The European Commission has published Delegated Directive (EU) 2025/1801 in the Official Journal of the European Union of 13 October 2025, substantially updating the rules for roadside checks on the carriage of dangerous goods under the ADR framework. Issued on 23 June 2025, the directive adapts Annexes I and II of Directive (EU) 2022/1999 to the latest technical developments, introducing a new inspection checklist and a revised classification of risk categories for infringements. The Commission explained that the aim is to strengthen the consistency and transparency of ADR checks across the Union, enhancing safety throughout the logistics chain. The changes take into account the periodic technical updates of the ADR system and the recommendations of the United Nations Committee of Experts on the Transport of Dangerous Goods.
The key operational change is the introduction of a new inspection checklist for roadside checks, which will become mandatory for all national enforcement bodies. The document, annexed to the Directive, sets out the criteria for verifying the compliance of ADR vehicles, tanks and containers, the presence and validity of approval certificates, the accuracy of transport documentation and the required safety equipment on board. Each item is linked to a specific ADR reference to ensure uniform application across member states.
Another important change is the redefinition of infringement risk categories, which will now be divided into three levels: high risk, medium risk and low risk. Category I covers infringements leading to the immediate immobilisation of the vehicle—such as leaks of dangerous substances, missing documentation or the absence of a driver’s ADR certificate—or events posing a high risk of death, serious injury or significant environmental damage. Category II covers medium-level infringements—such as non-functional fire extinguishers or incorrect markings—that require immediate correction, or events with a risk of injury or environmental harm. Category III includes minor or formal errors that may be remedied later, or events with a low risk of injury or environmental impact.
The new framework also strengthens traceability of responsibilities along the logistics chain: the Directive explicitly refers to the roles of consignors, carriers, consignees, loaders, packers, fillers, tank operators and unloaders. Each party is required to verify compliance with ADR provisions, reducing areas of interpretative ambiguity and clarifying the allocation of liability in cases of non-compliance.
From a documentation standpoint, Directive 2025/1801 requires that all mandatory documents—including training certificates, vehicle approvals and ADR written instructions—must be kept in the driver’s cab and be immediately available for inspection. Digital documentation is permitted only when rapid and verifiable access is guaranteed, as defined by ADR practices. The absence or irregularity of such documents may result in vehicle immobilisation and the imposition of administrative or criminal penalties, as specified in the new annexes.
For transport and logistics companies, the directive entails the adaptation of internal procedures and training programmes. Businesses will need to check whether the materials they handle fall under the new risk classes, update documentation and operating instructions, and ensure that staff hold up-to-date ADR certifications. They will also need to review the obligation to appoint an ADR safety adviser in light of the new thresholds and exemptions.
The Directive also refers to updates in ADR 2025, including new UN numbers and revised hazard thresholds for certain materials such as lithium batteries, lead compounds and metallic waste. The updated tables, published in the annexes to the Directive, reflect alignment with both the ADR framework and UNECE recommendations. According to the Official Journal of the European Union, Directive 2025/1801 will enter into force twenty days after publication, on 2 November 2025. Member States will have until 23 June 2026 to complete national transposition, with the new procedures becoming fully operational from 24 June 2026.
