Since 17 March 2026, Poland's SENT system covers the transport of clothing and footwear. The penalty for failing to register a shipment is 46% of the gross value of the goods, with a minimum of PLN 20,000 (approximately EUR 4,300). It does not matter whether you are a freight forwarder, a carrier or the owner of the goods - the regulations apply to everyone involved in the supply chain.
This article is a practical guide. Thresholds, CN codes, the registration procedure, obligations of each party and - most importantly - how to avoid penalties.
What Is SENT and Why Clothing Now?
SENT stands for System Elektronicznego Nadzoru Transportu (Electronic Transport Monitoring System). Until March 2026, it covered fuels, alcohol, tobacco and other sensitive goods. Now clothing and footwear have been added.
Why now? Poland's Ministry of Finance points to the scale of VAT fraud in the textile industry. Cheap clothing imports from Asia, trading goods without invoices, understating customs values. SENT is designed to close these gaps - just as it previously tightened the fuel market.
Legal basis: Regulation of the Minister of Finance of 10 September 2025. The provisions entered into force on 17 March 2026.
Which Goods Require Registration?
Not every shipment of clothes requires a SENT registration. There are specific thresholds.
| Goods | CN Code | Registration Threshold |
|---|---|---|
| Knitted clothing | Chapter 61 | Over 10 kg gross |
| Non-knitted clothing | Chapter 62 | Over 10 kg gross |
| Used clothing | 6309 00 00 | Over 10 kg gross |
| Footwear | Chapter 64 | Over 20 pieces (not pairs!) |
| Mixed shipments | Chapters 61 + 62 + 64 | Over 10 kg gross combined |
Watch out with footwear: the threshold is 20 pieces, not 20 pairs. 10 pairs of shoes = 20 pieces = threshold reached. This is a trap that many overlook.
Exclusion from Chapter 64: footwear components classified under CN code 6406 (soles, insoles, uppers) are not subject to SENT.
Who Must Register and What Exactly?
SENT divides obligations between three parties. Each has a different task.
Sender (consignor)
This is your obligation if you are the goods owner, a wholesaler, a clothing manufacturer or a retailer dispatching a shipment.
- Submits the SENT registration before transport begins
- Provides: goods data, CN code, weight/quantity, route, carrier details
- Receives a reference number (valid for 10 days)
- Passes the reference number to the carrier
Carrier
Regardless of whether you use your own fleet or subcontract.
- Verifies the reference number before loading
- Ensures active GPS tracking during transport within Poland
- Carries out transport in accordance with the data in the registration (route, goods, weight)
Recipient (consignee)
A shop, warehouse, distributor - whoever receives the shipment.
- Closes the SENT registration after receiving the goods
- Confirms the quantity and type of goods received
For freight forwarders: If you organise clothing transport, make sure your client (the sender) has submitted a SENT registration and passed the reference number to the carrier. If they have not, and the shipment is caught at inspection, the penalty hits everyone in the chain.
Registration Procedure - Step by Step
The entire procedure takes place on the PUESC platform (puesc.gov.pl).
- Register on PUESC - create a company account, assign permissions to people who will submit registrations. One-time setup, but it takes a while - better to do it in advance.
- Submit the SENT registration - online form. Enter the goods code (see table below), weight/quantity, sender, recipient and carrier details, planned route.
- Reference number - the system generates a number valid for 10 days. If transport is delayed and the number expires, you need to submit a new registration.
- Transport - the carrier drives with active GPS. The reference number must be available for inspection at any time.
- Closure - the recipient closes the registration on PUESC after delivery.
Goods Codes in the SENT Form
| Goods | Code in SENT Form |
|---|---|
| Knitted clothing (CN Chapter 61) | 6100 |
| Non-knitted clothing (CN Chapter 62) | 6200 |
| Used clothing | 6309 00 00 |
| Footwear (CN Chapter 64) | 6400 |
| Mixed shipments (Chapters 61+62+64) | 0006 |
Transit Through Poland - This Applies to Foreign Companies Too
This is crucial information for foreign companies and freight forwarders handling international routes.
Even if you are just passing through Poland (e.g. Germany to Lithuania, or Italy to the Baltic states), SENT registration is mandatory. It does not matter that the goods are neither dispatched from nor delivered to Poland.
