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Compliance summary: ADR 2021 changes

Percy Thrower, Manager – Dangerous Goods Information, Member Advice Centre, Logistics UK

The carriage of dangerous goods by road is governed by a specific agreement. This agreement is updated every two years. As the previous updates were carried out in 2019, the latest updates were released at the start of this year (2021).

ADR has seen several updates and amendments this time around with the most notable being the removal of ‘European’ from its title. This reflects the growing number of Contracting Parties outside of Europe. There are now 52 Contracting Parties including Kazakhstan, Morocco, Nigeria, Tajikistan, Tunisia, and Uzbekistan. The following transitional provisions have been removed:

  • – Provision for inner receptacles of composite IBCs manufactured before 1 July 2011;
  • – Provision for pre-2015 style labels; already expired 30 June 2019;
  • – Provisions for driver training certificates issued pre-2014;
  • – Provisions for pre-July 2019 EX/III vehicle certificates of approval.

Four new UN classification entries have been added:

  • UN 0511, 0512 &0513, Electronic detonators programmable for blasting.

There have also been some changes to the classifications of certain products.

Self-inflating devices under UN nos.3537-3548 did not apply to goods containing products in Class 1. An amendment in confirms that UN nos.3537-3548 does apply to articles containing explosives which are excluded from class 1.

Articles that contain polyhalogenated dibenzodioxins and dibenzofurans of Class 6.1, or component of PG III can now be classified and transported as Class 9 as this will allow articles such as condensers and transformers which have been contaminated with Class 6.1 compounds through use to be carried, unpackaged, in metal trays.

Assignment of articles to UN 0431 ARTICLES PYROTECHNIC for technical purposes, can now be made in accordance with the default fireworks classification table provided they meet the following criteria, They are designed for theatrical use, meet the definition of an article and, the 1.4G criteria in table

There are two new special provisions that have been introduced which mandate chemical stability testing for nitrocellulose entries of Class 1 and Class 4, these are SP393 and SP394. SP376 has seen an amendment and note added which support users in deciding whether lithium ion/metal cells or batteries identified as being damaged or defective such that they do not conform to type tested.

Some names and descriptions have been amended, a new proper shipping name option for UN 3363 DANGEROUS GOODS IN ARTICLES has been added in addition to existing name option. UN 1010 BUTADIENES has seen a change to harmonise the name. Some generic names are now allowed in lieu of technical names for UN 3077 and UN 3082, ENVIROMENTALY HAZARADOUS SUNSATNCE SOLID/LIQUID N.O.S. has been added which provides the amended provisions and ‘STABILISED’ has been added to the proper shipping name of UN 2522.

New organic peroxide substances now give specific packing options. The packing method and UN entry for DI-(4-tertBUTYLCYCLOHEXYL) PEROXYDICARBONATE in has been amended to reflect that OP7 is replaced with OP8 in packing instruction P520 and UN 3116 has been replaced by UN 3118. Two new substances have been added to packing instruction IBC520 under UN 3119 ORGANIC PEROXIDE TYPE F, LIQUID, TEMPERATURE CONTROLLED, they are tert-Amyl peroxypivalate and tert-Butyl peroxypivalate.

In other changes, UN 3316 CHEMICAL or FIRST AID KIT has been amended to resolve an issue for kits which only contained dangerous goods to which no packing group is assigned, shall now be allocated to transport category 2 for completion of transport documents and the exemption related to quantities carried per transport unit ( Special provision 327 has been extended to include waste cartridges. UN3291 has seen its packing group removed to align it with the classification chapter. And the Hazard identification number of UN 2683 AMMONIUM SULPAHTE SOLUTION has changed from 86 to 836.

The holding time for UN portable tanks carrying refrigerated liquefied gases are now required to be mentioned on the transport document.

The maximum test period for fire extinguishing agents under UN 3500 CHEMICAL UNDER PRESSURE N.O.S. has been increased from five to 10 years in the new special provision PP97 in packing instruction P206.

The maximum allowed pressure for aerosol dispensers has been increased. This is to align the regulations with the new provisions in the Aerosol Dispensers Directive 75/234/EEC.

Under the new provisions of packing instructions P801(2), used batteries can be transported in stainless steel or plastic bins if they are resistant to the battery electrolyte and are not filled above the stated limit. There are also new provisions for the movement of batteries on pallets.

Packing instructions P400 and P404, which apply for pyrophoric liquids and pyrophoric solids, now allow other types of closures to be used, physically held in place to prevent their back-off of loosening during transport.

Large packing instruction LP101 now authorised for an additional 35 Class 1 entries.

Special provision 653, which applies to UN 1006, 1013, 1046 and 1066, will now require the provisions for filling to be observed.

The lithium battery mark dimensions have been reduced to 100mm x 100mm and the line thickness 50mm x 50mm. The label shape can now be square or rectangle. Existing labels still meet the requirements of the amended provisions.


The amendment to CV36 (special provision for loading, unloading, and handling) requires that gas exchange must be prevented between the loading space and the driver’s cab when closed vehicles are used.

The constant supervision requirement is now limited to high consequence dangerous goods loads in accordance with the security plan of Steps have been taken to harmonise the security provisions and supervision provisions.

The unloader had been added to the list of individuals obliged to ensure an accident report is made in the case of a serious accident or incident.

Mixed loading with Class 1 (aside from 1.4S) with UN2211 and UN3314 is now prohibited due to an incident reported by the Russian Federation, SP675 now reflects this.

When passing through tunnels with restrictions, the following changes to SP 363 (I) confirms the orange plate marking requirements for transport units when carrying internal combustion engines or machinery under UN3528, 3529, 2530.


Amendments to allow portable tanks which have missed the timeframe of their scheduled five- or 2.5-year periodic inspection and test to be filled and offered for transport if a new periodic inspection and test is performed.

On the tank plate on FRP tanks, a new indent stating the second part of the tank code – the calculation pressure – shall indicate the highest value of the calculation pressure for the substance(s) permitted for carriage according to the type approval certificate  (rather than the calculation pressure of the tank).

ADR now confirms that vehicles should not carry dangerous goods after the expiry of the annual technical inspection, even if it remains within the one-month window.

In relation to the updated guidance, operators who carry dangerous goods in accordance with ADR have a six-month window from the start of the new guidance (January 2021) to comply with the latest updates. In this period, they can carry on operating under the 2019 requirements or adopt the 2021 requirements. However, after this grace period the operator must fully comply with the latest requirements. For a full explanation of the changes please refer to ADR 2021.


Published On: 15/04/2021 17:00:38


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