EPR in Poland

Extended Producer Responsibility in Poland requires businesses to take responsibility for certain products and packaging they place on the Polish market. Depending on the product category and the company’s role in the supply chain, this can include registration in the BDO database, maintaining detailed records, submitting annual reports and financing recovery or recycling obligations.

The Polish system can be difficult for international businesses because several obligations operate together. Registration and reporting are generally completed through BDO, Poland’s central database for products, packaging and waste management. ForSURE helps businesses centralise their Polish product and packaging data, prepare recurring reports, and manage EPR obligations alongside their requirements in other countries.

What Is EPR in Poland?

EPR in Poland is known as Rozszerzona Odpowiedzialność Producenta, often shortened to ROP. It makes producers responsible for the environmental impact of covered products after those products or their packaging become waste.

The responsible producer may need to finance or organise collection, recovery, recycling and public education activities. Businesses must also provide authorities with information about the products and packaging introduced to the Polish market.

EPR is not one single registration or payment. It is a framework covering several waste streams, with separate legislation and practical requirements for packaging, electrical and electronic equipment, batteries, tyres, lubricating oils, vehicles and certain single-use plastic products.

For packaging, responsibility generally applies when a business introduces packaged products to the Polish market. This includes packaging added to products before sale and, in many cases, shipment packaging used for e-commerce deliveries.

The company responsible under Polish EPR rules is not necessarily the company that manufactured the physical packaging. Responsibility normally depends on who first introduces the packaged product or regulated item to the market in Poland.

Who Must Comply with EPR in Poland?

Polish EPR requirements can apply to manufacturers, importers, online sellers and other businesses that first make covered products available in Poland.

A Polish brand owner may be responsible when it supplies products in packaging under its own name. An importer can become responsible when it brings packaged goods, electrical equipment, batteries or other regulated products into Poland from another EU country or from outside the EU.

E-commerce businesses may also be affected. A company that sells products directly to Polish customers can introduce both the product packaging and the additional shipment packaging to the Polish market. The absence of a Polish shop, warehouse or subsidiary does not automatically remove EPR obligations.

Responsibility should be assessed separately for each product stream. A seller supplying an electronic product with a battery and packaging may need to address three different areas:

• Electrical and electronic equipment
• Batteries or accumulators
• Product and shipment packaging

There is generally no universal minimum packaging quantity below which a business can assume that registration is unnecessary. Businesses introducing even relatively small quantities of packaged goods should therefore assess whether BDO registration applies before beginning sales.

Which Products Are Covered by Polish EPR?

Packaging is one of the broadest EPR categories in Poland. It can include sales packaging surrounding the product, grouped packaging used to combine several items and transport or shipment packaging used during distribution.

Common packaging materials include plastic, paper and cardboard, glass, aluminium, steel, wood and multi-material packaging. A single parcel may contain several reportable components, such as a cardboard box, plastic protective film, paper filling and adhesive tape.

Polish EPR rules also cover electrical and electronic equipment. Depending on the product, this can include domestic appliances, consumer electronics, computers, lighting equipment, tools and other devices that depend on electricity or electromagnetic fields.

Batteries and accumulators form a separate compliance stream. Obligations can apply to standalone batteries and to batteries incorporated into products.

Other regulated categories include tyres, lubricating oils, vehicles and selected single-use plastic products. Some businesses may also have duties relating to plastic carrier bags, fishing gear containing plastic or food and beverage containers covered by Poland’s implementation of the Single-Use Plastics rules.

Because the scope differs by waste stream, businesses should assess the complete product rather than only its primary commercial category.

What Is BDO Registration in Poland?

BDO is Poland’s electronic database for products, packaging and waste management. Businesses covered by the relevant Polish rules must generally obtain an entry in the BDO register before starting the regulated activity. The registration identifies the business and the product or waste categories for which it is responsible.

The application is normally handled by the marshal’s office in which the business has its registered office or place of residence. Where a business has no registered office or residence in Poland, the Marshal of the Mazowieckie Voivodeship is generally the competent authority for the annual product and packaging report.

Once registered, the company receives a BDO number. That number should be retained with the company’s compliance records and used where Polish law requires it on business documents.

