CN Code 1518 in the SENT System from 31 October 2026: New Obligations for the Transport of Fats and Oils

One of the most important changes is the inclusion of goods classified under CN code 1518 in the SENT system. The new rules will apply from 31 October 2026.

What is changing?

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

• CN 1507–1516;
• CN 1517, excluding margarine and liquid margarine;
• CN 1518;

where the gross weight of the consignment exceeds 500 kg or its volume exceeds 500 litres.

In practice, the key development is the inclusion of CN 1518, which covers, among other things, certain animal, vegetable or microbial fats and oils, and their fractions that have undergone specific chemical processes, as well as certain mixtures and preparations made from such fats or oils.

The change may also affect businesses outside the “typical” oils sector

The extension of SENT may be relevant not only to producers and distributors of oils and fats. Goods classified under CN 1518 may also occur in the operations of businesses in the food, bakery, confectionery, catering, animal-feed and chemical sectors, as well as in trade in raw materials and by-products used for industrial purposes.

The decisive factor is not the product’s commercial description, but its correct CN classification. Businesses should therefore verify not only goods sold as oils or fats, but also mixtures, preparations and processed products that may be classified under CN 1518.

What should be done before 31 October?

There are still several weeks before the new rules apply. This is the right time to analyse goods flows and determine whether goods classified under CN 1518 occur in purchases, sales, imports, intra-EU acquisitions or movements between warehouses.

Particular attention should be given to cases where an individual consignment exceeds the threshold of 500 kg or 500 litres. If a given transport operation is subject to SENT, it may be necessary to submit the relevant transport notification and fulfil the obligations that, depending on the transaction model, fall on the sender, recipient or carrier.

Failure to fulfil obligations under the SENT system may result in penalties provided for in the Act on the Road and Rail Transport Monitoring System for Goods and Trade in Heating Fuels.

Transitional provisions

The Regulation includes a transitional rule for goods under CN 1518. Transport operations that began but were not completed before the new rules enter into force will remain subject to the existing provisions.

This means that the new obligations will generally apply to transport operations commencing from 31 October 2026.

It is worth verifying the classification before the new rules take effect

In practice, the greatest challenge may be determining whether a particular product actually falls within CN 1518. For processed products, mixtures and preparations, the commercial name alone will often not make it possible to determine the classification unambiguously.

Before the new rules take effect, it is therefore advisable to review the CN codes used, safety data sheets, product specifications and transport models. This will help determine which goods flows will require handling through the SENT system from 31 October 2026.

Contact:

Tomasz Orłowski
Senior Manager
Email: tomasz.orlowski@thedy.pl
Tel.: +48 519 504 890