What is ADR?
The ADR regulation is the international agreement regarding the transport of dangerous goods by road. The acronym “ADR” stands for Agreement for the transport of Dangerous goods by Road. This agreement was signed in Geneva in 1957 and entered into force in 1968. It has currently been signed by 54 countries, including Italy. The main objective of the ADR agreement is to harmonize the various safety regulations regarding the transport of dangerous goods, in order to ensure a high level of safety during transport.
The new lead classification?
The mandatory application, starting from September 1st, of the 21st ATP to the CLP Regulation, which modifies the classification of lead, imposes more stringent requirements regarding labelling, transport and compliance with the Major Hazards Directive (so-called Seveso).
By applying this new classification to mixtures/substances/semi-finished products containing lead, in a threshold above 0.25% for maximum lead (≥1mm) and 0.025% for lead in powder form (<1mm), these substances are classified as hazardous to the environment and fall within the scope of the ADR.
Multilateral Agreement
The ADR establishes specific procedures for authorizing derogations from the “harmonized” provisions, which are included in Multilateral Agreements. These agreements must be signed by at least two of the countries adhering to the ADR Agreement.
Ultimately, a Multilateral Agreement, relating to a very specific derogation, is proposed by one of the countries adhering to the ADR (defined as the initiating country) to the other countries for possible signature.
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The Ministry of Transport has proposed a specific Multilateral Agreement M366, recently signed and endorsed by Slovenia and France, other states adhering to the ADR Agreement, making this exemption applicable.
The Agreement, valid until 31/08/2027, provides for the exemption from the transport under ADR of metallic materials containing lead classifiable only as dangerous for the environment pursuant to UN code 3077, subject to certain conditions.
On September 16, 2025, the news was also published on the official website of the Ministry of Transport.
We remain available to provide further clarification on the operational procedures for correctly applying the Multilateral Agreement.
