Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics : final report.
Date: 2025-11-03
Institutions: Directorate-General for Migration and Home Affairs
Subjects: EU Member State, accident prevention, action programme, civil defence, dangerous substance, explosive, fight against crime, firearms and munitions, fireworks, illicit trade, organised crime, report, terrorism

Feasibility study on 
reducing the security 
risks posed by the 
criminal misuse of 
pyrotechnics 

HOME-ISF-TF2-FW-EVA2-3097 

Final Report 

Written by an Ecorys-led Consortium 
October 2025 

 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Migration and Home Affairs 
Directorate D — Internal Security 
Unit D.2 — Counter-Terrorism 

European Commission 
B-1049 Brussels 

 
 
EUROPEAN COMMISSION 

Feasibility study on reducing the 
security risks posed by the 
criminal misuse of pyrotechnics 
HOME-ISF-TF2-FW-EVA2-3097 
Final Report 

2025 

 EN 

Directorate-General for Migration and Home Affairs 
HOME-ISF-TF2-FW-EVA2-3097 

Manuscript completed in October 2025 

First edition 

This document should not be considered as representative of the European Commission’s official position.  

Luxembourg: Publications Office of the European Union, 2025 

LEGAL NOTICE  

This document has been prepared for the European Commission. However, it reflects the views only of the authors, and 
the European Commission is not liable for any consequence stemming from the reuse of this publication. More 
information on the European Union is available on the internet (http://www.europa.eu). 

PDF 

ISBN 978-92-68-32932-0 

doi:10.2837/9601501  DR-01-25-018-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Contents 

List of tables and figures ................................................................................. 7 

List of abbreviations and glossary ................................................................. 9 

Abstract ........................................................................................................... 11 

Preface ............................................................................................................ 12 

1. 

Introduction ............................................................................................ 13 

1.1.  Background ..................................................................................................... 13 

2.  Methodology ........................................................................................... 22 

2.1.  Typology ......................................................................................................... 22 

2.2.  Methodology and limitations ........................................................................... 29 

3.  Analysis .................................................................................................. 38 

3.1.  Study area 1: Updated picture of the security problem ................................... 38 

3.1.1.  Introduction to the illegal pyrotechnics supply chain ................................ 38 

3.2.  Study area 2: Harmonisation of national laws and practices .......................... 55 

3.2.1.  Introduction to the legal framework .......................................................... 55 
3.2.2.  Gaps in the EU approach ......................................................................... 57 
3.2.3.  National criminal sanctions and deterrence ............................................. 61 
3.2.4.  Potential for harmonisation ....................................................................... 65 

3.3.  Study area 3: Potential use of substances covered by Regulation (EU) 

2019/1148 on explosive precursors to make illegal pyrotechnic articles ........ 69 

3.3.1.  Introduction ............................................................................................... 69 
3.3.2.  Legal and illegal manufacture of pyrotechnic articles and links with 

Regulation (EU) 2019/1148 ...................................................................... 74 
3.3.3.  Effectiveness in preventing misuse .......................................................... 84 
3.3.4.  Challenges from differences in national enforcement .............................. 85 

3.4.  Study area 4: Cross-border exchange of information and cooperation .......... 87 

3.4.1.  Introduction to cross-border exchange of information and cooperation ... 87 
3.4.2.  Extent of information exchange and cross-border cooperation on criminal 

misuse ...................................................................................................... 89 

3.4.3.  Barriers and hindrances to information exchange and cross-border 

cooperation ............................................................................................... 95 

3.5.  Study area 5: Tracking and tracing high-risk articles ...................................... 96 

3.5.1.  Introduction to the issue ........................................................................... 96 
3.5.2.  Existing mechanisms ................................................................................ 97 
3.5.3.  Law enforcement challenges in tracing illegal pyrotechnics ..................... 98 

3.6.  Study area 6: Strengthening customs enforcement ...................................... 102 

5 

Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

3.6.1.  Introduction to customs enforcement and the current legislative framework

 102 

3.6.2.  Challenges in detecting illegal imports ................................................... 106 
3.6.3.  Limitations of customs enforcement tools and procedures .................... 108 
3.6.4.  Role of intelligence and risk assessment ............................................... 111 

3.7.  Study area 7: Role of online sales/mail order sales ...................................... 112 

3.7.1.  Introduction to online trade of pyrotechnics ............................................ 112 
3.7.2.  Modus operandi for online trade ............................................................. 114 
3.7.3.  Modus operandi for delivery ................................................................... 118 
3.7.4.  Challenges ............................................................................................. 119 

3.8.  Case study A - From factory to the black market: Illegal manufacturing and 

diversion of pyrotechnics in the EU .............................................................. 123 

3.9.  Case study B - Explosions across borders: Security challenges in EU Member 
States most affected by pyrotechnic misuse ................................................ 124 

4.  Conclusions ......................................................................................... 126 

4.1.  Updated picture of the security problems (study area 1) .............................. 126 

4.2.  Harmonisation of national laws (study area 2) .............................................. 128 

4.3.  Potential use of substances covered by Regulation (EU) 2019/1148 on 

explosive precursors to make illegal pyrotechnic articles (study area 3) ...... 129 

4.4.  Cross-border exchange of information and cooperation (study area 4)........ 130 

4.5.  Tracking and tracing high-risk articles (study area 5) ................................... 131 

4.6.  Strengthening customs enforcement (study area 6) ..................................... 132 

4.7.  Role of online sales/mail order sales (study area 7) ..................................... 132 

4.8.  Overview of horizontal conclusions .............................................................. 133 

Annex I Bibliography ................................................................................... 136 

Annex II Case study A – From factory to the black market: illegal 

manufacturing and diversion of pyrotechnics in the EU .................. 154 

Annex III Country fiches case study A ....................................................... 165 

Annex IV Case study B - Explosions across borders: Security challenges 

in EU Member States most affected by pyrotechnic misuse ........... 198 

Annex V Country fiches case study B ........................................................ 206 

Annex VI Synopsis Report ........................................................................... 223 

6 

 
List of tables and figures 

Table 1 Key abbreviations .......................................................................... 9 

Table 2 Glossary of terms ........................................................................ 10 

Table 3 Updated scope of the study ......................................................... 29 

Table 4 Comparison data on arrests, charges and seizures for December 
2023-2024 .............................................................................................. 179 

Table 5 Spanish production of F4 flash bangers (2016) ......................... 191 

Table 6 Overview of stakeholder categories .......................................... 223 

Table 7 Completed scoping interviews ................................................... 226 

Table 8 Stakeholder response rate of targeted interviews ..................... 228 

Table 9 Completed targeted interviews .................................................. 228 

Table 10 Overview of stakeholders targeted through surveys and replies
 ............................................................................................................... 239 

Table 11 Agenda .................................................................................... 249 

Figure 1 Pyrotechnics life cycle ................................................................ 22 

Figure 2 Pyrotechnics - illegal and legal life cycle .................................... 23 

Figure 3 Overview of relevant stakeholders in the pyrotechnics supply 
chain ........................................................................................................ 27 

Figure 4 Overview of relevant rules on pyrotechnics ................................ 28 

Figure 5 Coverage of study areas ............................................................ 29 

Figure 6 Study areas ................................................................................ 35 

Figure 7 Diversion in the pyrotechnics lifecycle ........................................ 42 

Figure 8 Criminal use in the pyrotechnics lifecycle ................................... 47 

Figure 9 Entire pyrotechnics lifecycle ....................................................... 53 

Figure 10 Overview of relevant rules on pyrotechnics .............................. 55 

Figure 11 Life cycle of illegal and legal pyrotechnics ............................... 88 

Figure 12 Survey responses on the primary focus of cross-border 
cooperation and information exchange related to pyrotechnic articles. .... 92 

Figure 13 Survey responses from LEAs (N11) on the usefulness of the 
manufacturer name and serial number for product tracing ....................... 99 

Figure 14 Survey responses on key challenges faced by national LEAs in 
tracking and tracing ................................................................................ 100 

Figure 15 Survey responses on the effectiveness of current customs tools 
and procedures in assessing illegal imports of pyrotechnic articles ....... 106 

7 

 
 
 
Figure 16 Survey responses on the primary challenges customs 
authorities face in detecting illegal imports of pyrotechnics .................... 108 

Figure 17 Cycle of trade (legal/illegal) .................................................... 112 

Figure 18 Member States’ survey responses on what proportion of the 
pyrotechnics used for committing illegal acts are estimated to have been 
obtained online (N=47) ........................................................................... 115 

Figure 19 Member State survey responses on the most common ways to 
purchase illegal (either illegally produced or diverted) pyrotechnics online 
(N = 47) .................................................................................................. 116 

Figure 20 Overview of cycle ................................................................... 154 

Figure 21 Map of explosions with pyrotechnics related to the theft of a 
cocaine shipment in port of Antwerp ...................................................... 214 

Figure 22 Overview of responding authorities per Member States ......... 239 

Figure 23 Overview of responding authorities per category ................... 240 

Figure 24 Overview of industry organisations per Member State ........... 241 

Figure 25 Overview of responding industry organisations per category . 241 

Figure 26 Poll results on the level of agreement with the findings of area 1
 ............................................................................................................... 250 

Figure 27 Poll results on the level of agreement with the findings of area 2
 ............................................................................................................... 252 

Figure 28 Poll results on the level of agreement with the findings of area 3
 ............................................................................................................... 254 

Figure 29 Poll results on the level of agreement with the findings of study 
area 4 ..................................................................................................... 255 

Figure 30 Poll results on the level of agreement with the findings of area 5
 ............................................................................................................... 257 

Figure 31 Poll results on the level of agreement with the findings of area 6
 ............................................................................................................... 258 

Figure 32 Poll results on the level of agreement with the findings of area 7
 ............................................................................................................... 260 

8 

 
 
 
 
List of abbreviations and glossary 

Table 1 Key abbreviations 

Abbreviation 
ATM  

CBRN  

CE 

CRMF  

CSO 

Term 

Automated Teller Machine  

Chemical, Biological, Radiological and Nuclear  

Conformité Européenne 

Custom Risk Management Framework  

Civil Society Organisations 

DG GROW  

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs  

DG HOME  

Directorate-General for Migration and Home Affairs  

DG TAXUD  

Directorate-General for Taxation and Customs Union  

DSA 

ECHA 

EIO 

EU  

EuFIAs 

FEEM 

GDPR  

HMEs  

ICSMS 

IEDs  

IMI 

ISF  

ISG 

LEA  

MIAT 

MS 

MSA 

NEC 

OCG  

SAC 

  Digital Services Act 

  European Chemicals Agency 

European Investigation Orders 

European Union  

European Fireworks Association 

Federation of European Explosives Manufacturers 

General Data Protection Regulation  

Homemade Explosives  

Information and Communication System on Market Surveillance 

Improvised explosive devices  

Internal market Information System 

Internal Security Fund  

Inter Service Steering Group 

Law Enforcement Agency / Authority 

Military Institute of Armament Technology 

Member States 

Market Surveillance Authorities 

Net Explosive Content 

Organised Crime Group  

Schengen Associated Countries 

SCEPYLT 

The Explosives Control System to Prevent and Fight against Terrorism 

SIS II 

SMEs  

TATP 

TESTA 

UCC 

UN 

Schengen Information System II 

Small- and Medium sized Enterprises  

Triacetone Triperoxide 

Trans European Services for Telematics between Administrations Network 

Union Customs Code 

United Nations 

Source: Consortium’s elaboration. 

9 

 
 
 
 
Table 2 Glossary of terms 

Term 
CE marking (Conformité Européenne) 

Criminal misuse of pyrotechnics 

Diversion 

Explosive precursors 

F1, F2, F3, F4  

Flash powder 

Homemade Explosives 

Improvised Explosive Devices  

Illegal manufacturing 

Illegal pyrotechnics 

Illegal trade 

Net Explosive Content (NEC) 

Online sales 

P1, P2 

Pyrotechnic articles 

T1, T2 

Source: Consortium’s elaboration. 

Explanation 

Certification indicating conformity with EU safety 
standards for pyrotechnic articles.  
The use of pyrotechnic articles for illegal purposes, 
including violence, intimidation, property damage, etc. 
The redirection or misappropriation of legally 
manufactured or imported pyrotechnic articles from the 
authorised supply chain for unauthorised sale or use. 
Includes bypassing traceability, falsifying documents, or 
exploiting supply chain vulnerabilities. 
Chemical substances that can be used to manufacture 
explosives or pyrotechnic mixtures (e.g., potassium 
nitrate, ammonium nitrate, potassium perchlorate, 
aluminium powder). Subject to EU Regulation 
2019/1148. 
Categories of fireworks: F1 (very low hazard), F2 (low 
hazard), F3 (medium hazard), F4 (high hazard, for 
professional use only).  
A highly explosive mixture (often potassium perchlorate 
and aluminium powder) used in high-risk pyrotechnics 
(e.g., F4 flash bangers). Extracted for use in IEDs. 
refer to the explosive material itself, which is usually 
created using readily available chemicals and other 
materials 
make reference to the entire device used for carry out an 
explosion, including the explosive material along with 
other components. 
Production, assembly, or modification of pyrotechnic 
articles by individuals or groups without complying with 
legal requirements (e.g., without permits, using restricted 
substances, or in unsafe conditions). 
Umbrella term for pyrotechnics that are illegally 
manufactured, diverted, or traded, often ending up in 
criminal misuse. 
Sale and distribution of illegally manufactured or diverted 
pyrotechnics, often via online platforms, social media, or 
informal transactions. 
The amount of explosive material in a pyrotechnic article, 
relevant for assessing risk and regulatory compliance. 
The sale of pyrotechnic articles via e-commerce 
platforms, social media, or the dark web, often facilitating 
illegal trade and diversion. 
Categories of other pyrotechnic articles: P1 (low hazard), 
P2 (high hazard, for professional use). 
Any article containing explosive substances or mixtures 
designed to produce heat, light, sound, gas, or smoke 
through self-sustained exothermic chemical reactions. 
Classified into fireworks (F1–F4), theatrical pyrotechnics 
(T1, T2), and other pyrotechnics (P1, P2). 
Categories of theatrical pyrotechnic articles: T1 (low 
hazard), T2 (high hazard, for professional use). 

10 

 
 
 
 
Abstract 

This feasibility study investigates the extent of the threat posed by the 
criminal misuse of pyrotechnic articles across Europe. It responds to 
concerns about illicit manufacturing, diversion to criminal channels, and 
misuse of pyrotechnic articles in criminal activities, aiming to provide the 
European Commission with an updated and comprehensive picture of the 
pyrotechnic threat landscape. Adopting a phenomenon-based approach, 
the study examines pyrotechnic incidents both in isolation and as part of 
broader trends, exploring the socio-economic, legal, and criminal 
dynamics that contribute to their misuse. The primary objective is to 
provide the European Commission with a picture of the pyrotechnic threat 
landscape. This study examined the criminal misuse of pyrotechnic 
articles across Member States, identifying key vulnerabilities, cross-border 
dynamics and enforcement challenges. Overall, the evolving tactics of 
criminal actors highlight the need for a more integrated approach across 
Member States. The results of the study will support the European 
Commission in informing EU-level future responses.  

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Preface 

This  report  presents  the  findings  of  the  feasibility  study  on  reducing  the 
security  risks  posed  by  the  criminal  misuse  of  pyrotechnics  (HOME-ISF-
TF2-FW-EVA2-3097). 

The structure is as follows: 

●  Chapter 1 – Introduction: describes the policy context and 
provides a common understanding of how the study team 
approaches the different layers of the security problem in this piece 
of research; 

●  Chapter 2 – Methodology: outlines the methodological framework, 
including its strengths and weaknesses, challenges faced and 
mitigation measures for limitations in approach and information 
gathered; 

●  Chapter 3 – Analysis: provides a critical assessment of each 
research area, supported by triangulated quantitative and 
qualitative evidence, ensuring balanced analysis; 

●  Chapter 4 – Conclusions: presents a logical synthesis linking the 

analysis to the study findings, and drawing well-supported 
conclusions; 

●  Annexes (I to VIII): provide information to complement the main 

body of the report.  

12 

 
 
 
1. 

Introduction  

This study examines the evolving threat landscape surrounding the 
misuse of pyrotechnics. This first chapter presents the context for the 
subject of the study and provides the foundation for understanding the 
security risks posed by the criminal misuse of pyrotechnics. 

1.1. 

Background 

Pyrotechnic articles 

According to Directive 2013/29/EU, pyrotechnic articles refer to 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.1 They are classified according to the type of use into 
three main categories: fireworks,2 theatrical pyrotechnical articles,3 and 
other pyrotechnics articles (such as for vehicles).4 Each of these 
categories is further divided into multiple sub-categories. In particular, the 
main category of fireworks consists of four categories identified by the 
codes F1, F2, F3, and F4; the main category of theatrical pyrotechnic 
articles is divided into categories identified by the codes TI and T2; finally, 
the main category of other pyrotechnic articles is subdivided into the 
categories P1 and P2. 

2025: state of play 

Recent developments across Europe reveal that pyrotechnic materials are 
increasingly being repurposed for criminal and violent activities.  

New Year’s Eve is traditionally the peak moment for the use of 
pyrotechnics, and the 2025 celebrations were no exception. However, 
there is a growing and deeply concerning trend where pyrotechnics, 
increasingly being used for criminal purposes even during traditional times 
of celebration. During the New Year’s celebration in the Netherlands, 
police reported serious incidents across the country, including fireworks 

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). Link. Hereinafter: ‘Pyrotechnics Directive 2013/29/EU’.  
2   Article 3(2) of Directive 2013/29/EU: ‘firework’ means a pyrotechnic article intended for 

entertainment purposes. 

3   Article 3(3) of Directive 2013/29/EU: ‘theatrical pyrotechnic articles’ means pyrotechnic articles 
designed for indoor or outdoor stage use, including film and television productions or similar 
use. 

4   See ‘other pyrotechnic articles’ in Article 3 of Directive 2013/29/EU. 

13 

 
 
 
thrown at emergency officers,5 similarly to the situation in Belgium, where 
in Brussels the police arrested hundreds of people for disturbance, such 
as throwing Molotov cocktails6 and fireworks at the police.7 

While New Year’s Eve remains the single largest occasion for pyrotechnic 
use, the challenges associated with these materials extend well beyond 
the holiday season. Throughout the year, criminal groups repurpose 
pyrotechnical articles for violent and unlawful activities. This study 
examines the evolving threat landscape surrounding the misuse of 
pyrotechnics.  

In Sweden, a rapid surge in gang-related violence has prompted 
authorities to pay close attention to the role of encrypted messaging 
platforms in recruiting children into serious crimes, such as murders, 
attempted murders, and explosions, highlighting the growing use of 
pyrotechnics (and other weapons) in organised criminal activity.8 

Similarly, the region of Rotterdam experienced a disturbing surge in 
attacks using dangerous pyrotechnic material. In July 2025, over the 
course of just two nights, seven separate explosions caused significant 
structural damage.9 These are part of a broader trend affecting the 
Netherlands as the availability of powerful illegal pyrotechnics continues to 
pose serious risks to public security.10 

This is all supported by, inter alia, the illegal importation and illicit 
domestic manufacturing of pyrotechnic articles. For example, the 
Italian police seized one ton of illegal Chinese-made fireworks at the 
maritime port of Gioia Tauro.11 This seizure highlights the issue of 
imported pyrotechnics entering the country illegally. Separately, in the 
Campania region, known for illegal local production, police confiscated 
over three tonnes of dangerous, locally manufactured fireworks in 
Naples.12  

Recent events over the summer of 2025 have further highlighted the 
growing threat posed by the misuse of pyrotechnics. In June 2025, three 
19-year-old men in Poland were charged with gathering pyrotechnic 
materials and planning terrorist actions, including a school attack 

5      NL Times, Over 200 arrested on New Year’s “full of destruction and violence,” says police 

chief. Link; Dutch News, Dutch ring in New Year with fireworks, car fires and riot police. Link 

6   Britannica, Molotov cocktail definition. Link 
7   HLN (2025), Minstens 230 arrestaties, tientallen voertuigen uitgebrand en hulpdiensten 

aangevallen: de balans van nieuwjaarsnacht in Vlaanderen en Brussel (At least 230 arrests, 
dozens of vehicles burned out, and emergency services attacked: the toll of New Year's Eve in 
Flanders and Brussels. Link  

8   Politico (2025), Sweden eyes EU fireworks ban to blow up the mob. Link 
9   NL Times (2025), Seven explosions in Rotterdam region in two nights. Link 
10   Government of the Netherlands (2025), Offensive presents approach to tackle attacks using 

explosives Link 

11   Ansa (2025), One tonne of illegal fireworks seized at Gioia Tauro. Link  
12  

Il Mattino (2025), Dangerous explosive devices seized in Naples: The 'Champion Bombs' 
Phenomenon. Link  

14 

 
 
 
inspired by recent events in Norway.13 During the night of 13 to 14 July 
2025 alone, French police seized over 15,000 fireworks in the Paris 
region, conducting more than 250 checks and making 176 arrests, 43 of 
which were linked to the possession or use of powerful pyrotechnic 
devices. Authorities warned that dangerous fireworks are easy to buy 
online or in specialised shops. They have raised concerns about their 
frequent misuse in acts of violence and intimidation.14  

Call for solutions 

In the meantime, stakeholders across Europe call for measures to 
address the misuse of pyrotechnic articles. Law enforcement, medical 
professionals15 and politicians across EU Member States raise alarm bells. 
In Germany, a petition launched by the Berlin Police Union, directed at the 
government, calls for a nationwide ban on all privately used pyrotechnics, 
including rockets, firecrackers, and other consumer fireworks, due to 
concerns over criminal misuse, violence against emergency services, 
environmental pollution, noise disturbance, and public safety risks.16 Over 
two million signatures were collected within weeks, sparking further 
political debate. While the German government does not favour a 
nationwide ban, support seems to be there for stricter penalties for those 
misusing fireworks.17 In Belgium, mayors push for both a national ban and 
a European embargo on the sale of fireworks. The Association of Flemish 
Cities and Municipalities claims that four out of five mayors want to see a 
nationwide moratorium.18 It cites that an EU sales ban would prevent 
people from crossing a border to buy fireworks and, in this way, 
circumvent local bans. In the Netherlands, the government, in response to 
a series of explosions linked to, inter alia, organised crime, calls for EU 
cooperation. It also works with law enforcement and judicial authorities to 
clarify that Category F4 pyrotechnics, when possessed without the 
required specialised permits, may qualify as weapons under the Weapons 
and Ammunition Act.19 In April 2025, the Dutch Parliament voted to 
implement a nationwide ban on F2 category consumer fireworks.20 
However, the ban will not take effect until after the next New Year’s Eve 

13   Reuters. (2025). Poland detains 19-year-old man suspected planning terrorist attack - interior 

ministry. Link 

14   Le Figaro (2025), «Les choses sont en train de bouger»: comment la lutte contre les mortiers 

d’artifice dangereux s’intensifie. Link 

15   European Journal of Trauma and Emergency Surgery (2025), Firework injuries around New 

16  

Year’s Eve – epidemiology, injury patterns and risk factors. Link 
Inn, Petition · Bundesweites Böllerverbot, jetzt! (Bundesweites Böllerverbot, jetzt). Link  
 Gewerkschaft der Polizei (GdP), Bundesweites Böllerverbot, jetzt!. Link 

17   DW (2025), Germany: Thousands sign petition for fireworks ban. Link 
18   Politico (2025), Belgium mayor call for Europe wide ban sale fireworks. Link 
19   Government of the Netherlands (2025), Dutch Government commits to crackdown on-

explosives and dangerous fireworks Link 

20   F1 category articles for consumer use will not be affected by the ban in the Netherlands.. F3 

and F4 category articles are banned for consumers.Only certified professionals may obtain and 
use F3 and F4 pyrotechnic articles. 

15 

 
 
 
(2025–2026) due to potentially enormous compensation claims from 
pyrotechnics suppliers.21  

Various EU Member States have been particularly vocal at the EU 
level in calling for stronger action against the misuse of 
pyrotechnics. France and the Netherlands recently issued a joint non-
paper proposing a coordinated European response. The document 
highlights the increasing use of pyrotechnic articles in public disorder and 
urban violence. In addition, it raises concerns about the effectiveness of 
the current Conformité Européenne (CE) marking system,22 indicating that 
many tests are conducted by notified bodies in Asia, where oversight is 
limited, undermining the reliability of safety standards. The non-paper calls 
for strengthening EU legislation, improving enforcement, and reinforcing 
cooperation among Member States.23 

France’s strong engagement on the issue of pyrotechnic misuse was 
further demonstrated through a dedicated study visit held in June 2025. 
Organised by the French Ministry of the Interior, the visit brought together 
representatives from the European Commission and eleven Member 
States and included a live demonstration of various pyrotechnic articles 
and their potential misuse, followed by roundtable discussions focused on 
possible measures to address such a challenge.24  

Sweden has also emerged as a strong advocate for EU-level action, 
warning of a rapid shift in criminal tactics involving the use of fireworks as 
Improvised Explosive Devices (IEDs)25. Swedish ministers have stressed 
the urgency of addressing this trend before it spreads further across 
Member States. Sweden is calling for tougher rules on the illicit trade of 
fireworks, improved traceability of sales, closer cooperation between law 
enforcement and industry, and the use of technologies such as artificial 
intelligence to detect and prevent trafficking and misuse.26 

The urgency of addressing the misuse of pyrotechnics, long 
emphasised by stakeholders, has reached the EU level. In June 2025, 
the Council of the European Union adopted conclusions recognising 
pyrotechnics as a significant and evolving threat to public safety and 
internal security. The Council calls for stronger enforcement of Directive 

21   BBC (2025), Dutch vote to ban New Year's fireworks, but not just yet. Link 
22   European Commission, CE marking, Link  

The ‘CE’ marking is found on many products sold within the extended Single Market of the 
European Economic Area (EEA). It indicates that the product has been evaluated and meets 
the EU’s standards for safety, health, and environmental protection." 

23   Government of the Netherlands, République Française (2025), Modify the pyro directive to 

protect public order and safety. Link 

24   French Ministry of Interior (2025), Study visit to France on the misuse of pyrotechnic articles. 

25  

Source shared by the European Commission. 
Improvised explosive devices (IEDs) are often used by terrorists and criminals to cause harm, 
destruction, and fear. They can be made of chemical, biological, radiological, and nuclear 
(CBRN) agents. 

26   Politico (2025), Sweden eyes EU fireworks ban to blow up the mob. Link 

16 

 
 
 
2013/29/EU27, particularly regarding online access, product traceability, 
and harmonised classification. It recommends restricting high-risk 
categories such as F4, improving oversight of online sales, and enhancing 
cross-border cooperation with Europol to combat illicit trade and misuse.28 

More recently, in July 2025, the Mayor of Rotterdam, supported by other 
mayors of EU cities, issued a joint letter to the Council of the European 
Union, European Parliament, and European Commission calling for 
stronger EU-level action. Framing the issue as an urban security concern, 
the letter urges stricter rules and enforcement and considers the 
evaluations of Directive 2013/29/EU and Regulation (EU) 2019/1148 to be 
a good opportunity to give increased attention to the topic.29  

Framework in place and challenges to it 

At the EU level, the Pyrotechnics Directive 2013/29/EU sets out a 
harmonised approach to placing pyrotechnic articles on the market 
across the EU Member States and considers their specificities. These 
articles are divided into categories (fireworks, theatrical pyrotechnical 
articles, and other pyrotechnic articles) and sub-categories (see section 
3.2) to ensure appropriate levels of protection.30 Another important piece 
of legislation is Regulation (EU) 2019/1148 on explosives precursors, 
which imposes stringent controls on the sale and distribution of 
precursors, implemented by economic operators and Member State 
authorities. Its introduction made obtaining such precursors, which can 
be used to make Homemade Explosives (HMEs)31, more difficult. This 
Regulation establishes harmonised rules across EU Member States on the 
availability, introduction, possession, and use of explosive precursors. In 
particular, it imposes restrictions on access to certain explosive 
precursors. Furthermore, the Regulation focuses on enhancing reporting 
and monitoring mechanisms. It establishes detailed record-keeping and 
reporting requirements for economic operators handling these substances, 
enabling better tracking and early detection of suspicious activities. 

It is important to clarify, from the outset, that pyrotechnic articles, as 
defined in Directive 2013/29/EU, are explicitly excluded from the scope of 

27   Pyrotechnics Directive 2013/29/EU. 
28   Council of the European Union (2025), Council conclusions on combating trafficking of 

weapons and fighting threats stemming from firearms and pyrotechnic articles, 9907/25. Link 
29   Joint Letter of European Mayors (2025), Calling for measures against the misuse of explosives 

and pyrotechnics. Source shared by the European Commission.  

      Summary report of the workshop organised for this study (12 September 2025): a Member 

State authority reported that currently the Netherlands experiences nearly three explosions per 
day in criminal contexts, frequently involving heavy pyrotechnics. 

30   Pyrotechnics Directive 2013/29/EU. 
31   Homemade Explosives (HMEs) refer to the explosive material itself, which is usually created 
using readily available chemicals and other materials. Improvised Explosive Devices (IEDs) 
make reference to the entire device used for carry out an explosion, including the explosive 
material along with other components. 

17 

 
 
 
Regulation (EU) 2019/1148 and its restrictions. Article 2(2)(b) of the 
Regulation states that it does not apply to pyrotechnic articles covered by 
Directive 2013/29/EU. This exemption applies to finished pyrotechnic 
products. Nonetheless, the Regulation remains relevant in the context of 
this study when looking at the illegal manufacturing of pyrotechnic articles, 
as it governs access to certain chemical substances that are typically used 
in the production of pyrotechnic mixtures. These substances, when 
acquired outside legal channels (from non-authorised actors) or diverted 
from legitimate supply chains, may be used unlawfully to produce illegal 
pyrotechnics. Therefore, while pyrotechnic articles themselves are 
excluded, the Regulation plays a critical role in controlling access to the 
raw materials that could be misused in their illicit production.32 

Despite the restrictions, criminals access the more strictly regulated 
pyrotechnic articles.  

Europol identified the illegal use of pyrotechnics as a significant threat to 
public safety and security in the Union.33 Criminal organisations exploit the 
materials for violent crimes and illegal trade. A recent cross-border action 
day in January 2025 resulted in the seizure of powerful explosive 
pyrotechnics. The Agency also reported arrests and seizures of criminal 
assets, such as powerful pyrotechnics, and the reliance of criminals on 
minors to perform attacks.34  

There are reports of increased misuse of pyrotechnic articles by criminal 
groups, especially for intimidation against other rival groups or law 
enforcement authorities.35 In the past years, the use of category F4 
pyrotechnic articles (products such as flash bangers) in IEDs (e.g., to carry 
out attacks against automated teller machines, ATMs) has increased in 
some EU Member States.36  

As an unwanted consequence of the stringent control on explosive 
precursors, pyrotechnic articles have become a more attractive 
alternative to criminals for manufacturing IEDs.  

32   See study area 3 in Chapter 3. 
33   Europol (2024), Pyrotechnics in the EU: State of Play. Source shared by the European 

Commission.  

34   Europol (2025), Violence as a service: criminals hire criminals. Link  

Europol (2024), The recruitment of young perpetrators for criminal networks. Link 
35   Europol (2024), Pyrotechnics in the EU: State of Play. Source shared by the European 

Commission.  

36   This has been observed in the Netherlands, Belgium, Germany, France and Sweden. See for 

example: 
A.S Fabre, N. Florquin, M. Schroeder (2023), Illicit firearms ammunition and other explosive 
munitions in the European Union, Link; Justice and Home Affairs Council of the Netherlands, 
Modify the Pyrotechnics Directive for the sake of public order and safety. Non-paper by the 
Netherlands 2023. Link; Europol (2022), Heavy fireworks off the market for safer holidays, Link; 
Regeringens (2023), Skjutvapen och explosiva varor – skärpta straff för de allvarligare brotten, 
proposition 2023/24:33 (Firearms and explosive materials – tougher penalties for the more 
serious crimes), Link; Polisen (2022), Lägesrapport avseende explosiva och andra farliga 
ämnen. Link 

18 

 
 
 
Low-risk category pyrotechnics do not require a licence for purchase, 
while such a requirement (‘specialist knowledge’) is set for (licensed) 
professional-use pyrotechnics. Pyrotechnic articles are subject to age 
restrictions, depending on their type.37 Access from the public is severely 
restricted for explosive precursors (in this case, age restrictions are not 
applicable), and a license is required for certain substances (for 
concentrations above thresholds, as indicated in Annex 1 of Regulation 
(EU) 2019/1148). Explosive precursors are subject to a number of controls 
(in addition to licensing), such as sales monitoring (requirement for the 
suppliers to verify identity and license before the sale and keeping a 
record of all transactions for restricted precursors), mandatory reporting of 
suspicious transactions, thefts, or losses (within time limits and to the 
national contact points), and use restrictions (for legitimate and 
documented purposes, e.g. agricultural), labelling and provision of 
information. In case of pyrotechnic articles, manufacturers and importers 
have to follow certain requirements (registration number for articles, 
product labelling, technical documentation), but retail-level traceability 
(e.g., tracking individual buyers) is not required for consumer-grade 
pyrotechnic articles, such as fireworks. 

For the enforcement, both EU-level instruments require Member States to 
define and enforce sanctions and penalties at the national level, resulting 
in a wide disparity at the national level. 

For the Pyrotechnics Directive, this diversity means that similar infractions 
may be treated with varying degrees of severity across the EU. In some 
Member States, relatively lenient penalties may fail to deter non-
compliance, potentially increasing the risk of accidents and misuse. 
Moreover, this inconsistency complicates cross-border enforcement and 
undermines the uniformity of the EU’s response to security threats 
involving pyrotechnic articles.38  

In addition, the Pyrotechnics Directive 2013/29/EU (in contrast to Directive 
2014/28/EU on civil explosives39) does not set out measures to be 
adopted by Member States concerning the potential public security threats 
posed by pyrotechnic articles, such as per-item traceability and transfer 
rules, but allows Member States to further regulate, at the national level, 
access to pyrotechnics on the grounds of public security, with the 
exception of F4 category pyrotechnic articles.  

37   Member States have the possibility to set additional restrictions based on grounds of public 
order, security, health and safety, or environmental protection (Article 4.2 Pyrotechnics 
Directive). For instance, some Member States introduce limitations to the use of pyrotechnic 
articles during certain periods of time (e.g. New Year’s Eve).  

38   European Commission, Evaluation study of pyrotechnics’ legislation, Interim Report. 
39   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 for civil uses (recast) Text with EEA relevance, OJ L 96, 
29.3.2014, p. 1–44.  

19 

 
 
 
As indicated above, differences exist at the national level. The current 
context underlines that Member States remain vulnerable to criminals 
who might benefit knowingly or unknowingly from potential gaps and/or 
differences in the enforcement level across Member States.  

However, key questions are: “What and where are these gaps and 
shortcomings, and what are the security implications of criminal misuse of 
pyrotechnics in the EU?”. This study aims to address these issues.  

The feasibility study 

To investigate the extent of the threat posed by the misuse of 
pyrotechnics, the European Commission assigned the Ecorys 
Consortium40 the task of carrying out a feasibility study on reducing the 
security risks posed by the criminal misuse of pyrotechnics. This initiative 
responds to increasing concerns about the illicit manufacturing, diversion, 
and use of pyrotechnics in criminal activities across the EU. The study is 
essential to provide the European Commission with a comprehensive and 
updated picture of the pyrotechnic threat landscape, enabling informed 
decisions on future policy measures and regulatory actions. 

This study takes a phenomenon-based approach to investigate the 
criminal misuse of pyrotechnics across the EU. By examining pyrotechnic 
articles as isolated incidents and as part of a broader trend, the study aims 
to understand the underlying causes, patterns, and impacts of illegal 
pyrotechnic activities.41 The phenomenon-based perspective allows for a 
comprehensive exploration of how socio-economic, legal, and criminal 
dynamics intersect in the misuse of fireworks.  

This study starts with a typology of the supply chain and illegal 
activities to create a common understanding of the complexities of 
pyrotechnic misuse. The legal supply chain includes manufacturing, 
distribution, trade, and consumption, all regulated to ensure safety. 
Pyrotechnics are produced by licensed manufacturers, distributed to 
wholesalers and retailers, and sold to consumers who meet legal 
requirements such as a certain age and specialist knowledge. Conversely, 
illegal pyrotechnics encompass illegally manufactured products, legally 
produced items diverted into unauthorised channels, and those distributed 
and sold illegally. 

It should be noted that illegal pyrotechnics clearly occur at the 
intersection of economic and criminal perspectives. Financial 
incentives drive unlawful actions and undermine regulations, business and 

40    In this assignement, Ecorys Europe is supported by Fondazione SAFE, Spark Legal and Policy 

Consulting and the Netherlands Organisation for Applied Scientific Research (TNO). 

41   The study team investigated whether other types of pyrotechnic articles than fireworks pose a 
threat to security/are misused for criminal purposes. Information can be found in study area 1.  

20 

 
 
 
safety. The following considerations underpin the typology presented in 
Chapter 2. 

In illegal pyrotechnics manufacturing, the economic perspective entails 
low-cost production, black-market competition and financial losses for 
legitimate manufacturers. Low-cost production means that safety 
regulations and quality standards might be bypassed to reduce costs. The 
black market often sells products at lower prices, undercutting fair 
competition. Finally, legitimate manufacturers' position in the market 
erodes, and government tax revenue decreases. The criminal perspective 
includes violating laws regulating explosive materials and manufacturing. It 
also focuses on the use of stolen or illegally manufactured precursors. 
Finally, it deals with endangerments to public safety due to illegal 
manufacturing practices being unsafe. 

In diverting pyrotechnics, the economic perspective entails unregulated 
resale of diverted goods in informal or black markets for personal profit or 
to fund other illegal activities. It also considers undermining legal markets, 
creating unfair competition. Finally, diversion can also cause tax losses 
and evade customs duties. From a criminal angle, the diversion of 
pyrotechnics includes theft of pyrotechnics, e.g. from storage or transport, 
as well as smuggling and corruption, as well as the falsification of 
documentation. 

Further, from an economic point of view, the illegal trade of diverted or 
illegally manufactured pyrotechnics generates profits for sellers and 
creates market demand from buyers. It might also contain low-cost 
components, as these items can be cheaper. Ultimately, legitimate 
businesses also lose money and the government's tax income.42 From a 
criminal angle, trading in unlicensed or stolen pyrotechnics violates the 
law. There is also a possible link to organised crime, as smuggling 
networks overlap with other criminal activities, such as funding terrorism.43    

42   Europol (2018), International cooperation disrupts illegal fireworks network. Link 
43  

Interpol (2023). Tracing terrorist finances. Link. Illegal trade in goods by organised crime can 
be a source of other criminal activities/terrorist funding. The team investigates whether profits 
from illegal pyrotechnic articles finance other criminal activities.   

21 

 
 
 
 
 
2. 

Methodology 

This chapter outlines the typology used for this study (section 2.1) and 
describes the methodology applied (section 2.2). 

2.1. 

Typology 

For the purposes of this study, it is essential to elaborate on the key terms 
used to describe the phenomenon of the criminal misuse of pyrotechnics. 
This allows for a common understanding of how the different layers of the 
security problem in this study are defined. 

Supply chain for pyrotechnics 

In simple terms, the supply chain includes legal manufacturing, 
distribution, trade and consumption. Pyrotechnics are produced by 
licensed manufacturers, adhering to rules and regulations (legal 
manufacturing). After production, the pyrotechnics are transported to 
warehouses, wholesalers and retailers. This logistics part ensures the 
pyrotechnics remain secure and documented (legal distribution). After this, 
the products are sold by licensed retailers to end-users, professionals or 
consumers. They verify whether buyers comply with the legal 
requirements, such as age or permits for professional use (legal trade). 
Finally, the pyrotechnics are used by consumers or professionals for lawful 
purposes, such as celebrations or industrial applications. They follow 
safety guidelines and legal restrictions (professional use/consumer use). 

Figure 1 Pyrotechnics life cycle 

Source: Consortium’s elaboration. 

Illegal pyrotechnics 

This umbrella term encompasses three related concepts: illegal 
manufacturing, diversion, and illegal trade of pyrotechnics. All three 
connect to economic and criminal considerations, which can ultimately 

22 

 
 
 
lead to criminal misuse of pyrotechnics.44 This definition also includes 
counterfeited pyrotechnic articles, as they are produced without required 
permits and in non-compliance with the requirements of the Pyrotechnics 
Directive. 

Figure 2 Pyrotechnics - illegal and legal life cycle 

Source: Consortium’s elaboration. 

Illegal pyrotechnics manufacturing  

Illegal pyrotechnics manufacturing is understood as individuals or 
(criminal) groups producing, assembling or modifying pyrotechnic articles 
intentionally not complying with the legal requirements as laid out in the 
Pyrotechnics Directive.45 This definition includes also counterfeited 
pyrotechnic articles, as they are produced without required permits and in 
non-compliance with the requirements of the Pyrotechnics Directive. 

Several additional key characteristics are:46 

●  This can occur in underground factories or labs, which the illegal 
manufacturer aims to keep hidden due to the absence of proper 
permits and licenses. Oversight is deliberately evaded. 

●  Substances are not sourced through approved channels for 
purchase and use. They are often classified as restricted or 
controlled, such as explosive precursors.  

●  Safety standards are likely to be neglected, which leads to risks of 

accidents and related health implications.47 

●  The motivation behind the illegal manufacturing could be for 

commercial profit, personal use or criminal intent. 

44   To understand the dynamics of illicit pyrotechnics manufacturing, diversion and misuse, the 

study mostly relies on a criminological framework grounded in situational crime prevention and 
routine activity theory. This combines a focus on systemic weaknesses and criminal intent to 
drive the illicit activities surrounding pyrotechnics. More information can be found here: Link 

45   Pyrotechnics Directive 2013/29. 
46  
Information on explosives. Link  
47   Safety risks posed by pyrotechnic materials. Link 

23 

 
 
 
 
●  Risks associated with illegal pyrotechnics manufacturing are public 

safety risks, environmental damage, economic impacts, and 
national security concerns. 

Diversion of pyrotechnics  

Diversion of pyrotechnics entails legally manufactured or imported 
pyrotechnic articles lawfully manufactured or imported legally that are 
being redirected or misappropriated from the intended and authorised 
supply chain, ultimately for unauthorised sale or use.  

Several additional key characteristics are:48 

●  Pyrotechnics are moved outside of the authorised supply chain, for 

example, by bypassing traceability requirements or customs 
controls. 

●  The destination of the goods is hidden by falsifying or misusing 

documentation and permits. 

●  Vulnerabilities in the supply chain, such as storage facilities, 

transport schemes, etc., are exploited. 

●  The motivation behind the diversion of pyrotechnics could be for 

commercial profit, personal use or criminal intent. 

●  Risks associated with pyrotechnics diversion include public safety 
risks, economic impacts, undermining rules and regulations, and 
(national) security concerns. 

Two key areas for diversion within the supply chain are highlighted: 
diversion from distribution and trade diversion. 

Diversion from distribution refers to when pyrotechnics are in transit 
between the producer and the wholesaler, retailer or warehouses. For 
example, diversion from distribution occurs when products are stolen 
during transport by postal services, storage or when the origins of 
shipments are hidden (e.g., mislabelling) to enable redirection to the illegal 
market. Trade diversion happens when individuals or criminals buy legal 
pyrotechnics from sellers without proper licenses or verification of 
specialist knowledge. This also entails the purchasing of pyrotechnics from 
third countries without specialist knowledge and thereby, illegally importing 
them into the EU. 

Several additional key characteristics are identified: 

48   Based on discussions with the European Commission and a similar mapping conducted for 

project POSEIDON funded under the Internal Security Fund. Link 

24 

 
 
 
●  Sales can occur online and offline. Online sales can occur, for 

example, via online shops, social media, or dark web platforms. 
Offline sales could occur in physical shops. 

●  Buyers tend to remain anonymous, which complicates regulatory 

oversight and taxation. 

● 

Illegally traded pyrotechnics are often sold at a lower price.49 

●  Trade diversion can be cross-border, which complicates 

enforcement efforts.50 It can also include smuggling networks.51 

●  Diversion includes parties, such as middlemen, distributors and 

sellers. 

Criminal misuse of pyrotechnics 

Illegal pyrotechnics clearly occur at the intersection of economic and 
criminal perspectives. Financial incentives drive unlawful actions and 
undermine regulations, business and safety.  

In illegal pyrotechnics manufacturing, the economic perspective entails 
low-cost production, black-market competition and financial losses for 
legitimate manufacturers. Low-cost production means that safety 
regulations and quality standards might be bypassed to reduce costs. The 
black market often sells products at lower prices, undercutting fair 
competition. Finally, legitimate manufacturers' position in the market 
erodes, and government tax revenue decreases. The criminal perspective 
includes violating laws regulating explosive materials and manufacturing. It 
also focuses on the use of stolen or illegally manufactured precursors. 
Finally, it deals with endangerments to public safety due to illegal 
manufacturing practices being unsafe. 

In diverting pyrotechnics, the economic perspective entails unregulated 
resale of diverted goods in informal or black markets for personal profit or 
to fund other illegal activities. It also considers undermining legal markets, 
creating unfair competition. Finally, diversion can also cause tax losses 
and evade customs duties. From a criminal angle, the diversion of 
pyrotechnics includes theft of pyrotechnics, e.g. from storage or transport, 

49  

Illegal good can be often sold at a lower price than the legal ones. This can be linked to several 
factors, such as producers using lower quality materials and not having to comply with 
requirements established by lawmakers (such compliance increases the cost of legal products 
for manufacturers); and, sellers/buyers avoiding taxes on goods and sellers offering lower 
prices to attract buyers.  
Rai, Fuochi d'artificio, Traffico redditizio (Fireworks. A profitable trade). Link 
OECD, Illicit Trade. Link 

50   Europol reported cases of cross-border investigations into illegal pyrotechnics.  
E.g. Europol (2022), Heavy fireworks off the market for safer holidays. Link 

51   Europol (2022), 350 tonnes of dangerous fireworks seized in Germany and the Netherlands. 

Link 

25 

 
 
 
as well as smuggling and corruption, as well as the falsification of 
documentation. 

Further, from an economic point of view, the illegal trade of diverted or 
illegally manufactured pyrotechnics generates profits for sellers and 
creates market demand from buyers. It might also contain low-cost 
components, as these items can be cheaper. Ultimately, legitimate 
businesses also lose money and the government's tax income.52 From a 
criminal angle, trading in unlicensed or stolen pyrotechnics violates the 
law. There is also a possible link to organised crime, as smuggling 
networks overlap with other criminal activities, such as funding terrorism.53  

Finally, all three concepts of illegal manufacturing of pyrotechnics, 
diversion and the illegal trade thereof, lead to opportunities for criminal 
misuse of pyrotechnics. This refers to criminals' use of pyrotechnics for 
illegal purposes. Often, the explosive, incendiary or disruptive nature of 
pyrotechnics is used. Various types of criminal misuse can be identified: 

Violence, for example, during riots, protests or vandalism.  

Linked to this is also the targeted violence, intimidation and coercion by 
organised crime groups in criminal rivalries 

Theft and sabotage, such as using pyrotechnics to force open bank cash 
dispensers (ATMs) or igniting fires in commercial establishments. 

These types of criminal misuse are deployed by differently motivated 
groups, such as organised crime groups and individual, more opportunistic 
criminals, and sometimes terrorists and extremists. The motivation behind 
using pyrotechnics for criminal use might vary from destruction to 
intimidation and even symbolism when amplifying a message. Its impact is 
significant because it causes economic damage, security concerns, and 
threats to public safety.54 Criminal misuse of pyrotechnics is usually 
directed at specific targets, in other words, ATMs to break open, rival 
gangs to attack, or public spaces and anti-riot police for riots. Finally, the 
misuse of pyrotechnics is enabled by the absence of control and oversight 
mechanisms, such as weak regulation or enforcement or limited 
surveillance (like streets at night or online platforms on the dark web).  

In addition, criminals might use pyrotechnics to create IEDs by extracting 
the flash powder from the pyrotechnic articles.55 The use of pyrotechnics 

52   Europol (2018), International cooperation disrupts illegal fireworks network. Link 
53  

Interpol (2023). Tracing terrorist finances. Link 
Illegal trade in goods by organised crime can be a source of other criminal activities/terrorist 
funding. The team investigates whether profits from illegal pyrotechnic articles finance other 
criminal activities.  

54   As observed, for example, in the Netherlands in the organised crime rivalries. See study area 1 

and case study B for more information. 

55   Europol, Pyrotechnics in the EU: State of Play 2024 (source not available to the general 

public). 

26 

 
 
 
in terrorism seems somewhat limited, but might witness an increase in 
popularity as rules on explosives precursors have become stricter. 

Criminal misuse of pyrotechnics is the final stage in the illegal lifecycle. 
Illegal manufacturing and diversion supply the products, illegal trade 
distributes them to criminals, and it ends with their use.  

Addressing illegal pyrotechnics 

Addressing the issue of illegal pyrotechnics needs to take into account 
economic and security dimensions. For illustrative purposes, the report 
presents a simplified overview of the institutional stakeholders 
involved in the pyrotechnics lifecycle. Within the EU, financial aspects, 
such as market regulation, supply chain oversight, and industry 
competitiveness, fall under the purview of DG GROW56 and DG MOVE57, 
which oversee legal frameworks for manufacturing, trade, and transport. 
Security implications, such as the prevention of diversion, smuggling and 
misuse for criminal and terrorist activities, are primarily the responsibility of 
DG HOME, focusing on law enforcement and public safety. Together, 
economic and security challenges can be addressed.  

Figure 3 Overview of relevant stakeholders in the pyrotechnics supply 
chain 

Source: Consortium’s elaboration. 

The Pyrotechnic Directive (2013/29/EU) regulates the pyrotechnics supply 
chain, which is overseen by DG GROW.58 DG MOVE is in charge of the 
transport of dangerous goods, and the European Chemicals Agency 

56   European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and 

SMEs (GROW). 

57   European Commission, Directorate-General for Mobility and Transport (DG MOVE). 
58   The Civil Explosives Directive (2014/28/EU) excludes pyrotechnics. However, it intersects with 

the Pyrotechnics Directive when it comes to criminal misuse and, in particular, when 
pyrotechnic materials are repurposed for IED.  

27 

 
 
 
 
 
(ECHA) is responsible for the assessment of substances that might be 
used in pyrotechnic articles. Member States enforce compliance through 
licensing, transport checks, and market surveillance. The illegal supply 
chain involves violations of rules, such as Regulation 2019/1148 
(Explosives Precursors59) and Directive 2017/541 (Counter-Terrorism60). 
DG HOME, Europol, and Eurojust tackle illegal manufacturing, smuggling, 
and criminal use. DG JUST is involved in complying with consumer 
protection laws. DG TAXUD is in charge of the import/export procedures 
of goods with third countries. Frontex and Member States monitor borders 
and black markets. This complex collaborative framework protects the 
legal market and combats illegal activities. 

Figure 4 Overview of relevant rules on pyrotechnics 

Source: Consortium’s elaboration. 

The primary focus of this study is on the criminality or criminal 
misuse61 of pyrotechnics, manufactured illegally or legally and 
diverted. Untangling the economy from security is difficult. Through the 
case studies, the study looks at the security component and the illegal 
manufacturing and diversion of pyrotechnics. The seven study areas look 
at different elements of the legal and illegal supply chain, shedding light on 
the security risks posed by the misuse of pyrotechnics.  

59   For example, the extraction of materials from fireworks to build a HME. 
60   For example, when manufacturing, purchasing or transporting is done with a terrorist intent. 
61   Criminality focuses on the illegal activities related to pyrotechnics throughout the chain, 

including smuggling, manufacturing, and selling. Misuse only focuses on the specific use of 
illegal pyrotechnics, so committing a crime resulting in physical or material harm. 

28 

 
 
 
 
Figure 5 Coverage of study areas 

Source: Consortium’s elaboration. 

2.2. 

Methodology and limitations 

This section presents the methodology and the main limitations 
encountered during the research.  

Overall methodological approach 

The study's primary objective is to develop an updated overview of the 
security challenges linked to the misuse of pyrotechnics. The table 
below illustrates the scope of the study, more precisely, the material 
scope, the time period considered, the geographical scope and the key 
stakeholders affected. 

Scope’s 
dimension 

Material 
scope 

Temporal 
scope 

Geographical 
scope 

Table 3 Updated scope of the study 

Explanation 

•  Relevant policy and legislative frameworks (Directive 2013/29/EU and 

Regulation (EU) 2019/1148). 

•  The study focuses on the period from 2019 (the adoption of Regulation 

(EU) 2019/1148) to 2024. 

•  Relevant information before 2019, if needed, will be used to better 

understand the context and the key issues at stake. In contrast, significant 
events and other information related to 2025 will be included only to the 
extent possible and in agreement with the European Commission. 

•  The study covers all 27 EU Member States and Schengen Associated 

Countries (SACs) (i.e. Iceland, Liechtenstein, Norway and Switzerland). 
•  Particularly focus on those Member States most affected by pyrotechnic-
related security issues: Belgium, Germany, France, the Netherlands, and 
Sweden. 

•  EU Member States with a strong pyrotechnic industry, such as France, 

Germany, Italy, Poland, Portugal, and Spain. 

29 

 
 
 
Scope’s 
dimension 

Explanation 

Key 
stakeholders 
(non-
exhaustive, 
see Annex 
VI) 

•  Relevant national authorities of EU Member States and SACs. 

•  Relevant EU Institutions and agencies, such as Europol and Eurojust. 
•  Notified bodies. 
•  Action Leader of the EMPACT Firearms O.A. 1.4 ‘Explosives & 

pyrotechnics’. 

•  Relevant industry representatives. 
•  Relevant other stakeholders, such as independent researchers on this 

topic, and EU projects related to parts of this study. 

Source: Consortium’s elaboration. 

The methodological approach for the study was divided into three tasks, 
in line with the ToR:  

●  Task 1: Study Design; 

●  Task 2: Consultation Activities; 

●  Task 3: Synthesis and Reporting. 

These tasks resulted in key deliverables: 

●  Draft Inception Report; 

●  Final Inception Report; 

●  Revised Final Inception Report; 

●  Draft Interim Report; 

●  Final Interim Report; 

●  Revised Final Interim Report; 

●  Draft Final Report; 

●  Synopsis Report (as Annex to the Draft Final Report); 

●  Final Report; 

●  Revised Final Report.  

To support the coordination of these tasks, the study team organised key 
meetings linked to these deliverables,62 along with regular online progress 
meetings with the European Commission. 

This study adopts a mixed-methods approach, integrating qualitative 
and quantitative data collection and analysis. 

62   Kick-off meeting, first inception meeting, second inception meeting, interim meeting and final 

meeting.  

30 

 
 
 
 
The research process began with extensive desk research and scoping 
interviews, which helped refine the methodological approach to better 
align with the study’s objectives. 

The stakeholder engagement process included interviews, targeted 
surveys, and detailed case studies. Seven key study areas were explored, 
each forming a dedicated chapter that responds to specific research 
questions. The case studies offered deeper insights into particular areas of 
concern, allowing for a more nuanced understanding of the pyrotechnics-
related security challenges. 

A targeted consultation strategy was implemented to ensure broad and 
representative feedback. This included six scoping interviews, 72 
responses to two targeted surveys, 30 targeted interviews, responses to a 
follow-up questionnaire from 14 Member States, and written contributions. 
These activities were designed to capture diverse perspectives and gather 
both qualitative and quantitative data. Follow-up exchanges with national 
authorities were particularly valuable in complementing survey responses 
and enhancing the accuracy and completeness of the data collected. The 
results of these consultation activities are documented in Annex VI, 
Synopsis Report. 

Two case studies were conducted to collect in-depth information on 
specific areas of particular interest for the study. The information gathered 
via the case studies was integrated to deliver comprehensive responses to 
the study questions. 

All data collected throughout the study were systematically processed, 
analysed, and validated. An in-depth analysis was conducted using a 
triangulation approach, which involved comparing and integrating 
information from multiple sources to ensure the robustness and reliability 
of the findings. Where uncertainties or ambiguities arose, the team 
engaged in further discussions with the European Commission and 
relevant stakeholders to clarify and verify the information. This iterative 
process strengthened the evidence base and ensured consistency across 
data sources. When this was not possible, the study team flagged the 
limitations of the research to the European Commission. 

A workshop was organised with stakeholders. The purpose of this session 
was to confirm whether the conclusions reflected stakeholder experiences, 
to identify any gaps or overlooked aspects, and to assess the relevance 
and applicability of the study’s outcomes. 

Adjustments to the methodology 

Based on discussions within the European Commission (between DG 
HOME and DG GROW), adjustments to the methodology were adopted. 

31 

 
 
The ToR for this study included assessing the feasibility of the potential 
options to tackle the growing security problems posed by the criminal 
misuse of pyrotechnic articles. During the inception phase of the study, the 
European Commission requested the team to adopt a more summative 
approach (rather than a forward-looking approach) and focus on the 
updated picture of the pyrotechnic threats. Suggestions from stakeholders 
on future improvements are presented, without anticipation of any future 
decisions. 

The study builds upon previous studies and research conducted in parallel 
by the European Commission (DG GROW and DG HOME), such as the 
evaluation of the pyrotechnics and civil explosives legislation and the 
evaluation and impact assessment of legislation on explosive precursors, 
to avoid duplication. This required some changes to the methodology and 
consultation material. A key priority for this study is to ensure 
complementarity with existing work, rather than replicating it. In this 
respect, DG GROW shared interim results from its ongoing evaluation of 
pyrotechnics and civil explosives legislation. This collaboration helped the 
team refine its approach and avoid overlaps with DG GROW’s findings. In 
addition, DG HOME emphasised the importance of aligning the study with 
other internal initiatives, encouraging the team to focus on aspects not 
covered by parallel evaluations. This guidance informed the development 
of a targeted methodology that complements the broader regulatory 
landscape, ensuring that the study contributes unique insights and 
supports the European Commission’s decision-making without 
redundancy. 

Following feedback from the European Commission, the study’s 
methodology was revised. The final version includes seven study areas 
instead of the originally planned eight. The removed area, number 8 
(covered policy measures/options), was excluded to avoid formulating 
recommendations for future actions, as this responsibility remains with the 
European Commission. Additionally, the number of case studies has been 
reduced from three to two, allowing for a more focused analysis and 
minimising overlap with other elements of the study. 

Where relevant, suggestions based on input from stakeholders on 
potential measures to tackle the misuse of pyrotechnic articles are 
presented. This is done without anticipating the assessment of policy 
measures/options by the European Commission that are planned to be 
implemented in other studies/initiatives.  

Study areas and case studies  

To deliver on the objectives of the study, seven study areas and two 
case studies (indicated below) serve as a guiding framework for the 

32 

 
 
research. They focus on key areas of interest, ensuring the study aligns 
with its objectives and addresses the core concerns related to pyrotechnic 
threats.  

Area 1: Updated picture of the security problem 

This area examines how pyrotechnics are illegally manufactured, diverted, 
and traded. It also addresses the security challenges posed by criminal 
misuse, including cross-border threats. 

Area 2: Harmonisation of national laws and practices 

This area explores the potential gaps in the EU's approach to criminal 
misuse of pyrotechnics and evaluates the extent of harmonisation across 
Member States, including sanctions and best practices. 

Area 3: Potential use of substances covered by Regulation (EU) 
2019/1148 on explosives precursors to make illegal pyrotechnic articles 

This area investigates the chemical substances commonly used in both 
the legal and illegal manufacture of pyrotechnic articles, assessing 
whether these substances are covered by Regulation (EU) 2019/1148 on 
explosives precursors. Additionally, it explores potential disparities in the 
national enforcement of the Regulation, creating opportunities for criminals 
to circumvent restrictions and access the necessary substances. 

Area 4: Cross-border exchange of information and cooperation 

This area reviews the extent of information exchange and cooperation 
among Member States and with industry stakeholders in addressing the 
criminal misuse of pyrotechnics. 

Area 5: Tracking and tracing high-risk articles 

This area examines existing traceability systems for pyrotechnics and the 
challenges law enforcement faces in tracing illegal articles. 

Area 6: Strengthening customs enforcement 

This area reviews the customs framework for pyrotechnics across the EU 
and identifies challenges in detecting illegal imports. 

33 

 
 
Area 7: The role of online sales/mail order sales 

This area explores the role of online platforms and mail order sales in the 
illegal trade of pyrotechnics and the challenges in regulating and 
preventing this trade. 

Case study A – From factory to the black market: Illegal manufacturing 
and diversion of pyrotechnics in the EU 

This case study looks at illegal manufacturing of pyrotechnics and the 
diversion of legally produced pyrotechnics. 

Case study B – Explosions across borders: Security challenges in EU 
Member States most affected by pyrotechnic misuse 

This case study looks at the EU Member States most affected by security 
issues posed by the criminal misuse of pyrotechnics.

34 

 
 
Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Figure 6 Study areas 

Source: Consortium’s elaboration. 

35 

 
 
 
 
Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Methodological limitations 

The study team faced methodological limitations, requiring adjustments to 
the methodology during the course of the research. 

These limitations became apparent mainly at the interim stage of the study, 
particularly in relation to the completeness of data collection and stakeholder 
partial input. In response, mitigation measures were implemented, including 
additional desk research and engagement efforts with stakeholders, such as a 
follow-up questionnaire and targeted outreach to key stakeholders, such as the 
Presidency of the Council of the European Union (a full overview of these 
activities is provided in Annex VI, Synopsis Report).  

Despite these efforts, certain limitations remain in the Report. The study team 
has  maintained  transparency  with  the  European  Commission  throughout  the 
project's implementation regarding these challenges. 

The key limitations identified are as follows: 

●  The level of engagement and the quality of information provided by 

stakeholders varied significantly. While some stakeholders 
systematically collect and report data, for instance, on incidents involving 
pyrotechnics, others were unable to provide complete responses, due to 
either a lack of data or limited relevance to their national context. In such 
cases, they provided, although valuable, qualitative or anecdotal 
information and contextual insights, limiting the comparability and 
robustness of the findings.  

●  The clandestine nature of the production, trade and use of illegal 

pyrotechnics made it inherently difficult to obtain reliable 
quantitative data. The research encountered significant challenges in 
accessing evidence on the illegal production of pyrotechnic articles, 
substances used and the methods of acquisition of such (restricted) 
substances by unauthorised actors. Much of the information presented is 
based on stakeholders’ input and anecdotal accounts rather than 
systematic forensic analysis or verified data from investigations. 
Additionally, variations in national enforcement practices, data 
availability, and reporting mechanisms across Member States further 
limited the ability to draw comprehensive, comparative conclusions. This 
issue is made complex by variations in national enforcement practices 
and a general lack of intelligence and structured reporting across 
Member States, further limiting the ability to draw comprehensive and 
comparative conclusions. In particular, illegal production of pyrotechnics 
appears to be concentrated only in a limited number of Member States or 
originating outside the EU, with others seeming either unaffected or 
lacking relevant data.  

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

●  Due to the sensitive and restricted nature of information related to 

terrorism, national authorities were often unable to share detailed 
data. In many cases, more precise information was either unavailable or 
not accessible for the purposes of this study. 

In addition to these general limitations, the study team identified specific 
challenges linked to each study area and case study. These are presented 
in the corresponding chapters/sections of this Report. The issues ranged from 
data inconsistencies and definitional ambiguities to gaps in operational 
practices and enforcement mechanisms. This iterative and collaborative 
approach allowed the team to tailor its analysis to the realities of each thematic 
and geographical focus area. This helped strengthen the evidence base and 
ensure that the final findings are as robust and reliable as possible within the 
constraints of the available data. 

Overall, these constraints underscore the need for improved data 
collection, cross-border intelligence sharing, and further research to close 
existing knowledge gaps. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

3. 

Analysis 

This chapter presents a critical analysis of the seven study areas and two 
case studies, drawing on a combination of quantitative and qualitative 
evidence. Each section offers a structured assessment of the respective area, 
highlighting key trends, challenges, and patterns identified. The analysis is 
underpinned by a robust triangulation of sources, ensuring the reliability and 
coherence of findings. Where relevant, comparisons are drawn to contextualise 
national experiences and identify commonalities or divergences. The chapter 
aims to provide a comprehensive and evidence-based foundation for the 
conclusions and recommendations that follow in Chapter 4. 

3.1. 

Study area 1: Updated picture of the security 
problem 

This section presents the findings on how pyrotechnics are illegally 
manufactured, diverted, traded and misused. It offers an updated overview 
of the security threats and emerging trends based on current evidence. 

3.1.1. 

Introduction to the illegal pyrotechnics supply chain 

This section outlines the findings on the different nodes of the supply chain, 
comprising an updated picture of the security problem posed by the criminal 
misuse of pyrotechnics. First, the section on illegal manufacturing focuses on 
the production of pyrotechnics without appropriate permits and requirements as 
laid down by the Pyrotechnics Directive. Second, the section on diverted 
pyrotechnics zooms in on how legally produced pyrotechnic articles are diverted 
from the legal supply chain to the criminal circuit. Third, the section on illegal 
trade dives into how illegally manufactured or diverted pyrotechnics are sold 
and how criminals obtain them. Fourth, the section on the misuse of 
pyrotechnics looks into criminal acts where pyrotechnics are used and the 
associated modus operandi. In the elaboration of these nodes, different parts 
(e.g., modus operandi, scale, drivers) are emphasised according to data and 
information available to the study team. For example, more data and 
information on the scale of the security problem has been received on diversion 
than on illegal manufacturing. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Illegal manufacturing 

The previous studies in 2016 and 2019 on the illegal manufacturing of 
pyrotechnic articles and the security risks posed by illegal pyrotechnic articles63 
found that, following the Chinese government's ban on the exports of category 
F4 flash bangers, the illegal manufacturing of these pyrotechnics in the EU 
witnessed an increase. Factories illegally manufacturing pyrotechnic articles 
have been found in Italy, Austria, Denmark, and Spain, which have since been 
closed.64 

Based on the information and data analysed, the modus operandi of illegal 
pyrotechnics manufacturing seems closely linked to the manufacturing scale.  

Modus operandi and estimated scale 

Pyrotechnics seem to be manufactured both at a small and large scale, which 
indicates two different modes of operation and motivations. Therefore, the level 
of professionalism of illegal manufacturing varies greatly from small garages 
and apartments to well-founded manufacturing sites.65 The illegal manufacturing 
of pyrotechnics on a small scale refers to homemade pyrotechnics by 
individuals or hobbyists in their apartments or garages. Pyrotechnics are often 
illegally manufactured for their own entertainment or use in riots and protests.66 
Whereas, pyrotechnics manufactured illegally at a large scale entail mass 
production in more comprehensive production sites, such as underground 
factories or secret back rooms of, for example, textile factories.67 One EU-level 
stakeholder reported that organised crime groups (OCGs) have established 
their “own” production lines at legitimate factories of pyrotechnic articles. This 
seems to occur in the EU Member States with a strong pyrotechnic industry or 
outside of Europe, for example, in China.68 It is unclear how prevalent this 
modus operandi is, as only one stakeholder mentioned this issue despite the 
study team's inquiries to other stakeholders during the interviews. 

In some Member States (e.g., Italy), national authorities have reported 
significant issues with illegal manufacturing of pyrotechnics both at a 
small-scale and large-scale.69 For example, two trucks transporting illegally 
manufactured F4 category flash bangers from Italy to the Netherlands were 
intercepted in 2023. The shipments contained over 60,000 pieces of fireworks 

63   DJS, 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, 
2016; Oxford Research, Study on the illegal sales of F4 pyrotechnics articles destined for professional 
users to the general public, 2019; Europol (2024) Pyrotechnics in the EU (restricted). 
Ibid. 

64  
65   Case study A: Portugal, France and Italy; interviews with an EU agency and Member State's 

representative part of an EU-level initiative and with authorities of two Member States; follow up 
questionnaire addressed to national competent authorities: response from three Member States.  

66   Case study A: Portugal, France and Italy; Documentary Explosief Nederland, Link. 
67  
68  
69  

Ibid. 
Interview and interview with an EU agency.  
Ibid. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

with a net explosive content (NEC) of approximately. 1700 kilograms.70 Further, 
Italian authorities reported having carried out 736 interventions in illegal 
production, possession and marketing of pyrotechnic articles from 1 January 
2020 to 31 December 2024. During the same time period, more than 850 
tonnes of explosives and gunpowder, as well as more than 25 million pieces of 
fireworks, were seized.71 The Italian authorities have estimated that the illegal 
manufacturing of pyrotechnics constitutes 25%-50% of the overall national 
market of pyrotechnics.72 

In other Member States (e.g., Spain, Croatia, Germany and Sweden), national 
authorities have encountered illegally manufactured pyrotechnics mostly made 
at home at a small scale, but no mass production has been detected. 73 For 
example, Spanish authorities discovered illegally manufactured pyrotechnics 
with fraudulent markings; however, it was unclear whether the pyrotechnics 
were manufactured in Spain or abroad.74 Furthermore, Swedish customs 
authorities have detected shipments of “pyro-kits”, chemicals and empty 
cylindrical containers, which suggests some kind of illegal manufacturing of 
pyrotechnic articles despite the fact that no illegal manufacturing sites have 
been found.75 Some national authorities (e.g., Romania, Estonia, the 
Netherlands, and Latvia) have reported no occurrences or issues with the illegal 
manufacturing of pyrotechnics.76 

The Member States' survey responses further underscore fragmented 
experiences and perceptions on the issue of illegal manufacturing. 
Respondents indicated the importance of illegal manufacturing as either 
minimal (35%) or somewhat minimal (35%).77 Respondents reported an 
increasing trend in the illegal manufacturing of pyrotechnics, to a very small 
extent (35%).78 Similarly, most of the industry survey respondents assessed the 
issue as insignificant (45%),79 and the scale of illegal pyrotechnics 
manufacturing was considered non-significant (55%).80 Despite multiple 
inquiries through different consultation tools, other Member States than Italy 
have not been able to provide data or information on illegal manufacturing in 
their respective Member States. This can be caused by illegal manufacturing, 
indeed constituting a security issue to varying degrees across Member States, 

70   Follow up questionnaire addressed to national competent authorities: response from one Member 

State.  
Ibid. 

71  
72   Case study A: Italy. 
73   Case study A: Spain, Germany and Italy; follow up questionnaire addressed to national competent 
authorities: response from four Member States;  interviews with authorities of two Member States.  

74   Case study A: Spain. 
75   Follow up questionnaire addressed to national competent authorities: response from one Member 

State; interviews with one Member State’s authorities 

76   Follow up questionnaire addressed to national competent authorities: response from four Member 

States.  

77   The Member States Survey, N=37. In this report, this number refers to the total responses in the 

survey.  
Ibid, N=40. 

78  
79   The Industry survey, N=22. 
80  

Ibid, N=22. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

or due to the lack of collection and recording of data on the phenomenon.81 This 
might also point to an issue of criminal activities related to pyrotechnics taking 
place without the knowledge of authorities if the national authorities are not 
aware of the problem. 

Possible drivers of illegal manufacturing 

The possible drivers for issues with illegal manufacturing, specifically at a 
large scale, are rooted in the historical role of pyrotechnics in the national 
context and the ease of access to the necessary materials. For example, in 
Italy, fireworks and other pyrotechnics have traditionally been used in festivities, 
celebrations and theatrical performances.82 However, organised crime groups in 
Italy have also used pyrotechnics, for example, in welcoming mafia heads 
released from prison, or in celebrating victory over rival groups, or to signal the 
arrival of drug shipments.83 In addition to use in the organised crime context, the 
increased use of pyrotechnics in other criminal activities (e.g., public 
disturbances, misuse against LEAs, intimidation and violence) in other EU 
Member States increases the demand for more illegal manufacturing of 
pyrotechnics, which has been noticeable in Italy. This is corroborated by 
stakeholder input stating that most of the detected illegally manufactured 
pyrotechnics originate from another EU Member State.84 

Given pyrotechnics' historical role and strong legal industry, illegal 
manufacturing requires access to the necessary materials.85 The components 
needed for the illegal manufacturing of pyrotechnics are relatively easy to order 
online, e.g., through web shops.86 This is supported by stakeholder views on the 
relatively easy access to the materials and substances needed to manufacture 
pyrotechnics.87 Relatedly, organised crime groups operate as businesses and 
use shell companies to obtain relevant materials in large quantities.88 

Some stakeholders mentioned the prevalence of illegal manufacturing of 
pyrotechnics in the Western Balkans, particularly Albania.89 This might be due 
to the strict legislation on producing pyrotechnic articles in the EU, whereas the 

81   Follow up questionnaire addressed to national competent authorities. 
82   Case study A: Italy. 
83  
84   Case study A: Poland, Portugal, Germany, Italy, France and Spain; Follow up questionnaire 

Ibid. 

addressed to national competent authorities: response from five Member States; Documentary 
Explosief Nederland, Link 

85   This includes for example explosives precursors listed in Regulation (EU) 2019/1148, under Annex I 
(i.e., ammonium nitrate, hydrogen peroxide and potassium perchlorate) and under Annex II (i.e., 
aluminium powder, magnesium powder, potassium nitrate, and sodium nitrate). See further analysis in 
Area 3. 
Interviews with one industry organisation/ industry representative association;, authorities of four 
Member States; Documentary Explosief Nederland, Link  
Interviews with an EU institution and agency, an industry organisation/ industry representative 
association and a Member State’s authority.  

