As of 17 March 2026, an amended regulation of the Minister of Finance concerning the SENT transport monitoring system will enter into force. The new rules will significantly affect the transport of clothing and footwear through the territory of Poland. Under the new regulations, the SENT system will also cover the monitoring of clothing and footwear transport within Poland.

Below we present the key information regarding the scope of the new regulations and the obligations of entities required to submit notifications in the SENT register.

Scope of the new SENT regulations

According to the amended regulation, the SENT system will also cover the transport of:

• clothing and clothing accessories (knitted and non-knitted),
• footwear,
• parts of these articles,
• used clothing and other used articles.

It is important to verify the specific CN code, as SENT regulations refer directly to these classifications.

When will transport be subject to SENT notification?

From 17 March 2026, notification in the SENT system will be required when the following conditions are met:

• CN Chapter 61 (knitted apparel) – when the gross weight of the shipment exceeds 10 kg
• CN Chapter 62 (non-knitted apparel) – when the gross weight of the shipment exceeds 10 kg
• CN Code 6309 00 00 (used clothing) – when the gross weight of the shipment exceeds 10 kg
• CN Chapter 64 (footwear) – when the shipment contains more than 20 pairs of shoes (excluding CN 6406)
• Goods from CN Chapters 61, 62 and/or 64 combined – when the gross weight of the entire shipment exceeds 10 kg

Who is subject to SENT obligations?

Consignor

An entrepreneur who:

• performs domestic supply of goods,
• carries out intra-Community supply of goods (ICS),
• performs export of goods.

Consignee

An entrepreneur who:

• - carries out intra-Community acquisition of goods (ICA),
• - performs import of goods,
• - purchases goods under domestic supply.

Carrier

The entrepreneur physically transporting the goods.

Practical obligations for ATC Cargo S.A. customers

Under the new regulations:

• The consignor or consignee (depending on the procedure) will be required to submit a SENT notification before the transport begins within Poland
• ATC Cargo customers should inform us at the quotation stage if the shipment includes goods subject to the SENT system
• This will allow for efficient planning of the transport process and the selection of a carrier prepared to handle SENT-monitored shipments.
• The notification data (including the SENT reference number/key) must be provided to ATC Cargo S.A. if the road transport within Poland is carried out by ATC Cargo

Then:

1. ATC Cargo forwards the data to the carrier
2. The carrier
   • completes their part of the SENT notification
   • activates the GPS locator during transport

After transport completion:

• the consignee must confirm receipt of the goods in the SENT system
• the notification must be closed no later than the next working day after deliver

Responsibility for SENT Notification

The consignor or consignee is directly responsible for the correct and timely submission of the SENT notification.

Administrative penalties may be imposed on these entities in case of non-compliance with the regulations.

Exemptions – When SENT will not apply

Individual categories of goods covered by SENT have their own scope of exemptions. This means that exemptions applicable to other goods (e.g., fuels or tobacco products) do not necessarily apply to clothing and footwear.

According to §1 point 10 of the amended regulation, SENT regulations do not apply to the following goods:

1. Goods transported under Article 5 of the Monitoring Act

Except for:

• transport of goods from third countries after release for free circulation in the EU, where the destination is another EU country other than Poland- (so-called customs procedure 4200)
• transport of goods without an accompanying VAT invoice documenting:
  • completes their part of the SENT notification
  • activates the GPS locator during transport
  • intra-Community supply
  • export of goods (if the exemption can be applied operationally)

2. Entities with special status

If the entity required to submit the notification (e.g., importer or exporter):

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• holds AEO status (Authorised Economic Operator) under the EU Customs Code,

or

• is a party to a cooperation agreement with the Head of the National Revenue Administration

3. Postal shipments

Goods transported by postal operators in postal parcels.

What This Means in Practice

In practice, from 17 March 2026, the obligation to notify shipments in the SENT system will primarily apply to companies in the clothing and footwear sector. However, it is important to emphasize that the regulations may also affect companies from other industries.

If a shipment contains clothing or footwear – even incidentally – the transport may be subject to SENT notification. This may occur, for example, when a company imports other goods (e.g., technical components) but also includes

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