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How To Transport Batteries Safely

Batteries are one of the most tightly regulated categories of dangerous goods, and one of the most frequently transported incorrectly. From lithium-ion batteries in laptops and power tools to large EV battery packs, lead-acid batteries in vehicles, and lithium metal cells in specialist equipment, almost every business that handles battery-powered products needs to understand how to transport batteries safely and legally. This guide covers everything UK businesses need to know.

Why Battery Transport Is Regulated

Batteries, particularly lithium-ion batteries and lithium metal batteries, are classified as dangerous goods under the ADR regulations (the European Agreement Concerning the International Carriage of Dangerous Goods by Road) because they present a genuine fire and explosion risk during transport if they are damaged, incorrectly packaged, short-circuited, or exposed to excessive heat.

The risk is not theoretical. There have been numerous incidents involving battery fires during transport across all modes of transportation, in road vehicles, cargo aircraft, and ships.

The energy density of modern lithium-ion batteries means that a thermal runaway event, a self-sustaining, temperature-escalating chemical reaction within the battery, can generate intense heat and fire that is extremely difficult to extinguish. Once thermal runaway begins in one battery cell, it can propagate to adjacent cells and spread rapidly.

The dangerous goods regulations for battery transport have been progressively tightened over the past decade in response to these risks. The International Civil Aviation Organization (ICAO), the International Maritime Dangerous Goods (IMDG) Code for sea transport, and ADR for road transport have all introduced increasingly specific requirements for battery transport, covering state of charge limits, packaging specifications, labelling, and documentation.

Battery Types and Their Dangerous Goods Classification

Not all battery types are treated the same under dangerous goods regulations. Different battery chemistries present different levels of risk, and the transport requirements vary accordingly. The key distinction for regulatory purposes is between lithium-based batteries and non-lithium batteries, with lithium-based batteries subject to the most stringent requirements.

Lithium-Ion Batteries (Li-ion)
Rechargeable. Used in smartphones, laptops, tablets, power tools, e-bikes, electric vehicles, and energy storage systems. Classified as Class 9 dangerous goods. The most commonly transported battery type requiring ADR compliance in the UK.
 
Lithium Metal Batteries (Primary)
Non-rechargeable. Used in watches, hearing aids, calculators, military equipment, and specialist devices. Also classified as Class 9. Generally considered higher risk than lithium-ion batteries due to higher lithium content and greater reactivity.
 
Lithium Polymer Batteries (LiPo)
A variant of lithium-ion chemistry using a polymer electrolyte rather than a liquid one. Common in drones, RC vehicles, and consumer electronics. Classified identically to lithium-ion batteries under ADR — UN 3480 or UN 3481 depending on configuration.
 
Lead-Acid Batteries
Wet (flooded) lead-acid batteries are classified as Class 8 corrosive substances under ADR. Sealed valve-regulated lead-acid (VRLA) batteries are Class 9. Common in vehicles, industrial equipment, and UPS systems. Less restrictive than lithium but still regulated.
 
Nickel-Metal Hydride (NiMH)
Rechargeable. Found in hybrid vehicles, power tools, and consumer electronics. NiMH batteries are generally not classified as dangerous goods for transport unless they meet specific criteria for hazardous substances — check the Safety Data Sheet for the specific product.
 
Nickel-Cadmium (NiCd)
Rechargeable. Used in industrial equipment, power tools, and emergency lighting. NiCd batteries may be classified as Class 9 under certain conditions due to cadmium content. Check the specific UN number and Safety Data Sheet before transport.

 

The UN Numbers for Battery Transport

Each category of battery has a specific UN number, the four-digit code assigned under the UN dangerous goods classification system that identifies the substance or article and triggers the applicable transport requirements.

Using the correct UN number is a fundamental requirement of ADR compliance, an incorrect UN number on the transport document or outer packaging is a breach of the dangerous goods regulations.

