SENT expands its catalogue — what 31 October 2026 means

For years the SENT system has monitored the carriage of selected sensitive goods on Polish territory: fuels, alcohol, tobacco and vegetable oils under CN headings 1507–1517. From 31 October 2026 the list also includes heading CN 1518 — inedible fats and oils used for technical and industrial purposes. For the TSL sector this is not a “new system”, but an extension of an existing register. What does change is the map of loads for which a forwarder must immediately ask for the CN code and quantity, instead of treating the order as an ordinary liquid haul.

The legal basis is the ordinance of the Minister of Finance and the Economy of 22 April 2026 (Journal of Laws 2026, item 589), published on 30 April. The rules enter into force six months later — on 31 October. Poland’s National Revenue Administration (KAS) states clearly on gov.pl that the duty will cover, among others, used cooking oil (UCO), a feedstock for biocomponents, when a consignment exceeds 500 kg or 500 litres.

Why CN 1518 is joining SENT now

The market for collecting and processing used frying oil is growing with demand for biofuels and transport decarbonisation. The chain often looks like this: a restaurant or caterer hands over oil → a collector delivers it to a purification plant → the product goes to a biocomponent producer. Until now some of those runs could sit outside SENT’s radar, even though fresh vegetable oils under neighbouring CN headings were already monitored. Adding CN 1518 closes that gap and aligns rules for the whole 1507–1518 fats-and-oils group.

From Idea Logistyka’s perspective the fiscal intent is secondary to operations: this order segment often sits beside classic FTL freight. It is handled by tanker fleets, waste-collection vehicles and local carriers registered in Poland’s BDO waste database. If a forwarding dispatcher fails to spot CN 1518 at order intake, the load may leave without a SENT reference number — and a roadside or site check ends in detention, a fine and a lost slot at the customer.

What CN heading 1518 actually covers

The Combined Nomenclature classifies under CN 1518 inedible fats and oils of animal or vegetable origin intended for technical and industrial uses — not for food. KAS’s practical example is used frying oil from bars, restaurants and mass-catering points, collected by companies that process it. That is not the only case: chemical industry, lubricant production and technical process feedstocks can also fall under 1518 if the customs/goods classification points there.

Oil as waste and as a SENT good at the same time

In UCO collection, paperwork often joins two logics: waste management (BDO, waste code) and CN classification for a SENT-monitored carriage. PUESC materials stress that a SENT declaration for such goods should use CN 1518 at every stage — from hospitality to the plant and from the plant to the final recipient — and also state the correct waste code when rules on additional declaration data so require. For the forwarder that means: a “BDO waste code” alone is not enough; you also need awareness of the CN heading.

The 500 kg / 500 l threshold — how to read it without traps

The monitoring duty does not arise from a magic half-tonne weight for every load in Poland. Conditions must be met together: the goods must belong to the SENT catalogue (here: CN 1518) and the consignment’s gross mass must exceed 500 kg or its volume must exceed 500 litres. The same threshold already applies to oils under 1507–1517 (excluding margarine in CN 1517). After 31 October 2026, CN 1518 enters the same quantity rule.

In multi-stop collection another question appears: when do you count the threshold — after each stop or on the vehicle total? Practice described in the PUESC FAQ for UCO picked up from many outlets assumes the declaration is updated as successive batches are added once the limit is exceeded in aggregate. That is not an academic detail: the collection route plan and the moment of filing must be agreed with the carrier before departure, not at the third stop in a car park.

500 kg or 500 l — the threshold for CN 1518 (as for other oils in the 1507–1517 group).
Gross mass of the consignment — use the parameter in the rules, not a “rough weight from the client”.
A description “oil” or “fat” on the order does not replace the CN code — without classification you cannot assess SENT.
Multi-stop collection needs a declaration-update procedure, not a one-off guess.

Exemptions — when CN 1518 does not require SENT

KAS states that heading 1518 will use the same exemptions as other vegetable oils regulated in the SENT goods ordinance. In practice that includes certain movements under customs procedures (e.g. transit, storage, temporary admission, processing, export or re-export) and movements under duty-suspension with an e-AD or a document replacing it. A separate path covers goods in unit packs with gross mass up to 26 kg or volume up to 26 litres.

An exemption is not a licence to stop thinking. The forwarder must document why a run falls outside SENT: which customs document, which procedure, which packing. An automatic rule “above 500 kg = always SENT” can be as harmful as the reverse “it’s only fryer oil, we won’t declare”. Both end in conflict at a KAS or road inspectorate (ITD) check.

Who is responsible for what: shipper, forwarder, carrier

SENT splits roles among carriage participants. The shipper (or the party obliged to declare for a given relation type) is responsible for correct goods and quantity data. The carrier — for declaration accuracy as regards the vehicle, geolocation and route updates on Polish territory. The forwarder organising transport is often not the formal “declarant”, but chooses the carrier, sets the loading window and passes order data. An error at briefing travels down the chain — and the customer still calls the forwarder when the truck is stopped.

