Poland EPR

What is Poland EPR Batteries

Poland's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States from 18 August 2025. At the national level, Poland's battery EPR obligations are implemented through the Act on Batteries and Accumulators (Ustawa o bateriach i akumulatorach) and integrated into the broader waste management legislation underpinning the BDO — the national Product, Packaging and Waste Management Database (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). The BDO system (bdo.mos.gov.pl) is the central registration and reporting platform for all EPR-related obligations in Poland, including batteries, WEEE, and packaging. The BDO is administered by the Ministry of Climate and Environment (Ministerstwo Klimatu i Środowiska). The Chief Inspectorate for Environmental Protection (GIOŚ) oversees enforcement and compliance. Poland was included in the first wave of Zalando's battery EPR number verification — active from January 2026. Amazon requires Polish battery BDO registration numbers from sellers and will deactivate non-compliant offers. Kaufland also requires Polish battery registration numbers. Without a BDO number, it is not legally possible to trade batteries and accumulators in Poland.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation and Polish waste legislation explicitly capture distance sellers and e-commerce operators. Any company placing batteries — standalone or incorporated into products — on the Polish market for the first time is a producer regardless of sales channel or country of establishment. Foreign companies selling battery-containing products directly to Polish consumers via e-commerce must register in the BDO, obtain a BDO number, and appoint a Polish-based authorised representative. The BDO number must appear on all invoices, receipts, contracts, and business documents related to the product. Amazon, Zalando, and Kaufland all actively verify Polish battery BDO registration numbers. Amazon will deactivate non-compliant offers in Poland — making BDO registration a practical market access requirement, not only a legal one.

Who is the "Producer" under Poland EPR?

Under Regulation (EU) 2023/1542 and the Polish Act on Batteries and Accumulators, a battery introducer (wprowadzający baterie lub akumulatory) is an entrepreneur who introduces batteries or accumulators — including those installed in equipment or vehicles — to the Polish market for the first time. This definition is broad and covers:

1. Manufacturers established in Poland who produce and sell batteries domestically under their brand.
2. Importers bringing batteries into Poland from non-EU countries for the first time under their name.
3. Companies introducing batteries from another EU Member State into Poland for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Poland who sell batteries or battery-containing products directly to Polish consumers.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Poland

All battery producers must register in the BDO (bdo.mos.gov.pl) before placing batteries on the Polish market. The BDO number issued upon registration must appear on all invoices, receipts, contracts, and records related to the product. Without BDO registration, it is not legally possible to trade batteries in Poland. Producers must also join an approved Producer Responsibility Organisation (PRO) or demonstrate individual compliance with collection and recycling obligations. The BDO registration portal is available in Polish only, which creates a significant language barrier for foreign companies. Foreign companies without a Polish presence are legally required to appoint a Polish-based authorised representative to manage BDO registration and compliance on their behalf.

Poland EPR Battery Registration Threshold

Poland applies a zero threshold for BDO registration. The obligation applies to every battery that is placed on the Polish market, starting from the very first one. There is no minimum sales volume, weight, or turnover threshold. All producers, regardless of size, must register in the BDO. The only exemption in the EU Battery Regulation concerns batteries used in military or space equipment, which are outside scope entirely.

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Poland: Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Poland operates an approved PRO system for batteries. Producers join a licensed collective organisation that manages collection, recycling, and reporting on their behalf. PROs operating in Poland for batteries and WEEE include Rekopol, Eko-Punkt, and other approved organisations listed in the BDO system. The PRO manages the physical collection network, reports compliance data to GIOŚ, and ensures that producers meet annual collection and recycling targets set by the Ministry of Climate and Environment. Producers pay contributions to the PRO based on the weight and category of batteries placed on the Polish market. Producers may alternatively fulfil obligations individually — establishing their own collection system approved by the relevant authorities — but this is rarely the practical route for most companies due to the operational complexity involved.

EPR Registration in Poland

The registration process for battery producers in Poland is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Polish Act on Batteries and Accumulators.
2. Appoint a Polish-based authorised representative before initiating any registration — the BDO portal is in Polish only and foreign companies without a Polish presence must act through a representative. The representative must hold a PESEL number (not necessarily a Polish citizen).
3. Submit a BDO registration application through the BDO portal (bdo.mos.gov.pl), selecting the correct categories for batteries. Registration costs approximately 200 PLN per year for small companies and 800 PLN per year for larger entities.
4. Allow up to 30 days for the BDO authority to process the registration and issue a BDO number.
5. Receive the BDO number and include it on all invoices, receipts, contracts, and records related to batteries placed on the Polish market.
6. Join an approved PRO for batteries, concluding a contract for collection and recycling obligations.
7. Submit annual declarations of batteries placed on the Polish market through BDO and the PRO system.
8. Provide the BDO number to Amazon, Zalando, Kaufland, and other marketplaces where battery-containing products are sold in Poland.

