Transport of Dangerous Goods: Regulations, Classes and Operational Obligations

The transport of dangerous goods on German roads is subject to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR — Accord relatif au transport international des marchandises Dangereuses par Route) and the national Dangerous Goods Ordinance for Road, Rail and Inland Waterways (GGVSEB). Both regulatory frameworks are updated every two years; the current ADR 2025 version has been in force since 1 January 2025. For companies that transport, ship or load dangerous goods, this creates extensive documentation, training and appointment obligations.

This article provides a structured overview of the nine dangerous goods classes, the obligations of the parties involved (carrier, shipper, consignor, consignee), the documentation requirements in the transport document and the internal organisation through an appointed dangerous goods officer. The aim is not to provide exhaustive legal advice, but rather an orientation framework for compliance officers within companies.

The ADR divides dangerous goods into nine main classes, defined according to their primary hazardous property. Class 1 covers explosive substances and articles; class 2, gases; class 3, flammable liquids; class 4, flammable solids, self-reactive substances and desensitised explosives; class 5, oxidising substances and organic peroxides; class 6, toxic and infectious substances; class 7, radioactive substances; class 8, corrosive substances; and class 9, miscellaneous dangerous substances and articles.

Within the classes, a distinction is made between packing groups (I: high danger, II: medium danger, III: low danger). The packing group determines, among other things, the permissible type of packaging, the labelling requirement and the exempt quantities under subsection 1.1.3.6 ADR.

For operational practice, the classification of a company's own products into classes and packing groups is the starting point for all further compliance obligations. The dangerous goods officer is responsible for this classification and must continually assess changes in the product portfolio.

Under Chapter 1.4 ADR, the consignor bears primary responsibility for correct classification, packaging, labelling and documentation. Classification is based on the UN number and the official name in the dangerous goods list (Chapter 3.2 ADR, Table A). For substances not explicitly listed, classification applies according to the general criteria of the relevant class.

Packaging must comply with the ADR test standard for the applicable packing group and be marked as approved packaging. The transport document (section 5.4.1 ADR) must contain the UN number, official name, class, packing group, number and description of the packages and — above certain quantity thresholds — a tunnel category.

Incorrect or missing classification by the consignor constitutes an administrative offence under Section 10 GGVSEB, even if the carrier accepted the goods without verification. The consignor and carrier are each liable for their respective area of responsibility; neither party can shift its own obligation onto the other.

Under subsection 1.4.2.2 ADR, the carrier is responsible for ensuring that the vehicle complies with the ADR technical requirements, that the driver holds the required ADR training certificate and that the load is correctly secured. For certain transports, a vehicle approval certificate is required (Chapter 9.1 ADR), in particular for tank vehicles.

The written instructions (section 5.4.3 ADR) must be kept readily accessible in the vehicle: they provide the driver with clear emergency measures for each type of hazard. The company is responsible for making the instructions available in the driver's language.

Vehicles carrying dangerous goods left overnight are subject to special requirements: they must be parked in supervised parking areas or — for certain quantities — in specially approved parking spaces (subsection 8.4 ADR). This requirement is frequently underestimated in day-to-day operations and is treated as a violation during inspections.

The transport document under section 5.4.1 ADR is the central document for the transport of dangerous goods. It must be drawn up for each transport unit and contain all information required for the transport-specific category. For several dangerous goods in the same vehicle, the information for each item must be listed separately.

Since ADR 2015, tunnel categories (A to E) have been required for certain goods. Category E represents the highest level of restriction; in some tunnels, transit by such goods is completely prohibited. Where a company ships goods falling under a tunnel category, the category must be noted in the transport document so that the driver can plan the route accordingly.

Electronic transport documents are permissible under subsection 5.4.0.2 ADR, provided they are legible during transport and can be made available to the competent authorities upon request. A mobile solution guaranteeing offline access is a mandatory requirement for legally compliant electronic transport documents.

