ADR 2025: Key Changes and Retraining Your Team for Lithium/Sodium Ion Bulk Transport

If your fleet moves batteries in any form, ADR 2025: Key Changes and Retraining Your Team for Lithium/Sodium Ion Bulk Transport is not just another update—it reshapes definitions, UN numbers, classification codes, marks/labels, and training obligations. Below, we unpack the ADR 2025 amendments that matter for road carriers and warehouse operators, with practical checklists and a retraining blueprint you can roll out this quarter.

Introduction to ADR 2025 Changes

Overview of ADR 2025

ADR 2025 (in force from 1 January 2025 with transitional use of ADR 2023 permitted until 30 June 2025) introduces new entries for sodium ion batteries, expands lithium-battery rules to sodium chemistry, and adds new vehicle entries (battery-powered) plus updates to special provisions and packing instructions.

Importance of Compliance in Bulk Transport

Even when you don’t literally pour “bulk” product into a hopper, a trailer stacked with battery packages is high-consequence bulk transport in the risk sense. The 2025 dangerous goods regulations align road transport with the latest UN Model changes, ensuring consistent transport safety across modes. ADR compliance protects drivers, yards and emergency responders—and it’s the basis of insurance defensibility and customer trust.

Key Changes in ADR 2025

New UN Numbers for Lithium and Sodium Ion Batteries

ADR 2025 adds sodium-ion entries and battery-powered vehicles while retaining the familiar lithium entries:

Topic	New / existing entries (Class 9 unless noted)	What changed
Sodium ion batteries (organic electrolyte)	UN 3551 (batteries), UN 3552 (contained in/packed with equipment)	First dedicated ADR entries for sodium chemistry.
Battery-powered vehicles	UN 3556 (vehicle, lithium ion), UN 3557 (vehicle, lithium metal), UN 3558 (vehicle, sodium ion)	Separate vehicle entries; UN 3171 remains for vehicles powered by wet/metallic sodium or sodium alloy batteries.
Legacy sodium	UN 3292 retitled (batteries/cells containing metallic sodium or sodium alloy)	Clarifies distinction from new sodium-ion entries.

National authorities also summarize the sodium-ion addition and the expansion of Class 9 code M4 to explicitly cover both lithium and sodium ion batteries (see 2.2.9.1 & 2.2.9.1.7.2).

Updated Classification Codes and Special Provisions

ADR 2025 extends many lithium-battery special provisions to sodium-ion, and clarifies the “test summary” obligation:

2.2.9.1.7 basic requirements for batteries now include 2.2.9.1.7.1 (lithium) and 2.2.9.1.7.2 (sodium ion); manufacturers/distributors must “make available” the UN 38.3 test summary—same accessibility expectation for sodium ion.
Sodium-ion entries (UN 3551/3552) inherit key special provisions already known from lithium, including SP 118, 230, 310, 348, 376, 377, 636 and others (see mapping table below).
New P912 packing instruction applies to vehicles powered by lithium or sodium-ion batteries (UN 3556–3558).

Impact on Bulk Transport of Lithium and Sodium Ion Batteries

Packaging and Labeling Requirements

ADR 2025 broadens the packaging framework and updates labelling/marking practice for batteries:

Packing instructions extended to sodium-ion (UN 3551/3552): P903/LP903 (general), P908/LP904 (damaged/defective), P909 (disposal/recycling), P910/LP905 (prototypes), P911/LP906 (high-risk damage).
Vehicles powered by batteries: P912 (new) specifies robust, non-type-tested strong rigid outers for certain movements of vehicles under UN 3556–3558.
Marking/labels: ADR-aligned industry practice renames the “lithium battery mark” to the broader “battery mark” to cover both lithium ion batteries and sodium ion batteries; check your labeling requirements and labeling symbol requirements to avoid legacy text.

Bulk transport compliance note: For UN 3480/3551 standalone batteries, carriage in bulk, tanks or portable tanks is not permitted—use the assigned packaging requirements only.

State of Charge Restrictions and Documentation

Road (ADR): ADR 2025 itself does not impose a universal numeric state of charge restrictions percentage for road consignments of loose cells/batteries; you follow ADR Part 2/Part 4 rules, SP 188/230/310, etc., and keep the UN 38.3 documentation (test summary) available on request (extended to sodium-ion).
Air (contextual, many supply chains are multimodal): ICAO/IATA maintain a 30% SoC cap for lithium-ion (UN 3480) and—now—sodium-ion (UN 3551) shipped by themselves, with expanded SoC reductions for equipment/vehicles from 1 Jan 2026. Use this as a carrier risk assessment benchmark when your road legs connect to air.

