Dangerous goods 33/1203: Kemler number, UN number and obligations when transporting gasoline

The number sequence 33/1203 on the orange warning sign of a tanker comes from ADR 2025, Chapter 5.3.2. It combines the Kemler number 33 for highly flammable liquids with the UN number 1203 for gasoline. Shippers, carriers and recipients share responsibility for this in accordance with Section 9 GGVSEB.

This article explains what the codes stand for, what labelling and documentation obligations follow from them and when a dangerous goods representative must be appointed according to the GbV. CIVAC works as a compliance platform and officer-as-a-service: you licence the workspace for your internal representatives or have our representatives order it. The auditor calls, the evidence is ready.

The orange warning sign is regulated in ADR 5.3.2. The danger number is at the top and the UN number at the bottom. Both numbers are separated by a horizontal line. The dimensions, reflection and durability of the board are also standardised.

The top 33 is a Kemler number. The repetition of a number represents increased danger. 3 means flammable liquid substance, so 33 signals a highly flammable liquid with a low flash point.

The lower 1203 is the UN number for gasoline (motor fuel, gasoline). It is valid worldwide and comes from the UN Recommendations on the Transport of Dangerous Goods. It also applies to RID (railway) and IMDG (sea vessel).

Anyone who sees a warning sign 33/1203 knows: tanker or tank container transports petrol of class 3, packing group II. Flash point below 23 degrees Celsius, boiling point above 35 degrees Celsius.

The labelling is not decorative. Emergency services, police and customs derive initial measures from this. An incorrect or missing board is a violation according to Section 37 GGVSEB and can be punished with fines of up to 50,000 euros. To correctly order external expertise, read the role Dangerous Goods Officer.

Gasoline belongs to class 3 of the ADR, i.e. flammable liquid substances. The classification is based on flash point and boiling point according to ADR 2.2.3. Petrol fuels have typical flash points between minus 40 and minus 20 degrees Celsius.

This results in packing group II. Packaging groups indicate the level of danger: I high, II medium, III low. Petrol is therefore in the middle level and is subject to stricter packaging and tank regulations than, for example, diesel fuel (UN 1202, packaging group III).

The danger label for class 3 shows a red flame on a white or red background. On shipments it must be visibly attached to the packaging, on tank vehicles in large areas as a placard in accordance with ADR 5.3.1.

The transport document in accordance with ADR 5.4.1 contains the UN number, official name, class, packing group, tunnel restriction code (D/E for UN 1203) and quantity. The entry is, for example: UN 1203 PETROL, 3, II, (D/E).

Tunnel restriction D/E means: Driving through tunnel categories D and E is prohibited if the vehicle is carrying dangerous goods in non-exempt quantities. This information is operationally relevant for route planning and belongs in the appointment certificate.

If you want to systematically document classification and labelling, you will find the appropriate templates in the CIVAC Workspace for Dangerous Goods Officers.

ADR 1.4 and Section 9 GGVSEB define the obligations of those involved. When transporting UN 1203, each role has its own duty of care. There is no mandatory delegation in the contract that eliminates this responsibility.

The shipper checks the admissibility of the packaging, the marking of the packages, the compliance with the transport document and the suitability of the vehicle. He only delivers compliant shipments. He is responsible for the initial classification together with the sender.

The carrier checks the transport document, warning signs, large notices, the vehicle's ADR certificate, the driver's training certificate in accordance with ADR 8.2 and written instructions. He secures cargo and equipment, checks leaks and damage.

The recipient accepts the shipment, checks that it is complete, unloads in accordance with ADR specifications and ensures that the equipment is returned. If there are any abnormalities, he documents deviations and reports them to the sender and carrier.

Each role must document the training of its employees in accordance with ADR 1.3. The records must be kept for five years and presented to the responsible authority upon request.

The dangerous goods officer monitors all three roles and reports to company management. It is not a replacement for those responsible, but rather an additional supervisory and advisory function. If you don't have the capacity here internally, you can also appoint an external dangerous goods officer.

The obligation to order results from Section 1 Paragraph 1 GbV. Companies whose activities include the transport of dangerous goods or the associated packaging, loading, filling or unloading must appoint at least one dangerous goods representative in writing.

For UN 1203 petrol, this obligation practically always applies as soon as transport-relevant quantities are moved. Filling stations, mineral oil wholesalers, heating oil and fuel forwarders, tank cleaning companies and workshop operators with their own tankers are affected.

Exceptions are regulated by Section 2 GbV. These include domestic recipients, transports in quantities below the exemption according to ADR 1.1.3.6 and companies that only handle quantities below the thresholds. The exemption quantity for Class 3 Packaging Group II is 333 liters per transport unit.

The order is made in writing. The appointment certificate states the name, tasks, reporting line and representation. According to Section 8 GbV, it must be kept for five years. The appointment certificate, signed, filed, verifiable.

The proof of training (IHK examination according to § 4 GbV) must be current. The training must be repeated every five years, otherwise the proof will expire.

CIVAC offers the appointment certificate as a digital template, the reporting line as a structured workflow and the annual report as an audit template. Licence the workspace for your internal representatives or have our representatives order it.

§ 8 GbV lists the tasks of the dangerous goods officer. They range from monitoring classification to staff training and preparing the annual report. The focus is on six mandatory tasks.

First: monitoring compliance with regulations. This means regular spot checks and documented controls along the process chain. Loading, transport and unloading processes must be documented in an audit-proof manner.

