Guidance

Supplying explosives precursors and poisons

Updated 27 March 2024

Certain chemicals can be used in the illicit manufacture of explosives or to cause harm.

Members of the public who want to import, acquire, possess or use these chemicals must hold an Explosives Precursors and Poisons (EPP) licence issued by the Home Office and an associated photographic identity document. For further information see EPP licences: application guidance.

For retailer-specific information on selling chemicals responsibly please see ProtectUK.

Sales of regulated substances

An EPP licence is required before regulated substances can be legitimately supplied to a member of the public. Businesses and professional users do not require EPP licences for regulated substances, where the substance is being used as part of their business or profession.

Regulated poisons must only be supplied to the public by or under the supervision of a registered pharmacist. Specific guidance for pharmacists is available.

A member of the public must show their valid EPP licence and associated photo ID document before you can supply any regulated chemicals.

The full lists of regulated substances and concentration thresholds are available at the end of this page.

If a member of the general public requests to purchase a regulated substance above the concentration threshold, you should:

  1. Ask to see their Explosives Precursors and Poisons (EPP) licence and associated photographic ID.
  2. Compare the photograph to the customer.
  3. Verify the photographic ID reference against the ID reference on the front page of the licence.
  4. Check the product being purchased is allowed as part of the licence conditions: substance, concentration, volume.
  5. Record the transaction details in the table on the back of the licence.
  6. If it is a regulated poison and you are not a registered pharmacist or operating under the supervision of a registered pharmacist, refuse the sale. If it is a regulated poison and you are a registered pharmacist, or operating under the supervision of a registered pharmacist, enter the transaction details into your poisons register.

If the transaction is suspicious or unusual in any way:

More information on suspicious transactions is provided below.

Guidance to assist you in checking a licence is available.

Professional users

From 1 October 2023 businesses supplying regulated explosives precursors to professional users and other businesses (those who don’t need a licence) will need to take additional steps to verify the legitimacy of the professional user or business. These additional steps are not required for sales of regulated poisons.

The person making the sale must obtain the following from the business customer:

  • the business customer’s name and address. If the business customer is not an individual, the name of an individual who is authorised on behalf of the business customer should be recorded;
  • a form of photographic identification of the business customer or, if the business customer is not an individual, of the individual making the purchase;
  • a statement of the nature of the business customer’s trade, business or profession, or of the public function that the business customer performs; and
  • the business customer’s VAT registration number, if the business customer has such a number.

This information does not need to be physically presented in person. For example, a photo of a driving licence attached to an email would be acceptable as a form of identification.

This information must be recorded and retained for 18 months and available for inspection.

In all cases, the supplier should assess whether the intended use is reasonably consistent with the trade, business or profession. If in doubt, the sale must be refused and reported as a suspicious transaction within 24 hours.

Businesses and professional users should be verified every time a new purchase is made. Where regulated substances are being supplied frequently or on a routine basis to the same professional user or business, verification should occur every 18 months or whenever there is a change or deviation from normal purchasing patterns.

For the purposes of this requirement, examples of photographic identification can include: passport, driving licence, trade identification card, business ID card. This list is not exhaustive.

For advice on verifying a business customer, you can either:

Suspicious transactions, disappearances and thefts

Any suspicious transactions or attempted transaction (business to consumer and business to business) of regulated substances and reportable substances must be reported.

Suspicious activity reports must be made using the online Report suspicious chemical activity service.

However, if you are unable to report in this way you can make a report to the national contact point on 0800 789321.

Look out for suspicious behaviour in your customers. Ask yourself:

  • are they your regular type of customer?

  • do they appear nervous, or are they avoiding communication?

  • are they trying to buy an unusual amount of a product or a strange combination of products?

  • are they unfamiliar with the product’s handling instructions?

  • are they refusing to buy a lower concentration product?

  • are they unwilling to share what they plan to use the product for?

  • are they insisting on paying in cash?

  • are they unwilling to provide ID or home address details?

  • are they requesting unusual packing or delivery methods?

