Dangerous goods labelling for trucks: ADR obligations, plates, UN numbers

The dangerous goods labelling on trucks is based on ADR 2025, which is binding in Germany via the Road Hazardous Goods Ordinance (GGVSEB). Anyone who transports substances from classes 1 to 9 must mark the towing vehicle, trailer and shipping items in such a way that rescue workers can recognise in seconds what they are dealing with. According to Section 37 GGVSEB, violations cost up to 50,000 euros per trip.

This article explains when orange warning signs with a Kemler number are sufficient, when additional danger labels must be visible and how tunnel codes control the choice of route. You can also read how CIVAC, as a compliance platform and officer-as-a-service, bundles the labelling into an auditable dossier so that the auditor calls and the evidence is ready.

The legal framework for dangerous goods labelling on trucks consists of three components. The ADR 2025 provides the technical regulations, the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways (GGVSEB) makes them binding in Germany, and the Dangerous Goods Officer Ordinance (GbV) regulates internal responsibility. This triad applies equally to shippers, carriers and recipients.

According to Section 1 GbV, every company that transports dangerous goods or packs them for transport appoints a dangerous goods representative. The order is made in writing and the training according to ADR 1.8.3 must be renewed every five years. Anyone who does not appoint an officer risks fines of up to 50,000 euros per violation according to Section 37 GGVSEB.

The dangerous goods officer monitors the labelling, checks transport documents and keeps the annual report in accordance with ADR 1.8.3.3. He is not a driver himself, but rather a supervisor and interface to the authorities. In the event of an incident, he creates the report according to 1.8.5 within 30 days.

The labelling itself is the carrier's obligation, the provision of the data is the sender's obligation. Both stick next to each other if panels are missing or codes are incorrect. Anyone who appoints an external dangerous goods officer outsources the supervision, but retains the entrepreneurial obligation.

CIVAC combines both models in a compliance platform and officer-as-a-service. Licence the workspace for your internal representatives, or have our representatives order it. The appointment certificate, signed, filed, verifiable.

The orange warning sign is the most noticeable symbol on the dangerous goods truck. According to ADR 5.3.2.2.1, it measures at least 400 by 300 millimeters, has a black border of 15 millimeters and is reflective. For small vehicles under 12 tons, 300 by 120 millimeters are permitted, provided legibility is maintained.

There are two numbers on the board. Above is the Kemler number that describes the type of danger, around 33 for highly flammable liquid or 80 for corrosive substance. Below is the four-digit UN number, approximately 1203 for gasoline. For bulk and tank transport, the board is material-specific on both sides, otherwise it remains unmarked.

It is attached to the front and rear of the vehicle. For tank containers, demountable tanks and tank vehicles with multiple compartments, each compartment is marked separately if it contains different substances. After emptying, the panels must be covered or removed, otherwise the vehicle will continue to be considered a dangerous goods truck.

Frequent defects during inspections include faded colors, damaged reflections and incorrect UN numbers after metabolism. The BAG inspection statistics for 2024 show labelling deficiencies as the second most common complaint after transport documents. Every defect discovery is recorded in OBELIS.

In the CIVAC workspace, you store board templates for each vehicle, material and route. The driver scans the QR code on the vehicle, the system shows the correct panel configuration and records the visual inspection. Audit-proof, documented, § 37 GGVSEB-proof.

Hazard labels on trucks are formally called large labels or placards. They are square, rotated by 45 degrees, measure 250 by 250 millimeters and bear the danger class symbol. In contrast to the danger label on the package, which only measures 100 by 100 millimeters, they can be read from a great distance.

The large labels are attached when the vehicle is uncleaned and loaded with packages of a hazard class or is functioning as a tanker, bulk or container vehicle. If there are several classes, all the flyers must be shown next to each other. Class 1 (explosives) and Class 7 (radioactive materials) require additional subgroup information.

The placement is on both long sides and at the rear. In the case of articulated lorries, the towing vehicle and semi-trailer are considered separately, each with its own large label. The large labels are attached directly to swap bodies and containers so that they travel with the cargo.

