LPG and propane-butane under CN 2711 in SENT, no threshold

What heading ex 2711 covers

The list carries ex 2711, that is only part of the heading: propane, butane and propane-butane mixtures, liquefied (§ 1 pkt 4 of the goods regulation). Natural gas CNG and LNG are also in 2711 but fall outside the ex and outside SENT. Autogas for filling stations, gas in tankers for domestic tanks, propane for industrial burners are this code.

When carriage of 2711 is under SENT

There is no threshold: LPG is covered regardless of the quantity in the consignment. The only quantity exclusion concerns the package: cylinders up to 69 kg gross or up to 85 l are outside the system (§ 2 ust. 4 pkt 4), so a truck of 11 kg household cylinders is not covered, while a tanker is. In the notification the quantity is recommended in litres (FAQ 05.01). Dead stock in the tanker, 200 to 500 kg of gas that cannot be physically pumped out, is not part of the goods if it is part of the tare (FAQ 05.06). Gas left after a route and topped up the next day may travel on two notifications or on one new one for the whole volume (FAQ 05.05).

Is an LPG tanker delivering to five customers under SENT? Yes, for each delivery. For round deliveries there is the collective notification SENT_120 with several consignees and a 10 % tolerance for each (FAQ 05.16 to 05.27).

When 2711 is not covered

Cylinders up to 69 kg or 85 l. The customs procedures of transit, storage, temporary admission, processing, export or re-export (§ 2 ust. 4 pkt 1). Movement under excise duty suspension with an e-AD, and outside it with an e-DD, including gas exempt from excise by purpose, for example for heating (§ 2 ust. 4 pkt 2 and 3, FAQ 05.31, 03.10).

What it means for a Ukrainian carrier

LPG from Poland to Ukraine leaves under the export procedure and is outside SENT on that leg. The notification covers only the road from the depot to the customs office where export is opened, and the consignor files it. Transit of gas from the EU through Poland without a customs procedure is art. 7 and SENT300 from the carrier. A gas tanker also carries ADR (UN 1965), and SENT is not linked to ADR. An RMPD is filed in every case.