ADR catalogue of fines 2022 for dangerous goods: How much does a violation really cost today?

The ADR catalogue of fines 2022 is the last binding reference on the desk of the dangerous goods officer in many fleets, logistics departments and industrial companies. The legal basis is the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways (GGVSEB) in conjunction with the Dangerous Goods Officer Ordinance (GbV) and Section 24 GGBefG. The catalogue specifies the amount of fines that supervisory authorities can impose for violations of the ADR agreement. However, the framework has changed since its publication in 2022: the RSEB was updated in 2024, the ADR agreement was revised in 2025 and the federal states have partly issued their own application instructions. At the same time, the density of controls has increased significantly.

Anyone who works with the 2022 catalogue of fines in 2026 should be aware of the changes and check whether the old rates still apply. This guide classifies the catalogue, describes the ten most expensive offenses, clarifies the distribution of responsibility between the shipper, carrier, recipient and vehicle driver and shows how an appointed dangerous goods representative in accordance with Section 1 GbV can demonstrably reduce the risk of fines. The obligations regarding the annual report, training register and emergency plan are also classified. The CIVAC Compliance Platform and Officer-as-a-Service maps the mandatory documentation, the annual report and the training register in an audit trail that can be verified within an hour and is maintained at the current RSEB status.

The ADR catalogue of fines 2022 is an administrative regulation of the federal-state working group on dangerous goods. It combines the fine rates for violations of the GGVSEB, the GbV, the GGBefG and the ADR agreement in a table, thereby creating a largely uniform practice nationwide. It is binding for the supervisory authorities of the federal states, usually the district governments, state road traffic offices or police departments. It provides guidance for citizens and companies, but not a direct legal basis; The fine notice remains binding in individual cases.

The catalogue is applicable to transport operations according to ADR classes 1 to 9, i.e. from explosives to flammable liquids and gases, oxidizing substances, toxic substances, corrosive substances and various dangerous substances such as lithium-ion batteries. Class 7 (radioactive substances) is covered in a separate chapter of the RSEB and has additional radiation protection requirements. The heights stated in the catalogue apply to road transport; For railways, inland shipping and air transport, different rates apply in some cases according to RID, ADN and ICAO-TI.

A central rule of application is the unity of offense according to Section 19 OWiG. If several violations are discovered at the same time during an inspection, such as missing labelling, incorrect transport documents and inadequate equipment, the fines are not simply added together, but are calculated taking the uniform facts into account. In practice, this usually means the highest individual fine as a starting point, supplemented by appropriate surcharges. The final amount depends on the blameworthiness, economic situation and previous burden. Anyone who can prove that they have a functioning dangerous goods officer can achieve significant reductions because a structural failure of compliance can be ruled out. In addition, documented participation in the process can further reduce the level of sanctions if violations were proactively reported.

The most expensive offenses from the 2022 catalogue of fines are all in the area of ​​shipper and transport obligations according to Sections 17 to 19 GGVSEB. First place is regularly taken by the transport of inadmissibly assigned goods, such as the transport of an explosive substance declared as class 9; The standard rate here is 3,000 to 5,000 euros, in rough cases up to 50,000 euros according to Section 10 GGBefG. Second place is transport without proper packaging approval with rates starting from 1,500 euros.

The following places include: missing or insufficient labelling of the means of transport (large notice, orange warning sign) with 800 to 1,500 euros; incorrect or missing transport documents according to ADR 5.4.1 with 500 to 1,000 euros; Transport above the maximum quantities according to 1.1.3.6 (exemption provision) without an ADR certificate with 1,000 to 2,500 euros; Transport without a valid ADR training certificate from the driver according to 8.2.1 with 500 to 1,000 euros; Missing equipment according to 8.1.5 (fire extinguisher, eyewash bottle, high-visibility vest) at 250 to 750 euros.

Two other topics that are subject to fines deserve special mention. Firstly, the missing or incomplete training of the non-driving parties involved according to Chapter 1.3, i.e. shippers, packers, fillers and recipients. This obligation is often overlooked, but is regularly monitored and charged with rates of up to 1,500 euros. Secondly, the violation of the obligation to appoint a dangerous goods representative according to Section 1 GbV. Rates of up to 5,000 euros per month for unlawful transport are common here; in repeated cases there is a risk of an order from the supervisory authority in accordance with Section 9 GGBefG. The BMDV regularly publishes a complete list of updated rates in the traffic bulletin; The current status of the research is the RSEB update 2024, which has adjusted individual rates by 10 to 20 percent.

A special feature of dangerous goods law is the shared responsibility along the transport chain. § 17 GGVSEB specifies the obligations of the carrier, § 18 those of the shipper, § 19 those of the packer, § 20 those of the filler and § 21 those of the recipient. Each party is liable for its circle of obligations, regardless of whether another party may be liable at the same time. A shipper who hands over an incorrectly classified package is liable even if the carrier passes it on without checking it.