For limited quantities in accordance with ADR 3.4, large labels are no longer required, but the diamond LQ is attached to the shipping item. Exempt quantities according to 3.5 use the symbol E. Both regulations reduce the effort for shippers with small packaging units, but are linked to fixed quantity limits for each dangerous goods class.

CIVAC stores a substance database with the correct billets in the workspace and uses a plausibility check to check whether the board, billboard and transport document match. This means that labelling becomes a routine, not a puzzle before every tour.

Tunnel codes regulate which tunnels a dangerous goods truck can drive through. They are in column 15 of ADR table A and range from B (very restrictive) to E (hardly any restriction). According to ADR 1.9.5, tunnels themselves are classified into five categories A to E; the combination determines admissibility.

The tunnel code must be included in the transport document, according to the UN number in brackets, for example UN 1203 PETROL, 3, II, (D/E). If the code is missing, the paper is formally defective and the vehicle is not allowed to enter routes that require tunnels. BAG and the police carry out random checks at tunnel portals.

The route planning must compare the tunnel code with the actual tunnel categories. In Germany, categories can be accessed via the Federal Highway Research Institute. In the Alps, through Switzerland or Austria, there are sometimes stricter national requirements that must also be observed.

Security obligations apply to transport with particularly high risks according to ADR 1.10.3.1 (High Consequence Dangerous Goods). This includes a security plan, training of those involved and access restrictions. Quantity thresholds are substance-specific in 1.10.3.1.2, around 5,000 liters for flammable liquids of packaging group I.

In the workspace, CIVAC links substance data, tunnel codes and route data with a plausibility check. Before the tour starts, dispatchers check whether the planned route is compatible with the shipment and document the release in an audit-proof manner.

The identification on the vehicle is only the visible half of the obligations. In the driver's cab are the transport document according to ADR 5.4.1, the written instructions according to 5.4.3 and the driver's ADR certificate (training certificate according to 8.2.2). If one is missing, the transport is considered improper.

The transport document states the UN number, official name, danger class, packing group, tunnel code, number of pieces, sender and recipient. For group shipments, all substances must be listed individually. Electronic transport documents are permitted according to ADR 5.4.0.2, provided authorities have access.

The written instructions are the emergency card for the driver. They show immediate measures to be taken in the event of an accident or fire and are available on four pages in the languages ​​that the crew understands. The UNECE model template is a mandatory model, your own variants are not permitted.

According to 8.1.5, the personal protective equipment in the driver's cab includes, among other things, a high-visibility vest, portable lighting, two self-standing warning signs, eyewash fluid and, depending on the class, a breathing mask. The equipment must be checked regularly; expired eyewash leads to fines.

CIVAC bundles these documents into a tour dossier in the workspace. The shipper, shipping company and driver work on a file and changes are versioned. The auditor calls, the evidence is ready., from the transport document to the inspection receipt for the high-visibility vest.

The most common labelling errors follow a pattern. First: old Kemler number according to metabolism. Second: faded or missing reflection on the warning sign. Third: large notices only on one side, not at the rear. Fourth: incorrect or missing tunnel code in the transport document. Fifth: panels that have not been removed after emptying.

The fine reinforcement is in Section 37 GGVSEB in connection with the Fines Catalog Ordinance. The usual fine is 50 to 5,000 euros per violation, and up to 50,000 euros for intentional or serious violations. Repeat offenders are targeted by the Federal Office for Goods Transport, which maintains risk profiles in OBELIS.

In addition to the fine, there is a risk of being banned from continuing the journey. The vehicle will remain at the checkpoint until the defects are corrected. Costs for towing, downtime and loss of orders regularly exceed the fine. Insurers reduce benefits if the labelling is disputed.

Risk also arises under civil law. In the event of an accident with inadequate marking, those injured argue that the carrier was partly at fault. Authorities will revoke the traffic permit if defects accumulate. The manager's personal liability according to Section 130 OWiG can also be added.

