EU Delegated Directive 2025/1801: What do transport operators need to know?

Starting November 2025, the EU will implement Delegated Directive (EU) 2025/1801, bringing significant updates to compliance requirements across the logistics sector on uniform procedures for checks on the transport of dangerous goods by road. The directive introduces a unified compliance checklist, a new classification system for risk violations, and extends responsibility throughout the entire logistics chain, from carriers to operators.

For logistics companies, this means updating internal procedures, staff training, and documentation to align with the new standards. Operators should start reviewing their processes now to ensure a smooth transition and maintain regulatory compliance under the updated framework.

It updates Annexes I and II to Directive (EU) 2022/1999, adapting the regulations to the latest technical changes in the ADR system and to the recommendations of the UN Committee of Experts on the Transport of Dangerous Goods.

The most significant operational change is the introduction of a new checklist, mandatory for all enforcement authorities in Member States. The document specifies criteria for assessing the compliance of vehicles, tanks, and ADR containers, as well as the requirements concerning transport documentation, approval certificates, and safety equipment. Each point of the list refers to a specific ADR regulation, ensuring uniform application of regulations across the entire Union.

Member States must adopt and publish the laws, regulations and administrative provisions necessary to comply by 23 June 2026 at the latest. IN this context, the Member States must apply the provisions from 24 June 2026.

What has changed now?

The directive introduces a new classification of risk categories for violations related to the transport of dangerous goods:

Category I – High Risk: includes cases requiring immediate vehicle stop, such as leaks of hazardous substances, missing documentation, or lack of an ADR driver’s certificate. It also includes incidents posing a risk of death, serious injury, or significant environmental damage.

Category II – Medium Risk: concerns violations requiring immediate correction, such as malfunctioning fire extinguishers or incorrect markings, and incidents posing a risk of injury or environmental damage.

Category III – Low Risk: refers to formal discrepancies or minor errors that can be corrected later, without significant impact on safety.

In summary, the risk categories (I, II, III) in Annex II have been updated: Risk category I covers infringements with high risk of death, serious injury or significant environmental damage (leading e.g. to vehicle immobilization). Risk category II covers medium risk, and III covers lower risk.

What does this mean in practice for transport operators?

For operators transporting dangerous goods by road (consignors, carriers, loaders, tank-operators, etc), this means that enforcement controlling auhority will apply an updated checklist and risk-categories based on the current ADR provisions.

In this context, transport operators should review their checklists, their documentation and training to ensure that amendments (markings, documentation, roles of participants in chain) align with the updated classification and checklist.
It improves clarity and enforcement: the checklist will identify which participants in the transport chain might incur liability, and the risk-category for each infringement will be clearly listed, helping authorities to report, act and exercise the penalty.

For Member States, it means they must transpose the updated annexes into national law by the given deadline and begin applying them — so national enforcement, training, internal check forms may need updating.

Check out our other news about changes to the transport of dangerous goods (ADR).