Transporting Dangerous Goods UK–EU: ADR, Documents, Driver and Adviser

Dangerous goods travel by road between the UK and the EU under the ADR agreement: the consignor classifies, packs and marks the load, the vehicle must carry a transport document with written emergency instructions, and the driver must hold ADR training. On top of that come a dangerous goods safety adviser (DGSA) and the separate rules of the ferry or tunnel operator, and the customs clearance itself does not replace any of these requirements.

Which rules govern the carriage of dangerous goods between the UK and the EU?

The basis is the ADR agreement (European Agreement concerning the International Carriage of Dangerous Goods by Road). According to GOV.UK it has been in force since 1968, is administered by the United Nations Economic Commission for Europe (UNECE) and is updated every 2 years. Annex A sets out how goods are classified, packaged, labelled and certified, and Annex B covers vehicle and tank requirements and operational rules.

Each country implements ADR through its own law. In Great Britain the legal framework is the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009), which, according to the HSE, implement ADR 2025 with some exceptions. In the EU, Directive 2008/68/EC applies; its Article 4 provides that transport between Member States and third countries (which, after Brexit, includes the United Kingdom) is authorised as long as it complies with ADR. In Poland the basis is the Act of 19 August 2011 on the carriage of dangerous goods.

Sea carriage is different: ADR covers the road leg, while a load on a ferry is also subject to the IMDG code (see below).

Dangerous goods classes and UN numbers

GOV.UK separates dangerous goods into classes that determine how they must be packaged and transported:

Class	Type of material
1	Explosive substances and articles
2.1 / 2.2 / 2.3	Flammable gas / non-flammable, non-toxic gas (including oxidisers) / toxic gas
3	Flammable liquids
4.1 / 4.2 / 4.3	Flammable solids and self-reactive substances / substances liable to spontaneous combustion / substances that emit flammable gases in contact with water
5.1 / 5.2	Oxidising substances / organic peroxides
6.1 / 6.2	Toxic substances / infectious substances
7	Radioactive material
8	Corrosive substances
9	Miscellaneous dangerous substances and articles

A specific substance or article is identified by its UN number, the United Nations identification number given to a substance or article in the dangerous goods list (part 3 of ADR). In a UK export declaration in CDS, the UN dangerous goods code (data element 6/12) has up to four characters; it is only required on a combined EXS and pre-departure declaration where a UN code applies to the goods, with one code per goods item (CDS Volume 3, group 6).

The consignor is responsible for classifying, packaging and marking the goods, as GOV.UK states plainly. So ask your supplier or manufacturer for the class and UN number before you book the transport.

Which documents must be in the vehicle?

According to GOV.UK, in addition to documents required under other regulations (for example CMR and customs documents), the transport unit must carry:

• a transport document with the information ADR prescribes for each substance, material or article (the information must be presented in a certain order and follow rules on language);
• written emergency instructions, in languages that every member of the crew understands; one set of instructions, based on a four-page model, covers all dangerous goods rather than individual products;
• means of identification, including a photograph, of each member of the vehicle crew.

The sender usually has to fill in a form describing the nature of the goods, and the form must travel with the load (GOV.UK: packaging, labelling and documentation). Packaging must be approved: in the UK, the Vehicle Certification Agency (VCA) is the certification authority for dangerous goods packaging.

If the carriage is made under a multilateral agreement (a derogation from ADR), you must carry a copy of that agreement in the vehicle.

Driver and vehicle: ADR training and inspection

According to GOV.UK, drivers of all vehicles carrying dangerous goods must have an ADR training certificate; exemptions apply to small loads below the thresholds, goods packed in limited quantities and goods packed in excepted quantities.

• United Kingdom: the driver takes training and exams and receives an ADR card showing which classes he or she may carry; the qualification lasts 5 years and further classes can be added through extra modules (GOV.UK: ADR driver).
• Poland: driving a vehicle carrying dangerous goods requires an ADR certificate where ADR requires driver training; the driver must be at least 21, complete a course and pass an exam (gov.pl).

Vehicles with tanks, and certain others (for example those carrying explosives), must pass a technical inspection and obtain an ADR certificate; in Great Britain DVSA issues a certificate valid for one year (GOV.UK).

Dangerous goods safety adviser (DGSA)

In the United Kingdom you must have a DGSA if you transport dangerous goods (GOV.UK) unless you do it only occasionally, you are only receiving the goods (the consignee), they are in limited quantities, you are moving them a very short distance by road (for example between buildings on an industrial estate) or you are using private vehicles. GOV.UK adds that you should employ one if you are transporting goods internationally, and the HSE notes that the GB exemptions do not apply to international carriage (HSE). A DGSA certificate is valid for 5 years and is mutually recognised by all contracting parties to ADR and RID.

