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ADR reliefs: limited quantities and the thousand-point rule

Two reliefs that cover most European fuel-container movements, and the obligations that survive both.

Dangerous goods labelling on palletised fuel containers
Below the threshold is not outside the rules.

Two reliefs in ADR do most of the work for anyone moving fuel containers around Europe: limited quantities, and the exemption at 1.1.3.6 that everyone calls the thousand-point rule. Both are widely misunderstood in the same direction, as blanket exemptions from dangerous goods law. Neither is.

The thousand-point rule, properly

ADR 1.1.3.6 relieves smaller loads from parts of the regime. It works on points rather than litres, because a litre of petrol and a litre of diesel are not equally hazardous. The calculation is quantity multiplied by a factor set by the substance’s transport category, and the relief applies below 1,000 points per transport unit.

FuelUN numberTransport categoryMultiplierApprox. limit for the relief
PetrolUN 12032× 3~333 litres
DieselUN 12023× 1~1,000 litres

Categories and multipliers come from the substance’s own entry in the dangerous goods list. Check the entry for what you actually ship rather than assuming the figures above transfer to another liquid.

In cans, that is roughly sixteen 20-litre cans of petrol, or fifty of diesel, before the relief stops applying. Which is why a van doing a rural refuelling round usually sits inside it and a pallet delivery usually does not.

What the relief does not do

This is the part that catches people. Below 1,000 points you do not need the ADR driver certificate, but you are not outside dangerous goods law. Obligations that remain include instruction under ADR 1.3 for everyone involved, correct UN-approved packaging, correct marking and labelling, a fire extinguisher on the vehicle, and the general duties of the consignor. The widespread belief that under the threshold nothing applies is wrong, and it is the version that produces roadside penalties.

Limited quantities

Limited quantities is a separate relief, for dangerous goods packed in small inner packagings below substance-specific thresholds. It brings simplified conditions: no ADR transport document required, packages marked with the LQ diamond, and a cap of 8 tonnes gross per transport unit.

For jerricans this matters less than people expect, because LQ works on small inner packagings and a 20-litre can is not one. It is the relief that governs retail-sized bottles of solvent, not field-sized fuel cans. Know which regime you are actually in before planning a shipment around the wrong one.

Empty is not the same as clean

An uncleaned container that has held a dangerous good remains regulated. It stays closed, stays marked, and travels under the rules until it has been cleaned and purged. New empty cans ship as ordinary cargo. The two must not be mixed in one consignment or under one document, and treating a used can as an empty one is a common and expensive error.

What this means for the packaging you buy

None of these reliefs change the packaging requirement. The can still has to be UN-approved for the substance and packing group, and that approval is granted per design type and per manufacturing plant. A relief on the transport side does not relieve the container. If your supplier moves production, the approval does not move with it.

Where to start

Your use caseRecommended canWhy this one
Petrol and diesel under ADR 20L NATO Steel Fuel Can20L NATO Steel Fuel Can UN-marked steel, coated for hydrocarbons.
Solvents and permeating liquids Fluorinated HDPE JerrycanFluorinated HDPE Jerrycan UN 3H1 route with a barrier treatment.
Flammables in classified areas Antistatic HDPE JerrycanAntistatic HDPE Jerrycan Static control where the atmosphere matters.
Keeping the approval valid Caps, Closures & GasketsCaps, Closures & Gaskets The closure is part of the approved design.

Common questions

What is the ADR thousand-point rule?

The exemption at ADR 1.1.3.6 for smaller loads. Points are quantity multiplied by a factor set by the substance transport category, and the relief applies below 1,000 points per transport unit. Petrol is category 2 with a multiplier of 3, so the relief runs out at about 333 litres; diesel is category 3 with a multiplier of 1, so about 1,000 litres.

Do I still need ADR training below the thousand-point threshold?

You do not need the full ADR driver certificate, but instruction under ADR 1.3 is still required for everyone involved. Correct UN-approved packaging, marking, labelling, a vehicle fire extinguisher and the consignor duties all continue to apply. Below the threshold is not outside dangerous goods law.

Does the limited quantities relief apply to 20 litre jerry cans?

Generally no. Limited quantities works on small inner packagings below substance-specific thresholds, which a 20 litre can is not. It governs retail-sized bottles rather than field-sized fuel containers. LQ shipments also carry the LQ diamond and cap at 8 tonnes gross per transport unit.

Do ADR reliefs change the packaging I have to use?

No. The container still has to be UN-approved for the substance and packing group, and that approval is granted per design type and per manufacturing plant. A relief on the transport side relieves nothing on the container side, and it does not travel if your supplier changes factory.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

Last reviewed .

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