Fireworks Consultation Reponses
1. Are there any other particular F2 and F3 fireworks products that you think the general public should not be allowed to buy? Please state which products and give your reasons.
There is a serious question about why Category F2 and F3 fireworks are still available for unrestricted public use. These are not harmless novelties: F2 fireworks are designed for outdoor use with significant safety distances, while F3 fireworks are classed as a medium hazard and require large open spaces. Yet they can still be bought by any adult and discharged in residential areas, often with no training, no assessment of the surroundings and no warning to neighbours.
The consequences extend far beyond the person lighting them. Sudden explosive noise can cause profound distress to vulnerable people, veterans, those with sensory sensitivities, domestic animals, livestock and wildlife, while misuse carries an obvious risk of burns and other serious injury.
If a product is powerful enough to require substantial exclusion distances and careful management, it is reasonable to ask why its use should not be limited to trained or licensed operators and properly organised displays. Celebration does not require giving individuals unrestricted access to explosives capable of frightening, injuring and severely disrupting everyone around them.
2. If more products are added to the Regulation 33 banned list, what consequences might there be for consumers, industry, enforcement authorities, professional users and others?
Adding further F2 and F3 products to the Regulation 33 banned list would inevitably have some consequences, but I believe these would be proportionate if the products concerned present an unacceptable level of risk, noise or potential for misuse.
For consumers, the main consequence would be reduced choice. However, consumers would still have access to a substantial range of lower-risk and lower-noise fireworks, so the ability to celebrate with fireworks would not be removed. In practice, the restriction could encourage manufacturers and retailers to provide more visually impressive but less disruptive alternatives. There is a possible risk that some consumers would seek prohibited products through illegal or unregulated sources, which means enforcement and clear public information would be important.
For the fireworks industry, there would be an initial commercial impact. Retailers, importers and manufacturers might have to change product ranges, manage existing stock and invest in developing compliant alternatives. However, this should be weighed against the wider social costs associated with products capable of causing significant disturbance or being easily misused. A clearly announced transition period would allow legitimate businesses to adapt. It could also stimulate innovation towards fireworks where the emphasis is on visual effect rather than extreme explosive noise.
Enforcement authorities may initially face additional work in identifying prohibited products, monitoring sales and dealing with illegal supply. For that reason, any additions to Regulation 33 should be defined very clearly by objective product characteristics wherever possible. Clear regulation is easier to enforce than relying on subjective judgements about whether individual use has become unreasonable.
Professional users should experience relatively little disadvantage because Regulation 33 products can continue to be supplied to persons with specialist knowledge. This seems a sensible distinction. Professional operators have training, experience, appropriate safety procedures and insurance, and displays can be planned with consideration for location, spectators and the surrounding community.
There would also be consequences for people who do not use fireworks themselves. Restricting particularly loud, hazardous or easily misused products could reduce unpredictable explosive noise in residential areas and therefore reduce distress to vulnerable people, people with sensory sensitivities or trauma-related responses, domestic animals, livestock and wildlife. It could also reduce some of the nuisance, intimidation and antisocial use associated with powerful fireworks.
Overall, the relevant question should not be whether adding products to Regulation 33 causes any inconvenience or commercial cost, but whether those consequences are proportionate to the risks being addressed. Where a particular F2 or F3 product creates a level of risk, noise or potential for misuse which is difficult for an ordinary member of the public to manage responsibly, restricting it to people with specialist knowledge is a reasonable and proportionate approach.
3. Do you agree that Regulation 33(1)(g) should be amended to make explicit that a firework comprising more than one shot tube is banned from sale to the general public?
I agree. If a single shot tube meeting the criteria in Regulation 33(1)(g) is prohibited from sale to the general public, it is logical that combining several such tubes into one firework should not provide a way around that restriction.
Making this explicit in the legislation would remove ambiguity rather than introduce an entirely new principle. Clear wording would benefit consumers, retailers and enforcement authorities by making it immediately apparent which products may legally be supplied to the general public.
It would also reduce the possibility of manufacturers, importers or sellers interpreting the existing wording differently or attempting to exploit a technical distinction between a single prohibited shot tube and several of the same tubes combined within one product. Where legislation concerns explosive articles and public safety, there should be as little room for uncertainty as possible.
For those reasons, Regulation 33(1)(g) should be amended to state expressly that fireworks comprising more than one shot tube are included within the prohibition.
4. Do you agree that the age limit for purchasing Christmas crackers should be removed?
I answered neither agree nor disagree.
