On behalf of the German Ammunition Research Association, on the implementation of Article 11 of the EU Firearms Directive 

The petitioner takes the view that the Firearms Directive (2017/853) , because of its requirements for national implementation, makes research into ammunition in an international context almost impossible. He says that meetings of ammunition researchers organised in the European Cartridge Research Association usually take place alternately in Germany, the Netherlands and Switzerland. He states that the aim of these events is to bring ammunition in small quantities (individual items or small packaging units) to the meetings in order to present or exchange research findings, extend researchers’ own collections or sell or exhibit cartridges or have them examined. The petitioner says that, under Article 11 of the directive, official authorisation is required for any transfer to another Member State and that the same applies to the sale of ammunition. This is not practicable, according to the petitioner, is logistically very complex, and is very costly. The petitioner is therefore calling for revision or interpretation of Article 11 of the directive with a view to exempting cross-border transfers of ammunition for research purposes.