6.1 The Dangerous Goods Transport Document (ADR 5.4.1)

The Dangerous Goods Transport Document (ADR 5.4.1)

Core Regulatory Principle: Under ADR 5.4.1 and ADR 1.4.2.1.1(b), dangerous goods may not be accepted for carriage unless accompanied by a legally compliant Dangerous Goods Transport Document. The consignor bears the primary statutory duty to generate and furnish this document to the carrier before the vehicle departs.

Statutory Purpose of the Dangerous Goods Transport Document

The dangerous goods transport document—frequently termed a Dangerous Goods Note (DGN) or consignment note—is the foundational legal and operational record in dangerous goods road freight. In contrast to standard commercial bills of lading or waybills, the ADR transport document fulfills critical safety and regulatory functions:

1. Hazard Communication to Vehicle Crew: Informs the driver and crew of the exact chemical hazards, physical properties, packaging types, and gross quantities loaded on the transport unit.
2. Emergency Responder Information: Provides police, fire brigades, and chemical response units with unequivocal, standardized data during roadside emergencies, collisions, or chemical spills.
3. Regulatory Verification: Enables competent roadside enforcement authorities to cross-examine cargo manifests against vehicle placarding, orange-coloured plates, driver training certifications, and stowage compliance.

The document may take the form of a dedicated dangerous goods note or be incorporated into an existing transport document, such as a CMR consignment note, provided all mandatory information prescribed under ADR Chapter 5.4 is present and formatted in accordance with statutory sequence rules.

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Mandatory Standardized Information Sequence (ADR 5.4.1.1.1)

To prevent confusion across international borders and emergency situations, ADR 5.4.1.1.1 strictly dictates the sequence of core dangerous goods information. This core sequence is non-negotiable: no extraneous elements, abbreviations, or commentary may be interspersed within these items.

The mandatory sequence consists of the following consecutive elements:

1. UN Number: The four-digit serial number preceded immediately by the capital letters "UN" (e.g., UN 1090, UN 1203, UN 1993).
2. Proper Shipping Name (PSN): The official chemical or generic name specified in Table A (Column 2). When a substance is assigned to a generic or Not Otherwise Specified (N.O.S.) entry subject to Special Provision 274, the PSN must be supplemented with the technical or chemical name of the hazardous constituent enclosed in parentheses (e.g., FLAMMABLE LIQUID, N.O.S. (contains toluene and acetone)). Commercial brand names or registered trademarks are strictly forbidden from substituting for technical names.
3. Primary Hazard Class: The primary class number assigned under ADR Part 2 (e.g., 3, 6.1, 8). For Class 1, the division and compatibility group letter must be stated (e.g., 1.1D).
4. Subsidiary Hazard Class(es): Any secondary hazard class numbers must be enclosed in parentheses immediately following the primary class (e.g., (6.1), (8)). If there is no subsidiary risk, this element is omitted.
5. Packing Group: The assigned packing group represented by Roman numerals I, II, or III, optionally preceded by the initials "PG" (e.g., PG II or II). As established under Part 2, substances belonging to Classes 1, 2, 5.2, 6.2, and 7 do not utilize packing groups and this entry is omitted for those classes.
6. Tunnel Restriction Code: The tunnel category code in capital letters enclosed in parentheses, as listed in Table A (Column 15), reflecting restrictions through road tunnels (e.g., (D/E), (C/D), (E)). It need not be added where it is known beforehand that carriage will not pass through a tunnel with dangerous-goods restrictions. A dash signifies no ADR tunnel restriction for that entry, subject to specified special-arrangement cases.

Standardized String Examples

• Single Substance with Subsidiary Hazard:
  UN 1230 METHANOL, 3 (6.1), PG II, (D/E)
• Generic N.O.S. Entry with Technical Name:
  UN 1992 FLAMMABLE LIQUID, TOXIC, N.O.S. (contains methanol), 3 (6.1), PG II, (D/E)
• Corrosive Substance Without Subsidiary Hazard:
  UN 1789 HYDROCHLORIC ACID, 8, PG II, (E)
• Class 2 Gas (No Packing Group):
  UN 1965 HYDROCARBON GAS MIXTURE, LIQUEFIED, N.O.S., 2.1, (B/D)

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Additional Mandatory Consignment Information

Beyond the standardized core hazard line, ADR 5.4.1.1.1 requires the transport document to state comprehensive operational information:

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Special Required Declarations and Notations

Specific transport situations trigger mandatory statutory declarations under ADR Chapter 5.4:

1. Environmentally Hazardous Substances (ADR 5.4.1.1.18)

When a consignment of dangerous goods meets the aquatic environmental hazard criteria of ADR 2.2.9.1.10, the transport document must include the additional statement, where 5.4.1.1.18 requires it:
"ENVIRONMENTALLY HAZARDOUS"
This additional statement is not required for UN 3077/3082 or the exceptions expressly listed in 5.4.1.1.18.

(For combined multimodal journeys involving maritime transit, the notation "MARINE POLLUTANT/ENVIRONMENTALLY HAZARDOUS" is accepted under ADR 5.4.1.1.18).

2. Waste Consignments (ADR 5.4.1.1.3)

If dangerous goods are being transported as chemical waste under the classification provisions of ADR 2.1.3.5.5, the Proper Shipping Name must be preceded by the word "WASTE", unless this term is already part of the official PSN.
Example: UN 1230 WASTE METHANOL, 3 (6.1), PG II, (D/E)

3. Empty Uncleaned Packagings and Tanks (ADR 5.4.1.1.6)

Receptacles, packagings, intermediate bulk containers (IBCs), and tanks that have not been decontaminated or purged retain flammable vapours or toxic chemical residues and present acute hazards. The transport document must declare their status:

• For empty packagings: "EMPTY PACKAGING", "EMPTY RECEPTACLE", or "EMPTY IBC", followed by the hazard class of the last loaded substance (e.g., EMPTY PACKAGING, 3).
• For empty uncleaned tank-vehicles, portable tanks, or battery-vehicles: "EMPTY TANK-VEHICLE, LAST LOAD: UN 1203 MOTOR SPIRIT, 3, PG II, (D/E)".

4. Small Load Calculation Note Under ADR 1.1.3.6

When a consignment qualifies for exemption from full ADR rules under the 1,000-point rule, the transport document must state the total points calculated for each transport category and verify that the aggregate threshold is not exceeded.
Example Entry: Transport category 2: 240 L; calculated value 720. Record each transport category’s total quantity and calculated value; a single aggregate number without the category quantities is insufficient.

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Language Requirements and Record Retention

Under ADR 5.4.1.4.1, the transport document must be drafted in an official language of the forwarding country. Furthermore, if that language is not English, French, or German, the document must also be provided in English, French, or German for international transport operations.

Under ADR 5.4.4, both the consignor and the carrier have an explicit legal obligation to retain copies of dangerous goods transport documents, along with any supplemental documentation, for a minimum period of three months following the completion of carriage. Records may be archived in electronic or paper format, provided they can be retrieved immediately during regulatory audits or official investigations.

Source check: 17 October 2026 — ADR 2025, English text published by the Slovak Ministry of Transport, 5.4.1 and 5.4.4.