New ADR Regulations on Inaccessible Battery Declarations

Introduction

The Driver and Vehicle Standards Agency (DVSA) has introduced a new requirement for Perilous Goods (ADR) vehicle applications concerning inaccessible batteries. This update is critically important for transport operators, drivers, and compliance professionals to ensure ADR inspections meet regulatory standards and avoid delays or refusals during testing.

New Inaccessible Battery Declaration from 6 February 2026

From 6 February 2026, ADR vehicle applications (ADRIII and ADRIIIS forms) will include a new Inaccessible Battery Declaration. This applies only when starter or auxiliary batteries cannot be accessed during the ADR inspection. In such cases, the batteries must be inspected prior to the test to confirm compliance with ADR Section 9. 2. 2.

Applicants must use the updated ADRIII or ADRIIIS forms, available on GOV. UK. If any starter or auxiliary battery is inaccessible at the time of the test, the following steps are required:

• Inspect the battery before the ADR test.
• Complete the Inaccessible Battery Declaration section on the submission form, confirming compliance with ADR requirements.
• Ensure the declaration uses the exact wording specified by the DVSA.

The declaration reads:

INACCESSIBLE AUXILIARY/STARTER BATTERIES DECLARATION

“Due to restricted access to the auxiliary/starter batteries at the DVSA ADR inspection, I declare that the auxiliary/starter batteries installed in the vehicle have been inspected and confirm they fully comply with the requirements of ADR Section 9. 2. 2. ”

The declaration must be signed and include the name (in block capitals), company, status, and date.

Requirements for Applications Already in Progress

For applications submitted before 6 February 2026, the updated forms cannot be used. Instead, the following applies:

• A signed declaration on company letterhead must be presented at the ADR test, confirming that the batteries were inspected before the test.
• Declarations completed on the day of the test without prior proof of inspection will not be accepted.

Where to Find the Updated Forms

The updated ADRIII and ADRIIIS application forms are available on the GOV. UK website at:
https://www.gov.uk/government/publications/application-for-adr-road-vehicle-certification-adr-iii

Mi Compliance Advice

Transport operators and compliance professionals should review their current ADR application processes to incorporate the new Inaccessible Battery Declaration where relevant. It is essential to inspect batteries before the ADR test and ensure all declarations are completed accurately and in advance. This will help avoid delays or refusals during inspections.

For further guidance or assistance with ADR compliance, please contact Mi Compliance.

Source: https://content.govdelivery.com/accounts/UKDVSA/bulletins/4066fb6