Customs FAQ: EU law and practice in Poland

Which documents are needed to take goods from the EU to Ukraine?

Establish customs status and the legal exit arrangement first. Under UCC Art. 269 (1), Union goods leaving the EU customs territory are placed under export; paragraph 2 provides exceptions, including outward processing and other specified cases. For non-Union goods, UCC Art. 270 supplies the starting rule for re-export, also with exceptions. The same physical route can therefore involve different customs treatment.

The declaration and supporting documents are different categories. UCC Art. 158 requires a declaration appropriate to the procedure. A standard declaration contains the necessary particulars under UCC Art. 162. Under UCC Art. 163 (1–2), required supporting documents must be in the declarant's possession and available to customs when the declaration is lodged; they are provided where EU law requires or controls make this necessary. The article separately addresses availability of certain data through the EU Single Window.

Invoices, packing information and transport documents help establish a shipment's circumstances. “Everyone needs EX1 and CMR” is an inadequate legal checklist: EX1 does not determine the correct procedure, and the transport document depends on the carriage. Product restrictions and permits require separate examination. Determine the list after checking status, goods, transaction, transport and subsequent treatment. EU exit formalities do not replace Ukrainian import formalities.

Which documents are needed to export goods from Ukraine to the EU?

A commercial shipment requires transaction and transport records, Ukrainian export clearance and the documents for the procedure chosen in the EU. Transit, origin evidence and product authorisations are assessed separately. A Ukrainian export declaration does not replace an EU import declaration; CMR, EUR.1 and T1 serve different purposes.

1. Transaction, shipment contents and transport

The invoice should identify the seller, buyer, goods, quantity, price, currency and delivery terms. The contract, order, specifications, payment records and freight or insurance evidence substantiate the transaction and relevant customs-value elements. EU valuation follows UCC Art. 70–UCC Art. 74: costs up to the place of introduction and subsequent costs must be distinguished. Free supplies, returns and equipment sent for repair require their own transaction analysis and valuation method; no payment does not mean a zero customs value.

A packing list or equivalent specification connects the goods with packages, net and gross weight, marks and serial numbers. A CMR consignment note is normally used for international road carriage; other modes require the corresponding transport document. CMR evidences carriage, not customs release or preferential origin. Invoice, packing, transport and declaration data must be consistent.

2. The export side: Ukraine

Chapter 16 of the Ukrainian Customs Code governs the export procedure and its conditions. Article 257 concerns declaration; Article 335 distinguishes control documents and information according to transport and clearance. The exporter or representative prepares the electronic declaration and required commercial, transport and authorisation information. Check current Ukrainian export restrictions and licensing for the specific goods before dispatch. Retain the electronic messages needed for completion and evidence of actual exit: opening transit and proving exit are different events. See Ukrainian Customs Code and Ukrainian customs guidance.

3. The EU side: arrival, ENS and import

UCC Art. 127 governs the entry summary declaration, ENS, including exceptions and responsibility for lodging. ENS supports advance security risk assessment; it is not an import declaration. Required data must reach the filing party before the deadline applicable to the transport mode. Goods are presented on arrival under UCC Art. 139. Where temporary storage applies, its declaration and subsequent treatment are addressed separately under UCC Art. 145; temporary storage and customs warehousing are distinct.

UCC Art. 158 and UCC Art. 162 govern placement under a procedure and standard declaration data. Under UCC Art. 163, required supporting documents must be held by the declarant and available to customs; submission is required where legislation or controls demand it. Operator registration follows UCC Art. 9 and representation UCC Art. 18–UCC Art. 19. Release for free circulation under UCC Art. 201 requires compliance with applicable duties, other charges and non-tariff measures. Poland uses AIS/IMPORT PLUS for ordinary electronic import clearance; an EORI and a user’s PUESC permissions are different requirements. See PUESC: import clearance.

4. Are T1 and EUR.1 required?

T1 or common transit is used when goods move under the selected transit arrangement, for example from a Ukrainian office of departure to an agreed destination office. It is not an obligatory addition to every shipment or an exemption from subsequent import clearance. Union external transit involves UCC Art. 226 and the holder’s obligations under UCC Art. 233; common transit is governed by the relevant Convention.

EUR.1 or an admissible origin declaration supports a preferential tariff claim when the applicable origin rules are satisfied. Dispatch from Ukraine alone does not establish Ukrainian origin. Resale, storage or repacking does not by itself turn Chinese-origin goods into Ukrainian-origin goods. Check the evidence type, issuing conditions, rate, quota and rules applicable on the import date against the agreement and product code. See Commission: EU–Ukraine trade; UCC Art. 59–UCC Art. 64 distinguish non-preferential and preferential origin.

5. Product-specific authorisations and records

Animals, certain animal products, plants and other controlled consignments may require official certificates, advance notification, a CHED in TRACES NT and entry through an appropriate border control post. Requirements depend on the category and origin; not every food shipment follows the same control arrangements. The legal basis is Regulation (EU) 2017/625, particularly Articles 47 and 56.

For equipment, assess the applicable safety and conformity legislation: CE marking and a declaration of conformity are not required for every product. Goods containing fluorinated gases require separate consideration of F-gas registration and other conditions under Regulation (EU) 2024/573. Excise goods, chemicals and other regulated goods have additional documentary regimes beyond a general import checklist.

6. What to give the broker before loading

Provide the invoice and specifications, packing details, goods description and use, proposed classification with technical data, origin and available evidence, party details and the relevant operator’s EORI, delivery terms and transport costs, route, intended procedure and power of attorney. Include applicable licences and certificates. The broker should assess participant roles, data consistency, valuation and restrictions before lodging. A zero preferential duty rate does not itself remove import VAT. Use Access2Markets to check product requirements.

