Do I Need a DGSA?

Who must appoint a DGSA?

The requirement comes from section 1.8.3 of ADR (road) and RID (rail). In Great Britain these are applied by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG).

A business must appoint at least one DGSA if its activities include any of the following:

• Consigning: sending dangerous goods, even if someone else packs and transports them
• Carrying: transporting dangerous goods by road or rail
• Packing: putting dangerous goods into packages
• Filling: filling tanks, tank containers or bulk vehicles
• Loading: loading dangerous goods onto vehicles
• Unloading: unloading dangerous goods from vehicles

That covers far more than hauliers. Manufacturers, distributors, wholesalers, waste and recycling operators, laboratories, online retailers and many warehouses can all be in scope.

Consignors: the rule that catches many businesses out

For many years, businesses that only consigned dangerous goods didn't need a DGSA. ADR 2019 changed that. Consignors were brought into the requirement, with a transition period that ended on 31 December 2022. Since then, consignor-only businesses, including office-based shippers who never touch the goods, have needed a DGSA unless an exemption applies.

ADR 2025 then made it clear that the occasional-activity exemption applies to consignors too. Before that, the UK had relied on a temporary multilateral agreement (M351) to allow it.

Quick check: are you exempt?

If your business consigns, carries, packs, fills, loads or unloads dangerous goods by road or rail, start here.

1. 1Do you only ever handle small loads within the ADR 1.1.3.6 limits, or limited or excepted quantities?
   Yes
   Likely exempt The small-quantity exemption should apply to UK journeys. Check every load stays within the limits.
2. No
3. 2Is dangerous goods activity outside your main or secondary business, occasional, low risk and within the UK only?
   Yes
   May be exempt The occasional-activity exemption may apply. It's narrow, so get it checked.
4. No
5. You need a DGSA Appoint a qualified DGSA, either a member of staff or an external adviser like dgsa.net.

A simplified guide. Read DGSA Exemptions Explained for the detail, or ask us to check your position.

What if you don't appoint one?

Failing to appoint a DGSA when you need one is a breach of CDG. In Great Britain, HSE has overall responsibility for enforcement, with DVSA and the police carrying out roadside checks. The consequences can include:

• Vehicles being stopped and prohibited at the roadside
• Enforcement action and, in serious cases, prosecution, with fines set by the courts
• Problems with your operator licence if failures are referred to the Traffic Commissioner
• Difficulties with insurance claims if an incident happens

Just as important, without a DGSA nobody is checking that your classification, packaging, paperwork and training are right, which is how most incidents and roadside prohibitions start.

What to do next

1. List what you handle: the dangerous goods you send, receive or carry, and roughly how much and how often.
2. Check the exemptions against every activity, not just your typical one.
3. Appoint a DGSA if you're not clearly exempt. Your DGSA can be an employee, the business owner or an external consultant.