The CIVAC platform contains 490 ready-to-use audit templates for dangerous goods, training and incident reporting. Random checks and self-audits run weekly; the dashboard shows open defects per location, vehicle and substance.

Drivers of dangerous goods trucks need the ADR training certificate according to 8.2.2 ADR. The basic course includes 18 teaching units, advanced courses for tank, class 1 and class 7 must be completed separately. The certificate is valid for five years; repeat training must be completed before it expires, otherwise it expires.

Other parties involved, i.e. shippers, packers, loaders, unloaders and employees who do not work as drivers, must be given task-related training in accordance with Chapter 1.3 ADR. This instruction must be repeated every three years and proof of participation must be retained. Loading and security personnel also need instruction in 1.10 Security.

The dangerous goods officer himself takes part in his own examination by the IHK. The test catalogue includes all modes of transport or focuses on roads. The certificate is personal and non-transferable; if you change it, you must order a new one. Violations fall under Section 9 Paragraph 2 GbV.

Proof of training belongs in a central register. Who completed which course, when, and with what validity must be presented to the authorities upon request. Gaps in the register are a typical audit finding and lead to requirements for the following period.

CIVAC maintains a training matrix in the workspace for each employee, role and material. Expiring certificates are reported 90 days in advance and bookings are made directly in the system. Others run compliance like a filing cabinet. We run it like software.

Dangerous goods labelling is part of a larger compliance network. In the warehouse, the Hazardous Substances Ordinance applies with safety data sheets, storage classes according to TRGS 510 and CLP labelling. The Hazardous substances officer and the hazardous goods officer exchange material data and risk assessments.

When loading and unloading, DGUV regulation 70, occupational safety according to BetrSichV and, if necessary, the Major Accident Ordinance for quantity thresholds apply. The occupational safety specialist checks loading ramps, anchor points and protective equipment. For tank transports, the TÜV tank inspector with a five-year test cycle is also included.

In terms of environmental law, the Water Resources Act (WHG) combines dangerous goods with the AwSV system regulation for substances that are hazardous to water. The emergency officer ensures that collection trays, binding materials and reporting channels to authorities work in the event of damage. Reports to water protection authorities must be made within 24 hours.

On the IT side, tour, material and training data flow into transport and warehouse management systems. The confidentiality of security plans according to 1.10.3.2 requires state-of-the-art protection. Anyone who operates an ISO 27001:2022 ISMS has already addressed controls A.5.7 (Threat Intelligence) and A.8.3 (Access Control).

CIVAC integrates these disciplines in one platform. Substance data comes in once and supplies dangerous goods officers, hazardous materials officers, environmental officers and emergency planning. Duplication is eliminated, audit templates can be used across roles, EU data residency included.

Dangerous goods labelling on trucks is not a detail, but a mandatory program with clear sanctions. ADR boards, billboards, tunnel codes and transport documents must be correct on a daily basis, be verifiable retroactively for five years and be available in the audit within hours. Anyone who does this in Excel and file folders is running behind reality.

CIVAC, as a compliance platform and officer-as-a-service, is built precisely for this routine. 25 representative roles run via a workspace, 490 audit templates cover dangerous goods, hazardous substances, fire protection and more, EU data residency and ISO 27001:2022-compliant processes are standard. The appointment certificate, signed, filed, verifiable.

Licence the workspace for your internal representatives, or have our representatives order it. The SLA for the initial appointment is two working days, instead of two to six weeks via traditional law firms. The order is then completed before the next tanker truck rolls into the yard.

During onboarding, we scan your list of materials, vehicle fleet, training levels and previous templates. Within the first session you will see which Kemler numbers, tunnel codes and certificates currently do not match. Defects are assigned a deadline and who is responsible, escalations are reported via the reporting line to management.

Turn reading into a mandate. Write to info@civac.de or use the contact form on civac.de, and you will have an initial discussion and a suggestion that suits your fleet within two working days.