EPR Obligations EU → 🇵🇱 Poland
EPR in Poland 2026: BDO Number for Packaging, WEEE & Batteries
Who needs a BDO number, how foreign sellers get registered with the marshal's office, what the PPWR changed in 2026 and what fines apply.
Last reviewed: · Sources linked below
Short answer: if you place packaged goods, electrical or electronic equipment (EEE) or batteries on the Polish market, you generally need an entry in the BDO register and the BDO number that comes with it. The entry is made by the voivodeship marshal's office (Urząd Marszałkowski) and must be in place before you start. Foreign sellers may need a BDO entry even without a Polish branch — and operating without one can cost PLN 1,000 to PLN 1,000,000.
At a glance
- Packaging register / scheme
- BDO register (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami); entry by the marshal's office. Packaging recovery organisations (organizacje odzysku) are themselves a registered category in BDO.
- Authorised representative
- Packaging: required under PPWR Art. 45 for EU and non-EU distance sellers to Polish end users. WEEE: not clearly settled for distance sellers — check case by case.
- WEEE
- BDO entry as a company placing EEE on the Polish market.
- Batteries
- BDO entry as a company placing batteries on the market; EU Battery Regulation EPR regime since 18 Aug 2025.
- Thresholds
- BDO entry is tied to the activity, not to a volume: apply before the regulated activity starts; report changes within 30 days.
- Penalties
- PLN 1,000–1,000,000 administrative fine for registrable activity without a BDO entry (Waste Act art. 194(1)(5a)).
- Marketplace checks
- Amazon names Poland in its EU packaging EPR notice (from 12 Aug 2026); eBay may hide listings without a valid number.
- What changed in 2026
- PPWR applies since 12 Aug 2026. Packaging reform bill UC100 (v4.0, 17 Aug 2026) Proposal – not yet law
What is the BDO register?
BDO is Poland's electronic database on products, packaging and waste management. It is the single register in which companies that place packaging, packaged products, electrical and electronic equipment, batteries and accumulators or vehicles on the Polish market are entered — together with waste transporters, recyclers, recovery organisations and other waste-sector businesses. After the entry, the company receives its BDO registration number, which business partners and marketplaces use to check that you are registered.
Entries are made by the marshal of the voivodeship (provincial marshal's office). The register is kept electronically, and the marshal can also make entries ex officio.
What changed in 2026
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in Poland and every other member state since 12 August 2026. It entered into force on 11 February 2025 and replaced most of the old Packaging Directive 94/62/EC, which was generally repealed on 12 August 2026 (some provisions continue). National registers and schemes still exist — the PPWR sits on top of them. Read the full overview on our PPWR 2026 page.
- Authorised representative (Art. 45): producers that sell packaged products directly to end users in another member state — whether established in the EU or outside it — must appoint an authorised representative in each member state where they first make packaging available, other than their own. For other non-EU producers, member states may require one.
- Pragmatic enforcement: the European Commission has asked member states to enforce the authorised-representative duty in a "constructive and pragmatic" way while an exemption is being negotiated.
- Penalties: member states must lay down their PPWR penalty rules by 12 February 2027 (Art. 68).
- Fees and labels: EU-harmonised fee modulation by recyclability grade is expected from around 2028–2030; harmonised packaging labelling applies from 12 August 2028 or 24 months after the implementing acts, which had not been adopted as of September 2026.
Proposal – not yet law EU omnibus and the AR exemption. The Environmental Omnibus (COM(2025) 982, 10 December 2025) proposes suspending the authorised-representative duty for EU-established producers. The European Parliament adopted its position on 20 October 2026 (exemption for EU micro and small enterprises until 2035, as reported). The Council agreed its negotiating position on 21 October 2026: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need an authorised representative there, until 2032. Trilogue negotiations follow. This is not law yet, and it does not cover sellers established outside the EU.
Poland: packaging EPR reform bill UC100
Proposal – not yet law Poland's government is preparing a new act on packaging and packaging waste (bill UC100; version 4.0 dated 17 August 2026). The draft would make the National Fund for Environmental Protection and Water Management (NFOŚiGW) the central body of the system, introduce a fee per kilogram of packaging and move to quarterly fee payments. The bill has not been adopted; until it is, the current BDO-based rules continue to apply. We will update this page when the act is passed.
Packaging obligations in Poland
A packaging producer in Poland is any business that places packaging or packaged products on the Polish market — for example a manufacturer, an importer, a company bringing goods in from another EU country, or a distance seller shipping packaged goods to Polish customers. Under the PPWR, a seller who ships directly to end users in Poland is treated as the producer in Poland for that packaging.
- Check your activity. Do you ship packaged goods to Polish customers, import into Poland or store stock in Polish warehouses (for example in marketplace fulfilment networks)? Each of these can be relevant for whether your activity is registrable.
- Apply for the BDO entry at the competent marshal's office before you start the activity. Expect the procedure to run in Polish.
- Organise recovery and recycling. Producers typically work with a packaging recovery organisation (organizacja odzysku opakowań), which is itself registered in BDO.
- Report and keep data current. Reports on packaging placed on the market are submitted electronically through BDO; changes to your registered data must be reported within 30 days. We confirm the current forms and dates for your case.
- Appoint an authorised representative if you sell directly to Polish end users from another member state or from outside the EU (PPWR Art. 45).
If you also sell into Germany, note that LUCID registration there is separate — see our Germany guide and the LUCID registration guide on register-epr.com.
WEEE obligations in Poland
Companies that place electrical and electronic equipment on the Polish market also need a BDO entry, declaring the EEE activity. Collection and treatment of the resulting waste equipment is financed by the producers, in practice usually through a specialised organisation.