87  

86 

88    Interview with an EU agency.   
89  

Interviews with industry organisations/ industry representative associations and one Member State’s 
authority. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

rules in Western Balkan countries vary, as they are still at various stages in 
alignment with EU rules. The section on illegal trade below provides more 
analysis on the possible illegal trade from the Western Balkans to the EU. 

Diverted pyrotechnics 

Figure 7 Diversion in the pyrotechnics lifecycle 

The diversion of legally produced and distributed pyrotechnic articles 

seems to pose more significant 
concerns than illegal 
manufacturing among Member 
State authorities and the industry. 
Based on the information and data 
analysed, a few key elements 
enabling the diversion of 
pyrotechnics have been identified. 

Source: Consortium’s elaboration. 

Diversion occurs in two ways: from legal distribution and from legal trade. The 
former has not demonstrated prominence in the research; rather, the latter 
seems to pose more significant issues. 

Modus operandi and estimated scale 

The main modus operandi of diversion is the purchase of pyrotechnics 
through online web shops and platforms, which pertains to the node in the 
supply chain where diversion occurs from legal trade. Fragmented approaches 
for checking licenses and specialist knowledge in sales through online 
webshops and platforms across Member States seem to leave this gap for 
diversion of pyrotechnics from the supply chain.90 Online sellers in some 
Member States (e.g., Poland) do not have the capabilities or procedures to 
check licenses to purchase category F4 pyrotechnic articles.91 This leaves room 
for OCGs and criminals to purchase these articles from online sellers in other 
Member States due to the diverging implementation of the restrictions on 
category F4 pyrotechnic articles across Member States, as well as the diverging 
restrictions on F3.92 

90   Case study A; Council of the EU (2023) Draft Report of action 11.9 Explosives – fireworks, 

pyrotechnics and their precursors Link;  interviews with an EU agency and two Member State 
authorities. 
Ibid. 
Ibid. See more analysis on national laws in area 2. 

91  
92  

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Related to the illegal purchase of pyrotechnics online, these are then often 
shipped through postal services in large quantities. Overall, criminals use 
similar methods of diversion as in the trafficking of firearms and drugs. 
Shipments of diverted pyrotechnics are concealed among shipments of other 
legal goods, with false customs declarations or mislabelling.93 To further avoid 
detection by authorities, criminals use high-volume periods (e.g., Black Friday 
and Christmas) and split shipments of pyrotechnic articles destined for the 
criminal circuit.94 These modus operandi have been observed in both road 
transport as well as in the EU ports. Stakeholders have reported that legally and 
illegally manufactured pyrotechnic articles enter EU Member States through 
ports.95 For example, illegal shipments have been intercepted in ports at Gioia 
Tauro in Italy96, Rotterdam in the Netherlands, and various ports in Sweden.97 
In the Netherlands, illegal shipments were transported from the port to official 
storage facilities in Spain, Italy, Romania, and the Czech Republic.98 For 
example, criminals use reinforced “NATO bunkers”, which were built during the 
War, for storing weapons, as a “safe environment” for storing large quantities of 
fireworks.99 The pyrotechnic articles are then diverted into the criminal circuit at 
the storage facilities and distributed to persons not allowed to possess these 
articles. 

No conclusive evidence of diversion from distribution was found in the 
information and stakeholder input collected, despite the study team's specific 
inquiries. 

The scale of diverted pyrotechnics remains difficult to assess, as most 
Member States do not collect data on this aspect, similarly to illegal 
manufacturing.100 Looking at the legal consumption of pyrotechnics in the EU, 
the average is approximately 134,000 tonnes and between 1.5 billion-4.5 billion 
pieces annually.101 Some Member States have been able to provide data on the 
number or weight of seized illegal pyrotechnics; however, Member States were 
not always able to distinguish whether these were illegally manufactured or 
diverted pyrotechnics.102 The data below has been received from national 
authorities through the follow-up questionnaire: 

93    Case study A; Saarijärvi et al. (2024) Link; GI-TOC and Insights, Link; workshop, September 2025. 
94   Case study A: Germany, Italy and France;  interviews with a EU-funded project representative, one 

industry organisation/ industry representative association and with one Member State’s authority.  

95   Case study A: Germany, Italy and France;  interviews with one industry organisation/ industry 

representative association, EU-funded project representative, EU agency, authorities of five Member 
States; follow up questionnaire addressed to national competent authorities: response from one 
Member State. 

96   See Annex III for specific data. 
97   Case study A; Italy and Sweden; interviews with authorities of three Member States; Documentary 

Explosief Nederland, Link 
Interviews with one Member State’s authorities. 
Interviews with one Member State’s authority.  

98  
99  
100   Follow up questionnaire addressed to national competent authorities.  
101  See; https://www.indexbox.io/blog/fireworks-europe-market-overview-2024/ and  

https://www.gmiresearch.com/report/europe-fireworks-market 

102   Ibid. 

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●  Croatia: 120,000 pieces of pyrotechnics were seized in 2023, a sharp 
increase from the 10,000 pieces seized in the four years prior. Around 
90% of seized pyrotechnics are from illegal physical stores, and around 
10% are from online stores. 

●  Denmark: 782 pyrotechnic articles seized during 2022-2024, including 

both EU and non-EU goods. 

●  France: Several tonnes of firework mortars were seized in 2023, 

originating from Poland. In 2024, two seizures of 100kg of fireworks 
originating from Germany and Poland. 

● 

● 

Ireland: A total of 6,319 pyrotechnic articles imported from abroad were 
seized during 2023-2025. 

Italy: more than 850 tonnes of explosives and gunpowder, and more than 
25 million pieces of fireworks seized during 2020-2024. 

●  Sweden: 175,000 pyrotechnic articles seized during 2021-2025, of which 

95% are shipments originating from other Member States, 1% seized at 
the land border, and 3.5% have been seized in the context of house 
searches. 

●  Romania: 369,652 kilograms of pyrotechnics were seized during 2022-

2024 from prohibited categories.  

Member States have provided information on seized illegal pyrotechnics 
(both illegally manufactured and diverted) in varying degrees, which hinders 
the drawing of robust comparisons between the numerical data. However, the 
received data should be treated as a high-level overview of the scale of the 
issue regarding diverted pyrotechnics in the Member States that have provided 
data. It underscores the use of shipments through land and sea by criminals as 
a prominent modus operandi linked to diversion from trade and the inherently 
cross-border linkages thereof. The collection of more accurate and streamlined 
data in the future could allow for drawing solid comparisons.    

It should also be noted that national authorities have emphasised the limited 
possibilities of identifying which pyrotechnic articles have been obtained 
through online stores and used in criminal acts.103 Apart from Croatia's 
response to the follow-up questionnaire, no other stakeholders have raised 
issues regarding diversion from physical stores selling pyrotechnic articles. This 
could be caused by better abilities to check licenses and control individuals' 
specialist knowledge in person as opposed to online sales. 

103   Case study A: Germany, Italy, France and Spain; interviews with authorities of six Member States; one 
industry organisation/ industry representative association further indicated that online platforms as 
used for (re)selling purposes. 

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Illegal trade 

Illegal trade of pyrotechnics, as understood in this study's typology, includes 
diverted and illegally manufactured pyrotechnic articles. It is closely linked 
to the nodes in the supply chain, where illegally manufactured pyrotechnics and 
diverted pyrotechnics are sold further. This contributes to creating a “parallel 
market”, which is underground and hidden from the authorities. Regarding the 
understanding of illegal trade, stakeholders often did not separate illegally 
manufactured pyrotechnic articles from “illegal pyrotechnics” in the interviews, 
despite clarification requests posed by the study team. Only the Dutch 
authorities have reported drawing the distinction between illegally manufactured 
and diverted pyrotechnics in illegal trade.104 

The Member States’ survey responses assess the issue of illegal trade of 
pyrotechnics as minimal (38%), somewhat critical (15%) and quite critical 
(15%).105 The input from interviews seems to support the latter two responses, 
whereby illegal trade has been highlighted as one of the main issues related to 
the criminal misuse of pyrotechnics.106 This discrepancy between the survey 
responses and input from interviews could be explained by the type of Member 
States’ authorities responding to the survey, which often includes market 
surveillance authorities as per the Pyrotechnics Directive. The role of market 
surveillance authorities focuses mainly on the legal trade of pyrotechnics rather 
than the criminal issues, and therefore, they might have less insight into the 
extent of the problem of illegal trade. All national authorities interviewed were 
often involved in the criminal side of the issue. Taking this into account, the 
input received from the interviews mainly points to a few key issues regarding 
the illegal trade of pyrotechnics. 

Modi operandi of illegal trade  

Illegal trade of illegally manufactured or diverted pyrotechnics through 
social media seems to constitute the main modus operandi and has been 
observed in most Member States. As with illegal trade of other goods such as 
drugs and firearms, social media platforms (e.g. TikTok and Telegram) are 
popular in the illegal trade of pyrotechnics. Due to some social media platforms' 
anonymity and encrypted nature, the risk of getting caught for illegal trade in 
pyrotechnics is low.107 This is underscored by the increase in the detection of 
pyrotechnics in postal services and parcels, as reported by some 

104   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

105   The Member States Survey, N=39. 
106   Interviews with an EU agency, an EU-funded project, and two Member State authorities. 
107   Case study A: Germany, Italy, France and Spain; Case study B: Sweden, the Netherlands, Germany; 
interviews with authorities of two Member States, one industry organisation/ industry representative 
association; follow up questionnaire addressed to national competent authorities. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

stakeholders.108 Moreover, there have been some indications that instructions 
and “tips” to avoid controls and checks by authorities when purchasing 
pyrotechnics illegally are circulated through social media platforms.109 This is a 
widely known phenomenon also in other forms of crime, such as firearms and 
drug trafficking. 

Another modus operandi has also been observed in Italy: the illegal trade of 
pyrotechnics through informal interactions. This includes, for example, 
selling illegally manufactured or diverted pyrotechnics from vans or private 
vehicles on the street.110 In 2015, an individual was arrested for selling 
prohibited pyrotechnics from his personal vehicle.111 A similar modus operandi 
has also been observed in the Netherlands, where individuals (often minors and 
youth) obtain storage boxes through organised crime members to store illegally 
manufactured and diverted pyrotechnics to be sold further.112  

Criminal use 

Criminals access and misuse even the more strictly regulated pyrotechnic 
articles. A recent Europol report presents quantitative data and concrete 
examples from multiple Member States, demonstrating a consistent increase in 
incidents linked to the criminal misuse over recent years. For instance, Belgian 
authorities recorded 33 explosions involving pyrotechnics in 2022, while Dutch 
authorities reported over 100 incidents where IEDs containing pyrotechnic 
mixtures were used, with at least 39 confirmed cases involving pyrotechnics as 
the main charge. The report also highlights large-scale seizures, such as 350 
tonnes of illegal pyrotechnics confiscated in a single operation in 2022, and 
notes that these materials are increasingly used by criminals. This information 
and repeated observations from national law enforcement agencies across 
Europe confirm that the use of pyrotechnic articles in attacks is escalating, 
representing a documented and ongoing trend that poses a serious challenge.113 

In the context of this study, the criminal use of pyrotechnic articles was 
recognised as the most prevalent issue among consulted stakeholders in 
comparison to illegal manufacturing, diversion and illegal trade of pyrotechnics. 
This is supported by the survey results of both Member States and the industry, 
whereby the former has assessed the issue as critical (20%) and the latter as 
very significant (36%).114 Although both survey results also show fragmentation, 
some Member States assessed the issue as minimal (25%), and some industry 

108   Case study A: Germany, Italy, France; Case study B: Sweden, Netherlands, France; interviews with 
authorities of two Member States and EU-funded project; follow up questionnaire addressed to 
national competent authorities. 

109   See study area 7. 
110   Case study A: Italy 
111   Ibid. 
112   Interview with one Member State authority; Documentary Explosief Nederland, Link 
113   Europol, Pyrotechnics in the EU: State of Play 2024 (source not available to the general public). 
114   The Member States Survey N=39; The Industry survey, N=22 

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respondents reported encountering the issue only rarely (45%).115 The input 
received from the interviews tends to confirm the former findings of the surveys 
and underscore the prominence of the criminal misuse of pyrotechnics in 
Member States. Nevertheless, criminal misuse of pyrotechnics seems to 
impact Member States to varying degrees, where some Member States 
report having experienced limited or no issues.116 Other Member States have 
observed significant problems and have prioritised addressing the issue.117  

Figure 8 Criminal use in the pyrotechnics lifecycle 

Source: Consortium’s elaboration. 

Public disturbances and property damage 

Pyrotechnics misused by unauthorised persons, not necessarily linked to 
organised crime, are often involved in public disturbances and civil unrest as 
well as, in causing property damage and theft In the former case, pyrotechnics 
are misused in riots, demonstrations, sports events and against law 
enforcement authorities and rescue services in many Member States (such 
as, the Netherlands, Germany, France, Belgium, Estonia, Sweden, Italy).118 In 
France, two people were killed and approximately 200 people were injured 
during the Champions League win celebrations, whereby pyrotechnics were 
also misused against the authorities. It is unclear to what extent all injuries have 
been caused by direct use of pyrotechnics; however, at least one police officer 
was hit by a firework.119 Similarly, over 95% of football matches in Sweden have 

115   Ibid, N=39 and N=22 
116   Interviews with authorities of three Member States. 
117   Interviews with authorities of three Member States; follow up questionnaire addressed to national 

competent authorities: response from five Member States. 

118   Case studies A and B; Follow up questionnaire addressed to national competent authorities: response 

from one Member State.. 

119   Case study B: France. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

witnessed the misuse of pyrotechnics by the audience in the past two years.120 
In Belgium, the misuse of pyrotechnics by large groups of young people against 
law enforcement authorities has exacerbated the issue, as these instances 
have become more violent.121 On the other hand, some Member States (such 
as Croatia, Romania and Spain) have reported having no issues regarding the 
misuse of pyrotechnics in public disturbances.122 There seems to be a large 
variation between Member States on the extent to which the misuse of 
pyrotechnics in public disturbances has been observed. This may be caused by 
lower levels of occurrence, the lack of recording of specific data on the issue, 
or, for example, the strict national controls and rules on pyrotechnics in some 
Member States (e.g., Spain).123 

Property damage and theft are other examples of the misuse of pyrotechnics, 
and they include attacks on ATMs and public or commercial buildings for 
financial gain. ATM attacks have been very visible and on the rise since around 
the late 2010s, but have been on the decline again in the past few years.124  
Some EU Member States (such as Belgium, the Netherlands and Germany) 
have reported having taken more protective measures for ATM machines 
against explosions caused by pyrotechnic articles, which seems to have 
decreased the attractiveness for criminals.125 As ATM attacks have not been 
observed as a major issue in many EU Member States today, the more detailed 
analysis is presented in the context of case study B in Annex IV. 

Relatedly to property damage, pyrotechnics have increasingly been used in 
personal disputes and conflicts in the Netherlands. Flash bangers are used 
for intimidation of an ex-partner or retaliation. This is also linked to other 
aggressive behaviour such as stalking and domestic abuse.126 There have been 
multiple cases of ex-partners using flash bangers to place on the apartment or 
house of their former partners with the aim of retaliation or intimidation.127 Other 
Member States have not reported major issues in this regard. 

Due to their easy accessibility, articles involved in misuse in public 
disturbances, property damage, and theft are often sourced online through 
diversion or illegal trade.128 To illustrate, the Italian authorities have estimated 
that more than 50% of pyrotechnics used in criminal acts originate online.129 

120   Ibid. 
121   Case study B: Belgium. 
122   Follow up questionnaire addressed to national competent authorities; interview with one Member 

State’s authority. 

123   Ibid. 
124   Case study B:The Netherlands, Belgium and Germany   
125   Ibid. 
126   Case study B: The Netherlands 
127   Case study B: The Netherlands 
128   Case study B: All Member States; interviews with authorities of four Member States; follow up 

questionnaire addressed to national competent authorities: responses from five Member States.  

129   Case study A: Italy 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Organised crime 

The misuse of pyrotechnics by OCGs has been highlighted in the recent 
Europol SOCTA 2025, whereby the use of pyrotechnics as “weapons” 
enables different kinds of crime, ranging from the trafficking of illicit goods (e.g. 
drugs and firearms) to carrying out robberies and violence used for 
intimidation.130 When diving into the general modes of operation of OCGs, some 
changes can be identified in the past decade. There seems to have been a shift 
from the use of hand grenades and firearms to “more accessible” means of 
carrying out violence and intimidation. Due to the strict EU-level legislation and 
national sanctions on the use of hand grenades in criminal acts, they seem to 
have become less attractive.131 Similarly, the image and perception attached to 
pyrotechnics have fewer illegal connotations than, e.g. firearms, as they are 
mainly viewed as something used in celebrations and fun activities.  

The main types of misuse of pyrotechnics by OCGs are violence and 
intimidation, which can occur in different contexts. Pyrotechnics can be misused 
with the product itself or as part of IEDs. In the former case, multiple 
pyrotechnic articles (mainly F4 flash bangers) are attached together without the 
need for reconstruction.132 In Belgium, authorities have observed the use of 
whole F4 flash bangers combined with petrol to achieve more powerful 
explosions.133 In the latter case, for example, flash bangers are opened and the 
flash powder is extracted to be used as ignition in an IED.134 Swedish 
authorities report that the number of IEDs incorporating pyrotechnic materials 
has grown significantly in just the past six months. In nearly half of recent 
explosions, pyrotechnics were used instead of traditional explosives.135 

Violence and intimidation through the misuse of pyrotechnics often take place in 
disputes and conflicts between rival OCGs involved in drug trafficking. 
This is particularly prominent in EU Member States with significant OCGs and 
big ports through which drugs are trafficked.136 A notable case of the misuse of 
pyrotechnics in this context happened in Belgium and the Netherlands, where a 
cocaine shipment of 1400 kilos was stolen by a rival OCG in the Port of 
Antwerp. This sparked a string of multiple explosions where pyrotechnics were 
used in eight Dutch cities. Further, business owners with ties (e.g., family, 
money laundering, etc.) to the organised crime were targeted with explosions by 
the rival OCG.137 This resonates also in Sweden, where OCGs use 
pyrotechnics as “bombs” and place them at or inside the entrances of apartment 

130   SOCTA 2025; Case study B: The Netherlands, Belgium and Sweden 
131   Ibid.  
132   Case study B: The Netherlands, Belgium and Sweden ; Documentary Explosief Nederland, Link 
133   Interview with one Member State’s authority. 
134   Ibid. 
135   Interviews with one Member State’s authorities; follow up questionnaire addressed to national 

competent authorities: response from one Member State; Regeringens proposition 2023/24:33, 
Skjutvapen och explosiva varor - skärpta straff för de allvarligare brotten, Link; See also: Link 

136   Case study B: The Netherlands and Sweden; Documentary Explosief Nederland, Link 
137   Case study B: The Netherlands; See also: Link 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

blocks with the aim to intimidate, extort and kill.138 This underlines the spill-
over of explosions and the misuse of pyrotechnics to the broader society, 
outside of the core members and activities of OCGs. However, the prominent 
misuse of pyrotechnics by organised crime has not been observed in all EU 
Member States to the same extent. For example, German, Croatian, Czech, 
Lithuanian, Latvian and Spanish authorities have not reported issues with the 
misuse of pyrotechnics linked to organised crime.139 Danish authorities noted 
736 criminal acts involving pyrotechnics in 2024. However, they could not 
provide information on definitive links to organised crime.140     

As an overall development in organised crime activities, the use of violence 
seems to be connected to the entry points of drugs and other illicit goods into 
the EU. This includes mainly seaports, but the entry points are diversifying in 
terms of the type of entry point and locations. This could also be seen to affect 
the displacement of violence and intimidation by OCGs and the use of 
pyrotechnics therein, as criminal conflicts and rivalries shift.141 

In general, a concerning trend has been pointed out by many national law 
enforcement authorities as well as Europol.142 OCGs offer violence-as-a-
service, whereby targeted killings, attacks, intimidation and extortion can be 
ordered through social media and online platforms.143 Similar to different types 
of violence with for example, firearms, attacks carried out with pyrotechnics or 
IEDs are increasingly ordered by other OCGs or individuals as part of the 
violence-as-a-service. Some Member State authorities (such as the 
Netherlands and Sweden) have provided comprehensive insights on how this is 
organised in practice:144 

●  The OCG and the principal criminal in the middle management of the 

organisation, who offers attacks with pyrotechnics. 

●  The middleman (often young individuals under 18), who coordinates the 
“assignment for an attack”. This includes the recruitment of individuals 
(often minors) for carrying out the attack, the verification and timing of the 
attack, as well as the payment of the rewards. 

●  Runners, who carry out the attack and place the pyrotechnics or IEDs at 

the correct target and agreed time and date. 

This overview ties closely to the prominent recruitment and involvement of 
minors and youth by OCGs in carrying out attacks with pyrotechnics and 
IEDs. OCGs downplay the criminal side of pyrotechnics, as they are advertised 

138   Case study B: Sweden; Documentary Explosief Nederland, Link 
139   Follow up questionnaire addressed to national competent authorities; responses to the follow-up 

questionnaire; interviews with authorities of two Member States.  

140   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

141   Interview with an EU agency.  
142   Europol SOCTA 2025; Case study B: Sweden, Belgium and The Netherlands. 
143   Case study B: Sweden, Belgium and The Netherlands ; Documentary Explosief Nederland, Link 
144   Ibid. 

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Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

as “harmless”, opposed to, for example, explosives and firearms. In 
combination with offering high rewards and quick cash for small jobs, OCGs can 
appeal to youth from deprived neighbourhoods and poor backgrounds.145 
However, youth involvement is twofold. Some young people are driven by 
financial gain or the assimilation of subcultures, such as drill rap.146 They 
actively seek opportunities to earn money and belong to a certain subculture.147 
However, the other side of the coin is the exploitation of young people by 
OCGs. OCGs control and intimidate young people by forcing them to carry out 
explosions on their behalf. This includes forcing young people to complete 
assignments without compensation, and combined with threats to their families, 
which leads to fear among youth.148 The voluntary or coerced involvement of 
youth in carrying out explosions with pyrotechnics in the context of organised 
crime has been observed as particularly prevalent in the Netherlands and 
Sweden, but other Member States have not raised issues in this regard. 

Violent extremism and/or terrorism 

There have been some indications of the use of pyrotechnics in the context of 
violent extremism and terrorism.149  However, the information and data collected 
by the study team do not allow for drawing conclusive findings on the extent of 
the problem. Additionally, due to the highly sensitive nature of information and 
data related to violent extremism and terrorism, many Member States have not 
been able to or are not comfortable sharing the information with the study team. 
Bearing these caveats in mind, we provide a descriptive snapshot of some 
cases that have involved the use of pyrotechnics for extremist and terrorist 
purposes. 

Similar to organised crime, the online environment plays a role in the use of 
pyrotechnics by terrorists and violent extremists. In jihadist, left-wing and 
right-wing extremist propaganda, pyrotechnics have been featured as an 
alternative for planning attacks with HMEs. These developments could be seen 
in the context of the use of pyrotechnics during riots, and specifically against 
law enforcement, which has increased the visibility of pyrotechnics in criminal 
acts.150This could serve as a warning sign of the potential for the use of 
pyrotechnics to become popular in future terrorist acts. 

145   Case study B: Sweden and The Netherlands . 
146   Drill rap is a sub-genre of hip-hop that traditionally includes confrontational and violent lyrics, inciting 

violence and criminality on the street. 

147   Case study B: Sweden and The Netherlands ;  interviews with one Member State’s authority; 

Documentary Explosief Nederland, Link. 

148   Ibid. 
149   Interviews with an EU agency and one Member State’s authority; follow up questionnaire addressed to 

national competent authorities: response from one Member State.  

150   Euronews, Two people killed and hundreds arrested in France during Champions League win 

celebrations. Link 
Following the riot on the Champs-Élysées avenue after the Champions League final match (1 June 
2025), one officer was hospitalised (and in induced coma) after being hit in the face by fireworks. 

51 

 
 
Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Some law enforcement authorities at the EU and national level have reported 
that some cases of pyrotechnics used by terrorists have been reported, 
but not on a large scale so far.151 Further, in June 2025, three people in 
Poland were charged with the possession of pyrotechnic materials for the 
purpose of planning terrorist actions.152 The Spanish authorities have reported 
that the risk of misuse of pyrotechnics for terrorist purposes is low due to the 
robust national administrative controls and regulatory framework.153 
Furthermore, some Member States (such as Latvia, Lithuania, Croatia, France, 
Romania) have specifically stated that no cases of pyrotechnics used in 
extremist and/or terrorist activities have occurred.154 Taken together, this 
information points to fragmented concerns among Member States regarding the 
threat posed by the misuse of pyrotechnics in a violent extremist and terrorist 
context. 

151   Interviews with EU agency and one Member State authority; Follow up questionnaire addressed to 

national competent authorities: response from two Member States.  

152   Case study A: Poland 
153   Case study A: Spain 
154   Follow up questionnaire addressed to national competent authorities.. 

52 

 
 
 
Feasibility study on reducing the security risks posed by the criminal misuse of pyrotechnics 

Security challenges 

Figure 9 Entire pyrotechnics lifecycle 

Source: Consortium’s elaboration. 

53 

 
 
 
 
Cross border 

The analysis of the identified instances of the security problem, ranging from 
illegal manufacturing to diversion and the illegal trade thereof, as well as diverse 
types of misuse, direct to some key security challenges with a cross-border 
dimension: 

●  Diversion of high-risk pyrotechnic articles poses a growing threat across 
the borders of Member States. Criminals take advantage of diverging 
rules on online sales in Member States, and cross-border operation of 
postal services in distributing high-risk pyrotechnic articles destined for 
criminal acts or persons without specialist knowledge. 

●  Relatedly, illegal trade of either illegally manufactured or diverted 

pyrotechnics poses a key security challenge. This contributes to the 
creation of a “parallel market”, which is underground and hidden from the 
authorities. Illegal trade routes seem to follow the trafficking routes for 
other illicit goods, such as drugs and firearms, which pass through 
multiple Member States through, for example, seaports and exploit the 
absence of border checks within the EU. Online stores and social media 
play a central role as the intermediaries of illegal trade. Additionally, 
criminals store pyrotechnic articles at the borders of Member States 
(e.g., Germany, Belgium and the Netherlands) to facilitate illegal trade 
thereof across borders. 

●  The misuse by OCGs manifests in the form of violence and intimidation, 
which in some cases also spills across borders (e.g., Germany, Belgium 
and the Netherlands). This is closely linked to international drug 
trafficking and Member States with major seaports and the presence of 
significant OCGs.  

●  Waterbed effects between Member States can occur as Member States 
take diverging approaches to tackling the security issues posed by the 
criminal misuse of high-risk pyrotechnic articles. Thereby, the security 
issues might shift from one Member State to another Member State. 

Types of pyrotechnic articles 

The evidence collected confirms that category F4 pyrotechnic articles pose the 
highest risk in criminal misuse of pyrotechnics.155 Some stakeholders have also 
mentioned that category F4 pyrotechnic articles seem to contain increased flash 
powder levels, increasing their power and possibility of causing damage.156 The 
shells of category F4 pyrotechnics also pose security issues, as they contain 

155   Case study B: All countries 
156   Interviews with authorities of two Member States, an EU agency and one industry organisation/ 

industry representative association. 

54 

 
 
 
 
flash powder that can be used in explosions.157 In addition to category F4 
pyrotechnic articles, there have been some indications of misuse in category F3 
pyrotechnics, although not at a high level.158 Some stakeholders (e.g., industry 
representatives and national authorities of two Member States) have raised 
concerns about possible further restrictions on category F4 articles that might 
lead to criminals misusing category F3 articles.159 

3.2. 

Study area 2: Harmonisation of national laws and 
practices 

This section assesses the extent to which national laws and practices 
across Member States are harmonised and identifies gaps that could be 
exploited for criminal misuse of pyrotechnics. It also explores the potential 
for further harmonisation at the EU level. 

3.2.1. 

Introduction to the legal framework 

Figure 10 Overview of relevant rules on pyrotechnics 

Source: Consortium’s elaboration. 

As briefly explained in the introduction chapter, the Pyrotechnics Directive 
2013/29/EU is the main piece of EU legislation covering the manufacture 
and making available on the market of pyrotechnic articles throughout the 
EU, with the main aim to ensure the free movement of such articles in the 
internal market, while guaranteeing the protection of the health and safety of 

157   Ibid. 
158   Case study B: All countries 
159   Ibid. 

55 

 
 
 
 
 
consumers and professional end-users of these articles. However, other pieces 
of EU legislation are essential to fully understanding the legal framework 
impacting pyrotechnics. In this regard, Regulation (EU) 2019/1148 on 
explosives precursors introduces harmonised rules on the availability, 
introduction, possession, and use of substances or mixtures that could 
be misused for the illicit manufacture of explosives, limiting their access 
to the general public. While the Regulation specifically excludes pyrotechnic 
articles from its scope, it is nonetheless relevant insofar as certain explosive 
precursors are substances used to make pyrotechnic articles. In addition, the 
stricter rules set for explosive precursors introduced with this Regulation might 
potentially cause a shift in criminal use towards pyrotechnic articles, for which 
currently no similar authorisation system is in place.  

When looking at the broader picture, several other pieces of EU legislation are 
to be considered throughout the whole pyrotechnics life cycle. While civil 
explosives, falling in the scope of Directive 2014/28/EU, are formally 
categorised differently from pyrotechnic articles, and concern a different 
industry and market compared to pyrotechnics, some similarities, especially 
between professional pyrotechnics and civil explosives, can be observed, 
including the fact that they can be used for similar criminal uses.160 Similar to 
explosive precursors, the stricter requirements established for civil explosives 
under Directive 2014/28/EU could lead criminals towards a greater use of 
pyrotechnic articles, due to their being easier to access.161 

Moreover, about manufacturing and making available of products in the internal 
market, economic operators are also bound by Regulation (EC) 1272/2008 on 
classification, labelling and packaging of substances and mixtures (CLP 
Regulation), Regulation (EU) 2023/988 on general product safety,162 
Regulation (EC) 1907/2006 on Registration, Evaluation, Authorisation and 
Restriction of Chemicals (REACH), 163 and Regulation (EU) 2019/1020 on 
market surveillance.164 In particular, concerning trade and distribution, it 
should be noted that all pyrotechnic articles should be labelled as dangerous 
goods and respect the Directive 2008/68/EC on the inland transport of 
dangerous goods.165 

160   Interview with an EU institution.  
161   Ibid. 
162   Consolidated text: 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.  
163   Consolidated text: 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. 

164   Consolidated text: 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 765/2008 and (EU) No 305/2011. 

165   Consolidated text: Directive 2008/68/EC of the European Parliament and of the Council of 

24 September 2008 on the inland transport of dangerous goods. 

56 

 
 
 
 
Other EU legislative instruments which come into play with the fight against the 
criminal misuse of pyrotechnics are Directive (EU) 2017/541 on combating 
terrorism,166 and Directive (EU) 2024/1203 on the protection of the 
environment through criminal law.167  

3.2.2. 

Gaps in the EU approach 

Concerning the legislative framework regulating the different aspects of the 
pyrotechnics life cycle, summarised above, the inputs gathered through desk 
research and stakeholder consultation have highlighted different issues 
regarding the possible legal gaps in the EU approach towards pyrotechnics 
misuse. These gaps can be summarised in the following areas:  

●  Gaps concerning the effective enforcement of current, already existing 
EU and national legal frameworks, especially for what concerns online 
and postal sales;  

●  Gaps related to the lack of harmonisation, as diverse national 
regulations would hinder an effective cross-border cooperation, 
information exchange and enforcement itself and create loopholes to be 
exploited for criminal misuse;  

●  Gaps linked to the categorisation of pyrotechnic articles, which might 
facilitate misuse of products considered as ‘low-hazard’ while potentially 
highly harmful. 

The input gathered from three industry stakeholders focused more on effectively 
enforcing and implementing the existing rules rather than proposing significant 
changes.168 In particular, according to one industry stakeholder, the legislative 
framework around pyrotechnics would be solid and comprehensive 
enough, if properly enforced, to counter criminal misuse of pyrotechnic 
articles.169 Another industry representative made similar observations, stressing 
the necessity of ensuring proper enforcement of existing rules while recognising 
the potential for further harmonisation of national rules.170 Yet, two industry 
stakeholders also agreed that more harmonisation of national laws could  help 
in tackling illegal trade of pyrotechnics. This because some products are more 
strictly regulated in some countries - which have in place additional limits to the 
ones in the Pyrotechnics Directive- and less in others (e.g. in Germany a rocket 
is limited to 20 grams, and additional measures are set in place by the German 
explosive act, as well as several additional measures on the packaging). This 

166   Directive (EU) 2017/541 of the European Parliament and of the Council of 15 March 2017 on 

combating terrorism and replacing Council Framework Decision 2002/475/JHA and amending Council 
Decision 2005/671/JHA. 

167   Directive (EU) 2024/1203 of the European Parliament and of the Council of 11 April 2024 on the 
protection of the environment through criminal law and replacing Directives 2008/99/EC and 
2009/123/EC. 

168   Interviews with three industry organisations/ industry representative associations.  
169   Interview with one industry organisation/ industry representative association 
170   Interview with one industry organisation/ industry representative associations  

57 

 
 
 
 
has an impact on trade, as products coming from countries where pyrotechnics 
are less regulated can be sent to countries where they might not be in 
conformity with the national rules. However, these stakeholders agreed that any 
further harmonisation should not simply result in a generalised tightening of 
measures.171 Rather, enhanced harmonisation should keep the distinction 
between different types of product groups or businesses to avoid unnecessarily 
affecting industries that are not problematic, such as the automotive industry.172 
In particular, representatives of the automotive industry highlighted how the 
pyrotechnic articles used for vehicles (such as explosives for airbags, which fall 
under P1 category) are not affected by criminal misuse as other type of 
pyrotechnics (such as fireworks) are. This would be linked to the fact that these 
type of products can only be distributed within the professional market and are 
not available for consumers unless already installed in the vehicle.173 
Replacements of these parts are only carried out in service stations, and while 
an illegal market of replacements of original products in old cars exists, this is 
considered to be linked only to the high costs of official parts, and not to criminal 
misuse.174 Still, the prevalence of this phenomenon is unknown, although, given 
the size of the pyrotechnic articles in question, their criminal misuse seems 
unrealistic.175 

Furthermore, stakeholder consultation has also confirmed how the issue of 
online sales remains one of the most pressing ones, as was already largely 
suggested by the preliminary scoping interviews and desk research, which 
highlighted the opportunities that the dark web provides to OCGs to acquire 
pyrotechnic articles without the need for physical interactions.176 In particular, 
several stakeholders have emphasised the issue of online sales of 
pyrotechnics, which appears to raise significant concerns in terms of 
enforcement and control. Namely, 26% of the answers provided by national 
authorities consulted indicated ‘e-commerce’ as one of the most problematic 
areas in the fight against the criminal misuse of pyrotechnics, together with 
‘cross-border surveillance’ (17% of the answers) and ‘traceability’ (indicated by 
16% of the answers)177The exact impact and problems of this area will be 
analysed further in detail in Area 7. However, as far as the gaps in the EU 
approach are concerned, it is worth noting that, while some stakeholder inputs 
suggested that more could be done to regulate online markets and sales, others 
described the issue as ultimately going back to the problem of an effective 
enforcement of already existing rules, such as, for example, the Digital Services 
Act (DSA).178  

171   Interviews with two industry organisations/ industry representative associations. 
172   Ibid. 
173   Interviewswith one industry organisation/ industry representative association 
174   Ibid. 
175   Ibid. 
176   Interview with  an EU institution. 
177   The other areas indicated as problematic were ‘ prosecution’ (indicated by 12% of the answers), 

‘enforcement’(9%), ‘manufacturing’(5%) and ‘retail’ (7%). 

178   Interviews with an EU institution andan industry organisation/ industry representative association; see 

dedicated focus in Area 7. 

58 

 
 
 
 
Despite these inputs, a relevant number of stakeholders still consider the 
existing legal framework insufficient to effectively limit the criminal 
misuse of pyrotechnic articles. As both desk research and stakeholder 
consultation have highlighted so far, the lack of harmonisation of national 
rules is still largely perceived as a limit of the existing framework and an 
obstacle to cross-border information exchange and to the fight against 
illegal trade. The principle of free trade that characterises the EU approach to 
pyrotechnic articles implies that Member States are not allowed to unilaterally 
prohibit, restrict or hinder the making available on the market of pyrotechnic 
articles satisfying the requirements of the Pyrotechnics Directive.179 At the same 
time, the Directive allows Member States to introduce limitations to the 
possession, use, and/ or sale to the general public of category F2 and F3 
fireworks, theatrical pyrotechnic articles and other pyrotechnic articles, on 
grounds of public order, security, health and safety, or environmental 
protection.180 While the Pyrotechnics Directive includes restrictions such as 
product requirements and age limitations (to F1, F2, F3 fireworks) and limits to 
the accessibility F4 fireworks and theatrical pyrotechnic articles of category T2 
and other pyrotechnic articles of category P2 only to persons with specialist 
knowledge, Member States might have different national requirements relating 
to manufacturers, security measures for factories, expert authorisation, or 
licensing.181 Among the possible explanations for these differences is the 
perception of the dangers and risks related to the criminal misuse of 
pyrotechnics, which seems to differ across Member States. For instance, in 
Spain, the pyrotechnics sector is highly monitored, and risks of non-authorised 
individuals accessing restricted pyrotechnic material are considered limited by 
authorities.182 Lithuanian national authorities have also indicated that 
differences in regulations and enforcement between countries can create 
loopholes that smugglers exploit.183 One Member State’s authority noted that 
further harmonisation of national laws and practices would greatly improve the 
detection, enforcement, and prosecution of cross-border activities related to the 
criminal misuse of pyrotechnics, identifying one of the main obstacles to these 
aims in the unharmonised regulations.184 However, the main gap observed by a 
Member State authority was still the level of regulatory ineffectiveness and the 
lack of a horizontal approach at the EU level to combat illegal fireworks used for 
criminal misuse (considering that the Pyrotechnics Directive, being primarily 
focused on consumer safety standards rather than criminal misuse, does not 
specifically target the latter).185 The need for harmonisation of national 
approaches was also highlighted in regards to common scanning standards and 
real-time exchange of risk data between courier operators and authorities.186 

179   Neve ed. (2022). Dutch Environmental Crime Threat Assessment 2021. 
180   Pyrotechnics Directive, Article 4(2). 
181    Interview with a Member State authority. 
182   Ibid; workshop with stakeholders organised for this study, September 2025..  
183   Follow-up questionnaire: response from a Member State authority 
184   Interview with a Member State authority. 
185   Ibid.  
186    Interview with a EU-funded project. 

59 

 
 
 
 
Interestingly, one of the issues that emerged from the stakeholder consultation 
in terms of potential regulatory gaps focuses on the categorisation of 
pyrotechnic articles. One industry representative, in particular, stressed the 
role and potential of certain types of P1 articles, namely sound emitters, in 
causing severe damage if used for unlawful purposes.187 According to this 
stakeholder, these products, while being categorised as P1 articles, which do 
not entail specific limitations per se (being categorised as low hazard), aside 
from age restriction, can actually bear a significant amount of flash powder and 
cause significant damage if misused. While the P1 category also encompasses 
products (such as pyrotechnics used for vehicle airbags) which do not constitute 
a problem for criminal misuse, the consulted industry representative highlighted 
how sound emitters, being categorised as P1 pyrotechnic articles, might 
constitute a potential loophole to be exploited for criminal purposes. In fact, 
some type of P1 articles are not much dissimilar from F2 or F3 categories of 
fireworks in terms of design and manufacture. At the same time, they are often 
perceived as less problematic and are less strictly regulated in some national 
frameworks, even though they appear to be often misused.188 Moreover, as P1 
sound emitters have many diverse and legitimate uses (in airports, farms, for 
maritime purposes, historical simulations), they are more easily obtainable than 
F2 and F4 articles, which are more commonly restricted. However, in practice, 
they are comparable to flash bangers. According to this representative, a 
stricter certification system could help tackle this issue. During a workshop held 
with various stakeholders, an industry representative,189 emphasised that the 
current categorisation system in the Directive, particularly for categories P1 and 
P2, needs improvements. However, another stakeholder highlighted that that 
challenges arise in practice, when products are incorrectly classified, and that 
the Directives categorisation system is sufficient.190  

Finally, a number of concrete perspectives emerged from a study visit to France 
on the misuse of pyrotechnic articles, which took place on 26 June 2025 and 
saw the participation of national and EU authorities. These perspectives 
included suggestions on aspects to be potentially strengthened. Among these, 
the conclusions adopted following the study visit highlight the possible positive 
impact of introducing a limit for the quantity of explosive material in certain 
articles, or a ban on the sale of certain articles. Moreover, they also focus on 
harmonising professional firework qualifications and strengthening controls on 
national certifying bodies.191 

187    Interview with one industry organisation/ industry representative association. 
188   Ibid. 
189   Input of industry organisation/ industry representative association  during the workshop with 

stakeholders organised for this study, September 2025 

190   Input of one Member State authority  during the workshop with stakeholders orgaised for this study, 

September 2025. 

191   Statement of conclusions of a Study visit to France on the misuse of pyrotechnic articles, Thursday 

26th June 2025, not available to the general public. 

60 

 
 
 
 
3.2.3. 

National criminal sanctions and deterrence  

Article 45 of the Pyrotechnics Directive leaves to Member States the possibility 
to lay down rules on penalties for infringements by economic operators of the 
provisions of national law adopted pursuant to the Directive, which may include 
criminal penalties for serious infringements. 

In the context of this research, the study team looked at the current national 
legal frameworks regarding criminal misuse of pyrotechnic articles. However, 
national frameworks regarding sanctions might vary a lot, including 
sanctions for various aspects relating to illegal manufacturing, illegal trade, 
pyrotechnics diversion and misuse for criminal purposes. 

In order to assess the impact of criminal sanctions and the criminalisation of 
offences involving pyrotechnics on the prevention of their criminal misuse, a 
mapping exercise of the relevant criminal and administrative penalties 
across EU Member States was conducted. This mapping was primarily 
based on the 2023 Evaluation study of Pyrotechnics and Civil Explosives 
Legislation, as well as the Study on illegal sales of pyrotechnic articles destined 
for professional users (category F4) to the general public (for what concerns F4 
articles only) and was integrated with the findings of the stakeholder 
consultation carried out as part of the present study. For what concerns the data 
extracted from the 2023 Evaluation study of Pyrotechnics and Civil Explosives 
Legislation, it is important to note that these refer only to sanctions on economic 
operators violating national laws adopted pursuant to the Pyrotechnics 
Directive. Moreover, to enhance data collection on national legal frameworks 
addressing the criminal misuse of pyrotechnics, a follow-up questionnaire was 
also distributed to national authorities. However, it should be noted that the 
response rate to these follow-up questionnaires was particularly low and input 
received was fragmented and/or not sufficiently detailed, representing a 
significant limitation to its comprehensiveness. 

It also needs to be noted that the comparability of the regimes across 
Member States proved to be limited. This is due to the broad spectrum of 
offences taken into consideration under this study question, which includes 
those linked to illegal manufacturing, illegal trade, and the criminal misuse of 
pyrotechnic articles, and to the varying nature of applicable sanctions. These 
divergences hinder a direct comparison between Member States. For this 
reason, the relevance of comparing different types of offences and associated 
crime rates across Member States was also deemed limited. Ultimately, the 
results of the mapping exercise were compared to the results outlined regarding 
the sanctions’ effectiveness gathered through the stakeholder consultation.  

In this regard, the following paragraphs will first introduce briefly what the 
landscape of sanctions related to the type of crimes considered under 

61 

 
 
 
pyrotechnic articles’ misuse is, including the general trends observed. Moving 
from the different levels of severity and deterrence of such sanctions, it will then 
highlight some of the horizontal and then country-specific conclusions resulting 
from the research and stakeholder consultation.  

As an industry stakeholder stressed, some Member States (e.g. Germany, 
France, the Netherlands) have set in place a wide and extensive legal 
framework that regulates pyrotechnic articles very strictly.192 For instance, 
according to an industry representative, Germany’s Explosives Act, regulating 
pyrotechnic articles, and the ordinances accompanying it, set out strict 
provisions on enforcement but also on offences and sanctions, including the 
sanctioning of illegal imports and the lack of CE marking. In addition, there are 
other legislative acts that, despite not being directly part of the pyrotechnic 
legislation, they have pyrotechnics in their scope, e.g. occupation health and 
safety legislation. Finally, in Germany, both F3 and F4 categories of 
pyrotechnics are reserved for people with specialist knowledge.193 Still, where 
present, criminal sanctions related to the misuse of pyrotechnics seem to have 
different levels of deterrence. Namely, only eight national authorities have 
deemed their own national criminal sanctions as effective in preventing the 
criminal misuse of pyrotechnics in their countries.194 On the contrary, twenty-
three Member States' authorities described them as ‘neutral’195, and fifteen as 
‘ineffective’.196 Only one considered them as ‘very effective’.197 

In this regard, both national authorities and industry representatives have 
stressed that the effectiveness and deterrent value of criminal sanctions 
depend not only on the legislative framework but also on the authorities’ 
ability to enforce it.198 Looking at the case of Germany, two industry 
representatives stressed that the national criminal sanctions foreseen under 
their national legal framework work well as a deterrent.199 At the same time, 
only one of the eleven German national authorities that responded to the 
surveys has indicated their national criminal sanctions as ‘effective’. According 
to an industry representative and a Member State authority, one of the issues is 
that the lack of resources or coordination can hinder the effective 
prosecution of such violations, especially when dealing with online sales, 
small-scale irregular imports, or individuals coming from other countries.200 
Moreover, a Lithuanian national authority has indicated that the volume of 
goods moving through ports makes it difficult to thoroughly inspect each 

192   Interview with one industry organisation/ industry representative association. 
193   Ibid.  
194   Survey addressed to NCA: seven Member States.  
195   Survey addressed to NCA: thirteen Member States. 
196   Survey addressed to NCA: nine Member States.  
197   Survey addressed to NCA: one Member State. 
198   Interviews with one industry organisation/ industry representative association and authorities of 

two Member States. 

199   Interviews with two industry organisations/ industry representative associations.  
200   Interviews with one industry organisation/ industry representative association and one Member State 

authority. 

62 

 
 
 
 
shipment, and that often customs agencies lack the resources to carry out all 
the necessary inspections.201 A French national authority representative also 
indicated that even though they consider French sanctions to be sufficient, the 
authorities lack the capacity necessary to track the pyrotechnic material.202 
More specifically, French authorities face difficulties in controlling intra-EU 
trade, particularly in the context of e-commerce, given that the lack of 
harmonised controls across Member States limits the ability of customs 
agencies to enforce regulations effectively.203  

What has also been suggested by both national authorities and industry 
stakeholders in this regard is that the effectiveness of stringent national criminal 
sanctions might be impacted by the fact that such strict frameworks are not 
equally in place in other legislations.204 These differences in national legal 
frameworks could possibly increase the chances of pyrotechnics being legally 
produced in one Member State and then transported and made available for 
illegal use in other Member States with stricter legal frameworks, especially 
through online sales or adjacent countries. This is particularly important 
because, as indicated by national authorities and other stakeholders, illegal 
imports from other EU countries are particularly challenging to monitor and 
detect, taking into account the free movement of goods within the EU.205 Among 
some of the countries where sanctions are less stringent, countries like Czech 
Republic, where no type of criminal sanction in relation to the criminal misuse of 
pyrotechnics is in place, were mentioned.206  

For what concerns the severity of the sanctions and their level of effectiveness, 
it appears that the perceived effectiveness of criminal sanctions in relation 
to the criminal misuse of pyrotechnics (including illegal manufacturing, illegal 
trade, misuse for criminal purposes, possession of pyrotechnics articles without 
having the required authorisation) does not seem to correlate with the 
maximum duration of imprisonment foreseen in national legislation for 
economic operators. In other words, longer prison sentences foreseen for 
economic operators do not seem to lead national authorities to view the criminal 
sanctions overall as more effective. Among the Member States represented by 
the 9 national authorities (from Austria, Estonia, Germany, Hungary, Latvia, 
Romania, Spain) that characterised their own criminal sanctions as ‘effective’ or 
‘very effective’, imprisonment penalties for economic operators varied greatly, 
ranging from up to 6 weeks in Austria, to up to 20 years in Romania. In three 

201   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

202   Interview with one Member State’s authority. 
203   Input of one Member State authority in the workshop with stakeholders organised for this study, 

September 2025. 

204   Interview with one industry organisation/ industry representative association;  Interview with authorities 

of two Member States.  

205   Follow questionnaire addressed to national competent authorities: response from two Member States. 
Interview with a Member State's representative part of an EU-level initiative; interviews with one 
Member State’s authority, two industry organisations/ industry representative associations. 

206   Interview with one Member State authority. 

63 

 
 
 
 
Member States where national authorities described criminal sanctions as 
‘effective’ or ‘very effective’, national law does not even seem to provide for 
imprisonment sentences for economic operators.207 Clearly, the broad category 
of criminal sanctions for pyrotechnics’ misuse also include sanctions arising 
from other type of criminal misuse, not limited to the ones applicable to 
economic operators only. However, these are hardly comparable across 
Member States, as they refer to an extremely wide variety of different criminal 
offences. It was also not possible to carry on an analysis of the effectiveness of 
national criminal sanctions in comparison with the crime rate of each crime in 
each Member State, as this type of data was not made available in a 
comprehensive manner by the stakeholders consulted. 

The data collected also show that sometimes different national authorities 
within the same Member State have conflicting views regarding the 
effectiveness of criminal sanctions. For instance, in Austria, while two 
national authorities208 characterised criminal sanctions as ‘ineffective’, a third 
national authority209 surveyed considered them ‘effective’. Similarly, in 
Germany, four national authorities210 surveyed indicated that the criminal 
sanctions are ‘ineffective’ while one considered them as ‘effective’.211 The same 
trend was identified in Latvia where out of the three national authorities 
surveyed, one indicated that the criminal sanctions foreseen in national 
legislation are ‘very effective’212, a second one that they are just ‘effective’213 
and a third one characterised them as ‘ineffective’.214 Thus, the analysis of 
maximum imprisonment sentences for economic operators and how national 
authorities perceive the effectiveness of criminal sanctions does not seem to 
lead to conclusive findings.  

Finally, it is worth mentioning that a Member State authority reported facing a 
challenge with OCGs using minors to plant fireworks and buying heavy, 
illegal fireworks. In facing this issue, it was mentioned how the Netherlands 
focuses on deterring minors from engaging in such activities, rather than heavily 
punishing them, and for this reason they have in place a tiered system of 
measures meant to be lighter for minors and first offenders, but heavier for older 
suspects attacking people.215  

207   Survey addressed to NCAs: three Member States. 
208   Survey addressed to NCAs: one Member State.  
209   Survey addressed to NCAs: one Member State.  
210   Survey addressed to NCAs: one Member State.  
211   Survey addressed to NCAs: one Member State  
212   Survey addressed to NCAs: one Member State.  
213   Survey addressed to NCAs: one Member State. 
214   Survey addressed to NCAs: one Member State.  
215   Interview with one Member State’s authority. 

64 

 
 
 
 
3.2.4. 

Potential for harmonisation 

Some of the issues mentioned in the previous paragraphs (e.g., the possibility 
for criminals to exploit differences in national laws or the lack of harmonisation 
thereof, the existence of potential loopholes deriving from the categorisations of 
pyrotechnic articles) already suggest that enhancing further harmonisation of 
national legal frameworks could be helpful in limiting the criminal misuse 
of pyrotechnics.216 

The potential of harmonisation had already emerged during the preliminary 
scoping interviews and desk research, which underlined how further 
harmonisation of national legislations across the Member States was deemed to 
be essential to prevent criminal misuse of pyrotechnics, as organised crime 
groups might exploit differences between national laws to shift their illegal 
activities to Member States with less stringent controls.217 The significant 
differences among Member States both in terms of rules to ensure that 
the specialist knowledge requirement for purchasing F4 articles is met, 
and in the nature and gravity of sanctions established for the non-
compliant sale of F4 pyrotechnics to the general public, had already been 
observed by a 2019 Study on illegal sales of pyrotechnic articles destined for 
professional users.218  

Harmonisation can take place at different levels and can have different targets, 
as indicated below.  

EU-level harmonisation 

Looking at rules on pyrotechnic articles and their potential harmonisation, a first 
type of input received by stakeholders regarded the possibility of introducing 
new common limitations on pyrotechnics at the EU level. One Member 
State authority, for example, suggested a general ban of flash bangers-type 
pyrotechnics throughout the EU.219 Another Member State authority suggested 
including a flow of authorisations for transfers similar to the one 
established in the Directive on explosives for civil uses.220 This input was 
strongly supported by other two Member State authorities, indicating the system 
established under Article 11 of the Directive on explosives for civil uses, 
regulating the transfer of explosives, as a possible model to be applicable to 
pyrotechnic articles as well.221 According to these stakeholders, inspiration 

216   Interviews with authorities of three Member States, three industry organisations/ industry 

representative associations and an EU agency.  

217   Interview with EU agency and one industry organisation/ industry representative association. 
218   European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(2019). Study on illegal sales of pyrotechnic articles destined for professional users (category F4) to 
the general public. 

219   Interview with one Member State’s authority. 
220   Interviews with one Member State’s authority and one industry organisation/ industry representative 

association. 

221   Interview with authorities of two Member State. 

65 

 
 
 
 
could be drawn from the security provision applying to explosives for civil 
uses, which limits their transfer to consignees who have received approval to 
such transfer from the competent authority of their Member State, verifying their 
possession of the proper licences and authorisations for transfer. Under the 
Directive on explosives for civil uses, economic operators may not transfer 
explosives, unless the consignee of such has obtained the necessary 
authorisations for the transfer, a system which is not in place for pyrotechnic 
articles. Similarly, a national authority representative suggested the use of the 
Explosives Control and Protection System to Prevent and Fight against 
Terrorism (SCEPYLT), currently used for explosives, to overcome cross-border 
issues with pyrotechnics as well, including for issuing EU authorisations for 
intra-EU trade and facilitating information exchange between Member States.222 
The same authority, also proposed the use of systems, similar to those used for 
ammunition, for monitoring suspect transactions of pyrotechnics taking place 
both online and offline.223  

Input gathered from another Member State’s targeted interview stressed the 
opportunity to introduce a ban on heavier fireworks, as well as a 
restriction to the maximum amount of flash powder in fireworks (2 grams), 
as there is currently no limit on the amount of explosive powder within 
pyrotechnics.224 Another authority from the same Member State highlighted the 
need to regulate pyrotechnics and explosives for civil uses equally.225 On 
the other hand, an EU agency suggested that the introduction of stricter 
penalties for offences related to the criminal misuse of pyrotechnic 
articles could be helpful in equating them with penalties foreseen for other 
types of articles, like firearms.226 A complete ban on online sales of 
pyrotechnics was also suggested, to leave the purchase of articles to physical 
shops only.227 

At the operational level, stakeholders recommended various measures aiming 
at improving inter-state cooperation. Two Member States’ authorities suggested 
the introduction of an instrument similar to the Pyro-pass, to function as a 
control mechanism placing responsibility with the provider.228 The Pyro-pass is 
an initiative adopted by the Benelux Committee of Ministers in 2020. It 
introduces a control document for F3 and F4 categories of pyrotechnics, valid 
amongst these Member States. A Member State authority also suggested 
sharing information by means of digital tools to improve cross-border 
surveillance, enforcement, and prosecution.229 Interestingly, the 2023 

222   Input of one national authoritiy in the workshop with stakeholders organised for this study, September 

2025.  

223   Ibid.  
224    Interview with one Member State’s authority. 
225   Interview authorities of two Member State. 
226   Interview with EU agency. 
227   Interviews with two industry organisations/ industry representative associationsIndustry; and one 

Member State’s authority. 

228   Interview with authorities of two Member States. 
229   Interview with one Member State’s authority. 

66 

 
 
 
 
Evaluation study of Pyrotechnics and Civil Explosives Legislation highlighted 
how a European Commission 2017 Pyrotechnics Expert Group meeting 
explored various solutions for ensuring better control over cross-border sales of 
F4, P2, and T2 articles, including the idea of a European database to help 
sellers verify the specialist knowledge of the buyer. However, this was 
eventually considered too complex to implement considering the current context 
of fragmentation.230 

Finally, one Member State authority suggested enhancing Europol's role to 
reduce the fragmented powers across law enforcement services, which 
makes mutual communication difficult.231 

Member State-level actions and good practices 

Stakeholders have indicated some national-level actions that could qualify as 
good practices that could be implemented on a broader scale. 

These include specific rules in place in France (with the Code de la Défense), 
making it mandatory for all manufacturers and economic operators storing 
explosives to have measures in place to protect the sites where 
explosives and pyrotechnic articles are produced. These measures aim to 
protect sites from the outside and may include, for example, alarm systems and 
physical measures.232 

Another element that emerged from stakeholder consultation is the 
abovementioned Pyro-Pass, which, according to stakeholders, could either be 
implemented at the EU level or remain an initiative at the national level.233 

Regarding Spain, this was the first country to implement a certification card 
for pyrotechnics experts (Carné de experto). In Spain, there are three types 
of expert certifications, the first is for the execution of pyrotechnics shows, 
covering T2 articles, the second is for the use of pyrotechnic articles of category 
T2 in non-pyrotechnic shows and the third for the use of pyrotechnic articles of 
Category P2. All three licences require amongst other things, theoretical and 
practical training and a medical certificate proving the holder is in a 
psychological position to use pyrotechnics.234 Concerning the first expert licence 
intended for pyrotechnic shows, the expert must first hold an apprentice licence, 
while the P2 certification is specific for each type of P2 category pyrotechnic 
article and is not a generic certification for the entire P2 category.235 Similar to 

230   European Commission, Evaluation study of Pyrotechnics’ Legislation. 
231   Interview with one Member State’s authority. 
232   Interview with one Member State’s authority. 
233   Interviews with authorities of two Member States. 
234   Real Decreto 989/2015, de 30 de octubre, por el que se aprueba el Reglamento de artículos 

pirotécnicos y cartuchería. 

235   Real Decreto 989/2015, de 30 de octubre, por el que se aprueba el Reglamento de artículos 

pirotécnicos y cartuchería. 

67 

 
 
 
 
the Spanish model, a Pyro Pass is in place in the Benelux countries,236 which 
foresees mandatory checks by the selling party and aims to contribute to a 
more reliable market.237 

In the Netherlands, authorities keep an inventory of seized F4 fireworks 
originating from producers and importers based in other countries. They also 
make use of the European Investigation Order (EIO) to request and obtain 
documentation relating to sales, including records on orders, invoices, transport 
documents, and bank or cash transfers, from producers and importers based in 
other Member States. This approach aims at gathering information and 
identifying the source of the illegality, the delivery chain followed, and the sales 
to individuals in the Netherlands without the necessary specialist knowledge 
and to conduct further investigations and interventions.238  

Furthermore, authorities in the Netherlands can use a mobile application for 
tracking pyrotechnics after explosions. According to the Netherlands Forensic 
Institute, the application allows users to visually recognise fragments after an 
explosion by taking a picture, which helps them identify what types of fireworks 
were involved. The database is being updated with all seized fireworks in the 
Netherlands and there are plans to expand and translate the application to 
facilitate its use by other Member States.239 

Spain has also introduced the prohibition of the online sale of pyrotechnic 
articles, which are shipped directly to end users. Purchasers are required to 
collect the articles in person from the physical store, where their identity and 
age are verified, ensuring compliance with all the legal requirements.240 Other 
Member States have been looking into this practice. According to the national 
representatives, this strict regulation enables more effective control and 
monitoring of the pyrotechnics market. For this reason, France has even 
proposed a similar prohibition of online sales and deliveries in 2023, which, 
however, did not concretise.241 

Another good practice identified by Spanish authorities, but also by a Dutch 
national authority representative,242 is the fact that in Spain, the Guardia Civil is 
the only law enforcement body with full competencies on explosives, 

236   Interview with one Member State’s authority. 
237   Interview with one Member State’s authority. 
238   The Intelligence and Investigation Service of the Human Environment and Transport Inspectorate (ILT-
IOD), Presentation on the “Findings of international investigations into illegal trade with F4 fireworks, 
Request police contacts & Dutch Pyro-Pass, 22 September 2025. Source not available to the general 
public. 

239   Input of one national authority in the workshop with stakeholders organised for this study, September 

2025.  

240   Survey addressed to NCAs: one Member State; interview with one industry organisation/ industry 

representative association. 

241   Interview with one Member State’s authority; Sénat, Rapport d'information n° 521 (2023-2024), 2024. 

Link 

242   Interview with one Member State’s authority. 

68 

 
 
 
 
pyrotechnic articles, weapons and ammunition.243 The entire pyrotechnics 
domain (supervision, import, product control, system control, etc) falls 
under the jurisdiction of one authority, i.e. Guardia Civil.244 Furthermore, the 
Guardia Civil has trained a number of operatives in the administrative control of 
explosives, pyrotechnic articles, weapons, and ammunition. These operatives, 
designated as Specialists in Weapons and Explosives, are assigned to 
dedicated Weapons and Explosives Inspection Offices located throughout 
Spain.245 While in other Member States, the responsibilities may be fragmented 
among multiple authorities, the Spanish Guardia Civil has a central role and its 
specialists can carry out controls on any type of transaction related to weapons, 
explosives, pyrotechnics and ammunition in the whole of Spanish territory (entry 
points, airports, etc.).246  

3.3. 

Study area 3: Potential use of substances 
covered by Regulation (EU) 2019/1148 on 
explosive precursors to make illegal pyrotechnic 
articles 

This section examines the potential use of explosive precursors in the 
manufacture of pyrotechnic articles and assesses whether existing EU 
rules effectively prevent their misuse for the illegal pyrotechnic 
production. 

3.3.1. 

Introduction 

Rationale and objective of study area 3 

The rationale for area 3 stems from growing concerns about the misuse of 
pyrotechnic articles in criminal activities, particularly in the context of access 
to restricted explosive precursors under Regulation (EU) 2019/1148.  

Explosive precursors are chemicals that can be used to manufacture HMEs and 
have been exploited in terrorist attacks. Regulation (EU) 2019/1148 was 
introduced to restrict access to these substances, thereby reducing the risk of 
their misuse.  

As access to explosive precursors has become more difficult, there is the risk 
that criminals may be turning to alternative sources, namely, pyrotechnic 
articles, particularly category F4 ones, to carry out criminal activities (as 

243   Survey addressed to NCAs: one Member State. 
244   Interview with one Member State authority. 
245   Survey addressed to NCAs: one Member State. 
246   Interview with one Member State’s authority; survey addressed to NCAs: one Member State. 

69 

 
 
 
 
indicated in area 1). These pyrotechnic articles can be used on their own or 
potentially be repurposed to create IEDs. 

This study area, therefore, seeks to determine whether such pyrotechnic articles 
are  being  illegally  manufactured  from  scratch,  which  would  require  access  to 
explosive  precursors (as  they  are components  of the pyrotechnic  mixtures),  or 
whether  legally  produced  pyrotechnic  articles  are  being  diverted  into  illegal 
channels (to be misused). Understanding this distinction is critical for assessing 
the effectiveness of the current regulatory framework.  

Specifically, this area aims to: 

●  Understand whether pyrotechnic articles are illegally manufactured, and 

if so, how this occurs; 

● 

● 

Identify the chemical substances traditionally used in the legal 
manufacturing of pyrotechnic articles; 

Investigate whether there are any differences in the illegal manufacture 
of pyrotechnic articles; 

●  Explore whether Regulation (EU) 2019/1148 on explosive precursors 
covers the chemical substances used to make (legal and illegal) 
pyrotechnic articles; 

●  Map the type of misuse. 

It should be noted that this area does not provide a comprehensive assessment 
of how Member States implement Regulation (EU) 2019/1148. This was 
decided during the inception phase of the study (as it should be done by the 
parallel study launched by the European Commission247). Where feasible, it 
incorporates the views of consulted stakeholders on whether differences in the 
national enforcement of Regulation (EU) 2019/1148 (in relation to explosive 
precursors used to make legal pyrotechnic articles) could be potentially 
exploited by criminals to make illegal pyrotechnic articles. 

The following section outlines the relevant framework within which the research 
for area 3 operates.  

Background 

Despite the restrictions introduced with the Pyrotechnics Directive 2013/29/EU, 
reports indicate that enforcement challenges linked to this Directive might 
persist as criminals and terrorists access and misuse the more strictly 
regulated pyrotechnic articles, including the F4 category ones.248 Europol 

247   Study supporting the evaluation and impact assessment of Regulation (EU) 2019/1148. 
248   Europol, Pyrotechnics in the EU: State of Play 2024 (source not available to the general public). 

Justice and Home Affairs Council of the Netherlands, Modify the Pyrotechnics Directive for the sake of 
public order and safety. Non-paper by the Netherlands 2023. Link 

70 

 
 
 
 
reported the emerging trend of criminals,249 terrorists and violent extremists250 
increasingly planning to use or using pyrotechnic articles in making 
IEDs251 to carry out attacks.252  

It is difficult to clearly establish whether the pyrotechnics, including F4 ones, 
misused by criminals are made legally and diverted to the black market  - which 
would imply challenges with the enforcement of of Pyrotechnics Directive 
2013/29/EU - or are made illegally and used for criminal purposes - which would 
also imply challenges with the enforcement of the Regulation (EU) 2019/1148 
that poses conditions to access explosive precursors, which are a chemical 
component to make pyrotechnics.253  

Regulation (EU) 2019/1148 in this context 

In case criminals make illegal pyrotechnic articles, a  key element to consider is 
Regulation (EU) 2019/1148 on explosive precursors, as criminals would 
need to get – illegally – access to restricted explosive precursors.   

In fact, explosives precursors are chemicals that have been increasingly 
used over the last decade in the pyrotechnic industry as part of the 
pyrotechnic mixtures.  

However, Regulation (EU) 2019/1148 poses strict conditions to access 
restricted explosive precursors (see section 3.2.2).  

In the past, these substances were misused by criminals for making HMEs.254 
Examples of HMEs are different mixtures of ammonium nitrate, i.e. a restricted 
explosive precursor, with other easily available products, such as gasoline,255 or 
sugar256. The Regulation was adopted in response to the 2015-2016 terrorist 
attacks across the EU, as the frequent use of such explosive precursors in 
attacks pushed for more stringent rules and tighter controls.257 The Counter-

249   Examples are: pyrotechnics used to facilitate ATM attacks and serious and organised crime-related 

violence. 

250   Examples are: pyrotechnics used to carry out incidents related to violent extremism (e.g. during 

protests) or used in terrorism-related propaganda and plots.  
NL Times, Arrest made in terrorism bomb plot at Dutch Covid-19 vaccination site. Link 

251   Improvised explosive devices (IEDs) are often used by terrorists and criminals to cause harm, 

destruction, and fear. They can be made of chemical, biological, radiological, and nuclear (CBRN) 
agents. 

252   Europol, Pyrotechnics in the EU: State of Play 2024 (source not available to the general public). 

Europol, EU Serious and Organised Crime Threat Assessment 2025 (EU-SOCTA). Link 

253   Establishing whether a pyrotechnic article was legally produced or not becomes particularly difficult 

following an explosion or misuse incident. National competent authorities have reported that in many 
cases including involving F4 category pyrotechnics, the physical evidence left behind is insufficient to 
verify the origin or legality of the item. 

254   Homemade Explosives (HMEs) refer to the explosive material itself, which is usually created using 

readily available chemicals and other materials. Improvised Explosive Devices (IEDs) make reference 
to the entire device used for carry out an explosion, including the explosive material along with other 
components. 

255   ANFO (ammonium nitrate fuel oil) is an explosive made up of ammonium nitrate and gasoline. Link 
256   ANIS is an explosive made up of ammonium nitrate and sugar. Link 
257   Regulation (EU) 2019/1148 rreplaced and strengthened Regulation (EU) No 98/2013. 

71 

 
 
 
 
Terrorism Agenda and Security Union Strategy of 2020 emphasised the need to 
continue efforts in preventing the misuse of explosive precursors and alternative 
chemicals for manufacturing HMEs.258 The Regulation has made procuring 
explosive precursors more difficult for members of the general public to reduce 
the risk that these precursors fall into the hands of terrorists and criminals while 
safeguarding their legitimate use (e.g. for industrial purposes). To achieve this, 
a more harmonised framework and stringent controls on the sale and 
distribution of certain explosives precursors must be imposed, combined with a 
reporting obligation for suspicious transactions, thefts and disappearances. 
Despite the Regulation introducing stricter rules and controls on explosive 
precursors, if criminals access the most strictly controlled explosive precursors 
(including to make pyrotechnic mixtures), this would signal that challenges 
remain in its enforcement. 

It is important to note that, while Regulation (EU) 2019/1148 poses limitations 
for public access to those explosive precursors, pyrotechnic articles, as 
defined under the Pyrotechnic Article Directive 2013/29/EU, are not 
included under the scope of the Regulation. Article 2(2)(b) of Regulation 
(EU) 2019/1148 specifies that the scope of application does not extend to 
pyrotechnic articles as defined in point (1) of Article 3 of Directive 2013/29/EU. 
This means that pyrotechnic articles, as defined in Directive 2013/29/EU, are 
exempt from these restrictions. This exemption applies only to finished 
pyrotechnic products, as they fall under Directive 2013/29/EU.  

Regulation (EU) 2019/1148 controls the sale and possession of certain 
chemicals to the general public, and it imposes obligations on professional 
users and economic operators, including licensed manufacturers of (legal) 
pyrotechnic articles, in relation to the verification, reporting, and secure handling 
of these substances. The Regulation does not prohibit the use of substances by 
legitimate actors; rather, it ensures that such access is controlled, traceable, 
and secure.259 Moreover, as a result of the stricter rules on accessing explosive 
precursors, pyrotechnic articles have become a more attractive alternative, 
compared to explosive precursors, for criminals seeking to manufacture 
or use IEDs.260 This is considering that pyrotechnic articles are generally 
products available to consumers; while only a limited number are more 
restricted and addressed to professionals, although the study points to the 
possibilities of criminals acquiring such heavy pyrotechnics. For instance, 
acquiring pyrotechnic articles categorised as F4 requires a license. In addition, 
F4 category pyrotechnics articles, while extremely powerful, are also easier to 
handle or more stable compared to some substances used to make HMEs, 
such as the highly sensitive triacetone triperoxide (TATP).261 This relative 

258   European Parliament, Explosives precursors. Fighting the misuse of chemicals by terrorists. Link 
259   European Commission, Evaluation study of Pyrotechnics’ Legislation, Interim report. Source not 

available to the general public.  

260   Europol, Pyrotechnics in the EU: State of Play 2024. Source not available to the general public. 
261   Justice and Home Affairs Council of the Netherlands, Modify the Pyrotechnics Directive for the sake of 

public order and safety. Non-paper by the Netherlands 2023. Link 

72 

 
 
 
 
stability of F4 category pyrotechnics articles (compared to TATP) may further 
incentivise their misuse in the construction of IEDs. 

Finally, the Pyrotechnics Directive 2013/29/EU does not prescribe specific 
penalties, leaving it to Member States to establish rules on penalties applicable 
to infringements by economic operators of the provisions of national law 
adopted pursuant to the Directive and their implementation. Such rules may 
include criminal penalties for serious infringements. This disparity in sanction 
severity may contribute to the different levels of attractiveness of pyrotechnics 
for criminal purposes. Regulation (EU) 2019/1148 does not define specific 
penalties. Instead, it mandates that each Member State must establish its own 
penalties for violations such as unauthorised possession, acquisition, or use of 
restricted explosive precursors. Therefore, both instruments require Member 
States to define and enforce penalties at the national level. Therefore, any 
comparison must be based on national implementing rules.262  

For illustrative purposes, France foresees (by referring to the Environmental 
Code263) that economic operators who violate national laws derived from the 
Pyrotechnics Directive 2013/29/EU face both administrative and economic 
sanctions, with fines up to €150,000 and imprisonment up to two years. It also 
establishes the revocation of licenses as an additional measure.264 Regarding 
explosive precursors, France sets penalties265 for economic operators failing to 
comply with the requirements (including to verify, record, or report transactions) 
and for unauthorised individuals or legal entities (acting for non-professional or 
non-commercial purposes) for the possession or use of restricted explosive 
precursors. These penalties are accompanied by complementary measures, 
such as confiscation of items.266  

262   The comparison of national legislation is outside the scope of this study. 
263   French Environmental Code, Link 
264   French transposing legislation: Order of September 30, 2013; Decree No. 2015-799 of July 1, 2015. 

Link 
European Commission, Evaluation study of Pyrotechnics’ Legislation, Interim Report. 

265   Reference is made to the contravention classes (3rd, 4th and 5th class) and fine amounts (Article 131-
13 of the French Penal Code): 3rd class  €450, 4th class €750, 5th class €1,500. For legal entities, the 
fine can be increased compared to the one for individuals. 

266   Decree No. 2021-1033 of August 4, 2021 relating to the limitation and control of the marketing and use 

of explosive precursors. Link 

73 

 
 
 
 
3.3.2. 

