Importing mineral fuels and chemicals from the UK – ADR, licences and excise procedures

Importing mineral oils and mineral fuels from the United Kingdom to Poland is one of the most heavily regulated logistics operations in UK–EU trade. Chapter 27 of the Combined Nomenclature (HS27), covering crude petroleum, petrol, diesel, LPG and aviation fuels, has in recent years represented one of the largest trade flows on the UK–Poland axis by value. Every such consignment must simultaneously satisfy the requirements of three independent regulatory regimes: transport safety (ADR), excise duty (Polish excise legislation) and quality requirements (laboratory certificates). Failing to understand these interdependencies leads to goods being held at the border, refusal of entry into Polish territory, or revocation of an excise permit. This article is a practical guide for companies considering or already carrying out fuel imports from the UK.

HS27 classification – what falls within the scope of mineral fuels?

Chapter 27 of the Combined Nomenclature is broad. Below are the key headings relevant to importers from the UK:

HS code	Goods description	Import notes
2709	Crude petroleum oils	Require refining before use
2710 11	Motor spirit (petrol)	ADR Class 3, UN 1203
2710 19 43	Gas oil (diesel)	ADR Class 3, UN 1202
2710 19 25	Aviation turbine fuel JET A-1	ADR Class 3, UN 1863
2711 12	Propane (LPG) liquefied	ADR Class 2, UN 1978
2711 13	Butane (LPG) liquefied	ADR Class 2, UN 1011
2710 19 61	Heavy fuel oils	Colour differentiation applies
2713	Petroleum coke and bitumen	Solid goods, different ADR rules

Customs duty rates for fuels imported from the UK to the EU under the TCA may be zero for goods that satisfy UK rules of origin. However, mineral fuels often do not meet the UK origin criterion (e.g. crude processed in the UK may originate from third countries), which results in MFN (Most-Favoured-Nation) duty – for certain gas oils as high as 3.5%.

ADR – road transport regulation for fuels

ADR (Accord Dangereux Routier – European Agreement concerning the International Carriage of Dangerous Goods by Road) is the mandatory regulation for all road transport of fuels in Europe, including the UK–PL route.

ADR classes for fuels

ADR class	Description	Fuel examples
Class 2	Gases	LPG (propane, butane)
Class 3	Flammable liquids	Petrol, diesel, kerosene, JET A-1

Petrol (UN 1203): Class 3, Packing Group II – the most stringent requirements among liquid fuels owing to the low flash point (<21°C).

Diesel (UN 1202): Class 3, Packing Group III – less stringent requirements than for petrol (higher flash point).

Mandatory ADR documents for fuel transport

1. Dangerous goods declaration (DG Declaration / Shipper's Declaration): Issued by the consignor. Must include: UN number, proper shipping name, ADR class, Packing Group, quantity, and packaging information.

2. Written instructions: A document for the driver with instructions on action to be taken in the event of an accident. Mandatory in the cab within easy reach of the driver.

3. CMR consignment notes: Must include ADR information in accordance with Section 5.4 of ADR.

4. ADR plates (orange): Tankers and vehicles transporting fuels in quantities above the exemption threshold must be marked with ADR plates showing the hazard identification number (Kemler Code) and UN number.

5. Driver's ADR certificate: The driver must hold a valid ADR certificate for the relevant class (for Class 3 – basic certificate plus tank module for tankers). The certificate is valid for 5 years and renewed by training.

ADR exemption thresholds

Below certain quantities, an exemption from the full ADR requirements applies (subject to basic requirements – correct packaging and labels):

• Petrol (Packing Group II): 333 litres in total per vehicle – at this quantity no ADR driver certificate or ADR plates are required
• Diesel (Packing Group III): 1,000 litres – higher threshold
• LPG (Class 2): 333 kg

Note: The threshold applies to quantities per vehicle – all dangerous goods of different classes are added together.

Excise duty on fuels – key Polish regulations

Importing fuels into Poland entails an obligation to pay excise duty, which is one of the highest cost components of fuel. Excise duty is regulated by the Polish Excise Duty Act (Journal of Laws 2009 No. 3 item 11, as amended) and implementing regulations.

Excise duty rates for selected fuels (2025/2026)

Fuel type	Excise duty rate
Motor spirit / petrol (CN 2710 11)	1,540.00 PLN/1,000 litres
Gas oil / diesel (CN 2710 19 43)	1,171.00 PLN/1,000 litres
LPG (CN 2711 12/13)	670.00 PLN/1,000 kg
Light heating oil	232.00 PLN/1,000 litres

Indicative rates – subject to change. Always verify the current rates in the Excise Duty Act.

Excise permit – who needs one?

Commercial imports of motor fuels require the status of an excise entity or operating through a registered consignee (in excise terminology). Key definitions:

• Tax warehouse operator: An entity operating a tax warehouse where fuels may be received, processed and dispatched under duty suspension.
• Registered consignee: An entity registered in the Central Register of Excise Entities (CRPA), authorised to receive fuels under the duty-suspension procedure.
• Unregistered entity: Pays excise duty at import at the border – an option for one-off imports.

Registration in the CRPA is free of charge but requires meeting formal conditions and lodging an excise security deposit. For regular fuel importers this is a practical necessity.

Fuel quality certificates (PQ Certificate)

In addition to customs and ADR documentation, importing fuels into Poland may require quality certificates:

1. Manufacturer's quality certificate (Product Quality Certificate / Certificate of Analysis): A document issued by the manufacturer or refinery in the UK. Contains the physicochemical parameters of the fuel: density, flash point, sulphur content, cetane number (diesel), octane rating (petrol), and bio-additive content.

2. Laboratory testing at the border: The Trade Inspection Authority or Customs Office may take fuel samples for laboratory analysis at the point of entry. Non-conformity with standards (e.g. EN 590 for diesel, EN 228 for petrol) results in seizure of the goods.

3. European fuel standards: Diesel must comply with EN 590 and petrol with EN 228 – these standards apply equally to imported fuels.

Heating oil vs diesel – colour differentiation

Light heating oil (CN 2710 19 62) is frequently confused with gas oil (diesel), but it is subject to a different excise rate and different marking requirements. In Poland, light heating oil must be dyed with red marker (Solvent Red 19/24) and marked with a chemical marker (Euromarker). Using heating oil as motor fuel is an excise offence. Importers must be aware when dealing with consignments from the UK, where a similar distinction (red diesel vs white diesel) applies on the British side, although the markers may differ technically.

Practical checklists for fuel importers from the UK

Before loading: - [ ] Identify the HS code and ADR class of the goods - [ ] Confirm the driver holds a valid ADR certificate - [ ] Check that the tanker / packaging has a valid ADR technical inspection - [ ] Obtain the fuel quality certificate (PQ Certificate) from the UK supplier - [ ] Verify the excise permit status (CRPA) on the Polish importer's side

Documents for the shipment: - [ ] Commercial invoice stating the HS code, value and quantity - [ ] EUR.1 certificate or UK origin declaration (for TCA preference) - [ ] DG Declaration (ADR Shipper's Declaration) - [ ] Written instructions (ADR) for the driver - [ ] CMR with ADR details - [ ] Fuel quality certificate (PQ Certificate) - [ ] e-AD document (electronic administrative document) or SAD for excise purposes