The expansion of the SENT system as of March 17, 2026, represents one of the most significant regulatory changes for the TSL sector and the clothing industry. Its impact goes beyond an additional administrative obligation—in practice, it fundamentally changes how certain categories of goods are traded and how the transport of clothing and footwear is managed.

From that date, the transport monitoring system covers clothing and footwear, marking a major shift for the entire supply chain—from importers to carriers.

The Electronic Transport Supervision System (SENT) operates under the Act of March 9, 2017, on the monitoring of road and rail transport of goods and the trade in heating fuels. This legislation forms the legal basis for the obligations imposed on transport participants. From the outset, the law makes clear that its purpose is to control the trade in sensitive goods. Under Article 5, “the transport of goods is subject to notification in the register,” which in practice means an obligation to actively report shipments in the SENT system.

Previously, the system mainly covered fuels, alcohol, and selected waste. However, as of March 2026, its scope has been extended to include additional categories of goods, such as clothing and footwear. This introduces new obligations not only for carriers but also for commercial entities.

A key point for businesses is that SENT 2026 obligations apply to the entire supply chain—covering the sender, the carrier, and the recipient. This makes it necessary to implement consistent transport compliance procedures.

Key changes under SENT 2026 include:

• inclusion of clothing and apparel (CN Chapters 61 and 62) in the SENT system
• inclusion of used clothing (CN 6309) and footwear (CN Chapter 64)
• dependence of reporting obligations on quantity and weight thresholds
• extension of liability to all parties involved in the transport
• retention of severe penalties for failure to report or for reporting errors

In practice, this means that the transport and trade of clothing are no longer regulatory-neutral but are now subject to strict monitoring. This aligns with a broader trend of tightening the tax system and increasing control over economic activity.

The expansion of SENT is not accidental—it reflects tax authorities’ observations of risks associated with high-volume goods, particularly in import and distribution. As a result, the clothing sector has been identified as requiring increased oversight.

From a practical standpoint, it is crucial that carrier obligations in the SENT system are linked to the responsibilities of other participants. This means that incorrect reporting may result not only from carrier errors but also from inaccurate data provided by the contracting party.

Sanctions and risks

The penalties provided under the SENT regulations are severe and intended to be preventive. They may reach:

• up to 46% of the gross value of the transported goods
• a minimum of PLN 20,000 per violation
• additional consequences, including detention of the transport

Given this structure, SENT 2026 should not be treated as a formality but as a critical element of risk management within a business.

It is also important to consider exemptions and exceptions предусмотренные in implementing regulations. While they may apply in specific cases, their interpretation can be uncertain, requiring case-by-case analysis.

Operational implications

Implementing SENT obligations requires:

• verification of goods classification according to CN codes
• analysis of quantity and weight thresholds for each shipment
• implementation of reporting procedures in the PUESC system
• ensuring consistency between documentation and SENT notifications
• training employees responsible for transport and logistics

In practice, many companies are only now realizing that transport compliance under SENT requires a systemic approach—covering processes, personnel, and IT tools.

Conclusion

The extension of the SENT system to clothing and footwear should be seen as part of a broader regulatory trend that may eventually affect other sectors. Businesses should therefore prepare for further changes and increasing reporting obligations.

Experience shows that the greatest challenges arise not from the regulations themselves but from their practical application—especially in complex supply chains where responsibility for SENT obligations is not clearly defined.

For this reason, it is crucial to organize responsibilities, information flows, and procedures at the implementation stage. This helps reduce the risk of penalties and disruptions in transport operations. In this context, tailored legal support plays an important role—not only in interpreting the law but in translating it into effective and compliant operational processes.

Author: Ewa Sławińska-Ziaja
Legal Counsel at Trans Lawyers

www.translawyers.eu