Legal and illegal manufacture of pyrotechnic articles and 
links with Regulation (EU) 2019/1148  

Substances used in legal pyrotechnics manufacturing  

Composition and legal manufacturing of pyrotechnics  

From a chemical point of view, pyrotechnic articles generally contain an 
oxidising agent and an easy-to-oxidise fuel, producing lots of gas. 

They are made of various pyrotechnic mixtures, the most basic being the 
‘black powder’. Black powder is a combination of the following elements: 
charcoal,267 potassium nitrate,268 and sulfur269. In such a mixture, charcoal and 
sulphur act as energy sources/fuel and react with potassium nitrate, which is an 
oxidiser that supplies the necessary oxygen to sustain combustion. The 
percentage of these ingredients varies, and metals can be added to the mixture 
to produce different colors, e.g. strontium carbonate (red), barium chloride 
(green), and copper compounds (blue). Black powder has to come into contact 
with a heat source to explode, and it generally burns more slowly, produces 
smoke and less intense light (compared to flash powder; see below).270 

Currently, black powder is subject to strict controls under Directive 2014/28/EU 
on explosives for civil use.271 Such controls are related to licensing and 
traceability, storage and transport requirements, market surveillance and 
marking requirements. 

Beyond black powder, additional ingredients have been added to create 
new pyrotechnic mixtures, including a number of explosive precursors. 
Today, only 10 to 15% of the pyrotechnic mixture comprises the black 
powder.272  

267   An amorphous form of carbon produced by partially burning or oxidizing wood or other organic matter. 

Link 

268   A chemical compound composed of potassium ions and nitrate ions. It has a variety of applications, 
including as fertilisers, in pyrotechnic mixtures, food preserver, and rocket propellants. Link and Link 
Potassium nitrate is classified as a reportable explosives precursors (Annex II of Regulation (EU) 
2019/1148). 

269   A chemical element. It is a non-metal and is found naturally in various forms, including as a yellow 

crystalline solid. This substance is used in the following products: fertilisers, plant protection products 
and explosives. Link and Link 

270   Joukowsky Institute for Archaeology and the Ancient World, Gunpowder: Origins in the East. Link 

NASA Glenn Research Center, The Process of Combustion. Link 

271   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 for civil uses (recast) Text with EEA relevance, OJ L 96, 29.3.2014, p. 1–44. 
Link 

272   Specialised knowledge acquired by the study team during exchanges with industry representatives as 

pa. 

74 

 
 
 
 
Use of explosive precursors in the legal production of pyrotechnics  

Explosive precursors are ingredients added to the pyrotechnic mixture for 
various reasons: economic efficiency, as some precursors can be more 
cost-effective than traditional pyrotechnic ingredients; performance 
enhancement, with certain chemicals, such as chlorates (potassium chlorate 
and sodium chlorate),273 perchlorates (potassium perchlorate and sodium 
perchlorate),274 and ammonium nitrate,275 being reactive and sensitive, allowing 
for more performing mixtures; and mixture potentiation, where these 
precursors enhance the overall effectiveness of the pyrotechnic mixture.276  

Risks of category F4 pyrotechnics 

This shift in composition has implications for security, particularly in the case of 
high-risk articles like those in Category F4 (high hazard) pyrotechnic articles, F4 
bangers and flash bangers, since they have been predominantly reported in 
seizures and are known to be misused in criminal activities.277 Category F4 
articles are made of a pyrotechnic mixture typically containing potassium 
perchlorate, i.e. an explosive precursor, acting as oxidiser, combined with 
various metal powders, such as aluminium powder acting as fuel, and are 
designed to produce loud sounds and intense flashes. This mixture is known 
as ‘flash powder’.278 Flash bangers of Category F4 are considered high-risk 
due to the high explosive power of their flash powder load.279 They generally 
pose a greater threat than bangers, as they contain a less stable mixture that 
reacts more easily and with greater results than black powder. Most importantly, 
currently there is no upper limit imposed on the composition of the F4 articles 
regarding their Net Explosive Content (NEC), unlike for categories F1 to F3 
pyrotechnics articles. A flash banger usually contains a couple of hundred 
grams of pyrotechnic mixture (per unit).280 This amount is very powerful and 
equivalent to a hand grenade.281  

273   Potassium chlorate and sodium chlorate are classified as restricted explosives precursors (Annex I of 

Regulation (EU) 2019/1148). 

274   Potassium perchlorate and sodium perchlorate are classified as restricted explosives precursors 

(Annex I of Regulation (EU) 2019/1148). 

275   Ammonium nitrate is classified as restricted explosives precursors (Annex I of Regulation (EU) 

2019/1148). 

276   Information based on specialised knowledge of the study team. 
277   Council of the European Union, Draft report of action 11.9 Explosives – fireworks, pyrotechnics and 

their precursors, 8577/1/23. Link  

278   D. Coppe, S. Impemba,, Flash Powder: Introduction, Risks and Experimental Tests. Link 
279   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 

280   Council of the European Union, Draft report of action 11.9 Explosives – fireworks, pyrotechnics and 
their precursors, 8577/1/23. Link. Summary report of the workshop organised for this study (12 
September 2025): a Member State authority reported on incidents taking place in the Netherlands 
often involving flash bangers containing between 25 and several hundred grams of flash powder. 

281   Europol, Pyrotechnics in the EU: State of Play 2024. Source not available to the general public. 

75 

 
 
 
 
Regulatory framework in place 

Given the risks, the EU has implemented measures to control access to 
explosive precursors. As indicated above, the pyrotechnics industry uses 
chlorates and perchlorates nowadays.282 These chemicals are explosive 
precursors, subject to Regulation (EU) 2019/1148 and cannot be made 
available to the general public at concentrations above 40% w/w. Ammonium 
nitrate is also classified as a restricted explosive precursor, with a limit value of 
16% w/w of nitrogen in relation to ammonium nitrate. 

Annex I and Annex II of Regulation (EU) 2019/1148 list respectively 
the restricted explosives precursors and reportable explosives 
precursors. Annex I includes substances that are not to be made available to, 
introduced, possessed, or used by members of the general public, whether on 
their own or in mixtures, unless the concentration is equal to or lower than the 
limit values set out in the Regulation. Suspicious transactions, significant 
disappearances, and thefts of these substances must be reported within 24 
hours. On the other hand, Annex II lists substances that, whether on their own 
or in mixtures, require reporting suspicious transactions, significant 
disappearances, and thefts within 24 hours, but do not have the same 
restrictions on availability and use by the general public. 

Underlying reasons for the regulatory framework in place 

There is a difference in the motives behind the adoption of Directive 
2013/29/EU and Regulation (EU) 2019/1148, although they share the same 
legal basis. Recognising that the two instruments are based on different needs 
is important. The Pyrotechnics Directive 2013/29/EU (Article 1) establishes 
rules designed 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. It allows 
Member States to regulate access to pyrotechnic articles further. The primary 
focus of the Directive is regulating the legal making available on the market of 
safe pyrotechnical articles and, thus, cannot, in its own right, address the 
criminal misuse of pyrotechnic articles. In contrast, Regulation (EU) 2019/1148, 
although also based on ensuring the well-functioning of the internal market, was 
intended by the EU to respond to waves of terrorist attacks involving HMEs.283 

The misuse of pyrotechnic articles by criminals has been a central topic of 
discussion at the EU level. Participants of the Expert Group on Pyrotechnic 
Articles pointed out that future initiatives linked to Directive 2013/29/EU should 

282   Based on exchanges with the industry organisations as part of case study A. 
283   Based on the policy background and text of the two legislative instruments.  

76 

 
 
 
 
explore security aspects, as the Directive currently focuses on safety rather 
than security.284  

On this topic, in June 2025, the Council of the European Union raised the 
urgency of addressing the misuse of pyrotechnic articles as it poses a 
significant and evolving risk to public safety and internal security across the 
Union. It acknowledged that Directive 2013/29/EU primarily focuses on product 
safety and the free movement of pyrotechnic articles within the internal market. 
However, recent trends show that this is insufficient, and the Council stressed 
the need to better address the security dimension. It called for stronger 
enforcement of existing rules, particularly regarding online access to 
pyrotechnics, traceability of products, and harmonised classification of 
categories, especially for high-risk articles such as those in category F4. Also, 
the Council urgently invited the European Commission to, among others, 
evaluate the measures taken at the EU level and take action to strengthen the 
regulatory framework and develop legislative proposals to prevent the illicit 
production, trade (including online), and use of dangerous pyrotechnic 
articles.285 

Substances used in illegally manufactured pyrotechnics 

Scale and nature of illegal manufacturing of pyrotechnics 

Illegal pyrotechnics manufacturing is understood as individuals or (criminal) 
groups producing, assembling or modifying pyrotechnic articles and intentionally 
not complying with the legal requirements as laid out in the Pyrotechnics 
Directive 2013/29/EU.286  

The illegal manufacture of pyrotechnic articles is a complex and 
clandestine activity, making it challenging to obtain precise information on the 
size of this activity287 and the chemical substances used in this 

process. Different levels of data collection exist across Member States.288  

284

   European Commission, Expert Group, Draft Report of action 11.9 Explosives – fireworks, pyrotechnics 

and their precursors – Brussels, 30 May 2023. Link 

285   Council of the European Union (2025), Council conclusions on combating trafficking of weapons and 

fighting threats stemming from firearms and pyrotechnic articles, 9907/25. Link 

286   Typology used for this study. 
287   Surveyed national authorities assessed the significance of the manufacturing of illegal pyrotechnics in 
their country, with fourteen authorities assessing it as ‘minimal’ (0 on a scale of 5), seventeen as ‘low’ 
(1 on a scale of 5), eight as ‘somewhat significant’ (2 on a scale of 5), five as ‘moderate’ (3 on a scale 
of 5), and none as ‘high’ or critical’. Stakeholders’ input coming from industry representatives also 
largely indicated as ‘non-significant (less than 10% of the licit pyrotechnics production)’ the scale of the 
illegally produced pyrotechnics market within the EU. 

288   Follow up questionnaire addressed to national competent authorities: response from one Member 
State. Authorities from a Member State reported having carried out 736 interventions in the area of 
illicit production, possession and marketing of pyrotechnic articles in the period from 1 January 2020 to 
31 December 2024.  

77 

 
 
 
 
The research conducted as part of case study A (Annex II, section on 
production) has shed light on the illegal production of pyrotechnic articles 
across several Member States. It mapped key Member States interested by the 
illegal production, identified the types of sites involved (ranging from small-scale 
operations in garages and apartments to concealed workshops in commercial 
premises) and profiled both the producers (often organised crime groups, such 
as the Camorra operating in the region of Campania, Italy) and the end users 
(including private individuals seeking cheaper fireworks, sport enthusiasts using 
hand-manufactured articles during sport events, criminal networks using them 
for signaling illegal activities, e.g. alerting on drug delivery, or intimidation). 
Despite these valuable insights and a tentative mapping of substances used in 
the illegal manufacturing of pyrotechnic articles, the study team faced limitations 
in identifying and understanding how unauthorised individuals/groups gain 
access to such substances, often strictly regulated.289 The available information 
remains largely anecdotal, reflecting differing national contexts and varying 
levels of efforts dedicated to this topic. It relies on the experiences shared by 
consulted stakeholders rather than resulting from direct forensic evidence or 
systematic analysis of seized materials retrieved as part of investigations.290 

A close look at the illegal production is provided for Italy, France and Spain in 
Annex III. 

According to consulted stakeholders, illegal manufacturing is an emerging trend 
that poses significant security risks requiring close monitoring. Information 
collected suggests that illegal production is localised and significant in specific 
contexts. Illegal manufacturing sites, including ones producing unlicensed 
pyrotechnics similar to certified F4 pyrotechnics, have been detected in a 
limited number of EU Member States.291 Italy stands out as a major hotspot, 
with authorities estimating that illegal production accounts for 25–50% of the 
national pyrotechnics market, often operated through family-run businesses.292 
These sites often produce counterfeit pyrotechnics that do not comply with EU 
safety standards.293 Targeted research conducted for selected Member States, 

289   Considering its scope, the study did not include an evaluation of the effectiveness of measures set 

under Regulation (EU) 2019/1148 in relation to access to explosive precursors. At the interim stage, 
the study team agreed with the European Commission to adjust this research,, considering a parallel 
initiative on the evaluation and impact assessment of Regulation (EU) 2019/1148. 

290   Case study A. 
291   The study does not provide a precise count of EU Member States affected by illegal manufacturing of 
pyrotechnics. Case study A offers country-level insights for key pyrotechnics-producing countries, i.e. 
Poland, Germany, Portugal, France, Italy, and Spain. Apart from the case of Italy, Portugal also 
reports evidence of a parallel market, with seizures and unregistered operators, while France has 
launched over 100 judicial proceedings in the past five years against individuals suspected of 
manufacturing pyrotechnic powders, some of which were intended for fireworks, although industrial-
scale sites are not common. Germany and Poland have reported limited but existing cases, mostly 
involving homemade firecrackers. 

292   Information collected points that the illegally produced pyrotechnics articles seem to account for an 

estimated 25-50% of the overall market. 
Survey addressed to NCAs: one Member State; Linkiesta. (2016). Il 50 per cento dei botti di 
Capodanno non è a norma, in Italia esplode il mercato illegale. Link  

293

   Case study A.  

European Commission, F4 Flash Bangers in EU Member States. Study on production, import and use 

78 

 
 
 
 
namely Poland, Germany, Portugal, France, Italy and Spain, revealed varying 
degrees of concern, ranging from substantial evidence and judicial proceedings 
to isolated seizures and rare instances of homemade production. Broader 
insights were gathered through the survey, with a minority seeing the illegal 
production as somewhat significant or moderate, while most see it as a limited 
or localised phenomenon.294 

An EU agency reported a significant presence of illegally produced F4 
category flash banger pyrotechnics on the illegal market,295 and already in 
2016, it was found that limitations on imports from China to the EU, particularly 
concerning flash bangers, had led to an increase in illegal production of F4 
articles within the EU.296 

Substances used in the illegal production of pyrotechnics  

Various stakeholders suggested that the illegal production of pyrotechnics 
often involves using the same or similar chemicals as those used in legal 
manufacturing,297 making detection and differentiation difficult.298 This 
assumption is based on the observation that illegal manufacturers aim to 
replicate the effects and appearance of legally produced pyrotechnics. 

Numerous seizures of large quantities of F4 flash bangers (e.g.in the 
Netherlands)299 have shown that these items are frequently counterfeit. The high 
demand for such products and the profitable market have led to the emergence 
of many imitations. These counterfeit items seem to replicate the look of 
original F4 flash banger products by using similar external components. 
However, the flash powders in these imitations may differ in quality or 
quantity (lower concentration of substances) and are often combined with 
other materials, e.g. sawdust or gravel, to cut costs and avoid 
detection.300 

in the EU of high risk pyrotechnic articles categorised F4 according to Directive 2007/23/EC and 
Directive 2013/29/EU. Source not available to the general public. 

294   The majority of respondents from national authorities (31 out of 44, or 70%) consider illegal 

manufacturing of pyrotechnics to be a minimal or low issue in their country. Only a small minority (13 
out of 44, or 30%) see it as somewhat significant or moderate. These responses represent authorities 
from 22 different Member States. 

295   Interview with an EU agency. 
296

   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. Source not available to the general public. 

297   Survey addressed to NCAs, Responses to Q28. ‘What types of explosive mixtures are most commonly 

extracted from pyrotechnics for illicit use?’; interview with an EU institution.  

298   Detection of illegal pyrotechnic articles could be facilitated with chemical tags to be added to the 

substances used for the legal production of pyrotechnic articles. However, the stakeholders indicated 
that this would be practically difficult to implement and costly.  
Interviews with one industry organisation/ industry representative association and an EU institution. 

299  Summary report of the workshop organised for this study (12 September 2025): a Member State 

authority reported that many heavy flash bangers seized in the Netherlands lack CE markings, 
indicating illegal production, and falsified CE labels are also frequently encountered. These dynamic 
underscores the ongoing risks posed by both the availability of powerful pyrotechnics and the 
adaptability of criminal actors in sourcing materials for illicit use. 

300   Europol, Pyrotechnics in the EU: State of Play 2024. Source not available to the general public. 

79 

 
 
 
 
Several chemical substances were consistently reported as suspected of 
being used in the illegal production of pyrotechnic mixtures, particularly for 
black powder and to produce flash bangs.301 These substances include: 

●  Under Annex I of Regulation (EU) 2019/1148, ammonium nitrate, 

hydrogen peroxide and potassium perchlorate; 

●  Under Annex II of Regulation (EU) 2019/1148, aluminium powder, 

magnesium powder, potassium nitrate, and sodium nitrate.  

These substances are often combined in varying ratios as key components in 
pyrotechnic powders and compositions. Mixtures of magnalium powder (used 
as a substitute for the classic light metal powders),302 potassium perchlorate 
and sulphur are increasingly being detected when analysing flash-bang sets.303  

Despite the identification of these substances, a stakeholder highlighted the 
difficulty in tracing their use in the illegal manufacturing of pyrotechnic articles. 
In many cases, it is not possible to determine whether seized IEDs were 
produced from raw precursors or taken from commercial pyrotechnics. This 
ambiguity complicates enforcement and risk assessment efforts.304 

Overall, the research pointed out that the chemicals used in the illegal 
production of pyrotechnics might be generally similar to or the same as those 
used in the legal production.305 Moreover, production often takes place in 
illegal sites within the EU that do not adhere to all the requirements, such 
as licensing and do not meet compliance standards.306  

Production vs diversion  

At the same time, the broader concern lies with the criminal misuse and 
import of non-compliant pyrotechnics from source or transit countries 
outside the EU, from Asia (China) and non-EU neighbouring countries. 
Some EU Member States were also mentioned by stakeholders as countries 
from which pyrotechnics are purchased online and shipped across borders.307  

301   Follow up questionnaire addressed to national competent authorities: response from three Member 

State.  

302   Magnalium is a mixture (alloy) of aluminum [...] and magnesium [...], both of which are listed in Annex 
II of Regulation (EU) 2019/1148. Therefore, magnalium powders (particle size < 200 micrometers) and 
products containing more than 70% of such powders are subject to the notification requirements under 
the Regulation 

303   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

304   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

305   Survey addressed to NCAs, Responses to Q28 ‘What types of explosive mixtures are most commonly 

extracted from pyrotechnics for illicit use?. 

306   Survey addressed to NCAs, Responses to Q7 ‘Manufacturing of illegal pyrotechnics’; Q9 ‘What types 
of criminal activities involving pyrotechnic articles are prevalent in your country? Please select all that 
apply’. 

307   Summary report of the workshop organised for this study: stakeholders from the industry (EU level) 

also referred to illegal products imported from third countries, with Albania cited as a significant source 
of flash bangers. 

80 

 
 
 
 
In their joint non-paper, the Netherlands and France raised concerns about the 
influx of non-compliant pyrotechnic products manufactured outside the EU, 
particularly from Asia. These products often enter the EU market without 
meeting the necessary conformity and safety standards. The paper questions 
the reliability of the current CE marking system, noting that many conformity 
assessments are conducted by notified bodies in Asia, where oversight is 
limited. This undermines the credibility of safety assurances and increases the 
risk of dangerous products circulating within the EU.308 

Case study A revealed that although illegal production within the EU is a topic 
worth keeping an eye on, particularly in specific national contexts, the 
diversion of legally produced pyrotechnic articles appears more 
prominent. Both seem to be linked with and impact the national authorities' 
enforcement level, as illegally manufactured articles are harder to detect.309 

Misuse of pyrotechnic articles and explosive precursors 

Shift from HMEs to pyrotechnics 

Tighter controls on explosive precursors introduced since 2019 have led to 
shifts in criminal activities.  

HMEs composed of restricted explosives precursors, such as TATP,310 have 
become increasingly difficult to produce and use due to mechanisms in place to 
restrict access to explosive precursors and to enhanced law enforcement 
controls on accessing and marketing of explosive precursors. Additionally, past 
failures in producing and using TATP, such as incidents during the synthesis 
process and malfunctions of IEDs equipped with TATP charges,311 have 
contributed to criminals looking for alternatives. Information collected by Europol 
suggests a shift took place with criminals procuring and utilising alternative 
types of explosives and bomb-making materials to avoid the restrictions on 

      According to survey responses, Poland, Czech Republic, Slovakia are frequently mentioned as 

countries from which pyrotechnics are purchased online and shipped across borders.  
Survey addressed to NCAs, Responses to Q23 ‘How would you estimate the scale of the illicit 
pyrotechnics market within your country?’; Q29 ‘Is Regulation (EU) 2019/1148 effective in preventing 
non-authorised persons from sourcing substances used to make illegal pyrotechnic articles?”; Q55 
‘What are the most common ways to purchase illegal pyrotechnics online’; Q56 ‘If other ways, please 
specify’. Q62 ‘What are the primary regulatory gaps?’. Survey addressed to industry representatives: 
Responses to Q20 ‘In your experience, how do criminals illicitly trade pyrotechnics?’; Q21 ‘If other, 
please specify.’; Q62 ‘What other emerging trends in the industry might impact the risk of misuse in 
the near future?’. See case study A in Annex II. 

308   Government of the Netherlands, République Française (2025), Modify the pyro directive to protect 

public order and safety. Link 

309   See case study A in Annex II. 
310   TAPT can contain restricted explosives precursors, such as hydrogen peroxide, and reportable 

explosives precursors, such as acetone. 

311   Chemical & Engineering News, Explosive used in Brussels isn’t hard to detect. Link 

Examples include the 2016 Brussels Airport bombings, where authorities recovered undetonated 
TATP-based devices, indicating synthesis or deployment issues due to the compound’s instability; and 
the 2015 Paris attacks, where some suicide vests containing TATP failed to detonate as intended, 
likely due to handling errors or degradation of the explosive material.  

81 

 
 
 
 
explosive precursors. Recently, one of the primary concerns has been the 
increasing availability of legal and illegal professional category F4 flash 
bangers, which contain powerful pyrotechnic mixtures, and can be 
acquired and used in the construction of IEDs.312 

Trends in IEDs construction 

The central issue emerging from desk research and stakeholder consultation is 
that, in the past few years, flash powder from F4 pyrotechnic articles, which 
includes explosive precursors, has been extracted by criminals to create 
more powerful explosives, e.g., to carry out attacks against other criminal 
groups or violent extremists, e.g., in protests against law enforcement 
authorities.313 

According to survey respondents (Member State authorities), the misuse of 
pyrotechnics for producing IEDs is generally considered rare, but it remains a 
significant concern that merits attention.314  

This has been observed particularly in the Netherlands, which in recent years 
has seen a significant rise in the use of IEDs, being made using flash powder 
extracted from professional-grade pyrotechnic articles, especially F4 flash 
bangers. This trend is reflected in the increase in the quantity of illegal fireworks 
confiscated in the Netherlands: whereas 61,000 kilograms were confiscated in 
2019, by 2022, this figure had surged to 684,000 kilograms. This increased 
number of confiscations is indicative of the growing misuse of professional 
pyrotechnic articles.315 

According to the stakeholder consultation, more than 90% of IEDs in the context 
of the violence among organised groups in Belgium and the Netherlands are 
prepared using flash powder obtained from pyrotechnics.316 Survey responses 

312   Europol, Pyrotechnics in the EU: State of Play 2024. Source not available to the general public. 

Summary report of the workshop organised for this study (12 September 2025): a Member State    
authority observed that F4 fireworks appear to be readily available via social media channels, driven 
by high demand on the illegal market.  

313   Interviews with an EU agency, authorities of two Member States. Survey addressed to NCAs, 

Responses to Q28. ‘What types of explosive mixtures are most commonly extracted from pyrotechnics 
for illicit use?’. Justice and Home Affairs Council of the Netherlands, Modify the Pyrotechnics Directive 
for the sake of public order and safety. Non-paper by the Netherlands 2023. Link 

       Summary report of the workshop organised for this study (12 September 2025): a Member State 
authority reported that IEDs can be made using lesser categories of fireworks, not just the most 
powerful ones. Another Member State authority highlighted that the F4 category provides particularly 
easy access to large quantities of flash powder at once. 

314   Survey addressed to NCAs, Responses to Q27. ‘In your experience, how prevalent is the misuse of 
pyrotechnics involving the extraction of mixtures contained in pyrotechnic articles which are used to 
produce Improvised Explosives devices?’ 
Responses received: Rare=26; Occasional=11; Frequent=9; Widespread=1.  

315   Justice and Home Affairs Council of the Netherlands, Modify the Pyrotechnics Directive for the sake of 

public order and safety. Non-paper by the Netherlands 2023. Link 

       Summary report of the workshop organised for this study (12 September 2025): a Member State 

authority reported that pyrotechnic articles are also commonly used as sources of flash powder for 
constructing IEDs. 

316   Interviews with an EU agency.   

82 

 
 
 
 
further corroborate this trend. For illegal use, black and flash powder are the 
most commonly extracted mixtures from pyrotechnics. One response 
highlighted minimal extraction of individual components; instead, the entire 
pyrotechnic mixture is transferred into another container, suggesting an illegal 
use method involving minimal processing.317  

Scenarios of misuse 

The misuse of explosive precursors and pyrotechnic articles can manifest 
in various ways, driven by different motivations and objectives. This merits 
attention as it forms the basis for understanding the issues at stake and their 
likelihood. Two potential scenarios have emerged.318 

A first scenario is a profit-driven illegal pyrotechnics manufacturing. In 
this scenario, criminals use a two-step illegal process to manufacture 
pyrotechnic articles for profit. Through illegal means, they first acquire explosive 
precursors, such as potassium perchlorate and aluminium powder. These 
substances are then used to create pyrotechnic articles sold on the black 
market. The financial incentives make this a lucrative venture, despite the 
significant risks of illegally obtaining and using these dangerous materials.  

The first scenario is particularly relevant if considering the illegal pyrotechnic 
manufacturing in Italy, as reported in case study A and country fiche on Italy, as 
presented in Annexes II and III. 

A second scenario is the illegal manufacturing of pyrotechnics to commit 
criminal or terrorist activities. The second scenario involves a three-step 
illegal process where criminals or terrorists acquire explosive precursors to 
manufacture pyrotechnic articles, which are then used in attacks. In some 
cases, these pyrotechnic articles are used directly in attacks; in others, their 
flash powder content is extracted to build more powerful IEDs. This includes 
obtaining restricted explosives precursors illegally, manufacturing the 
pyrotechnic articles despite rules and controls, and using them in various forms 
of violence, such as attacks against other criminal groups, terrorist activities, or 
confrontations with law enforcement during riots. Given the complexity and high 
risks associated with this process, it would be more practical for these 
individuals to acquire Category F4 pyrotechnic articles directly (either illegally 
made or legally made but acquired through illegal means) and extract the 
powerful flash powder they contain. This flash powder is extremely powerful and 
already contains (including restricted) explosive precursors, and can be used to 
create IEDs for attacks. As emerged during the consultation, flash powder is 
increasingly being extracted from F4 flash bangs. (Alternatively, restricted 

317   Survey addressed to NCAs, Responses to Q28. ‘What types of explosive mixtures are most commonly 

extracted from pyrotechnics for illicit use?’ 

318   Hypothetical scenarios developed by the study team based on information collected. 

83 

 
 
 
 
explosive precursors can be obtained illegally and mixed with easily obtainable 
materials to manufacture HMEs). 

The second scenario is particularly relevant if considering the use of IEDs, 
containing Category F4 pyrotechnic articles or flash powder extracted by such 
articles, as reported in case study B and country fiche on the Netherlands and 
Belgium, as presented in Annexes IV and V. 

3.3.3. 

Effectiveness in preventing misuse 

Considering the clandestine nature of the illegal manufacturing of pyrotechnic 
articles, the research encountered limitations in investigating how non-
authorised persons would have access to explosive precursors. The 
findings below are based on stakeholders’ opinions rather than hard evidence 
from investigations on material recovered at illegal production sites.  

As mentioned, to make illegal pyrotechnic articles, criminals would have to 
gain access to heavily regulated substances, such as restricted 
explosives precursors. Despite the Regulation’s restrictions, stakeholders 
noted that criminals continue to access explosive precursors, either by 
circumventing controls or exploiting gaps in enforcement, particularly for 
imports from non-EU countries. 

Stakeholders expressed mixed views on the effectiveness of Regulation (EU) 
2019/1148. On the positive side, both surveys’ responses (to national 
authorities and industry representatives) highlighted the effectiveness of 
Regulation (EU) 2019/1148 in certain areas, such as limiting public access and 
introducing suspicious activity reporting.  

Regarding limitations, substances used in illegal pyrotechnic manufacturing 
could be either already classified as explosive precursors (and are accessed by 
criminals in the EU, circumventing controls) or could not be effectively covered 
by the Regulation (EU) 2019/1148.319 While the Regulation applies equally to 
explosive precursors produced within the EU and those imported from third 
countries, the challenge lies in proper enforcement, particularly for substances 
sourced from non-EU suppliers (e.g. China).320 Uneven control level for imports 
has consequences for the EU area. 

While some consulted industry representatives point to the potential misuse of 
regulated explosive precursors to manufacture illegal pyrotechnics, the majority 
of industry respondents suggest that the issue lies less in the acquisition of 
explosive precursors to make illegal pyrotechnics and more in the 
diversion of pyrotechnic articles imported into the EU or legally 
manufactured in the EU. This highlights the need for ongoing vigilance and 

319   Interview with one industry organisation/ industry representative association. 
320   Interview with an EU agency. 

84 

 
 
 
 
enhanced enforcement measures to address the evolving tactics of those 
seeking to misuse these substances.321 

Responses from national authorities provide additional insights. They 
considered the Regulation effective in limiting the general public’s access and 
ensuring supply chain traceability. Notably, one respondent suggested that the 
measures introduced by Regulation (EU) 2019/1148 could serve as a 
model for controlling the trade of pyrotechnic articles, which are 
frequently diverted for malicious purposes.322 However, other respondents 
pointed out that, while Regulation (EU) 2019/1148 makes it more difficult to 
source explosive precursors, the relative ease in the procurement of high-
performance pyrotechnics, such as those of the F4 category, can circumvent 
these measures. They cautioned that if a ban on such pyrotechnics were 
implemented, the focus might shift back to sourcing explosive precursors.323 

At the same time, some consulted stakeholders paid greater attention to the 
practice of criminals extracting the mixtures (which include explosive 
precursors) contained within pyrotechnic articles, whether legally or 
illegally produced, to create powerful IEDs.324  

3.3.4. 

Challenges from differences in national enforcement325 

Explosive precursors are subject to EU rules to ensure their use for 
legitimate purposes while combating their misuse to make HMEs.326 

Regulation (EU) 2019/1148 has made procuring explosive precursors more 
difficult to minimise the misuse of these precursors by criminals while allowing 
their legitimate use (e.g. for industrial purposes).  

On Regulation (EU) 2019/1148, some stakeholders appreciated its roles in 
limiting access to explosive precursors and indicated that its verification upon 

321   Survey addressed to industry representatives, Q33. ‘To your knowledge, is any of the substances 
covered by Regulation (EU) 2019/1148 on explosives precursors used to make illegal pyrotechnic 
articles?’. At least 5 respondents (from national and EU-level industry associations) explicitly stated 
that diversion of pyrotechnic articles is the main issue, not the acquisition of regulated precursors. The 
majority of respondents (over 15 out of 25) did not identify the use of regulated precursors as a 
significant problem for illegal pyrotechnic manufacturing. 

322   Summary report of the workshop organised for this study (12 September 2025): a Member State 

authority suggested that the regulatory approach used for explosive precursors could be adapted for 
pyrotechnics. 

323   Survey addressed to NCAs: responses to Q29. ‘In your opinion, is Regulation (EU) 2019/1148 on 
explosive precursors effective in preventing non-authorised persons from sourcing the substances 
used to make illegal pyrotechnic articles?’. Survey addressed to NCAs: responses to Q30. ‘Please 
explain’. Summary report of the workshop organised for this study (12 September 2025): a Member 
State authority stressed that economic factors, like the low cost and high availability of pyrotechnics, 
must be considered in the study, warning that changes could lead to renewed use of traditional 
explosives. 

324   Interviews with authorities of three Member States, an EU institution and an EU agency; survey 

addressed to NCAs.  

325   The evaluation of Regulation (EU) 2019/1148 is subject to a separate study carried out by another 

contractor for the European Commission.  

326   European Commission, Legislation on chemicals used in Home Made Explosives. Link 

85 

 
 
 
 
sale obligation (Article 8) can indirectly support traceability. These control 
mechanisms could serve as a model for controls on pyrotechnics.327  

Despite Regulation (EU) 2019/1148, criminals still appear to be able to access 
such substances. A few stakeholders suggested that differences in the national 
level of enforcement of Regulation (EU) 2019/1148 might create opportunities 
for criminals to exploit less stringent requirements in certain Member States.328 
These differences might arise from the Regulation leaving discretion to 
Member States to regulate the public’s access to substances, and to 
introduce penalties,329 as well as from the different monitoring/licensing 
systems in place for precursors across Member States. 

Stakeholders mentioned the following concerns: the lack of awareness of 
restrictions among economic operators; and the continued availability of 
restricted substances.330 For instance, ammonium nitrate used in fertilisers is 
subject to control under Regulation (EU) 2019/1148, which applies irrespective 
of the quantity purchased. However, a stakeholder indicated the risk that control 
measures might not always be applied consistently at the local or national level 
across Member States.331. If the European Commission becomes aware of an 
inconsistent or incorrect application, it will act to ensure uniform and correct 
implementation of the Regulation throughout the EU. 

Also, while online marketplaces have different obligations compared to 
economic operators who sell or own the goods (since they provide only a 
platform), all economic operators, whether offline or online, are bound by 
the same rules under Regulation (EU) 2019/1148. Nevertheless, 
stakeholders have raised concerns that the approach to online 
marketplaces may not be sufficiently comprehensive,  potentially creating 
gaps that criminals can exploit to procure such substances. Among these 
vulnerabilities is the risk of insufficient compliance with monitoring and reporting 
obligations for online platforms.332 Platforms might not actively and sufficiently 
monitor transactions or report suspicious activities, which could result in a high 
number of unreported cases. This makes it challenging for authorities to detect 
and prevent illegal sales, especially when sellers and buyers can operate 
anonymously or use platforms that do not require robust verification procedures. 
Moreover, enforcement authorities often face resource constraints and technical 

327   Survey addressed to NCAs, Responses to Q29. ‘In your opinion, is Regulation (EU) 2019/1148 on 
explosive precursors effective in preventing non-authorised persons from sourcing the substances 
used to make illegal pyrotechnic articles?’. Responses to Q30. ‘Please explain your responses’. 

328   Interviews with an EU institution. 
329   It should be noted, however, that while penalties can differ, the Regulation requires that they be 

effective, proportionate, and dissuasive in all EU Member States. 

330   Survey addressed to NCAs, Responses to Q29. ‘In your opinion, is Regulation (EU) 2019/1148 on 
explosive precursors effective in preventing non-authorised persons from sourcing the substances 
used to make illegal pyrotechnic articles?’. Responses to Q30. ‘Please explain your responses’. 

331   Interview with one Member State’s authority.  
332   The DSA strengthens the regulatory environment for online marketplaces. Among other requirements, 

it introduces for online marketplaces the requirement to adopt measures to prevent the sale of illegal 
or unsafe goods and services offered on their platforms, and to collect and verify essential information 
about traders using their services. 

86 

 
 
 
 
challenges in monitoring and regulating online sales, making it harder to 
respond effectively to the evolving risks associated with online marketplaces. 
The issue is further exacerbated by cross-border selling, as goods purchased 
online can be shipped across borders with minimal scrutiny.333 

Looking forward, some suggestions to improve the current framework were 
made, such as: increased harmonisation of conditions to access explosive 
precursors across Member States (for Annex I explosive precursors ); 
introducing a centralised (potentially EU-level) tracking database of explosive 
precursors (to limit the ability of criminals to purchase undetected substances 
from multiple shops and source substances across borders); and adding 
chemical tags to explosive precursors (and to be used also in the production of 
pyrotechnic articles).334  

3.4. 

Study area 4: Cross-border exchange of 
information and cooperation 

This section reviews the current mechanisms for cross-border information 
exchange and cooperation among Member States. It highlights the 
challenges and opportunities for strengthening collective efforts against the 
criminal misuse of pyrotechnics. 

3.4.1. 

Introduction to cross-border exchange of information and 
cooperation 

Cross-border cooperation and information exchange form the cornerstone of 
tackling security threats in the EU. The new EU internal security strategy, 
ProtectEU, further emphasises the need for strengthening operational 
cooperation in security coordination between the EU, Member States and third 
countries.335 Similarly, the recent EU Serious and Organised Crime Threat 
Assessment (SOCTA) 2025 states the importance of deeper cooperation 
between various stakeholders, ranging from national authorities to civil society 
and private parties, in tackling the complex cross-border security challenges 
posed by OCGs.336 Solidified mechanisms and practices of cross-border 
cooperation and information exchange have been established in, for example, 
firearms and drugs trafficking. In the context of the criminal misuse of 
pyrotechnics, these tools seem less systematic and concrete. Similarly, 
information exchange and cross-border cooperation centres on certain Member 

333   Survey addressed to NCAs: responses to Q29. ‘In your opinion, is Regulation (EU) 2019/1148 on 
explosive precursors effective in preventing non-authorised persons from sourcing the substances 
used to make illegal pyrotechnic articles?’. Responses to Q30. ‘Please explain your responses’. 
334   Interviews with one industry organisation/ industry representative association, one Member State’s 

authority and an EU institution.  

335   ProtectEU (2025), Link 
336   SOCTA (2025), Link 

87 

 
 
 
 
States (such as Germany, Belgium and the Netherlands), which have taken a 
more active role in tackling the misuse of pyrotechnics. 337 Whereas in other 
Member States (e.g., Estonia, Sweden, Poland), cross-border exchange of 
information and cooperation remains more limited. 

The research indicates that one of the main reasons for the differences in the 
exchange of information and cross-border cooperation is that Member States 
experience the security threat to varying degrees. The survey results 
support this fragmented picture, whereby 32.5% of the Member States’ 
respondents stated that they exchange information with competent authorities 
and national contact points from other Member States to some extent.338 This is 
coupled with cross-border cooperation and information exchange, 
focusing mainly on investigations in ongoing cases rather than 
systematic approaches to prevention.339 The diverging understanding and 
urgency of the security issues related to the criminal misuse of pyrotechnic 
articles across Member States, combined with different penalties, demonstrates 
hindrances to effective cross-border cooperation and information exchange. 

The figure below on the life cycle of illegal pyrotechnics provides a visual 
representation of the points where cross-border cooperation currently occurs 
based on the information gathered. 

Figure 11 Life cycle of illegal and legal pyrotechnics 

Source: Consortium’s elaboration. 

Cross-border cooperation and information exchange occur mainly on 
nodes where the pyrotechnic articles shift from the legal sphere to the 
illegal sphere. Information is often shared on a need-to-know basis and 
bilaterally between Member States’ authorities rather than through EU-level 
mechanisms, such as Europol. Cross-border cooperation and information 
exchange in these nodes focuses primarily on investigations rather than 
prosecution or prevention. However, some Member States, such as France, 

337   Europol (2024). Pyrotechnics in the EU. State of Play. [Sensitive].  
338   The Member States Survey, N=40. 
339   Interviews with an EU Institution, an EU agency and one Member State authority. 

88 

 
 
 
 
 
Germany and the Netherlands, notify the respective national authorities of 
suspected illegal deliveries of pyrotechnic articles entering the other Member 
State as part of prevention efforts.340 

The following sections explore existing information exchange systems, types of 
cross-border cooperation, public-private cooperation and the barriers to 
information exchange and cross-border cooperation in tackling the criminal 
misuse of pyrotechnics. 

3.4.2. 

Extent of information exchange and cross-border 
cooperation on criminal misuse  

The findings from the stakeholder consultation and desk research demonstrate 
fragmented approaches to cross-border cooperation and information 
exchange among Member States. The survey results show that 32.5% of the 
Member States’ respondents stated that they exchange information with 
competent authorities and national contact points from other Member States to 
some extent.341 Whereas, Member States’ respondents report that information 
is exchanged to no extent with notifying authorities (27.5%), Europol (25%) and 
the European Commission (30%).342 This is supported by findings from the 
interviews, where national authorities stated that information exchange takes 
place normally between certain Member States and in a more reactive than 
systematic manner.343 One of the key reasons for variance in the extent of 
information exchange and cross-border cooperation among Member States 
seems to be the degree of impact of the issue.344 

The study team has conducted a mapping of existing information exchange 
systems at the EU-level and their use in the context of organised crime and 
terrorism. Evidence of their use in the context of pyrotechnics remains limited 
after the feedback collected from stakeholders. 

Information exchange systems at the EU-level 

The findings indicate that mechanisms for information exchange among EU 
Member States and EU institutions regarding organised crime and terrorism are 
in place, although they are utilised to different degrees in Member States. 

The first tool is the Secure Information Exchange Network Application 
(SIENA), which facilitates the secure and rapid exchange of sensitive crime-
related information, such as firearms and drug trafficking.345 SIENA has been 

340    Group interview with one Member State’s authorities. 
341    The Member States survey, N=40.  
342    Ibid, N=40. 
343   Interviews with EU agency and authorities of three Member States. 
344   See study area 1 for more in-depth analysis on the degree of the impact on Member States. 
345   Europol (2025) Link. At this stage of the study, one national authority has mentioned SIENA 

specifically as a tool they use for information exchange during the interviews.  

89 

 
 
 
 
solidified as one of the primary channels for law enforcement cooperation over 
the past decade. Feedback from stakeholders on the use of SIENA and the role 
of Europol in facilitating information exchange and cross-border cooperation 
regarding the misuse of pyrotechnics is fragmented. Some national authorities 
state that the use of Europol and its information systems is lacking among 
Member States, and there is a need for more involvement of Europol.346 
Whereas others state that Europol already plays a substantial role in tackling 
the security risks arising from the misuse of pyrotechnics.347  

Second, the Schengen Information System II (SIS II) is a centralised system 
that provides real-time alerts on individuals and objects across the EU and the 
Schengen Area during border and police checks.348 SIS is currently already 
being used in preventing criminals and terrorists from entering or moving within 
the EU undetected. Inquiry checks and alerts allow authorities to collect 
targeted information on suspects of organised crime and terrorism, including 
vehicles and other objects that might be used. Europol’s access to SIS II alerts 
within its operational domains could further facilitate more centralised 
intelligence sharing and cooperation on the criminal misuse of pyrotechnics. 

Third, the Internal Market Information System (IMI) is a secure, multilingual 
online tool that facilitates the exchange of information between Member States' 
authorities involved in the practical implementation of EU legislation. In the 
context of organised crime and terrorism, it is used, for example, for the transfer 
authorisations and refusals of firearms within the EU.349 This aims to enhance 
the traceability of firearms and deter citizens aiming to purchase firearms in 
another Member State, whilst having been rejected in one Member State. In the 
context of pyrotechnics, feedback from stakeholders remains limited on the 
potential use of IMI in deterring the security risks of pyrotechnics. Some 
stakeholders have suggested looking for examples of IMI in deterring firearms 
trafficking and possibly applying this to pyrotechnics.350 This could be explored 
under Article 4 of the IMI Regulation 1024/2012, which enables pilot projects for 
assessing the potential extension to additional areas.351 

Fourth, the Trans European Services for Telematics between 
Administrations Network (TESTA network, in the future TESTA EIRIS) is 
designed to facilitate the secure, reliable, and efficient exchange of electronic 
sensitive data between EU Member States.352 TESTA is employed in various 
contexts, including the fight against organised crime. By providing a private 
infrastructure segregated from the internet, TESTA supports the Explosives 
Control System to Prevent and Fight against Terrorism (SCEPYLT). 
SCEPYLT facilitates the approval of transfers of civil explosives within the EU 

346   Interviews with authorities of three Member States. 
347   Interviews with authorities of three Member States. 
348   DG HOME (n.d.) Schengen Information System, Link 
349   See Link 
350   Interview with an EU agency.  
351   Regulation 1024/2012 
352   European Commission (2021). Link 

90 

 
 
 
 
by electronically issuing transfer permits.353 This system is currently utilised by 
some EU Member States such as the Netherlands, Germany, Belgium, Estonia, 
Finland, France, Lithuania, Luxembourg, Poland, Portugal, Slovenia, Spain and 
Sweden.354 Authorities from Spain, Sweden and France stated that SCEPYLT is 
useful in the field of explosives, but it could be explored how to use the system 
for pyrotechnics.355 

It has been observed in this study that information exchange can occur either 
bilaterally or through dedicated information exchange tools. Many stakeholders 
(e.g., Italy, Spain, the Netherlands, Germany, France and Sweden) have 
reported that information on the criminal misuse of pyrotechnics is often 
exchanged bilaterally through emails, as the impact of the security issue on 
Member States varies. In this way, direct bilateral communication between 
Member States’ authorities constitutes a more efficient and quicker mode of 
information exchange than the use of the EU-level mechanism.356 However, 
reliance on bilateral information exchange tends to hinder harmonised 
approaches to information exchange at the EU-level as information and data on 
modus operandi, perpetrators, types of pyrotechnics used and other intelligence 
are not centrally recorded by, for example, Europol. This is further echoed in the 
recent Council Conclusions 12 June 2025 underscore the need to intensify 
cross-border cooperation with the support of Europol as the central information 
and knowledge hub.357 

In relation to Europol’s role, the agency supports the European Multidisciplinary 
Platform Against Criminal Threats (EMPACT) driven by EU Member States on 
tackling threats posed by organised and serious crime.358 The current policy 
cycle has included some information exchange on pyrotechnics, but mainly in 
connection to explosives. The upcoming policy cycle 2026-2029 will have more 
focus on pyrotechnics and their misuse.  

Type of cross-border cooperation 

Findings show that there is a certain degree of increased operational cross-
border cooperation among EU Member States, in particular from a law 
enforcement perspective.359 A recent Europol report highlighted the results of 
three recent cross-border investigation and enforcement actions in which 
Europol was involved.360 In 2018, Dutch authorities launched an initiative to 

353   European Commission (2011). Progress report on the implementation of the EU Action Plan on 

enhancing the security of explosives. Link 

354   Dutch Ministry of Infrastructure and Water (2024). Cabinet response to the Commission’s consultation 

regarding the European Procedure on explosives for civil use. [in Dutch] Link 

355   Interview with one Member State authority; workshop with stakeholders organised for this study, 

September 2025. 

356   Interviews with an EU agency and authorities of six Member States. 
357   Council conclusions on combating trafficking of weapons and fighting threats stemming from firearms 

and pyrotechnic articles, 12 June 2025. 

358   See: https://www.europol.europa.eu/crime-areas-and-statistics/empact 
359   Also mentioned by law enforcement stakeholders of two Member States; interview with an EU agency. 
360   Europol (2024). Pyrotechnics in the EU. State of Play. [Sensitive].  

91 

 
 
 
 
address the illegal online purchase of F4 pyrotechnics from Poland. European 
Investigation Orders (EIO) were exchanged between Poland, Germany, the 
Netherlands, and France, leading to the closure of four web shops in Poland, 
the arrest of 35 individuals, and the search of 150 properties.361 In 2022, 
German and Dutch authorities arrested eleven suspects and dismantled a 
criminal network trafficking fireworks, based on intelligence from the EncroChat 
operations.362 Another joint investigation that year led to the seizure of a large 
quantity of illegal fireworks intended for Dutch consumers.363  

The Member States’ respondents to the survey reported that the main types of 
cross-border cooperation concern criminal investigations (27.5%) and 
prevention of illegal trade and misuse (62.5%).364 Additionally, Member States’ 
respondents answered that information exchange should be improved in the 
areas presented in the figure below.  

Figure 12 Survey responses on the primary focus of cross-border cooperation 
and information exchange related to pyrotechnic articles. 

Other
8%

Coordination of 
prosecution of 
offenders
3%

Criminal 
investigations
27%

Prevention of illicit 
trade and misuse
62%

Source: Survey addressed to national authorities. 

The survey results highlight a primary focus on prevention which does not fully 
align with feedback received from the targeted interviews and the findings of the 
desk research. The targeted interviews and desk research highlighted more 
reactive and ad-hoc approaches to cross-border cooperation regarding the 
criminal misuse of pyrotechnics. Systematic intelligence sharing and more 
preventive approaches seem to be lacking, mainly due to the differences in 
national legislation and the impact of the security issue on Member States. 
Nevertheless, somewhat increasing attention has been paid to the preventive 
side of the security risks posed by pyrotechnics among Member States in 
various EU working groups. Almost all Member States have expressed the 

361   Ibid; Eurojust (2018). International cooperation disrupts illegal fireworks network. Link  
362   Ibid; Europol (2023). Dismantling encrypted criminal EncroChat communication leads to over 6500 

arrests and close to EUR 900 million seized. Link  

363   Ibid; Europol (2022). Heavy fireworks off the market for safer holidays. Link 
364   The Member States Survey, N=40.  

92 

 
 
 
 
 
need and willingness to take more preventive action on tackling the issue 
through for example, the set-up of the Pyro-Pass at EU-level or enforcement of 
product restrictions.365 

Operational cooperation among EU Member States from a market surveillance 
perspective appears to receive mixed opinions regarding the progress of cross-
border cooperation. The Administrative Cooperation Group (AdCo) for 
Pyrotechnic Articles plays a key role in discussing market surveillance issues 
and supporting the proper and uniform application of the EU legislation related 
to pyrotechnics. A previous study on the illegal sales of pyrotechnic articles 
destined to for professional users to the general public indicates that, while 
progress in cross-border cooperation on addressing the illegal trade of category 
F4 articles had been slow, the AdCo Group had been growing interested in this 
issue.366 This group, along with Europol and Eurojust, has been increasingly 
investing resources into addressing the illegal trade of pyrotechnic articles. 
However, it has been noted that this AdCo Group is not intended to be utilised 
as a forum to discuss criminal activities, especially those conducted by non-
licensed entities. Some of the difficulties underpinning the use of the AdCo 
Group for discussing issues related to the criminal side of pyrotechnics seem to 
be on the lack of institutional links between relevant authorities. The 
identification of relevant counterparts and national authorities in Member States 
seems to be challenging.367  

Public-private cooperation 

The study findings indicate that cooperation between the public and private 
sectors regarding the criminal misuse of pyrotechnics exists, but to a 
limited extent. The survey results of Member States demonstrate that 
information on the misuse of pyrotechnics is exchanged with the industry mainly 
to a limited extent (35%) and to no extent (22%).368 Meanwhile, responses to 
the industry survey show that information is exchanged with national competent 
authorities to a very large extent (40%) and with law enforcement authorities to 
a large or to a small extent (both at 31%).369 This is supported by feedback 
received from the interviews. Some stakeholders mentioned that the 
pyrotechnics industry is quite national and focus more on trade and consumer 
side of pyrotechnics, rather than security issues posed by pyrotechnics. 
Similarly, the communication lines between the industry and law enforcement 
seem lacking.370 This could be due to the lack of common understanding of the 
security issues posed by pyrotechnics. Initiating dialogue between the different 

365   Information retrieved from restricted documents. This was also supported by one Member State 

authority in the workshop with stakeholders organised for this study, September 2025. 

366   European Commission (2019). Study on illegal sales of pyrotechnic articles destined for professional 

users (category F4) to the general public.  

367   European Commission (2019). Study on illegal sales of pyrotechnic articles destined for professional 
users (category F4) to the general public; interviews with national authorities of two Member States. 

368   The Member States Survey, N=40. 
369   The industry survey, N=22 
370   Interview with one industry organisation/ industry representative association. 

93 

 
 
 
 
stakeholders on the risks of criminal exploitation of the industry in the context of 
diversion, illegal manufacturing, and illegal trade could support the industry to 
remain vigilant and report suspicious activity to the authorities. 

Yet, some stakeholders have stated that public-private cooperation would be 
useful in more effectively tackling the illegal manufacturing, diversion, and illegal 
trade of pyrotechnics.371 In some Member States, this is demonstrated by the 
close contact between national authorities and the pyrotechnics industry. In 
France, legally operating pyrotechnics companies cooperate with the French 
government. Through this cooperation, French authorities have knowledge of 
the companies engaged in illegal production and trade of pyrotechnics.372 
Similarly, Spain holds a national roundtable on pyrotechnics, where different 
government officials and law enforcement authorities discuss the ongoing 
issues with the pyrotechnics industry stakeholders. They meet several times a 
year to discuss industry issues and risks related to criminal exploitation of the 
industry.373 For instance, if there is suspicion of illegal pyrotechnics being 
brought in from abroad, the industry can inform the authorities. The relationship 
between the authorities and the industry is described as collaborative by the 
stakeholders interviewed, as both parties have a vested interest in maintaining 
the security and legality of pyrotechnics.374 In addition, some stakeholders have 
suggested, for example, establishing agreements on the type of data and 
information, and the format of cooperation between wholesalers and the 
national authorities. 375 However, this would require extensive coordination at 
the national level and would, therefore, necessitate the buy-in from both public 
and private stakeholders. 

Furthermore, inspiration could be drawn from other policy fields, where 
public-private cooperation is more solidified, such as explosives precursors 
and firearms. The European Commission holds regular dialogues with the 
industry and Member States’ authorities for explosives precursors to identify 
common challenges and ways to tackle them. Moreover, the European 
Commission has released guidance documents to assist Member States’ 
authorities, economic operators, and online marketplaces in implementing the 
rules for explosive precursors.376 Similar practices exist in tackling firearms 
trafficking. 

371   Interview with EU institution, industry representatives and one Member State authority.  
372   Interviews with industry organisations/ industry representative associations and one Member State.  
373   Interviews with one Member State authority. 
374   Ibid. 
375   Interviews with an EU agency and industry organisations/ industry representative associations. 
376   European Commission (2020). Guidelines for the implementation of Regulation (EU) 2019/1148 on the 

marketing and use of explosives precursors. Link 

94 

 
 
 
 
3.4.3. 

Barriers and hindrances to information exchange and 
cross-border cooperation 

The analysis allows for the identification of three main barriers in information 
exchange and cross-border cooperation. 

First, the differences in the degree of security impact experienced by 
Member States pose a challenge in the collection of data and information. 
Member States experiencing the security threat more (e.g. the Netherlands, 
Belgium and Germany) have more advanced data collection and information 
gathering practices on the incidents and attacks with pyrotechnics. Meanwhile, 
Member States with a strong pyrotechnic industry have more illegal production 
and diversion data.377 Member States outside these groups might not 
systematically collect information and data, as the “sense of urgency” can be 
lower.378 This poses inherent barriers to effectively exchanging information 
between Member States. Additionally, this might hinder the development of 
more preventive approaches in cross-border cooperation, as some Member 
States might not experience the need for that. This is closely linked to study 
area 2 and the different classifications and approaches to pyrotechnics, 
whereby certain types of high-risk articles are more heavily restricted and 
sanctioned in one Member State than in another Member State.379 The Member 
States’ survey responses resonated with this aspect as the obstacle to cross-
border cooperation and information exchange (87.5%).380 

Second, as pyrotechnics are legitimate products destined for consumers and 
professionals, but are also increasingly being misused, many different 
national authorities are involved. This leads to disjunctions in cooperation 
and information exchange between national authorities in a Member State, 
which hinders effective information flow. Similarly, market surveillance 
authorities do not have access to all Europol information exchange systems or 
other systems targeted more at the criminal side.381 This can hinder the 
effective information exchange regarding trends or modus operandi in the 
misuse of pyrotechnics between different authorities, from market surveillance 
to customs, law enforcement, and judicial authorities. 

Third, public-private cooperation exists, but to a limited extent. The 
cooperation between public and private actors currently focuses on the 
commercial side of pyrotechnics rather than the security issues. The industry 
survey respondents report limited resources as the main challenge in 

377   Case study A: Italy and France. 
378   European Commission (2019). Study on illegal sales of pyrotechnic articles destined for professional 
users (category F4) to the general public.; interviews with the authorities of two Member States. 
379   DG GROW (2025). Evaluation of the Pyrotechnics Directive [ongoing]; Interviews with authorities of 

three Member States.  

380   The Member State Survey, N=40 
381   Op ‘t Hoog & Saarijärvi (2023). International exchange of information in the context of firearms control. 

REGISYNC Project; Neve, R. (2021). Environmental crime threat assessment; One market 
surveillance stakeholder in the survey (N=15). 

95 

 
 
 
 
information exchange between public and private stakeholders, which could be 
improved by standardising reporting and communication platforms. In addition, 
guidelines on issues that should be reported were considered as useful. This 
links to the challenge of developing a common understanding of the security 
issue posed by pyrotechnics among public and private stakeholders. The 
research has identified divergences in how prominent and significant the 
security issues are considered by both different Member States’ authorities as 
well as industry representatives. 

3.5. 

Study area 5: Tracking and tracing high-risk 
articles 

This section analyses the existing systems for tracking and tracing 
pyrotechnic articles,382 focusing on their effectiveness in preventing diversion 
and supporting law enforcement investigations. 

3.5.1. 

Introduction to the issue 

While pyrotechnic articles are subject to free movement within the EU, the 
Pyrotechnics Directive 2013/29/EU indicates some common restrictions 
applicable to the entire EU market to ensure safety and, to some extent, 
security. Within the framework of Chapter 2 of the Directive, related to the 
obligations of economic operators, Article 9 focuses on defining common 
obligations in support of the traceability of pyrotechnic articles. These 
minimum obligations are particularly important when it comes to supporting the 
work of LEAs in tracing the origin of high-risk articles, especially when used 
illegally.  

Understanding the main working principles of the system currently in place at 
the EU level for tracking and tracing not only pyrotechnic articles (i.e. 
those regulated by Directive 2013/29/EU) but also of other high-risk articles 
falling within the broader explosive supply chain (e.g. explosives for civil 
use, but also precursors) is key to assess the challenges that LEAs working 
within this field face when attempting to identify the origin of pyrotechnic 
articles used to commit criminal acts. 

The following sections will briefly elaborate on these systems before proceeding 
with a preliminary analysis of the findings emerging from the data collection that 
feeds into this final report. 

382   Information collected refers to both mechanisms needed to track the movement of articles across 

borders and to trace the origin of the articles/their manufacturers.  

96 

 
 
 
 
3.5.2. 

Existing mechanisms 

Article 9 of Directive 2013/29/EU indicates that, to facilitate traceability of 
pyrotechnic articles, i.e. the identification of origin, manufacturers must label 
pyrotechnic articles with a registration number and maintain records of the 
registration numbers of the pyrotechnic articles they make available on the 
market. The registration number is not allocated per specific item.383 This 
information is to be made available to the relevant authorities upon 
request. Implementing Decision 2014/58/EU further indicates that the 
information should be kept by manufacturers for at least 10 years after the 
product is placed on the market, but it does not foresee any specific 
requirements to ensure this information is accessible through a centralised, EU-
wide system, as is the case for other articles that fall within the explosives 
supply chain (see below).  

Member States must abide by the traceability requirements in these Articles. In 
addition, they may introduce stricter traceability requirements within their 
national frameworks, although this is not possible for all categories (e.g. it’s not 
possible for F1 and F4 and can only be done if justified on the grounds listed in 
Article 4(2) of the Directive.  

With regard to other high-risk articles that fall within the broader explosive 
supply chain, the main reference legislative acts are the Civil Explosives 
Directive (Directive 2014/28/EU),384 and the Explosive Precursors 
Regulation (Regulation (EU) 2019/1148).385  

The Civil Explosives Directive sets out, under Article 15, the provisions for 
ensuring that economic operators adhere to a uniform system for the 
unique identification and traceability of explosives intended for civil use. 
This system is expected to further provide for the collection and storage of this 
data. This data is to be tested at regular intervals and stored for 10 years 
following the explosive's purchase, use or disposal. Specific obligations for 
manufacturers are further laid out under Article 5, which details their role in 
ensuring explosives placed on the market bear a unique, per-item identification, 
connected to the system explained above and that, in case the explosives do 
not fall within the EU-wide identification system, a) that they “bear a type, batch 
or serial number or other element allowing their identification”; b) that they 
indicate the name, registered trade name/mark and postal address of the 
producer. The Directive is complemented by Commission 
Directive 2008/43/EC386, which introduces the identification and tracing system 
itself387.  

383   This is, on the contrary, the case for civil explosives.  
384   Link 
385   Link 
386   Link 
387   The Civil Explosives Directive is currently being evaluated.  

97 

 
 
 
 
The Explosives Precursors Regulation – which focuses on regulating 
“substances or mixtures that could be misused for the illegal manufacture of 
explosives” – while not requesting the setup of a unique traceability system, 
includes provisions that bind economic operators to perform comprehensive 
checks on buyers (including proof of identity and licence); maintaining 
information on purchases for 18 months; and reporting significant 
disappearances and thefts within 24 hours to the designated national contact 
point. Operators are further required to report suspicious transactions. National 
authorities are required to inform the European Commission every year in 
relation to reported suspicious transactions, disappearances or thefts; licence 
requests received and granted; inspections carried out; and awareness-raising 
activities performed.388 

3.5.3. 

Law enforcement challenges in tracing illegal 
pyrotechnics 

When it comes to traceability of illegal pyrotechnics, the report of the Evaluation 
study of Pyrotechnics and Civil Explosives Legislation of the Directive had 
already highlighted that serious challenges exist. According to the study, 
Member States often lack aggregated data tracking systems, and access to 
information on origin/acquisition, as well as storage, testing and certification of 
these articles is particularly complex. Additionally, the Study had underlined 
data standardisation as an important challenge affecting product traceability 
within supply chains; disconnected digital tracks, and costs and resource 
allocation limits within relevant authorities as key issues.389 

The data collected for the purposes of this study point in a similar direction. 
Forty-seven percent of survey respondents amongst Member State 
Authorities390 indicate that tracking and traceability play a significant role in 
investigating misuse of fireworks, but that other investigative methods are 
also needed. Eighty percent of LEAs responding to the survey (N11) confirm 
this view. Amongst the most relevant key indicators that help trace the origin 
of the products when investigating a case, manufacturer marking was reported 
by 34% of respondents, followed by batch number (23%), purchase records 
(22%) and chemical composition analysis (14%). The manufacturer name and 
serial number on the products were indicated by 49% of respondents as 
“somewhat useful” for tracing their origin; however, gaps exist in tracking the 
supply chain. For example, a consulted National Authority reflected that, while 
there are provisions in the Directive allowing batch-level traceability through the 
distribution chain, there is no system in place to trace products to the end 
user391 (see also Case Study A for a reflection on the diversion of the legal 
supply chain). Sixty-three percent of LEAs responding to the survey (N11) 

388   Link 
389   Interim Evaluation of the Pyrotechnics Directive 2013/29/EU 
390   N. 47, of which N. 11 are LEAs. 
391   Stakeholder workshop organised for this study, September 2025. 

98 

 
 
 
 
confirm this view. Representatives of Swedish authorities responding to the 
survey indicated that purchase records for them are the most significant asset, 
since a majority of the seizures come directly from retailers in other EU Member 
States via parcels. 

Figure 13 Survey responses from LEAs (N11) on the usefulness of the 
manufacturer name and serial number for product tracing 

Are manufacturer name and serial numbers useful for 
tracing their origin?

9%; 1

27%; 3

64%; 7

Yes, they provide a clear link to
the source

(27%)

Somewhat, but gaps exist in
(64%) 
tracking supply chains

No, they are often missing or
tampered with

(9%)

Source: Survey addressed to national authorities. 

Last but not least, respondents were equally split when discussing the key 
challenges faced by their country’s LEAs in tracking and tracing. Thirty-
three percent of respondents (24) pointed to limited technical expertise and 
resources, whereas 16 per cent (12) highlighted challenges in integrating the 
system with existing customs or law enforcement systems. Fifteen per cent of 
respondents (10) pointed to resistance from manufacturers392, importers, or 
distributors and to high implementation costs as key issues. No respondent 
elaborated further in detail on the systems currently in use.  

392   Resistance to implementing additional systems that might increase costs for the manufacturer. 

99 

 
 
 
  
 
Figure 14 Survey responses on key challenges faced by national LEAs in 
tracking and tracing 

24

Limited technical expertise or resource to
implement the system

Challenges in integrating it with existing customs
or law enforcement tools

Other

High implementation costs

Resistance from manufacturers, importers,
distributors

Concerns about data privacy and compliance with
GDPR

4

Source: Survey addressed to national authorities. 

12

11

11

10

The findings from the interviews carried out in this study area further indicate 
that limited tracking and tracing capabilities represent a significant challenge 
for law enforcement in this domain.393 At the EU level, interviewed 
representatives indicated that the challenge is two-fold: on the one hand, 
tracing is only possible through actual boxes or packages of fireworks, 
and not, for example, in instances where you only find residue from 
explosions or shells; on the other hand, boxes or packages are often 
intentionally mislabelled, often to reduce detection when moving articles 
cross-border. All these elements limit law enforcement agencies' work in 
identifying misused pyrotechnics.394  

At the national level, LEA stakeholders interviewed in Spain expressed regrets 
at the ineffectiveness of the current approach, indicating it is easy to circumvent 
and fraught with difficulties related to cross-border information exchange. They 
suggested changes to harmonise the system with the one currently in place for 
civil explosives.395  

Similar considerations were expressed by a stakeholder from the Netherlands, 
who indicated that information exchange with Member States’ counterparts, 
when required for cross-checking the manufacturer’s name and details, can be 
challenging and resource-intensive. The interviewee further highlighted that 
significant investment in time and resources for cooperation, in particular, is 
required when cooperating on illegally manufactured products, where 
traceability of the manufacturer is by definition not immediately evident.396 This 
investment is often not possible, therefore hampering the possibility of rapid and 
effective investigations. According to interviewees, the ability to track and 

393   Interviews with an EU institution an and EU agency.  
394   Interview with an EU agency.  
395   Interview with one Member State’s authority. 
396   Interview with one Member State’s authority. 

100 

 
 
 
 
 
trace pyrotechnic articles used in illicit activities is undermined by 
inconsistent labelling practices, lack of harmonised systems (no 
traceability requirements for labelling or transfers), and limited investigative 
and enforcement capacity.397 This feedback is consistent with the results 
gathered through the survey. A stakeholder in particular highlighted operational 
challenges such as the lack of standardised scanning procedures for parcels, 
time pressure, and limited access to customs agencies’ risk profiles, which 
collectively reduce the effectiveness of LEAs tracking efforts.398 Surveyed 
French National Authorities also highlighted how the absence of a harmonised, 
transnational system of authorisations to check transfers between Member 
States hampers tracking and tracing abilities.399 Lack of traceability tools and 
forensic markers, jointly with the use of online sales and encrypted 
communications, were also reported as key challenges affecting the 
effectiveness of investigations by interviewed Cypriot law enforcement 
representatives.400  

Another issue raised by interviewees is the frequent use of unlabelled postal 
parcels to move articles across countries (see case study A for additional 
details). The use of this method reportedly affects the capacity of authorities to 
track and trace the movement of pyrotechnic articles.401.This, combined with the 
disharmonised approach across EU countries for transferring articles 
cross-border, with some requesting the use of permits, while others do not, is 
identified as a major issue by interviewed stakeholders from three Member 
States.402 

Looking forward, some stakeholders offered suggestions for future action to 
address challenges in this area. Interviewed representatives from German, 
French and Spanish Member State Authorities, all suggested that current 
tracking and tracing approaches are ineffective, and that the implementation of 
systems similar to those used for explosives could be beneficial.403 At the same 
time, one industry representative from France404 pointed out that the traceability 
system for explosives had cost the industry over EUR 5 million to establish, and 
expressed doubt that the pyrotechnic industry would be able to bear similar 
costs. An EU-level industry representative agreed, emphasising that such 
systems might only be feasible for high-risk articles, such as F4 or P2, but 
would be impossible to implement for lower-risk categories like F1 to F3. It was 
noted that the industry could not support extending these costly requirements to 
all pyrotechnic items.405 Interviewed German representatives406 also indicated 
that law enforcement (police, as well as in some federal states also customs) 

397   Interviews with authorities of three Member States 
398   Interview with a partner of an EU-funded project in this area. 
399   Survey addressed to NCAs: one Member State.  
400   Interview with one Member State’s authority. 
401   Interviews with authorities of three Member States.   
402   Interviews with authorities of three Member States.  .  
403   Interviews with authorities of three Member States.   
404   Stakeholder workshop organised for this study, 23 September 2025. 
405   Stakeholder workshop organised for this study, 23 September 2025. 
406   Interviews with authorities of one Member State.  

101 

 
 
 
 
would be in favour of introducing a EU-wide system similar to the Pyropass 
implemented by the Benelux region.407 Dutch stakeholders further stressed the 
need for reinforced operational cooperation with postal companies, supporting a 
targeted and specialised detection approach to further uncover illegal shipments 
in parcels.408 The importance of involving all actors across the pyrotechnics 
distribution supply chain in tracking and tracing efforts was also recalled by one 
interviewed industry representative.409  

3.6. 

Study area 6: Strengthening customs 
enforcement 

This study examines the customs framework for pyrotechnics across the 
EU and identifies challenges in detecting illegal imports. 

3.6.1. 

Introduction to customs enforcement and the current 
legislative framework 

In this area, different instruments are in place. The Pyrotechnics Directive 
2013/29/EU provides a harmonised framework to regulate pyrotechnic products 
relating to the making available on the market of pyrotechnic articles. As such, it 
mandates measures such as conformity assessments, CE markings, 
appropriate labelling, and the provision of safety instructions and age limits 
applicable to goods produced in the EU and imported products from third 
countries. Additionally, international level instruments concern pyrotechnic 
articles, which should be classified as dangerous goods under the United 
Nations Recommendations on the Transport of Dangerous Goods and fall 
within Class 1 (Explosives) of the ADR and the International Maritime 
Dangerous Goods (IMDG). Furthermore, their import is further subject to safety 
and security checks under the EU’s customs risk management procedures. 

The study team looked at the customs procedures at the external borders and 
at intra-EU flows. 

External border 

Customs procedures at the external borders are regulated by the EU Customs 
Code (UCC), and pyrotechnics undergo all standard customs procedures. 
The UCC equips customs with tools to apply risk-based controls, as Article 
46 of the Union Customs Code stipulates. These common risk criteria are 
established at the EU level and set out in an implementing act that is not 

407   Interviews with authorities of one Member State.  
408   Interviews with authorities of one Member State. . 
409   Interview with a national-level industry organisation/ industry representative association.  

102 

 
 
 
 
publicly available.410 In addition, Articles 134 and 267 of the UCC allow for 
“prohibitions and restrictions” (P&R) requirements411 that can be imposed on 
dangerous or non-compliant goods that can affect public health and safety risks, 
including pyrotechnics. These provisions can help prevent non-compliant 
pyrotechnic products from entering the EU and ensure that only products 
meeting safety standards circulate within the market. Pyrotechnic goods must 
be declared under specific CN (Combined Nomenclature) codes, usually falling 
under Chapter 36 of the TARIC database, which will indicate the duty rates, 
licensing requirements and prohibitions or restrictions. Importers must submit 
an Entry Summary Declaration (ENS) through the Import Control System 2 
(ICS2)412 before the arrival of the goods at the EU’s external border. Supporting 
documentation typically includes the EU Declaration of Conformity, safety 
certificates, technical documentation, transport documentation compliant with 
ADR (for road) or IMDG (for sea) and import or handling licenses, if required by 
the Member States. EU customs authorities employ automated risk analysis 
systems to assess incoming shipments. Pyrotechnics are also subject to 
additional controls due to their classification as Class 1 explosives. These 
include enhanced risk profiling, verification of proper labelling and transport 
classification, and secure storage requirements during clearance. Customs 
authorities may also consult national safety regulations, such as bans on certain 
categories (e.g., F3 fireworks) or, if the receiver has the authorisation to import 
pyrotechnic articles, to determine if goods are legally admissible.  

For example, in Sweden, customs need to confirm that companies (not 
individuals) have been authorised by the Swedish Civil Contingency Agency to 
import pyrotechnics. If this is the case, goods are usually released, and no 
controls are performed.413  

If a shipment of pyrotechnic articles is found to be non-compliant, for example, 
through missing CE marking, false declarations or undeclared explosive 
classification, which could hint at illegally manufactured pyrotechnics, customs 
authorities can, depending on the non-compliance identified, detain or seize the 
goods, refuse entry into the EU customs territory or refer the case to market 
surveillance authorities or police. In addition, depending on the explosive 
categorisations, only specific entry points may be authorised to handle specific 
goods. Proper storage should also be ensured, requiring temporary depot 
detention or secure customs zones. 

While the Pyrotechnics Directive sets out general compliance rules for 
economic operators and harmonises product classification, implementing 
these rules and enforcement provisions is the responsibility of the 
Member States. For example, Swedish customs authorities conduct checks to 
verify whether importing companies, primarily wholesalers and retailers, 

410   Customs Risk Management Framework (CRMF), here 
411   Prohibitions and Restrictions, here 
412   Link 
413   Interview with one Member State’s authority. 

