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ADR 2025 amendments and changes

This summary identifies some significant changes made to the Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) for the 2025 edition.

For the most part, minor editorial changes have not been included in this summary, which provides brief descriptions of the changes made, some of which may be relevant to Irish Stake holders.  The provisions of the ADR 2025 have been applicable from 1 January 2025 and will become mandatory by means of national regulations on 1 July 2025. To read the UNECE document related to the full changes made click here.

Some significant changes that have been made include the following:

  • Sodium Ion Batteries
  • Waste Paints
  • Waste Asbestos in Bulk
  • New provisions for ‘Lab smalls’ waste
    • 4.1.1.5.3
    • 5.4.1.1.3.3
  •  Molten Aluminium in bulk
  • 9.1.3.3 Certificate of Approval
  • De-Energising e-circuits

  1. Sodium Ion batteries

In ADR 2.2.9.1, the classification code M4 has been amended to include both lithium batteries and sodium ion batteries. ADR 2.2.9.1.7 now includes provisions for lithium batteries (2.2.9.1.7.1) and sodium ion batteries (2.2.9.1.7.2).

A new note has been added for both lithium batteries and sodium ion batteries to explain the term “make available’, which is to ensure that manufacturers and distributors make the test summary available to the consignor on request.

Where applicable through Chapters 3-5, provisions for lithium batteries have been amended to include sodium ion batteries.

In Chapter 3, new entries include SODIUM ION BATTERIES with organic electrolyte (UN 3551) and SODIUM ION BATTERIES CONTAINED IN EQUIPMENT or SODIUM ION BATTERIES PACKED WITH EQUIPMENT, with organic electrolyte (UN 3552).   Chapter 3.3 includes a number of new and amended special provisions relating to lithium batteries and sodium ion batteries.

Three new entries (UN 3556, 3557 and 3558) have been added, respectively, for vehicles powered by lithium ion, lithium metal and sodium ion batteries.

  1. Waste Paints

For waste paints, special provision 650 has been amended to permit the mixed packing and loading of UN1263 and UN 3082. For mixed loading in the same vehicle or container, the entire contents can be assigned to UN 1263.

  1. Waste Asbestos in bulk

A new special provision 678 has been added for waste consisting of objects and materials contaminated with free asbestos (UN Nos. 2212 and 2590), which permits the carriage of certain types of waste asbestos under the provisions of Chapter 7.3 when specified conditions are met.

For the carriage of any material under the special provision 678, 5.4.1.1.4 provides that the transport document shall include the statement “Carriage under special provision 678”, along with a description of the wastes and specific accompanying documentation.

A new provision AP12 has been added to ADR 7.3.3.2.7 relating to the bulk carriage of asbestos in a ‘container-bag’. The waste may be carried provided that it is contained in a bag the size of the load compartment, which must be designed to resist perforation or tearing and to include a zipper system.  Inner bags must be dust tight for waste asbestos.

In Chapter 7.5, additional provisions for the container bags are provided in new CV38 to include, for example, that the load compartments should be free from sharp edges capable of tearing the container bags during loading and that they shall be inspected before any loading operation.  

Note: These provisions for the carriage of waste asbestos in bulk are for road transport only. For carriage by sea under the provisions described above, it may be appropriate to apply to the Marine Survey Office for an IMDG marine competent authority approval.

  1. New provisions for ‘Lab Smalls’ waste

A new provision 4.1.1.5.3 has been added, which will ultimately replace the provisions of CA Exemption 05/2023, colloquially known in Ireland as the ‘lab smalls exemption’.  It is advised to examine the packagings permitted under the provisions of 4.1.1.5.3 as they are different from those provided for in the current exemption, which is due to expire on 30 June 2027. 

ADR 4.1.1.5.3 provides that, for the carriage of waste, other than articles, inner packages can contain solids or liquids in different shapes in the same outer package provided they conform under normal conditions of carriage to the following (summary only): waste in the inner packagings is not of Class 1, 2, 6.2 or 7; outer package must be one of listed types and must be tested for PG I; outer package does not need to be tested for liquids but must be able capable of retaining liquid; sufficient cushioning material to restrict movement of inner packages; inner packages contain sufficient absorbent material or equally efficient means of retention.

The packaging of the waste under these provisions must be performed by trained or competent personnel, in accordance with 1.3.2.2 with use of instructions of or procedures in compliance with 4.1.1.6 and mixed packing of 4.1.10.4. 

ADR 4.1.1.5.3 (d) provides that the waste contained in one outer packaging may be assigned to the most appropriate entry, and more than one entry may be used if needed.

A new 5.4.1.1.3.3 has been added to provide for a statement to be included in the transport document as follows: “Carriage in accordance with 4.1.1.5.3”. Information in the transport document shall be based on the entry or entries assigned to the outer packaging in accordance with 4.1.1.5.3 (d).

  1. Molten Aluminium in Bulk

A new AP11 has been added to 7.3.3.2.7 for the carriage of molten aluminium in accordance with VC3, to define what is meant by ‘standards set by the competent authority’, under which certain requirements need to be met. For example, the provisions for the means of containment defined as a ‘Vat’, include the requirement for temperature control, that they be positioned so that they cannot be touched by other road users and that they must be secured to the vehicle in accordance with 7.5.7.1. Marking and placarding in accordance with 5.3 is not required provided that the vehicle bears the marks and placards.

AP11 includes provisions for fire and explosion protections, construction of vats, inspection of vats, requirements for operation and requirements for the vehicles used for carriage. In addition to the basic course in accordance with 8.2.1.2, drivers shall receive supplementary training from a competent person about the detailed risk of the carriage of molten aluminium. The training must include the handling behaviour of vehicles, general driving physics, limits of electronic stability control and special measures to be taken in the event of an accident.

  1. Certificate of Approval

An amendment to 9.1.3.3 allows Contracting Parties to introduce additional security features in the certificate of approval and if so, to provide the UNECE secretariat with an example of a national model of any certificate intended for issue. Contracting Parties shall also provide explanatory notes to enable the verification of conformity of certificates against the samples provided.

  1. De-Energising e-circuits

In Chapter 9.2, the term “Battery master switch” has been replaced by the term “De-energizing electrical circuits”.

ADR 9.2.2.8 has been amended to provide for features to enable the de-energising of electrical circuits.

For all voltage levels, such features shall be placed as close to the energy source as reasonably practicable. A control device shall facilitate the de-energising and shall be placed in the driver’s cab. It shall be readily accessible to the driver and be distinctively marked. It should be protected from inadvertent operation. Additional control measures can be installed if they are marked and protected. Features to enable the design must be suitable to so that they can be operated while the vehicle is stationary.  New detailed provisions for the cable connections on the feature have been included in 9.2.2.8.5.