Revision of 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
Date: 2026-03-26
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: area of freedom, security and justice

1 

Public Consultation  

Marketing and use of explosives precursors  

– updated rules 

Factual summary report 

1. Introduction 

Background to the Public Consultation 

Regulation (EU) 2019/1148 on the marketing and use of explosives precursors 
(hereafter, the Regulation) establishes harmonised rules on the making available, 
introduction,  possession  and  use  of  substances  and  mixtures,  so-called 
“explosives  precursors”,  that  could  be  misused  for  the  illicit  manufacture  of 
explosives. It seeks to limit the availability of explosives precursors to the general 
public and ensure appropriate reporting of suspicious transactions throughout the 
supply  chain,  both  offline  and  online.  By  reducing  the  risk  of  terrorists  and 
criminals  accessing  explosives  precursors and  enhancing  threat  detection,  the 
Regulation seeks to enhance security throughout the EU and beyond.1  

This  public  consultation  was  undertaken  in  the  context  of  the  evaluation  and 
impact assessment of  the  Regulation   + subject  matter.  The questionnaire 
consisted of two parts covering (i) the evaluation of the  Regulation and (ii) the 
assessment of impacts linked to a potential revision of the Regulation. 

The survey sought views from stakeholders on:  

■ 
■ 
■ 

■ 

the effectiveness of the Regulation in achieving its objectives 
the costs, benefits and efficiency of the Regulation 
the  coherence  of  the  Regulation  with  other  EU  and  national  policies  and 
legislation 
the relevance of the Regulation, for example, considering evolutions in the 
chemicals sector and the threat situation 

1 When reference is made to “European Union (EU)’ in this questionnaire, the three EEA EFTA 

States are also included (Iceland, Liechtenstein and Norway). 

 
 
 
 
 
 
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■ 
■ 

the ‘EU added value’ of the Regulation  
the impact of the Regulation on fundamental rights and freedoms 

This public consultation also solicited reactions to specific policy measures that 
may  be  considered  during  a  possible  future  revision  of  the  EU  framework  on 
explosive precursors. 

2. Methodology, distribution and scope of the Public Consultation 

In line with Better Regulation Guidelines, the public consultation was published 
on  the European  Commission’s ‘Have  Your Say’ website  and  was  open  for all 
stakeholders to participate.2 The public consultation was launched on 31 March 
2025 and ran for a period of twelve weeks, closing on 23 June 2025.  

The questionnaire was made available in the 24 official languages of the EU.  It 
included  24  open  and  closed-ended  questions.  The  questionnaire  included 
questions aimed to gather views on: (i) the implementation of the Regulation, in 
particular its effectiveness, efficiency, EU added value, relevance, coherence and 
impact  on  fundamental  rights  and  freedoms;  (ii)  the  scale  of  the  threat  from 
alternative explosives precursors; (iii) ways of controlling alternative explosives 
precursors; and (iv) the functioning of the single market for explosives precursors.  

3. Overview of respondents to the Public consultation 

A  total  of  208  respondents  replied  to  the  Public  consultation.  The  most 
represented group was EU Citizens (78%, 162). Reponses from Non-EU Citizens 
made up 9% (19), 6% of responses were from Companies/Businesses (13), 4% 
of 
from 
from  Business  Associations 
Academic/Research  Institutions  (4),  and  three  respondent  groups  were  each 
represented by 1 respondent, there were NGOs, Public Authorities, and Other. 

responses  were 

(8),  2%  were 

Respondents by user type (n=208) 

2 Marketing and use of explosives precursors – updated rules 

 
 
 
 
 
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This figure does not match the total number of submissions received during the 
public consultation. Ten contributions were excluded from this factual summary 
report,  as  they  were  either  duplicates  or  contained  general  remarks  about  EU 
regulation. 

3.1. Organisation size 

A total of 27 respondents stated the size of organisation they worked for, and  the 
category "Large (250 or more)" was reported by 12 respondents (44%), "Medium 
(<  250  employees)"  were  selected  by  3  respondents  (11%),  "Small  (<  50 
employees)" was noted by 4 respondents (15%), and "Micro (< 10 employees)" 
was indicated by 8 respondents (30%). 

Organisation size (n=27) 

3.2. Respondent country of origin 

A total of 32 countries were represented among the 208 respondents. However, 
30% (62) of the responses were from Germany making it the most represented 
country  in  the  sample.  All  other  countries  were  represented  by  <10%  of  the 
respondents. The second most represented country in the sample was France 
(9%, 18), followed by Poland (8%, 16), and Italy (7%, 15). 

4. Overview of responses 

Q1. How familiar are you with the Regulation (Regulation 2019/1148)? 
Across  the  208  respondents,  65%  (135)    stated  that  they  have  detailed 
knowledge of the Regulation. A total of 30% (62) stated that they are aware of 
the existence of the Regulation, but do not know details about its objectives or 
requirements. A minority (5%, 11), do not have any knowledge of the Regulation, 
and  all  of  these  respondents  are  citizens  except  one  organisation,  an 
Academic/Research Institution from Australia. 

 
 
 
How familiar are you with the Regulation (Regulation 2019/1148)? (n=208) 

4 

Q2. What is your role or involvement with regulated explosives precursors? 
All  respondents  stated  their  role  or  involvement  with  regulated  explosives 
precursors. The most selected option was Use of regulated explosives precursors 
for non-professional activities (50%, 104), followed by Academic and/or scientific 
research  in  the  field  of  regulated  explosives  precursors (39%,  81),  and  Use  of 
regulated explosives precursors for professional activities (29%,60). 

What is your role or involvement with regulated explosives precursors? (n=208) 

A total of 35 respondents provided additional remarks on their role or involvement 
with  regulated  explosive  precursors.  A  total  of  16  stated  that  they  were 
hobbyists/amateur chemists (46 %), 9 were students or academic users within 
the  chemistry  field  (26  %),  6  stated  that  they  were  professionals/industry 
stakeholders (17%), and 4 stated general or household use (11%).  

 
 
 
 
 
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Q2.1  If  you are  involved in the  sale  or  distribution  of  explosives precursors,  do 
you do this offline, online or both? 
A total of 13 responses were received in response to whether respondents are 
involved in the sale or distribution of explosives precursors, and if so whether do 
this offline, online or both. "Offline" was indicated by 9 respondents (69%), while 
"Both offline and online" was noted by 4 respondents (31%). 

If  you  are  involved  in  the  sale  or  distribution  of  explosives  precursors,  do  you  do  this 
offline, online or both? (n=13) 

Q3.1. Please explain if you are dealing with explosives precursors not included in 
the above list and describe your activity in relation to them.  
A  total  of  27  respondents  stated  whether  they  were  dealing  with  explosives 
precursors not included in a provided list and described their activities in relation 
to them. A few respondents did not directly address the question, however among 
those that did, the explosive precursors and the activities in which they are used 
by the respondents are given below:  

Explosive precursors 

Activity 

Nitrites 

Citric acid 

Used as dye precursors 

Cleaning agent for polishing oxides on metals 

Isopropyl alcohol 

Cleaning and degreasing 

Heavy  metal  salts 
AgNO3) 

(e.g., 

Used for silvering 

Acetylene 

Used as a reagent/fuel 

Hydrogen peroxide 

Perchloric acid (70%) 

Mentioned  in  context  of  organic  peroxide  formation  (some  form 
without it) 

to 

Used 
organometallic complexes 

form  non-coordinating  anions 

(perchlorate) 

for 

Nitrocellulose 

Used as a binding agent for optically active phosphors 

Propane 

Gasoline 

Diethyl ether 

Used for grilling and heating 

Used as vehicle fuel and for degreasing 

Common solvent in organic chemistry (not regulated but explosive 
risk noted) 

