Hazard number 90, UN 3082: What the label means for transport and compliance

The number combination 90 / 3082 on the orange warning sign of a truck indicates an environmentally hazardous liquid substance of class 9 according to ADR. 90 is the danger number (environmentally hazardous substance), 3082 is the UN number for environmentally hazardous liquid substances, n.o.s. (not otherwise stated). The labelling results from Part 5 ADR and Annex A of the Dangerous Goods Ordinance on Roads, Railways and Inland Waterways (GGVSEB). Anyone who transports, provides, packs, loads or unloads substances with this profile is a party within the meaning of Section 9 GbV and assumes clearly defined duties that cannot be delegated and must be verifiably documented to the Federal Office for Logistics and Mobility (BALM, formerly BAG) and the police.

This guide classifies the most important requirements for UN 3082 and hazard number 90. You will find out which substances typically fall under this classification and which packaging ADR Chapter 4.1 is permissible, what transport documents and markings on the package and on the vehicle should look like, what training and ordering obligations apply and what fines are threatened in the event of violations. You will also see how a dangerous goods officer secures transport in practice, how ADR overlaps with the Water Resources Act and the AwSV and how a compliance platform consolidates documentation for multiple shipments, locations and carriers. You form, ADR reference, concrete procedure instead of general instructions.

The marking of dangerous goods on the road follows a double code: danger number and UN number. Danger number 90 denotes substances that are hazardous to the environment, various dangerous substances and objects, as well as substances and objects that are transported in a heated state. It is written in the top half of the orange warning sign, with the UN number underneath. The UN number 3082 stands for environmentally hazardous liquid substances, not otherwise specified (UN 3082, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S.). The warning sign itself has a standardised size of 400 mm wide and 300 mm high according to ADR 5.3.2.

Class 9 is a collective class for various hazards that cannot be assigned to the classic classes 1 to 8. Environmentally hazardous substances here are primarily aquatic toxic substances that are classified as Aquatic Acute 1 or Aquatic Chronic 1 or 2 according to GHS criteria. Typical representatives are certain mineral oil products, crop protection products, solvents, cleaning concentrates, varnishes, some inks and biocidal formulations. The classification follows from the CLP Regulation (EC) 1272/2008 and is documented in Section 2 of the safety data sheet.

UN 3082 is always assigned to packing group III (low danger in the sense of dangerous goods, but environmentally relevant). The packaging instructions according to ADR Chapter 4.1.4 are typically P001 or IBC03 for large packaging. Anyone checking whether a specific product falls under UN 3082 starts with the safety data sheet (Section 14 contains the UN number and the dangerous goods class). If Section 14 is empty or formulated openly, a separate classification by competent persons according to ADR Chapter 2.2.9 applies. This self-classification must be documented and presented in the event of an audit. If you produce your own product or formulate your own recipe, complete classification documentation including the underlying toxicity data is mandatory.

UN 3082 is a collective item. It captures all liquid substances that are classified as environmentally hazardous (aquatic hazard) according to ADR subsection 2.2.9.1.10 and are not assigned a more specific UN number. In practice, this affects a wide range of products: certain diesel and heating oil formulations with aquatic additives, many crop protection products, some pharmaceutical precursors, technical surfactants, organic solvents with environmental relevance, printing inks and cleaning concentrates for the food industry. Depending on their composition, used lubricating oils and coolants can also fall under UN 3082.

It is important to differentiate between specific UN numbers. If a substance has its own UN number (e.g. UN 1170 for ethanol, UN 1219 for isopropanol), this takes precedence, even if the substance is hazardous to the environment. UN 3082 only applies if no specific entry exists. If there are additional dangerous properties (flammable, corrosive), another class is usually given priority, supplemented by the note environmentally hazardous with a fish and tree symbol according to special regulation 375. In the case of mixtures, the component with the highest risk decides on the classification.

