Benzene, toluene and xylene under CN 2707 in SENT from 500 l

What heading 2707 covers

Heading 2707 is oils and other products of high-temperature coal-tar distillation and similar products in which aromatic constituents exceed non-aromatic ones: benzene, toluene, xylene, naphthalene, solvent naphtha, creosote oils. It is feedstock for solvents, paints, lacquers and synthesis. A common mix-up in chats: a ready paint thinner is usually 3814, which is under SENT only with ethyl alcohol or with over 70 % petroleum oils; pure toluene or xylene invoiced as 2707 is always covered from the threshold.

When carriage of 2707 is under SENT

The threshold is the standard one for chemicals listed in the act itself: over 500 kg gross or over 500 litres per consignment (art. 3 ust. 2 pkt 1 lit. b). A consignment is counted per CN heading from one consignor to one consignee, to one place, by one means of transport. Unit packages up to 11 l inclusive are outside the system (art. 3 ust. 4 pkt 2 lit. aa), so a pallet of 5-litre tins of toluene is not covered, while one 200-litre drum plus an IBC is.

Is 800 l of xylene in four 200-litre drums under SENT? Yes. The package exceeds 11 l and the consignment exceeds 500 l. The consignor, consignee or carrier files depending on direction (art. 5, 6, 7 of the SENT Act).

When 2707 is not covered

The customs procedures of transit, storage, temporary admission, processing, export or re-export exempt the leg under the procedure (art. 3 ust. 6 pkt 2). Goods from the act's list moving under excise duty suspension with an e-AD in EMCS are also outside SENT (art. 3 ust. 6 pkt 3); benzene and toluene are excise goods, so deliveries between tax warehouses carry no SENT, and the procedure is visible in the e-AD. Postal parcels of a postal operator are outside the system (art. 3 ust. 6 pkt 1).

What it means for a Ukrainian carrier

Chemicals from Germany to Ukraine through Poland with an export MRN travel outside SENT; the same load without a customs procedure is transit under art. 7, and the carrier files SENT300 before entering Poland. Import of 2707 for a Polish consignee is art. 6, the consignee files, but the fine for a gap in locator data still goes to the carrier (art. 22 ust. 2a). ADR is a separate matter: benzene UN 1114, toluene UN 1294, xylene UN 1307, class 3, and SENT says nothing about it.