DeCA and dangerous goods: ADR document and DeCA together or separate?

If you carry dangerous goods on journeys subject to the DeCA (Documento electrónico de Control Administrativo), you have two separate documentary obligations: the ADR transport document (documento de transporte ADR, or DT-ADR) and the DeCA. You can carry them separately, with the DeCA always electronic, or integrate them into a single document that meets everything required by the technical resolution of 5 June 2026 (Resolución de 5 de junio de 2026). That is how Spain’s Ministry of Transport (Ministerio de Transportes y Movilidad Sostenible) explains it in its FAQ and in the presentation from its webinars (the rest of its clarifications are in what the Ministry clarified about the DeCA in its webinar).

They are two different documents

Question 14 of the FAQ, the one on dangerous goods, separates two obligations: the transport document of chapter 5.4 of the ADR and the control document (documento de control) of Order FOM/2861/2012 (Orden FOM/2861/2012). And it sums them up like this: “They are two different documents, with different regulation and different data” (our translation). In the DeCA’s case, moreover, the eighth transitional provision (disposición transitoria octava) of the Sustainable Mobility Law (Ley de Movilidad Sostenible) requires it to be electronic.

Slide 21 of the presentation compares them:

• Nature: both are administrative, compliance documents.
• Responsible parties: for the DeCA, the contractual shipper (cargador contractual) and the effective carrier (transportista efectivo); for the DT-ADR, the consignor (expedidor).
• Signature: neither of them needs one.
• Legislation: for the DeCA, the LOTT and the ROTT (Spain’s Land Transport Act and its Regulation), Order FOM/2861/2012 and the eighth transitional provision of Law 9/2025 (Ley 9/2025); for the DT-ADR, chapter 5.4 of the ADR and Royal Decree 97/2014 (Real Decreto 97/2014).

It is the same distinction the Ministry draws with the consignment note (carta de porte), which we explain in DeCA and the consignment note (in Spanish).

What data each one asks for

Slide 22 puts the data of both side by side. The DeCA carries the data of article 6 of the Order: parties, origin and destination, goods and weight, special authorisation where applicable, date and number plates (they are listed one by one in mandatory DeCA data, in Spanish). The DT-ADR includes:

• UN number preceded by “UN” and proper shipping name (where applicable, technical name);
• classification code, class number and label model numbers;
• packing group preceded by “GE” (the Spanish for “PG”), where applicable;
• number and description of packages, where applicable, and total quantity of each dangerous good;
• name and address of the consignor and of the consignee or consignees;
• declaration in accordance with the provisions of any special agreement;
• tunnel restriction code.

They overlap very little. The DT-ADR identifies the consignor and the consignee; the DeCA, the contractual shipper and the effective carrier. One company can play more than one role, but each document asks for its own parties.

The two options: separate or integrate

Slide 24 sets it out as two options:

1. Do not integrate. Each document goes its own way; the Ministry’s example is “DeCA in digital form and DT-ADR on paper”. The DeCA then meets the Resolution on its own: native digital PDF, QR code with its direct-download URL and a copy for the driver (they are all in DeCA requirements).
2. Integrate both documents. In the slide’s words, “the resulting document must meet the requirements of both, the DeCA and the DT ADR. It must therefore comply with the Resolution of 5 June”.

If you integrate them, the FAQ answer sets out what the combined document must meet:

• Contain all the data of article 6 of Order FOM/2861/2012, whatever the format.
• Identify the contractual shipper and the effective carrier “expressly and distinctly”, just as section eight (apartado octavo) of the Resolution requires of any third-party format used as a DeCA, ADR included.
• Be an electronic document that complies with the Resolution of 5 June 2026.
• It does not need a signature.

Note slide 20: using another document’s template “does not mean it can be on paper”, and section two (apartado segundo) of the Resolution does not accept scans. A DT-ADR filled in by hand is not a DeCA, even if it has the article 6 boxes. What is valid is for the driver to carry the copy on their phone or printed, with the QR code (section seven).

“One paper for everything” is no longer the idea

Slide 23 explains the change of approach. On paper, the rule was “one paper for everything”, with the data of all the documents. In digital form, “each document contains only the information that each party needs to see (authority, counterparty, etc.), since exporting data is easy”. The diagram shows a single dataset from which the DeCA, the ADR document and the consignment note are produced.

Integrating is valid but not mandatory: with the data of each consignment (envío) in one system, generating two documents does not mean typing it in twice.

The Ministry’s two examples

Slide 25 points to two integration examples.

Example 1: the DT-ADR followed by the DeCA

This is the “integration of the DT-ADR on one page (or several pages) followed by the DeCA”. The first page is a bilingual transport document with the goods carried (UN number, name, labels, packing group, tunnel code, packages), consignor, consignee, carrier and driver declarations. The second is a DeCA with a QR code: the two parties, a table of consignments, a table of vehicles with a vehicle-change column, observations from each party and a box reminding readers that data a) to d) are the contractual shipper’s responsibility and data e) to g) the effective carrier’s.

Example 2: the merged fields

This is the “integration of the information fields”: a single page headed “ADR Transport Document / Electronic Administrative Control Document (DeCA)”, with date and QR code. At the top are the consignor, the contractual shipper (with the origin) and the effective carrier (with number plates and special authorisation). Then comes one block per consignment with consignee, destination, the goods’ ADR data, packages, quantity and date. It closes with observations, totals per type of goods, three declarations (maximum weight, ADR marking and labelling, written safety instructions) and a certificate of receipt.

Grouping consignments in one DeCA, as in this example, requires the contractual shipper and the effective carrier to be the same for all of them (section six of the Resolution). And in both examples the contractual shipper and the effective carrier have their own box, separate from the consignor’s: that is how they are identified “expressly and distinctly”, as section eight requires.

Who answers for the DeCA

The fact that the consignor answers for the DT-ADR does not change who answers for the DeCA. Article 4 of the Order obliges the contractual shipper and the effective carrier to formalise it, and article 7 splits the data: the contractual shipper answers for points a) to d) and the effective carrier for points e) to g), plus whatever observations each of them includes. If you are a shipper, the DeCA for shippers (in Spanish) explains how to organise things with your carriers.

DeCAya generates the DeCA, not the ADR transport document, so it fits the Ministry’s first option: the electronic DeCA on one side and your DT-ADR on the other. Its form has an optional field for the consignor, which the PDF shows in its own box next to those of the contractual shipper and the effective carrier.