103 

 
 
 
 
possess valid authorisation from the Swedish Civil Contingencies Agency to 
import pyrotechnic articles. Only once this verification is complete are the goods 
cleared and allowed to enter the market. Sweden is currently planning to 
strengthen its control measures, with a greater focus on verifying the actual 
content of shipments. This includes checking whether the declared quantities 
(e.g., weight) match the physical goods and whether the products are approved 
for sale on the Swedish market to minimise the circulation of non-approved 
pyrotechnics in the country.414 

Intra-EU flows 

The Single Market is one of the strengths of the European Union, as goods are 
free to move across borders and there is a lack of customs controls between 
Member States. Contrary to controls at the external borders, where common 
rules apply to all Member States, intra-EU flows do not usually undergo any 
type of control from customs, as also outlined in Case study B. According 
to the Staff Working Document on the Evaluation of the Pyrotechnics 
Directive415Intra-EU trade has increased constantly since the introduction of the 
Directive, raising the risk that larger volumes of potentially illegal or diverted 
pyrotechnic articles move freely across the EU. Stakeholders have identified the 
lack of harmonised customs controls and enforcement between Member States 
as the main issue for the free circulation of pyrotechnic articles within the EU. 

Some Member States, however, have developed national-level approaches 
to enforcing intra-EU customs control. For example, Swedish customs 
authorities explained that in Sweden, controls on intra-EU trade are regulated 
by national legislation which allows customs to carry out controls even on intra-
EU flows, based on suspicions that some means of transport are used to 
smuggle restricted goods, such as firearms, explosives and drugs. These 
controls may also target specific parcel recipients based on existing intelligence 
linking them to criminal activities.416 The same approach of enforcing controls 
based on intelligence or information on the package is confirmed by Dutch Law 
enforcement authorities.417  

While some countries opt to enforce intra-EU customs controls, this 
approach is not used in a homogeneous manner across all EU Member 
States, as in most Member States, customs enforcement is usually 
focused on third-country imports, and there is limited authority to control 
intra-EU flows.418 These inconsistent mandates419 regarding performing 
controls on intra-EU parcels and practices across Member States in the 
pyrotechnics field420 create additional vulnerabilities in detecting and controlling 

414   Interview with one Member State’s authority. 
415   Commission Staff Working Document, Evaluation of Directive 2013/29/EU, SWD(2025) 269 final. 
416   Interview with one Member State’s authority. 
417   Interview with one Member State’s authority.. 
418   Interview with one Member State’s authority. 
419   Draft report of action 11.9 Explosives - fireworks, pyrotechnics and their precursors.  
420   Pyrotechnics Directive 2013/29/EU, recital 16. 

104 

 
 
 
 
non-compliant pyrotechnic products within the EU. National authorities stress 
that the lack of harmonisation of pyrotechnics legislation within the EU is 
a major issue,421 especially the absence of a uniform licensing requirement, 
which they identify as one of the main regulatory challenges. In practical 
terms, pyrotechnic articles can be sourced online from retailers established in 
Member States with more permissive requirements and after entry into free 
circulation, parcels move within the single market without systematic customs 
checks, allowing access to items that would otherwise be restricted under 
national rules. The Pyrotechnics Directive focuses only on the market aspect of 
pyrotechnics sales the obligations of economic operators. It envisages 
enforcement through the EU’s horizontal market-surveillance framework but it 
does not establish any provisions for enforcement from a customs point of 
view,422 limiting the legal authority to carry out controls on these goods. The 
lack of a harmonised authorisation framework for circulation leaves 
Member States exposed, particularly when combined with high parcel 
volumes and limited inspection capacity.  

Beyond differing enforcement practices, different legal classifications and 
consumer access rules among Member States contribute to these 
vulnerabilities. For instance, in Ireland, only category F1 fireworks are 
available for purchase, possession and amateur use. The Netherlands prohibits 
private individuals from using F3 fireworks, whereas other Member States such 
as Poland, and Czechia allow consumers access to this category. In addition, 
Belgium, Luxembourg and the Netherlands have introduced a so-called Pyro-
Pass, which introduces an additional step for market operators to verify whether 
individuals purchasing specific pyrotechnic articles possess the required 
specialised knowledge. These national rules on use and sale determine what 
goods can legally be placed on the market for consumers, and customs should 
verify that imports comply with EU-wide rules and the destination country's laws. 
Last, in the case of restricted categories of pyrotechnics, customs may hold, 
verify, or even block shipments unless all national requirements (like buyer 
qualifications) are met.  

Authorities who have replied to the survey have a generally positive view of the 
current tools and procedures for assessing illegal imports, with 14 out of the 20 
respondents replying that they are very to somehow effective.423 Positive views 
on the effectiveness of current tools and procedures are mainly shared by 
customs authorities, while more neutral or negative views come from other 
authorities such as Ministry of Interior, Law enforcement and Safety authorities, 
who typically engage with illegal imports only after customs procedures have 
failed, and may therefore see the existing tools as less sufficient or too limited in 
scope to fulfil the necessary objectives. 

421   Interviews with authorities of two Member States. 
422   Interview with one Member State’s authority. 
423   27 of respondents indicated ‘I don’t know’. 

105 

 
 
 
 
Figure 15 Survey responses on the effectiveness of current customs tools and 
procedures in assessing illegal imports of pyrotechnic articles 

1

2

4

3

10

Very effective

(4)

Somehow effective

(10)                   (3)                       (2)                                (1)

Very ineffective

Ineffective

Neutral

Source: Survey addressed to national authorities. Results (N=20). 

3.6.2. 

Challenges in detecting illegal imports 

Despite the existing legal framework, stakeholders highlighted that criminals 
and smugglers exploit existing enforcement differences and gaps (see also 
Study area 1). The main underlying issue is that customs perform mainly 
targeted interventions based on risk-based operations,424 on intra-EU 
flows and third-country imports. Routine misclassification can evade 
detection unless flagged through profiling or intelligence. 

According to desk research, a significant tactic identified in the Netherlands425 
used by traffickers is the misclassification of fireworks to bypass safety 
regulations. Fireworks classified as F3, which, in the Netherlands, are typically 
reserved for professional use, are often falsely labelled as F1, F2, or P1 
categories, which face lighter regulatory scrutiny due to their lower hazard 
categorisation. In addition, many of these products lack proper CE markings or 
identifying information on the manufacturer or importer, further complicating 
enforcement and traceability. One law enforcement authority mentioned in the 
survey that, in several cases, the incorrect transport classification can be an 
interesting starting point for an investigation. However, sectoral knowledge and 
expertise remain key for customs authorities in the identification of 
misclassification. In particular, the nuanced distinctions between legitimate and 
falsified labelling are not always easy to identify without specialised training. 

424   Veenstra, A., & Heijmann, F. (2023). The Future Role of Customs. World Customs Journal, 17(2), 13–

30. Link 

425   Neve R. (2021) Environmental Crime Threat Assessment 2021. 

106 

 
 
 
 
 
In addition, the distribution of illegal fireworks through small postal parcels 
of pyrotechnics sold online has become an increasingly common method, 
particularly in the months before New Year’s Eve.426 This method presents 
serious enforcement challenges due to the high volume of parcels and the 
difficulty of detection. This applies equally to imports from third countries 
and to intra-EU flows of pyrotechnics. However, the limited oversight of 
intra-EU mail flows427 makes it a critical blind spot in customs enforcement, 
especially within the EU single market, where many small shipments do not 
pass through customs control at all. The recent e-commerce communication428 
acknowledges the surge of online sales and related challenges, one of these is 
the risk of criminals exploiting online sale, and this lack of systematic controls in 
the single market to distribute illicit goods, including explosives, via small 
parcels sold on the grey and dark web, and sometimes through open online 
marketplaces. This concern has been mentioned by several Member State 
authorities consulted throughout the study, including in the workshop where the 
lack of harmonised controls across Member States is seen as a limit to the 
ability of customs authorities to enforce regulations effectively. This represents 
an issue in particular in the Netherlands. As noted by two stakeholders,429 The 
sheer quantity of packages entering the Netherlands makes enforcement 
challenging. Another Member State authority, which pointed out the difficulties 
of carrying out controls on each parcel, also confirmed that the Netherlands 
represents an entry point due to the presence of big shipping ports.430 The 
industry also acknowledges the difficulty of controlling small-scale 
shipments, particularly those arriving via parcel delivery from other EU 
countries or from China. It is widely recognised that the volume of 
shipments is so high that systematic inspection of all packages is 
unfeasible. As a result, many illegal products enter disguised as other 
items, making detection even more challenging.431 

In addition, an interviewed national authority432 noted that a critical obstacle in 
the fight against illegal fireworks trafficking lies in the identification of the true 
consignor, the individual or entity responsible for sending the goods. 
These consignor names are often fictitious, generic, or represent intermediary 
logistics companies uninvolved in the actual sale of the goods. One of the most 
frequently reported tactics is the constant rotation of consignor names and 
addresses, a method designed to avoid detection by customs profiling 
systems. This makes it impossible to build a reliable sender profile or create 
automated flags for repeat offenders. Even when intelligence systems are in 
place, the lack of consistent consignor data means that parcels cannot be 

426   Ibid. 
427   Interviews with authorities of three Member States. 
428   European Commission (2025), A comprehensive EU toolbox for safe and sustainable e-commerce, 

COM/2025/37 final. 

429   Interviews with one Member State’s authority and a Member State's representative part of an EU-level 

instrument. 

430   Interviews with authorities of two Member States. 
431   Interview with a national-level industry organisation/ industry representative association.  
432   Interview with one Member State’s authority. 

107 

 
 
 
 
systematically linked to known sources of illegal fireworks. Moreover, unlike 
high-profile criminal actors, many consignors in these operations are either 
unknown to law enforcement or do not appear in existing criminal or customs 
intelligence databases. 

While the number of contributions from customs authorities to the survey 
addressed to national authorities is limited (see figure below), inputs received 
confirm the challenges highlighted in the literature. Incorrect labelling of goods 
and high volumes of goods to inspect are considered the main issues, followed 
by smuggling via small parcels or personal vehicles. False declaration of goods 
is also mentioned. Although to a lesser extent, limited detection technologies 
are also a challenge, while limited detection knowledge is a very minor factor 
hampering proper controls. 

Figure 16 Survey responses on the primary challenges customs authorities face 
in detecting illegal imports of pyrotechnics 

Incorrect labelling of goods

High volume of goods to inspect

Smuggling via small parcels or personal vehicles

13

13

12

False declaration

9

Limited detection technology

6

Limited detection knowledge

2

Other

Lack of trained personnel

0

0

Source: Survey addressed to national authorities. Results (N=47). 

3.6.3. 

Limitations of customs enforcement tools and 
procedures 

The growing use of international postal and courier services for the illegal 
distribution of illegal fireworks presents a significant challenge to customs 
authorities across the European Union.  

Detection is further complicated by the fact that these parcels typically circulate 
within the EU, meaning, once they enter the single market, they are not 
subject to customs declarations or routine inspections.433 Enhanced 
cooperation between enforcement authorities and courier companies is 

433   Interview with one Member State’s authority.. 

108 

 
 
 
 
 
considered essential.434 However, courier companies are often unaware of the 
contents of the packages and have limited ability to control or verify what is 
being shipped. Unlike arms, these products are more difficult to detect in 
parcels due to their non-distinctive appearance or packaging. This means that 
in many cases, pyrotechnics move across countries legally before being 
diverted into illegal use or distribution.435 One national authority stressed that 
retailers selling online cannot lawfully ship pyrotechnic articles to consumers 
using ordinary mail or parcel couriers without breaching courier polices, which 
prohibit fireworks, and transport regulations (e.g ADR and hazardous goods 
legislation). In fact, the business model of online sales is often built on 
systematically bypassing or disregarding these rules.436 In addition, the 
complexity of the parcel delivery chain, which often involves multiple 
subcontracted handlers, makes the tracing of shipments difficult. In many 
cases, the consignor listed on the parcel is merely the name of a logistics 
intermediary rather than the actual pyrotechnics seller. The information is 
not systematically stored with sufficient detail across the different courier 
companies. Even when intelligence leads to a suspected shipment, 
enforcement fails because courier companies operate very rapidly, and the 
goods have already been delivered by the time customs attempts to intervene. 
As outlined in the recent e-commerce communication,437 the increase in the 
flows of goods resulting from online sales has not seen an equal increase in 
capacity at the border, with the risk that unsafe, counterfeit or otherwise non-
compliant products enter the market, therefore calling for more coordinated 
enforcement actions and for setting clear responsibilities for online 
marketplaces. 

Seizures of pyrotechnics originating from other EU Member States 
currently rely heavily on manual inspection and individual initiative. A 
designated customs office monitors incoming intelligence and parcel data to 
identify patterns or individuals of interest. This is supported by a database 
system used to flag potentially suspicious shipments. However, actionable 
enforcement depends on customs officers physically intercepting and inspecting 
the parcels, as receiving a package flagged as suspicious is not an offence in 
itself. Given resource constraints, only a fraction of the shipments flagged 
by intelligence can be inspected on-site, limiting the capacity to fully respond 
to the volume of potentially illegal fireworks in circulation. 

A study from 2020438 explores how trace residues from fireworks can adhere to 
packaging materials such as cardboard and plastic during handling, storage, or 
transport. Traditional methods such as manual inspections, X-ray scanning and 

434   European Commission (2025), A comprehensive EU toolbox for safe and sustainable e-commerce, 

COM/2025/37 final. 

435   Interview with one Member State’s authority. 
436   Interview with one Member State’s authority. 
437   European Commission (2025), A comprehensive EU toolbox for safe and sustainable e-commerce, 

COM/2025/37 final. 

438   K.D.B. Bezemer, T.P. Forbes, A.W.C. Hulsbergen, J. Verkouteren, S.T. Krauss, M. Kobeberg, P.J. 

Schoenmakers, G. Gillen, A.C. van Asten (2020) Emerging techniques for the detection of pyrotechnic 
residues from seized postal packages containing fireworks, Forensic Sci. Int. 308 

109 

 
 
 
 
database checks may be insufficient given the volume of parcels and the covert 
nature of smuggling methods. Detection dogs can also be used but are mainly 
trained for explosives. Recent developments offer promising new approaches 
for identifying illegal shipments through non-invasive residue detection 
techniques. These residues can serve as a forensic indicator of illegal fireworks 
presence, even if the items are concealed or not declared. For customs 
authorities, this research could present a viable screening solution for parcels 
suspected of containing illegal fireworks. However, while using technologies can 
provide benefits, some limitations include false positives, the need for 
standardised protocols and training for customs officers and the initial 
equipment investments and maintenance costs. 

As noted by stakeholders consulted,439 current challenges include outdated 
technology at border crossings, inconsistent risk data, and a lack of predictive 
intelligence. Enhancing customs capabilities through real-time alerts, shared 
databases, and the integration of systems into pre-clearance workflows would 
represent significant improvements. 

In addition, the illegal trade in heavy fireworks presents a growing cross-
border enforcement challenge. According to a Dutch report,440 the majority of 
illegal fireworks originate in China and are imported into the EU via major ports 
such as Antwerp, Rotterdam, Hamburg, and Gdansk. This issue was also 
highlighted by officials of an EU agency,441 who claimed that pyrotechnic 
articles are often imported legally from third countries, primarily China, through 
means of using false declarations, misrepresenting the type, quantity, or 
classification of the goods to circumvent regulations. Shipments often pass 
through Belgium or Germany from these entry points, where storage in former 
military bunkers or barns is common. These facilities serve as staging grounds 
for further distribution into the Netherlands and other countries, often using 
vans, trailers, private vehicles, or even international postal parcels. However, 
the Dutch police have no control over these storage facilities; additionally, they 
stress that differences in the prioritisation of the fight against misuse of 
pyrotechnics across the Member States and in penalties hamper effective 
cross-border enforcement.  

Inconsistent enforcement standards have also been mentioned as one of the 
main limitations by stakeholders surveyed, alongside limited detection 
technology, insufficient personnel, a high volume of shipments, and limited 
collaboration with economic operators. 

439   Interview with an organisation partner of an EU-funded project.  
440   Neve R. (2021) Environmental Crime Threat Assessment 2021. 
441   Interview with an EU agency. 

110 

 
 
 
 
3.6.4. 

Role of intelligence and risk assessment 

Customs authorities, primarily national customs administrations, are the 
frontline actors responsible for enforcing import controls. They often work 
closely with other agencies such as market surveillance bodies, police, and 
specialised units. These agencies exchange intelligence with national and EU-
LEAs, including OLAF and Europol, to trace illegal supply chains and dismantle 
trafficking networks. 

Targeted enforcement increasingly depends on risk-based intelligence, which, 
when used, has proven effective when agencies work jointly. However, a lack 
of coordination and clear communication channels between authorities in 
different Member States continues to limit the ability to conduct cross-
border tracking of suspicious operators or to identify common fraud 
patterns.442 Discussions in the workshop with stakeholders also pointed out 
how cross-border cooperation can be enhanced in the framework of customs 
controls (see also Study area 4 in Section 0). Participants emphasised the 
critical importance of sharing information about seizures between Member 
States, noting that even a single seizure can be highly valuable, as it may alert 
authorities in other countries to previously unknown activities or emerging 
threats. 

In cases where cooperation is enhanced, for example, between the Dutch 
police, investigative services, and customs, enforcement outcomes have 
improved, leading to a doubling of seizures in recent years.443 Better 
intelligence sharing, digital investigations, and improved mapping of local illegal 
trade networks have supported this. However, despite these improvements, 
gaps remain. As mentioned above, the systems in place regarding parcels 
hamper proper intelligence gathering and use and prevent an effective 
tracing of supply chains. In this regard, the need to improve the coordination 
of customs authorities and law enforcement at the EU level was also mentioned 
in the workshop. One authority also observed that in the illegal market there is 
an increase of high-risk pyrotechnic articles that cannot be traced by name, 
brand, or registration number, making enforcement and intelligence gathering 
especially challenging. This leads to the need for a dedicated platform or 
mechanism that would allow Member States to share information about these 
specific high-risk articles, facilitating cooperation and potentially helping to 
locate illegal manufacturing sites. Stakeholders highlighted the possibility of 
using existing EU frameworks, such as those for firearms, to systematically 
share and analyse data on explosives and pyrotechnics. Broadening the 
mandate of such focal points could strengthen cross-border cooperation, 
improve intelligence on illegal production, and support more effective 
enforcement across the EU. 

442   Interview with a national-level industry organisation/ industry representative association.  
443   Ibid. 

111 

 
 
 
 
Moreover, gaps remain in customs cooperation at maritime ports, where 
the potential for intercepting large shipments remains underexploited. The 
Council Resolution on an EU strategy to tackle cross-border crime (2023)444 has 
underscored the importance of addressing enforcement gaps to enhance public 
safety and security. Strengthening customs involvement requires improved 
procedural integration and investment in their operational knowledge, training, 
and analytical capacity to effectively identify and respond to emerging 
smuggling trends. 

3.7. 

Study area 7: Role of online sales/mail order 
sales 

This section explores the role of online sales and mail order sales in the 
criminal misuse of pyrotechnic articles. It focuses on describing how the 
trade of pyrotechnics, illegally produced or diverted, generally operates online 
and describes the key challenges national authorities face in preventing such 
trade.  

3.7.1. 

Introduction to online trade of pyrotechnics 

Figure 17 Cycle of trade (legal/illegal) 

Following the increasing digitalisation of the 
market that has characterised the past 
decade, pyrotechnic articles have 
established a growing online retail 
presence, becoming more easily accessible 
to EU consumers.445 However, new 
technologies and e-commerce platforms have 
also been increasingly exploited by OCGs and 
terrorists, together with the postal services 
used to deliver the goods sold online.446  

Source: Consortium’s elaboration. 

444   Strategy for customs cooperation in the area of law enforcement and its contribution to the internal 

security of the EU, available here 

445   European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(2019). Study on illegal sales of pyrotechnic articles destined for professional users (category F4) to 
the general public. 

446   Eurojust. International cooperation disrupts illegal fireworks network, 2018; Project ARIEL final report, 
2015; Project POSEIDON, Study on corruption vulnerabilities in the EU seaports’ supply chain, 2024; 
Savona & Riccardi. From Illegal Markets to Legitimate Businesses: the Portfolio of Organised crime in 
Europe. Final report of Project OCP Organised Crime Portfolio, 2015. 

112 

 
 
 
 
 
Following this trend, the prominent role played by online sales in fostering the 
criminal misuse of pyrotechnics and posing security issues has been observed 
by several studies. In fact, as the role of online marketplaces has become more 
extensive in the everyday lives of citizens, it has also been proven difficult to 
regulate. A 2024 Europol Report on the State of play of Pyrotechnics in the EU 
underlined how web-shops, together with sellers on social media, have 
become a primary source of illegal pyrotechnic articles, especially of F4 
flash bangers. A previous 2019 Study on illegal sales of pyrotechnic articles 
showed that 73% of web shops selling F4 articles do not put in place 
security controls to verify if the purchaser of the article has the required 
specialist knowledge.447 Moreover, the fact that F4 pyrotechnics were 
proven to be sent by post in unlabelled parcels to consumers using non-
certified courier services also raised concerns regarding the control of online 
markets and postal sales.448 

The data collected for this study strongly confirms that online sales remain 
one of the main issues national authorities face in tackling criminal 
activities relating to pyrotechnics. In relation to the question on ‘what types 
of criminal activities involving pyrotechnic articles are prevalent in your country’ 
around 25% of the responses of the responding Member States authorities 
indicated ‘unauthorised sales both physical and online (dark web)’.449 Moreover, 
85,11% of the 47 Member States’ authorities indicated how ‘e-commerce’ was, 
in their opinion, one of the most problematic areas in the fight against the 
criminal misuse of pyrotechnics.450 

Of 25 representatives of the pyrotechnics industry451 which responded to this 
Study, 21 indicated that they sell pyrotechnics on online marketplaces, 
confirming the importance of such markets on the pyrotechnics market. At the 
same time, 5 out of 25 of the industry respondents indicated the role of online 
marketplaces in the illicit trade of pyrotechnics in their country as either ‘very 
significant’452 or ‘significant’;453 while 6 of them indicated it as ‘partially 
significant’ and 9 of them as ‘non-significant’.  

The relevance of online sales was also strongly reflected in the scoping and 
targeted interviews conducted. Preliminary scoping interviews have underlined 
the opportunities that the dark web provides to OCGs to acquire pyrotechnic 
articles without the need for physical interactions,454 making it harder to 
trace the origins and distribution of these articles.455 Regarding the targeted 

447   European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(2019). Study on illegal sales of pyrotechnic articles destined for professional users (category F4) to 
the general public. 

448   Stefano Betti, Measuring the scope and scale of illicit trade and counterfeit goods, 2023. 
449   Responses from authorities representing 18 Member States. 
450   Responses from authorities representing 19 Member States. 
451   Including businesses, national industry representatives, and EU-level industry representatives. 
452   More than 50% of the licit pyrotechnics production. 
453   From 25% to 50% of the licit pyrotechnics production. 
454   Interview with an EU institution.  
455   Interview with an EU institution. . 

113 

 
 
 
 
interviews carried out thus far with both Member State national authorities and 
industry representatives, while the majority of stakeholders shared the view that 
online sales constitute a major challenge, only one Member State seemed to 
express a more limited concern about online sales of pyrotechnics, suggesting 
that the online purchase of pyrotechnics would not necessarily be easier than 
other channels.456  

3.7.2. 

Modus operandi for online trade 

The study investigated how pyrotechnics are traded online and aimed to gather 
information on the key modus operandi for online trade used by criminals, as 
reported below.  

The data collected suggests that Member States' authorities do not 
systematically collect data or have estimates on what proportion of the 
pyrotechnics used for committing illegal acts is obtained online. Around 
48.94% of the respondent authorities (23), in fact, answered ‘I don’t know’ to 
this question,457 while 17,02% (8) answered that such a proportion amounts to 
‘Less than 10%’ 458 (plus, four Member States authorities indicated ‘I don't know, 
as another authority is better placed to reply on this’).459 Only four respondents 
indicated as the answer ‘more than 70%’,460 and five answered ‘from 50% to 
70%’, 461 and one ‘from 25% to 50%’.462 Similarly, it seems even more difficult to 
evaluate what proportion of the pyrotechnics used for committing illegal acts 
comes from legal suppliers selling online. Twenty-seven of the responding 
authorities indicated they do not have an answer to this question,463 while seven 
of them answered ‘less than 10%’464, one estimated ‘from 10% to 25%’465 and 
four ‘from 50% to 70%’.466 Only three respondents indicated that such a 
proportion amounts to ‘more than 70%’.467 

In the context of targeted interviews, only one Member State authority declared 
to be able to estimate the percentage of the pyrotechnics used for the 
commission of illegal acts in their country (Italy) obtained online, indicating it is 
more than the 50% of the pyrotechnics sold online (without being able to 
indicate, however, whether these would be coming from legal or illegal 
suppliers).468 

456   Interview with one Member State’s authority. 
457   Responses from authorities representing 13 Member States.  
458   Responses from authorities representing six Member States.  
459   Responses from authorities representing three Member States.  
460   Responses from authorities representing four Member States. . 
461   Responses from authorities representing four Member States.  
462   Responses from authorities representing one Member State. . 
463   Responses from authorities representing 14 Member State.. 
464   Responses from authorities representing six Member State. 
465   Responses from authorities representing one Member State. 
466   Responses from authorities representing four Member State authorities. 
467   Responses from authorities representing three Member State authorities. 
468   Responses from authorities representing one Member State, 

114 

 
 
 
 
Figure  18  Member  States’  survey  responses  on  what  proportion  of  the 
pyrotechnics used for committing illegal acts are estimated to have been obtained 
online (N=47) 

4

8

2

1

5

4

23

Less than 10%

(8) 

From 10% to 25%

(2) 

From 25% to 50%

(1) 

From 50% to 70%

(5) 

More than 70%

(4) 

Source: Survey addressed to national authorities. 

 In this regard, a Dutch 2021 Environmental Crime Threat Assessment 
highlights how the possibility to operate fairly anonymously on social 
media, the speed and brevity of contact, and the possibility to encrypt 
messages make it harder for law enforcement authorities to get an 
overview of the digital trade.469 On the other hand, one Member State 
enforcement authority reported that the lack of data on the issue is due to the 
very low number of cases in which pyrotechnic articles are used to commit 
illegal acts in their country.470 

Regarding the exact modus operandi of online trade of pyrotechnics, ‘e-
commerce platforms’ were indicated in 29% of the survey responses by 
Member State authorities as the most common way to purchase illegal 
pyrotechnics online. Right after, ‘social media and messaging apps’ were 
indicated in 27% of the survey responses. Also, during targeted interviews, two 
industry representatives have indicated e-commerce platforms, such as eBay 
and Amazon, as among the most commonly used for the illegal market of 
pyrotechnics.471 Similarly, a national Member State authority indicated other e-
commerce platforms, such as Wish and Temu.472 The ‘use of the dark web to 
trade in high-risk pyrotechnics’ was included in 18% of the responses, while 
19% of the responses pointed at ‘cross-border online purchases from non-EU 
countries’ and 7% at ‘other’. However, only one of the respondents further 
specified what type of other means were observed, pointing at cross-border 
online sales from other EU countries.473 

469   Neve ed. (2022). Dutch Environmental Crime Threat Assessment, 2021. 
470   Interview with one Member State’s authority. 
471   Interview with one national-level industry organisation/ industry representative association.  
472   Interview with one Member State’s authority. 
473   Interview with one Member State’s authority. 

115 

 
 
 
 
Figure 19 Member State survey responses on the most common ways to 
purchase illegal (either illegally produced or diverted) pyrotechnics online (N = 
47) 

30

25

20

15

10

5

0

E-commerce
platforms

Social media or
messaging apps

Cross-border
online purchases
from non-EU
countries

Use of the dark
web to trade in
high-risk
pyrotechnics

Other

Source: Survey addressed to national authorities. 

For what concerns e-commerce, the input gathered from one industry 
representative highlighted the necessity of drawing a distinction between 
online marketplaces, such as Amazon or eBay, where more than one 
seller can offer their products, and online shops of specific sellers (of 
pyrotechnics).474 According to this same representative, online marketplaces 
seem to pose fewer problems than online shops of specific sellers, as 
more checks and controls take place when an item is put online for sale 
and/or is sold on these platforms. Moreover, the major online marketplaces 
participate in the Standing Committee on Precursors and are thus engaged in 
countering the misuse of their platforms for criminal misuse. A bigger problem 
would be represented by individual e-shops, where pyrotechnic articles can be 
sold more easily with almost no preliminary controls on the seller or on the 
product being sold. This would seem to be confirmed by a Member State 
authority, indicating how the majority of pyrotechnics sold in their country are 
sold on the distributors’ own internet homepage.475 

In line with this input, a representative of an online sales and distribution 
platform stressed that most pyrotechnic articles are prohibited from being sold 
on such a platform.476 This makes enforcement easier, as the legality of these 
types of articles varies per Member State. In addition, the platform has 
shipping restrictions and requirements that block certain products from 
entering the online marketplace. Such security measures are based on 
keywords and Artificial Intelligence (AI) models that work with image detection, 
notifying a seller if he or she tries to list an explosive precursor or a pyrotechnic 
article on their marketplace.477 However, in these types of checks, no ‘human 

474   Interview with one industry organisation/ industry representative association.  
475   Interview with one Member State’s authority. 
476   Interview with a sal 
477   Ibid. 

116 

 
 
 
 
 
element’ is present, and the mechanism is entirely automated. In addition to 
this, one national member state authority confirmed that big platforms, such as 
eBay and Amazon, have some communication channels in place with 
national law enforcement authorities and collaborate with them. On the other 
hand, this appears more complicated with social media platforms or messaging 
apps such as Facebook, Telegram, and Snapchat.478  

Another distinction needs to be drawn between online marketplaces and 
online shops on one hand, and social media platforms, such as TikTok and 
Snapchat or messaging apps, like Telegram, on the other. As data gathered 
suggests, several stakeholders identify social media platforms as popular 
channels in the context of the purchase of illegal products, as they can 
host guidance content indicating how to avoid controls, for example ‘the 
best ways to avoid controls to transport goods across borders’.479 According to 
one industry representative, the use of such social media platforms can be a 
much easier way to purchase pyrotechnic articles, as they appear to be, in 
general, less controlled than other types of platforms.480 This seems to be 
confirmed by another targeted interview, stressing how the increase of online 
sales works mainly through social media, encrypted messaging apps, and dark 
web platforms, where they are disguised as novelty or party items.481 Among 
these, Telegram channels, hidden marketplaces (such as AlphaBay, before it 
was shut down), and platforms like Facebook Marketplace seem to be 
commonly used, especially with cross-border payment and delivery.482 

Finally, it is worth noting that, among the 25 industry representatives responding 
to the survey for this study, only 14 indicated that they had measures in place to 
prevent criminal misuse of pyrotechnics sold online.483 Of those, it’s necessary 
to consider that 11 are from French industry representatives, and that in France, 
a sales register is compulsory, as all data relating to the transaction must be 
kept and the buyer must show proof of identity and not deal anonymously with 
the seller. Therefore, an identity document is required to purchase online. 
However, such a measure does not seem to appear systematically in any other 
country. Still, these security measures were assessed as ‘very effective’ by 12% 
of the respondents, ‘effective’ by 28% of the respondents and ‘neutral’ and 
‘ineffective’ by 20% and 12% of the respondents, respectively. When 
questioned whether they had ever experienced issues with their delivery 
channels, only three of the industry representatives answered positively. Of 
such issues, two French businesses indicated ‘delivery by competitors in 
lockers and no controls by Member States on the movement of fireworks’. One 
Slovenian business representative emphasised having an issue with postal 

478   Interview with one Member State’s authority. 
479   Interviews with two industry organisation/ industry representative associationand and one Member 

State’s authority. 

480   Ibid. 
481   Interview with an organisation partner of an EU-funded project.  
482   Ibid. 
483   Interview with three national-level industry organisations/ industry representative associations. 

117 

 
 
 
 
companies, such as DHL, GLS and Gold Express, transferring all types of 
pyrotechnic articles without proper checks or limitations. 

3.7.3. 

Modus operandi for delivery 

Once purchased online, products need to be sent to the buyer. The data 
gathered from Member States’ authorities in this regard suggests that ‘Private 
postal services’ is a common channel used by criminals to have the 
pyrotechnic articles delivered or transferred, as indicated by 35% of the 
answers. ‘National postal services’ was indicated by 32% of the answers 
collected, while 20% of the answers pointed to ‘peer-to-peer transfers’. No 
authority included ‘reshipping companies’ in their answer, while 14% of the 
responses suggested delivery might be carried out by ‘other’ means, among 
which one national authority mentioned the use of fictional consignors, and of 
straw men or post box companies as consignees.484 

Stakeholder input gathered through a targeted interview with one industry 
representative further detailed how the delivery of online-sold pyrotechnics 
usually takes place, highlighting how articles purchased online may be 
sent over in normal parcels, with no labels, hence not compliant with the 
regulations concerning the transport of dangerous goods. In particular, the 
rules concerning the transport of pyrotechnic articles are covered by 
international conventions and agreements, including the Directive 2008/68/EC 
on the inland transport of dangerous goods, the European Agreement 
concerning the International Carriage of Dangerous Goods (ADR) as well as the 
Universal Postal Convention, regulating postal sales at international level.485 
According to the Recommendations on the Transport of Dangerous Goods, 
pyrotechnics would fall under Class 1 articles, which refers to ‘explosive 
substances and articles’ dangerous goods, 486 and ‘may be admitted in letter-
post items and parcels in relations between member countries that have 
declared their willingness to admit them either reciprocally or in one direction, 
provided that they are in compliance with national and international transport 
rules and regulations, and are not carried by air’.487 At EU level, the Directive 
2008/68/EC on the inland transport of dangerous goods regulates the matter. 
While pyrotechnics should always be classified as dangerous goods for 
transport, they seem to be often sent by post as any other item by courier 
services to the buyer's home address. About these transfers of unlabelled 
parcels, one Member State authority highlighted that they have no specific 
measures in place to detect them488 or too little capacity in the face of the high 
volume of parcels circulating daily.489 As law enforcement authorities from 
different Member States indicated, since many shipments are undeclared and 

484   Interview with one Member State’s authority. 
485   Interview with one industry organisation/ industry representative association. 
486   UN Recommendations on the Transport of Dangerous Goods, Article 2.1.1. 
487   Regulations to the Universal Postal Convention -A Final Protocol, Article 19-001 (2). 
488   Interview with one industry organisation/ industry representative association.. 
489   Interview with one industry organisation/ industry representative association. 

118 

 
 
 
 
unlabelled or consigned under fictional names, it is difficult to identify the nature 
and risk of the goods being imported or initiate joint investigations with other 
Member States.490 Similarly, an industry representative reported that products 
purchased illegally online are typically shipped via standard courier services, 
without properly declaring the contents of the package, and indicated cases in 
which deliveries were sent to temporary addresses or tourist accommodations 
in Spain in order to avoid direct tracking of the usual buyer.491  

3.7.4. 

Challenges  

Messaging apps (such as WhatsApp, Telegram, or Signal), ‘Dark web 
market places’, and Social media platforms (such as Facebook, 
Instagram), seem, from the input gathered through the stakeholder 
consultation, to be considered among the most challenging types of 
platforms to monitor and regulate when it comes to the sales of illegal 
pyrotechnics, being indicated respectively by 34%, 32% and 26% of the 
answers given by the respondent Member States authorities. On the other 
hand, ‘E-commerce platforms’, such as Amazon or eBay, were considered 
challenging by only 14% of the responses, which seems to be in line with the 
input gathered from one industry stakeholder reported in the previous 
paragraph on e-commerce platforms being less problematic for illegal 
pyrotechnic sales. The remaining 9% of the responses provided to the survey 
targeted to Member State authorities indicated ‘other’ types of platforms as 
challenging, although only one national authority specified that – since 
economic operators have clear legal obligations (such as selling only compliant 
products and ensuring that restricted pyrotechnic articles are accessible only to 
individuals with specialised knowledge or official authorisation) – ‘every platform 
where no responsible economic operators are identified poses a risk’.492 

This overview portrays a rather challenging landscape for national 
authorities to monitor and regulate online sales of pyrotechnics, which is 
confirmed by Member States' authorities’ responses to the question of whether 
their national legal frameworks are sufficient to regulate the online sales of 
pyrotechnics to prevent criminal misuse: 17 of them answered positively,493 
while 16 negatively.494 The rest of the respondents declared not to know the 
answer. In this regard, one Member State authority indicated that the lack of 
specialist capacity to identify and enforce existing rules would be a bigger limit 
than potential gaps in the legal framework.495 One national authority highlighted 
how national rules offer a more secure framework, including controls on the 
buyer's identification, when pyrotechnic articles are bought online from national 

490   Input from authorities of three Member States.  
491   Interview with one industry organisation/ industry representative association..  
492   Interview with one industry organisation/ industry representative association. 
493   Responses from authorities of nine Member States. 
494   Responses from authorities of 12 Member States.  
495   Response from one Member State’s authority.   

119 

 
 
 
 
companies.496 However, this is not the case when pyrotechnic articles are 
bought on foreign websites, as in this situation, the article bought online 
would be shipped directly to the buyer without additional controls.497 This 
would seem to confirm that an issue also emerged in the 2023 Evaluation study 
of Pyrotechnics and Civil Explosives Legislation regarding challenges related 
to online sales from abroad, as one manufacturer underlined the lack of 
jurisdiction for national authorities to regulate and penalise sellers, 
buyers, or international courier companies.  

However, that is not always the case, and different Member States’ authorities 
stakeholders focus on different reasons for which their national legal 
frameworks are not sufficient to regulate online sales of pyrotechnics to 
prevent criminal misuse. One Member State authority stressed that most 
illegal trades are done in closed online chat groups, making it hard for 
authorities to join these groups undercover and carry out investigations.498 
Others pointed out the administrative nature of sanctions, which would not be 
deterrent enough to discourage criminal activities online, and the lack of 
monitoring and enforcement mechanisms.499  

Concerning specific regulatory gaps, thirteen Member States’ authorities 
indicated ‘Insufficient monitoring and enforcement mechanisms’, 500 twelve 
authorities indicated ‘difficulty in identifying and tracking online sellers’501 while 
nine authorities also added ‘lack of accountability for online platforms hosting 
illegal sales,502 and one authority indicated ‘inconsistent rules for cross-border 
e-commerce transactions’.503  

Consistent with these results, inputs gathered through the targeted interviews 
conducted during this study highlighted how one Member State authority 
mentioned collaboration between enforcement authorities and the main online 
platforms as insufficient.504 Another industry representative also pointed to 
ineffective rule enforcement, which they believed was possibly linked to a lack 
of sufficient personnel and methods available to detect illegal or diverted 
pyrotechnics.505 This aligns with the input received from another industry 
representative, who supported a reinforced surveillance of online sales and 
postal services rather than a simple reduction of online sales.506 Finally, the 
input from two industry representatives also suggests that many of the 
challenges arising from the online pyrotechnics market could be tackled through 

496   Response from one Member State’s authority.   
497   Ibid, and  interviews of authorities of two Member States. 
498   Response from one Member State’s authority.   
499   Response from one Member State’s authority.   
500   Responses from authorities of nine Member States.  
501   Responses from authorities of nine Member States.  
502   Responses from authorities of seven Member States.  
503   Response from one Member State’s authority.   
504   Responses from authorities of nine Member States.  
505   Interview with one industry organisation/ industry representative association. 
506   Interview with one industry organisation/ industry representative association. 

120 

 
 
 
 
an effective enforcement of already existing EU regulations (such as the Digital 
Services Act (DSA)).507  

One specific case regarding the regulation of online sales of pyrotechnics 
is in Spain. In Spain, any online sale with direct home delivery of pyrotechnic 
articles is prohibited, and customers can only purchase these items in person 
from authorised establishments, where their identity and age are verified. Still, 
issues with online platforms selling pyrotechnics persist.508 These include 
platforms selling pyrotechnics from countries where online sale is permitted, as 
well as platforms established in Spain, selling directly outside authorised 
circuits.509 In both cases, law enforcement seems to be significantly challenged 
by the large number of cases and sales, as well as the lack of traceability 
determined by fake labelling.510 

Eventually, one of the most quoted recurring issues linked both to the 
challenges of online sales and the lack of harmonisation between Member 
States is the issue of foreign online websites selling pyrotechnics 
illegally.511 The Swedish Customs’ authority, in particular, stressed how 
‘criminals mainly exploit the online sales of pyrotechnics in other EU member 
States’, taking advantage of regulatory differences among them. While in 
Sweden (as well as in other EU countries) some products are prohibited (for 
example bangers, fireworks, and sticks), they are available in other EU markets, 
particularly online. According to the Swedish authority representative, most of 
the seizures done by customs are parcels coming from other EU Member 
States purchased online. Swedish customs reported 193 cases in 2025 – a 
case is a seizure of one product or many – the vast majority would be coming 
from online retailers in Poland (although no evidence during this data collection 
was found demonstrating where these are illegally produced there or diverted 
there). The retailers of origin are not obvious, as parcels are unmarked 
because the consignor's name is never a company. Moreover, inside, 
there is no information on the retailer, except sometimes an invoice for 
orders and costs, but no name of the retailer.512 The Italian State Police 
Department also stressed that ‘controls related to European and intercontinental 
shipments are very few and low-profile’. 

During the workshop on the security risks posed by the misuse of pyrotechnics, 
held on 23 September 2025, while certain stakeholders seemed to consider an 
EU wide ban on online sales as a good practice, others were more sceptical 
about its potential impact. More specifically, a national  authority representative 
maintained that there is currently no reliable way of enforcing the regulatory 
requirements imposed on pyrotechnics, such as the age restriction, when 

507   Interview with one industry organisation/ industry representative association.  
508   Interview with one industry organisation/ industry representative association. 
509   Interview with one industry organisation/ industry representative association. 
510   Ibid. 
511   Interviews with authorities of three Member States and one industry organisation/ industry 

representative association. 

512   Response from one Member State’s authority.   

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transactions take place online across borders. Another Swedish authority 
representative, highlighted that only banning online sales in one Member State 
would be ineffective as sellers based in other MSs could continue operating. For 
these reasons they supported the idea of an EU-wide ban. 513 On the other 
hand, an industry representative argued that such a ban would primarily impact 
legitimate sellers and would not meaningfully deter criminals from selling high-
risk fireworks for illicit purposes. From an industry point of view, they 
maintained, a ban of only high risk products, such as F4 pyrotechnics, could be 
considered as a reasonable choice, while a total bun of all pyrotechnics would 
be ineffective.514 

Similarly, a Member State authority, expressed concern that tightening controls 
and restrictions over legally produced pyrotechnic articles, for instance by 
introducing measures preventing online sales, might lead to an increase of the 
illegal production of high-risk articles and the proliferation of illegal trade. This is 
because, according to the stakeholder, the demand for easily accessible 
explosives, such as flash powder, for illegal activities will remain unchanged.515  

As concerns the application of the DSA, there are multiple avenues 
available for addressing the illegal online sale of pyrotechnics. Firstly, 
under Article 9 of the DSA, when national judicial or administrative authorities 
issue orders against illegal content (including pyrotechnics illegally sold online) 
providers of intermediary services are required to act against such content 
without undue delay, and to inform the relevant authority about what action was 
taken. Such orders can be used to request the deletion of content.516 The same 
applies to requests to providers of intermediary services to provide specific 
information about one or more specific individual recipients of the service, in 
accordance with Article 10 DSA.517  

Moreover, hosting service providers are under an obligation to allow any entity 
to report the presence of illegal content on their service.518 Generally, notices 
that provide sufficient information to allow the service provider to identify the 
illegality of the reported content may lead to the loss of the liability exemption of 
the hosting service provider under Art 6 DSA; as such, hosting service providers 
are under an obligation to expeditiously remove or disable access to the content 
that is manifestly illegal.519 The role of this reporting mechanism in combating 
the illegal sale of pyrotechnics online can also be enhanced through reliance on 
trusted flaggers, in accordance with Article 22 DSA.520 In this regard, one of the 
conclusions of the Study visit to France on the misuse of pyrotechnic articles of 

513   Input from a Member State’s authority during the workshop with stakeholder organised for this study.   
514   Input from an EU-level industry organisation/ industry representative associationduring the workshop 

with stakeholder organised for this study.   

515   Input from a Member State’s authority during the workshop with stakeholder organised for this study.  .  
516   Regulation 2022/2065, article 9.  
517   Ibid, article 10.  
518   Ibid, article 16. 
519   Ibid, articles 6 and 16(3). 
520   Ibid, article 22.  

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the 26th June 2025 was the need for economic players in the legal sector to 
take up this role. Lastly, hosting service providers can take additional measures, 
such as account suspension, against ‘repeat offenders’ who frequently post 
manifestly illegal content.521 

A specific regime is applied to marketplaces, which are under the obligation to 
collect trader traceability information, including copies of identification 
documents, payment account details or trade register information.522 This 
traceability obligation for traders can play a role in the mitigation of the illegal 
sale of pyrotechnics, allowing for the facile identification of offenders.  

For very large online platforms and search engines (VLOPSEs), there is 
also an obligation to assess the risk of dissemination of illegal content 
through their services and take reasonable, proportionate, and effective 
mitigation measures against it.523 While the illegal sale of pyrotechnics may, 
in theory, fall under this systemic risk category, there is limited data in this 
regard, as none of the publicly available Risk Assessment Reports submitted by 
the VLOPSEs so far identifies this risk. This finding is congruent with an 
overarching conclusion on the application of the DSA to the illegal sale of 
pyrotechnics: there is limited practice or guidance in this regard, given that the 
enforcement of the DSA has only recently begun. In that sense, further 
assessments on the synergies between the DSA and the Pyrotechnics 
Directive appear necessary down the line. 

3.8. 

Case study A - From factory to the black market: 
Illegal manufacturing and diversion of 
pyrotechnics in the EU  

Findings from the data collected and analysed seem to indicate that illegal 
manufacturing appears to be a smaller phenomenon compared to 
diversion and trade of diverted pyrotechnics, with Member States identifying 
as a primary challenge the reliance on online shops and social 
media/communication channels to perform sales of diverted pyrotechnics. The 
data collected suggests that illegal pyrotechnic production within EU Member 
States is relatively limited in size, or geographically restricted to only some 
Member States, as illustrated by the deep dive into Italy, compared to the 
diversion of legally produced articles. Feedback collected from National 
Authorities through the survey indicates that illegal production within EU 
Member States does not seem to have significantly increased in the past five 
years and is considered to be of little importance by most national authorities. 
The use of (unlabelled) postal parcels has emerged as a key area of concern 
for several of the interviewed stakeholders from various Member States, linked 

521   Ibid, article 23(1).  
522   Ibid, article 30.  
523   Ibid, articles 34 and 35.  

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to the use of online retailers and marketplaces for carrying out purchases. In 
terms of specific articles concerned, F4 category articles seem to represent the 
primary concern for the most affected Member States; however, specific 
Member States such as Sweden and France report important seizures of 
F2/F3/P1 articles as well, purchased legally in Member States with less 
stringent licensing requirements and then illegally introduced in the national 
territory. Online retailers play a significant role in facilitating this type of trade.  

The full version of the case study A and country fiches is presented in Annexes 
II and III. 

3.9. 

Case study B - Explosions across borders: 
Security challenges in EU Member States most 
affected by pyrotechnic misuse  

Over the past decade, there has been a shift from hand grenades and firearms 
to the use of powerful pyrotechnics like F4 flash bangers in the EU Member 
States (Netherlands, Belgium, Germany, France and Sweden)  covered by this 
case study. Pyrotechnics seem to be more attractive to criminals due to 
their availability, relatively low cost, and less severe legal consequences. 
The Dutch authorities estimate that 80–90% of flash bangers used in the 
Netherlands are either illegally manufactured or diverted from the legal market. 
Mainly, category F4 fireworks emerge as the most commonly misused 
pyrotechnic articles across the case study countries, although there are some 
concerns about the increasing use of Category F3 products. This shift could 
accelerate if stricter restrictions are imposed on F4 articles. In the Netherlands, 
there is a specific concern over F4 shells, which are adapted for criminal 
purposes using modified ignition systems and can reach considerable 
distances. 

The misuse of pyrotechnics manifests in a variety of criminal contexts. 
They are used in acts of violence and intimidation, both in the private and 
criminal spheres. Examples include public disturbances (e.g., riots, 
demonstrations and attacks on law enforcement) and personal conflicts (e.g., 
relationships and debts). Flash bangers have been used to damage public 
infrastructure and private residences, contributing to growing fear among 
citizens. Organised crime groups play a central role in the criminal deployment 
of pyrotechnics. In cities like Antwerp, Rotterdam, and Amsterdam, through 
which drugs are trafficked, pyrotechnics are used in disputes and retaliatory 
violence between OCGs. In Sweden, they are even planted at residential 
entrances as a form of intimidation or attempted murder. This violence involving 
the misuse of pyrotechnics often crosses borders and involves international 
criminal networks. 

124 

 
 
 
A particularly alarming trend is the involvement of minors in carrying out 
attacks and explosions with pyrotechnics. Organised crime groups recruit or 
coerce young people into executing explosions, offering cash incentives or 
using intimidation tactics. In the Netherlands and Sweden, these practices are 
especially prevalent. Youths act as intermediaries or "runners" in a broader 
"violence-as-a-service" system, where attacks can be ordered online via 
encrypted messaging apps. 

Theft and sabotage, particularly ATM attacks, represent another form of 
criminal misuse. These incidents have been frequent in Belgium, the 
Netherlands, and Germany, where criminals use flash powder extracted from 
fireworks to break into cash machines. Although the number of such attacks 
appears to be declining due to better ATM security and protective measures, 
such as ink-stained bills, concerns persist about their spread to neighbouring 
countries. 

Some links between pyrotechnics and terrorism have also been noted, 
though on a limited scale. In the Netherlands, there have been isolated cases 
where fireworks were considered for use in terrorist plots, possibly driven by the 
restricted availability of conventional explosive precursors. Pyrotechnics are 
also featured in extremist propaganda across ideological lines, raising concerns 
about their potential future role in violent extremism. Nevertheless, more 
evidence of the possible misuse of pyrotechnics by extremists and/or terrorists 
has not been available to the study team due to the sensitivity of this field.  

Together, these findings underscore the urgent need for coordinated, cross-
border responses to the criminal misuse of pyrotechnics. While national efforts 
are essential, stakeholders have underscored the need for EU-wide initiatives to 
harmonise regulations, strengthen enforcement, and improve information 
exchange across Member States. 

The full version of the case study B and country fiches is presented in Annexes 
IV and V.  

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4. 

Conclusions 

This chapter presents the overall conclusions of the study, highlighting the 
key insights and implications derived from the evidence. In addition, the 
chapter draws out horizontal, cross-cutting conclusions that synthesise common 
themes, challenges, and patterns observed across the study areas and case 
studies. These overarching reflections aim to provide a coherent and evidence-
based picture of the security situation in the EU related to pyrotechnic articles. 
This, in addition to the upcoming evaluation and impact assessment of the 
Pyrotechnics Directive, can serve as a foundation for any future policy 
considerations to be made by the European Commission. 

4.1. 

Updated picture of the security problems (study 
area 1) 

The analysis of the criminal misuse of pyrotechnics reveals a fragmented and 
uneven threat landscape across the European Union. Several Member States, 
such as Italy, France, Germany, Belgium, the Netherlands, and Sweden, report 
significant challenges related to security risks posed by the criminal misuse of 
pyrotechnics. Other Member States perceive the issue as minimal or limited. 
The diverging degrees of impact on security across Member States result in 
different levels of prioritisation of the security issue, a fragmented collection of 
data and information, and a lack of a coherent regulatory framework. 

Illegal manufacturing of pyrotechnics presents a demarcated yet serious 
threat in certain Member States on a small and large scale. Activities range 
from small-scale homemade pyrotechnics production to sophisticated 
operations involving underground factories and, in some instances, production 
lines within legitimate companies on a large scale. Italy stands out, with 
authorities estimating that illegal manufacturing could constitute between 25% 
and 50% of the national pyrotechnics market. However, most Member States 
lack structured data collection mechanisms, which significantly hampers a 
comprehensive understanding of this issue. 

More prominent across the EU is the diversion of pyrotechnics from legal 
trade, particularly via online platforms. Weak or inconsistent enforcement of 
licensing and buyer verification, especially for high-risk Category F4 articles, 
creates vulnerabilities in the supply chain. Diverging regulatory frameworks and 
fragmented oversight across Member States further enable criminals and 
organised crime groups (OCGs) to exploit these gaps. This leaves room for 
legal pyrotechnics being diverted into the illegal market across borders. 

This, in turn, leads to the development of a parallel, underground market 
for pyrotechnics, sustained by both illegally manufactured and diverted 

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pyrotechnics. The illegal trade of both illegally manufactured and diverted 
pyrotechnics is increasingly facilitated via encrypted social media channels 
(such as Telegram and TikTok) and informal face-to-face transactions. 
Authorities face challenges not only in detecting pyrotechnics but also in 
distinguishing between illegally manufactured and diverted pyrotechnics, which 
undermines enforcement efforts and data reliability. 

Criminal misuse of pyrotechnics, particularly in the form of violence, 
intimidation, and property damage, emerges as the most prevalent and 
visible issue. Pyrotechnics are regularly used in public disturbances, such as 
riots, demonstrations, and football matches, and are also linked to attacks on 
ATMs, commercial buildings, and private residences. Countries such as the 
Netherlands, France, Sweden, and Belgium have experienced escalating 
incidents of violence involving fireworks, whereas other Member States report 
minimal to no problems. In this context, the involvement of organised crime 
groups in the misuse of pyrotechnics has been on the rise. OCGs 
increasingly favour pyrotechnics over firearms and hand grenades, viewing 
them as less regulated and less “conspicuous”. These articles are used both in 
their original form and as components of improvised explosive devices (IEDs). 
The destructive potential of high-powered products like flash bangers has been 
exploited in criminal disputes, drug trafficking conflicts, and targeted attacks. 

A particularly concerning trend is the recruitment and exploitation of 
minors by OCGs to carry out such attacks. Youth (e.g. from 
socioeconomically deprived backgrounds) are attracted by promises of money 
or coerced under threats to their family. In the Netherlands and Sweden, this 
phenomenon has become particularly acute, forming part of a broader 
“violence-as-a-service” system, where criminal acts, including attacks with 
pyrotechnics, are ordered via digital platforms. 

Across all the components of the security problem related to the criminal misuse 
of pyrotechnics, a clear cross-border dimension is evident. Criminals exploit 
postal services, seaports, and intra-EU trade routes to traffic large quantities of 
high-risk pyrotechnic articles. Ports such as Rotterdam and Gioia Tauro are 
common entry points, whereby storage facilities close to land borders are used 
to illegally distribute fireworks across borders. Differences in national legislation 
and enforcement practices further leave gaps for OCGs to operate cross-
border. Evidence confirms that Category F4 pyrotechnics pose the highest 
risk, given their high flash powder content and destructive capability. 
Stakeholders have raised concerns that restricting access to F4 articles could 
lead to the increased misuse of Category F3 products as a “waterbed effect”. 

While some indications of the use of pyrotechnics in terrorism or violent 
extremism have been identified in a few isolated cases, such as in Poland and 
the Netherlands, the overall scale of this threat seems to remain limited. 
However, the featuring of pyrotechnics in extremist and terrorist propaganda 
might point to concerns regarding the popularity of pyrotechnics in this field in 

127 

 
 
 
the future. This is further underscored by the use of pyrotechnics in other types 
of attacks (e.g. ATM attacks, violence, intimidation, etc.), which could act as a 
warning sign for the use of pyrotechnics in terrorism in the future. Due to the 
limited access to information regarding extremism and terrorism by the study 
team, conclusive evidence on the extent of the use of pyrotechnics in this field 
is lacking. 

A recurring theme across all components  is the lack of systematic data 
collection and reporting, which severely limits the ability of authorities to 
monitor, assess, and respond to the misuse of pyrotechnics effectively. Many 
Member States cannot distinguish between illegally manufactured and diverted 
articles in seizure data, nor can they consistently track criminal incidents 
involving pyrotechnics. 

Finally, the emergence of “waterbed effects” whereby the criminal misuse of 
pyrotechnics shifts between Member States in response to differing regulatory 
or enforcement approaches, highlights the necessity for greater EU-wide 
alignment. Without a coordinated response, restrictive measures in one 
Member State may simply displace the problem to another, rather than 
addressing it comprehensively. 

4.2. 

Harmonisation of national laws (study area 2) 

This area seeks to identify existing potential gaps or loopholes in the EU 
approach to criminal misuse of pyrotechnics while providing an overview of 
national legislation across Member States regulating the matter. These two 
levels of research aim to assess the potential for further harmonisation of 
national laws at the EU level and help identify Member States’ best practices. 

Overall, in terms of legal gaps in the EU approach towards pyrotechnics 
misuse, stakeholders have indicated the potential for further harmonisation 
between national laws on limitations on pyrotechnics. At the same time, 
they expressed concerns about the effective enforcement and 
implementation of the already existing rules. Regarding criminal sanctions, it 
appears that effectiveness and deterrent value depend not only on the 
legislative framework, but also on the authorities’ capacity to enforce it and the 
level of harmonisation between the criminal sanctions in effect in different EU 
member states.  

Certain EU-level actions were identified as potentially beneficial when 
considering the potential for further harmonisation of national legal frameworks. 
These proposed actions refer, among other things, to a European authorisation 
system for transfers, potentially inspired by the one set up in the Directive on 
explosives for civil uses, limitations on online sales of pyrotechnics, and the 
introduction of a certification system. In addition, operational-level measures 

128 

 
 
 
have been introduced in some Member States that could be replicated in 
other national contexts. 

Overall, based on the feedback gathered during the stakeholders workshop on 
the security risks posed by the misuse of pyrotechnics, organised on 23 
September 2025, most responding stakeholders (20 out of 30) agreed with the 
findings presented for Study Area 2.524  

4.3. 

Potential use of substances covered by 
Regulation (EU) 2019/1148 on explosive 
precursors to make illegal pyrotechnic articles 
(study area 3) 

Criminals continue to access and misuse pyrotechnic articles, including 
F4 category ones, and an increasing trend of using pyrotechnics to make 
IEDs for attacks has been reported.  

The illegal manufacturing sites producing unlicensed pyrotechnics, especially 
similar to certified F4 category pyrotechnics, have been detected in a limited 
number of EU Member States. Explosive precursors covered by Regulation 
(EU) 2019/1148 are substances used in the (legal and illegal) manufacture 
of pyrotechnic articles. While legal manufacturers operate under strict 
regulatory controls, illegal production typically occurs in non-compliant facilities, 
with products often replicating the effects of powerful F4 category articles. In 
case of illegal manufacturing, such production is suspected of using the same 
or similar chemicals as those used in legal manufacturing, making detection and 
differentiation difficult.  

Although Regulation (EU) 2019/1148 has strengthened controls on explosive 
precursors, differences in licensing and enforcement practices across Member 
States could lead to uneven results. However, the study findings point more 
strongly to the role of non-compliant imports, diversion of legal products, 
and extraction of pyrotechnic mixtures as key sources of misuse. Other 
factors may also influence the likelihood of illegal production, such as the 
presence of a (legal) pyrotechnic industry, e.g. by increasing access to 
materials, expertise, and infrastructure. 

F4 category pyrotechnics (potentially made in the EU or outside), which 
contain powerful pyrotechnic mixtures with restricted explosive precursors, are 
significant on the illegal market and are particularly attractive for misuse. 
This bypasses strict controls on explosive precursors. 

524   Summary report on the Security risks posed by misuse of pyrotechnics workshop with stakeholders, 

23rd September 2025 (source not available to the general public). 

129 

 
 
 
 
Research revealed that illegal manufacturing does occur within the EU. 
However, several consulted stakeholders suggested that the more prominent 
issues are the influx of non-compliant pyrotechnics from outside the EU, 
notably from China and Eastern Europe, and the diversion of legal 
products.  

Recent reports indicate the emerging practice of criminals extracting 
pyrotechnic mixtures, such as flash powder, directly from ready-made 
pyrotechnic articles. These are increasingly being repurposed by criminals to 
build IEDs, especially in some Member States, such as Belgium, the 
Netherlands, and Sweden. 

While illegal manufacturing has been detected in a few Member States, 
consulted stakeholders generally viewed the diversion of legal products and the 
influx of non-compliant imports, particularly from outside the EU, as more 
prominent issues. The extraction of pyrotechnic mixtures from legal articles for 
misuse was also highlighted. These findings suggest that illegal production is 
localised (and less prominent than diversion or import-related issues) and may 
be influenced by a combination of regulatory, industrial, and enforcement 
factors. 

4.4. 

Cross-border exchange of information and 
cooperation (study area 4) 

The analysis reveals a fragmented picture of cross-border cooperation and 
information exchange among EU Member States in addressing the criminal 
misuse of pyrotechnics. While certain Member States (e.g., Germany, the 
Netherlands, France and Belgium) demonstrate a proactive and coordinated 
approach, other Member States (e.g., Poland, Estonia, and Sweden) seem less 
engaged in the information exchange on the misuse of pyrotechnics. These 
disparities are primarily driven by differing perceptions of the threat level and 
variations in the enforcement of national legislation. 

Despite the availability of several EU-level tools—such as the Secure 
Information Exchange Network Application (SIENA), the Schengen Information 
System II (SIS II), the Internal Market Information System (IMI), and the TESTA 
network and SCEPYLT, their application in the context of pyrotechnics seems 
limited. Cooperation tends to occur bilaterally and on a need-to-know 
basis, with little reliance on centralised platforms. This fragmented usage of 
EU-level platforms and systems hinders transparency, coordinated intelligence-
sharing, and the development of a harmonised EU-wide strategy. 

Moreover, current cooperation efforts focus predominantly on reactive 
measures, such as ongoing investigations, rather than systematic and 
preventive approaches. This is compounded by the lack of a shared 
understanding of the nature and scale of the threat, as well as inconsistencies 

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in penalties and regulatory frameworks across Member States. While some 
operational successes have been recorded, such as joint investigations 
facilitated by Europol, these remain as specific cases rather than part of a 
broader coordinated framework. Furthermore, several structural and institutional 
barriers further impede effective cooperation. Divergent national experiences of 
the security threat result in uneven data collection practices and levels of 
engagement. Fragmentation at the national level, particularly between law 
enforcement, market surveillance, customs, and judicial authorities, also limits 
the flow of relevant information. The wide range of actors involved in the misuse 
of pyrotechnics poses difficulties in pinpointing the right counterparts in other 
Member States. Relatedly, not all relevant authorities have access to the key 
EU information-sharing systems, which further hinders effective information 
sharing and cross-border cooperation. 

Public-private cooperation remains underdeveloped. Most engagement 
between national authorities and the pyrotechnics industry focuses on the legal 
trade and consumer aspects, with limited attention to security concerns. Some 
examples of public-private cooperation exist such as, France’s industry-
government collaboration and Spain’s national roundtable on pyrotechnics. 
However, broader cooperation is hindered by a lack of established 
communication channels, shared terminology, and a common understanding of 
the associated risks. 

In light of these findings, there is a clear need for a more harmonised approach 
at both the national and EU levels. Based on the feedback received from 
national authorities, this could include strengthening Europol’s role as a central 
information and knowledge hub, as highlighted by the Council Conclusions of 
12 June 2025. Developing standardised procedures for reporting and 
information exchange between public and private actors, which could 
contribute to improving institutional connectivity and fostering a shared sense of 
urgency among Member States, are essential steps forward. In relation, findings 
highlight that successful models from related policy areas, such as explosives 
precursors and firearms, could inform the development of more effective public-
private cooperation mechanisms in the pyrotechnics sector. Establishing regular 
dialogue forums, guidance documents, and standardised data-sharing protocols 
could enhance collective efforts to prevent and respond to the criminal misuse 
of pyrotechnic articles. 

4.5. 

Tracking and tracing high-risk articles (study area 
5) 

This study area seeks to identify the challenges law enforcement agencies face 
when attempting to trace the origin of pyrotechnic articles used to commit illegal 
acts. Findings showed a broad consensus on the existing key shortcomings in 
LEAs' ability to perform tracking and tracing activities. These seem to 

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relate primarily to the different national legislations, and in particular 
disharmonised licensing requirements across Member States, the 
increasing reliance on web shops for purchasing articles, and the related 
anonymity that online platforms can offer, and limited resources affecting 
the rapidness of cross-border information exchange. Inconsistent 
labelling practices across Member States, as well as the frequent use of 
unlabelled postal parcels to move articles across countries, were 
identified as modus operandi which affect the capacity of authorities to track 
and trace pyrotechnic articles across borders. Feedback collected pointed to the 
interest of some representatives of the law enforcement community in setting up 
a similar system for tracing as the one currently in place for civil explosives use, 
or as the Pyropass currently being tested by the Benelux countries. Scepticism 
was expressed by some representatives of industry on the possibility of 
employing a system similar to the one used for civil explosives due to its high 
costs.  

4.6. 

Strengthening customs enforcement (study area 
6) 

Despite the harmonised framework provided by the Pyrotechnics Directive 
2013/29/EU and the EU Customs Code, enforcement of import controls on 
pyrotechnic articles faces significant challenges. While customs authorities 
generally view current tools and procedures as effective, the data gathered on 
this topic remains limited due to low participation from customs authorities and, 
more broadly, from enforcement actors. This restricts the ability to fully assess 
the effectiveness of current measures and identify systemic gaps. Nonetheless, 
the available inputs confirm several persistent issues: inconsistent intra-EU 
control practices, misclassification of goods, high parcel volumes, and 
limited detection capabilities. The growing use of online sales and parcel 
delivery and the consequent increase in the number of goods moving 
across the EU further complicate enforcement. Strengthening intelligence 
sharing, enhancing technological capabilities, and establishing a uniform 
authorisation framework could be considered to improve the detection and 
control of illegal pyrotechnic imports across the EU. 

4.7. 

Role of online sales/mail order sales (study area 
7) 

The research conducted in this area aims to clarify the scope, impact, and 
modus operandi of the online trade of illegal pyrotechnics and the challenges it 
poses to law enforcement authorities. The findings of this study area show that 
it is still difficult for both Member States’ national authorities and industry 
representatives to identify and quantify, or estimate, what proportion of the 

132 

 
 
 
pyrotechnics used for committing illegal acts is obtained online, or what 
proportion of these pyrotechnics comes from legal suppliers. Although the 
precise scale of the problem remains difficult to determine, stakeholders from 
various Member States seem to agree that online sales, especially the cross-
border ones, and postal deliveries, pose significant security challenges. 

At the same time, more and more Member States are becoming more aware of 
the potential loopholes that online sales of pyrotechnics can create, and are 
focusing their attention on online sales coming from other EU countries, which 
might have in place different regulations. In general, there is a growing 
concern over the effective enforcement of both national and EU rules on 
the sales of pyrotechnic articles online, and a growing attention is being 
paid to the challenges of tracking and tracing parcels due to the vast 
amount of goods sold and sent every day, but also to the possibilities 
provided by different types of online platforms to elude controls. 
Furthermore, the ability of the buyer to remain anonymous and avoid any 
physical interaction with the seller, when purchasing articles online, creates 
considerable obstacles for law enforcement agencies’ efforts to prevent 
diversion to criminals. 

Concerning the platforms used, messaging services have been found to be 
particularly challenging to regulate due to, among other things, the informal 
nature of the transactions, making them more problematic than online shops. 
Specifically concerning online retailers, individual online shops seem be more 
challenging to control than big e-commerce platforms. 

Overall, the feedback collected during the stakeholders’ workshop on security 
risks linked to the misuse of pyrotechnics, held on 23 September 2025, 
indicated that stakeholders strongly agreed with the findings of Study Area 7.525 

4.8. 

Overview of horizontal conclusions 

This study has examined the criminal misuse of pyrotechnic articles across 
Member States, identifying key vulnerabilities, cross-border dynamics and 
enforcement challenges. As specific conclusions for individual study areas 
have already been presented above, this final section reports conclusions of a 
horizontal nature, highlighting overarching patterns and structural issues, as 
follows: 

●  Member States differ in how seriously they view the security risks linked 

to pyrotechnics. This leads to uneven levels of prioritisation and 

525 Summary report on the security risks posed by misuse of pyrotechnics workshop with stakeholders, 

23rd September 2025 (source not available to the general public). 

133 

 
 
 
 
engagement, which in turn undermines the effectiveness of collective 
action. 

●  The absence of reliable data on illegal manufacturing, diversion, and 
misuse makes it difficult to build a shared intelligence picture. This 
weakens Member States' ability to identify trends, track suspicious 
actors, or respond to emerging threats. 

●  Differences across national frameworks, e.g. in licensing rules, specialist 
knowledge requirements, and sanctions, create potential loopholes for 
criminal exploitation. 

●  The lack of a centralised system for tracking and tracing pyrotechnic 

articles across borders makes it easier for items to be diverted from the 
legal to the illegal market.  

●  Online platforms and social media have become key channels for illegal 
sales and the ordering of attacks as part of violence-as-a-service. Their 
speed, anonymity, and use of encrypted messaging make it difficult for 
national authorities to monitor activity or identify those involved. 

●  Postal and courier services, including private operators, are widely used 

to move illegal pyrotechnics. These items are often mislabelled or 
disguised as ordinary goods, and the high volume of parcels entering the 
EU and moving across Member States makes systematic inspection 
nearly impossible. 

●  National authorities face serious resource constraints. Only a small 

proportion of flagged shipments can be inspected, and seizures often 
depend on individual initiative rather than coordinated systems among 
the authorities of Member States. 

●  Cooperation between Member States remains limited. There are still 

gaps in communication, data sharing, and joint enforcement, particularly 
at key entry points like maritime ports. Similarly, public-private 
cooperation could be improved. 

●  Waterbed effects occur in three ways: 

o  Shifts in the modus operandi of OCGs and criminals (e.g. if F4s are more 

restricted, likely moving to category F3) 

o  Changes in the locations of violence with pyrotechnics in the organised 
crime context (e.g., related to drug trafficking routes and seaports) 

o  From  Member States with stricter rules and controls, to other Member 

States with less stringent rules. 

●  The involvement of minors and youth in the illegal trade of pyrotechnics 
and carrying attacks adds a worrying social dimension to these criminal 
activities, calling for targeted prevention efforts. 

134 

 
 
 
Overall, the evolving tactics of criminal actors highlight the need for a 
more integrated approach across Member States. The findings point to the 
need for future discussions on reinforcing the security dimension of the 
Pyrotechnics Directive, improving cross-border cooperation among Member 
States, and addressing the risks posed by non-compliant imports from outside 
the EU. Furthermore, aligning regulatory frameworks and enforcement practices 
across Member States is essential to closing existing loopholes and enhancing 
collective security. 

135 

 
 
 
 
Annex I Bibliography  

The study team compiled a list of relevant sources of information for the study. 
It is reviewed and enriched with sources, based on feedback from the European 
Commission, information gathered through desk research, and suggestions 
from stakeholders.  

EU Legislative / Non-legislative acts 

Directive (EU) 2017/541 of the European Parliament and of the Council of 15 
March 2017 on combating terrorism and replacing Council Framework Decision 
2002/475/JHA and amending Council Decision 2005/671/JHA  

Directive 2008/68/EC of the European Parliament and of the Council of 
24 September 2008 on the inland transport of dangerous goods 

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) 

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 for civil 
uses (recast) 

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  

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 765/2008 and (EU) 
No 305/2011  

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 (EU) No 98/2013 

Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 
October 2022 on a Single Market For Digital Services and amending Directive 
2000/31/EC (Digital Services Act) 

136 

 
 
 
EU documents (policy documents, studies and media) 

Council of the EU (2023). Draft Report of action 11.9 explosives – fireworks, 
pyrotechnics and their precursors. 
https://data.consilium.europa.eu/doc/document/ST-8577-2023-REV-1/en/pdf  

DJS (2016). F4 Flash Bangers in EU Member States. Study on production, 
import and use in the EU of high-risk pyrotechnic articles categorised according 
to Directive 2007/23/EC and Directive 2013/29/EU. [Restricted] 

European Commission (forthcoming). Evaluation study of Pyrotechnics’ 
Legislation, Interim Report. [Restricted].  

