IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

Week of January 19, 2026

Executive Overview

The week of January 19, 2026 sits squarely in the post-effective-date enforcement phase of the global DG regulatory cycle. With ADR 2025 fully operative, IMDG Code Amendment 42-24 mandatory worldwide, and ICAO Technical Instructions / IATA DGR 2026 in force, regulators are prioritizing implementation discipline, enforcement consistency, and alignment with UN Model Regulations rather than introducing new treaty text.

Across regions, the dominant risk drivers this week are enforcement posture, carrier acceptance standards, and documentation accuracy, particularly for battery technologies (lithium-ion and sodium-ion), hazardous waste, pressure receptacles, and undeclared DG in parcel/e-commerce channels.

II. North America

  • United States — PHMSA Enforcement Continues to Set the Effective Standard

A. PHMSA Field Operations Emphasize High-Risk Categories

No amendments to 49 C.F.R. Parts 171–180 were published during the week. Nonetheless, PHMSA’s data-driven inspection and enforcement framework—rolled out in late 2025—continues to shape compliance expectations in practice. Field activity during this week reflects sustained attention to:

  • Lithium-ion and sodium-ion batteries, including battery-powered equipment and vehicles;

  • Pressure receptacles (cylinder manufacture, requalification, and testing);

  • Undeclared or misdeclared hazardous materials, particularly in parcel, courier, and e-commerce shipments; and

  • Repeat violators, identified through historical inspection and incident data.

Legal Significance

From a legal perspective, PHMSA’s posture underscores that enforcement policy can function as de facto regulation. Although the Hazardous Materials Regulations remain unchanged textually, regulated parties—especially exporters—are increasingly expected to demonstrate functional equivalence with UN Model Regulations and ADR-aligned practices in classification, packaging, documentation, and training. Failure to do so elevates exposure to enforcement action, contractual disputes, and insurance challenges.

  • Canada – Public Consultation – New Editions of CSA B620, CSA B621, and CSA B622

The Canadian Standards Association (CSA) has released the drafts of the update to safety standards CSA B620, CSA B621, and CSA B622 for a 60-day consultation period, which will close on January 27, 2026. Once the safety standards have been finalized and published, a notice will be issued specifying the coming into force date of the updated standards. All CSA public review drafts are reviewed online and comments from the public to improve the standard can be posted online. The drafts cannot be downloaded but may be accessed from the CSA Group website via the links included belo,w with a summary of some of the proposed changes (note that you must be located in Canada in order to access the links).

CSA B620 (Draft B620) sets out the requirements for the design, manufacture, assembly, modification, inspection, testing and repair of highway and TC portable tanks. The standard also prescribes registration requirements by Transport Canada (TC) of facilities, training organizations, design engineers and design review agencies for conducting the activities within the scope of the standard.

  • Expanded and clarified definitions (Clause 3.2);
  • Updated requirements for lightweight appurtenances, including pad size, weld requirements (Clause 5.1.4);
  • Introduction of clearer requirements for marking inlets/outlets with “liquid” “vapour” (Clause 5.2.2.9);
  • Updated gauge calibration and digital gauge selection requirements (Clause 7.1.4);
  • Clarified requirements for reclosing pressure relief device testing or replacement (Clause 7.2.7.6);
  • Improved requirements for tests and inspections following repairs (Clause 7.5.8); and
  • Established qualification requirements for training instructors, including trainee supervision (Clauses 8.1.7.5 & 8.1.7.6).

CSA B621 (Draft B621) sets out the selection and use requirements for highway and TC portable tanks transporting dangerous goods of Class 3, 4, 5, 6.1, 8, and 9.

  • Recognition of compatibility information from the tank or composite material manufacturer for FRP tanks (Clause 4.3);
  • Clarified requirements for tests and inspections of tanks involved in an accident (Clause 7.1 c));
  • Strengthened requirements for automatic engine air intake shut-off devices, including installation, maintenance, and testing (Clause 7.1 j));
  • Addition of methanol (UN1230) to the dangerous goods selection and use table for easier identification (Table 3); and
  • Introduction of requirements to reinstall parts removed during loading/unloading before transport (Clauses 7.4 d) and 7.7 c)).

CSA B622 (Draft B622) sets out the selection and use requirements for highway and TC portable tanks transporting dangerous goods of Class 2.

  • Removal of outdated references to ton containers (Clause 4);
  • Clarified requirements for tests and inspections of tanks involved in an accident (Clause 5.1 c));
  • Strengthened requirements for automatic engine air intake shut-off devices, including installation, maintenance, and testing (Clause 5.1 i));
  • Introduction of requirements to reinstall parts removed during loading/unloading before transport (Clauses 5.4 f) and 5.7 c));
  • Improved visibility of monthly test of off-truck emergency shutdown systems (Clause 5.5.3 and Annex A); and
  • Clarified requirements for parts in contact with ammonia liquid or vapour (Clause 6.3).