The register contains different sections for different activities. A company must select the correct product, packaging or waste categories rather than applying for a general BDO registration that automatically covers everything.

The registration fee is currently PLN 200 for micro-enterprises and PLN 800 for other businesses in categories subject to the fee. An annual fee is also required to maintain the registration. A company operating in multiple fee-bearing BDO categories generally pays one registration or annual fee rather than a separate fee for every section.

Obtaining a BDO number is only the first step. Registration does not replace ongoing record keeping, reporting, recycling or payment obligations, and in many cases producers must also register with a Producer Responsibility Organisation (PRO) to fulfil their recycling and recovery duties.

EPR Packaging Obligations in Poland

A business introducing products in packaging to the Polish market must maintain information about the packaging associated with those products. This can include the packaging immediately surrounding the item as well as grouped, transport and e-commerce shipment packaging.

Packaging data must normally be divided by material. For example, a product delivered in a cardboard box with plastic film and a wooden pallet should not be reported as one combined packaging weight. Each relevant material fraction must be identified and measured.

Producers must also ensure that the required recovery and recycling levels are met. A business can arrange compliance independently or transfer certain obligations to an authorised packaging recovery organisation under an appropriate agreement.

Where recycling obligations are not fulfilled, a product fee may become payable. This means the cost is not simply a fixed annual EPR charge. It can depend on the packaging quantities, materials, statutory targets and evidence of recovery or recycling.

Businesses introducing packaged products also have obligations relating to public educational campaigns. These can be managed directly or, depending on the compliance arrangement, through a recovery organisation.

The correct compliance model depends on the company’s packaging volumes and internal capabilities. Using a recovery organisation can reduce the operational burden, but the producer must still supply accurate placed-on-market data and retain evidence supporting its declarations.

What Data Do You Need to Report?

Polish EPR reporting requires a reliable connection between product information, packaging specifications and sales into Poland.

For packaging, businesses should record the weight introduced to the Polish market for every relevant material. This may include plastic, paper and cardboard, glass, aluminium, steel, wood and other or multi-material packaging.

The data should show the reporting year and the activity that made the business responsible. For example, a company may be introducing packaged products from another country, packaging goods in Poland or adding shipment packaging when fulfilling online orders.

Where electrical equipment or batteries are involved, additional information may be required. This can include the product category, weight, quantity and information connected to collection or recycling obligations.

Single-use plastic rules can require separate records for covered products such as beverage cups or certain food containers. These figures should not be merged into a general packaging total when the BDO system requires a dedicated reporting table.

Businesses should therefore retain, at minimum, the following information:

• Product or SKU identifier
• Packaging component and level
• Packaging material
• Weight per component
• Number of products supplied in Poland
• Total weight placed on the Polish market
• Product or EPR category
• Reporting period
• Recovery organisation or compliance arrangement

A structured database in EPR software reduces the risk of missing materials or applying the same packaging weight to the wrong sales volumes.

EPR Fees and Product Fees in Poland

The cost of Polish EPR compliance can consist of several separate payments. Businesses should avoid treating every environmental charge as one general EPR tax.

BDO registration and annual fees are administrative charges associated with maintaining the required register entry. These are separate from packaging recovery costs or product fees.

A business working with a recovery organisation generally pays a contractual contribution based on its declared packaging quantities and materials. The organisation then performs specified recovery or recycling obligations on the producer’s behalf.

A statutory product fee may apply when the required recovery or recycling levels are not achieved. The calculation depends on the relevant material or product category, the unmet target and the applicable legal rate.

Separate charges may apply to lightweight plastic carrier bags and certain single-use plastic products. For example, Polish rules require businesses in specified sectors to collect consumer charges for certain single-use plastic beverage cups and food containers.

Businesses selling drinks in containers covered by the deposit return system must also account for the relevant deposit. That deposit is not the same as an EPR or product fee because it is intended to be returned when the empty packaging is brought back.

Keeping these charges separate in the compliance dataset helps finance teams understand which amounts are administrative fees, recycling contributions, product fees, consumer charges or refundable deposits.

