ADR reliefs: limited quantities and the thousand-point rule

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 known as the thousand-point rule. Neither is a blanket exemption from dangerous goods law, though both are widely treated as one.

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 a mixed load qualifies up to 1,000 points per transport unit. A load in a single transport category is tested on its quantity against that category’s maximum instead, so 333 litres of petrol passes and 333.2 does not. Our ADR 1,000-point calculator applies both tests to a whole vehicle.

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.

Sitting inside the relief changes which routes you can take. Loads carried under 1.1.3.6 are exempt from the ADR tunnel restrictions, and both petrol and diesel carry the tunnel code D/E. Above the threshold, a category E tunnel is closed to the load in packages and the diversion can add serious distance on an alpine or a long bored-tunnel route. The points calculation therefore decides a journey time as well as a paperwork burden.

Excepted quantities, the third relief

Alongside limited quantities and the thousand-point rule sits a third and much narrower relief: excepted quantities, marked EQ. It covers very small amounts in inner packagings well below the LQ thresholds, with its own marking and its own inner and outer limits per package.

EQ volumes are laboratory and sample scale, not container scale, so a jerrican never travels under it. If a forwarder raises EQ in a conversation about 20-litre cans, the conversation has gone wrong somewhere.

The dangerous goods list carries the codes. Petrol at UN 1203 is excepted quantity code E2 and diesel at UN 1202 is E1, and the codes cap the inner packaging at millilitres. Nothing in that range is a container in the sense this site uses the word.

Two reliefs that are not about quantity at all

Alongside the quantity reliefs sit two in ADR 1.1.3.1 that turn on who is carrying and why. Dangerous goods packaged for retail sale and carried by private individuals for personal or domestic use, leisure or sport fall outside ADR, provided leakage is prevented. For flammable liquids in refillable containers, the load must also stay within 60 litres per container and 240 litres per transport unit. That is the provision that covers a member of the public buying a jerry can and filling it. It says nothing about a business, and it does not travel with the goods once a company is moving them.

The second is the one trade customers rely on without naming it: carriage by an enterprise ancillary to its main activity, such as a contractor taking fuel to its own site plant. It is capped at 450 litres per packaging and the 1.1.3.6 totals, it does not cover supply or distribution rounds, and inside those limits ADR does not apply provided leakage is prevented. A supplier asked whether a customer "needs ADR" is usually being asked about this provision. It removes ADR only inside narrow limits, and most trade loads fall back on the 1.1.3.6 threshold.

Mixed loads add up

The thousand points are counted across the transport unit, not per substance. Carry petrol and a Class 8 corrosive on the same vehicle and the points from each are summed against the same limit, each at its own transport category multiplier.

This case breaks the relief. A van carrying a modest amount of several different substances can pass 1,000 points while no single item looks anywhere near it. The driver is then operating outside the exemption without anything on board looking unusual. Total the load, not the line items.

What the relief does not do

Up to 1,000 points you do not need the ADR driver certificate, but you are not outside dangerous goods law. Obligations that remain include:

• a transport document carried in the cab;
• instruction under ADR 1.3 for everyone involved;
• correct UN-approved packaging;
• correct marking and labelling;
• a 2 kg fire extinguisher on the vehicle;
• the general duties of the consignor.

In Great Britain, road derogation 2 lets classes 2 to 6, 8 and 9 leave the document off the vehicle under the threshold. The widespread belief that under the threshold nothing applies is wrong, and it is the version that produces roadside penalties.

The belief survives because the relief removes the visible things: no orange plates, no placards, no driver certificate to produce. A vehicle stopped under the threshold looks like an ordinary van and is treated as one until somebody looks in the back. An enforcement officer who opens the load checks the packaging, the marking and the paperwork.

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 the LQ mark on the vehicle once more than 8 tonnes gross travels on a transport unit over 12 tonnes.

The reason is a single number in the dangerous goods list. The limited quantity value for petrol at UN 1203 is 1 litre per inner packaging, and for diesel at UN 1202 it is 5 litres. Those are inner-packaging caps, so a 20 or 25-litre can is outside the relief by an order of magnitude and no amount of outer packaging changes it.

Limited quantities is therefore the regime for a case of one-litre bottles on a retail pallet, not for the format this site builds. The relief looks attractive on paper, comes up in most freight conversations and costs time to rule out. For a jerrican load the relief that applies is the 1.1.3.6 threshold above.

Does a limited quantity need UN packaging?

A limited quantity needs no UN-marked or design-tested packaging. It still needs sound packaging: ADR 2025, 3.4.1, keeps the general packing rules of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8 and the construction requirements of 6.1.4. It leaves out 4.1.1.3, the paragraph that calls for a design type tested under Chapter 6.1.

