ADR 2023: key changes

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Regulations regarding the road transport of dangerous goods (DG) are updated every odd-numbered year, with the adoption of a new version of theADR.

All 9 parts of the ADR have been amended, and we invite you to review the key changes that can be applied starting January 1^st , 2023, and will become mandatory on July 1^st , 2023.

New ADR version

Signatory countries

The ADR now applies to 54 countries, including all countries in continental Europe: 2 new signatory countries compared to the 2021 ADR (Armenia and Uganda).

Part 1: "General Provisions"

Exemptions related to quantities transported per transport unit (ADR chapter 1.1.3.6)

Changes have been made to table 1.1.3.6.3.

Notably:

1- Reinstatement of UN code 3291 "CLINICAL WASTE, UNSPECIFIED, N.O.S." into the list of transport category 2 goods.

This is not a substantive change, as UN3291 was previously assigned (prior to the 2021 ADR update) to transport category 2 due to its classification as Packing Group (PG) II dangerous goods.

2- Addition of UN code 3536 "LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNIT" to the list of transport category 2 goods.

Previously, this UN number did not have a defined transport category.

3- Extension of security obligations toall high-consequence Class 1 dangerous goods transported in packages.

Even if transport is carried out under the 1.1.3.6 exemption, the obligations related to establishing a security plan now apply to high-consequence Class 1 dangerous goods transported in packages, rather than specifically to a few listed UN numbers (however, these may continue to be transported without applying the provisions of Chapter 1.10 until December 31, 2024 – ADR 1.6.1.53).

Applicability of other regulations (ADR Chapter 1.1.4)

Creation of new exemptions regarding the transport of refillable pressure receptacles authorized by the US Department of Transportation (ADR 1.1.4.7 & 5.4.1.1.24).

The following are therefore authorized:

Definitions (ADR Chapter 1.2)

1- Modification of the definitions for "Recycled plastics material" & "Working pressure" (ADR 1.2.1).

"Recycled plastics material": it is specifically clarified that the properties of the recycled material used to manufacture new packaging must be guaranteed and documented regularly as part of a quality assurance program recognized by the competent authority.

"Working pressure": clarifications have been added for UN codes 1001 and 3374.

2- Addition of the definition for "Large tank-container" (ADR 1.2.1).

Creation of subsection 1.2.3 "List of abbreviations" (ADR Chapter 1.2.3).

This subsection consolidates the meanings of abbreviations, acronyms, and shortened designations used in the ADR. Previously, these were listed in subsection 1.2.1 "Definitions".

Transitional measures (ADR Chapter 1.6.1.51)

Certain adhesives, paints and paint-related materials, printing inks, and resins in solution assigned to UN 3082 Environmentally hazardous substance, liquid, n.o.s., Packing Group III may be transported until June 30, 2025, in steel, aluminum, other metal, or plastic packaging under certain conditions.

Part 2: "Classification"

LC₅₀ for UN 1008 "BORON TRIFLUORIDE", 1052 "HYDROGEN FLUORIDE, ANHYDROUS", 2196 "TUNGSTEN HEXAFLUORIDE" and 2198 "PHOSPHORUS PENTAFLUORIDE" have been revised upwards.

Reminder: LC₅₀ = lethal concentration

Lithium batteries

Manufacturers and distributors of cells or batteries manufactured after June 30, 2003, must make available the test summary as specified in the Manual of Tests and Criteria. ADR 2023 clarifies that this does not apply to button cells installed in equipment (including circuit boards).

Part 3: "Dangerous goods list, special provisions and exemptions related to limited and excepted quantities"

Table A (ADR Chapter 3)

1- Creation

UN 3550 "COBALT DIHYDROXIDE POWDER"

This is a highly toxic dangerous good (PG I) – Environmentally hazardous.

It is primarily used for laboratory analysis.

This substance was previously classified under UN 3288 "TOXIC SOLID, INORGANIC, N.O.S.".

2- Deletion

UN 1169 "EXTRACTS, AROMATIC, LIQUID"

Dangerous goods classified as UN 1169 must be reclassified under UN 1197 "EXTRACTS, LIQUID, for flavouring".

3- Modification

- UN 1197 "EXTRACTS, LIQUID, for flavouring" (PG II and III)

The official transport designation has changed: the term "for flavouring" has been removed.

- UN 1891 "ETHYL BROMIDE"

Change in primary hazard class (3 instead of 6.1) and associated transport regulations.

- UN 3536 "LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNIT"

Addition (in column 15) of transport category 2. Previously, no transport category was defined for these dangerous goods.

- UN 3509 "PACKAGINGS, DISCARDED, EMPTY, UNCLEANED"

Addition (in column 17) of special provision VC1, authorizing bulk transport in sheeted vehicles, sheeted containers, or sheeted bulk containers.

- UN 1872 "LEAD DIOXIDE"

Removal of the toxicity risk (6.1) and corresponding adaptation of transport regulations.

