Law SENT – full name “Act on the monitoring system for the road and rail transport of goods and trade in heating fuels” – contains a closed catalog of goods that must be registered in the SENT system. What can happen if we register goods that are not included in this catalogue? In fact, this does not cause any negative effects for the applicant, but it may cause the tax authorities to initiate control activities and unnecessarily extend the transport of goods.

When is carriage not subject to registration in SENT?

Despite the fact that the type of goods has been listed in the SENT catalog and is subject to the obligation to monitor the transport, it will not be subject to this obligation if:

  • goods will be transported by postal operators in postal packages,
  • the goods have been placed under the customs procedure of transit, storage, temporary admission, processing or export, re-export,
  • the goods are moved under an excise duty suspension procedure, using an e-AD document,
  • the transport of goods takes place on the basis of a document confirming the inter-warehouse transfer and is not related to the performance of activities subject to VAT.

Does the quantity of goods transported matter for SENT registration?

Yes, the Act excludes the obligation to transport goods in small quantities, but it sets individual standards. The standards apply to individual packaging.

  • Fully denatured alcohol up to 5 liters,
  • Ethyl alcohol and products (CN 2207) unmarked with excise tax marks up to 5 liters,
  • oils (CN 2707) up to 11 liters,
  • Petroleum oils (CN 2710) up to 11 liters, excluding heating fuels,
  • alcohols (CN 2905) up to 11 liters,
  • Lubricating preparations (CN 3403) up to 16 liters,
  • Anti-knock agents (CN 3811) up to 16 liters,
  • organic solvents (CN 3814) containing ethyl alcohol up to 11 liters,
  • antifreeze (CN 3820) containing ethyl alcohol up to 16 liters.

What goods are included in CN heading 2710?

These will be essentially petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70% or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils. Automobile gasoline, lubricants, cutting fluids, cleaning oils.

    What does the regulation say about heating fuels?

    Heating fuels will be exempt from the obligation to submit a notification to SENT, but only in specific situations, in the following quantities:

    Unit packages with a gross weight not exceeding 30 kg or with a volume not exceeding 30 liters, in a total amount not exceeding 100 kg or a volume of 100 liters, respectively, for one collecting entity.

    This will apply only in the case of the maintenance of a register of purchasers by an intermediate oil entity, i.e. the case referred to in the Act on Excise Duty, and precisely in Art. 139 of this Act.

    What about inter-warehouse movement?


    Unfortunately, here the regulations also contain exceptions, despite the movement from warehouse to warehouse there may be an obligation to register the carriage.

    The Act provides that in the case of an inter-warehouse transfer, it will be mandatory to submit a notification in the SENT system if the goods are transported from the territory of one Member State to the territory of another Member State or a third country.


    Agnieszka Szkutnik

    Tax advisor, Expert customs and excise duties

    Customs and excise expert. For over 25 years, he has been a customs and customs and tax officer in control, judicial and managerial positions. Supports the operation of entrepreneurs, including customs agencies in the field of customs consultancy, excise duty, tax on games, authorized entrepreneur with AEO status, or tax and customs warehouses. Provides assistance in obtaining Binding Tariff Information and in solving problems related to the obligations and control under the SENT system.

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    Łukasz Oleś


    He currently focuses his practice on banking, insurance and criminal cases, in particular concernin. crimes against financial institutions. He believes that practicing as an attorney consists of providing services to all those who need it, regardless of their current situation. His motto is the words of Roman jurist Ulpian Domitius: "Advocatus non accusat - a lawyer does notaccuse."

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