Last week, Peter East attended the Dangerous Goods Training Advisory Panel (TAP) Meeting hosted by the Department for Transport (DfT). During the event challenges and opportunities in dangerous goods training were discussed, and the DfT shared some potential forthcoming amendments to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) 2027. These proposed updates have direct implications for organisations involved in the transport, storage, and handling of dangerous goods across the UK and Europe. There is still one meeting before these proposals will be finally implemented, but usually there are few changes at this late stage.

Here’s a look at three significant developments that are expected to feature in ADR 2027:

1. New Exemption for Retail Delivery

One of the most significant changes is the likely introduction of an exemption to ADR for retail delivery. Admittedly this will have limited impact on UK based shippers, since it will align ADR more closely with the existing UK derogation number four, which currently allows for a more flexible approach to final delivery of dangerous goods directly to retail premises or consumers.

Whilst most operating from the UK won’t notice a difference in deliveries travelling through other European nations, there may be opportunities to simplify processes and reduce costs at local distribution centres in overseas.

Why it matters:
This exemption could significantly reduce the regulatory burden on carriers conducting local delivery routes in all ADR signatory nations, helping streamline logistics while still maintaining safety. However, the scope, limitations, and eligibility criteria of this exemption under ADR 2027 remain to be clarified.

2. Special Provision 680 under Packing Instruction P911

A new special provision—SP680—is set to be introduced, with direct application to Packing Instruction P911 for transporting damaged or defective lithium batteries or cells. The provision may state:

“When the packaging is designed to be used and carried under the conditions specified in paragraph (f) of the packaging performance assessment criteria outlined in table note a of packing instruction P911 (2) in 4.1.4.1 or LP906 (2) in 4.1.4.3, the consignor shall provide the loader and the carrier with the description of the surrounding conditions in which the packaging may be used and carried. This description shall be attached to the transport document.”

Why it matters:
This amendment enhances clarity around the use of packaging under specific safety conditions for damaged batteries. It places a new responsibility on consignors to formally communicate environmental or operational constraints via documentation, thereby increasing the transparency and safety of lithium battery transport.

3. More Flexibility for Empty, Uncleaned Drums and IBCs

ADR 2027 is also expected to address a long-standing challenge in the movement of empty, uncleaned packaging—particularly drums and IBCs—whose inspection certificates have lapsed or whose documentation is missing.

There is a proposed exemption from current requirements under ADR 4.1.1.15, specifically where:

a) The packaging exceeds 150 litres in capacity, and

b) Residues inside are not:

i) classified as dangerous goods of:

- - - Class 1 (Explosives)
    - Class 2 (Gases)
    - Class 4.2 (Substances liable to spontaneous combustion)
    - Class 4.3 (Substances which emit flammable gases when in contact with water)
    - Class 5.2 (Organic peroxides)
    - Class 6.2 (Infectious substances)
    - Class 7 (Radioactive materials)

ii) Substances assigned to packing group I or that have “0” assigned in column (7a) of Table A of Chapter 3.2

iii) Desensitized explosive substances of Class 3 or Class 4.1

iv) Self-reactive substances of Class 4.1

v) Asbestos (UN Nos. 2212 and 2590)

c) Drums and IBCs remain upright and firmly closed using the original closure devices, so they remain leakproof under normal conditions of carriage

d) Labelling and marking corresponds to the residues present

e) Information in the transport document complies with 5.4.1.1.6

Why it matters:
If adopted, this provision would allow certain large empty containers with minor non-hazardous residues to be transported without full compliance if standard testing or paperwork is missing. This would reduce operational delays and costs, especially in scenarios involving container returns or disposals.

ADR 2027 – Direction of Travel

While these changes are not yet finalised, they signal the direction of travel for ADR 2027. There are clearly attempts to make transport of dangerous goods both safer and simpler, with more tailored exemptions that reflect real-world logistics.

Peter East will continue to monitor developments and provide updates as formal texts are released. For organisations handling dangerous goods, these proposed changes offer an opportunity to review compliance processes and prepare early for regulatory transition.

If you have questions or would like to discuss how these changes may impact your operations, feel free to contact our team.