Two obligations that coexist
In international transport of dangerous goods by road, two frameworks meet:
- The CMR Convention and its Additional Protocol, which govern the consignment note — the contractual document of the carriage — and allow it to be issued electronically as an eCMR.
- The ADR (Agreement concerning the International Carriage of Dangerous Goods by Road), which requires a dangerous goods transport document containing safety information, in addition to other obligations for the consignment.
They operate on different levels: one is the contract (who carries what for whom), the other is safety (what the goods are and how to respond). That is why the eCMR and the ADR document do not replace each other; they complement each other.
What the ADR requires in terms of documentation
Under the ADR, the consignment must be accompanied by a transport document containing the information that identifies the hazard. Typical entries include:
- The UN number, preceded by the letters “UN”.
- The proper shipping name of the goods.
- The hazard labels / label model number(s).
- The packing group, where applicable.
- The number and description of the packages (when carried in packages; a tank has none) and the total quantity of each item of dangerous goods.
- The name and address of the consignor and the consignee.
- The tunnel restriction code, when the journey may pass through tunnels with restrictions.
This document must be accessible throughout the journey, because it is what enforcement officers and, above all, the emergency services consult if there is an incident. The text in force in Spain is ADR 2025 (BOE-A-2025-77), with the amendments adopted by the working party of the United Nations Economic Commission for Europe (UNECE).
eCMR + ADR without duplication
The good news is that much of that data already sits in the consignment note. If the eCMR is generated from a system that knows the goods, their ADR data can travel with the same electronic consignment instead of being typed twice on separate papers. The aim is a single workflow: one electronic record that serves as the consignment note and links to or includes the ADR safety information.
For emergency access, the emerging practice is to link the document to the electronic safety data sheets and provide quick access — for example a QR code that can be checked on the spot, or a copy kept on board — so that anyone arriving at an accident can see at once what the vehicle is carrying. The principle is the ADR’s own: critical information available when it is needed.
Tankers and bulk: the typical case
In tanker and bulk transport — fuels, chemicals, liquid foodstuffs — ADR paperwork is an everyday matter, often with added details on temperature, compartments or prior cleaning. Digitising the consignment note with eCMR and carrying the ADR data in the same workflow cuts paperwork in a sector where every load comes with several documents. It also avoids the classic problem of having the consignment note in one place and the dangerous goods document in another, with the risk that they do not match.
Domestic (Spain) vs international dangerous goods transport
It pays to keep the two scopes apart:
- International: CMR / eCMR consignment note + ADR transport document.
- Domestic, in Spain: the mandatory control document since 5 October 2026 is the DeCA, Spain’s electronic administrative control document. The Spanish Resolution of 5 June 2026 allows the format of the ADR transport document to be reused as the medium for the DeCA if it includes the required data. We cover this in ADR dangerous goods and the DeCA.
A fleet that does both needs a system that recognises the scope of each shipment and generates the right document: eCMR for international journeys, the DeCA (in ADR format) for domestic journeys within Spain.
Official sources
- Additional Protocol to the Convention on the Contract for the International Carriage of Goods by Road (CMR) concerning the Electronic Consignment Note (Geneva, 20 February 2008) — Spain’s Instrument of Accession (BOE-A-2011-10283). boe.es
- Amended text of Annexes A and B of the ADR Agreement (ADR 2025), Spanish publication (BOE-A-2025-77). boe.es
- Resolution of 5 June 2026 of the Spanish Directorate-General for Road and Rail Transport (Dirección General de Transporte por Carretera y Ferrocarril) (BOE-A-2026-12784). boe.es
- Spanish Law 9/2025 of 3 December on Sustainable Mobility (Ley de Movilidad Sostenible) (BOE-A-2025-24545). boe.es