By the end of this guide your company will hold the BDO entry Poland requires for extended producer responsibility (EPR) on packaging, electronics and batteries, with the right party filing each stream.
Poland has EPR rules for eight waste streams. This guide explains packaging, electronics and batteries in full, because those are the three most sellers meet.
It covers companies established in Poland and those selling into it from abroad, and sets out what the entry costs, what the application asks for and what it makes due each year.
How do I register for EPR in Poland?
Poland has EPR rules for eight waste streams, and all of them run through one register, the BDO database kept by the regional marshals. The steps below cover packaging, electronics and batteries in depth, and for those three a company abroad reaches BDO in three different ways.
- Packaging goes into BDO under your own name. A company abroad files it itself, on a paper application to the Mazowieckie marshal in Warsaw, or leaves it to its Polish importer when it sells to Polish businesses.
- Electronics go into BDO too. A company abroad that sells them at a distance must appoint a Polish authorised representative, and the representative registers in its own name.
- Batteries go into BDO as well. A company abroad without a Polish branch files them through a Polish intermediary it has a contract with.
The entry must be in place before your first product reaches the Polish market, and the marshal has up to 30 days to make it. It ends in one 9-digit BDO number that goes on your invoices.
Do you want help with EPR registration in Poland? Repax Comply runs your registrations market by market, with an authorised representative where one is required. Explore ComplyWhat to gather first
Before you open the BDO application, gather these five company details and documents.
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Your tax number
A Polish company gives its NIP. The application asks for one only if you have it, so a company abroad without a Polish NIP can still apply.
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A person with a PESEL number
Using the BDO account after the entry needs someone with a Polish PESEL number to log in. It can be your representative or a proxy.
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Your products by stream
Packaged products, electronics by equipment group and whether they go to households, and batteries by type.
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Your brand names
Every brand you sell under in Poland, for the electronics and battery sections.
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Your recycling route
The recovery organisation you plan to use, with its BDO number, or your decision to meet the targets yourself.
The one question that decides your whole route
To guide you the best way, it helps to know where your company is based, because the steps are not the same for a company set up in Poland as for one selling into Poland from abroad.
Is your company based in Poland or abroad?
Pick your answer below for the right guidance.
If your company is based abroad, it also matters who buys from you:
- A Polish business. Your Polish buyer is usually the producer and makes the BDO entry.
- Consumers directly. You are the producer, and step 3 shows who files each stream.
One BDO entry and three routes into it
EPR registration is national everywhere in Europe, and how to register for EPR in Europe sets out the frame. Poland fills it in with a single register.
Across EPR in Poland the duties most producers trigger sit in these three streams. A webshop selling a boxed electric toothbrush with a rechargeable battery touches all of them, and the answer to who files each one from abroad is not the same.
Below are Poland's three registrations side by side, with fees as published in September 2026.
| Registration | Who files from abroad | Time and cost |
|---|---|---|
| BDO, packaging | You, on paper to the Mazowieckie marshal. Your Polish importer when you sell to Polish businesses | Up to 30 days. 200 zł for a micro firm, 800 zł otherwise, then the same every year |
| BDO, electronics | Your Polish authorised representative when you sell at a distance | Up to 30 days. Covered by the same fee |
| BDO, batteries | Your Polish intermediary | Up to 30 days. Covered by the same fee |
Two EU rules now sit on top of BDO. Since 18 August 2025 the EU Battery Regulation requires a battery distance seller to appoint an EPR authorised representative in Poland.
Since 12 August 2026 the EU packaging regulation (PPWR) requires the same of a seller shipping packaged goods straight to Polish consumers.
Poland has not yet created a BDO category for either representative. The reform bill that would do it, known as UC100, cleared the government's European Affairs Committee on 9 September 2026 and has not been adopted or sent to parliament.
A 6-step guide to EPR registration in Poland
This guide takes you from the first check, whether Poland counts you as the producer, to holding your BDO number. The steps run in the order the application sets, and each one ends with what you should have in hand before you move on.
Step 1. Confirm Poland counts you as the producer
Each stream draws the line in its own place. For packaging the duty sits with whoever first makes packaged products available in Poland, and importing counts, so a Polish business buyer is usually the producer.
For electronics the producer is a Polish maker, rebrander or importer, or a company abroad selling to Polish users at a distance.
For batteries the test is the first placing in Poland, with batteries built into devices and vehicles counted.
You are done when every product line has a yes or no against each stream, and a note of whether you sell it to Polish businesses or straight to consumers.
Step 2. Work out which registers you owe
In Poland every yes leads to the same place. Packaging, electronics and batteries are all sections of one entry in BDO, and a company established in Poland files them in one application.
A company abroad that only sells to Polish businesses can usually cross packaging and batteries off, because its Polish importer carries them. Electronics differ, since a sale at a distance to a Polish business still needs your representative.
You are done with the list of sections you owe. The toothbrush sold straight to Polish consumers from abroad owes all three. Other streams are in the table further down.
Step 3. Decide who files each one
Established in Poland. You file yourself or give a proxy a power of attorney, and the entry stays in your name. A recovery organisation can take over your recycling duties but not the registration.
Selling from abroad. You file packaging yourself with the Mazowieckie marshal. Your Polish authorised representative registers electronics in its own entry and lists you in it, and your Polish intermediary files your battery section.
Ask the marshal how to record the EU representatives until BDO has a category for them.
You are done when each section has a name against it. How to appoint an EPR authorised representative walks the appointment.
Step 4. Gather what each section asks for
The application takes the same company data once and adds a cut per stream.
