Last updated: 25.03.2025
In the Republic of Poland, business activities related to the production and trade of explosives, weapons, ammunition, and products for military or police use (commonly referred to as „special trade”) are subject to strict regulations.
These regulations are outlined in the Act of June 13, 2019, on the Conduct of Business Activities in the Field of Manufacturing and Trading in Explosives, Weapons, Ammunition, and Products and Technology for Military or Police Use (Journal of Laws of 2023, item 1743).
As a result, individuals or entities planning to engage in such activities, as well as potential buyers, must obtain a relevant license from the Minister of Interior and Administration. This license defines the type and scope of permissible activities and may also impose specific conditions for their execution.
The law distinguishes between two categories of activities requiring a license:
- Manufacturing and trade of explosives, weapons, ammunition, and products for military or police use.
- Trade in technology intended for military or police use.
Which activities involving weapons and similar products do not require a license?
Not all activities related to weapons and similar products require a license. Specifically, a license is not required for the trade of:
- Pyrotechnic products, including:
- Fireworks (Class F1, F2, and F3)
- Theatrical pyrotechnics (Class T1)
- Other pyrotechnic devices (Class P1)
- Dismantled firearms and dismantled military or police-use products.
- Alarm and signal weapons.
Who can obtain a license?
Entrepreneurs registered in the CEIDG (sole proprietorships) and in the KRS (for example, general partnerships or limited liability companies) can apply for a license.
In the case of an entrepreneur registered in the CEIDG, the license is granted if the following requirements are met, i.e. when the applicant:
- Citizenship/Residence:
- Polish citizenship or citizenship of another EU member state, Switzerland, or an EFTA member state, or
- A permit to settle or reside as a long-term resident of the European Communities, or
- The possibility of obtaining reciprocal rights under relevant international agreements.
- Age: At least 21 years old.
- Education: At least secondary education (except for gunsmiths and those involved in the manufacture and trade of replica black powder weapons), or a vocational qualification.
- Professional Training: has documented vocational training to carry out or manage business activities in the field of manufacturing and trading in explosives, weapons, ammunition and products for military or police use, or trading in technology for military or police use, which takes the form of training at an authorized institution*
- *All costs associated with obtaining a license, including training, are borne by the applicant.
- Legal and Mental Capacity:
- Full legal capacity.
- No established mental disorders or significant psychological dysfunctions.
- Criminal Record:has not been convicted of an intentional crime or an intentional fiscal offense, and no proceedings for an intentional crime or an intentional fiscal offense are pending against the applicant.
The aforementioned requirements also apply to selected representatives of companies registered in the National Court Register. In addition, it should be noted that the requirements for natural persons applying for a license must be met by:
- at least two board members, or
- one board member and a proxy or authorized signatory.
The requirement of having no criminal record applies to:
- Shareholders,
- Board members,
- Holders of commercial power of attorney,
- Shareholders who own at least 20% of the shares,
As a result, the following documents must be attached to the license application for these individuals:
- Certificate of no criminal record from the National Criminal Register (for foreigners, an equivalent document issued by an authorized office in their country of origin).
- Certificate of good conduct for a collective entity, required if the shareholder is not a natural person. For foreign shareholders, a relevant document issued by an authorized office in their home country must be provided.
Furthermore, in order to obtain a license, the entrepreneur must not be listed in the register of insolvent debtors of the National Court Register or disclosed in the Central Register of Restructuring and Bankruptcy.
What are the requirements for the storage of special trade goods?
If the business activity includes storage, additional documentation must be obtained. This includes:
- An opinion confirming that the planned storage location meets the necessary technical and organizational requirements.
- Certificates verifying compliance with sanitary, fire protection, and environmental regulations, issued by:
- The state district sanitary inspector,
- The district commander of the State Fire Service, and
- The provincial environmental protection inspector.
A list of institutions authorized to issue these opinions is available in the relevant sources (PDF).
However, businesses that operate solely as intermediaries or traders without the right to store goods are not required to obtain these documents.
What is a promise of awarding a special trading license?
In order to secure a license, it is possible to apply for a promise of awarding it – the so-called promise of awarding a license. However, it should be emphasized that this document does not entitle the applicant to conduct business in the field of special trading.
Instead, it serves as a point of assurance that if an application for a license is submitted during the validity period of the promise, the Minister of Interior and Administration cannot refuse to issue the license – provided that all legal conditions and requirements are met.
The promise is issued for a minimum of six months and specifies the range of conditions the company must fulfill in order to obtain a full license. It is important to note that an application for a promise must meet the same requirements as an application for a license.
