The ADR 1000-point rule: calculation under 1.1.3.6 and remaining duties

150 litres of petrol and 400 litres of diesel in suitable packaging produce an ADR calculation of 850 points. Provided the conditions of subsection 1.1.3.6 are met, that load can travel with exemptions from certain requirements, including orange plates on the transport unit. The goods retain their dangerous goods classification, however, and packaging, documentation, staff training and safe loading still matter.

When arranging dangerous goods transport, check the entire vehicle load rather than a single booking. This guide explains how the points are calculated, works through a practical fuel example and identifies what must be ready before the vehicle arrives. The calculation follows ADR 2025, subsections 1.1.3.6.3 and 1.1.3.6.4. 

What the quantity exemption covers

The 1000-point rule is the common name for an exemption linked to the quantity of dangerous goods carried per transport unit. For goods in one transport category, use the limit in table 1.1.3.6.3. For a combination of categories, apply the calculation in 1.1.3.6.4.

This mechanism covers carriage in packages. Depending on the substance, permitted packaging may include drums, jerricans, boxes or IBCs. Carriage in tanks or in bulk does not qualify merely because the quantity is small. When planning packaged cargo delivery, establish the permitted packaging and method of carriage before assessing the quantity.

A transport unit is a motor vehicle on its own or a motor vehicle with a trailer or semi-trailer. Count the relevant goods throughout that unit, including consignments from different senders. There is no separate allowance for each pallet, CMR, customer or compartment. 

Transport categories and measurement units

For each item, establish the UN number, proper shipping name, class, packing group where assigned, and transport category. Section 14 of the Safety Data Sheet or SDS often provides the starting information, which must be checked against the relevant entry in Table A of ADR Chapter 3.2. The transport category appears in column 15.

Hazard class, packing group and transport category are different characteristics. In the example below, both petrol and diesel belong to Class 3 but have different transport categories.

* The measurement depends on the goods. For liquids, use the actual quantity contained, in litres. For solids, liquefied gases, refrigerated liquefied gases and dissolved gases, use net mass in kilograms. For compressed gases, adsorbed gases and chemicals under pressure, use the water capacity of the receptacles in litres. Articles have separate rules in 1.1.3.6.3, generally based on their mass without packaging. Do not automatically use a pallet’s gross weight.

** The Category 1 exception applies to UN 0081, 0082, 0084, 0241, 0331, 0332, 0482, 1005 and 1017, as listed in note a to table 1.1.3.6.3. Category 4 does not mean that the goods cease to be dangerous or that all other applicable requirements disappear. 

If the vehicle carries only Category 2 goods, use the table’s limit of 333. Do not replace it with a rounded result obtained by dividing 1000 by 3.

Worked example of an 850-point load

Consider a shipment containing: 150 litres of petrol, UN 1203, Class 3, Packing Group II, and 400 litres of diesel, UN 1202, Class 3, Packing Group III. For this example, the petrol is in one suitable drum and the diesel is in two drums containing 200 litres each. The packaging must be permitted for the substance, in good condition and closed in accordance with ADR.

The calculation is 150 × 3 + 400 × 1 = 850 points. This is below 1000, so the mixed-load quantity condition is met. The result is a calculated value: 850 points does not mean 850 kg or 850 litres. The table explains the arithmetic and does not replace a dangerous goods transport document.

Adding another 50 litres of the same petrol at the next collection brings the total to 1000. ADR permits a value that does not exceed the threshold, so exactly 1000 is acceptable if all other conditions are met. An additional 51 litres produces 1003 points, making this exemption unavailable for the resulting load.

The calculation remains valid only while the composition and quantity match the information used. A total of 850 alone does not establish that packaging is suitable, goods are compatible or the driver is prepared.

Requirements disapplied by 1.1.3.6

Where the exemption is validly used, Chapter 5.3 orange plates and transport-unit marking, the ADR instructions in writing under 5.4.3, and the driver training certificate under 8.2.1 are not required. Part 9 requirements are also disapplied. The full list of exemptions and exceptions is set out in 1.1.3.6.2. 

