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Institut Européen des Armes de Chasse et de Sport

IEACS

The aim of IEACS is to study all the issues related to the sporting firearms industry, their components and the specific manufacturing material, from a scientific, technical, safety, regulatory and institutional point of view, and establish a dialogue between the Industry, the actors of other sectors and international and European bodies.

Lobbying Activity

Response to Establishment of the Electronic Licensing System for import, export and transit of firearms

14 Aug 2025

It should first be noted that the deadline for the full implementation of the system by Member States is set for 12 February 2029, while its interconnection with the CSW-CERTEX platform has been postponed until 2031. Nonetheless, Article 34(3)(6) of Regulation (EU) 2025/41 provides that the electronic licensing system must be made operational by 12 February 2027. Accordingly, this earlier deadline should be regarded as the relevant one, especially considering that Article 34 is among the provisions that entered into force on 11 February 2025. It is worth emphasizing that the electronic system for licence issuance represents a key instrument for economic operators, as it is intended to shorten the time required to obtain authorizations. These timeframes have been extended in the recast version of the Regulation to a degree that is wholly incompatible with the pace of contemporary international trade, and which clearly undermines the competitiveness of both Union-based operators and the Union as an economic system. Article 5 of the Draft Implementing Regulation provides for interconnection with national electronic systems, as referred to in Article 2(d); however, we consider it essential to define a uniform standard and the modalities for interoperability between systems, especially as additional national systems will undoubtedly be developed beyond those listed in the Annex. Although reference is made to compliance with the GDPR and Regulation (EU) 2018/1725, there are nonetheless risks of automated profiling (Article 2(1)(f)), and the system provides for unrestricted access to data by the European Commission (Article 4(4)), without specifying essential safeguards such as data retention periods, anonymization procedures, or the modalities for exercising data subjects' rights. This may result in violations of the principle of data minimization and the risk of misuse, particularly in cases of non-transparent profiling. The use of the Firearms Reference Table of the Royal Canadian Mounted Police as a reference tool for firearm identification, as provided for in Article 2(1)(m), appears wholly inappropriate and should be removed. It constitutes a system that is inconsistent with the categories established under Directive (EU) 2021/555 and includes a legal classification based on Canadian law, which is entirely incongruous with the legal framework applicable within the European Union. A dynamic reference to a legal source from a third country entails that all future amendments to the referenced document automatically become applicable law within the European Union, without any form of control by the Union's regulatory bodies. Moreover, it is debatable whether the delegation of powers to the Commission under Regulation (EU) 2025/41 extends to incorporating references to sources outside the Union legal order. The system will not be limited to professional operators and officials of the competent authorities; it will also be accessible to Union citizens applying for authorizations - such as temporary export for hunting or sport, or permanent export due to relocation. In such cases, simplified procedures may be appropriate, particularly regarding authentication and supporting documentation, given the low volumes involved and the minimal relevance to public security. With regard to the system itself, it is necessary to provide for the following: a) a technical support mechanism for both economic operators and national authorities, capable of handling system malfunctions and offering assistance in resolving related issues; b) a clear definition of the legal and operational consequences of system failures, including the procedures to be followed in the event that the system becomes unavailable or unusable; c) a transitional period for testing and training, aimed at preparing both operators and national authorities for the effective use of the system.
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Response to Firearms Trafficking Directive

