Can the dangerous goods safety adviser come from outside the company?

Yes, and without permission from any authority. Section 3 Para. 2 sentence 1 GbV reads: Die Funktion des Gefahrgutbeauftragten kann nach dem Unterabschnitt 1.8.3.4 ADR/RID/ADN vom Leiter des Unternehmens, von einer Person mit anderen Aufgaben in dem Unternehmen oder von einer dem Unternehmen nicht angehörenden Person wahrgenommen werden, sofern diese tatsächlich in der Lage ist, die Aufgaben des Gefahrgutbeauftragten zu erfüllen. Unlike Section 29 Para. 2 GenTSV, for example, no application is needed. The condition is actual competence, and under Section 3 Para. 3 GbV its minimum evidence is a valid training certificate for each affected mode of transport.

Does our company need a dangerous goods safety adviser at all?

That depends not on headcount but on goods, quantities and your role in the carriage process. Section 2 Para. 1 GbV exempts, among others, undertakings whose quantities do not exceed the maximum quantities in sub-section 1.1.3.6 ADR (no. 5), undertakings whose goods are exempted under chapters 3.3, 3.4 and 3.5 ADR (no. 6), and the consignor's principal, the unloader and own-use carriage up to 50 tonnes net per calendar year (nos. 2, 3 and 7). Under Section 2 Para. 2 GbV the exemptions can be combined. Where none applies, Section 3 Para. 1 sentence 1 GbV does. And even an exempt undertaking can be ordered to appoint an adviser under Section 3 Para. 4 GbV if it repeatedly or seriously breaches dangerous goods rules.

Can the managing director take on the function personally?

Yes. Under Section 3 Para. 1 sentence 3 GbV no appointment is needed where the business owner performs the function personally. Section 3 Para. 3 GbV still requires a training certificate valid for the affected mode of transport. Under Section 5 Para. 4 GbV that means training of at least 22 hours and 30 minutes for one mode of transport and an examination under Section 6 GbV, and under Section 4 sentence 2 GbV the certificate must be renewed after five years. Holding the function without a valid certificate is an offence under Section 10 no. 1 lit. b GbV.

What must the annual report contain?

Section 8 Para. 5 GbV requires the adviser to prepare an annual report for the business owner within six months of the end of the financial year. It must at least contain: the type of dangerous goods by class, the total quantity in one of four bands (up to 5 tonnes, more than 5 up to 50 tonnes, more than 50 up to 1,000 tonnes, more than 1,000 tonnes), the number and type of accidents on which an accident report was prepared, other information relevant to the safety situation, and whether the company took part in carrying goods under section 1.10.3 ADR/RID/ADN or 1.4.3 IMDG Code. Goods received count towards the total quantity. Under Section 9 Para. 3 GbV your company must keep the report for five years.

What does a missing appointment cost?

Up to fifty thousand euros, and the figure is not in the GbV. Section 10 no. 1 lit. a GbV provides that a business owner commits an offence within the meaning of Section 10 Para. 1 no. 1 lit. b of the Dangerous Goods Transport Act who, intentionally or negligently and contrary to Section 3 Para. 1 sentence 1, fails to appoint a dangerous goods safety adviser, or does not appoint one in the prescribed manner or in time. Only Section 10 Para. 2 GGBefG sets the fine for these cases at up to fifty thousand euros. The list in Section 10 GbV goes further: it also covers failing to keep records and annual reports under Section 9 Para. 3 GbV, and in no. 3 it addresses the adviser personally, for example for failing to prepare the annual report or to prepare it in time.

What stays with us when the adviser is external?

Responsibility for the carriage and the business owner's duties under Section 9 GbV. You may not disadvantage the adviser for performing their tasks, you must provide the necessary information, documents and resources under Section 9 Para. 2 GbV, and you must make sure the adviser can put proposals and concerns directly to the deciding body at any time. You keep records and annual reports for five years and produce them to the authority on request. Your duties as consignor, packer, loader or filler under the GGVSEB or the GGVSee are unaffected.

What does the service cost at CIVAC?

The price has four components: the one-off exemption check and set-up, an ongoing retainer for the appointed adviser including a deputy and the annual report, site visits, and event-driven work such as the accident report. The figure depends on the number of modes of transport and sites, on the classes and quantities of goods, on your role in the carriage process and on the visit cadence. Anyone comparing offers should ask two questions: is it checked before the appointment whether an exemption under Section 2 GbV applies? And is the annual report under Section 8 Para. 5 GbV part of the mandate or billed per report? You receive a fixed figure per component once goods, quantities and modes of transport are settled. The platform costs 49 € per officer role per month and is shown separately.

