ADR catalogue of fines 2021: What still applies today and what was reframed in 2025

The ADR catalogue of fines is not a separate set of rules in Germany. The amount of fines for dangerous goods violations on the road result from Section 37 Paragraph 1 GGVSEB in conjunction with the ADR and the Federal Catalog of Administrative Offenses for Road Traffic (BKat). The frequently googled “Catalog of Fines 2021” refers to the status of the GGVSEB after the change in July 2021 and to the ADR 2021. Both sets of rules continue to apply in their basic structure, but have been modified by the ADR updates 2023 and 2025 and the Dangerous Goods Commissioner Ordinance (GbV) amendment 2024.

This article organises the status 2021, explains the current fine limits, shows the chains of responsibility between the sender, packer, shipper, carrier and recipient and provides a practical checklist for the dangerous goods officer. Licence the CIVAC workspace for your internal representatives, or have our representatives order it. Both models help to ensure that the transport documents, labels and proof of training are verifiable in the audit. Anyone who is dealing with the 2021 catalogue of fines today should use the transition to the current situation as an opportunity to switch platforms instead of repeating the same research program every year, and thus build a resilient compliance architecture that can withstand the next ADR update. This saves research time and noticeably reduces the risk of fines.

There is no independent “ADR fine catalogue 2021”. The ADR is an international agreement that does not itself regulate sanctions. In Germany, the fines arise from Section 37 Paragraph 1 GGVSEB, the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways. This standard lists in detail which violations result in which range of fines, from the lack of labelling on the package to the lack of written instructions in the driver's cab. The maximum limit according to Section 10 Paragraph 1 GGBefG is 50,000 euros, in individual cases higher.

The 2021 status reflects the GGVSEB change of July 21, 2021 and the ADR 2021, which came into force on January 1, 2021 with a transition period until June 30, 2021. Carriers and consignors who Fine notices received in 2021 were generally sanctioned based on this version. Anyone who checks a decision from 2021 today should use the law at the time, not the current one. The clock starts on awareness.

The table structure in Section 37 GGVSEB is of practical interest. It lists hundreds of facts, each with a responsible party (shipper, packer, loader, filler, carrier, vehicle driver, recipient) and legal basis reference to the ADR. The fines range from a few hundred euros for formal deficiencies to several thousand euros for serious violations with a safety relevance. Audits by the responsible authorities, such as BALM and the police, are based on this catalogue and report complaints accordingly. The complaint lists the specific facts, the person responsible, the legal basis and the amount determined, so that the decision remains comprehensible at all times and can be examined in a structured manner in the objection process.

Three waves of changes will shape the status after 2021. First, the ADR 2023, in force since January 1, 2023 with a transition period until June 30, 2023. Among other things, it brought new regulations on lithium batteries (UN 3536, UN 3171), expanded requirements for the transport of oxygen cylinders and new classifications for medical waste. Secondly, the ADR 2025, in force since January 1, 2025 with a transition until June 30, 2025. The focus is on digital transport documents, new UN numbers for fuel cell cassettes and adjustments to labelling and accompanying documents.

Thirdly, the GbV amendment 2024, which has modernized the requirements for the appointment, training and the annual report of the dangerous goods officer. According to Section 2 GbV, the obligation to order applies to every company that transports, loads, unloads, packs or ships dangerous goods, with the exceptions mentioned there. The appointment certificate must be made in writing, the obligations according to Section 8 GbV (annual report) and Section 9 GbV (accident report) remain critical in the audit.

The basic structure of the fine framework from Section 37 GGVSEB has not changed, but the individual offenses have been regularly adjusted because the ADR references are shifting. Anyone checking a decision from 2024 or 2025 must use the version valid at the time of the offense. The same applies to the reference to the ADR: The specific marginal number reference (e.g. 5.4.1.1) does not change in number from edition to edition, but in content. Audit-proof, documented, § 37-GGVSEB-proof. Anyone working in an order route should have the valid ADR reference updated automatically instead of checking it manually, and thus take the ADR updates 2023, 2025 and following with them without any research effort.

Section 37 Paragraph 1 GGVSEB assigns each offense to one or more of the seven parties involved. The sender (paragraph 1 no. 1 ff.) is responsible for the correct classification, the labelling of the packages, the selection of packaging and the preparation of the transport documents in accordance with 5.4.1 ADR. If the transport document is missing, the classification information is missing or the UN number is incorrect, the sender will be fined between 500 and 5,000 euros depending on the severity.

The packer (paragraph 1 no. 2 ff.) is responsible for the approved packaging, the labelling of the package and the closures. The shipper (para. 1 no. 3 ff.) checks the transport documents and the condition of the vehicle, the filler (para. 1 no. 4 ff.) checks the tank and large packaging specifications. The carrier (paragraph 1 no. 5 ff.) is responsible for the training of the drivers, the written instructions, the vehicle identification and the equipment. The vehicle driver (paragraph 1 no. 6 ff.) must carry the documents with him, know the instructions and check that the load is secured. The recipient (paragraph 1 no. 7 ff.) may not delay acceptance without justification and checks the unloading.

