Poland sets new import certificate template for strategic goods

The Minister Finansów i Gospodarki has issued a regulation establishing a new template for the import certificate used in trade with foreign countries in goods, technologies and services of strategic importance for state security and for maintaining international peace and security. The regulation of 7 September 2026 was published in the Dziennik Ustaw Rzeczypospolitej Polskiej of 16 September 2026 as Dz.U. 2026 poz. 1216, and enters into force 14 days after publication, that is on 30 September 2026. It replaces the template in force since 2012 and is signed, on behalf of the minister, by M. Jaros.

The new act is issued under Article 22(7) of the Act of 29 November 2000 on trade with foreign countries in goods, technologies and services of strategic importance for state security and for maintaining international peace and security (Dz.U. 2023 poz. 1582, as amended by Dz.U. 2026 poz. 471). The Minister Finansów i Gospodarki is competent for the economic affairs portfolio under the regulation of the Prezes Rady Ministrów of 25 July 2025 (Dz.U. poz. 997). The regulation consists of two paragraphs: one defining the template, which forms an annex, and one setting the vacatio legis.

What the new certificate contains

The annex sets out a bilingual Polish-English form headed CERTYFIKAT IMPORTOWY (IMPORT CERTIFICATE), issued in the name of the Rzeczpospolita Polska by the minister competent for economic affairs. It carries an import certificate number and identifies:

• The importer or consignee, with name and address.
• The foreign exporter or foreign supplier, with name and address.
• A table listing each item by number, with the name and description of the good of strategic importance, its control number, quantity and value.
• A description of the end-use of the good of strategic importance.
• A continuation sheet for further items, plus the full name, position, signature, date and stamp of the issuing minister.

Validity, obligations and controls

The certificate ceases to be valid unless it is presented to the competent authorities outside the Rzeczpospolita Polska within 12 months of its date of issue. By signing it, the importer or consignee certifies that it will bring the listed goods onto Polish territory and will immediately notify the organ kontroli obrotu of any change in the terms of the contract.

The importer or consignee also declares that it is aware that re-export, intra-Union transfer, a change of end user or a change of the declared end-use requires the prior consent of the organ kontroli obrotu. Together with the end user, it undertakes to allow that authority to verify, at the place of use and throughout the period the goods remain on Polish territory, that their use complies with the licence conditions; representatives of the foreign exporter’s country may take part in such checks.

The form also reproduces the standard appeal instructions: no appeal lies against the decision, but a party may ask the issuing authority to reconsider the case within 14 days of service, or file a complaint directly with an administrative court within 30 days.

Replacing the 2012 template

The regulation was preceded by the regulation of the Minister Gospodarki of 30 July 2012 on the template of the import certificate (Dz.U. poz. 923), which loses force on the date the new act enters into force. That repeal follows Article 11(2) of the Act of 13 March 2026 amending the Act on trade with foreign countries in goods, technologies and services of strategic importance and the Act on carrying out economic activity in the manufacture of and trade in explosives, weapons, ammunition and products and technology for military or police purposes (Dz.U. poz. 471).

For importers of strategic goods and technologies, the change means a new documentary format must be used for certificates issued from 30 September 2026, with the same 12-month presentation window and the same notification and inspection duties towards the organ kontroli obrotu. Companies holding certificates issued under the 2012 template should confirm with the issuing authority how those documents are treated once the old regulation lapses.

Source: Dziennik Ustaw Rzeczypospolitej Polskiej, no. 1216 of 16 September 2026, section I (official reference: Dz.U. 2026 poz. 1216).