COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE 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

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   EUROPEAN COMMISSION  Brussels, 12.9.2025  SWD(2025) 269 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE 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) 268 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE 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) 

1.  Background 

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. 
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 the Pyrotechnics 
Directive by setting up a system for the traceability of pyrotechnic articles.4 

The  environment  in  which  EU  pyrotechnics  legislation  operates  has  changed  since  the 
introduction of the substantive provisions in 2007 but also since the recast in 2013. Studies have 
been carried out on certain aspects of the Directive, but no comprehensive evaluation of the 
Directive  and  Implementing  Directive  2014/58/EU  has  yet  been  carried  out.  Against  this 
background, it was necessary to assess the overall performance of the Directive and whether it 
is still fit for purpose. In line with the Better Regulation Guidelines and Toolbox5, the evaluation 
examined  the  relevance,  effectiveness,  coherence  and  efficiency  of  EU  pyrotechnics 

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 the 
market of pyrotechnic articles (OJ L 154, 14.6.2007, p. 1, ELI: 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 Regulation (EEC) 
No 339/93 (OJ L 218, 13.8.2008, p. 30, ELI: http://data.europa.eu/eli/reg/2008/765/oj).  

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).  

5 European Commission, Better regulation guidelines, 2021; European Commission, Better Regulation Toolbox 

2023. 

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legislation,  as  well  as  its  EU  added  value,  considering  the  results  and  impacts  of  its 
implementation.  

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 March 20256. 

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.  These  shortcomings  were  mitigated  through 
triangulation of information from different sources and validation of findings in the stakeholder 
validation workshop. 

2.  Conclusions 

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.  

The Directive has led to an integrated single market for pyrotechnic articles, although the 
discretion  provided  by  the  Directive  with  regard  to  the  licensing  of  persons  with  specialist 
knowledge,  age  limits  and  the  restriction  or  prohibition  of  all  pyrotechnic  articles,  except 
categories F1 and F4, created some fragmentation.  

In terms of health and safety, the essential safety requirements, especially for categories F1, 
F4 and P1, do not seem  enough to sufficiently protect 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 has improved. Concerns remain, in particular, with regard to imported 
fireworks and the accessibility of high-risk pyrotechnics to consumers.  

The  Directive  has  not  effectively  prevented  security  threats  related  to  pyrotechnic  articles. 
Pyrotechnic  articles  are  increasingly  used  for  criminal  purposes,  such  as  to  attack  first-
responders and law enforcement personnel, the cracking of ATMs, but also organised crime. 
This  is  possible,  on  the  one  hand,  because  the  Directive  does  not  effectively  prevent  the 
diversion of legally manufactured pyrotechnic articles, especially when sold via online shops. 
On the other hand, the lack of a system for item-level tracking makes it difficult to trace back 
to  which  point  in  the  supply  chain  an  article  was  diverted.  At  the  same  time,  illegally 

6 Ibid. 

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manufactured pyrotechnic articles are traded on the black market. Enforcement and penalties 
seem insufficient to effectively deter illegal behaviour. 

Finally, the Pyrotechnics Directive does not fully ensure the protection of the environment 
from  the  negative  effects  of  pyrotechnic  articles,  such  as  chemical  contamination,  plastic 
pollution and distress for animals.  

Efficiency 

On the basis of 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 seem 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. 

Coherence 

The Directive is  coherent  with  other relevant  EU legislation, but  with  its  limited focus  on 
security, 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. 

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 

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Directive seems to be essential for cross-border trade in the internal market, Member States 
might have achieved better protection of safety and security if allowed to take action at national 
level on safety and security issues with regard to F4 fireworks. In light of circumvention of 
national  rules  via  cross-border  sales,  a  harmonised  approach  seems,  however,  preferable  to 
individual national measures. 

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, security seems even more important than ever. Similarly, 
environmental protection seems to have become more relevant since the Directive was adopted. 
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 the armed forces, the police or fire departments, 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. 

3.  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 in the Directive would facilitate more effective checks 
and help prevent abuse, notably online. Another way of intentionally or unintentionally 
circumventing  the  strict  rules  for  F4  fireworks  is  miscategorisation  into  the  less 

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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 
considered not 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. 

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