UN Number Proper Shipping Name Class Key Notes
UN 3480 Lithium ion batteries Class 9 Standalone lithium-ion battery cells and packs, not installed in equipment. State of charge limit of 30% applies under Section II. Watt-hour limits per cell and per battery apply.
UN 3481 Lithium ion batteries packed with equipment / Lithium ion batteries contained in equipment Class 9 Lithium-ion batteries shipped in the same outer packaging as equipment, or already installed inside equipment. Must be protected against activation and short circuit.
UN 3090 Lithium metal batteries Class 9 Standalone lithium metal battery cells and packs. Lithium content limits per cell and per battery apply. More restrictive than lithium-ion in some contexts due to higher reactivity.
UN 3091 Lithium metal batteries packed with equipment / Lithium metal batteries contained in equipment Class 9 Lithium metal batteries shipped with or inside equipment. Lithium content limits apply. Equipment must be protected against activation.
UN 2794 Batteries, wet, filled with acid Class 8 Standard wet lead-acid batteries. Corrosive risk from sulphuric acid. Must be transported upright with secure, sealed vents. Subsidiary risk Class 9 in some configurations.
UN 2800 Batteries, wet, non-spillable, electric storage Class 9 Sealed, valve-regulated lead-acid (VRLA) batteries including AGM and gel types. Less restrictive than wet acid. Common in UPS systems and mobility aids.
UN 3171 Battery-powered vehicle / Battery-powered equipment Class 9 Vehicles or equipment powered by lithium batteries or wet batteries when transported as a complete unit — such as electric wheelchairs, e-bikes, or electric scooters. Special provisions apply.

How To Transport Lithium-Ion Batteries Safely by Road

Transporting lithium-ion batteries safely by road in the UK requires compliance with ADR Packing Instruction P903, which sets out the requirements for UN 3480 and UN 3481. The specific requirements depend on whether you are shipping under Section I (full ADR compliance) or Section II (simplified compliance for smaller batteries and quantities).

Section I: Full ADR Compliance

Section I applies to larger batteries, higher watt-hour ratings, and quantities that exceed the Section II thresholds. Under Section I, the full ADR requirements apply, including ADR-certified drivers, a complete Dangerous Goods Transport Document, and vehicle marking and placarding. Section I is typically required for:

  • Lithium-ion cells exceeding 20Wh per cell
  • Lithium-ion batteries exceeding 100Wh per battery
  • Large-format EV battery packs
  • Industrial battery systems
  • Consignments exceeding the Section II quantity limits

Section II: Simplified Compliance

Section II provides a reduced-requirement route for smaller batteries and lower watt-hour ratings. Under Section II, the driver is not required to hold an ADR certificate and a full transport document is not required, however, the lithium battery handling mark must appear on the outer packaging, and a basic transport document with the UN number and battery type is still required. Section II applies to:

  • Lithium-ion cells not exceeding 20Wh
  • Lithium-ion batteries not exceeding 100Wh
  • Subject to quantity limits per package

State of Charge (SOC) Requirements

One of the most critical, and most frequently overlooked, requirements for the transport of lithium batteries under Section II is the state of charge limit. Lithium-ion batteries transported as UN 3480 (standalone) under Section II must not exceed 30% of their rated capacity at the time of transport.

This requirement exists because the thermal runaway risk from a short circuit or physical damage is proportional to the energy stored in the battery. A battery at 30% SOC presents a significantly lower risk than one at full charge. The 30% SOC limit must be applied before the battery is packaged, it cannot be adjusted during transit.

Damaged, Defective, and End-of-Life Batteries

Batteries that are damaged, defective, recalled, or showing signs of a safety concern, including leaking, venting, deformation, or evidence of previous overheating, present a substantially higher transport risk than undamaged batteries. They are subject to enhanced requirements under ADR Special Provision 376, which applies specifically to lithium batteries that present a safety concern.

Do not transport damaged lithium batteries in standard packaging.

Standard UN-approved packaging for batteries is designed for undamaged goods in normal condition. It is not sufficient for batteries that are leaking, venting, deformed, hot to the touch, or showing any sign of damage or thermal activity. Attempting to transport a damaged lithium battery in standard packaging is both a compliance failure and a serious fire risk. Always seek specialist advice before attempting to move any suspect battery.

