From the earlier proposal to an enacted law
Law 15/2009 of 11 November regulates contracts for carriage of goods by road and rail. It entered into force on 12 February 2010. A historical description of the bill should therefore not be read as a reform still awaiting adoption.
Article 2 places the contract within the applicable international treaties, EU rules and the law. Identify the journey and contractual arrangement before selecting the legal reference.
Identify the contracting parties and documents
The law distinguishes the party contracting the carriage, the carrier, the recipient and a third party delivering goods on the contracting party’s behalf. Article 10 addresses the consignment note; Article 10 bis contains additional requirements for contracts with the actual carrier.
Record the roles actually performed and the documents used. A role name in a commercial agreement should not be assumed to match every participant definition in dangerous goods legislation.
Road transport: the April 2026 change
Royal Decree-law 9/2026 of 14 April, published on 15 April, amended Article 38 on road transport price revision following fuel-price changes. It requires the adjustment to be shown separately on the invoice and also amends the general contracting conditions in Order FOM/1882/2012.
Check the current wording and applicable conditions when reviewing a contract or invoice. Older procedures may reflect an earlier revision mechanism. This road transport provision should not be transferred automatically to a rail contract.
Contract duties and dangerous goods compliance
Article 24 of Law 15/2009 deals with information about dangerous goods and their hazards. Contract documentation and commercial responsibility must be reviewed alongside the separate transport safety rules.
ADR 2025 and RID 2025 provide the respective dangerous goods frameworks for road and rail. The contractual law does not replace their classification, documentation, equipment or participant requirements. Check each transport leg and the rules applicable to it.
Prepare a focused review file
Gather the contract, consignment notes, amendments, invoices, participant roles, transport modes and dates. Ask the responsible contract specialist to resolve commercial questions and coordinate the dangerous goods assessment with the safety adviser.
Keep the edition and review date visible when revising a company procedure. DGSA advisory services can support the dangerous goods interface; contact DGSA with the actual operation and documents.