- Packaging asks whether you meet the recycling duty yourself or through a recovery organisation, and if so its name and BDO number.
- Electronics asks for your brands, the equipment group, whether it is for households, your sales technique and your recovery organisation, or the financial guarantee for household equipment without one.
- Batteries ask for the battery type, the brand, and the intermediary you use if you have one.
Every application also carries a signed declaration that you meet the requirements.
Step 5. Register in the order the application sets
The application asks for things that must exist first.
- Appoint your Polish parties first if you sell from abroad. Both need a written contract before they can file.
- Settle your recycling route. Sign with the recovery organisations you name, or lodge the household electronics guarantee.
- Pay the registration fee, because the proof goes in with the application.
- File in BDO online if you are established in Poland, or print the generated form and post it to the Mazowieckie marshal if you are not.
How to choose a producer responsibility organisation compares the options. You are done when you hold a 9-digit BDO number and know which sections sit under your representative.
Step 6. Do what the entry makes due next
The entry starts one yearly calendar for every stream.
- By the end of February. Pay the annual BDO fee, from the year after you registered.
- By 15 March. File last year's report through your BDO account for each stream, and pay any product fee for targets you missed.
- All year. Put the BDO number on your invoices, meet the packaging education duty yourself or through your recovery organisation, and lodge the household electronics guarantee by 30 June if you comply on your own.
Marketplaces ask for the same number, and how to get EPR numbers for Allegro shows where it goes there.
The other streams Poland regulates
Beyond packaging, electronics and batteries, Poland has producer rules for five more streams and none yet for textiles.
Below is the register each one runs through, so you can rule them in or out in one pass.
| Stream | Register | Read more |
|---|---|---|
| Tyres | BDO, the same entry. Recovery and recycling targets, alone or through a recovery organisation | Tyres EPR in Poland |
| Lubricant oils | BDO, the same entry. Targets under the same law as tyres | Waste oils EPR in Poland |
| End-of-life vehicles | BDO, the same entry. Vehicle makers and importers run a collection network | Vehicles EPR in Poland |
| Single-use plastics | BDO, the same entry. A yearly producer fee since 1 January 2024 | Single-use plastics in Poland |
| Fishing gear | BDO, the same entry. Producers finance the collection of plastic gear | Fishing gear EPR in Poland |
| Textiles | None yet. Polish law has no producer responsibility for textiles | Textiles EPR in Poland |
One product record behind every BDO report
There are two ways through the work above, and both rest on the same product data.
Run the filings yourself
Every step above is data work before it is filing work. Packaging weights by material, electronics by equipment group split between households and businesses, batteries by type, and then the same figures again in every 15 March report.
Repax Core holds one structured record per product, broken down to its materials and components, takes your sales data in through integrations or order imports, and builds each report from it.
The packaging, electronics and battery sections of your BDO report all come out of that one record.
Try Repax Core for free - no card required Describe your products once and Core builds the report each market and scheme expects. Try it freeOr hand the filings over
Repax Comply, linked at the top of this guide, runs registrations market by market and works through an authorised representative where a country requires one, as Poland does for electronics sold from abroad. It confirms coverage stream by stream before it starts.
For the tools that handle Polish EPR data today, the best Polish EPR software in 2026 ranks them.
6 common mistakes when registering for EPR in Poland
Below are the six mistakes producers make most often when they register in Poland.
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Treating the entry as free
Budgeting nothing for BDO. The entry costs 200 zł for a micro firm and 800 zł otherwise, the same fee falls due every year by the end of February, and an unpaid annual fee gets you struck off.
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Applying before choosing a recycling route
Opening the application with no recovery organisation signed. The packaging and electronics sections ask for it, and household electronics without one need the financial guarantee lodged before you apply.
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Carrying one stream's filer to the next
Assuming the representative who registers your electronics also files your batteries and packaging. In Poland each stream has its own route from abroad, even inside the one register.
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Waiting for the packaging reform
Holding off until the new packaging law arrives. The bill is still inside the government, so today's act and BDO apply now, and the EU representative duties for direct sellers already apply.
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Reading the deposit as registration
Assuming a drinks producer in the deposit system, running since October 2025, needs nothing else. The deposit sits beside packaging EPR, and the BDO entry is still required.
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Relying on the 1 tonne rule
Skipping the entry because you place little packaging. Up to 1 tonne a year lifts the targets and the fee, and only if you file the paperwork by 15 March. The entry itself is still required.
Frequently asked questions about registering for EPR in Poland
Below are the five questions producers ask most often about registering for EPR in Poland.
How long does this take?
The marshal must make the entry within 30 days of a complete application. From abroad, add the time to sign your representative and intermediary, and the post for a paper application to the Mazowieckie marshal.
Do I need a company or an address in Poland?
No. A company abroad files its packaging entry on paper with the Mazowieckie marshal. Electronics sold at a distance need a Polish authorised representative, batteries a Polish intermediary, and someone with a PESEL number logs in.
Does one BDO entry cover every stream?
Yes. One application covers packaging, electronics, batteries and the other BDO streams, with one registration fee and one number. From abroad, electronics sold at a distance sit under your authorised representative's own entry instead.
Can Repax register for me?
Repax Comply runs registrations market by market, with an authorised representative where the law requires one, as Poland does for electronics sold from abroad. Repax Core prepares the product data behind the application and every annual report.
What happens if I sell in Poland without registering?
Only a registered business may place these products on the Polish market. Trading without the BDO entry carries a fine of up to 1,000,000 zł, about 230,000 euros, and no one may distribute packaged goods from an unregistered producer.