The carrier must:
- Submit a SENT registration before entering Polish territory
- Ensure active GPS tracking during the transit
- Have the reference number available for inspection
AEO status (Authorised Economic Operator) does not exempt you from the registration obligation during transit. This is an important difference compared to domestic shipments.
Who Is Exempt?
1. VAT Invoice - but only for transport originating in Poland
This is the most important exemption and simultaneously the biggest trap. A VAT invoice exempts from SENT, but only when transport starts in Poland (Article 5 of the SENT Act).
| Transport Type | Does an invoice exempt from SENT? |
|---|---|
| Domestic (PL to PL) | YES - invoice documenting goods delivery |
| Export (PL to outside EU) | YES - invoice documenting export |
| Intra-Community supply (PL to another EU country) | YES - invoice documenting ICS |
| Import (to PL) | NO - invoice does not exempt |
| Transit (through PL) | NO - invoice does not exempt |
The invoice can be paper or electronic (KSeF - the reference number or QR code is sufficient). Key point: it must document a delivery, intra-Community supply or export - a transport service invoice is not enough.
In practice: If you are transporting clothing from a warehouse in Lodz to a shop in Krakow and you have a sales invoice, SENT does not apply. But if you are picking up a container of clothing at the port of Gdynia (import), the invoice will not help - you must register.
2. AEO Status
Entities with an Authorised Economic Operator (AEO) certificate are exempt from the registration obligation as sender or recipient. But note - this does not apply to transit. During transit through Poland, even a company with AEO must register the shipment.
3. Cooperation agreement with KAS
Companies that have signed a cooperation agreement with the Head of Poland's National Revenue Administration (KAS). In practice, these are large entities with a history of cooperation with tax authorities - this does not apply to most freight forwarding companies.
Penalties - How Much Does It Cost?
There is no room for mistakes here.
Penalty for missing registration or incorrect data: 46% of the gross value of the unregistered goods, minimum PLN 20,000 (approximately EUR 4,300).
A shipment of t-shirts worth PLN 50,000 without SENT registration = PLN 23,000 penalty (approx. EUR 5,000). A shipment worth PLN 200,000 = PLN 92,000 penalty (approx. EUR 20,000).
The penalty can hit every participant in the chain - sender, carrier and recipient. Failing to close the registration as a recipient is also a violation.
Practical Tips
For freight forwarders and logistics managers
- For every order involving clothing or footwear, ask your client for the SENT reference number
- Add it to your order checklist - same as the CMR or liability insurance
- Check that your subcontractor (carrier) has active GPS on routes through Poland
- Keep a list of CN codes handy - you will need them for every clothing order
For goods owners and importers
- Register your company on PUESC now, do not wait for the first shipment
- Remember the 10 kg threshold - that is very little. Two boxes of winter jackets can exceed it
- If you have AEO status, check whether your exemption covers the specific route (transit = no exemption)
- A VAT invoice with the goods is the simplest way to avoid SENT - but it must be available for inspection
For carriers
- Make sure your GPS system is working and transmitting position in real time
- Before loading: verify the SENT reference number
- If the sender does not have a number, do not load the goods. Better to lose the order than pay a PLN 20,000 (EUR 4,300) penalty
- For transit through Poland: you submit the registration, not the foreign sender
Summary
SENT for clothing and footwear is an extension of a system that has been running for years. Check the threshold, submit the registration on PUESC, drive with GPS on, close after delivery.
10 kg of clothing is very little. Two boxes of jackets and you have already hit the threshold. And the penalty? 46% of the goods value. For a shipment worth PLN 100,000 that is PLN 46,000 (approx. EUR 10,000). Nobody wants that surprise at an inspection.
Sources
- Changes to the SENT system from 17 March 2026 - National Revenue Administration (gov.pl)
- New SENT obligations in 2026 - KPMG
- SENT covers clothing and footwear - what importers and exporters need to know - PFC24
- SENT for clothing and footwear - obligations, thresholds and penalty risks - ASB Group
- SENT from 17 March 2026 - new obligations, thresholds and penalties - Transport w praktyce
- SENT exemptions for clothing and footwear transport - PrawnicyTransportu.pl