How to calculate the ADR 1.1.3.6 exemption
The ADR 1.1.3.6 exemption is calculated by multiplying the packaged quantity of each transport category by its factor (50, 20, 3 or 1) and checking that the total on the transport unit does not exceed 1 000 points, a sum that DGAssistant performs as goods are added to the consignment. A load within that limit no longer needs placards, instructions in writing and other requirements, but the rest of ADR still applies and the transport document must show the figures.
Edition and provisions applied
This guide follows ADR 2025, whose transitional period ended on 30 June 2025 (1.6.1.1). The calculation is set out in sub-section 1.1.3.6, from 1.1.3.6.1 to 1.1.3.6.5. The category of each entry comes from column (15) of Table A of Chapter 3.2, and the duty to record the result comes from NOTE 1 to 5.4.1.1.1 (f). What stays in force is defined by reference to Chapter 1.10 and Parts 5, 7, 8 and 9, cited below where they apply. The full text is available in volume 1 and volume 2 of ADR 2025.
Step 1: read the transport category
Table A of Chapter 3.2 gives the transport category of every entry in column (15): the figure at the top of the cell is the category and the code in brackets below it is the tunnel restriction code. Read the entry instead of deducing the category from the packing group. UN 1824 SODIUM HYDROXIDE SOLUTION is category 2 in packing group II and category 3 in packing group III; UN 2810 TOXIC LIQUID, ORGANIC, N.O.S. remains in category 2 even in packing group III; and the entries of UN 1950 AEROSOLS range from category 1 to category 3 according to their classification code.
| Transport category | Goods it includes (examples) | Maximum per transport unit (kg or litres) | Factor in a mixed load |
|---|---|---|---|
| 0 | Class 4.2 substances of packing group I, hydrogen cyanide (UN 1051), polychlorinated biphenyls (UN 2315), infectious substances (UN 2814) | 0 | None: the exemption is not available |
| 1 | Packing group I goods outside category 0; Class 2 groups T, TC, TO, TF, TOC and TFC | 20 | × 50 |
| 1, note a to the table | UN 0081, 0082, 0084, 0241, 0331, 0332 and 0482 (Class 1), anhydrous ammonia (UN 1005) and chlorine (UN 1017) | 50 kg | × 20 |
| 2 | Packing group II goods outside categories 0, 1 and 4; Class 2 group F; Class 6.1 of packing group III; lithium batteries (UN 3090, 3091, 3480 and 3481) | 333 | × 3 |
| 3 | Packing group III goods outside categories 0, 2 and 4; Class 2 groups A and O; wet batteries filled with acid (UN 2794) | 1 000 | × 1 |
| 4 | Class 1 goods of 1.4S; UN 1361 and UN 1362 of packing group III; electrically initiated safety devices (UN 3268); empty uncleaned packagings outside category 0 | Unlimited | None: not counted |
Empty uncleaned packagings follow their last contents: those that held a category 0 substance remain in category 0, and all the others fall into category 4.
Step 2: measure the quantity as ADR requires
The figure that enters the calculation depends on what is being carried, and the gross mass of the package never plays a part.
| What is carried | Quantity to use |
|---|---|
| Liquids | Litres of dangerous goods contained |
| Solids, and liquefied, refrigerated liquefied or dissolved gases | Net mass in kilograms |
| Compressed gases, adsorbed gases and chemicals under pressure | Water capacity of the receptacle, in litres |
| Articles | Kilograms of articles without their packagings |
| Articles of Class 1 | Net mass in kilograms of the explosive substance |
| Dangerous goods in machinery or equipment specified in ADR | Total quantity they contain, in kilograms or litres as appropriate |
The formula makes no conversion between litres and kilograms: each quantity enters with its own figure.
Some goods are not counted (1.1.3.6.5): limited quantities carried under Chapter 3.4, excepted quantities under Chapter 3.5, goods released by a special provision of Chapter 3.3, empty uncleaned packagings whose hazards have been nullified (1.1.3.5), the gases of 1.1.3.2, the liquid fuels of 1.1.3.3, and the cases in 1.1.3.1 (a) and (d) to (f), 1.1.3.7, 1.1.3.9 and 1.1.3.10. Carriage under 1.1.3.1 (c), ancillary to the main activity of an enterprise, is not on that list, so it does count.