5. Are there any other specific F1 and P1 pyrotechnics that should have their regulatory requirements increased or decreased?
I believe the regulatory requirements for P1 smoke bombs and similar high-output smoke devices should be increased. Although P1 products are classified as presenting a low hazard, smoke bombs can create substantial volumes of smoke, significantly reduce visibility and, when used in crowded or inappropriate environments, cause panic, distress and confusion.
Their potential effect therefore appears greater than the description “low hazard” might suggest to an ordinary consumer.
I would support tighter controls on their sale and use, particularly where products produce substantial or prolonged smoke. This could include restricting higher-output smoke devices to persons with specialist knowledge, introducing clearer limits based on smoke output or duration, and strengthening requirements concerning where they may be used.
At the very least, packaging and point-of-sale information should make it very clear that such products are not suitable for use in crowds, enclosed spaces or locations where smoke could be mistaken for a fire or other emergency.
I would also support reviewing F1 products intended for indoor use to ensure that their classification genuinely reflects their potential consequences when used in a domestic environment. F1 covers products ranging from very low-risk items such as party poppers and Christmas crackers to small fountains and other pyrotechnic effects. Where an F1 product produces flame, sparks or significant smoke, clearer safety requirements and distinctions within the category may be justified.
I would not support increasing regulation simply because a product is pyrotechnic. Regulation should remain proportionate to demonstrable risk. Very low-risk products such as party poppers and Christmas crackers do not require the same controls as products capable of filling an area with smoke or producing significant flame or sparks.
6. Do you agree the decibel level of fireworks consumers use should be lowered? Choose one of the following options:
I chose Yes to 90dB
7. What might be the positive impacts of reducing the maximum decibel level of fireworks available to the general public?
Reducing the maximum decibel level of fireworks available to the general public could have substantial positive effects for people, animals and communities, while still allowing fireworks to be used for celebration.
One of the most important benefits would be reducing the intensity of the sudden startle response caused by explosive noise. The issue is not simply whether a sound is loud enough to damage hearing. Sudden, unpredictable noise can activate an automatic threat response before a person has consciously assessed whether they are actually in danger. This is particularly relevant for people with PTSD, autism, sensory sensitivities and other conditions associated with heightened responses to unexpected noise.
Reducing the intensity of the stimulus would not eliminate every reaction, but it should reduce the severity and reach of the disturbance.
There would also be significant animal-welfare benefits. Animals cannot understand that an explosion is recreational or predict when the next one will occur. Firework noise can therefore trigger panic and flight behaviour, sometimes resulting in injury or death. Dogs, horses, livestock and wildlife can all be affected.
There are wider community benefits as well. Government polling has shown strong concern about the effects of firework noise on animals, vulnerable people and community peace and quiet. Lower-noise fireworks could reduce sleep disturbance, fear, nuisance and conflict between neighbours, particularly because privately used fireworks are often unpredictable and may be discharged over a much wider period than organised displays.
Importantly, reducing the maximum noise level would not prevent people from enjoying fireworks. The visual spectacle would remain, and lower-noise fireworks are already commercially available. It could also encourage manufacturers to innovate and shift the consumer market towards products in which visual effects rather than explosive noise provide the entertainment.
I would favour a substantial reduction rather than a minimal one. Reducing the limit from 120 dB to 110 dB would still leave fireworks exceptionally loud. A reduction to 100 dB, or preferably 90 dB for fireworks sold for domestic use, would create a more meaningful distinction between fireworks considered suitable for general public use in residential environments and louder fireworks reserved for properly organised professional displays.
Professional displays could still use louder products where appropriate. Unlike an unexpected firework discharged in a neighbouring garden or street, organised displays are generally advertised in advance, allowing vulnerable people and animal owners at least some opportunity to prepare.
8. What might be the negative impacts of reducing the maximum decibel level of fireworks available to the general public?
There would be some negative impacts from reducing the maximum permitted decibel level of fireworks available to the general public, although I believe these are largely manageable and should be weighed against the benefits to people, animals and communities.
The most immediate impact would be on the fireworks industry. Manufacturers and importers might need to reformulate or replace products, undertake conformity assessment and testing, alter packaging and change future orders. Retailers could also be left with stock that could no longer legally be sold to consumers if the transition period were inadequate.
Consumers would have a smaller choice of very loud fireworks. Some people specifically value the explosive report as part of the firework experience and may consider lower-noise products less impressive. However, this is a loss of one particular type of effect rather than a loss of access to fireworks themselves.
