Advisory notes for collectors on the situation regarding ammunition and The Manufacture and
Storage of Explosives Regulations 2005 (MSER), The Control of Explosives Regulations, 1991
(COER) and the Explosives Act, 1875, Section 23

Considerations in relation to ammunition collections
The collecting of ammunition is recognised as a good reason for possession by those who can
demonstrate they are bona fide collectors, or those with interests in research or an academic interest
in the subject of the development etc of firearms and ordnance. Reference in the Home Office
guidance to police [13.53] sets out that ammunition can be collected in its own right.

Ammunition collections are authorised by a Firearms Certificate, however dependant upon the
amounts and types of ammunition the collector wishes to acquire, other legal requirements may
present themselves and these are not always either known to or appreciated by the collector.
Firearms certificates issued for collections apply the Firearms Act definition of ammunition and there
is provision for the collection including exhibits to which section 5 applies. This can include all sizes
of ammunition and also those that have projectiles that are pyrotechnic (tracer), incendiary and high
explosive.

•

The anticipation is that a greater number of collections are concerned with ammunition that
can be described as small arms, in the main for firearms and shotguns.

A lesser number have an encompassing interest in the wider areas of ammunition and large
ordnance, including those articles that are grenades, missiles, bombs etc.

•

The additional regulatory areas have to be considered when items in the collection move outwith
ammunition that is regarded as possessing ‘inert projectiles’, or it is in some of the categories under
Section 5, e.g. containing noxious substances. In these cases other criteria needs to be addressed
by the collector. None of the issues in this paper relate to situations where the collection
consists of ammunition that is inert, empty or dummy or to items that are inert, empty or
dummy ammunition that form part of a collection.

The main area that arises is in the application of MSER. These regulations include provisions for all
classified forms of explosives including all the recognised types of ammunition. Hazard Type (HT) in
MSER creates both the appropriate licensing where that is applicable and also safety requirements.
Ammunition as any other explosives will, according to its classification, be placed in a HT group that
provides criteria that relates to its storage. There is a rough general matrix in Appendix A.

Ammunition articles are ‘explosives’ classified under the UN system, which encompasses all that
within the firearms act, but allocates it specifically to its hazard and will appear under a number of
references upon that basis. The risk in storage presents the main concern and the cumulative effect
that could occur in collections, where ammunition is not acquired for use and then replaced, but
continues to add to the explosive mass. It also has to be considered in the reckoning of amounts
where a person is both one who shoots and is also a collector.

When looking at allocations of ‘shooting’ ammunition in a firearms certificate there is a relatively
straight forward way to determine the amounts that could be kept by reference to the cartridge data.
This allows both the regulator and the certificate holder to be confident that the allocation authorised
would not exceed the limits for explosive to be kept without a licence or registration under MSER.

It needs to be remembered that ammunition that would in firearms legislation be regarded as
ammunition for firearms, may not co-relate when looking at the application for explosive storing under
MSER. There have been and are still cartridges that would be considered as fitting within the ‘small
arms’ criteria (by calibre or description), but for the fact that they possess explosive, incendiary or
illuminating effects in their projectiles. Such ammunition was in use in certain military rifle and light/
medium automated firearms cartridges of many nations armed forces, for example .303, 7.92mm, .50”
7.62mm NATO. Particular reference is made in a cartridge identification publication that the 20mm
rounds have explosives present in most that are not either ball or practice. All these present a
legitimate cartridge when considering a collection.

MSER
As a yard stick, under these regulations certain explosive limits are set for any place where
explosives, which includes all types of ammunition, are being stored in regard to –

•

The total of the explosive content in any small arms ammunition collected without being required
to licence or register –

The explosive content of any round of ammunition (a cartridge or shell) is determined by adding
the weight of the propellant to that of the primer and any other explosive material contained. This
provides the net mass of explosive (NEM) for explosive legislation purposes.

In small arms ammunition with inert projectiles this will be the powder load plus the accepted
average of a primer at .05gram (.8 grain). You may have, without a licence or registration to
store under MSER, small arms ammunition with a total content not more than 15 kilograms nett
explosive mass and in addition a further 5 kilograms, if you have no other explosives at your
premises. This includes items such as fireworks or flares which may be seasonal acquisitions.

