Trade with Strategic Goods in Poland (Arms, Dual-Use and Military Technology)

Last updated: 04.07.2025

What are strategic goods?

Strategic goods are goods that are particularly important for national security and for maintaining international peace and security. These include:

• armaments – weapons, ammunition, explosives, products, their parts and technology, which are specified in the regulation on the list of conventional arms for which a license is required
• dual-use products – products, including software and technology, which can be used for both civilian and military purposes, and include all goods which can be used in non-explosive applications and in any way to support the manufacture of nuclear weapons or other nuclear explosive devices.
• goods, technologies, software specified in Annex 1 to EU Regulation No. 428/2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items.

Trade in goods of strategic importance means any activity related to the movement, making available or provision of services concerning such goods, which may affect national security and international peace and stability.

Trade in goods of strategic importance includes:

• export,
• intra-EU transfer,
• intermediary services,
• technical assistance,
• import,
• transit.

Trade in this sense is subject to strict legal regulations and controls aimed at preventing the unauthorized use of strategic goods. Trade in this context is subject to strict legal regulations and controls aimed at preventing the unauthorized use of such goods, particularly in connection with terrorism or the proliferation of mass destruction capabilities.

These measures reflect both national law and binding instruments such as UN Security Council Resolutions and multilateral frameworks, including the Missile Technology Control Regime.

Importing strategic goods into Poland

Import means the introduction into Poland of goods of strategic importance originating from countries outside the European Union, i.e., from so-called third countries. This activity is regulated not only by domestic law but also by Poland’s obligations under EU foreign policy and international non-proliferation agreement.

Import license in Poland – When is it required?

In Poland, the obligation to obtain a permit applies to the import of armaments. However, no permit is required for the import of dual-use products from third countries to Poland.

Note! If you plan to import dual-use products used in telecommunications or for information protection, you must notify the Head of the Internal Security Agency of your intention. This notification should be made at least 14 days before the planned import and concerns goods listed in Part 1 “Telecommunications” item 5A001a or 5A001b4 and in Part 2 “Information security” category 5 of Annex I to EU Regulation No. 428/2009.

Authorization for the import of arms in Poland is granted in the form of an individual administrative decision (so-called individual authorization), issued to one entity importing specified goods, their quantities and values from a specific seller.

Who may apply for an arms import authorization in Poland?

An application for a license may be submitted by:

• a natural person,
• a legal person,
• an organizational unit without legal personality, if it has legal capacity.

The applicant must have their place of residence or registered office in the territory of the Republic of Poland.

General import authorization for strategic goods in Poland

The Minister of Development and Technology may also issue a national general import license in the form of a regulation. It specifies the countries, entities, and goods of strategic importance covered by such a license. Importantly, no individual license is required for activities covered by a general license.

How to apply for an import license for strategic goods in Poland?

An individual license is obtained on the basis of an administrative decision issued after the submission of a complete application with attachments, specifying its period of validity – not longer than one year. The form must include, among other things:

• applicant’s details: name, address of registered office or place of residence in Poland,
• tax identification number (NIP),
• nature and scope of business activity, if the applicant is an entrepreneur,
• details of trading partners (name, address of registered office/place of residence, role in trade),
• details of goods of strategic importance (type, quantity, value),
• a statement of commitment to take measures to ensure the delivery of goods of strategic importance to the end user,
• details of the manufacturer and end users,
• a description of how the goods will be used by the end user.

The application must be accompanied by, among other things:

• a statement of possession of the relevant licenses or permits,
• a draft or copy of the trade agreement, a letter of intent or a request for quotation,
• an import certificate or a statement from the end user,
• a certificate of conformity confirming that the internal control and management system for trade in arms complies with the statutory requirements,
• the consent of the competent foreign authority to dispose of the goods, if required.

Note! Documents drawn up in a foreign language must be accompanied by a certified translation into Polish.

The minister responsible for the economy has the right to request additional information to verify the data provided.

After submitting the application, the Minister of Development and Technology conducts a formal and substantive assessment, taking into account the position on the absence or existence of contraindications to granting the permit expressed, inter alia, by:

• the Minister of Internal Affairs and Administration,
• the Minister of Foreign Affairs,
• the Minister of Finance,
• the Internal Security Agency, and the Intelligence Agency.

Each authority has 14 days to express its opinion. If another EU country has previously refused to issue a similar permit, Poland is required to consult with that country before making a decision.

When can an import license be refused in Poland?

The minister may refuse to grant a permit, including if there is a risk that the imported armaments:

• will be used for acts of war or violations of humanitarian law,
• will lead to the outbreak or prolongation of armed conflict or tensions,
• will be used against another country in armed conflict or in the event of territorial claims,
• would be contrary to Poland’s international obligations.

