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When reviewing compliance with the ADR legislation, I note that companies that are the recipients of dangerous goods are not paying attention to the packaging in which dangerous goods are packed.

According to the Dangerous Goods Transport Act, the take-over of dangerous goods in packaging which is inadequate is an offence punishable by a fine of up to EUR 4 000. If you are interested in which potential penalties you are still  exposed as recipients of dangerous goods, then this blog post is right for you.

For packaging of dangerous goods, you can only packaging which:

  • in terms of quality and performance, correspond to the quantity and characteristics of the dangerous goods for which they are used (dangerous goods must not damage or react with the packaging),
  • it admissible the transport of dangerous goods (in accordance with the packaging instructions according to the ADR),
  • is tested and approved in accordance with the ADR (has the relevant ADR packaging code),
  • has, in accordance with the ADR, inscriptions and labels or labels to indicate the danger and other information on dangerous goods and packaging (has a UN number and ADR labels)).

Here’s a picture of the most common ADR labels on the packaging:

Let me also draw your attention to the shelf life of plastic packaging such as plastic drums and jerricans and IBC containers.

Plastic drums and jerricans may be used for the transport of dangerous goods for 5 years from the date of manufacture. It is specified in the packaging code. After five years from the date of manufacture (month and year must be taken into account), plastic packaging may no longer be used for the transport of dangerous goods.

An example of the labeling on the jerrican, which was made in 2018:

The month of manufacture is usually defined by "hour". Example of a label on plastic packaging made in November 2010:

IBC containers also have a shelf life, which can be extended. Each IBC must be checked according to the requirements of the competent authority for first use and after each processing, and at least every 5 years thereon thereon. 

The following should be reviewed:

  • the suitability of the type of manufacture, including labeling,
  • interior and exterior,
  • the suitability of the equipment. 

At least every 2,5 years should be examined:

  • exterior,
  • the suitability of the equipment. 

 Any IBC that is replenished or emptied under pressure must be tested for tightness. 

Examples of tags on IBCs:

The above image shows the date of the regular review, i.e., 19.5.2021. In the light of the foregoing, this means that this IBC can be used for the transport of dangerous goods, since 2,5 years have not yet elapsed until the mid-term review. 

Let's look at the last example of inappropriate labeling:

This IBC should not be used for the transport of dangerous goods because the date of the periodinum inspection is deleted or is not apparent.  The date of production of IBC is 21.1.2015. 

These are just a few "little things" you should look out for as recipients of dangerous goods. But it is these little things than can cost you dearly. 

And if you interested in how ADR applies to packaging of lithium batteries you can read it here

If you need help in regulating and mastering ADR legislation, just write to me at

Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at
ADR | November 11, 2022

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