Poland
How registration works in Poland
Packaging EPR in Poland starts at the BDO. Every producer of packaged goods must register before placing them on the Polish market. The voivodeship marshal assigns a BDO registration number, and that number is a precondition to sell.
The Act of 13 June 2013 on packaging and packaging waste management is the legal basis. It runs on a product-fee model: miss your statutory recovery and recycling targets and you pay a product fee (opłata produktowa) on the shortfall.
Hit them and you owe nothing beyond the cost of the recovery organisation you may have joined.
Three things stack on top of that base model under EPR in Poland: the deposit-return system, the PPWR, and a draft reform that would hand the entire model to a single state operator.
Who the packaging rules cover in Poland
The obligation sits with whoever first places packaged goods on the Polish market. The roles covered are:
- Manufacturers packaging goods and placing them in Poland
- Importers bringing packaged goods into Poland for the first time
- Own-brand sellers placing packaged goods under their label
- Distributors first making packaging available on the Polish market
The 2013 Act does not establish a de minimis for registration. No official source confirms an authorised representative or registration route for foreign packaging-only distance sellers. The verified AR path in Poland is for WEEE only.
Enforcement in Poland
The voivodeship environmental inspector (WIOŚ) enforces compliance. Fines run from 1,000 to 1,000,000 zł for operating without a BDO entry. Poland itself places no verification duty on online marketplaces, so the BDO obligation stays with the producer rather than the platform.
What changes next for packaging in Poland
Three changes are stacking up. The deposit-return system is already live since October 2025. The PPWR (Regulation (EU) 2025/40) applies directly from 12 August 2026 and adds packaging design, labelling, and reuse requirements that cut across the national model.
The biggest pending shift is the central packaging reform (draft bill UC100). It would move the entire model to a single state operator (NFOŚiGW) with full financing by 2028.
The reform is not yet law, and the new ROP model did not start in January 2026 as originally planned. Today's product-fee model remains but may not be permanent.
Frequently asked questions about packaging EPR in Poland
The questions packaging producers ask most about the Polish rules.
What does packaging EPR mean in Poland?
It means producers of packaged goods finance the recovery and recycling of packaging waste through a product fee on shortfalls against statutory targets. The obligation runs through the BDO register under the Act of 13 June 2013.
Do foreign or online sellers need an authorised representative in Poland?
No AR or registration route for foreign packaging-only distance sellers has been verified on an official source. The only confirmed AR path in Poland is for WEEE under the 2015 Act.
When are packaging reports due in Poland?
The annual report is filed through the BDO account by 15 March for the previous calendar year. It covers packaging volumes placed on the market and recovery achieved against statutory targets.
What changes next for packaging EPR in Poland?
The PPWR applies directly from 12 August 2026. A central packaging reform (UC100) would replace the current product-fee model with a single state operator (NFOŚiGW) and full financing by 2028, but the bill is still in draft.
Is the deposit scheme part of packaging EPR in Poland?
The deposit-return system (system kaucyjny) on beverage containers went live on 1 October 2025. It sits alongside the packaging producer duty. Drinks producers pay the deposit and still meet their packaging obligations through the product-fee model separately.