Authorized Representative

Foreign companies without a Polish legal establishment must appoint a Polish-based authorised representative to manage BDO registration and EPR compliance. This is a mandatory legal requirement for WEEE and is extended to batteries under the EU Battery Regulation. The representative must hold a PESEL number — the Polish national identification number — but does not need to be a Polish citizen. The representative handles all BDO interactions, PRO contracting, annual declarations, and communication with GIOŚ on behalf of the foreign producer. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers must declare and report the following data annually through the BDO system:

• Total weight (kilograms) of batteries placed on the Polish market during the reporting year, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
• Battery chemistry type where relevant to compliance reporting
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, reported through the PRO to GIOŚ
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

Annual declarations must be submitted through the BDO system. The BDO number must appear on all waste transfer notes, invoices, and documents related to battery products throughout the year.

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been mandatory in Poland for many years. The EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 August 2025: EU Battery Regulation EPR obligations fully in force. Amazon deactivates non-compliant offers in Poland from this date.
• January 2026: Zalando activated battery EPR number verification for Poland — sellers without a valid BDO number have listings suspended.
• Annual (15 March): Annual report on batteries placed on the Polish market and waste batteries collected — submitted to GIOŚ through BDO. Confirm exact deadline with your PRO as this may vary.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. BDO number on documents The BDO number must appear on all invoices, receipts, contracts, and records related to battery products placed on the Polish market. This is a Polish-specific requirement — operating without displaying the BDO number is an independently actionable offence. Language requirements Consumer-facing information on batteries sold in Poland must be provided in Polish where required under Polish consumer protection law. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Poland.

EPR Eco Fees & Eco-Modulation

Polish battery PROs set contribution rates for their members based on the weight and category of batteries placed on the Polish market. Contributions are paid to the PRO and cover the costs of collection, transport, and recycling of waste batteries. Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all Member States. Poland's specific eco-modulation framework under the new Regulation has not been separately published as of May 2026. Specific fee schedules should be confirmed with the chosen PRO at the time of membership registration.

Risks, Penalties & Common Mistakes

1. Operating without a BDO number. Without BDO registration, it is not legally possible to trade batteries in Poland. Penalties range from 5,000 PLN to 1,000,000 PLN (approximately €1,000 to €250,000) for operating without registration. Amazon deactivates non-compliant battery offers from 18 August 2025.
2. Failing to display the BDO number on documents. The BDO number must appear on all invoices, receipts, contracts, and records. Failure to include it carries fines of 5,000 PLN to 1,000,000 PLN.
3. Not appointing a Polish authorised representative. Foreign companies without a Polish presence must appoint a representative with a PESEL number. The BDO portal is available in Polish only — attempting to navigate it without Polish-language support creates significant compliance risk.
4. Underestimating BDO processing time. Authorities have up to 30 days to process registration. Companies must not begin selling battery products in Poland until the BDO number is received. Starting the process early is essential.
5. Assuming one EU registration covers Poland. Battery EPR registration is national. Registration in another EU member state does not fulfil Polish obligations.
6. Treating battery BDO registration as the same as WEEE registration. Battery and WEEE registrations are separate categories within BDO. Each requires its own registration entry and number.
7. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Polish consumers.
2. Appoint a Polish-based authorised representative with a PESEL number before initiating any BDO registration.
3. Submit a BDO registration application at bdo.mos.gov.pl through your representative, selecting the correct battery categories. Pay the annual registration fee (~200 PLN for small companies, ~800 PLN for larger entities).
4. Allow up to 30 days for BDO processing — plan accordingly before product launch.
5. Receive your BDO number and include it on all invoices, receipts, contracts, and product-related documents.
6. Join an approved Polish PRO for batteries — such as Rekopol or Eko-Punkt — to fulfil collection and recycling obligations.
7. Submit the BDO number to Amazon, Zalando, and Kaufland for their EPR compliance verification systems.
8. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Polish-language consumer instructions as required.
9. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

• Is battery EPR mandatory in Poland?

Yes. Battery EPR has been mandatory in Poland for many years under the Act on Batteries and Accumulators. From 18 August 2025, the EU Battery Regulation (2023/1542) fully applies. All producers placing batteries on the Polish market must register in BDO, obtain a BDO number, join an approved PRO, and comply with collection and reporting obligations. Amazon deactivates non-compliant battery offers in Poland from this date.

• Do foreign brands selling online into Poland need to register?

Yes. Distance sellers and e-commerce operators are captured as producers under the EU Battery Regulation and Polish waste legislation. Foreign companies must appoint a Polish-based authorised representative with a PESEL number, register in BDO, and obtain a BDO number before placing batteries on the Polish market. Zalando activated Polish battery EPR number verification from January 2026.

• What is the BDO and why is it critical for Poland?

The BDO (bdo.mos.gov.pl) is Poland's national Product, Packaging and Waste Management Database — the central registration and reporting system for all EPR obligations including batteries. Without a BDO number, it is not legally possible to trade batteries in Poland. The BDO number must appear on all invoices, receipts, and commercial documents. The portal is available in Polish only, making authorised representative support essential for foreign companies.

• How long does BDO registration take?

Polish authorities have up to 30 days to process BDO registration applications and issue a BDO number. Companies must not begin selling battery products in Poland until registration is complete. Starting the process well in advance of planned market entry is strongly advised.

• Is there a minimum volume threshold for Polish battery EPR?

No. Poland applies a zero threshold — the BDO registration obligation applies from the very first battery placed on the Polish market, regardless of volume, weight, or turnover. All producers must register regardless of size.