EPR obligations in Poland: volume threshold and registration obligation

European packaging legislation and the role of the authorized representative

Since 13 June 2013, the handling of packaging waste in Poland has been regulated by the Act on Packaging and Packaging Waste Management (Journal of Laws 2019.542). Among other things, it sets out requirements for packaging, the handling of packaging waste and regulations regarding recycling fees.

This means that companies in Poland are subject to extended producer responsibility (EPR). The EPR regulations are intended to ensure that companies take responsibility for the disposal of their packaging and thus contribute to the promotion of the circular economy. The EPR entails obligations regarding the handling of a company’s own products and packaging. In the following article, we shed light on what you need to consider as a retailer on the Polish market.

The registration obligation in the BDO

In Poland, the Product and Packaging and Waste Management Database (BDO) ensures the collection of information on waste and the electronic processing of registration, recording and reporting obligations of companies. Registration with the BDO is mandatory for all retailers and manufacturers and has been carried out exclusively online using forms in Polish since 2020. The obligation to register with the BDO also applies without a quantity threshold and from the very first packaging placed on the Polish market.
For companies with a Polish branch, registration in the BDO is carried out via the Marshal’s Office of the Voivodeship in their region, for foreign companies at the Marshal’s Office of the Voivodeship in Warsaw.

The EPR obligations for packaging

The EPR obligations in Poland apply to all companies that import packaging and products in packaging. This includes producers and importers as well as online retailers. Companies are generally obliged to minimise the volume and weight of their packaging and ensure that their packaging waste is recycled. Materials subject to EPR include paper, cardboard, carton, steel, aluminium, glass, plastic and wood.

To be compliant in Poland, you have to register as a producer in the BDO. In addition, depending on the amount of packaging you put into circulation in Poland, you pay a so-called eco fee to your EPR system. The fees you have to pay depend on a volume threshold in Poland. The volume threshold determines the quantity of packaging put into circulation above which a company is obliged to make a contribution to packaging licensing.

EPR Annual Report

All domestic and foreign companies are obliged to prepare an annual report. Among other things, this must contain information on the weight of the recovered and recycled packaging and the degree to which it has been recycled.

However, the report does not necessarily have to be prepared by the company itself, but can be prepared by the organisation commissioned by the company to fulfil the EPR obligations.

Sanctions for failure to fulfil EPR obligations

Non-compliance with EPR obligations in Poland can have significant consequences for traders. Companies that fail to register or fulfil their other EPR obligations may face fines and administrative penalties, depending on the severity of the case. Timely and correct registration is therefore essential in order to be compliant and avoid possible sanctions.

By fulfilling your obligations, you not only ensure that you comply with the requirements of the EPR legislation in Poland, but also contribute to the promotion of the circular economy.


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