Conditions for revoking a strategic trade license in Poland

The minister may withdraw or amend an authorization if:

• the trade is not conducted in accordance with the terms of the authorization,
• the entity has lost the right to trade legally,
• it is required for the security and defense of the country,
• it is necessary due to Poland’s international obligations.

Internal compliance systems for arms trade in Poland

Entrepreneurs applying for a license or using a national general license are required to implement and apply a system for the control and management of arms trade. This system should define the tasks of individual company bodies and employees, the rules for data archiving, internal control, order fulfillment, and training.

Important! The permit issuance service is free of charge, and the processing time is up to 30 days, with the possibility of extension to 60 days.

The decision of the minister responsible for the economy is final and cannot be appealed. However, it is possible to submit a request for reconsideration of the case.

Import Certificate for goods of strategic importance in Poland

An Import Certificate for goods of strategic importance is a document issued by the Ministry of Development and Technology which confirms that the import of military or dual-use equipment complies with national law and Regulation (EU) 2021/821 of the European Parliament and of the Council.

An Import Certificate may also be issued at the request of an entity if required by the competent authorities of the exporting country as a certificate of the importer’s reliability and the transaction’s supervision by the Polish trade control authority.

The certificate is required if the foreign supplier expects confirmation that the end user in Poland will use the equipment for its intended purpose and that the transaction does not violate international export control standards. In practice, this document is sometimes necessary to obtain an export license in the supplier’s country, e.g., in accordance with US ITAR regulations or the Korean export regime.

Import certificate in Poland – when is it mandatory?

An import certificate is used primarily in the case of:

• imports of military equipment covered by strategic trade regulations,
• dual-use components and technologies,
• formally civilian goods with potential military applications (e.g., MWC explosives).

Failure to obtain a certificate may result in the foreign manufacturer refusing to deliver the goods, customs clearance being suspended, or administrative sanctions being imposed.

Required documents for import certification in Poland

An application for a certificate must be submitted to the Ministry of Development and Technology. It must be accompanied by:

• company registration details (KRS/CEIDG, NIP, REGON),
• description of the activity and scope of the planned transaction,
• classification of the goods according to strategic control codes,
• information about the end recipient and place of delivery,
• statement on the intended use of the equipment,
• confirmation of the company’s compliance system,
• a copy of the commercial contract (or draft) and any export permits.

Please note! Documents in a foreign language must be translated into Polish by a sworn translator. All documentation is subject to substantive assessment by several ministries and services: the Ministry of the Interior and Administration, the Ministry of Finance, the Internal Security Agency, the Government Information and Analysis Center, and the Foreign Intelligence Agency.

Why the Import Certificate Matters for Foreign Investors?

From the point of view of foreign companies operating in Poland, the Import Certificate minimizes regulatory risk. For manufacturers subject to strict export regulations (e.g., the US, South Korea, Israel), the certificate is proof that the Polish partner is a reliable recipient and that control over the final use of the equipment is ensured.

Certified companies can freely participate in international defense supply chains and compete effectively in tenders for NATO and EU member states.

Export restrictions for strategic and dual-use goods from Poland

Polish entrepreneurs involved in international trade in goods of strategic importance are required to meet strict legal requirements. The export of such goods requires obtaining an appropriate administrative permit, the lack of which may result in serious legal consequences, including under international law.

Definition and scope of strategic export from Poland

Strategic export is subject to a set of export restrictions imposed under both EU and national regulations. In particular, this includes Regulation (EU) 2021/821 and the Polish Act of November 29, 2000 on foreign trade in goods, technologies, and services of strategic importance.

Export in this context is broadly understood as the transfer of goods outside the territory of the European Union. This applies not only to the physical movement of items, but also to electronic transfers – such as the transmission of technology or software to entities located outside the EU.

In particular, the following exports require a license:

• armaments,
• dual-use goods listed in Annexes I and IV to Regulation 2021/821.

Types of export licenses in Poland

Depending on the type of goods and the direction of the transaction, the following types of licenses are available:

• individual export license – mandatory for armaments, may also apply to dual-use goods; granted to a specific entity in relation to a specific end user or recipient in a third country, for specific goods, their quantities and values; valid for up to one year;
• global export license – possible for dual-use goods; granted to a specific entity in relation to one or more end users or recipients in one or more third countries, for strictly defined types or categories of goods; valid for up to three years;
• national general export license – the Minister of Development and Technology, in the form of a regulation, may also issue a national general export authorization. It specifies the countries, entities, and goods of strategic importance covered by such authorization. Importantly, activities covered by a general license do not require an individual license or a global license.

