Transport /

EMPD register for non-EU carriers – new obligations

With the beginning of November 2024 and partly with the beginning of January 2025, major changes to SENT, the Electronic Transport Supervision System supervised by the National Tax Administration and used to monitor the transport of sensitive goods, came into force. From now on, SENT will become mandatory for non-EU carriers as well, and regardless of the type of goods transported.

From now on, SENT will become mandatory for non-EU carriers as well, and regardless of the type of goods transported.

When to report to RMPD?

RMPD is the Register of International Carriage by Road.

When international carriage of goods by road , as referred to in Article 28 (1) and (1a) of the Road Transport Law, and cabotage carriage, as referred to in Article 29, is performed by an entity based in a non-EU and EEA country, the foreign transport operator:

  • on the basis of a permit to perform international road transportation of goods;
  • on the basis of a multilateral ECMT permit;
  • without a permit – transports liberalized on the basis of bilateral agreements with the Republic of Poland or transports that do not require a permit, such as those performed on the basis of the agreement between Ukraine and the European Union of June 29, 2022 on the transport of goods by road;
  • on the basis of a permit for cabotage transport, issued by an administrative decision by the Chief Inspector of Road Transport

shall be obliged, prior to the commencement of carriage on the territory of the Republic of Poland, to send a notification of such carriage to the register of notifications.

Obligation to report to RMPD – from when?

Under the new regulations, the obligation to register the carriage of goods by road will apply:

  • from November 1, 2024. – carriers who are not established in an EU member state, the Swiss Confederation or an EFTA member state,
  • as of January 1, 2025. – carriers from other EU member states, the Swiss Confederation or EFTA member states. These are entities that carry out road transport on the territory of Poland to or from a non-EU country on the basis of a permit required by the provisions of an international agreement binding Poland and that country.

Register of notifications and notification forms are available online on the PUESC platform: https://puesc.gov.pl/

Fines for RMPD-related violations

There are penalties for violations of the obligation to report carriage to the RMPD register or GPS monitoring. They can be imposed on both the carrier and the driver. Fines are also threatened for errors in the notifications or failure to update them.

If several transport operations are carried out in a single trip, requiring separate international permits – then each such operation will require a separate notification to the RMPD register.Therefore several fines may be imposed for failure to do so.

Violation of the obligation to report to the RMPD may also lead to the detention of the vehicle by authorized services.

Importantly, transports carried out without notification to the RMPD will be treated as being carried out without a permit to transport goods by road.

Importantly, transports carried out without notification to the RMPD will be treated as being carried out without a permit to transport goods by road.

Very often, when inspecting and stopping foreign vehicles, it is necessary to pay a deposit in the amount of the expected penalties for the violations found. Without payment of the deposit, release of the vehicle for further transportation is most often impossible.

Is it possible to appeal a fine?

Fines in statutory amounts are imposed by administrative decision, which can be appealed within 14 days from the date of service of the decision, followed by a complaint to the Provincial Administrative Court and a cassation complaint to the Supreme Administrative Court.

If the appeal is upheld and the penalty is revoked, the deposit is refunded and the penalty is not due.

What are your obligations?

Remember to report to the RMPD before the start of transportation on Polish territory.

Even if you are a few minutes or hours late and you only report while transiting Poland, fines may be imposed by the relevant authorities.

Remember, too, that in addition to reporting to the RMPD, the need to report SENT and the need to provide geolocation during the transit may also apply independently.

Want to learn more? If you are wondering whether it is necessary to declare to RMPD or SENT or to make both declarations, you have doubts about which goods and which transports the declarations and registers apply to, you have had problems with documents during a customs inspection, or you have been imposed fines, please contact our law firm at [email protected].

Author team leader DKP Legal
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