Ethanol 

Common solvent in organic chemistry (fire/explosion risk noted) 

Potassium permanganate  Used as an oxidizing agent 

Red phosphorus 

Used in chemistry hobby 

 
 
 
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Explosive precursors 

Activity 

Sulphuric acid 

Phosphoric acid 

Used as an acidic catalyst and drying agent 

Mentioned as a strong acid potentially included in regulation 

Hydrochloric acid 

Mentioned similarly to phosphoric acid 

Sulphur 

Alkali metals 

Mentioned as a possible explosive precursor 

Mentioned as potentially explosive-related substances 

Q3.2.  Please  specify  whether  you  take  any  control  and monitoring  measures  in 
relation to these explosives precursors which are not included in the Regulation.  
A total of 31 respondents specified whether they take any control and monitoring 
measures in relation to the explosives precursors which are not included in the 
Regulation. A total of 4 respondents stated that they did not take any additional 
measures (13%), the remainder outlined their practices which included ensuring 
secure  access  and  control,  for  example  through  restricted  access  and  locked 
storage (87%). As stated by one respondent “Amounts are kept low and access 
is restricted to trusted professionals.”  

Other measures included following institutional or legal protocols, and minimising 
and reducing risk. For example following lab safety protocols was cited, as was 
using  small  quantities,  and  avoiding  unnecessary  use.  Following  chemical 
handling best practices was also mentioned, for example  “Peroxides and other 
oxidizers are always stored separately from organics”, as was using monitoring 
and logging systems to track usage.   

Q4. How effective is the current system of controls and monitoring on regulated 
explosives precursors in achieving the following results?  
A total of 194 respondents reported how effective they felt the current system of 
controls  and  monitoring  is  on  regulated  explosives  precursors  in  achieving 
results. In regards Limiting the availability of restricted explosives precursors to 
the general public across the EU, Informing the supply chain, offline and online, 
of relevant restrictions and obligations regarding regulated explosive, and Raising 
awareness of the supply chain concerning risks related to the misuse of regulated 
explosives  precursors,  over  half  of  respondents  viewed  achievements  in  these 
areas as either highly effective or somewhat effective (68%, 132; 62%,120;  50%, 
97 respectively).  

In contrast, for Preventing regulated explosives precursors from being acquired 
and  used  by  terrorists  and  criminals  and  Improving  the  detection  of  potential 
misuse  of  explosives  precursors  throughout  the  EU,  over  half  felt  that 
achievements  were  not  effective  in  these  areas  (69%,  134  and  50%, 
97respectively).  

 
 
 
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In certain areas, namely Facilitating the free movement of regulated explosives 
precursors  within  the  EU,  Harmonising  control  and  monitoring  across  Member 
States,  and  Ensuring  comprehensive  and  effective  reporting  of  suspicious 
transactions,  disappearances  and  thefts  along  the  supply  over  a  quarter  of 
respondents  were  not  aware  of  the  effectiveness  (30%,58;  25%,  48;  28%,54 
respectively). 

How effective is the current system of controls and monitoring on regulated explosives 
precursors in achieving the following results?  (n=194) 

A total of 23 respondents provided additional comments to support their answers. 
Overall, the commentary was critical of the current system. The most prominent 
area of discussion was the negative impact the current system of controls and 
monitoring  has  on  legitimate  use.  Respondents  expressed  concern  that  the 
system  hinders hobbyist  and  educational  chemistry,  discourages scientific 
curiosity  and  experimentation,  and  makes  it  difficult  to  obtain  chemicals 
for benign  or  household  uses.  A  few  respondents  felt  that  this  has  a  negative 
impact  on  education  and  innovation  as  it  stifles  learning outside  formal 
institutions, discourages youth from pursuing STEM (especially chemistry), and 
slows research and innovation, especially among independent researchers. 

Q4.1. Do you have further comments on the effectiveness of the current system of 
controls and monitoring to achieve the results listed above?  
A total of 95 respondents provided further comments on the effectiveness of the 
current  system  of  controls  and  monitoring  to  achieve  the  results  listed  above. 
Overall, the responses underscored widespread dissatisfaction with the current 

 
 
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system, with many calling for more targeted and effective approaches to achieve 
the intended goals of safety and security. 

Nearly a third of respondents expressed dissatisfaction with the current system. 
Respondents  regarded  the  regulations  as  overly  broad.  Several  responses 
highlighted inconsistencies in enforcement across EU Member States, with one 
respondent  stating,  "Harmonization  is  poor  due  to  inconsistent  Member  State 
enforcement." Others suggested that the regulations disproportionately impacted 
legitimate users while failing to deter criminals. A recurring sentiment was that 
the focus should shift toward targeted monitoring and international cooperation 
rather than broad restrictions. 

Safety and security concerns were raised by nearly a third of respondents. While 
some  acknowledged  that  the  system  effectively  limited  access  to  dangerous 
chemicals for the general public, others argued that determined individuals could 
easily  circumvent  the  restrictions.  One  respondent  noted,  "Terrorists  order 
chemicals abroad and have the packaging mislabelled, making it impossible to 
stop them effectively." Another respondent emphasized that the regulations might 
inadvertently increase safety risks by encouraging amateur chemists to attempt 
hazardous processes, such as distilling sulfuric acid at home.   

Scientific research and innovation were impacted according to nearly a quarter 
of  respondents.  Several  expressed  frustration  that  the  regulations  hindered 
legitimate scientific exploration, particularly for hobbyists and amateur chemists. 
Respondents described how restrictions on common chemicals stifled curiosity 
and experimentation. Others complaint about the bureaucratic burden imposed 
on  researchers,  who  spent  significant  time  navigating  regulations  instead  of 
conducting experiments. 

Other areas that were mentioned included that the regulations restricted access 
to chemicals for legitimate purposes, such as education, research, and hobbyist 
activities, that the stigma surrounding regulated chemicals discouraged scientific 
curiosity  and  learning.  One  respondent  noted,  "The  younger  generation  really 
thinks there is something inherently criminal or dangerous about basic chemicals, 
which  were  once  thought  to  be  the  backbone  of  industrial  chemistry."    A  few 
responses indicated that the regulations imposed a disproportionate burden on 
small businesses and industries reliant on restricted chemicals. 

Q5. To what extent do you think the Regulation is implemented in a uniform way 
across Member States? 
A  total  of  192  respondents  stated  the  extent  to  which  they  think  Regulation  is 
implemented  in  a  uniform  way  across  Member  States.  A  total  of  39%  (75) 
respondents felt that it had either to a great extent or to some extent, while 26% 

 
 
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(50) felt it had been implemented to a limited extent. A minority (9%, 17) felt that 
it had not, and 27% (52) stated that thy did not have the knowledge to comment. 

To  what  extent  do  you  think  the  Regulation  is  implemented  in  a  uniform  way  across 
Member States? (n=192) 

Q5.1. Please clarify and explain how this could be addressed 
A  total  of  39  respondents  provided  further  clarification  on  how  the  Regulation 
could  be  implemented  in  a  uniform  way  across  Member  States.  Respondents 
outlined areas where they viewed weaknesses in the implementation and made 
suggestions for improvement.  

The  implementation  challenges  that  were  identified  included  inconsistent 
enforcement, as there is significant variation in how Member States interpret and 
enforce the Regulation, leading to confusion and legal uncertainty. As stated by 
one  respondent,  “The  Regulation  is  not  uniformly  implemented  due  to  varying 
interpretations and enforcement across Member States. Some countries impose 
stricter controls, while others are more lenient, creating confusion and unequal 
burdens for businesses. This inconsistency undermines harmonization.”. It was 
also  mentioned  that  chemicals  are  often  sold  online  or  mislabeled  to  bypass 
restrictions. 

