Key takeaway
What This Development Means
FuelsEurope is urging the ADN Safety Committee to reopen discussions on how CMR substances are classified, advocating for the integration of exposure-based risk assessments. Using tools like the Advanced REACH Tool could lead to more proportionate safety measures across the inland waterway transport sector.
Why is FuelsEurope proposing changes to CMR hazard classification under ADN?
FuelsEurope believes that current ADN rules focus too narrowly on intrinsic hazards and ignore real-world exposure risks. The group argues that using validated tools like ART can ensure safety while avoiding unnecessary regulatory burdens.
What is the Advanced REACH Tool and how does it support ADN compliance?
The Advanced REACH Tool is a recognised model for estimating chemical exposure in workplace scenarios. It calculates the Risk Characterisation Ratio (RCR), helping determine whether additional safety measures are necessary based on realistic exposure levels.
Source basis: The assignment of the CMR hazard and consequential operational measures to be taken
FuelsEurope has formally requested the ADN Safety Committee to revisit how carcinogenic, mutagenic and reprotoxic (CMR) substances are classified and managed under the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN).
The proposal, tabled ahead of the Committee’s 47th session in January 2026, argues for greater consideration of exposure-based risk assessments, using established tools such as the Advanced REACH Tool (ART), to inform transport safety measures.
The request follows earlier discussions at the 46th session, where the Committee rejected exposure route as a criterion for classification, suggesting instead that a broader policy-level dialogue was needed across all transport modes.
FuelsEurope, representing major European fuel producers, acknowledges this complexity but maintains that a targeted discussion within ADN remains both feasible and essential.
Calls For Practical Exposure Assessments Using Recognised Tools
FuelsEurope’s proposal centres on the Advanced REACH Tool (ART V.1.5), a widely accepted industry model developed with support from institutions such as TNO and Germany’s Federal Institute for Occupational Safety and Health (BAuA).
The tool calculates the Risk Characterisation Ratio (RCR) for specific industrial tasks, comparing estimated exposure to acceptable limits.
In one example, the process of coupling or decoupling loading arms and hoses—coded as PROC8b in ECHA guidance—is assessed for a substance soon to be classified as H360fd (Toxic for Reproduction, Category 1B).
The RCR value was found to be less than one, indicating an acceptable risk level and suggesting that mandatory vapour recovery systems may not be required for such tasks.
Relevance Beyond Fuel Operators
While originating from the fuel sector, the implications of FuelsEurope's proposal could extend across the chemicals value chain.
Current ADN rules focus on the intrinsic hazard (CMR classification) of substances, without factoring in real-world exposure risks.
This disconnect, FuelsEurope argues, could lead to overly conservative transport requirements that impose unnecessary costs and technical burdens without measurable safety benefits.
If adopted, exposure-based considerations could affect not just manufacturers but also logistics providers, port operators, and regulators who must interpret and enforce ADN requirements.
Alignment With Sustainable Development Goals
FuelsEurope also links its proposal to the UN Sustainable Development Goals (SDGs), citing SDG 3 on good health and well-being, and SDG 11.2 on sustainable transport systems.
By promoting evidence-based risk management, the industry group argues, ADN can better support safe, efficient, and proportionate chemical transport.
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