In the audit, these roles are examined individually. A dangerous goods officer who cannot clearly document what role the company takes on and what duties follow from it risks systemic complaints. The CIVAC platform maps the roles as its own audit template and links them to the appointment certificates, instructions and transport documents. The appointment certificate, signed, filed, verifiable. A client usually acts as a consignor and loader, often also as a transporter using its own fleet or subcontractors, so that several roles have to be maintained in parallel. The platform shows an overview of the open tasks and the due evidence for each role, with clear traffic light logic, deadline information for management and an escalation track in the reporting line.

Some examples from Section 37 GGVSEB illustrate the range. Anyone who ships without a transport document risks 500 to 5,000 euros according to Section 37 Paragraph 1 No. 1 lit. a. If the danger label is missing on the package (paragraph 1 no. 2 lit. b), the limit is 500 to 3,000 euros. Carriers who do not carry written instructions (paragraph 1 no. 5 lit. c) pay 500 to 5,000 euros. If the vehicle is used without orange plates, 1,000 to 5,000 euros are possible.

Serious violations, such as transporting prohibited goods or exceeding the maximum permitted quantities per transport unit, reach the maximum limit of 50,000 euros according to Section 10 Paragraph 1 GGBefG. If committed intentionally, the fine can be doubled, Section 17 Paragraph 4 OWiG. In addition, there is a risk of road traffic measures such as prohibiting further travel, securing the load and points in Flensburg for the driver.

The responsible authorities publish statistics annually. The Federal Office for Logistics and Mobility (BALM, formerly BAG) carries out around 30,000 to 35,000 dangerous goods checks per year, with complaint rates between 18 and 24 percent. The most common defects concern labelling, transport documents and load securing. If a company keeps a clean audit trail of appointment certificates, instructions and transport document templates, the risk of fines is significantly reduced. The auditor calls, the evidence is ready. In the event of repeated or intentional violations, the authority also examines criminal offenses in accordance with Section 328 of the Criminal Code, so that platform-supported documentation is also of considerable importance from a liability law perspective. If there is evidence of gross negligence, insurance coverage can be reduced or refused entirely, which multiplies the financial damage in the event of an incident. The reputation of management also suffers if an incident with documented compliance deficiencies becomes public, which in turn can put a strain on customer relationships and creditworthiness.

The personal liability of the management results from Section 130 OWiG if supervisory measures were omitted that would have prevented or made the violation more difficult. In the event of dangerous goods violations, the authority regularly checks whether the obligation to appoint the dangerous goods representative in accordance with Section 2 GbV has been fulfilled, whether instructions in accordance with Chapter 1.3 ADR are documented and whether the annual report in accordance with Section 8 GbV is available. If one of these points is missing, the sanction extends to the supervisors.

According to Section 5 GbV, the dangerous goods officer himself is obliged to monitor compliance with the regulations, advise the company, document incidents and prepare the annual report. He does not have line responsibility for operational promotion, but his opinion remains relevant in the audit. If management decides against its recommendation, this must be documented so that the line of responsibility remains traceable.

CIVAC provides a standardised reporting line for this. The appointment certificate, the annual reports, the proof of instruction and the incident documentation come together in a workspace, with versioning and EU data residency. An audit by the supervisory authority receives a key date export within hours, not days, upon request. Licence the workspace for your internal representatives, or have our representatives order it. Both models cover the obligations under Section 5 GbV and significantly relieve management of the risk situation under Section 130 OWiG. The substitution rule in the event of vacation and illness is part of the appointment certificate, so that the function is not lost due to personnel events. The external appointment via CIVAC-Officer-as-a-Service also fulfils the obligations according to § 2 GbV because the external representative is equipped with an appointment certificate, proof of training and reporting line and is seamlessly integrated into the management line without affecting the management's duty of responsibility.

Structured audit preparation covers eight points. First: Appointment certificate from the dangerous goods representative, written, dated, signed by the management and accepted by the representative, including clear rules for substitution in the event of vacation and illness. Secondly: proof of training in accordance with Section 4 GbV, including initial training and further training every five years, with an examination certificate from the IHK and details of the mode of transport for which the representative is approved. Third: Proof of training for employees in accordance with Chapter 1.3 ADR, documented with content, date, participants and signature, separated according to the respective fields of activity such as loaders, fillers or vehicle drivers.

Fourth: Annual reports in accordance with Section 8 GbV of the last five years, with statistics on quantities transported, incidents, training and improvement measures, with signature of the management. Fifth: Incident reports in accordance with Section 9 GbV for reportable events, with clear filing and links to investigation files, if available. Sixth: Transport documents and accompanying documents as samples, for example for the last twelve months, with a link to the processing activity and reference to the template check. Seventh: Vehicle equipment in accordance with 8.1.5 ADR, including fire extinguishers with a valid test date, eyewash bottles, warning signs and personal protective equipment for drivers.

