Key takeaways:
- ADR 2027 applies from 1 January 2027, and the current ADR 2025 rules may still be used until 30 June 2027.
- UN 3536 is split: lithium-metal (UN 3563) and sodium-ion (UN 3564) batteries installed in cargo transport units get their own UN numbers.
- New special provisions cover hybrid batteries, damaged lithium and sodium-ion batteries, and liquid organic hydrogen carriers (LOHC).
- ADR driver training may partly be delivered remotely and via e-learning.
When do the new rules apply?
The amendments to Annexes A and B of ADR enter into force on 1 January 2027. As in previous editions, there is a transitional period: until 30 June 2027, dangerous goods may still be carried in line with ADR 2025. From 1 July 2027, the new requirements become mandatory for everyone.
Some changes come with longer transitional periods, in certain cases running until 2030–2034. Even so, companies should not wait until the last minute. Changes to classification, documents and marking mean that TMS software, warehouse instructions and customer contracts all need updating.
Batteries in cargo transport units: three separate UN numbers
The most significant change for the industry concerns batteries installed in cargo transport units, such as containers housing energy storage systems or bodies with their own power supply. Until now, they were all covered by a single entry, UN 3536. From 2027, it is split into three:
- UN 3536 – lithium-ion batteries installed in a cargo transport unit,
- UN 3563 – lithium-metal batteries installed in a cargo transport unit,
- UN 3564 – sodium-ion batteries installed in a cargo transport unit.
The split means shippers and carriers will need to review how they classify these loads and what they enter in transport documents. Cargo transport units carrying such batteries will also have to display orange plates showing the hazard identification number and the UN number. This directly affects the equipment of vehicles and containers – carriers need to have the correct plates on board.
Hybrid batteries and damaged cells
More and more batteries on the market combine lithium-ion and sodium-ion cells. ADR 2027 clarifies how to classify them in a new special provision 410. Such hybrid batteries are assigned to UN 3480, UN 3481 or UN 3536. When carried under special provision 188 (the relief for small batteries), their rated energy must not exceed 100 Wh and must be marked on the outer casing.
The rules for damaged or defective batteries are also changing. Under the new special provision 680, when lithium and sodium-ion batteries are carried in packagings under packing instructions P911 or LP906, the consignor must give the loader and the carrier a description of the conditions under which the packaging may be used and carried. This description must be attached to the transport document.
In practice, this means more paperwork for consignors, for example when shipping returned electronics or batteries from repair shops and recycling. Carriers, in turn, should check that they have received this description before accepting the load.
Hydrogen: new rules for carriers and pressure vessels
The package also reflects the growth of hydrogen technologies. The new special provision 413 deals with liquid organic hydrogen carriers (LOHC). It sets a threshold for traces of physically dissolved hydrogen in such carriers: 0.5 litres of hydrogen per kilogram of LOHC. This makes it easier to classify these substances, which are increasingly used to store and transport hydrogen.
Another change (special provision 679) concerns composite pressure vessels designed for compressed hydrogen (UN 1049). Such vessels may be carried filled with compressed nitrogen (UN 1066) – for example for servicing and maintenance – within specified pressure limits.
It is worth remembering that electric and hydrogen-powered vehicles have already been allowed to carry dangerous goods in the FL and AT categories since ADR 2025. Companies handling gases should nevertheless review the amended special provisions and tank requirements. A specific trailer or tank configuration may need its own assessment. The topic is becoming more relevant as Germany becomes the hub for Europe’s hydrogen truck rollout.
Tanks, packagings and recycled plastics
ADR 2027 introduces a new section 6.9.3 with requirements for the service equipment of fibre-reinforced plastic tanks. The new rules also make it easier to use recycled plastics in selected packagings. Packaging manufacturers and users should check whether the changes cover the types of drums and jerricans they use.
Table A gets four new UN numbers, one entry is deleted (UN 2941), and around 185 other entries are amended. These include diesel fuel (UN 1202), where paraffinic fuels such as HVO are now covered.
Remote training and new instructions in writing
ADR 2027 explicitly allows remote training and e-learning for drivers (section 8.2.2). Initial training can be classroom-based, remote or a combination of both, but practical exercises must still take place on site. Refresher training may be delivered as e-learning within defined limits.
Chapter 1.3 will explicitly cover not only employees but all persons whose duties involve dangerous goods, including the self-employed.
The wording of the instructions in writing (section 5.4.3) is also changing. The current versions may be used until 31 December 2027. After that, drivers must carry the new version in the cab. Missing documents can be costly: since June 2026, EU ADR roadside checks follow a single checklist, and the most serious infringements can lead to the vehicle being immobilised. Brussels is also pushing for consistent enforcement and has launched proceedings against 14 EU countries over delayed ADR roadside check rules.
Lower limits for some substances
A change to section 1.1.3.6.3 reduces the maximum exempted quantity per transport unit from 50 kg to 20 kg for nine UN numbers in transport category 1. They include ammonia (UN 1005) and chlorine (UN 1017). The transitional period for this change runs until 31 December 2030.
What should companies do before 2027?
- check how the batteries they carry are classified and update UN numbers in TMS systems and documents,
- equip vehicles with the correct orange plates and the new instructions in writing,
- agree with customers who prepares the description of carriage conditions for damaged batteries,
- update job-specific training, checklists and driver training schedules,
- review subcontractors and purchasing specifications for packagings and tanks.
The full list of amendments is set out in UNECE document ECE/TRANS/WP.15/274.
