We occasionally move solar panels and wind generators, albeit small ones. But along with that we have to take pallets of batteries, usually 4 pallets with 16 boxes on each. These are not duracell double aa size batteries. They are all marked with adr class 8 corrosive. I told the office I did not have an adr licence but I know there is a limit you can carry before an adr is needed, and the customer stated that they didn’t come under adr and the corrosive labels were a requirement of the shipping line. Personally I think that’s crap. But my question is, what is the limit I can carry before I need adr licence please?
degsy4wheels:
… we have to take pallets of batteries, usually 4 pallets with 16 boxes on each. These are not duracell double aa size batteries. They are all marked with adr class 8 corrosive. I told the office I did not have an adr licence but I know there is a limit you can carry before an adr is needed, and the customer stated that they didn’t come under adr and the corrosive labels were a requirement of the shipping line. Personally I think that’s crap. But my question is, what is the limit I can carry before I need adr licence please?
Hi Degsy,
You’re correct that normally there is a ‘freebie’ limit that can be carried without an ADR licence, but in this case there is NO limit, provided that the following is complied with…
I’m guessing a little here, but I think you’re carrying “wet” batteries.
If so, they’ll be either:
UN 2794 BATTERIES, WET, FILLED WITH ACID, electric storage, 8
UN 2795 BATTERIES, WET, FILLED WITH ALKALI, electric storage, 8
The company is probably spot-on about ADR not applying because there’s an ADR Special Provision at work here, provided that the conditions attaching to the Special Provision are complied with. 
The conditions are in the little quote box below.
ADR does not limit the size, weight or number of these “wet” batteries that you can carry.
This is from a partial exemption called SP598(a), but there’s also the following that needs to be correct too:
- they are secured in such a way that they cannot slip, fall or be damaged;
- they are provided with carrying devices, unless they are suitably stacked, e.g. on pallets;
- there are no dangerous traces of alkalis or acids on the outside;
- they are protected against short circuits;
(All batteries follow the quote above, whether new or second-hand and must comply with marking rules below.)
If the batteries are used
The rules are slightly different.
Definition of used:
“Used storage batteries” means storage batteries carried for recycling at the end of their normal service life.
Now you know the definition, are the batteries “used” 
Marking rules
If the battery or batteries are not individually marked with the UN number and a class 8 label, then the following applies:
(Because what you’re carrying becomes an “overpack” according to ADR)
“UN 2794” (Or UN 2795) must be written on the shrink wrap, or it can be a sticker like this:
There must also be 2 of these on the shrink-wrap, one on each side:
Or the arrows can be indelibly hand-drawn.
There must also be a “proper” one of these on the pallet too:
And finally, there must also be one of these:
It can be a sticker, or the word “OVERPACK” can be indelibly handwritten.
Otherwise than the above, you’re good to go mate.
Thank you for this. The batteries are wet ones not used. Much appreciated
The only other thing I’d add to Daves post is…
We are drivers, we are not to know what is and isn’t going to put us into ADR regs, the manual Dave is quoting above is just 1 of the manuals, we do not carry or know these by heart.
It is upto someone else to tell you if you come in scope of ADR or not, so don’t worry your head about it in future, if they say it’s not ADR, then as far as you’re concerned, it’s not ADR and crack on, if it turns out it is ADR the blame will sail straight past you my friend 