Step 3: apply the limit or the sum
When everything on the transport unit belongs to one category, compare the total with the maximum in the table. When categories are mixed, apply the sum of 1.1.3.6.4, in which each term is the quantity of that category:
(category 1 × 50) + (category 1, note a × 20) + (category 2 × 3) + (category 3 × 1) ≤ 1 000
ADR calls the result the calculated value, and in daily practice it is known as points. The two methods agree: each maximum in the table is equivalent to 1 000 (note b to the table). A total of exactly 1 000 still qualifies: only exceeding it is excluded.
Three conditions frame the calculation:
- It is made per transport unit, meaning a motor vehicle alone or with its trailer attached, and it takes in everything on board, not each consignment separately.
- It is reserved for goods in packages. The term includes IBCs, large packagings and gas receptacles but, radioactive material apart, not goods in bulk or substances in tanks (1.2.1).
- It is all or nothing. If the total goes over the limit, the whole load falls under total execution of ADR, that is, its full provisions, and not only the excess.
Three worked examples
Example 1: one category. A delivery van carries UN 1203 PETROL, 3, II, (D/E) in 20-litre jerricans. Column (15) gives category 2, so the maximum is 333 litres. Fifteen jerricans hold 300 litres, which amounts to 900 points, and the load is exempt. A sixteenth brings it to 320 litres and 960 points, still exempt. A seventeenth brings it to 340 litres, above the maximum, and the exemption is lost.
Example 2: several categories in one load. A chemical distributor loads the following goods on one vehicle.
| Goods | Category | Quantity | Factor | Points |
|---|---|---|---|---|
| UN 1155 DIETHYL ETHER (ETHYL ETHER), 3, I, (D/E) | 1 | 4 L | × 50 | 200 |
| UN 1090 ACETONE, 3, II, (D/E) | 2 | 100 L | × 3 | 300 |
| UN 1823 SODIUM HYDROXIDE, SOLID, 8, II, (E) | 2 | 50 kg | × 3 | 150 |
| UN 1824 SODIUM HYDROXIDE SOLUTION, 8, III, (E) | 3 | 200 L | × 1 | 200 |
| Empty uncleaned drums that held UN 1090 | 4 | 4 drums | None | 0 |
| Total | 850 |
The load is exempt. The table also shows how much the factors weigh: 4 litres of diethyl ether count as much as 200 litres of sodium hydroxide solution.
Example 3: gas cylinders above the limit. A supplier of welding gases loads the following cylinders.
| Goods | Category | How it is measured | Quantity | Factor | Points |
|---|---|---|---|---|---|
| UN 1072 OXYGEN, COMPRESSED, 2.2 (5.1), (E) | 3 | 8 cylinders of 50 L water capacity | 400 L | × 1 | 400 |
| UN 1001 ACETYLENE, DISSOLVED, 2.1, (B/D) | 2 | 4 cylinders of 8 kg net | 32 kg | × 3 | 96 |
| UN 1978 PROPANE, 2.1, (B/D) | 2 | 6 cylinders of 35 kg net | 210 kg | × 3 | 630 |
| Total | 1 126 |
With 1 126 points, the three products travel under total execution of ADR. Moving two propane cylinders to another transport unit leaves 140 kg (420 points) and a total of 916, so the remaining load is exempt. Oxygen counts by water capacity while acetylene and propane count by net mass: entering the mass of the oxygen would produce a wrong figure.
What the exemption lifts and what remains in force
Paragraph 1.1.3.6.2 works by listing what ceases to apply, so anything it does not mention stays in force.