•

What ammunition is included as ‘small arms.’

MSER states that “small arms ammunition” within the regulations refers only to those cartridges
classified as UN0012, – Cartridges for weapons, Inert projectile or cartridges, small arms; UN0014
– Cartridges for weapons blank, or cartridges, small arms; or UN0055 – Cases, cartridge, empty,
with primer, that are intended exclusively for use in small arms. The missile in any cartridge must
be of a type that is inert, usually described as ‘ball’. Cartridges with expanding missiles are also
inert

Under the UN system, the expression ‘small arms’ means a cartridge not exceeding 19.1mm
calibre (approximately 10 bore or .79”) or shotgun cartridges of whatever bore. This ammunition
will normally be seen as Hazard Type 4 for the purposes of safety in storage.

The general rule is that once removed from their authorised packaging, the likelihood is that
the Hazard represented will be increased. In certain large diameter or for long items, this can
relate to palletising and banding, not therefore found in “packaging” as we would understand the
word. In relation to ammunition for rifles and shotguns, the basic presumption is that it does not
normally move from HT4. When in storage it is for the person storing to determine the hazard
type if not readily identified by any packing. There is a need for the regulator to be satisfied that
the Collector has taken steps to assess or have assessed the appropriate Hazard Type presented
by any unpackaged ammunition and also that presented by any live explosive components of
ammunition that are within the collection. Whilst the firearms legislation does not control the
components of ammunition, explosive legislation does in these situations. There is no regulated
process for declaring any article “free from explosive” (FFE). The duty lies with the person
possessing.

The situation where the ammunition is of other types.

•

When looking at ammunition that is not “small arms”, its propellant, whilst making up probably a
bulk of a round, the amount of any other explosive, pyrotechnic or other explosive composition is
the feature which brings the other safety considerations into play and these we believe collectors
need to bear in mind.

When looking at provisions for safe storage in MSER, there are a number of considerations that
need to be addressed –

(a) Where articles are stored in the same store, the total net explosive mass of all explosives
in that store will be considered to be equal to the highest HT. For example if you add to a
store of 15 kg of small arms ammunition, [HT4 not requiring separation up to 250 kg nem] a
small arms cartridge with 2 grams of high explosive [HT1-2 separation distance required from
100 grams NEM], the store is considered to contain 15.002 kg of HT1. This can result in a

separation distance requirement of considerable distance.

(b) As collectors use buildings such as houses etc, if they are keeping combined HT cartridges in
one place such as mentioned above, they are likely to be in breach of requirement to provide
separation distance between store and occupied premises [Regulation 5] and possibly the duty
to protect persons from fire and explosion [Regulation 4] dependant upon the HT allocated to the
cartridges.

(c) The collector is the duty holder under the regulations and despite what the condition on a
firearms certificate states that person may possess, is responsible for compliance with the
storage requirements.

(d) The variance in propellant content within ammunition and any additional factors such as other
pyrotechnic or explosive material possessed at the place of storage needs to reflect either the
NEM being mapped by the collector or the collection is calculated so that where a number of
rounds or types are in a collection, the quantity applied by the Firearms Certificate can accord
with the limit that can be authorised without breaching MSER limits.

•

The need to hold either a licence or registration under the regulations where the collection
exceeds the limit of that defined as small arms, or the ammunition being collected is of other
types.

Where collections are being gathered under a firearm certificate, unless that collection consists
only of ammunition that may be kept under Regulation 10(2)(b) of MSER, there is likely to be need
for that storage to be within the licensed or registered provisions of MSER

As Chief Officers of Police are regulators of both the Firearms and Explosives legislation that bears
upon collectors, there is a need to be transparent and inclusive in the approach to the collector and
their application for a firearms certificate. It is necessary to have a process that allows appropriate
advice to be given when the applicant is considering their collection to ensure both at the outset and
as the collection develops, that due attention is being brought to bear on the aspects identified.

As a means to address these issues it would seem logical that in the situation where collections are
being considered –

(a) The initial enquiry includes exchange of information between the enquiring officer and the
applicant to try to establish the extent to which the collection is to develop that can allow the Firearms
certificate to then be conditioned accordingly.