EPR Reporting Deadlines in Poland

Annual EPR reports concerning products, packaging and the management of the resulting waste are submitted electronically through BDO.

The standard deadline is 15 March for information relating to the preceding calendar year. Where that date falls on a non-working day, the practical deadline may move according to Polish procedural rules.

The submission should reflect the actual quantities introduced during the reporting year. Businesses should therefore complete their sales reconciliation and packaging calculations well before March.

Corrections may be needed when the authority identifies missing or inconsistent information. Retaining source data and calculation records makes it easier to explain reported amounts and update the filing where necessary.

Registration fees, annual BDO fees, product fees and other charges can have separate payment deadlines. Companies should not assume that completing the annual BDO report automatically settles every financial obligation.

A compliance calendar should distinguish between registration renewal, reporting, payment, recovery organisation declarations and any waste-stream-specific deadlines.

EPR Poland for Foreign and Online Sellers

Foreign companies can trigger Polish EPR requirements when they supply covered products directly to customers in Poland. This is particularly relevant for online stores, marketplace sellers and businesses shipping goods from another EU Member State.

Packaging responsibility can arise for the product’s original packaging and for any additional packaging used to deliver the order. A seller that does not manufacture its own packaging may still be responsible because it introduces the packaged goods to the Polish market.

The BDO registration and reporting process can be more complex for businesses without a Polish establishment. The correct authority, registration route and representation requirements depend on the product category and legal position of the seller.

Authorised representative requirements should be assessed separately for packaging, electrical equipment and batteries. EU rules do not apply an identical representation model to every EPR stream.

Marketplaces can request a seller’s BDO number or other evidence of EPR compliance. Missing registration information may therefore create commercial problems even before formal enforcement action is taken.

Foreign sellers should determine:

• Which regulated products are sold in Poland
• Who first places each product on the Polish market
• Whether a Polish representative is required
• Which BDO sections are needed
• What product and packaging data must be retained
• Which organisation will meet recycling obligations
• Who will submit and approve the annual report

How Polish EPR Rules Are Changing

Polish packaging legislation is changing as the country aligns its system with Regulation (EU) 2025/40 on packaging and packaging waste.

The EU Packaging and Packaging Waste Regulation generally applies from 12 August 2026. It introduces more harmonised requirements covering packaging design, recyclability, recycled content, labelling, reuse and producer responsibility.

Poland is also developing national legislation to implement and administer the new framework. The draft rules address producer responsibility, packaging-related charges, the deposit return system and enforcement of the EU regulation. Because the national legislation remains subject to the legislative process, businesses should distinguish between enacted requirements and proposals that may still change.

The direction of travel is towards more detailed packaging data and a closer connection between packaging design and compliance cost. Material alone may no longer be sufficient. Businesses may increasingly need evidence relating to recyclability, recycled content, reusable formats and packaging minimisation.

The PPWR also creates specific requirements for producers selling packaging into other Member States, including rules concerning registration and authorised representatives. These requirements can affect foreign businesses selling directly to Polish customers once the relevant provisions apply.

Companies should therefore avoid building a reporting process that only reproduces historic BDO totals. Product-level packaging data will be increasingly important for meeting future Polish and EU requirements.

How to Manage EPR Compliance in Poland

Polish EPR compliance starts with identifying every regulated product stream. Packaging, electrical equipment, batteries and single-use plastics should be assessed separately, even when they relate to the same finished product.

The business must then establish who introduces each product to the Polish market. Sales through a Polish subsidiary, direct webshop, distributor or marketplace can produce different legal outcomes.

Once responsibility has been assigned, registration numbers, BDO sections, recovery organisation agreements and reporting deadlines should be stored centrally.

ForSURE’s EPR compliance software connects this compliance information to product and sales data. Packaging weights can be assigned to each SKU and multiplied by the number of products introduced in Poland during the reporting year. The resulting totals can then be mapped to the material categories required for Polish reporting.

The same system can be used to validate missing weights, identify products without EPR classifications and separate Polish volumes from sales made in other countries. It also provides a record of how each reported total was calculated giving you total control over your EPR process. Learn more by booking a demo.