In short
There are two ways to be exempt from appointing a DGSA in Great Britain. Either every load stays within the small-quantity limits, or your dangerous goods activity is occasional, low risk, within the UK and not part of your main or secondary business. Both are narrower than most businesses think.
ADR 1.8.3.2 allows countries to exempt certain businesses from appointing a DGSA. In Great Britain these exemptions are applied through CDG regulation 3(j), and HSE's guidance explains how they work in practice. HSE's guidance is that these GB exemptions do not apply to international carriage.
Exemption 1: small quantities
You don't need a DGSA if your activities only involve dangerous goods in quantities that stay within certain limits. That includes:
- Small loads within the thresholds in ADR 1.1.3.6, worked out per transport unit
- Limited quantities carried under ADR chapter 3.4
- Excepted quantities carried under ADR chapter 3.5
- Quantities within limits set by special provisions in ADR chapter 3.3
- Certain radioactive material covered by ADR 1.7.1.4
Every load counts. This exemption depends on the quantities on each transport unit. If even some of your loads go over the 1.1.3.6 thresholds, you can't rely on it for those activities.
Exemption 2: occasional, low-risk activity
The second exemption is for businesses whose main or secondary activities are not the carriage of dangerous goods or the related packing, filling, loading or unloading, but which occasionally carry out these activities within the UK, with goods that pose little danger or risk of pollution.
All of these conditions must be met:
| Condition | What it means in practice |
|---|---|
| Not your main or secondary business | Dangerous goods are incidental to what you do. Carriers, delivery companies and freight forwarders usually can't use this exemption, because moving goods is their business. |
| Occasional | HSE's guidance suggests roughly one or two journeys a month. |
| Little danger or risk of pollution | HSE gives examples such as goods in transport category 4, or transport category 3 in packages up to 1,500 litres or kilograms. |
| National only | The exemption only covers journeys within the UK. International movements aren't covered by it. |
HSE's examples of businesses that might qualify include a construction company taking dangerous goods to its own sites, and a repair business that occasionally recovers a vehicle carrying dangerous goods.
What ADR 2025 changed for consignors
Consignors have needed a DGSA since 1 January 2023, when the transition period introduced by ADR 2019 ended. At first, the wording of the occasional-activity exemption didn't clearly cover consignors, so the UK signed a temporary multilateral agreement (M351) to extend it to them.
From ADR 2025, the exemption itself covers consignors, so occasional, low-risk consignors no longer depend on a temporary agreement.
Common mistakes
- "We only send limited quantities." That may be true of most shipments, but one fully regulated consignment changes the picture.
- "We use vans, so ADR doesn't apply." ADR applies to any vehicle. Vehicle size doesn't create an exemption.
- "Our haulier has a DGSA." Their DGSA covers their activities, not your consigning, packing or loading.
- "We're occasional." Occasional has to be genuine and low risk, and it doesn't cover international journeys.
- "Nobody's ever asked." Enforcement often starts with a roadside stop. Have your reasoning written down before then.
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