The  suggested  solutions  to  improve  effectiveness  of  the  Regulation  included 
establishing a central coordination body or binding guidelines to ensure uniform 
application  and  standardised  EU-wide  enforcement.  A  licensing  system  was 
suggested under Article 5 to manage access rather than impose outright bans. 
Similarly,  controlled  distribution  was  suggested,  allowing  limited,  monitored 
access rather than full prohibition. A few respondents, however, suggested repeal 
or  reform  and  felt  significant  revision  was  needed  rather  than  amendments  to 
implementation.    

Q6.  To  what  extent  have  the  following  factors  hindered  the  effective 
implementation of the Regulation?:  
A  total  of  185  respondents  reported  on  the  extent  to  which  certain  factors 
hindered the effective implementation of the Regulation. Across legal, economic, 

 
 
 
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social and technological factors the respondents views were reasonably similar: 
between 39% and 49% of respondents felt that these factors hindered effective 
implementation  to  a  large  or  to  some  extent.  However,  at  least  40%  of 
respondents across all of these factors did not have the knowledge to comment 
on their impact. 

To what extent have the following factors hindered the effective implementation of the 
Regulation?  (n=185) 

A  total of 15  respondents  provided  supplementary  comments.  The  views  were 
varied  and  included  concerns  about  the  proportionality  and  practicality  of 
compliance  requirements,  which  some  respondents  find  burdensome  or 
discouraging –in contexts such as agriculture and scientific inquiry for example.  
While  acknowledging  the  importance  of  public  safety,  several  respondents 
questioned the effectiveness of deterring malicious actors, who are often seen as 
operating  outside  legal  boundaries.  Others  highlighted  inconsistencies  in 
enforcement across jurisdictions and the potential unintended consequences for 
legitimate users.  

Q6.1. You indicated that certain factors had hindered the effective implementation 
of the Regulation, at least to some extent. Could you explain what these factors 
are and how they negatively affected the implementation of the Regulation?  
A total of 66 respondents provided details on theirs views on what factors hinder 
effective implementation of the Regulation and how they do so. 

Nearly a third of respondents reported public safety and security concerns and 
felt that the Regulation had not achieved its intended goal of preventing misuse 
of  chemicals,  as  criminals  could  easily  bypass  restrictions.  One  respondent 
noted, "Bad actors which are already willing to break [the] law would not have 
great  difficulty  in  obtaining  precursors  or  manufacturing  their  own  precursors." 

 
 
 
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Others  criticised  the  Regulation  for  disproportionately  affecting  law-abiding 
citizens while having minimal impact on organised crime. 

Nearly a third of respondents discussed compliance and administrative burden 
and  described  the  Regulation  as  overly  bureaucratic  and  resource-intensive. 
Respondents  highlighted  the  high  costs  of  compliance,  particularly  for  small 
businesses,  and  the  complexity  of  adhering  to  the  Regulation’s  requirements. 
One respondent remarked, "The enormous administrative burden involved in the 
delivery  of  explosives  leads  to  a  high  degree  of  complexity  and  costs,"  while 
another noted that "deadlines in regulation for renewing verification upon sales 
are not adapted to the agricultural sector." 

Just  under  a  quarter  of  respondents  identified  regulatory  complexity  as  a 
significant barrier to  effective  implementation.  They  highlighted  issues  such  as 
unclear  definitions  within  the  Regulation,  inconsistent  enforcement  across  EU 
member  states,  and  the  lack  of  clarity  surrounding  key  terms  like  "suspicious 
transaction."  

A few respondents highlighted the financial burden of compliance, particularly for 
small businesses and individuals. Licensing fees, administrative overhead, and 
reduced trade opportunities were cited as significant challenges. One respondent 
remarked,  "Economic  factors  like  licensing  fees,  administrative  overhead,  and 
compliance burdens hit small businesses and private users hardest." Additionally, 
some respondents noted that the Regulation's impact on legitimate trade had led 
to unintended consequences, such as increased reliance on black markets.  

Knowledge and education gaps were also highlighted by a few respondents who 
noted that insufficient awareness and understanding among both the public and 
stakeholders  hindered  compliance.  One  respondent  stated,  "Social  factor: It  is 
simply unreasonable to expect every farm supply employee or others implicated 
in the sale of the aforementioned chemicals to know of the risks." Connectedly, 
social and cultural factors were mentioned by a few respondents who pointed to 
societal resistance and a lack of awareness as obstacles. Several respondents 
expressed frustration with public misunderstanding of the Regulation’s goals, with 
one  stating,  "Socially, 
led  to  overly  cautious 
the  fear  of  misuse  has 
implementation,  restricting  legitimate  low-risk  activities  without  proven  security 
gains." Others noted that cultural attitudes toward scientific exploration clashed 
with the restrictive nature of the Regulation. 

A  few  respondents  highlighted  the  uneven  implementation  of  the  Regulation 
across  EU  member  states  and  the  ethical  implications  of  restricting  access  to 
widely used chemicals. Additionally, technological challenges were mentioned by 
a few respondents who pointed to difficulties in detecting suspicious transactions 
and the limitations of current systems. One respondent suggested the need for 
"automated,  system-based  solutions  in  POS  systems,  similar  to  alcohol  sale 

 
 
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restrictions,"  while  others  emphasized  that  technological  barriers  hindered 
effective monitoring and enforcement. 

Q7.  To  what  extent  have  the  following  factors  facilitated  the  effective 
implementation of the Regulation? 
A  total  of  183  respondents  provided  feedback  on  the  extent  to  which  various 
factors  supported the effective  implementation of  the  Regulation. Legal factors 
were  viewed  most  positively,  with  42%  (77)  indicating  they  contributed  either 
significantly  or  to  some  extent.  Social  factors  followed,  with  27%  (49)  of 
respondents  perceiving  them  as  facilitators  of  effective  implementation.  In 
contrast,  32%  (59)  felt  that  economic  factors  did  not  support  implementation 
efforts.  Notably,  for  all  factors,  45%  (83)  or  more  of  respondents  expressed 
uncertainty about their impact, highlighting a general lack of clarity or consensus 
on these influences. 

To what extent have the following factors facilitated the effective implementation of the 
Regulation? (n=183) 

Four  respondents  provided  additional  views  and  the  principal  focus  of  the 
comments was that societal fears in relation to terrorism were the drivers of the 
Regulation which has resulted in “public distrust of chemistry”.  

Q7.1. You indicated that certain factors had facilitated the effective implementation 
of the Regulation, at least to some extent. Could you explain what these factors 
are and how they positively affected the implementation of the Regulation?  
A  total  of  45  respondents  provided  their  views,  however,  a  minority  directly 
addressed  the  question  and  outlined  the  factors  that  positively  affected  the 
implementation of the Regulation.  

 
 
 
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A  few  respondents  stated  that  the  implementation  of  the  Regulation  was 
positively  influenced  by  a  combination  of  legal,  social,  economic,  and 
technological  factors.  Clear  legal  frameworks  and  enforcement  mechanisms 
provided  structure  and  accountability,  for  example,  “Clear  guidelines  and 
increased  awareness  among  suppliers  and  users  have  helped  implement  the 
Regulation  more  effectively.  Improved  labelling  and  online  information  make  it 
easier  to  identify  restricted  substances  and  comply  with  legal  requirements, 
reducing unintentional misuse while maintaining a degree of access for legitimate 
purposes.”  Also  public  awareness  and  fear  of  terrorism  fostered  broad  social 
support. For example, as stated by one respondent “Heightened concerns about 
terrorism  led to  strong  support  for  restrictions,  even  when  risks  were  low.  This 
perception helped drive compliance but may also foster an illusion that regulation 
alone ensures complete safety, which can lead to overreach or complacency.”  

