Limited Quantities vs Excepted Quantities vs Small Load

ADR offers three different reliefs for small amounts of dangerous goods, and they are routinely confused because all three sound like exemptions. Two of them genuinely take the consignment outside ADR. The third only reduces what applies — and the difference decides your packaging, your marking and whether the driver needs a qualification.

What is the difference between limited quantities and excepted quantities?

Both are ADR reliefs for small amounts of dangerous goods, but they work at different scales and carry different obligations. Limited quantities (ADR 3.4) covers retail-sized receptacles packed in a box or on a shrink-wrapped tray. Excepted quantities (ADR 3.5) covers much smaller amounts in a combination package.

There is also a third relief that gets confused with both: the small load exemption (ADR 1.1.3.6), which is not about the package at all but about the total quantity on the transport unit.

Choosing between them is not a preference. Each substance is assigned its own limits in Table A of ADR — column 7a for limited quantities, column 7b for excepted quantities — and for some substances one or both routes do not exist at all.

How do the three reliefs compare?

The last row is the one that matters most. Limited and excepted quantities take the consignment out of ADR; the small load exemption only reduces what applies. Below the threshold you still owe general driver training, a fire extinguisher and proper stowage — and in HSE's own phrase, what is not exempted is still required.

What are the limited quantity limits?

The maximum quantity per inner packaging comes from column 7a of Table A. The outer package then has a mass limit: 30 kg gross, or 20 kg for a shrink-wrapped tray.

Where column 7a shows 0 for a substance, there is no limited quantity route and the relief simply does not exist for it. That is the check to make first, before working out whether your receptacles fit.

Packaging for limited quantities must be good quality and suitable, but it does not have to be UN approved — which is the saving that makes the relief worth using. Class 8 corrosives carry an additional requirement at ADR 3.4.4. The paint and solvents page covers the practical case, and ADR sets out the classes.

What are the excepted quantity limits?

Excepted quantities work through a code, E0 to E5, in column 7b of Table A. E0 means no excepted quantity provisions apply. The codes then link to ADR 3.5.1.2, where E1 permits inner packagings up to 30 g or 30 ml in an outer with maximum net contents of 1000 g or 1000 ml.

Like limited quantities, excepted quantities require a combination package — a bottle in a box. Unlike limited quantities, the rules on packaging testing and documentation are more prescriptive, which is the trade-off for the much smaller quantities being allowed.

The concept came to road transport from air, where it has long been used, and one of its purposes is to make the road and rail legs of a journey that includes a flight work smoothly. It is also a standalone provision, so it is an alternative for many substances regardless of whether an air leg is involved.

The practical consequence of the tighter rules is that excepted quantities suit a product that is genuinely tiny — a reagent vial, a test kit, a sample of a few millilitres — rather than a scaled-down version of a retail line. If your inner receptacle is a 500 ml bottle, excepted quantities is not the route; limited quantities may be, and the check is column 7a rather than 7b.

What marking does each relief require?

The limited quantity mark must be a minimum of 100 mm by 100 mm, reduced to 50 mm by 50 mm only where the package is too small to take the larger one. A different version of the mark applies where an air leg is involved.

The excepted quantity mark shows the first label number of the goods, plus the name of the consignor or consignee if that is not shown elsewhere on the package. Where documents are carried, they must state "dangerous goods in excepted quantities" and indicate the number of packages.

There is one further marking obligation specific to limited quantities that catches larger operations: a transport unit carrying more than 8 tonnes of limited quantity packages must be marked, under ADR 3.4.10, in force since 1 January 2011. A full load of boxed retail chemicals can cross that line without any single package being close to a limit.

How does the small load exemption work?

It works on the transport category in column 15 of Table A, not on the packing group — and the two are not synonymous. Where the category is not available, the table at ADR 1.1.3.6.3 has to be consulted.

The fourth column is the interaction worth understanding. Packages meeting the limited quantity criteria are not counted towards the small load threshold, so using LQ packaging can keep a mixed load under the threshold that would otherwise exceed it. Where there is no LQ route, every package counts.

What still applies below the small load threshold?

Three obligations survive, and they are short enough to be worth memorising.

1. Step 1 — general driver training under ADR 1.3.2, with a record kept under ADR 1.3.3.
2. Step 2 — one 2 kg dry powder fire extinguisher or equivalent, under ADR 8.1.4.2.
3. Step 3 — proper stowage of the dangerous goods, under ADR 7.5.7.

Using the exemption is optional. A carrier may choose to display orange plates whenever dangerous goods are on board, and some do as a matter of policy. What is not optional is removing them: all vehicle marks must come off when no dangerous goods are being carried, and a plated empty vehicle is itself a defect.

The exemption does not apply to tankers or to bulk carriage at all. For documentation, the duty to carry it is disapplied on GB domestic journeys below the threshold — except for explosives and radioactives — but the consignor's duty to furnish the carrier with it remains. See dangerous goods note for what that document contains.

Can limited quantity packages be broken down for retail distribution?

Yes, subject to conditions. Retail distribution of limited quantity packages that have been broken down is allowed, and where those conditions are met no other requirement of ADR applies. That is what makes the relief workable for a distribution round rather than only for a single trunk movement.

The principle behind limited quantities is that an acceptable level of safety comes from the receptacles being inside a box or a shrink-wrapped tray. Breaking that outer open changes the basis of the relief, which is why the permission is conditional rather than general.

For a van doing 20 or 30 retail drops of boxed chemicals, this is the provision that keeps the work outside ADR. It is also the provision most often assumed rather than checked, and the conditions are worth reading rather than taking on trust — particularly where the round mixes classes.

Which relief should you be using?

Work it in this order. Check column 7a: if your receptacles fit the limited quantity inner limit and the outer is within 30 kg, that is normally the cheapest route, because the packaging does not need UN approval and no ADR documentation is required. If column 7a shows 0, check column 7b for an excepted quantity code — E1 to E5 give you a route at much smaller volumes with more prescriptive rules.

If neither fits, you are carrying dangerous goods under ADR, and the question becomes whether the whole load sits under the small load threshold for its transport category. That reduces the requirements but does not remove them.

We hold ADR competence across classes 2, 3, 4, 5, 6, 8 and 9 — not class 1 explosives and not class 7 radioactives. Our hazardous goods page sets out the handling, and individual cases are covered on aerosols and gas cylinders. Classification is the consignor's responsibility and we cannot do it for you, but send us the UN numbers and the quantities and we will tell you which relief the load appears to fall under before you buy packaging.