Distance sellers and representatives: whether a foreign seller shipping EEE directly to Polish consumers must appoint a Polish authorised representative for WEEE is not clearly settled in the sources we reviewed. We check the current practice for your case in the free obligation check.
Battery obligations in Poland
Companies that place batteries or accumulators on the Polish market need a BDO entry for this activity. If your devices contain batteries, we check how they are covered in the free obligation check.
On top of national rules, the EU Battery Regulation (EU) 2023/1542 has applied its extended producer responsibility regime since 18 August 2025. Further steps are scheduled from 18 February 2027: a QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh. Battery due-diligence obligations have been postponed to 18 August 2027 (Regulation (EU) 2025/1561).
Proposal – not yet law The EU omnibus would also suspend the authorised-representative duty for batteries (European Parliament vote on 20 October 2026; Council position pending).
Authorised representative in Poland
An authorised representative (AR) is a Poland-established person or company that fulfils the producer's EPR obligations in Poland on the producer's behalf. For packaging, the PPWR makes an AR mandatory for producers that sell packaged products directly to end users in Poland from another member state or from outside the EU. For other non-EU producers, member states may require one.
The AR handles the Polish-language registration, communication with the marshal's office and recurring reporting, while you keep selling. The proposed EU exemption for small EU-established producers is not law yet and would not help sellers established outside the EU. More background: authorised representative explained on register-epr.com. The answer by product stream, including the mandatory representative for electrical equipment: authorized representative in Poland.
How Certify helps
- Free obligation check. Tell us what you sell into Poland, through which channels (Amazon, eBay, your own shop) and roughly in what volumes. We map which registers, schemes and representative duties apply to you.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorised 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.
Deadlines for Poland and the EU
Poland has no single annual registration deadline: the BDO entry must exist before you start, and changes must be reported within 30 days. The EU dates below apply to every seller. Full calendar: EPR deadlines.
| Date | Scope | What happens |
|---|---|---|
| Before first sale | Poland | BDO entry in place before the regulated activity starts |
| Within 30 days | Poland | Report changes to registered data or activities in BDO |
| 12 Aug 2026 | EU | PPWR applies; authorised-representative duty for distance sellers (Art. 45) |
| 20–21 Oct 2026 | EU | Parliament (20 Oct) and Council (21 Oct) positions on the AR exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | EU | Member states must have PPWR penalty rules in place |
| 18 Feb 2027 | EU batteries | QR code on all batteries, removability rules, battery passport (EV, LMT, industrial >2 kWh) |
| 18 Aug 2027 | EU batteries | Battery due-diligence obligations start (postponed) |
| 12 Aug 2028 | EU | Harmonised packaging labelling (or 24 months after implementing acts) |
| Pending | Poland | Packaging reform bill UC100 (version 4.0, 17 Aug 2026) Proposal – not yet law |
Penalties for missing BDO registration
Carrying out a registrable activity without a BDO entry can be fined with PLN 1,000 to PLN 1,000,000 (article 194(1)(5a) of the Polish Waste Act, as summarised by Rödl & Partner). The amount within that range depends on the case.
Beyond fines, the practical risk for online sellers is the marketplace: without a valid number, listings may be stopped or hidden.
Marketplaces check EPR numbers. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named Poland among the countries concerned; Amazon "may need to stop selling your non-compliant products". eBay requires packaging EPR numbers from 12 August 2026 for each country in which the seller is a producer, and listings may be hidden from buyers in that country. See also our sister site's guide to the Amazon EPR number.
FAQ: EPR in Poland
What is a BDO number in Poland?
A BDO number is the registration number a company receives when the competent marshal's office enters it in Poland's BDO register (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). The register covers, among others, companies that place packaging, packaged products, electrical and electronic equipment or batteries on the Polish market.
Do foreign sellers need a BDO number?
Often, yes. Foreign businesses may need a BDO entry even without a Polish branch if they place regulated products on the Polish market, for example by importing goods or by shipping packaged products to Polish customers. Whether a specific activity is registrable is assessed case by case, so check before your first sale.
Who issues the BDO entry and when do I need it?
The entry is made by the competent voivodeship marshal's office (Urząd Marszałkowski). The register is kept electronically. You must apply before the regulated activity starts, and changes to your registered data or activities must be reported within 30 days.
What is the fine for selling in Poland without BDO registration?
Carrying out a registrable activity without a BDO entry can lead to an administrative fine of PLN 1,000 to PLN 1,000,000 under article 194(1)(5a) of the Polish Waste Act. In addition, marketplaces may stop selling or hide non-compliant products.
Do I need an authorised representative in Poland?
For packaging, the EU Packaging Regulation (PPWR) requires producers that sell packaged products directly to end users in Poland from another member state or from outside the EU to appoint an authorised representative in Poland. The proposed EU exemption for small EU-established producers is not law yet and would not cover non-EU sellers. For electrical equipment, whether distance sellers must appoint a Polish representative is not clearly settled, so it should be checked for your case.
Is Poland reforming its packaging EPR system?
A reform is being prepared. Bill UC100 (version 4.0 dated 17 August 2026) would make the National Fund for Environmental Protection and Water Management (NFOŚiGW) the central body and introduce a fee per kilogram of packaging with quarterly payments. It is a proposal and has not been adopted.
- Rödl & Partner: The BDO register – obligations and penalties
- BDO register portal (Ministry of Climate and Environment)
- Gov.pl: Draft act on packaging and packaging waste (UC100)
- Regulation (EU) 2025/40 (PPWR) on EUR-Lex
- European Commission: EPR for packaging and small businesses
- Council of the EU press release, 21 October 2026
- Amazon Global Selling notice, 25 March 2026
This page is general information, not legal advice. Last reviewed 27 October 2026.
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