ADR question
Question asked to Palen
Revised on Jun 27, 2026 · Precision level : BOT_PROFILE_EXPRESS
↗A vehicle is carrying only packaged dangerous goods assigned to Transport Category 4. According to ADR 1.1.3.6.3, the calculation factor for Transport Category 4 is 0, so the transport falls within the ADR 1.1.3.6 small load exemption. However, the UN number carried has Tunnel Restriction Code (TRC) = E. May this vehicle pass through a Category E tunnel? Or, Do the tunnel restrictions in ADR Chapter 8.6 still apply, even though the transport qualifies for the ADR 1.1.3.6 exemption?
Yes. If the vehicle is carrying only packaged dangerous goods transported under ADR 1.1.3.6, the Chapter 8.6 tunnel restrictions do not apply to those goods.
ADR 1.1.3.6.2 states that, when the 1.1.3.6 threshold is not exceeded, the goods may be carried in packages without applying Part 8, except for the specifically listed provisions; Chapter 8.6 is not among the retained provisions (ADR 1.1.3.6.2, Volume 1, pages 9-10) . ADR 8.6.3.3 confirms this directly: dangerous goods transported in accordance with 1.1.3 are not subject to tunnel restrictions and are not to be taken into account when determining the tunnel restriction code for the transport unit, except for the specific limited-quantity marking case under 3.4.13/3.4.14 (ADR 8.6.3.3, Volume 2, page 656) .
Therefore, even if the UN number normally has Tunnel Restriction Code E, a transport unit carrying only packaged dangerous goods qualifying under ADR 1.1.3.6 may pass through a Category E tunnel, provided the transport is genuinely under 1.1.3.6 and is not within the limited-quantity marking exception mentioned in 8.6.3.3 (ADR 8.6.3.3, Volume 2, page 656) .
If the 1.1.3.6 exemption did not apply, Tunnel Restriction Code E would mean “passage prohibited through Category E tunnels” (ADR 8.6.4, Volume 2, page 658) .
Sources:
- Volume 1 — ADR 1.1.3.6.2, exemptions related to quantities carried per transport unit, pages 9-10.
- Volume 2 — ADR 8.6.3.3, tunnel restrictions and goods transported under 1.1.3, page 656.
- Volume 2 — ADR 8.6.4, tunnel restriction code E, page 658.