Product codes in JPK - what do you need to know?


JPK V7 is effective from October 1, 2020 and is more detailed than the previously valid file. Therefore, taxpayers must include even more information in it than in the declarations submitted so far. Although it contains the data of the JPK_VAT and VAT-7 / 7K declaration currently in force, the legislator expanded it with additional markings. One of them is the mandatory codes of goods in JPK, which are designed to facilitate the legislator's verification of purchased goods, e.g. whether they are included in the catalog of sensitive goods (Annex 15 to the VAT Act). Let's check which goods codes are distinguished in JPK.

Product codes in JPK - are they valid in JPK_VAT?

The previously applicable JPK_VAT structure does not contain the codes of the goods or services sold, which should be specified in it. Currently, tax offices use the PKD data of taxpayers reported in CEIDG-1 or in the National Court Register. They check the business profile of the taxpayer and on this basis analyze whether the sale includes sensitive goods / services. It is a relatively labor-intensive process for officials.

According to the justification of the draft to the ordinance of the Minister of Finance on the detailed scope of data contained in tax declarations and records in the field of tax on goods and services, "the regulation provides for some new fields in relation to the currently applicable information from the records kept (JPK_VAT). These new fields are aimed at improving the precision of analyzes carried out with the use of JPK_VAT files, which will increase the effectiveness of KAS bodies' operation.

You can read more about JPK V7 in the articles:
Cancellation of VAT returns - new SAF-T as a taxpayer control tool
Marks of purchase and sale documents in JPK V7M and JPK V7K
Mandatory marking of goods and services in the new JPK_VAT

Product codes in JPK V7M and JPK V7K - how to mark them?

JPK V7 is intended to replace VAT and JPK_VAT declarations and thus facilitate settlements with the tax office. However, although the taxpayer submits one file instead of two separate files, it is much more complex. Therefore, taxpayers or accountants themselves must demonstrate diligence in its creation. The taxpayer is obliged, inter alia, to to inform the tax office about 13 groups of products sold.

The codes of goods placed in JPK will play a key role in verifying the taxpayer's sale. They facilitate the analysis of economic transactions performed in the company and contribute to a more precise selection of companies for tax audit or the checking activities themselves.

Product codes in JPK do not apply to cost invoices. Taxpayers are only required to mark transaction procedures on the purchase invoice as:
-> MK - for invoices marked with the annotation "checkout method”,
-> VAT_RR - in the case of the VAT RR invoice referred to in art. 116 of the act,
-> WEW - in the case of an internal document, example: making an annual input tax adjustment due to a change in the input tax deduction ratio,
-> SPP - transaction subject to the obligation to use the split payment mechanism,
-> IMP - indication of the input tax on the import of goods, including the import of goods accounted for in accordance with art. 33a of the Act.
In the absence of these markings - the field remains blank.

Product codes in JPK are presented as symbols GTU_01 - GTU_13. Each code is responsible for a specific type of transaction. What do the codes mean? We explain in the table below:

Field name

Field description


Supply of alcoholic beverages - ethyl alcohol, beer, wine, fermented beverages and intermediate products, as defined in the provisions on excise duty.


The delivery of the goods referred to in Art. 103 paragraph 5aa of the Act.


Supply of heating oil within the meaning of the provisions on excise duty and lubricating oils, other oils with CN codes from 2710 19 71 to 2710 19 99, excluding products falling within CN code 2710 19 85 (white oils, liquid paraffin) and plastic lubricants classified under the CN code 2710 19 99, lubricating oils falling within CN code 2710 20 90, lubricating preparations of CN heading 3403, excluding plastic lubricants of this heading.


Supply of tobacco products, raw tobacco, liquid for electronic cigarettes and innovative products, within the meaning of the provisions on excise duty.


Delivery of waste - only specified in item 79-91 of Annex 15 to the Act.


Delivery of electronic devices and parts and materials for them, only specified in item 7-9, 59-63, 65, 66, 69 and 94-96 of Annex 15 to the Act.


Delivery of vehicles and car parts with codes only CN 8701 - 8708 and CN 8708 10.


