From draft amendments to the applicable edition
Spain’s official ADR 2025 publication records entry into force on 1 January 2025. The general transition in 1.6.1.1 allowed use of the previous provisions until 30 June 2025, unless otherwise specified. That general transition has ended; individual transitional measures still need separate checking.
Start with the adopted text and the Spanish correction published on 6 May 2025. For English-language material, consult UNECE’s ADR 2025 edition and corrections. A working document or an amendment proposal is useful background, but its document date alone does not establish the rule applicable to a shipment.
Changes to screen against your operation
The Irish Health and Safety Authority’s summary highlights several changes in the common ADR text:
- Sodium-ion batteries and battery-powered vehicles: review the new entries, classification provisions and special provisions.
- Waste paints, certain asbestos waste and small inner packagings of waste: check the conditions of the relevant packing, bulk and documentation provisions.
- Molten aluminium in bulk: review the specific containment, vehicle and training requirements.
- Vehicle approvals and electrical systems: review the revised certificate and electrical provisions where they affect your fleet.
The HSA page also discusses Irish arrangements. Those national arrangements should not be assumed to apply in Spain. For the new entries themselves, use our guide to the eleven new UN numbers.
Include corrections and specific transition dates
The BOE correction changes, among other items, the special provision for UN 0514 to 407 and corrects references in battery packing instruction P903. Check the corrected provision before updating a packing instruction or a transport-document template.
Some transitions run beyond the general 2025 changeover. For example, 1.6.1.55 provides a specific arrangement through 31 December 2026 for substances assigned to UN 1835 or UN 3560, using the earlier classification and carriage conditions for UN 1835. Verify that the substance and proposed conditions actually fall within that provision.
Record the exact clause supporting any transition you use, together with its end date. A deadline applying to one substance or item of equipment cannot be extended to other products by analogy.
Build an operation-specific change record
Prepare a short record for each affected product or process:
- Identify the goods, composition, condition, quantities and transport modes.
- Compare the classification, packaging, marks, labels and documentation with the applicable adopted provisions.
- Check the supporting evidence, including relevant test summaries, packaging information and inspection certificates.
- Assign each update to the person responsible for purchasing, packing, dispatch, carriage or receiving.
- Keep the revised procedure and brief the staff whose work changes.
For Spanish road operations, read this alongside our RD 97/2014 guide. Contact DGSA with your product list, transport modes and operating locations to discuss a review in English.
Discuss your operation in Spain
Tell us which goods, activities and transport stages are involved. We will discuss the scope of the advice or training you need.