In practical terms this means for shippers: Before each transport, it must be checked whether the safety data sheet shows the correct UN number and whether the environmental hazard is according to ADR 5.2.1.6 must be marked. For packaged quantities of less than 5 liters or 5 kg, an exemption under Special Provision 375 applies. This threshold makes UN 3082 a typical stumbling block because many shippers assume that they fall under small quantities without reading ADR Table A carefully. For repeated shipments, it makes sense to have a material card that centrally documents the classification, packaging group and special regulations for each material number. The deadline expires as soon as we become aware of it, this also applies to labelling defects.

For UN 3082, the packaging instructions P001 (packages up to 450 liters) and IBC03 (large packaging) are relevant. P001 allows drums, canisters, combination and composite packaging made of steel, aluminum, plastic or wood, provided they are type-tested according to ADR 6.1. The type test can be recognised by the UN coding on the packaging body, approximately 3H1/Y1.4/100 for a type-tested plastic bottle of packaging group II/III. The UN coding contains information on the type of packaging, material, packaging group, year of testing and testing centre. A blanket reuse of used packaging without type testing is not permitted.

IBC03 allows bulk packaging made of metal, rigid plastic or composite material. The design must be tested according to ADR 6.5; the marking contains the UN symbol, type, packaging group, gross weight and year of manufacture. IBCs must be tested for leaks every 2.5 years and fully tested in accordance with ADR 6.5.4.4.2 every 5 years, documented in a test certificate. Anyone who uses expired IBCs not only risks fines, but also civil liability in the event of damage. A central IBC list with test dates is therefore standard in every structured dangerous goods organisation. Reconditioned IBCs can only be used with a valid reconditioning certificate.

Anyone who ships UN 3082 in small quantities checks the exemption according to special regulation 375 and the limited quantities according to ADR Chapter 3.4. Both regulations make shipping and labelling easier, but do not completely exempt from duties of care. The packaging must still be suitable, transport documents can be shortened, and the training requirement for the people involved in accordance with ADR 1.3 is generally not eliminated. In the CIVAC workspace, the packaging logic is linked to the safety data sheet, parts list and appointment certificate from the hazardous goods officer and documented in an audit-proof manner in the audit. A reminder of upcoming IBC exams is automatically played in the workspace. Audit-proof, documented, ADR 4.1-proof.

The labelling is divided into three levels. Firstly, on the package: UN number 3082 preceded by UN, the hazard label model no. 9 (class 9) and the mark for environmentally hazardous substances (fish and trees) according to ADR 5.2.1.6, unless the exemption according to special provision 375 applies. Shipments weighing more than 30 kg or 30 liters gross weight must bear the environmental label. The minimum size of the danger label is 100 x 100 mm, the environmental label is also 100 x 100 mm on the package.

Secondly, on the container, large container or MEGC: Placards corresponding to the danger label, if necessary with an additional UN number in 25 mm high digits, the environmental label at least 250 x 250 mm. Thirdly, on the vehicle: orange warning sign at the front and rear, and on the side of tank vehicles with danger number 90 and UN number 3082. When transporting general cargo, the neutral warning sign without numbers is sufficient; the substance information is in the transport document. For combined loads with several UN numbers, the warning signs are displayed neutrally. If the quantity thresholds according to ADR 1.1.3.6 are not met, the warning sign can be omitted entirely.

Transportation documents according to ADR Chapter 5.4 must include the UN number, official name (ENVIRONMENTALLY HAZARDOUS LIQUID, N.O.S. with details of the components contained), class, packaging group, number and description of the packages, gross weight and shipping address. For sea transport, the mark MARINE POLLUTANT is also required; for air transport, the IATA-DGR with its own, often stricter requirements apply. Anyone who works uncleanly here risks a fine of 250 to 2,500 euros per violation in accordance with Section 37 GGVSEB, or more in repeat cases. Even an exemption in accordance with Section 5 GGVSEB does not change the documentation requirement. The appointment certificate, signed, filed, verifiable.