(b) The certificate when issued is accompanied by a letter/note, which gives information regarding the
possession and keeping of ammunition that may have requirements under MSER.

(c) That where the enquiry or through subsequent notification it is established that that the collection
either exceeds the unlicensed limits or is to contain ammunition subject to the licensing provisions of
MSER

• that application for the appropriate registration or licence is submitted. (Collections
containing ammunition that is not subject to an explosive certificate will require to be licensed/
registered by the appropriate Local Authority)

•

that the requirements in regard to storage under MSER have been arranged and are being
observed.

COER
Under these regulations, any ammunition regulated or prohibited by the firearms acts is not the
subject of an explosive certificate to either acquire or keep. If however the collection includes those
live components of ammunition such as fuses, filled shell heads etc, which are, as components of
ammunition not regulated by the firearms acts and therefore outwith the provision of the exception,
then an explosive certificate will be required.

Home Office Guidance for Section 5(1A)(b) says that free fall bombs are not regarded as ammunition
for the purposes of the Act and as a consequence, the items are subject to the requirement to have
an explosive certificate in relation to any such articles. They can also not benefit from being able
to be acquired under the collection condition of a firearms certificate. Under the UN classification
system the term “bomb” refers to explosive articles dropped from aircraft.

Where a licence or registration under MSER and explosive certificate under COER are required for
the collector, then the two are subject to the appropriate fee(s)

EXPLOSIVES ACT 1975 – Section 23
Where ammunition or those components of explosive, incendiary or pyrotechnic type that attracts a
need to be licensed or registered, that brings into consideration their secure storage when included
in a collection. There is need to ensure that the security criteria for such items is seen as fulfilling
both that which would be expected by the Firearms legislation and the duty under Section 23. This
balance is important to provide consistency on the application of appropriate secure and safe storage
and to prevent a dual view of the same item when considering for either set of legislative requirement.

The outcome of the recommendations on secure storage needs to have an adequate and proportional
application to the collected items that takes account of not just the volume but also the practicalities
of what the security entails. It is seen that a ‘one size fits all’ may not be suited to collectables in this
field. A look into those items that are formed into collections may best inform views on what will be
appropriate in each case.

For information a list of Explosives classification under the UN system, edited to items of ammunition
and components is at Appendix B

Anthony J Slate AIExpE
Martyn Kaye MIExpE, AISEE
for ACPO FELWG – Explosive issues

Issue 1 – March, 2013

Appendix A

Under the UN classification explosives are classified as packaged and this transposed in the main to
MSER Hazard Types (HT). The table below sets out considerations that need to be addressed when
looking at ammunition collections. The types listed are not all encompassing.

Type of ammunition

Expected
Hazard
Type

Separation Distance
applies from

MSER licence
or registration

Ammunition with inert
projectiles fitting small
arms criteria in MSER
and
the quantity is within
the limits in 10(2)(b) or
Exception Order 1-2012
Ammunition with inert
projectiles fitting small
arms criteria in MSER
and
the quantity is more than
the limits in 10(2)(b) or
Exception Order 1-2012
Ammunition with
incendiary projectiles in
small arms calibres
Ammunition with
explosive projectiles in
small arms calibre
Ammunition with
incendiary projectiles, not
small arms
Ammunition with
explosive projectiles, not
small arms
Ammunition, explosive
shell heads
Ammunition components
containing explosives, e.g.
artillery fuses
Grenades, rockets,
missiles and other bombs
that are ammunition
for the purposes of the
Firearms Act

HT 4

250 kg NEM

No

HT 4

250 kg NEM

Yes

HT3

25 kg NEM

Yes

HT1 – HT2

HT2 to HT3

HT1 – HT2

HT1

HT1 to HT3

100 grams NEM

100 grams – 25 Kgs
NEM

100 grams NEM

100 grams NEM

100 grams (HT1 & 2) –
25 Kgs (HT3) NEM

Yes

Yes

Yes

Yes

Yes

Ht1 to HT3`

100 grams (HT1 & 2) –
25 Kgs (HT3) NEM

Yes

Appendix B

UN LIST – Items which are, or can be representative of ammunition components

UN Numbers and descriptions (Items in italics are Schedule 1 or otherwise exempt explosive
certificate). The Firearms Act does not include within the meaning of ammunition generally any
of the components required to make the ammunition, save in the case of certain items contained
in Section 5 of the 1968 Firearms Act, as amended. There is by this, no authority to possess
such components by virtue of having a Firearms Certificate conditioned to allow the collecting of
ammunition. Possession of any explosive component outwith the Firearms Act is subject to any
appropriate requirements in Explosives legislation.

