Introduction

Poland is intensively aligning its waste management system with EU requirements. A key element of these changes is the Extended Producer Responsibility (EPR) system, primarily implemented through the BDO register (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). The year 2026 is a turning point due to the first full year of the national deposit-refund system and preparations for the new EU packaging revolution (PPWR). Compliance with Polish regulations is essential for legal business operations, and a lack of registration results in severe administrative fines.

Definition and legal framework of EPR in Polands

The Polish EPR system is based on the Act on Packaging Management. An important act is also the Act on Waste Electrical and Electronic Equipment. These regulations implement EU directives regarding environmental protection. The main goal is the financing of waste collection by entities introducing products. Since 2025, a nationwide deposit-refund system has been functioning in Poland. It includes single-use plastic bottles, cans, and returnable glass bottles. Supervision over the system is exercised by the Ministry of Climate and Environment and GIOŚ. Each company must correctly classify its products into the appropriate groups. This allows for the avoidance of errors in reporting and product fees. Poland aims to create a circular economy by 2030.

Entities Subject to Registration ObligationsDefinition and Legal Framework of EPR in Greece

In Poland, EPR responsibility rests with the so-called introducer of products. This definition includes manufacturers producing goods under their own brand. It also applies to importers bringing products from abroad into Poland. Companies performing intra-Community acquisition of goods (WNT) also have obligations. Online sellers conducting shipping should pay particular attention. A shop sending goods in a cardboard box is treated as an introducer of packaging. This also applies to foreign companies selling directly to Polish consumers. A company must register in the database before starting its activities. The mere fact of possessing transport packaging imposes an obligation to register in the system. Marketplace platforms increasingly require a registration number from sellers.

Supervisory Institutions and Recovery Organizations

The key tool for supervision in Poland is the BDO system. This is the Database on products and packaging and on waste management. Every entrepreneur subject to the regulations must have an active number there. In addition to registration, companies often cooperate with packaging recovery organizations. Recovery organizations for electrical and electronic equipment operate in the electronics sector. These entities help companies achieve statutory recovery and recycling levels. They collect fees that finance waste collection infrastructure in municipalities. They take responsibility for educational campaigns and reporting. The Marshal's Office competent for the company's registered office exercises financial supervision. The Inspectorate for Environmental Protection conducts inspections regarding the correctness of records.

Procedure for registration and obtaining a BDO number

The registration process takes place fully electronically via the BDO portal. The application requires an electronic signature or a trusted profile. It is necessary to precisely define the scope of activity and the types of introduced products. Some entrepreneurs must pay a registration fee when submitting the application. After positive verification, the office assigns a unique BDO registration number. This number must be placed on invoices and commercial documents. The registration process usually takes up to 30 days from the submission of the application. In the case of electronics, it is required to pay a financial security. This can be done in the form of a deposit or a bank guarantee. A correct entry in the BDO is the foundation of legal sales in Poland.

Reporting and Weight Record Obligations

Companies in the BDO system must maintain ongoing mass records. The records include the weight of all packaging introduced to the Polish market. Data must be reported broken down into plastics, paper, wood, and metals. The annual report on products and packaging is submitted by March 15. This document goes to the Marshal's Office via the electronic system. In the case of electronic equipment, the mass of devices and batteries is reported. It is also necessary to maintain records of waste generated in the company. Data precision is key to avoiding the product fee. This fee is a penalty for failing to achieve the required recycling levels. Errors in reports can lead to audits and high penalties.

Fee System and Recycling Financing

EPR fees in Poland depend on the tonnage and type of materials. Entrepreneurs pay an annual fee to maintain the entry in the BDO. The costs of cooperation with a recovery organization depend on market rates. From 2025, costs related to the deposit-refund system are added. Beverage sellers must participate in financing the system operator. Poland is introducing eco-modulation of rates for selected packaging fractions. Packaging that is difficult to process will be charged higher levies. Ecological materials can count on preferential fee rates. Companies must also allocate funds for public educational campaigns. This is usually a specified percentage of the revenue from introduced packaging.

Thresholds for Exemption and Simplifications for Small Companies

The Polish act provides for de minimis aid for the smallest introducers. The exemption applies to companies introducing less than 1 tonne of packaging annually. Such entities do not have to pay the product fee after completing the formalities. However, they must submit an application for de minimis aid on time. Exemption from the fee does not mean exemption from the obligation to register. Every commercial company must have a BDO number and submit reports. Simplifications mainly concern the financial side, not the recording side. In the case of electronics and batteries, weight thresholds usually do not apply. Even the sale of one electronic device requires full registration. This is important for small online stores starting out on the market.

Product Labeling Requirements

Poland uses standard EU symbols on electronics and batteries. Equipment must have the crossed-out wheeled bin symbol. From 2025, new regulations apply to the labeling of bottles in the deposit-refund system. Products covered by the deposit must have a special logo and barcode. This informs the consumer about the possibility of recovering the deposit in the store. It is also recommended to use symbols that facilitate the segregation of materials. This helps Poles in correctly throwing away waste into colored containers. Operating instructions must contain information about the impact of waste on the environment. This is a statutory information obligation for every introducer. The lack of appropriate markings may result in the withdrawal of the goods from circulation.

Consequences of EPR Violations

The Inspectorate for Environmental Protection conducts strict inspections of entrepreneurs. The lack of a BDO number on invoices risks a fine of up to 1 million PLN. Administrative fines are threatened for the lack of registration in the system. The minimum amount of a fine for serious deficiencies is 5 thousand PLN. Marketplace platforms block sellers without a verified BDO number. The lack of an annual report results in the retroactive calculation of the product fee. The office may also impose a fine for the lack of record-keeping. The most severe penalty is a ban on placing products on the Polish market. Transport companies may refuse to collect waste from an entity without a BDO.

Rulity Consulting support on the Polish market

Fulfilling EPR obligations in Poland requires ongoing monitoring of regulations. Rulity Consulting offers comprehensive support for companies in the BDO system. We help with correct registration and updating entries in the register. We represent companies before Marshal's Offices and recovery organizations. We prepare annual reports on products, packaging, and waste. Cooperation with Rulity Consulting eliminates the risk of errors in reporting. We prevent severe financial penalties for lack of required compliance. We advise on optimizing recycling costs and the deposit-refund system. We help obtain exemptions under de minimis aid. Our support guarantees full legal security for your company in Poland.

FAQ

Do you need support with registration in the Polish market? Rulity Consulting will help you through the verification process and ensure correct reporting.