The expansion of the SENT system as of March 17, 2026, directly impacts the clothing and footwear industry. From the perspective of manufacturers and distributors, the key issue is that obligations under the transport monitoring system do not apply solely to carriers—in many cases, they fall דווקא on the sender or the recipient of the goods.

New regulations not only for carriers

Manufacturers and distributors of clothing and footwear are becoming key participants in the SENT system. In practice, this means that a company previously focused mainly on sales and logistics must now incorporate additional reporting obligations within SENT. Failure to comply may result in severe penalties.

According to the SENT Act, particularly Article 5(1), in the case of transport starting in Poland, the sender is required to submit a notification before the transport begins, obtain a reference number, and provide it to the carrier. This means that, in many cases, the obligation rests with the manufacturer or distributor.

At the same time, an analysis of implementing regulations and their practical application shows that not every transport in the clothing sector will require notification. However, this does not allow discretion—it requires a precise assessment of each individual case.

Three key scenarios for manufacturers

1. Goods imported from outside the EU
   This applies to goods imported from countries such as China or Vietnam and then resold to another EU Member State. In such cases, SENT notification is mandatory regardless of other circumstances, meaning exemptions cannot be applied.
2. EU-origin or domestic sales
   For goods originating within the EU or domestic transactions, exemptions from notification may apply, provided that the shipment is accompanied by a VAT invoice. “Accompanied” should be interpreted broadly—as a document linked to the shipment, not necessarily physically attached.
3. Imports (as the recipient)
   When the manufacturer or distributor acts as the recipient, the regulations are much stricter. As a rule, no exemptions apply, meaning that any shipment exceeding specified thresholds must be reported in SENT.

Key threshold in the footwear sector

A particularly important aspect in the footwear industry is the quantity threshold, which is defined in units rather than pairs. In practice, the obligation arises for shipments exceeding 20 items (equivalent to 10 pairs of shoes). This interpretation reflects a functional approach aimed at preventing circumvention of the system.

What manufacturers and distributors must keep in mind

• SENT obligations apply not only to large shipments but also to standard commercial deliveries
• It is not possible to bypass the system by splitting goods into smaller batches within a single transport
• Responsibility for notification often lies with the seller, not the carrier
• Imports almost always trigger SENT obligations

A common mistake is assuming that the carrier or freight forwarder is responsible for SENT compliance. In reality, obligations are assigned based on the party’s role in the transaction—not who physically performs the transport.

Returns and e-commerce considerations

Returns generally do not require SENT notification—but only if they involve the actual return of the same goods and are properly documented with an invoice correction. If the returned goods are used or differ from the original, they may be treated as a new delivery, potentially triggering SENT obligations.

Another important exemption concerns postal shipments, which may be excluded from SENT under certain conditions. This can be relevant for e-commerce, but only if requirements regarding parcel dimensions and the nature of the postal service are met.

Operational challenges

For manufacturers and distributors, the biggest challenge is not understanding the law itself, but implementing it correctly—especially in businesses that combine import, domestic sales, and export, with complex supply chains involving multiple parties.

In practice, this requires organizing processes in areas such as:

• classification of goods according to CN codes
• assigning responsibility for SENT obligations
• ensuring proper documentation accompanies each shipment
• monitoring quantity thresholds
• verifying return processes

Conclusion

SENT 2026 is not merely a technical change—it significantly affects how businesses in the clothing and footwear sectors operate. It introduces new risks while also enforcing greater transparency and structured processes.

Advisory experience shows that the greatest risks arise when regulations are interpreted without considering operational realities. Therefore, it is crucial to properly structure business models and clearly assign responsibilities within the supply chain.

In this context, legal support plays not only a reactive role but, more importantly, a preventive one—helping to minimize risks and avoid penalties.

Autor: Ewa Sławińska-Ziaja

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