From 17 March 2026, the SENT system will cover the transport of selected categories of clothing and footwear. For some businesses in e-commerce, omnichannel distribution, retail, and for certain entities in the transport and logistics sector, this will be the first practical encounter with the regime for monitoring the movement of goods classified as “sensitive”. The change is broad, because it may affect everyday warehouse deliveries, and mistakes can trigger both financial and operational consequences. The coming weeks are, in practice, the last moment to approach SENT as a process rather than as an ad hoc task.
Why is SENT gaining new importance?
SENT has operated since 2017 and is used to monitor road and rail transport of specific goods whose trade (from the legislator’s perspective) is associated with an increased risk of tax fraud. The legal basis for its operation is the Act of 9 March 2017 on the monitoring system for road and rail transport of goods and trade in heating fuels. Until now, SENT has been associated mainly with fuels, alcohol, tobacco products, selected waste, chemicals, and certain agricultural products. Extending the catalogue to clothing and footwear means that the system enters a very broad market segment.
The purpose of the changes indicated in the regulations is to limit VAT fraud and increase supply-chain transparency in the textile and footwear sectors. As a result, SENT becomes a tool that directly affects how goods flows are organised, especially where operations are repetitive and high-volume, as in logistics and e-commerce in Poland.
Which shipments does SENT cover?
SENT applies to transport carried out within the territory of Poland: road, rail and intermodal. It covers domestic transport, import, export and transit within the section of the route that runs through Poland. The system is therefore not merely an “add-on” for carriers; it is a regime that applies to supply-chain participants whose obligations differ depending on the direction of movement.
In practice, SENT requires preparing a notification, keeping it up to date when data changes, and closing the notification after the transport is completed. In shipments where operational corrections are frequent (e.g., a change of delivery location, a change of vehicle, stoppages), ongoing updates become an operational necessity rather than a mere formality.
Which goods will be subject to SENT from 17 March 2026?
The extension covers clothing and footwear identified by CN codes, with thresholds based on weight or number of pieces. The obligation to notify a transport in SENT will arise, among others, for:
Goods classified under CN Chapter 61 (knitted apparel) where the gross weight of the consignment exceeds 10 kg. The same applies to CN Chapter 62 (non-knitted apparel) above 10 kg. The scope also includes used clothing classified as CN 6309 00 00, again with a 10 kg threshold. For footwear (CN Chapter 64, excluding parts of footwear), the obligation is linked to quantity: where the consignment includes more than 20 pieces. Mixed consignments from Chapters 61, 62 and 64 are subject to monitoring if they exceed 10 kg.
In retail and e-commerce realities, this catalogue means that a significant share of standard warehouse deliveries (both cross-border and domestic) may fall under SENT. What becomes critical is what is often “invisible” in logistics: the correct CN code and correct consignment parameters (gross weight, number of pieces).
Can CN classification determine whether a sanction applies?
Yes, because correct assignment of goods to the right CN code is key. CN codes determine whether, in a given case, a notification obligation arises at all, and the weight/quantity thresholds require data that is correct and consistent. Classification errors may lead to an incorrect assessment of the obligation, and, as a consequence, the transport may be treated as unreported or reported incorrectly.
In companies with dispersed data sources (warehouse systems, e-commerce platforms, forwarding systems, sales documents), risk does not arise solely from a lack of knowledge of the regulations. More often, it results from the absence of a single, controlled point of responsibility for what is entered into the notification and on what basis.
Who is responsible in SENT: the carrier or the shipper?
This is one of the most common questions, and the answer is clear: the new obligations do not apply only to carriers. Responsibility in SENT depends on the type and direction of movement.
If a transport starts in Poland, the notification obligation, as a rule, lies with the shipping entity. If a transport is carried from another EU Member State or from a third country into Poland, the obligation shifts to the receiving entity. In the case of transit through Poland, the notification is made by the carrier. At the same time, assigning the primary notification obligation to one participant does not release the other participants from their own independent obligations within the system.
What do the obligations of transport participants look like?
The sender is responsible for submitting a SENT notification before the transport begins. The notification includes, among others, the type of goods (CN code), quantity or weight, the place of loading and unloading, and the receiver’s details. Without an active notification in the system, the transport should not be commenced.
The receiver is obliged to confirm receipt of the goods and formally close the notification in the system. A failure to confirm receipt or an incorrect closure of the notification may result in administrative sanctions.
The carrier supplements the notification with the means-of-transport data, ensures active GPS monitoring within Poland, and carries out the route in line with the notification. If operational changes occur during the journey, ongoing updates are required. Activities related to entering transport data and updating it may (based on an authorisation granted by the carrier) be taken over by a logistics operator, which is particularly relevant for groupage shipments.
Exclusions and exceptions in SENT: are they really important?
The SENT regulation provides exclusions, among others, for entities holding AEO (Authorised Economic Operator) status, for entities covered by the Cooperative Compliance Programme with the Head of the National Revenue Administration (KAS), and for postal operators with respect to consignments meeting the definition of a postal parcel. An exclusion is also indicated for some transports if they are accompanied by an invoice in paper or electronic form, including a structured invoice in KSeF (Poland’s National e-Invoicing System), or a warehouse transfer document.
At the same time, an amendment to the regulation of the Minister of Finance and Economy concerning exclusions from certain obligations related to transport notifications in the SENT system is being processed, including exclusions linked to sending postal parcels by postal operators. According to the draft, the changes are to enter into force on 17 March i.e., on the day when clothing and footwear become subject to SENT, meaning the final shape of the provisions applicable from that date is not yet known.