In relation to the term ‘Bomb’ the UN system uses that term only for articles that are released from
aircraft and the term ammunition defined under the Firearms Acts does not include free fall bombs
[Home office Guidance to Police]. The UN references to Bombs have therefore been omitted from
the list as they appear to be not within the requirements for ammunition regulated or prohibited by the
Firearms Act.

The UN Hazard Division (HD) / MSER Hazard Type (HT), is assigned and applicable when the
explosive is in its authorised package. Please note the below list does not include any ammunition –

•

that has been classified under the various N.O.S designations, that is those articles that are
found in UN 0349 to 0356 and 0462 to 0472. – That is due to the large array of explosive that are
contained under these ‘Not Otherwise Specified’ classifications.

•

that is classified under “Articles, pyrotechnic, for technical purposes” found in UN0428 to 0432.
This is due to the variety of articles that can fall under this classification.

that is for military purposes and has been classified by the Explosives Storage & Transport
Committee, MoD (ESTC) and may not have an immediate UN equivalent. Martyn Kay is FELWG
single point of contact with MoD CI Exp compliance for queries regarding articles with ESTC
classification.

•

UN
No
0005
0006
0007
0009
0010
0012
0014
0015
0016
0018
0019
0020
0021
0044
0049
0050
0054
0055
0056
0073
0092
0093

Generic description

Cartridges for weapons, with bursting charge
Cartridges for weapons, with bursting charge
Cartridges for weapons, with bursting charge
Ammunition, Incendiary, with or without burster, expelling charge or propelling charge
Ammunition, Incendiary, with or without burster, expelling charge or propelling charge
Cartridges for weapons, Inert projectile or cartridges, small arms
Cartridges for weapons, blank or cartridges, small arms, blank
Ammunition, Smoke, with or without burster, expelling charge or propelling charge
Ammunition, Smoke, with or without burster, expelling charge or propelling charge
Ammunition, Tear-producing with burster, expelling charge or propelling charge
Ammunition, Tear-producing with burster, expelling charge or propelling charge
Ammunition, Toxic with burster, expelling charge or propelling charge
Ammunition, Toxic with burster, expelling charge or propelling charge
Primers, cap type
Cartridges, flash
Cartridges, flash
Cartridges, signal
Cases, Cartridge, empty, with primer
Charges, depth
Detonators for ammunition
Flares, Surface
Flares, aerial

HD / HT

1.1F / 1
1.1E / 1
1.2F / 2
1.2G / 2
1.3G / 3
1.4S / 4
1.4S / 4
1.2G / 2
1.3G / 3
1.2G / 2
1.3G / 3
1.2K / 2 *
1.3K / 3 *
1.4S / 4
1.1G / 1
1.3G / 3
1.3G / 3
1.4S / 4
1.1D / 1
1.1B / 1
1.3G / 3
1.3G / 3

0101
0105
0106
0107
0110
0136
0137
0138
0160
0161
0167
0168
0169
0171
0180
0181
0182
0183
0196
0197
0212
0221
0238
0240
0242
0243

