Documentation for Road Freight Transport: Rules and Exemptions
Regulatory compliance is a mandatory issue in every industry, and transport is no exception. Furthermore, it's an activity that interacts with other sectors and private individuals, such as when driving various types of vehicles on roads.
To ensure complete safety, there's a very exhaustive control system, and documentation is the first line of defence in security. When we talk about transporting sensitive and dangerous goods, this document management also becomes a fundamental pillar for guaranteeing safety. While ADR regulations, which govern the transport of dangerous goods worldwide, are strict, considering different scenarios to adapt requirements in each case is essential.
Standard Documentation for Dangerous Goods
For the transport of dangerous goods, these are subject to a series of provisions depending on the type of goods. However, there is documentation that is always mandatory according to these ADR provisions. The following documents are obligatory:
ADR Transport Document (Consignment Note):
With a precise description of the goods (UN number, class, packing group, etc.). More information about Loading Receipt or Consignment Note
ADR Written Instructions:
For the driver, detailing actions in case of emergency.
ADR Driver Training Certificate:
Driver's training certificate.
Vehicle Approval Certificate:
For special vehicles (e.g., tanks).
Safety Data Sheet (SDS):
Provided by the consignor.
Key ADR Exemptions in Europe
ADR regulations provide for a series of exemptions that allow for simplified transport without compromising safety by reducing the risk of the load. These are applicable in cases such as:
1. Exemption for Limited Quantities (LQ)
This is the most common exemption for packaged goods for final consumption, such as supermarket products or aerosols. If you comply with the quantity limits per package and per package, you can transport them without many of the ADR obligations.
Limits:
The gross weight of the package must not exceed 30 kg (or 20 kg for goods on trays).
Documentation:
A Transport Document (Consignment Note) is not mandatory, but the package must be marked with the Limited Quantities (LQ) pictogram.
Vehicle and Driver:
Orange plates are not required on the vehicle, nor is an ADR driver training certificate for the driver.
Continuing Obligations:
Personnel (including the driver) must have general training according to ADR Chapter 1.3, and the packaging must be robust and approved.
2. Exemption for Excepted Quantities (EQ)
Applicable to extremely small quantities of dangerous goods. The limits are so low that they are considered minimum risk.
Limits:
Quantities per package and per package are very small, as specified in the ADR.
Documentation:
Only a mention of the exemption on the Transport Document (if used) is required.
Marking:
The package must bear a specific Excepted Quantities (EQ) label.
Total Simplification:
This exemption releases most ADR requirements (placards, ADR driver training certificate, etc.).
3. Exemption by Transported Quantity (1,000 Points Rule)
This is one of the most relevant exemptions. It allows for the transport of a considerable quantity of dangerous goods without the need for an ADR driver training certificate or a vehicle with orange plates.
How it Works:
Each dangerous good is assigned a Transport Category (from 0 to 4), which in turn has a points value. You multiply the quantity of the substance (in litres or kilograms) by its points value.
Limit:
The total sum of points for all dangerous goods in the vehicle must not exceed 1,000 points.
Example: A substance from Transport Category 3 allows you to transport up to 1,000 litres/kg. One from Category 2, only up to 333 litres/kg.
Documentation:
A Transport Document (Consignment Note) is mandatory and must include the total quantity of goods per transport category.
Continuing Obligations:
Despite the exemption, a fire extinguisher and other personal protective equipment must be carried, and packages must be correctly labelled.
4. Total Exemptions (by Nature of Transport)
There are specific situations where ADR does not apply at all.
Transport by Private Individuals:
Goods packaged for retail sale and intended for personal or domestic use (e.g., a person carrying a can of petrol for their lawnmower).
Emergency Services:
Transport intended to save lives or protect the environment (e.g., firefighters or rescue services).
Vehicle Fuel:
Fuel contained in the vehicle's tanks for its own propulsion.
Always Verify the Regulations
To ensure our transport of dangerous goods is trouble-free, it's always advisable to be familiar with the regulations governing the transport of goods. Exemptions are applicable at a European level, but each country may have additional regulations or traffic restrictions.
Always consult the ADR and your product's Safety Data Sheet to confirm the transport conditions and applicable exemptions before each shipment.
Types of Documentation
The Loading Receipt
Document that certifies the delivery of goods to the carrier, key in logistics and shipment control.
CMR Convention
Mandatory international document for road transport between countries signatory to the CMR convention.
SAD (Single Administrative Document)
Presents the essential customs form for import and export operations outside the EU.
EAD (Export Accompanying Document)
Document that certifies the effective exit of goods exported from the EU.
EUR-1
Certificate that allows obtaining tariff benefits in exports to countries with preferential agreements.
ATR
Document that certifies the customs status of products between the EU and Turkey, allowing certain tax exemptions.
Transit T1 and T2
Documents that allow the movement of goods under customs control within or outside the EU customs territory.
DGD (Dangerous Goods Declaration)
Mandatory form for the safe transport of dangerous goods, complying with international regulations.
Summary Declaration
Document containing prior information on goods arriving or leaving the customs territory for control and security purposes.