Beginning from November we are going to face great changes in SENT, namely System for Electronic Transport Supervision, monitored by the National Revenue Agency, that is used to monitor sensitive goods. Starting from now, SENT becomes obligatory for haulers from outside EU, as well. Solutions that originally were supposed to come into force since 2025 are going to be implemented on 1 November 2024.
From that day all foreign haulers who do not have their registered offices on the territory of EU, the Swiss Confederation or a member state of the European Free Trade Association (EFTA) are obliged to register transports they perform in the SENT register. The above must be made irrespective of the type of goods that are transported. Both transportations carried out w the territory of Poland and cabotage transports are subject to SENT registration.
This obligation results from art. 28b of the Act on road transport, according to which in the event where the following is required to carry out international road transport of goods referred to in art. 28(1)(1a) (and cabotage transport referred to in art. 29):
- permit to carry out international road transport of goods on the territory of the Republic of Poland,
- foreign ECMT permit,
- cabotage transport carriage,
as well as where provisions of international agreements concerning the road transport that are binding for the Republic of Poland release one from the obligation to possess such permits, a foreign entity that carries out such a transport is obliged to, prior to commencement of transport on the territory of the Republic of Poland, send to the register of notifications a registration of such a transport and obtain a reference number for such a registration (the reference number must be valid for 10 days from the date it is issued). Thus, registrations in SENT must be made before crossing the Polish border.
Obligation to register SENT transports in the RMPD Register
Foreign haulers who do not have their registered offices in any of the EU Member States make registrations in SENT in the Register of International Road Transport (RMPD Register) that has been specifically created for this purpose and is available on the PUESC platform.
For this purpose, 3 dedicated forms are made available on the PUESC platform:
- RMPD100 – registration of transport by the hauler,
- RMPD – update,
- RMPD406 – checking transport registration validity together with the last GPS position [RMPD].
A registration of transport should itself include the following:
- foreign data of entity that carries goods by road transport,
- tax identification number of entity that carries goods by road transport,
- sender’s and recipient’s data,
- planned place and date of commencement and ending of transport on the territory of the Republic of Poland,
- country of loading,
- country of unloading,
- transportation document number that accompanies the transported goods,
- permit number,
- registration numbers of vehicles used for carrying out transport,
- locator number.
Note: Please be reinformed that SENT registration for road haulers from outside UE is required irrespective of the goods they transport. This means that it does not apply only to sensitive goods.
More than one registration possible in RMPD
If a foreign entity carrying out international road transport of goods simultaneously carries out several transport operations as a part of such transport (including cabotage operations) for which there is required more than a single permit or there are different legal bases exempting from such an obligation, then each such transport operation requires a separate registration in RMPD in the SENT system.
Absence of registration in the RMPD register is subject to sanctions
Transport that is not registered in the notifications register can be stopped by authorised services that, in such a case, issue the hauler relevant financial penalties. Transport carried out without registration in RMPD is considered to be carried out without permit for road transport of goods.
Currently, on the basis of art. 24 of the Act on SENT, hauler can be issued a fine in the amount of PLN 10.000 if the transport is not registered. However, foreign haulers will be subject to sanctions foreseen in appendix no. 3 to the Act on road transport in the amount of PLN 10.000 or PLN 12.000.
What happens with SENT from 1 January 2025?
As of this date, the obligation to register the transport of goods by road is to apply to haulers from other EU countries, the Swiss Confederation or EFTA member states. These are, specifically, entities that carry out road transportation on the territory of the Republic of Poland to or from countries outside EU on the basis of a permit required by provisions of an international agreement that binds Poland and such other country.
Due to this, starting from the upcoming year the obligation to make registration in SENT will also apply to the EU haulers in certain situation.
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