The reference text: Royal Decree 989/2015 and its ITC 8
Royal Decree 989/2015 of 30 October approves the Reglamento de artículos pirotécnicos y cartuchería, which transposes Directive 2013/29/EU. Its complementary technical instruction no. 8 (ITC 8) governs pyrotechnic shows performed by experts with F1 to F4, T1, T2, P1, P2 articles and self-manufactured fireworks without CE marking. It also applies to firings of F1/F2/F3/T1/P1 articles that together exceed 10 kg of NEC: they must then be performed by experts.
ITC 8 defines the launch zone (reserved to the empresa de expertos staff), the safety zones watched by the organiser, the safety distance measured from the mortars, and distinguishes the entidad organizadora, which bears responsibility before the administration, from the empresa de expertos that fires. It forbids the mechanisation of F1 to F3 articles by non-experts and their electric ignition.
Three tiers by NEC: notification or authorisation
Point 3 of ITC 8 sets the regime according to net explosive content. Type A shows, NEC above 10 kg and up to 50 kg: simple notification to the Delegación del Gobierno by the organising entity, at least 10 days ahead, with a responsible declaration that the point 3 documents are available. Type B, 50 to 100 kg: same 10-day notification, but the safety plan is handed in with the notification.
Type C, NEC above 100 kg: express authorisation from the Delegación del Gobierno, after reports from the Área Funcional de Industria y Energía and the Intervención de Armas y Explosivos, applied for at least 15 working days before the event, with safety plan, emergency plan and the organiser's liability insurance. Notification or authorisation does not exempt from other permits, notably municipal ones, and the Delegación forwards a copy to the ayuntamiento.
The file: products, staff, insurance and distances
Whatever the tier, the organiser must hold the landowner's consent, the liability insurance of the empresa de expertos, a copy of the authorisation of the taller de preparación y montaje and proof of its storage capacity, the list of articles to be fired with type, number and NEC per article, firing times per section, identification of experts and apprentices with copies of their carnés, social security proofs (TC-2) and a declaration of compliance with Law 31/1995 on risk prevention.
Safety distances must come with a site plan on which they are drawn. Above 100 kg, the firing sequence with graphic diagram and the emergency plan are added, and surveillance of the safety zone must be human. PyroDesk produces the article list with NEC per line and total, the site plan with safety radii, the firing sequence and each expert's sheet, ready to attach to the Annex I notification model.
Qualification: carné de aprendiz and carné de experto
Technical Specification 8.01 reserves firing to holders of a carné de experto or de aprendiz issued by the Área Funcional o Dependencia de Industria y Energía of the Delegación del Gobierno, always tied to an authorised taller de preparación y montaje and to employment by an empresa de expertos. The apprentice must be 18, hold the primary education certificate, have received theoretical training from the company and a medical fitness certificate.
The expert must hold the apprentice carné and prove, through company certification, practice in at least 10 shows under the supervision of an expert shooter, over a continuous period or at most three years in discontinuous periods. The expert carné includes T2 entitlement but not P2. The carné is unique and follows the person when changing company; the organiser must be able to show copies for the whole crew, substitutes included.
After the show, incidents and local restrictions
ITC 8 provides for suspension or interruption of the show when authorisation is lacking or safety conditions are no longer met; any accident or incident must be reported to the Delegación del Gobierno within 24 hours, and faulty articles declared within 5 working days. Post-firing actions (sweeping, neutralising misfires) are detailed in point 10. The organiser keeps a record of the incident and of the articles concerned, which the Delegación may request together with the insurer.
Autonomous communities and municipalities add their own rules: summer bans in areas at risk of forest fire, time limits, public-domain occupation licences, and for the Comunitat Valenciana a specific regime for mascletàs and traditional firings. PyroDesk shows on its Spain formalities page the competent authorities and lets you attach the municipal permit to the file alongside the notification to the Delegación. Where a show takes place on public land, the ayuntamiento's consent is often requested by the Delegación before it processes the file, so both applications should be filed together.
Invoicing: Verifactu, Crea y Crece and what PyroDesk brings
Spain regulates invoicing software through Royal Decree 1007/2023 (the Verifactu system, tamper-proof records), whose compliance calendar was set and then adjusted by regulation, and Law 18/2022 'Crea y Crece' provides for mandatory business-to-business electronic invoicing, whose entry into force depends on its implementing regulation and on company size. A display company must therefore check, at the date of each invoice, which regime applies to it.
PyroDesk draws up quotes, contracts and the client portal in Spanish (or the client's language), computes the total NEC of the firing plan and flags tier A, B or C with the matching deadline (10 days or 15 working days), and issues invoices in a structured format compliant with European standard EN 16931, the basis of the formats expected by Spanish e-invoicing. The file gathers carnés, insurance, plan and sequence: everything the Delegación asks for.