Poland: changes in the SENT system from 1 January 2025

New obligations for carries related to the SENT system will be introduced from 1 January 2025.

Today, the monitoring system SENT only apply to selected products (list published by Ministry of Finance). However, from 1 January 2025, it will be necessary for every non-EU carrier performing international transport, and for EU carrier if cabotage operation takes place, to notify their operations.

Official website e-toll:

https://etoll.gov.pl/en/

Detailed changes:

A non-EU registered foreign entity performing transport operations under:
(1) Polish road permit,
(2) ECMT license,
(3) exemptions from the obligation to have these permits,
will be obliged to notify the transport on territory of Poland through the SENT system. This obligation must be completed before commencing the transport within the territory of Republic of Poland.  A Reference number must be obtained.

The obligation concerns also carriers registered in EU if performing cabotage operations. 

Entities are also obliged to immediately update the data.

During the entire transport operation covered by the notification, the company must ensure to transfer live geolocation data of the vehicle, through a GPS device (OBU or External Location System (ZSL)) or the application e-TOLL PL on smartphone. 

The driver is obliged to:

1. turn on the locator:
   a) before the start of the operation in case of transport from Poland (export). In case of multiple loading places in the territory of Poland, the system should be tuned on from the first place of loading,
   b) while entering the territory of Poland in case of import to Poland or transit.
2. turn off the locator no earlier than:
   a) delivery of the goods to the place of delivery of the goods in the territory of Poland; and in case of several places of delivery in the territory of Poland, at the last place of delivery of in Poland,
   b) after completion of the transport operation in the Polish territory.

If the locator or external location system is not operable for more than an hour, the driver is obliged to immediately stop at the nearest parking area or parking bay. In case of ADR transport, the driver is obliged to stop the vehicle at the nearest parking area taking into account the provisions of sections 8.4 and 8.5 of ADR agreement.

The operation can then continue after:

1. restoring the functionality of the locator or external location system, or
2. reloading the goods onto a vehicle equipped with a functional locator or whose geolocation data is transferred to the register from an external location system, or
3. equipping the vehicle with an operational locator, or
4. imposing official seals on the vehicle or goods or ordering a convoy by the tax and customs administration.

The reference number is valid for 10 days from the date of issuance. After this time the transport of goods may continue only after obtaining a new reference number.

The SENT notification includes:

1. Data of the foreign entity performing road transport operation of goods, including:
   a) name and surname or name,
   b) address of residence or registered office.
2. Tax identification number of the foreign entity performing road transport of goods or number,
   by which the entity is identified for the purposes of tax on goods and services or value added tax, if it is obliged to have it.
3. Sender's details including:
   a) name and surname or name,
   b) address of residence or registered office.
4. Consignee’s data including:
   a) name and surname or name,
   b) address of residence or registered office.
5. Planned place and date of commencement of transport within the territory of the Republic of Poland.
6. Planned place and date of completion of transport within the territory of the Republic of Poland.
7. Country of loading.
8. Country of unloading.
9. Number of the transport document accompanying the transported goods.
10. Permit number and in the case of:
    a) performing road transport on the basis of an ECMT permit - the number of this permit, validity period, the country of residence of the road carrier,
    b) exemption from the obligation to have a permit, on the basis of the provisions of international agreements binding on the Republic of Poland in the field of road transport or ECMT permits - the legal basis for this exemption.
11. Registration plate numbers of the vehicles used for transport.
12. Device number used for sending gelocalisation data (GPS device: OBU or  External Location System (ZSL) or application e-TOLL PL on smartphone).

Separate notifications are required if performing multiple operations subject to notifications with more than one road permit (or in case of separate exemptions).

If the journey is performed without notification in the SENT system, the journey is considered to be carried out without a valid permit.

A foreign entity carrying out road transport of goods is obliged to provide the driver with a reference number before starting the transport within the territory of Poland. If the driver does not receive the reference number or a document replacing the notification and the confirmation of acceptance of the document replacing the notification, the driver is obliged to refuse to start transporting the goods.

Penalties:

• For driver in the case of road transport of goods without presenting the reference number or a document replacing the notification or confirmation of acceptance of the document replacing the notification - PLN 1,500
• For a company in the case of road transport of goods without reporting to the SENT register or reporting data and information that is incomplete or inconsistent with the actual situation - PLN 12,000
• For a company in the case of road transport of goods, in the event of violation of the obligation to provide geolocation data - PLN 10,000

Source: ZMPD