Chemical regulations: the challenge facing land-based armaments

Chemistry lies at the heart of land-based armaments. Behind every round of ammunition is a pyrotechnic chain — explosives, propellant powders, priming compositions — built on energetic materials whose formulations have been inherited and qualified over many years. Over the course of a decade, the regulatory framework governing these substances has become a structural factor for the sector. Long treated as a peripheral compliance matter, the chemical dossier has today emerged as a strategic variable, at the crossroads of three requirements long considered separately: industrial sovereignty, the availability of military capabilities, and environmental and social responsibility.

By Ivy Carter

REACH and beyond: major impacts

The REACH regulation, a cornerstone of European environmental legislation since 2007, governs the registration, evaluation, authorisation and restriction of chemical substances.¹ Among the substances that are banned or classified as substances of very high concern are the main lead salts and oxides — azide, styphnate, chromate, mono- and tetroxide —, dichromates, lead solders and alloys, dibutyl phthalate and dinitrotoluene. The mechanisms of this regulation have very concrete effects upstream in the defence sector: a substance restricted for civilian uses can undermine an energetic formulation, a stabiliser or a priming composition with no qualified alternative. “Substances used in initiation, for example, are very heavily impacted by REACH,” note one industry representatives. The consequences are measured in delays and costs: “registering a substance can require twelve to eighteen months of procedure and in the order of 25 million euros,” details a GICAT study.² While conditions were set to tighten, in late April 2026 the European Commission confirmed the abandonment of the “REACH 2.0” project launched in 2020, with Commissioner Jessika Roswall taking the view that the time had not come to reopen the text.³ A reprieve, but not a blank cheque: “stability is necessary for sectors with long cycles. That said, existing regulatory processes continue to operate and heavy dossiers — foremost among them PFAS — remain open,” industry representatives note. Other substances may be subject to upcoming restrictions: barium chromate, lead dioxide and silver. Beyond REACH, export-control constraints require the absence of any controlled component in initiation systems, in the name of supply autonomy and continuity.

Reducing pollution: efforts already under way

The sector did not wait to be forced into action. EURENCO, the European leader in energetic materials, has made reducing its environmental footprint one of its three strategic priorities: remediation of contaminated soils at Bergerac and Angoulême (200  hectares rehabilitated), and a new effluent treatment plant at Sorgues that has cut site discharges tenfold.⁴ The development of reduced-hazard munitions — “insensitive” explosives and powders — responds both to a safety imperative for sites and operators and to an eco-design logic.⁵ For dual-use applications, European initiator manufacturers have decided to switch to lead-free electric igniters and detonators, for example.

Replacing problematic components: where does research stand?

Substitution is the long-term horizon, constrained by the physics of energetic materials and the burden of qualification procedures. Several avenues coexist: some solutions are already qualified, others still in development. Among the former are ZPP (zirconium/potassium perchlorate), SINTOX (potassium chlorate/antimony sulphide) and DDNP (diazodinitrophenol); among the latter, silver azide — whose long-term viability is not guaranteed, as silver itself is under REACH scrutiny — as well as ISL’s NSTEX (a nanothermite and nanostructured explosive blend), PyroMEMs and energetic nanocomposites. Research is also focusing on primary-explosive-free systems, such as the slapper (an electropyrotechnic projected-foil initiator) or the IOP/DOP (an optopyrotechnic initiator), as well as on new processing technologies: micro-extrusion, spin coating, inkjet printing and vapour deposition. On primers, teams from the US Army and Purdue University have synthesised new leadfree primary explosives as candidates to replace lead azide. These alternatives are not without their difficulties: “with an identical design, performance is not always equivalent and regression remains possible. Added to this are a high qualification cost, the need for type approval for the French defence market, extended procurement lead times and rising series prices,” industry representatives specify.⁶

What scenarios for the future?

Three hypotheses are taking shape. The first is that of the reprieve prolonging the status quo: REACH is not reopened, but pressure is applied dossier by dossier, starting with PFAS, and the simplification announced by Brussels does not remove the uncertainty. The second, that of accelerated substitution, presupposes a massive public financing effort: the European ASAP programme has already mobilised more than 40  million euros for projects led by the ammunition division of KNDS and its partners, notably to strengthen powder and explosive production in France and Sweden. Combined with sustained R&D on green energetics, this path would transform the constraint into a competitive advantage. The third, the most risky, would see regulation advance faster than science: a critical substance restricted before a substitute is qualified, and a capability disappears. To bound this risk, states have tools at their disposal — the Substitution is the long-term horizon, constrained by the physics of energetic materials and the burden of qualification procedures. European Defence Agency has adopted a common position on the classification of ammunition with regard to REACH⁷ — but their use remains uneven. combining defence and csr: the sector’s proposals Defence industry players advocate a coherent approach rather than a rejection of regulation. Their proposals converge: long-term regulatory visibility, compatible with fifteen-year industrial cycles; documented and harmonised use of the exemptions provided, on defence grounds, by Article 2(3) of REACH; public funding directed towards research on substitutes; structured and early dialogue with ECHA and the relevant ministries. “Far from setting military performance against responsibility, this approach articulates the two. Reducing dependence on the most concerning substances protects operators, secures the territories where facilities are located, reinforces the social acceptability of a sensitive industry and consolidates the resilience of supply chains,” industry representatives add. The condition lies in the pace: a transition imposed abruptly undermines capabilities; anticipated, funded and planned, it strengthens them. CSR in land-based armaments is therefore not measured solely by extra-financial indicators: it is played out in the ability of industry players to embed the control and reduction of chemical risk in their strategy. The abandonment of “REACH 2.0” offers a reprieve, but the underlying trajectory remains. For ammunition manufacturers and military pyrotechnics, the response lies in anticipation — integrating regulatory chemistry into capability planning, investing in substitutes, and keeping dialogue with regulators alive. On that condition, the constraint ceases to be a risk endured and becomes an element of strategy — and CSR, a genuine asset for sovereignty.

1. Regulation (EC) No 1907/2006 (REACH). European Chemicals Agency (ECHA), echa.europa.eu/en

2. “War economy: the European REACH regulation risks hampering the build-up of ammunition stocks”, 2023

3. “REACH regulation: the European Commission buries its reform”, franceinfo, May 2026 ; “European lawmakers shelve major revision of REACH chemical regulation”, C&EN, April 2026

4 eurenco.com

5. Presentation of ammunition activities, nexter-group.fr

6. Source: gtps.fr

7. eda.europa.eu