The ADR 1.1.3.6 exemption: how to calculate 1000 points per transport unit

In brief

• Every dangerous product has a transport category from 0 to 4, given in column (15) of Table A in Chapter 3.2 of ADR.
• The sum: quantity of category 1 × 50, quantity of category 2 × 3, quantity of category 3 × 1. Category 4 has no limit, category 0 rules out the exemption.
• If the sum does not exceed 1000, carriage in packages does not require orange-coloured plates, instructions in writing or an ADR driver certificate, among other things.
• These still apply: classification, packagings, marking of packages, the transport document, a 2 kg fire extinguisher, Chapter 1.3 training and the prohibitions in Chapter 8.3.

How does the ADR 1.1.3.6 exemption work?

ADR 1.1.3.6 says that if the quantity of dangerous goods in one transport unit does not exceed the limit, they may be carried in packages without applying some of the provisions. A transport unit is a motor vehicle without a trailer or a combination of a vehicle and a trailer. The limit therefore applies to the whole combination, not to one customer or one order.

In practice, this exemption is used by technical gas cylinder services, paint wholesalers delivering by van, workshops and construction companies. A correctly calculated exemption saves money. A miscalculated one usually comes to light at a roadside check by the Polish Road Transport Inspection (ITD), when a vehicle without plates and without a certified driver is carrying a load above the limit.

The exemption covers packages only: drums, jerrycans, cylinders, cartons, IBCs. Carriage in tanks or in bulk is subject to the full ADR requirements, even for a few litres.

Table: transport categories and multipliers

You will find the transport category in Table A of Chapter 3.2 of ADR, column (15). It is the digit before the tunnel restriction code in brackets, for example "2 (D/E)". The maximum quantities and multipliers are given in 1.1.3.6.3 and 1.1.3.6.4:

All the limits correspond to a calculated value of 1000. With one category you can therefore compare the quantity directly with the limit, and with several categories you calculate the sum using the multipliers and compare it with 1000.

Category 0 includes, among others, class 4.2 substances in packing group I, some substances of classes 6.1, 6.2 and 7, and empty uncleaned packagings that contained such substances. Empty uncleaned packagings that contained substances of other categories fall into category 4 (1.1.3.6.1).

A change from 2027

Under the amendments to ADR due to enter into force on 1 January 2027 (UNECE document ECE/TRANS/WP.15/274), the multiplier of 20 for the UN numbers in footnote a will disappear from 1.1.3.6.4. A transitional provision, however, allows the existing footnote and multiplier to be used until 31 December 2030. The categories, limits and multipliers of 50, 3 and 1 remain unchanged.

What to count: litres, kilograms or cylinder capacity?

This is where companies most often get it wrong. "Quantity" in 1.1.3.6 depends on the type of goods (explanation below table 1.1.3.6.3):

In practice, this means a 50-litre cylinder of compressed nitrogen is 50 points of category 3, whatever its pressure. A propane cylinder counts by the mass of the gas, not the capacity of the cylinder. An acetylene cylinder is a dissolved gas, so net mass counts there too.

Three worked examples

The quantities in the examples are illustrative. The transport categories come from Table A of ADR 2025.

Example 1: a technical gas cylinder service

The result is below 1000, so the exemption applies. The same van with 20 oxygen cylinders of 50 l would already have 1000 points from oxygen alone, and any further product would exceed the limit.

Example 2: a paint wholesaler

That is 20 points over. Moving one jerrycan of adhesive to the next trip or reducing the paint by 20 litres brings the load within the exemption. These decisions are made when the order is picked, not in a lay-by during an inspection.

Example 3: a service company with batteries and empty chemical packagings

Empty uncleaned packagings add no points if they contained substances of a category other than 0. However, they must be closed and marked in the same way as full packagings.

The 1.1.3.6 points calculator

Add every product in the transport unit, choose the category and enter the quantity in the unit from the table above. If you give a UN number from the list of common goods, the category fills in automatically.

What still applies despite the 1.1.3.6 exemption

The exemption disapplies only the provisions listed in 1.1.3.6.2. You do not then apply, among others, Chapter 1.10 (security, apart from exceptions for classes 1 and 7), Chapter 5.3 (orange-coloured plates and placards on the vehicle), section 5.4.3 (instructions in writing), most of Part 8 and all of Part 9.

Everything else applies. In practice, the pre-departure checklist looks like this:

• correct classification and packagings approved for the goods,
• marks and danger labels on every package,
• a transport document with the total quantity and the calculated value for each transport category (Note 1 to 5.4.1.1.1 (f)),
• at least one portable fire extinguisher with 2 kg of powder for fire classes A, B and C (8.1.4.2), with a seal and a current inspection date,
• a driver trained under Chapter 1.3 (8.2.3), no opening of packages, portable lighting without sparking metal surfaces and no smoking during handling (8.3.3-8.3.5),
• the mixed loading prohibitions of Chapter 7.5 and load securing.

Most common mistakes when counting 1000 points

The same errors keep coming up in audits:

• counting the gross mass of packages instead of litres of liquid or net mass,
• counting compressed gas cylinders by mass rather than water capacity,
• leaving out the trailer, although the combination is one transport unit,
• using the exemption for carriage in tanks or in bulk,
• no calculated value in the transport document,
• taking the category from the safety data sheet or from memory rather than column (15) of Table A,
• adding LQ cartons, which under 1.1.3.6.5 do not count, so that the company gives up the exemption for no reason.

A separate problem is a product whose packing group changes after a change of formula. Paint in packing group II has category 2, the same paint in packing group III has category 3. The same litre then weighs three times as much in the calculation. Check the safety data sheet and the classification every time the supplier changes.

If you carry dangerous goods regularly, the 1.1.3.6 exemption also matters for the duty to appoint an adviser, because Polish law exempts only companies that stay within the limits every time. There is more on this in my article does your company need a DGSA. Vehicles above the limit need plates: I explain how to read them in my article on the ADR orange plate.

Legal basis: ADR 2025 (Polish text: Dz.U. 2025 item 642): 1.1.3.6.1-1.1.3.6.5, 1.1.3.4, the definition of transport unit in 1.2.1, Note 1 to 5.4.1.1.1 (f), 8.1.2.1, 8.1.4.2-8.1.4.5, 8.2.3, 8.3.3-8.3.5, Table A in Chapter 3.2 (column 15). ADR 2027 amendments: ECE/TRANS/WP.15/274.

If you want to be sure your typical loads fall within the exemption, I can prepare a list of categories for your whole product range and a calculation template for the transport document as part of an ADR audit. For regular carriage above the limit, a DGSA will take care of it.