Dangerous goods classes according to ADR: Overview, obligations and documentation

The dangerous goods classes according to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) are the basis for every transport decision, every label and every transport document. The ADR 2025, the German Dangerous Goods Ordinance for Road, Railway and Inland Shipping (GGVSEB) and the Dangerous Goods Officer Ordinance (GbV) form the legal framework. According to Section 10 of the GGBefG, violations are punished with fines of up to 50,000 euros; serious violations can be prosecuted under Section 328 of the Criminal Code. The Federal Institute for Materials Research and Testing (BAM) and the state authorities check compliance in random checks, especially at ports, railway junctions and on motorways.

This article brings together the nine classes of dangerous goods, their subclasses, the associated UN numbers and the obligations of those involved in the transport. You will find out which documentation is required for each shipment, how the dangerous goods officer (GbB) monitors the processes and how the annual reporting is carried out in an audit-proof manner in accordance with Section 8 GbV. CIVAC operates the documentation as a compliance platform and officer-as-a-service, so that appointment certificates, transport documents and annual reports are signed, filed and verifiable. Licence the workspace for your internal representatives, or have our representatives order it. The EU data residency protects sensitive business data, the reporting line is preset as the default path, and the SLA of two business days replaces classic waiting times of two to six weeks.

ADR Chapter 2.1 distinguishes between nine classes of dangerous goods. Class 1: Explosive substances and objects with subclasses 1.1 (risk of mass explosion), 1.2 (risk of splinters and projectiles), 1.3 (fire and low pressure effect), 1.4 (low risk), 1.5 (very insensitive with risk of mass explosion) and 1.6 (extremely insensitive). Class 2: Gases with subclasses 2.1 (flammable), 2.2 (non-flammable, non-toxic) and 2.3 (toxic). Class 3: Flammable liquids, such as gasoline (UN 1203), ethanol (UN 1170) and diesel fuel (UN 1202). Class 4 is divided into three parts: 4.1 (flammable solid substances), 4.2 (self-igniting) and 4.3 (substances that develop flammable gases with water).

Class 5: Oxidizing substances (5.1) and organic peroxides (5.2). Class 6: Toxic substances (6.1) and infectious substances (6.2), which include medical waste and diagnostic samples. Class 7: Radioactive substances, regulated additionally by the Radiation Protection Act and Radiation Protection Ordinance. Class 8: Corrosive substances, such as sulfuric acid (UN 1830) and caustic soda (UN 1824). Class 9: Various dangerous substances and articles, including lithium-ion batteries (UN 3480, UN 3481), environmentally hazardous substances and asbestos.

Each class has its own marking in the form of diamond-shaped danger labels, which are attached to packages in accordance with Section 5.2.2 ADR, and in the form of large posters (bills) on transport units in accordance with Section 5.3.1. Anyone who appoints a dangerous goods representative has the class assignment of each shipment systematically checked before it leaves the factory. The appointment certificate, signed, filed, verifiable. During inspections, the supervisory authorities pay particular attention to the correspondence between the transport document, the danger label on the package and the large label on the vehicle. An incorrect class assignment is reflected in all three documents at the same time and leads to cumulative complaints. Anyone who systematically records the assignment in goods receipt avoids this cascade.

Every hazardous substance has a four-digit UN number that uniquely identifies it worldwide. The UN list includes over 3,500 substances and objects. The UN number and the packing group (PG I for high danger, PG II for medium danger, PG III for low danger) determine the permissible packaging, the maximum quantities and the transport conditions. A UN 1203 (petrol) is Class 3, Packing Group II, the tunnel restriction code is D/E, which excludes tunnels of categories D and E.

The packing group is specified in the transport document (Section 5.4 ADR). It is crucial for the permissible package size, the testing requirements for the packaging (UN coding), the stackability and the co-packing standards with other classes. A Class 3 PG II consignment may not be packed with a Class 5.1 PG I consignment in one package because the oxidizing agent can cause the flammable liquid to self-ignite.

