Sigil RMPD™SENT goods list with search

SENT goods list with search

Coal and coke under CN 2701 and 2704 in SENT from 500 kg

Hard coal, briquettes (2701) and coke (2704) under Poland's SENT from 500 kg on entry into Poland and in transit without T1. Carriage out of Poland is outside.

List as in force from

Entries from the list

  • 2701Fuels, coal, gas

    Coal; briquettes and similar solid fuels manufactured from coal

    Monitored when
    gross weight of the consignment over 500 kg or volume over 500 litres
    Exclusions
    except unit packages of no more than 25 kg
    Customs procedures
    not covered under the customs procedure of transit, storage, temporary admission, processing, export or re-export
    Legal basis
    § 1 pkt 8 lit. a, goods regulation

    Note: Charcoal (CN 4402) is not on the list.

    Open this entry in the searchable list
  • 2704Fuels, coal, gas

    Coke and semi-coke of coal, lignite or peat; retort carbon

    Monitored when
    gross weight of the consignment over 500 kg or volume over 500 litres
    Exclusions
    except unit packages of no more than 25 kg
    Customs procedures
    not covered under the customs procedure of transit, storage, temporary admission, processing, export or re-export
    Legal basis
    § 1 pkt 8 lit. b, goods regulation
    Open this entry in the searchable list

What headings 2701 and 2704 cover

Heading 2701 is hard coal, briquettes, ovoids and similar solid fuels made from coal. Heading 2704 is coke and semi-coke of coal, lignite or peat, and retort carbon. Charcoal 4402 and wood pellets 4401 are not on the list. Lignite 2702 is not either. Both headings were added by the regulation, not by the act itself (§ 1 pkt 8 of the goods regulation), which is why their set of exclusions differs from the fuels in art. 3 ust. 2.

When carriage of 2701 and 2704 is under SENT

Threshold: over 500 kg gross per consignment. Unit packages up to 25 kg are excluded (§ 2 ust. 8 pkt 3), so a pallet of 20 kg bags is outside the system, while a tipper or big bags are covered. Direction decides everything. Carriage starting in Poland (art. 5) is outside SENT entirely (§ 2 ust. 8 pkt 1): coal from a Polish mine to Ukraine needs no notification. Entry into Poland (art. 6) is covered, the consignee files. Transit through Poland from an EU state (art. 7) without a customs procedure is covered, the carrier files form SENT300 (FAQ 09.01).

Does 24 tonnes of coal from Czechia to Ukraine through Poland without T1 need SENT? Yes. Transit under art. 7, the carrier files before entering Poland. The same coal from a Polish mine? No. The carriage starts in Poland and § 2 ust. 8 pkt 1 removes the duty.

When 2701 and 2704 are not covered

Carriage out of Poland (art. 5). The customs procedures of transit, storage, temporary admission, processing, export or re-export (§ 2 ust. 8 pkt 2). Packages up to 25 kg. Coal from outside the EU released for free circulation at the border and then sold to a Polish buyer travels under art. 5 and is not covered (FAQ 09.04); the same coal from the border to an inland customs office under T1 is not covered either (FAQ 09.05).

What it means for a Ukrainian carrier

Coal from Poland to Ukraine is the simplest case in SENT: no notification, only the non-EU carrier's RMPD and the border documents. Charcoal is harder, where SENT does not apply but ADR does (UN 1361), and so is coke from Czechia through Poland without T1, where the carrier files SENT300. Both cases with fines are taken apart in Coal and charcoal from Poland under SENT, ADR, or neither.

Frequently asked questions

Does coal from Poland to Ukraine need SENT?
No. Carriage starting in Poland (art. 5 of the SENT Act) is excluded for 2701 and 2704 (§ 2 ust. 8 pkt 1 of the goods regulation). There is no notification; a Ukrainian carrier files the RMPD as always.
Is charcoal under SENT?
No. Charcoal has code 4402, which is not on the SENT list. It is, however, dangerous goods UN 1361 class 4.2 under ADR, and without test N.4 the truck runs under full ADR.
Who files SENT for coke from Czechia to Ukraine through Poland?
The carrier, when there is no customs procedure. Transit from an EU state to a third country is art. 7, form SENT300 before entering Poland (PUESC FAQ 09.01). With T1 or an export MRN from Czechia the load is outside SENT (§ 2 ust. 8 pkt 2).

Sigil handles RMPD declarations. The SENT declaration is filed by the consignor or consignee; a carrier from outside the EU files SENT itself only in transit through Poland (art. 7 of the SENT Act).

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