Special provision mappings (quick reference)

UN No.	Name	Key special provisions (examples)	Core packing
UN 3551	Sodium ion batteries (organic electrolyte)	SP 118, 230, 310, 348, 376, 377, 400, 401, 636, 677	P903, P908, P909, P910, P911 / LP903–LP906
UN 3552	Sodium ion batteries in/with equipment	Inherits lithium-like SPs noted above	P903, P910, P911 / LP903–LP906 (no bulk/tanks)
UN 3480/3481	Lithium ion batteries	SP family mirrored in sodium-ion updates; check 2.2.9.1.7	As per P903-series, P908–P911
UN 3556–3558	Vehicles powered by Li-ion / Li-metal / Na-ion	New vehicle IDs + SP 360/363 alignments	P912 (vehicles), plus Article/vehicle provisions

Always verify column (9–11) of Table A and Chapter 4.1 in your official ADR book for your exact configuration.

“AP” codes and bulk: what changed—and what didn’t

ADR uses AP codes in Chapter 7.3 to control carriage in bulk (loose solids). ADR 2025 introduces AP 11 with tighter vehicle-stability requirements and driver training expectations for certain bulk solids—not batteries. If your operation also carries bulk Class 9 solids (e.g., waste streams), ensure your team can read ADR 2025 AP codes and understand when AP rules apply vs. battery packing instructions (P903-series).

Retraining Your Team for Compliance

The chemistry adds complexity; your training programs should add clarity. Build a competency based training plan that pinpoints battery roles (picker, packer, load planner, DG signatory, driver, supervisor) and the exact hazardous goods training each must complete.

Identifying Training Needs (matrix)

Map tasks to rules, not titles:

Role	Core tasks	Must master	Evidence
Warehouse picker/packer	Build outer packs, apply marks/labels	P903, P908–P911, “battery mark” content, packaging material standards	Pass/fail pack audit; photo log
Shipping doc specialist	CMR, shipper’s declaration (when applicable), hazmat documentation standards	UN 38.3 test summary availability, classification change notice, SP 188/230 text	Correct docs on 5 of 5 mock jobs
Driver	Compliant handling procedures, segregation, incident reporting procedures	What to do if package is damaged/leaks, call tree, incident response planning	Ride-along checklist
DG supervisor	Approvals, supplier documentation checks, regulatory compliance audits prep	UN number updates, SP mapping; internal audit readiness	Quarterly audit file

Official wording clarifies that manufacturers and subsequent distributors must “make available” the UN 38.3 test summary for both lithium and sodium ion batteries—train people to verify links/QRs and capture screenshots in shipment files.

Developing a Comprehensive Training Program

Structure content into refresher course modules (90–120 minutes each) that blend SOPs and regulation:

ADR 2025 updates: new UN numbers, special provisions, transport code changes, and labeling requirements (the “battery mark”).
Battery transport regulations deep-dive: classification codes (M4 for batteries), SP 188/230/310/376/377, plus waste & battery recycling guidelines (P909).
Packaging validation procedures: choosing the right packing instruction, inner protection, non-combustible cushioning, and packaging material standards.
Labeling symbol requirements & marks: where/when to apply the battery mark, Class 9A label, and any carrier-specific overlays.
Operations & safety measures: transport risk management, loading plans, fire/isolation kits, incident response planning, and carrier risk assessment steps.
Documentation & compliance: UN 38.3 test summary handling, SDS extracts, competency assessment tests, and training record keeping.

Use a blend of classroom ADR training, toolbox talks, and remote training modules. Support it with online training resources (video refreshers, QR-linked SOPs at packing benches) to keep knowledge “close to the task”.

Implementing and Monitoring Training Effectiveness

Performance training metrics: picking errors per 1,000 packs; label defects; document “first-time right” rate; incident reporting procedures within 60 minutes; quarterly regulatory compliance audits pass rate.
Competency assessment tests: 15-question scenario quizzes (SP 188 or SP 376?) and two practicals (correctly build a P903 pack; correctly label a UN 3552 device).
Refresher cadence: 12 months for signatories/lead hands; 24 months for general handlers—or sooner after a classification change notice or SOP update.
Training record keeping: keep rosters, scores, photos of practicals, and manager sign-offs in a shared compliance drive; align with your internal audit readiness schedule.

Practical Checklists & Tables You Can Use Today

A) Sodium vs. Lithium—what changed for you (road)

Item	Lithium (UN 3480/3481)	Sodium ion (UN 3551/3552)
ADR class/code	Class 9, M4	Class 9, M4 (now explicit)
SP family	118, 230, 310, 348, 376, 377, 636 (others as assigned)	Same family extended (see mapping)
Pack rules	P903, P908–P911 (+ LPs)	Same P903, P908–P911 (+ LPs)
Vehicle entries	UN 3556/3557 for Li	UN 3558 for Na-ion vehicles
Bulk/tanks	Not permitted	Not permitted (use package PI/LP)

B) Damaged/defective, prototypes & recycling (road)

Scenario	Apply	Key rule
Damaged/defective cell/battery	SP 376 + P908/P911	Enhanced containment, thermal separation.
Prototypes/small production	SP 310 + P910/LP905	Test-exempt handling with robust packaging.
Disposal/recycling	SP 377 + P909	Mixed chemistries allowed with conditions; distinct marks for waste streams.

