Heating fuels under code 0004 in SENT, no threshold, AKC-RU

What lies behind code 0004

Code 0004 is not a CN code but a system code of the SENT register for heating fuels: goods not covered by an excise exemption by purpose, referred to in art. 89 ust. 1 pkt 9, 10 and 15 lit. a of the Excise Duty Act, above all light heating oil and heating oils (art. 3 ust. 2 pkt 1a of the SENT Act). By CN these are oils of heading 2710, but with a duty that goes beyond carriage: trade in heating fuels in Poland has been monitored by SENT since 2019 together with the AKC-RU registration of sellers and consumers.

When carriage of heating fuel is under SENT

There is no threshold: heating fuel is covered regardless of the quantity in the consignment (art. 3 ust. 2 pkt 1a). The package exclusion is narrower than for 2710: up to 30 kg or 30 l in unit packages and no more than 100 kg or 100 l in total for one recipient (art. 3 ust. 5a). Code 0004 in the register is chosen by businesses and individuals who made the simplified AKC-RU registration and hold the status of an intermediary or consuming oil entity (footnote to the Ministry of Finance list). A delivery to a foundation, association or municipality is covered in any quantity (FAQ 03.19).

Is 800 l of heating oil for a private house under SENT? Yes. There is no threshold, and the buyer must hold an AKC-RU registration; the seller files, the recipient confirms receipt with a transaction code or on PUESC.

When heating fuel is not covered

Packages up to 30 kg or 30 l up to 100 kg or 100 l per recipient. Movement with an e-AD under excise duty suspension (art. 3 ust. 6 pkt 3). The customs procedures of transit, storage, temporary admission, processing, export or re-export (art. 3 ust. 6 pkt 2). The same fuel with an excise exemption by purpose is not code 0004 but ordinary heading 2710 with its own rules.

What it means for a Ukrainian carrier

Heating fuel in SENT is almost always Polish domestic trade: a seller with AKC-RU, a buyer with AKC-RU, a SENT_100 notification with a declaration of purpose. A Ukrainian carrier appears here rarely, and then as a subcontractor on the Polish leg: carries the reference number, keeps the locator on, and pays 10,000 zł, about 117,000 ₴ at the NBU rate of 11.74 ₴/zł on 21.09.2026, for a gap in data (art. 22 ust. 2a). Transit of heating oil through Poland to Ukraine is already heading 2710 with a 500 l threshold and the export-procedure exemption, not code 0004. Cabotage and the RMPD for a non-EU carrier are described in Who must file an RMPD.