On October 13, the Delegated Directive (EU) 2025/1801 on standardised procedures for the inspection of road transport of dangerous goods was published. It updates Annexes I and II to Directive (EU) 2022/1999, adapting the regulations to the latest technical changes in the ADR system and to the recommendations of the the UN Committee of Experts on the Transport of Dangerous Goods.
The European Commission emphasizes that the aim of the changes is to increase the consistency and transparency of inspections across the Union and improve the safety of dangerous goods transport.
The most significant operational change is the introduction of a new checklist, mandatory for all enforcement authorities in member states. The document specifies criteria for assessing the compliance of vehicles, tanks, and ADR containers, as well as the requirements concerning transport documentation, approval certificates, and safety equipment. Each point of the list refers to a specific ADR regulation, ensuring uniform application of regulations across the entire Union.
Three levels of risk violations
The directive introduces a new classification of risk categories for violations related to the transport of dangerous goods:
- Category I – High Risk: includes cases requiring immediate vehicle stop, such as leaks of hazardous substances, missing documentation, or lack of an ADR driver’s certificate. It also includes incidents posing a risk of death, serious injury, or significant environmental damage.
- Category II – Medium Risk: concerns violations requiring immediate correction, such as malfunctioning fire extinguishers or incorrect markings, and incidents posing a risk of injury or environmental damage.
- Category III – Low Risk: refers to formal discrepancies or minor errors that can be corrected later, without significant impact on safety.
Shared responsibility across the logistics chain
The new regulations strengthen traceability and responsibility of transport participants.
The directive explicitly lists the obligations of shippers, carriers, consignees, loaders, packers, fillers, tank operators, and unloaders.
Each of these entities is obliged to ensure that their activities comply with ADR requirements, which is intended to limit interpretative ambiguities and clearly define responsibility in case of violations.
Mandatory documentation and digital options
According to the new rules, all required ADR documents – including training certificates, vehicle approvals, and written instructions – must be present in the driver’s cabin and made available during inspections.
Electronic documentation is allowed, but only if immediate and reliable access is ensured. Missing or incorrect documents may result in vehicle detention and the imposition of administrative or criminal sanctions.
Challenges for the Transport Industry
The new regulations mean carriers and logistics operators need to update internal procedures, training, and documentation.
Companies must check if the materials they transport fall within the new risk categories and ensure drivers have up-to-date ADR certificates.
Reassessing the obligation to appoint an ADR advisor, in light of new thresholds and exceptions, will also be required.
Link to ADR 2025
Directive 2025/1801 also refers to changes in ADR 2025, including new UN numbers, revised hazard thresholds for certain materials – including lithium batteries, lead compounds, and metal waste – and updated compatibility tables, developed in accordance with UNECE guidelines.
According to the Official Journal of the European Union, the directive will come into force on November 2, 2025, and member states have until June 23, 2026 to implement its provisions. The new procedures will become mandatory from June 24, 2026.
