ADR exemptions in 1.1.3.1 to 1.1.3.3
When ADR doesn’t apply at all to tradespeople, private individuals and the emergency services, with every limit from the text.
In this guide
A plumber with two gas cylinders in the van, a family with a can of petrol for the lawnmower, the fire service clearing up after a crash. All of them are carrying dangerous goods, and in many cases ADR doesn’t apply to them at all. The reason is the set of exemptions in ADR 1.1.3.1 to 1.1.3.3. This guide goes through what they allow and where they stop.
Private individuals: retail packaging, personal use
ADR doesn’t apply when private individuals carry dangerous goods that are packaged for retail sale and meant for personal or domestic use, or for leisure or sport. Measures must be in place to prevent any leakage in normal conditions of carriage (ADR 1.1.3.1 (a)(i)). A barbecue gas cylinder from the DIY shop or a box of aerosols for decorating both fall under this.
Flammable liquids in refillable receptacles filled by, or for, a private individual have a hard limit: 60 litres per receptacle and 240 litres per transport unit. Goods in IBCs, large packagings or tanks never count as packaged for retail sale (ADR 1.1.3.1 (a)(i)).
ADR 2025 added a second case. Private individuals can carry the same kind of goods, within the same limits, as waste, for example leftover paint going to the household recycling centre. This also covers goods that are no longer in their original retail packaging, as long as nothing can leak (ADR 1.1.3.1 (a)(ii)).
Businesses: carriage ancillary to the main activity
For companies, paragraph (c) matters most. ADR doesn’t apply to carriage that a business undertakes as ancillary to its main activity. The text gives examples: deliveries to or returns from building and civil engineering sites, and journeys for surveying, repairs and maintenance. Four conditions apply (ADR 1.1.3.1 (c)):
- no more than 450 litres per packaging, IBCs and large packagings included,
- within the maximum quantities in 1.1.3.6, so you work it out as you would for the 1,000 points rule. Transport category 0 has a maximum of 0 there, so those goods never qualify (ADR 1.1.3.6.3),
- measures taken to prevent any leakage,
- nothing from Class 7.
A roofer taking four 33 kg propane cylinders to a site carries 132 kg in transport category 2, which is 396 points. That stays under the limit, so ADR doesn’t apply to the journey.
The text expressly excludes carriage for the company’s own supply or for its internal or external distribution (ADR 1.1.3.1 (c)). Collecting cylinders from the supplier and taking them back to your own yard is supply. Paragraph (c) won’t cover that trip, which leaves the other exemptions, such as 1.1.3.6.
Paragraph (b): the old exemption for machinery and equipment has been deleted. A transitional provision kept it alive until 31 December 2022 (ADR 2021, 1.6.1.46), and since ADR 2023 that paragraph has been deleted as well. Such machinery now has its own UN numbers, for example UN 3363 or UN 3537–3548.
Emergency response and empty storage vessels
Three more paragraphs cover special situations (ADR 1.1.3.1 (d) to (f)):
- (d) Emergency response: carriage by the competent authorities, or under their supervision, where it’s needed for the emergency response. That mainly means breakdown vehicles recovering crashed or broken-down vehicles loaded with dangerous goods, and containing and recovering goods after an incident or accident, then moving them to the nearest appropriate safe place.
- (e) Saving lives: emergency transport to save human lives or protect the environment, provided every measure is taken to carry it out in complete safety.
- (f) Empty static storage vessels: uncleaned, if they last held Class 2 gases of group A, O or F, Class 3 or 9 substances of packing group II or III, or Class 6.1 pesticides of packing group II or III. All openings except pressure relief devices must be hermetically closed, and the load secured so it can’t come loose or shift. The exemption doesn’t apply to vessels that held desensitized explosives or substances ADR prohibits.
Fuel in the tank and gases: 1.1.3.2 and 1.1.3.3
Fuel that drives the vehicle, or runs equipment used during the journey such as a fridge unit, is outside ADR. It can be carried in fixed tanks or in portable containers such as jerrycans. The limits (ADR 1.1.3.3 (a)):
- fixed tanks: 1,500 litres in total per transport unit,
- a tank fitted to a trailer: 500 litres,
- portable fuel containers: 60 litres per transport unit,
- none of these limits apply to emergency service vehicles.
A spare can for your own lorry is exempt. A can of petrol for the generator on site is load, and comes under 1.1.3.1 (c) or 1.1.3.6.
Gases work in a similar way (ADR 1.1.3.2). Gas used as vehicle fuel is exempt as long as the total capacity of all fuel tanks and cylinders on the transport unit, liquid fuel tanks included, stays within 54,000 MJ energy equivalent. The ceiling is 1,080 kg of LNG or CNG and 2,250 litres of LPG. Also exempt:
- group A and O gases at no more than 200 kPa (2 bar) at 20 °C, provided they aren’t liquefied or refrigerated liquefied,
- gases in the vehicle’s own equipment such as fire extinguishers, and in spare parts such as inflated tyres, including tyres carried as load,
- gases in the vehicle’s refrigeration or heating equipment, with spare receptacles,
- gases in food and fizzy drinks (except UN 1950) and in sports balls.
How this differs from LQ, EQ and 1,000 points
The exemptions in 1.1.3.1 to 1.1.3.3 are total: ADR simply doesn’t apply to that journey. No orange plates, no transport document, no ADR training certificate. The other exemptions are partial and come with their own duties:
| Provision | What it covers |
|---|---|
| 1.1.3.4 | special provisions in column (6), limited quantities (LQ) and excepted quantities (EQ) |
| 1.1.3.5 | uncleaned empty packagings, once any hazards have been eliminated |
| 1.1.3.6 | small quantities per transport unit; the transport document and fire extinguisher still apply |
If none of these total exemptions fits, ADR applies. At most, the partial exemptions in 1.1.3.4 to 1.1.3.6 can still help. Typical cases: the business is delivering to customers, a packaging holds more than 450 litres, the goods are Class 7, or a private individual fills a 100-litre container with petrol or buys stock to sell on.
Practise exemption questions
In the exam, exemptions nearly always come up as a scenario: who is driving, what’s on board, how much, and why. Check those four things in order and you’ll land on the right provision.
In the free test you get an explanation and the ADR reference after every answer. The app has more questions on exemptions and quantity limits.
Sources
ADR 2025 (UNECE English text): sub-sections 1.1.3.1 to 1.1.3.6. Transitional provision 1.6.1.46 as worded in ADR 2021, deleted since ADR 2023. In Great Britain, the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 apply ADR and allow national derogations (HSE guidance on ADR and the CDG Regulations; Department for Transport, “Carriage of dangerous goods: approved derogations, transitional provisions and exceptions”), which are not covered here. This guide explains the basics. For an actual load, the wording of ADR is what counts.
Updated: 3 October 2026