SENT 2026: new obligations for the clothing and footwear sectors

The year 2026 brought about key changes to transport and tax law that are of vital importance to businesses. Regulations that until now had been associated mainly with the fuel or alcohol markets have, in an unprecedented move, been extended to the clothing, footwear and e-commerce sectors. Given the strict penalty system and the wide scope of the new obligations, we have prepared a comprehensive summary of the most important changes for you below.

What is the SENT system and how does the monitoring of goods transport work?

The Electronic Transport Surveillance System (SENT) is a tool managed by the National Revenue Administration (KAS), used to closely monitor the road and rail transport of specific groups of goods, mainly those most vulnerable to irregularities or tax fraud. The transport of such goods requires prior registration in the system, obtaining a unique reference number and the continuous transmission of the vehicle’s geolocation data during transport (e.g. via the e-TOLL PL app or an external ZSL tracking system).

SENT 2026 – new limits for clothing and footwear subject to monitoring

Initially, under the regulations of March 2026, the SENT system covered clothing and footwear with relatively low weight thresholds, applying to shipments exceeding 10 kg or 20 pairs of footwear. This caused considerable confusion within the logistics and e-commerce sectors. In response to feedback from the market, the legislator implemented an amendment to the regulation of 18 June 2026, which came into force on 20 June 2026, significantly raising these limits.

Currently, knitted or crocheted clothing (CN Chapter 61), clothing other than knitted or crocheted (CN Chapter 62) and second-hand clothing (CN code 6309 00 00) are subject to monitoring if the gross weight of such a consignment exceeds 31.5 kg. In the case of footwear (CN Chapter 64), registration in the system is required when a consignment contains more than 64 pairs. The above rules also apply to mixed consignments containing goods from at least two of the above-mentioned chapters, provided their total weight exceeds the 31.5 kg threshold.

Who is subject to the obligations? The consignor, consignee and carrier

The new obligations under the SENT system do not rest solely with transport companies, but apply jointly to the main participants in the supply chain.The consignor (e.g. a Polish wholesaler) is responsible for declaring a consignment commencing within the territory of the Republic of Poland.

In turn, the consignee(e.g. a Polish importer or retail chain) is obliged to register shipments entering Poland from abroad, whether from the EU or a third country. The carrier, meanwhile, is responsible, amongst other things, for declaring transit through Poland, but above all must complete the declaration with the vehicle’s details and ensure that the driver has a reference number and that the geolocator is switched on throughout the entire journey.

Which consignments of clothing and footwear are subject to SENT checks?

According to the latest guidelines, in the clothing and footwear sector, it is primarily operations with a higher level of tax risk that are subject to reporting to SENT. The Ministry of Finance places emphasis on strict control of imports of goods from third countries, intra-Community acquisition of goods (WNT), transit through Polish territory, and intra-Community supply carried out immediately after customs clearance (the so-called 42 00 procedure).

When is the carriage of goods exempt from the obligation to declare?

The amendment has also introduced a wide range of exemptions that every business should be aware of to avoid unnecessary red tape:

• Transports carried out as part of ordinary domestic sales between Polish traders, intra-Community supply of goods (ICS) and the export of goods outside the European Union have been completely exempted from the obligation to declare to the SENT system.
• Parties to a transaction who hold Authorised Economic Operator (AEO) status or have entered into a cooperation agreement with the Head of the National Revenue Administration (KAS) are exempt from reporting.
• Declarations are not required if comprehensive logistics (warehousing, packaging, returns handling) are provided by a fulfilment operator holding AEO status or having a relevant cooperation agreement with KAS.
• Postal parcels and registered consignments (up to 31.5 kg) handled by authorised postal operators are exempt.
• The requirements have been relaxed for micro-enterprises and general partnerships trading at markets – the exemption applies to consignments of clothingup to 500 kg or up to 700 pairs of shoes.
• Shipments of clothing and footwear intended for humanitarian purposes are, by law, exempt from the SENT system.

Penalties for breaching SENT obligations – how severe are the sanctions?

The sanctions provided for in the SENT Act are extremely severe and can pose a real threat to a company’s financial stability. For the consignor or consignee, failure to submit the required declaration or providing information in it that does not correspond to the facts carries a financial penalty of as much as 46 per cent of the gross value of the goods being transported, but not less than 20,000 PLN.

The carrier is also exposed to severe consequences; for example, commencing transport without a declaration results in a fine of PLN 20,000 being imposed on them. Furthermore, for failing to keep the data in the declaration up to date (e.g. registration numbers) or for failing to transmit geolocation data (e.g. due to a switched-off device), the carrier faces a penalty of PLN 10,000. Drivers themselves also face financial consequences; for starting a journey without an active reference number or with a location tracker switched off, they may receive a fine of between 5,000 and 7,500 PLN.

How can you prepare your company for the SENT obligations in 2026?

The new SENT obligations require companies operating in the clothing and footwear sectors to adapt their operational and logistical procedures accordingly. It is worth reviewing supply chains, the classification of goods according to CN codes, and the rules governing imports and intra-Community acquisitions of goods. Our team can assist businesses with an audit of their SENT obligations and an assessment of whether their current procedures comply with the new regulations.

Contact us to check whether your company is adequately prepared for the new SENT requirements.