Delivery of precious and non-precious metals - only specified in item 1-3 of Annex 12 to the Act and in item 12-25, 33-40, 45, 46, 56 and 78 of Annex 15 to the Act.


Supply of medicines and medical devices - medicinal products, foodstuffs for particular nutritional uses and medical devices subject to the notification obligation referred to in Art. 37av paragraph. 1 of the Act of September 6, 2001 - Pharmaceutical Law.


Delivery of buildings, structures and land.


Provision of services for the transfer of greenhouse gas emission allowances referred to in the Act of June 12, 2015 on the greenhouse gas emission allowance trading scheme.


Provision of intangible services - exclusively: advisory, accounting, legal, management, training, marketing, head offices, advertising, market research and public opinion research, in the field of scientific research and development works.


Provision of transport and storage services - Section H of PKWiU 2015 symbol ex 49.4, ex 52.1.

Qualifying a sales invoice to a given product code is done by selecting "1"In the structure in the appropriate field - under the symbol GTU_01 to GTU_13. In the event that a given sales invoice does not qualify for any GTU Symbol, a blank field is indicated under each of the symbols.

Example 1.

Mr. Stanisław sold goods from group 01, 02, 05. In this case in JPK V7 he indicates "1" next to a given invoice appropriately in the field "GTU_01", "GTU_02", and "GTU_05".

Product codes in JPK are not marked in the case of sales records that show sales recorded at the cash register or sales records not documented with invoices (e.g. non-accounting sales) and sales not subject to the obligation to keep sales records using a cash register. The product codes in JPK are also not used in the case of purchase transactions resulting in the appearance of output VAT (eg intra-tax collection, import of services).

In addition to the product codes in JPK, the taxpayer makes additional sales markings in JPK V7, e.g. SPM, if the sale is covered by the split payment mechanism.

Incorrect codes of goods in JPK - are there penalties for taxpayers?

The tax office will penalize for errors in JPK V7. This also applies to errors in the incorrect assignment of codes for goods and services. The sanction for errors is to be PLN 500, so each error in JPK V7 will definitely hit taxpayers in their wallets. At the same time, the taxpayer may avoid the penalty if, within 14 days of detecting the error (by himself or the tax office), he makes appropriate explanations or corrects the JPK V7 file immediately. The Ministry of Finance stipulates that the penalties will apply to the most serious errors that make it difficult for the tax office to analyze the data. Entrepreneurs can therefore rest easy - typos should not be penalized. Nevertheless, there is no official catalog that lists the permissible (non-punished) and unacceptable (punished) errors. Therefore, it is not yet clear how the irregularities generated by incorrectly completed product codes in JPK will be treated.

Analyzing the codes of goods in JPK V7, we can conclude that due to the fact that some codes contain a wide range of types of goods, it is not difficult for entrepreneurs to make a mistake in marking them. It may also happen that one sales invoice (shown in SAF-T V7) includes many product codes, and in some cases - none (e.g. for some food products, i.e. milk or bread).

Example 2.

Mr. Władysław in JPK_V7M (settled monthly) showed the sales invoice in the code GTU_01. However, the sale concerned tobacco products, which should be entered in the GTU_04 code. The tax office called the taxpayer with information about the bad code contained. The taxpayer must correct JPK_V7M within 14 days in order not to be exposed to criminal consequences - imposing a penalty of PLN 500.

Summing up, the extensive product codes in SAF-T may facilitate the work of tax office officials, but not the taxpayers themselves. Therefore, in order to properly draw up SAF-T V7, the taxpayer must use a system that will enable automatic assigning of codes and other markings, so that there is no mistake and thus no penalties related to it.

Start a free 30-day trial period with no strings attached!

Product codes in JPK in the system

In the system, it is possible to define GTU codes, the reporting of which is mandatory for the purposes of the new JPK file from October 1, 2020. To select the appropriate GTU, go to the SETTINGS »TAXES» TYPE OF TRANSACTIONS IN JPK V7 »GTU tab, where there is a list of thirteen GTU codes, of which you should select the appropriate designations for the user and click SAVE.

After selecting the appropriate GTU codes, they will be visible when issuing an invoice and it will be possible to assign them to products or services (if you have an extensive warehouse). More in the help article: Codes for groups of goods and services.