Regulation (EU) 2024/197 and its Impact on ADR Law
Introduction
Regulation (EU) 2024/197, also known as the 21st ATP (Adaptation to Technical Progress) to the CLP Regulation, is an important legal update that modernizes the classification, labeling, and packaging of dangerous substances in the European Union. These changes are of great relevance for the transport of dangerous goods, as the correct classification under the CLP Regulation forms the basis for the provisions of ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road). In this post, Regulation 2024/197 is explained in detail, its content and implementation are described, and the concrete effects on ADR law and practitioners in the transport sector are presented.
Background of Regulation 2024/197
The CLP Regulation (Regulation (EC) No 1272/2008) defines binding rules for the classification, labeling, and packaging of chemical substances and mixtures in Europe. Its objectives are to ensure a high level of protection for people and the environment and to harmonize the communication of dangerous properties across the EU.
To take into account scientific and technical progress, the CLP Regulation is regularly updated through so-called ATPs (Adaptations to Technical Progress). Regulation (EU) 2024/197 is the 21st ATP and was officially published on January 5, 2024. It came into force on January 25, 2024, and is binding from September 1, 2025. A transition period allows companies to prepare for the changes by that time.
Key Points of Regulation 2024/197
Regulation 2024/197 changes Annex VI Part 3 of the CLP Regulation, which contains the list of harmonized classifications and labeling of dangerous substances. This has the following important consequences:
Changes to existing entries: 26 substances, including benzyl alcohol, methyl acrylate, lead powder, and lead metal, received updated classifications based on the latest scientific findings and risk assessments by the European Chemicals Agency (ECHA).
Inclusion of new substances: 41 new chemical substances, including nonylphenol isomers (branched and linear, ethoxylated) and cinnamaldehyde, were newly included in the harmonized classification. These substances exhibit different physicochemical, health, and environmental hazards.
Focus on environmental and health hazards: The regulation includes stronger classifications for environmentally hazardous substances, particularly lead in various forms. This results in a clearer classification of substances with high hazard potential.
Transition period: Companies may continue to market existing stocks according to the old classification until September 1, 2025, but must comply with the new requirements thereafter.
Impact on ADR Law
The ADR system relies heavily on the classification of dangerous goods under the CLP Regulation. The following changes result directly or indirectly from Regulation 2024/197:
New and changed dangerous goods classes: Due to updated classifications, transport containers, loading, and vehicles must consider the new classifications. Special provisions for packaging, labeling, and documentation (e.g., danger labels, UN numbers, transport documents) must be adjusted accordingly.
Increased safety requirements: The upgrading of classifications (e.g., for lead) leads to stricter transport conditions and enhanced protective measures during handling and storage.
Documentation obligations: Safety data sheets and ADR documents such as transport documents must reflect the new classifications to ensure proper handling and emergency measures.
Training and information: Drivers and personnel in the dangerous goods supply chain must be informed and trained about the new classifications and their practical consequences.
Practical Recommendations for Companies and Professional Drivers
Update substance data: Check whether your transported, produced, or stored substances are affected by the regulation. Update the classifications and labeling according to the new CLP list.
Adjust documentation: Ensure that all required transport and safety documents are up to date, especially from the deadline of September 1, 2025.
Train all involved parties: Make sure that professional drivers, loaders, and all persons involved in the transport process are thoroughly informed about the changes and their implications.
Inventory management: Plan the sale of old stocks with outdated classification and ensure that only properly labeled substances are transported from the binding date onward.
Consider environmental aspects: Especially for environmentally hazardous substances like lead, the additional regulations and protective measures are mandatory to ensure legal compliance and safety.
Conclusion
Regulation (EU) 2024/197 marks an important step in adapting European chemical legislation to the current state of science and technology. For ADR law, this means an update of the basis for the classification of dangerous substances and thus an improvement of safety standards in road transport of dangerous goods. The transition period until September 1, 2025, provided sufficient time to make adjustments in production, labeling, documentation, and transport. For all actors in the dangerous goods supply chain—from manufacturer to trader to professional driver—it is important to understand and implement these changes early to ensure safe transport and the protection of people and the environment.
Sources
- Delegated Regulation (EU) 2024/197 of the Commission of 19 October 2023
- REACH-CLP Helpdesk: Publication of the 21st ATP to the CLP Regulation
- Analysis of the 21st ATP at Trace One
- Chemius.net: 21st ATP EU 2024/197 – Chemical Safety Rules
- CLP Regulation ATP – Chemicals Registration Authority Switzerland
(As of: September 2025)