This can allow curtain-sided road transport where the vehicle is suitable and the remaining requirements are satisfied. The absence of a driver-certificate requirement does not remove training duties, and the absence of orange plates does not remove hazard labels from packages.

“Transport without an ADR licence” is therefore an unsuitable blanket promise. A driver training certificate, vehicle approval and the carrier’s operating licence are separate matters. For international road freight, national requirements, market-access rules and route restrictions must be checked separately. Subsection 1.1.3.6 does not replace that assessment.

Duties that remain in force

Packaging and package marking

Use packaging permitted by the applicable packing instruction, in the required condition, with appropriate closures and filling limits. Apply UN numbers, hazard labels and additional marks under the relevant provisions of Chapter 5.2. When an overpack is used, check whether the package markings remain visible and whether they need to be reproduced.

Packaging intended for non-dangerous products does not become suitable for a dangerous substance simply because the quantity is small. The exemption does not permit damaged packaging or concealed classification.

The transport document and category totals

The ADR dangerous goods transport document is still required under the baseline ADR provisions. It must contain the particulars required by 5.4.1, including the goods description, quantities, packages, consignor and consignee, together with other applicable entries. When using 1.1.3.6, show both the total quantity and calculated value for each transport category, as required by note 1 to 5.4.1.1.1(f).

For this example, record Category 2: 150 litres and 450 points; Category 3: 400 litres and 400 points. Writing only “850 points in total” is insufficient. An SDS supports the preparation of information but does not replace the transport document. 

Staff training and the fire extinguisher

Training under Chapter 1.3 and section 8.2.3 remains mandatory, appropriate to the driver’s duties and those of other personnel involved. Keep training records in accordance with 1.3.3. The absence of a requirement for the special certificate is not permission to use an untrained driver.

The transport unit needs a portable extinguisher suitable for Class A, B and C fires, with a minimum capacity of 2 kg of dry powder or an equivalent quantity of another suitable extinguishing agent. Check the seal, inspection validity and accessibility; provisions 8.1.4.2–8.1.4.5 apply.

Loading and crew conduct

Applicable mixed-loading, stowage and securing requirements in Chapter 7.5 remain. Drivers and their assistants may not open packages containing dangerous goods. Requirements for portable lighting and the prohibition on smoking, including electronic cigarettes during handling operations in the locations specified by ADR, also remain applicable.

Certain goods retain special conditions such as temperature control, ventilation or supervision. Dangerous goods safety adviser requirements and any national exemptions need separate assessment: Chapter 1.8 is not automatically disapplied. Some explosive and radioactive goods are subject to additional limitations on the exemption. 

Groupage transport and additional collections

In groupage transport, an individual consignment may meet the threshold while the combined load exceeds it. Reassess the transport unit’s current load after each additional collection. Separate consignment notes do not justify independent calculations for goods travelling on the same unit.

When arranging cargo consolidation, agree who gathers the consignors’ information, calculates the total and checks changes to the load. Dividing the paperwork into two shipments is insufficient if both consignments remain on the same vehicle.

LQ and EQ are separate mechanisms under Chapters 3.4 and 3.5. This article addresses only 1.1.3.6. Goods may be left out of the calculation under another exemption only after all conditions of that exemption have been checked; a small carton alone proves nothing.

Information needed to arrange the shipment

Provide the SDS, description and classification of each item, actual quantities in the correct units, package numbers and types, photographs of markings, and gross weight and dimensions for vehicle selection. Include the route, cargo-ready date and special loading conditions. Our guide to the information needed for an international freight quotation covers the wider booking details.

Save Pro Solutions can help agree the delivery option and loading requirements. Giving verified categories and calculations is more useful than describing a shipment simply as “ADR below 1000 points”: it allows the consignment to be assessed alongside the other goods and the transport to be prepared on agreed terms.