One unit, three possible numbers

Anyone who parks a power station in the yard and later drives it to a customer on a trailer is moving dangerous goods. Until now one line in the packing instruction was enough: lithium-ion batteries, UN 3480, packaged, done. From 1 January 2027 that line is no longer enough, because ADR stops classifying the battery purely by packaging and adds where it is installed.

The amendments are adopted and were formally notified to all ADR contracting parties by the United Nations on 1 July 2026; objections were possible until 1 October 2026. Switzerland has published the explanations of the amended text, and the German transport ministry has issued advance information. Transport planning can therefore work with today's text — while keeping in mind that individual points may still be sharpened in the ongoing procedure.

What changes on 1 January 2027

One number becomes three. The existing UN 3536 is split:

  • UN 3536 — lithium-ion batteries installed in cargo transport units
  • UN 3563 — lithium-metal batteries installed in cargo transport units
  • UN 3564 — sodium-ion batteries installed in cargo transport units

Until now everything ran under a single number. From 2027 the cell chemistry helps decide what appears on the paperwork — relevant for any business that carries sodium-ion equipment alongside lithium-ion, or plans to.

Orange plates for units with installed batteries. Cargo transport units with lithium or sodium-ion batteries installed (UN 3536, 3563, 3564) must carry orange plates showing the hazard identification number and the UN number. This mirrors a rule that already applies by rail — for road transport it is new.

Vehicles as cargo. Vehicles with batteries under UN 3556, 3557 and 3558 must be marked and labelled under Chapter 5.2 when carried packed as cargo. That concerns businesses loading an electrically driven trailer or a battery-powered piece of equipment rather than driving it themselves.

Hybrid batteries get clearer rules. The new special provision 410 clarifies how batteries combining lithium-ion and sodium-ion cells are treated.

What is explicitly not affected

The new three-way split covers batteries installed in a cargo transport unit — fixed into a body, a container, a trailer. The power station that sits in a carton in the boot and is unpacked again at the customer's site remains packaged dangerous goods under UN 3480 and its packing instruction.

In daily work this distinction matters more than the new number itself: it decides whether a business falls within the scope of the orange plates at all. Anyone delivering only boxed goods has nothing to do with 3536/3563/3564. Anyone who fixes a battery permanently into a sales or service trailer very much does.

Two deadlines that look longer than they are

Written instructions: the wording in 5.4.3 is updated. Old instructions may still be carried until 31 December 2027. That is a transition period, not an exemption — anyone inspected in 2028 needs the new ones.

Defective batteries: for defective lithium and sodium-ion batteries packed under P911 or LP906, the consignor must inform the loader and the carrier of the description of the ambient conditions and attach it to the transport document. For rental businesses handling returns this is the most practical point of the whole change: accepting a defective unit is a dangerous goods operation, not a stock movement.

Training: more digital, not without presence

Initial training may be delivered in person, remotely or as a combination. Refresher training may also be e-learning — but the theoretical part not entirely, and practical individual exercises stay in-person. A driver training block planned as classroom time can therefore be stretched, but not fully moved online.

What to check in the business now

1. Which units are installed, which are only packaged? This single question defines the scope.

2. Which cell chemistries do you carry? Lithium-ion, lithium-metal, sodium-ion — the number follows the chemistry.

3. How do returns arrive? P911/LP906 packaging and the ambient conditions description belong in the acceptance procedure.

4. When do the instructions expire? 31 December 2027 is the hard edge.

The amendments enter into force on 1 January 2027; until then ADR 2025 applies unchanged. Checking now means checking against an adopted but not yet applicable text — and keeping an eye on the authorities' advance information.

Sources: Erläuterungen zu den Änderungen des ADR 2027, ASTRA (https://www.astra.admin.ch/dam/de/sd-web/mP6-i-cH6aj6/Erl%C3%A4uterungen%20zu%20den%20%C3%84nderungen%20f%C3%BCr%20ADR%202027.pdf) and ADR 2027 im Überblick, TÜV Akademie, 23 September 2026 (https://die-tuev-akademie.de/blog/adr-2027-mehr-klarheit-fuer-die-gefahrgutpraxis-die-wichtigsten-aenderungen-im-ueberblick).