It was reported that technological tools, such as automated tracking and reporting 
systems, aided compliance, particularly for large-scale operations. Economically, 
larger  companies  adapted  more  easily  (sometimes  gaining  monopolistic 
advantages)  while  smaller  entities  struggled.  Respondents 
felt  social 
understanding  of  the  reasons  behind  regulation  helped  promote  acceptance, 
though concerns about overreach and the impact on legitimate users - especially 
in research and education  - were also noted. Overall, respondents felt that while 
the  Regulation  benefited 
its 
implementation  revealed  tensions  between  safety,  fairness,  and  scientific 
freedom. 

legal  and  societal  backing, 

from  strong 

Q8. If  you are  a market  participant (offline  and/or  online),  online marketplace  or 
business  association,  what  measures  have  you  adopted  to  implement  the 
Regulation? 
A  total  of  11  respondents  provided  comments  but  only  a  minority  directly 
addressed the question. The measures that were cited were in regards training, 
for example “all staff in 14.000 stores across Europe needs to be trained” and 
one  respondent  stated  they  conducted  promotion  of  voluntary  tracking  and 
industry-led training to balance security and access. 

Q8.1. If  possible,  please explain  your  answer and provide  a  link to any  relevant 
guidelines or voluntary codes.  
A total of 6 respondents provided commentary and details on relevant guidelines, 
the shared details are as follows: 

-  1  respondant    offers  platforms  for  staff  to  exchange  best  practices  and 
provides  information  on  current  developments  as  well  as  information 
material 

-  1 association introduced a Model Agreement 

 
 
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-  Know Your Customer (KYC) 
-  Responsible Care Security Code 

Q9. To what extent do the current requirements of the Regulation generate costs 
for you, your organisation or the organisations you represent?  
A total of 116 responses reported on the extent to which the current requirements 
of the Regulation generate costs for them, their organisation or the organisations 
they  represent.  In  most  cases,  <10%  (12)  of  respondents  were  subject  to  no 
costs.  This  is  with  the  exception  of  Costs  incurred  to  obtain  information  on 
regulated substances, Costs associated with reporting suspicious transactions, 
disappearances and thefts, and Costs associated with retaining transaction data 
where the rates were higher (18%,21; 14%,16 and 14%,16 , respectively were 
not subject to any costs). 

In  most  cases  significant  costs  were  reported  between  14%  and  24%  of 
respondents, however, for Costs associated with licensing procedures and Loss 
of  turnover due  to  the  removal of  certain  restricted  explosives precursors from 
sale to the general public, significant costs were incurred by a higher proportion 
(32%,37 and 42%,49). 

It  should  also  be  noted  that  for  most  areas,  between  40%  and  48%  of 
respondents did not have the information to report on this subject.  

To  what  extent  do  the  current requirements  of the  Regulation generate costs  for you, 
your organisation or the organisations you represent? (n=114) 

 
 
 
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A  total  of  5  respondents  provided  other  comments  related  to  cost.  These 
respondents mentioned social cost, specifically the hindrances experienced by 
those  pursuing  “Chemistry  in  Professional  and  Non-Professional  Context”  and 
wishing to pursue chemistry within education. Concrete costs were mentioned for 
obtaining chemicals, for example, as stated by one respondent “Huge costs have 
been made since the restrictions make us use other alternatives that are worse 
and more expensive”. 

Q9.1. If possible, please explain and quantify these costs 
A  total  of  19  respondents  provided  supplementary  comments,  however,  most 
respondents  stated  that  they  were  unable  to  quantify  the  costs  incurred,  for 
example, “Not possible since it depends but it may be upwards of 600% in some 
cases.” A few respondents discussed costs in terms of time, for example  “The 
limitations of the law cause severe additional paperwork. While hard to quantify, 
it  really  chokes  down  on  the  effectiveness  of  just  doing  business.  The  missed 
opportunity  to  sell  these  item  causes  severe  loss  in  this  section  and  also  the 
missed opportunity to do work with them.”. 

Q10.  Do  any  parts  or  provisions  of  the  Regulation  create  costs  that  are 
disproportionate to the benefits? 
A total of 179 responses stated whether any parts or provisions of the Regulation 
create  costs  that  are  disproportionate  to  the  benefits,  to  which  68%  (122) 
responded  in  the  affirmative,  4%  (7) responded  in  the  negative,  and  27%  (48) 
reported that they did not know. 

Do any parts or provisions of the Regulation create costs that are disproportionate to the 
benefits? (n=179) 

Q10.1. Could you please explain what parts or provisions of the Regulation create 
disproportionate costs?  
A total of 87 respondents provided further details on the parts or provisions of the 
Regulation that create disproportionate costs. 

A  third  of  respondents  outlined  administrative  and  operational  burdens. 
Respondents 
documentation 
excessive 
requirements, and verification processes as disproportionately costly, particularly 

bureaucracy, 

described 

the 

 
 
 
16 

for small businesses and hobbyists. Respondents noted that maintaining detailed 
transaction records, training staff, and investing in IT systems created financial 
logistical  challenges.  One  respondent  stated,  "Maintaining  detailed 
and 
hazardous substances records and navigating excessive bureaucracy has made 
it increasingly unprofitable to sell basic chemicals." 

Economic  concerns  were  raised  by  nearly  a  third  of  respondents  who 
emphasised the disproportionate financial costs associated with the Regulation. 
Increased  purchase  prices  for  regulated  chemicals,  the  need  for  costly 
alternatives,  and  the  financial  strain  on  small  businesses  were  recurring 
elements. One respondent noted, "Purchase prices of regulated chemicals rose 
disproportionately,"  while  another  explained, 
forcing 
manufacturers  to  dilute  the  compounds  creates  higher  barriers  of  entry  to  the 
market, while creating a strain on current manufacturers."  The financial burden 
was  seen  as  particularly  problematic  for  smaller  entities,  which  struggled  to 
absorb these costs. 

"Licensing  and 

Societal  costs  were  mentioned  in  various  capacities.  Security  and  safety 
concerns  were  mentioned  by  a  few  respondents.  They  questioned  the 
effectiveness  of  the  Regulation  in  preventing  terrorism,  arguing  that  criminals 
could still access regulated substances through illegal means. Respondents felt 
the measures disproportionately affected legitimate users while failing to address 
the  root  causes  of  terrorism.    A  few  respondents  discussed  accessibility  and 
freedom  constraints,  who  expressed  frustration  over  restricted  access  to 
chemicals  for  private  individuals,  hobbyists,  and  researchers.  They  felt  the 
Regulation infringed on personal freedoms and discouraged scientific curiosity. 

Q11.  To  what  extent  do  you  agree  with  the  following  statements  about  the 
Regulation? 
A  total  of  190  respondents  reported  on  the  extent  to  which  they  agreed  with 
various statements about the Regulation. The results were varied; 68% (129) of 
respondents agreed or strongly agreed that the Regulation is too ambitious, too 
detailed  and  covers  too  many  aspects,  a  total  of  46%  (87)  agreed  or  strongly 
agreed that there are gaps in the Regulation.  

Three quarters of respondents (76%, 144) either disagreed or strongly disagreed 
that  the  Regulation  is  relevant  considering  the  evolving  role  of  homemade 
explosives in terrorism and organised crime and 66% (125) either disagreed or 
strongly disagreed that the Regulation is sufficiently flexible considering current 
and future developments in the manufacturing of home-made explosives.  