At the same time, it is worth emphasizing that such a promise is issued for a minimum of 6 months and specifies the conditions that the company must meet in order to obtain a license. In addition, it is worth bearing in mind that an application for a promise should meet the same requirements as an application for a license.
However, in exceptional circumstances, the minister may still refuse to issue a license, even if it was covered by a promise. One example includes cases where:
- There have been changes to the data in the application for the promise.
- The company does not meet all the conditions specified in the promise.
- It is justified by a threat to national defense, security, or public order.
- The company is undergoing liquidation or bankruptcy proceedings.
What should an application for a license to conduct business activities in the manufacture and trade of explosives, weapons, ammunition, and products and technologies for military or police purposes contain?
To obtain a license for business activities involving the manufacture and trade of explosives, weapons, ammunition, and products and technologies for military or police use, an application must be submitted to the Minister of Interior and Administration, along with the following documents:
- A document specifying the status of the applicant entity.
- A certificate confirming no entry in the register of insolvent debtors of the National Court Register.
- Documents confirming the applicant’s education.
- A document confirming professional training.
- Certificates of no criminal record.
- A medical certificate.
- A psychological certificate.
- An opinion confirming that the applicant can meet the required technical and organizational conditions.
- A certificate from the state district sanitary inspector stating that the building structures and technical equipment intended for business activities comply with sanitary regulations.
- A certificate from the district commander of the State Fire Service confirming compliance with fire protection regulations.
- A certificate from the regional environmental protection inspector verifying compliance with environmental protection regulations.
Documents submitted in a foreign language must be translated into Polish by a sworn translator. Additionally, all submitted copies must be certified as true to the original by a notary or a party’s attorney-in-fact, who must be a legal counsel, attorney, patent attorney, or tax advisor.
What is the duration of the concession?
The concession is granted for the period specified in the application, with a minimum duration of 5 years and a maximum of 50 years. However, it is important to note the following obligations:
- Business operations must begin within 6 months of the concession being granted. Failure to do so will result in the revocation of the concession.
- The ministry must be notified within 14 days of commencing activities; otherwise, the concession may be revoked.
- Any changes to the data contained in the license or submitted documents must be reported to the ministry within 14 days, or the concession may be revoked.
- License holders and individuals authorized to manage the licensed activities must submit updated medical and psychological certificates every 5 years to the Minister of Interior and Administration. Failure to do so will result in the revocation of the license.
The Minister of Interior and Administration may refuse to grant a license if any of the following conditions apply:
- Granting the license would pose a threat to national defense, security, or public order.
- The company is undergoing liquidation or bankruptcy proceedings.
- The company had its license revoked within the last 10 years, unless the revocation was due to failure to commence operations within 6 months of receiving the license.
- The company is represented by a person who was a partner, board member, proxy, or attorney in another company whose actions led to the revocation of a license.
- A partner, shareholder, or stockholder of the company is a person or entity whose license was revoked within the last 10 years, unless the revocation was due to non-commencement of business within the required 6-month period.
What are the fees for the licensing procedure?
- 616 PLN – stamp duty for granting a license.
Note! This fee applies to one scope of activity. If multiple scopes are involved (e.g., trade in arms, ammunition, products, and technology), the 616 PLN fee is multiplied by the number of activity types.
- 98 PLN – stamp duty for the promise to issue a license (promise).
How long does the procedure for issuing a license for special trading take?
The licensing procedure should be completed within 2 months. However, the actual waiting time may vary depending on factors such as the need to obtain positive opinions regarding the application.
Appeal procedure
If you are not satisfied with the decision made by the Minister of Interior and Administration, you have the following options:
- Request reconsideration of the case by the Minister of Interior and Administration within 14 days of receiving the decision.
- Submit a complaint to the Regional Administrative Court in Warsaw within 30 days of receiving the decision to refuse the license or uphold a previous decision.
Obligations when terminating special trading activities
If a business decides to terminate special trading activities, it must:
- Immediately notify the Minister of Interior and Administration and the competent provincial police commander.
- Secure any remaining goods and records in accordance with legal requirements.
Authorization for the trade in dual-use items
What are dual-use items?
According to Article 2(1) of Council Regulation (EC) No. 428/2009 of May 5, 2009, dual-use items are products, including software and technology, that can be used for both civil and military purposes. This includes all goods that can be used for non-explosive purposes as well as those that may assist in the manufacture of nuclear weapons or other nuclear devices.
How to Obtain Authorization for Trading Dual-Use Items?
