Ultimo aggiornamento 16 June 2026

When it comes to explosives, people immediately think of the finished product.
In reality, the real danger does not come from the explosive itself, but from the substances and mixtures that can be used to make it.

These are compounds commonly used in industrial processes: acids, peroxides, nitrates, and solvents. They are found in surface treatment facilities, laboratories, maintenance shops, farms, and even in large retail stores.

And it is precisely their accessibility that has necessitated a much stricter regulatory framework in recent years.
Regulation (EU) 2019/1148 was adopted with this objective in mind: to prevent legitimate substances from being converted into explosives for illicit purposes.

Why is there a regulation on explosive precursors?

The European Union has long recognized that various attacks and criminal activities have been carried out using products purchased legally through standard commercial channels. Nitric acid, sulfuric acid, hydrogen peroxide, nitrates: substances that we all use every day and that, if purchased in unusual quantities or concentrations, can be converted into homemade explosives.

The new Regulation 2019/1148, effective as of February 1, 2021, completely replaces the previous regulatory framework and introduces a preventive control system based on:

• restrictions on sales to private individuals
• Due diligence obligations for economic operators
• transaction traceability
• rapid reporting of suspicious activity
• staff training

Two categories, one shared responsibility

The Regulation distinguishes between:

• restricted explosive precursors
• explosive precursors subject to reporting requirements

The first category covers the most sensitive substances, for which limit concentrations are established to determine whether a product can be sold freely, only to professionals, or cannot be sold to the general public.

The second category covers very common substances (e.g., acetone, nitrates, metal powders), which are not prohibited but require special care during sale and storage, and, above all, require that any abnormalities be reported within 24 hours.

The system works only if every link in the chain—manufacturer, distributor, retailer, and professional user—acts responsibly.

Professionals and business operators: roles that cannot be improvised

The regulation introduces precise definitions:

• Professional user: someone who uses the precursor in the course of their work.
• Economic operator: anyone who places a product on the market, whether offline or online.

Specific obligations apply to both, but the role of economic operators is even more delicate: they cannot simply sell a product; they must assess the customer, the intended use, and compatibility with the declared activity.

This means that sales staff, buyers, warehouse staff, and customer service representatives must be trained to:

• identify the products covered by the Regulation
• identify professional clients
• request and retain the proper documentation
• reject suspicious transactions
• report thefts, missing persons, or irregularities promptly

It is a cultural shift even before it is a regulatory one.

When a product can no longer be sold to consumers

Some of the best-known examples include:

• nitric acid at a concentration of more than 3%
• hydrogen peroxide with a concentration of more than 12%
• sulfuric acid at more than 15%

These are very common consumer products, but their status changes completely once they exceed the threshold value.

Furthermore, in Italy, the Ministry of the Interior has adopted a very clear policy: no licenses for private individuals.
This means that, unlike in other EU countries, any product exceeding the limits set out in Annex I may never be sold to a consumer.

Suspicious Transactions: How to Spot Them and Why You Should Report Them Within 24 Hours

The Regulation lists several types of behavior that should raise a red flag:

• a customer who cannot explain why they are using the product
• quantities or combinations that are unusual for the market
• refusal to provide documents
• unusual payments, especially in cash
• requests from parties outside the industry

In such cases, the operator may (and must) refuse the sale and report it to the national contact point at the Ministry of the Interior.

The same applies to missing persons and thefts, which must be reported within 24 hours.
Failure to report such incidents is a criminal offense.

It’s not just a compliance requirement—it’s a security system that involves the entire company

The regulation goes beyond just sales.
It requires that the entire company supply chain be structured in such a way as to prevent unauthorized access:

• safe storage procedures
• procurement controls
• regular staff training
• supplier evaluation
• monitoring of internal inconsistencies

The result is an integrated safety and security approach that goes far beyond traditional chemical safety.

Penalties: What Risks Does the Company Face?

The penalties are severe, including:

• up to 18 months in prison and a fine for the unauthorized sale of restricted precursors
• up to 12 months in prison and a fine for failing to report thefts and missing persons
• direct liability of the economic operator in the event of inspections by the authorities

Every incomplete internal procedure, every piece of information that is not collected or stored properly, is a risk.

How can we help you?

Join the masterclass “Regulations for the Control of Certain Chemical Substances”
If you’d like to explore this topic further and understand its scope, you’ll find a masterclass dedicated to chemical weapons and their precursors, drug precursors, and explosive precursors in the “C’è chimica tra noi” community.

Or, if your company uses or may use substances listed in the CWC schedules:

Request a personalized consultation
to verify your compliance and properly set up your internal processes.