The tunnel restriction code must be stated in brackets in the transport document before the UN number and determines the permissible route. Tunnels are classified into categories A to E, with A being the most dangerous and E being the safest. A shipment with tunnel code B/D is not allowed to travel through tunnels of categories B, C, D or E, which significantly restricts route planning. The operational implementation is carried out via telematics systems that automatically take tunnel management into account. Anyone who links the UN list with the company's own substances in the compliance platform automates the transport documents and significantly reduces error rates. Others run compliance like a filing cabinet. We run it like software. The substance index should also reference safety data sheets according to REACH and CLP so that shipping and hazardous substance management are fed from a single source.

In medium-sized industrial companies, most dangerous goods shipments fall into two classes: Class 3 (flammable liquid substances) and Class 8 (corrosive substances). Class 3 includes petroleum products, cleaning products, varnishes, paints, adhesives, aerosols, ethanol and solvents. The flash point is the decisive criterion: liquids with a flash point of up to 60 degrees Celsius fall into class 3, with distinctions depending on the packaging group. Class 8 includes acids, alkalis, hypochlorites, phenols and concentrated hydrogen peroxide solutions above 8 percent.

What both classes have in common is that they are transported in containers of up to 1,000 liters (IBC, intermediate bulk container) and in general cargo (canisters, barrels) as well as in tank containers and tank trucks. The packaging must be UN-certified, the test data can be read in the code, for example "1H1/Y1.4/200" for a plastic barrel, packaging groups II and III suitable, tested up to 1.4 specific gravity, hydraulic test pressure 200 kPa.

Section 5.2 ADR applies to the labelling: danger label of the class, UN number, technical name. For tank vehicles, orange plates are added in accordance with Section 5.3.2, with the Kemler number (hazard number) at the top and the UN number at the bottom. A 33/1203 indicates a highly flammable liquid substance, UN 1203, i.e. gasoline. The correct reading of these boards is a mandatory part of driver training according to ADR Chapter 8.2.1. CIVAC provides all 490 ready-to-use templates for Class 3 and Class 8 shipments in the Dangerous Goods Workspace, including transport documents, emergency plans and training certificates. The auditor calls, the evidence is ready. The combination of Class 3 and Class 8 in the same package deserves special attention because acids can cause dangerous reactions in contact with solvents. The packing standards according to Section 4.1.10 ADR must be consulted here. Separation into separate packages is the safest solution, provided it is economically justifiable.

Class 9 collects heterogeneous substances that cannot be assigned to other classes but still pose a transport risk. Since the ADR amendment in 2017, the focus has been on lithium-ion batteries (UN 3480, UN 3481) and lithium metal batteries (UN 3090, UN 3091). With electric mobility, the boom in power tools and the energy storage market, these shipments are the fastest growing category. ADR special regulations SV 188, SV 230 and SV 240 regulate the conditions for exempt quantities, fully tested batteries and shipping for disposal.

For damaged or defective lithium-ion batteries, the special regulation SV 376 applies, which requires special packaging (UN-certified for damaged batteries) and a label with the symbol "DAMAGED/DEFECTIVE LITHIUM ION BATTERIES" is required. In the case of critically defective cells with a risk of thermal runaway, transport is only possible with individual approval from the authorities after a special agreement.

Lithium batteries are a classic stumbling block in shipping: consumer electronics, e-bikes, tool batteries, power banks. Many shippers underestimate the ADR obligations and treat these shipments as pure mail, even though the obligations for UN marking, safe packaging testing and employee training apply. For online retailers with large orders, violations are regularly sanctioned during supervisory visits. A systematic check of every new article for its UN number and class is mandatory. For this purpose, CIVAC offers a substance index with a link to the ADR list, so that each article master is assigned a UN number and shipping errors are identified at an early stage. The deadline runs as soon as we become aware of it, here too. When shipping by air freight, the IATA DGR regulations also apply, which are even stricter for lithium batteries than the ADR. If you use both shipping methods, you should separate the logic and store it in the system. For sea transport, the IMDG code applies in parallel, which has its own stowage requirements.

