Does 600 l of grease in 200-litre drums need SENT?

**Yes.** A consignment over 500 l in a package larger than 16 l is covered (art. 3 ust. 2 pkt 1 lit. f of the SENT Act). Three drums of 200 l is exactly the example PUESC gives in FAQ 03.04.

Lubricant in 20-litre canisters: is the limit 16 or 20 l?

**It depends on the code.** For heading 3403 in general the exclusion is up to 16 l (art. 3 ust. 4 pkt 2 lit. d), so a 20-litre canister is covered. For lubricants for machines, equipment and vehicles under ex 3403 19 20 and ex 3403 19 80 the limit is 20 kg or 20 l (§ 2 ust. 1 pkt 4 and 5 of the exclusions regulation), so a 20-litre canister is not covered and a 25-litre one is.

A lubricant with 80 % petroleum oils: 3403 or 2710?

**2710.** Heading 3403 covers preparations with petroleum oils below 70 % by weight; from 70 % it is 2710 with an exclusion for packages up to 11 l (and for 2710 19 81 up to 20 kg or 20 l). The consignor sets the code from the composition and puts it on the invoice.

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Lubricants and greases under CN 3403 in SENT from 500 l

Greases, cutting fluids and anti-corrosion preparations (CN 3403) under Poland's SENT from 500 kg or 500 l. Packages up to 16 l outside, machine lubricants 20 l

List as in force from 20.06.2026

Entries from the list

3403Alcohol and chemicals
Lubricating preparations (including cutting-oil, anti-rust and anti-corrosion preparations), excluding those containing 70 % or more of petroleum oils
Monitored when
gross weight of the consignment over 500 kg or volume over 500 litres
Exclusions
except unit packages of no more than 16 l, and for machine and vehicle lubricants (ex 3403 19 20 and ex 3403 19 80) no more than 20 kg / 20 l
Customs procedures
not covered under the customs procedure of transit, storage, temporary admission, processing, export or re-export
Legal basis
art. 3 ust. 2 pkt 1 lit. f, SENT Act
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What heading 3403 covers

Heading 3403 is lubricating preparations containing less than 70 % petroleum oils: greases, cutting and cooling fluids, penetrating oils, anti-corrosion preparations, mould-release agents, preparations for treating textiles and leather. At 70 % or more petroleum oils it is already 2710 with a different package limit. The consignor sets the code from the composition, and that code is on the invoice.

When carriage of 3403 is under SENT

Threshold: over 500 kg gross or over 500 litres per consignment (art. 3 ust. 2 pkt 1 lit. f of the SENT Act). Unit packages up to 16 l inclusive are excluded (art. 3 ust. 4 pkt 2 lit. d). For lubricants for machines, equipment and vehicles under codes ex 3403 19 20 and ex 3403 19 80 the package limit is different: 20 kg or 20 l (§ 2 ust. 1 pkt 4 and 5 of the exclusions regulation).

PUESC takes a mixed consignment: 100 containers of 10 l plus three drums of 200 l, 1,600 l in total. The notification covers only the 600 l in drums, because the 1,000 l in 10-litre containers fall under the exclusion (FAQ 03.04). Is a pallet of grease in 400 g cartridges under SENT? No. The package is smaller than 16 l, however many cartridges there are.

When 3403 is not covered

Packages up to 16 l (for machine lubricants up to 20 kg or 20 l). The customs procedures of transit, storage, temporary admission, processing, export or re-export (art. 3 ust. 6 pkt 2). Excise duty suspension with an e-AD, when the preparation is an excise good (art. 3 ust. 6 pkt 3). Postal parcels (art. 3 ust. 6 pkt 1).

What it means for a Ukrainian carrier

Lubricants from a Polish warehouse to Ukraine leave under the export procedure, so SENT is needed only up to the export clearance point and the consignor files it. Import into Poland from Germany for a Polish consignee is art. 6, the consignee files. Transit from the EU to Ukraine without a customs procedure is art. 7 and SENT300 from the carrier before entry. In all three cases a non-EU carrier files an RMPD; the SENT threshold has no effect on the RMPD, which is needed from the first kilogram.

Frequently asked questions

Does 600 l of grease in 200-litre drums need SENT?: Yes. A consignment over 500 l in a package larger than 16 l is covered (art. 3 ust. 2 pkt 1 lit. f of the SENT Act). Three drums of 200 l is exactly the example PUESC gives in FAQ 03.04.
Lubricant in 20-litre canisters: is the limit 16 or 20 l?: It depends on the code. For heading 3403 in general the exclusion is up to 16 l (art. 3 ust. 4 pkt 2 lit. d), so a 20-litre canister is covered. For lubricants for machines, equipment and vehicles under ex 3403 19 20 and ex 3403 19 80 the limit is 20 kg or 20 l (§ 2 ust. 1 pkt 4 and 5 of the exclusions regulation), so a 20-litre canister is not covered and a 25-litre one is.
A lubricant with 80 % petroleum oils: 3403 or 2710?: 2710. Heading 3403 covers preparations with petroleum oils below 70 % by weight; from 70 % it is 2710 with an exclusion for packages up to 11 l (and for 2710 19 81 up to 20 kg or 20 l). The consignor sets the code from the composition and puts it on the invoice.

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).

Sources

Other codes with their own page

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