An  area  in  which  views  were  split  is  on  whether  the  Regulation  provides  a 
comprehensive  policy  framework  for  regulating  explosives  precursors  as  33% 
(62) agreed to some extent while 40% (76) disagreed to some extent. 

 
 
To what extent do you agree with the following statements about the Regulation? (n=190) 

17 

A total of 116 respondents provided additional commentary. The principal focus 
was  on  terrorism  –  mentioned  by  over  half  of  respondents.  As  in  previous 
questions  in  the  consultation,  respondents  expressed  dissatisfaction  with  the 
regulation's scope and implementation, arguing that it disproportionately burdens 
law-abiding citizens while failing to deter criminals. For instance, one respondent 
stated,  "The  regulation  is  overly  restrictive,  burdening  legitimate  users  while 
failing to stop criminals who use unregulated precursors or black markets." While 
some  believed  the  regulation  had  reduced  the  availability  of  dangerous 
substances to the general public, others questioned its impact on actual security 
outcomes. Several respondents noted that terrorists and organized crime groups 
often circumvent regulations by using alternative methods or sourcing materials 
illegally  such  as  through  illicit  channels  or  manufacturing  them  independently. 
One  respondent  commented,  "Terrorists  procure  raw  materials  via  the  black 
market and thus undermine any control”, while another observed, "The regulation 
does not stop terrorists and criminals from creating explosives. A persistent threat 
can easily create explosives while avoiding regulated substances."  

In  line  with  previous  questions,  some  respondents also  outlined  dissatisfaction 
with the regulation's effectiveness and implementation, with recurring concerns 
about its unintended consequences for legitimate users, scientific progress, and 
societal perceptions of chemistry. They called for a more targeted, flexible, and 
balanced approach that prioritizes security while minimizing harm to innovation, 
education, and personal freedoms.  

 
 
 
18 

Q12.  To  what  extent  do  you  agree  with  the  following  statements  about  the 
Regulation?  
A  total  of  186  respondents  reported  on  the  extent  to  which  they  agreed  with 
statements about the Regulation. The views were split across respondents but 
similar across both statements; just under a quarter of respondents either agreed 
or  strongly  agreed  that  there  are  no  inconsistencies  in  terms  and  definitions 
throughout the Regulation and that there are no contradicting provisions within 
the  Regulation.  In  contrast,  just  under  30%  felt  either  strongly  disagreed  or 
disagreed with both statements.  

To what extent do you agree with the following statements about the Regulation? (n=186) 

A total of 47 respondents provided further comments.  Over a third of respondents 
highlighted inconsistencies and contradictions within the regulation, for example 
between Articles 7 and 8, which govern supply chain information and verification 
upon  sale.  One  respondent  noted,  “Article  7  provides  for  the  path  of  mere 
information in the supply chain. This sensible approach is completely undermined 
by  Article  8.”  Others  criticized  the  overlap  and  lack  of  alignment  with  existing 
chemical  regulations,  such  as  REACH  and  CLP,  which  create  confusion  and 
increase  compliance  burdens.  A  recurring  sentiment  was  that  the  regulation’s 
complexity made it difficult for laypersons and even professionals to interpret its 
provisions.  For  example,  one  respondent  stated,  “The  regulation  is  overly 
complicated and prevents  most  laymen  from  figuring  out  legal boundaries  and 
prerequisites.”  Suggestions  for  improvement  included  streamlining  definitions 
and  aligning  terms  across  regulatory  frameworks  to  enhance  coherence  and 
reduce operational challenges. 

Legal and compliance issues were the second most frequently mentioned theme, 
mentioned  by  nearly  a  third.  Respondents  expressed  frustration  with  unclear 
language and definitions, for example one respondent remarked, “Key terms like 
‘suspicious  transaction’  and  ‘professional  use’  are  poorly  defined,  leading  to 
inconsistent interpretation and fear-driven overcompliance.” Others criticized the 
regulation for imposing business-level procedures on private individuals, which 
they  felt  was  disproportionate  and  counterproductive.  Additionally,  national 

 
 
 
19 

deviations in enforcement were seen as undermining harmonization across the 
EU,  

Chemical-specific  issues  were  raised  by  a  few  respondents  who  pointed  out 
perceived inconsistencies in the regulation’s treatment of specific substances... 
Several respondents criticized the regulation for targeting chemicals that are vital 
for legitimate uses, such as car batteries, while allowing other substances that 
could  be  misused  to  remain  unregulated.  One  respondent  summarized  this 
concern  by  stating,  “Chemical  reagents  that  see  extensive  use  in  many  fields 
besides  explosives  manufacture  are  branded  as  explosives  precursors 
regardless of how vital they are.” 

Q13.  To  what  extent  do  you  agree  with  the  following  statements  about  the 
Regulation? 
A total of 179 respondents stated the extent to which they agreed with various 
statements  about  the  Regulation.  For  all  statements  between  just  over  half  of 
respondents either did not have the knowledge to respond or did not have a view 
to share.  

A total of 30% (53) of respondents either agreed or strongly agreed that National 
policy and legislation in their Member State is coherent with the Regulation, while 
25%  (45)  agreed  or  strongly  agreed  that  the  Regulation  is  coherent  with  the 
Regulation concerning the registration, evaluation, authorisation and restriction 
of chemicals (REACH Regulation). For all other statements, agreement was at a 
rate of 15% (27) or less. 

The  statement  that  garnered  the  most  disagreement  was  the  Regulation  is 
rendered more effective thanks to Article 9 of the Digital Services Act (‘Orders to 
act  against  illegal  content’)  where  31%  (55)  of  respondents  with  strongly 
disagreed or disagreed.  

 
 
To what extent do you agree with the following statements about the Regulation? (n=179) 

20 

A  total  of  38  respondent  provided  further  comments.  A  few  respondents 
expressed concerns about the independence and fragmentation of the regulation, 
noting  that  it  was  not  harmonized  with  other  laws  such  as  REACH,  CLP,  or 
environmental directives. One respondent stated, “The Regulation conflicts with 
REACH, CLP, and environmental laws, creating redundant compliance burdens. 
National variations further disrupt harmonization.” Another noted, “While I support 
sensible  regulation  in  principle,  this  Regulation  conflicts  with  the  goals  and 
methods of other EU frameworks. REACH and CLP are grounded in scientific risk 
assessment, while this law is fear-driven and inconsistent.” 

Others  highlighted  the  need  for  uniformity  across  EU  member  states,.  Other 
mentions included the practical challenges in enforcing the regulation, particularly 
in cases where national laws diverged or lacked clarity. For example, “National 
policy  coherence  with  the  Regulation  varies  among  Member  States,  hindering 
uniform implementation”.  

Q14.  To  what  extent  do  you  agree  with  the  following  statements  about  the 
Regulation? 
A  total  of  182  respondents  reported  on  the  extent  to  which  they  agreed  with 
various  statements  about  the  Regulation.  Levels  of  agreement  with  the 
statements ranged from 7% to 31% while disagreement ranged from 18% to 71%. 

Respondents most frequently agreed that Member States have issued national 
rules  on  regulated  explosives  precursors  that  go  beyond  the  scope  of  the 
Regulation (31%, 56), followed by the Regulation has achieved more than could 
have been achieved through national legislation implemented unilaterally by the 
Member States (17%, 31), and the Regulation has helped to create a level playing 

 
 
 
21 

field  at  EU  level  regarding  the  control  of,  and  access  to,  regulated  explosives 
precursors (17%, 31). 