The transport document according to ADR Chapter 5.4.1 is the central document in transport. In addition to the UN number and classification, it contains the number of packages, gross weight, sender and recipient and, if applicable, the mark MARINE POLLUTANT for sea transport. In addition, written instructions in accordance with ADR 5.4.3 must be carried, which must be available in every official language of the transport route. The driver needs it in a language he understands. The written instructions follow the four-page standard template specified by the UNECE.

The training of the people involved is regulated in ADR Chapter 1.3. It includes induction training, task-related training and safety training. The employer is responsible for ensuring that training is carried out before starting work and is repeated every three years. Training documents and participant lists must be kept and presented to the responsible authority (usually the trade inspection or regional council) during the audit. Retention periods are at least five years after participation in the training. The content and depth of the training depends on the function and range of materials.

Drivers also need an ADR certificate in accordance with ADR Chapter 8.2 for tanks or Class 1 and Class 7 substances; for UN 3082 in general cargo it is only required if the allowances according to 1.1.3.6 are exceeded. Anyone who regularly sends UN 3082 trains internal employees, documents the training with date and content and links it to the appointment certificate from the dangerous goods officer. This link is stored as a template in the CIVAC workspace, including training plans for shipping, packaging, loading and receiving. The recurring training according to Chapter 1.3 is also automatically accompanied with reminders and proof of participants. Others run compliance like a filing cabinet. We run it like software.

The obligation to appoint a dangerous goods officer results from the Dangerous Goods Officer Ordinance (GbV) in conjunction with ADR Chapter 1.8.3. Anyone who regularly transports, packs, fills, loads or unloads dangerous goods domestically must appoint one or more dangerous goods officers in writing. The threshold is not linked to quantities, but to the activity. Smaller senders with regular shipments under UN 3082 are also affected. Exemptions according to Section 2 Paragraph 3 GbV only apply in narrowly limited constellations.

The catalogue of tasks results from Section 8 GbV and ADR 1.8.3.3. This includes monitoring compliance with ADR requirements, advising the company, annual reports to management, investigating accidents and incidents, emergency plans, organising training, selecting subcontractors and packaging testing. The dangerous goods officer reports to the management, has the right to speak and may not be disadvantaged in his tasks (Section 8 Para. 5 GbV). The annual report must be prepared by March 31 of the following year and retained for at least five years. In the case of accidents with material damage of over 50,000 euros or personal injury, an accident report must also be prepared in accordance with ADR 1.8.5.

External representatives are permitted according to Section 3 Paragraph 1 GbV and are the most economical solution in many small and medium-sized companies. The qualification is proven by training and examination certificates in accordance with Section 4 GbV, usually via the IHK. Training certificates must be renewed every five years with a refresher test. CIVAC provides the dangerous goods officer as an officer-as-a-service. Order in the standard path in two working days, including initial audit, catalogue of tasks and creation of emergency plans. Licence the workspace for your internal representatives or have our representatives order it. Audit-proof, documented, GbV-proof.

The ADR obligations apply to transport. As soon as UN 3082 substances are stored or handled internally, regulations from the Water Resources Act (WHG), the Ordinance on Facilities for Handling Substances Hazardous to Water (AwSV) and the Technical Rules for Hazardous Substances (TRGS) are added. Substances that are hazardous to the environment are also hazardous to water and are subject to the corresponding requirements for collecting trays, floor sealing and leak detection. The Federal Immission Control Act (BImSchG) can also be relevant for larger systems.

In practice, three points are central. Firstly, the classification into a water hazard class (WGK 1, 2 or 3) according to the AwSV and the announcement by the Federal Environment Agency, which determines the structural requirements. Secondly, the requirements for collection rooms according to AwSV § 18, which must collect 100 percent of the volume of the largest container or 10 percent of the total volume. Thirdly, the obligation to report to the responsible water authority in accordance with AwSV § 40 above certain volume limits. For systems larger than 10 m³, an expert inspection in accordance with the AwSV is regularly required. Stricter location requirements also apply to systems in water protection areas.

