ADR UN 1977 Multi-Stop Delivery: CV36 and P203 Rules

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Revised on Nov 6, 2026

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Under ADR, is it legal to deliver refrigerated liquid nitrogen (UN 1977) to several customers using a light commercial vehicle compliant with CV36 and containing a closed 600-litre cryogenic receptacle compliant with P203?

CV36 and P203 compliance is not, by itself, sufficient to authorize the delivery operation. The key distinction is between carrying the closed receptacle and opening it to dispense nitrogen to customers. ADR permits UN 1977 in P203 packaging, but prohibits the driver or attendant from opening a package containing dangerous goods. (ADR 3.2, Table A, UN 1977, Volume I, p. 388; ADR 8.3.3, Volume II, p. 649.)

1. A closed 600-litre receptacle is not prohibited by its capacity

A closed cryogenic receptacle may have a water capacity up to 1,000 litres. Consequently, a compliant 600-litre closed receptacle is within that definition. The 450-litre limit in P203 concerns open cryogenic receptacles, not closed ones. (ADR 1.2.1, definition of “closed cryogenic receptacle”, Volume I, p. 29; ADR 4.1.4.1, P203, Volume II, p. 94.)

UN 1977 is assigned packing instruction P203. For closed receptacles, that instruction requires compliance with section 4.1.6 and Chapter 6.2, together with its filling, pressure-relief and inspection requirements. (ADR 3.2, Table A, UN 1977, column 8, Volume I, p. 388; ADR 4.1.4.1, P203, Volume II, p. 93.)

2. CV36 addresses carriage conditions—not permission to dispense

UN 1977 is assigned CV36. It prefers open or ventilated vehicles; where another closed vehicle is used, gas exchange between the load compartment and the driver’s cab must be prevented, and the loading doors must bear the prescribed warning in letters at least 25 mm high. These requirements do not override the prohibition on opening packages. (ADR 3.2, Table A, UN 1977, column 18, Volume I, p. 389; ADR 7.5.11, CV36, Volume II, p. 636; ADR 8.3.3, Volume II, p. 649.)

3. The decisive condition for your delivery round

Carriage and delivery of closed packages to several customers: multiple consignees are expressly contemplated by ADR. Their names, addresses and delivered quantities may be recorded in accompanying documents carried aboard, so that the nature and quantity of the load can be established at any time. (ADR 5.4.1.4.1, Volume II, p. 285.)
Opening the 600-litre package by the driver or attendant to transfer nitrogen into customers’ receptacles: this conflicts with the prohibition in 8.3.3. The quantity-based partial exemption does not remove that prohibition: 8.3.3 is expressly retained. (ADR 8.3.3, Volume II, p. 649; ADR 1.1.3.6.2, Volume I, p. 9.)

Therefore: the 600-litre capacity and the use of a light commercial vehicle are not the decisive obstacle. However, if your intended operation is a dispensing round in which the driver opens that packaged receptacle at successive customers, P203 and CV36 do not make that operation lawful under ADR 8.3.3. (ADR 1.2.1, Volume I, p. 29; ADR 3.2, Table A, UN 1977, Volume I, pp. 388–389; ADR 8.3.3, Volume II, p. 649.)

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