ADR Special Provision 376: Requirements for Damaged Batteries

Under Special Provision 376, lithium batteries that are known or suspected to be damaged or defective must be:

  • Transported in a salvage container or equivalent outer packaging that is capable of containing a thermal event, typically a metal container with a lid, or a specialised fire-containment battery transport bag
  • Transported with a minimum quantity of non-combustible, thermally insulating material around the battery to absorb any leakage
  • Each damaged battery transported in its own individual outer packaging, they must not be grouped together
  • Accompanied by additional documentation noting the damage and the special provision being applied
  • Subject to emergency response procedures appropriate to the risk, the driver must be briefed on the nature of the battery and the response actions required.

End-of-Life and Waste Batteries

Batteries being transported for recycling, treatment, or disposal are subject to both the ADR dangerous goods requirements and, where they meet the definition of waste, the Hazardous Waste Regulations.

Under the Waste Batteries and Accumulators Regulations 2009, batteries transported as waste in the UK must be accompanied by appropriate waste transfer documentation in addition to the ADR transport document.

Our battery transport service covers both the ADR and waste regulatory requirements for end-of-life battery collections.

What Is Classified As Dangerous Goods?

Many businesses that handle, ship, or receive chemicals, batteries, gases, paints, cleaning products, or industrial materials are already working with dangerous goods, whether they know it or not. Understanding how dangerous goods are classified under UK law is essential for anyone involved in their production, distribution, or transport. This guide explains exactly what counts as a dangerous good, how goods are classified, and what that classification means in practice.

What Is a Dangerous Good: The Legal Definition

Under the ADR regulations, the European Agreement Concerning the International Carriage of Dangerous Goods by Road — a dangerous good is defined as any substance or article that, due to its physical, chemical, or biological properties, presents a hazard to human health, safety, property, or the environment when transported.

The classification system for dangerous goods originates from the United Nations Model Regulations for the Transport of Dangerous Goods, which forms the international framework on which all major transport regulations, including ADR for road transport in the UK, are based. When a substance or article is assigned a UN number, it has been formally identified as a dangerous good under this international system.

In practical terms, a dangerous good is any substance or article that appears in the UN Dangerous Goods List, or that meets the classification criteria for one of the nine dangerous goods classes set out in ADR. The classification is based on the inherent physical or chemical properties of the substance, not on how carefully it is handled, how securely it is packaged, or how experienced the person transporting it might be.

The Two Key Questions: Substance or Article?

The ADR regulations make an important distinction between a substance and an article. Understanding this distinction helps clarify why some goods that don’t look dangerous at first glance are still classified as dangerous goods.

Dangerous Substances

A dangerous substance is a chemical or material that presents a hazard due to its inherent properties, for example, its flammability, corrosiveness, toxicity, reactivity with water, or ability to harm human health or the environment. Dangerous substances include liquids, solids, gases, powders, and mixtures. Examples include petrol, sulphuric acid, chlorine gas, sodium hydroxide, and hydrogen peroxide.

Dangerous Articles

A dangerous article is a manufactured item that contains or incorporates a dangerous substance or energy source, and that presents a hazard during transport. The substance itself may be contained within the article, meaning it is not immediately visible, but it still makes the article a dangerous good. Examples include lithium batteries (which contain reactive lithium chemistry), aerosol cans (which contain pressurised gas and often a flammable propellant), fire extinguishers, and airbag inflators.

Why this matters for UK businesses:

Many businesses that would never describe themselves as handling chemicals are, in fact, regularly transporting dangerous articles. A business that ships laptops containing lithium-ion batteries is transporting dangerous goods. A cleaning company that moves aerosol products between sites is transporting dangerous goods. A motor trade business that dispatches vehicle airbag modules is transporting dangerous goods. The article classification means that many goods that appear harmless in their packaged state are still subject to ADR requirements when transported.

The Nine Dangerous Goods Classes

The UN Model Regulations, and the ADR framework based on them, divide all dangerous goods into nine classes according to the primary type of hazard they present. These are the classes used by the transportation of dangerous goods regulatory system worldwide whether by road, sea, rail, or air.

