According to the current plans, the Polish Ministry of Finance is about to launch the new AIS/IMPORT PLUS import handling system on 19 June 2025, which is expected to increase the efficiency of customs operations thanks to greater automation.

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The change has turned out to be particularly troublesome for entities authorized to lodge customs declarations in the form of an entry in the declarant’s records (EIR). First of all, due to the new scope of data to be included in the records and its format, declarants are required to approve the new records’ design with the customs authority. However, in the recently published document, the Ministry of Finance pointed out a very important circumstance related to the implementation of the new system that will cause many importers to effectively lose their ability to use the EIR simplification.

Importers who are not exempted from the obligation to present the goods in their authorizations will be required to send a specific electronic notification PW433 to the AIS/IMPORT PLUS system. The problem is that the PWD-S notification, the content of which is derived from EU regulations, contains a limited range of data and does not provide the technical possibility to declare data including “Supporting documents” and “Additional information”, where it would be possible to indicate document codes subject to automatic validation in national or EU databases.

In this context, the Ministry of Finance points out that customs authorities are required to verify before releasing goods that they comply with applicable prohibitions and restrictions provided for in non-customs regulations. Thus, since the declarants will not be able to invoke in the PWD-S notification the codes of documents that need to be verified before release of goods into free circulation, importers should in such a case lodge a standard or simplified declaration instead of making an entry in the declarant’s records.

The problem under discussion will apply to declarations involving a number of Polish customs codes and goods for which the following documents must be submitted: CHED-A, CHED-P, CHED-D, CHED-PP (with exception for CHED-PP certificates submitted in connection with transport on pallets or other wooden packaging material - such submissions will continue to be allowed in the form of an entry in the declarant’s records), COI, ODS, F-GAS, ICG-L, ICG-S, ICG-D, CBAM (since 1 January 2026).

On the date of implementation of AIS/IMPORT PLUS, the PWD-S notification will, unfortunately, be the only available way to handle notification of the presentation of goods. At a later date, a separate option for the presentation of goods with an entry in the records on the customs portal, the so-called PWD-W notification, is expected to be launched - in this case, customs will have access to all data from the declarant's records, including the codes of documents necessary for verification, which will solve the current problem. Unfortunately, the exact date of the launch of this second option is not yet known, so declarants should immediately check which declarations will not be able to be submitted under EIR simplification as of June 19, in order to properly prepare for the start of the AIS/IMPORT PLUS system. If you need support in such analysis and preparation, please feel free to contact us.

You can read more about the problem in the Ministry of Finance’s Guidelines version 1.15 available (in Polish) at: https://www.podatki.gov.pl/clo/informacje-dla-przedsiebiorcow/aeo-i-uproszczenia-celne/procedura-uproszczona/wytyczne-i-instrukcje/wytyczne-w-sprawie-stosowania-uproszczen/