Who can apply for a export license in Poland?

An application for a license may be submitted by:

• a natural person,
• a legal person,
• an organizational unit without legal personality, if it has legal capacity.

The applicant must have their place of residence or registered office in the territory of the Republic of Poland.

Export license procedure for strategic goods from Poland

Individual and global licenses are issued in the form of an administrative decision after a complete application has been submitted. The form must include, among other things:

• applicant’s details: name, address of registered office or place of residence in Poland,
• tax identification number (NIP),
• nature and scope of business activity, if the applicant is an entrepreneur,
• details of trading partners (name, address of registered office/place of residence, role in trade),
• details of goods of strategic importance (type, quantity, value),
• a statement of commitment to take measures to ensure that goods of strategic importance are delivered to the end user,
• details of the manufacturer and end users,
• specification of the country of final destination,
• description of how the goods will be used by the end user,
• the EU Member State where the dual-use product is located or will be located,
• the EU Member State where the customs declaration or declaration for the re-export of the dual-use product will be submitted
• specification of the country of origin of the strategic goods.

The application must be accompanied by, among other things:

• a declaration of possession of the relevant licenses or permits,
• a draft or copy of the trade agreement, if such an agreement is required for the trade in question, or a letter of intent or request for quotation,
• an import certificate or a declaration by the end user,
• a certificate of conformity confirming that the internal control and management system for trade in arms complies with the statutory requirements
• the consent of the competent foreign authority to dispose of the goods, if required.

Note! In the case of documents drawn up in a foreign language, a certified translation into Polish must be attached.

The trade control authority has the right to request additional information to verify the data contained in the application.

Export Licensing in Poland: What is the procedure?

After submitting the application, the Minister of Development and Technology conducts a formal and substantive assessment, taking into account the position on the absence or existence of contraindications to granting the permit expressed, inter alia, by:

• the Minister of Internal Affairs and Administration,
• the Minister of Foreign Affairs,
• the Minister of Finance,
• the Internal Security Agency, and the Intelligence Agency.

Each authority has 14 days to express its opinion. If another EU country has previously refused to issue a similar permit, Poland is required to consult with that country before making a decision.

Internal Controls for Arms Export from Poland

Entrepreneurs applying for a license or using a national general license for arms trade are required to implement and apply a system for controlling and managing such trade. This system should define the tasks of individual bodies of the enterprise and employees, the rules for data archiving, internal control, order fulfillment, and training.

Grounds for Refusal of Export Licenses in Poland

The minister may refuse to issue a license, including if:

• it is required by the defense or security needs of the Republic of Poland
• it is required by the Republic of Poland’s obligations under international agreements and alliance treaties
• the entity does not provide a guarantee of lawful trade
• there is a risk that the arms intended for export could be used for acts of war, acts in violation of international humanitarian law, or to provoke or prolong an armed conflict

License Revocation Conditions for Strategic Exports in Poland

The Polish minister may withdraw or amend the license if:

• the trade is not conducted in accordance with the terms of the license,
• the entity has lost the guarantee of lawful trade
• it is required for the security and defense of the country,
• it is necessary due to Poland’s international obligations.

The decision of the minister responsible for the economy is not subject to appeal. However, it is possible to submit a request for reconsideration of the case.

Legal guidance for exporting strategic goods from Poland

The export of goods of strategic importance from Poland requires precise preparation and knowledge of the applicable regulations. Each transaction should be preceded by a legal analysis and, in case of doubt, consultation with the competent authority.

For foreign investors and suppliers cooperating with Polish entities, having complete export documentation is not only a formal obligation but also a key element of risk management.

The permit issuance service is free of charge, and the processing time is up to 30 days, with the possibility of extension to 60 days.

EU general export authorizations for dual-use items

In order to streamline international trade controls and ensure security, the European Union has introduced a system of general export authorizations for dual-use goods. Such goods can be used for both civilian and military purposes, which is why their trade is subject to special regulations. EU general authorizations, marked with symbols from EU001 to EU008, facilitate export procedures in specific cases and cover various groups of countries and categories of goods.

Each of these authorizations applies to the export of dual-use items to specific countries or regions and is subject to separate conditions. This enables the European Union to effectively manage the export of such goods while supporting trade with countries considered to be reliable partners.

EU general authorization EU001

One of the most commonly used authorizations is EU001, which allows the export of dual-use goods to a group of countries considered stable, closely cooperating with the EU, and having similar export control standards.

