Who must register for packaging EPR in Poland, and how

Last checked against Polish law, including the consolidated 2013 Act, on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Poland's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

Packaging EPR runs under the Act of 13 June 2013 on packaging and packaging waste management (consolidated text Dz.U. 2026 poz. 619), with BDO registration under Art. 50 of the Waste Act. Producers must be entered in the BDO (the database on products, packaging and waste) at bdo.mos.gov.pl, through the Marshal of the Voivodeship (Marszałek Województwa) for the company's seat. For a foreign company with no Polish branch, the competent authority is the Marshal of the Masovian Voivodeship in Warsaw, and the application is on paper, printed and signed.

You need the BDO entry before your first sale (a recurring annual BDO fee applies), then discharge a statutory recovery and recycling obligation, either directly or by transferring it to a recovery organisation (organizacja odzysku opakowań) such as Rekopol or Interzero. If the recovery and recycling levels are missed, a product fee (opłata produktowa) is payable.

De-minimis: none for registration

BDO entry is required regardless of quantity, from the first sale, with no turnover threshold. Small-quantity reliefs exist at the product-fee level, reported at about 1 tonne (1 Mg) a year, but confirm the exact treatment with the Marshal's office before relying on them.

The Authorised Representative rule

Polish law does not require foreign producers to appoint an Authorised Representative. The BDO application can be filed by the business itself or by a proxy (pełnomocnik) of its choice. Working in the BDO system afterwards needs a PESEL number: a foreign business person can request one (in Polish or with a certified translation), or the business can act through a proxy who has one.

The one Authorised Representative duty that does apply is EU law. Since 12 August 2026, Art. 45(3) of Regulation (EU) 2025/40 requires a producer that supplies Polish end users directly without being established in Poland, including one based in another EU country, to appoint an Authorised Representative in Poland. Supplying Polish distributors who resell your goods unchanged does not make you the producer there under the PPWR. The Council ended negotiations on the proposal to suspend Art. 45(3) in April 2026 and left it out of its 24 June 2026 mandate, so do not plan around a delay.

Reporting, penalties and the UC100 draft

Reporting is annual via BDO, due by 15 March for the previous year, giving the weight of packaging by material in kilograms, with records kept for five years. Operating without a BDO entry carries an administrative fine of PLN 5,000 to PLN 1,000,000, and a consultancy reports that Allegro and Amazon block listings from sellers without one. A PPWR-aligned draft Act on Packaging and Packaging Waste (UC100) exists, but it had not reached the Sejm as at 29 September 2026. Until a new act is passed, the 2013 Act applies alongside the PPWR.

How onerous is it?

Moderate to high. BDO registration with no small-volume exemption, a signed paper application in Warsaw for sellers with no Polish branch, a PESEL number or a proxy to work in the system, an annual 15 March report, and a recovery obligation usually outsourced to a recovery organisation. Poland adds no Authorised Representative duty of its own; Art. 45(3) applies only if you sell straight to Polish end users.

Frequently asked questions