All services

Service

External Dangerous Goods Officer

Section 3 Para. 1 sentence 1 of the German Dangerous Goods Safety Adviser Ordinance (Gefahrgutbeauftragtenverordnung, GbV) requires every undertaking that takes part in the carriage of dangerous goods, and to which the GGVSEB or the GGVSee assigns duties as a participant, to appoint at least one dangerous goods safety adviser (Gefahrgutbeauftragter) in text form. Section 3 Para. 2 sentence 1 GbV expressly allows that function to be performed by a person who does not belong to the undertaking, with no application and no permission from any authority. Whether the duty applies to you does not depend on your headcount but on what you ship, in what quantity and in which role; Section 2 Para. 1 GbV exempts many shippers of small quantities entirely. This service therefore starts with the exemption check and fills the appointment from outside only where no exemption holds. Your duties as consignor, packer, loader or filler stay with your company.

Manufacturers shipping paints, coatings, adhesives, cleaning agents or chemicals beyond the exemptionsOnline retailers and producers whose shipments no longer fall under the exemptions in Section 2 Para. 1 GbVLaboratories, diagnostics and MedTech companies shipping samples, reagents or devices classed as dangerous goodsCompanies that used to be exempt and whose quantities have grownManaging directors who have held the function themselves under Section 3 Para. 1 sentence 3 GbV and no longer hold a valid training certificate under Section 4 GbV

What CIVAC takes on

Exemption check and appointment

Inventory of the carriage operations: which goods, which classes, which quantities per calendar year, which modes of transport and in which role your company takes part.
Comparison with the exemptions in Section 2 Para. 1 nos. 1 to 7 GbV, which Section 2 Para. 2 GbV allows to be combined.
Draft of the appointment in text form under Section 3 Para. 1 sentence 1 GbV and, where there are several advisers, the demarcation of their tasks under Section 3 Para. 1 sentence 2 GbV.
Evidence of a valid training certificate for each affected mode of transport, which Section 3 Para. 3 GbV requires before the appointment.
Notice of the adviser's name to all staff in text form or by posting, Section 3 Para. 2 sentence 2 GbV.

Monitoring and advice

Performance of the tasks in sub-section 1.8.3.3 ADR/RID/ADN, to which Section 8 Para. 1 GbV refers.
Records in text form of the monitoring activity, with date, persons monitored and business operations monitored, as Section 8 Para. 2 GbV requires.
Site visits that check packing, marking, loading and documentation of shipments in live operation.
Opinions on planned changes and on applications for derogations, which Section 9 Para. 2 no. 5 GbV entitles the adviser to give.
Ensuring the accident report under sub-section 1.8.3.6 ADR/RID/ADN is prepared, Section 8 Para. 4 GbV, if an accident occurs.

Annual report and evidence

The annual report under Section 8 Para. 5 GbV within six months of the end of your financial year, with the five mandatory items in sentence 2.
Filing of the appointment, records and annual reports in the CIVAC workspace, so your company can show the five-year retention required by Section 9 Para. 3 GbV.
Producing the training certificate to the authority on request and renewing it before the five years run out, Section 8 Para. 6 GbV together with Section 4 GbV.
Updating the appointment when a mode of transport, a site or a new role in the carriage process is added.