There could also be enforcement and technical difficulties. Firework noise is affected by environmental conditions and the method by which it is measured. Any lower UK limit would therefore need a robust and unambiguous testing standard so that compliant businesses were not disadvantaged and enforcement authorities could determine reliably whether a product complied.
There is also a potential risk that consumers who particularly want very loud fireworks could seek them through illegal, unregulated or overseas sources. That could create an unintended safety problem if such products do not meet UK safety requirements. This risk would need to be addressed through effective enforcement of importation and online sales.
The scale of these disadvantages would depend considerably upon the level chosen. A reduction to 110 dB would affect fewer existing products and therefore cause less commercial disruption than a reduction to 90 dB. However, avoiding disruption to an established market should not in itself determine the appropriate safety standard.
Overall, I recognise that reducing the maximum decibel level would involve costs, reduced consumer choice and some enforcement challenges. These are legitimate considerations, but they appear capable of being mitigated through clear technical standards, effective enforcement and an adequate transition period. They should therefore be balanced against the much wider involuntary effects that very loud fireworks can impose on people and animals who have made no choice to participate in their use.
9. How much lead-in time would businesses need to prepare for the changes proposed in this consultation and why?
I believe a lead-in period of 12 months would be reasonable and proportionate.
The fireworks industry operates through an international and highly seasonal supply chain. Products may be ordered many months in advance, so a six-month period could leave responsible importers and retailers holding substantial quantities of products that were entirely lawful when ordered but could no longer be sold to the general public.
A 12-month period would allow businesses to complete a full annual purchasing and sales cycle, revise future orders, identify products affected by new Regulation 33 restrictions or lower noise limits, and arrange for alternative compliant products. Where products need to be redesigned or replaced, manufacturers and importers may also need time for testing, conformity assessment, certification and revised labelling.
This is particularly important if the maximum permitted noise level is substantially reduced. Depending upon the level selected, a significant proportion of the existing consumer range could be affected, so expecting businesses to restructure their ranges within only six months may create unnecessary financial loss and problems concerning the storage or disposal of unsaleable explosives.
However, I would not favour a transition extending for several years simply because existing stock remains in the supply chain. The purpose of these reforms is to address recognised concerns about noise, public safety, antisocial behaviour and the effects of fireworks on people and animals. Excessively long transitional arrangements would postpone those benefits.
Twelve months therefore appears to strike an appropriate balance. It gives legitimate businesses meaningful time to adapt while ensuring that agreed improvements to public safety and welfare are implemented without unreasonable delay.
10. What other things should be considered when setting a lead-in time?
When setting a lead-in time, consideration should be given not only to manufacturers, importers and retailers but also to enforcement bodies, the police, consumers and the wider public.
Trading Standards and other enforcement authorities need sufficient time before the changes take effect to receive clear technical guidance, understand which products may and may not be supplied to the general public, and establish consistent enforcement procedures. This is particularly important if changes involve new decibel limits or additions to Regulation 33.
The police and local authorities should also be given clear information about the changes, particularly where restrictions on supply interact with existing offences involving possession, antisocial behaviour or the misuse of fireworks in public places. Enforcement agencies need to understand the new rules before they come into force rather than having to interpret them after implementation.
Consumers will also need adequate notice. There should be a national information campaign explaining what has changed, which fireworks remain available for domestic use and why certain products have been restricted. Clear communication could also help prevent consumers inadvertently purchasing illegal products online or believing incorrectly that all fireworks have been banned.
The timing within the calendar year should also be considered. Fireworks are heavily associated with particular periods of demand, including Diwali, Halloween, Bonfire Night and New Year. Introducing major changes immediately before a peak purchasing period could create confusion for consumers, enforcement authorities and retailers.
Online sales and illegal imports should be considered as part of the transition. If products previously available legally become restricted, consumers who still want those products may seek them from unregulated online sellers or overseas suppliers. Enforcement of online sales and imports should therefore be ready from the date the new rules take effect, otherwise legitimate UK businesses could be placed at a disadvantage while unsafe or non-compliant products remain obtainable elsewhere.
There should also be absolute clarity about exemptions for professional users and persons with specialist knowledge so that legitimate professional displays are not unnecessarily disrupted.
Finally, the lead-in period should take account of the people and animals the proposed regulations are intended to protect. A very lengthy transition would mean continuing exposure to the noise, disturbance and antisocial use that the reforms are intended to reduce.
For these reasons, I believe a 12-month lead-in period, accompanied by clear guidance, coordinated enforcement preparation and a public information campaign, would provide an appropriate balance between allowing an orderly transition and delivering the intended public benefits without unnecessary delay.
