ADR 1000 points rule: the 1.1.3.6 small load exemption, with worked examples

A load of dangerous goods in packages escapes a large part of ADR if its calculated value does not exceed 1000. Multiply the category 1 quantity by 50 (by 20 for the note a entries), category 2 by 3 and category 3 by 1. Category 4 does not count. Category 0 always rules the exemption out.

This is ADR 1.1.3.6, in the 2025 edition applicable from 1 January 2025, and it reads the same in every country that is party to the agreement. Drivers and traffic offices call it the 1000 points rule. Below is the category table, then three mixed loads worked out by hand, using UN numbers you see on vans every week.

Where 1000 comes from

Every dangerous substance or article has a transport category from 0 to 4. You find it in column (15) of Table A in Chapter 3.2 (1.1.3.6.1). The exemption covers goods in packages only: tanks and bulk stay outside it (1.1.3.6.2).

If the whole load is in one category, the table in 1.1.3.6.3 gives the maximum per transport unit: 20 for category 1, 333 for category 2, 1000 for category 3. Category 0 has a maximum of zero. Category 4 has no limit.

Mixed loads fall under 1.1.3.6.4. Each quantity is multiplied by its factor, and the sum “shall not exceed a calculated value of “1 000”“. The factors are built to match: 20 × 50 is 1000, 333 × 3 is 999. Note b to the table says so in plain words.

The transport category table

Category	Maximum if the whole load is in this category	Factor in a mixed load	Examples from column (15)
0	0	none, exemption ruled out	UN 2215 maleic anhydride, molten; Class 4.2 packing group I; UN 3343; empty uncleaned packagings that held category 0 goods
1	20	× 50	packing group I not in category 0: UN 1263 paint PG I, UN 1993 PG I; toxic or corrosive aerosols (UN 1950, codes 5T, 5C)
1, note a	50 kg	× 20	UN 0081, 0082, 0084, 0241, 0331, 0332, 0482, UN 1005 anhydrous ammonia, UN 1017 chlorine
2	333	× 3	packing group II: UN 1203 petrol, UN 1090 acetone, UN 1823 solid sodium hydroxide; group F gases: UN 1965, 1978 propane, 1011 butane, 1001 acetylene; lithium batteries UN 3480 and 3090
3	1000	× 1	packing group III: UN 1202 diesel, UN 1223 kerosene; group A and O gases: UN 1072 compressed oxygen, UN 1066 nitrogen, UN 1013 carbon dioxide; UN 2794 lead-acid batteries
4	unlimited	left out of the sum	UN 1944 safety matches, Class 1 1.4S, empty uncleaned packagings other than category 0 ones

Note a deserves its own paragraph. For nine UN numbers, anhydrous ammonia and chlorine among them, the maximum per transport unit is 50 kg and the mixed-load factor is 20, not 50. The arithmetic holds again: 50 × 20 = 1000. Use 50 on these entries and you inflate the value, possibly giving up an exemption you were entitled to.

At the two ends the text is blunt. Category 0 has a maximum of zero, so one package is enough to lose 1.1.3.6 for the whole load. Category 4 is simply absent from the sum in 1.1.3.6.4, which names categories 1, 2 and 3 only.

Empty uncleaned packagings have their own rule. If they held goods of a category other than 0, they go into category 4. If they held category 0 goods, they stay in category 0, except UN 2908.

What goes into the formula

The text right after the table in 1.1.3.6.3 defines quantity, type by type.

Type of goods	What you count	Unit
Liquids	quantity of goods contained	litres
Solids	net mass	kg
Liquefied, refrigerated liquefied and dissolved gases	net mass	kg
Compressed gases, adsorbed gases, chemicals under pressure	water capacity of the receptacle	litres
Articles	mass of the articles without packaging	kg
Class 1 articles	net mass of explosive substance	kg
Goods in machinery and equipment	quantity contained	kg or litres

For liquids the text says “the total quantity of dangerous goods contained in litres”. So you count the goods, not the drum. A drum holding 200 litres counts 200, whatever its capacity.

Acetylene trips people up. A UN 1001 cylinder looks like a compressed gas, yet ADR treats it as a dissolved gas: you count the net mass of acetylene in kg, not the water capacity. Compressed oxygen, UN 1072, works the other way round. There you count litres of water capacity.