European Commission (2011). Progress report on the implementation of the EU 
Action Plan on enhancing the security of explosives. https://home-
affairs.ec.europa.eu/system/files/2020-
09/progress_report_on_explosives_security_2012_en.pdf  

European Commission (2020). Guidelines for the implementation of Regulation 
(EU) 2019/1148 on the marketing and use of explosives precursors. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020XC0624(01)  

European Commission (2021). TESTA – 20 years of history.  
https://ec.europa.eu/isa2/sites/default/files/testa_-
_20_years_isa_2_web_page_-_01_2021.pdf  

European Commission (2023). Strategy for Customs cooperation in the area of 
law enforcement and its contribution to the internal security of the EU. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52023XG0620(01)#:~:text=The%20overall%
20aim%20of%20this,responses%20to%20cross%2Dborder%20crimes  

European Parliament (2019). EU legislation in progress. Explosive precursors. 
Fighting the misuse of chemicals by terrorists. 
https://www.europarl.europa.eu/RegData/etudes/BRIE/2019/635571/EPRS_BRI
(2019)635571_EN.pdf  

Europol (2023). TE-SAT 2023. https://www.europol.europa.eu/publication-
events/main-reports/european-union-terrorism-situation-and-trend-report-2023-
te-sat  

Europol (2024). The recruitment of young perpetrators for criminal networks. 
Intelligence notification. 
https://www.europol.europa.eu/cms/sites/default/files/documents/IN_The-
recruitment-of-young-perpetrators-for-criminal-networks.pdf  

Europol (2024). Pyrotechnics in the EU: State of Play. [Restricted]  

137 

 
 
 
Europol (2025). SOCTA. The changing DNA of serious and organised crime. 
https://www.europol.europa.eu/publications-events/main-reports/socta-report  

Oxford Research (2019). Study on the illegal sales of F4 pyrotechnics articles 
destined for professional users to the general public. 
http://healthandsafetyineu.it/images/product-safety/products/Study-on-illegal-
sales-of-pyrotechnic-articles-PAD-2013_29_EU-April-2019.pdf  

DG HOME (n.d.). Schengen Information System. https://home-
affairs.ec.europa.eu/policies/schengen/schengen-information-system_en  

European Commission (n.d.). Import Control System 2 (ICS2). https://taxation-
customs.ec.europa.eu/customs-4/customs-security/ics2_en  

Eurojust (2018). International cooperation disrupts illegal fireworks network. 
https://www.eurojust.europa.eu/news/international-cooperation-disrupts-illegal-
fireworks-network  

European Commission (2025). Legislation on chemicals used in Home Made 
Explosives. https://home-affairs.ec.europa.eu/policies/internal-security/counter-
terrorism-and-radicalisation/protection/legislation-chemicals-used-home-made-
explosives_en  

European Commission (n.d.). Customs Risk Management Framework (CRMF). 
https://taxation-customs.ec.europa.eu/customs-4/customs-risk-
management/customs-risk-management-framework-crmf_en  

European Commission (n.d.). Internal Market Information System (IMI). 
https://ec.europa.eu/internal_market/imi-net/about/index_en.htm  

European Commission (n.d.). Mutual legal assistance and extradition. 
https://commission.europa.eu/law/cross-border-cases/judicial-
cooperation/types-judicial-cooperation/mutual-legal-assistance-and-
extradition_en  

European Commission (n.d.). Prohibitions and Restrictions. https://taxation-
customs.ec.europa.eu/customs-4/prohibitions-and-restrictions_en  

Europol (2022). Heavy fireworks off the market for safer holidays. 
https://www.europol.europa.eu/media-press/newsroom/news/heavy-fireworks-
market-for-safer-holidays  

Europol (2023). Dismantling encrypted criminal EncroChat communication 
leads to over 6500 arrests and close to EUR 900 million seized. 
https://www.europol.europa.eu/media-press/newsroom/news/dismantling-
encrypted-criminal-encrochat-communications-leads-to-over-6-500-arrests-and-
close-to-eur-900-million-seized  

138 

 
 
 
Europol (2025). Secure Information Exchange Network Application (SIENA). 
https://www.europol.europa.eu/operations-services-and-innovation/services-
support/information-exchange/secure-information-exchange-network-
application-siena  

Europol (2025). Violence as a service: criminals hire criminals. 
https://www.europol.europa.eu/media-press/newsroom/news/violence-service-
criminals-hire-criminals  

National-level documentation 

French Ministry of Interior, Press review: misuse of fireworks and pyrotechnics 
in France. [shared by the European Commission] 

French Republic, 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 – Légifrance [in French] 
https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000047800682  

French Senate (2024), Émeutes de juin 2023: comprendre, évaluer, réagir 
Rapport d'information n° 521 (2023-2024) [in French] 
https://www.senat.fr/rap/r23-521/r23-5213.html#toc65  

Spain (2015), Real Decreto 989/2015, de 30 de octubre, por el que se aprueba 
el Reglamento de artículos pirotécnicos y cartuchería [in Spanish] 
https://www.boe.es/buscar/act.php?id=BOE-A-2015-12054  

Spanish Guardia Civil (2025), Weapons And Explosives Central Inspectorate 
Report On The Seizure In Public Areas Of Counterfeit And Illegally 
Manufactured Pyrotechnics. [shared by the European Commission]  

Spanish Ministry of Interior, Uso de artículos pirotécnicos de las categorías F1, 
F2, F3, T1, P1 [in Spanish], https://www.interior.gob.es/opencms/es/servicios-
al-ciudadano/tramites-y-gestiones/seguridad/articulos-pirotecnicos/uso-de-
articulos-pirotecnicos-de-las-categorias-F1-F2-F3-T1-P1/  

Government of the Netherlands, République Française (2025), Modify the pyro 
directive to protect public order and safety. 
https://www.rijksoverheid.nl/documenten/rapporten/2025/02/14/tk-bijlage-
collaborative-non-paper-pyrotechnics-nl-fr  

Dutch Cabinet (2025). Initiative bill for a fireworks ban for consumers. 
https://www.tweedekamer.nl/kamerstukken/plenaire_verslagen/kamer_in_het_k
ort/initiatiefwetsvoorstel-vuurwerkverbod-voor  

Dutch Ministry of Infrastructure and Water (2024). Cabinet response to the 
Commission’s consultation regarding the European Procedure on explosives for 
civil use. [in Dutch] https://zoek.officielebekendmakingen.nl/blg-1150081.pdf  

139 

 
 
 
Dutch Ministry of Infrastructure and Water Management, The Intelligence and 
Investigation Service of the Human Environment and Transport Inspectorate 
(ILT-IOD) (2025). Presentation on the “Findings of international investigations 
into illegal trade with F4 fireworks, Request police contacts & Dutch Pyro-Pass”. 
Source not available to the general public.  

Government of The Netherlands (2024). Dutch government commits to 
crackdown on explosives and dangerous fireworks. 
https://www.government.nl/latest/news/2024/12/19/dutch-government-commits-
to-crackdown-on-explosives-and-dangerous-fireworks  

Government of the Netherlands (2024). Modify the pyrotechnics Directive for 
the sake of public order and safety. [Non-paper]. 
https://www.rijksoverheid.nl/documenten/rapporten/2024/02/23/tk-bijlage-3-nl-
non-paper-pyrotechnics-directive  

Police Sweden (2024). Status report regarding explosives and other hazardous 
substances [In Swedish]. 
https://polisen.se/siteassets/dokument/ovriga_rapporter/lagesrapport-om-
explosiva-och-andra-farliga-amnen-2023.pdf  

Regerinskansliet (2023). Firearms and explosives – tougher penalties for the 
more serious crime.[In Swedish]. https://www.regeringen.se/rattsliga-
dokument/proposition/2023/10/prop.-
20232433#:~:text=Det%20f%C3%B6resl%C3%A5s%20ske%20p%C3%A5%20
f%C3%B6ljande,%C3%A5r%20och%20h%C3%B6gst%20tio%20%C3%A5r.  

Other (e.g. Academia, Civil Society, Media) 

ABC News. (2023) Why is France rioting? What to know about the fatal police 
shooting of Nahel M https://abcnews.go.com/International/france-rioting-police-
shooting-nahel/story?id=100655786  

Anadolu Agency. (2025). German officials call for tighter controls on illegal 
fireworks after deadly chaos in country. 
https://www.aa.com.tr/en/europe/german-officials-call-for-tighter-controls-on-
illegal-fireworks-after-deadly-chaos-in-country/3440968. 

ANCI. (n.d.). Piroguida. [In Italian] https://www.anci.it/wp-
content/uploads/Piroguida_compressed-1.pdf  

ANSA English (2024). One tonne of illegal fireworks seized at Gioia Tauro. 
https://www.ansa.it/english/news/general_news/2024/12/30/one-tonne-of-illegal-
fireworks-seized-at-gioia-tauro_8b4206c8-ba6a-477e-9899-5e150b853737.html  

ANSA. (2023). 6 tonnes illegal fireworks seized in Rome. 
https://www.ansa.it/english/news/general_news/2023/12/30 ù 

140 

 
 
 
Approdolacabria.it. (n.d.). Oltre 78 tonnellate di fuochi d’artificio sequestrati al 
Porto di Gioia Tauro. [In Italian] https://www.approdocalabria.it/giornale/oltre-78-
tonnellate-di-fuochi-dartificio-sequestrati-al-porto-di-gioia-tauro/  

Articolo 21. (2021). Fuochi d’artificio, il messaggio cifrato della criminalità 
organizzata: da Roma a Napoli. [In Italian] 
https://www.articolo21.org/2021/09/fuochi-dartificio-il-messaggio-cifrato-della-
criminalita-organizzata-da-roma-a-napoli/  

ATF (n.d.). Illegal explosives. https://www.atf.gov/explosives/tools-services-
explosives-industry/explosive-products-and-devices/illegal-explosives  

BBC News. (2017). Portugal fireworks factory blast kills five near Lamego. 
https://www.bbc.com/news/world-europe-39500649 

Betti, S. (2023). Measuring the scope and scale of illicit trade and counterfeit 
goods. Global Initiative against Transnational Organized Crime. 
https://globalinitiative.net/wp-content/uploads/2023/04/Stefano-Betti-Measuring-
the-scope-and-scale-of-illicit-trade-and-counterfeit-goods-GI-TOC-August-
2023.pdf  

Bezemer, K.D.B., Forbes T.P., Hulsbergen, A.W.C., Verkouteren, S.T., Kraus., 
Kobeberg, M., Schoenmakers, P.J., Gillen, G., & van Asten, A.C. (2020). 
Emerging techniques for the detection of pyrotechnic residues from seized 
postal packages containing fireworks, Forensic Sci. Int. 308  

BFMTV. (2025) INFO BFMTV. 389 interpellations, 28 blessés chez des forces 
de l'ordre et secours... La nuit de dimanche à lundi marquée par des violences. 
[in French] https://www.bfmtv.com/police-justice/info-bfmtv-389-interpellations-
28-blesses-chez-des-forces-de-l-ordre-la-nuit-de-dimanche-a-lundi-marquee-
par-des-violences_AN-202507140389.html 

Brandweer Nederland (2025). General fireworks ban from 2026 – Dutch Fire 
Brigade relieved and concerned. [In Dutch]. 
https://www.brandweernederland.nl/nieuws/algeheel-vuurwerkverbod-vanaf-
2026-brandweer-nederland-opgelucht-en-bezorgd/  

Bundesministerium des Innern und für Heimat. (2024). Kampf gegen 
Organisierte Kriminalität und hochgefährliche Taten mit Explosivstoffen: 
Kabinett beschließt Änderung des Sprengstoffgesetzes. [In German] 
https://www.bmi.bund.de/SharedDocs/pressemitteilungen/DE/2024/10/kabinett-
sprengstoffge.html. 

Business Insider. (2021). Niemcy "przemycają" polskie fajerwerki, bo u nich 
kupić ich nie wolno. Wielkie kontrole na granicy. [In Polish] 
https://businessinsider.com.pl/gospodarka/fajerwerki-w-niemczech-zakazane-
wiec-przemyt-z-polski-kwitnie/w4r43wy. 

141 

 
 
 
Business Insider. (2023) France is banning the sale of fireworks on its biggest 
national holiday after protesters used them as weapons against police. 
https://www.yahoo.com/news/france-banning-sale-fireworks-biggest-
143544044.html?utm_source=chatgpt.com&guccounter=1&guce_referrer=aHR
0cHM6Ly9jaGF0Z3B0LmNvbS8&guce_referrer_sig=AQAAAIG4dtai5rMywzquR
2aBamRApt9hPKqaGVUogvW7UzWU2LfAnmOYI0EMzq0kls5-
tvkLTXXfcXVx_Rp-
mQRuA11_e1q5U4FzSkhkenTmaurXedGX_o4hrwYgwH6VUyTedqOS0qbo45s
P_ipcSv7mp-3Yi3GSUMU2dleVuLwtmhkj  

BVPK. (n.d.). Umsatz 2024. [In German] https://bvpk.org/aktuelles/umsatz-
2024. 

C. Schouten. (2025), Joint Letter of European Mayors Calling for measures 
against the misuse of explosives and pyrotechnics. [shared by the European 
Commission] 

Carabinieri Facebook Page: [In Italian] 
https://www.facebook.com/photo.php?fbid=1431984273603632&id=837551153
046950&set=a.896546523814079  

Carabinieri. (n.d.). Campagna d'informazione e sicurezza sull'uso dei fuochi 
d'artificio. [In Italian] https://www.carabinieri.it/in-vostro-aiuto/consigli/Cose-di-
tutti-i-giorni/fuochi-artificio/campagna-d'informazione-e-sicurezza  

Carabinieri. (n.d.). Smantellati due laboratori di artifizi pirotecnici illegali. [In 
Italian] https://www.carabinieri.it/in-vostro-aiuto/informazioni/comunicati-
stampa/smantellati-due-laboratori-di-artifizi-pirotecnici-illegali  

Comune di Napoli (2011) Usa la testa, non rovinarti la festa! A servizio del 
consumatore – Fuochi d’artificio, Città e Consumi, n. 18 (Dicembre 2011–
Gennaio 2012) [In Italian] 
https://www.comune.napoli.it/flex/files/5/b/7/D.9710fff00db5326fe08d/5._a_servi
zio_del_consumatore.pdf  

Coppe, D., & Impemba, S. (2024). Flash powder: Introduction, risks and 
experimental Tests. Aspects Min Miner Sci, 12(3), 
https://crimsonpublishers.com/amms/pdf/AMMS.000788.pdf  

Corriere della Sera. (2015). Roma, una tonnellata di fuochi illegali sequestrata 
tra Capitale e Castelli. [In Italian] 
https://roma.corriere.it/notizie/cronaca/15_dicembre_29/fuochi-illegali-
tonnellata-sequestrata-roma-castelli-1e05b766-ae3d-11e5-a515-
a44ff66ae502.shtml  

Corriere della Sera. (2023). Fuochi d’artificio a Napoli, svelato il codice dello 
spaccio. [In Italian] https://napoli.corriere.it/notizie/cronaca/23_marzo_15/fuochi-

142 

 
 
 
d-artificio-a-napoli-svelato-il-codice-dello-spaccio-859e1ade-3699-40c5-ae5c-
77d7d6efbxlk.shtml  

De Standaard (2025). Police confiscate 5,300 fireworks from candidate Les 
Engagés: “for my daughter’s wedding”.[In Dutch]. 
https://www.standaard.be/cnt/dmf20250101_96847874  

Deutscher Bundestag. (2024). Entwurf eines Dritten Gesetzes zur Änderung 
des Sprengstoffgesetzes, des Strafgesetzbuches und weiterer Gesetze. 
https://dserver.bundestag.de/btd/20/140/2014040.pdf. 

La Repubblica (2025) Botti di Capodanno, 309 feriti: mai così tanti negli ultimi 
dieci anni. 146 arresti, [In Italian] 
https://www.repubblica.it/cronaca/2025/01/01/news/botti_capodanno_feriti-
423915312/  

Diário da República Eletrónico. (2021). Decreto-Lei n.º 62/2021 de 20 de julho. 
https://diariodarepublica.pt/dr/detalhe/decreto-lei/62-2021-168296687; Diário da 
República Eletrónico. (2021). Decreto-Lei n.º 82/2021 de 13 de outubro. [In 
Portuguese] https://files.dre.pt/1s/2021/10/19900/0000200047.pdf. 

Diário de Notícias. (2025). PSP lembra tragédia de 1996 para alertar para os 
perigos da pirotecnia na final da Taça de Portugal. [In Portuguese] 
https://www.dn.pt/desporto/psp-lembra-trag%C3%A9dia-de-1996-para-alertar-
para-os-perigos-da-pirotecnia-na-final-da-ta%C3%A7a-de-portugal. 

DW (2022), Dutch and German police seize 250 tons of illegal fireworks. 
https://www.dw.com/en/police-seize-250-tons-of-illegal-fireworks-at-dutch-
german-border/a-64170955 

DW. (2022). Germany: New Year's Eve fireworks for sale again after ban. 
https://www.dw.com/en/germany-new-years-eve-fireworks-for-sale-again-after-
ban/a-
64234295#:~:text=People%20in%20Germany%20will%20be,hospitals%20durin
g%20the%20COVID%20pandemic.&text=The%20sale%20of%20fireworks%20f
or,of%20fireworks%20sales%20this%20year  

Elevated Fireworks (2025). Salute Fireworks: The Loudest Booms in the Sky. 
https://elevatedfireworks.com/blogs/product-education/salute-fireworks-the-
loudest-booms-in-the-sky-elevated-
fireworks?srsltid=AfmBOoobMaAHsvge8uGSLBwNcVX4n-Vv-
siCdRfgWsE_qsYLaXRUPhmB  

Emmelle. (2023). Sospesa dalla prefettura l’attività della fabbrica di petardi. [In 
Italian] https://www.emmelle.it/2023/02/21/sospesa-dalla-prefettura-lattivita-
della-fabbrica-di-
petardi/#:~:text=Sospesa%20dalla%20prefettura%20l'attivit%C3%A0%20della
%20fabbrica%20di%20petardi%20%2D%20emmelle.it.&text=TERAMO%20%E

143 

 
 
 
2%80%93%20La%20prefettura%20di%20Teramo%20ha,di%20Dino%20Trigna
ni%2C%20avvenuta%20la%20scorsa%20settimana  

Etcetaljornal. (2019). Pirotecnia portuguesa conquistou mais um prémio 
internacional ao ser vice-campeã em festival internacional realizado na Rússia. 
[In Portuguese] https://etcetaljornal.pt/j/2019/09/pirotecnia-portuguesa-
conquistou-mais-um-premio-internacional-ao-ser-vice-campea-em-festival-
internacional-realizado-na-russia/  

Eurojust. (n.d.). International cooperation disrupts illegal fireworks network. 
https://www.eurojust.europa.eu/news/international-cooperation-disrupts-illegal-
fireworks-network  

Europol. (n.d.). 350 tonnes of dangerous fireworks seized in Germany and 
Netherlands. https://www.europol.europa.eu/media-press/newsroom/news/350-
tonnes-of-dangerous-fireworks-seized-in-germany-and-netherlands 

Euro News. (2025) Two people killed and hundreds arrested in France during 
Champions League win celebrations. https://www.euronews.com/my-
europe/2025/06/01/two-people-killed-over-200-injured-in-champions-league-
win-celebrations-in-france  

Expresso. (2018). Fogo de artifício nos céus europeus é 98% chinês. Portugal 
é exceção. [In Portuguese] https://expresso.pt/economia/2018-12-31-Fogo-de-
artificio-nos-ceus-europeus-e-98-chines.-Portugal-e-excecao 

F.A.Z. (2025), Wie Händler in Deutschland niederländische Kriminelle mit 
Sprengstoff versorgen [in German]. 
https://www.faz.net/aktuell/politik/inland/sprengstoff-haendler-in-deutschland-so-
versorgen-sie-niederlaendische-kriminelle-
110590277.html?GEPC=s9&premium=0x1034a8c60183b03f9399fe04e076714
3abfa3d65fd8a3371980c1aa5cb468f7e 

Fabre, A.S., Florquin, N., & Schroeder, M. (2023). Illicit firearms ammunition 
and other explosive munitions in the European Union. 
https://www.smallarmssurvey.org/resource/illicit-firearms-ammunition-and-other-
explosive-munitions-european-union  

Federal Ministry of Research, Technology and Space (n.d.). Vorsicht! 
Celebrating the New Year's Eve. https://www.study-in-
germany.com/en/community/vorsicht-celebrating-the-new-years-eve/  

FirenzeToday. (2024). Fuochi d'artificio, le mafie e i segnali criminali: la 
fondazione Caponnetto chiede un'interrogazione al ministro. [In Italian] 
https://www.firenzetoday.it/cronaca/fuochi-artificio-mafie-segnali-criminali-
calleri-fondazione-caponnetto-interrogazione-ministro.html  

144 

 
 
 
French Ministry of Interior (2025), Study visit to France on the misuse of 
pyrotechnic articles. [shared by the European Commission] 

French Ministry of Interior, Gendarmerie National (2025), Misuse of fireworks. 
[shared by the European Commission] 

GazetaPrawna. (2018). CBŚP przejęło 80 ton nielegalnych materiałów 
wybuchowych. 35 osób z zarzutami. [In Polish] 
https://www.gazetaprawna.pl/wiadomosci/artykuly/1381995,cbsp-przejelo-80-
ton-nielegalnych-materialow-wybuchowych.html 

Gazzetta Ufficiale. (1930). Art. 703 - Accensioni ed esplosioni pericolose. [In 
Italian] 
https://www.gazzettaufficiale.it/atto/serie_generale/caricaArticolo?art.versione=1
&art.idGruppo=79&art.flagTipoArticolo=1&art.codiceRedazionale=030U1398&ar
t.idArticolo=703&art.idSottoArticolo=1&art.idSottoArticolo1=10&art.dataPubblica
zioneGazzetta=1930-10-26&art.progressivo=0  

GI-TOC and Insights Crime (2021). The cocaine pipeline to Europe.  

Gorzow24.pl. (2025). Batalia legislacyjna: Czy Polska zakaze fajerwerków 
konsumenckich?. [In Polish] https://www.gorzow24.pl/news/33/ogloszenia/2025-
06-30/batalia-legislacyjna-czy-polska-zakaze-fajerwerkow-konsumenckich-
16630.html  

Government of the Netherlands, Offensive presents approach to tackle attacks 
using explosives. Offensive presents approach to tackle attacks using 
explosives | News item | Government.nl 

HLN (2025). At least 230 arrests: dozens of vehicles burned out and emergency 
services attacked: the balance sheet of New Year's Eve in Flanders and 
Brussels. [In Dutch] https://www.hln.be/regio/minstens-230-arrestaties-
tientallen-voertuigen-uitgebrand-en-hulpdiensten-aangevallen-de-balans-van-
nieuwjaarsnacht-in-vlaanderen-en-brussel~a3865250/  

https://globalinitiative.net/wp-content/uploads/2021/02/The-cocaine-pipeline-to-
Europe-GI-TOCInsightCrime.pdf 

Il Centro. (2023). Operaio ucciso dall'esplosione, preparava i fuochi d'artificio. 
[In Italian] https://www.ilcentro.it/pescara/operaio-ucciso-dall-esplosione-
preparava-i-fuochi-d-artificio-1.3080072  

Il Mattino (2024). Dangerous explosive devices seized in Naples: the champion 
bombs phenomenon [In Italian] 
https://www.ilmattino.it/en/dangerous_explosive_devices_seized_in_naples_the
_champion_bombs_phenomenon-8496349.html 

Innit (n.d.) Online petition on nationwide firecracker ban started by Berlin Police 
Union [in German]. https://innn.it/boellerverbot#info  

145 

 
 
 
Jornal de Notícias. (2024). PSP apreende milhares de artigos pirotécnicos e 75 
quilos de pólvora. [In Portuguese] https://www.jn.pt/8268762194/psp-apreende-
milhares-de-artigos-pirotecnicos-e-75-quilos-de-polvora/  

Jornal de Notícias. (2025). Três detidos, dois feridos e 438 artigos de pirotecnia 
apreendidos no Jamor. [In Portuguese] https://www.jn.pt/4539342400/tres-
detidos-dois-feridos-e-438-artigos-de-pirotecnia-apreendidos-no-jamor/  

Lebensmittelpraxis. (n.d.). Hohe Zustimmung in Bevölkerung: Pyrotechnik-
Branche schaffte 2024 einen Rekordumsatz. [In German] 
https://lebensmittelpraxis.de/industrie-aktuell/44668-hohe-zustimmung-in-
bevoelkerung-pyrotechnik-branche-schaffte-2024-einen-
rekordumsatz.html#:~:text=Polarisierendes%20Brauchtum%20Pyrotechnik%2D
Branche%20schaffte%202024%20einen%20Rekordumsatz&text=Eine%20neu
e%20Studie%20zeigt:%2070,ein%20Verbot%20von%20privatem%20Feuerwer
k.&text=Der%20Verband%20der%20pyrotechnischen%20Industrie,Deutschen
%20steht%20Feuerwerk%20positiv%20gegen%C3%BCber  

Le Figaro. (2025) « Les choses sont en train de bouger »: comment la lutte 
contre les mortiers d’artifice dangereux s’intensifie. [in French] 
https://www.lefigaro.fr/conso/les-choses-sont-en-train-de-bouger-comment-la-
lutte-contre-les-mortiers-d-artifice-dangereux-s-intensifie-20250714 

Le Monde. (2023) Mort de Nahel M.: comment les mortiers d’artifice, dirigés 
vers les forces de l’ordre, sont devenus l’arme de base des émeutes. [in 
French] https://www.lemonde.fr/societe/article/2023/07/01/mort-de-nahel-m-
comment-les-mortiers-d-artifice-diriges-vers-les-forces-de-l-ordre-sont-devenus-
l-arme-de-base-des-emeutes_6180102_3224.html  

Le Monde. (2025) In photos: Paris's Bastille Day fireworks and pyrotecnics 
show. https://www.lemonde.fr/en/culture/article/2025/07/15/in-photos-paris-s-
bastille-day-fireworks-and-pyrotecnics-show_6743379_30.html  

Levante. (2024) Incautan hasta 390 artículos de pirotecnia ilegales a tres 
holandeses. [in Spanish] https://www.levante-
emv.com/fallas/2024/03/17/incautan-390-articulos-pirotecnia-ilegales-
99593418.html  

Levante. (2025) Las fallas movilizan a 6.500 policías con el foco puesto en 
combatir la pirotecnia ilegal. [in Spanish] https://www.levante-
emv.com/fallas/2025/02/19/fallas-movilizan-7-000-policias-114473900.html  

L'Indipendente. (2025). Gli effetti nocivi dei fuochi di Capodanno su ambiente, 
uomini e animali. [In Italian] https://www.lindipendente.online/2025/01/06/gli-
effetti-nocivi-dei-fuochi-di-capodanno-su-ambiente-uomini-e-animali/  

146 

 
 
 
LecceNews24. (2024). Maxi sequestro di giocattoli e fuochi d’artificio “illegali”. 
[In Italian] https://www.leccenews24.it/cronaca/sequestro-giocattoli-fuochi-
artificio-illegali.htm  

Linkiesta. (2016). Il 50 per cento dei botti di Capodanno non è a norma, in Italia 
esplode il mercato illegale. [In Italian] https://www.linkiesta.it/2016/12/il-50-per-
cento-dei-botti-di-capodanno-non-e-a-norma-in-italia-esplode/  

https://maisribatejo.pt/2025/03/06/operacao-carnaval-em-seguranca-2025-psp-
detem-919-pessoas-e-apreende-mais-de-20-mil-artigos-de-pirotecnia/Mais 
Ribatejo. (2025). Operação Carnaval em Segurança 2025: PSP detém 919 
pessoas e apreende mais de 20 mil artigos de pirotecnia. [In Portuguese] 
https://maisribatejo.pt/2025/03/06/operacao-carnaval-em-seguranca-2025-psp-
detem-919-pessoas-e-apreende-mais-de-20-mil-artigos-de-pirotecnia/  

MDR. (n.d.). Pyrotechnik: Illegale Kugelbomben und Kilo-Ware beschlagnahmt. 
[In German] https://www.mdr.de/nachrichten/sachsen/dresden/freital-
pirna/pyrotechnik-feuerwerk-kugelbomben-verboten-beschlagnahmt-102.html  

Neve, R. (2021). Dutch Environmental Crime Threat Assessment 2021. 
https://www.om.nl/documenten/publicaties/milieucriminaliteit/2021/07/environme
ntal-crime-threat-assessment-netherlands-2021  

NL Times (2023). Some 1,700 kilograms of illegal fireworks seized at Noord-
Brabant sales point. https://nltimes.nl/2023/12/11/1700-kilograms-illegal-
fireworks-seized-noord-brabant-sales-point 

NL Times (2023). Some 18,000 kilograms of illegal, wrongly labeled fireworks 
seized from Dutch importer. https://nltimes.nl/2023/12/14/18000-kilograms-
illegal-wrongly-labeled-fireworks-seized-dutch-importer 

NL Times (2025), Seven explosions in Rotterdam region in two nights. 
https://nltimes.nl/2025/07/09/seven-explosions-rotterdam-region-two-nights 

NL Times (2025). Fireworks ban needed to stop explosives attacks; disaster 
waiting to happen, police say. https://nltimes.nl/2025/02/25/fireworks-ban-
needed-stop-explosive-attacks-disaster-waiting-happen-police-say  

Normattiva. (2015). Decreto Legislativo 29 luglio 2015, n. 123. [In Italian] 
https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2015-07-
29;123  

Notes from Poland. (2021). Polish opposition seeks ban on fireworks to protect 
animals. https://notesfrompoland.com/2021/07/23/polish-opposition-seeks-ban-
on-fireworks-to-protect-animals/ 

Onet Wiadomości. (2025). Polacy powitali Nowy Rok. Ponad tysiąc interwencji 
służb ratunkowych. [In Polish] https://wiadomosci.onet.pl/kraj/polacy-powitali-
nowy-rok-ponad-tysiac-interwencji-sluzb-ratunkowych/txjdjky 

147 

 
 
 
Op ‘t Hoog, G., & Saarijärvi J. (2023). International exchange of information in 
the context of firearms control. REGISYNC Project 
https://www.ecorys.com/app/uploads/2019/02/REGISYNC-INTL-EXCHANGE-
INFORMATION.pdf  

PalermoToday. (2023). Mafia, audizioni commissione Antimafia Ars: "Fuochi 
d'artificio nei quartieri per festeggiare scarcerazioni". [In Italian] 
https://www.palermotoday.it/cronaca/mafia/audizioni-commissione-antimafia-
ars-fuochi-artificio-quartieri.html  

Pirovagando. (n.d.). Cenni Storici. [In Italian] 
https://www.pirovagando.it/menu/cenni-storici.html  

Poland Insight. (n.d.). Firework-Free Zones: Industry Proposes a Compromise. 
https://polandinsight.com/firework-free-zones-industry-proposes-a-compromise-
26954/ 

Policja.pl. (2017). Nielegalnie wytwarzał materiały pirotechniczne. [In Polish] 
https://policja.pl/pol/aktualnosci/139112,Nielegalnie-wytwarzal-materialy-
pirotechniczne.html  

Politico (2025), Sweden eyes EU fireworks ban to blow up the mob. 
https://www.politico.eu/article/sweden-fireworks-gang-violence-organized-crime/ 

Politico (2025). Belgian mayors call for Europe-wide ban on sale of fireworks. 
https://www.politico.eu/article/belgium-mayor-call-for-europe-wide-ban-sale-
fireworks/ 

Politico. (2023) France bans fireworks on concerns about Bastille Day violence. 
https://www.politico.eu/article/french-government-banned-fireworks-until-july-15-
bastille-celebrations-parade/ 

Polizia di Stato. (2025). I dati relativi al Capodanno 2025. [In Italian] 
https://www.poliziadistato.it/articolo/i-dati-relativi-al-capodanno-2025  

Polizia di Stato. (n.d.). Guida: Fuochi d'artificio, un po' di chiarezza. [In Italian] 
https://www.poliziadistato.it/articolo/pdf/642  

Portfolio, Organised Crime. (2015) From Illegal Markets to Legitimate 
Businesses: The Portfolio of Organized Crime in Europe. Final Report of Project 
OCP, Transcrime https://www.researchgate.net/profile/Jesus-
Palomo/publication/339237083_Where_do_Organised_Crime_proceeds_come
_from_illicit_markets_in_Spain/links/5e454db192851c7f7f349e0a/Where-do-
Organised-Crime-proceeds-come-from-illicit-markets-in-Spain.pdf  

Portugal Resident. (2020). Portugal’s fireworks manufacturers face ‘millions of 
euros in losses’. https://www.portugalresident.com/portugals-fireworks-
manufacturers-face-millions-of-euros-in-losses/  

148 

 
 
 
Portugal Resident. (2021). Fireworks sector in meltdown as Covid used to 
scupper New Year displays. https://www.portugalresident.com/fireworks-sector-
in-meltdown-as-covid-used-to-scupper-new-year-displays/  

Prasula, M. et al (2023) Bezpieczeństwo materiałów pirotechnicznych w Polsce. 
[In Polish] https://yadda.icm.edu.pl/baztech/element/bwmeta1.element.baztech-
086b0bad-f3e0-40be-be9c-953711950861/c/Prasula_165.pdf  

Prasula, P., Mazur, I., & Czerwinska, M. (2023). Safety risks posed by 
pyrotechnic materials. Problemy techniki uzbrojenia, 165 (3), 41-66. 
https://www.researchgate.net/publication/374488485_SAFETY_RISKS_POSED
_BY_PYROTECHNIC_MATERIALS  

Público. (2017). Empresas de pirotecnia garantem estar a cumprir a lei. [In 
Portuguese] https://www.publico.pt/2017/04/05/sociedade/noticia/empresas-de-
pirotecnia-garantem-estar-a-cumprir-a-lei-1767813  

Público. (2018). Ainda se facilita na complicada arte da pirotecnia. Por isso ela 
ainda mata. [In Portuguese] 
https://www.publico.pt/2018/08/06/sociedade/noticia/ainda-se-facilita-na-
complicada-arte-da-pirotecnia-por-isso-ela-ainda-mata-1839989  

Público. (2025). PSP apreendeu 111 mil artigos pirotécnicos e 18 mil quilos de 
produtos explosivos. [In Portuguese] 
https://www.publico.pt/2025/02/17/sociedade/noticia/psp-apreendeu-111-mil-
artigos-pirotecnicos-18-mil-quilos-produtos-explosivos-2122471  

Questure.Poliziadistato.it. (n.d.). Capodanno Sicuro: La Polizia di Stato di 
Salerno in campo per la legalità. [In Italian] 
https://questure.poliziadistato.it/it/Salerno/articolo/32836756db250d34a1861427
61  

Questure.Poliziadistato.it. (n.d.). I botti di Capodanno: la Polizia di Stato in 
campo per la legalità. [In Italian] 
https://questure.poliziadistato.it/it/Verona/articolo/5730e70a552cb300349048  

Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. [In Italian] 
https://www.rai.it/dl/doc/1739980511321_LARTIFICIO%20DEI%20FUOCHI%20
di%20Chiara%20De%20Luca.pdf  

RaiNews. (2022). Botti di Capodanno illegali, decine di sequestri e denunce in 
tutta Italia. [In Italian] https://www.rainews.it/articoli/2022/12/botti-di-capodanno-
illegali-decine-di-sequestri-e-denunce-in-tutta-italia--624a96db-69d4-481d-
a640-027a86035e01.html  

Reuters. (2025). Poland detains 19-year-old man suspected planning terrorist 
attack - interior ministry. https://www.reuters.com/world/poland-detains-19-year-
old-man-suspected-planning-terrorist-attack-interior-2025-06-12/  

149 

 
 
 
Rijnmond (2025). 14 year old boy died because of fireworks. [In Dutch] 
https://www.rijnmond.nl/nieuws/1945668/jongen-14-overleden-door-vuurwerk  

RTL 102.5. (2024). Capodanno 2025, è già trionfo di botti illegali. [In Italian] 
https://www.rtl.it/notizie/articoli/capodanno-2025-e-gia-trionfo-di-botti-illegali/  

RTP Notícias. (2024). Liga de clubes reforça combate à pirotecnia com novo 
regulamento. [In Portuguese] https://www.rtp.pt/noticias/futebol-nacional/liga-
de-clubes-reforca-combate-a-pirotecnia-com-novo-regulamento_d1566584  

Rzeczpospolita. (2025). Zakaz fajerwerków to straty dla gospodarki i zagrożenie 
bezpieczeństwa. [In Polish] https://www.rp.pl/gospodarka/art42225541-zakaz-
fajerwerkow-to-straty-dla-gospodarki-i-zagrozenie-bezpieczenstwa  

Saarijärvi, J., Hellemons, S., op t Hoog, G., Steensma, J., Beke, M., Jeney, P., 
Guelai, H., Colman, C., Janssens, J., Stamouli, E., Gasparinatou, M., Jimenez 
Sanchez, F., Miralles de Imperial, J., Genna, F., & Tokatzian, V. (2024). Study 
on corruption vulnerabilities in the EU seaports’ supply chain, project 
POSEIDON. https://poseidon.safe-europe.eu/wp-
content/uploads/2024/10/POSEIDON_Study-on-corruption-vulnerabilities-in-the-
EU-seaports-supply-chain.pdf 

Savona, E., & Riccardi, M. (2015). From illegal markets to legitimate 
businesses: the portfolio of organised crime in Europe. Final report of project 
OCP. https://www.transcrime.it/wp-content/uploads/2015/04/executive.pdf  

Savona, E., Berlusconi, G., di Bono, L., & Garofalo, L. (2015). Organized crime 
infiltration of legitimate businesses in Europe: a pilot project in five European 
countries. 
https://www.researchgate.net/publication/305710696_Organized_Crime_Infiltrat
ion_of_Legitimate_Businesses_in_Europe_A_Pilot_Project_in_Five_European_
Countries  

Scottish Government. (2020). Impact of fireworks regulations: case studies. 
https://www.gov.scot/binaries/content/documents/govscot/publications/research
-and-analysis/2020/11/impact-fireworks-regulations-case-
studies/documents/impact-fireworks-regulations-case-studies/impact-fireworks-
regulations-case-studies/govscot%3Adocument/impact-fireworks-regulations-
case-studies.pdf  

Security of Sales (n.d.). Advice on marketplace sales of explosives precursors 
and poisons. https://home-affairs.ec.europa.eu/document/download/04f82a01-
c181-4c88-bc47-
9a5ed1f389a3_en?filename=advice_internet_marketplace_retail_of_chemicals
_en.pdf  

Sejm Rzeczypospolitej Polskiej. (2022). Ustawa z dnia 15 grudnia 2022 r. o 
zmianie ustawy o wykonywaniu działalności gospodarczej w zakresie 

150 

 
 
 
wytwarzania i obrotu materiałami wybuchowymi, bronią, amunicją oraz 
wyrobami i technologią o przeznaczeniu wojskowym lub policyjnym oraz 
niektórych innych ustaw. [In Polish] 
https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20220002378  

Sky TG24. (2024). Botti di Capodanno, tra i più pericolosi le 'bombe Sinner'. [In 
Italian] https://tg24.sky.it/cronaca/2024/11/23/botti-capodanno-pericolosi-
bomba-sinner  

Sky TG24. (2024). Capodanno, botti e petardi: le misure di sicurezza. [In Italian] 
https://tg24.sky.it/cronaca/2024/12/31/capodanno-botti-petardi-misure-sicurezza  

Sky TG24. (2024). Petardi e botti di Capodanno, cosa si rischia tra regole e 
divieti. FOTO. [In Italian] https://tg24.sky.it/cronaca/2024/12/29/petardi-botti-
capodanno-regole-divieto?card=8  

Storia e Memoria di Bologna. (n.d.). La Società pirotecnica italiana e le feste 
popolari. [In Italian] https://www.storiaememoriadibologna.it/archivio/eventi/la-
societa-pirotecnica-italiana-e-le-feste-popolari  

Süddeutsche Zeitung. (2025). Gefährliche Substanzen: Illegale Böller daheim 
bei Jugendlichen beschlagnahmt. [In German] 
https://www.sueddeutsche.de/wirtschaft/gefaehrliche-substanzen-illegale-
boeller-daheim-bei-jugendlichen-beschlagnahmt-dpa.urn-newsml-dpa-com-
20090101-250124-930-354164  

The Brussels Times. (2023) A tense Bastille Day as France deploys 130,000 
police officers and bans fireworks. https://www.brusselstimes.com/600534/a-
tense-bastille-day-as-france-deploys-130000-police-officers-and-bans-fireworks 

The Economic Times. (2023) France: Protesters set police station ablaze in 
Rouen. https://economictimes.indiatimes.com/news/international/world-
news/france-protesters-set-police-station-ablaze-in-
rouen/videoshow/101471804.cms?from=mdr  

The Guardian. (2025). A risk to life and limb: residents of Germany and 
Netherlands rue dangers of fireworks. 
https://www.theguardian.com/world/2025/jan/10/a-risk-to-life-and-limb-
residents-of-germany-and-netherlands-rue-dangers-of-fireworks  

The Portugal News. (2022). New law to criminalise pyrotechnics in stadiums. 
https://www.theportugalnews.com/news/2022-10-24/new-law-to-criminalise-
pyrotechnics-in-stadiums/71448  

Today.it. (2025). Bombe artigianali comprate online e spedite con il corriere: 
"Arsenale" in casa, 33enne arrestato. [In Italian] 
https://www.today.it/cronaca/bombe-artigianali-comprate-online-spedizioni-
corriere.html  

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Truenumbers.it. (2023). Fuochi d’artificio, il giro d’affari è crollato dell’80%. [In 
Italian] https://www.truenumbers.it/fuochi-dartificio-il-giro-daffari-e-crollato-
dell80/  

Veenstra, A., & Heijmann, F. (2023). The Future Role of Customs. World 
Customs Journal, 17(2), 13-30. https://doi.org/10.55596/001c.88415  

Veiligheid NL (2024). Increase in serious injuries by illegal fireworks. [In Dutch] 
https://www.veiligheid.nl/sites/default/files/2024-
01/VeiligheidNL%20%27Infographic%20vuurwerkletsels%202023-2024%27.pdf 

VeronaSera. (2024). Botti di Capodanno illegali, sequestri, denunce e un 
arresto: i consigli della Questura. [In Italian] 
https://www.veronasera.it/cronaca/botti-capodanno-illegali-sequestri-denuncia-
arresto-consigli-30-dicembre-2024.html  

VianaTV. (2024). Agente da PSP sofreu queimaduras de primeiro grau em 
desmantelamento de pirotecnia ilegal. [In Portuguese] https://vianatv.pt/agente-
da-psp-sofreu-queimaduras-de-primeiro-grau-em-desmantelamento-de-
pirotecniilegal/  

Vice. (2025). The Deadly Mafia Party Bombs of Naples. 
https://www.vice.com/en/article/the-deadly-mafia-party-bombs-of-naples/  

VPI. (n.d.). Aktiv gegen illegales Feuerwerk. [In German] 
https://www.feuerwerk-vpi.de/innovation-sicherheit-und-forschung-1/aktiv-
gegen-illegales-feuerwerk 

Wanted in Rome. (n.d.). Naples suffers toxic air after New Year's fireworks. 
https://www.wantedinrome.com/news/naples-suffers-toxic-air-after-new-years-
fireworks.html  

Washington Post. (2022). Why many rules-loving Germans love rogue New 
Year’s fireworks. https://www.washingtonpost.com/world/2022/12/30/fireworks-
new-years-germany/  

WEI. (2022). Branża pirotechniczna. [In Polish] http://wei.org.pl/wp-
content/uploads/2022/12/Branza-pirotechniczna.pdf  

World Bank WITS. (2023). Comtrade Database: Fireworks (HS 360410) Poland, 
2023. 
https://wits.worldbank.org/trade/comtrade/en/country/ALL/year/2023/tradeflow/I
mports/partner/WLD/product/360410  

World Bank WITS. (2023). Comtrade Database: Fireworks (HS 360410) 
Germany, 2023. 
https://wits.worldbank.org/trade/comtrade/en/country/DEU/year/2023/tradeflow/
Exports/partner/WLD/product/360410  

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WP Wiadomości. (2019). Polowanie na "polskie petardy" za Odrą. Kontrole aut. 
[In Polish] https://wiadomosci.wp.pl/polowanie-na-polskie-petardy-za-odra-
kontrole-aut-6333062332790401a  

Zeit Online. (2025). Zoll Hannover deckt mehr organisierte Kriminalität auf. [In 
German] https://www.zeit.de/news/2025-06/10/zoll-hannover-deckt-mehr-
organisierte-kriminalitaet-auf  

Zoll. (2024). Zoll stoppt tonnenweise illegale Pyrotechnik. [In German] 
https://www.zoll.de/SharedDocs/Pressemitteilungen/DE/Sonstiges/2024/y32_to
nnenweise_pyrotechnik_h.html  

Zoll. (2025). Illegaler Pyrotechnikhandel aufgedeckt. [In German] 
https://www.zoll.de/SharedDocs/Pressemitteilungen/DE/Sonstiges/2025/z92_py
rotechnik_zfa_ffm.html  

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Annex II Case study A – From factory to the black 
market: illegal manufacturing and diversion of 
pyrotechnics in the EU 

Introduction  

When discussing criminal misuse of pyrotechnics, it is essential to distinguish 
between the criminal misuse of legally manufactured and sold pyrotechnic 
articles, and the misuse of pyrotechnics coming from a parallel illegal market. 526 
This illegal market includes both illegally manufactured pyrotechnics and legally 
produced pyrotechnics that are diverted and smuggled for criminal purposes.527  

In light of these considerations, the study team has gathered data from desk 
research, surveys, follow-up questionnaires and (scoping and targeted) 
interviews, obtaining an overview of the security problem stemming from the 
existence of a parallel illegal market.  

Case study A is structured in two parts: the first one, focusing on illegal 
manufacturing of pyrotechnics, and the second one, diving into the topic of 
diversion of legally produced pyrotechnics.  

To guide this case study, the team has relied on the typology outlined chapter 2. 
The case study further offers more detailed country-level insights for key 
pyrotechnics producing countries, i.e. Poland, Germany, Portugal, France, Italy 
and Spain (Annex III). For the latter three, deep-dives are included following the 
general assessment outlined in these pages, which, to the extent possible, 
covers all EU27 Member States.  

Illegal manufacturing 

Figure 20 Overview of cycle 

526   Ibid. 
527   For additional information, see chapter 2 (typology).  

154 

 
 
 
 
 
Source: Consortium’s elaboration. 

The  first  part  of  case  study  A  focuses  on  the  segment  of  the  illegal  market  of 
pyrotechnic articles characterised by illegally manufactured pyrotechnic articles. 
As  illustrated  in  the  typology  of  this  study,  the  notion  of  illegally  manufactured 
pyrotechnic articles includes all those cases where pyrotechnics are intentionally 
produced or assembled from the start of the supply chain in a way that does not 
comply with the Pyrotechnics Directive 2013/29/EU.  

Overall, findings show that the issue of illegal manufacture of pyrotechnics, while 
remaining an important concern,528 is less widespread across EU Member States 
compared to the diversion of legal pyrotechnic articles.  

Surveyed national authorities assessed the significance of the manufacturing 
of illegal pyrotechnics in their country, with fourteen authorities assessing it as 
‘minimal’ (0 on a scale of 5), seventeen as ‘low’ (1 on a scale of 5), eight as 
‘somewhat significant’ (2 on a scale of 5), five as ‘moderate’ (3 on a scale of 5), 
and none as ‘high’ or critical’. In terms of recent trends, the majority of national 
Member States’ authorities (51% of the respondents) indicated that illegal 
manufacturing has witnessed an increase ‘to no extent’529 or ‘to little extent’ in 
the last five years.530 In this regard, only two Member State authorities indicated 
that between 2019 and 2024 they have witnessed an increase in the 
manufacturing of illegal pyrotechnics ‘to a large extent’;531 none indicated that 
such an increase was noted ‘to a very large extent’. Stakeholders’ input coming 
from industry representatives also largely indicated as ‘non-significant (less than 
10% of the licit pyrotechnics production)’ the scale of the illegally produced 
pyrotechnics market within the EU.532  

No Member State authority was able to provide quantitative details on the 
extent of occurrences of illegal manufacturing in their country.533 
Authorities from Sweden, France and Croatia provided a few anecdotal pieces 
of evidence of cases of illegal manufacturing534; Croatian authorities highlighted 
how some hand-manufactured articles were found during sport events in 
football stadia, but that no mass illegal production and distribution was ever 
identified;535 and Swedish Customs indicated that, while some instances of 
“pyro-kits”, i.e. parcels of chemicals and empty cylindrical containers that point 
to hand-made production of pyrotechnic articles, were intercepted, it is 

528   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. 
Oxford Research, Study on the illegal sales of F4 pyrotechnics articles destined for professional users 
to the general public, 2019. 

529   14 out of 47 Member States’ national authorities.  
530   10 out of 47 Member States’ national authorities.  
531   National authorities of two Member States  
532   12 out of 25 industry organisations/ industry representative associations. 
533   Authorities either declined. 
534   Follow up questionnaire addressed to national competent authorities: responses from three Member 

States. 

535   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

155 

 
 
 
 
impossible to assess the size of the issue536. Swedish stakeholders were also 
adamant in stating that, at the national level, the key issue is not the illegal 
manufacturing or pyrotechnics, but rather the ease of accessibility of articles 
considered illegal in the country through online purchases from shops based in 
other countries.537 

Italy represents an important outlier in the landscape described above, with 
consulted Member State authorities indicating the illegal production of 
pyrotechnic articles to be a thriving market,538 accounting for an estimated 25-
50% of the overall market for pyrotechnics.539 According to a consulted law 
enforcement representative, illegal production is carried out domestically, in a 
“family-run” fashion, with activities primarily located in central and southern 
Italy.540 Illegally manufactured articles are intended both for the domestic as 
well as for the foreign market, where in the latter case production focuses on 
manufacturing devices that often replicate the characteristics of legal articles.541 
Additional details can be found in the Italy deep-dive (Annex III). Although on a 
smaller scale, instances of illegal manufacturers are also present in Portugal. 
While around 32 companies are registered and legally operate in the field of 
pyrotechnics,542 an estimated 300 "economic operators" are involved in the 
pyrotechnics sector, with some engaging in sales "without an invoice," 
indicating a parallel, less regulated market. Further details are provided in the 
Portugal in-depth overview (Annex III). Interviewed Law Enforcement 
stakeholders from Cyprus also reported having observed and documented 
some illicit production of pyrotechnic articles, noting, however, that it is less 
widespread than trade diversion.543 Homemade firecrackers are the most 
common type of article manufactured illegally, through the use of extracted 
black powder from legal fireworks, fertilizer-based mixtures, metal or plastic 
tubes as casings.544 

In terms of raw materials used in the illegal manufacturing process, 
Member State authorities have reported the following: potassium nitrate, 
magnalium/aluminium powder;545 potassium perchlorate and aluminium powder 
(usually starting materials for flashbang production), as well as mixtures of 
magnalium powder, potassium perchlorate and sulphur, as increasingly 

536   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

537   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

538   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

539   NCA Survey: response from one Member State.; Linkiesta. (2016). Il 50 per cento dei botti di 
Capodanno non è a norma, in Italia esplode il mercato illegale. Link (Accessed: 7 July 2025). 

540   Ibid. 
541   Ibid. 
542   Ibid. 
543   Interview with one Member State’s authority. 
544   Ibid.  
545   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

156 

 
 
 
 
detected in flashbang sets;546 potassium nitrate, sulphur powder and charcoal 
powder (used for black powder production);547 ammonium nitrate and hydrogen 
peroxide548. 549 

In conclusion, the findings seem to suggest that the issue of illegal production 
remains of little significance for national authorities compared to diversion, save 
for specific cases such as Italy and, to a lesser extent, Portugal and Cyprus. At 
the same time, the data should be interpreted with caution, as the issue of 
illegal manufacturing seems to be linked with, and to have an impact on, 
enforcement challenges by national, including customs, authorities, as illegally 
manufactured articles seem to be harder to detect.550 One stakeholder also 
expressed difficulties in clearly proving whether explosive devices used as the 
means of committing an offense were manufactured in-house or elaborated 
starting from commercial pyrotechnics.551  

Some anecdotal feedback received through interviews still suggests that this 
issue is worth keeping an eye on: one national authority mentioned how, in their 
country, the legal production of fireworks seemed to have stopped (due to 
circumstances which were not made explicit by the source), while small 
factories illegally producing pyrotechnics seem to have emerged.552 While still 
focusing mostly on the impact of the diversion of originally legal pyrotechnics, 
the same stakeholder also indicated another source of illegally manufactured 
pyrotechnics in the Cobra articles produced in Italy under the DiBlasio brand.553 
While such a brand has been closed, counterfeit articles sold as Cobra-like 
articles appear to still be circulating in the illegal market, as confirmed by an EU 
agency.554 Another Member State authority indicated how, among the products 
traded, they noted an increase in P2 and T2 fireworks (in particular distress 
signals and smoke flares) and in the number of articles containing more than 
100 grams of flash powder; however, it did not specify which type of articles are 
usually found containing such quantities.555 

Trade of illegally manufactured pyrotechnics 

Further to these results, it appears important to distinguish between illegal 
manufacturing within the EU and illegal manufacturing outside of the EU 
territory, as stressed by one industry representative.556 The issue of ‘trade of 

546   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

547   Ibid. 
548   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

549   See study area 3.  
550   Interview with with one EU institution. 
551   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

552   Interview with one Member State’s authority. 
553   Ibid. 
554   Interview with one EU agency . See deep-dive on IT. 
555   Interview with one Member State’s authority. 
556   Interview with one industry organisation/ industry representative association. 

157 

 
 
 
 
illegal or diverted pyrotechnics’ has been indicated as a bigger concern than 
‘illicit manufacturing’ by national authorities. Namely, twenty-five Member States 
authorities rated ‘trade of illegal or diverted pyrotechnics’ as from ‘somewhat 
significant’ to ‘critical’. Yet, another Member State authority reported an 
increase in problems with parcels, indicating how, in the Netherlands, a police 
investigation found a lot of articles lacking any indication of the producer. 
According to this authority, this could suggest a problem with illegal production 
within the EU.557 

From the industry side, two representatives agreed that even if illegal 
manufacturing of pyrotechnics in their country is not considered problematic, it 
is the trade of illegal pyrotechnics in general that constitutes a more prominent 
and problematic issue.558 What also emerged from one industry representative 
is how imports from non-EU countries to EU countries play a significant role in 
feeding the black market.559 The same stakeholder indicated, in fact, that a 
significant amount of products is illegally produced in Albania, and sent daily by 
ship to Italy. According to this source, many illegally produced pyrotechnics 
enter the illegal market in the EU from this route, and originate from the same 
factory, deemed to be the biggest factory for pyrotechnic articles in Europe. In 
this case, the counterfeit articles would enter the market marked as CE-marked 
products, without actually being in compliance with EU rules and standards. 
Challenges related to the import of pyrotechnics produced abroad, primarily in 
China, and non-compliance with certification requirements appear to be an 
issue for Poland and Germany as well, as instances were reported of these 
items entering the Polish market and then being dispatched through online 
purchases to German territory.560 Recent instances of illegal pyrotechnic articles 
seized without CE markings, purchased from other EU Member States, were 
also reported by Latvian authorities561.  

As far as the tracking and tracing562 of such articles is concerned, a national 
authority pointed out the limits of the traceability system, making it easier to 
introduce counterfeit articles in the market.563 This appears to be confirmed by 
other Member States' authorities, highlighting how the checks on the 
manufacturer name and serial numbers on pyrotechnic products are not always 
effective in tracing back their origin. In particular, twenty-three Member States' 
authorities considered that manufacturer name and serial number on products 
are ‘somewhat useful for tracing their origin, but gaps exist in tracking supply 

557   Interview with one Member State’s authority. 
558   Interviews with two industry organisations/ industry representative associations. 
559   Interview with one industry organisation/ industry representative association.  
560   Wirtualna Polska (WP) Wiadomości, 2018. Polowanie na "polskie petardy" za Odrą. Kontrole aut. 30 

December. Link (Accessed: 23 July 2025). 

561   Follow up questionnaire addressed to national competent authorities: response from one Member 

State.  

562   For additional information, see study area 5.  
563   Interview with one Member State’s authority. 

158 

 
 
 
 
chains’,564 while three Member States' authorities considered them ‘not useful, 
as they are often missing or tampered with’.565  

Finally, one industry representative highlighted that, in the current system, the 
production of pyrotechnics for criminal purposes would result less 
convenient for criminals than their simple direct purchase from the illegal 
market.566 The existence of easily accessible F4 fireworks coming from illegal 
trade, for example, would discourage autonomous production of pyrotechnics, 
which would have an excessive level of hazard for criminals.567 Interestingly, a 
civil society organisation also suggested that the focus on illegal manufacturing 
of pyrotechnics might derive from its being a relatively easier factor to focus on. 
However, understanding the exact point in which diversion happens appears to 
be equally important, and by concentrating solely on production, authorities may 
risk overlooking the critical aspect of how pyrotechnic articles transition from 
legal to illegal use.568  

Diversion 

This second part of case study A focuses on the diversion of pyrotechnics from 
their legal supply chain, i.e. when legally manufactured and/or imported 
pyrotechnic articles are being redirected or misappropriated from their intended 
use. As illustrated in the typology of this study, diversion encompasses two key 
components:  

●  Diversion from distribution, when pyrotechnics are in transit between 

the producer and the wholesaler, retailer or warehouses.  

●  Trade diversion, when criminals buy legal pyrotechnics, for example, 

using fake identification, or when retailers sell to unauthorised individuals 
or groups (for their economic gain).  

While estimating the concrete size of the issue remains challenging, also due to 
the different approaches across Member States to track incidents involving 
pyrotechnics misuse,569 recent reports point to the existence of a market for 
illegal trade in pyrotechnic articles originating from legitimate businesses. For 
illustrative purposes, in 2022, police forces across the EU seized 350 tonnes of 
professional fireworks, for an estimated value of estimated value of EUR 25 
million.570 More recently, in a report published in 2024 on the state of play on the 
misuse of pyrotechnics in the EU, Europol provides the staggering figure of 680 
tonnes of seized fireworks in just a few selected transnational investigation 

564   Input from eleven Member States’  (national authorities). 
565   Input from three Member States’  (national authorities). 
566   Interview with one industry organisation/ industry representative association. . 
567   Ibid. 
568   Interview with a civil society organisation.  
569   Stakeholder consultations and in responses from the follow up questionnaire. 
570   Council of the EU (2023) Draft Report of action 11.9 Explosives – fireworks, pyrotechnics and their 

precursors. Link  

159 

 
 
 
 
cases between 2018 and 2022, leading to speculate that the general figure 
might be much bigger.571  

The increasingly frequent use of pyrotechnics diverted from the legal supply 
chain was also reflected in Europol’s latest SOCTA report.572 The report 
highlights how heavy pyrotechnics sourced illegally have become an item of 
choice for criminal networks to use as components in explosive devices, or as 
explosives themselves, in particular in contexts of drug trafficking retaliation, as 
well as thefts, robberies and Trafficking in Human Beings (THB).  

Indeed, in terms of pyrotechnics moving across the supply chain, as outlined in 
previous sections of this report, the Pyrotechnics Directive 2013/29/EU clarifies 
that pyrotechnic articles falling under categories F4, T2 and P2 may be made 
available only to persons with specialist knowledge.573 However, there is no 
harmonised standard at the EU level for defining licenses that attest to the 
possession of this knowledge. Additionally, while the Directive provides 
minimum rules at the EU level on the age requirements for purchasing specific 
articles, Member States are at liberty to impose stricter limits.574 Thanks to 
cross-border purchases, including through online platforms (further elaborated 
below), individuals who, within their Member State, should not be able to have 
access to a specific category of pyrotechnics may do so legally by purchasing 
the article from an online shop based in a Member State with lower age 
restrictions. These all represent potential vulnerabilities within the supply chain, 
which could be exploited by criminals. Conversely, the lack of harmonised 
requirements and standards for purchase and detention of pyrotechnics across 
Member States can make it challenging for law enforcement to obtain a swift 
and comprehensive picture of the threat when dealing, in particular, with cross-
border cases. One stakeholder consulted within the framework of this study 
further supported this hypothesis, indicating that the issue is not represented by 
“illegal pyrotechnic articles” but rather by the fact that through trade (both online 
and physically, through air, land or maritime transport for example) pyrotechnic 
articles end up in the hands of non-specialised individuals, who are not allowed 
to use them.575 

Most stakeholders consulted agree that the priority should be placed on either 
banning or better monitoring through specific tracking systems the category F4 
pyrotechnic articles, in particular to ensure that purchases are not performed by 
non-specialists,576 as the increasing availability of these articles to non-
specialists is raising concerns577. Beyond F4, F3 category articles also emerged 

571   Source shared by the European Commission. 
572   Europol (2025). Serious and Organised Crime Threat Assessment 2025.  
573   Directive 2013/29/EU. 
574   Council of the EU (2023) Draft Report of action 11.9 Explosives – fireworks, pyrotechnics and their 

precursors. Link 

575   Interview with one Member State’s authority..  
576   Survey addressed to NCAs: respondents from three Member States provided specific comments on 
this. Overall 27% of survey respondents indicated that F4 articles are most commonly involved in 
criminal misuses. Extracts from desk research relating to BE, DE, IT further corroborate this.  

577   Europol (2024). Pyrotechnics in the EU State of Play; Interviews with one Member State’s authorities. 

160 

 
 
 
 
as a concern for some Member States and SACs. For example, Norwegian law 
enforcement indicated that F3 represent their primary concern as they are 
legally sold and readily available to the public, but frequently misused for 
creating HMEs by placing the entire pyrotechnic mixture into another 
container.578 German and Swedish representatives also indicated F3 category 
articles as representing an increasing issue, with articles illegally imported in the 
country from Poland or Czechia, where legal purchases are possible thanks to 
lower licencing requirements.579 It should be noted that legislative discussions 
are currently ongoing both in Germany as well as in Poland on the possibility of 
enforcing nation-wide bans for the use of fireworks (Germany) and F2 / F3 
products (Poland) (see Annex III, country deep dives for additional details).  

Diversion from distribution 

The data collected and triangulated for the purposes of this study confirms that 
diversion is an issue meriting increasing attention. Amongst surveyed national 
authorities, while the majority of respondents (59%) indicates that the diversion 
of pyrotechnics both along the supply chain as well as after a commercial 
transaction is a minimal issue in their country (ranked 0 or 1 on a scale of 1 to 
5), the trade of illegal or diverted pyrotechnics is considered an issue of 
relevance (ranked between 3 and 5 on a scale of 1 to 5) by 39% of 
respondents; and 23% indicate that they have seen to some extent an 
increasing trend in diversion between 2019-2024. Forty percent of industry 
representatives responding to the survey also indicate that diversion is a 
significant or very significant issue in their country. Responses collected through 
interviews and follow-up questionnaires to national authorities indicate that 
diversion of legally produced pyrotechnics is often linked to weaknesses in the 
supply chain and/or inadequate physical border controls and monitoring of 
online purchases. Several Member States reported limitations in their ability to 
detect and intercept such illegal trade.580 

Information collected through interviews and follow up questionnaires suggest 
that diversion from distribution is a more limited issue, with only one 
industry representative indicating that they had been subject to theft on some 
occasions when the articles were in transit to the customers, noting, however, 
that this was not a frequent occurrence.581 No national authorities reported this 
to be an issue.  

578   Survey addressed to NCAs: one Member State. 
579   Interviews  with two Member State’s authorities. Follow up questionnaire addressed to national 

competent authorities: response from one Member State. .  

580   Follow up questionnaire addressed to national competent authorities..  
581   Interview with one industry organisation/ industry representative association. 

161 

 
 
 
 
Trade diversion 

Consulted stakeholders indicate that unauthorised sales, both physical and 
online – a key configuration of trade diversion – merit attention. This is 
considered as a prevalent criminal activity for pyrotechnic misuse by 25% of 
national authorities responding to the survey, ranking highest amongst all 
possible options, with e-commerce considered by 26% of respondents as the 
most problematic area in the fight against criminal misuse of pyrotechnics, also 
ranking highest amongst possible options. Across different Member States, both 
national authorities as well as industry representatives voiced similar concerns 
in relation to the proportion of trade diversion through online resellers, with a 
Belgian stakeholder indicating that there is no visibility on the proportion of 
pyrotechnics used to commit illegal acts that is obtained online, speculating that 
a large part of the diverted market likely remains under the radar.582 Consulted 
Swedish customs authorities reported that, between June 2021 and June 2025, 
they have seized about 175.000 units of pyrotechnical articles, of which 95 % 
were seized in parcels incoming from other EU Member States. The estimation 
of customs authorities is that a vast majority of the pyrotechnics they seize are 
legally produced inside or outside of the EU before being diverted to Sweden 
through the sale of online retailers.583  

In Spain, a national authority representative indicated that current regulatory 
frameworks will not be sufficient as long as individuals are allowed to buy 
pyrotechnic articles, of any category, through foreign online shops, which ship 
directly to the individual’s address584. Similarly, an industry representative in 
Slovenia argued that while strong restrictions are in place in the country – 
therefore placing pressure on legal entities – individuals are able to order from 
online shops in Poland, Czechia and Slovakia and, thus, avoid restrictions on 
age as well as on type and category.585 In some cases, buyers can also drive 
across the border to pick up their purchases with their own cars or trucks, often 
simply needing to reach a barn located in a remote area where the articles are 
stored.586 These concerns were echoed by national authorities in Sweden, 
Austria and Germany in particular, who report frequent introduction on their 
national territory of F2/F3/P1 articles for which purchase and possession 
without a licence is not legal.587  

582   Interview with one Member State’s authority.. Interview with one industry organisation/ industry 

representative association further indicated that online platforms as used for (re)selling purposes. 
583   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

584   Survey addressed to NCAs: one Member State. .  
585   Survey addressed to industry: one response. Interview with one EU agency. 
586   Interviews with authorities of two Member States. One interviewee indicated that this is a frequent 

occurrence at the NL-DE border, as well as with BE.  

587   Interviews with authorities of two Member States; follow up questionnaire addressed to national 

competent authorities: response from one Member State.; Survey addressed to NCAs: one Member 
State. 

162 

 
 
 
 
Instances of items purchased from other Member States by individuals who did 
not hold the appropriate licences were also reported by Irish authorities.588 
Surveyed representatives of the Portuguese national authority also raised the 
issue of falsification of the labelling of pyrotechnic articles that are legally 
produced but then do not undergo the required conformity assessment and are 
thus made available on the market illegally.589 Similarly, interviewed law 
enforcement representatives from Cyprus, highlighting the “high prevalence of 
Illicit trade” in their country, especially around New Year’s Eve festivities, 
reported how pyrotechnic articles of category F3 and F4 are smuggled from 
mainland Europe590 hidden in commercial cargo and either underdeclared 
or mislabelled as toys, electronics or fragile items591.  

Data collected from these stakeholders further corroborates the insights shared 
by Europol in its 2024 report,592 which pointed out how the different rules in 
place within EU countries at the different stages of the supply chain for 
production, distribution and control of buyers using pyrotechnical products are 
problematic and create particular challenges for Law Enforcement Authorities.  

A second industry representative from Germany further pointed to the 
worrisome existence of a “whole parallel supply chain”, enabled by both online 
marketplaces such as eBay and Amazon (to a lesser extent), as well as other 
online shops. According to the interviewee, the online shops pose more 
considerable challenges compared to online marketplaces, as they are subject 
to fewer controls and articles can be shipped over through unlabelled postal 
parcels.593 The use of unlabelled postal parcels – reportedly increasingly on the 
rise according to some interviewees594 – is also further confirmed by the most 
recent Europol analyses.595 Interviewed Cypriot, Swedish, Dutch and Belgian 
stakeholders further complemented this, with the latter two saying that the high 
amount of postal parcels going through the flow on a regular basis makes it 
challenging to ensure constant monitoring.596 Consulted representatives of 
Croatian authorities also indicated that, while the issue is more limited in their 
country compared to other Member States, over the course of the last year, 
they have seen a sharp increase in the seizure of diverted pyrotechnics 
(120,000 units seized against 10,000 units seized over the course of the 
previous 4 years). These articles are either imported by trucks via land or 

588   Follow up questionnaire addressed to national competent authorities: response from one Member 
State..  The respondent reported having seized 6,319 pyrotechnic articles between June 2023 and 
June 2025, all imported by individuals that did not retain proper licences.  

589   Survey addressed to NCAs: one Member State.  
590   Source countries mentioned were Greece, Bulgaria, Slovakia and Poland.  
591   Interview with one Member State’s authority. 
592   Europol (2024). Pyrotechnics in the EU State of Play. Not for public distribution 
593   Interviews with one industry organisation/ industry representative association and authority of one 

Member State. Interview with BE representative. 

594   Interview with one Member State’s authority. 
595   Europol (2024). Pyrotechnics in the EU State of Play. 
596   Interviews with authorities of five Member States.  

163 

 
 
 
 
through postal parcels, with Internet advertising and subsequent online 
ordering and home delivery indicated as a significant issue.597  

Social media platforms, such as TikTok, are also emerging as an increasingly 
popular platform both for selling pyrotechnic articles as well as for providing 
information on how to best avoid controls when driving to transport goods 
across borders.598 Communication platforms, such as Telegram, were also 
indicated by two interviewed Law Enforcement stakeholders as areas where 
illegal trade of pyrotechnics is very active, with closed groups often including 
over thousands of members.599 According to the interviewee, within these 
groups, online sellers ask for relatively low prices for flash bangers (between 10 
and 20 euros for a pack of three products), contributing to the blossoming of this 
parallel market. For the Netherlands, this is becoming an increasing issue, as 
also reported in recent media coverage.600 Another interviewee from Dutch Law 
Enforcement further stressed the challenges LEAs face when dealing with these 
closed online chat groups, as it is difficult for investigators to join these 
groups undercover due to the required procedural authorisations.601 
Interviewees, both from Member States as well as from an EU agency, echoed 
the concerns listed above in terms of the worrying size of the online market. EU 
agency representatives shared that, while it is difficult to concretely estimate the 
size, countries such as Germany and the Netherlands are reporting increasing 
seizures, with a Dutch-led Operational Task Force finding that the profit of 
illegal pyrotechnics obtained online can go up to EUR 1 M per year.602 Similarly, 
a Swedish interviewee estimated that around 70% of pyrotechnics used to 
commit illegal acts are obtained online, including legally from suppliers in other 
EU countries.603 Custom authorities further reported that some web shops 
actively try to help their customers to receive the ordered items by frequently 
changing the listed consignor and/or by changing courier companies, thus 
hampering authorities tracking and tracing efforts.604  

597   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

598   Ibid. Survey results further show that social media platforms are considered by 21% of respondents as 

particularly challenging to monitor and regulate for illegal sales of pyrotechnics. 

599   Interviews with authorities of two Member State.  
600   NL Times, February 2025: Fireworks ban needed to stop explosive attacks; Disaster waiting to 

happen, police say. Link  

601   Interview with one Member State’s authority. 
602   Interview with one EU agency.   
603   Interview with one Member State’s authority. 
604   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

164 

 
 
 
 
 
Annex III Country fiches case study A 

Case study A focused on the illegal manufacturing of pyrotechnics and the 
diversion of legally produced pyrotechnics. Beyond a broad overview touching, 
to the extent possible, on all EU27 Member States (Annex II), this case study 
offers more detailed country-level insights for key pyrotechnics producing 
countries, i.e. Poland, Germany, Portugal, France, Italy and Spain. For the latter 
three, deep-dives are provided.  

Non-deep dive countries  

Poland 

The Polish pyrotechnic industry has deep roots, with traditions dating back as 
early as the 16th century, when pyrotechnic articles were used in celebration to 
accompany state ceremonies and battle victories.605 Today, firework displays 
remain a key component of New Year’s Eve celebrations and, to a more limited 
extent, in weddings.606 Contrary to several other EU Member States, the Polish 
regulatory framework for the purchase and possession of F2 and F3 class 
pyrotechnics does not require specific professional licences.607 Over the last few 
months, and building on proposals submitted already in 2021608, the Lower 
House of the Polish Parliament has been debating three bills proposing stricter 
regulations on pyrotechnics, with the three options including respectively: a) 
delegating bans to local governments; b) establishing a complete ban on F3 
class fireworks; and c) establishing a ban on both F2 and F3 classes.609 These 
proposals are largely driven by animal welfare concerns, with the pyrotechnic 
industry warning against serious economic consequences, and a potential 
surge in illegal manufacturing and trade (due to demand).610  

The perception of the public population, surveyed in 2022 by the Ariadna 
National Research Panel, is split, with 51% of respondents expressing against 
blanket bans.611 In an effort to show a position open to compromise, in October 
2024 the Polish Association of Importers and Distributors of Pyrotechnics 
(SIiDP) put forward a proposal for "pyrotechnics-free zones" around inter alia 

605   WEI. (2022). Branża pirotechniczna. Link (Accessed: 23 July 2025). 
606   Ibid.  
607   Sejm Rzeczypospolitej Polskiej. (2022). Ustawa z dnia 15 grudnia 2022 r. o zmianie ustawy o 

wykonywaniu działalności gospodarczej w zakresie wytwarzania i obrotu materiałami wybuchowymi, 
bronią, amunicją oraz wyrobami i technologią o przeznaczeniu wojskowym lub policyjnym oraz 
niektórych innych ustaw. Link (Accessed: 23 July 2025).  

608   Notes from Poland. (2021). Polish opposition seeks ban on fireworks to protect animals. Link 

(Accessed: 23 July 2025). 

609   Gorzow24.pl. (2025). Batalia legislacyjna: Czy Polska zakaze fajerwerków konsumenckich?. Link 

(Accessed: 23 July 2025). 

610   Poland Insight. (n.d.). Firework-Free Zones: Industry Proposes a Compromise. Link (Accessed: 23 July 

2025). 

611   Rzeczpospolita. (2025). Zakaz fajerwerków to straty dla gospodarki i zagrożenie bezpieczeństwa. Link 

(Accessed: 23 July 2025). 