The box and the bottles must:

• survive normal handling;
• stay closed as the maker instructs;
• resist the contents;
• leave room for expansion.

Nobody has to drop-test them or print a UN code on them.

The package rules sit in 3.4.2 to 3.4.4. Goods travel only in inner packagings placed in an outer packaging, with intermediate packagings allowed, and the package may weigh no more than 30 kg gross. A shrink-wrapped or stretch-wrapped tray can serve as the outer up to 20 kg gross, with breakable inners held in an intermediate packaging. The quantity cap applies to each inner packaging and comes from column (7a) of Table A in ADR 2025: 1 litre for petrol, 5 litres for diesel and for solvent paint at UN 1263, packing group II. A 0 in that column rules the entry out, and no entry allows more than 5 litres or 5 kg. Our UN number packaging finder gives the figure for common UN numbers.

Air tests the package. IATA describes a limited quantity box as combination packaging built to the same criteria as UN specification packaging, with testing as the difference. The package must pass a 1.2 m drop and a 24-hour stacking test, so an ordinary carton will not do. 49 CFR 173.27(f)(2) puts the same tests into US law. On US roads, 49 CFR 173.150(b) frees a Class 3 limited quantity from specification packaging when it travels as inner packagings in a strong outer packaging of 30 kg (66 lb) gross or less.

On the road, limited quantities also drop out of the points. ADR 1.1.3.6.5 leaves goods exempted under 1.1.3.4, the gateway to Chapter 3.4, out of the 1,000-point sum, so leave limited-quantity cartons out when you run the 1,000-point calculator. The duties that remain are short: training under Chapter 1.3, the mark, orientation arrows on combination packages with liquid inners (5.2.1.10), and a note to the carrier of the total gross mass, in a traceable form, before carriage (3.4.12).

Limited quantity label size, colours and the Y mark

ADR calls the limited quantity label a mark: a square set at 45°, with black top and bottom portions and a black border around a white or contrasting centre. It must be at least 100 mm by 100 mm with a border line at least 2 mm wide (ADR 2025, 3.4.7.1). If the size of the package requires it, the mark may shrink to 50 mm by 50 mm with a 1 mm line, provided it stays visible (3.4.7.2). The IMDG Code (3.4.5.1) and 49 CFR 172.315(a) set the same design and sizes, so one printed diamond serves road, sea and US ground. A 2026 US amendment lets a shipper print a mark of at least 25 mm on the package shipping label, except by air, by international vessel or for radioactive material (172.315(a)(2)(iii)). Vehicles and containers that need a mark use the same design at 250 mm by 250 mm or more (ADR 3.4.15; IMDG 3.4.5.5.4).

The Y mark is the same diamond with a black letter Y in the centre. It certifies that the package meets the air rules for limited quantities in Part 3, Chapter 4 of the ICAO Technical Instructions (ADR 3.4.8.1). A Y-marked package is accepted by road and sea without the plain mark (ADR 3.4.9; IMDG 3.4.5.3.1). The plain mark does not work the other way. ADR 3.4.7.1 applies it to every mode except air, and US law requires the Y on every air limited quantity, with the whole mark on one side of the package (172.315(b)). A carton packed and tested to the air rules can carry the Y and travel by road and sea on the same mark. One packed to ADR alone carries the plain mark and stays on the road and at sea.

Overpacks follow the same logic. If the marks on the packages inside are hidden, the overpack carries the LQ mark and the word OVERPACK in letters at least 12 mm high (ADR 3.4.11; IMDG 3.4.5.4).

Limited quantities by sea, air and US ground

Every mode uses the same idea: small inner packagings, a package of 30 kg gross at most and a diamond mark. The inner limits drop by air, and the paperwork changes by mode. The table follows petrol, UN 1203, through each set of rules.

By air the limits fall and the list narrows. Limited quantities follow the Y-prefixed packing instructions in the IATA list, which applies the ICAO Technical Instructions; petrol’s is Y341. Only goods permitted on passenger aircraft qualify, and packing group I flammable liquids are excluded (49 CFR 173.27(f)(2)). For packing group III flammable liquids, Table 3 of 173.27(f) allows 5 litres per metal or plastic inner and 10 litres per package. Limited quantities can fly inside those limits, as tested packages with the Y mark. IATA and IMDG rules for air and sea covers the fully regulated route.