Class Hazard Type Description UK Examples
Class 1 Explosives Substances or articles that can explode, deflagrate, or react rapidly to produce gas, heat, or light. Divided into six divisions (1.1–1.6) based on the type and scale of explosion risk. Fireworks, ammunition, detonators, signal flares, airbag inflators
Class 2 Gases Substances that are gaseous at 50°C or have a vapour pressure exceeding 300 kPa at 20°C. Divided into flammable gases (2.1), non-flammable non-toxic gases (2.2), and toxic gases (2.3). LPG, oxygen cylinders, aerosol cans, refrigerant gases, acetylene, carbon dioxide cartridges
Class 3 Flammable Liquids Liquids with a flash point of not more than 60°C, or liquids transported at elevated temperatures. The flash point — the temperature at which a liquid gives off enough vapour to ignite — is the key classification criterion. Petrol, diesel, solvents, paints, lacquers, alcohols, acetone, adhesives
Class 4 Flammable Solids Three subdivisions: 4.1 (flammable solids and self-reactive substances), 4.2 (substances liable to spontaneous combustion), and 4.3 (substances that emit flammable gases on contact with water). Matches, metal powders (aluminium, magnesium), calcium carbide, sodium metal
Class 5 Oxidising Substances & Organic Peroxides Class 5.1: substances that release oxygen and can cause or intensify fire in other materials. Class 5.2: organic peroxides that can decompose exothermically and may be explosive, flammable, or toxic. Hydrogen peroxide, ammonium nitrate, sodium hypochlorite (bleach), potassium permanganate
Class 6 Toxic & Infectious Substances Class 6.1: substances that can cause serious injury or death to human health through inhalation, ingestion, or skin contact. Class 6.2: infectious substances containing pathogens capable of causing disease in humans or animals. Pesticides, herbicides, industrial reagents, cyanides, biological specimens, medical waste
Class 7 Radioactive Material Substances containing radionuclides where both activity concentration and total activity exceed specified thresholds. Requires specialist licensing and transport provisions. Medical isotopes, nuclear material, radiography sources, smoke detector elements (in large quantities)
Class 8 Corrosive Substances Substances that, by chemical action, cause severe damage to living tissue or materially damage or destroy other goods or the means of transport. Assessed by their ability to damage skin and metal. Sulphuric acid, hydrochloric acid, sodium hydroxide (caustic soda), battery acid, industrial cleaning chemicals
Class 9 Miscellaneous Dangerous Goods Substances and articles that present a danger during transport but do not meet the criteria for any other class. This is a broad category that includes many modern commercial goods. Lithium batteries, dry ice, magnetised materials, elevated temperature substances, environmentally hazardous substances

A note on Class 4.3 — substances that emit flammable gases on contact with water:

This is one of the less well-known dangerous goods classifications but covers a range of substances that UK industrial businesses may handle regularly. Substances in Class 4.3, sometimes called “water-reactive” or “dangerous when wet” substances, react with moisture or water to emit flammable gases, creating a fire or explosion hazard. Examples include sodium metal, potassium, calcium carbide, and certain metal powders. If a specific chemical in your inventory reacts vigorously with water, check whether it falls into Class 4.3 before assuming it does not require ADR transport.

How Dangerous Goods Are Classified in Practice

The classification of a dangerous good follows a defined process based on the substance’s chemical and physical properties. For most common commercial substances, the classification has already been determined and published in the UN Dangerous Goods List, a comprehensive database that forms the core of ADR and its equivalents for other transport modes.

The UN Dangerous Goods List

The UN Dangerous Goods List assigns each classified substance or article a UN number, a four-digit code that uniquely identifies it, along with a proper shipping name, primary hazard class, any subsidiary risk class, packing group, and applicable special provisions. For example, UN 1263 covers paints and related products as a Class 3 flammable liquid, and UN 3480 covers lithium ion batteries as a Class 9 miscellaneous dangerous good.

If your substance appears in the UN Dangerous Goods List with a UN number, it is a classified dangerous good and must be transported in accordance with the requirements for that class and packing group.

Self-Classification

For substances not already listed in the UN Dangerous Goods List, for example, new chemical compounds or proprietary formulations, the manufacturer or supplier is responsible for determining whether the substance meets the classification criteria for any dangerous goods class. This process is called self-classification and involves testing the substance against the physical, chemical, and toxicological criteria set out in the UN Model Regulations and the ADR.