Respondents most frequently disagreed that Businesses have benefited from the 
harmonised  framework  established  by  the  Regulation  (71%,  129),  followed  by 
EU-level  intervention  remains  warranted  to  limit  the  availability  of  regulated 
explosives  precursors  that  could  be  misused  to  manufacture  homemade 
explosives (59%, 107). 

To what extent do you agree with the following statements about the Regulation? (n=182) 

Q15. Overall, have you observed positive changes that would not have occurred 
in the absence of the Regulation? 
A total of 186 respondents stated whether they had observed positive changes 
that would not have occurred in the absence of the Regulation, to which 6% (11) 
responded  in  the  affirmative  but  the  majority  83%  (155)  responded  in  the 
negative.  

Overall,  have  you  observed  positive  changes  that  would  not  have  occurred  in  the 
absence of the Regulation? (n=186) 

 
 
 
 
22 

Q15.1. Please explain what these positive changes may be. 
A  total  of  8  respondents  elaborated  further  and  stated  the  positive  changes 
resulting  from  the  Regulations.  These  changes  included  greater  knowledge, 
awareness, and heightened interest in explosive precursors, implementation of 
“Dedicated  storage  and  management  procedure  for  substances  object  of  the 
regulation”,  improved  professional  access  to  the  market,  and  a  “widely 
harmonised single market, except MS with licensing system”. 

Q16. To what extent do you agree that the impact of the Regulation on fundamental 
rights  and  freedoms  (such  as  the  right  to  privacy,  the  right  to  protection  of 
personal data or the freedom to conduct a business) is justified. 
A  total  of  189  respondents  reported  the  extent  to  which  they  agreed  that  the 
impact of the Regulation on fundamental rights and freedoms is justified. Over 
half (54%, 102), felt it was not justified, while 43% (80) believed there was some 
level of justification. Specifically, nearly a quarter (23%, 42)  felt it was justified 
either to a great or some extent, and 20% (38) believed it was justified to a limited 
extent. 

To what extent do you agree that the impact of the Regulation on fundamental rights and 
freedoms is justified. (n=189) 

A total of 90 respondents expanded on their view.  Over a third of respondents 
expressed frustration with the administrative burdens imposed by the regulation, 
including  licensing  requirements,  documentation,  and  compliance  costs.  Many 
felt  that  these  hurdles  disproportionately  affected  small  businesses,  hobbyists, 
and  amateur  scientists.  One  chemist  remarked  ,  “As  a  chemist,  I  am  greatly 
frustrated  having  to  deal  with  the  costs  and  time-consuming  documentation 
required  to  purchase  some  of  the  most  basic  chemicals.”  Another  respondent 
noted, “The Regulation disproportionately restricts freedom to conduct business, 
burdening SMEs with high compliance costs.”  

Privacy and surveillance were a significant concern, mentioned in nearly a third 
of responses. Respondents criticized the regulation for infringing on their privacy 
through measures such as identity verification, data collection, and monitoring of 
transactions. They expressed fears of data breaches and misuse by third parties. 
One respondent stated, “The Regulation impacts rights like privacy and business 
freedom through ID checks, data collection, and licensing,” while another noted, 

 
 
 
23 

“Traffic of personal data always has a huge risk of data breaches, especially when 
third parties are involved.”  

Public safety and security was mentioned in a quarter of responses. While some 
respondents acknowledged the importance of safety measures, many questioned 
the  effectiveness  of  the  regulation  in  preventing  terrorism  or  criminal  activity. 
Several  argued  that  the  restrictions  disproportionately  affected  law-abiding 
citizens while failing to deter criminals, who could easily bypass the controls. One 
respondent  remarked,  “Making  certain  substances  more  difficult  or  illegal  to 
purchase only affects those already not breaking the law. If someone were to try 
and synthesize explosive materials they could still obtain the required materials.” 

Research  freedom  and  innovation  was  a  recurring  concern,  mentioned  by  a 
quarter of respondents. They emphasized that the regulation hindered scientific 
exploration, amateur research, and innovation by restricting access to essential 
chemicals.  Many  argued  that  the  regulation  stifled  curiosity  and  discouraged 
young scientists from pursuing chemistry as a hobby or career. One respondent 
stated, “Parts of the regulation that are effective at achieving their goal (that is, 
prevent 
justified. 
the  manufacture  of  homemade  explosives)  are 
However….many restrictions are so trivially easy to bypass, that the restriction 
really only impacts legitimate users. I also find it disturbing that the impact on the 
freedom of the sciences has not been discussed. This right applies to individuals 
just the same as companies and universities, and is severely restricted by this 
regulation!”. 

Q17. To what extent do you think the following issues pose a threat in the EU or in 
your country? 
A total of 202 respondents reported on the extent to which they felt issues related 
to the manufacturing of home-made explosives by criminals and terrorist usage 
of home-made or alternative explosive precursors posed a threat in the EU or in 
their country.  

All  of  the  issues  raised  were  viewed  as  a  serious  threat  by  <10%  (20)  of 
respondents. In the case of manufacturing home-made explosives by criminals, 
nearly half respondents viewed this as a minor threat. Similarly, 40% (81) viewed 
the  threat  of  terrorists  using  home-made  explosives  made  from  explosives 
precursors that are already regulated by the Regulation as minor. The threat of 
terrorists  using  alternative  explosives  precursors  that  are  not  regulated  by  the 
Regulation was viewed as slightly higher as 34% (67) of respondents rated it as 
minor while 19% (38) rated it as moderate. 

 
 
To  what  extent  do  you  think  the  following  issues  pose  a  threat  in  the  EU  or  in  your 
country? (n=202) 

24 

A  total  of  106  respondent  provided  comments,  many  of  which  covered  topics 
addressed through previous questions in the consultation. 

A third of respondents view the restrictions as overly burdensome for legitimate 
users,  such  as  researchers  or  hobbyists,  while  failing  to  deter  criminals  and 
terrorists.  Others  noted  that  criminals  often  bypass  regulations  by  sourcing 
chemicals 
the 
restrictions ineffective. A recurring sentiment was that the regulations might harm 
scientific progress and innovation without significantly enhancing security. 

illegally  or  manufacturing 

independently,  rendering 

them 

A quarter discussed criminal activities and emphasized the adaptability of criminal 
organizations  in  circumventing  regulations.  Respondents  noted  that  criminals 
often  rely  on  stolen  industrial  explosives  or  black-market  sources  rather  than 
homemade precursors. One respondent stated, "Criminals source explosives and 
explosives precursors regardless of this regulation". Others highlighted the use 
of non-regulated substances, such as flammable gases, in crimes like ATM thefts, 
suggesting that the focus on chemical precursors might overlook other significant 
threats. 

A  few  respondents  mentioned  terrorism  methods  and  largely  argued  that 
terrorists are unlikely to rely on homemade explosives due to their complexity and 
risk. They noted that terrorist attacks often involve alternative methods, such as 
vehicles, knives, or firearms, which are easier to obtain and use. One respondent 
remarked, "Terroristic attacks using explosives are very rare in the EU and are 
much more commonly performed with trucks, knives, or illegally obtained guns 
and  ammunition."  Others  emphasized  that  terrorists  could  acquire  explosives 
through  illegal  channels  or  smuggle  them  from  outside  the  EU,  rendering 
regulations on precursors ineffective. 