At sea the IMDG Code follows ADR on packing and marks, and adds three rules. Every limited quantity is stowage category A (3.4.3). The segregation rules of chapters 7.2 to 7.7 do not apply to stowing limited-quantity packages (3.4.4.2). A container holding only limited quantities carries the 250 mm mark on the outside whatever its load (3.4.5.5.1). In the US, the Class 3 inner limits are 0.5 litre for packing group I, 1.0 litre for II and 5.0 litres for III (173.150(b)). Other classes have their own exception sections, listed in column 8A of the Hazardous Materials Table and covered in our guide to US hazmat shipping.

None of these routes takes a filled jerrican. ADR’s largest inner allowance is 5 litres, and petrol stops at 1 litre by road, by sea and on US roads. A 20 litre can of petrol or diesel therefore travels in a UN-approved can, outside the limited quantity rules. It goes under or above the 1.1.3.6 threshold by road, as dangerous goods transport sets out, and, for petrol, on a cargo aircraft only. UN specification packaging explains that can’s mark, and packing groups why petrol is group II and diesel group III.

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. Keep the two apart in your stock and your paperwork, because treating a used can as an empty one is a common and expensive error. A drained can sits in transport category 4, so it adds nothing to the 1,000 points, but it still travels closed and marked.

The rule turns on cleaning and purging rather than on emptiness, and the two are different operations. Draining removes the liquid and leaves the vapour, which is both the hazard and the reason the classification persists. So a can drained at the end of a job and loaded straight onto a return pallet is carrying dangerous goods, and the consignment it joins is a dangerous-goods consignment whatever the rest of the pallet holds.

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, made under quality assurance the competent authority accepts. A relief on the transport side does not relieve the container. If your supplier moves production, the approval does not follow it until the authority accepts the new plant.

Ask two questions at enquiry, before any switch. Which certificate covers the design I am buying, and has the authority accepted the plant that will make it? What happens to my order if that plant cannot run it? A supplier with a real answer names a second accepted plant or admits there is a qualification period. One without an answer will move the order quietly and let the marking travel with the drawing rather than with the certificate.

Where to start

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 a mixed load qualifies up to 1,000 points per transport unit. A load in one category is tested on its quantity: petrol is category 2, so it runs out at 333 litres; diesel is category 3, so 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. A transport document, correct UN-approved packaging, marking, labelling, a 2 kg 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?

No. The limited quantity cap applies to each inner packaging, and ADR 2025 Table A, column (7a), sets it at 1 litre for petrol (UN 1203) and 5 litres for diesel (UN 1202). A can holding 20 litres of either is 4 to 20 times over the limit.

The can travels in UN-approved packaging, under or above the 1.1.3.6 threshold. LQ packages carry the LQ diamond, and a transport unit over 12 tonnes carrying more than 8 tonnes gross of them shows the mark front and rear.

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, made under quality assurance the competent authority accepts. A relief on the transport side relieves nothing on the container side, and the approval does not follow a change of factory until the authority accepts the new plant.

Is a limited quantity still classed as dangerous goods?

Yes. A limited quantity is a dangerous good shipped under a relief, so its classification, UN number and training duties stay. ADR 2025, 3.4.1, keeps Part 2 on classification, Chapters 3.1 to 3.3 and the training in Chapter 1.3, and the IMDG Code keeps the same parts at sea (3.4.1.2).

What goes is most of the paperwork, labelling and vehicle rules, which is why the term is often mistaken for an exemption from the rules.

Do limited quantities need shipping papers or a dangerous goods declaration?

Not by road in Europe: ADR 3.4.1 does not keep the transport document of 5.4.1, though the consignor must tell the carrier the total gross mass in a traceable form before carriage (3.4.12). At sea, yes: the IMDG Code keeps Chapter 5.4 and adds "limited quantity" or "LTD QTY" to the description (3.4.6.1).

In the US a limited quantity needs a shipping paper only by aircraft or vessel, or as a hazardous substance, hazardous waste or marine pollutant (49 CFR 173.150(b), 172.200(b)(3)).

Does a limited quantity shipment need placards or orange plates?

No. ADR does not apply orange-plate marking to limited quantities. Instead, a transport unit over 12 tonnes maximum mass carrying more than 8 tonnes gross of them shows the 250 mm LQ mark front and rear (ADR 3.4.13 to 3.4.15).

Orange plates required for other goods on board may replace it. A sea container holding only limited quantities is not placarded but carries the LQ mark outside (IMDG 3.4.5.5.1). US placarding does not apply to a marked limited quantity (49 CFR 172.500(b)(2)).

Does a limited quantity package need hazard labels?

Not by road or sea. ADR 3.4.1 and the IMDG Code (3.4.1.2) leave the labelling rules out, so the LQ diamond stands in for the class label, and in the US 49 CFR 173.150(b) excepts Class 3 limited quantities from labels.