Not every transport of dangerous goods is subject to the full ADR regime. Subsection 1.1.3 ADR provides for several exemptions. The most important for SMEs is the exemption under 1.1.3.6 ADR (limited quantities): where the total quantities per transport unit specified in Table 1.1.3.6.3 ADR are not exceeded, the driver training requirement and further ADR requirements cease to apply.

The calculation uses a multiplication factor per packing group and class. An incorrect calculation — for example by overlooking a substance or using the wrong factor — leads to an erroneous assumption of exemption. The company then acts unlawfully, even if an intention to comply was present.

Further exemptions exist for certain packaging (limited quantities, Chapter 3.4 ADR) and excepted quantities (Chapter 3.5 ADR). The dangerous goods officer must document all applicable exemptions and verify annually whether the conditions continue to be met. A change in production or a new distribution territory may cause an exemption to cease to apply.

Packages must be marked under Chapter 5.2 ADR with hazard labels (diamond symbol, colour-coded by class) and — where required — the UN number on a white rectangle. Excepted quantities under Chapter 3.5 ADR receive a simplified marking under 3.5.5.2 ADR instead of the hazard label.

Vehicles transporting dangerous goods must be marked under Chapter 5.3 ADR with orange warning panels and — for certain goods and tank vehicles — with large labels. The warning panels must bear the hazard identification number and the UN number; tank vehicles also receive a dangerous goods identification number (Kemler number).

Marking requirements vary according to transport quantities and class. A company that regularly transports dangerous goods should produce a marking manual documenting the correct marking for each item transported. This manual forms part of the dangerous goods officer's annual report.

Companies involved in the transport of dangerous goods — as carriers, consignors, loaders or unloaders — must appoint a dangerous goods officer under Section 3(1) GbV if the activity does not exclusively concern exempt quantities. The appointment must be made in writing; the representative must hold a valid ADR certificate of expertise (Chamber of Commerce and Industry examination).

Small companies that exclusively ship exempt quantities are exempt from the appointment obligation (Section 3(2) GbV). The assessment of this exemption is the company's own responsibility; if it is applied incorrectly, the administrative offence sanction under Section 10 GGVSEB applies.

The dangerous goods officer has extensive monitoring duties: they monitor compliance with the regulations, submit an annual report and are obliged to report incidents under Section 9 GbV. The role may be filled internally or assigned to an external representative. CIVAC offers both options: a workspace licence for the internal representative, or the appointment of an external dangerous goods officer from the certified partner network, with order document within two working days.

In the event of accidents or incidents during the transport of dangerous goods, specific reporting obligations apply. Under Section 9 GbV, the dangerous goods officer must report accidents that have resulted in injuries, significant property damage or material delays in transport to the competent authority. The reporting deadline is one month from the time of knowledge.

The accident prevention reporting obligations under DGUV V1 (Principles of Prevention) and the road traffic notification obligations apply in parallel. Where dangerous goods are released into the environment, reporting obligations under the Federal Soil Protection Act (BBodSchG) and water management notification obligations under Section 32 WHG are added.

Companies should keep an emergency card available for incidents, documenting the reporting chain, competent authorities and internal contact persons. This emergency card forms part of the dangerous goods officer's annual report and evidences the company's emergency preparedness. The auditor calls, the evidence is ready — this applies to the dangerous goods area as well.

Legally sound dangerous goods compliance within a company rests on four pillars: first, a complete inventory of all dangerous goods transported, with UN numbers and classes; second, an annually updated exemption review for each transport category; third, systematic training management for all deployed drivers (ADR certificates, expiry dates, refresher planning); and fourth, a structured annual report by the dangerous goods officer documenting deficiencies, measures and training status.

These four pillars are not optional — they are statutory minimum requirements. A company that fails to fulfil one or more of these pillars risks not only a fine at the next BAG inspection but, in serious cases, a prohibition on transporting dangerous goods.

CIVAC maps the dangerous goods officer function completely in the workspace: deadlines are automatically monitored, the annual report is generated in a structured manner, and the order document and reporting-line documentation are stored in an audit-proof manner. Licence the workspace for your internal dangerous goods officer — or appoint our certified external representatives.

Turn reading into action: write to us at info@civac.de.