Note d'Analyse
Groupe de recherche et d'information sur la paix et la sécurité
70 Rue de la Consolation, B-1030 Bruxelles
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Date d'insertion : 15/06/2004

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by Ilhan BERKOL and Claudio GRAMIZZI, GRIP researchers

1. Ammunition and explosives: a specific category of small arms and light weapons

The definition of small arms and light weapons (SALW) elaborated by the United Nations Group of Experts in 1997(1) includes, alongside firearms with a calibre of less than 100mm, ammunition for these weapons, as well as explosives. Within the framework of an instrument for marking, registering the transfer of, and tracing SALW, these two product categories require a specific approach, different from the one advocated for arms. This is mainly because the measures envisaged for marking firearms cannot be directly transposed in the case of ammunition and explosives on account of specificities concerning their use and technical characteristics.

Contrary to firearms, ammunition and explosives are completely destroyed once used. This significantly complicates any efforts to recuperate information or carry out tracing operations a posteriori, even when marking elements are added to the goods upon manufacture. Marking techniques for explosives currently in use involve adding substances that can be decoded through chemical analysis, even after an explosion has taken place.(2)

As far as ammunition is concerned, several marking methods can be envisaged: in addition to the possibility of engraving information on cartridges using the same techniques as for weapons (e.g. laser inscription, cold-stamping or engraving the case), it is also possible to mark powder by adding chemical tracers, as is the case for explosives.

It should be noted that from a regulatory point of view, ammunition and explosives are categorised as dangerous goods and are already subject to certain international control measures, notably concerning their transport and stockpiling.

2. International covering the transport of dangerous goods

The transport of dangerous goods is subject to international regulation and itemized according to several categories: in this list, structured according to nine criteria, we find explosive materials and objects, including ammunition. These international model regulations seek first and foremost to guarantee public security as well as the security of personnel involved in the transport and stockpiling of these materials in the four transport categories (road, air, marine and rail). Moreover, they seek to heighten the degree of harmonisation between national and international practices.

The worldwide acceptance of this system for classifying, designating, packing, marking, labelling, and documenting dangerous goods has led to the simplification of transport and handling operations and accelerated the implementation of more rigorous control measures. Elaborated by a United Nations committee of experts in December 1996 (3), these conventions are revised and amended every two years, with amendments entering into force on 1 January every other year.(4)

All packages containing ammunition or explosives must be legibly and durably marked, in accordance with the provisions of the conventions; these markings must comprise, notably, a unique serial number, the year of transport, the weight of the package and information permitting the identification of the country that authorised the transport as well as the company that requested the authorisation. The conventions require that packages containing ammunition be marked with a United Nations acronym comprised of four numbers indicating the category and type of ammunition contained.

The United Nations group of experts also recommends that all companies operating in this area of activity must submit to at least one external control per year, the purpose of which is mainly to verify the legibility and durability of the inscriptions contained on their packaging. (5) Moreover, manufacturers must ensure that internal controls are carried out on their packaging (6) and must select from an external control organisation registered with the proper authorities.(7)

In this way, the conventions attribute direct responsibility to companies involved in this domain.
For road transport, for example, each company must produce an annual activity report which includes, inter alia, the classification of dangerous goods transported, loaded or unloaded, the terms of transport and expedition, and, in case of incident, a description of the anomalies observed. (8)

Manufacturers are therefore responsible for packing ammunition, explosives and other dangerous goods in such a way that they conform with the applicable model regulations, to apply appropriate markings and to maintain a registry of these for a minimum of five years. Moreover, notably as far as road transport is concerned, they must provide their clients, through their transport companies, with all documentation concerning the goods transferred (authorisations, certificates and other notices).
As for transport companies, they must ensure that the merchandise transported is accompanied by all necessary documentation and, if this is not the case, signal any infractions or anomalies observed concerning the load.
The consignees of a transaction are also obliged to refuse reception of any merchandise unaccompanied by the necessary technical documentation.

a. International regulations covering the transport of dangerous goods

There already exists a series of regional agreements concerning road transport. (9)

In Europe, an agreement involving approximately forty countries has been in place since 1968. Since the integration of relevant provisions set out in various different national legislations, the recommendations of the ADR (10) are legally binding in numerous countries.
In 1994, European Union member states adopted this document in the form of a European Directive, thereby bringing about the standardisation of national legislation in accordance with the international norms. (11) Up to that point in most EU member states there existed two sets of norms for road transport: one setting out provisions in force covering national transport, and the other for international transfers, with direct reference to the ADR.