How it runs

1
Carriage operations and roles
We record which goods your company consigns, packs, loads, fills or unloads, in what quantities per calendar year and over which modes of transport. That shows which participant duties the GGVSEB or the GGVSee assigns to you, and those duties are what Section 3 Para. 1 sentence 1 GbV attaches to. Classifying a substance as dangerous goods is for you and your supplier; we supply the inventory and the open points.
2
Exemption check under Section 2 GbV
Before anything is appointed, we check the seven exemptions in Section 2 Para. 1 GbV. Those that most often apply are the quantity limit in sub-section 1.1.3.6 ADR (no. 5), the exemptions under chapters 3.3, 3.4 and 3.5 ADR (no. 6), and the limit of 50 tonnes net per calendar year for the consignor's principal, the unloader and own-use carriage (nos. 2, 3 and 7). Where an exemption holds, you receive the reasoning in writing and no appointment. The decision to rely on an exemption is your company's.
3
Appointment in text form
Where no exemption holds, we draft the appointment under Section 3 Para. 1 sentence 1 GbV. Under Section 3 Para. 3 GbV only a person holding a training certificate under Section 4 GbV that is valid for the affected mode of transport may be appointed; Section 9 Para. 2 no. 1 GbV requires that certificate to be in place before the appointment and geared to your company's activities. The name is announced to all staff in text form under Section 3 Para. 2 sentence 2 GbV.
4
Ongoing monitoring
The appointed adviser performs the tasks in sub-section 1.8.3.3 ADR/RID/ADN and keeps the records under Section 8 Para. 2 GbV in text form. Site visits at the agreed cadence check operations where they happen. Proposals and concerns go directly to the deciding body in your company under Section 9 Para. 2 no. 4 GbV, not through the department that runs shipping.
5
Annual report and renewal
Within six months of the end of the financial year the adviser prepares the annual report under Section 8 Para. 5 GbV: type of goods by class, total quantity in one of the four bands in sentence 2 no. 2, number and type of accidents with an accident report, other information relevant to safety, and the statement under sentence 2 no. 5 on whether the company took part in carriage under section 1.10.3 ADR/RID/ADN. Under Section 4 sentence 2 GbV the training certificate is valid for five years and is renewed before it expires.

Legal framework

The provisions below determine who must appoint a dangerous goods safety adviser, who is exempt, that the person may come from outside, what they must hold and what a missing appointment costs. Each is quoted in the original German so that you can check it against the ordinance.

Section 3 Para. 1 sentence 1 and Para. 2 sentence 1 GbV: Sobald ein Unternehmen an der Beförderung gefährlicher Güter beteiligt ist und ihm Pflichten als Beteiligter in der Gefahrgutverordnung Straße, Eisenbahn und Binnenschifffahrt oder in der Gefahrgutverordnung See zugewiesen sind, muss es mindestens einen Sicherheitsberater für die Beförderung gefährlicher Güter (Gefahrgutbeauftragter) in Textform bestellen. Die Funktion des Gefahrgutbeauftragten kann nach dem Unterabschnitt 1.8.3.4 ADR/RID/ADN vom Leiter des Unternehmens, von einer Person mit anderen Aufgaben in dem Unternehmen oder von einer dem Unternehmen nicht angehörenden Person wahrgenommen werden, sofern diese tatsächlich in der Lage ist, die Aufgaben des Gefahrgutbeauftragten zu erfüllen.
Para. 1 creates the duty and requires text form. Para. 2 is the legal basis of this service, and it is stronger than comparable sentences in German officer law: no application and no permission are needed, your company decides. The only condition is that the person can actually perform the tasks.
Section 2 Para. 1 nos. 5 and 6 GbV: Die Vorschriften dieser Verordnung gelten nicht für Unternehmen, [...] 5. deren Tätigkeit sich auf die Beförderung gefährlicher Güter im Straßen-, Eisenbahn-, Binnenschiffs- oder Seeverkehr erstreckt, deren Mengen die in Unterabschnitt 1.1.3.6 ADR festgelegten höchstzulässigen Mengen nicht überschreiten, 6. deren Tätigkeit sich auf die Beförderung gefährlicher Güter erstreckt, die nach den Bedingungen des Kapitels 3.3, 3.4 und 3.5 ADR/RID/ADN/IMDG-Code freigestellt sind
These are the two exemptions that most often apply to smaller shippers. Add the limit of 50 tonnes net per calendar year in nos. 2, 3 and 7 and the other grounds in Para. 1, which Para. 2 allows to be combined. An exemption is not permanent cover: where an exempt undertaking repeatedly or seriously breaches dangerous goods rules, the authority may order an appointment under Section 3 Para. 4 GbV.
Section 3 Para. 3 and Section 4 sentence 2 GbV: Als Gefahrgutbeauftragter darf nur bestellt werden oder als Unternehmer selbst die Funktion des Gefahrgutbeauftragten wahrnehmen, wer Inhaber eines für den betroffenen Verkehrsträger gültigen Schulungsnachweises nach § 4 ist. Der Schulungsnachweis gilt fünf Jahre und kann jeweils um weitere fünf Jahre verlängert werden, wenn der Betroffene eine Prüfung nach § 6 Absatz 4 mit Erfolg abgelegt hat.
The training certificate is a precondition of the appointment, not a consequence of it, and it applies per mode of transport. It is issued by the Chamber of Industry and Commerce under Section 7 Para. 1 no. 1 GbV. A business owner who holds the function personally needs it too; an expired certificate makes holding the function unlawful.
Section 10 no. 1 lit. a GbV together with Section 10 Para. 1 no. 1 lit. b and Para. 2 GGBefG: Ordnungswidrig im Sinne des § 10 Absatz 1 Nummer 1 Buchstabe b des Gesetzes über die Beförderung gefährlicher Güter handelt, wer vorsätzlich oder fahrlässig 1. als Unternehmer a) entgegen § 3 Absatz 1 Satz 1 einen Gefahrgutbeauftragten nicht, nicht in der vorgeschriebenen Weise oder nicht rechtzeitig bestellt [...]. Die Ordnungswidrigkeit kann in den Fällen des Absatzes 1 Nr. 1, Nr. 1a und Nr. 2 mit einer Geldbuße bis zu fünfzigtausend Euro [...] geahndet werden.
The amount is not in the GbV: Section 10 GbV points to the Dangerous Goods Transport Act, and only Section 10 Para. 2 GGBefG states the figure. Negligence is enough, and an appointment without text form or a late appointment also completes the offence. Under Section 10 no. 1 lit. b GbV it is equally an offence to appoint someone without a valid training certificate.