In practice, most UK businesses will be working with substances that have already been classified by their manufacturer or supplier. The classification information is communicated through the product’s Safety Data Sheet.

Mixtures and Preparations

Many commercial products are mixtures of substances rather than pure chemicals. Where a mixture contains one or more classified substances, the mixture itself may be classified as dangerous depending on the concentration of the hazardous component. 

What Dangerous Goods Classification Means for UK Transport

Once a substance or article has been classified as a dangerous good, the classification triggers a specific set of requirements for its transportation of dangerous goods by road in the UK under ADR.

These requirements are not optional, they are legal obligations that apply to everyone involved in the movement of the goods, including the sender, the carrier, and in some cases the recipient.

What is ADR Transport? The Complete UK Guide

ADR Transport Overview

If your business generates, ships, or receives chemical products, batteries, gases, or other potentially hazardous materials, you have almost certainly encountered the term “ADR” — or been told that your goods require ADR transport. This guide explains what ADR transport is, what it requires, which goods fall under it, and what the regulations mean for businesses in the UK.

1. What is ADR?

ADR is the international regulatory framework that governs the road transport of dangerous goods in the UK and across Europe. It sets out the rules that apply whenever a dangerous substance or article is moved by road — covering what can be transported, how it must be packaged and labelled, what documentation must accompany the goods, how the driver must be trained, and what equipment the vehicle must carry.

In practical terms, ADR is the reason a lorry carrying chemicals displays orange warning plates. It is the reason certain delivery drivers carry specific qualifications. It is the legal framework that determines how paints, solvents, batteries, gases, acids, and thousands of other common commercial substances must be transported by road to protect people, property, and the environment.

ADR is not a UK-specific rule — it is an international agreement used across Europe and beyond. But it has been incorporated into UK domestic law and continues to apply in Great Britain following the UK’s departure from the EU.

2. What Does ADR Stand For in Transport?

ADR stands for Accord Dangereux Routier — a French phrase meaning “Agreement on Dangerous Goods by Road.” Its full official name is the European Agreement Concerning the International Carriage of Dangerous Goods by Road.

The agreement was first established in 1957 under the auspices of the United Nations Economic Commission for Europe (UNECE). It was created to provide a consistent regulatory framework for the movement of dangerous goods by road across national borders in Europe — ensuring that a lorry carrying hazardous chemicals in France would be subject to the same rules as one crossing into Germany or the Netherlands.

ADR in full: Accord Dangereux Routier

Full English name: European Agreement Concerning the International Carriage of Dangerous Goods by Road

Origin: United Nations Economic Commission for Europe (UNECE), 1957

Updated: Every two years (even-numbered years)

Applies in UK via: The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (as amended)

Despite its name referencing “international carriage,” ADR applies to domestic road transport within the UK as well — not just cross-border movements. If you are moving dangerous goods from Birmingham to Leeds, the same ADR rules apply as if you were crossing from the UK into France.

ADR is updated every two years by UNECE, with each new edition incorporating changes to classifications, packaging requirements, and safety standards as chemical and battery technology evolves. The most recent updates have included significant changes to the rules for lithium battery transport, reflecting the rapid growth of electric vehicles and portable electronics.

3. How ADR Applies in the UK

Although ADR is a European agreement, it continues to apply in Great Britain following Brexit through the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG Regulations), as amended by subsequent legislation. These regulations incorporate the substantive requirements of ADR into UK domestic law.

In Northern Ireland, the position is slightly different — Northern Ireland continues to align more closely with the EU framework under the terms of the Windsor Framework, and the ADR regulations apply there as part of the UK-EU relationship for goods moving between Northern Ireland and the Republic of Ireland.

The Health and Safety Executive (HSE) is the primary competent authority for dangerous goods transport by road in Great Britain, alongside the Driver and Vehicle Standards Agency (DVSA). Both organisations have enforcement powers — the HSE primarily in relation to the wider regulatory framework, and the DVSA in relation to vehicles and drivers on the road.

Who enforces ADR in the UK?

