IHMM Global DG Transport Compliance Matrix (2025–2026)
IHMM Certificant Compliance Checklist
Week of January 25-February 2, 2026
Executive Overview
The period January 25–February 2, 2026, reflects a steady-state enforcement phase in global DG regulation rather than a burst of new rulemaking. With ADR 2025 fully embedded, IMDG Code Amendment 42-24 mandatory, and ICAO Technical Instructions / IATA DGR 2026 in force, regulators are emphasizing inspection consistency, documentation accuracy, and harmonization with the UN Model Regulations.
Across regions, compliance risk this week is driven by how existing instruments are applied, especially for battery technologies (lithium-ion and sodium-ion), hazardous waste/asbestos, pressure receptacles, and undeclared DG in parcel and e-commerce channels.
II. United States — PHMSA Enforcement Sets the Effective Standard
A. No New Text, Continued Targeted Inspections
No amendments to 49 C.F.R. Parts 171–180 were published during this period. However, PHMSA continued applying its data-driven inspection and enforcement framework, with field activity concentrating on:
Lithium-ion and sodium-ion batteries, including battery-powered equipment/vehicles;
Pressure receptacles (cylinder manufacture, requalification, testing);
Undeclared or misdeclared hazmat, notably in parcel, courier, and e-commerce shipments; and
Repeat violators, identified through historical inspection and incident data.
Legal Significance
Enforcement posture continues to operate as de facto regulation. While the HMR text is unchanged, regulated parties—especially exporters—are increasingly expected to demonstrate functional equivalence with UN Model Regulations and ADR-aligned practices for classification, packaging, documentation, and training. Non-alignment elevates exposure to enforcement actions, contractual disputes, and insurance challenges.
III. Europe — ADR 2025 Fully Normalized; ADR 2027 Preparations Continue
A. ADR 2025 as Settled Law
Across Contracting Parties, ADR 2025 is fully normalized. During this week, authorities continued routine inspections and issued operational clarifications on:
Application of new battery-related UN entries (including sodium-ion batteries);
Revised requirements for hazardous waste and asbestos transport;
Vehicle/equipment standards under ADR Part 9, particularly for alternative propulsion; and
Recognition of ADR driver training certificates under Chapter 8.2.
B. Informal Work Toward ADR 2027
Within UNECE’s DG machinery, preparatory work for ADR 2027 remains active, with focus areas including:
DG carriage by battery-electric and hybrid heavy vehicles;
Reverse-logistics/returns involving DG;
Potential refinement of limited quantity (LQ) provisions; and
Enhanced controls for undeclared DG in small-parcel and e-commerce networks.
Legal Significance
ADR 2025 tolerance periods have ended. Contracts, SOPs, and training should already include change-management mechanisms anticipating further tightening in ADR 2027, particularly for batteries and consumer-distribution channels.
IV. Asia — Mandatory Global Codes Drive Compliance
A. Legislative Quiet, Operational Stringency
No major national DG statutes were promulgated this week in key Asian jurisdictions. Operationally, however:
IMDG 42-24 is enforced without transitional leniency;
ICAO TI / IATA DGR 2026 are uniformly applied; and
Ports and carriers apply UN-aligned battery, waste, and documentation requirements as acceptance criteria.
Legal Significance
In Asia, carrier and port acceptance standards define compliance. UN- and ADR-aligned classification, packaging, labeling, and documentation now represent the minimum standard of care, regardless of domestic legislative lag.
V. Africa — Practice-Led Convergence with UN/ADR Norms
A. No New DG Statutes
No African jurisdiction enacted a DG-specific statute during this period.
B. Enforcement and Trade Practice
Ports and customs authorities continue to:
Require DG documentation consistent with UN classification and numbering;
Apply IMDG 42-24 for maritime shipments; and
Scrutinize battery and hazardous-waste consignments more closely.
Legal Significance
Compliance failures increasingly manifest as shipment delays or refusals rather than formal citations, but commercial and liability impacts remain significant. Practice is converging on UN/ADR standards ahead of legislation.
VI. Central & South America — MERCOSUR Stability; National Enforcement in Focus
A. Regional Baseline Unchanged
No new MERCOSUR-level DG decisions were adopted. The governing instrument remains the MERCOSUR Agreement on the Land Transport of Dangerous Goods (modernized by CMC Decision 15/2019), expressly tied to the UN Model Regulations.
B. National-Level Developments
More consequential are national enforcement and interpretive actions:
Argentina continues intensified inspections of battery-powered equipment/vehicles under its UN-aligned implementation regime;
Brazil applies clarified guidance under ANTT Resolution 5.998/2022 for sodium-ion batteries and updated UN entries; and
Colombia maintains active enforcement of its DG transport registry, with reporting and traceability obligations.
Legal Significance
While MERCOSUR provides technical harmonization, compliance exposure is increasingly national and enforcement-driven. Shippers must verify alignment with each country’s implementing measures and inspection practices.
VII. Overall Assessment
For January 25–February 2, 2026, global DG regulation is characterized by:
Enforcement-led evolution without new statutory text (U.S., South America);
Full consolidation of ADR 2025 (Europe);
Mandatory application of IMDG 42-24 and ICAO/IATA 2026 (Asia and globally); and
Rising reliance on UN/ADR standards as the de facto global benchmark (Africa and emerging markets).
Across regions, battery technologies, hazardous waste/asbestos, pressure receptacles, and undeclared DG remain the principal pressure points.
VIII. Conclusion
As late January turns into early February 2026, DG transportation law is defined less by new rules than by how existing rules are enforced and harmonized internationally. For practitioners and certificants, the prudent course is to treat PHMSA enforcement priorities, ADR 2025, the UN Model Regulations, IMDG 42-24, and ICAO/IATA 2026 as the operative global standard of care—and to review documentation accuracy, packaging approvals, training currency, and contractual controls accordingly.
Leave A Comment