Secondly: Advice to the company. The representative advises on the selection of packaging, vehicles, routes and suppliers. The advice must be recorded and deposited in the reporting line.

Third: training of employees in accordance with ADR 1.3. Content, date, participants and exam results are documented in the workspace. Repetitive training must be scheduled as required or at the latest after changes to the regulations.

Fourth: obligation to investigate and report accidents. Section 8 GGVSEB requires a report in the event of incidents involving personal injury, environmental contamination or property damage over 50,000 euros.

Fifth: Preparation of the annual report. The report includes quantities, incidents, training and suggestions for improvement. It goes to management and must be retained.

Sixth: Maintain written procedures. Emergency plans, safety instructions, load securing concepts. CIVAC stores these as versioned templates in the workspace, which can be accessed in the audit.

Three documents must always be carried with you when transporting 33/1203. If one is missing, the journey is not ADR-compliant and can be prohibited.

The transport document according to ADR 5.4.1 contains the UN number, substance name, class, packing group, tunnel restriction code, quantity as well as the sender and recipient. It must be carried in the original or as an approved electronic form.

The written instructions according to ADR 5.4.3 inform the driver about the measures to be taken in the event of an accident. They must be presented in a language that the driver understands, in practice German. The standard template is in ADR 5.4.3.4.

The ADR certificate of the vehicle according to ADR 9.1.3 confirms the suitability of the tanker for the substances transported. It is issued by a notified body after successful testing and is valid for one year.

The driver also requires proof of training in accordance with ADR 8.2.2 (ADR certificate). For UN 1203 he must provide evidence of the tank and class 3 advanced courses. The journey is not permitted without these structures.

On board, the equipment in accordance with ADR 8.1.5 (wheel chock, high-visibility vest, eyewash fluid, collection container) and the personal protective equipment must correspond to the list of written instructions.

If you want to centrally manage the transport document, ADR certificate and proof of training, use the CIVAC workspace with reminders before expiry. Others run compliance like a filing cabinet. We run it like software.

Gasoline is mainly transported in tankers. ADR 4.3 and 6.8 regulate the construction, equipment and testing of fixed tanks and demountable tanks. Tank containers and MEGCs are a special form.

The tank code for gasoline is LGBF: L for liquid substances, G for calculated minimum pressure, B for bottom openings with safety devices, F for pressure relief and ventilation. ADR 4.3.4 assigns the codes to substances.

General cargo transport is possible, for example in canisters or IBCs up to the ADR maximum quantities. Different packaging regulations apply here according to ADR 4.1. The packaging bears UN certification codes such as 3H1 or 31HA1.

Quantities below 1,000 points according to ADR 1.1.3.6 are exempt. For UN 1203 Class 3 Packing Group II, one point corresponds to three liters, so the exemption threshold is 333 liters. Attention: the exemption only applies if there are no other dangerous goods in the same transport process and no transport takes place in tanks.

Even below the exemption quantity, labelling of the packages, a simplified transport document and fire extinguishers are mandatory. Transport is not completely training-free.

In the CIVAC workspace, you assign tank and general cargo processes to separate templates. The reporting line to management remains uniform, the evidence remains consistent.

Framework of fines for dangerous goods violations are set out in Section 37 GGVSEB. Depending on the violation, they range up to 50,000 euros per individual case. In the event of intentional violations, criminal liability is added according to Section 328 of the Criminal Code, with a prison sentence of up to five years.

Frequent findings in the audit: missing or incorrect warning signs, expired ADR certificate, incomplete written instructions, missing proof of training according to ADR 1.3, missing tunnel restriction information and missing appointment certificate from the dangerous goods officer.

A recurring finding is the inadequate reporting line. The representative reports verbally, but without documented confirmation of receipt from the company management. In the event of damage, proof according to Section 130 OWiG is missing.

Section 130 OWiG sanctions the company's violation of its duty of supervision. Fines against the legal entity are possible according to Section 30 OWiG of up to ten million euros. Appointment orders documented in compliance with compliance reduce this risk.

The burden of proof lies with the company in the event of a dispute. Anyone who has a digital reporting line with a time stamp has an advantage. The appointment certificate, reporting line and annual report are stored in a version-proof version in the CIVAC workspace.

Audit-proof, documented, § 8 GbV-proof. If you want to be prepared for a call from the BAG, the district government or LANUV, you don't just build evidence when you knock on the door.

Three levels must be mastered: classification and labelling, role obligations of those involved and operational supervision by the dangerous goods officer. Each level generates its own evidence.

At level one you check whether all shipments with UN 1203 have the warning plate 33/1203, the danger labels and the transport document correctly. Labeling is mandatory from the first litre.

On level two, you clarify roles in writing. Who is the shipper, who is the carrier, who is the recipient? The representative for each role must be named, the training documented, and representation arranged.

At level three, you appoint the dangerous goods representative. You choose between an internal representative with a current IHK certificate or an external representative from CIVAC. Both paths lead to compliance, the difference lies in capacity and time.

Licence the workspace for your internal representatives or have our representatives order it. In both cases you will receive an appointment certificate, 490 audit templates and the reporting line in accordance with Section 8 GbV. EU data residency, ISO/IEC 27001:2022 ISMS.

Turn reading into a mandate. Write to info@civac.de or use the contact form on civac.de. We will appoint your dangerous goods representative within two working days instead of the industry standard two to six weeks.