IHMM Global DG Transport Compliance Matrix (2025–2026)
IHMM Certificant Compliance Checklist

Week of February 3-February 10, 2026

Executive Overview

The period February 2–10, 2026, continues the post-implementation enforcement phase of the global DG regulatory cycle. With ADR 2025 entrenched, IMDG Code Amendment 42-24 mandatory worldwide, and ICAO Technical Instructions / IATA DGR 2026 fully operational, regulators are emphasizing inspection rigor, documentation accuracy, and international harmonization rather than issuing new treaty text.

Across regions, compliance risk during this period is driven by application and enforcement, particularly 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 Shapes the Operative Standard

A. Continued Targeted Inspections; No New Rule Text

No amendments to 49 C.F.R. Parts 171–180 were published during this week. Nevertheless, PHMSA continued applying its data-driven inspection and enforcement framework, with field activity focusing on:

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

  • Pressure receptacles, including cylinder manufacture, requalification, and testing;

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

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

Legal Significance

PHMSA’s posture reinforces that enforcement functions as de facto regulation. While the HMR text is unchanged, regulated parties—particularly exporters—are expected to demonstrate functional equivalence with UN Model Regulations and ADR-aligned practices in classification, packaging, documentation, and training. Non-alignment heightens exposure to enforcement action, contractual disputes, and insurance coverage issues.

III. Europe — ADR 2025 Fully Settled; ADR 2027 Workstreams Advance

A. ADR 2025 Normalized Across Contracting Parties

Throughout this period, ADR 2025 remained the settled baseline. Authorities continued routine inspections and issued operational clarifications addressing:

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

  • Revised provisions for hazardous waste and asbestos transport;

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

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

B. Forward Planning for ADR 2027

Within UNECE’s DG machinery, preparatory work for ADR 2027 continued, with emerging focus on:

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

  • Regulation of reverse-logistics and returned DG flows;

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

  • Enhanced controls for undeclared DG in parcel and e-commerce distribution.

Legal Significance

ADR 2025 tolerance periods have concluded. Contracts, SOPs, and training programs should already include change-management provisions anticipating further tightening in ADR 2027, particularly in battery-driven and consumer-distribution contexts.

IV. Asia — Mandatory Global Codes Drive Compliance

A. Legislative Quiet, Operational Stringency

No major national DG statutes were promulgated during this period 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.

  • On December 31, 2025, China’s National Technical Committee on Road Transport Standardization announced that, in accordance with the national standard formulation and revision plan, it has organized the development of seven mandatory national standards in the series of Regulations Concerning Road Transportation of Dangerous Goods. These are a crucial component of China’s road transport standard system for dangerous goods and serve as the fundamental technical standards for such transport. IHMM wrote about this effort here.

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 continued 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 the commercial and liability impacts remain substantial. Practice is converging on UN/ADR standards ahead of legislation.

VI. Central & South America — MERCOSUR Stability; National Enforcement Emphasis

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 were national enforcement and interpretive actions:

  • Argentina continued intensified inspections of battery-powered equipment/vehicles under its UN-aligned implementation regime;

  • Brazil applied clarified guidance under ANTT Resolution 5.998/2022 for sodium-ion batteries and updated UN entries; and

  • Colombia maintained 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 February 2–10, 2026, global DG regulation is characterized by:

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

  2. Full 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 regions, battery technologies, hazardous waste/asbestos, pressure receptacles, and undeclared DG remain the principal regulatory pressure points.

VIII. Conclusion

As early February 2026 unfolds, DG transportation law continues to evolve through enforcement intensity, interpretive guidance, and international harmonization, rather than headline rulemaking. 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.