For air, marine and rail transport, the recommendations of the UN group of experts were accepted worldwide and are considered to have the value of a convention.

b. The role of control organisms

Generally speaking, control organisms ensure that personnel involved in the transport of dangerous goods featured on the UN list are provided with training and have access to documentation regarding to the norms regulating this domain of activity. They also carry out tests for each new model packaging developed by producers with a view to delivering a certificate of approval. (12) Furthermore, control agencies play a key role in the conservation of data and information concerning the transport of dangerous goods.

c. Data conservation

The international conventions on the transport of dangerous goods require producers to keep all documents related to controls, especially those concerning the marking of packages, for a minimum of five years. As for control organisms, they are required to keep this information for the entire duration of use of a given type of packaging used in transport, at which point they are to be archived.

State authorities (for instance in Belgium) do not keep copies of this information but are entitled to access it through a request sent to the control organism. The latter therefore play a similar role to that of the national agencies in the framework of a convention on marking, registering and tracing SALW proposed by GRIP. They ensure the conservation of information related to transport and only provide this information to the authorities in the event of a specific request (that is, when there is a need to investigate), thereby guaranteeing an important degree of confidentiality.

It should be noted that the control institutes of three European countries have taken steps among themselves and with the European Union to set up a database that would make information currently at their disposal available to the European institutions.(13) This initiative could be the embryo of a broader system of information exchange.

3. Conclusions and remarks

Existing conventions and regulations covering the transport of dangerous goods such as ammunition and explosives allow packages containing these goods, but not the goods themselves, to be traced rapidly. If the original packaging is changed, it is unlikely that the contents will be able to be traced.

Nonetheless, the mechanism introduced by the international agreements present interesting aspects for a future instrument for tracing SALW.

First, it establishes a comprehensive, harmonised marking system that is particularly reliable and almost indelible. Furthermore, it attributes specific responsibilities to actors involved in transport (from producers, intermediaries, through to consignees) as far as controlling the conformity of transfers and the conservation of information related to the goods transported. The introduction of numerous control procedures, which demonstrates the responsibility of the actors involved at each intermediary step, serves not only to render all parties involved in these transfers accountable by defining in detail their role, but also to identify operational anomalies and eventual offences when they happen. This allows control measures to be taken or sanctions to be imposed immediately against those responsible (for example by blocking the transport) without having to wait until the transfer process is completed.

Secondly, it authorises control organisms to carry out inspections of the package production sites without prior notification, with a view to verifying their conformity and quality, as well as their markings. A similar provision could be adopted in the framework of an international instrument for marking, registering and tracing SALW. National control agencies could, for example, be empowered to carry out inspections of production sites in order to verify the conformity of weapons markings and, in the event that the visit should take place a few days before the shipment of weapons, to seal the packages. This would make it possible for control organisms to carry out physical inspections of products listed in the documents accompanying shipments, which is often practically impossible to do upon loading goods for delivery.

Moreover, the conventions on the transport of dangerous goods introduce national control agencies having as one of their main tasks the centralisation of information concerning transfers of these goods and the conservation of this information for long periods of time. Furthermore, while this information is centralised, it is not systematically sent to the authorities.

In the framework of an instrument for marking and tracing SALW currently being negotiated at the United Nations, these same agencies could, providing that their competences are slightly redefined (14), serve as national agencies for controlling the transfer of ammunition and explosives. This would allow states to take advantage of existing structures, thereby reducing costs and the effort required to implement fully the recommendations of the convention that is to be adopted by 2006. It should be noted that these organisms function independently and their costs are covered by the clients on a contract by contract basis.

