Authorized Representative Poland 2026: Who Needs One?

Short answer: if you are established outside Poland — in another EU member state or outside the EU — and sell electrical or electronic equipment at a distance directly to Polish households or other users, you must appoint an authorized representative (autoryzowany przedstawiciel) established in Poland. That is Art. 26(2) of the Polish WEEE Act. For packaging, Art. 45 of the EU Packaging Regulation has applied directly since 12 August 2026, but Poland has not yet adopted its national law, so the practical route is not settled.

Authorized representative in Poland at a glance

Electrical equipment: Mandatory under Art. 26(2) of the Act of 11 September 2015 on waste electrical and electronic equipment: producers established in another member state or outside the EU that sell equipment by distance communication directly to households or other users in Poland.
Other foreign producers of equipment: A right, not a duty: producers from other member states that do not sell at a distance to users may appoint a representative (Art. 26(1)).
Form: Written contract; without written form it is void (Art. 26(3)).
Who can act: A natural person, legal person or organisation established in Poland, including a recovery organisation for electrical and electronic equipment (Art. 26(4)).
Minimum quantity: None, and no exemption for micro or small enterprises, according to Interzero Poland.
Packaging: Art. 45 PPWR applies directly since 12 August 2026. Poland's implementing law (draft UC100) has not been adopted. Proposal – not yet law
Batteries: EU Battery Regulation, Art. 56(3), according to law-firm analysis. In practice: according to Interzero Poland (page status April 2026), a representative for packaging and batteries could not yet be appointed.
Register: BDO — one register for packaging, electrical equipment and batteries; entries by the marshal's office of the voivodeship.

Do I need one?
Electrical equipment
Packaging and batteries
Why Poland asks for it
Without a representative
Proposed exemption
Dates
How Certify helps
FAQ

Do I need an authorized representative in Poland?

It depends on the product — and Poland is the country where the three answers differ most.

Your situation	What applies in Poland
Company established in Poland	No representative. You register in BDO yourself.
Company in another EU member state selling electrical equipment at a distance directly to Polish households or other users	Representative mandatory (Art. 26(2) WEEE Act).
Company outside the EU (for example US, UK, China) selling electrical equipment at a distance directly to Polish users	Representative mandatory — the statute covers producers established in a non-member state as well.
Producer in another member state supplying equipment to Polish distributors, no distance sales to users	Voluntary: you have the right to appoint a representative (Art. 26(1)).
You ship packaged goods directly to Polish end users from abroad	Art. 45 PPWR requires a representative. Poland's national rules for it are pending — we check the current practice for your case.
Your products contain or are batteries	EU Battery Regulation: representative for distance sellers. National implementation pending; check case by case.

Not sure which row is yours? Ask for a free check.

Electrical equipment: what Art. 26 of the Polish WEEE Act says

The Polish Act of 11 September 2015 on waste electrical and electronic equipment separates two groups of foreign producers: one may appoint a representative, the other must.

Point	Rule
Who must appoint	A producer established in another member state or in a non-member state that sells equipment in Poland by means of distance communication directly to households or to users other than households (Art. 26(2) with Art. 4(11)(d)).
Who may appoint	Producers established in another member state that fall under Art. 4(11)(a)–(c) — for example manufacturers that supply equipment for distribution (Art. 26(1)).
Form	Contract in writing; otherwise the appointment is void (Art. 26(3)).
Who can be the representative	A natural person, an organisation or a legal person established in Poland, including a recovery organisation for electrical and electronic equipment (Art. 26(4)).
Effect	Once appointed, the producer acts only through the representative. The representative acts in the producer's name and on its behalf and is responsible for the duties the Act places on a company introducing equipment to the Polish market (Art. 26(9)).

According to Interzero Poland, there is no minimum quantity and no exemption for micro or small enterprises: the duty starts with the first device sold at a distance to a Polish household. The representative should be in place before sales to Poland begin.

Packaging and batteries: the EU duty applies, the Polish route is not settled

For packaging and batteries we cannot give you the same clear answer as for electrical equipment — and we would rather say so than guess.

What is settled: Art. 45 of the EU Packaging Regulation (PPWR) has applied directly in Poland since 12 August 2026. Producers — EU or non-EU — that sell packaged products directly to end users in Poland from another country have to appoint a representative there. The EU Battery Regulation has applied its EPR regime since 18 August 2025.
What is not settled: Poland has not yet adopted the national law that would organise this. The packaging reform bill (draft UC100, latest version of 28 August 2026) is still under government review, and its start dates are expected to change. Proposal – not yet law
What practice looked like: Interzero Poland, a Polish recovery organisation, states on its website (page status April 2026) that foreign producers of packaging and batteries could not yet appoint an authorized representative in Poland because national implementation was missing.