Chapter 1.4 ADR assigns clear safety obligations to those involved in transport. The consignor (shipper) must ensure that the shipment complies with ADR, that the packaging is approved and properly marked and that the transport documents are marked with the correct UN number, class, packing group and tunnel code. The carrier (carrier) checks the transport document, the external condition of the shipment and the conformity with the loaded vehicle.

The shipper (loader) is responsible for proper stowage in the vehicle, the recipient for immediate acceptance and unloading. The filler (for tank containers and tank vehicles) has additional responsibility for filling pressure, remaining quantities and cleaning status. Each of these roles can be subject to fines according to Section 10 GGBefG if the obligations are breached. The supervisory authorities clearly differentiate between roles, so that the recipient can also be sanctioned if he accepts a shipment that is obviously not ADR-compliant.

The obligation to appoint a dangerous goods representative according to Section 1 GbV applies to everyone involved who ships, transports, loads or unloads dangerous goods. Exceptions only exist for exempt quantities (subchapter 1.1.3 ADR) and for small quantities. The order is made in writing with an appointment certificate, the qualification is proven by the IHK training certificate. Anyone who has not appointed a dangerous goods representative or cannot present the appointment certificate will be immediately sanctioned during the supervisory visit. Licence the CIVAC workspace for your internal representatives, or have our representatives order it, with a two-day SLA instead of the classic two to six weeks. The appointment certificate, signed, filed, verifiable. The distribution of tasks between several representatives in larger companies should also be recorded in the compliance department's rules of procedure so that representation arrangements are clearly documented.

The transport document according to Section 5.4.1 ADR must be carried with every shipment. Mandatory information: UN number, official name of the substance according to column 2 of the list of substances, class, packing group, number and description of the packages, gross mass or volume, name and address of the sender and the recipient, as well as the tunnel restriction code in brackets before the UN number. An example line: "UN 1203 GASOLINE, 3, II, (D/E)".

If a shipment contains several substances, they must be listed in class order, separated by package or tank compartment. For shipments in tank vehicles, the maximum total quantity per tank chamber must also be stated. The transport document can be generated electronically, but must be presented in a form that the authorities can read. A PDF on the driver's smartphone is accepted in the event of a check, provided the file is also available offline.

In addition to the transport document, written instructions in accordance with Section 5.4.3 ADR must be carried. They inform the driver about the dangers, protective equipment and emergency procedures in the event of an incident. The written instructions are linguistically adapted to the driver and are in a language he can understand. For cross-border traffic, the instructions are provided in the languages ​​of the countries being traveled through. CIVAC offers ready-made templates in the workspace in German, English, French and Polish, which can be accessed per shipment. Audit-proof, documented, § 5.4-proof. When transporting groupage from several senders, consolidation documentation must also be kept in order to be able to clearly assign the transport documents to the respective shipments. The shipper has a special responsibility here. The written instructions must be available in a uniform version for the loaded classes, regardless of the shipment mix, so that the driver is able to act immediately in the event of an incident.

The dangerous goods officer prepares an annual report on the company's activities and the safety measures taken in accordance with Section 8 GbV. The report must be kept for at least five years and presented to the responsible authority upon request. In terms of content, it must contain the type of dangerous goods shipped or transported, the quantities per class, the defects identified and the training carried out.

In practice, a structured report with seven chapters is useful: firstly, company data and the appointment of representatives, secondly, area of activity (shipper, carrier, loader), thirdly, quantities shipped/transported by class, fourthly, incidents and cases of damage, fifthly, the level of training of the employees, sixthly, defects and measures, seventhly Recommendations for the following year. A pure statistics list is not enough. The report must contain a substantial assessment and identify potential for improvement.