In practice, there are two constellations that regularly lead to disputes. Firstly, there is multiple liability for affiliated companies: If the shipper is a subsidiary of the carrier, both violations will be examined, but the fine can go to the parent company if the supervisory obligation according to Section 130 OWiG has been violated. Secondly, the liability of the driver in addition to the carrier: The driver is liable for the obligations under Chapter 8 ADR (vehicle equipment, personal protective equipment, transport documents in the vehicle); The carrier is liable for the organisational obligation to provide the driver with this equipment and to train him accordingly.

In the fine procedure, the authority checks the chain of responsibility based on the documentation. Anyone who takes delivery of a package should document the transfer, including checking the markings, transport documents and equipment. A declaration of handover with the date, time, participants and test result is the most important line of defence against a subsequent suspicion of breach of duty. This documentation belongs in the workspace of the dangerous goods officer, together with the annual appointment certificate and the annual report in accordance with Section 8 GbV. An appointment certificate, signed, filed and verifiable, is also the basis for any subsequent official inspection. Anyone who keeps the documentation structurally not only protects themselves from fines, but also from recourse claims along the supply chain.

The obligation to appoint a dangerous goods officer results from Section 1 Paragraph 1 of the Dangerous Goods Officer Ordinance (GbV). It applies to companies whose activities include the transport of dangerous goods or which undertake the packaging, loading, filling or dispatch associated with this transport. According to Section 2 GbV, exceptions apply for transport in limited quantities, for military and police transport as well as for transport based on exemptions according to 1.1.3 ADR. In practice, most industrial and commercial companies exceed the thresholds more quickly than expected.

The dangerous goods officer must present a training certificate in accordance with Section 4 GbV, which must be extended every five years through an IHK examination. The initial training includes 30 teaching units and the extension training includes 16 units. The contents are the ADR agreement, the GGVSEB, the GbV, the dangerous goods law for classes 1 to 9, the packaging regulations, the transport documents, the emergency planning and the reporting obligations. Specialization is possible for classes 1 (explosives), 2 (gases) and 7 (radioactive substances).

The order is made in writing. A copy goes to the responsible IHK, the original remains in the company. The scope of the order includes the tasks according to Section 8 GbV: monitoring compliance with regulations, advising the company, preparing the annual report, assisting in emergencies and training employees. Anyone who fails to comply with the order risks a fine of up to 5,000 euros per month for unlawful transport and, in the event of a repeat offense, an order in accordance with Section 9 GGBefG. CIVAC offers this role as an officer-as-a-service with a five business day SLA for ordering and full handover to the IHK. Licence the workspace for your internal representatives, or have our representatives order it.

The dangerous goods officer is obliged to prepare an annual report according to Section 8 Paragraph 2 No. 7 GbV. This report documents the company's activities in the area of ​​dangerous goods, the violations identified, the measures implemented and the planned development. It must be kept for at least five years and presented to the supervisory authority upon request. A missing or incomplete annual report is regularly a separate offense and is seen in the supervisory audit as an indicator of a lack of structural quality.

The training register according to Chapter 1.3 ADR includes all non-driving participants who handle dangerous goods: loaders, packers, fillers, recipients, dispatchers, warehouse workers. Each of these people must undergo initial and refresher training, the contents and dates of which are documented. The retention period is three years after the end of the employment relationship. During the audit, the training register is one of the first documents to be examined because it makes the structural compliance depth of the organisation visible.

The emergency plan according to 1.1.3.6.3 and 5.4.3 ADR is an independent document that regulates the response to incidents during transport. It includes written instructions for the vehicle driver (in the language of the driver and in the languages ​​of the countries traveled through), emergency contacts, rules of conduct in the event of an accident, fire detection, spillage and damage. The emergency plan is carried in the vehicle and checked upon request. CIVAC provides these three mandatory documents as preconfigured templates in the workspace and reduces the creation time from a typical six to eight weeks to two business days SLA. The auditor calls, the evidence is ready. This makes it possible to carry out an audit or traffic control without hasty searching through old folders, and management receives a consolidated overview on a monthly basis.

In addition to the individual fine according to Section 24 GGBefG, German law provides for an association fine according to Section 30 OWiG. It applies if a person authorised to represent the company (managing director, board of directors, authorised signatory) has committed a breach of duty or has violated a supervisory duty in accordance with Section 130 OWiG. The amount is up to 10 million euros for intentional violations and up to 5 million euros for negligent violations. In addition, the economic advantage of the act can be skimmed off, which significantly increases the effective sanction.

The duty of supervision according to Section 130 OWiG is particularly relevant in the context of dangerous goods. It requires company management to take appropriate supervisory measures to prevent breaches of duty within the company. This includes appointing qualified officers, providing training, enforcing instructions and responding to identified grievances. Anyone who formally appoints a dangerous goods representative but does not grant him any authority has not fulfilled the supervisory obligation and risks the association's fine despite formally having an authorised representative.