Wording retrieved on 23 September 2026 from gesetze-im-internet.de. The quantity limits and exemptions that Section 2 GbV refers to are set out in the ADR, not in the GbV; the version of the ADR in force is decisive.

How the price is built

The price has four components, shown separately. The first comes before any appointment and ends with a result even where an exemption holds and no appointment is needed.

Exemption check and set-up

One-off. Inventory of carriage operations and roles, check of the exemptions under Section 2 Para. 1 GbV with written reasoning and, where the duty applies, the draft appointment in text form under Section 3 Para. 1 GbV and the staff notice under Section 3 Para. 2 sentence 2 GbV.

Retainer for the appointment

Ongoing. Availability of the appointed adviser and a deputy, monitoring and advice under Section 8 Para. 1 GbV, records under Section 8 Para. 2 GbV and the annual report under Section 8 Para. 5 GbV.

Site visits

Per visit, scaled by site and volume of operations. Cadence and number are set in the mandate, not assumed across the board.

Event-driven work

Optional. Accident report under Section 8 Para. 4 GbV, further sites or modes of transport, and updating the appointment when goods, quantities or roles change.

Number of modes of transport, because Section 3 Para. 3 GbV requires a valid training certificate for each.
Number of sites where goods are consigned, packed, loaded or unloaded.
Classes and total quantity of goods, which also set the band in the annual report under Section 8 Para. 5 sentence 2 no. 2 GbV.
Your company's role in the carriage process, for example as consignor, packer, loader, filler or unloader.
Cadence and number of site visits.

You receive a fixed figure per component once goods, quantities and modes of transport are settled. The platform costs 49 € per officer role per month and is shown separately in the mandate.

Where the service ends

CIVAC is not a law firm and does not provide legal services within the meaning of the German Legal Services Act (Rechtsdienstleistungsgesetz). What this page describes is risk indication and organisational support; the legal assessment of an individual case belongs with your legal advisers.

Participant duties under the GGVSEB and the GGVSee, for example as consignor, packer, loader or filler, stay with your company and the persons named there. The adviser monitors and advises; the adviser does not ship.
The undertaking's duties under Section 9 GbV cannot be appointed away: not to disadvantage the adviser, to provide information, documents and resources, to keep records and annual reports for five years and to produce them to the authority on request.
The decision to rely on an exemption under Section 2 GbV is your company's. We supply the inventory and the reasoning, not the decision.
Classifying a substance or mixture as dangerous goods and the content of the safety data sheet are for you and your supplier.
Air freight is outside the GbV. Air transport requirements are a separate duty and not part of this appointment.
Orders by the authority under Section 3 Paras. 4 and 5 GbV are addressed to your company. We prepare the response; you submit it.

