On March 17, 2026, the Regulation of the Ministry of Finance and Economy of September 10, 2025, amending the regulation on goods whose transport is subject to the road and rail transport monitoring system and the trade in heating fuels (Journal of Laws, item 1244) will enter into force. As a result of the introduction of the new regulations, the list of goods covered by SENT monitoring will be extended to include clothing and footwear.
Reason for change
The aim of the changes is to prevent fiscal offences aimed at non-disclosure or understatement of the tax base in trade in clothing, clothing accessories and footwear, particularly in the context of intra-Community acquisitions (ICA) and imports of these goods from third countries.
Goods covered by SENT
The SENT transport and trade monitoring system is to cover the transport of the following goods:
- from HS section 61 à knitted clothing and clothing accessories, if the gross weight of the consignment of goods covered by this section exceeds 10 kg,
- from HS section 62 à articles of apparel and clothing accessories, other than knitted or crocheted, if the gross weight of the consignment of goods covered by this section exceeds 10 kg,
- from HS code 6309 00 00 à used clothing and other used articles, if the gross weight of the consignment of goods covered by this code exceeds 10 kg,
- from HS section 64 à footwear, excluding CN 6406 (parts of footwear), if the consignment of goods covered by this section contains more than 20 items of footwear (which is 10 pairs of footwear or, for example, 20 right shoes),
- covered by CN section 61 or 62 (clothing and clothing accessories, knitted or crocheted, or other than knitted or crocheted) or CN section 64 (footwear), excluding CN heading 6406 (parts of footwear), if the gross weight of the consignment containing goods from at least two of these chapters exceeds 10 kg.
Exemptions
The new regulation also provides for exemptions from SENT obligations. Transport of the above-mentioned goods starting in the territory of Poland will be excluded from the monitoring obligation, however, with the exception of:
- goods originating in a third country, after they have been released for free circulation in the European Union and whose place of delivery is outside the territory of the country or in another EU Member State, i.e. goods covered by the procedure for release for free circulation (customs procedure 42 00), or
- the transport of goods not accompanied by an invoice within the meaning of the Value Added Tax Act, in paper or electronic form and in a format that allows its content to be read, documenting the supply of goods, intra-Community supply of goods or export of goods.
This means that commercial entities that perform transport of the indicated goods purchased domestically will be exempt from the obligation to make a notification if the transported goods are accompanied by an invoice. In other cases of transport of these goods across the national territory, i.e. in the so-called transit through Poland and in formal customs transit and within the framework of WNT, each consignment will be subject to notification to the SENT system.
In addition, transportation of goods will be exempt from SENT obligations:
- commencing on the territory of Poland or from the territory of the EU or a third country to the territory of Poland, if the entity obliged to send a notification to the SENT register has the status of an authorised economic operator (AEO) or is a party to a cooperation agreement concluded with the Head of the National Revenue Administration, and
- transported by postal operators in postal parcels within the meaning of the Postal Law.
New obligations and penalties
The inclusion of the transport of clothing and footwear in the SENT system will impose additional burdens on commercial entities – senders, receivers and carriers. It will consist in the necessity to notify the carriage of goods to the SENT register, to complete and update the data contained in the notification. In the case of transport on a public road, the carrier will be obliged to ensure the transmission of geolocation data during the entire route through the national territory.
Obliged entities that neglect to fulfil their obligations under SENT may be charged with a fine of 46% of the gross value of the goods subject to the notification obligation, not less than PLN 20,000. Other penalties range from PLN 2,000 to as much as PLN 100,000.
What about transport operations that began before 17 March?
For transport operations that began and were not completed before the date of entry into force of the regulation, the existing provisions apply. This means that such transport will take place without notification to the SENT register.
How can we help?
Our experts have been assisting businesses in fulfilling their SENT. We offer comprehensive support – from analysing the obligation to report under SENT, through registering the entity on the dedicated Electronic Tax and Customs Services Platform (PUESC), to ongoing support in making, completing and updating transport reports. If you transport clothing and do not know or are not prepared to fulfil your obligations under SENT, we encourage you to contact us.