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eCMR and ADR: the electronic consignment note in international transport of dangerous goods

Anyone moving dangerous goods by tanker or in bulk across Europe handles two sets of paperwork at once: the consignment note and the ADR transport document. Digitising the first with eCMR does not do away with the second. Here is how they coexist and how to handle both in a single workflow.

The key point. The eCMR (electronic consignment note) and the ADR transport document are separate obligations. The eCMR digitises the contract of carriage; the ADR requires certain safety information to be accessible on the road. You can carry both in the same digital workflow, but the eCMR does not remove what the ADR requires.

Two obligations that coexist

In international transport of dangerous goods by road, two frameworks meet:

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:

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:

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.

At Giormo we work with tanker and bulk fleets: the documentation for each load — consignment note, ADR data, photos and signatures — is generated from the transport order, distinguishing between domestic and international scope. If you would like to see it with your own goods, take a look at how our eCMR works.

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

Frequently asked questions

Does the eCMR replace the ADR transport document?
No. They are two separate obligations that coexist. The eCMR is the electronic consignment note (the contractual document of the carriage). The ADR transport document provides the safety information on the dangerous goods required by the ADR Agreement. A single workflow can carry both, but the eCMR does not remove the requirement for the ADR document.
Can the eCMR be used for international transport of dangerous goods?
Yes. The consignment note for international transport of dangerous goods can be issued electronically as an eCMR, with the same validity as on paper. What you need to ensure is that the safety information required by the ADR (UN number, proper shipping name, packing group, quantity, etc.) is present and accessible throughout the journey.
What about domestic transport of dangerous goods in Spain?
For domestic transport in Spain, the mandatory control document since 5 October 2026 is the DeCA. 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, so documents are not duplicated. The eCMR remains the document for international routes.
How do emergency services access the data if everything is digital?
The ADR requires the safety information to be accessible during carriage. In a digital workflow, the usual practice is to link the electronic document to the safety data sheets and provide quick access — for example a QR code or a copy kept on board — so that emergency services can check the critical data in the event of an accident.

Digitise the paperwork for your dangerous goods loads

Tell us what you move — tanker, bulk, which ADR classes — and on which routes, and we will show you how to handle the consignment note and the ADR data in a single workflow, with eCMR for international journeys and the DeCA for domestic work in Spain.

or email us at info@giormo.com