C) Documents you must be ready to show

UN 38.3 test summary (URL/QR accepted—“make available” applies to sodium ion now).
Correct UN number and proper shipping name on the transport document (e.g., “UN 3551, SODIUM ION BATTERIES, Class 9, (9A)”).
If using SP 188 (excepted), ensure your pack/marking fit the small-battery limits—couriers are issuing new 2025 handbooks reflecting sodium ion; don’t rely on 2023 rules.

Putting “Bulk Transport” into Policy

While ADR uses a narrow, technical meaning for carriage in bulk (Chapter 7.3, governed by AP codes), many companies use “bulk” to mean “palletized large quantities.” Your policy should make the distinction:

Technical bulk (AP codes): Not for UN 3480/3551—stick with P903-family packaging; AP 11 changes are still relevant if your fleet also carries loose solids under bulk provisions. Train dispatchers/drivers to check ADR 2025 AP codes in the DG list.
Operational bulk (pallet loads): Treat as high-consequence shipments—tighten transport risk management (temperature, fire monitoring, segregation from Class 1/2.1/3/4.1/5.1 as applicable), and pre-brief roadside incident response planning.

Your 30-Day Retraining Plan (batteries only)

Week 1 — Regulatory baseline

Toolbox talk: ADR 2025 updates, new UN number updates, the “battery mark”, and why “no tanks/bulk” still matters.
Micro-test (10 Qs): choose correct entry (UN 3551 vs 3292; UN 3558 vs 3171).

Week 2 — Packaging mastery

Bench demo: build P903 for four SKUs; when to escalate to P908/P911; how to document packaging validation procedures.

Week 3 — Paper & symbols

Drill: apply labeling requirements and the battery mark on two mock shipments; file documentation with QR link to test summary; create a one-page classification change notice for internal comms.

Week 4 — Incidents & audit

Simulate a pallet crush: trigger incident reporting procedures, quarantine, compliant handling procedures, update training record keeping.
Run a 30-minute regulatory compliance audits dry-run for internal audit readiness (files, photos, scores).

Metrics to track: mark/label defects → 0.5% or less; document “first-time right” → 98%+; practical pass rate on competency assessment tests → 90%+.

Extra context you’ll hear from shippers (multimodal reality)

Even if your leg is road-only, shippers will ask about state of charge and battery transport safety, because many supply chains touch air or sea. Expect questions like:

“Can you keep SoC ≤30% for this leg?” (Air leg upstream/downstream.)
“Will your marks say ‘battery’ as required?” (Updated labeling symbol requirements.)
“Do you have ADR 2025 retraining proof for handlers and drivers?” (Your ADR training and refresher course modules.)

Have a short written answer key ready for sales and supplier documentation checks so your teams reply consistently.

Conclusion

Ensuring Ongoing Compliance and Safety

To stay ahead of battery transport regulations under ADR 2025:

Align your SKUs to the right UN numbers (3551/3552 for sodium ion; 3480/3481 for lithium ion; 3556–3558 for vehicles).
Use correct special provisions and packing instructions—especially for damaged, prototypes, and waste—then verify bulk shipping guidelines don’t apply to these UN numbers.
Update marks/labels to the current battery mark and keep the UN 38.3 test summary available in your shipment files.
Roll out targeted retraining strategies with competency based training, remote training modules, and measurable performance training metrics.
Rehearse incident response planning and maintain spotless documentation for compliance audits.

If you shore up these five areas, you’ll meet ADR 2025 bulk transport expectations, minimize disruptions from transport code changes, and improve safety outcomes on your worst day.

Reference notes (authorities & reputable summaries)

RID/ADR 2025 “What’s new” (OTIF/UNECE) — new UN entries (UN 3551–3552; UN 3556–3558), extension of SPs to sodium ion, P903/P908–P911/P912 updates, “make available” test-summary language extended to Na-ion.
HSA (Ireland) summary — M4 code covers both lithium and sodium ion; 2.2.9.1.7 split for Li/Na; confirms three new vehicle entries.
ADR-tool / NextSDS pages — operational lookups for UN 3551/3552 special provisions and packing instructions (use alongside your official ADR text).
IATA/ICAO guidance (context for SoC) — 30% SoC for UN 3480 and UN 3551 (by themselves), and reduced SoC for equipment/vehicles from 1 Jan 2026; helpful for multimodal planning even when your leg is road.
Label/mark change — trade sources highlight the rename of the “lithium battery mark” to the broader battery mark now used for lithium and sodium ion. Verify exact mark details in your ADR edition and carrier manuals.