Towards the end of last year, the Firearms Taskforce, European Commission started to review the Regulations surrounding the import and export of firearms and ammunition. This has been put out to consultation with the following message:
“The European Commission started during the last quarter of 2020 the process to review Regulation (EU) No 258/2012 on exports, imports and transit of civilian firearms. The current EU legislation 258/2012 on exports, imports and transit of civilian firearms was designed to prevent diversion of firearms from the legal trade to the black market. The Commission is conducting an impact assessment, as stated in the 2020-2025 EU Action plan on firearms trafficking, to examine ways to improve traceability, exchange of information and to increase the security of export and import control procedures.
In order to receive as much input as possible, the Commission is launching a public consultation through the following link: Firearms – review of export rules and import & transit measures (europa.eu). The public consultation will be closed on 11/10/2021.
The Commission especially calls upon firearms users (hunters and sport shooters), manufacturers and collectors to give their opinions on the problems and the future of EU rules on exports, imports and transit of firearms. Now is the time to inform the Commission of any challenges, shortcomings or best practices.”
As you are aware, the NSRA are heavily involved in the British Shooting Sports Council (BSSC) in defending target shooting and their response that was sent on 2nd July 2021 as follows:
Firearms – review of export rules and import & transit measures
While we support the principles, embodied in the UN Arms Trade Treaty, which are designed to prevent illicit transfer, trafficking or diversion of firearms, we maintain that a strong, viable network of lawful and registered firearms dealers is fundamental to preventing illicit trade.
We also note the text, as cited in the CSP7 preparatory meetings (April 26-30, 2021) that: “ATT stakeholders should formalise discussions concerning post-delivery cooperation experiences from both exporter and importer perspectives and should consider developing guidelines on cooperation and assistance to ensure ongoing compliance with export documentation, including authorised end-use.”
We therefore understand the rationale behind the EU adoption of 'authorised' End Use Certificates (EUCs). This is, however, causing difficulties for importing countries such as the UK, and is putting shipments at greater risk than is necessary. The reason for this is that UK legislation does not require authorised EUCs and there is therefore no competent UK authority willing to endorse such documents. Neither the UK Department of International Trade, the Home Office nor the Police have at present the mandate to endorse these certificates.
Shipments which formerly came from Austria to the UK through Germany and France are now being trans-shipped by sea via several ports on the Atlantic and Mediterranean, as Germany now requires an 'authorised' EUC in order for a transit permit to be issued. (We understand that even with an 'authorised' EUC, the time taken to obtain a transit permit has increased from 4-6 weeks to 10-12 months.) The costs of shipment have tripled or quadrupled and the shipment time has increased from a few days to about a month, greatly increasing the exposure of shipments to the risk of theft or illicit diversion.
UK dealers are in consequence finding alternatives to EU vendors.
Anyone wishing to comment should respond directly before 11/10/2021 to:
The Firearms Task-Force
DG Migration and Home Affairs
Organised Crime – Task-force Firearms (unit D5)