Any significant disappearances or thefts of regulated substances and reportable substances must be reported within 24 hours to your local police force using 101 (or 999 in an emergency). Please include a reference to the Poisons Act in your report and if it is a regulated/reportable explosive precursor/poison.

The selling chemical products responsibly leaflet and poster provide advice to managers on how to alert your staff to suspicious transaction reporting requirements. Suppliers will need to identify your affected products and can utilise the editable poster to make a note of them. We suggest this poster is placed in a position where it can be easily seen by your staff but, as far as possible, hidden from view to customers.

From 1 October 2023 - Any suspicious transactions of regulated substances and reportable substances must be reported within 24 hours of considering a transaction to be suspicious.

From 1 October 2023 it will be a legal requirement for retailers to provide all information that they hold which may be of reasonable assistance in identifying the individual involved in a suspicious transaction when submitting the suspicious activity report (e.g name, email address, home address, payment card details).

This will not create an obligation to collect identifiable information where this is not held, only a requirement to report information relating to a suspicious transaction which is held as routine. Policing colleagues need this minimum level of detail to effectively investigate reports of suspicious activity.

Supply chain notification and training

From 1 October 2023 businesses supplying regulated and reportable substances to another business must inform them that the products they are purchasing are regulated or reportable under the Poisons Act 1972.

To comply with these measures, it is understood that different methods will need to be employed dependent on the specific environment of the supplier and customer base. Businesses should ensure they have a process in place that provides those in the supply chain with an awareness of their obligations under the Poisons Act when that product is sold on.

Consideration should be given to implementing one of the following methods of notification:

  • notification flag when making an order
  • separate email notification when a purchase is made
  • providing notices on shipping information (invoices)
  • providing a separate information note with deliveries

This is not a prescriptive list and businesses should utilise methods of notification that will work for their business within the environment that they operate.

Online marketplaces have new obligations to take all reasonably practicable measures to provide information to any supplier who uses the online marketplace to sell regulated or reportable substances about their obligations and to identify and report any suspicious transactions.

Businesses supplying any substances to professional users or members of the public must also ensure and be able to demonstrate that its staff are aware which of its products contain listed substances and are instructed on obligations and the potential offences which apply.

For retailer-specific information on selling chemicals responsibly please see ProtectUK.

Offences

The Poisons Act 1972 as amended introduces the following offences:

1) The supply of a regulated substance to a member of the general public:

(a) without first verifying that the member of the general public has a licence to import, acquire, possess and use that substance:

  • on conviction on indictment: imprisonment for a term not exceeding 2 years or a fine (or both)
  • on summary conviction: in England and Wales, imprisonment for a term not exceeding 3 months or to a fine (or both)
  • in Scotland, imprisonment for a term not exceeding 3 months or to a fine not exceeding level 5 on the standard scale (or both)

(b) without first entering details of the transaction on the licence:

  • on summary conviction: a fine not exceeding level 2 on the standard scale

(c) without first ensuring that a warning label is affixed to the packaging in which the substance is supplied:

  • on summary conviction: a fine not exceeding level 2 on the standard scale.

2) Failure to report suspicious transactions or significant disappearances or thefts:

  • on summary conviction: in England or Wales, imprisonment for a term not exceeding 3 months or to a fine (or both)
  • in Scotland, imprisonment for a term not exceeding 3 months or to a fine not exceeding level 5 on the standard scale (or both)

3) Failure to comply with regulations about poisons and explosives precursors:

  • on summary conviction: a fine not exceeding level 4 on the standard scale and for every day subsequent to conviction, a fine not exceeding one-tenth of level 1 on the standard scale

Complying with the law

  1. Identify which of your products contain regulated or reportable substances
  2. Implement a system that reminds the cashier that a product requires a licence or extra checks or is subject to suspicious transaction reporting.
  3. Be clear with staff about suspicious behaviours.
  4. Make sure your staff know about the record of suspicious transactions (or other internal company record procedures) and how to report to the police if needed.
  5. Make sure the above points are in your training manual.

Remind your staff about the tips on refusing a sale.