What does not change: the BDO register covers packaging, electrical equipment and batteries, and foreign entities may need a BDO entry even without a Polish branch. We check the current practice for your case.

Register, reporting and fines in full: EPR in Poland.

Why Poland asks for a representative

Polish EPR is administered through the BDO register and the marshal's offices of the voivodeships. A company that sells into Poland from abroad at a distance has no seat there. The WEEE Act therefore makes the representative the responsible party: it must be established in Poland, and it answers for the duties that would otherwise fall on a company introducing equipment to the Polish market.

The rule mirrors EU law. Under Art. 17 of the WEEE Directive, every member state must make sure that its own distance sellers appoint a representative in the member state they sell into. Poland applies the same duty to sellers from non-member states.

What happens without a representative

Failing to appoint a representative where Art. 26(2) requires one is subject to an administrative fine under the WEEE Act (Art. 91). We do not quote an amount for it here because we have not verified the figure against the statute.

What is documented: carrying out an activity that requires a BDO entry without that entry can be fined between PLN 1,000 and PLN 1,000,000 (Waste Act, Art. 194(1)(5a)).

Marketplaces check as well. In its notice of 25 March 2026, Amazon named Poland among the countries where it checks packaging EPR compliance from 12 August 2026 and said it "may need to stop selling your non-compliant products". eBay may hide listings from buyers in a country for which the seller has no packaging EPR number.

Would the proposed EU exemption help?

Only small producers established in the EU, only for packaging — and only once it is law. It would not change the representative duty for electrical equipment under the Polish WEEE Act.

Proposal – not yet law EU exemption for small EU-established producers. The European Commission's Environmental Omnibus of 10 December 2025 proposes suspending the authorized-representative duty for producers established in the EU. The European Parliament adopted its position on 20 October 2026 (as reported: an exemption for EU micro and small enterprises until 2035). The Council's negotiating mandate of 21 October 2026 covers packaging only: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need a representative there until 1 January 2032. It does not cover batteries. Trilogue negotiations follow. None of this is law yet, and none of it helps sellers established outside the EU — until a final text is adopted, the current duty applies.

Dates that matter for Poland

Date	What applies
1 Jan 2016	WEEE Act in force: representative duty for foreign distance sellers of electrical equipment
Before sales to Poland begin	Appoint the representative for electrical equipment
18 Aug 2025	EU Battery Regulation: EPR regime applies
12 Aug 2026	PPWR applies: authorized representative for packaging distance sellers (Art. 45)
12 Feb 2027	Member states must have PPWR penalty rules in place
Pending	Polish packaging reform (draft UC100) Proposal – not yet law

Full calendar: EPR deadlines 2026–2027.

How Certify helps

Free obligation check. Tell us what you sell into Poland, through which channels (Amazon, eBay, your own shop) and where your company is established. We tell you which representative duties apply to you — and which do not.
Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorized representative. Certify offers an authorized representative in all EU member states.
Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.

This page explains the obligation. If you already know that you need a representative, the practical steps are on our sister site: appointing an EPR authorized representative (register-epr.com).

Start the free obligation check

FAQ: authorized representative in Poland

Do foreign online sellers need an authorized representative in Poland?

For electrical and electronic equipment, yes. Under Art. 26(2) of the Polish WEEE Act, a producer established in another member state or outside the EU that sells equipment at a distance directly to households or other users in Poland must appoint an authorized representative established in Poland.

Does the Polish duty also apply to sellers from outside the EU?

Yes. The WEEE Act covers producers established in another member state and producers established in a non-member state that sell equipment at a distance directly to users in Poland.

Is there a minimum quantity or an exemption for small businesses?

According to Interzero Poland, no. The Polish rules provide neither a quantity threshold nor an exemption for micro or small enterprises: the duty starts with the first device sold at a distance to a Polish household.

I only supply Polish distributors. Do I need a representative?

Not necessarily. Producers from other member states that do not sell at a distance directly to users have the right, but not the duty, to appoint an authorized representative under Art. 26(1) of the WEEE Act.

Do I need an authorized representative for packaging in Poland?

Under Art. 45 of the EU Packaging Regulation, producers that sell packaged products directly to end users in Poland from another country need one since 12 August 2026. Poland has not yet adopted its national implementing law, so the practical route is not settled and has to be checked case by case.

What is the BDO register?

BDO is Poland's national register for products, packaging and waste management. It covers packaging, electrical equipment and batteries; entries are made by the marshal's office of the voivodeship.

Sources (official and legal references)

This page is general information, not legal advice. Last reviewed 5 November 2026.

Related guides

Representative rules differ from country to country and from product to product:

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Authorized Representative in Poland 2026:Who Needs One and Why