Note: The following UN codes have also been modified: 1002, 1010, 1012, 1038, 1051, 1060, 1081, 1082, 1085, 1086, 1087, 1092, 1093, 1143, 1167, 1185, 1218, 1245, 1247, 1251, 1301, 1302, 1303, 1304, 1345, 1545, 1589, 1614, 1724, 1829, 1860, 1917, 1919, 1921, 1961, 1966, 1972, 1991, 2015, 2055, 2200, 2218, 2227, 2251, 2277, 2283, 2348, 2352, 2396, 2426, 2452, 2521, 2522, 2527, 2531, 2607, 2618, 2838, 2908 to 2911, 3022, 3073, 3079, 3208, 3209, 3269, 3138, 3302, 3312, 3527, 3531, 3532, 3533, 3534 and 3538.

Special Provisions (SP) (ADR Chapter 3.3)

1- Regarding "REFRIGERATING MACHINES" falling under UN 2857 & UN 3358.

Clarification that for transport purposes, heat pumps may be considered refrigerating machines (SP 119 & SP 291).

2- Regarding "PACKAGINGS, DISCARDED, EMPTY, UNCLEANED" falling under UN 3509 and the use of package refrigerants (e.g., nitrogen, argon, etc.).

SP 663 and 593 have been rewritten for clarity.

3- Creation of 3 new special provisions:

SP 396 for dangerous goods, particularly those classified under UN 3538 "ARTICLES CONTAINING NON-FLAMMABLE, NON-TOXIC GAS, N.O.S.". It is specified that large, robust articles may be transported with gas cylinders connected and valves open under certain conditions.

SP 397 which clarifies the classification of nitrogen and oxygen mixtures for compressed air (UN 1002).

SP 398 which concerns butylene mixtures (UN 1012).

Part 4: "Provisions concerning the use of packagings and tanks"

Packing rules (ADR chapters 4.1 & 4.2)

1- Amendment to packing instruction P621, which applies to UN 3291 "CLINICAL WASTE, UNSPECIFIED, N.O.S.".

It is now possible to use non-removable head packagings.

2- Inclusion of fiber-reinforced plastic (FRP) tanks (ADR 4.2.5.2.1 & 4.2.5.2.6).

3- Addition of a note to several instructions: "The net mass of authorized packagings may exceed 400 kg".

Part 5: "Consignment procedures"

Marking and labeling (ADR chapter 5.2)

New mark for lithium battery packages prepared according to SP 188 (ADR 5.2.1.9).

This change concerns UN 3090 / UN 3480 / UN 3091 / UN 3481.

Consequently, the telephone number is no longer required.

Note: The old label may continue to be used until December 31, 2026 (ADR 1.6.1.49).

Transport document (ADR chapter 5.4)

1- Option for waste to indicate an estimated quantity in the transport document (ADR 5.4.1.1.3.2).

In this context, it is now necessary to indicate, after the transport description: "ESTIMATED QUANTITY ACCORDING TO 5.4.1.1.3.2".

However, estimated quantities are prohibited:

• when using 1.1.3.6;
• if the waste contains, in particular, Class 2 substances or desensitized liquid explosives of Class 3.

2- Rewriting of special provisions for the transport of stabilized substances and temperature-controlled substances (ADR 5.4.1.1.15).

The following information must now appear in the transport document:

• "STABILIZED" when stabilized substances do not include the word "Stabilized" in their official transport name,
• "STABILIZED WITH TEMPERATURE CONTROL" when substances stabilized by temperature control do not include the word "Stabilized" in their official transport name,
• "Control temperature: … °C Emergency temperature: … °C" when substances include the words "with temperature control" in the official transport name.

3- Addition of 5.4.1.1.23 "Special provisions for the transport of substances transported in the molten state".

4- Addition of 5.4.1.1.24 "Special provisions concerning rechargeable pressure receptacles authorized by the US Department of Transportation (Chapter 1.1.4)".

Part 6: "Requirements for the construction and testing of packagings, IBCs, large packagings, tanks and bulk containers"

Main changes to the requirements for the construction and testing of packagings, IBCs, large packagings, tanks and bulk containers

1. Creation of subsection 6.2.1.5.4 regarding initial inspections and tests for tube bundles.
2. Creation of a new Chapter 6.9 regarding the design and construction of portable tanks with shells made of fiber-reinforced plastics (FRP).
3. Renumbering of the former Chapter 6.9, which becomes 6.13, regarding the design and construction of fixed tanks and demountable tanks made of fiber-reinforced plastics.

Part 7: "Provisions concerning the conditions of carriage, loading, unloading and handling"

Transport (ADR Chapter 7.3)

For bulk transport, the definition of "major defects" to be checked prior to filling a bulk container, container, or vehicle has been rewritten (ADR 7.3.1.13)

Loading, unloading, and handling (ADR Chapter 7.5)

Clarification of the requirement to inspect the transport unit prior to loading (ADR 7.5.1.2).

Part 9: "Requirements concerning the construction and approval of vehicles"

Tank vehicles (ADR Chapter 9.7)

New safety requirements for FL vehicles (ADR 9.7.9).

FL vehicles registered on or after 01/01/2027 that transport flammable liquids of PG I and PG II or flammable liquefied or compressed gases (classification code including an F) must be equipped with:

• Automatic fire extinguishers for the engine compartment;
• Thermal protection capable of slowing the spread of fire from the wheels