| Requirement | Reference | Under the exemption |
|---|---|---|
| Placards and orange-coloured plates on the vehicle | Chapter 5.3 | Not required |
| Instructions in writing | Section 5.4.3 | Not required |
| ADR training certificate for the driver | 8.2.1 | Not required |
| Equipment for general and personal protection | 8.1.5 | Not required |
| Vehicle construction and approval | Part 9 | Not required |
| Ban on passengers; photo identification of the crew | 8.3.1; 8.1.2.1 (d) | Not required |
| Provisions on carriage in packages | Chapter 7.2 | Not required, except V5 and V8 of 7.2.4 |
| Security provisions | Chapter 1.10 | Not required, except for high consequence dangerous goods of Class 1 and for excepted packages of UN 2910 and UN 2911 above the A2 value |
| Tunnel restrictions | 1.9.5.3.6; 8.6.3.3 | Not applicable, unless the unit must display the limited quantity marking of 3.4.13, subject to 3.4.14 |
| Transport document in the cab | 5.4.1; 8.1.2.1 (a) | Required |
| One portable fire extinguisher for classes A, B and C, with at least 2 kg of dry powder or an equivalent, conforming to EN 3-7, sealed, with its inspection date in force and within easy reach of the crew | 8.1.4.2 to 8.1.4.5 | Required |
| Training suited to the duties of each person, drivers included | 8.2.3; Chapter 1.3 | Required |
| No opening of packages by the driver or the assistant; portable lighting without metal surfaces that can spark; no smoking or electronic cigarettes during handling | 8.3.3 to 8.3.5 | Required |
| Supervision of vehicles, when the goods carry S1(6), S14 to S21 or S24 | Chapters 8.4 and 8.5 | Required |
| Special provisions S1(3), S2(1), S4 and S5 | Chapter 8.5 | Required |
| Classification, permitted packagings, marks and labels on packages, mixed loading prohibition, handling and stowage | Parts 2 and 4; Chapters 5.2 and 7.5 | Required; of 7.5.11, only CV1 is lifted |
Two consequences are easily missed. UN 1017 CHLORINE carries S14, which requires supervision of the vehicle for any amount, so the exemption does not release it from that duty. The cylinders of Example 3 carry CV9, CV10 and CV36 in column (18), and all three keep applying: if a closed vehicle without ventilation has to be used, CV36 calls for preventing gas exchange with the cab and marking the cargo doors.
The obligation to appoint a safety adviser is handled separately. Under 1.8.3.2 (b) the competent authorities may dispense undertakings whose activities stay within these quantities, so the dispensation is not automatic and depends on national rules.
What the transport document must state
The exemption does not remove the transport document. Each entry keeps the particulars of 5.4.1.1.1, with (a), (b), (c), (d) and (k) in that order, and NOTE 1 to 5.4.1.1.1 (f) adds two figures for each transport category: the total quantity and the calculated value, obtained under 1.1.3.6.3 and 1.1.3.6.4. The note fixes the content, not a form of words. For Example 2, a clear statement would be:
- ADR 1.1.3.6 exemption
- Transport category 1: 4 L, calculated value 200
- Transport category 2: 100 L and 50 kg, calculated value 450
- Transport category 3: 200 L, calculated value 200
- Total calculated value: 850
The empty drums of that load may be described as EMPTY PACKAGING, 3, as 5.4.1.1.6.2.1 allows. The driver, the loader or an inspector can then verify on the spot why the load is exempt.
Frequent errors
- Calculating per consignment. Two consignments that are exempt on their own can exceed 1 000 points when they share a transport unit.
- Using the wrong quantity. Gross mass, or the nominal capacity of a drum that is only partly full, gives a false figure, and so does the mass of a compressed gas.
- Deducing the category from the packing group. Column (15) decides, as the cases of UN 2810 and UN 1950 show.
- Assuming category 0 is free because the sum has no factor for it. The table gives it a maximum of zero, so a transport unit carrying those goods should be treated as outside the exemption. The same applies to empty uncleaned packagings that held them.
- Applying the factor of 50 to UN 1005 or UN 1017. Note a gives them a factor of 20 and a cap of 50 kg.
- Extending the exemption to tanks or bulk. It covers goods in packages only.
- Reading the exemption as total. Labels, document, extinguisher and training all remain mandatory.
- Leaving the figures off the document. When 1.1.3.6 is to be applied, NOTE 1 to 5.4.1.1.1 (f) requires them.
- Counting the wrong goods. Limited quantities do not count; carriage under 1.1.3.1 (c) does.
- Not recalculating during the round. Goods collected on the way change what is on the transport unit and, with it, the total.
How DGAssistant resolves it
The ADR transport document function of DGAssistant groups the goods of a consignment by transport category, multiplies by the factors and, when the result allows it, applies the 1.1.3.6 exemption, with the points of each category and their total in view. The calculation runs while you work: each dangerous good added to the consignment updates the points per transport unit, and the application indicates the exemption level that results.
When the consignment stays below the limit, the transport document states the exemption with its exact total of points and shows the most restrictive tunnel restriction code among the goods loaded. It exports to PDF, Excel and Word.
When several consignments share a vehicle, the consolidation functions take the calculation to the whole transport movement by road and issue the ADR 1.1.3.6 exemption report, broken down by category and by consignment. If the load changes, the report is not issued until the calculation is repeated. The steps are in the manual section on transport movements.
To see the whole procedure, watch the ADR video tutorial or follow the ADR section of the manual. To prepare a document by hand, download the free ADR 2025 transport document template (Excel).