The Health and Safety Executive (HSE) and the Driver and Vehicle Standards Agency (DVSA) are the primary enforcement bodies for ADR in Great Britain. DVSA officers can stop and inspect vehicles carrying dangerous goods, check driver ADR certificates, verify documentation, and prohibit vehicles from continuing if they are non-compliant. Penalties for ADR breaches include fixed penalty notices, prohibition notices, and prosecution — with unlimited fines and potential imprisonment for serious breaches.

4. What is ADR Transport — and When Does It Apply?

“ADR transport” is the term used to describe the road transport of goods that fall within the scope of the ADR regulations — that is, goods classified as dangerous under the ADR framework. If a substance or article has been assigned a UN number and an ADR hazard class, it requires ADR-compliant transport when moved by road.

This covers a far broader range of goods than most people expect. ADR transport is not just for tankers carrying industrial chemicals or lorries carrying explosive materials. It applies to enormous quantities of everyday commercial products that happen to be classified as hazardous under ADR:

  • Paints, varnishes, and lacquers (flammable liquids — Class 3)
  • Aerosol products including deodorants, sprays, and cleaning products (gases — Class 2)
  • Lithium-ion batteries in laptops, phones, power tools, and electric vehicles (Class 9)
  • Industrial cleaning chemicals including bleach, acids, and alkalis (corrosives — Class 8)
  • Pesticides and herbicides (toxic substances — Class 6)
  • Hydrogen peroxide above certain concentrations (oxidising substances — Class 5)
  • Solvents, fuels, and adhesives containing flammable liquids (Class 3)
  • Compressed gas cylinders including oxygen, LPG, and refrigerant gases (Class 2)

If your business manufactures, distributes, or uses any of these products — or generates them as waste — you are likely already involved in ADR transport, whether you realise it or not.

The key question: Does your product have a UN number?

The quickest way to determine whether a substance requires ADR transport is to check its Safety Data Sheet (SDS). Section 14 of every SDS contains the transport information — including the UN number, proper shipping name, and ADR hazard class. If Section 14 contains a UN number and a hazard class, the product requires ADR-compliant transport when moved by road.

5. The ADR Dangerous Goods Classes Explained

ADR divides dangerous goods into nine classes based on the primary hazard they present. Understanding which class your goods fall into is the starting point for understanding how they must be transported.

Class Hazard Type Common Examples
Class 1 Explosives Fireworks, ammunition, airbag inflators, detonators. Requires specialist licensing — not carried by most ADR operators.
Class 2 Gases LPG, aerosols, compressed gas cylinders, oxygen, acetylene, refrigerant gases.
Class 3 Flammable Liquids Petrol, solvents, paints, lacquers, alcohols, adhesives — one of the most common ADR classes in commercial transport.
Class 4 Flammable Solids Matches, metal powders, self-reactive substances, desensitised explosives, spontaneously combustible materials.
Class 5 Oxidising Substances & Organic Peroxides Hydrogen peroxide, ammonium nitrate, bleach, potassium permanganate, organic peroxides.
Class 6 Toxic & Infectious Substances Pesticides, herbicides, cyanides, industrial chemical reagents, biological substances, medical waste.
Class 7 Radioactive Material Radioactive isotopes, nuclear material. Requires specialist licensing and transport provisions — not carried by most ADR operators.
Class 8 Corrosive Substances Sulphuric acid, hydrochloric acid, sodium hydroxide, battery acid, industrial cleaning chemicals, electroplating solutions.
Class 9 Miscellaneous Dangerous Goods Lithium batteries, dry ice, magnetised materials, environmentally hazardous substances, EV batteries.

Some goods have more than one hazard — for example, a substance might be both flammable and toxic. In these cases, ADR assigns a primary class based on the dominant hazard and a subsidiary risk for the secondary hazard. Both must be communicated on the packaging and transport document.

Packing Groups

Within each class, dangerous goods are further subdivided into packing groups that reflect the degree of hazard:

  • Packing Group I (PG I) — high danger
  • Packing Group II (PG II) — medium danger
  • Packing Group III (PG III) — low danger

The packing group determines the packaging specification required for the goods. A substance in Packing Group I requires more robust, more tightly tested packaging than one in Packing Group III — even if they are in the same ADR class.

