Guidance

The definition of a ‘closed vehicle’ for the purpose of transporting dangerous goods by road

Updated 6 April 2020

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Use of closed vehicles

The ADR requires that, for some dangerous goods loads, a ‘closed vehicle’ or ‘closed container’ must be used for carriage by road.

The ADR defines a ‘closed vehicle’ in section 1.2.1 as “a vehicle having a body capable of being closed”.

Following enforcement action in mainland Europe, the UK Department for Transport (DfT) has clarified its interpretation of this definition as concerns vehicle design with other contracting parties to the ADR.

Interpretation of the term ‘closed vehicle’

A ‘closed vehicle’ is one with rigid walls and a rigid roof. Vehicles with fabric sides or fabric tops are not considered to be closed. Curtain-sided vehicles (also called tautliners) do not meet the definition of a closed vehicle.

This interpretation has been confirmed by the UK competent authority (DfT) through consultation with other contracting parties to the ADR and relevant persons at the United Nations Economic Commission for Europe.

Basis for the interpretation

The interpretation of a ‘closed vehicle’ set out in this guidance is aligned with related definitions in the Model Regulations and the ADR:

The definition of a ‘closed cargo transport unit’ in the Model Regulations

The United Nations’ Model Regulations is the multi-modal foundation text for the ADR. It refers to ‘cargo transport units’, of which vehicles are a type.

In section 1.2.1, a ‘closed cargo transport unit’ is defined as one which “totally encloses the contents by permanent structures with complete and rigid surfaces”.

It confirms that “cargo transport units with fabric sides or tops are not considered closed cargo transport units”. Vehicles with fabric sides or tops cannot therefore be considered closed cargo transport units.

The definition of a ‘closed container’ in the ADR

Where such a condition is relevant, the ADR always provides an option of using either a ‘closed vehicle’ or ‘closed container’. It follows that the ‘closed’ structural features of both types of unit should be comparable.

The ADR defines a ‘closed container’ in section 1.2.1 as “a totally closed container having a rigid roof, rigid side walls, rigid end walls and a floor”. It follows that a closed vehicle should also have a rigid roof and rigid walls.

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