Finally, the conventions demonstrate that states have already agreed to improve the traceability of ammunition and explosives, given the danger that their transport and storage entail. In light of the positive results achieved to date, this should encourage them to take the next step in adopting similar provisions for firearms, properly speaking.

The agreements on the transport of dangerous goods demonstrate that when such measures are justified on grounds of public security, governments are willing to accept a reduction in the level of confidentiality by actively engaging in an effective system that is globally accepted.






The packaging of type 4D plywood box manufactured by Mecar s.a. – Petit-Roeulx-lez-Nivelles (B) and described in report n° G-01.003 issued by IBE-BVI is accepted for the transport by land (road and rail), by sea and by air of dangerous goods mentioned in following annex, within the limits prescribed in that annex.

Type-series packagings shall in every way be in conformity with the approved design type described in the above mentioned report and successfully pass all the tests specified in :

- the IMDG-Code, Annex I
- the European ADR-Agreement, appendix A5
- the International RID-Regulation, appendix V
- the ICAO Technical Instructions, part 7.

These packagings shall bear the following identification marking :


(*) The two last digits of the year of manufacture.
Packagings of types 1H and 3H shall also be appropriately marked with the month of manufacture; this may be marked on the packaging in a different place from the remainder of the marking.

The identification marking shall be indelible and preferably inscribed on one of the lateral sides of the packaging. The affixing of the marking shall not weaken the strength of the packaging.

The closing devices of the approved packagings shall be in accordance with those described in the report and bear the following identification mark :

If the closing devices are manufactured by subcontractors, the manufacturer to whom the certificate of approval was assigned remains directly responsible for the conformity of the whole packaging.

Any alteration of the above mentioned packaging (including the closing devices) or of it operating conditions implies the automatic cancellation of this certificate.

The Commission reserves at any time the right to invalidate this certificate.

Special requirements :

Inner packaging and cushioning material must be at least as efficient as those described in the report.

Annex : 3 pages

Brussels, 31.01.01

For the Administration for the Maritime for the Civil Aviation of Transport, Administration Administration,

Adresses : Mecar s.a. Ministry of Economic Affairs
Rue Grinfaux, 50 Administration of the Quality&Security




Page 1 : Road and rail transport

Substances accepted for carriage and conditions for packing

Substances of the classes 1,3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 8 and 9

if allowed by the following marginals of the ADR/RID and under the conditions specified in these marginals :

2100 to 2105, 2300 to 2312, 2400 to 2412, 2430 to 2442, 2470 to 2482, 2500 to 2512, 2550 to 2559, 2600 to 2612, 2800 to 2812, 2900 to 2912 (ADR)

100 to 105, 300 to 312, 400 to 412, 430 to 442, 470 to 482, 500 to 512, 550 to 559, 600 to 612,
800 to 812, 900 to 912 (RID)

The following conditions must also be fulfilled :

Classification under the letters
max. relative density
max. vapour pressure at 50° C (kPa)
max. gross mass (kg)

For products of class 1, the packaging shall also be approved by the Belgian Service of Explosives (Ministry of Economic Affairs)

Page 2 : For Seatransport

General conditions

- This packaging may only be used for the products for which this packaging is allowed in the IMDG-code and under the conditions specified in that code.

- The product may not attack the packaging (nor the closing devices).

- For products of class 1, the packaging shall also be approved by the "Ministry of Economic Affairs, Administration of the Quality and Security, Belgian service of Explosives, Bd.Emile Jacqmain 154, 1000 Brussels".

- The manufacturer must inform the user of the packaging and all persons, responsable for the loading and the stowing of the ship, of the conditions specified in this certificate.

- All accidents or events that may influence the security adversely during loading, during the voyage or during the unloading of the ship, shall reported to the Belgian Maritime Inspectorate.