165 

 
 
 
 
national parks, nature reserves, hospitals, educational and childcare facilities, 
heritage sites and densely populated areas612 - modelling the approach on 
German experiences in cities such as Berlin, Hamburg, Munich and Hanover. 
Approximately 75% of surveyed citizens expressed in favour of this solution.613 
In some cities, firework displays have already been replaced since a few years 
with laser shows or other forms of entertainment in response to the concerns 
brought forward by animal welfare associations.614  

Looking at the Polish context and its stakeholders, the Polish pyrotechnics 
industry is a significant global player. According to the World Bank Database, in 
2023, Poland imported over 35,824.93 USD worth of pyrotechnic articles, 
(11,056,400 Kg); and exported 17,678.27 USD (3,161,220 Kg).615 Imported 
articles originate from China (USD 32,366.65K; 10,420,500 Kg); Czech 
Republic (USD 2,489.36K; 523,511 Kg); Albania (USD 660.05K; 70,459 Kg), 
India (USD 157.81K; 13,080 Kg); and Italy (USD 97.57K; 5,708 Kg)616. Exports 
target primarily France (21.3%), Romania (14.4%), Italy (12.7%), and Germany 
(11%).617 The sector generates an annual turnover of PLN 769 M (EUR 181 M 
approximately), contributes PLN 94 M (EUR 22 M approximately) in VAT 
revenue, and involves approximately 25,000 companies, employing over 35,000 
workers, including 10,000 specialists with required certifications.618 In 2023, 
over 30 million pyrotechnic products were sold to nearly 7 million 
consumers.619 The industry is predominantly composed of small, often family-
run businesses, for whom fireworks sales, particularly around New Year's, are a 
crucial income source.620 The most popular articles are batteries, firecrackers, 
rockets, and Roman candles, which collectively constitute 95% of the 
market621 and which primarily belong to classes F2 and F3. F1 class products 
and professional F4 class products have a relatively small share.622 While F2 
and F3 products are frequently used in celebrations such as weddings or New 
Year's Eve festivities, instances of F4 use appear more limited. The 2016 study 
on Flash Bangers, commissioned by the EU, had highlighted623 a certain extent 
of professional use of F4 flash bangers in Poland, in particular in firework 
displays, for local competitions amongst pyrotechnicians as well as by the 
Polish military for training purposes; in terms of illegal use, the study reported 

612   Poland Insight. (n.d.). Firework-Free Zones: Industry Proposes a Compromise. Link (Accessed: 23 

July 2025). 

613   Ibid. 
614   Gorzow24.pl. (2025). Batalia legislacyjna: Czy Polska zakaze fajerwerków konsumenckich?. Link 

(Accessed: 23 July 2025). 

615   World  Bank  WITS.  (2023).  Comtrade  Database:  Fireworks  (HS  360410)  Poland  Imports,  2023.  Link 

(Accessed: 23 July 2025). 

616   Ibid. 
617   Ibid. 
618   Rzeczpospolita. (2025). Zakaz fajerwerków to straty dla gospodarki i zagrożenie bezpieczeństwa. Link 

(Accessed: 23 July 2025). 

619   Ibid. 
620   WEI. (2022). Branża pirotechniczna. Link(Accessed: 23 July 2025). 
621   Ibid. 
622   Ibid. 
623   DNQ – f4 report 2016.  

166 

 
 
 
 
instances of flash bangers being used n the context of football matches, or by 
youth in the framework of anti-social behaviour.  

Instances of illegal manufacturing appear limited, with few anecdotal 
examples reported in the news.624 Representatives from the industry argue that 
illegal production is limited to non-existent due to the vast availability of legal 
products, and that regular controls by the Office of Competition and Consumer 
Protection (UOKiK) and the National Revenue Administration (KAS) ensure that 
fireworks are in line with safety requirements625. In 2023, controls by these 
authorities reportedly showed that 98% of 2 M pyrotechnic articles examined 
complied with safety standards.626 At the same time, experts at the Military 
Institute of Armament Technology (MIAT) argue in a report from 2023 that the 
fact that “pyrotechnic articles used in Poland originate in many cases from 
foreign manufacturers” implies they do not necessarily always comply with 
quality standards at manufacture627, potentially leading to incidents. The MIAT 
has noted instances of non-compliance between article design and 
manufacturer declarations, highlighting the danger of diminished net content of 
pyrotechnic material for the safety of transportation and storage.628 

Serious incidents, although not frequent and not on a large scale, have 
occurred. Most recently, in June 2025, three 19-year-old men in Poland were 
charged with gathering pyrotechnic materials and planning terrorist actions, 
including a school attack inspired by recent events in Norway.629 In the context 
of the 2024 New Year's festivities, emergency services attended to teenagers 
injured by firecracker explosions in Koszalin, Racibórz, and Wieleń.630  

Diversion of pyrotechnic articles from Poland represents a significant 
issue, often linked to cross-border smuggling. Representatives of both Swedish 
as well as German authorities in particular have been vocal about the 
challenges posed by the different licencing requirements in Poland, which 
facilitate the introduction – through both online as well as physical sales – of F3 
class fireworks in their countries, where their sale and use are more 
restricted.631 Stakeholders argue for the positive impact harmonisation of 
legislation across Member States could have on curbing this phenomenon632. 
Cross-border smuggling, particularly into Germany, is also evident (see section 

624  Policja.pl. (2017). Nielegalnie wytwarzał materiały pirotechniczne. Available at: Link 

(Accessed: 23 July 2025). 

625   Poland Insight. (n.d.). Firework-Free Zones: Industry Proposes a Compromise. Link (Accessed: 23 

July 2025). 

626   Ibid. 
627  Prasula,  M.  et  al  (2023)  Bezpieczeństwo  materiałów  pirotechnicznych  w  Polsce.  Link 

(Accessed: 23 July 2025). 

628  Ibid 
629  Reuters. (2025). Poland detains 19-year-old man suspected planning terrorist attack - interior 

ministry. Link (Accessed: 23 July 2025). 

630  Onet  Wiadomości.  (2025).  Polacy  powitali  Nowy  Rok.  Ponad  tysiąc  interwencji  służb 

ratunkowych. Link (Accessed: 23 July 2025). 
631  Interviews with authorities of two Member States.  
632  Interview with one Member State’s authority. 

167 

 
 
 
 
1.1.3 on Germany below for additional details). Interested buyers in Germany 
are able to illegally introduce Polish F2 and F3 fireworks – legally purchasing 
them in Poland – via land, often relying on shops that are set up at the border 
between the two countries.633 In recent years, German customs have 
intercepted several tons of illegal fireworks originating from Poland, often 
concealed in packages and shipped via parcel services.634 A specific type of 
article, known in Germany under the name of "Polish firecrackers", often 
produced in China but entering Germany via Poland, raised the attention of the 
German authorities due to its widespread pervasion of the German market and 
non-compliance with CE certifications.635 To the extent possible, law 
enforcement response to this cross-border challenge has also been 
coordinated. In December 2018, a Europol-supported operation led to 35 
arrests of members of Organised Crime Groups (OCGs) in Poland and the 
seizure of 80 tons of F4 fireworks from a warehouse636. These OCGs were 
trading in F4, T2, and P2 class products, sold online "under the guise of legal 
pyrotechnics trade," with some even geo-blocked for foreign customers. 
Proceeds from these illegal sales were reportedly invested in luxury cars and 
real estate.637 OCG members were suspected of shipping approximately 1,500 
kg of pyrotechnics, including approximately 500 kg of F4 class, to different 
Member States every day.638 

Portugal 

The Portuguese pyrotechnics sector, while a small niche market, sustains 
approximately 12,000 people639 and generates a turnover exceeding EUR 40 M 
per year.640 Pyrotechnic displays are associated not only to New Year’s Eve 
festivities, but also to Easter Celebrations as well as festivals that take place in 
the spring or summer time.641 Between 50% to 60% of fireworks consumed in 
Portugal are manufactured domestically,642 and Portuguese manufacturers are 

633   Business Insider. (2021). Niemcy "przemycają" polskie fajerwerki, bo u nich kupić ich nie wolno. Wielkie 

kontrole na granicy. Link (Accessed: 23 July 2025). 

634   Interview with one Member State’s authority; follow up questionnaire addressed to national competent 

authorities: response from one Member State. 

635   WP Wiadomości. (2019). Polowanie na "polskie petardy" za Odrą. Kontrole aut. Link (Accessed: 23 July 

2025). 

636   Eurojust.  (n.d.).  International  cooperation  disrupts  illegal  fireworks  network.  Link  (Accessed:  23  July 

2025). 

637   GazetaPrawna.  (2018).  CBŚP  przejęło  80  ton  nielegalnych  materiałów  wybuchowych.  35  osób  z 

zarzutami. Link (Accessed: 23 July 2025). 

638   Ibid.  
639   Portugal Resident. (2021). Fireworks sector in meltdown as Covid used to scupper New Year displays. 

Link (Accessed: 23 July 2025). 

640   Portugal  Resident.  (2020).  Portugal’s  fireworks  manufacturers  face  ‘millions  of  euros  in  losses’.  Link 

(Accessed: 23 July 2025). Data from 2020.  

641   Ibid.  
642   Expresso.  (2018).  Fogo  de  artifício  nos  céus  europeus  é  98%  chinês.  Portugal  é  exceção.  Link 

(Accessed: 23 July 2025). 

168 

 
 
 
 
known globally for their impressive displays, having often won international 
awards.643  

The Portuguese legislative framework governing pyrotechnics is considered by 
national manufacturers as one of the strictest globally for producers.644 
Amendments put in place by Decree-Law 30/2002, which inter alia requests the 
establishment of ‘safety zones’ around the places where pyrotechnic articles are 
manufactured, ranging from 10 to 40 hectares, owned by the manufacturers 
themselves,645 were deemed to be amongst the factors that led to a significant 
resizing of the production industry. Today, around 32 legal companies operate 
in Portugal, down from 92 in 2002, as many smaller entities were forced to 
close due to not being able to comply with the new requirements646 and a 
licensing process that is described as particularly complex. Despite the small 
number of licensed companies, an estimated 300 "economic operators" are 
involved in the pyrotechnics sector, with some engaging in sales "without an 
invoice," indicating a parallel, less regulated market.647 In March 2024, a Polícia 
de Segurança Pública (PSP) agent suffered first-degree burns while dismantling 
a "family-run, very home-based pyrotechnics industry, with no safety standards" 
in Arcos de Valdevez.648 Amongst the most well-known security incidents took 
place in Lamego, in August 2017, when an explosion at a family-run factory 
killed at least five people, highlighting the dangers of unregulated production.649 
The incident prompted a comprehensive review of legislation and 
standardisation of licensing procedures for shows and training for 
pyrotechnicians by the PSP, which led to the legislative framework currently in 
place.650  

Today, the most frequent and immediately evident instances of misuse of 
pyrotechnics primarily revolve around sports competitions. To address 
worrying increasing trends of safety and security incidents at football matches, 
in 2023 a new regulation was adopted by the Portuguese government which 
criminalises the use of pyrotechnic instruments in sports venues – both inside 
and outside the venue – punishable by up to five years imprisonment or a fine 
of up to 600 days.651 Building on this new framework, the Portuguese 

643   Etcetaljornal.  (2019).  Pirotecnia  portuguesa  conquistou  mais  um  prémio  internacional  ao  ser  vice-

campeã em festival internacional realizado na Rússia. Link (Accessed: 23 July 2025). 

644   Público. (2017). Empresas de pirotecnia garantem estar a cumprir a lei. Link (Accessed: 23 July 2025). 
645   Ibid. 
646   Ibid 
647   Público.  (2018).  Ainda  se  facilita  na  complicada  arte  da  pirotecnia.  Por  isso  ela  ainda  mata.  Link 

(Accessed: 23 July 2025). 

648   VianaTV.  (2024).  Agente  da  PSP  sofreu  queimaduras  de  primeiro  grau  em  desmantelamento  de 

pirotecnia ilegal. Link (Accessed: 23 July 2025). 

649   BBC  News.  (2017).  Portugal  fireworks  factory  blast  kills  five  near  Lamego.  Link  (Accessed:  23  July 

2025). 

650   Diário da República Eletrónico. (2021). Decreto-Lei n.º 62/2021 de 20 de julho. Link (Accessed: 23 July 
2025);  Diário  da  República  Eletrónico.  (2021).  Decreto-Lei  n.º  82/2021  de  13  de  outubro.  Link 
(Accessed: 23 July 2025). 

651   The Portugal News. (2022). New law to criminalise pyrotechnics in stadiums. Link (Accessed: 23 July 

2025). 

169 

 
 
 
 
Professional Football League (LPFP) approved new measures in April 2024, 
allowing for game interruption in cases of, amongst others, the use of 
pyrotechnics.652 Despite the new framework in place, the PSP continues to 
report of a "substantial and worrying increase" in incidents involving the 
possession or detonation of pyrotechnics in stadiums. In the 2023/2024 sports 
season alone, 5,673 such incidents were recorded, constituting 63.9% of all 
incidents related to violence in sports.653 Sporting and Benfica are the clubs with 
the reported highest number of incidents of this kind.654 In May 2025, during the 
Portuguese Cup final, three people were arrested and 438 pyrotechnic articles 
were seized by the PSP.655  

Law enforcement efforts to counter the diversion of pyrotechnics are 
ongoing. Data published in February 2025 by the PSP on seizures of 
pyrotechnic articles during 2024 indicate a slightly decreasing trend from the 
previous year, with 111,183 pyrotechnic items seized - 29,408 fewer compared 
to 2023656. More recently, 20,464 pyrotechnic articles were seized during PSP 
Operation “Carnival in Safety" in March 2025657. In December 2024, in occasion 
of stricter controls associated with the New Years’ Eve celebrations, inspections 
carried out by the PSP both physical stores as well as through "cyber patrolling" 
online platforms led to the seizure of 3,400 pyrotechnic articles, and an arrest 
for unauthorized possession of F4 pyrotechnic articles.658  

Germany 

Germany’s tradition of consumption and display of pyrotechnic articles is 
associated to New Year's Eve celebrations. The regulatory framework in 
Germany is strict, with sales of pyrotechnic articles restricted to 29-31 
December, and the possibility of setting them off only during New Year's Eve 
and New Year's Day, with specific allotted timeframes that may vary depending 
on the city.659  

652   RTP  Notícias.  (2024).  Liga  de  clubes  reforça  combate  à  pirotecnia  com  novo  regulamento.  Link 

(Accessed: 23 July 2025). 

653   Diário de Notícias. (2025). PSP lembra tragédia de 1996 para alertar para os perigos da pirotecnia na 

final da Taça de Portugal. Link (Accessed: 23 July 2025). 

654   Ibid. 
655   Jornal de Notícias. (2025). Três detidos, dois feridos e 438 artigos de pirotecnia apreendidos no Jamor. 

Link (Accessed: 23 July 2025). 

656   Conversely,  seizures  of  explosives  increased  exponentially.  The  18,787  kilograms  seized  last  year 
represent  a  99%  increase  compared  to  2023.  Público.  (2025).  PSP  apreendeu  111  mil  artigos 
pirotécnicos e 18 mil quilos de produtos explosivos. Link (Accessed: 23 July 2025) 

657   Mais Ribatejo. (2025). Operação Carnaval em Segurança 2025: PSP detém 919 pessoas e apreende 

mais de 20 mil artigos de pirotecnia. Link (Accessed: 23 July 2025). 

658   Jornal de Notícias. (2024). PSP apreende milhares de artigos pirotécnicos e 75 quilos de pólvora. Link 

(Accessed: 23 July 2025). 

659   Federal Ministry of Research, Technology and Space (n.d.). Vorsicht! Celebrating the New Year's Eve. 

Link (Accessed: 23 July 2025). 

170 

 
 
 
 
The quality of pyrotechnics must be certified by Germany's Federal Institute for 
Materials Research and Testing (BAM), or a comparable EU notified body.660 
Imported purchased fireworks that do not comply with these requirements are 
illegal. Violations can result in fines up to EUR 50,000 or three years 
imprisonment.661  

The German pyrotechnics industry is a significant economic actor. In 2024, 
sales reached a record of EUR 197M, marking a 60% increase compared to 
2019, in a strong upward trend following a couple of years of downturns due to 
bans put in place during the COVID-19 pandemic.662 Germany hosts some of 
the largest production sites in Europe and ranks among the world's biggest 
exporters, as well as Europe’s biggest national importer.663 Data from the World 
Bank show that in 2023, Germany's imports of fireworks were USD 137.5 M 
(39,966 tons), making it the largest importer in the EU, while exports were USD 
33.1 million (8,422 tons), ranking second in the EU after the Netherlands.664 The 
primary recorded countries of import were China (USD 131,195.77K; 
38,705,200 Kg); Hong Kong (USD 3,810.46K; 1,033,210 Kg); Switzerland (USD 
2,515.60K; 210,209 Kg); Poland (USD 25.17K; 15,015 Kg); and the Netherlands 
(USD 16.00K; 2,744 Kg)665. In line with the stringent regulatory framework for 
use of pyrotechnic articles, the industry generates 90% of its annual revenue in 
the last three working days of the year through New Year's Eve sales.666  

While the display of pyrotechnic articles during New Year’s Eve is strongly 
rooted in German culture, an increasing trend of serious safety incidents667 has 
led to the launch of a petition by the Berlin Police Union calling for a nationwide 
ban on firecrackers. The petition, strongly supported by the German first 
responder community, collected over two million signatures in a few weeks.668 
While a nation-wide ban is still not fully contemplated, “firework-free” zones 
have been in place in cities such as Berlin, Munich and Hanover since 2019. 
These were met with positive reactions from residents and have served as 

660   DW. (2022). Germany: New Year's Eve fireworks for sale again after ban. Link (Accessed: 23 July 2025). 
661   Federal Ministry of Research, Technology and Space (n.d.). Vorsicht! Celebrating the New Year's Eve. 

Link (Accessed: 23 July 2025). 

662   Lebensmittelpraxis. (n.d.). Hohe Zustimmung in Bevölkerung: Pyrotechnik-Branche schaffte 2024 einen 

Rekordumsatz. Link (Accessed: 23 July 2025). 

663   Washington  Post.  (2022).  Why  many  rules-loving  Germans  love  rogue  New  Year’s  fireworks.  Link 

(Accessed: 23 July 2025). 

664   World Bank WITS. (2023). Comtrade Database: Fireworks (HS 360410) Germany Exports, 2023. Link 

(Accessed: 23 July 2025) 

665   Ibid. 
666   BVPK. (n.d.). Umsatz 2024. Link (Accessed: 23 July 2025). 
667   As an illustrative example, on 1 January 2025 at least five people were killed and dozens injured by 
fireworks across Germany, with incidents in Berlin involving "ball bombs" (Kugelbomben) that caused 
severe injuries and property damage. The Guardian. (2025). A risk to life and limb: residents of Germany 
and Netherlands rue dangers of fireworks. Link (Accessed: 23 July 2025). 

668   The  Guardian. (2025).  A  risk  to life and limb:  residents of Germany  and  Netherlands  rue  dangers  of 

fireworks. Link (Accessed: 23 July 2025). 

171 

 
 
 
 
inspiration for possible similar measures to be implemented across the border in 
Poland, where a similar political debate is currently taking place.669  

While illegal manufacturing is reportedly not a particular concern in the 
country,670 instances of seized "homemade" firecrackers and substances for 
pyrotechnics do exist.671 In January 2025, police seized homemade firecrackers 
and production substances during apartment searches in Paderborn, leading to 
the investigation of three young people for alleged violations of the Explosives 
Act.672  

According to representatives of German national authorities, F4 and F3 
represent the most problematic categories of articles when it comes to misuse 
of pyrotechnics.673 The former are used in public events and football matches, 
as well as by criminals for damage to public spaces; the latter are illegally 
imported from Member States that have less strict regulations, such as Poland, 
where they can be purchased legally by the general public.674 Recent legislative 
updates from October 2024675 have focused on amending the Explosives Acts 
with the goal of introducing stricter penalties for gang-related and commercial 
offences involving explosives – including pyrotechnics in category F4 – with 
imprisonment ranging from six months to five years. Causing an explosion to 
commit theft (e.g., ATM bombings) is now punishable by at least two to 15 
years imprisonment, with higher sentences for causing serious harm to people. 
The amendment further criminalises the attempted illegal acquisition and 
handling of explosives and F4 pyrotechnics, as well as their illegal non-
commercial storage and transport.676  

Diversion of pyrotechnics in Germany represents the most pressing 
issue, and it primarily involves illegal imports from abroad, often transported via 
vans and online deliveries.677 The COVID-19 pandemic-related bans on legal 
fireworks sales in 2020-2021 represented an unwanted trigger for the illegal 
import of Polish fireworks across the border,678 with long queues taking place in 
shops located in border towns, such as Słubice679. Similar import activities were 

669   Scottish  Government.  (2020).  Impact  of  fireworks  regulations:  case  studies.  Link  (Accessed:  23  July 

2025). 

670   Interview with one Member State’s authority. 
671   VPI. (n.d.). Aktiv gegen illegales Feuerwerk. Link (Accessed: 23 July 2025). 
672   Süddeutsche  Zeitung.  (2025).  Gefährliche  Substanzen:  Illegale  Böller  daheim  bei  Jugendlichen 

beschlagnahmt. Link (Accessed: 23 July 2025). 

673   Interview with one Member State’s authority. 
674   Ibid.  
675   Deutscher Bundestag. (2024). Entwurf eines Dritten Gesetzes zur Änderung des Sprengstoffgesetzes, 

des Strafgesetzbuches und weiterer Gesetze. Link (Accessed: 23 July 2025). 

676   Bundesministerium  des  Innern  und  für  Heimat.  (2024).  Kampf  gegen  Organisierte  Kriminalität  und 
hochgefährliche Taten mit Explosivstoffen: Kabinett beschließt Änderung des Sprengstoffgesetzes. Link 
(Accessed: 23 July 2025). 

677   Interview with one Member State’s authority. 
678   Business Insider. (2021). Niemcy "przemycają" polskie fajerwerki, bo u nich kupić ich nie wolno. Wielkie 

kontrole na granicy. Link (Accessed: 23 July 2025). 

679   Ibid 

172 

 
 
 
 
also reported from Czechia, whose licencing requirement are alike the Polish 
ones.680 As a result, German officials have long called for tighter controls on 
illegal fireworks imports, particularly from these two neighbouring countries.681 A 
few numbers and figures from 2024 and 2025 are sufficient to underscore the 
scale of the problem. In June 2025, Hanover Customs reported a tripling of 
illegal pyrotechnics found from 2023 to 2024682, with the key example of 4.4 
tons of illegal fireworks of F3 and F4 categories from Poland in over 460 
packages seized in December 2024683. That same month, customs in Frankfurt 
am Main seized a package from Czechia containing pyrotechnic items of 
category F3; following up on this lead, the authorities were able to recover an 
additional amount of pyrotechnic articles, rounding up to a total of around 554 
kilograms of net explosive mass.684 Federal police also seized 36 “ball bombs” 
and 22 kg of F4 battery fireworks during a car search at the German-Czech 
border in December 2024.685 

A recent investigative enquiry carried out jointly published by Dutch broadcaster 
RTL Nieuws and the German outlet F.A.Z. shed further light on another cross-
border challenge, of a different nature – i.e. the illicit activities covering the 
border between the Netherlands and Germany.686 The investigation 
highlights the significant role played by German wholesalers in diversion of 
pyrotechnic articles into the Netherlands, where they are used by organised 
crime for ATM attacks, drug trafficking and settling internal feuds. According to 
law enforcement representatives interviewed as part of this investigative piece, 
retailers across the German-Dutch border are numerous and belong to both 
nationalities, and they exploit legislative loopholes to move into grey areas. The 
article reports that, in order to obtain a permit to trade in professional fireworks 
in Germany, applicants must prove that they are reliable, i.e. their criminal 
record needs to be clean. For German applicants, this is checked by the police. 
Foreign applicants must present a certificate of good conduct from their home 
country. There is no direct contact among the national authorities, which 
according to the reporters opens up major loopholes. During their research, 
RTL Nieuws and the F.A.Z. came across at least seven Dutch dealers with 
relevant criminal records that were provided with a permit to trade fireworks in 
Germany.687 Interviewed German investigators further explained that there is a 
lack of coordination and communication even at national level, with permits 
often granted in one Federal State after being refused in another. Permit 

680   Ibid.  
681   Anadolu Agency. (2025). German officials call for tighter controls on illegal fireworks after deadly chaos 

in country. Link (Accessed: 23 July 2025). 

682   Zeit  Online.  (2025).  Zoll  Hannover  deckt  mehr  organisierte  Kriminalität  auf.  Link  (Accessed:  23  July 

2025). 

683   Zoll. (2024). Zoll stoppt tonnenweise illegale Pyrotechnik. Link (Accessed: 23 July 2025). 
684   Zoll. (2025). Illegaler Pyrotechnikhandel aufgedeckt. Link (Accessed: 23 July 2025). 
685   MDR. (n.d.). Pyrotechnik: Illegale Kugelbomben und Kilo-Ware beschlagnahmt. Link (Accessed: 23 July 

2025). 

686   F.A.Z. (2025). Wie Händler in Deutschland niederländische Kriminelle mit Sprengstoff versorgen. Link 

(Accessed: 23 July 2025). 

687   Ibid.  

173 

 
 
 
 
requests and the necessary documents are also often forged, and there is no 
central database to keep track of this paperwork.688 Pyrotechnic articles illegally 
traded from one country to the other are also often stored in locations along the 
border, such as former NATO bunkers. In 2022, the joint investigation 
supported by Europol in the framework of the EncroChat operations dismantled 
a criminal network trafficking fireworks between Germany and the 
Netherlands.689 The 350 tons of dangerous fireworks seized had been stored in 
unsecured locations, including former NATO bunkers and barns along the 
border690.  

Deep dive countries 

Italy 

Context 

The manufacturing, use and trade of pyrotechnic articles in Italy have deep 
roots, ingrained in the country’s social and cultural fabric. Fireworks are used to 
celebrate religious festivities, cultural festivals and weddings, with a tradition 
that goes back at the very least to the 16th century.691 As evidenced by 
Vannoccio Biringuccio's "De Pirotechnia"692 which provides a historical overview 
of the art of pyrotechnics, pyrotechnic articles were used to celebrate, inter alia, 
papal elections in Rome; the arrival of high-level guests in Venice; and in the 
context of theatrical performances.693 As the centuries progressed, the Italian 
pyrotechnic manufacturing industry continued to grow, marked by the 
establishment of cultural and professional associations such as the Società 
Pirotecnica Italiana in 1863;694 and of several pyrotechnic competitions and 
festivals of national and international relevance, which continue to exist to 
date.695  

Today, Italy is home to approximately 2.000 businesses operating within the 
pyrotechnics sector, with the industry generating a turnover of about EUR 600 
million.696 Most of these companies are small, usually family-run businesses, 

688   Ibid.  
689   Europol. (n.d.). 350 tonnes of dangerous fireworks seized in Germany and Netherlands. Link (Accessed: 

23 July 2025). 

690   F.A.Z. (2025). Wie Händler in Deutschland niederländische Kriminelle mit Sprengstoff versorgen. Link 

(Accessed: 23 July 2025). 

691   Pirovagando. (n.d.). Cenni Storici. Link (Accessed: 7 July 2025). 
692   Ibid. 
693   Ibid. 
694   Storia e Memoria di Bologna. (n.d.). La Società pirotecnica italiana e le feste popolari. Link (Accessed: 

7 July 2025). 

695   Examples include the “Fiori di Fuoco" festival in Omegna; the "Caput Lucis" festival near Rome, and the 

National Fireworks Festival in San Severo. 

696   Truenumbers.it. (2023). Fuochi d’artificio, il giro d’affari è crollato dell’80%. Link (Accessed: 7 July 2025). 

174 

 
 
 
 
with secrets of the trade passed on from generation to generation. While 
factories, wholesale warehouses, and small retailers are present across the 
entire national territory, the culture of pyrotechnics is particularly robust in 
Southern Italy, with 70% of businesses located in the area.697 The region of 
Campania alone reportedly accounts for roughly 50% of manufacturing 
companies.698  

Despite its significant legitimate cultural role, the pyrotechnics sector in Italy is 
often associated with illegal activities. OCGs frequently exploit fireworks for 
communicative purposes.699 Fireworks can be used to welcome home a 
mafia head being released from prison; to mark the victory of one rival gang 
over another,700 or demonstrate territorial control701; to warn of the arrival of law 
enforcement; or to signal the arrival of drug shipments702. In the latter case, 
specific colours or sounds are associated with a specific message: if the 
fireworks are red, the drug shipment has arrived but cannot yet be retrieved; if 
they are white or green, the retrieval operation can proceed.703 If there is no 
colour but only sound, it means that retrieval is not at all possible.704 While 
traditionally associated exclusively with the working-class areas of Naples,705 
this phenomenon is now widespread to other cities in the South706, as well as 
across the regions of Northern and Central Italy,707 reflecting the relocation or 
expansion of operations in these areas by organised crime groups. In 2024, the 
President of a local foundation in Florence (region of Tuscany) called for a more 
in-depth investigation into the use of pyrotechnic articles in the municipality, 
arguing that the “200/300 recorded instances” of pyrotechnic use go “widely 
beyond the number of authorised events”, and recalling how “the experience 
gathered [in recent years] by police and judicial practitioners” shows that 
fireworks “are used [by organised crime] to convey messages with very specific 
meanings”.708 Italian Law Enforcement representatives further suggest that the 
ease of availability allows for the acquisition of pyrotechnic articles for use in 

697   Linkiesta.  (2016).  Il  50  per  cento  dei  botti  di  Capodanno  non  è  a  norma,  in  Italia  esplode  il  mercato 

illegale. Link (Accessed: 7 July 2025). 

698   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Full transcript. Link (Accessed: 7 July 2025). 
699   Corriere della Sera. (2023). Fuochi d’artificio a Napoli, svelato il codice dello spaccio. Link (Accessed: 

7 July 2025). 

700   Articolo  21.  (2021).  Fuochi  d’artificio,  il  messaggio  cifrato  della  criminalità  organizzata:  da  Roma  a 

Napoli. Link (Accessed: 7 July 2025). 

701   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Full transcript. Link (Accessed: 7 July 2025). 
702   Corriere della Sera. (2023). Fuochi d’artificio a Napoli, svelato il codice dello spaccio. Link (Accessed: 

7 July 2025). 

703   Ibid. 
704   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Full transcript. Link (Accessed: 7 July 2025). 
705   Corriere della Sera. (2023). Fuochi d’artificio a Napoli, svelato il codice dello spaccio. Link (Accessed: 

7 July 2025). 

706   PalermoToday. (2023). Mafia, audizioni commissione Antimafia Ars: "Fuochi d'artificio nei quartieri per 

festeggiare scarcerazioni". Link (Accessed: 7 July 2025). 

707   Articolo  21.  (2021).  Fuochi  d’artificio,  il  messaggio  cifrato  della  criminalità  organizzata:  da  Roma  a 

Napoli. Link (Accessed: 7 July 2025). 

708   FirenzeToday. (2024). Fuochi d'artificio, le mafie e i segnali criminali: la fondazione Caponnetto chiede 

un'interrogazione al ministro. Link (Accessed: 7 July 2025). 

175 

 
 
 
 
various types of criminal activities, including demonstrations against police 
forces; extortion against commercial businesses; and property damage709.  

Law enforcement activities to counter the illegal manufacturing of 
pyrotechnic articles and diversion from the legal supply chain intensify in 
the weeks surrounding the Christmas and New Year’s Eve celebrations, when 
demand for use by regular citizens to celebrate the festivities increases. In 
recent years, to counter growing safety issues, as evidenced by an increase in 
the number of wounded and deaths reported, 710 as well as environmental711 
and animal rights concerns, Municipalities have taken to enforcing a ban on the 
use of pyrotechnic articles between the end of December and early January. 
This includes major municipalities such as Rome, Turin, Florence and Genoa, 
inter alia.712 In spite of the bans in place, of the numerous awareness-raising 
campaigns put in place yearly,713 and the subsequent level of political attention 
generated by the issue, substantial challenges continue to exist. Data released 
by the Italian State Police on the occasion of the 2025 New Year festivities 
indicate an increase in the number of seriously injured people compared to the 
previous year, including minors,714 and in general, the highest figures of the last 
10 years.715  

The legal framework for the production, trade and use of pyrotechnics in 
Italy is regulated by Legislative Decree 123/2015716, which transposes the 
Pyrotechnics Directive 2013/2019 and categorises pyrotechnic articles into the 
F1-F4, T1-T2 and P1-P2 categories with the relevant associated limitations for 
use and possession. While the Italian Decree does not introduce restrictions 
that go beyond the minimum EU requirements, the Italian Penal Code (Art. 703) 
does further specify that unauthorised use of pyrotechnic articles can be 
punished with a fine of up to EUR 103, with aggravating circumstances in case 
pyrotechnic articles are used where people are gathered.717 In this case, the 

709   Interview  with  one  Member  State’s  authority;  Europol,  Pyrotechnics  in  the  EU:  State  of  Play  2024 

(source not available to the general public). 

710   ANSA. (2023). 6 tonnes illegal fireworks seized in Rome. Link (Accessed: 7 July 2025); L'Indipendente. 
(2025). Gli effetti nocivi dei fuochi di Capodanno su ambiente, uomini e animali. Link (Accessed: 7 July 
2025). 

711   Ibid; Wanted in Rome. (n.d.). Naples suffers toxic air after New Year's fireworks. Link (Accessed: 7 July 

2025).  

712   Sky  TG24.  (2024).  Petardi  e  botti  di  Capodanno,  cosa  si  rischia  tra  regole  e  divieti.  FOTO.  Link  
(Accessed: 7 July 2025).The governance of Italy and the degree of autonomy retained by Regional and 
Municipal governments implies that there is an amount of liberty on the application of specific regulations 
such  as  these  bans.  These  prevent  the  application  of  a  uniform  approach  across  the  entire  national 
territory. 

713   Carabinieri. (n.d.). Campagna d'informazione e sicurezza sull'uso dei fuochi d'artificio. Link (Accessed: 

7 July 2025). 

714   309 injured,  of which  69  admitted  to hospital against  the  274 (of  which  49 admitted)  in  2024. Ninety 
affected minors, compared to the previous years’ 64. Polizia di Stato. (2025). I dati relativi al Capodanno 
2025. Link (Accessed: 7 July 2025). 

715   Di Costanzo, A. (2025) Botti di Capodanno, 309 feriti: mai così tanti negli ultimi dieci anni. 146 arresti, 

la Repubblica, 1 January. Link (Accessed: 10 July 2025). 

716   Normattiva. (2015). Decreto Legislativo 29 luglio 2015, n. 123. Link (Accessed: 7 July 2025). 
717   Gazzetta Ufficiale. (1930). Art. 703 - Accensioni ed esplosioni pericolose. Link (Accessed: 7 July 2025). 

176 

 
 
 
 
Penal Code mandates arrest and up to one month of prison time.718 Additional 
aggravating circumstances can be called for if the use of pyrotechnics 
generates injuries or if illegally manufactured pyrotechnics are involved. 

Types of pyrotechnic articles produced 

As a country with such deep-rooted history in the pyrotechnic industry, Italy is a 
significant producer, exhibiting a diverse range across all product 
categories.719 Examples include firecrackers, squibs, luminous sparks, 
fountains, paper bombs and professional high-reach fireworks720. Along with 
Spain, Italy is also recognised as one of the primary European producers of F4 
flash bangers.721 In 2016, the estimated annual production volume ranged 
between 500.000 and 700.000 units, 75% of which were destined for the 
manufacturer’s own use.722 

A notable example of pyrotechnic articles produced in Italy is a flash banger 
(previously marketed as “COBRA“), widely demanded internationally.723 It was 
legally produced in Teramo by the Di Blasio family, sole proprietors of the 
brand. Following a fatal incident involving one of its employees724 and the 
retrieval close to the factory of almost 500 kg of irregularly stored explosive 
material,725 the company’s operations were suspended in 2023 by the Teramo 
Prefecture726. Despite this, according to the family’s statements, not being 
legally produced since the company’s operations shut down, such products are 
flooding the market. In 2023, Italian authorities intercepted at Milan Malpensa 
Airport several illegal shipments of F4 pyrotechnics destined for the 
Netherlands, including two trucks illegally transporting over 60,000 "COBRA 6" 
devices with a NEC of approximately 1,700 kilograms727. The Di Blasio family 
claims these and other COBRAs currently circulating across European territory 
are counterfeit.728 

718   Gazzetta Ufficiale. (1930). Art. 703 - Accensioni ed esplosioni pericolose. Link (Accessed: 7 July 2025).  
719   European  Commission,  Evaluation  study  of  Pyrotechnics’  Legislation,  Interim  report.  Source  not 

available to the general public. 

720   Consultations with IT expert.  
721   European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs 
(2019).  Study  on  illegal  sales  of  pyrotechnic  articles  destined  for  professional  users  (category  F4). 
Source not available to the general public. 

722   Ibid.  
723   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Link (Accessed: 7 July 2025). 
724   Il Centro. (2023). Operaio ucciso dall'esplosione, preparava i fuochi d'artificio. Link (Accessed: 7 July 

2025). 

725   Emmelle.  (2023).  Sospesa  dalla  prefettura  l’attività  della  fabbrica  di  petardi.  Link  (Accessed:  7  July 

2025). 

726   Ibid. 
727   Interview with one Member State’s authority. 
728   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Link (Accessed: 7 July 2025). 

177 

 
 
 
 
Illegal manufacturing 

Illegal manufacturing of pyrotechnics represents a thriving market in Italy, 
accounting for an estimated 25-50% of the overall market.729 According to an 
interviewed representative of Italian Law Enforcement, many illegal producers 
operate from family-run businesses. Production is intended for the national 
market, and intensifies around the New Year festivities, in line with the 
increased demand, seeping into the social fabric as a black market.730 Naples 
and the surrounding areas, but also Bari and Palermo, are assessed as urban 
centres where the black market for both production and trade is most 
ingrained.731 Clandestine operations often take place in garages, apartments 
or secret backrooms of textile factories732 and can result in serious accidents 
due to the improper handling of the explosive material. Amongst the most 
recent instances of this kind uncovered by Law Enforcement, in November 
2024, an illegal factory exploded in Ercolano, causing the death of three young 
individuals.733 The fireworks produced there were entirely illegal, destined for 
the black market, and the operation exploited unsuspecting and vulnerable 
young workers. Similarly, in Reggio Calabria in January 2025, authorities 
dismantled what appeared to be a small illegal factory where individuals were 
assembling large-scale pyrotechnic articles, including highly explosive 
homemade firecrackers734. Small illegal laboratories containing explosive 
precursors, gunpowder, and undeclared cartridges were discovered in 
Mammola735 and Castel Volturno736. In April 2025, a 33-year-old man from 
Naples was arrested for the illegal manufacturing and trade of dangerous, 
artisanal pyrotechnic products. His hidden laboratory contained aluminium and 
titanium powder, fuses, cardboard tubes, and labelling equipment.737 To attract 
buyers, illegally manufactured and sold pyrotechnic articles are often given 
creative names, such as “Maradona’s football738”, “the Championship bomb739”, 
or, more recently “Sinner’s bomb740”. 

729   Survey addressed to NCAs: one Member State; Linkiesta. (2016). Il 50 per cento dei botti di Capodanno 

non è a norma, in Italia esplode il mercato illegale. Link (Accessed: 7 July 2025). 

730   Survey addressed to NCAs: one Member State; Vice. (2025). The Deadly Mafia Party Bombs of Naples. 

Link (Accessed: 7 July 2025). 

731   Linkiesta.  (2016).  Il  50  per  cento  dei  botti  di  Capodanno  non  è  a  norma,  in  Italia  esplode  il  mercato 

illegale. Link (Accessed: 7 July 2025). 

732   Survey addressed to NCAs: one Member State; Vice. (2025). The Deadly Mafia Party Bombs of Naples. 

Link (Accessed: 7 July 2025). 

733   Rai. (n.d.). L'ARTIFICIO DEI FUOCHI di Chiara De Luca. Link (Accessed: 7 July 2025). 
734   Carabinieri. (n.d.). Smantellati due laboratori di artifizi pirotecnici illegali. Link (Accessed: 7 July 2025). 
735   Ibid. 
736   RTL 102.5. (2024). Capodanno 2025, è già trionfo di botti illegali. Link (Accessed: 7 July 2025). 
737   Today.it. (2025). Bombe artigianali comprate online e spedite con il corriere: "Arsenale" in casa, 33enne 

arrestato. Link (Accessed: 7 July 2025). 

738   Polizia di Stato. (n.d.). Guida: Fuochi d'artificio, un po' di chiarezza. Link Link (Accessed: 7 July 2025). 
739   Sky  TG24.  (2024).  Botti di  Capodanno, tra  i più  pericolosi  le  'bombe Sinner'.  Link  (Accessed: 7 July 

2025). ANSA. (2024). Capodanno, sequestri di botti in tutta Italia. Link (Accessed: 7 July 2025). 

740   Ibid. 

178 

 
 
 
 
As is the case for the legal production market, illegal manufacturing is a family 
business.741 This often implies the involvement of minors, who are either 
knowingly or unknowingly participants in the illicit trafficking of pyrotechnic 
material.742  

Instances of illegal trade are also present in Italy. Illegal products and 
precursors, particularly from China and Eastern Europe,743744 enter the 
country via road or sea. Large quantities of illegal pyrotechnics, often concealed 
within legitimate cargo with false customs declarations, are often intercepted at 
ports, with Gioia Tauro (Reggio Calabria) as a notable example.745 Reportedly, 
precursors from China are also used for illegal manufacturing purposes.746  

Diversion 

Diversion from the trade of pyrotechnic articles in Italy is performed 
primarily through unauthorised sellers, both physical and online. 
Instances of diversion are evident in numerous seizures across Italy, 
which, as mentioned above, tend to increase during the winter holiday period. 
Official data from the Italian State Police for New Year’s 2025 reports a marked 
increase in arrests, charges, and seizures for most article categories in 
December 2024 compared to the previous year, as evidenced in the table 
below. 

Table 4 Comparison data on arrests, charges and seizures for December 2023-
2024  

Category 

December 2023 

December 2024 

Arrested individuals 

Charges made 

Seized articles 

Rocket fireworks 

Gunpowder 

50 

304 

473 units 

836 kg 

F1/F2/T1/P1 and F3/F4/T2/P2 

12.490 kg 

Articles with “CE” markings747 

41.775 kg 

Illegal articles/mislabelled articles 

3.475 kg 

88 

386 

21 units 

1.214 kg 

64.416 kg 

52.489 kg 

31.247 kg 

741   Vice. (2025). The Deadly Mafia Party Bombs of Naples. Link (Accessed: 7 July 2025). 
742   Vice.  (2025).  The  Deadly  Mafia  Party  Bombs  of  Naples.  Link  (Accessed:  7  July  2025). 

Interview with national authority. 

743   Linkiesta.  (2016).  Il  50  per  cento  dei  botti  di  Capodanno  non  è  a  norma,  in  Italia  esplode  il  mercato 

illegale. Link (Accessed: 7 July 2025). 
744   Interview with one Member State’s authority. 
745   Approdolacabria.it. (n.d.). Oltre 78 tonnellate di fuochi d’artificio sequestrati al Porto di Gioia Tauro. Link 
(Accessed:  7  July  2025);  RTL  102.5.  (2024).  Capodanno  2025,  è  già  trionfo  di  botti  illegali.  Link 
(Accessed: 7 July 2025). 

746   Vice. (2025). The Deadly Mafia Party Bombs of Naples. Link (Accessed: 7 July 2025). 
747   In the framework of the typology adopted by this study, this would fall under illegal manufacturing. 

179 

 
 
 
 
Category 

December 2023 

December 2024 

Pyrotechnic components 

162.678 units 

Detonators 

Igniter capsules 

186 units 

3.521 

612.537 units 

7 units 

2.183 units 

Source: Italian Police, Link. 

The investigations leading to these seizures and arrests often provide insights 
into the modus operandi applied to divert pyrotechnic articles from the 
legal to the illegal market. For example, the arrest in April 2025 of the 
Neapolitan illegal manufacturer mentioned above was also possible due to the 
retrieval of pyrotechnic articles in a house in Turin, in Northern Italy. The articles 
were purchased online, via Telegram, and dispatched across Italy through 
regular post parcels labelled as house products.748The modus operandi of 
ordering articles online and receiving them through postal parcels was reported 
in several other instances.749 Instances of illegal or counterfeit articles sold 
through vans or private vehicles are also frequent.750 In a less recent case from 
2015, an individual was arrested after Law Enforcement realised that he was 
receiving orders for specific, prohibited articles, via phone, which he would then 
sell in the streets out of his personal vehicle.751 

Today, Law Enforcement estimates that more than 50% of the pyrotechnics 
used for the commission of illegal acts in Italy are obtained online.752 
Platforms such as Amazon, Wish and Temu are identified as the most 
frequently used ones for these purposes, and online commerce eschews 
thorough checks from LEAs due to a variety of constraints, which include a 
limited number of resources, as well as different rules across EU Member 
States: pyrotechnic articles that are legal in one European country may be 
illegal in Italy, and vice versa, creating loopholes in online commerce.753 
Industry representatives also report an increase in the past 5-10 years in the 
number of channels supporting online sales, arguing that the sale online of 
pyrotechnic articles purposely mislabelled to circumvent restrictions 
related to export, transport and storage represents a significant issue.754  

While diversion from trade is evident, both law enforcement and industry 
representatives indicate that diversion from distribution (i.e. when pyrotechnics 

748   Today.it. (2025). Bombe artigianali comprate online e spedite con il corriere: "Arsenale" in casa, 33enne 

arrestato. Link (Accessed: July 7, 2025). 

749   VeronaSera.  (2024).  Botti  di  Capodanno  illegali,  sequestri,  denunce  e  un  arresto:  i  consigli  della 
Questura.  Link  (Accessed:  7  July  2025);  RaiNews.  (2022).  Botti  di  Capodanno  illegali,  decine  di 
sequestri e denunce in tutta Italia. Link (Accessed: 7 July 2025). 

750   LecceNews24. (2024). Maxi sequestro di giocattoli e fuochi d’artificio “illegali”. Link (Accessed: 7 July 

2025). 

751   Corriere della Sera. (2015). Roma, una tonnellata di fuochi illegali sequestrata tra Capitale e Castelli. 

Link (Accessed: 7 July 2025). 

752   Interview with one Member State’s authority. 
753   Ibid.  
754   Interview with one Member State’s authority. 

180 

 
 
 
 
are in transit between the producer and the wholesaler, retailer or 
warehouses) is not a reported issue in Italy755.  

Good practices 

Italian public authorities and LEAs are particularly attentive to raising 
awareness of both safety and security issues revolving around the (mis)use 
of pyrotechnic articles, in particular close to the New Year festivities. The 
Guardia di Finanza’s seizure efforts are boosted through the yearly 
Capodanno Sicuro operations,756 - intelligence-led operations that seek to 
dismantle illegal production sites and seize illegal pyrotechnic articles prior to 
their use on New Year’s Eve - and through similar operations carried out by 
other LEA branches such as Carabinieri and Polizia di Stato. These operations 
are complemented by awareness-raising campaigns put in place both by Law 
Enforcement as well as by local municipalities757. For example, the Carabinieri – 
adopting the Usa la testa, non rovinarti la festa tagline (Use your head and don’t 
mess up the party) regularly publish detailed information on their website on 
key risks deriving from (illegally manufactured) pyrotechnics and provide 
several recommendations for safe use.758 These messages are also reposted 
across social media channels,759 and the same tag line is adopted by local 
Municipalities wishing to spread the message.760 At the level of local 
Municipalities across Italy, the Polizia di Stato carries out targeted youth 
seminars in junior high schools and high schools before Christmas,761 
informing the youth about the applicable legislation and warning them, including 
through images of real-life injuries, of the risks.  

Albeit a costly and therefore not particularly widespread approach, some legal 
pyrotechnic manufacturers in Italy incorporate chemicals into their pyrotechnic 
powders to "tag" their products to help clearly determine (with production batch 
- year and location) from which production batch a specific article comes. This 
supports tracking and tracing of their articles if they are diverted or misused.762  

755   Interviews  with  one  Member  State’s  authority  and  one  industry  organisation/  industry  representative 

association. 

756   Sky TG24. (2024). Capodanno, botti e petardi: le misure di sicurezza. Link (Accessed: 7 July 2025). 
757   ANCI. (n.d.). Piroguida. Link (Accessed: 7 July 2025). 
758   Carabinieri. (n.d.). Campagna d'informazione e sicurezza sull'uso dei fuochi d'artificio. Link (Accessed: 

7 July 2025). 

759   Carabinieri Facebook Page: Link (Accessed: 10 July 2025). 
760   See for example: Comune di Napoli (2011) Usa la testa, non rovinarti la festa! A servizio del 

consumatore – Fuochi d’artificio, Città e Consumi, n. 18 (Dicembre 2011–Gennaio 2012) Link 
(Accessed: 10 July 2025). 

761   See for example: Questure.Poliziadistato.it. (n.d.). I botti di Capodanno: la Polizia di Stato in campo 

per la legalità. Link (Accessed: 7 July 2025). 
Questure.Poliziadistato.it. (n.d.). Capodanno Sicuro: La Polizia di Stato di Salerno in campo per la 
legalità. Link (Accessed: 7 July 2025). 
762   Interview with one Member State’s authority. 

181 

 
 
 
 
France 

Context 

As one of the leading producers of pyrotechnic articles in the European Union, 
as  well  as  a  country  facing  significant  challenges  with  their  misuse,  especially 
during  riots  and  against  law  enforcement  authorities,  France  constitutes  a  key 
country in the context of the present study. A closer look at the national context 
has revealed key aspects of one of Europe’s strongest pyrotechnic industries, as 
well  as  the  challenges  it  faces,  and  the  methods  used  by  those  misusing 
pyrotechnic articles. 

Regarding production, France ranks among the top producers of 
pyrotechnics over time, with significant output in both fireworks and other 
signalling devices.763 Overall, France ranks as the second-largest country in 
terms of average turnover in the explosive sector between 2008 and 2020, with 
an average turnover of €549 million, second only to Germany. More specifically, 
the average production value of signalling flares, rain rockets, fog signals, and 
other pyrotechnic articles (excluding fireworks) in France rose to €127.1 million, 
representing 60% of the EU average production value of €213 million over the 
period 2003–2022. Germany recorded the second-highest average production 
value in this category, with only €42.1 million.764  

Concerning criminal misuse, a 2016 study revealed that illegal use of F4 flash 
bangers in France was not considered a major concern.765 According to French 
authorities, the illegal use of pyrotechnics by unqualified individuals is mostly 
centred around the New Year’s Eve and Bastille Day in July.766 More 
specifically, pyrotechnics play a prominent role in the celebrations on the 14th of 
July, Bastille Day, which commemorates the storming of the Bastille, a key 
moment in the French Revolution.767  

On June 27, 2023, just weeks before Bastille Day, the death of a young man 
caused by police officers sparked widespread unrest across France.768 During 
these riots, protesters frequently used pyrotechnic devices, especially “firework 
mortars” (roman candles) against police forces.769 Much of the illegal trade 

763   European Commission, Evaluation study of Pyrotechnics’ Legislation; overall, the EU is clearly a net-

importer of fireworks. By contrast, the EU is a net-exporter of signalling flares, rain rockets, fog signals 
and other pyrotechnic articles (excluding fireworks) and of matches (excluding Bengal matches and 
other pyrotechnic products). 

764   European Commission, Evaluation study of Pyrotechnics’ Legislation. 
765   DJS, 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, 
2016. 

766   Ibid; follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

767   Le Monde, In photos: Paris's Bastille Day fireworks and pyrotecnics show, link. 
768   ABC News, Why is France rioting? What to know about the fatal police shooting of Nahel M, link 
769   The Brussels Times, A tense Bastille Day as France deploys 130,000 police officers and bans 

fireworks, link; Le Monde, Mort de Nahel M.: comment les mortiers d’artifice, dirigés vers les forces de 

182 

 
 
 
 
reportedly occurred online through social media platforms like Telegram and 
Snapchat.770  

Against this backdrop, and in the days leading up to the Bastille Day 2023, the 
French authorities, concerned about the potential for renewed unrest, decided 
to ban the “the sale, transportation, and use of pyrotechnic articles and 
fireworks throughout the country” between the 8th and the 15th of July with the 
exception of “the acquisition, carrying, transport and use of the equipment” by 
professionals. 771 The same phenomenon of civil unrest in the days leading up 
to Bastille Day continued in 2025, with approximately 15,000 mortars seized 
and 176 individuals arrested, 43 of whom in connection with the possession or 
use of mortars, during the night of 13-14 July in Paris.772  

Similarly, ahead of the Christmas holidays in 2023, police in the Paris 
metropolitan area increased inspections, leading to seizures of pyrotechnic 
articles.773 On 19 December, an order was also issued banning the acquisition 
and possession of fireworks and pyrotechnic articles. According to French 
authorities, this contributed to a significant drop in projectile-throwing incidents 
during New Year’s Eve. 774 

When asked about the criminal misuse of pyrotechnics, a representative from 
an EU agency noted that France faces particular challenges. According to the 
EU agency and representatives of different national authorities, pyrotechnics in 
France are not typically used by organised crime but rather by individuals, who 
often use firework mortars, to target law enforcement authorities during 
festivities, sports events, and riots.775 According to French authorities, while the 
majority of these types of attacks are directed against law enforcement, public 
buildings are also prime targets, and residential buildings are affected, either 
intentionally or unintentionally.776 Similarly, French authorities report that, during 
protests, some organized movements use fireworks against law enforcement 

l’ordre, sont devenus l’arme de base des émeutes, link; Business Insider, France is banning the sale 
of fireworks on its biggest national holiday after protesters used them as weapons against police, link; 
The Economic Times, France: Protesters set police station ablaze in Rouen, link; follow up 
questionnaire addressed to national competent authorities: response from one Member State. 
770   Le Monde, Mort de Nahel M.: comment les mortiers d’artifice, dirigés vers les forces de l’ordre, sont 
devenus l’arme de base des émeutes, link; Business Insider, France is banning the sale of fireworks 
on its biggest national holiday after protesters used them as weapons against police, link. 

771   Politico, France bans fireworks on concerns about Bastille Day violence, link; 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 - Légifrance, link; Interview with FR Industry Representative (PYRAGIC). 

772   Le Figaro, « Les choses sont en train de bouger »: comment la lutte contre les mortiers d’artifice 

dangereux s’intensifie, link. 

773   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

774   Ibid. 
775   Euro News, Two people killed and hundreds arrested in France during Champions League win 

celebrations, link; interviews with one EU agency, two authorities of two Member States and one 
Member State's representative part of an EU-level instrumen ; follow up questionnaire addressed to 
national competent authorities: response from one Member State. 

776   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

183 

 
 
 
 
and institutional buildings but also against rival movements.777 The fireworks 
used include roman candles or similar fireworks, and firecrackers with fuses to 
enhance improvised incendiary devices. French authorities also report the 
extraction of pyrotechnic powder, possibly from commercially manufactured 
fireworks, to create improvised explosives.778  

According to national authorities representatives, in 2024, 47 incidents of public 
disturbances, including riots and violence against law enforcement, involved the 
use of pyrotechnics. Additionally, there have been 101 cases of property 
damage involving pyrotechnics, 18 of which caused damage to security forces 
barracks. Furthermore, overall for 2024, 338 legal proceedings were initiated for 
incidents involving the misuse of fireworks in the gendarmerie zone,779 with 175 
people charged with criminal acts, out of which 34% were minors.780 Between 
January 1st and June 30th 2025, the national police recorded 1,347 uses of 
fireworks mortars, amounting to 12.2% of all the urban violence incidents, 
leading to the arrest of 157 individuals.781  

At the political level, French authorities appear to have been actively 
monitoring and reacting to threats regarding the criminal misuse of 
pyrotechnics. More specifically, in response to the misuse of pyrotechnic 
articles against police forces in the days leading up to and during Bastille Day 
celebrations, French authorities introduced a ban on the sale of pyrotechnic 
articles and fireworks in 2023 and have since increased police presence and 
controls during this period each year.782 

Regarding political initiatives, France and the Netherlands have jointly circulated 
a non-paper to address the criminal misuse of pyrotechnic articles with the aim 
of strengthening EU law and regulations and reinforcing collaboration between 
Member States. The non-paper proposes, among other measures, to enhance 
cooperation and information exchange between Member States, introduce a 
ban on certain products such as flash bangers, establish maximum limits on the 
amount of flash and gunpowder contained in certain pyrotechnic articles and 
consider implementing an EU-wide Pyro-Pass, a document proving an 
individual’s specialised knowledge.783 

777   Ibid.  
778   Ibid. 
779   Ibid. 
780   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

781   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

782   Le Figaro, « Les choses sont en train de bouger »: comment la lutte contre les mortiers d’artifice 

dangereux s’intensifie, link.; BFMTV, INFO BFMTV. 389 interpellations, 28 blessés chez des forces de 
l'ordre et secours... La nuit de dimanche à lundi marquée par des violences, link. 

783   Government of the Netherlands and Republic of France, Modify the Pyro Directive to Protect Public 

Order and Safety A collaborative non-paper between the Netherlands and France; interviews with 
authorities of two Member States. 

184 

 
 
 
 
Finally, in 2023, the French Senate tabled a proposal to ban the online sale and 
postal delivery of pyrotechnic articles, requiring buyers to collect them in person 
from physical stores. 784 

In conclusion, France is one of the leading producers of pyrotechnic articles and 
seems to face ongoing challenges related to their misuse against national 
enforcement authorities. Political attention to the pyrotechnic sector is strong, 
with the French government actively engaging at both the EU and national 
levels. 

Illegal manufacturing 

The French authorities report that they have not identified any illegal 
manufacturing sites operating at an industrial scale in France.785 However, by 
monitoring pyrotechnic precursors, in the past five years, they have launched 
100 judicial proceedings against individuals suspected of producing pyrotechnic 
powders, 15% of which were intended for use in fireworks.786 F3 and F4 
firecrackers, rockets, and similar bombs were among the pyrotechnic articles 
mainly manufactured at these sites.787 In France, the illegal manufacturing of 
pyrotechnic articles commonly involves the majority of easily accessible 
precursors listed in Annex II of Regulation (EU) 2019/1148.788 These include 
nitrates such as potassium and sodium, as well as aluminium and magnesium 
powders. Hexamine is also used, though less frequently. 789 

According to a French representative, a significant number of illegally produced 
homemade pyrotechnic articles were found in France over the past two years. 
These articles were primarily based on black powder, and in some cases, 
authorities observed the addition of aluminium to create homemade 
pyrotechnics that are used like bombs.790 While national authorities' 
representatives were unable to provide any official data on these seizures, they 
reported that this phenomenon was rare prior to the last two years.  

Along this line, a national authority representative pointed at online videos with 
instructions on how to create counterfeit pyrotechnic articles.791 The same 
representative indicated that counterfeiting is a widely observed and significant 
phenomenon in the products seized in France. However, authorities lack 
sufficient information to determine whether these counterfeit articles originate 

784   Interview with one Member State’s authority; Sénat, Rapport d'information n° 521 (2023-2024), 2024. 

Link 

785   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

786   Ibid. 
787   Ibid. 
788   Ibid. 
789   Ibid.  
790   Interview with four authorities of one Member States.  
791   Ibid. 

185 

 
 
 
 
from within France or from abroad.792 French national authorities indicate that 
the most commonly imitated categories, include firecrackers with fuses, rockets 
and bombs similar to F3/F4 category pyrotechnics, particularly regarding the 
quantities of active material.793 

Another national authority representative reported that in the Nièvre region, an 
individual was arrested for manufacturing homemade pyrotechnic bombs and 
sharing his methods on YouTube. The case, which was initiated following a 
report from the Prefecture, the Service central des armes et explosifs (‘Central 
service of weapons and explosives’, hereinafter SCAE), and the Plateau 
d'investigation sur les explosifs et les armes à feu (‘Investigation platform on 
explosives and firearms’ hereinafter PIXAF), remains open. Regarding the 
challenges faced by national authorities in addressing the illegal manufacture of 
pyrotechnics, the representative noted that there are only a few reports 
submitted to the authorities, with only one economic operator reporting incidents 
to the national point of contact, PIXAF.794 

According to a French industry representative, French companies produce 
fireworks for recreational purposes and comply with regulations.795 Their main 
concern, on the other hand, is that foreign companies sell F4 fireworks online to 
buyers in France without complying with the same legal requirements as French 
companies. The same industry representative highlighted that many companies 
in France avoid manufacturing ‘multi-shot roman candles’ type of fireworks, to 
avoid being associated with criminal activities, as these articles appear to be 
often misused.796  

Overall, based on the stakeholders consulted, France is facing a rise in the 
illegal production of homemade pyrotechnic articles. Counterfeit articles 
are also being seized in French territory, but authorities cannot determine 
whether they are manufactured in France or abroad.  

Diversion 

According to the Direction Nationale du Renseignement Territorial (National 
Directorate of Territorial Intelligence), the most common forms of diversion of 
pyrotechnics involve traders, such as general food stores, bazaars, and prank 
shops, who fail to maintain the required registers and verify the necessary 
fireworks certifications, and individuals who purchase directly from third 
countries or order online through foreign web-sites that do not require evidence 

792   Ibid. 
793   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

794   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

795   Interview with one industry organisation/ industry representative association. 
796   Ibid. 

186 

 
 
 
 
of compliance with legal requirements.797 Similarly, customs authorities report 
that the most common form of diversion that they encounter involves the import 
of pyrotechnic articles into the country from other Member States without 
customs authorisations. These articles are typically transported via express and 
postal freight or in personal vehicles.798  

The scale of the cross-border illegal trade of pyrotechnics is reflected in figures 
provided by the French authorities, which report that customs authorities seized 
56,000 pyrotechnic articles in 2023, and 42,000 in 2024.799 According to French 
Authorities, none of these were produced in France.800 The majority originated 
from other Member States, with Poland accounting for 50% of the total. During 
a special operation in the days leading up to 14 July 2025, 15,000 fireworks 
were seized in the Paris region, 10,000 of which came from Poland.801 

More specifically, national enforcement authorities have identified significant 
challenges posed by illegal online sales of pyrotechnics, where a significant part 
of the diversion of pyrotechnics seems to take place.802 In particular, the French 
authorities reported that an estimated 50% - 70% of pyrotechnics used for 
committing illegal acts have been obtained online,803 and an interview with 
multiple law enforcement authorities highlighted how market places and social 
media platforms play a significant role in the online sale of illegal 
pyrotechnics.804 In particular, as noted by multiple national authorities’ 
representatives, web shops do not consistently verify whether buyers possess 
the required expertise or meet minimum age requirements.805  

Additionally, pyrotechnics purchased online are often shipped via standard 
postal services and because of the large quantities of packages to intercept and 
control and the fact that sellers frequently disguise parcels (e.g. as wine, by 
displaying clothing brand logos on the package) authorities face serious 
challenges in detecting illegal flows.806  

National representatives also reported particular challenges in monitoring 
transactions conducted through social media platforms, which are frequently 
used for illegal pyrotechnic sales, as these are informal exchanges rather than 
official transactions like those on online marketplaces. 807 French national 

797   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

798   Ibid. 
799   Ibid. 
800   Ibid.  
801   Ibid.  
802   Interview with four authorities of one Member States.  
803   Survey addressed to NCAs: one Member State.  
804   Interview with four authorities of one Member States.  
805   Ibid 
806   Ibid; Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

807   Interview with four authorities of one Member States.  

187 

 
 
 
 
authorities reported a significant rise in the use of instant or encrypted 
messaging services to bypass regulations, including those on sales registration 
and sales to minors.808 According to French Authorities, the Office of Anti-
Cybercrime (OFAC), has launched an investigation into the sale of firework 
mortars on Snapchat. In 2025, this investigation led to the identification of an 
account illegally selling firework mortars ahead of the July 14 festivities, 
resulting in the discovery of 43 firework mortars at the residence of the 
account’s owner.809 

According to industry and national authority representatives, cross-border online 
sales of pyrotechnic articles, particularly from countries with lower prices and 
more relaxed regulations, for instance, regarding age limits, safety standards, or 
required expertise, pose significant challenges in preventing the diversion of 
illegal pyrotechnics.810 Since these online sellers are based outside France, 
French authorities have limited jurisdiction on such cases, and therefore 
struggle to take direct action against them.811 On the other hand, the capacity of 
authorities in the country of origin to address the issue is often reported to be 
limited. 812 

In addition to illegal cross-border online sales, a national authority reported that, 
in many cases, perpetrators purchased large quantities of pyrotechnic articles in 
Eastern European countries, including Germany and Poland, and transported 
them by road for resale in France. According to French authorities, between 
20/12/24 and 02/01/25, the Haut Rhin Departmental Gendarmerie Group seized 
507 kg of pyrotechnic articles purchased this way.813 However, French 
authorities indicate, that overall, they lack the capacity to effectively control, 
target, and seize illegal pyrotechnics entering France from abroad.814 No other 
internal security force, apart from the customs services, have the capacity to 
inspect freight.815 These inspections rely on visual targeting of parcels and 
through cooperation with express and postal freight operators. 816 Checks are 
particularly carried out during special control operations around high-demand 
periods, such as Bastille Day and New Year’s celebrations. 817 However, 
according to French national authorities, the capacity of the customs services is 
limited by the absence of a mandatory authorisation system for transporting 

808   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

809   Ibid. 
810   Interview with four authorities of one Member States and two industry organisations/ industry 

representative associations.= 

811   Interview with four authorities of one Member States.  
812   Ibid. 
813   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

814   Interview with four authorities of one Member States and one one industry organisation/ industry 

representative association. = 

815   Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

816   Ibid. 
817   Ibid. 

188 

 
 
 
 
pyrotechnic articles within the EU.818 This is juxtaposed with imports from third 
countries, which are required to have an authorisation issued by the customs. 
This allows the authorities to target and control illegal flows more precisely. 819 

The capacity of French authorities to control illegal flows of pyrotechnic articles 
into France is particularly important, as an industry representative noted 
significant differences in purchase requirements across EU Member States. For 
instance, while buyers in France must be over eighteen to purchase an F2 
pyrotechnic, the age restriction might be different in other countries.820 A 
national authority representative also noted that assessments by different 
notified bodies are not consistent. As a result, one body might classify an article 
as F4, requiring specialised knowledge, while another might classify the same 
article as F3, which can be purchased without such requirements.821 

Overall, stakeholders reported challenges with the illegal online trade of 
pyrotechnics, particularly involving cross-border sales from countries 
with less strict regulations than those in France. 

Good practices 

For what concerns good practices, in France there is a requirement for the 
seller to register the ID of the buyer for specific pyrotechnic articles 
defined by the Ministry of Interior as ‘more dangerous’.822 According to 
industry representatives, French authorities are exploring the development of an 
online central registry which, according to the representative, would allow 
authorities to check the information of the buyers but also, potentially, the 
seller’s certifications.823  

According to the same industry representative, in France, the Code de la 
Défense requires that sites producing and storing explosive and pyrotechnic 
articles should be secured with measures such as alarm systems. On this 
regard, French authorities are currently working to modernise these regulations 
to better address today’s security context.824 

818   Ibid. 
819   Ibid. 
820   Interview with one industry organisation/ industry representative association.  
821   Interview with four authorities of one Member States.  
822   Interview with one industry organisation/ industry representative association. 
823   Ibid. 
824   Ibid. 

189 

 
 
 
 
Spain 

Context 

When examining the security risks posed by the criminal misuse of 
pyrotechnics, Spain, being one of the largest producers825 of pyrotechnic 
articles and having a strong cultural tradition of fireworks, is a country 
worth examining in greater depth. Spain has a strong tradition of using 
pyrotechnics, especially in cultural and religious events. One notable example is 
the widespread use of F4 flash bangers in mascletàs, a type of pyrotechnic 
display characterised by a steadily intensifying rhythm and explosion pattern, 
culminating in a dramatic finale.826 These displays are primarily auditory rather 
than visual, and are especially popular in Valencia, as well as other regions of 
Spain. In addition to large-scale events, there is a more limited but notable use 
of F4 flash bangers in private celebrations such as weddings, baptisms, and 
First Holy Communions.827 A 2016 study on F4 flash bangers indicated that 
approximately 300,000 units of F4 articles were used in fireworks displays, 
particularly in the context of mascletàs and religious festivities.828 According 
Spanish representatives, there is, also, a growing concern over the use of 
pyrotechnics at sporting events such as football matches, which raises some 
security and safety issues.829  

Regarding the production of pyrotechnics, the Spanish fireworks culture 
creates demand and drives domestic production, ranking the country 
among the top EU producers of pyrotechnic articles. The production of 
pyrotechnics in Spain is largely artisanal, with small batches and manual 
processes that lack advanced technologies.830 A 2016 study indicated that 
Spain, along with Italy, is one of the top producers of F4 flash bangers, with 
around 50 manufacturers, and between 300,000 and 400,000 units produced 
per annum, valued at approximately €6 million to €7 million (see table below).831 
Furthermore, Spain's average production value of fireworks, at €28.6 million, 

825   Interview with one Member State’s authority. 
826   DJS, 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, 
2016. 

827   DJS, 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, 
2016. 

828   DJS, 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, 
2016. 

829   Interview with one Member State’s authority. 
830   Interview with one industry organisation/ industry representative association. 
831   DJS, 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, 
2016. 

190 

 
 
 
 
accounted for approximately 26% of the overall average EU production value of 
€109 million during the period from 2003 to 2022.832 

Table 5 Spanish production of F4 flash bangers (2016) 

Manufacturers 

50 

Units 
per annum 

produced 

Value of the entire 
production 
(annual) 

300,000 – 400,000 

€6 – €7 million 

Source: 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, 
2016. 

The strong culture of fireworks in Spain has sometimes led to the illegal use of 
pyrotechnics during festivities, such as in 2024, when authorities seized 390 
illegal pyrotechnic articles during the Fallas festival in Valencia. 833 In the same 
year, following the police intervention, prohibited pyrotechnic articles were 
seized, and the Guardia Civil conducted a study which concluded that the 
majority of the articles had likely been manufactured illegally.834 In 2025, 
Spanish authorities responded to the phenomenon by increasing inspections in 
selling points and during the festivities to verify compliance with the regulations 
in the marketing "of pyrotechnic materials and devices".835 According to an 
industry representative, this campaign has led to the reduction of illegal use.836 
The same industry representative reported isolated incidents of explosive 
articles, such as high-powered salutes, pyrotechnics producing a loud noise and 
a flash,837 being used during riots or clashes with the police as improvised 
explosive devices. They also identified a risk of accidental explosions from 
powerful illegal products being handled in private residences.838 

Despite high production levels and a strong fireworks culture, stakeholders 
interviewed report that Spain does not face significant issues with systematic 
criminal use of pyrotechnics.839 The ban on online sales with direct home 
delivery in the Spanish territory,840 the central role of a single national authority, 

832   European Commission, Evaluation study of Pyrotechnics’ Legislation. 
833   Levante, Las fallas movilizan a 6.500 policías con el foco puesto en combatir la pirotecnia ilegal. Link; 

Levante, Incautan hasta 390 artículos de pirotecnia ilegales a tres holandeses. Link 

834   Guardia Civil, Weapons and Explosive Central Inspectorate Report on the Seizure in Public Areas of 
Counterfeit and Illegally Manufactured Pyrotechnics, 2024. Source not available to the general public. 
835   Levante, Las fallas movilizan a 6.500 policías con el foco puesto en combatir la pirotecnia ilegal. Link 
836   Interview with one industry organisation/ industry representative association 
837   Elevated Fireworks, Salute Fireworks: The Loudest Booms in the Sky. Link. 
838   Interview with one industry organisation/ industry representative association 
839   Interviews with two authorities of one Member State, one industry organisation/industry representative 
association and one Member State's representative part of an EU-level instrument; ; survey addressed 
to NCAs: one Member State;  ; survey addressed to industry: one response.  

840   Interview with one Member State’s authority. 

191 

 
 
 
 
the Guardia Civil, in cases of explosives and pyrotechnic articles841 and the 
implementation of a certification card for pyrotechnics experts,842 has been 
recognised as a good practice adopted by Spain.  

As reported by a Spanish representatives, incidents such as ATM attacks and 
extortion, which have been reported in other Member States, seem to be rare 
and considered isolated cases.843 Notably, the few reported ATM attacks 
appear to involve legally purchased pyrotechnics that were later modified.844 
According to the input collected through the stakeholder consultation, 
pyrotechnics do not seem to be commonly used by organised criminal groups to 
commit offences.845 Overall, according to the Spanish representative, there 
appears to be no identifiable security risks within Spain’s pyrotechnics industry 
that could be exploited by organised crime, and no current trend of using 
pyrotechnic products for criminal activities.846 According to another Spanish 
representative interviewed, the risk of using illegal fireworks for terrorist 
purposes is low.847 This low misuse rate is largely attributed to Spain’s robust 
administrative controls and regulatory framework,848 which apply to the 
manufacturing, distribution, purchase and use of pyrotechnic articles. 

According to the representatives interviewed, obtaining an authorisation to 
manufacture, store, and sell pyrotechnic articles in Spain is a difficult, complex, 
and costly process.849 Unlike other Member States, Spain regulates 
pyrotechnics, especially category F4 articles restricted to professional use, 
almost as strictly as explosives, imposing substantial penal and administrative 
sanctions. 850 In Spain, the non-compliant sale of F4 pyrotechnics is punishable 
by up to 2 years in prison, fines up to €600,000, closure of establishments for 
up to 2 years, and seizure of the materials.851 Moreover, every pyrotechnic 
display requires prior authorisation from the Guardia Civil, and the Spanish 
legislation imposes strict sanctions for the misuse of pyrotechnics.852 
Additionally, online sales of pyrotechnic articles with direct home delivery are 
completely prohibited in Spain, as purchases must be collected in person. 