Air is the exception: US rules require hazard labels on a limited quantity that travels by aircraft, as well as the Y mark and the UN number and proper shipping name (173.27(f)(2), 172.315(b)).

What is the difference between fully regulated and limited quantity?

A fully regulated package uses UN-approved packaging tested for its packing group, carries the UN number, proper shipping name and hazard labels, and travels with a transport document. A limited quantity packs small inner packagings, each within the column (7a) limit, in a strong outer of 30 kg gross at most, and shows the LQ diamond in place of most of that. A 20 litre can of petrol is fully regulated; the same petrol in 1 litre cans in a carton can be a limited quantity.

What are examples of limited quantity shipments?

Retail and trade packs below their column (7a) limit: a carton of 1 litre cans of petrol for small engines (UN 1203, 1 litre limit). A box of 5 litre tins of solvent paint (UN 1263, packing group II, 5 litres) is another.

A case of aerosols (UN 1950, 1 litre) or of 5 litre cans of diesel (UN 1202) qualifies too. Each package stays at or under 30 kg gross and carries the LQ diamond. A filled 20 litre jerrican of either fuel never qualifies.

How do Canada’s TDG Regulations treat limited quantities?

Much like ADR. Section 1.17 of the Transportation of Dangerous Goods Regulations makes goods a limited quantity when each inner quantity is within column 6(a) of Schedule 1 and the outer weighs 30 kg gross or less. If each package carries the square-on-point mark, at least 100 mm a side or 50 mm on a small package, with a Y allowed for packages meeting the ICAO rules, Parts 3 to 8 and 17 do not apply. That lifts documents, marks, containment rules, training, emergency plans, reporting and site registration.

How much fuel can you transport legally?

ADR governs road carriage in Great Britain and Europe. Under it, a private individual may carry up to 60 litres of petrol or diesel per refillable container and 240 litres per vehicle for personal use, if nothing leaks (ADR 1.1.3.1(a)).

A business in UN-approved packaging gets relief up to 1,000 points: 333 litres of petrol or 1,000 litres of diesel per transport unit (1.1.3.6). Other countries set their own limits.

What is transport category 2 or 3 under ADR?

They are two of the five bands that set the small-load limit at ADR 1.1.3.6: transport category 2 allows up to 333 litres or kilograms per transport unit, and category 3 up to 1,000. Category 2 takes most packing group II substances, such as petrol, and category 3 most packing group III substances, such as diesel.

Column (15) of ADR Table A gives each entry's category. Category 0 gets no relief, category 1 stops at 20 and category 4 has no limit.

Do excepted quantities need UN-approved packaging?

No. Dangerous goods in excepted quantities need no UN-marked packaging, but ADR 3.5.2 still sets the build. A resistant inner packaging, of plastic at least 0.2 mm thick for liquids, is cushioned in an intermediate packaging with absorbent for the whole contents.

Both go inside a strong rigid outer. The finished package must pass 1.8 m drops and a 24-hour stacking load (ADR 3.5.3). The amounts are small: code E1 allows 30 ml of liquid per inner packaging and 1 litre per package.

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.

• ADR: Agreement concerning the International Carriage of Dangerous Goods by Road (UNECE)
• UNECE ADR 3.4: dangerous goods packed in limited quantities
• UN Model Regulations on the Transport of Dangerous Goods (Rev. 24)
• IMO: IMDG Code for dangerous goods at sea
• IATA Dangerous Goods Regulations
• 49 CFR 173.150: exceptions for Class 3, including limited quantities and combustible liquids
• BAM DGG-Info: UN 1203 Motor spirit under the IMDG Code, Amendment 42-24, stowage category, EmS, segregation, limited quantity and marine pollutant data
• BAM DGG-Info: UN 1203 Motor spirit under the ICAO Technical Instructions 2025-2026, packing instructions Y341, 353 and 364, labels and air segregation
• 49 CFR 172.315: limited quantity marking, including the reduced-size mark on shipping labels
• 49 CFR 173.27: general requirements for transportation by aircraft, including the pressure differential
• 49 CFR part 172, subpart C: shipping papers, 172.200 to 172.205, including the basic description, retention and the shipper’s certification
• 49 CFR part 172, subpart F: placarding, including 172.500 exceptions and the 172.504 tables and 454 kg exception
• Transportation of Dangerous Goods Regulations (Canada), SOR/2001-286, section 1.17: limited quantities (text current to 30 September 2026)

First published 12 August 2026

Last reviewed 26 October 2026 by David Guru, Co-Founder & Business Development Director. How we review our guides Fortitude21 makes and sells liquid containers; our guides carry no affiliate links.