Common questions

Can the dangerous goods safety adviser come from outside the company?: Yes, and without permission from any authority. Section 3 Para. 2 sentence 1 GbV reads: Die Funktion des Gefahrgutbeauftragten kann nach dem Unterabschnitt 1.8.3.4 ADR/RID/ADN vom Leiter des Unternehmens, von einer Person mit anderen Aufgaben in dem Unternehmen oder von einer dem Unternehmen nicht angehörenden Person wahrgenommen werden, sofern diese tatsächlich in der Lage ist, die Aufgaben des Gefahrgutbeauftragten zu erfüllen. Unlike Section 29 Para. 2 GenTSV, for example, no application is needed. The condition is actual competence, and under Section 3 Para. 3 GbV its minimum evidence is a valid training certificate for each affected mode of transport.
Does our company need a dangerous goods safety adviser at all?: That depends not on headcount but on goods, quantities and your role in the carriage process. Section 2 Para. 1 GbV exempts, among others, undertakings whose quantities do not exceed the maximum quantities in sub-section 1.1.3.6 ADR (no. 5), undertakings whose goods are exempted under chapters 3.3, 3.4 and 3.5 ADR (no. 6), and the consignor's principal, the unloader and own-use carriage up to 50 tonnes net per calendar year (nos. 2, 3 and 7). Under Section 2 Para. 2 GbV the exemptions can be combined. Where none applies, Section 3 Para. 1 sentence 1 GbV does. And even an exempt undertaking can be ordered to appoint an adviser under Section 3 Para. 4 GbV if it repeatedly or seriously breaches dangerous goods rules.
Can the managing director take on the function personally?: Yes. Under Section 3 Para. 1 sentence 3 GbV no appointment is needed where the business owner performs the function personally. Section 3 Para. 3 GbV still requires a training certificate valid for the affected mode of transport. Under Section 5 Para. 4 GbV that means training of at least 22 hours and 30 minutes for one mode of transport and an examination under Section 6 GbV, and under Section 4 sentence 2 GbV the certificate must be renewed after five years. Holding the function without a valid certificate is an offence under Section 10 no. 1 lit. b GbV.
What must the annual report contain?: Section 8 Para. 5 GbV requires the adviser to prepare an annual report for the business owner within six months of the end of the financial year. It must at least contain: the type of dangerous goods by class, the total quantity in one of four bands (up to 5 tonnes, more than 5 up to 50 tonnes, more than 50 up to 1,000 tonnes, more than 1,000 tonnes), the number and type of accidents on which an accident report was prepared, other information relevant to the safety situation, and whether the company took part in carrying goods under section 1.10.3 ADR/RID/ADN or 1.4.3 IMDG Code. Goods received count towards the total quantity. Under Section 9 Para. 3 GbV your company must keep the report for five years.
What does a missing appointment cost?: Up to fifty thousand euros, and the figure is not in the GbV. Section 10 no. 1 lit. a GbV provides that a business owner commits an offence within the meaning of Section 10 Para. 1 no. 1 lit. b of the Dangerous Goods Transport Act who, intentionally or negligently and contrary to Section 3 Para. 1 sentence 1, fails to appoint a dangerous goods safety adviser, or does not appoint one in the prescribed manner or in time. Only Section 10 Para. 2 GGBefG sets the fine for these cases at up to fifty thousand euros. The list in Section 10 GbV goes further: it also covers failing to keep records and annual reports under Section 9 Para. 3 GbV, and in no. 3 it addresses the adviser personally, for example for failing to prepare the annual report or to prepare it in time.
What stays with us when the adviser is external?: Responsibility for the carriage and the business owner's duties under Section 9 GbV. You may not disadvantage the adviser for performing their tasks, you must provide the necessary information, documents and resources under Section 9 Para. 2 GbV, and you must make sure the adviser can put proposals and concerns directly to the deciding body at any time. You keep records and annual reports for five years and produce them to the authority on request. Your duties as consignor, packer, loader or filler under the GGVSEB or the GGVSee are unaffected.
What does the service cost at CIVAC?: The price has four components: the one-off exemption check and set-up, an ongoing retainer for the appointed adviser including a deputy and the annual report, site visits, and event-driven work such as the accident report. The figure depends on the number of modes of transport and sites, on the classes and quantities of goods, on your role in the carriage process and on the visit cadence. Anyone comparing offers should ask two questions: is it checked before the appointment whether an exemption under Section 2 GbV applies? And is the annual report under Section 8 Para. 5 GbV part of the mandate or billed per report? You receive a fixed figure per component once goods, quantities and modes of transport are settled. The platform costs 49 € per officer role per month and is shown separately.