Authorization to trade in dual-use products is granted upon meeting the requirements set forth in the Act of November 29, 2000, on Foreign Trade in Goods, Technologies, and Services of Strategic Importance for State Security, as well as for the maintenance of international peace and security (Journal of Laws of 2023, item 1582).
Applicants may choose from the following licensing options:
- Individual license – granted for a specific transaction or product.
- Global license – allows multiple transactions within defined parameters.
- General license – used for certain low-risk transactions, requiring only a statement of use.
All applications and declarations must be submitted to the Ministry of Development and Technology, Department of Trade in Sensitive Goods and Technical Security, Export Control Division.
Individual and global authorization for the trade of dual-use products
The following entities are eligible to apply for authorization:
- A natural person,
- A legal person,
- An organizational unit without legal personality, provided it has legal capacity.
The applicant must be a resident of Poland or an entity with a registered office in Poland.
Required Attachments for the Application
The application must be submitted with the following documents:
- A draft contract or contract related to the trade (if required), or a letter of intent or request for quotation.
- An import certificate or end-user statement, if the trade involves export or intra-Community transfer.
- Consent from the competent foreign authority for a specific disposal of the goods, if the importer or end-user is required to obtain such consent. If not applicable, a declaration confirming no knowledge of such an obligation (as per Article 9(2)(10) of the Act) must be provided.
Important! Any document in a foreign language must be accompanied by a certified Polish translation completed by a sworn translator.
How long does it take to obtain a license for trading in dual-use products?
A license for trading in dual-use products is issued within one month of submitting the application, provided that the application is correctly completed and all required attachments are submitted in full.
What Are the Fees for Issuing a License?
Issuing a license is free of charge.
General licenses for trading in dual-use products
Trading under a general EU or national export license requires the submission of a statement declaring the date of commencement of trading. The deadlines for submitting statements for EU general licenses are specified in Annex II to Regulation 2021/821.
If using the national general authorization ZG-PL-DU-1, the declaration must be submitted to the Minister of Development and Technology at least one month before the start of trading.
ATTENTION!
Entities trading under general permits must submit an annual report on trade activities to the Ministry of Development and Technology. This report must be submitted by the end of the first quarter of the following year to comply with trading control regulations.
FAQ – License for explosives, weapons, ammunition and technologies for military or police use
Who can obtain a license for activities related to weapons, ammunition, and military technologies?
A license can be obtained by entrepreneurs registered in the CEIDG or KRS. Requirements include full legal capacity, no criminal record, and meeting professional qualification criteria. The verification process also includes documentation for company management and shareholders.
What are the requirements for storing explosives and military technologies?
The storage of materials such as high explosives or smokeless powder must meet strict technical and organizational standards. Storage facilities must receive sanitary, fire protection, and environmental approvals. These requirements aim to protect both businesses and the general public from potential threats.
How long does the licensing process take, and what are the fees?
The process takes up to 2 months, depending on the need for additional opinions from relevant institutions. The fee for a license is PLN 616 per scope of activity.
Is it possible to obtain a preliminary license approval?
Yes, a promise of awarding a license can be obtained, which guarantees that a license will be issued if all conditions are met. However, this document does not allow actual business operations in such areas until the full license is granted.
Are there specific regulations for transporting explosives and military technology?
Yes, to transport explosives and military technology, individuals and businesses must comply with specialized regulations and licensing requirements, including obtaining necessary permits and adhering to safety protocols. These regulations cover safety fuses, fire extinguishers, and transportation vehicles such as railway cars and aircraft, ensuring safety on the battlefield and in civilian areas.
How does military innovation impact the development of new technologies in this sector?
Military innovation has historically driven the development of new technologies, from the earliest stone tools to modern radar, jet engines, and guide weaponry. The evolution of weaponry, communication systems, and missiles continues to
shape the future of warfare, protecting soldiers and armies while enhancing combat capabilities.
How does military technology influence the licensing of explosives and weapons?
The licensing process has been developed in such a manner that considers advancements in military technology, ensuring that initiating explosives, metal tools, and any chemical compound used for explosive purposes are regulated for a primary or common purpose – national security. Strict controls prevent unauthorized distribution, protecting armed forces and the general public.
The strict licensing of explosives, weapons, and military technologies has been developed in response to lessons from World War, shaping regulations that govern the ability to create, trade, and mobilize troops, guns, and bombs. From the earliest evidence of firearms to modern research projects, these controls ensure national security against any potential enemy on earth.
To navigate this complex regulatory landscape, ensure compliance, or obtain a concession, contact us for expert guidance on legal frameworks and requirements.
