What EPR obligations must companies observe in Poland? Companies that supply or sell products in Poland must comply with the registration, licensing, and disposal requirements under EPR in Poland. Anyone distributing packaging, batteries, or electrical equipment must actively manage their recycling and disposal to avoid fines. In this article, you will learn how to comply with all relevant EPR requirements in Poland and avoid penalties.
Registration requirement in the BDO register
In Poland, companies must register in the Product, Packaging, and Waste Management Database (BDO). The BDO register serves to record and monitor all waste-relevant data and is a prerequisite for legally operating in the Polish market.
The registration requirement applies to:
- Manufacturers and importers of packaging
- Manufacturers of electrical equipment and batteries, as well as their authorized representatives
- Companies importing packaged goods, vehicles, used tires, or lubricants into Poland
German companies shipping goods to Poland must also register in the BDO register and receive a BDO number. Registration is in Polish and costs approximately 200PLN per year for small companies and 800PLN for large companies.
What applies to companies in other European countries? – PESEL
As the EPR country comparison shows, foreign entrepreneurs from EU member states as well as those based in third countries can act through an authorized representative or lawyer who has a PESEL number (not necessarily a Polish citizen).
The registration number should be indicated on documents related to the product and waste activities, such as:
- VAT invoice
- Tax receipt
- Purchase agreement
- Reports
- Waste transport documents
- Waste records of companies that generate, transport, collect, or process waste and are required to maintain waste records
Troubled by the BDO register?
Significant warnings and fines may be imposed, and ignorance of the law does not protect against penalties.
Deutsche Recycling supports you with national and international recycling legislation, offering services tailored to your products and regions, focusing on packaging, batteries, and electrical equipment.
Labeling and documentation requirements in Poland: Overview for packaging, batteries, and electrical equipment
Poland has different information and labeling obligations for packaging, batteries, and electrical equipment.
The following table provides a quick overview of the main requirements related to BDO registration:
What to consider for registration in transportation?
For the transport and export of waste, a special registration number is required in Poland.
For cross-border waste transport, the Polish Waste Shipment Act and EU Regulation No. 1013/2006 apply.
Companies exporting waste internationally must be registered in the BDO as waste traders or brokers to apply for permits from the General Inspectorate of Environmental Protection (GIOŚ).
- A cross-border waste shipment permit is required for the export of both types of waste (lubricants and tires).
- Only a Polish company can apply for such a permit for waste export from Poland.
- The recipient of the waste must be a company that processes the waste in the destination country.
- It does not have to be the manufacturer; another entity authorized by the manufacturer can act as the Notifier.
- Usually, this is not the transport company, but it can be if the company’s activities have a broader scope.
Tires: How does extended producer responsibility (EPR) apply here?
Tires may not be disposed of in trash bins or landfills in Poland. Tire importers must submit special forms. If waste arises at a facility in Poland, registration in the waste database is mandatory.
Legal obligations in Poland: Understand duties, act compliantly
We provide consulting, analysis, and implementation of legal obligations in Poland from a single source.
Navigating BDO regulations can be confusing — with potentially serious financial consequences.
Deutsche Recycling handles all associated obligations, reducing effort and costs for your company, preventing potential fines and warnings, and responding to ongoing legal changes. Our expert team looks forward to supporting you personally.
EPR in Poland – our expertise is your advantage
Deutsche Recycling is your competent partner in Poland. We help you with:
- Years of expert knowledge
- Established Polish partner systems for returns
- Stable pricing models
- Language skills (contracts, power of attorney, etc.)
- No PESEL number application required
Importing to Poland and need further advice on EPR in Poland? Please contact us. Our colleagues are happy to assist.
Penalties in Poland – sanctions and warnings
Non-compliance with the BDO register regulations may result in the following penalties, depending on the offense:
- Failure to register, modify, or delete an entry in the register, or submission of an untruthful application – penalty: imprisonment or fine
- Operating a business without the required registration – administrative fine from 5,000 PLN to 1,000,000 PLN (1,000 EUR – 250,000 EUR)
- Failure to include the registration number on documents related to BDO-registered activities – fine from 5,000 PLN to 1,000,000 PLN
- Transporting waste without BDO registration – fine from 2,000 PLN to 10,000 PLN
- Failure of a waste carrier to deliver waste to the designated owner/destination – fine from 1,000 PLN to 100,000 PLN
- Incorrect information in the BDO register – penalty: imprisonment or fine
FAQ: EPR Poland
Do foreign companies without a branch in Poland need to appoint a local representative?
Yes, foreign companies without a presence in Poland that place products on the Polish market for the first time must appoint a representative in Poland. This representative assumes all duties related to registration, record-keeping, and reporting to authorities.
How often must companies report their waste and packaging data in the BDO?
Companies must report their waste and packaging data annually by March 15 for the previous year in the BDO system. For certain types of waste or activities, additional quarterly reports may be required.
What sanctions apply for missing or incorrect BDO registration?
Companies that fail to properly register in the BDO or provide incorrect information risk high fines, potentially amounting to several hundred thousand zlotys. Additionally, a sales ban on the affected products may be imposed.
Are reporting or labeling obligations also applicable for B2B deliveries to Poland?
The BDO registration requirement and other legal obligations apply to both B2C and B2B transactions involving packaging, batteries, and electrical equipment, if these products are placed on the Polish market for the first time.
