Poland EPR
Provinces
Packaging
Provinces
Packaging
About
Packaging
About
Packaging
Packaging
Packaging
What is Packaging EPR
Extended Producer Responsibility (EPR) is a regulatory framework under which companies that place packaging or packaged goods on the Polish market are required to assume financial and organizational responsibility for the entire lifecycle of packaging, including collection, recycling, and final treatment. The system implements the “polluter pays” principle under Polish law and is aligned with current and upcoming EU legislation, including the Packaging and Packaging Waste Regulation (PPWR).Applicability to e-commerce and distance sales
Yes. Packaging EPR applies to e-commerce, distance selling, and cross-border online sales into Poland where packaged goods are supplied to the Polish market via online stores, marketplaces, or similar channels. The obligation applies irrespective of the seller’s place of establishment.Definition of “producer” under Polish EPR
For the purposes of Polish packaging EPR, the term “producer” is broadly defined and includes:- manufacturers of packaging and packaged products,
- importers and distributors placing packaging or packaged goods on the Polish market,
- online retailers and platforms supplying packaged goods to end users in Poland.
Who must register
Registration is mandatory for any company that:- manufactures or imports packaging or packaged goods for the Polish market;
- sells packaged goods in Poland, both online and offline;
- acts as an importer or distributor of packaged products.
Registration threshold
There is no minimum volume threshold in Poland. Registration is required regardless of the quantity of packaging placed on the market. Compliance is managed through the Polish BDO register (Database on Products, Packaging and Waste Management).Packaging scope
Packaging covered by EPR includes:- primary packaging (consumer sales packaging),
- secondary packaging (group or transport-related packaging),
- tertiary packaging (transport and logistics packaging).
Producer Responsibility Organizations (PROs)
As of 2026, the Polish packaging EPR system remains in a transitional phase. Producers continue to fulfil their obligations through existing compliance mechanisms, including BDO registration and contractual arrangements for waste management and recycling services. However, legislative reform foresees a transition to a centralized EPR model administered by the National Fund for Environmental Protection and Water Management (NFOŚiGW) by 2028. Commercial PROs have not been formally abolished as of 2026, but their role is expected to be gradually phased out.EPR registration in Poland
To comply with packaging EPR obligations, companies must:- register in BDO (the Polish electronic EPR and waste management register);
- obtain a BDO registration number prior to placing packaging on the market;
- appoint an authorized representative if they are not established in Poland.
Authorized representative
Companies without a legal establishment in Poland are required to appoint an authorized representative located in Poland. The representative acts on behalf of the producer for EPR registration, reporting, and communication with the competent authorities.Reporting data requirements
Producers are generally required to report:- the weight of packaging placed on the market, broken down by material type (e.g. plastic, paper, glass);
- all data expressed in kilograms (kg), in accordance with BDO reporting formats.
First reporting period
If a producer registers in BDO in 2026 but placed packaging on the market prior to registration, reporting must cover the period starting from the actual date of first placement on the Polish market. Authorities may require retroactive reporting. If market placement begins after registration, reporting obligations apply from the relevant reporting period in which the first supplies occurred.Reporting deadlines
Reporting frequencies (annual or other periodic submissions) are determined by the applicable regulatory framework and contractual arrangements. Where an eco-operator or waste management partner is engaged, reports must be submitted to that entity by the 15th day of the month following the end of the applicable reporting period. Annual statutory packaging reports are submitted through BDO in accordance with deadlines set by Polish law.Labelling and environmental claims
Polish law and EU legislation (including PPWR) impose requirements on packaging labelling, recyclability information, material composition, and environmental claims. Misleading or unsubstantiated environmental claims (“greenwashing”) are prohibited, and all labelling must comply with applicable EU and national rules.EPR fees and eco-modulation
Packaging EPR in Poland involves a packaging fee calculated based on the weight and material composition of packaging placed on the market. Fee rates are expected to be eco-modulated, with lower fees for recyclable or environmentally favourable materials and higher fees for materials that are difficult to recycle. Fees are payable by producers in proportion to the quantities of packaging introduced to the market.Risks, penalties, and common compliance issues
Non-compliance may result in:- significant administrative fines for failure to register or report;
- restrictions on commercial activities or sales;
- retroactive payment of fees and reporting obligations;
- penalties arising from incorrect packaging classification or data submission.
Recommended next steps for e-commerce sellers
E-commerce operators should:- assess whether they place packaging on the Polish market;
- complete BDO registration and obtain a registration number;
- appoint an authorized representative if not established in Poland;
- implement internal systems to track packaging quantities and materials;
- prepare for ongoing reporting and fee calculations;
- review packaging labelling and consumer communications for compliance.