Fuse, Instantaneous, Non-detonating (Quickmatch)
Fuse, Safety
Fuzes, Detonating
Fuzes, Detonating
Grenades, Practice, hand or rifle
Mines with bursting charge
Mines with bursting charge
Mines with bursting charge
Powder, smokeless
Powder, smokeless
Projectiles, with bursting charge
Projectiles, with bursting charge
Projectiles, with bursting charge
Ammunition, Illuminating, with or without burster, expelling charge or propelling charge
Rockets, with bursting charge
Rockets, with bursting charge
Rockets, with bursting charge
Rockets with inert head
Signals, smoke
Signals, smoke
Tracers for ammunition
Warheads, Torpedo, with bursting charge
Rockets, line-throwing
Rockets, line-throwing
Charges, propelling, for cannon
Ammunition, Incendiary, White phosphorous with burster, expelling charge or
propelling charge
Ammunition, Incendiary, White phosphorous with burster, expelling charge or
propelling charge
Ammunition, Smoke, White phosphorous with burster, expelling charge or propelling
charge
Ammunition, Smoke, White phosphorous with burster, expelling charge or propelling
charge
Ammunition, Incendiary, liquid or gel, with burster, expelling charge or propelling
charge
Ammunition, Illuminating with or without burster, expelling charge or propelling charge
Charges, propelling
Charges, propelling
Charges, Propelling, for cannon
Rocket Motors
Rocket Motors
Grenades, hand or rifle, with bursting charge
Grenades, hand or rifle, with bursting charge
Warheads, Rocket, with bursting charge
Warheads, Rocket, with bursting charge
Bombs, with bursting charge
Grenades, hand or rifle, with bursting charge
Grenades, hand or rifle, with bursting charge
Mines, with bursting charge
Rockets, with bursting charge

0244

0245

0246

0247

0254
0271
0272
0279
0280
0281
0284
0285
0286
0287
0291
0292
0293
0294
0295

1.3G / 1
1.4S / 4
1.1B / 1
1.2B / 2
1.4S / 4
1.1F / 1
1.1D / 1
1.2D / 2
1.1C / 1
1.3C / 3
1.1F / 1
1.1D / 1
1.2D / 2
1.2G / 2
1.1F / 1
1.1E / 1
1.2E / 1
1.3C / 3
1.1G / 3
1.4G / 4
1.3G / 3
1.1D / 1
1.2G / 2
1.3G / 3
1.3C / 3
1.2H / 2

1.3H / 3

1.2H / 2

1.3H / 3

1.3J / 3

1.3G / 3
1.1C / 1
1.3C / 3
1.1C / 1
1.1C / 1
1.1C / 1
1.1D / 1
1.2D / 2
1.1D / 1
1.2D / 2
1.2F / 2
1.1F / 1
1.2F / 2
1.2F / 2
1.2F / 2

0297
0299
0300
0301

Ammunition, Illuminating, with or without burster, expelling charge or propelling charge
Bombs, photo-flash
Ammunition, Incendiary, with or without burster, expelling charge or propelling charge
Ammunition, tear-producing, with or without burster, expelling charge or propelling
charge
Ammunition, Smoke, with or without burster, expelling charge or propelling charge
Tracers for ammunition
Cartridges, signal
Grenades, practice, hand or rifle
Primers, tubular
Primers, tubular
Cartridges for weapons, with bursting charge
Projectiles, with bursting charge
Cartridges for weapons, blank
Cartridges for weapons, blank or Cartridges, Small arms, blank
Cartridges for weapons, inert projectile

0303
0306
0312
0318
0319
0320
0321
0324
0326
0327
0328
0329
0330
0338
0339
0344
0345
0346
0347
0348
0362
0363
0364
0365
0366
0367
0368
0369
0370
0371
0372
0376
0377
0378
0379
0395
0396
0397
0398
0399
0400
0403
0404
0405

Torpedoes with bursting charge
Torpedoes with bursting charge
Cartridges for weapons, blank or Cartridges, Small arms, blank

Cartridges for weapons, inert projectile or Cartridges, Small arms
Projectiles, with bursting charge
Projectiles, Inert, with tracer
Projectiles with burster or expelling charge
Projectiles with burster or expelling charge
Cartridges for weapons, with bursting charge
Ammunition, Practice
Ammunition, Proof
Detonators for ammunition
Detonators for ammunition
Detonators for ammunition
Fuzes, Detonating
Fuzes, igniting
Warheads, Rocket, with bursting charge
Warheads, Rocket, with burster or expelling charge
Warheads, Rocket, with burster or expelling charge
Grenades, Practice, hand or rifle
Primers, Tubular
Primers, Cap type
Primers, Cap type
Cases, Cartridge, empty, with primer
Rocket motors, liquid fuelled
Rocket motors, liquid fuelled
Rockets, liquid fuelled, with bursting charge
Rockets, liquid fuelled, with bursting charge
Bombs with flammable liquid, with bursting charge
Bombs with flammable liquid, with bursting charge
Flares, aerial
Flares, aerial
Cartridges, signal