 
 
 
25 

Q18.  To  what  extent  do  you  think  the  following  activities  pose  a  risk  to  EU 
security? 
A  total  of  201  respondents  reported  on  the  extent  to  which  they  felt  certain 
activities posed a risk to EU security. In all cases, at least a third felt the activities 
posed  no  risk  (between  36%,  72and  59%,  118).    The  activities  of  the  highest 
concern are the Import of regulated explosives precursors from third countries to 
which 26% (52) noted this activity was a risk to a great or some extent, followed 
by Insufficient enforcement capacity which 25% (50) noted as a risk to a great or 
some  extent.  The  area  reported  of  least  concern  is  Storage  of  regulated 
explosives precursors as 59% (118) felt that it did not pose a risk to EU security.  

To what extent do you think the following activities pose a risk to EU security? (n=201) 

A total of 53 respondents provided their views and these echoed those shared 
under other questions in the consultation. In summary, the key areas of concern 
are that the current EU regulation disproportionately burdens legitimate users  - 
such  as  researchers,  educators,  and  hobby  chemists  -  while  offering  limited 
security benefits. Respondents argue that the regulation targets materials rather 
than  intent,  failing  to  deter  malicious  actors  who  often  bypass  legal  channels 
entirely. Many believe the rules hinder scientific progress, innovation, and public 
engagement with chemistry, while enforcement gaps, inconsistent oversight, and 
lack  of  education  across  the  supply  chain  further  undermine  effectiveness. 
Suggestions  for  improvement  include  shifting  focus  to  monitoring  large-scale 
purchases,  enhancing  enforcement  and  awareness,  and  enabling  responsible 
access through licensing rather than blanket restrictions. 

 
 
 
26 

Q19. High-risk chemicals are substances that can be used to manufacture devices 
that can spread lethal or poisonous gases to stage an attack. To which extent do 
you think that the Annexes of the Regulation should be expanded to cover such 
substances? 
A total of 189 respondents reported the extent to which they thought the Annexes 
of the Regulation should be expanded to cover high-risk chemicals to which 59% 
(111) felt that they should not and 34% (64) felt it should be to an extent (22% felt 
it should be limited, 7% felt it should be to some extent and 4% felt it should be 
to a great extent). 

High-risk chemicals are substances that can be used to manufacture devices that can 
spread lethal or poisonous gases to stage an attack. To which extend do you think that 
the Annexes of the Regulation should be expanded to cover such substances? (n=189) 

Q20.  Do  you  consider  that  the  Regulation  currently  covers  all  the  relevant 
explosives precursors? 
A  total  of  190  responses  stated  whether  they  consider  that  the  Regulation 
currently covers all the relevant explosives precursors. The views were split, 35% 
(67) felt that it does, 37% (70) felt it does not, and 28% (53) stated that they were 
unsure. 

Do  you  consider  that  the  Regulation  currently  covers  all  the  relevant  explosives 
precursors? (n=190) 

Q20.1. Which  explosives  precursor(s)  should  be included  in  the  Regulation  and 
why?  
A total of 51 respondents provided further information in regards which explosives 
precursor(s)  should  be  included  in  the  Regulation  and  why.  Most  felt  that  no 
further  additions  should  be  made.  Some  respondents  also  remarked  that 
everyday  substances  are  precursors  therefore  questioned  the  utility  of  further 

 
 
 
 
27 

additions.  As  stated  by  one  respondent    “How  would  one  define  an  explosive 
precursor? All of the substances listed in the regulation could be synthesized from 
non-regulated substances. I am not advocating in adding additional substances 
but  rather to  eliminate  tracking  of  some.  Acetone,  hydrogen  peroxide,  etc.  are 
chemicals  essential  for  hobbyist  and  professional  use  that  can  be  easily 
concentrated to levels required for explosive production.” 

Q21. To what extent do you think certain market participants (e.g., farmers, other 
professional users, large companies, public institutions) or business-to-business 
sales should be excluded from the verification upon sale obligation? 
A  total  of  189  respondent  stated  the  extent  to  which  think  certain  market 
participants  or  business-to-business  sales  should  be  excluded  from  the 
verification  upon  sale  obligation.  Most  respondents  (76%,  144)  supported 
exclusion to an extent, specifically 50%  (94) felt it should be to a great extent, 
16% (30) felt it should be to a some extent, and 10% (19) felt it should be to a 
limited extent. 

To what extent do you think certain market participants  or business-to-business sales 
should be excluded from the verification upon sale obligation? (n=189) 

Q21.1. Which market participants should be excluded from the verification upon 
sale obligation and why?  
A  total  of  68  respondents  provided  their  views  on  which  market  participants 
should be excluded from the verification upon sale obligation. While some felt all 
market  participants  should  be  excluded,  of  the  respondents  that  made 
suggestions, the following participants were proposed for exclusion: 

-  Academics/academic and research institutions/education institutions 
-  Farmers 
-  Within B2B transactions 
-  Certified laboratories 
-  Hobbyists 
-  Public companies 
-  Professional users 
-  Manufacturers 

Very few outlined their reasons but of those that did, explanations included that 
participants  using  very  small  amounts  should  be  excluded  to  reduce  the 

 
 
 
28 

administrative  burden,  and 
from 
simplification and that “the manufacture, distribution and end use of ammonium 
nitrate-based fertilisers are integrated into a single supply chain”. 

fertilizer  sector  could  benefit 

that  the 

Q22.  To  what  extent  do  you  think  that  the  exclusion  from  the  scope  of  the 
Regulation provided for in Article 3 (13) for homogeneous mixtures is too  strict 
(and thus that the 1% should be increased)? 
A total of 183 respondents stated the extent to which they agree that the exclusion 
from the scope of the Regulation provided for in Article 3 (13) for homogeneous 
mixtures of more than was too strict. Only 4% (7) said ‘Not at all’, while 72% (132) 
agreed to an extent. 

To what extent do you think that the exclusion from the scope of the Regulation provided 
for in Article 3 (13) is too strict? (n=183) 

A total of 67 respondents provided supplementary comments and nearly half felt 
that the strictness of the 1% concentration threshold for regulated chemicals was 
overly  restrictive  and  created  unnecessary  burdens  for  manufacturers,  sellers, 
and users. For instance, one respondent stated, "The 1% threshold is overly strict 
and excludes many harmless, complex mixtures from exemption, even when the 
risk of extraction or misuse is negligible." 

A  third  of  respondents  reported  on  the  technical  impracticality  of  extracting 
chemicals  from  mixtures  with  such  low  concentrations,  with  one  noting,  "The 
amount of time and resources necessary to concentrate that 1% is so large that 
it's  impractical  to  do”.  Others  pointed  out  that  the  1%  limit  rendered  many 
products  ineffective  for  their  intended  purposes,  such  as  fertilizers  or  cleaning 
agents.  

A  few  respondents  acknowledged  the  importance  of  safety,  but  questioned 
whether  the  1%  threshold  meaningfully  reduced  risks.  Others  suggested  that 
higher  thresholds,  such  as  5%,  could  maintain  safety  while  allowing  for  more 
practical applications.  

 
 
 
29 

Q23. Do you think that the concentration thresholds (see columns 2 and 3 of table 
of Annex 1 of the Regulation) should be amended? If yes, why should that be?  
A  total  of  93  respondents  provided  their  views  on  whether  they  think  the 
concentration  thresholds  should  be  amended,  to  which  nearly  half  (45%,  42) 
directly addressed the question and responded in the affirmative. The reasons 
given included to support education, laboratory use, and hobbyists, and as stated 
by one respondent “Yes. Current thresholds are overly restrictive, limiting access 
to  chemicals  vital  for  agriculture,  pharmaceuticals,  and  industry.  Raising 
thresholds would reduce burdens on legitimate users while maintaining security 
through monitoring and licensing. Criminals bypass controls regardless, so focus 
should  be  on  enforcement,  not  stricter  limits.”  Some  respondents  noted 
thresholds should be increased for certain substances in particular such as nitric, 
sulfuric acid, hydrogen peroxide, H2O2, and the named Acids.  

