Paul,
This is why we've been involved in the ELR process for the past few years. The outcome will be a very concise, definitive guidance document, which will be published in 2014 - that will explain what you can, and cannot do. It will be perfectly acceptable to prepare 100g of a composition, assemble a firework / pyrotechnic article with it, and test fire it - at the place of manufacture. You will require at the very minimum a COER acquire cert to cover your acquisition (by making) of BP-type compositions, and also flash compositions (which will no longer be exempt on schedule 1 of COER).
There will be absolutely no confusion once our document has been published, I can assure you of that.
- charlie3 likes this