1.4G / 4
1.3G / 3
1.4G / 4
1.4G / 4

1.4G / 4
1.4G / 1
1.4G / 4
1.3G / 1
1.3G / 3
1.4G / 4
1.2E / 2
1.2F / 2
1.1C / 1
1.3C / 3
1.2C / 2

1.1E / 1
1.1F / 1
1.4C / 4

1.4C / 4
1.4D / 4
1.4S / 4
1.2D / 2
1.4D / 4
1.4F / 4
1.4G / 4
1.4G / 4
1.2B / 2
1.4B / 4
1.4S / 4
1.4S / 4
1.4S / 4
1.1F / 1
1.4D / 4
1.4F / 4
1.2G / 2
1.4S / 4
1.1B / 1
1.4B / 4
1.4C / 4
1.2J / 2
1.3J / 3
1.1J / 1
1.2J / 2
1.1J / 1
1.2J / 2
1.4G / 4
1.4S / 4
1.4S / 4

0408
0409
0410
0412
0413
0414
0415
0417
0424
0425
0426
0427
0434
0435
0436
0437
0438
0446
0447
0449
0450
0451
0452
0453
0488
0491
0498
0499
0501
0502

Fuzes, detonating with protective features
Fuzes, detonating with protective features
Fuzes, detonating with protective features
Cartridges for weapons, with bursting charge
Cartridges for weapons, blank
Charges, propelling, for cannon
Charges, propelling
Cartridges for weapons, inert projectile, or cartridges, small arms
Projectiles, inert with tracer
Projectiles, inert with tracer
Projectiles, with burster or expelling charge
Projectiles, with burster or expelling charge
Projectiles, with burster or expelling charge
Projectiles, with burster or expelling charge
Rockets, with expelling charge
Rockets, with expelling charge
Rockets, with expelling charge
Cases, combustible, empty, without primer
Cases, combustible, empty, without primer
Torpedoes, liquid fuelled, with or without bursting charge
Torpedoes, liquid fuelled, with inert head
Torpedoes, with bursting charge
Grenades, practice, hand or rifle
Rockets, line-throwing
Ammunition, practice
Charges, propelling
Propellant, solid
Propellant, solid
Propellant, solid
Rocket, with inert head

In relation to the Hazard Divisions (HD) quoted for the above explosives, certain comparability groups attached
to the articles are worth noting for their associated characteristics –

E

Article containing a secondary detonating explosive substance, without means of initiation and with a
propelling charge (other than a charge containing a flammable or hypergolic liquid)
Article containing a secondary detonating explosive substance, with means of initiation, and either
with a propelling charge (other than a charge containing a flammable or hypergolic liquid) or without a
propelling charge
A substance which is an explosive substance because it is designed to produce an effect by heat,
light, sound, gas or smoke or a combination of these as a result of not-detonative self-sustaining
exothermic chemical reactions or an article containing such a substance or an article containing both
a substance which is explosive because it is capable by chemical reaction in itself of producing gas at
such a temperature and pressure and at such a speed as could cause damage to surroundings and
an illuminating, incendiary, lachrymatory or smoke-producing substance (other than a water-activated
article or one containing white phosphorus, phosphide or a flammable liquid or gel)
Article containing both an explosive substance and white phosphorus
Article containing both an explosive substance and a flammable liquid or gel
Article containing both an explosive substance and a toxic chemical agent – * Carriage is prohibited

F

1.1D / 1
1.2D / 1
1.4D / 4
1.4E / 4
1.2C / 2
1.2C / 2
1.2C / 2
1.3C / 3
1.3G / 3
1.4G / 4
1.2F / 2
1.4F / 4
1.2G / 2
1.4G / 4
1.2C / 2
1.3C / 3
1.4C / 4
1.4C / 4
1.3C / 3
1.1J / 1
1.3J / 3
1.1D / 1
1.4G / 4
1.4G / 4
1.3G / 3
1.4C / 4
1.1C / 1
1.3C / 3
1.4C / 4
1.2C / 2

G

H
J
K

Primary source: UN Carriage of Dangerous Goods