Anyone who places packaging, electrical appliances, or batteries on the Polish market is subject to extended producer responsibility (EPR). The central platform is the BDO system (Baza Danych o Produktach i Opakowaniach oraz o Gospodarce Odpadami).
What makes it unique is that, as a central point of contact, it consolidates EPR compliance for various product categories.
These include:
1. Packaging
- Scope: Household, commercial, industrial, shipping, and e-commerce packaging.
- Obligations: BDO registration, annual volume reporting, and financing of recycling.
- New as of 2026: Direct connection to the Polish deposit system (System Kaucyjny) for single-use plastic bottles, metal cans, and reusable glass containers.
2. Batteries and Rechargeable Batteries
- Scope: Loose batteries and built-in rechargeable batteries in electronic devices.
- Categorization: Strict separation into device, industrial, and automotive batteries.
- Obligations: Registration, proper labeling (e.g., the trash can symbol), annual reporting, and physical take-back.
3. Electrical and Electronic Equipment
- Scope: From small household appliances to industrial machinery.
- Obligations: Classification by category, compliance with labeling requirements, annual reporting, and financing the take-back of end-of-life equipment.
The Path to EPR Compliance in Poland
Registration on the BDO Government Portal:
Before making your first shipment to the Polish market, you must register your company in the BDO registry. After a successful review, you will receive a unique identification number, which serves as the basis for all further legal steps.
Contractual Arrangements for Recycling Quotas:
As an importer or manufacturer, you are responsible for the entire life cycle of your products. In Poland, you typically organize take-back and recycling through mandatory membership in an authorized national recycling organization.
Annual Data Reporting and Fee Processing:
All quantities and material types placed on the market in Poland must be fully documented and reported digitally once a year via the BDO system. In addition, registration administration fees and material-flow-based recycling fees apply.
Legally compliant labeling on business documents:
Upon receipt of the BDO number, a strict labeling requirement takes effect. You are required to include this number on invoices, delivery slips, and shipping documents.
Important note: The BDO number alone does not guarantee legal certainty. Full compliance requires the ongoing combination of document labeling, active recycling agreements, and timely volume reports.
All details and a step-by-step overview for packaging, WEEE, and batteries can be found in our EPR Poland Guide: Poland Guide
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