On September 1, 2025, the EU regulation 2024/197 came into effect, which may revolutionize the operations of many transport companies in Europe. The changes, although motivated by environmental regulations, mean huge costs and new obligations for carriers. The greatest concerns are expressed by Italian carriers, gathered in FAI, who appealed for a moratorium.
Hauliers under ADR regime
The new regulations classify selected solid mixtures containing lead (e.g., brass, fasteners, pipes) as environmentally hazardous materials under the code UN 3077. This means full inclusion of these goods under the ADR regime, with all its requirements: classification, labeling, and transport procedures.
The impact of this change is not limited exclusively to the chemical sector. It also affects key industrial sectors such as metallurgy, armature production, or technical components. Particularly affected will be regions heavily industrialized like Lombardy or the Veneto.
FAI warns of paralysis
According to FAI’s analysis, the changes introduced by Delegated Regulation 2024/197 will cause significant difficulties for transport companies. Each company transporting goods containing lead will need to:
- appoint an ADR advisor,
- adapt the fleet to requirements (sealed containers, markings, extinguishers, etc.),
- train drivers and equip them with a competency certificate (C.F.P. – so-called ADR),
- develop safety instructions,
- carry out technical adjustments to vehicles.
These are not cosmetic changes – it is a full operational overhaul that requires time and financial investment.
This could halt all logistics related to the processing of brass and other lead-containing alloys,” warns FAI Secretary General, Carlotta Caponi.
Moratorium as an adjustment opportunity?
Due to the urgency of the situation, FAI approached the Italian Ministry of Infrastructure and Transport with a request to introduce a moratorium. The federation argued that without additional time, companies will not be able to adapt to the new regulations, which could lead to disruptions in production and logistics.
The union also raised the issue of uneven playing fields: not all EU countries intend to enforce the new regulations with equal strictness, which threatens to disrupt competition in the common market.
The introduction of new regulations shows how strongly environmental regulations can affect the functioning of road transport. Although the EU’s intention is to protect the environment, the effects may be felt mainly by small and medium-sized transport companies. ADR requirements for products that have been treated as neutral until now present enormous challenges for the industry.
FAI does not deny the need for transformation but emphasizes the necessity of a pragmatic approach. A temporary moratorium was supposed to allow avoiding sector paralysis and maintaining continuity in industrial supplies. However, it was not introduced.
