The Polish Extended Producer Responsibility (EPR) framework for packaging aims to reduce the environmental impact of products and packaging throughout their lifecycle. Enforced since 7 July 2023, the Act on Packaging Management and Packaging Waste obligates producers, importers, and distributors to take responsibility for packaging from design to end-of-life. Businesses must register in the BDO Register, ensure recycling targets are met, conduct public awareness campaigns, and submit annual reports with accurate packaging data. Non-compliance can result in administrative fines up to PLN 1,000,000.

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Poland EPR Regulations for Manufacturers, Importers and Ecommerce

The obligations apply to entities that:

• Introduce packaging or products in packaging into the Polish market.
• Make intra-community deliveries of packaged products.
• Export packaging or packaged products.
• Run retail or wholesale units offering plastic shopping bags subject to a recycling fee.

Producers can comply by managing recycling obligations independently, joining an authorized Packaging Recovery Organization (e.g., Rekopol), or an Economic Self-Government Organization for specific packaging types. Special rules apply to multi-material packaging and hazardous substances in packaging.

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Covered and Exempted Packaging under Poland EPR

Covers: All packaging materials (plastic, metal, paper, cardboard, glass, wood, multi-material).

Exemptions:

• Businesses introducing products in packaging and subsequently exporting or making intra-community supply of the same packaging within the same year (except Articles 14 & 45).
• Businesses introducing packaging ≤1 Mg/year – exempt from recycling targets, product fee, and some reporting obligations (must submit de minimis aid documentation by 15 March).

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Who Must Register under Poland EPR

Registration in the BDO Register is mandatory for:

• Manufacturers, importers, or intra-community acquirers of packaging.
• Entities introducing packaged products.
• Exporters of packaging or packaged products.
• Retail or wholesale units selling plastic shopping bags subject to a recycling fee.

Registration must occur before commencing business. A unique BDO registration number will be issued and must appear on business documents.

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Poland EPR Data Reporting

Annual EPR reporting is submitted via the BDO system by 15 March for the previous year. Reports must detail:

• Weight and type of packaging introduced (single-use/reusable, material type).
• Compliance with heavy metal content limits (≤100 mg/kg).
• Packaging containing hazardous substances.
• Mass of recycled packaging waste.
• Recycling targets achieved vs. required.
• Number of plastic shopping bags sold (subject to recycling fee).
• Public educational campaign expenditure (≥2% net packaging value or equivalent payment to Marshal’s account).

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Poland EPR Schedule and Deadlines

• BDO Registration: Before starting relevant activities.
• Annual Report: 15 March (previous calendar year).
• Annual Fee: By end of February.
• Product Fee Payment: 15 March (following the year of obligation).
• Recycling Fee Payment: By the 15th day of the month following the quarter collected.

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Poland EPR Fees and Penalties

• Registration fee: PLN 100 (micro-entrepreneurs) / PLN 300 (others).
• Product fee: Up to PLN 4.50/kg of packaging.
• Recycling fee: Up to PLN 1 per plastic bag.
• Penalties: Administrative fines from PLN 5,000 to PLN 1,000,000 for non-compliance.

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Common EPR Compliance Challenges In Poland

• Complex BDO registration and reporting procedures.
• Accurate calculation of recycling targets and product fees.
• Maintaining 5-year data records for packaging and waste.
• Meeting selective collection rates for beverage bottles (77% by 2025, 90% by 2029).
• Organizing compliant public educational campaigns.

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Why choose RegSurance as your Poland EPR Compliance Partner

RegSurance is a trusted EPR compliance service provider for international businesses needing to comply with Poland packaging EPR rules. We support manufacturers, importers, and e-commerce sellers with complete EPR solutions — including EPR registration, packaging compliance assessments, ongoing regulatory updates, and accurate EPR data reporting for Poland. With our in-depth knowledge of Poland EPR requirements, we ensure your business stays fully compliant and up to date with changing legislation.

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• Get a free EPR compliance Assessment
• Receive a personalized registration roadmap
• Book a 1:1 consultation with our experts
• Register or Sign-in for our comprehensive EPR Compliance Guide

FAQs

• Who must register for Poland EPR packaging compliance? All producers, importers, intra-community acquirers, and exporters of packaging or packaged products must register in the BDO Register before starting operations.
• What is the Poland EPR reporting deadline? The annual EPR report must be submitted via the BDO system by 15 March for the previous calendar year.
• What packaging is exempt from Poland EPR requirements? Businesses introducing ≤1 Mg of packaging annually or exporting all packaging in the same year are exempt from certain obligations.
• What are the recycling targets for beverage bottles in Poland? From 2025, 25% recycled PET content is required; from 2030, 30%. Selective collection rates: 77% by 2025, 90% by 2029.
• What fees apply under Poland EPR? Registration fee: PLN 100–300, product fee up to PLN 4.50/kg, recycling fee up to PLN 1 per plastic bag.
• How do I register in the BDO system? Registration is completed online via the BDO system before starting business activities, requiring company identification details and business type.
• What documents are needed for Poland EPR reporting? Reports must include packaging weights, material type, recycling performance, hazardous packaging details, bag sales, and educational campaign spending.
• What are the penalties for non-compliance with Poland EPR? Penalties range from PLN 5,000 to PLN 1,000,000 depending on the violation, including failure to register, report, or meet recycling targets.
• Do foreign companies need Poland EPR registration? Yes, foreign businesses placing packaging or packaged products on the Polish market must register in BDO, often via an authorized representative.
• What is the product fee in Poland EPR? A fee based on the weight and type of packaging if recycling targets are not met, up to PLN 4.50 per kg.