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ADR Interpretation List

Below is a list of ADR interpretation statements adopted by the Working Party on the Transport of Dangerous Goods since 2016. To view the interpretation adopted for a given subject, click on the entry below.

Interpretation questions discussed by the Working Party which consequently resulted in clarification of the text of ADR are not reproduced.

For additional clarification or more information concerning the interpretation of ADR and its implementation, contact the national competent authorities.

Transport of dangerous goods as part of duties to protect the public - 1.1.3.1 (d) and (e)

At its 113th session (15–17 May 2023), the Working Party confirmed that the provisions in 1.1.3.1 (d) and (e) allowed public services (e.g. police, enforcement, customs) to carry dangerous goods as part of their duties to protect the public. see § 48 of the report ECE/TRANS/WP.15/262.

Calculation of the net mass of explosive substance in 1.1.3.6, 7.5.5.2 and for traffic restrictions in tunnels

At its 112th session (8–11 November 2022), the Working Party confirmed that the quantities of pyrotechnic substances should be taken into account in the calculation of the net mass of explosive substance in 7.5.5.2, as well as in the other provisions of ADR that made use of the concept, in particular in 1.1.3.6 and the provisions relating to traffic restrictions in tunnels.. See § 40-41 of report ECE/TRANS/WP.15/260 and explanations in document ECE/TRANS/WP.15/2022/9.

Provisions of Chapter 4.4 for the use of fibre-reinforced plastics tank-containers

At its 112th session (8–11 November 2022), in response to a question by the secretariat (document ECE/TRANS/WP.15/2022/10), the Working Party confirmed that the provisions of Chapter 4.4 in force until 31 December 2022 remained applicable to fibre-reinforced plastics tank-containers used in accordance with transitional measure 1.6.4.59. See § 37 of report ECE/TRANS/WP.15/260.

Total quantity of each dangerous good included in the transport document (ADR 5.4.1.1.1 (f))

At its 108th session (10–13 November 2020), in response to a question by the representative of Switzerland (document ECE/TRANS/WP.15/2020/9), the Working Party confirmed that the information on the total quantity of each dangerous good included in the transport document(s) carried on board, in accordance with 5.4.1.1.1 (f), should make it possible to assess the quantity present in the vehicle at a given moment, for example during an inspection. See § 51-52 of report ECE/TRANS/WP.15/251.

Requirements for thermal insulation (ADR 7.1.7.4.5)

At its 106th session (13–17 May 2019), in response to a question by the representative of the Netherlands (informal document INF.3), the Working Party confirmed that the methods listed in 7.1.7.4.5 (c), (d) and (e) for preventing the control temperature from being exceeded involved thermal insulation of vehicles and containers and not thermal insulation of packages. See § 49 of report ECE/TRANS/WP.15/246.

Precautions against electrostatic charges (ADR 7.5.10)

At its 103rd session (6–10 November 2017), in response to a question by the representative of Sweden (informal document INF.4), the Working Party confirmed the interpretation of Sweden, according to which, in order to meet the requirements of section 7.5.10, an earthing connection must be established with the vehicle chassis prior to the filling or emptying of tanks, either by means of a direct connection of the vehicle or tank to the earth or by connecting the vehicle or the tank to an earthed storage tank. See § 59 of report ECE/TRANS/WP.15/239.

Reference to competent authorities in Parts 8 and 9

At its 109th session (4–7 May 2021), the Working Party confirmed the interpretations proposed in paragraphs 8, 9, 12 and 14 of document ECE/TRANS/WP.15/2021/5 and clarified the use of the term "competent authority" in 9.1.2.1 as detailed below. See § 36 and 37 of report ECE/TRANS/WP.15/253.

References to competent authority in Chapter 8.2
The Working Party confirmed that “competent authority” in Chapter 8.2 referred to the competent authority of the country where the training and examinations take place. 

References to competent authority in Chapter 8.5, additional requirement S1
The Working Party confirmed that “competent authority” in additional requirement S1 referred to the competent authority of the countries where the carriage, loading or unloading takes place.

References to competent authority in Chapter 8.5, S16 and S21
The Working Party confirmed that “competent authority” in S16 and S21 referred to competent authorities of the countries where the carriage takes place.

References to competent authority in 9.1.2.2
The Working Party confirmed that the term “competent authority” in 9.1.2.2 referred to the competent authority of the country of registration.

References to competent authority in 9.1.2.2
The Working Party confirmed that this paragraph referred to the competent authority in accordance with UN Regulation No. 105

Tunnel restrictions for dangerous goods with code "(-)" (ADR 8.6.4) 

At its 106th session (13–17 May 2019), in response to a question by the representative of France (informal document INF.13), the Working Party confirmed that the passage through road tunnels of vehicles containing dangerous goods, other than UN Nos. 2919 and 3331, for which “(-)” is indicated instead of a tunnel restriction code in column (15) of Table A of Chapter 3.2, could not be restricted for safety reasons. See § 55 of report ECE/TRANS/WP.15/246.

First date of registration in the table in 9.2.1.1

At its 109th session (4–7 May 2021), the Working Party confirmed the interpretation proposed by Netherlands in paragraph 3 of document ECE/TRANS/WP.15/2021/6 that the provision in the table in 9.2.1.1 concerning the electrical equipment of vehicles first registered for road traffic in general after 31 March 2018 (first registration after manufacture, in accordance with road traffic law) referred to the registration within the meaning of road traffic law. See § 45 of report ECE/TRANS/WP.15/253. See also the Guideline for the determination of the first date of registration of road vehicles.

Sections of the vehicle certificate of approval (ADR 9.1.3.5)

At its 106th session (13–17 May 2019), in response to a question by the representative of Latvia (informal document INF.11), the Working Party confirmed that the certificates should include all the sections shown in the model of 9.1.3.5 including the items that were not applicable. The Working Party noted that No.13 was not included in the certificates issued at that time in Latvia. The Working Party invited Latvia to incorporate this item as soon as possible into the new certificates. In the meantime, certificates issued without No. 13 could still be used. See § 52-53 of report ECE/TRANS/WP.15/246.