Two  respondents  replied  in  the  negative  but  did  not  provide  supporting 
information. While several of the other respondents did not explicitly state their 
position, they expressed dissatisfaction with the current thresholds and viewed 
them as too low. 

Q24.  Do  you  have  any  suggestions  on  how  to  improve  the  current  system  of 
controls and monitoring on explosives precursors (including with non-legislative 
measures)?  
A  total  of  86  respondents  provided  their  views  on  how  to  improve  the  current 
system  of  controls  and  monitoring  on  explosives  precursors.  A  quarter  of 
respondents  called  for  the  relaxation  or  repeal  of  existing  regulations,  arguing 
that they are overly restrictive. Others proposed alternative approaches, such as 
focusing on quantity limits rather than concentration thresholds, or implementing 
licensing  systems  that  are  accessible  to  private  individuals.  One  respondent 
emphasized,  "Instead  of  limiting  the  concentration,  the  amount  that  can  be 
purchased should be limited—like with red phosphorus."  

A  quarter  of  respondents  advocated  for  targeted  monitoring  of  suspicious 
transactions  and  individuals  rather than  broad  regulations  that  affect  all  users. 
Others suggested creating centralized systems to flag unusual purchases, such 
as  a  platform  linked  to  personal  identification.  A  recurring  sentiment  was  that 
stricter monitoring could deter misuse without stifling legitimate activities. Another 
respondent  proposed,  "Creating  a  file  associated  with  a  personal ID which  will 
work  across  multiple  manufacturers/sellers and  will  be  used  to  flag  suspicious 
purchases." 

Accessibility  and  legitimate  use  were  discussed  by  a  quarter  of  respondents, 
many  of  whom  expressed  frustration  with  restrictions  that  limit  access  for 
hobbyists,  researchers,  and  educators.  They  argued  that  the  regulations 
disproportionately affect individuals with legitimate purposes, such as chemistry 

 
 
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enthusiasts  or  small-scale  researchers.    Suggestions  included  allowing  small-
scale access to regulated substances, and ensuring that legitimate users are not 
unfairly burdened. A respondent proposed, "Personally, I think that a system of 
licenses,  free  to  obtain  and  obtainable  even  by  the  common  citizen,  on  which 
every  transaction  is  registered,  will  do  the  job  of  avoiding  illegal  misuse  of 
substances." 

International  and  cross-border  cooperation  was  highlighted  by  a 
few 
respondents,  who  stressed  the  importance  of  harmonizing  regulations  and 
improving  collaboration  across  countries.  Some  suggested  standardizing 
definitions  and  reporting  processes  within  the  EU  to  ensure  consistency.  For 
example,  one  respondent  proposed,  "Legal  clarity:  define  what  constitutes  a 
'suspicious transaction' in a harmonized way throughout the EU. Standardization 
and  harmonization  of  reporting  processes."  Others  emphasized  the  need  for 
stronger border controls to prevent the illicit movement of explosives precursors. 

A few respondents advocated for increasing awareness and knowledge among 
both  users  and  industry  stakeholders.  Suggestions  included  mandatory  safety 
seminars for non-professionals, voluntary industry training programs, and better 
communication throughout the supply chain. One respondent noted, "Improving 
education  and  awareness  throughout 
the  supply  chain  would  enhance 
understanding  of  obligations  and  restrictions."  Another  proposed,  "Instead  of 
banning  chemicals  above  a  certain  percentage,  it  should  be  connected  with 
safety seminars non-professionals have to attend." 

A  few  respondents  recommended  leveraging  digital  systems  to  enhance 
monitoring  and  compliance.  They  suggested  implementing  electronic  systems 
capable  of  detecting  suspicious  sales  or  creating  online  reporting  platforms  to 
streamline processes. For example, one stated,  "Introducing better digital tools 
for  transaction  monitoring,  like  online  reporting  systems  and  data  sharing 
between countries, could help." 

Q25. Would you like to share any other views on the Regulation? 
A  total  of  97  respondents  shared  their  final  remarks.  Nearly  half  expressed 
concerns about how the Regulation infringed on individual liberties. Many felt that 
the  restrictions  on  chemical  access  disproportionately  targeted  law-abiding 
citizens,  particularly  hobbyists  and  amateur  chemists,  while  failing  to  deter 
criminals. One respondent stated, "I am generally in support of efforts to restrict 
the  availability  of  explosive  precursors.  But  in  the  current  form,  the  impact  on 
basic freedoms appears to outweigh the benefits, especially in the case of sulfuric 
acid." Others highlighted the stigmatization of legitimate scientific curiosity, with 
one remarking, "This regulation makes young and curious people fear that they 
will be prosecuted because of their interest in these chemicals." 

 
 
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Over  a  third  of  respondents  argued  that  the  Regulation  did  not  to  prevent 
criminals  or  terrorists  from  obtaining  restricted  substances,  as  alternative 
methods or black-market access remained available. One respondent noted, "I 
think the regulation is ineffective at preventing malicious  people from obtaining 
these  precursors.  An  unregulated  market  already  exists.  I  believe  making  all 
these  substances  (except  NH4NO3,  (per)chlorates)  available  AND  making 
buyers fill out an end use declaration is much more effective. This way malicious 
people are more likely to buy from legitimate sources making it easier to identify 
them. When a suspicious order is placed (unusually large quantities, etc.) it can 
be investigated."  

Just  under  a  quarter  of  respondents  highlighted  the  Regulation’s  detrimental 
impact on scientific advancement and creativity. They argued that the restrictions 
stifled  innovation  by  limiting  access  to  essential  chemicals  for  research  and 
experimentation. One respondent explained, "The regulation is part of a trend in 
legislation  that  recognizes  the  potential  harm  of  chemicals  but  overlooks  their 
everyday  benefits  in  many  contexts.  The  comparatively  easy  availability  of 
chemicals  a  few  decades  ago  allowed  many  amateurs  to  acquire  experience, 
which  they  later  transformed  into  a  career.  This  is  becoming  increasingly  rare 
today, stifling innovation in science and business." Another emphasized the need 
for  a  balance  between  safety  and  fostering  innovation,  stating,  "We  need 
chemistry  to  create  future  technology,  to  lead  and  to  show  the  world  that 
democracy,  freedom  of  experiments,  and  ideas  will  lead  to  prosperity." 

A  few  respondents  highlighted  the  financial  and  administrative  burden  the 
Regulation imposed on businesses and industries. They noted vague definitions, 
excessive  red  tape,  and  the  impracticality  of  enforcing  certain  provisions,  and 
increased costs associated with compliance and the negative impact on smaller 
enterprises. One respondent stated, "The Regulation puts unnecessary red tape 
and burden mostly on small companies and private individuals that will disrupt 
their commercial or academic activities." A few also emphasized the importance 
of fostering scientific curiosity and educating the public about safe chemical use 
rather than imposing blanket restrictions. One respondent suggested, "If the EU 
wants  to  make  society  safer,  it  should  invest  in  education,  curiosity,  and 
opportunity—not  restrict  chemicals.  Support  science,  empower  hobbyists,  and 
create pathways for young minds to explore." 

Disclaimer:  This  document  should  be  regarded  solely  as  a  summary  of  the 
contributions made by stakeholders in the open consultation on ‘Marketing and 
use of explosives precursors – updated rules’. It cannot in any circumstances be 
regarded as the official position of the Commission or its services. Responses to 
the consultation activities cannot be considered as a representative sample of the 
views of the EU population.”