Poland Expands SENT Monitoring to CN 1518 Fats and Oils: New Transport Obligations from October 2026

Summary

• Poland has extended its SENT transport monitoring system to cover certain chemically modified animal, vegetable or microbial fats and oils classified under CN heading 1518.
• The monitoring obligation applies only to consignments exceeding 500 kg or 500 litres, aligning with existing SENT quantitative thresholds.
• The new rules enter into force six months after publication, meaning they will apply from the end of October 2026.

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Article

On 22 April 2026, the Polish Minister of Finance adopted a regulation expanding the scope of the SENT transport monitoring system. The regulation was published in the Polish Journal of Laws on 30 April 2026 and introduces additional categories of goods that will be subject to transport monitoring when moved for business purposes within, into or through Poland.

Extension of SENT to CN Heading 1518

The key change introduced by the regulation is the inclusion of goods classified under Combined Nomenclature (CN) heading 1518. This heading covers a wide range of chemically modified fats and oils, including animal, vegetable or microbial fats and oils and their fractions that have been boiled, oxidised, dehydrated, sulphurised, blown or polymerised by heat (in vacuum or inert gas), as well as other chemically modified products. It also includes inedible mixtures or preparations of fats or oils or of fractions of different fats or oils. Products already falling under CN heading 1516 are explicitly excluded from this extension.

By bringing CN 1518 within the SENT framework, the Polish authorities are further broadening the monitoring net to include goods that may present an increased risk of tax fraud or irregularities in supply chains, particularly where such products are used as inputs in industrial or energy-related processes.

Thresholds and scope of application

The regulation does not impose monitoring obligations on all movements of CN 1518 goods. As with many other goods already covered by SENT, monitoring will only be required where the transport exceeds specific quantitative thresholds. In this case, the obligation arises when consignments exceed 500 kilograms or 500 litres.

This threshold-based approach is consistent with the existing structure of the SENT system and aims to balance effective tax oversight with proportionality, avoiding excessive administrative burdens for small-scale or low-volume movements.

Practical implications for businesses

Businesses involved in the production, distribution, or transport of chemically modified fats and oils falling under CN 1518 should assess whether their operations are affected. Where the thresholds are exceeded, the standard SENT obligations will apply, including registration of the transport in the SENT system, submission of the required data before the transport starts, and ensuring that reference numbers are carried during transport.

Failure to comply with SENT obligations can result in significant administrative penalties, including fines and potential seizure of goods. Companies operating cross-border supply chains or using Poland as a transit country should pay particular attention, as SENT can apply not only to domestic transports but also to imports, exports and intra-EU movements.

Entry into force and next steps

The amendment will become effective six months after its publication, meaning that the extended scope of SENT will apply from the end of October 2026. This lead time gives affected businesses a limited but important window to review product classifications, update internal procedures, train staff, and adjust IT or logistics processes to ensure compliance.

Given the increasing use of transport monitoring and digital oversight tools in Poland, the extension to CN 1518 should be seen as part of a broader trend towards tighter control of sensitive goods flows. Businesses would be well advised to proactively prepare for the change rather than react once enforcement begins.

Note: In Poland, the transportation of selected goods for business purposes is subject to monitoring under the SENT system, which is designed to combat tax fraud and improve oversight of high-risk goods movements.

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