In addition, there are GefStoffV obligations that overlap with ADR but have different priorities. Risk assessment according to § 6 GefStoffV, operating instructions according to § 14 GefStoffV and training of personnel are mandatory regardless of ADR. In practice, anyone who stores, transports and processes UN 3082 requires a combination of a hazardous goods officer (transport), a hazardous materials officer (handling in the facility) and, if necessary, a water protection officer (WHG facilities above the threshold value). In the CIVAC workspace, the three roles are created as separate but linked procedures, so that double documentation is avoided and the reporting lines to management are consistent. The waste officer according to Section 59 KrWG can also be relevant depending on the quantity structure.

Violations of ADR and GGVSEB can be sanctioned as an administrative offense according to Section 37 GGVSEB. The fine range is up to 50,000 euros per violation; in practice, 250 to 5,000 euros are typical. Fines are distributed according to fault among those involved, i.e. the shipper, packer, loader, carrier and driver. Anyone who sender provides incorrect UN numbers or conceals an environmentally hazardous characteristic can remain liable even if the police stop the truck. The catalogue of fines for dangerous goods specifies the offenses and standard rates and is regularly adjusted by the administrative regulations of the federal states.

It becomes relevant under criminal law in dangerous situations. Section 328 of the Criminal Code criminalizes the unauthorized placing on the market of radioactive substances and dangerous goods, while Section 326 of the Criminal Code criminalizes the unauthorized disposal of waste. In the event of environmental damage, Section 324 (water pollution) and Section 324a (soil contamination) of the Criminal Code apply. In addition, there is strict liability under civil law under the Environmental Act, which makes it easier for injured parties to provide evidence. Insurance coverage is often linked to ADR compliance, and internal D&O policies also respond to major regulatory violations. In the event of damage, experts are involved who retrospectively check compliance with packaging, training and documentation obligations.

§ 130 OWiG also creates a breach of supervisory duty for management if dangerous goods violations occur within the company and no appropriate supervision is in place. Fines can be significantly higher here, up to 10 million euros according to Section 30 OWiG. This is one of the main reasons why appointing a dangerous goods officer and a documented reporting line are not only mandatory, but also protective for management. The auditor calls, the evidence is ready. In the CIVAC workspace, the reporting line to management is linked to the ADR annual report in accordance with Section 8 GbV; the annual status report contains key figures on shipments, incidents and training status. In addition, a quarterly dashboard with open measures, IBC inspection dates and audit results is maintained, which is available for access at every management meeting.

CIVAC is a compliance platform and officer-as-a-service. For dangerous goods, this means a workspace in which UN numbers, safety data sheets, packaging instructions, transport document templates, training matrices and appointment certificates are stored in a uniform structure. The 490 audit templates cover the annual report of the dangerous goods officer, the accident reports, the training certificates and the packaging inspection protocols. The data is stored with EU data residency, the ISMS follows ISO/IEC 27001:2022 with 93 controls and thus provides an audit-proof IT environment for sensitive shipping data.

You have two choices. Variant one: You have an internal dangerous goods officer and licence the workspace so that shipping, packaging and training are consistently documented for each location. You retain personnel sovereignty, but gain standard templates, a central register of substances and a standard process for inquiries from authorities. Variant two: You hand over the mandate. An external dangerous goods representative is appointed, the work takes place in the workspace, and the management receives quarterly or monthly reports. A hybrid model with an internal contact point for day-to-day business and external specialist responsibility for special ADR questions is also possible. Licence the workspace for your internal representatives or have our representatives appointed.

If you want to check today whether your UN 3082 shipments are ADR-compliant and whether the appointment of a dangerous goods representative has been set up correctly, then write to us. Turn reading into a mandate.: info@civac.de or the contact form on civac.de. Within one working day you will receive an initial assessment, an indication of effort and a suggestion as to which packaging and labelling gaps should be closed first. In the initial consultation, we also clarify the interface with hazardous substances and water protection officers, if relevant, and discuss the distribution of roles between shipping, warehouse and forwarding company. If you wish, we can also assist you with the initial check of your safety data sheets and transport documents. The appointment certificate, signed, filed, verifiable.