19 Dec 2024

On behalf of the Institut Européen des Armes de Chasse et de Sport (IEACS), a non-profit association composed of national associations of sporting firearms manufacturers from France, Belgium, Germany, Italy, Great Britain, and Spain, and representing nearly 1,000 companies across the sector, including about 150 manufacturers of civilian firearms in Europe, we express our appreciation for the European Commissions initiative to seek input on measures aimed at enhancing the harmonization of sanctions related to illegal firearms trafficking across the EU. We fully support the Commissions work to ensure the safety and security of EU citizens. In line with these efforts, we would like to point out the importance of aligning the proposed measures with international standards, specifically Article 5 of the UN Firearms Protocol. This article establishes clear principles for the criminalization of illicit firearms activities, emphasizing that only intentional offensessuch as illicit manufacturing, trafficking, or falsification of markingsshould be considered criminal. This principle is fundamental, as it ensures that administrative errors or unintentional mistakes, which may arise due to the complexity of the regulatory framework, are not unduly penalized. We trust the Commission will consider this important distinction when formulating future legislative proposals. As representatives of the legal firearms and ammunition industry, we wish to highlight the potential impact these measures could have on the legal sector, particularly regarding civilian and sporting firearms and ammunition. The EU has long been a leader in firearms regulation, with high standards that influence global arms control. However, this progressive regulatory framework also imposes significant burdens on EU manufacturers, particularly SMEs, who face challenges in adapting to frequent regulatory changes. These changes, while aimed at increasing security, often place EU manufacturers at a competitive disadvantage compared to non-EU counterparts. Precisely due to the frequent regulatory changes that have multiplied over the years, and the need to coordinate provisions at different levelsinternational, EU, and nationalthe legal framework applicable to the civilian firearms and ammunition sector has become exceedingly complex and, at times, very difficult to interpret. This inevitably increases the likelihood that operators may make good-faith errors, potentially arising from interpretations differing from those of national authorities or from logistical challenges. Given these challenges, we urge the Commission to assess the impact of potential sanctions or regulatory changes on legitimate operators within the firearms sector. Unintended consequences, such as excessive penalties on legal businesses, could destabilize the industry. The sector is already highly regulated, with strict obligations on production, storage, and distribution. Administrative errors should remain within the realm of administrative penalties and not escalate to criminal sanctions. The increasing complexity of the legal framework, due to overlapping international, EU, and national provisions, heightens the risk of unintentional errors. Such errors, made in good faith, should not attract criminal penalties, which could harm SMEs, lead to job losses, and incentivize businesses to relocate outside the EU. It is also important for the Commission to take into account that the compliance obligations imposed to prevent illicit trafficking, which represent a burden and therefore a cost for businesses, should be proportionate to the actual security outcomes they can realistically achieve, in line with the proper application of the principle of proportionality. We encourage the Commission to carefully consider the broader impact that these measures could have on the legal firearms industry and remain available for further discussions to help shape a balanced and effective approach to these issues.
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Response to Review of rules of export authorisation, and import and transit measures for firearms

2 Jul 2021

The "alarm and signal weapons" are defined by art. 1.1.4 from the directive as devices "which are not capable of being converted to expel a shot, bullet or projectile". According to the Implementing Directive (EU) 2019/69 those devices that are not convertible are excluded from the definition of “firearms” and from the scope of the directive, and therefore of the Regulation. The issue consequently boils down to security checks by MSs. Deactivated weapons, according to the directive, are "firearms that have been rendered permanently unfit for use by deactivation". The Implementing Regulation (EU) 2018/337 establishes common guidelines on deactivation standards and techniques. Weapons that are not in compliance with it cannot be considered as "deactivated", thus being firearms for traceability and export purposes. The issue consequently boils down to security checks by MSs. The civil and military spheres must be kept separate. On the former, the check must be carried out with reference to the recipient (economic operator), on the latter it concerns the country of destination (governments). Applying the criteria of Common Position 2008/944/CFSP to civilian exports appears inappropriate, as it would be to do the opposite. Therefore, the mere reference to the Common Position should be removed from the provisions of the Regulation. It is thus correct to exclude that civilian firearms and military weapons may be subject to the same authorization. It seems correct to wish for greater detail of the regulatory rules, which reduce the discretionary space and increase the homogeneity of the application, also in terms of procedures and controls. In this regard, it appears essential to establish the impossibility for MSs to create obstacles of any kind – tariff-related, regulatory, connected to the granting of authorizations, etc. – to the intra-Union transfers for export purposes made based on the export authorization referred to in the regulation. It is paradoxical that free transit in third countries is possible as a result of tacit consent on the request for non-objection (Article 2 par.2), and, instead, that MSs can limit the intra-EU circulation of goods, whose export has already been authorized pursuant to a Union law of direct application. A strongly felt need is to greatly simplify the procedures for the operators, reviewing the maximum duration of the proceedings, which is currently inconsistent with the necessarily very fast times of international trade. A complete request sent electronically should be processed in 10 working days (doubled in particular cases). The classification of firearms - and the distinction between civilian firearms and military weapons - belongs to the scope of the directive and does not pertain to the Regulation. The risks of illegal trafficking and diversion in relation to civilian firearms must be assessed concretely and in relation to the actual events that occurred. Otherwise, we end up limiting rights of the EU economic operators - on the basis of merely perceived risks. Such a compression of individual freedoms would not be legitimate under the European law, as it violates the principle of proportionality. It should be emphasized that the marking and traceability of imported firearms and the import of signal and alarm weapons are matters that fall outside the competence of the regulation. Semi-finished parts, which cannot be utilized, cannot be considered as essential components, hence they are excluded from the discipline of acquisition and export. In any case, the regulation on semi-finished parts is excluded from the scope of the Regulation. The increased circulation of information should not result in an indiscriminate increase in denials. The fact that a MS has adopted a denial of a specific authorization does not mean that the recipient for this alone has become unreliable and remains so. Each authorization and denial must be evaluated in relation to specific and individual criteria.
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Response to Technical specifications for the marking of firearms and their essential components

