Does glycol antifreeze need SENT?

**No.** The list carries only 3820 containing ethyl alcohol (art. 3 ust. 2 pkt 1 lit. i of the SENT Act). Antifreeze on ethylene or propylene glycol without ethanol is outside SENT whatever the quantity. The SDS from the consignor confirms the composition.

Is winter screen wash in 5-litre canisters under SENT when the total exceeds 500 l?

**No.** Goods of 3820 with ethanol in unit packages up to 16 l are excluded (art. 3 ust. 4 pkt 2 lit. f). PUESC confirms this in FAQ 03.09 for a 540-litre pallet in 5-litre canisters. In a 1,000-litre IBC the same fluid is covered.

Ethanol antifreeze from Germany to Ukraine through Poland: who files SENT?

**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. If export was opened in Germany and the driver has an MRN, the load travels under the export procedure and no SENT is needed (art. 3 ust. 6 pkt 2 lit. a, PUESC FAQ 04.13).

SENT goods list with search

Antifreeze under CN 3820 in SENT only with ethanol

Antifreeze and de-icers (CN 3820) are under Poland's SENT only with ethyl alcohol, from 500 kg or 500 l. Glycol antifreeze and packages up to 16 l are outside.

List as in force from 20.06.2026

Entries from the list

3820Alcohol and chemicals
Anti-freezing preparations and de-icing fluids containing ethyl alcohol
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. i, SENT Act
Note: Only preparations containing ethyl alcohol. Glycol antifreeze without ethanol (most automotive products) is outside SENT.
Open this entry in the searchable list

What heading 3820 covers

Heading 3820 is anti-freezing preparations and prepared de-icing fluids: engine coolants, winter screen wash, de-icers. The SENT list does not carry the whole heading, only "3820 zawierające alkohol etylowy", that is fluids containing ethyl alcohol (art. 3 ust. 2 pkt 1 lit. i of the SENT Act). Engine antifreeze based on ethylene or propylene glycol contains no ethanol and is not under SENT. Winter screen wash on ethanol, even fully denatured, is.

When carriage of 3820 is under SENT

Threshold: over 500 kg gross or over 500 litres per consignment. Unit packages up to 16 l inclusive are excluded (art. 3 ust. 4 pkt 2 lit. f). PUESC takes exactly this case: a pallet of 108 five-litre canisters of screen wash, 540 l in total, is not covered because each package is smaller than 16 l (FAQ 03.09). The same fluid in a 1,000-litre IBC is covered.

Is ethanol antifreeze in four 200-litre drums under SENT? Yes. 800 l in a package larger than 16 l. The composition is in the safety data sheet (SDS) from the consignor: section 3 shows ethanol and its share. Without an SDS the inspector judges by the name, and "antifreeze" without the word "glycol" works against you.

When 3820 is not covered

Glycol antifreeze is never covered, because it is not on the list. Ethanol fluid in packages up to 16 l 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). Postal parcels are outside the system.

What it means for a Ukrainian carrier

Antifreeze from Germany to Ukraine is the carriers' chat case taken apart in SENT transit through Poland, the control summons and border. Antifreeze from Germany to Ukraine: glycol is outside SENT in any quantity; ethanol with an export MRN from Germany is outside too, because it travels under the export procedure; ethanol without a customs procedure is transit under art. 7, the carrier files SENT300 before entering Poland, and a summons to present the vehicle at the border may arrive with the reference number (art. 12a). An RMPD is filed in all three variants.

Frequently asked questions

Does glycol antifreeze need SENT?: No. The list carries only 3820 containing ethyl alcohol (art. 3 ust. 2 pkt 1 lit. i of the SENT Act). Antifreeze on ethylene or propylene glycol without ethanol is outside SENT whatever the quantity. The SDS from the consignor confirms the composition.
Is winter screen wash in 5-litre canisters under SENT when the total exceeds 500 l?: No. Goods of 3820 with ethanol in unit packages up to 16 l are excluded (art. 3 ust. 4 pkt 2 lit. f). PUESC confirms this in FAQ 03.09 for a 540-litre pallet in 5-litre canisters. In a 1,000-litre IBC the same fluid is covered.
Ethanol antifreeze from Germany to Ukraine through Poland: who files SENT?: 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. If export was opened in Germany and the driver has an MRN, the load travels under the export procedure and no SENT is needed (art. 3 ust. 6 pkt 2 lit. a, PUESC FAQ 04.13).

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

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