CN 1518 in the SENT System as of 31 October 2026. New obligations for the transport of fats and oils

What is changing?

Following the amendment to § 1 point 1 of the Regulation, the SENT system will cover goods classified under the Combined Nomenclature (CN):

• CN 1507–1516,

• CN 1517, excluding margarine and liquid margarine,

• CN 1518,

provided that the gross weight of the shipment exceeds 500 kg or its volume exceeds 500 litres.

In practice, the key novelty is the addition of CN 1518, which covers, among others, certain animal, vegetable or microbiological fats and oils and their fractions subjected to specific chemical processes, as well as certain mixtures and preparations containing such fats or oils.

The change may also affect businesses outside the “typical” oil industry

The extension of SENT may be relevant not only for producers and distributors of oils and fats. Goods classified under CN 1518 may also appear in the operations of companies in the food, bakery, confectionery, gastronomy, feed, chemical industries, as well as in the trading of raw materials and by‑products used industrially.

The key factor is not the commercial name of the product, but its correct CN classification. Companies should therefore verify not only goods sold as oils or fats, but also mixtures, preparations and processed products that may fall under CN 1518.

What should be done before 31 October?

With several weeks remaining before the new provisions take effect, now is the right time to analyse your goods flows and determine whether purchases, sales, imports, intra‑EU acquisitions or warehouse transfers involve goods classified under CN 1518.

Particular attention should be paid to cases where a single shipment exceeds 500 kg or 500 litres. If a given transport falls under SENT, an appropriate notification may be required, along with the fulfilment of obligations imposed — depending on the transaction model — on the sender, receiver or carrier.

Failure to comply with SENT obligations may result in penalties under the Act on the road and rail transport monitoring system and the trading of heating fuels.

Transitional provisions

The Regulation introduces a transitional rule for goods under CN 1518. Transports that begin and are not completed before the effective date of the new provisions will be subject to the existing rules.

This means that the new obligations will generally apply to transports starting on or after 31 October 2026.

Verify your classification before the new rules take effect

In practice, the greatest challenge may be determining whether a specific product actually falls under CN 1518. For processed products, mixtures or preparations, the commercial name alone often does not allow for a clear classification.

Before the new provisions enter into force, it is therefore advisable to review the CN codes used, safety data sheets, product specifications and transport models. This will help identify which flows will require SENT handling from 31 October 2026.

Contact:
Tomasz Orłowski
Senior Manager
email: tomasz.orlowski@thedy.pl
mob: +48 519 504 890