ADR small load exemption 1.1.3.6: what you still need on board and what you don’t

Below the 1000 points of ADR 1.1.3.6 you still carry a transport document showing quantity and calculated value per category, plus one portable fire extinguisher of at least 2 kg. The driver needs training under Chapter 1.3. Orange plates, instructions in writing, the ADR driver certificate and the 8.1.5 kit are not required.

The list of what drops away is in 1.1.3.6.2 of ADR 2025. Anything not on that list keeps applying, and that is where many get it wrong: exempt does not mean outside ADR. How to work out the points is covered in our guide to the ADR 1000 points rule.

One condition first. The exemption only covers goods carried in packages. Tanks and bulk stay outside it.

Needed, not needed

Item	Under the 1.1.3.6 exemption	ADR 2025 reference
Transport document covering all dangerous goods	needed	8.1.2.1 (a), 5.4.1
Total quantity and calculated value per category on the document	needed	5.4.1.1.1 (f), Note 1
Portable A, B, C extinguisher, at least 2 kg	needed	8.1.4.2
Training in line with Chapter 1.3, driver included	needed	8.2.3
Ban on opening packages	applies	8.3.3
Portable lighting with no metal surface that could spark	applies	8.3.4
No smoking, e-cigarettes included	applies	8.3.5
Supervision when parked, only for goods with S1(6) or S14 to S24	applies	Chapter 8.4
Orange plates and placards	not needed	Chapter 5.3 lifted
Instructions in writing	not needed	5.4.3 lifted
Two extinguishers, 4 to 12 kg in total depending on mass, from the 8.1.4.1 table	not needed	replaced by 8.1.4.2
Wheel chock, warning signs, eye rinsing liquid, vest, lamp, gloves, eye protection, escape mask	not needed	8.1.5 lifted
ADR driver training certificate	not needed	8.2.1 lifted
Certificate of approval and vehicle construction rules	not needed	Part 9 lifted

The transport document

This is the obligation people forget most. Under 8.1.2.1 (a) the vehicle must carry “The transport documents prescribed in 5.4.1, covering all the dangerous goods carried”. Note 1 to 5.4.1.1.1 (f) adds that, where 1.1.3.6 is applied, “the total quantity and the calculated value of dangerous goods for each transport category shall be indicated in the transport document”.

Take the first load from our other article: 200 litres of diesel, 20 kg of caustic soda, 12 kg of acetylene. The document would show, for example: category 2, quantity 32, value 96; category 3, quantity 200, value 200; total calculated value 296.

The extinguisher

One, not two. Portable, suitable for fire classes A, B and C, with at least 2 kg of dry powder, or an equivalent capacity if another agent is used (8.1.4.2).

The general extinguisher rules still apply on top. It has to be suitable for use on a vehicle and meet EN 3-7 (8.1.4.3), be sealed and marked with its next inspection date (8.1.4.4), and sit within easy reach. And “During carriage, the date required in 8.1.4.4 shall not have expired” (8.1.4.5). An extinguisher a month out of date is the classic finding on vans that carry ADR goods only now and then.

Training

The ADR certificate is not needed, because 8.2.1 is not among the exceptions. Chapter 1.3 training is. Section 8.2.3 requires it from people involved in the carriage, including “drivers of vehicles other than drivers holding a certificate in accordance with 8.2.1”. That covers the van driver as much as the warehouse staff: 8.2.3 names consignor personnel and “personnel who load or unload dangerous goods” explicitly, and 1.3.1 already sets the same rule for everyone else whose duties concern the carriage.

On the road

Driver and assistant may not open packages of dangerous goods (8.3.3). Portable lamps used around the load must not have metal surfaces that could produce sparks (8.3.4). No smoking during handling operations near the vehicle or inside it, and the ban extends to electronic cigarettes (8.3.5).

Chapter 8.4 supervision of parked vehicles only bites for goods that show S1(6) or S14 to S24 in column (19) of Table A.

Chapter 1.10 on security is lifted, except for high consequence Class 1 goods and Class 7 excepted packages UN 2910 and 2911 above the A2 value. Chapter 7.2 does not apply apart from V5 and V8. Neither does CV1 in 7.5.11.

What stays by exclusion

1.1.3.6.2 does not mention classification, packagings, package marks and labels (Chapter 5.2), Chapter 1.3 training, safety obligations of participants (Chapter 1.4), or loading and stowage under Chapter 7.5. So they remain. This is a reading by exclusion. We have not re-read each of those chapters line by line.

Before you leave the yard

Three checks. The document lists every dangerous good, with quantity and value per category. The 2 kg extinguisher is on board, sealed, in date. The driver has had Chapter 1.3 training, and the employer keeps the training record, to be shown on request (1.3.3).

Cross 1000 points and the picture flips: plates, instructions in writing, the full kit, the certificate. To check the sum before loading, use the ADR exemption calculator.

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 these rules also cover domestic Italian journeys.

What this article does not cover. Specific cases, which call for a dangerous goods safety adviser, starting with passengers on board and use of the extinguishers (8.3.1 and 8.3.2), which we have not checked. National derogations and penalties. The detail of Chapters 1.3, 1.4 and 5.2, which we treat as applicable without having re-read them. Text read: the English ADR 2025 published by UNECE. General information, not legal advice.