Import, export and transit measures for firearms, their essential components and ammunition: implementation of Article 10 of the UN Firearms Protocol. Recast

Please find enclosed the opinion of ESFAM, the Association of European Firearms manufacturers, on the Proposals of the EU Commission to amend Regulation 258/2012 on import, export and transit measures for firearms, their essential components and ammunition. ESFAM is an international non-profit association whose members are leading European manufacturers of hunting and sport shooting weapons.

As a professional organisation representing the interests of economic players in the hunting, sport shooting and safety equipment sector in France, SNAFAM has developed the proposals and guidelines addressed through this introduction to the impact study. We have expressed opinions that are part of the analysis delivered independently by the IEACS.

Filed in French · English published by the European Commission

En temps qu' organisation professionnelle représentant les intérêts des acteurs économiques du secteur de la chasse, du tir sportif et des équipements de sécurité en France, le SNAFAM a étudié les propositions et orientations envisagées au travers de cette introduction d'étude d'impact. Nous avons exprimé des opinions qui sont parties prenantes de l'analyse délivrée indépendamment par l'IEACS.

The revision should perfect import procedures, to protect and not discriminate European products. We agree there is a need to streamline bureaucracy and reduce costs, but we are used to expecting the exact opposite whenever there is talk of “streamlining”. The revision could cause more work for the public administration: who will pay the price for this extra work and the inevitable delays, if not companies?

Finnish Arms Trade Association would like to thank you about the opportunity to make the comments set out below on the Inception Impact Assessment regarding "Review of rules of export authorization, and import and transit measures for firearms" Ref Ares(2021) 3677254. 1.

The Verband Deutscher Büsenmacher und Arms Professionals e.V. (Verband Deutscher Büsenmacher und Wafffachdler e.V.) thanked the Commission for the opportunity to comment on the first impact assessment of Regulation (EU) No 258/2012.

Filed in German · English published by the European Commission

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.

A.C.A.C. thanked the Commission for the opportunity to comment on the first impact assessment of Regulation (EU) No 258/2012. We have the following comments: Scope & definitions • Firearms, irritants and signal weapons, deactivated weapons and acoustic weapons are not by definition firearms and must therefore not be subject to the Firearms Regulation in future.

Filed in German · English published by the European Commission

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.

Transcrime – Joint Research Centre on Transnational Crime, Università Cattolica del Sacro Cuore welcomes and supports the European Commission´s initiative to review the rules of export authorization and import and transit measures for firearms. It provides below some comments: 1) Improving data collection on firearms is essential to build a better intelligence picture, safeguard the licit market and limit diversion.

We thank the Commission for giving us the opportunity to comment on the inception impact assessment regarding Regulation (EU) No 258/2012. At this stage, we have the following concerns. 1. With regards to the list of items requiring legislative clarification, specifically the identification of “objective criteria making it easier to differentiate between civilian and military firearms”, we believe that such an…

Position of ESFAM regarding certain measures proposed by the EU Commission to amend/clarify Regulation (EU) No 258/2012 on exports, imports and transit of civilian firearms (“the Regulation”) As a preliminary remark, ESFAM (https://www.esfam.eu/) which represents the interest of the most important European civilian firearms manufacturers considers the delay to react to the various measures proposed by the EU…

1. We have been calling for the uniform implementation of the UN Firearms Protocol in the EU for years and have repeatedly pointed out that there is no uniform application of the EU Firearms Regulation in the individual EU Member States. In this respect, we have advocated that there is a need to clarify the uniform scope of the EU Firearms Regulation.

Filed in German · English published by the European Commission

Below is a joint contribution from FITASC (Fédération Internationale de Tir aux Armes Sportives de Chasse) and ISSF (International Shooting Sport Federation): FITASC and ISSF hereby reaffirm their full support for measures to combat the illegal possession of weapons.

We appreciate that one of your objectives is to facilitate the legitimate international trade of firearms and support the EU industry with as little regulatory burden as possible since unfortunately, it has not been the case so far as the regulations are stricter but most of all, they keep changing and it is thus really hard to adapt our industrial and internal processes each time (e.g: marking; REACH).

Having been given the opportunity, the International Practical Shooting Confederation would like to make the comments set out below on the Inception Impact Assessment regarding "Review of rules of export authorization, and import and transit measures for firearms" Ref Ares (2021) 3677254.

Review of rules of export authorization, and import and transit measures for firearms - Ref Ares(2021) 3677254. Having been given the opportunity, the Swedish Multisport Federation would like to make the comments set out below on the Inception Impact Assessment regarding "Review of rules of export authorization, and import and transit measures for firearms" Ref Ares(2021) 3677254.

Feedback will be provided in consultation with the Civil Security Working Group (ARGE Civilian Security): • Deactivated weapons, acoustic weapons and alarm and signal weapons (pyrotechnic weapons) are not firearms used against living organisms. They are therefore, for good reason, not taken into account in the scope of the Firearms Regulation.

Filed in German · English published by the European Commission

We welcome and supports the Commission´s timely initiative to review the rules of export authorisation and import and transit measures for firearms and would like to present the following comments: 1) Pan-European data gathering on import and export controls is needed. 2) Classification of civilian and military firearms: military if not clearly civilian?

The suggested legislative proposal is not apporopriate: "better controls of “semi-finished” unmarked components, by import prohibitions, or authorising imports only to arms dealers" The regulations can only cover "essential components" as regulated by the firearms directive.

Dear Sirs, We are custom and hand made hunting shotgun manufacturers located in Eibar, north of Spain. We are having many difficulties to find authorized transports for our products. Sometimes with have no other option to ship our products by airfreight because there is no other alternative for us, which makes our logistics alternatives very limited and expensive.