Please read the guidance on labelling requirements for regulated poisons and explosives precursors.

Background legislation

On 26 March 2015, the Poisons Act 1972 was amended via the Deregulation Act 2015 and the Control of Poisons and Explosives Precursors Regulations 2015 were introduced to create a cohesive regime to control sales of explosives precursors and poisons. Poisons Act 1972 (legislation.gov.uk)

The Control of Poisons and Explosives Precursors Regulations 2023 introduced new substances to the lists of regulated explosives precursors and poisons. Offences relating to the acquisition, importation, supply, possession and use of the following substances were added and are effective from 1 October 2023:

  • hexamine
  • hydrochloric acid above 10% w/w
  • phosphoric acid above 30% w/w
  • ammonium nitrate above 16% nitrogen
  • aluminium sulfide, sodium sulfide, calcium sulfide and magnesium sulfide
  • arsenic compounds (specifically, calcium arsenites, copper acetoarsenite, copper arsenates,lead arsenates)
  • mercury compounds (mercuric chloride, mercuric iodide, organic compounds of mercury except compounds that contain a methyl group directly linked to the mercury atom)
  • zinc phosphide
  • calcium phosphide
  • 2,4-Dinitrophenol

The full lists are set out below.

Chemical list

To note: substances listed below, which fall below the stated concentration threshold, should still be considered reportable substances.

Regulated explosives precursors:

Substance CAS RN number
ammonium nitrate: 16% N (CAS RN 6484-52-2)
hexamine (CAS RN 100-97-0)
hydrochloric acid above 10% w/w (CAS RN 7647-01-0)
hydrogen peroxide:12% w/w (CAS RN 7722-84-1)
nitromethane: 30% w/w (CAS RN 75-52-5)
nitric acid: 3% w/w (CAS RN 7697-37-2)
phosphoric acid: 30% w/w (CAS RN 7664-38-2)
potassium chlorate: 40% w/w (CAS RN 3811-04-9)
potassium perchlorate: 40% w/w (CAS RN 7778-74-7)
sodium chlorate: 40% w/w (CAS RN 7775-09-9)
sodium perchlorate: 40% w/w (CAS RN 7601-89-0)
sulfuric acid: 15% w/w (CAS RN 7664-93-9)

Regulated poisons:

Substance CAS RN Number
aluminium phosphide (CAS RN 20859-73-8)
aluminium sulfide (CAS RN 1302-81-4)
arsenic and its compounds (arsenic: CAS RN 7440-38-2)
barium and its salts (other than barium sulphate, barium carbonate and barium silicofluoride) (barium: CAS RN 7440-39-3)
bromomethane (CAS RN 74-83-9)
calcium phosphide (CAS RN 1305-99-3)
calcium sulfide (CAS RN 20548-54-3)
chloropicrin (CAS RN 76-06-2)
fluoroacetic acid, its salts and fluoroacetamide (fluoroacetic acid: CAS RN 144-49-0)
hydrogen cyanide and metal cyanides (other than ferrocyanides and ferricyanides) (hydrogen cyanide: CAS RN 74-90-8)
lead acetates and compounds of lead with acids from fixed oils (lead acetate: CAS RN 15347-57-6)
magnesium phosphide (CAS RN 12057-74-8)
magnesium sulfide (CAS RN 12032-36-9)
mercury and its compounds (mercury: CAS RN 7439-97-6)
oxalic acid: 10% w/w (CAS RN 144-62-7)
phenols (phenol; phenolic isomers of the following: cresols, xylenols, monoethylphenols); compounds of phenols with a metal, 60% w/w of phenols or, for compounds of phenols with a metal, the equivalent of 60% w/w of phenols (phenol: CAS RN 108-95-2)
phosphorus yellow (CAS RN 7723-14-0)
sodium sulfide (CAS RN 1313-82-2)
strychnine and its salts and its quaternary compounds (strychnine: CAS RN 57-24-9)
thallium and its salts (thallium: CAS RN 7440-28-0)
zinc phosphide (CAS RN 1314-84-7)
2,4-dinitrophenol and compounds including sodium dinitrophenolate (2,4-dinitrophenol: CAS RN 51-28-5) (sodium dinitrophenolate: CAS RN 1011-73-0)