841   Interview with one Member State’s authority. 
842   Interviews with authorities of two Member States.  
843   Interview with one Member State’s authority. 
844   Interview with one Member State’s authority. 
845   Interview with one Member State’s authority. 
846 Interview with one Member State’s authority. 
847   Interview with one Member State’s authority. 
848   Interview with one Member State’s authority. 
849   Interview with one Member State’s authority. 
850   Interviews with two authorities of one Member State; input from authorities of one Member States  at 

the workshop organised for this study.  

851   Oxford Research, Study on the illegal sales of F4 pyrotechnics articles destined for professional users 

to the general public, 2019. 

852   Interview with one Member State’s authority. 

192 

 
 
 
 
Finally, in Spain authorisation is always needed for import, transit, and transfer 
pyrotechnic products.853  

As a result, Spanish representatives report a very low prevalence of illegal 
trade, involving mostly F4 articles, with a total of four cases of illegal trade 
identified over the past 5-10 years by the Central Division of Weapons and 
Explosives of the Guardia Civil in Spain.854 National authorities surveyed 
characterised the Illegal manufacturing, diversion, illegal trade, and misuse of 
pyrotechnics for illegal acts as minimal issues in Spain.855 Over the past five 
years, the authorities have not observed any significant increase in these 
phenomena.856 Overall, the magnitude of the illegal fireworks market in Spain is 
reported to be not significant, less than 10% of the legal market of fireworks.857  

Illegal manufacturing 

According to a Spanish representative, due to strict regulation and oversight 
from the Spanish authorities, there seems to be no evident issues with illegal 
manufacturing of pyrotechnic articles.858 

According to the Spanish representative, illegal production would primarily 
concern homemade fireworks, given that individuals can theoretically 
manufacture them from freely available F1, F2 and F3 materials.859 Yet, strict 
regulations apply to the explosive mass that an individual can possess, limiting 
it to 10 kg of net explosive content (NEC) of pyrotechnic articles of categories 
F1, F2, F3, T1 and P1.860 Furthermore,  criminals typically seek materials found 
in F4 pyrotechnics rather than the ones found in the freely available F1, F2 and 
F3 ones. Thus, while it is theoretically possible to create pyrotechnic articles at 
home using these materials, it is difficult to do so, and in Spain, these cases are 
characterised as rare.861  

Following the 2024 Fallas festival in Valencia,862  a Spanish authority conducted 
a study on articles suspected of being manufactured illegally. The study 
revealed that many of the pyrotechnic articles’ markings had been fraudulently 
applied to appear compliant with the manufacturing regulations and that, in 

853   Interview  with  one  Member  State’s  authority.;  input  from  authorities  of  one  Member  States    at  the 

workshop organised for this study.  

854   Interview with authorities of one Member States.  
855   Survey addressed to NCAs: one Member State.  
856   Survey addressed to NCAs: one Member State.  
857   Survey addressed to NCAs: one Member State. ). 
858   Interview with one Member State’s authority. 
859  Interview with one Member State’s authority. 
860   Ministry of Interior, Use of pyrotechnic articles of categories F1, F2, F3, T1, P1, Link; Interview with ES 

Law Enforcement Representatives (Guardia civil). 

861   Interview with one Member State’s authority.  
862   Levante, Las fallas movilizan a 6.500 policías con el foco puesto en combatir la pirotecnia ilegal. Link; 

Levante, Incautan hasta 390 artículos de pirotecnia ilegales a tres holandeses. Link 

193 

 
 
 
 
reality, they had not been produced in accordance with the standards required 
by the Pyrotechnic Article Directive 2013/29/EU. The study did indeed conclude 
that the articles were manufactured illegally, though it remained unclear whether 
in Spain or abroad.863 Despite not being able to determine the manufacturing 
country with certainty, many of the articles examined were fraudulently 
classified to appear as if they were certified by the Official Laboratory Jose 
Maria De Madariaga (LOM) in Madrid, a Spanish notified body recognised by 
the European Commission for the Pyrotechnic Article Directive 2013/29/EU. 864 
This might suggest that, regardless of the manufacturing country, they were 
produced with the specific intention of being distributed within Spain. 

Diversion 

In 2024, during the Fallas festivities in Valencia, Dutch participants were 
reported to have brought and used “prohibited pyrotechnic material that is 
impossible to access in the usual market, a material that in no case is easy to 
obtain” in Spain.865 An industry representative recognised that “some of the 
illegal products used in Valencia were extremely powerful salutes (containing 
between 100g and 4kg of explosive composition)”.866 Based on the input 
gathered by national authorities and industry representatives, certain issues 
have been identified in the field of diversion primarily linked to the illegal import 
of pyrotechnics across borders, both from other EU Member States and third 
countries, as well as, through online sales often originating from abroad.867 
According to national representatives, individuals can acquire pyrotechnic 
articles from countries with less stringent regulations, bypassing national 
restrictions.868  

One of the main practices reported is that some individuals travel to Spain to 
participate in firework festivals, bringing heavy pyrotechnics from their countries 
of origin and thereby evading Spain’s strict regulatory requirements.869 This has 
been characterised by an industry representative as “extreme pyrotechnics 
tourism”, “where products are purchased in one country and brought into 

863   Guardia Civil, Weapons and Explosive Central Inspectorate Report on the Seizure in Public Areas of 
Counterfeit and Illegally Manufactured Pyrotechnics, 2024. Source not available to the general public. 
864   Guardia Civil, Weapons and Explosive Central Inspectorate Report on the Seizure in Public Areas of 
Counterfeit and Illegally Manufactured Pyrotechnics, 2024. Source not available to the general public. 

865   Levante, Las fallas movilizan a 6.500 policías con el foco puesto en combatir la pirotecnia ilegal. Link; 

Levante, Incautan hasta 390 artículos de pirotecnia ilegales a tres holandeses. Link 

866   Interview with one industry organisation/ industry representative association.  
867   Interview with one Member State’s authority; survey addressed to NCAs: responses from two authorities 
of  one  Member  State;    survey  with  industry  organisation/  industry  representative  association:  one 
response.  

868   Interview with one Member State’s authority; survey addressed to NCAs:  one Member State. 
869   Interview with one EU agency; survey addressed to NCAs: one Member State.  

194 

 
 
 
 
another for unauthorised use, or shipped via courier to temporary addresses to 
be picked up just before their intended use.”870 

Another method involves online sales with direct home delivery. According to a 
Spanish representative, more than 70% of the fireworks used in illegal acts 
were obtained online.871 Regarding the origin of these products, according to an 
industry representative, most of them come from unauthorised operators; they 
lack CE marking or belong to categories that can be sold only to 
professionals.872 

According to stakeholders interviewed, pyrotechnics are purchased online often 
from abroad, in countries where online sale and delivery are not prohibited or 
controls are more relaxed, and are delivered directly to buyers’ homes in Spain 
via courier services.873 This makes enforcement and checks more challenging. 
According to an industry representative, these practices take advantage of the 
free movement of goods within the EU or the lack of systematic customs 
inspections for small shipments.874  

On the contrary, in Spain, the delivery of pyrotechnics, legal or illegal, by mail is 
strictly prohibited. Articles must be collected in person from legally authorised 
shops that are strictly regulated by the authorities and where the buyer’s identity 
and age are checked.875 Authorised establishments risk losing their licence and 
business if they engage in mail or parcel delivery of pyrotechnic articles.876 Yet, 
an industry representative indicated that despite the prohibition, there are well-
known platforms operating in Spain that openly sell and ship pyrotechnics from 
third countries.877 

According to national authorities, there are no specific measures in place to 
detect courier service transfers of illegal pyrotechnics acquired online. One of 
the main challenges in preventing the online trade of illegal pyrotechnics is the 
limited cooperation from major online platforms.878 National representatives 
have indicated that e-commerce and social media platforms, messaging apps 
and dark web markets are the most difficult to monitor and regulate in relation to 
illegal online sales of pyrotechnics.879 An industry representative noted that 
another challenge is the absence of effective means to take action against 

870   Interview with one industry organisation/ industry representative association 
871   Survey addressed to NCAs: one Member State.  
872   Interview with one industry organisation/ industry representative association. 
873   Interview  with  one  Member  State’s  authority  and  one  industry  organisation/  industry  representative 

association; survey addressed to NCAs: one Member State.  

874   Interview with one industry organisation/ industry representative association. 
875   Survey  addressed  to  NCAs:  one  Member  State.  ;  Interview  with  one  industry  organisation/  industry 

representative association.  

876   Interview with one Member State’s authority. 
877   Interview with one industry organisation/ industry representative association. 
878   Interview with one Member State’s authority. 
879   Survey addressed to NCAs: one Member State.  

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platforms that offer illegal shipping. These platforms often change names and 
domains to avoid being blocked by authorities.880 However, national authorities 
report that there is effective cooperation with shipping companies when there 
are doubts about the nature of a product. 881 

Good practices 

As already mentioned, Spain has prohibited the online sales of pyrotechnic 
articles with shipping directly to end users. Purchasers are required to 
collect the articles in person from the physical store, where their identity and 
age are verified, ensuring compliance with all legal requirements.882 This 
practice has been welcomed by other Member States as well. According to 
French representatives, this strict regulation enables a more effective control 
and monitoring of the pyrotechnics market. For this reason, in 2023, France 
proposed a similar prohibition of online sales and deliveries.883 

Another good practice identified by Spanish authorities, but also a Dutch 
national authority representative884 is the fact that in Spain, the Guardia Civil is 
the only law enforcement body with full competencies on explosives, 
pyrotechnic articles, weapons and ammunitions.885 The entire pyrotechnics 
domain (supervision, import, product control, system control, etc) falls under the 
jurisdiction of the Guardia Civil.886 Furthermore, the Guardia Civil has trained a 
number of operatives in the administrative control of explosives, pyrotechnic 
articles, weapons, and ammunition. These operatives, designated as 
Specialists in Weapons and Explosives, are assigned to dedicated Weapons 
and Explosives Inspection Offices located throughout Spain.887 While in other 
Member States, responsibilities may be fragmented among multiple authorities, 
the Spanish Guardia Civil has a central role and its specialists can carry out 
controls on any type of transaction related to weapons, explosives, pyrotechnics 
and ammunition in the whole of Spanish territory (entry points, airports, etc.).888  

Finally, Spain was the first country to implement a certification card for 
pyrotechnics experts (Carné de experto). There are three types of expert 
certifications: the first is for the execution of pyrotechnic shows, covering T2 
articles; the second is for the use of pyrotechnic articles of category T2 in non-

880   Interview with one industry organisation/ industry representative association. 
881   Interview with one Member State’s authority. 
882   Survey  addressed  to  NCAs:  one  Member  State;    interview  with  one  industry  organisation/  industry 

representative association.  

883   Interview with one Member State’s authority; Sénat, Rapport d'information n° 521 (2023-2024), 2024. 

Link  

884   Interview with one Member State’s authority. 
885   Survey addressed to NCAs: one Member State.  
886   Interview with one Member State’s authority. 
887   Survey addressed to NCAs: one Member State.  
888   Interview with one Member State’s authority; survey with ES Law Enforcement Representative (Central 

Division of Weapons and Explosives of the Guardia Civil). 

196 

 
 
 
 
pyrotechnic shows; and the third is for the use of pyrotechnic articles of 
Category P2. All three licences require, amongst other things, theoretical and 
practical training, and a medical certificate proving the holder is in a suitable 
psychological state to use pyrotechnics. Concerning the first expert licence 
intended for pyrotechnic shows, the expert must first hold an apprentice licence. 
Furthermore, the P2 certification is specific to each type of P2 category 
pyrotechnic article and is not a generic certification for the entire P2 category.889 
Similar to the Spanish model, a Pyro Pass is now being introduced in the 
Benelux countries,890 which foresees mandatory checks by the seller and aims 
to contribute to a more reliable market.891 

889   Real Decreto 989/2015, de 30 de octubre, por el que se aprueba el Reglamento de artículos pirotécnicos 

y cartuchería. 

890   Interview with one Member State’s authority. 
891   Interview with one Member State’s authority. 

197 

 
 
 
 
 
Annex IV Case study B - Explosions across borders: 
Security challenges in EU Member States most 
affected by pyrotechnic misuse 

Introduction  

This case study focuses on EU Member States most affected by the 
security issues posed by the criminal misuse of pyrotechnics. By zooming 
into the challenges faced in these Member States, this case study provides 
input for the updated picture of the security, cross-border cooperation and 
information exchange, and the role of online sales. Due to indications of illegal 
trade of pyrotechnic articles used in criminal acts in and to the case study 
countries, this case study will elaborate on this aspect as well. The focus is 
mainly on Category F4 fireworks, but indications of security issues posed by 
other categories have also been investigated. The geographical scope of the 
case study entails Belgium, Germany, the Netherlands, France and Sweden. A 
more in-depth analysis has been conducted on Belgium, Germany and the 
Netherlands due to recent cross-border cases demonstrating linkages on 
security issues between the three Member States. As stakeholders from 
different Member States have provided input to varying degrees, the length and 
level of detail in the case study and the country fiches have been reflected 
accordingly. The detailed country fiches are provided in Annex V. 

Types of pyrotechnic articles used in criminal acts 

There has been a shift from hand grenades to heavy pyrotechnic articles such 
as flash bangers, in organised crime in the past decades.892 Hand grenades are 
less readily available due to their inclusion in weapons legislation in Member 
States.893 In a similar vein, the rules and sanctions on firearms seem to have 
contributed to the shift to more accessible and less penalised articles for 
criminal acts.894 High-risk pyrotechnic articles are available on the legal market, 
but also largely on the illegal “parallel market” whereby the prices of, for 
example, Cobras are relatively low. The availability and low prices of high-risk 
pyrotechnic fuels their popularity in criminal acts.895 

The research carried out by the study team has confirmed the prominent role of 
category F4 fireworks, such as flash bangers, as one of the main pyrotechnic 
articles for criminal misuse.896 Specifically, 72% of the Member States’ 

892   Europol SOCTA 2025; interviews with authorities of three Member States; Regeringens proposition 

2023/24:33, Skjutvapen och explosiva varor - skärpta straff för de allvarligare brotten, Link; See also: 
Link 

893   Interviews with a CSO, a EU agency and authorities of two Member States. 
894   Interviews with a CSO, a EU agency and competent authorities of two Member States. 
895   Interviews with authorities of five Member States; Documentary Explosief Nederland, available at: Link 
896   Interviews with authorities of two Member States. 

198 

 
 
 
 
responses to the survey assessed category F4 pyrotechnics as most commonly 
used in criminal acts. It has been highlighted by Dutch authorities that the 
concentration of flash powder in the intercepted flash bangers  seems to 
be on the rise. 897 It is estimated by the Dutch authorities that 80-90% of flash 
bangers  used in the Netherlands are illegally manufactured or diverted.898 The 
power of a category F4 firework and its relatively low cost contribute to its 
popular use in criminal acts. It has been observed that a category F4 firework 
can have the same explosive power as a hand grenade, which renders it a 
more attractive option since penalties and sanctions are less strict.899 

Some indications of the misuse of category F3 pyrotechnic articles have 
also been observed.900 Member States’ survey responses demonstrate that, in 
addition to category F4 pyrotechnics, 62% respondents consider category F3 
pyrotechnics to be commonly used in criminal acts. This has also been reported 
by the respondents of the industry survey; 81% considered category F3 
fireworks to be used in criminal acts. Moreover, 45% of the industry 
respondents reported having witnessed an increase in the criminal misuse of 
pyrotechnic articles (other than category F4) in the past five years to some 
extent. There was more fragmentation among the Member States’ respondents. 
Member States’ authorities have stated that the availability of category F4 
pyrotechnics is more interesting to criminals due to their greater explosive 
power than category F3 articles.901 Nevertheless, should further restrictions be 
placed on category F4 articles, criminals might shift towards the use of category 
F3 articles. 

The shells of category F4 fireworks have also been mentioned as posing a 
risk to public security, especially in the Netherlands.902 Shells of category F4 
pyrotechnics are spherical articles, with diameters ranging from 5 to 30cm, with 
a launching charge designed to be shot from a mortar. These articles can 
produce effects over a distance of 100–200 meters.903 Some F4 shells still 
originate from China, although others come from Spain, Italy, and France—
often entering the Netherlands without appropriate labelling. These 
pyrotechnics, particularly salute shells, are adapted for criminal use by 
modifying their ignition methods, such as instantaneous fuses, to be able to use 
the articles without being hurt.904 The shells are then mainly used as projectiles 
against law enforcement authorities in e.g. riots and protests, and football-
related incidents. It should be noted that the criminal misuse of shells has been 

897   The flash bangers that are intercepted are Butterflies with a maximum NEM of 10- 15 g flash powder, 

Cobra 6 with 28-30 g flash powder, and Cobra 20 has 200 g of flash powder. 

898   Interview with authorities of one Member State.  
899   Interview with authorities of one Member State. 
900   Ibid. 
901   Ibid. 
902   Interview with with authorities of one Member State. 
903   Interviews with with authorities of one Member State, an EU agency and a Member State's 

representative part of an EU-level instrument; Environmental Crime Threat Assessment 2021, 
Netherlands Police, Link; Documentary Explosief Nederland, Link  

904   Interviews with with authorities of one Member State, an EU agency and a Member State's 

representative part of an EU-level instrument; Environmental Crime Threat Assessment 2021, 
Netherlands Police, Link; Documentary Explosief Nederland, Link  

199 

 
 
 
 
mentioned only by stakeholders in the Netherlands. In addition, the criminal 
misuse of categories P1 and P2 have been mentioned in the survey targeted to 
both Member States and the industry, however no further indications have been 
found through interviews or desk research. 

There are some indications that organised crime groups modify smoke 
flares and heavy firecrackers to cause more damage. This has been 
demonstrated by the use of flash bangers (previously marketed as Cobra 6) 
with a bottle of petrol, or the removal of flash powder from Cobras to complete 
IEDs.905 In more technical terms, such a flash banger has a plastic cap that is 
quite easy to open to extract the flash powder. The flash powder could then be 
used as an ignition component for more comprehensive IEDs or less 
professionally constructed IEDs, which are observed to be used in small-scale 
explosions. 906 In light of this, the misuse of the type of pyrotechnics varies 
somewhat between the case study countries. In Germany and Sweden, the 
misuse of pyrotechnics by criminals is mainly related to the flash powder of the 
flash bangers instead of the misuse of the whole firework.907 Whereas, in the 
Netherlands, France and Belgium, both the misuse of flash bangers as well as 
IEDs constructed with pyrotechnic articles are more prominent.908 

Types of criminal acts 

Violence and intimidation 

The research demonstrates that high-risk pyrotechnic articles are used in the 
commission of violence and intimidation. This manifests in different ways, and 
various actors are involved. First, high-risk pyrotechnic articles appear to be 
used in criminal acts related to disturbances of public order. Examples 
mentioned by stakeholders include mainly riots and violence against law 
enforcement authorities. Mainly, category F4 fireworks are used to attack 
authorities with violent means, resulting in physical and psychological injuries to 
law enforcement authorities.909 Similarly, property damage is a common 
instance of criminal misuse of pyrotechnics. In several cases, flash bangers 
have been used to blow up bus shelters, garbage bins, mailboxes, front doors, 
and hallways. This has been observed not only in public spaces, but also in 
private properties and residential neighbourhoods.910 Relatedly to property 
damage, pyrotechnics have increasingly been used in personal disputes 
and conflicts. For example, in the Netherlands, there have been multiple cases 
of ex-partners using flash bangers to place at the apartment or house of their 

905   Interviews with authorities of two Member States; Non-paper between the Netherlands and France. 
906   Interviews with authorities of one Member State. 
907   Interviews with authorities of two Member States and one industry organisation/ industry 

representative association. 

908   Interviews with authorities of three Member States. 
909   Interviews with authorities of three Member States; follow up questionnaire addressed to national 

competent authorities: response from one Member State.  

910   Interviews with authorities of two Member States. 

200 

 
 
 
 
former partners with the aim of retaliation or intimidation. This is also linked to 
other aggressive behaviour, such as stalking and domestic abuse.911 

Property damage caused by the criminal misuse of pyrotechnics results in 
collateral physical and emotional damage to bystanders and citizens. In the 
Netherlands, authorities have estimated that property damage by the criminal 
misuse of pyrotechnics amounts to 35 million euros annually.912 In a similar 
vein, the number of attacks with different types of improvised explosive devices 
(e.g., gas bottles combined with pyrotechnics) is increasing rapidly. In 2021, 
212 attacks took place, and in 2024, the number had increased more than 
sixfold to a (provisional) peak of 1,413 attacks, of which more than 1,000 were 
in homes. In these explosions, several victims and perpetrators have been 
seriously injured.913 This upward trend has also been observed in Belgium, 
Sweden and France. Germany has not reported major issues with property 
damage or attacks against law enforcement authorities caused by pyrotechnics. 

Second, high-risk pyrotechnic articles are commonly misused by 
organised crime groups. Pyrotechnic articles are used by rival organised 
crime groups to intimidate each other and resolve disputes often related to drug 
trafficking. This is demonstrated by several cases observed in port cities, such 
as Antwerp, Rotterdam and Amsterdam where drugs are trafficked into the 
EU.914 Stakeholders have mentioned that this phenomenon is inherently cross-
border and shows warning signs of spillover to multiple Member States where 
linkages with international organised crime are also observed, such as Belgium, 
the Netherlands and Germany.915 In Sweden, the misuse of pyrotechnics has 
also been observed in the organised crime context. Pyrotechnics are placed as 
bombs in and at the entrances of apartment blocks with the aim to intimidate, 
extort and kill.916 

In general, a concerning trend of violence-as-a-service offered by OCGs has 
been pointed out by many national law enforcement authorities as well as, 
Europol.917 OCGs offer this service, whereby targeted killings, attacks, 
intimidation and extortion can be ordered through social media and online 
platforms.918 Similar to different types of violence (e.g. firearms), attacks carried 
out with pyrotechnics or IEDs are increasingly ordered by other OCGs or 
individuals as part of violence-as-a-service. Some Member State authorities 
(such as, the Netherlands and Sweden) have provided comprehensive insights 
on how this service is organised in practice:919 

911   Documentary Explosief Nederland, Link; See also: Link 
912   Interviews with authorities of one Member State. 
913   Ibid. 
914   Interviews with authorities of three Member States. 
915   Ibid. 
916   Interviews with authorities of one Member State; follow up questionnaire addressed to national 

competent authorities: response from one Member State. 

917   Europol SOCTA 2025 
918   Case study B; Documentary Explosief Nederland, Link 
919   Interviews with law enforcement authorities of one Member State; Documentary Explosief Nederland, 

Link; See also: Link, Link and Link 

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•  The OCG and the principal criminal in the middle management of the 

organisation, who offers attacks with pyrotechnics; 

•  The middleman (often young individuals under 18), who coordinates the 

“assignment for an attack”. This includes the recruitment of individuals (often 
minors) for carrying out the attack, the verification and timing of the attack, as 
well as, the payment of the rewards; 

•  Runners, who carry out the attack and place the pyrotechnics or IEDs at the 

correct target at the agreed time and date. 

This overview ties closely to the prominent use and involvement of minors 
and youth by OCGs in carrying out attacks with pyrotechnics and IEDs. OCGs 
downplay the criminal side of pyrotechnics, as they are advertised as more 
“harmless” than, for example, explosives and firearms. In combination with 
offering high rewards and quick cash for small jobs, OCGs can appeal to youth 
from deprived neighbourhoods and poor backgrounds.920 The involvement of 
youth is, however, twofold. Some young people are driven by financial gain or 
the assimilation into subcultures, such as drill rap.921 They actively seek 
opportunities to earn money and belong to a certain subculture.922 It has been 
noted by Dutch authorities that a middleman earns around 1500€ per 
assignment, whereas runners earn around 50-250€ per assignment. The 
runners (or sometimes referred to as pawns) are normally aged 11-15.923 

However, youth involvement also occurs through the exploitation 
practices of OCGs. OCGs control and intimidate young people in forcing them 
to carry out explosions on their behalf. This includes forcing young people to 
complete assignments without compensation, and it is often combined with 
threats to their families, which leads to fear among youth.924 The voluntary or 
coerced involvement of youth in carrying out explosions with pyrotechnics in the 
context of organised crime has been observed as particularly prevalent in the 
Netherlands and Sweden, but authorities from France, Germany and Belgium 
have not raised issues in this regard. 

Theft and sabotage 

ATM-attacks have been identified as the most common form of theft and 
sabotage in the past decade. ATM-attacks have been a visible and serious 
issue particularly in the Netherlands, Belgium and Germany.925 Stakeholders 
have observed the use of heavy fireworks such as flash bangers in robbing 
banks by blowing up ATM-machines. Criminals often extract the powder from 
10-20 pyrotechnic articles in making IEDs and other improvised devices. 5 

920   Ibid. 
921   Drill rap is a sub-genre of hip-hop that traditionally includes confrontational and violent lyrics, inciting 

violence and criminality on the street. 

922   Interviews with law enforcement authorities of one Member State; Documentary Explosief Nederland, 

Link 
923   Ibid. 
924   Interviews with authorities of one MemberState; Documentary Explosief Nederland, Link; See also: 

Link, Link, Link and Link 

925   Interviews with authorities oof three Member States; See also: Link, Link and Link 

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kilograms of flash powder is needed for these devices, which can be extracted 
from approximately. 20 pyrotechnic articles rather than using the articles 
themselves.926 There have also been some indications that ATM-attacks could 
also be spreading to Austria, Luxembourg and Switzerland.927 However, this 
has not been investigated further in detail as the countries are out of the scope 
of this case study. 

In the past years, it seems that the prominence of ATM-attacks with 
pyrotechnics has been on the decline. One factor affecting the prevalence and 
attractiveness of ATM-attacks, is the design of the ATM-machines. In some 
Member States (e.g. Netherlands, Belgium and Sweden), attention has been 
focused on the protection of the ATM-machines.928 For example, measures 
such as, colour markings on bills are activated if the machines are opened by 
force.929 In some Member States, ATM-machines entail less protection against 
attacks which might render them more attractive to target. Moreover, Swedish 
authorities have reported that ATM-attacks have not been prominent due to the 
protective measures of ATM-machines but also, the fact that Sweden is not 
connected to the Economic and Monetary Union (EMU) and uses krona as its 
national currency.930 This could demotivate the use of ATM-attacks among 
criminals, as the stolen money could not be laundered outside of the country. 

Linkages to terrorism 

Some national authorities (such as the Netherlands) have mentioned that 
terrorists could use pyrotechnics in manufacturing IEDs.931 This might be 
due to the strict Regulation on Explosives Precursors and the restricted 
availability of traditionally used precursors for IEDs. Additionally, pyrotechnics 
seem more safe to handle by terrorists than fully manufactured IEDs. As with 
OCGs, the online environment plays a role in the use of pyrotechnics by 
terrorists. In jihadist, left-wing and right-wing extremist propaganda, 
pyrotechnics have been featured as an alternative for planning attacks with 
IEDs.932 These developments could be seen in light of the use of pyrotechnics 
by OCGs in ATM-attacks, riots and against law enforcement. This has brought 
more visibility to pyrotechnics in criminal acts, which could lead to the popularity 
of pyrotechnics among terrorists in the future. It was noted that there are cases 
of pyrotechnics being used by terrorists, but not on a large scale.933 In the 
Netherlands, stakeholders mentioned two cases in which there were indications 
that fireworks could be used as a possible means to commit terrorist 

926   Interviews with authorities of two Member States; follow up questionnaire addressed to national 

competent authorities: response from one Member State. 

927   Interviews with authorities of two Member States and an EU agency.  
928   Interviews with authorities of two Member States and an EU agency.  
929   Interviews with authorities of two Member States and an EU agency.  
930   Interviews with authorities of one Member State; follow up questionnaire addressed to national 

competent authorities: response from one Member State. 
931   Interviews with Europol and authorities of one Member State.  
932   Ibid. 
933   Ibid. 

203 

 
 
 
 
violence.934 In other case study countries, national authorities have not raised 
issues regarding pyrotechnics and terrorism, which might also be due to the 
restricted nature of information and data on terrorism. 

Measures taken by Member States 

Some Member States such as, the Netherlands, France, Belgium and 
Germany, have introduced targeted measures to address the growing 
security issues posed by the misuse of pyrotechnics. 

The Netherlands has  adopted the Wet op de Economische Delicten (Act on 
Economic Crimes) in 2025, which enhances the capacity of authorities to 
detect, investigate, and prosecute illegal activities involving pyrotechnics—
directly responding to their misuse in criminal settings.935 Another core measure 
is the implementation of the Pyro Pass-system developed jointly by the 
Netherlands, Belgium, and Luxembourg. The Pyro Pass mandates identity 
verification and administrative record-keeping of pyrotechnic articles for each 
purchase. This supports the sale of pyrotechnics to only authorised individuals 
and deters their use in criminal acts.936 The system is especially relevant to 
category F3 fireworks. 

To further support investigations of criminal acts where pyrotechnics have been 
used, the Netherlands has also developed a mobile application designed to 
improve tracking of fireworks after explosions. The app allows users to visually 
recognise fragments after an explosion by taking a picture, which helps identify 
the type of fireworks involved. The database is being updated with all seized 
fireworks in the Netherlands, and there are plans to expand and translate the 
app for use by other Member States.937 

In terms of enforcement, Dutch customs authorities deploy container X-ray 
scanning at ports to intercept illegal pyrotechnics concealed in shipments, 
stopping dangerous materials from entering domestic circulation.938 

An action plan Landelijk Offensief tegen Explosies addressing violence carried 
out with explosions and pyrotechnics has been developed in the Netherlands. 
This initiative is a collaboration between the Ministry of Justice, Police, Public 
Prosecution Service, Aedes (Housing corporations), municipalities, the 
association of insurers, probation services, and the private sector. The main 
goal of the action plan is to implement and further develop (innovative) 
measures and interventions to sustainably reduce the number of attempted 

934   Interview with authorities of one Member State.  
935   Interviews with authorities of one Member State; see also: Link 
936   Interviews with authorities of one Member State, an EU agency and a  Member State's representative 
part of an EU-level instrument; workshop with stakeholders organised for this study, September 2025; 
See also: Link, and Link  

937   Ibid. 
938   Ibid. 

204 

 
 
 
 
targeted attacks using explosives on homes, business premises and 
vehicles.939 

France and the Netherlands have jointly advocated for EU-level action by 
submitting a non-paper recommending targeted restrictions on high-risk 
category F4 fireworks. This specifically calls for a ban on articles such as flash 
bangers and a limitation on the amount of flash powder allowed in such 
products.940 These proposals are aimed at reducing the availability of 
pyrotechnics commonly used in violence and intimidation. France has also 
introduced a ban on the postal delivery of certain pyrotechnics in an effort to 
tackle the illegal trade of pyrotechnics used in criminal acts. 

Germany has responded to security concerns with a comprehensive legal 
framework aligned with the EU Pyrotechnics Directive. National laws and three 
accompanying ordinances provide detailed regulations and clear sanctions for 
violations. This strong legal foundation supports consistent enforcement and 
limits opportunities for criminal misuse.941 

Belgium has a specialised police taskforce on fireworks, which has been 
established to discourage the purchase of illegal fireworks online in Antwerp. 
Citizens who have placed such orders are encouraged to cancel them. Details 
about intelligence methods and operational procedures of the task force are 
deliberately withheld to prevent circumvention of the rules by criminals.942  

939   See: https://open.overheid.nl/documenten/37974468-c6b2-4d1a-a953-f6945373ae3b/file; interview 

with authorities of one Member State.  

940   Workshop with stakeholders organised for this study, September 2025; See: Link 
941   Interviews with authorities of one Member State.  
942   See: https://www.expatica.com/nl/general/police-to-crack-down-on-illegal-firework-orders-online-8040/ 
; https://www.nieuwsblad.be/regio/antwerpen/regio-antwerpen/antwerpen/taskforce-tegen-vuurwerk-
kliste-al-71-jongeren-ook-komende-weken-treden-we-streng-op/40300438.html ;  

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Annex V Country fiches case study B 

Non-deep dive countries 

France 

In recent years, France has faced increasing security risks related to the 
misuse of pyrotechnic articles, particularly in the context of civil unrest. 
Fireworks have been used during riots and public demonstrations not as 
celebratory products, but as a means to attack law enforcement and damage 
public property. One of the most problematic forms of fireworks in this context is 
the multi-shot Roman candle or bundles thereof, which are frequently used to 
incite violence or disrupt public order.943 Illegal pyrotechnic articles are sold 
through social media platforms such as Telegram and Snapchat using a similar 
modus operandi to drugs. Dealers of illegal pyrotechnics offer discounts and 
“bundle” offers to lure more customers.944 The low prices and ease of ordering 
illegal pyrotechnic articles can be seen to entice their unauthorised use. This 
further underpins the many observed instances of misuse of pyrotechnics in 
riots, public disturbances and against the law enforcement authorities. 

In 2024, there were 47 public disturbances involving pyrotechnics, 101 attempts 
on property damage, 18 of which caused damage to security force barracks, 
family zone, etc. and 48 involving personal disputes. Also in 2024, minors 
accounted for 34% of the 175 defendants (only 41 of the cases were 
resolved).945 Recently, two people were killed and approximately. 200 people 
were injured in France during the Champions League win celebrations. 
Fireworks were misused in this context against the law enforcement authorities. 
It is unclear to what extent all injuries have been caused by direct use of 
pyrotechnics; however, at least one police officer was hit by a firework. A total of 
294 people were arrested, although it is unclear how many were arrested 
directly in relation to the misuse of fireworks.946 

In addition to the misuse of pyrotechnics in criminal acts and violence, a 
significant concern lies in the unregulated sale of fireworks through foreign 
online platforms. Many of the F4-category fireworks, intended only for licensed 

943   Interviews with authorities of one Member States; follow up questionnaire addressed to national 

competent authorities: response from one Member State.; See also: 
https://www.euronews.com/2023/07/10/french-authorities-ban-the-transport-and-sale-of-fireworks-
ahead-of-bastille-day, https://www.lemonde.fr/en/france/article/2023/07/02/riots-in-france-how-
fireworks-became-the-staple-weapon-of-rioters_6041588_7.html and 
https://www.france24.com/en/20201012-fireworks-attack-on-french-police-sparks-protest  

944   Ibid. 
945   Interviews with authorities of one Member States and industry organisation/ industry representative 

association; follow up questionnaire addressed to national competent authorities: response from one 
Member State. 

946   See also: https://www.euronews.com/my-europe/2025/06/01/two-people-killed-over-200-injured-in-

champions-league-win-celebrations-in-france  

206 

 
 
 
 
professionals, are sold illegally to unlicensed individuals in France. These sales 
are largely facilitated by online web shops based in other EU Member States, 
such as Poland and the Czechia.947 Stakeholders have stated that there seems 
to be negligence for national age restrictions among sellers in these 
Member States. For example, while the minimum age to purchase F2-category 
fireworks in France is 18, it is only 16 in many other EU Member States. 948 This 
discrepancy allows sellers based outside of France to exploit regulatory 
loopholes and thereby contribute to cross-border security issues. 

The French authorities have reported having seized several tonnes of 
firework mortars in a gendarmerie zone (i.e. rural and suburban areas) in 
July 2023. These fireworks originated from Poland. At the end of December 
2024, 100 kilograms of fireworks were seized, which originated from Germany. 
Another seizure at the same time was carried out, whereby 100 kilograms of 
fireworks and one tube to launch mortars were seized. These articles originated 
from Poland.949 

In addressing the misuse of pyrotechnics in criminal acts and violence, the 
French authorities have implemented restrictions on the use of pyrotechnics 
in certain areas and during specific periods.950 While these measures aim to 
curb the misuse of fireworks, French industry stakeholders have expressed 
concerns regarding the misuse of pyrotechnics and the direct negative impact 
on the French industry.951 Although French law mandates that nearly all sales of 
fireworks be registered with the authorities, these rules can have a limited 
impact on individuals who are already operating outside the legal framework. 
Compounding the issue, the French authorities currently lack the legislative 
tools to block websites hosted outside of France selling pyrotechnics that might 
be legal in other Member States, but illegal in France.952 This risks creating a 
situation where compliant French pyrotechnics companies are unfairly 
penalised, while companies engaging in illegal sale of pyrotechnics outside of 
France continue to operate. 

Sweden 

Sweden has experienced a marked escalation in the misuse of 
pyrotechnic articles, particularly in relation to organised crime, gang 

947   Interviews  with authorities of one Member States and industry organisation/ industry representative 
association; follow up questionnaire addressed to national competent authorities: response from one 
Member State. 

948   Ibid. 
949   Ibid. 
950  Interviews  with authorities of one Member States and industry organisation/ industry representative 

association; follow up questionnaire addressed to national competent authorities: response from one 
Member State..; See also: https://www.euronews.com/2023/07/10/french-authorities-ban-the-
transport-and-sale-of-fireworks-ahead-of-bastille-day  

951  Interviews  with one industry organisation/ industry representative association; workshop with 

stakeholders organised for this study, September 2025.  

952  Interviews with authorities of one Member States and industry organisation/ industry representative 

association; follow up questionnaire addressed to national competent authorities: response from one 
Member State. 

207 

 
 
 
 
conflicts, and public disorder. A major challenge in combating the illegal use 
and trade of fireworks seems to be rooted in regulatory inefficiencies. At the EU 
level, the absence of horizontal regulations limits coordinated enforcement, 
while nationally, the Swedish legal framework struggles to effectively address 
challenges with the collection of evidence of the misuse of pyrotechnics in 
criminal acts, as well as enforcement, particularly for the online environment.953 

Traditionally, criminals in Sweden had easier access to high-powered 
explosives such as TNT, dynamite, and other civil explosives due to the 
country’s demand for such materials in the construction and mining sectors. 
Numerous companies are licensed to handle, store, and use these 
explosives.954 However, this legitimate market has also presented opportunities 
for diversion. Some operators falsely reported full usage of their stock while 
secretly supplying explosives to criminal groups. In response, Swedish 
authorities introduced stricter controls on dynamite. As a result, organised crime 
groups have increasingly turned to alternative means, most notably high-risk 
pyrotechnics, often in combination with smuggled hand grenades, many of 
which originate from the old conflicts in the Western Balkans. While dynamite 
was sometimes purchased in other EU Member States, the diversion and 
misuse mainly occurred within Sweden.955 

The misuse of pyrotechnics is increasingly linked to organised crime and 
gang violence in Sweden. In recent years, there has been a drastic increase in 
criminal disputes where pyrotechnics are used for intimidation, attacks, and 
even improvised explosive devices (IEDs). Pyrotechnics have been weaponised 
in inter-gang conflicts mainly through attacks on family members of rival factions 
as a method of extortion or intimidation. According to police reports, the number 
of IEDs incorporating pyrotechnic materials has grown significantly in just the 
past six months. In nearly half of recent explosions, pyrotechnics were used 
instead of traditional explosives.956 ATM attacks have not constituted a 
significant issue, as cash is not generally highly used in Sweden. Moreover, 
Sweden is not a member of the Economic and Monetary Union (EMU) and uses 
the Swedish krona as its currency. The ATMs in Sweden are also protected, 

953   Interviews authorities of one Member State; ; follow up questionnaire addressed to national competent 
authorities: response from one Member State.; Regeringens proposition 2023/24:33, Skjutvapen och 
explosiva varor - skärpta straff för de allvarligare brotten, available at: 
https://www.regeringen.se/contentassets/db37020030cd47caa67a89e7efe1f272/skjutvapen-och-
explosiva-varor--skarpta-straff-for-de-allvarligare-brotten-prop.-20232433.pdf; see also: 
https://www.politico.eu/article/sweden-fireworks-gang-violence-organized-crime/; workshop with 
stakeholders organised for this study, September 2025. 

954   Ibid. 
955   Ibid. 
956   Interviews with authorities of one Member State; follow up questionnaire addressed to national 
competent authorities: response from one Member State; Regeringens proposition 2023/24:33, 
Skjutvapen och explosiva varor - skärpta straff för de allvarligare brotten, available at: 
https://www.regeringen.se/contentassets/db37020030cd47caa67a89e7efe1f272/skjutvapen-och-
explosiva-varor--skarpta-straff-for-de-allvarligare-brotten-prop.-20232433.pdf; See also: 
https://www.politico.eu/article/sweden-fireworks-gang-violence-organized-crime/ 

208 

 
 
 
 
whereby in the event of an attack, cash would become useless.957 This could 
demotivate the use of ATM-attacks among criminals. 

It is worth mentioning that pyrotechnics in Sweden are used mainly with the 
purpose of frighten, extort and to kill. One method of operation is to emplace 
pyrotechnics by the entrances of apartment blocks or inside the entrances in 
residential areas. The pyrotechnics are either used in their original form or 
manipulated in the form of an IED. One modus operandi for manufacturing IEDs 
is, for example, to empty several bangers in order to achieve a “greater” 
outcome.958 This type of modus operandi results in major structural damages. 
The criminal perpetrators are often young, for example, minors at the age of 
13 to 14. The involvement of youth and minors has become a rising problem 
over the last two to three years. However, the Swedish authorities do not have 
available statistics regarding in how many cases the perpetrators have been 
under the age of 18.959 

The situation is further complicated by the misuse of fireworks in social and 
sports contexts. Over the past two years, 95% of football matches in Sweden 
have seen misuse of pyrotechnics by spectators. These acts have resulted in 
disruption of matches, pyrotechnics being thrown onto the field, and injuries to 
both players and fans.960 

Data from the Swedish customs authorities from 2025 shows that 193 seizures 
of illegal fireworks (involving 175.000 pyrotechnic articles restricted in Sweden) 
have been carried out. Most (approx. 70-90%) of the seized pyrotechnic 
articles originated from online sellers (web shops) in Poland and other EU 
Member States. Other platforms, such as Facebook, TikTok, etc., are used less 
frequently compared to the web shops. 961 The majority of commonly misused 
fireworks in Sweden include bangers, flash bangers, smoke devices, and flares. 
Over 70% of these products are obtained online, mostly from legal suppliers in 
other EU countries, especially Poland.962 Additionally, pyrotechnics are ordered 
and shipped to Sweden in the form of pyro-kits and bangers. These articles are 
typically shipped through postal parcels, making detection and interception 
more difficult. Although most fireworks are imported legally—primarily from 
China—into Sweden by about ten main companies, a significant portion of the 

957   Interviews  with authorities of one Member State; follow up questionnaire addressed to national 

competent authorities: response from one Member State.  

958   Interviews with authorities of one Member State; follow up questionnaire addressed to national 
competent authorities: response from one Member State; Regeringens proposition 2023/24:33, 
Skjutvapen och explosiva varor - skärpta straff för de allvarligare brotten, available at: 
https://www.regeringen.se/contentassets/db37020030cd47caa67a89e7efe1f272/skjutvapen-och-
explosiva-varor--skarpta-straff-for-de-allvarligare-brotten-prop.-20232433.pdf; See also: 
https://www.politico.eu/article/sweden-fireworks-gang-violence-organized-crime/ 

959   Ibid. 
960   Ibid. 
961   Interviews with authorities of one Member State; follow up questionnaire addressed to national 

competent authorities: response from one Member State; workshop with stakeholders organised for 
this study, September 2025.  

962   Interviews with authorities of one Member State. 

209 

 
 
 
 
market, especially for misuse, is supplied illegally from abroad.963 The seizures 
and modus operandi reflect a growing trend in cross-border online sales, often 
involving products that are either prohibited in Sweden or intended solely for 
professional users. 

The Swedish government has made efforts in responding to the security 
risks posed by the misuse of pyrotechnics. Importers of fireworks must be 
pre-authorised by the Swedish Civil Contingency Agency, and all imports of 
restricted pyrotechnic articles from other EU Member States require special 
permission. Customs authorities play an active role in verifying that importers 
are registered and authorised. However, most checks apply to wholesalers and 
retailers, not individuals, leaving a regulatory gap in personal imports, especially 
via online platforms.964 

Deep-dive countries 

Netherlands 

Context 

In the Netherlands, fireworks have been traditionally used during official 
festivities and smaller “city” festivals. In the 20th century, fireworks became a 
popular way to celebrate New Year’s Eve. Fireworks have solidified as a symbol 
of fun activities and celebrations to many Dutch people. Additionally, the use of 
heavy fireworks is used by people in the rural areas and suburbs of cities for 
their own entertainment.965 However, the use of fireworks is currently strictly 
regulated by type and timing in the Netherlands. Category F1 fireworks, such as 
ice fountains, may be used all year round. Category F2 fireworks are permitted 
for consumer use exclusively on New Year’s Eve, between 18:00 and 02:00. 
Category F3 is prohibited for consumer use altogether, while categories F4, T1, 
and T2 are restricted to professional use under permit. These professional 
displays can be authorised for various public and private events throughout the 

963   Interviews with authorities of one Member State; follow up questionnaire addressed to national 

competent authorities: response from one Member State 

964   Interviews with authorities of one Member State; follow up questionnaire addressed to national 
competent authorities: response from one Member State; Regeringens proposition 2023/24:33, 
Skjutvapen och explosiva varor - skärpta straff för de allvarligare brotten, available at: 
https://www.regeringen.se/contentassets/db37020030cd47caa67a89e7efe1f272/skjutvapen-och-
explosiva-varor--skarpta-straff-for-de-allvarligare-brotten-prop.-20232433.pdf; See also: 
https://www.politico.eu/article/sweden-fireworks-gang-violence-organized-crime/ 

965   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 
available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484; See also: 
https://rtvparkstad.nl/nieuws/jouwnieuws/vuurwerk-in-nederland-traditie-overlast-en-geschiedenis/ and 
https://npokennis.nl/longread/7482/sinds-wanneer-hoort-vuurwerk-bij-oud-en-nieuw  

210 

 
 
 
 
year, including festivals, football matches, and weddings, provided appropriate 
safety distances are observed.966 

Despite these regulations, the misuse of fireworks has increased 
significantly. In the past year, the Netherlands recorded a 71% rise in 
pyrotechnic-related incidents, surpassing 1,000 cases. The accessibility of 
illegal fireworks, particularly category F4 firecrackers (like the previously 
marketed Cobra 6), has created new security risks.967 Such products are now 
used in a variety of contexts beyond celebrations — including personal 
disputes, threats against police, and criminal intimidation. Where hand 
grenades were more commonly used by criminals before, flash bangers now 
serve as a more easily obtainable substitute with similarly destructive effects.968 
The most prevalent types of criminal misuse of pyrotechnics in the Netherlands 
concern violence and intimidation. This occurs both in the contexts of personal 
disputes and organised crime.969 In personal disputes, flash bangers are used 
for intimidation of an ex-partner or retaliation. This is also linked to other 
aggressive behaviour, such as stalking and domestic abuse.970  In the context 
of organised crime, misuse of pyrotechnics is closely linked to drug trafficking. 
This is elaborated in the section below. 

ATM attacks have been a visible and serious issue in the Netherlands in recent 
years. Dutch authorities have observed the use of heavy fireworks such as flash 
bangers in the efforts to rob banks by blowing up ATM machines. For example, 
using  10  flash  bangers  has  enough  power  to  open  up  an  ATM-machine.971 
However, ATM-attacks have been on the decrease in the past year due to the 
better protection measures taken. 

One of the primary enforcement challenges is the volume of illegal fireworks 
being trafficked into the country from abroad. Category F4 fireworks are 
legal to store in Germany, whereas in the Netherlands, such storage requires 
an 800-meter safety radius, making legal warehousing practically impossible. 
As a result, criminals in the Netherlands use neighbouring countries such as, 
Germany as logistical hubs, further complicating enforcement efforts.972 Another 

966   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 
available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484 

967  Interviews with authorities of two Member States.  
968  Interviews with authorities of one Member State, an EU agency and a Member State's representative 

part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 
available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484 

969   Ibid. 
970   Documentary Explosief Nederland, available at: https://v2.videoland.com/explosief-nederland-p_4484; 
See also: https://www.ad.nl/binnenland/als-de-relatie-uit-is-ontploft-er-een-cobra-6-bij-het-huis-van-
gizem-17~a539fc63/?referrer=https%3A%2F%2Fwww.google.com%2F 

971   Interviews with authorities of one Member State, an EU agency and a Member State's representative 

part of an EU-level instrument. 

972   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 

211 

 
 
 
 
challenge raised by the Dutch stakeholders is a lack of coordination across 
EU Member States. Illegal fireworks, especially from Eastern European 
countries, such as Poland and Czechia, are often sold online and delivered to 
persons in the Netherlands via private parcels. It seems that Member States’ 
authorities share little or no intelligence regarding the illegal trade, resulting in 
the high levels of criminal misuse, which hampers international investigations. 
Dutch stakeholders have reported that the main issue is the lack of prioritisation 
of the criminal misuse of pyrotechnics across Member States, as the impact 
thereof is lower in other Member States.973 

Types of pyrotechnic articles used in criminal acts 

The most commonly misused pyrotechnic articles are powerful category F4 
firecrackers, particularly the Cobra 6, which is often illegally manufactured or 
imported. The Dutch authorities estimate that 80–90% of these fireworks used 
in the Netherlands are illegal.974 In addition to firecrackers, shells are also being 
misused. Shells of category F4 pyrotechnics are spherical articles, with 
diameters ranging from 5 to 30cm, and a launching charge designed to be shot 
from a mortar. These articles can produce effects over a distance of 100–200 
meters and are increasingly entering the Netherlands through legitimate trade 
routes, before being diverted to unauthorised users.975 Some F4 shells still 
originate from China, although others come from Spain, Italy, and France—
often entering the Netherlands without appropriate labelling. These 
pyrotechnics, particularly salute shells, are adapted for criminal use by 
modifying their ignition methods, such as instantaneous fuses, to be able to use 
the articles without being hurt.976 The shells are then mainly used as projectiles 
against law enforcement authorities in e.g. riots and protests, and football-
related incidents. 

Dutch authorities have also detected category F4 articles to contain 
significantly higher levels of flash powder than allowed. Moreover, the 
concentration of flash powder in these articles has been increasing in the past 
few years.977 Category F3 fireworks (e.g., batteries) are less frequently used in 

available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484 

973   Ibid. 
974   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 
available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484 

975   Ibid. 
976   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; Environmental Crime Threat Assessment 2021, Netherlands Police, 
available at: https://www.politie.nl/binaries/content/assets/politie/onderwerpen/milieu/39eba72e-0631-
4c76-b64a-3a0c2fd8a43c.pdf; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484 

977   Interviews with authorities of two Member States. 

212 

 
 
 
 
criminal contexts, but they do appear, particularly in incidents involving 
aggression toward emergency responders during New Year’s Eve.978 

Organised crime 

OCGs are heavily involved in the illegal trade and the misuse of 
pyrotechnics in the Netherlands. Regarding illegal trade, Dutch OCGs use 
social media platforms such as Telegram and Snapchat to sell illegal 
pyrotechnics. Youth and minors are then used in the distribution of the illegal 
pyrotechnics to “customers” as well as, targeted intimidation with pyrotechnics. 
Distribution takes place in a storage box, where hundreds of illegal 
pyrotechnics, mainly flash bangers, are stored for illegal distribution.979 Some 
minors involved in the illegal trade of pyrotechnics have stated that they earn 
250-1500 EUR.980 

The misuse of pyrotechnics in the organised crime context is twofold. First, 
mainly heavy category F4 flash bangers and Cobras are used in intimidation 
and solving disputes between rival gangs. This is particularly prominent in port 
cities in the Netherlands, such as Amsterdam and Rotterdam. To illustrate, theft 
of a cocaine shipment by a rival OCG in Antwerp in 2024 caused a wave of 
violence where pyrotechnics have been used as explosives (either as such or 
as part of IEDs) in the Netherlands. Multiple explosions linked to each other and 
the theft of the cocaine shipment were detected in eight Dutch cities, as 
illustrated in the figure below.981 

978   Ibid. 
979   Interviews with authorities of two Member States; Documentary Explosief Nederland, available at: 

https://v2.videoland.com/explosief-nederland-p_4484 

980   Documentary Explosief Nederland, available at: https://v2.videoland.com/explosief-nederland-p_4484 
981   Interviews with authorities of one Member State, an EU agency and a Member State's representative 

part of an EU-level instrument; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484; See also: https://app.nos.nl/shorthand/dood-
aan-dieven/index.html  

213 

 
 
 
 
Figure 21 Map of explosions with pyrotechnics related to the theft of a cocaine 
shipment in port of Antwerp 

Source: NOS, Link. 

Relatedly, establishments of business owners with ties to the organised crime 
have been targeted by OCGs with pyrotechnics There are various reasons for 
this type of intimidation, but in some cases it concerns for example, unpaid 
debts. This was also the case in the stolen cocaine shipment from the port of 
Antwerp.982 

982   Interviews with authorities of one Member State, an EU agency and a Member State's representative 

part of an EU-level instrument; Documentary Explosief Nederland, available at: 
https://v2.videoland.com/explosief-nederland-p_4484; See also: https://app.nos.nl/shorthand/dood-
aan-dieven/index.html  

214 

 
 
 
 
 
Second, Dutch stakeholders have also reported that attacks with pyrotechnic 
articles are ordered through social media platforms as violence-as-a-
service.983 The organisation of these attacks consists of: 984 

●  The organised crime group and principal offering attacks with 

pyrotechnics; 

●  A middleman (often a young individual under 18) coordinating the 

“assignment for an attack”. This includes hiring and recruitment of minors 
to carry out the attack, verification of the target and the timing of the 
attack, as well as, the payment of rewards; 

●  Runners, placing the pyrotechnics at the correct target at an agreed time 
and date. They can be considered as kind of “freelancers”, who are on 
the list of the middle-man when an assignment is verified. 

In this type of violence-as-a-service offered with pyrotechnics, OCGs hire 
youth through online platforms such as Telegram and Snapchat – similar to 
the recruitment of drug extractors in the Port of Rotterdam. This includes OCGs 
downplaying the criminal side of pyrotechnics, as they are advertised as 
“harmless”, opposed to, for example, explosives and firearms. In combination 
with offering high rewards and quick cash for small jobs, OCGs can appeal 
youth from deprived neighbourhoods and poor backgrounds.985 

Terrorism 

There are some known cases where radicalised individuals attempted to use 
components of Cobras to construct IEDs for terrorist purposes. While such 
incidents remain quite rare in the Netherlands, they highlight the potential for 
the misuse of pyrotechnics to evolve into more severe security threats, including 
extremist and terrorist activity.986 It should be noted that the study team has 
received few responses to the questions related to pyrotechnics and terrorism 
from the Dutch stakeholders due to restricted access to this type of information. 

983   Interviews with authorities of one Member State; Documentary Explosief Nederland, available at: 

https://v2.videoland.com/explosief-nederland-p_4484; See also: https://www.europol.europa.eu/media-
press/newsroom/news/violence-service-criminals-hire-criminals, 
https://www.europol.europa.eu/media-press/newsroom/news/teenagers-recruited-hitmen-denmark-
and-sweden-strike-back-violence-service, 
https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/772903/EPRS_BRI(2025)772903_EN.pdf
, https://www.europol.europa.eu/operations-services-and-innovation/public-awareness-and-prevention-
guides/stop-criminal-networks-recruiting-youngsters and https://app.nos.nl/shorthand/dood-aan-
dieven/index.html  

984   Ibid.  
985   Ibid. 
986   Interviews with authorities of one Member State. 

215 

 
 
 
 
Good practices 

The Netherlands has implemented several measures to counter the growing 
misuse of pyrotechnics:987 

●  A new law (Wet op de Economische Delicten, WED – EN: Act on 
Economic Crimes) was adopted to strengthen the capacity of law 
enforcement to detect and prosecute illegal activities involving 
pyrotechnics. 

●  The Pyro Pass system ensures that only certified professionals can 

acquire and use high-risk category pyrotechnics. If adopted EU-wide, this 
system could help reduce the diversion of legal pyrotechnics into the 
black market and their use in criminal acts. 

●  The Netherlands and France have jointly developed a non-paper 
proposing an EU-wide response to the illegal trade and misuse of 
professional-grade fireworks. This document recommends coordinated 
action to protect public order and enhance safety. 

●  Dutch customs authorities use container X-ray scanning to detect illegal 

fireworks hidden in shipments arriving at ports. This allows early 
interception of prohibited items before they reach domestic markets. 

●  An action plan Landelijk Offensief tegen Explosies addressing violence 
carried out with explosions and pyrotechnics has been developed in the 
Netherlands. This initiative is a collaboration between the Ministry of 
Justice, Police, Public Prosecution Service, Aedes (Housing 
corporations), municipalities, the association of insurers, probation 
services, and the private sector. The main goal of the action plan is to 
implement and further develop (innovative) measures and interventions 
to sustainably reduce the number of attempted targeted attacks using 
explosives on homes, business premises and vehicles.988 

●  A mobile application designed to improve tracking of fireworks after 

explosions. The app allows users to visually recognise fragments after an 
explosion by taking a picture, which helps identify the type of fireworks 
involved. The database is being updated with all seized fireworks in the 
Netherlands, and there are plans to expand and translate the app for use 
by other Member States.989 

987   Interviews with authorities of one Member State, an EU agency and a Member State's representative 
part of an EU-level instrument; See also: https://wetten.overheid.nl/BWBR0044148/2020-10-01, 
https://www.eerstekamer.nl/nieuws/20250701/eerste_kamer_stemt_voor#:~:text=De%20Eerste%20Ka
mer%20heeft%20dinsdag,bij%20de%20jaarwisseling%202026%2F2027, 
https://www.rijksoverheid.nl/documenten/rapporten/2025/02/14/tk-bijlage-collaborative-non-paper-
pyrotechnics-nl-fr  

988   See: https://open.overheid.nl/documenten/37974468-c6b2-4d1a-a953-f6945373ae3b/file; Interviews 

with authorities of one Member State. 

989   Ibid. 

216 

 
 
 
 
Belgium 

Context 

In Belgium, pyrotechnic articles are legally used in a similar way as in the 
Netherlands. They are mainly used in festivities and celebrations, especially 
during New Year’s Eve, music festivals and weddings. Sometimes pyrotechnics 
are also used in legally organised shows before a football match and in a 
fireworks festival held annually in Knokke-Heist.990 The use of pyrotechnics by 
private individuals is allowed in Belgium for the lower categories (F1, F2, T1 and 
P1). For categories F3 and F4, a prohibition is in place for private individuals. 
These categories can only be used by professionals with appropriate licenses. 
Pyrotechnic articles are sold by physical sellers in Belgium. However, the use of 
pyrotechnic articles has been prohibited in some municipalities in Flanders. 991 
This is mainly due to the rising issues of misuse of pyrotechnic articles in 
violence and intimidation. 

National authorities have reported that obtaining illegal pyrotechnics, other 
explosives, grenades, and explosive precursors seems relatively easy through 
the parallel market. This is underscored by the large amounts of counterfeited 
and unsafe pyrotechnics encountered by the authorities. It is estimated that 
30% of the checked pyrotechnics fall into this category. In a similar vein, 14% of 
the sellers in Belgium do not comply with all requirements for selling 
pyrotechnics. This includes, for example, a lack of formal licenses to sell 
pyrotechnics, exceeding the amount that can legally be sold and selling 
pyrotechnics without proper CE-markings.992 In 2025, a man of Dutch nationality 
was arrested for the illegal trade of heavy fireworks operating from Belgium. He 
was also involved in money laundering of criminally obtained assets.993 The 
illegal trade, both offline and online, of these articles contributes to the misuse 
of pyrotechnic articles across both criminal and social contexts, as their 
availability is increased through the parallel market.994 

The main misuse of pyrotechnics in Belgium resembles the types identified in 
the Netherlands. Pyrotechnic articles are deployed by individuals and 
criminals against law enforcement authorities and rescue services during 
public disturbances. A particularly concerning phenomenon for the Belgian 
authorities is the use of heavy pyrotechnic articles by groups of young people. 
The misuse of pyrotechnics often goes hand in hand with the possession of 

990   Follow-up correspondence with authorities of one Member State.  
991   Interviews with authorities of one Member State; see: https://tntfireworks.be/nl/informatie/wetgeving/, 

https://www.vrt.be/vrtnws/nl/2024/12/18/geldt-een-vuurwerkverbod-in-jouw-gemeente/  

992   Interviews with authorities of one Member State; see: https://news.economie.fgov.be/216639-nog-

steeds-onveilig-vuurwerk-op-de-markt/ and https://www.ad.nl/buitenland/het-kan-wel-eens-afgelopen-
zijn-met-vuurwerk-halen-in-belgie-vlaamse-burgemeesters-willen-verkoopverbod~a66fb484/  

993   See: https://www.politie.nl/nieuws/2025/april/4/11-verdachte-aangehouden-vanwege-illegale-handel-

in-zwaar-vuurwerk-en-witwassen.html  

994   Ibid. 

217 

 
 
 
 
firearms. The violence carried out by groups of young people can be considered 
more violent than of lone perpetrators.995 

The misuse of pyrotechnics in ATM-attacks in Belgium is prominent, but 
appear to be less popular in the past couple of years. In 2019, there was a 
string of ATM-attacks with IEDs whereby pyrotechnics have been used to 
varying degrees.996 As a response, the banking institutions have closed down 
ATM-machines and taken protective measures due to the repeated attacks. As 
no official data has been received from the Belgian authorities, it is difficult to 
estimate to what extent ATM-attacks with the use of pyrotechnics poses still a 
security risk in Belgium. 

More information on the context of the legal use and misuse of pyrotechnics has 
been requested from the Belgian authorities in July 2025, and the study team is 
waiting for a response. 

Types of pyrotechnic articles used in criminal acts 

Belgium has witnessed a frequent criminal misuse of high-risk F4 
pyrotechnics, particularly counterfeit versions of the previously marketed 
Cobra 6 and Cobra 8, as well as P1 smoke flares. These items are easily 
accessible through illegal channels as mentioned above, and are increasingly 
employed in place of traditional weapons such as hand grenades and 
firearms.997 

All categories of fireworks are known to be misused. Category F2 batteries have 
been deployed against police and fire brigades during public disturbances. 
Category P1 smoke flares are commonly used in football stadiums, while even 
SOLAS maritime distress signals, intended for sea rescue, have occasionally 
been misused during football events. Nevertheless, organised crime groups use 
mainly category F4 pyrotechnics, including counterfeit ones. Some of these are 
marked with falsified labels that either mimic legitimate manufacturers or list 
fictitious companies, making traceability especially difficult.998 

995   Interviews with authorities of one Member State; see also: https://www.hln.be/binnenland/122-

slachtoffers-door-vuurwerk-tijdens-eindejaar-spoedartsen-pleiten-voor-totaalverbod-als-zo-n-auto-vol-
vuurwerk-ontploft-is-dat-hetzelfde-als-een-
aanslag~a1fad89c/#:~:text=Vuurwerk%20heeft%20tijdens%20de%20jaarwisseling,enkel%20nut%20g
ehad%20te%20hebben, https://www.ad.nl/buitenland/het-kan-wel-eens-afgelopen-zijn-met-vuurwerk-
halen-in-belgie-vlaamse-burgemeesters-willen-verkoopverbod~a66fb484/, 
https://www.politico.eu/article/belgium-mayor-call-for-europe-wide-ban-sale-fireworks/ and 
https://www.bruzz.be/veiligheid/politiechefs-merken-toename-van-groepsgeweld-en-zwaar-vuurwerk-
als-wapen-2023-11-17  

996   Interviews with authorities of one Member State; see also: https://www.tijd.be/politiek-

economie/belgie/economie/de-magische-aantrekkingskracht-van-de-geldautomaat/10177901.html,  

997   Interviews with authorities of one Member State. 
998   Interviews with authorities of one Member State.  

218 

 
 
 
 
Organised crime 

The primary concern in Belgium is the use of heavy category F4 fireworks, 
especially Cobra variants, by OCGs involved in drug trafficking. Drug 
traffickers, for example, are known to use high-risk pyrotechnics as substitutes 
for hand grenades in territorial disputes and intimidation tactics. Drug dealers 
frequently target rivals using fireworks as both a symbolic and physical means 
of asserting dominance or sending threats, further fuelling the climate of 
criminal unrest. This is further demonstrated by the cases of violence involving 
pyrotechnics in and around the Port of Antwerp. Dutch nationals are also 
involved in these cases of violence related to drug trafficking in Belgium.999 

Moreover, modified fireworks seem to be more common in Belgium. Criminals 
have adapted pyrotechnics by, for instance, combining a flash banger with 
petrol. Or alternatively, by extracting the explosive compound and placing it 
inside other objects to create improvised explosive devices (IEDs). These are 
used not only in confrontations with rival groups but also in attacks against the 
police and emergency services.1000 

Terrorism 

The study team has not been informed of any confirmed cases involving the use 
of pyrotechnics in (planned) acts of terrorism in Belgium. 

Good practices 

Belgium has adopted the Pyro Pass, which provides a structured way to 
verify and regulate access to professional-grade pyrotechnics. This 
approach improves traceability and supports enforcement efforts, especially in 
distinguishing legitimate use from criminal misuse.1001 

Moreover,  Belgium  cooperates  with  the  Netherlands  on  cross-border  cases  of 
pyrotechnics misuse. 

Belgium has a specialised police taskforce on fireworks, which has been 
established to discourage the purchase of illegal fireworks online in Antwerp. 
Citizens who have placed such orders are encouraged to cancel them. Details 
about intelligence methods and operational procedures of the task force are 
deliberately withheld to prevent circumvention of the rules by criminals.1002  

999   Interviews with authorities of one Member State; See also: 

https://www.vrt.be/vrtnws/nl/2025/02/06/politieactie-limburg/, https://app.nos.nl/shorthand/dood-aan-
dieven/index.html and https://www.gva.be/regio/nederlanders-opgepakt-voor-explosies-met-cobra-
vuurwerk-in-antwerpen/73803516.html  

1000  Interviews with authorities of one Member State. 
1001  Interviews with authorities of one Member State. 
1002 See: https://www.expatica.com/nl/general/police-to-crack-down-on-illegal-firework-orders-online-8040/ 
;https://www.nieuwsblad.be/regio/antwerpen/regio-antwerpen/antwerpen/taskforce-tegen-vuurwerk-
kliste-al-71-jongeren-ook-komende-weken-treden-we-streng-op/40300438.html.  

219 

 
 
 
 
Germany 

Context 

In Germany, all fireworks falling within the scope of the EU Pyrotechnics 
Directive comply with EU and national regulations, and the German Explosives 
Act includes clear sanctions, penalties and fines for non-compliance. While the 
legislative framework is considered effective, major challenges remain in 
enforcement, market surveillance, customs control, and regulating online sales. 

The cases of misuse of explosives are not regulated in the Explosives Act. 
Because of their serious consequences, these offences have been incorporated 
into the Criminal Code.1003 

German authorities have reported that the security risks related to the 
misuse of pyrotechnics are in general, not widespread. For example, there 
has been a consistent occurrence of ATM-attacks over the past years, 
although at a low level. The main shift here is that detonating ATM devices were 
previously linked mainly to gas explosives, but there has been a growing trend 
towards the misuse of flash powders and flash bangers. These products are 
often associated with category F4 pyrotechnics, which presents a significant 
problem. Criminals often extract the powder from 10-20 pyrotechnic articles, 
making new configurations. 5 kilograms of flash powder is needed, which can 
be extracted from approximately. 20 pyrotechnic articles rather than using the 
articles themselves.1004 However, German authorities have reported that in 
2024, there has been a sharp decline in the number of ATM-attacks by 40% 
compared to the previous year. This declining trend has been observed to 
continue in 2025.1005 The German authorities will publish a Federal Situation 
Report on ATM attacks and provide the study team with further details. Overall, 
German authorities report that 4000-4800 criminal offences in violation of the 
Explosives Act annually, where the operational databases demonstrate that 
nearly 50% of the data involves various forms of pyrotechnics.1006 

Another contributing factor is the lack of harmonisation of regulations across 
Europe. For example, pyrotechnics seem less regulated in some Eastern 
European countries, while Germany imposes strict limits, such as restricting 
rockets to 20 grams of propellant and additional packaging requirements. When 
strict rules are not enforced to the same extent in other Member States, it 
becomes easier to import non-compliant pyrotechnics without, for example, CE-
markings illegally into Germany, despite this being prohibited under German 
law.1007 

1003  Interviews with authorities of one Member State.  
1004  Ibid. 
1005  Follow up questionnaire addressed to national competent authorities: response from one Member 

State. 

1006  Ibid. 
1007  Ibid. 

220 

 
 
 
 
More information on the context of the legal use and misuse of pyrotechnics 
have been requested from the German authorities in July 2025, and the study 
team is waiting for a response. 

Types of pyrotechnic articles used in criminal acts 

The pyrotechnic articles most commonly involved in criminal misuse in 
Germany are categories F4 and P1. In Germany, both F3 and F4 are 
restricted to individuals with specialist knowledge, making F4 more frequently 
misused due to its relative availability compared to F3. More recently, a growing 
concern has emerged around the misuse of category P1 sound emitters. Some 
importers have circumvented stricter regulations on fireworks by increasing 
flash powder content in products classified as P1, which are subject to lighter 
controls.1008 

Flash bangers, black powder, potassium perchlorate and aluminium 
powder are reported as a well-known source for the illegal manufacture or 
use of pyrotechnics. Between 2020 and 2021, the sale of legal fireworks was 
banned in Germany due to the COVID-19 pandemic. This created a surge in the 
parallel market activity, significantly increasing misuse. Polish importers 
capitalised on the situation by promoting cross-border purchases, advertising 
online that fireworks were available just a few kilometres away across the 
border. Alongside F4, F3 fireworks are frequently imported illegally via online 
platforms.1009 

German stakeholders maintain that the production of these fireworks within the 
EU is not the main issue; rather, the problem lies with cross-border 
trafficking. For instance, many products originate from Albania, which 
hosts one of Europe’s largest pyrotechnic factories. Ferries between 
Albania and Italy facilitate the easy import of these fireworks into the EU.1010 

Organised crime 

According to German authorities, links between the misuse of pyrotechnics 
and violence with OCGs are not well-known in Germany. There have been 
investigations of explosions with pyrotechnics and possible links with OCGs; 
however, no evidence has been found.1011 Rather, a significant concern in 
Germany is the exploitation of legal business structures for illegal trade of 
pyrotechnics destined for misuse. Cross-border transactions often take place 
through business-to-business (B2B) channels, which complicates traceability. 
This method allows companies to sell fireworks to other companies, masking 
illegal activity and making it difficult for authorities to identify and intercept illicit 

1008  Interviews with authorities of one Member State.  
1009  Ibid. 
1010  Ibid. 
1011  Interviews with authorities of one Member State. . 

221 

 
 
 
 
products.1012 In this context, there is often a link to the Netherlands and Dutch 
criminals who are involved in the illegal trade of pyrotechnics and their misuse 
in Germany. 

Terrorism 

The study team has not been informed of any confirmed cases involving the use 
of pyrotechnics in (planned) acts of terrorism in Germany. 

Good practices 

Germany has a comprehensive legal framework regulating pyrotechnic 
articles, grounded in the EU Pyrotechnics Directive and enforced through 
detailed national laws, including three associated ordinances. These laws 
provide clear sanctions for non-compliance, supporting effective enforcement. 

According to the German stakeholders, the adoption of a uniform EU-level Pyro 
Pass licensing system would greatly enhance Member States' ability to track 
authorised purchasers and reduce diversion to illegal markets.1013 

1012  Ibid. 
1013  Interviews with authorities of one Member State.  

222 

 
 
 
 
 
Annex VI Synopsis Report 

The Synopsis Report covers all stakeholder consultation activities carried 
out as part of the study and presents their results. Its aim is to inform 
policymakers on the outcome of all consultation activities and to inform 
stakeholders on how their input has been considered in the context of the study.  

The stakeholder mapping served as a starting point for the consultation 
activities, based on desk research, the study team's existing contacts and 
networks, and the information received from the European Commission. The 
team updated such mapping on a regular basis, by adding stakeholders when 
the first choice did not reply or declined the invitations to engagement. 

The study team developed a stakeholder consultation strategy to guide the 
implementation of the consultation activities, which were organised at different 
stages of the project to gather relevant information, views, and insights from key 
stakeholders.  

To support evidence-based analysis across all study areas, the strategy foresaw 
engagement with the following stakeholder categories.  

Table 6 Overview of stakeholder categories 

Stakeholder category 

Reasons for outreach 

Relevant authorities from 
Member States and SACs1014 

Engaged due to their responsibility in assessing security threats, such 
as  the  criminal  misuse  of  pyrotechnics,  and  their  critical  role  in 
enforcing relevant rules. 

EU institutions, bodies, and 
agencies 

Industry representatives (both 
industry organisations and 
associations representing 
industry) 

Sales and distribution 
platforms  

Involved for their central role in shaping and refining policies related 
to  serious  and  organised  crime,  counter-terrorism  and  pyrotechnic 
articles. Specialised units within the European Commission provided 
insights  into  the  functioning  and  enforcement  of  current  legislation. 
Their input was complemented by input from operational actors such 
as EU agencies, who contributed valuable knowledge on crime trends 
and cross-border cooperation mechanisms. 

Consulted to provide practical insights into the enforcement of rules 
governing the production and sale of pyrotechnic articles. Their input 
was essential for understanding how requirements are applied in real-
world  settings,  as  well  as  identifying  any  operational  challenges  or 
barriers  to  compliance.  These  stakeholders  also  offered  valuable 
perspectives on industry best practices and the broader cultural and 
commercial context in which pyrotechnics are used. 

