News from Reeves & Dola, LLP 
*** R|D ALERT ***

December 31, 2019


On January 2, 2020, the 2019 List of Explosive Materials will be published in the Federal Register (Docket No. 2019R-04, available at This list, which the Bureau of Alcohol, Tobacco, Firearms and Explosives ("ATF") must publish annually, includes explosives, blasting agents and detonators determined to be captured under the statutory definition of "explosive materials" and subject to the explosives controls of 18 U.S.C. 841 et seq. and ATF's regulations at 27 C.F.R. part 555 . According to ATF, this year's list is the same as the 2018 list, except that it adds four explosives not previously listed:
  1. "dipicryl sulfide" and its synonym "hexanitrodiphenyl sulfide";
  2. "nitrotriazolone" and its synonym "3-nitro-1,2,4-triazol-5-one";
  3. "trinitrobenzenesulfonic acid" and its synonym "picryl sulfonic acid"; and
  4. "trinitrofluorenone."

The 2019 list supersedes the 2018 list, published on December 12, 2018.   The effective date for the 2019 list will be specified in the official notice.

Although the list is comprehensive, it is not all-inclusive. "Explosive materials" is defined in 18 U.S.C. 841 and includes explosives, blasting agents, water gels and detonators. Further, explosive materials include, but are not limited to all items in the List of Explosive Materials. Therefore, according to ATF, the addition of the four explosive materials to the annual list should not impact those subject to the federal explosives regulations because all explosive materials, including those not on the annual list are already regulated under Part 555. Be sure to regularly consult the statutory definitions in 18 U.S.C. 841 to determine whether your activities are subject to ATF's regulations governing commerce in explosives,  27 C.F.R. Part 555.

For additional information on changes and updates affecting the explosives industry, click here to read ATF's Explosives Industry Newsletter, published earlier this month.

And finally...

All  of us at Reeves & Dola wish you and yours a safe and prosperous 2020!

The above alert is for informational purposes only and is not intended to be construed or used as legal advice. Receipt of this alert does not establish an attorney-client relationship.     

Questions about this alert may be directed to: 

About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.

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