Fleet-side duties

When a carriage is subject to SENT, the driver must keep the locating device active on the monitored section: switch on before start, switch off after completion, and transmit live geolocation data. For transit starting and ending outside Poland it is usually the carrier that files the SENT declaration and obtains the reference number. The declaration includes, among others, shipper and consignee data, carrier, vehicle, locator, and places where carriage starts and ends on Polish territory. The forwarder should require SENT readiness confirmation from the fleet partner before the loading slot.

Operational scenarios worth rehearsing before the end of October

Scenario A — UCO collection from hospitality. A company collects oil from a restaurant chain with a tanker or specialised vehicle. When the route exceeds 500 l in total, SENT and BDO processes are required. A dispatcher must not assume “it is always below the limit” if Friday adds extra outlets.

Scenario B — delivery to a biocomponent producer. A purification plant ships a CN 1518 batch above the threshold to a refinery/biocomponent site. The relation looks like classic liquid FTL, but without a SENT number control risk is high. An industrial shipper should put the CN code and quantity in the TMS order, not in a rushed phone call.

Scenario C — technical / industrial oils. The load is not UCO, but customs classification still points to 1518. The most common mistake is a commercial description (“technical oil”, “feedstock”) without CN. The forwarder must ask for classification before dispatching trucks — especially if the client is used to unmonitored carriage.

Scenario D — carriage started before 31 October. Transitional rules provide that CN 1518 carriages started and not completed before the entry-into-force date remain under the previous rules. When planning runs across the October–November turn, note the start time and status in documentation clearly — you avoid disputes over whether a given trip already falls under the new regime.

Order-intake checklist — minimum before 31.10.2026

In forwarding companies the cheapest protection is updating the TMS/CRM checklist, not emergency training after the first fine. For every order involving oils, fats, UCO, oily waste or biofuel feedstocks, make these fields mandatory:

CN code (at least the 4-digit heading; ideally the full classification used in documents).
Gross mass and/or volume of the consignment — numbers, not a range “approx. 400–600”.
Packing method (bulk / IBC / drums / unit packs ≤26 kg or ≤26 l).
Route: domestic, import, export, transit — plus any customs procedure.
Whether the goods are also waste (BDO) — and whether SENT needs a waste code.
Who files the SENT declaration and who updates data (shipper / carrier / other party).
Whether the carrier has a locator and a start/stop geolocation procedure.
SENT reference number before departure — without it there is no green light at the ramp.

Impact on costs and SLA — what not to downplay

Filing in SENT itself is cheap compared with tanker detention, a lost window at a biocomponent receiver or an administrative fine. The real cost is dispatcher time to verify data, driver training, possible locator replacement or configuration, and an ETA buffer (declaration and corrections before start). Clients with regular UCO collections should renegotiate SLA for Q4 2026: an extra 30–60 minutes for SENT formalities is cheaper than chaotic mid-route fixes.

For B2B shippers it is worth splitting contractual responsibility for goods data and for geolocation. The forwarder can require a complete CN + quantity as a condition of accepting the order. A carrier without an active locator should not get a slot. That role split protects the chain better than a vague statement “we will do SENT if needed”.

CN 1507–1517 vs 1518 — what does not change

Existing rules for vegetable oils under CN 1507–1516 and 1517 (excluding margarine and liquid margarine) remain in force. The October 2026 change does not lower the threshold for the whole industry or introduce a universal 500 kg limit “for every good”. It extends the catalogue by one CN heading that in practice hits UCO and industrial oil flows especially hard. If your company already handles SENT correctly for food/vegetable oils, the process is similar — you only need to add CN 1518 to order-system filters and train sales and dispatch.

How Idea Logistyka prepares clients for SENT CN 1518

At Idea Logistyka we treat SENT compliance as part of quoting and route planning, not as “extra paperwork”. For oil and fat orders we verify the CN code, quantity, packing and relation type before selecting the fleet. We work with carriers that have a proven geolocation and declaration-update procedure — especially on domestic collection routes and deliveries to processing plants.

If in Q4 2026 you plan higher volumes of UCO, biocomponent feedstocks or technical oils above 500 kg/l, it is worth walking through the checklist together before new runs start. One operational workshop in October is better than a series of explanations after a November inspection.

Summary

From 31 October 2026 the carriage of CN 1518 goods — including used cooking oil — enters SENT above 500 kg or 500 litres, with the same exemptions as for other oils in the group. For the forwarder the essentials are correct classification, quantity, packing, route and a clear split of duties with the declarant and the carrier. No new monitoring system is created — a new load group appears that must no longer be “missed” at order briefing.

Need support with oils, UCO or SENT-monitored loads? Contact Idea Logistyka or request a quote with monitoring-duty verification.

Sources (verify the current status): KAS/Ministry of Finance notice “Changes in the SENT system – goods under CN 1518 subject to monitoring”; ordinance of the Minister of Finance and the Economy of 22 April 2026 (Journal of Laws 2026, item 589); PUESC materials and FAQ on SENT.

SENT from 31 October 2026 — CN 1518, UCO and the 500 kg threshold