6. What ADR Transport Requires

ADR compliance is not a single certification or a single document — it is a set of interlocking requirements that cover every element of a dangerous goods movement. Here is what ADR transport requires in practice:

ADR Driver Certification

Every driver carrying dangerous goods by road must hold a valid ADR vocational training certificate (often called an ADR licence, though technically it is a certificate). The certificate is issued following training and examination by an approved body, and must be renewed every five years.

Importantly, ADR certificates are class-specific. A driver certified for Class 3 flammable liquids is not automatically authorised to carry Class 2 gases or Class 6 toxic substances without the relevant additional endorsement. The driver’s certificate must cover the class of the goods being transported.

UN-Approved Packaging

Dangerous goods must be packed in packaging that has been tested and certified to the relevant UN specification for the goods being transported. The outer packaging must display the UN mark — a series of codes indicating the packaging type, material, performance standard, and the goods it is approved for.

Inner packaging (where used) must protect the contents from leakage and damage. Liquids must be packed with absorbent material. Batteries must be individually protected against short-circuit. The packaging specification depends on the ADR class and packing group of the goods.

Correct Labelling and Marking

Outer packaging must display:

  • The UN number of the substance (e.g. UN 1263 for paints, UN 3480 for lithium-ion batteries)
  • The ADR hazard diamond — the class-specific hazard label indicating the primary hazard (and subsidiary risk label if applicable)
  • Orientation arrows on packages containing liquids
  • Additional marks required by the specific packing instruction (e.g. the lithium battery handling mark for UN 3480/3481)

Dangerous Goods Transport Document

Every ADR shipment must be accompanied by a Dangerous Goods Transport Document — a written record that travels with the goods from collection to delivery. It must include:

  • The UN number (in the format “UN XXXX”)
  • The proper shipping name of the goods
  • The ADR class and subsidiary risk (if any)
  • The packing group (where assigned)
  • The total quantity (by mass or volume)
  • The number and type of packages
  • The name and address of the consignor (sender) and consignee (recipient)

Written Instructions for the Driver

In addition to the transport document, the driver must carry written instructions in the cab of the vehicle at all times during transit. These instructions — specified by ADR in a standard format — tell the driver what actions to take in the event of an accident or emergency involving the dangerous goods being carried. A separate instruction sheet is required for each ADR class being transported.

Vehicle Equipment Requirements

ADR specifies minimum equipment requirements for all vehicles carrying dangerous goods. This includes:

  • One or more fire extinguishers of the appropriate type and rating for the goods being carried
  • Wheel chocks
  • Two self-standing warning signs (cones or reflective triangles)
  • Eye rinse liquid (for certain classes)
  • A high-visibility vest for each crew member
  • A torch (non-sparking for flammable goods)
  • Personal protective equipment appropriate to the goods being carried
  • A shovel, drain seal, and collecting container for liquid spills (for certain classes)

Vehicle Marking and Placarding

Vehicles carrying dangerous goods above certain quantities must display orange warning plates — rectangular orange panels displayed front and rear. For tankers and bulk loads, the orange plates include the hazard identification number and UN number. For package loads, plain orange plates are used. Vehicles may also need to display hazard diamond placards for the classes being carried.

7. ADR Limited Quantities and Excepted Quantities

Not every consignment of dangerous goods requires full ADR compliance. ADR provides two important exemption pathways for smaller quantities of certain substances — limited quantities and excepted quantities:

ADR Limited Quantities (LQ)

The limited quantities provision allows certain dangerous goods to be transported with significantly reduced ADR requirements when they are packed in small amounts per inner package, below the thresholds specified for each substance. The thresholds vary by substance — typically ranging from 0.5 litres to 5 litres per inner package for liquids, and 0.5kg to 5kg for solids.

Under the limited quantities provision, the sender does not need to complete a full Dangerous Goods Transport Document, the driver does not need an ADR certificate, and the vehicle does not need to display orange warning plates. However, the outer packaging must still be correctly marked with the limited quantity mark (a diamond-shaped mark with “Y” inside it, or the LQ mark), and the goods must be packed to the specified inner package limits.