In practice, it is emphasised that most retail entities may not meet the conditions to use these exclusions. This is particularly relevant for businesses combining online sales with deliveries to warehouses and stores, where the number of shipments is high and processes are dispersed.
When does domestic transport fall back under SENT despite a general exclusion?
With respect to clothing and footwear, it is indicated that domestic transports are, as a rule, excluded from SENT, but the obligation returns in two cases: where there is no VAT invoice accompanying the transport, or where the goods originate in a third country and are imported under customs procedure 4200 (release for free circulation combined with a supply to another EU Member State). Such situations require particular vigilance in organisations handling complex supply chains, including omnichannel distribution and e-commerce.
Operational procedures in SENT. what must work from day one?
Implementing SENT does not end with registration on PUESC (Poland’s electronic customs and tax services platform). Real readiness means organising the flow of data and decisions within the company so that notifications are correct, complete and up to date. In practice, a review of supply chains and identification of transports subject to notification are needed. In parallel, CN classification of goods must be verified, and responsibility for notifications must be defined depending on the transport scenario.
Procedures for updating notifications when data changes cannot be omitted. From a risk perspective, controls for the correctness of sensitive data, such as weight, quantity and delivery location, are also crucial. The human factor also matters: training staff in logistics, accounting and tax, and preparing contingency procedures in case the system is unavailable.
In organisations carrying out many transports per day, even minor procedural shortcomings can quickly translate into repeatable errors and these, in turn, into an accumulation of risks.
The TSL sector under SENT’s formal pressure?
For transport companies, verifying the reference number before starting the transport is particularly important. This number is valid for 10 days, and its absence may result in the immediate stoppage of the transport. Operationally, this means synchronising processes with customers, updating driver instructions, and implementing formal controls for transport documentation.
A lack of appropriate procedures increases the risk of disputes between the carrier and the transport ordering party regarding responsibility for sanctions. In practice, tensions arise particularly when multiple parties are involved in the chain and the reference number information does not reach the person starting the transport in time.
Errors in SENT. What sanctions apply and why is the problem not only the fine?
The SENT Act provides for severe sanctions for failure to submit a notification or for providing incorrect data. The monetary penalty may amount to 46% of the gross value of the goods, but not less than PLN 20,000. Importantly, different penalties are provided for participants in the movement— including drivers. In addition to financial sanctions, operational risk must be taken into account, such as detention of the means of transport, suspension of delivery, delays in contract performance, and reputational risk.
In the trade of clothing and footwear, seasonality and delivery timeliness are critical, which is why operational consequences may be more severe than the administrative fine itself. This applies both to classic retail and to e-commerce, where a delay of a single batch can disrupt product availability and sales planning.
Summary and conclusions
The extension of SENT to clothing and footwear from 17 March 2026 changes day-to-day reality in supply chains in Poland. The monitored scope includes the indicated groups of goods by CN, with thresholds of 10 kg for clothing and 20 pieces for footwear, as well as mixed consignments. Obligations are distributed between the sender, the receiver and the carrier depending on the direction of movement, while other participants still have their own duties. Correct CN classification, correct consignment parameters, and the ability to update data and close the notification become critical.
The greatest risk does not stem from the mere existence of SENT, but from misalignment of data and responsibility within the organisation. Where e-commerce, omnichannel distribution, frequent transhipments and many daily transports occur, stable procedures, data controls and preparedness for operational changes during transport are needed. For TSL, discipline around the reference number valid for 10 days and readiness for formal verification before departure are key. Financial sanctions are high, but operational risks (transport stoppages and delays) are equally significant. In practice, these are the factors that can hit clothing, footwear, transport and e-commerce businesses the fastest.
FAQ
From when are clothing and footwear subject to SENT and what is the basis for the change?
From 17 March 2026. The basis for including clothing and footwear in SENT is the Regulation of the Minister of Finance and Economy of 10 September 2025 (Journal of Laws, item 1244).
Which thresholds determine the notification obligation for clothing?
For CN Chapters 61 and 62 and for used clothing CN 6309 00 00, the obligation arises when the gross weight of the consignment exceeds 10 kg, and for mixed consignments from Chapters 61, 62 and 64 when the gross weight exceeds 10 kg.
When does footwear fall under SENT?
For goods from CN Chapter 64 (excluding parts of footwear), the obligation applies to consignments including more than 20 pieces.
Who submits the notification depending on the direction of movement?
If the transport starts in Poland - the shipping entity. If the goods arrive from the EU or a third country into Poland— the receiving entity. In transit through Poland - the carrier. Assigning the primary obligation to one participant does not remove the independent obligations of the others.
When is domestic transport of clothing and footwear covered by SENT despite a general exclusion?
The obligation returns when there is no accompanying VAT invoice or when the goods originate in a third country and are imported under procedure 4200.
What sanctions apply for failure to notify or for incorrect data?
Penalties vary. The highest monetary penalty for the shipping or receiving entity may amount to 46% of the gross value of the goods, but not less than PLN 20,000. A separate penalty schedule is provided for the carrier and the driver. Additionally, operational consequences are possible, including detention of the means of transport, suspension of delivery and delays.
How can ASB help you with SENT?
Implementing and maintaining ongoing compliance with SENT requirements requires not only knowledge of the regulations, but above all efficient operational processes and well-documented decisions (especially in the areas of exclusions and goods qualification). The ASB team provides comprehensive support in activities such as:
- Proper qualification of assortment and the supply chain,
- an audit of internal processes for compliance with SENT requirements,
- preparation of operational and compliance procedures tailored to SENT,
- identification of exclusions and risks,
- representation in proceedings conducted by customs and tax authorities, including cases concerning monetary penalties,
- support in obtaining a Binding Tariff Information decision (BTI/WIT).
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