Included due to their role in facilitating access to pyrotechnic articles, 
both  through  physical  outlets  and  online  marketplaces.  These 
platforms  offered  critical  insights  into  how  pyrotechnic  products  are 
sold/acquired in practice. Their perspective helped identify potential 
gaps in enforcement, especially in the digital space, and contributes 
to understanding the dynamics of consumer access, traceability, and 
compliance with safety and legal standards. 

1014  This category consists of national law enforcement authorities, prosecutors, customs authorities and 

relevant ministries enforcing the rules on pyrotechnic articles.  

223 

 
 
 
 
Stakeholder category 

Reasons for outreach 

Civil society organisations  

Included  to  reflect  societal  concerns,  such  as  fire  safety  and  the 
involvement of minors in crime, ensuring that broader social impacts 
are considered in the regulatory approach. 

Researchers and research 
organisations 

Involved  their  specialised  expertise  to  ensure  that  the  consultation 
process was informed by evidence-based insights. 

Source: Consortium’s elaboration. 

The study team adopted a mixed-method approach, including a wide range of 
methods to guarantee a comprehensive consultation process. The strategy was 
set up to ensure that the consultation activities address different stakeholders 
and cover different aspects of the consultation. The choice of the targeted 
consultation method is based on a number of considerations, such as the 
diversity of the stakeholder categories, the level of engagement and the type of 
information the stakeholder categories provide.  

The  study  team  implemented  a  multi-method  consultation  approach,  which 
included: 

●  Completion of scoping interviews to refine the consultation strategy and 

deepen understanding of key research aspects; 

●  Design and dissemination of targeted stakeholder surveys; 

●  Conducting targeted interviews to gather qualitative insights and 

explore specific topics more thoroughly; 

●  Circulation of a follow-up questionnaire to national authorities to collect 

quantitative data; 

●  Review and analysis of written contributions submitted as alternatives 

to survey or interview participation. 

The consultation strategy is a dynamic tool and was subject to adjustments over 
the course of the project’s implementation based on the results of the desk 
research, scoping interviews, and feedback from the European Commission, 
suggestions from stakeholders and the level of engagement by stakeholders. 
Such adjustments allowed targeting the activities even further based on needs 
and were discussed with the European Commission. In response to outreach 
challenges, particularly the limited engagement from some stakeholder groups, 
the study team also implemented a range of mitigation measures. These 
included: 

●  additional mapping of stakeholders; 

●  extending timeline for scoping interviews, targeted interviews, surveys 

and follow-up questionnaire;  

●  offering flexible response formats, i.e. written contribution, for 

stakeholders unable to participate in interviews or complete the entire 
survey; 

224 

 
 
 
 
● 

follow-up questionnaire addressed to national authorities; 

● 

liaising with the European Commission to encourage responses via its 
contacts with national authorities, the Polish Presidency of the Council of 
the European Union, and EU agencies. 

Finally, this Annex provides an overview of the validation workshop planned to 
invite stakeholders to discuss findings and collect additional feedback on the 
study's emerging conclusions.  

The following sections describe each activity in more detail, including a 
synthesis of key findings emerging from the respective consultation tools. 

Overview of the interviews (scoping and targeted) 

Overall, the study team conducted 36 interviews, including 6 scoping 
interviews and 30 targeted interviews.  

The scoping interviews were primarily carried out during the early phase of the 
study to support the refinement of the study focus, stakeholder mapping, and 
the design of consultation tools, while the targeted interviews were conducted to 
gather in-depth insights from a diverse range of stakeholders directly affected 
by or involved in the study areas. 

The interviews provided predominantly qualitative insights that directly 
addressed the study’s core questions. They complemented other data collection 
methods by enabling the study team to explore in depth the specific issues, 
challenges, and examples of good practices and innovations related to the 
criminal misuse of pyrotechnic articles in the EU. 

Interview questionnaires were designed for each stakeholder group. They were 
designed with open-ended questions to encourage unrestricted responses, 
allowing for a nuanced understanding of the issue across different EU Member 
States and industry contexts. Interview questions were further targeted to each 
stakeholder based on their knowledge and expected input ahead of the 
interview, and their insights during the interview’s progression. 

Drawing on its extensive experience, the study team ensured that the interviews 
were effectively integrated with other information-gathering methods, avoiding 
duplication and minimising stakeholder fatigue. 

Interviews were conducted with key stakeholder groups selected according to 
the following criteria: 

●  Geographical balance: A diverse geographical representation was 
considered to support the reliability of findings and enable robust 
conclusions. 

225 

 
 
 
●  Level of governance: Interviewees were selected to reflect a balance 
across legislative, law enforcement, prosecutorial, and policy-making 
levels, in line with the study’s scope. 

●  Security and market perspective: To ensure comprehensive coverage 
of the study's dual focus, stakeholders representing both security and 
market regulation perspectives were included. 

Below, we present an overview of the interviews conducted (by stakeholder 
category), as well as key interview findings structured around the study areas, as 
well  as  a  list  of  adjustments  to  the  stakeholder  consultation  strategy  made 
throughout the implementation. 

Scoping interviews 

Six  scoping  interviews  were  conducted  between  November  and  December 
2024.  The  interviews  played a key role in  shaping the  subsequent  research 
activities  by  refining  the  study  focus  and  enhancing  the  team's 
understanding of the study's context. They also provided valuable contextual 
insights  into  key  issues  at  stake.  The  table  below  presents  an  overview  of 
completed scoping interviews.  

# 

1 

2 

3 

4 

Table 7 Completed scoping interviews 

Stakeholder group 

Date 

EU institution 

EU institution 

EU agency  

 Pyrotechnics industry 
organisation/ industry 
representative association 

 Pyrotechnics industry 

08/11/2024 

06/11/2024 

06/11/2024 

12/11/2024 

5  

organisation/ industry 

22/11/2024 

representative association 

6 

Member State’s authority  

11/12/2024 

Source: Consortium’s elaboration. 

Scoping interviews’ findings 

The main takeaways from the scoping interviews highlight the need for 
harmonisation of legislation in Member States to tackle the threats posed by 
pyrotechnical articles used by organised crime groups and terrorists operating 
across Member States.  

In addition, interviewees highlighted the relatively easy access to components 
needed to manufacture category F4 fireworks and the upward trend in illegal 
production in the past years. Additionally, some interviewees mentioned 

226 

 
 
 
indications of using flash powder derived from pyrotechnic articles to make 
HMEs. 

The increase in the illegal production of counterfeit pyrotechnic articles was 
highlighted among the significant concerns in terms of criminal misuse. In this 
regard, interviewees stressed that, on the one hand, the Pyrotechnics Directive 
2013/29/EU should provide for further safeguards against the criminal misuse of 
legally produced articles; however, on the other hand, interviewees noted that 
the issues posed by the use of illegal articles for criminal purposes fall beyond 
the possible reach of the Pyrotechnics Directive 2013/29/EU. 

Different methods for increasing the traceability of pyrotechnic articles were 
mentioned, and suggestions were proposed to ensure better enforcement of the 
existing rules.  

Concerning category F4 pyrotechnic articles, interviewees stressed that online 
marketplaces and shops often do not verify if the buyer has specialist 
knowledge. This underscores the general opinions of the majority of the 
interviewees regarding the difficulties in enforcing the current rules. 

Scoping interviews also shed light on potential limitations to gathering data on 
the illicit trade and production of pyrotechnic articles.  

Targeted interviews 

The targeted interviews aim to gather qualitative information relevant to 
the feasibility study’s question and complement the other data collection 
methods by allowing the study team to delve deeper into the specific 
issues, challenges, and possible good practices and innovations related 
to the criminal misuse of pyrotechnic articles in the EU. 

In total, the study team contacted 85 stakeholders across the relevant 
stakeholder types. Of these, 30 stakeholders participated in interviews, resulting 
in a response rate of 35.3%.  

Non-responses were recorded in cases where stakeholders did not reply after 
three follow-up reminders, after which they were considered to have declined 
participation. In other instances, stakeholders declined the invitation on the 
grounds that they were not the appropriate authority. Where possible, these 
stakeholders redirected the study team to the competent authority.  

The table  below provides an overview of the outreach efforts, including the 
distribution of contacted stakeholders by type and the corresponding response 
rates. 

227 

 
 
 
Table 8 Stakeholder response rate of targeted interviews 

Stakeholder type  Contacted 

Response rate 

EU institutions, bodies and 

agencies 

EU Member States’ competent 

authorities 

6 

42 

Competent authorities of 

Schengen Associated 

2 

Countries (SAC) 

Pyrotechnics industry 

organisation/ industry 
representative association  
Civil society organisations 

(CSO) 

Other (e.g. researchers, EU-

funded projects) 

Source: Consortium’s elaboration. 

25 

3 

7 

67% 

38% 

0% 

28% 

0% 

43% 

The study team conducted the following targeted interviews. 

Table 9 Completed targeted interviews 

# 

Stakeholder group 

Date 

Comments 

1 

2 

3 

4 

5 

6 

7 

8 

9 

EU institutions, bodies and 
agencies  
EU institutions, bodies and 
agencies 
EU institutions, bodies and 
agencies 
EU institutions, bodies, and 
agencies 

01/04/2025 

26/03/2025 

26/05/2025 

10/07/2025 

Member States authorities 

31/03/2025 

Member States authorities 

14/07/2025 

Member States authorities 

25/03/2025 

Member States authorities 

20/05/2025 

Member States authorities 

29/05/2025 

10 

Member States authorities 

05/05/2025 

11 

Member States authorities 

05/05/2025 

 12 

Member States authorities 

05/02/2025 

228 

This was also 
conducted as part 
of Case study B 
This was also 
conducted as part 
of Case study A 

This interview was 
also conducted as 
part of case study 
A. 
This interview was 
also conducted as 
part of case study 
A.  
This interview was 
also conducted as 
part of Case study 
B 

 
 
 
 
 
 
 
 
 
 
# 

Stakeholder group 

Date 

Comments 

13 

Member States authorities 

19/02/2025 

14 

Member States authorities 

18/06/2025 

15 

Member States authorities 

20/02/2025 

16 

Member States authorities 

09/07/2025 

17 

Member States authorities 

N/A 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

Member States authorities 

06/05/2025 

Member States Authorities 

03/04/2025 

Member States Authorities 

16/04/2025 

Sales and distribution 
platform  

Industry   

Pyrotechnics industry 
organisation/ industry 
representative association - 
national-level 
Pyrotechnics industry 
organisation/ industry 
representative association 
– national-level 
Pyrotechnics industry 
organisation/ industry 
representative association - 
national-level 
Pyrotechnics industry 
organisation/ industry 
representative association 
– national-level 

Pyrotechnics industry 
organisation/ industry 
representative association 
– national-level 

28/04/2025 

20/03/2025 

21/03/2025 

23/04/2025 

09/05/2025 

1/04/2025 

N/A  

Researcher 

17/03/2025 

EU-funded project 

16/04/2025 

Researcher 

24/07/2025 

This was a joint 
interview with both 
Ministries. 
This interview was 
with a different 
department in the 
Ministry than 
above. 
This interview was 
also conducted as 
part of Case study 
B 
This interview was 
also conducted as 
part of Case Study 
B  
The interview 
questionnaire was 
sent to be 
answered in 
writing.  

This was also 
conducted as part 
of case study A 

The interview 
questionnaire was 
sent to be 
answered in 
writing.  

Source: Consortium’s elaboration. 

Targeted interviews’ findings per study area 

229 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The responses reflect a wide range of perspectives and experiences, shaped by 
national contexts, enforcement capacities, and sectoral roles. 

Study area 1: Updated picture of the security problem 

The questions for this area focused on the scale and nature of illegal 
manufacturing, diversion, illicit trade, and security challenges related to 
pyrotechnics.  

Responses suggest that there is no uniform picture across Member States 
regarding the scale or severity of illegal pyrotechnic manufacturing and 
diversion. 

In this area, consulted stakeholders consistently highlighted the growing role of 
online platforms, postal shipments, and cross-border trade in facilitating the 
diversion and illicit trade of pyrotechnics. 

Stakeholders from the Netherlands and Sweden highlighted that the criminal 
misuse of pyrotechnics is increasingly linked to organised crime. In these 
countries, heavy fireworks are used in violent acts, including attacks on ATMs 
and against law enforcement authorities.1015 

While F4 articles remain a primary concern, several stakeholders also flagged 
also pyrotechnics articles F3 and P1 as problematic due to their availability and 
misuse potential.1016 

Stakeholders were divided on the extent of illegal manufacturing. Several 
reported no significant issues with illegal manufacturing in their national 
contexts, citing strict rules in place and/or low incidence.1017 Others indicated 
that illegal production is increasing, particularly in Member States where legal 
production has ceased or where national laws might not be sufficiently 
enforced.1018 This divergence reflects both differences in national enforcement 
priorities and varying levels of awareness of illicit production networks. 

Two stakeholders indicated the lack of reliable data or non-centralised data, 
making it difficult to assess the true scale, also considering the cross-border 
nature of such illegal activities.1019  

During interviews, diversion was widely recognised as a significant and growing 
issue. Several stakeholders described diversion through legal supply chains, 
including mislabelling, drop-shipping, and exploitation of customs loopholes.1020 

1015  Targeted interviews with national authorities: two Member States. 
1016  Targeted interviews with national authorities of two Member States, two national-level industry 

organisation and one EU-funded project in this area.  

1017 Targeted interviews with national authorities: five Member States.  
1018 Targeted interviews with national authorities of two Member States, one EU agency, one national-level 

industry organisation and one researcher. 

1019 Targeted interviews with national authorities: two Member States. 
1020 Targeted interviews with national authorities of three Member States, one partner of an EU-funded 

project in this area and oneEU agency. 

230 

 
 
 
 
The responses suggested that diversion is often transnational, with legal 
imports redirected to countries with weaker enforcement or higher demand. 

Moreover, consulted stakeholders highlighted cross-border and operational 
challenges, pointing out that criminal misuse is context-dependent, with some 
Member States facing increased threats linked to organised crime and youth 
violence. In this respect, some stakeholders reported that organised crime 
groups and extremists increasingly use pyrotechnics for intimidation, vandalism, 
and attacks on law enforcement.1021 Others viewed the issue as less severe, 
though they acknowledged risks at public events and football matches.1022 This 
can be read in light of an observation by an EU stakeholder who noted 
differences in how Member States perceive and address this problem, which 
makes cooperation more challenging. 1023 

Study area 2: Harmonisation of national laws and practices 

The interviews focused on identifying gaps in the approach to fighting the 
criminal misuse of pyrotechnics, the role and effectiveness of sanctions, the 
benefits of harmonisation, and best practices across Member States. 

Interviewees agreed that the current approach suffers from fragmented 
implementation, insufficient market surveillance,1024 limited and inconsistent 
enforcement,1025 and limited cross-border coordination1026.  

Responses revealed that sanctions in relation to the criminal misuse of 
pyrotechnics vary significantly across Member States in both form and severity. 
Two national authorities reported comprehensive criminal and administrative 
penalties, particularly targeting organised crime.1027 Other two national 
authorities confirmed that sanctions are in place and can be effective, especially 
when paired with preventive measures.1028 However, two stakeholders shared 
the opinion that penalties are often limited to fines and may lack a deterrent 
effect.1029 An industry representative stressed that enforcement is weak due to 
limited controls, even where measures are strict.1030 

Among interviewees, there was a broad consensus that inconsistent 
approaches at national levels represent a major obstacle to the detection, 
enforcement, and prosecution of cross-border activities related to the criminal 
misuse of pyrotechnics, and that harmonisation would significantly enhance 

1021 Targeted interviews with national authorities of two Member States and one EU agency.  
1022 Targeted interviews with national authorities: two Member States. 
1023 Targeted interview with an EU agency.  
1024  Targeted interview with an EU-level industry organisation and a national-level industry organisation.  
1025  Targeted interviews with national authorities of two Member States, one EU-level industry 

organisation, and one industry organisation. . 

1026  Targeted interviews with national authorities: two Member States. 
1027  Targeted interviews with national authorities: two Member States. 
1028  Targeted interviews with national authorities: two Member States. 
1029  Targeted interview with a national authority of one Member State  and one national-level industry 

organisation.  

1030 Targeted interview with a national-level industry organisation. 

231 

 
 
 
 
cross-border enforcement.1031 An EU-level stakeholder supported 
harmonisation as a means to close legal loopholes and raise the level of 
urgency among Member States.1032 However, some industry stakeholders 
cautioned that harmonisation should not lead to overly restrictive measures and 
that enforcement gaps may be a more pressing issue than legislative ones.1033  

Looking forward, one national authority proposed exploring the opportunity to 
introduce an EU-level Pyropass system based on the model in the Benelux 
region. 1034 

Stakeholders proposed a range of EU-level actions to support harmonisation, 
such as using digital tools (e.g. SCEPYLT),1035 clearer categorisation of 
pyrotechnic articles, 1036 stricter limits on explosive content and a ban on heavy 
firecrackers,1037and stronger coordination and enforcement mechanisms1038. 

Finally, the consulted stakeholders shared some best practices in this area. 
Among these, stakeholders made reference to the case of the Netherlands, 
which put in place the Pyropass licensing system, national registration of 
explosives-related incidents, and public-private partnerships;1039 while the case 
of Spain was recognised for its centralised oversight of the fireworks 
domain.1040 

Regarding new models, one stakeholder highlighted the potential of the 
iFLOWS system for customs authorities,1041 and one industry stakeholder 
proposed the use of inert taggants in pyrotechnic mixtures as a promising 
innovation.1042  

Study area 3: Potential use of substances covered by Regulation (EU) 
2019/1148 on explosive precursors to make illegal pyrotechnic articles  

The questions for this area focused on the types of chemical substances used 
in legal and illegal pyrotechnic manufacturing, the effectiveness of Regulation 
(EU) 2019/1148 in preventing unauthorised access to explosive precursors, and 
whether differences in national enforcement create vulnerabilities. 

Responses indicated many of the substances used in illegal pyrotechnic 
manufacturing are either already classified as explosive precursors or are not 

1031 Targeted interviews with national authorities: three Member States. 
1032 Targeted interview with an EU agency. 
1033 Targeted interview with an EU-level industry organisation and a national-level industry organisation. 
1034 Targeted interview with a national authority: one Member State. 
1035 Targeted interview with a national authority: one Member State. 
1036  Targeted interview with a national-level industry organisation. 
1037 Targeted interview with a national authority: one Member State. 
1038 Targeted interview with a national-level industry organisation and an EU agency. 
1039 Targeted interviews with national authorities of two Member States and an EU agency. 
1040 Targeted interviews with national authorities: two Member States. 
1041 Targeted interview with a partner of an EU-funded project in this area. 
1042 Targeted interview with an industry organisation.   

232 

 
 
 
 
effectively covered by the Regulation, particularly when sourced from outside 
the EU (as the Regulation (EU) 2019/1148 applies to EU-based production).1043 

According to an EU-level stakeholder, legal and illegal pyrotechnics likely share 
the same chemical composition, making detection difficult. In addition, the 
stakeholder indicated that while suggestions to tag chemicals in articles have 
been made and could help traceability, they would be hard to implement. 1044  

Another EU-level stakeholder reported that flash powder is widely used in both 
legal fireworks and IEDs, especially in the context of criminal violence in 
Belgium and the Netherlands. Moreover, such a stakeholder identified 
ammonium powder, potassium perchlorate, and potassium nitrate as commonly 
used substances and indicated that while reporting requirements exist, 
enforcement might be weak when substances are sourced from non-EU 
suppliers (e.g. China).1045 

A stakeholder pointed out that the Regulation (EU) 2019/1148 is only applicable 
under specific conditions, focusing only on sales to the public, while 
professionals are exempt.1046  

Several stakeholders noted that differences in national implementation and 
enforcement of the Regulation (EU) 2019/1148 may be exploited by 
criminals.1047 The absence of centralised tracking databases risks allowing 
criminals to purchase from multiple shops undetected and source substances 
across borders.1048 

Study area 4: Cross-border exchange of information and cooperation 

The questions explored the extent and effectiveness of cross-border information 
exchange, cooperation in criminal investigations, public-private collaboration, 
and the factors hindering these efforts. 

The interviewees indicated that cross-border information exchange among 
Member States is generally limited and often done on an ad hoc basis. 
Cooperation typically occurs upon request, often via email or during EU-level 
meeting,1049 while forums for exchange exist, only a few countries actively 
participate.1050 One stakeholder characterised cooperation between EU 
Member States and EU actors as sporadic and not strongly supported by 
EUROPOL.1051 Information between Member States is shared on a “need to 
know” basis, often through Interpol agreements.1052 

1043 Targeted interview with an EU-level industry organisation. 
1044 Targeted interview with an EU institution. 
1045 Targeted interview with an EU agency. 
1046 Targeted interview with national authority: one Member State. 
1047 Targeted interview with national authority: one Member State. 
1048 Targeted interview with an EU institution. 
1049 Targeted interview with national authority: one Member State. 
1050 Targeted interview with a national authority: one Member State. 
1051 Targeted interview with a national authority: one Member State. 
1052 Targeted interview with a national authority: one Member State. 

233 

 
 
 
 
Consulted stakeholders identified several shortcomings in the current 
information exchange system, as it is considered to be hindered by fragmented 
communication, limited real-time data sharing, and inconsistent engagement 
across Member States. Two stakeholders highlighted the need for harmonised 
rules and the use of digital platforms to streamline cooperation.1053 Other two 
interviewees stressed the importance of joint intelligence gathering and sharing 
as well as cross-border enforcement, particularly with some countries.1054 

Cooperation in criminal investigations appears to be limited and uneven. A 
national authority acknowledged that cooperation could improve, but expressed 
doubt about the capacity of EU institutions to enhance operations due to a lack 
of specific expertise.1055 Another stakeholder noted that customs authorities do 
cooperate, but primarily on an ad hoc basis.1056 An EU agency cited successful 
collaboration between Germany and the Netherlands on ATM attacks.1057 
These examples show that while cooperation does occur, it is not systematic 
and often depends on bilateral initiatives. 

Stakeholders pointed to the fact that cross-border cooperation is hindered by a 
combination of administrative barriers,1058 inconsistent national regulations and 
varying levels of urgency among Member States.1059 

According to interviewees, public-private cooperation in the context of cross-
border enforcement remains limited and fragmented. Three industry 
stakeholders reported some or ad hoc engagement with authorities,1060 while 
two other stakeholders called for more structured partnerships, including data-
sharing platforms and joint initiatives.1061 

Study area 5: Tracking and tracing high-risk articles  

The focus was on the challenges that law enforcement agencies face in tracking 
and tracing high-risk profiles of pyrotechnic articles used in illicit acts. 

The responses reveal technical and procedural difficulties in tracing the origin of 
pyrotechnic articles used in criminal acts.  

1053 Targeted interview with a national authority: one Member State. 

Targeted interview with a partner of an EU-funded project in this area. 

1054 Targeted interview with a national authority (one Member State) and an EU agency. 
1055 Targeted interview with a national authority: one Member State. 
1056 Targeted interview with a national authority: one Member State. 
1057 Targeted interview with an EU agency. 
1058 Targeted interviews with national authorities: two Member States. 
1059 Targeted interview with an EU agency and a national authority of one Member State. 
1060 Targeted interview with an EU-level industry organisation. 
Targeted interview with a sales and distribution platform.  
Targeted interview with an industry organisation.  

1061 Targeted interview with a partner of an EU-funded project in this area. 

Targeted interview with an EU agency.  

234 

 
 
 
 
An interviewee noted that while tracking legally produced pyrotechnics is 
relatively advanced, tracing illegally produced items is far more difficult due to 
the absence of a formal producer.1062  

The ability to trace pyrotechnic articles used in illicit activities is undermined by 
inconsistent labelling practices, lack of harmonised systems (no traceability 
requirements for labelling or transfers), and limited investigative and 
enforcement capacity.1063 In particular, a stakeholder highlighted operational 
challenges such as the lack of standardised scanning procedures, time 
pressure, and limited access to customs risk profiles, which collectively reduce 
the effectiveness of tracking efforts.1064 

An EU-level stakeholder explained that investigations are often hindered by the 
fact that only residue is found at crime scenes, and intentional mislabelling 
further obstructs efforts to trace origins.1065 

On solutions, three national stakeholders all called for tracking systems similar 
to those used for explosives, noting that current frameworks are insufficient.1066 
One stakeholder emphasised the importance of specialised detection and 
cooperation with postal companies to uncover illegal practices, 1067 one 
indicated the need to improve the available resources to allow effective 
enforcement, 1068 and another highlighted the pressing need for improved 
mechanisms and stronger collaboration among national and EU authorities.1069 
From an industry perspective, an organisation stressed that all stakeholders 
across the supply chain should support tracking and tracing.1070  

While the Benelux region has begun implementing a system called Pyropass to 
improve traceability,1071 responses received suggest broader EU-wide efforts in 
traceability infrastructure to close the existing gaps. 

Study area 6: Strengthening customs enforcement  

The questions focused on the current customs legislative framework, the 
challenges customs authorities face in detecting illegal imports of pyrotechnics, 
the limitations of enforcement tools, and the gaps in procedures. 

Consulted stakeholders on this topic described a fragmented customs 
enforcement landscape across Member States, with significant challenges in 
detecting and intercepting illegal pyrotechnics. While some Member States 
have implemented targeted prevention measures and technologies, others face 

1062 Targeted interview with national authority: one Member State. 
1063 Targeted interviews with national authorities: three Member States. 
1064 Targeted interview with a partner of an EU-funded project in this area. 
1065 Targeted interview with an EU agency.  
1066 Targeted interviews with national authorities: three Member States. 
1067 Targeted interview with national authority: one Member State. 
1068 Targeted interview with national authority: one Member State. 
1069 Targeted interview with national authority: one Member State.  
1070 Targeted interview with a national-level industry organisation. 
1071 Targeted interview with national authority: one Member State. 

235 

 
 
 
 
structural limitations such as insufficient personnel, lack of harmonised 
procedures, and limited detection of cross-border shipments. The free 
movement of goods within the EU, combined with the high volume of small 
parcels and inconsistent risk profiling, makes it extremely difficult to identify and 
intercept illegal items.1072 

The responses indicate that customs enforcement frameworks and practices 
vary significantly across Member States. While some countries have 
implemented strict national legislation and proactive enforcement measures, 
including the use of specialised detection technologies,1073 others, like Sweden, 
focus primarily on goods entering from outside the EU rather than intra-EU 
shipments.1074 An EU-level agency described standard customs checks based 
on shipment data and acknowledged that these are not uniformly applied. 1075 In 
addition, one stakeholder reported close cooperation with the customs 
authorities of neighbouring countries.1076  

Stakeholders highlighted a range of operational and systemic challenges that 
customs authorities face in detecting illegal imports of pyrotechnics. According 
to an EU stakeholder, while pyrotechnics are often legally imported from outside 
the EU, e.g. China, criminals exploit the system by using false declarations to 
conceal illicit shipments.1077 Another stakeholder added that customs operations 
are hampered by limited personnel, outdated technology at border crossings, 
inconsistent risk data, and a lack of predictive intelligence (due to a lack of real-
time alerts, shared databases, and integrated systems), all of which reduce the 
effectiveness of inspections.1078 From a national perspective, one national 
stakeholder pointed to the lack of harmonised licensing requirements across 
Member States as a structural vulnerability that criminals can exploit.1079 
Similarly, another authority noted that the presence of major ports in the country 
and the high volume of parcels processed daily present a significant 
enforcement burden.1080 Moreover, a third authority reported that customs 
authorities often lack the capacity to trace the origin of materials, further 
complicating efforts to detect and prevent illegal imports.1081 Finally, a 
stakeholder shared the opinion that, under the current conditions, it is virtually 
impossible to stop the shipment of illegal pyrotechnics.1082 

Study area 7: The role of online sales/mail order sales  

1072 Targeted interview with an EU agency.  
1073 Targeted interviews with national authorities: two Member States..  
1074 Targeted interviews with national authority: one Member State. 
1075 Targeted interview with an EU agency. 
1076 Targeted interviews with national authority: one Member State.  
1077 Targeted interview with an EU agency. 
1078 Targeted interview with a partner of an EU-funded project in this area. 
1079 Targeted interviews with national authority: one Member State. 
1080 Targeted interviews with national authority: one Member State. 
1081 Targeted interviews with national authority: one Member State. 
1082 Targeted interviews with national authority: one Member State. 

236 

 
 
 
 
The questions explored the scale and nature of online/ mail acquisition of 
pyrotechnics, the platforms used for illegal trade, delivery mechanisms, and 
enforcement challenges. 

Responses from stakeholders consulted on this area revealed that online sales 
are a significant and growing channel for acquiring pyrotechnics used in illegal 
activities. Several stakeholders estimated that more than half of such articles 
are obtained online, often from suppliers based in other EU Member States.1083 
However, the scale of this phenomenon is difficult to quantify precisely due to 
limited data and the fragmented nature of online trade.1084 

The trade in illegal pyrotechnics online operates across a spectrum of platforms. 
Stakeholders described a dual structure: on one hand, regulated marketplaces 
such as eBay, Amazon, and Wish, and on the other, unregulated or semi-
regulated environments including individual websites, social media platforms 
(Facebook Marketplace), and encrypted messaging apps, such as Telegram 
and Signal, private groups and anonymous transactions, which make detection 
and prosecution extremely challenging. While some platforms have monitoring 
systems in place, others remain largely unregulated.1085 

Delivery of illegal pyrotechnics is primarily organised through postal and courier 
services. According to two stakeholders, these shipments are often mislabelled 
to avoid detection.1086 Another respondent confirmed that postal parcels are the 
main delivery method, and noted that some national frameworks require specific 
permissions for such transfers.1087 An industry stakeholder also pointed to the 
role of unlicensed importers and miscategorised products in facilitating online 
trade.1088 

Challenges in preventing the online trade of illegal or diverted pyrotechnics 
include insufficient collaboration with major online platforms,1089 and a lack of 
enforcement capacity.1090 To address challenges, one stakeholder proposed 
more restrictive measures, such as limiting online sales to national markets and 
requiring companies to share customer and delivery data.1091 Meanwhile, others 
called for greater harmonisation of national laws, increased dedicated staffing 
resources, and a potential ban on online sales of certain products.1092 

1083 Targeted interviews with national authorities: two Member States.  
1084 Targeted interview with an industry organisation. 

Targeted interview with an EU agency. 

1085 Targeted interviews with national authorities: four Meber States, one EU agency, one EU-level industry 
organisation, two national level industry organisations; one sales and distribution platform, one partner 
of an EU-funded project. 

1086 Targeted interviews with national authorities: two Member States.   
1087 Targeted interview with a national authority: one Member State.  
1088 Targeted interview with an industry organisation. 
1089 Targeted interview with a national authorities: one Member State. 
1090 Targeted interview with an EU-level industry organisation. 
1091 Targeted interview with a national authority: one Member State. 
1092 Targeted interviews with national authorities: two Member States.  

237 

 
 
 
 
Overall, interviewees indicated that the online environment, particularly when 
combined with national legal differences and limited enforcement tools, 
presents a major vulnerability. 

Targeted surveys 

The targeted surveys aimed to gather evidence from national competent 
authorities and industry representatives by targeting a larger number of 
stakeholders compared to interviews and by asking more specific questions to 
each group consulted. 

The surveys have been launched on 4 March until 22 July. 

The team has reached the following stakeholder groups: 

●  National competent authorities, namely 

-  Relevant Ministries 
-  Customs authorities 
-  Law Enforcement authorities 
-  National  Contact  Points  under  the  legislation  on  chemicals  used  in 

Home Made Explosives 

-  National  authorities  part  of  the  Group  of  Experts  on  Pyrotechnic 

Articles 

● 

Industry: Manufacturers, distributors, importers and users of 
pyrotechnics as well as engineers through EU and national business 
associations (both at the national and EU level). In addition, the industry 
survey has been distributed to shipping companies, online marketplaces, 
consumer organisations and other stakeholders such as coordinators of 
EU-funded projects considered relevant by the European Commission. 

All stakeholders have been asked to forward the survey in order to reach the 
relevant person either within their organisation or across organisations and to 
ensure coverage of the different views. A first reminder was sent to 
stakeholders on 24 March. Following the request raised by authorities 
participating in the Group of Experts on Pyrotechnic Articles, who stressed the 
difficulties in covering areas outside their direct expertise, NCAs have received 
the survey in a Word file to facilitate distribution and allow authorities to provide 
joint feedback. Due to the low response rate, in agreement with European 
Commission, a second reminder was sent on April 2 following an extension of 
the deadline to April 18. To increase the response rate, a new deadline has 
been set for 16 May, which has been communicated to stakeholders via email 
with a further reminder on April 28. Another reminder has been sent to 
authorities through DG GROW. Additional time has been granted compared to 
the initial deadlines in order to increase response rate and balanced 
geographical distribution. 

238 

 
 
 
In total, the surveys gathered 47 replies from NCAs and 25 replies from the 
industry survey, distributed as follows. 

Table 10 Overview of stakeholders targeted through surveys and replies  

Stakeholder 

Stakeholders contacted 

Replies to date 

National Competent Authorities 

Industry 

Source: Consortium’s elaboration. 

NCAs 

93 1093 

59 

47 

25 

Overall, 47 replies were received. These are from 21 Member States and 2 SAC. 

Figure 22 Overview of responding authorities per Member States 

12

10

8

6

4

2

0

Source: survey addressed to national authorities. 

Among their responsibilities, half of the respondents are divide equally by Ministry 
of  Interior  (12,  25%),  and  by  law  enforcement  authorities  (12,  25%).  Customs 
authorities represent 12% of respondents (6 respondents), together with Other (5 
respondents). Under this category, there are three market surveillance authorities 
and  two  competent  authorities  for  explosives  legislation  which  were  not  listed. 
Additionally, five responses came from National Contact Points (NCPs), followed 
by safety authorities and the Ministry of Justice. Only one response was received 
from a Ministry of Economy. 

1093 These are authorities from 27 Member States and Schengen Associated Countries. In addition, 
National authorities, part of the Group of Experts on Pyrotechnic Articles, received the survey link 
through the CIRCABC platform. 

239 

 
 
 
 
 
Figure 23 Overview of responding authorities per category 

0

2

4

6

8

10

12

14

12

12

Law enforcement authority

Ministry of the Interior

Customs authority

Other

National contact points (for the reporting of
suspicious transactions, disappearances and…

6

5

5

Safety authority

4

Ministry of Justice

2

Ministry of Economy

1

Source: survey addressed to national authorities.  

The majority of respondents (70%, or 33 out of 47) identified their country as 
primarily a user or transit country for pyrotechnic articles, which includes 
involvement in addressing issues such as illegal imports or misuse. A smaller 
proportion (23%, or 11 respondents) indicated that their country plays both 
roles. Only one respondent (2%) classified their country as primarily a producer, 
mainly involved in the production and export of pyrotechnic articles. Meanwhile, 
2 respondents (4%) were uncertain about their country’s role. 

Industry 

A total of 25 replies were gather in the industry survey. As per geographical 
coverage, the majority of responses came from France (13), followed by 
Germany (3) and Spain (2). One response each was received from Austria, 
Croatia, Denmark, Portugal, Slovenia, Sweden, and one categorised as Other 
(UK). 

240 

 
 
 
 
Figure 24 Overview of industry organisations per Member State 

3

2

1

1

1

1

1

1

1

13

14

12

10

8

6

4

2

0

France Germany

Spain

Austria

Croatia Denmark

Other

Portugal Slovenia Sweden

Source: survey addressed to industry organisations. 

Among the 25 industry respondents, the majority (56%, 14 out of 25) identified 
as businesses. National industry representatives made up 32% (8), followed by 
EU-level industry representatives (8%, 2 replies). Two replies are from notified 
bodies for the assessment of pyrotechnics.  

Figure 25 Overview of responding industry organisations per category 

1

2

8

14

A business A national industry representative An EU-level industry representative Other
       (1) 

    (8) 

(14) 

(2) 

Source: survey addressed to industry organisations. 

Among business respondents, the most common role was importer (17), 
followed by distributor (10) and manufacturer (8). Fewer identified as involved in 
engineering (2), while 7 respondents selected other roles. 

Among the 14 business respondents, most were small enterprises with 10 to 49 
employees (9 respondents). Medium-sized businesses (50 to 249 employees) 

241 

 
 
 
 
 
 
 
 
 
 
 
made up 3 responses, while micro (1 to 9 employees) and large enterprises 
(250 or more employees) were each represented by just 1 respondent. 

Findings from the surveys 

Study area 1: Updated picture of the security problem 

Respondents across NCAs reported varying degrees of concern regarding the 
illicit use of pyrotechnics. While some countries noted only localised issues, 
others described widespread misuse with significant cross-border implications. 
Activities such as unauthorised sale (particularly online), deployment during 
public protests and use in ATM attacks were highlighted. Use in sports events 
and football matches emerged as a recurring theme in open responses. 
Although not always categorised as criminal in intent, the misuse of 
pyrotechnics in these settings, particularly by fans, has led to serious injuries 
and public safety concerns. Several respondents highlighted this as a growing 
issue, especially around New Year’s Eve and during major sporting events. The 
accessibility, ease of use, and low detection risk of these articles were 
commonly identified as factors contributing to their misuse. Notably, the 
categories most often implicated in criminal misuse were F3 and F4, with some 
respondents pointing to counterfeit or unclassified items. The consequences 
ranged from property damage and public disorder to serious injuries and 
fatalities, with several countries sharing specific incidents to illustrate these 
impacts. 

Most industry respondents report that misuse of related products occurs either 
rarely or occasionally, with only a small number describing it as very frequent. 
Illegal manufacturing is generally not considered a major concern, as the 
majority of respondents rated its significance as low. However, opinions were 
more divided regarding the diversion of products after sale, with equal numbers 
rating it as somewhat significant, neutral, or not very significant. In contrast, 
illegal trade is widely seen as a concern, with many viewing it as either 
somewhat or very significant. Intentional misuse is also a key issue, with 
several organisations rating it as very significant, while others remained neutral 
or considered it somewhat significant. The types of products most commonly 
involved are fireworks, often in combination with other items. Criminal methods 
typically include smuggling, online sales platforms, and black market 
operations. Despite these issues, most respondents believe the scale of the 
illegal market remains limited (under 10%) though a few perceive it as partially 
or very significant. However, one business noted that even below 10% is not a 
neglectable share. 

Study area 2: Harmonisation of national laws and practices 

NCAs identified several key areas that pose significant challenges in addressing 
the criminal misuse of pyrotechnic articles. The most frequently cited issue 
was e-commerce, reflecting growing concern over the ease with which 
pyrotechnics can be purchased online, often bypassing regulatory oversight. 

242 

 
 
 
Cross-border surveillance was the second most cited challenge, highlighting the 
difficulty of monitoring and controlling the movement of pyrotechnics across 
national boundaries, especially within the EU’s single market. Closely related is 
the issue of traceability. Other notable areas include: prosecution, enforcement, 
while retail and manufacturing were also flagged, though less frequently, 
indicating concerns about the point-of-sale environment and the production of 
illegal or unregulated pyrotechnics. 

Several respondents also cited falsification of product labelling, such as fake CE 
markings or reused registration numbers, as a specific concern. 

When asked about the effectiveness of criminal sanctions in their country, most 
respondents expressed scepticism. Only 1 respondent considered sanctions to 
be “very effective,” while 8 rated them as “effective.” In contrast, 15 described 
them as “ineffective,” and the largest group—23 respondents—gave a neutral 
assessment, suggesting that sanctions may exist but are not consistently 
applied or impactful. This ambivalence reflects broader concerns about 
enforcement and judicial follow-up. Several stakeholders noted that pyrotechnic 
offences often carry lower penalties compared to other explosive-related 
crimes, which may reduce deterrence. Others pointed to regulatory 
fragmentation and limited awareness among prosecutors and judges as 
contributing factors. 

Industry stakeholders noted that the current regulatory frameworks are lacking 
effectiveness, with the majority of respondents rating existing controls as either 
ineffective or very ineffective. Counterfeit issues appear to be less common, 
with only seven organisations reporting direct experience with them. There is 
mixed sentiment regarding the clarity and sufficiency of enforcement 
mechanisms, indicating uncertainty or disagreement about their adequacy. 
When asked whether the controls in place are sufficient to prevent misuse of 
pyrotechnics, only a small number of respondents expressed agreement, while 
a larger portion either disagreed or strongly disagreed. Similarly, clarity on 
whom to contact in case of suspicious activity was affirmed by some, but others 
expressed uncertainty or disagreement. However, there is a strong consensus 
(shared by 19 respondents) that enforcement practices vary significantly across 
Member States, highlighting inconsistency as a key concern. Several comments 
emphasised that while some countries, like France, have robust systems in 
place, such as sales registers and prefectural approvals, these are undermined 
by lax enforcement in other EU states. There were also concerns about the role 
of online platforms and postal services in facilitating illegal sales, with calls for 
stricter EU-wide regulation or even a ban on cross-border online sales. 

In terms of awareness, 10 respondents reported being fully aware of the 
criminal sanctions associated with misuse, 12 were aware of some types of 
misuse, and 3 were not aware at all. 

243 

 
 
 
Study area 3: Potential use of substances covered by Regulation (EU) 2019/1148 
on explosive precursors to make illegal pyrotechnic articles  

The extraction of explosive mixtures from pyrotechnics to create IEDs was 
reported as rare but concerning, with flash powder and black powder being the 
most commonly cited substances. Regulation (EU) 2019/1148 on explosive 
precursors received mixed reviews: some praised its role in limiting access to 
dangerous substances, while others criticised its limited enforcement and the 
ease with which determined actors could circumvent it. Those who supported 
the regulation cited its role in improving traceability and restricting access to 
precursors. Critics pointed to loopholes, such as the continued availability of 
restricted substances in pharmacies or the lack of awareness among economic 
operators. Several respondents suggested that the regulation could serve as a 
model for broader controls on pyrotechnics, particularly in the context of online 
sales. 

Industry’s responses to the question about explosive precursors revealed a 
mixed understanding. Some respondents confirmed that substances like 
potassium perchlorate and aluminium are used in illegal pyrotechnics, while 
others emphasised that the issue lies more in the misuse of legally 
manufactured compositions rather than the acquisition of restricted precursors. 

Study area 4: Cross-border exchange of information and cooperation 

Information exchange practices varied widely. While some authorities reported 
robust cooperation with national and international partners, others indicated 
minimal or no engagement. The primary focus of cross-border cooperation was 
the prevention of illicit trade and misuse, followed by criminal investigations. 
However, obstacles such as differing national rules, limited resources, and 
inadequate communication systems were frequently cited. Respondents called 
for improvements in traceability, enforcement, and prosecution, with some 
advocating for real-time data sharing platforms and joint operations. 

Cross-border communication is marked by strong information exchange 
between national competent authorities and domestic law enforcement 
agencies, but communication with authorities in other countries is notably 
weaker. Several barriers hinder effective collaboration, including limited 
resources, the absence of clear guidelines, and a lack of adequate training. To 
address these challenges, respondents suggested improvements such as the 
development of standardised communication platforms, the organisation of 
regular inter-agency meetings, and the creation of centralised databases to 
support more efficient and coordinated information sharing. 

For the industry, cross-border communication and cooperation remain areas 
with significant gaps. While information is exchanged with national authorities 
and law enforcement, collaboration with foreign counterparts is limited. 
Commonly shared data includes trends (17 mentions), incident reports (14), and 

244 

 
 
 
suspect profiles (14), with less frequent sharing of technical developments, 
suspicious activity, and theft cases. 

In business-to-business cooperation, key barriers include limited resources (18 
mentions), insufficient training and awareness (9), lack of guidelines (8), and the 
absence of proper information exchange systems (6). Legal and other 
unspecified challenges were also noted. 

Similar issues affect cooperation between businesses and public authorities. 
Limited resources (16 mentions), lack of guidelines and technological limitations 
(10 each), and insufficient training (9) were the main concerns, underlining the 
need for more structured and better-supported frameworks. 

Study area 5: Tracking and tracing high-risk articles  

Tracking and traceability were generally seen as valuable tools, though their 
effectiveness was often limited by gaps in implementation. Manufacturer 
markings and batch numbers were the most commonly used indicators, but 
many respondents noted that these were frequently missing or tampered with. 
Challenges included high implementation costs, resistance from industry 
stakeholders, and limited technical expertise. While some authorities reported 
that tracking played a critical role in investigations, others described it as 
minimal or ineffective, particularly in the absence of standardised systems. 

Tracking mechanisms are in place according to 13 industry respondents, while 
9 were unsure of their existence. The most commonly used methods include 
collaboration with law enforcement, internal investigations, and verification of 
suppliers and customers. Identified vulnerabilities are primarily concentrated in 
the e-commerce and retail sectors. 

Study area 6: Strengthening customs enforcement  

Customs authorities highlighted hurdles in detecting illegal imports of 
pyrotechnics due to limited detection technology, high shipment volumes, and 
inconsistent enforcement standards. Many respondents expressed uncertainty 
about the effectiveness of current tools, with some deferring to other authorities. 
Suggestions for improvement included standardised procedures, joint 
operations, and enhanced training. A few stakeholders proposed the creation of 
a European authorisation system to better control cross-border transfers of 
pyrotechnic articles. 

Study area 7: The role of online sales/mail order sales  

The survey indicates that a significant share of pyrotechnics used in illegal 
activities is believed to be sourced online, with online shops playing a major role 
in enabling access to pyrotechnics for criminal purposes. 

245 

 
 
 
When asked about the most common ways to purchase illegal pyrotechnics 
online, respondents identified several key channels. The most frequently 
mentioned were social media or messaging apps, followed by cross-border 
online purchases from non-EU countries and dark web marketplaces. These 
findings highlight the dual challenge of platform diversity and jurisdictional 
complexity. A major concern was the ease of purchasing pyrotechnics in 
countries where they are not restricted and shipping them into jurisdictions with 
stricter controls. 

In terms of delivery methods, private postal services were cited most often, 
followed by peer-to-peer transfers mentioned, highlighting the often-anonymised 
nature of such transactions, which complicates detection and enforcement 
efforts. Respondents also discussed challenges in platform monitoring. 
Messaging apps such as WhatsApp, Telegram, and Signal, along with dark web 
marketplaces and social media platforms like Facebook and Instagram, were 
considered particularly difficult to regulate. These platforms often lack 
transparency and are not subject to the same level of regulatory oversight as 
traditional e-commerce sites, making them attractive for illicit trade. Opinions on 
the sufficiency of national regulations to control online sales were mixed. Law 
enforcement agencies or ministries of the interior are almost equally split, 
suggesting that some enforcement bodies consider the legal framework 
adequate, even if challenges in enforcement persist. 

Online marketplaces play a varied role in the illicit trade of pyrotechnics. Nine 
respondents consider their impact non-significant, while others rate it as 
partially (6), significant (2), or very significant (3). Fourteen organisations report 
having measures in place to prevent misuse, including identity verification and 
sales registers, especially in France, where buyers must show ID and 
transactions are logged. Some companies avoid selling high-risk products or do 
not sell online at all. The German association also runs a dedicated working 
group on illegal fireworks. Views on the effectiveness of these measures are 
mixed: seven find them effective, five are neutral, and three consider them 
ineffective. Most respondents (17) report no issues with delivery channels, 
though a few note concerns. 

Follow-up questionnaire 

To complement the initial stakeholder consultation activities and address 
information gaps, mainly quantitative, that emerged at the interim stage, the 
study team prepared a follow-up questionnaire and circulated it to national 
authorities.  

Stakeholders were encouraged to coordinate their responses with the most 
relevant national services. Authorities were invited to submit their input by 27 
June 2025. Given the low response rate, extensions were progressively agreed 
upon up to 18 July. Responses were received from 12 Member States.  

246 

 
 
 
This short questionnaire focused on four key areas: security issues posed by 
the misuse of pyrotechnic articles; illegal production of pyrotechnics, referring to 
items manufactured outside the legal supply chain without proper authorisation; 
diversion of legally produced pyrotechnics into criminal circuits, such as through 
postal services or unlicensed purchases; and illegal trade involving either 
diverted or illicitly manufactured articles. 

Many Member States could not provide full responses due to a lack of data or 
relevance to their context. This was particularly evident in quantitative sections. 
Where data was lacking, some authorities provided valuable contextual 
information, such as enforcement challenges, legal definitions, and operational 
practices. 

The responses reveal that while some Member States systematically track 
incidents involving pyrotechnics, others rely primarily on anecdotal or qualitative 
accounts. The misuse of pyrotechnic articles is frequently associated with 
broader criminal activity, including youth violence and organised crime. Illegal 
production appears to be concentrated in a limited number of Member States, 
with others either unaffected or lacking relevant data. Identifying production 
sites and the materials involved remains a persistent challenge across Member 
States. Moreover, the responses suggest that diversion of legally produced 
pyrotechnics merits greater attention. This issue is often linked to weaknesses 
in the supply chain and/or inadequate controls at borders and in online 
marketplaces. Several Member States reported limitations in their ability to 
detect and intercept such illegal trade. In addition, concerns were also raised 
about the involvement of minors and the ease of access to pyrotechnics via the 
internet. Finally, multiple authorities highlighted the need for improved cross-
border coordination. 

The team used the responses to integrate the research findings presented in 
the Draft Final Report.  

Summary of written contributions 

Written  contributions  were  offered  to  stakeholders  as  an  alternative  or 
complementary  mode  of  engagement.  This  approach  was  introduced  as  a 
mitigation  measure  to  ensure  broader  and  more  flexible  participation, 
particularly for those unable to fill out the survey, attend interviews, or prefer to 
share their views in writing. Contributors were given full discretion regarding the 
length, format, and focus of their submissions, as well as the timeline for delivery. 

In total, two written contributions were received.  

Eurojust drew on case data from its Case Management System and identified 
relevant cases involving the criminal use of pyrotechnics, particularly in the 
context of production, illegal possession and trafficking, and use in ATM 

247 

 
 
 
attacks. These cases were linked to broader crime cases such as arms 
trafficking, money laundering, and terrorism and involved judicial cooperation 
from Eurojust through European Investigation Orders (EIOs), Mutual Legal 
Assistance (MLA) requests (such as witness hearings, searches, and seizures), 
European Arrest Warrants (EAWs), transfer of proceedings, and asset 
confiscation.1094 

A small contribution can be extrapolated from the exchanges for the 
consultation with a national authority declining to participate in a targeted 
interview, citing structural limitations in the national regulatory framework. 
Pyrotechnics are governed by federal administrative law, but implementation 
and oversight are decentralised and handled independently by each 
municipality. As a result, there is no single national authority or stakeholder 
competent to provide a consolidated response on the matter.1095 

Summary report of workshop 

23 September 2025, 14.00 – 16.00 (CET) 

Online (Microsoft Teams) 

Context and objectives of the workshop  

The workshop served as the final step in the stakeholder consultation for the 
study. Its main aims were to confirm whether the findings accurately reflect 
stakeholder experiences, to identify any gaps or overlooked aspects, and to 
assess the relevance of the study’s conclusions. It was also clarified that the 
findings presented are the sole responsibility of the study team and do not 
represent the views of the European Commission, which is not bound by the 
outcomes of the study. 

All feedback gathered during the workshop is integrated into the Final Report. 

Agenda and set-up  

The study team structured the workshop around the following agenda: 

1094 Written contribution from an EU agency.  
1095 Email exchanges with one national authority.  

248 

 
 
 
 
Table 11 Agenda 

Agenda 

Welcome and introduction to the workshop  

Presentation of key findings and lessons learned per areas 1, 2, 3, 4 

Note: The presentation will be followed by a discussion with participants 

Presentation of key findings and lessons learned per areas 5, 6, 7 and 

case studies 

Note: The presentation will be followed by a discussion with participants 

14:00 - 14:10 

14:10-15:00 

15:00-15:50 

Overview of the discussions and conclusions  

15:50-16:00 

Source: Consortium’s elaboration. 

An introductory session was organised to welcome participants, provide 
background information on the study, and explain the objectives and structure 
of the workshop. Initial polls were organised to gather general information and 
present the areas to stakeholders. 

The study team then presented the key findings of the Draft Final Report by 
grouping them according to the area of focus (1 to 7). Members of the study 
team presented the findings for their respective area of research. This was 
followed by a poll (rating from 1 to 5) on the question: “Do you agree with the 
findings on [respective section]?” and by a discussion guided through specific 
questions. The main takeaways from the discussions were then summarised in 
the concluding plenary session. 

The study team informed participants of the possibility of sharing feedback in 
writing (via email) by 25 September 2025. 

Participants 

In  agreement  with  the  European  Commission,  and  to  ensure  balanced 
representation, the study team invited representatives from various stakeholder 
groups which have participated in previous consultation activities, including: 

●  European Commission; 

●  Relevant Member States’ competent authorities; 

●  Member State's representative part of an EU-level instrument; 

● 

Industry organisations and industry representative associations. 

A total of up to 40 participants (including six study team members) took part in 
the workshop. 

249 

 
 
 
 
Key findings per area 

This section reports the feedback from participants per study area.1096 

Area 1: Updated picture of the security problem  

Questions to participants: 

Poll:  

●  To what extent do you agree with the findings presented for area 1? 

Specific questions: 

●  Have you detected small- or large-scale illegal manufacturing in your 

Member State? 

●  What are the main types of misuse of pyrotechnics in your Member 

State? E.g., organised crime, extremism/terrorism, public disturbances. 

●  Have you observed the involvement of youth in the criminal misuse of 

pyrotechnics? 

Figure 26 Poll results on the level of agreement with the findings of area 1 

25

20

15

10

5

0

22

3

6

0

2

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

Source: results of the polls launched during the workshop, N=33. 

Most respondents (25 out of 33) agreed with the statement, showing an overall 
positive sentiment with very few neutral or negative responses towards the 
finding presented. 

A representative from a Member State sought clarification on the mobile 
application for tracking pyrotechnics after explosions, which had been 
highlighted as a good practice during the presentation. The stakeholder asked 
which Member State was currently using such a system, and expressed interest 
in knowing the name of the application and whether it was actively in use at the 
time of the workshop. In response, a Member State authority involved with the 
application explained that the app allows users to visually recognise fragments 

1096 Not all stakeholders expressed feedback on all areas and/or questions.  

250 

 
 
 
 
 
after an explosion by taking a picture, which helps identify the type of fireworks 
involved. The database is being updated with all seized fireworks in the 
Netherlands, and there are plans to expand and translate the app for use by 
other Member States. 

A national agency raised a critical issue about the definition of illegal trade in 
the context of pyrotechnics, given the significant differences in national 
regulations. In Sweden, explicit permission is required to sell or trade 
pyrotechnic articles, so any transaction without such authorisation is considered 
illegal. However, in other countries where no such permission is required, the 
same trade would be legal. It was clarified that the study used the requirements 
outlined in the Pyrotechnics Directive to define authorised sales and trade, and 
that a more nuanced discussion of differences between Member States is 
provided in the report, with the concept simplified for the purpose of the 
workshop presentation. 

A Member State authority highlighted in the chat that a significant proportion of 
fireworks seized in the country do not bear a CE label, which is a clear 
indication of illegal production, as well as items featuring falsified CE labels. 

Finally, the European Commission stressed the importance of ensuring that 
findings are supported by evidence and that the study should highlight any gaps 
in the available data. 

Area 2: Harmonisation of national laws and practices 

Questions to participants: 

Poll:  

●  To what extent do you agree with the findings presented for area 2? 

Specific questions: 

● 

● 

If you believe a greater harmonisation could reduce the criminal misuse 
of pyrotechnics, which areas do you think would need to be more 
harmonised?  

In case you believe that the current categorisation under the 
Pyrotechnics Directive is problematic, which categories do you think 
should be modified, and in what way?  

●  Do you have evidence of any national measures aimed at limiting the 

criminal misuse of pyrotechnic articles that have affected pyrotechnics-
related crime rates?  

251 

 
 
 
Figure 27 Poll results on the level of agreement with the findings of area 2 

20

4

6

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

0

0

25

20

15

10

5

0

Source: results of the polls launched during the workshop, N=30. 

Most respondents (20 out of 30) agreed with the statement, showing clear 
support for the findings presented. 

The discussion then shifted to the broader question of what constitutes criminal 
misuse of pyrotechnics. An industry representative (EU level) questioned 
whether all participants shared the same understanding of this concept, 
highlighting the ambiguity and breadth of the term. In response, the study team 
clarified that their definition of criminal misuse was intentionally broad, 
encompassing any use of pyrotechnic articles for criminal purposes, as well as 
illegal trade and illicit production. 

Several stakeholders raised important points about the categorisation and 
regulation of pyrotechnic articles across the EU. A national-level industry 
representative emphasised that the current categorisation system, particularly 
for categories P1 and P2, needs improvement, describing this as the most 
pressing issue regarding categorisation from the perspective of manufacturers, 
reflecting ongoing concerns within the industry about the adequacy of existing 
classifications and their impact on safety and enforcement. Another Member 
State authority argued that the problem does not lie in the definitions provided 
by the directive, which clearly outline categories F1 to F4, T1, T2, P1, and P2. 
Instead, the challenge arises in practice, where products are sometimes 
incorrectly classified, e.g. items that should not be in P1 are placed there, for 
example. This misclassification is seen as a practical issue rather than a flaw in 
the directive itself. 

Further contributions illustrated the diversity of regulatory approaches across 
Member States. A Member State authority explained that in the Netherlands, 
the organisation and categorisation of pyrotechnics are generally satisfactory, 
with the greatest misuse occurring in category F4, which is already forbidden for 
consumers in all Member States. Despite these restrictions, F4 products remain 
available on the legal market and are still misused by criminals, often due to 
easy access to strong flash powder. Another Member State authority noted how 
the country faces lower issues with pyrotechnics related to imports, exports, and 

252 

 
 
 
 
internal movements of pyrotechnic articles thanks to strict national regulations, 
which closely resemble those for explosives, require licences for all activities 
involving pyrotechnics.  

Finally, another Member State authority highlighted the difficulties in controlling 
intra-EU trade, particularly in the context of e-commerce. The lack of 
harmonised controls across Member States limits the ability of customs 
authorities to enforce regulations effectively. The stakeholder advocated for 
extending successful national practices to the entire EU, underlining the need 
for greater harmonisation to address enforcement gaps and improve the overall 
regulatory framework. 

Area 3: Use of substances covered by Regulation (EU) 2019/1148 on 
explosive precursors to make illegal pyrotechnic articles  

Questions to participants: 

Poll:  

●  To what extent do you agree with the findings presented for area 3? 

Specific questions: 

●  Which is more significant in your context: illegal manufacturing or 

diversion/import of legal products? 

●  Detecting illegal manufacturing and distinguishing illegal from legal 

articles remains a challenge. Do you agree? 

●  Has Regulation (EU) 2019/1148 on explosive precursors changed the 
patterns of illegal manufacturing or misuse of pyrotechnics in your 
country? 

●  Do differences in licensing or enforcement Regulation (EU) 2019/1148 
on explosive precursors create vulnerabilities (that allow the misuse of 
explosive precursors in the manufacturing of pyrotechnics)? 

●  Local factors such as enforcement capacity and industry presence 
influence the risks of illegal manufacturing or diversion. What local 
factors are most influential in your country? 

●  Have you seen cases of criminals extracting pyrotechnic mixtures from 
legal articles to build IEDs? How significant is this compared to other 
risks? 

253 

 
 
 
 
Figure 28 Poll results on the level of agreement with the findings of area 3 

11

8

12

10

8

6

4

2

0

1

6

0

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

Source: results of the polls launched during the workshop, N=26. 

Most respondents were neutral (11), with fewer agreeing (8) or disagreeing (6), 
showing mixed opinions overall. 

Stakeholder interventions focused on the practical realities and limitations of 
controlling the criminal misuse of pyrotechnics, especially regarding explosive 
precursors. 

A law enforcement authority highlighted that while strict controls on explosive 
precursors are important, the study should also consider economic factors such 
as availability, demand, and pricing. The stakeholder explained that 
pyrotechnics are currently cheap, widely available, and in high demand. If any 
of these economic conditions were to change, there could be a shift back 
towards the use of traditional explosives like hand grenades. He emphasised 
that these economic factors are crucial and asked whether they have been 
addressed in the study. 

Stakeholders from an EU-level industry added another dimension, reminding 
participants that illegal products are not only produced within Europe but are 
also imported from third countries, with Albania cited as a significant source of 
flash bangers. Based on the association’s experience, it was noted that many 
products misused in Europe originate from outside the EU.  

A Member State authority contributed by suggesting that the regulatory 
approach used for explosive precursors in 2019 could be adapted for 
pyrotechnics. They advocated for better harmonisation, not just for the most 
powerful categories but also for F2 and F3, since all pyrotechnic articles have 
both legitimate and illegitimate uses. It was proposed that systems for 
monitoring suspect transactions, similar to those used for ammunition, could be 
considered for pyrotechnics sold both online and offline. 

A Member State authority reported in the chat that their country currently 
experiences nearly three explosions per day in criminal contexts, frequently 
involving heavy fireworks—both illegally and legally produced. These incidents 
often feature flash bangers containing between 25 and several hundred grams 
of flash powder. However, fireworks articles are also commonly used as 

254 

 
 
 
sources of flash powder for constructing IEDs. Customs authorities noted that 
IEDs can be made using lesser categories of fireworks, not just the most 
powerful ones. However, a Member State’s authority highlighted that the F4 
category provides particularly easy access to large quantities of flash powder at 
once. At the same time, the same stakeholder pointed out that F3 category 
fireworks are widely available for purchase from numerous online sites, 
whereas F4 fireworks are not as easily accessible on the open EU market. 
However, the Netherlands observed that F4 fireworks appear to be readily 
available via social media channels, driven by high demand on the illegal 
market. As a result, many heavy flash bangers seized in the Netherlands lack 
CE markings, indicating illegal production, and falsified CE labels are also 
frequently encountered. These dynamic underscores the ongoing risks posed 
by both the availability of powerful pyrotechnics and the adaptability of criminal 
actors in sourcing materials for illicit use. 

Area 4: Cross-border exchange of information and cooperation  

Questions to participants: 

Poll:  

●  Poll: To what extent do you agree with the presented findings on study 

area 4? 

●  To what extent do you agree with the findings presented for area 4? 

Specific questions: 

●  Do you think EU-wide information exchange systems can be used better 

for tackling the criminal misuse of pyrotechnics? E.g., SIS II, IMI, 
SCEPYLT. 

●  How do you view public-private cooperation on security issues of 

pyrotechnics? 

Figure 29 Poll results on the level of agreement with the findings of study area 4 

25

20

15

10

5

0

22

5

5

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

0

0

255 

 
 
 
 
 
Source: results of the polls launched during the workshop, N=32. 

A total of 27 respondents either agreed or strongly agreed, with only 5 neutral 
and none disagreeing, showing a clear overall positive sentiment for the need to 
increase cross-border cooperation and information sharing. 

Stakeholders provided detailed insights into the challenges of cross-border 
information exchange and cooperation, especially from the perspective of 
customs authorities. 

A Customs authority explained how the issue of cross-border cooperation is a 
very pressing issue. Most seizures in Sweden involve postal parcels arriving 
from other EU Member States, often containing F3 category items from 
countries where trade is not regulated. This creates a significant enforcement 
challenge: while the sale may not be a crime in the country of origin, importing 
these items into Sweden is illegal. The complexity is compounded by the fact 
that many parcels are consigned under fictional names, making it extremely 
difficult to initiate joint investigations with other Member States. Since a large 
number of these parcels originate from the same retailer in another Member 
State, cooperation with that country’s customs authorities would be the most 
effective way. In addition, it was also noted that many purchases in Sweden are 
made by underage individuals, which is not compliant with the pyrotechnic 
directive. It was also mentioned that these issues will be addressed in upcoming 
EU cooperation initiatives, such as Operation Armstrong, which will focus on the 
legal and illegal trade of pyrotechnics in parcel shipments. 

A national agency supported the comments, emphasising that cross-border 
regulation is complicated by the fact that an action may be legal in one country 
but illegal in another. The use of specific tracking systems was also raised, 
noting that some tools are designed for serial explosives rather than 
pyrotechnics, and that Member States use what is available in the absence of 
standardised regulation. 

A Member State authority confirmed facing similar difficulties with postal parcels 
from other EU Member States. The main challenge is that authorities can do 
little beyond seizing the goods. A suggestion for the use of SCEPYLT, currently 
used for explosives, was mentioned as a way to overcome several issues with 
pyrotechnics, including the issuance of EU authorisations for intra-EU trade and 
facilitating information exchange between Member States. 

Finally, a Member State authority noted that it is often challenging to determine 
whether pyrotechnic products found in parcels are legal or illegal, as counterfeit 
or uncertified items are frequently encountered. This ambiguity complicates 
enforcement efforts, and the stakeholder suggested that sharing information 
about such products between countries would enable authorities to better 
investigate and verify whether the items are officially sold or are illicit copies. 

256 

 
 
 
Area 5: Tracking and tracing high-risk articles 

Questions to participants: 

Poll:  

●  To what extent do you agree with the findings presented for area 5? 

Specific questions: 

●  Are you aware of any specific system used by Law Enforcement in your 
country to perform tracking and tracing of high-risk pyrotechnic articles? 

●  What kind of measures are needed, in your opinion, to ensure that 
current challenges to tracking and tracing are overcome? Of the 
following, which would you prioritise? 
o  Harmonised requirements for import / export and possession across 

EU Member States and implementation of a database; 

o  Stronger public-private collaboration (e.g. with manufacturers, postal 

companies, etc.); 

o  Requirements for manufacturers to add 'markers' that can support 

identification even through residue or shells. 

Figure 30 Poll results on the level of agreement with the findings of area 5  

19

3

3

2

1

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

20
18
16
14
12
10
8
6
4
2
0

Source: results of the polls launched during the workshop, N=28. 

Most respondents either agreed or strongly agreed, with only a few neutral and 
very little disagreement. 

Stakeholders focused on the economic and practical challenges of 
implementing traceability and tracking systems for pyrotechnics. An industry 
representative pointed out that the traceability system for explosives had cost 
the industry over EUR 5 million to establish and expressed doubt that the 
fireworks industry would be able to bear similar costs, especially given its 
current economic situation. An EU-level industry representative agreed, 
emphasising that such systems might only be feasible for high-risk articles, 
such as F4 or P2, but would be impossible to implement for lower-risk 

257 

 
 
 
 
categories like F1 to F3. It was noted that the industry could not support 
extending these costly requirements to all pyrotechnic items. 

A national agency added that, while there are provisions in the directive 
allowing batch-level traceability through the distribution chain, there is no 
system in place to trace products to the end user. The effectiveness of 
proposed solutions was also questioned, noting that the complexity and cost of 
implementing detailed tracking measures would be disproportionate to the 
benefits. For example, requiring manufacturers to add markers for identification, 
even through residues, might be technically possible, but would be nearly 
impossible to put into practice. 

Area 6: Strengthening customs enforcement 

Questions to participants: 

Poll:  

●  To what extent do you agree with the presented findings on study area 

6? 

Specific questions: 

●  How much do differences in Member States’ rules on pyrotechnics affect 

the ability to control their movement? 

●  To what extent are the rules and checks on pyrotechnics consistent 

when goods move between EU countries? 

●  To what extent do differences between Member States' customs 

enforcement affect the circulation of pyrotechnics? 

●  Have you noticed an increase in small parcel shipments of pyrotechnics 

(e.g., from online sales)? And related challenges? 

●  How would you rate the adequacy of current detection technology or 

procedures for identifying pyrotechnics? 

Figure 31 Poll results on the level of agreement with the findings of area 6 

20

25

20

15

10

5

0

5

2

2

0

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

258 

 
 
 
 
Source: results of the polls launched during the workshop, N=29. 

Most respondents expressed agreement or strong agreement with the findings 
on customs enforcement and issues stemming from intra-EU movements, with 
only a few neutral responses and minimal disagreement. 

 A customs authority emphasised the critical importance of sharing information 
about seizures between Member States, explaining how a single seizure can be 
as valuable, because it can alert authorities in other countries to activities they 
may not be aware of. The composition of law enforcement cooperation in 
Europe was also addressed, noting that it is often dominated by police 
agencies, while customs authorities have their own actions and networks, 
sometimes operating outside of these established frameworks. One of the major 
challenges and opportunities, is bringing police and customs together for joint 
operations, such as Operation Armstrong, which aims to address both legal and 
illegal trade in pyrotechnics through coordinated efforts. 

A representative from a Member State added that, while there are programmes 
for sharing information with other Member States, the lack of clear national 
contact points makes it difficult to send requests or seek information about 
specific pyrotechnic articles. The stakeholder stressed the need to establish 
designated contact points to streamline communication and cooperation, 
especially when multiple authorities within a country have overlapping 
competencies regarding illegal pyrotechnics. 

A Member State authority observed that in the illegal market there is an 
increased of high-risk pyrotechnic articles that cannot be traced by name, 
brand, or registration number, making enforcement and intelligence gathering 
especially challenging. This leads to need to have a dedicated platform or 
mechanism that would allow Member States to share information about these 
specific high-risk articles, facilitating cooperation and potentially helping to 
locate illegal manufacturing sites. A law enforcement authority highlighted the 
possibility of using the framework of the EU Commission’s EMPACT Firearms 
initiative, which has established National Firearms Focal Points. Since the 
scope of EMPACT covers the misuse of explosives and pyrotechnics, 
stakeholders suggested that the mandate of these focal points could be 
broadened to include systematic sharing and analysis of data on explosives and 
pyrotechnics. This would strengthen cross-border cooperation, improve 
intelligence on illegal production, and support more effective enforcement 
across the EU. 

Area 7: The role of online sales 

Questions to participants: 

Poll:  

●  To what extent do you agree with the findings presented for area 5? 

259 

 
 
 
Specific questions: 

● 

Is there one or more best practices that you believe could effectively 
tackle the issue of online illegal sales of pyrotechnic articles?  

Figure 32 Poll results on the level of agreement with the findings of area 7 

19

3

2

1

0

Strongly agree

Agree

Neutral

Disagree

Strongly disagree

20

18

16

14

12

10

8

6

4

2

0

Source: results of the polls launched during the workshop, N=25.  

The poll shows a strong overall agreement with the findings on online 
pyrotechnics sales and enforcement issues. Stakeholders engaged in a lively 
debate about the effectiveness and consequences of banning online sales of 
pyrotechnics. 

An industry representative expressed scepticism about the impact of a general 
ban on selling fireworks via web shops, arguing that such a ban would not deter 
criminals selling high-risk fireworks for illicit purposes; instead, it would primarily 
make business more difficult for legitimate operators. The implication was that 
regulatory measures targeting online sales might inadvertently disadvantage 
compliant businesses without meaningfully addressing criminal activity. An 
industry representative added that a ban can be considered for high-risk 
products, such as category F4, but extending it to all pyrotechnic products 
would be unreasonable and ineffective from the industry point of view. 

In contrast, A national agency supported the idea of an EU-wide ban on online 
sales, considering it a good practice. It was noted how if only one country 
imposes a ban, sellers in other Member States can still operate online, 
undermining the effectiveness of national restrictions. It was observed that 
when only one country imposes a ban, sellers based in other Member States 
can continue operating online, which undermines the effectiveness of national 
restrictions. Introducing an EU-wide ban would significantly reduce the ease of 
illegal pyrotechnic purchases, as authorities could close non-compliant websites 
and restrict access more effectively. A customs authority contributed with a 
practical enforcement perspective, noting that pyrotechnics are subject to age 
restrictions, yet there is currently no reliable way to verify the age of buyers 

260 

 
 
 
 
when transactions occur online across borders. It was noted that this represents 
a strong reason to prohibit online sales, as the current system does not align 
with the regulatory requirements for these products. 

Moreover, a Member State law enforcement also highlighted the operational 
challenges posed by online sales. Since most shipments are undeclared and 
unlabelled, it is difficult to identify the nature and risk of the goods being 
imported. The lack of categorisation and transparency means dangerous goods 
can enter countries without proper oversight, and customs authorities are 
expected to detect and manage these risks despite the sheer volume of 
shipments. 

A Member State authority noted that when regulation and control over legally 
produced pyrotechnic articles becomes stricter, such as measures preventing 
online sales, the illegal production of high-risk articles is likely to increase, since 
the demand for easily accessible explosives, particularly flash powder, will not 
decrease. Flash powder remains a preferred explosive due to its potency and 
ease of access, and tighter restrictions on legal channels may inadvertently 
drive more activity into the illegal market rather than reducing overall risk. 

Conclusions 

The study team provided an overview of key points of discussion and concluded 
with appreciation for the active and diverse participation, including contributions 
through live discussion, chat, and interactive polls. The study team emphasised 
that the issue of criminal misuse of pyrotechnics is complex and multifaceted, 
with many topics still requiring further exploration and resolution. This study is 
intended as an initial step to advance the conversation at the EU level. 

The study team integrated the feedback collected during the workshop into the 
Final Report, which will be formally submitted to the Commission. They thanked 
participants for their ongoing engagement, recognising the sensitivity of the 
topic and the challenges posed by data gaps. Attendees were invited to provide 
any additional written input by 25 September, and were informed that the 
presentation slides and discussion questions would be shared for further 
reflection. 

261 

 
 
 
 
 
 
 
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