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Fuel and oil additives under CN 3811 in SENT from 500 l

Fuel and oil additives (CN 3811: anti-knock, inhibitors, flow improvers) under Poland's SENT from 500 kg or 500 l per consignment. Packages up to 16 l outside.

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Entries from the list

  • 3811Alcohol and chemicals

    Anti-knock preparations, oxidation inhibitors, viscosity improvers, anti-corrosive and other additives for mineral oils or fuels

    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
    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. g, SENT Act
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What heading 3811 covers

Heading 3811 is additives: anti-knock preparations, oxidation inhibitors, gum inhibitors, viscosity improvers, anti-corrosion preparations and other additives for mineral oils and fuels or for other liquids used for the same purposes. In practice these are winter flow improvers for diesel, octane boosters, additive packages for lubricant blenders, petrol additives. The goods usually travel in IBCs or drums from a chemical plant to a fuel depot, and those are the consignments SENT sees most often.

When carriage of 3811 is under SENT

Threshold: over 500 kg gross or over 500 litres per consignment (art. 3 ust. 2 pkt 1 lit. g of the SENT Act). Unit packages up to 16 l inclusive are excluded (art. 3 ust. 4 pkt 2 lit. e). Retail bottles of additives of 250 ml or 1 l on a pallet are therefore outside the system even at a tonne gross, while a single 1,000-litre IBC is covered.

Is a pallet of diesel additive in 1-litre bottles, 1,200 l in total, under SENT? No. The package is smaller than 16 l. The same volume in 200-litre drums is covered.

When 3811 is not covered

Packages up to 16 l. 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). Additives that are excise goods moving under duty suspension with an e-AD are outside SENT (art. 3 ust. 6 pkt 3). Postal parcels are outside the system.

What it means for a Ukrainian carrier

Additives from the EU to Ukraine through Poland: with an export MRN outside SENT, without a customs procedure it is transit under art. 7 and SENT300 from the carrier before entering Poland. Additives for a Polish consignee are art. 6, the consignee files, and the carrier carries the reference number and keeps the locator on (art. 10a and 10b). A Ukrainian carrier files an RMPD in each of these cases.

Frequently asked questions

Do fuel additives need SENT?
Yes, from 500 kg or 500 l per consignment, in packages over 16 l. Heading 3811 is in the act itself (art. 3 ust. 2 pkt 1 lit. g), the exclusion for unit packages up to 16 l is in art. 3 ust. 4 pkt 2 lit. e.
Is a retail additive in bottles covered?
No. Bottles of 250 ml or 1 l are packages up to 16 l and are outside SENT whatever the total mass of the pallet. Drums and IBCs are covered from the threshold.
Who files SENT for additives from Germany to a Polish consignee?
The consignee in Poland. Carriage ending in Poland is art. 6 of the SENT Act: the consignee files before the goods enter Poland, and the carrier adds the locator number and carries the reference number.

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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