Limited quantities transport is a practical option for many businesses that ship moderate amounts of paints, cleaning chemicals, aerosols, and other common commercial dangerous goods in retail-sized containers.

ADR Excepted Quantities (EQ)

The excepted quantities provision applies to even smaller amounts of certain dangerous goods — typically individual sample sizes or very small retail quantities. Under excepted quantities, the requirements are minimal: correct inner and outer packaging, a simple mark on the outer packaging, and basic record-keeping. No transport document, driver certification, or vehicle marking is required.

The quantity thresholds for excepted quantities are very low — typically between 1ml and 30ml for liquids per inner package, depending on the substance — and the provision does not apply to all dangerous goods classes. It is genuinely only appropriate for very small quantities.

Important: Limited quantities and excepted quantities are not full exemptions from ADR — they are reduced-requirement pathways. The goods are still classified as dangerous, and the sender still has obligations regarding packaging and marking. If you are unsure whether your consignment qualifies for limited quantities or excepted quantities, our team can advise before you ship.

8. Who is Responsible Under ADR?

One of the most commonly misunderstood aspects of ADR is the question of who bears legal responsibility for compliance. Many businesses assume that once they hand their goods to an ADR-certified carrier, their obligations end. This is not the case.

ADR places obligations on multiple parties involved in a dangerous goods movement:

The Consignor (Sender)

The consignor is responsible for correctly classifying the dangerous goods, using compliant packaging that meets the UN specification, applying the correct labels and UN number markings to the outer packaging, completing or providing accurate information for the Dangerous Goods Transport Document, and ensuring the goods are in a condition that is safe for transport. The consignor’s obligations exist whether or not they employ a DGSA — though a DGSA appointment is legally required for most consignors of dangerous goods.

The Carrier (Transport Operator)

The carrier is responsible for ensuring the driver holds the appropriate ADR certificate for the goods being carried, the vehicle meets ADR equipment requirements, the transport documentation is present and correct, the vehicle is correctly marked and placarded, and the written driver instructions are in the cab. The carrier must also have a DGSA appointed.

The Consignee (Recipient)

The consignee has an obligation not to refuse or delay acceptance of dangerous goods without good reason, as this could force the carrier to hold the goods in a non-compliant or unsafe situation. The consignee also becomes responsible for the goods from the point of delivery.

The Driver

The driver has personal legal obligations under ADR — including holding valid certification, following the written instructions, reporting incidents, and not continuing a journey if a dangerous situation exists. A driver who knowingly drives with non-compliant documentation, incorrect packaging, or without the correct ADR certificate commits a criminal offence regardless of what their employer instructs.

The key takeaway for businesses:

Booking an ADR-certified carrier does not absolve you of your own legal obligations as the sender. If you ship dangerous goods regularly — chemicals, batteries, aerosols, or any other ADR-classified substance — your business has its own ADR compliance requirements, including the obligation to appoint a DGSA. Our team can advise on consignor obligations as part of every booking.

9. ADR Transport vs Standard Courier — The Difference

A question we are regularly asked is: “Can I just use a standard courier for my goods?” The answer depends on whether those goods are classified as dangerous under ADR. If they are, the answer is no — and attempting to do so creates significant legal and commercial risk.

  Standard Courier ADR Certified Transport
Driver certification No ADR certificate required ADR certificate required — class specific
Vehicle equipment Standard delivery vehicle ADR-compliant fire suppression, spill kit, PPE, warning signs
Documentation Delivery note or waybill only Dangerous Goods Transport Document + written driver instructions
Packaging check Not checked for ADR compliance UN-approved packaging verified before collection
Vehicle marking No hazard plates or labels Orange warning plates and class placards as required
Legal status for dangerous goods Non-compliant — criminal offence Fully compliant with ADR regulations
Incident liability Significant — both sender and carrier exposed Managed through compliance — documentation provides protection

Standard parcel networks — including major national couriers — are not equipped to carry dangerous goods. Their terms and conditions typically prohibit the shipment of ADR-classified goods entirely. If dangerous goods are found in the network, they may be removed, destroyed, or both — and the sender faces liability for any consequences.