What is T1 and when does external transit apply?

T1 identifies external transit, not a universal permission to ship to Ukraine. UCC Art. 226 (1) allows non-Union goods to move between points within the Union customs territory without the import charges and commercial policy measures specified there, while relevant entry and exit prohibitions remain. Paragraph 2 permits specified cases involving Union goods. Non-European origin does not itself define non-Union status; status is determined under UCC Art. 5.

The holder of the procedure has defined obligations. Under UCC Art. 233 (1), these include timely presentation of intact goods and required information at destination, compliance with identification measures and procedure rules, and a guarantee unless otherwise provided. A carrier or recipient who knows the goods are under transit also has duties under paragraph 3.

Ending transit under UCC Art. 233 (2) differs from customs discharge under UCC Art. 215 (2), which follows comparison of departure and destination data. For routes outside the EU, assess common transit under the Convention of 20 May 1987 separately. See the Commission's Union and common transit explanation. A truck's arrival alone does not establish discharge of T1.

Who needs EORI and what does it not establish?

EORI identifies a person for customs purposes. Its definition appears in Article 1(18) of Delegated Regulation (EU) 2015/2446. UCC Art. 9 (1) requires operators established within the Union customs territory to register where established. Paragraph 2 addresses non-EU operators in prescribed cases at the place of their first declaration or application for a decision. Paragraph 3 separately addresses persons other than economic operators.

This is more precise than saying every participant always needs EORI. Articles 5–6 of Regulation 2015/2446 specify additional registration rules and exceptions. EORI is not a warehouse operating authorisation and does not automatically confer power to represent another company. UCC Art. 18 distinguishes direct and indirect representation; UCC Art. 19 governs declaring representation and evidence of empowerment.

EORI, an individual's PUESC account, company registration and representative permissions are distinct elements. See PUESC company registration and EORI. Before filing, establish which person performs each role, where registered, and who may act on that person's behalf.

Can goods be stored in Poland before onward exit?

Yes, but select the legal arrangement by status and intended activities. UCC Art. 5 (22–23) distinguishes Union and non-Union status; UCC Art. 201 (3) links release for free circulation with acquisition of Union status. The seller's address or a future Ukrainian buyer alone therefore does not determine the storage arrangement. Ordinary commercial storage does not remove customs supervision where already applicable.

Non-Union goods enter temporary storage after presentation under UCC Art. 144. UCC Art. 149 requires placement under a procedure or re-export within 90 days. UCC Art. 147 limits storage locations and handling to preservation in an unaltered state. This is different from long-term customs warehousing.

For customs warehousing, UCC Art. 237, UCC Art. 238 and UCC Art. 240 govern the authorised facility, supervision and absence of a general time limit, subject to exceptions. Physical presence in a customs warehouse does not mean every item is under that procedure: UCC Art. 237 (3) separately allows storage of Union goods. Compare status, facility authorisation, deadlines and intended operations before choosing an arrangement.

What does a customs warehouse mean legally?

Distinguish the facility from the procedure. UCC Art. 240 provides for non-Union goods stored in customs-authorised premises or locations under supervision; paragraph 2 distinguishes public and private warehouses. Warehousing is a special procedure under UCC Art. 210. UCC Art. 211 (1(b)) requires authorisation to operate the facility. A public warehouse customer is different from its operating authorisation holder.

UCC Art. 237 defines storage treatment without the relevant import charges; it is not a universal exemption of every transaction from every tax. UCC Art. 238 provides no general storage duration but permits exceptional deadlines. UCC Art. 220 permits usual handling for defined purposes, rather than every manufacturing operation. Under UCC Art. 241, processing within the facility may occur under another procedure.

UCC Art. 242 allocates obligations between the authorisation holder and procedure holder; a public warehouse's particular authorisation matters. UCC Art. 215 (1) governs discharge. A service label therefore cannot replace checking authorisation, responsibility, records and the goods' subsequent treatment. Detailed legal guide to customs warehousing.

What is an F-GAS number and why is it required?

In import and export practice, an “F-GAS number” usually means the company’s registration identifier in the European Commission’s F-gas Portal. Article 23(3)(a) of Regulation (EU) 2024/573 expressly identifies this registration ID among the information supplied to customs where relevant. It is separate from the EORI number listed in Article 23(3)(b). The ID identifies the registered undertaking; it does not identify a consignment or a technician’s professional certificate.

Under Article 20(4)–(5), registration must be validated by the Commission, and valid registration at import or export constitutes the licence required by Article 22. The legislation includes an exception for temporary storage as defined in UCC Article 5(17). This exception must not be extended automatically to customs warehousing or another procedure. For a shipment, establish the gas, product or equipment, customs treatment and the undertaking occupying the relevant role under Article 23(2).

AGL DIVISION’s F-gas Portal ID is 143998. The Portal extract dated 3 March 2026 records registration as an importer and exporter of F-gases pre-charged in products and equipment. Registration and HFC quota authorisations are separate: where the rules require quota authorisations for pre-charged equipment, the appropriate quantities and declaration of conformity must also be checked. The registration ID alone does not establish those quantities.

Example: a shipment of air-conditioning units pre-charged with refrigerant. Establish whether the gas and equipment fall within the regulation, identify the importer, and collect the gas quantity and commodity classification. Article 23(3) lists the relevant customs data, including the Portal ID, EORI, gas net mass, commodity code and tonnes of CO₂ equivalent. The Portal registration links the undertaking to the licensing system; it does not replace the shipment data or any required HFC authorisation.

Legal basis: 2024/573 · 20, 22, 23 · European Commission: registration and Portal ID.