New law obliges exporters to provide additional information to customs authorities
On 11 February 2025, a law was published (Dz.U.2025 poz. 172) amending a number of normative acts relating to national security and countering support for aggression against Ukraine. The new law imposes stricter requirements on exporters supplying goods sanctioned by the European Union.
One of the key provisions of the law is the obligation for exporters sending sanctioned goods to countries that may be involved in circumventing EU restrictive measures, as well as transiting them through Russia or Belarus, to provide the following information to the customs authorities:
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- Details of the end user of the goods.
- A statement confirming that the transit through Russia or Belarus is only part of the transport route, with the start and end points located outside these countries.
- Guarantees that the goods will not be resold, processed, stored or handled by EU-sanctioned entities during the transit.
- Confirmation that the final destination of the goods is a third country other than Russia or Belarus.
In addition, at the request of the head of the customs and tax administration, the exporter is required to present:
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- Documents from the manufacturer confirming that he has taken measures to control the end-use of the goods and can document this.
- Confirmation that the goods have been cleared through customs in the country of destination within 45 days of being exported out of the EU customs territory. Failure to comply with this requirement may result in administrative sanctions.
The law also gives customs and revenue authorities the right to seize goods and request their confiscation if they are found to be in breach of EU sanction provisions.
What does this mean for entrepreneurs?
For exporters and foreign traders, the new rules mean increased scrutiny and a heavier bureaucratic burden. Companies will be required to accurately document the delivery routes, end users and destinations of their goods. This requires additional resources to collect and verify information, and may slow down the clearance of goods.
In addition, failure to comply with the new requirements can result in heavy fines and even confiscation of goods. Companies will therefore need to strengthen legal support and oversight of logistics operations to avoid potential risks.
The new regulations aim to prevent circumvention of sanctions and increase control over export operations, making them crucial for all participants in foreign trade business.