23 Nov 2018

IEACS, l’Institut Européen des Armes de Chasse et de Sport, is a non-profit association which was founded in 1976 and virtually speaks on behalf of 1.000 European companies and about 150 manufacturers of civilian firearms across Europe. IEACS represents national associations and companies such as: Belgium (BWF); Finland (SAKO); France (SNAFAM); Germany (JSM); Italy (ANPAM and CONARMI); Spain (Asociacion Armera and ASECATI); UK (GTA). The implementing powers on the setting of technical specification on the marking of firearms cannot, by law, rule on an essential part of the legislative act. This happens, for instance, in Recital 1 of the Draft (“firearms and their essential components, whether part of a firearm or placed separately on the market”), which provides differently from Art. 4.1 of the Directive (“any such firearm, or any essential component”). The implementing act should also not have an innovative legislative nature and give binding interpretations of the provisions contained in the Directive. It is clear that, as formulated, the implementing act defers form the firearms directive’s text. If the EC wants to adopt such interpretation, it should establish clearly on the text of the implementing act, and not in the preamble, such requests in order to reach the higher effect of uniformity of the EU system on marking and not give the possibility to MSs to apply different systems. The EC proposal does not mention anywhere the possibility of applying the provisions of the Convention for the reciprocal recognition of proof marks on small arms of 1 July 1969 (CIP). Every single firearms manufactured in the EU is obliged to go to the proof houses and it should be specified that the data provided by the CIP marking replace those provided by the Directive, as affixed by the manufacturer or the importer. For example, the year of proof marking can replace the year of production, and the Proof Houses’ marks can replace the place or countries of production for the manufactured firearms. Furthermore, it seems that the EC proposal is in contrast with the principle of proportionality since it is requiring a “unique” marking on each essential part (name of the manufacturer or brand, the country or place of manufacture, the serial number and the year of manufacture, if not already part of the serial number, and the model where feasible) for the traceability of a firearms. If the EC is sure that the firearms directive 91/477, amended with directive 2017/853, clearly establishes to mark all the essential parts of an assembled firearm, in order to be a proportionate, it should require a unique marking only one essential parts and for the others essential parts provide a simplified system (i.e. serial number and CIP identification mark of the company or manufacturers trademark). Recently at UN level, during the Third Review Conference on the PoA (New York, June 2018) it was reiterated that only the frame/receiver of an assembled firearm should be marked, as reported in the final outcome document and demanding for further discussions on the Government Group of Experts. Requiring a “unique marking” on all essential parts could affect the aesthetics of a firearm and constitute useless information, in terms of traceability. Moreover, it seems that the requested system of electronic registers, provided by directive 2008/51 has been fulfilled by few of the MSs. Now, Directive 2017/853 is requiring a data-filling system, whose implementation will take several years. Therefore we suggest starting smoothly the process and reviewing it step by step in order not to damage the companies and mostly SMEs. Instead of approving an implementing act that could create problems for the above reasons, we recommend to go deeper on all of its aspects, sharing it with stakeholders and national institutions in order to avoid harms to both, since many of the proposals highlighted from the manufacturing experts were not taken into account.
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and Association des Fabricants Européens de Munitions de Sport and Associazione Nazionale Produttori Armi e Munizioni Sportive e Civili

30 Jun 2015 · European civilian and sporting arms and ammunition