe and North America are currently leading 
the  global  market  of  pyrotechnic  products  in  the  automotive  sector.  The  interview 
suggested that 40% of the global production occurs in  Europe, 40% in  North America, 
17% in Asia (with China and India as emerging markets), and the remaining 3% in other 
countries. Notably, the number of pyrotechnic components in vehicles has increased, with 
pyrotechnic  systems  now  present  in  rear  seats  and  airbags,  which  were  less  common  a 
decade ago. 

In 2023, the European Association of Automotive Suppliers (CLEPA) has forecasted that 
the  pyrotechnic  automotive  market  is  expected  to  grow  significantly,  driven  by 
advancements in safety technologies and new applications such as pyrotechnic battery cut-
off systems319 and pedestrian protection systems320. These developments are supported by 
innovations in pyro-mechanic actuators that offer compact designs and quick activation 
times, enhancing overall vehicle safety321. 

According to the interviewee, the number of companies operating in the pyrotechnic 
sector within the automotive industry has remained relatively stable. The consulted 
industry  stakeholder  reveals  that  their  company  alone  employs  approximately  35 000 
people, with a turnover of  4.7 billion, underscoring the scale and economic importance of 
pyrotechnics  in  automotive  safety  systems.  Despite  the  relevant  role  of  pyrotechnic 

319 These mechanisms are able to detect and to interrupt excess or high electrical voltage safeguarding the 
vehicle  battery.  They  prevent  potential  issues  or  dangers  for  passengers  in  case  of  a  crash  or  a 
malfunction of the car electrical system 

320 CLEPA, Fleet vehicles capture larger share of the EU aftermarket, 2023. 
321 CLEPA, Innovation in the Automotive Supply Industry, 2019. 

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components in the automotive industry, the interviewee highlighted that the majority of 
companies specialised in pyrotechnic manufacturers, such as those involved in fireworks, 
are characterised by small-medium size compared to automotive suppliers. 

Finally, the interview with the manufacturer indicates that there is a slow pace of product 
development, which typically lasts from 15 to 20 years. 

Safety  and  security  issues  linked  to  the  use  of  pyrotechnic  devices  in  the  automotive 
industry 

Evidence from the literature indicates that the use of pyrotechnics in the automotive 
industry, particularly in seatbelt pretensioners and airbags, presents several risks to 
health  and  safety.  These  risks  include  the  potential  for  accidental  explosions,  toxic 
emanations  during  normal  operation,  and  hazards  across  the  value  chain,  such  as  those 
encountered during manufacturing, transportation, and assembly.322 Additionally, the end-
of-life disposal and recycling of vehicles equipped with pyrotechnic devices pose further 
concerns323. 

For example, airbag gas generators can explode, leading to the breakage of components 
and the generation of high-velocity projectiles or missile-like behaviour as gas is rapidly 
expelled.324  Toxic  substances,  such  as  sodium  azide,  may  be  emitted  in  confined 
environments, presenting further health risks.325 Furthermore, the compaction of vehicles 
during disposal can trigger explosions, resulting in the release and dissemination of toxic 
propellants326. 

The harmonised standard EN ISO 14451:2013 provides presumption of conformity with 
the legal requirements under the Directive. To date two studies have been conducted on 
testing the quality of pyrotechnic articles according to the specifications of the harmonised 
standards327. Both studies show that under various testing methods products conforming 
to EN ISO 14451:2013 meet the security requirements for ensuring their quality. 

Finally, the interview with the manufacture indicates that the essential safety requirements 
are easily adaptable to new products, such as those designed for autonomous vehicles or 
larger airbags. 

322  Aufauvre,  L.  (2006),  New  Trends  for  Pyrotechnic  Automotive  Safety  in  the  European  Union,  33. 

International Pyrotechnics Seminar (IPS 2006), 2006, 509-512. 

323 Ibid. 
324 Ibid. 
325 Ibid. 
326 Ibid. 
327 Garaliu-Bușoi et al., Evaluation of the effects produced by triggering pyrotechnic articles for automotive 
use by exposure to various hazardous external stimuli, MATEC Web of Conferences 389:00021, 2024; 
Radeanu  et  al.,  Evaluation  of  the  safety  quality  of  automotive  pyrotechnic  articles  following  their 
exposure  to  triaxial  vibrations  with  predetermined  thermal  conditioning  cycles,  MATEC  Web  of 
Conferences 389:0054, 2024. 

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Conclusion 

The  interview  conducted  for  the  case  study  suggests  that  the  European  market  for 
pyrotechnic products is stable both in terms of number and size of companies and in its 
pace of product development. In terms of safety, the case study did not reveal any safety 
gaps in the Directive. Furthermore, the market’s stability and gradual pace of innovation 
mean there are no abrupt technological advancements necessitating revisions to existing 
safety requirements. 

154