In Poland, businesses involved in consigning, carrying, packing, loading, filling or unloading dangerous goods should appoint one or more safety advisers; exceptions are set out in the Act. The adviser certificate is issued by the Director of the Transport Technical Inspectorate (TDT) for 5 years from the date of passing the exam (gov.pl). The participant files an annual report by 28 February of the year following the reporting year (GITD).

Limited quantities: when the rules are lighter

For limited quantities you do not need to follow all the normal packaging and labelling regulations, and you do not need a DGSA. The goods must travel in small containers (for example bottles) packed in boxes or on shrink-wrapped trays; the maximum weight is 30 kg for boxes and 20 kg for shrink-wrapped trays, and the limit for an individual container depends on the goods and comes from column 7a of the dangerous goods list in part 3 of ADR. For some goods the limit is zero, which means they cannot be shipped as limited quantities (GOV.UK).

Channel Tunnel and ferries

Channel Tunnel (LeShuttle Freight)

According to the operator, carriage of dangerous goods through the tunnel is based on ADR, and the customer (usually the haulier) is responsible for making sure the driver has made a full dangerous goods declaration. Account holders do this online, providing among other things the UN number, the ADR references (class, packing group, classification code), the proper shipping name with volume or weight, packaging details and the net or gross quantity. At check-in the driver goes to the information centre, where paperwork is checked and the vehicle is inspected externally, and a “DG” sticker with a unique reference goes on the windscreen. Missing declarations or incorrect paperwork may cause delays or refusal to travel. For limited quantities a declaration is not required, and an uncleaned empty tanker is treated as full. The list of accepted and prohibited goods is in the operator’s policy, so check it before booking.

Ferries (IMDG)

For sea carriage you need to complete a dangerous goods notification, and the governing rules are the International Maritime Dangerous Goods (IMDG) code; in the UK it is given effect by the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 (GOV.UK, GOV.UK: driving abroad). The rules of a specific shipping line (for example accepted classes and notification deadline) are set by the carrier, so do not assume them — confirm them before booking.

Customs clearance and dangerous goods

Customs clearance and ADR are two separate areas. A customs declaration, an ENS or a GMR number does not replace the ADR transport document or the written instructions. On the other hand, the data on dangerous goods must be consistent across documents: the description, class and UN number in the declaration should match the transport documents. To sort out the remaining formalities before departure, see ENS and GMR.

Step by step: preparing the carriage

1. Classify the goods: ask the manufacturer for the safety data sheet and confirm the class and UN number.
2. Check whether it is a limited quantity or another ADR exemption (the column 7a limits).
3. Pack and mark in packaging approved for those goods.
4. Prepare the transport document and written emergency instructions in a language the crew understands.
5. Verify the driver and vehicle: valid ADR training and, where needed, a vehicle certificate.
6. Contact the carrier: the tunnel declaration or ferry notification, before the lorry sets off.
7. Lodge the customs and safety declarations with the UN code where required, and obtain the GMR.

Most common mistakes

• Assuming the quantity is “limited” without checking the limit for that UN number.
• A driver without valid ADR training, or with a class range that does not cover the load.
• No written instructions in the crew’s language.
• Not declaring the dangerous goods to the tunnel or ferry operator — delays or refusal to travel may follow.
• Treating an empty, uncleaned tanker as empty; according to the tunnel operator it counts as full.
• Differences in the description of the goods between the invoice, the transport document and the customs declaration.

Practical example

An illustrative case: a Polish company sends paint in unit packaging to the UK as a class 3 load (flammable liquids). First the supplier confirms the class and UN number, and the forwarder checks whether the quantity fits within the limited-quantity limit. If it does not, the full ADR set is needed: marked packaging, a transport document, written instructions and a trained driver. Then the haulier declares the load to the tunnel or ferry operator. Customs clearance comes last: the declaration with the commodity code and, where required, the UN number, plus the ENS and GMR.

When a customs agency helps

A customs agency does not replace an ADR adviser and does not classify substances. It helps with the customs part: declarations in CDS, ENS, GMR and documents for exports to the UK and clearance from the UK. If you import chemicals, see also importing household chemicals to the UK. Costs are covered on the page how much does customs clearance cost, and you can send an enquiry via the contact form. Customs agency registered in CDS, UK EORI number.

Frequently asked questions