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Packaging EPR in Poland

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Checked 2026-09-13 · 4 sources · 3 open questions

Register

BDO

Authority

Ministerstwo Klimatu i Środowiska / Urząd Marszałkowski

Law

Ustawa o gospodarce opakowaniami i odpadami opakowaniowymi (consolidated text Dz.U. 2026 poz. 619)Registration in BDO is required from the first packaging placed on the Polish market, and the roles are separate: wprowadzajacy opakowania (empty packaging) and wprowadzajacy produkty w opakowaniach (packed goods). The 1 Mg (1 tonne) a year threshold does NOT exempt anyone from the register — it exempts from the recycling levels, the oplata produktowa and the educational-campaign duty, and it is formally de minimis state aid whose value is calculated at the maximum rate of 4.50 PLN per kg plus the 2 percent below. Public educational campaigns: art. 19 requires at least 2 percent of the net value of the packaging placed on the market in the previous year, spent on campaigns or paid to the marshal of the voivodeship, unless the duty is passed to a recovery organisation.

Who registers

Whoever first places packaging on that market, foreign sellers included

Threshold

1,000 kg a year1 Mg a year. Below it: no recycling levels, no oplata produktowa, no educational-campaign duty — but the BDO registration and the annual report are still required. Formally de minimis state aid.

Authorised representative

The register applies the requirementupoważniony przedstawiciel ds. ROP

Reporting

Annually, by 15 MarchAnnual report on products, packaging and waste, filed in BDO by 15 March for the previous year, in kilograms split by material: plastics, aluminium, ferrous metals, paper and board, glass, wood, multi-material, other. A composite counts as multi-material when no single material is 90 percent or more of the mass. A recovery organisation does not take the report over — the producer still files it.

Household packaging schemes

REKOPOL, REEKO, ENERGA, INTERZERO, EKO PUNKT, ERP, RLG, REBIS, PRO EKOL, TORENT, AURAEKO, ASEKOL, TOTAL-EKO, EUROBAC, BRANŻOWA, BIOSYSTEM, EKO-ŚWIAT, Alba, EKO CYKL, O TRZY, TOM-DOLEKO-EKOLA, Konsorcjum Olejów Przepracowanych, OILER

Industrial packaging schemes

REKOPOL, REEKO, ENERGA, INTERZERO, EKO PUNKT, ERP, RLG, REBIS, PRO EKOL, TORENT, AURAEKO, ASEKOL, TOTAL-EKO, EUROBAC, BRANŻOWA, BIOSYSTEM, EKO-ŚWIAT, Alba, EKO CYKL, O TRZY, TOM-DOLEKO-EKOLA, Konsorcjum Olejów Przepracowanych, OILER

What is not settled

• Penalties Sources disagreeSources give two different lower limits for the fine: 1 000 PLN and 5 000 PLN.
• Law Not established at sourcePoland is mid-reform and the new act is NOT law yet. The bill on packaging and packaging waste (UC100, Ministry of Climate and Environment) was published on 13 August 2025, its status at the Government Legislation Centre is still open, and an updated version was published on 8 July 2026 — publication in the Journal of Laws had been planned for Q4 2025 and has not happened. The bill would add an oplata opakowaniowa paid per kilogram QUARTERLY: 8 percent of the oplata produktowa rate in 2026, 20 percent in 2027, full cost from 2028, when the oplata produktowa for packaging would be abolished and the recovery organisations wound up. None of that is in force. Treat any advice to sign with a recovery organisation as advice with an end date.
• Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.

The same in every EU country

• PPWR Art. 44 — registration is a precondition for placing packaging on that market
• PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
• set nationally, Art. 68; national rules due by 12 Feb 2027
• Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029

Sources

• bdo.mos.gov.pl authority
• eunr.org authority
• bip.lodzkie.pl authority
• legislacja.rcl.gov.pl authority

Countries with the same answer

• Portugal Live
• Sweden Live
• Slovenia Live
• Romania Not assembled

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