In the process, the authority checks three points: Have the organisational measures been put in place? Have the representatives been given sufficient authority, resources and time? Have known grievances been remedied? The answers emerge from the documentation: appointment certificate, annual report, training register, escalation protocols. Anyone who keeps this documentation in a workspace with an audit trail can provide complete evidence of the duty of supervision. In the role of dangerous goods officer, CIVAC works with a documented reporting line to management and a monthly KPI set that ensures Section 130 proof in the event of a supervisory audit. This structurally reduces the risk of association fines and the defence in the proceedings does not depend on the memory of individual employees, but on orderly documentation.

There have been three significant changes since the 2022 ADR catalogue of fines was published. Firstly, the RSEB update 2024, which has adjusted individual fine rates by 10 to 20 percent, especially in the area of ​​packaging and labelling violations. The adjustment takes inflation and increased control density into account. Certain offenses, such as the transport of lithium-ion batteries without the correct UN number, were given their own sentences because the incidents increased significantly in the years 2022 to 2024.

Secondly, ADR 2025, which has been in force since January 1, 2025. It brings new provisions on transport documents, the classification of certain substances (in particular lithium batteries and energy-carrying components) and new special regulations. Depending on the facts of the case, the transition periods ran until June 30, 2025; The new law has been in full force since July 2025. Anyone who is still working with ADR 2023 risks fines, even if their own catalogue of fines has not yet been updated.

Thirdly, increasing digital control. Since 2024, several federal states have increasingly been using digital recording of transport documents and automatic comparisons with the central register. Violations are detected and documented more quickly. At the same time, the authorities' expectations of the company's digital availability of documents are growing. Anyone who takes three days to find the previous year's annual report during the audit is considered to be structurally deficient. CIVAC reduces this verification period to less than an hour through the central workspace and provides an audit template library with the current RSEB 2024 status. An update to future RSEB versions takes place centrally, without each company having to manually update its own documentation. This means that the status of your own compliance always remains up to date with the current legal status, which is an important relief argument in the event of a fine.

The most effective measures to reduce the risk of fines are not spectacular. You start with three basic building blocks. First, a complete inventory of all dangerous goods the company ships, receives, or stores. This list includes UN number, class, packing group, average quantities per month, shipping routes and people involved. Secondly: a clear role and responsibility model with a designated dangerous goods representative, loading representative and recipient representative. Third: a complete stack of documents with an appointment certificate, training register, annual report, emergency plan and handover protocols.

These three components demonstrably reduce the likelihood that an inspection will result in a high fine. They work in two directions: preventatively, because employees know what to do; and reactive, because the documentation can serve as a relief in the process. Anyone who reports a violation before the authorities discover it benefits from cooperation as a mitigation of punishment and in many cases avoids the full sanction. An internal reporting system with a clear escalation path is an effective lever here.

Operationally, CIVAC supports the role of dangerous goods officer with a workspace that contains 490 audit templates, a preconfigured appointment certificate, the training register and the annual report generator. The reporting line to management is set up by default and the monthly KPI report is generated automatically. This means that the effort required for mandatory compliance can be reduced to around 20 to 30 percent of the hours that a company without a platform spends. The effort saved is freed up for operational work: classification testing, supplier management, emergency drills. Others run compliance like a filing cabinet. We run it like software. In the area of ​​dangerous goods, this difference is immediately noticeable financially, because every fine avoided is directly visible in the result and, in the event of a repeat offense, even secures the right to further transport.

If you want to clarify your own status using this guide, start with three questions. Firstly: Is the appointment obligation according to Section 1 GbV fulfilled and is the training certificate from the dangerous goods officer available? Secondly: Are the annual report, training register and emergency plan available in their current form and auditable? Third: Is the workspace set up so that a traffic stop or supervisory visit can be responded to with the appropriate documents within an hour? Anyone who answers no to one of these three questions has a concrete project in front of them, which CIVAC will set up within two working days.

CIVAC supports the role of dangerous goods officer in two variants. In the first model, you licence the workspace for your internal dangerous goods officer and use 490 audit templates, preconfigured appointment certificates, the automatic training register and the annual report generator. In the second model, CIVAC provides an external dangerous goods officer with an IHK training certificate who takes on the formal role while your employees remain in the workspace as coordinators. Both models use EU data residency and are combined with the ISO 27001:2022 ISMS and the NIS 2 24-hour reporting path in a compliance platform and officer-as-a-service.

Turn reading into a mandate. Send a short email to info@civac.de with industry, shipping volume, classes 1 to 9 or 7, and the question about internal, external or hybrid ordering. Within two working days you will receive a written assessment of the risk of a fine, a proposal for the appointment certificate and a phase plan for the first 30 days. If you want to read more beforehand, you can find typical questions from supervisory audits as well as an overview of the most common fines on the CIVAC FAQ pages. An appointment certificate, signed, filed and verifiable, is often the only difference between a mild and a harsh sanction in the dangerous goods sector.