In the event of accidents or near misses, Section 9 GbV stipulates an accident report, which must be prepared immediately after becoming aware of it and submitted to the authorities. The accident report must be kept separately from the annual report. In the event of significant damage (death, personal injury, property damage over 50,000 euros, environmental damage), a report to the Federal Highway Research Institute (BASt) is also required. Deadline begins as soon as we become aware of it. CIVAC structures the annual report in the workspace so that all data from the shipment logs during the year is automatically aggregated. Whoever has to collect at the end of the year loses. Those who manage on an ongoing basis put together the report in a week. An integrated interface to the ERP system automatically reads the shipped quantities per UN number and stores them in the draft report on a daily basis. At the end of the quarter, the management receives a preliminary report that provides the data basis for the final annual report.

The training obligation according to Chapter 1.3 ADR applies to all people whose tasks affect dangerous goods, not just drivers. Shipping employees, warehouse managers, dispatchers, buyers and salespeople need training appropriate to their role. The training includes general instruction (classification, labelling, documentation), function-specific training (shipping, storage, loading) and safety training (emergency behaviour, first aid). The training certificates must be kept with proof of the date, content, participants and signature for at least five years.

Drivers need an ADR certificate ("dangerous goods driving licence") in accordance with Chapter 8.2, which is extended every five years through refresher training with an examination. There is a basic course (general cargo) and advanced courses (tank vehicles, class 1 explosives, class 7 radioactive materials). Transport is not permitted without a valid certificate and the driver risks having the vehicle shut down at the checkpoint.

The appointment of the dangerous goods officer can be combined with other roles, such as occupational safety specialist (SiFa), fire protection officer or hazardous materials officer. The multiple role reduces costs as long as the person is qualified for each role and fulfils the reporting requirements separately. CIVAC maintains a qualification file for each person in the workspace with all orders, training certificates and follow-ups. In the event of a change, illness or absence, the replacement is documented immediately. Also see the role overview for the interfaces to SiFa, BSB and GSB. Multiple capture is a tool issue. For companies with several branches, it makes sense to have a central qualification matrix that shows which representatives are effectively appointed at which location and which courses are due next. The resubmission takes place automatically. The workspace also offers a four-eyes principle when releasing critical transport documents, which is positively noted during supervisory visits and supports the internal control system in accordance with Section 130 OWiG.

Dangerous goods are a risk of litigation and a risk of fines at the same time. CIVAC is a compliance platform and officer-as-a-service that addresses both risks. The material index, the UN list link, the transport document templates, the training certificates and the annual report are stored in version form in the workspace. For each new shipment, the platform suggests the correct UN number, class, packing group and tunnel restriction code and carries out a plausibility check.

Licence the workspace for your internal dangerous goods officers, or have our officers appointed. The appointment certificate will be issued within two working days, instead of the usual two to six weeks. It is signed, filed and linked to management via the reporting line. In the event of an incident, the emergency plan is ready, the transport document can be reconstructed, and the accident report in accordance with Section 9 GbV can be drawn up within hours.

Anyone who only checks the dangerous goods inventory during the supervisory visit has lost. Anyone who keeps it in an auditable file with a reporting line significantly reduces the risk of fines according to § 10 GGBefG and avoids the immobilization of vehicles at the checkpoint. Turn reading into a mandate.: Write to info@civac.de or use the contact form on civac.de to initiate the appointment of an external dangerous goods officer or the licensing of the workspace. We will send you a sample folder with transport documents, material index and training plan, tailored to your classes and packaging groups. A 30-minute initial consultation with the dangerous goods officer is part of the initial contact. Others run compliance like a filing cabinet. We run it like software. For the first 90 days, new mandates receive a fixed onboarding plan with material inventory, class mapping and gap analysis for training and appointment certificates.