Eighth: The risk analysis for security plans in accordance with 1.10.3 ADR if high-risk goods are transported. This checklist covers the most common complaints and should be completed before every official audit. The CIVAC audit templates include 37 ready-to-use structures, several of which are specifically for dangerous goods topics with pre-filled fields for shippers, packers, loaders, fillers, carriers and recipients. Audit-proof, documented, § 37-GGVSEB-proof. The checklist should be updated annually and reviewed before each unannounced audit so that gaps are immediately visible and can be reported through the reporting line to management. The platform automatically reminds you of repeat appointments so that no deadline goes by unnoticed and the representative maintains an overview even as locations and new delivery relationships grow. The handover to a new representative is also possible without any loss.

Anyone who transports dangerous goods multimodally does not just check the ADR. Rail is subject to RID, inland shipping to ADN, sea transport to the IMDG Code and air to ICAO-TI or IATA-DGR. The GGVSEB integrates ADR, RID and ADN into German law. The GGVSee applies to sea freight and the LuftVO and the requirements of the national aviation authorities apply to air freight. The dangerous goods officer must know the modes of transport that the company actually uses.

The fine ranges differ. Similar structures apply to RID as to ADR because both works have been largely harmonised since 2005. With ADN there are additional requirements for skippers and fillers. The water police and the harbor master's office check the IMDG code; the federal police and aviation authorities are responsible for air traffic. A central workspace view allows all modes of transport to be managed in one audit template and sanctions to be prioritised based on risk.

In practical terms, this means: An industrial company that ships dangerous goods for subsidiaries in the EU by truck and train and at the same time ships containers to Asia needs three parallel documentation routes. CIVAC bundles these in a client view, with separate templates for ADR, RID and IMDG, but a common reporting line to the dangerous goods officer. This means that the audit does not notice that different standards apply to sea transport because the platform shows the differences and incorporates them into the deadline export. Preparation for controls at the port or airport also benefits from this because the platform documents the applicable mandatory information for each mode of transport. This means that downtime at transshipment points can be reduced and the supply chain is less disrupted by compliance deficiencies, which has significant economic value in time-critical just-in-time deliveries. The effort for internal special audits after a complaint is also reduced because the documentation can be verified directly from the workspace and the representative does not have to first gather files.

Four complaint patterns regularly appear in BALM reports. First: missing or incorrect transport documents. The UN number is missing, the classification is outdated, the packing group is incorrect or the name of the substance is incomplete. Can be avoided by a transport document template that requires all mandatory fields according to 5.4.1.1 ADR and checks the UN number against a current database.

Secondly: Defects in the vehicle identification. Orange plate is missing, large labels are faded or incorrect, the labelling does not match the load. Can be avoided with a pre-departure checklist that the vehicle driver signs and which the shipper checks. Third: Gaps in the written instructions. They are not in the driver's cab or do not correspond to the load carried. Can be avoided by a carrier standard procedure that links the printing of the instructions to the specific UN number.

Fourth: Defects in the equipment according to 8.1.5 ADR. Fire extinguisher expired, eyewash bottle missing, safety vest incomplete. Can be avoided through a quarterly equipment check with documented results. CIVAC provides an audit template for each of these points, which is maintained in the workspace per vehicle or per shipper location. Anyone who systematically addresses the four patterns will generally reduce the complaint rate from 20 percent to less than 5 percent within two audit cycles. The auditor calls, the evidence is ready. The reduction in the complaint rate also has an impact on insurance law because transport insurers are increasingly taking compliance maturity into account when setting tariffs. Client audits according to ISO 9001 or ISO 14001 also regularly query the dangerous goods documentation and use the clean platform view as an indicator of the maturity of the compliance system, which has a positive impact on supplier evaluations and makes new contractual relationships easier. As a result, the platform not only acts as an audit shield, but also as a sales argument to large clients.

The ADR fines catalogue 2021 is not a final status, but a snapshot. Anyone who transports dangerous goods today must use ADR 2025, the current version of the GGVSEB and the GbV amendment 2024. The fine framework from Section 37 GGVSEB remains stable in structure, but the offenses change with each ADR update because the marginal number references shift. A platform that maintains the references saves the dangerous goods officer reading and research time and ensures verifiability in the audit.

CIVAC is a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. Both models share the same data, the same 490 audit templates, the same reporting line and the same multi-client capability for multimodal transport according to ADR, RID, ADN and IMDG. You can switch between models at any time without breaking the documentation.

Turn reading into a mandate. Send us a short description of your transport structure, the modes of transport and the current audit situation to info@civac.de or use the contact form on civac.de. Within two working days you will receive a proposal with the scope of the licence, an appointment certificate for the external dangerous goods officer and a migration plan that transfers the existing transport documents and proof of training into the workspace. The platform is productive within four to eight weeks, the appointment certificate is available after two working days, and you will arrive at the next BALM inspection with a clearly maintained audit trail. The annual update of the annual report in accordance with Section 8 GbV also takes place in a structured workflow, without repeated research effort. External audits by large clients can also be carried out much more relaxed with this approach because the documentation is available without any preparation time.