Kilograms and litres are added as they are. The text provides no conversion.

What stays out of the count

Under 1.1.3.6.5, goods already exempted elsewhere in 1.1.3 are not counted. In practice:

• the vehicle’s own fuel, in its tanks and up to 60 litres in portable containers per transport unit (1.1.3.3);
• gases in equipment used to run the vehicle, such as fire extinguishers and tyres (1.1.3.2 d);
• batteries that power the vehicle (1.1.3.7);
• limited quantities and excepted quantities (1.1.3.4);
• empty uncleaned packagings exempted by 1.1.3.5.

One trap. Carriage by undertakings ancillary to their main activity, 1.1.3.1 (c), is missing from that list. What a plumber or a maintenance crew takes to site therefore counts, and 1.1.3.1 (c) itself requires staying within the 1.1.3.6 quantities.

Three mixed loads, worked by hand

Diesel, caustic soda and acetylene

Two hundred litres of UN 1202 diesel in drums, category 3: 200. Twenty kg of UN 1823 solid sodium hydroxide, packing group II, category 2: 20. Two UN 1001 acetylene cylinders, category 2, with 6 kg of gas each: 12 kg. The 6 kg per cylinder is our assumption for the example. The real figure comes from the supplier.

Sum: 200 × 1 + (20 + 12) × 3 = 200 + 96 = 296. Well below 1000, so the exemption applies.

The maintenance van

Three hundred kg of UN 1823 (category 2), 60 litres of UN 1263 paint, packing group II (category 2), one UN 1072 compressed oxygen cylinder with 50 litres of water capacity (category 3).

Sum: (300 + 60) × 3 + 50 = 1080 + 50 = 1130. Over 1000. No exemption: full ADR applies.

With 250 kg of caustic soda instead of 300: (250 + 60) × 3 + 50 = 930 + 50 = 980. Leaving 50 kg behind is enough.

LPG, diesel, a packing group I liquid and matches

Ten UN 1965 cylinders with 15 kg of gas each, category 2: 150 kg. Four hundred litres of UN 1202 diesel, category 3: 400. Two litres of UN 1993 flammable liquid, packing group I, category 1: 2. Five kg of UN 1944 safety matches, category 4: outside the sum.

Sum: 2 × 50 + 150 × 3 + 400 = 100 + 450 + 400 = 950. Exempt, with little room. The diesel in the truck’s tank stays out (1.1.3.3).

A variant using note a: 30 kg of UN 1005 anhydrous ammonia plus 300 litres of diesel. Sum: 30 × 20 + 300 = 900. Fine, as long as the ammonia alone stays within 50 kg per transport unit.

What to do in practice

Read the right row of Table A, not just the UN number. UN 1263 paint sits in category 1, 2 or 3 depending on packing group, and UN 1170 ethanol moves from 2 to 3. Pick the wrong row and the factor changes threefold, or fiftyfold.

Keep a margin. A load at 950 becomes 1010 with twenty kg of category 2 added at the last minute.

Damaged lithium batteries are a separate case: special provision 677 assigns to category 0 the cells and batteries that special provision 376 identifies as damaged or defective and liable to react dangerously, flame or give off dangerous gases under normal conditions of carriage.

Write the figures on the transport document. ADR asks for the total quantity and calculated value per transport category (5.4.1.1.1 (f), Note 1). What else stays mandatory on board is in our piece on what you still need under the ADR small load exemption. To run the numbers without pen and paper, use the ADR exemption calculator: it also drafts the text for the transport document.

A national note for Italy. The decree of the Ministry of Infrastructure and Transport of 13 February 2025 (Gazzetta Ufficiale no. 65, 19 March 2025) points Italian law to ADR as applicable from 1 January 2025, so 1.1.3.6 works the same way on domestic Italian journeys.

What this article does not cover. Specific cases: for loads close to the limit, goods with special provisions or lithium batteries, talk to a dangerous goods safety adviser. How to count aerosols (UN 1950) and gas cartridges (UN 2037), where the text we read is not explicit. National derogations and penalties, which we have not examined. Text read: the English ADR 2025 published by UNECE. General information, not legal advice.