Compliance with Explosives Precursors · Regulation (EU) 2019/1148
Your explosives precursors framework, measured article by article and turned into a costed action plan.
9 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 9 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Compliance with Explosives Precursors · Regulation (EU) 2019/1148
9 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2019/1148 of 20 June 2019, applicable since 1 February 2021 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 9 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, a level, the level above, and the action that links the two, that turns a finding into a trajectory.
Do sales and store staff know how to recognise a suspicious transaction and who to report it to?
- N1
No information has been circulated. The concept of a suspicious transaction is unknown to the relevant teams.
- N2
A note exists and mentions the obligation, but it has not been explained. Teams do not know what signals to look for or who to escalate to.
- N3
The suspicion criteria and escalation route are circulated and known. Relevant staff have been trained and know who to report to internally.
- N4
Training is built into induction and refreshed periodically. Reports are logged and the reporting deadline to the national contact point is met and measured.
- N5
Real cases and scenario exercises feed back into the review of criteria. Changes to the annexes and feedback from authorities are reflected in the materials, with documented tracking of updates.
Action to move from L2 to L3
Build a one-page quick reference listing suspicion signals, the internal contact and the twenty four hour deadline, present it at store briefings and the monthly safety meeting, then have staff authorised to dispense Annex I and II substances sign off.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2019/1148 replaced Regulation (EU) No 98/2013 and has applied since 1 February 2021. It distinguishes Annex I substances, whose making available to the general public is prohibited above limit values, from Annex II substances, which are subject to reporting of suspicious transactions. It requires economic operators and online marketplaces to verify the professional user or distributor status of their customers, to train sales staff, to keep records of verification, and to report suspicious transactions, disappearances and thefts to the national contact point.
In practice, the difficulty is not knowing the text but sustaining compliance over time, across multiple sites and purchasing channels. Who actually verifies customer status when an order arrives through an unusual channel? Does the storekeeper handing out ammonium nitrate or nitric acid know what a suspicious transaction is and who to report it to within twenty four hours? Do inventory discrepancies on these substances trigger a report, or are they simply written off in stock?
A confusion frequently arises in the extractive and drilling industries: the precursors regulation is not Directive 2014/28/EU on civil explosives, nor storage depot regulation. It covers everyday chemical substances, purchased for other purposes, that could be used to make explosives at home. A site can be flawless on its mining products and fall short on a container of acid delivered to the general store. The obligations also stack with REACH and CLP on labelling and safety data sheets.
A compliance audit concludes with a gap or a pass: the check exists or it does not, the register is kept or it is not. The maturity assessment answers a different question: what level of control the framework is actually at, and what specific action moves it up a level. This is the reading that allows two quarries to be compared, a common target to be set, and actions to be prioritised by effort and score gain.
Within Datamensio, the framework is ready to use and can be modified. The AI adjusts the themes, questions and levels to your organisation, or builds a variant from your purchasing procedures, your store instructions and your existing authorisations.
Reference standard: Regulation (EU) 2019/1148 of 20 June 2019, applicable since 1 February 2021
The themes assessed
Identification of the substances concerned
Inventory of Annex I and II substances present on site, mixtures involved, limit values, correspondence with safety data sheets and CLP labelling.
Organisation’s status under the regulation
Qualification as economic operator, distributor, professional user or online marketplace, scope of sale, introduction and possession activities.
Verification of customers and professional users
Checking of professional status, justification of intended use, documents requested, refusal of sale, retention of verification records.
Control of purchasing and supply channels
Supplier clauses, authorised ordering channels, receipt and inspection on arrival, handling of deliveries outside normal channels, contractors and service providers.
Storage, possession and physical access
Location of substances, restricted access, separation of stock, periodic inventories, management of leftovers and opened packaging.
Detection and reporting of suspicious transactions
Suspicion criteria, internal escalation procedure, reporting deadline to the national contact point, reporting of disappearances and thefts, traceability of reports.
Staff training and awareness
Information for sales and store staff, content and frequency of sessions, scenario-based exercises, integration into new starter induction.
Registers and data retention
Maintenance of transaction registers, retention period, protection of personal data, availability of records in the event of an inspection.
Governance, internal control and improvement
Assignment of responsibilities, second-line controls, follow-up of gaps, lessons learned, revision of procedures after an incident or a change to the annexes.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does Regulation 2019/1148 lead to a certification?
No. It is a directly applicable regulation, enforced by designated national authorities, with no certifying body. The assessment measures the maturity of your framework and prepares you for inspections, it does not issue any attestation.
How is this different from a standard compliance audit?
An audit records whether an obligation is present or absent and concludes with a gap. The assessment places each practice on a maturity scale and identifies the action that moves it up a level. The assessment prepares for the inspection, the inspection validates it.
Our site is not a seller, are we affected?
Yes, as soon as you hold or use Annex I or II substances. The obligations on possession, access control, and reporting of disappearances and thefts apply regardless of any sales activity.
How long does the assessment take?
The short version can be completed in 20 to 30 minutes by an HSE or security manager. The full version, run collaboratively with purchasing, the store and legal, generally takes one to two weeks, most of the time being spent gathering evidence.
Can the framework be adapted to our organisation?
Yes. The themes, questions and level wording can all be modified, and the AI can produce a variant based on your purchasing procedures and store instructions. You remain the owner of the resulting framework.
How can several sites or countries be compared?
The assessment can be launched as a campaign across all sites. Scores per theme can be compared between business units and against previous campaigns, and a cross-site roadmap consolidates common actions.
How does this assessment relate to REACH, CLP or the civil explosives directive?
These texts cover distinct subjects: chemical substances and labelling for REACH and CLP, explosive products for Directive 2014/28/EU. Evidence overlaps in part, notably safety data sheets and inventories, and the cross-framework roadmap avoids duplicating actions.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.