III. Europe — ADR 2025 Fully Settled; ADR 2027 Preparatory Work Advances

A. ADR 2025 Compliance Normalization

By late January 2026, ADR 2025 is a settled baseline across Contracting Parties. During the week of January 19, European authorities continued routine inspections and issued operational clarifications concerning:

  • Correct application of new battery-related UN entries, including sodium-ion batteries;

  • Revised requirements for hazardous waste and asbestos transport;

  • Vehicle and equipment standards under ADR Part 9, particularly for alternative propulsion systems; and

  • Ongoing validity and recognition of ADR driver training certificates under Chapter 8.2.

B. Forward Look to ADR 2027

Within the UNECE Working Party on the Transport of Dangerous Goods (WP.15), informal preparatory work continues for ADR 2027, with emerging focus on:

  • DG carriage by battery-electric and hybrid heavy vehicles;

  • Regulation of reverse logistics and returned DG;

  • Potential refinement of limited quantity (LQ) provisions; and

  • Enhanced treatment of undeclared DG in parcel and e-commerce distribution networks.

C. EU Council

European Council signs off postponing rules on classification, labelling, and packaging of chemicals to 2028. The EU Council has approved postponing key provisions of the 2024 revised classification, labelling, and packaging (CLP) regulation for chemicals until 1 January 2028. This “stop-the-clock” measure, part of the Commission’s Omnibus VI package, aims to give businesses, especially SMEs, more time and legal certainty to comply with requirements on relabelling, mandatory formatting, advertising, online sales, and fuel pump labelling. Denmark’s European Affairs Minister Marie Bjerre emphasized that the delay supports competitiveness while maintaining high safety standards. The law will be published in the EU Official Journal soon and enter into force 20 days later. (November 25, 2025 – Council of the EU)

Legal Significance

For European operators and international shippers, the compliance message is clear: ADR 2025 tolerance periods have ended. Contracts, SOPs, and training programs should incorporate change-management provisions anticipating additional tightening in ADR 2027, particularly for batteries and consumer-distribution channels.

IV. Asia — Mandatory Global Codes Drive Compliance Despite Legislative Quiet

A. Limited National Rulemaking

No major DG transport statutes or regulations were promulgated in key Asian jurisdictions during the week of January 19.

B. Mandatory Application of Global Instruments

Operationally, however, the compliance environment has materially shifted because:

  • IMDG Code Amendment 42-24 is now mandatory worldwide;

  • ICAO Technical Instructions / IATA Dangerous Goods Regulations 2026 are fully operative for air transport; and

  • Ocean carriers and ports are enforcing UN-aligned battery, waste, and documentation requirements without transitional leniency.

Legal Significance

In Asia, carrier and port acceptance criteria effectively define compliance. From a legal-risk standpoint, UN- and ADR-aligned classification, packaging, labeling, and documentation now constitute the minimum standard of care, even where domestic legislation has not yet been updated.

V. Africa — Enforcement-Led Convergence with UN and ADR Norms

A. No New DG Legislation Enacted

No African jurisdiction enacted a significant DG-specific statute during the week of January 19.

B. Practical Alignment Through Trade and Inspection

Nevertheless, African ports, customs authorities, and transport operators continue to tighten controls by:

  • Requiring DG documentation consistent with UN classification and numbering;

  • Applying IMDG 42-24 standards for maritime shipments; and

  • Subjecting battery and hazardous-waste consignments to increased scrutiny.

Legal Significance

For multinational operators, Africa exemplifies a broader trend: practice is converging toward UN/ADR standards ahead of formal legislation. Compliance failures increasingly manifest as shipment delays or refusals rather than formal citations, but the commercial and liability impacts can be significant.

VI. Central & South America — MERCOSUR Stability, National Enforcement Takes Precedence

A. Regional Framework Remains Unchanged

At the regional level, no new MERCOSUR DG decisions were adopted during the week. The governing instrument remains the MERCOSUR Agreement on the Land Transport of Dangerous Goods, as modernized by CMC Decision 15/2019, which is expressly tied to the UN Model Regulations.

B. National Enforcement and Interpretation Intensify

More consequential are national-level developments observed across the region:

  • Argentina continues intensified inspections of battery-powered equipment and 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 dangerous-goods transport registry, imposing reporting and traceability obligations.

Legal Significance

While MERCOSUR provides a harmonized technical baseline, compliance exposure is increasingly national and enforcement-driven. Shippers must ensure alignment with each country’s implementing measures, inspection practices, and reporting systems, not merely the regional agreement.

VII. Overall Legal Assessment

For the week of January 19, 2026, global DG regulation is characterized by:

  1. Enforcement-led evolution without new statutory text (United States, South America);

  2. Full operational consolidation of ADR 2025 (Europe);

  3. Mandatory application of IMDG 42-24 and ICAO/IATA 2026 (Asia and globally); and

  4. Rising reliance on UN/ADR standards as the de facto global benchmark (Africa and emerging markets).

Across all regions, battery technologies, hazardous waste, pressure receptacles, and undeclared DG remain the principal regulatory pressure points.