These are:

• Australia
• Canada
• Iceland
• Japan
• New Zealand
• Norway
• Switzerland (including Liechtenstein)
• United Kingdom
• United States

Importantly, the EU001 authorization is valid throughout the customs territory of the European Union, which means that entrepreneurs from any member state can use it when exporting goods to the above-mentioned countries. This greatly facilitates trade with these countries, which, due to their economic importance and frequency of transactions, are the most popular export destinations under the system in question.

Exporters shall declare their intention to use this authorization in their customs declaration.

EU authorization EU001 covers all dual-use goods listed in Annex I to Regulation 2021/821, except in the cases described below.

EU authorization EU001 does not cover the export of products where:

• the exporter has been informed by the competent authority of the Member State in which he is resident or established that the products in question are or may be intended, in their entirety or in part:
  • for use in connection with the development, production, handling, operation, maintenance, storage, detection, identification, or dissemination of chemical, biological, or nuclear weapons or other nuclear explosive devices, or with the development, production, maintenance, or storage of missiles capable of delivering such weapons;
  • for a final military use as defined in Article 4(1)(b) of Regulation 2021/821 in certain destinations that are subject to an arms embargo or other restrictive measures.
  • for use as parts or components in military products listed on the national arms list which have been exported from the territory of the Member State concerned without authorization or in violation of an authorization provided for by the national legislation of that Member State;
• the exporter is aware (or even suspects) that the products in question are intended, in whole or in part, for any of the uses referred to in point (a); or
• the products in question are exported to a free zone or free warehouse located in a destination covered by this authorization.
• Exporters are first required to inform the Ministry of Development and Technology that they intend to operate under this authorization. In addition, a declaration must be made in the customs declaration that the products are being exported under the EU General Export Authorization No. EU001.

Transit vs. intra-EU transfer of strategic goods in Poland

In the context of international trade in strategic goods, in addition to export issues, transit and intra-EU transfer are also of particular importance. Although these terms are sometimes confused, they have completely different legal meanings and practical consequences for businesses.

Transit of strategic goods through Poland – key regulations

Transit is the movement of goods of strategic importance:

• between a Member State of the European Union (excluding Poland) and a third country,
• between third countries – through the territory of the Republic of Poland.

Transit applies only to goods “passing through” Poland without being placed on the Polish market, but it nevertheless requires strict control and often appropriate permits.

Intra-EU transfer of dual-use goods – licensing requirements

Intra-EU transfer is the transfer or movement of goods of strategic importance between entities from two different Member States without leaving the customs territory of the European Union.

In the case of armaments, a license issued by the competent authorities of any EU member state is also valid in Poland – there is no need to obtain a separate national license for the movement of such armaments through Polish territory.

Importantly, the intra-EU transfer of dual-use items within the territory of Poland, like their import, does not require a license. However, transfers from Polish territory of products listed in Annexes 1 and 4 to Regulation 428/2009 are subject to an authorization requirement, which may be individual or global.

A similar rule applies to the transfer of arms – an individual authorization or, in some cases, a global authorization is required.

Who can apply for transit or transfer licenses in Poland?

Applications for a license for transit or intra-EU transfer may be submitted by natural persons, legal persons, and organizational units without legal personality that have legal capacity.

In addition, it is possible to obtain a national general authorization, which simplifies the procedure in certain cases. Such authorization is issued by the Minister of Economy in the form of a regulation.

Note! An entrepreneur applying for a license or using a national general license for trade in arms is required to establish and apply an internal arms control and management system.

Procedure for obtaining a permit for the transit or intra-EU transfer of goods of strategic importance

The procedure is initiated by submitting an application to the Ministry of Development and Technology. The application must be accompanied by, among other things:

• a certificate of conformity confirming that the internal arms control and management system complies with the statutory requirements
• a statement confirming possession of a license or permits authorizing the possession of goods of strategic importance or the conduct of activities related to the requested trade
• a trade agreement – should be submitted if such an agreement is required for the trade in question. In its place, it is permissible to submit a draft of such an agreement or a letter of intent or a request for quotation.
• consent of the competent foreign authority for the specific disposal of the goods – is required if the importer or end user has undertaken to obtain such consent. In its place, a statement may be submitted that the applicant has no knowledge of the importer’s or end user’s obligation to obtain prior consent from the competent foreign authority for the specific disposal of strategic goods that are the subject of the application or a component thereof.
• In addition to the application for an intra-EU transfer license, an import certificate or a declaration from the end user must be attached

Note! If the documents are in a foreign language, a certified translation into Polish must be attached.

The Ministry verifies the application in consultation with other authorities, which have 14 days to issue an opinion. Importantly, if another EU country has refused to issue a similar authorization, Poland is required to consult with that country before issuing a decision.

The entire procedure is free of charge and the standard processing time is up to 30 days (with the possibility of extension to 60 days).