the Regulation (EU) 2019/1148 on the marketing and use of precursors for explosives, also known as "Precursors for Explosives", aims to prevent potential terrorist perpetrators from obtaining explosives and their precursors. The aforementioned regulation aims to restrict access to explosive substances in such a way that their use cannot lead to any potential danger. It replaces Regulation (EU) 98/2013 and entered into force on 01 February 2021.
According to Annex II of the Regulation, acetone, as well as aluminum powder, belong to the list of regulated substances which, as such or in mixtures, are subject to the obligation to report all suspicious transactions, as well as the loss and theft of significant quantities within 24 hours. This must be reported to the appropriate national contact point.
The text of the Regulation and the EU Commission's implementing guidelines are available at www.eur-lex.eu or with relevant search engines under CELEX numbers 32019R1148 (Regulation) and 52020XC0624(01) (Guidelines). In particular, we would like to draw your attention to Annex 3 of the Guidelines "Compliance - Checklist for Economic Operators, Online Marketplaces' Professional Users and Members of the General Public", which precisely sets out the requirements for your company.
We hereby inform you that senotherm® spray cans that you purchase from us may contain 1% or more acetone and are therefore subject to the regulation. However, in our view, these products are not considered attractive precursors under the legislation and thus suspicious transactions are only reportable if the transaction exceeds household quantities. "Complex mixtures" with multiple ingredients are considered unattractive because extracting a substance from such a mixture for the purpose of making explosives is difficult to achieve or unprofitable.
Likewise, aluminum powder is not reportable until it contains at least 70%w/w aluminum, which can be practically ruled out in our products.
We hope to be able to support you with this information. If you have any questions, we are at your disposal.
Head of R&D
Phone: +49 6471 315 185
Fax: +49 6471 315 5185
E-Mail: f.pfeifer@weilburger.com
WEILBURGER Coatings GmbH
Ahäuser Weg 12-22
35781 Weilburg
Germany