Page 3 : Authorized Goods and Prescriptions for the Transport by Air

1. Combination packagings (outer packagings with inner packagings) and single packagings to be used for the transport of solids :

Classes 1*, 2, 3, 4 , 5, 8 and 9 : Division 6.1

All the products authorized for transport by air according to table 2-14 of the ICAO Technical Instructions and for the maximum net quantities indicated in that table. The type of packaging covered by the certificate of approval (1A2, 4C1 and so on ...) must conform to the appropriate packaging instructions detailled in Part 3 of the ICAO Technical Instructions.

See part 3, Chapter 1 and Part 4, Chapters 2 and 3 of the ICAO Technical Instructions about the general packaging instructions, the marking and label specifications.

- products classified in the packing group(s) II and III

- gross mass authorized per package <= 61 kg

* For this class, the package must also be approved by the :
Ministry of Economic Affairs
Bestuur van de Kwaliteit en Veiligheid/Administration de la Qualité et de la Sécurité
Service des Explosifs/Dienst der Springstoffen
Bd Emile Jacqmainlaan 154

2. Single packagings to be used for the transport of liquids

Classes 3, 8 and 9, divisions 4.3, 5.1 and 6.1

All the products authorized for transport by air according to table 2-14 of the ICAO Technical Instructions and for the maximum net quantities indicated in that table. The type of packaging covered by the certificate of approval (1A1, 3A1, 1H1 and so on ...) must conform to the appropriate packaging instructions detailed in Part 3 of the ICAO Technical Instructions.

See part 3, Chapter 1 and Part 4, Chapters 2 and 3 of the ICAO Technical Instructions about the general packaging instructions, the marking and label specifications.

- products classified in the packing group(s)
with a corresponding relative density <=

- vapour pressure at 50° C <=


(1) Report of the UN Group of Government Experts on SALW (A/52/298) of 27 August 1997.

(2) This method is practiced notably in Switzerland, where the marking of explosive materials with a view to permitting their identification is set out in national legislation. According to the Swiss authorities this is an effective way to control the proliferation of explosive materials. See I. Berkol, “Marking and Tracing Small Arms and Light Weapons. Improving transparency and control”, GRIP Report, special issue, 2002.

(3) Group of Experts in transport of Dangerous Goods of the United Nations Economic and Social Council. See « Recommendations on the Transport of Dangerous Goods », Model Regulation ref. ST/SG/AC10/1/rev.12, 12th edition, August 2001.

(4) The existing normative framework includes amendments from 2003.

(5) In certain countries, such as Belgium, when an offence has been committed, all packages produced since the last control are verified. Packages that do not conform to the regulations are destroyed.

(6) The primary products used in the production of packages should, for instance, be traceable.

(7) Several organisms exist in Europe. Examples include the Institut Belge de l’Emballage (IBE) in Belgium, the Bureau des Vérifications techniques (BVT) in France or the German Bundesanstalt für Materialprüfungr.

(8) These reports are generally written in cooperation with the personnel of the control agencies.

(9) The regulation of road transport is particularly important since all transfers foresee at least one transfer by road before reaching its final destination.

(10) European agreement on the international carriage of dangerous goods on road (ADR), signed in Geneva on 30 September 1957 under the auspices of the United Nations ECOSOC, and entered into force on 29 January 1968.

(11) European Directive n°94/55/CEE of 21 November 1994.

(12) These tests are mainly intended to verify the sturdiness of the packaging and its conformity with the security provisions foreseen in the international Conventions. This involves drop tests, stacking tests, testing for water and air tightness, internal (hydraulic) pressure, chemical compatibility and permeability.

(13) According to Mr. Maxence Wittebolle, Technical Director of the Belgian Packaging Institute (l’Institut Belge de l’Emballage). The three institutes are in Belgium, Austria and the Netherlands.

(14) For example, by including the contents of packages, and not simply the packages themselves, the scope of controls can be broadened.

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70 Rue de la Consolation, B-1030 Bruxelles
Tél.: +32.2.241 84 20 - Fax : +32.2.245 19 33
Internet : - Courriel : 

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