Who must register for packaging EPR in Poland, and how
Producers must register in the BDO database, filed to the Marshal of the Voivodeship (the Masovian Marshal in Warsaw for foreign firms, on paper), before commencing activity, then discharge a recovery/recycling obligation — usually via a recovery organisation such as Rekopol or Interzero. There is no de-minimis for registration. An AR becomes mandatory for foreign producers from 12 August 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.
| Register / authority | BDO database, filed to the Marshal of the Voivodeship (Masovia for foreign firms) |
|---|---|
| PRO / compliance scheme | A recovery organisation (e.g. Rekopol, Interzero) |
| Authorised Representative | From 12 Aug 2026 Mandatory from 12 August 2026 (Art. 45) |
| De-minimis threshold | None for registration (~1 t/yr simplification at fee level) |
| National instrument | the Polish packaging management act (BDO) |
The register and what it involves
Producers must register in the BDO (the database on products, packaging and waste) at bdo.mos.gov.pl, submitted to the Marshal of the Voivodeship (Marszałek Województwa) for the company's seat. For foreign companies with no Polish seat, the competent authority is the Marshal of the Masovian Voivodeship in Warsaw, and the application is on paper.
You must obtain a BDO entry before commencing activity (a recurring annual BDO fee applies), then discharge a statutory recovery/recycling obligation — either directly or by transferring it to a recovery organisation (organizacja odzysku opakowań) such as Rekopol or Interzero. If targets are missed, a product-fee (opłata produktowa) penalty levy applies.
De-minimis: none for registration
BDO entry is required regardless of quantity, from the first sale, with no turnover threshold. A roughly 1-tonne (1 Mg)/year simplification exists at the recovery/product-fee level (simplified reporting or relief from individual targets), but the exact statutory treatment should be confirmed.
The Authorised Representative rule
Foreign companies without a Polish establishment must appoint a Polish-located representative (pełnomocnik) or file directly (on paper) with the Marshal of Masovia. From 12 August 2026 an AR becomes mandatory for foreign producers, including those established in other EU member states, under PPWR.
Reporting, penalties and the pending reform
Reporting is annual via BDO, due by 15 March for the previous year — weight of packaging by material in kilograms, with records retained five years. Operating without BDO registration carries an administrative fine of PLN 5,000 to PLN 1,000,000, and e-commerce enforcement can include marketplace listing blocks. A major reform is pending: the draft Act on Packaging and Packaging Waste (UC100), aligning to PPWR, has a headline in-force date of 12 August 2026, but whether the Sejm has formally enacted it by mid-2026 is unconfirmed — check Dziennik Ustaw.
How onerous is it?
Moderate-to-high. Mandatory BDO registration with no small-volume exemption, a Polish-language paper process for non-established sellers, a Polish AR effectively required (mandatory for all foreign producers from 12 August 2026), an annual 15-March report, and a recovery obligation typically outsourced to a PRO.
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Get my full PPWR obligations report →Frequently asked questions
Does Poland have a small-volume exemption from BDO registration?
No. BDO entry is required regardless of quantity, from the first sale, with no turnover threshold. A roughly 1-tonne/year simplification exists at the recovery/product-fee level, but that is reporting relief, not an exemption from registering.
How does a foreign company register in the BDO?
A foreign company with no Polish seat files to the Marshal of the Masovian Voivodeship in Warsaw, on paper. From 12 August 2026 an Authorised Representative becomes mandatory for foreign producers, including EU-established ones.
Is the new Polish packaging law (UC100) in force?
As drafted it has a headline in-force date of 12 August 2026, but whether the Sejm has formally enacted it by mid-2026 could not be confirmed — check Dziennik Ustaw before relying on it. Until then the current BDO regime applies.
Sources
- CMS — Poland plastics and packaging laws (BDO, recovery obligation) — https://cms.law/en/int/expert-guides/plastics-and-packaging-laws/poland
- Poland EPR for foreign companies (Marshal of Masovia, paper filing) — https://ekokonsult.eu/en/news/bdo-epr-poland-foreign-companies/
- KPMG — the draft Act on Packaging and Packaging Waste (UC100) — https://kpmg.com/pl/en/insights/law/legal-alert-new-act-on-packaging-and-packaging-waste-a-revolution-in-the-epr-system-in-poland.html