Reportable explosives precursors:

Substance CAS RN number
acetone (CAS RN 67-64-1)
aluminium powders (CAS RN 7429-90-5)
calcium nitrate (CAS RN 10124-37-5)
calcium ammonium nitrate (CAS RN 15245-12-2)
magnesium nitrate hexahydrate (CAS RN 13446-18-9)
magnesium powders (CAS RN 7439-95-4)
potassium nitrate (CAS RN 7757-79-1)
sodium nitrate (CAS RN 7631-99-4)
sulfur (CAS RN 7704-34-9)

Reportable poisons:

Substance CAS RN Number
aldicarb (CAS RN 116-06-3)
alpha-chloralose (CAS RN 15879-93-3)
ammonia 10% w/w (CAS RN 7664-41-7 and CAS RN 1336-21-6)
barium, salts of, the following: barium carbonate; barium silicofluoride  
carbofuran (CAS RN 1563-66-2)
cycloheximide (CAS RN 66-81-9)
dinitrocresols (DNOC), their compounds with a metal or a base (dinitrocresol: CAS RN 534-52-1)
dinoseb its compounds with a metal or a base (CAS RN 88-85-7)
dinoterb (CAS RN 1420-07-1)
drazoxolon; its salts (drazoxolon CAS RN 5707-69-7)
endosulfan (CAS RN 115-29-7)
endothal, its salts (endothal: CAS RN 145-73-3)
endrin (CAS RN 72-20-8)
fentin, compounds of (fentin: CAS RN 668-34-8)
formaldehyde 5% w/w (CAS RN 50-00-0)
formic acid 25% w/w (CAS RN 64-18-6)
hydrofluoric acid alkali metal bifluorides; ammonium bifluoride alkali metal fluorides; ammonium fluoride; sodium silicofluoride (hydrofluoric acid: CAS RN 7664-39-3) (ammonium bifluoride: CAS RN 1341-49-7) (ammonium fluoride: CAS RN 12125-01-8) (sodium silicofluoride: CAS RN 16893-85-9)
metallic oxalates  
metal phosphides  
metal sulfides and polysulfides  
methomyl (CAS RN 16752-77-5)
nicotine, its salts; its quarternary compounds (nicotine: CAS RN 54-11-5)
nitrobenzene 0.1% w/w (CAS RN 98-95-3)
oxamyl (CAS RN 23135-22-0)
paraquat, salts of (paraquat: CAS RN 4685-14-7)
phenols in substances containing no more than 60%, weight in weight, of phenols; compounds of phenols with a metal in substances containing no more than the equivalent of 60%, weight in weight, of phenols  
phosphorus compounds, the following: azinphos-methyl, chlorfenvinphos, demephion, demeton-S-methyl, demeton-S-methyl sulphone, dialifos, dichlorvos, dioxathion, disulfoton, fonofos, mecarbam, mephosfolan, methidathion, mevinphos, omethoate, oxydemeton-methyl, parathion, phenkapton, phorate, phosphamidon, pirimiphos-ethyl, quinalphos, thiometon, thionazin, triazophos, vamidothion  
potassium hydroxide 17% of total caustic alkalinity (CAS RN 1310-58-3)
sodium hydroxide 12% of total caustic alkalinity (CAS RN 1310-73-2)
sodium nitrite (CAS RN 7632-00-0)
sodium hypochlorite solutions, above 6% available chlorine (CAS RN 7681-52-9)
thiofanox (CAS RN 39196-18-4)

Products of particular interest are those in which a reportable chemical is either: present on its own or the main ingredient, or present in a simple mixture, typically less than 5 ingredients.

Products containing less than 1% of any of the reportable chemicals, or fertilizers that are not labelled for nitrogen (N) content are, in general, of no concern.

The spelling of the EPPs referred to above is taken from the International Union of Pure and Applied Chemistry (IUPAC) nomenclature.