Enforcement in the Netherlands
What the ILT enforces: the nine most serious ADR road offences
The Dutch inspectorate ILT has worked out the LHSO intervention matrix for nine offences in the carriage of dangerous goods by road. This is that list, with the legal basis for each and the sanction that follows.
What this is, and what it is not. ILT calls these the nine most serious offences and states in terms that the overview is not exhaustive. It is therefore not a ranking by frequency, and it is not a complete list of everything ILT enforces.
ILT publishes no fine amounts in this source. The Richtlijn voor Strafvordering Wet vervoer gevaarlijke stoffen sets the tariffs. No amounts are stated here that are not in the source.
| No | Legal basis | Offence | Category | Sanction |
|---|---|---|---|---|
| 1 | ADR, several provisions | Carrying dangerous goods that are not permitted to be carried at all. | I | proces-verbaal (criminal citation) |
| 2 | ADR, several provisions | Leakage of dangerous goods. | I | proces-verbaal (criminal citation) |
| 3 | ADR, several provisions | Carriage in a containment (packaging, tank, receptacle, container) that was not manufactured or approved for this carriage, or is no longer fit for it. | I | proces-verbaal (criminal citation) |
| 4 | Wet vervoer gevaarlijke stoffen, articles 19 and 24 | Failing to avoid built up areas, or failing to follow the mandatory route. | I | proces-verbaal (criminal citation) |
| 5 | ADR 8.6.4 | Carrying dangerous goods through a tunnel where this is not permitted. | I | proces-verbaal (criminal citation) |
| 6 | ADR, several provisions | The vehicle is not correctly loaded under the stowage or loading provisions. | I | proces-verbaal (criminal citation) |
| 7 | ADR, several provisions | Vehicles carrying dangerous goods are not identifiable as such, for example marking or labelling is missing, or no transport document is present. | I | proces-verbaal (criminal citation) |
| 8 | ADR 8.2.1 and 1.3 | Personnel do not hold the required training, meaning the ADR certificate or general awareness training. | I | proces-verbaal (criminal citation) |
| 9 | ADR 1.8.3.1 | No dangerous goods safety adviser appointed or employed for carriage by road. | I | proces-verbaal (criminal citation) |
How the intervention matrix works
The inspector places each offence in a matrix with two axes. One is the characterisation of the offender, the other the consequences of the offence. The combination determines which intervention fits.
Chain responsibility. Because carriage of dangerous goods is a chain responsibility, anyone in the chain holding a role as described in ADR chapter 1.4 can be cited. Several offenders can be responsible and prosecuted at the same time. That reaches the consignor, the carrier, the loader and the unloader, not only the driver.
All offences under the Wet vervoer gevaarlijke stoffen are economic offences. On repeat, and where intent is shown, an offence can be treated as a crime.
What ILT actually inspected in 2025
Figures from the ILT annual report for 2025. The annual report gives no breakdown by offence type, so these sit alongside the matrix above rather than inside it.
ILT reported two recurring patterns: confusion about article 47 of the Wet vervoer gevaarlijke stoffen, and insufficient knowledge of multimodal transport among staff.
Machine readable
The nine rows as JSON, free to reuse under CC BY 4.0: ilt-enforcement-adr.json (9 rows).
Provenance and versions
- Dataset version
- 2026.08.1
- Methodology version
- 1.0
- Last verified
- Legal status
- A restatement of published ILT enforcement policy. Not legal advice. ILT and the law govern.
- Archived version
- This release stays reachable as a frozen snapshot so a citation does not rot: /v/2026.08.1/ilt-enforcement-adr
- Licence
- CC BY 4.0
Source manifest
| Document | Date | Role |
|---|---|---|
ILT interventiestrategie, Gevaarlijke stoffen weg | 2026-08-24 | the nine offences and the sanctions, taken verbatim |
ILT-Jaarverslag 2025 | 2026-05-20 | the 2025 inspection figures |
Landelijke Handhavingsstrategie Omgevingsrecht | standing | the intervention matrix itself |
Richtlijn voor Strafvordering Wvgs, HUM 2016 | standing | sets the tariffs, not reproduced here |
Method
The nine offences and their legal basis are taken verbatim from the ILT intervention strategy page and checked line by line against it. The English wording is a translation of that text, with the Dutch legal basis kept alongside so a reader can check the source.
Limitations
ILT states the list is not exhaustive, and it is not a frequency ranking. Fine amounts are not in this source and are not stated here. This page is a working reference, not legal advice.
Correction log
No corrections have been issued against this release.
Update cadence
This page is re-checked whenever ILT changes its intervention strategy and after each new ILT annual report, and at minimum yearly.
Disclosure
The organisation that maintains this reference also arranges the movements it describes, as ADR Transport & Hazardous Goods Transport across Europe. Nothing on this page depends on that. Vektor Group is a commercial road freight brokerage. This page is free to reuse under CC BY 4.0 and assumes no commercial relationship. Vektor does not sell ADR consulting or training.
How to cite
Vektor Group (2026). The nine most serious ADR road offences under Dutch enforcement. https://vektorgroup.eu/ilt-enforcement-adr. Accessed [DATE].
Vektor Group is a commercial road freight brokerage. This reference is free to reuse under CC BY 4.0, requires no registration, and assumes no commercial relationship.