Act on Packaging and Packaging Waste Management
Poland EPR — Act on Packaging and Packaging Waste Management. The regulatory authority is Marshal's Office, operating through the BDO Register system.
All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Poland market must register with a PRO and fulfill EPR obligations. Non-Poland sellers must appoint an Authorized Representative.
Poland operates a competitive market for packaging recovery organizations. Producers must register in the BDO register (Baza Danych o Odpadach — Waste Database) and either contract with a recovery organization or fulfill obligations individually. Major recovery organizations include:
Registration: BDO (rejestr-bdo.mos.gov.pl) — BDO number required
Reporting & Deadlines: Annual by March 15. Packaging data must be reported by material type and weight. Reports are submitted through BDO (Baza danych o odpadach).
Maximum Fine: PLN 500,000 (~€115,000). Non-compliance with Poland EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.
BDO number required for operating in Poland — Amazon requests it
If you sell on Amazon, eBay, or other marketplaces and ship products to Poland, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.
Follow these steps to become fully compliant with Poland's EPR packaging obligations. Non-Polish sellers should work with an Authorized Representative.
Create an account at bdo.mos.gov.pl — Poland's national database for products, packaging, and waste management (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). You will receive a BDO number, which is mandatory for all companies placing packaged goods on the Polish market. Non-Polish sellers need an Authorized Representative to complete this step.
Sign a contract with a licensed recovery organization such as Rekopol, EKO-PUNKT, or Biosystem. The PRO handles your packaging recovery and recycling obligations. This is a separate step from BDO registration — you need both. Costs depend on your packaging volumes and material types.
Submit quarterly reports of your packaging volumes through the BDO system, broken down by material type (paper, plastic, glass, metal, wood) and weight in kilograms. Your PRO will also need this data for their own reporting obligations.
Enter your BDO registration number in Amazon Seller Central (and other marketplace platforms) under the EPR compliance section. Amazon requires this number to verify your packaging compliance in Poland. Without it, your listings may be deactivated.
Submit your annual packaging report through the BDO system by March 15 each year. The report covers all packaging placed on the Polish market during the previous calendar year. Late or missing reports can trigger product fee charges and fines up to PLN 500,000.
The EU Packaging and Packaging Waste Regulation (PPWR) is a directly applicable regulation replacing the older Packaging Directive. Unlike a directive, it does not need transposition into Polish law — it applies automatically across all EU member states. Here is what sellers in Poland should prepare for:
If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.
What we deliver (15–18 documents):
✓ Full Technical Documentation (Annex VII, Module A)
✓ EU Declaration of Conformity (Annex VIII)
✓ Recyclability assessment of all packaging
✓ Substance restriction verification (PFAS, heavy metals)
✓ Recycled content declaration
✓ Packaging minimisation statement
✓ Labeling guidance (material codes, sorting pictograms, QR)
✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)
✓ EPR registration in target EU countries
✓ Authorised Representative appointment (Article 45)
BDO registration is mandatory for all companies placing packaged goods on the Polish market. Some sellers mistakenly believe a PRO contract alone is sufficient — it is not. You must have both a BDO number and a PRO contract.
BDO registration and a PRO contract are two separate obligations. BDO is the national database where you register your company. A PRO contract is a separate agreement with a recovery organization that handles your recycling obligations. Many sellers complete only one step and believe they are compliant.
Quarterly reporting in BDO is not optional. Even if your PRO handles recycling obligations, you are still required to submit quarterly packaging data in the BDO system. Missing these reports can result in fines and issues with your annual declaration.
Poland has 16 voivodeships, each with its own Marshal Office (Urząd Marszałkowski) that administers BDO registrations and oversees EPR compliance. Your registration must be submitted to the Marshal Office in the voivodeship where your company or Authorized Representative is located.
If you do not meet the required recycling and recovery targets, you must pay a product fee (opłata produktowa) to the Marshal Office. This is a separate obligation from your PRO fees. Many sellers are unaware of this requirement until they receive a demand for payment.
BDO (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami) is Poland's mandatory national database for tracking products, packaging, and waste management. Every company that places packaged goods on the Polish market must register in BDO and receive a BDO number. This is separate from and in addition to any PRO contract.
Yes, Poland operates a competitive market for recovery organizations. Major PROs include Rekopol (the dominant organization), EKO-PUNKT (Interseroh), and Biosystem. You can select the one that best fits your needs. Costs depend on your packaging volumes and material types — contact us for a quote tailored to your business.
BDO registration typically takes 2-4 weeks from submission. PRO contract setup can be completed within a few days once BDO registration is confirmed. The total process usually takes 3-6 weeks. Non-Polish sellers who need an Authorized Representative should allow additional time for appointment formalities.
The product fee is a charge levied when producers fail to meet the required recycling and recovery targets for packaging. The fee amount depends on the shortfall in recycled volume and the specific material types. It is paid to the Marshal Office and is separate from any PRO contract fees.
Yes, if your company is not established in Poland, you must appoint an Authorized Representative (AR) located in Poland. The AR handles your BDO registration, PRO contract, quarterly and annual reporting, and communication with the Marshal Office on your behalf. ekoniq provides AR services across all EU countries.
If Amazon cannot verify your BDO number or finds your EPR compliance documentation incomplete, your product listings for the Polish market may be deactivated. Amazon can independently check the public BDO register. Ensure your BDO number is active and correctly entered in Seller Central.
Costs depend on your packaging volumes, material types, and whether you need an Authorized Representative. BDO registration itself is free. PRO contract fees vary by organization and are based on the weight and type of packaging materials you place on the market. Contact us for a personalized quote.
Complete overview of EPR requirements in every EU member state for online sellers.
Key changes in the EU Packaging and Packaging Waste Regulation and how they affect your business.
Step-by-step tutorial for uploading your EPR registration numbers to Amazon Seller Central.
How to register with LUCID and comply with Germany's VerpackG packaging law.
ekoniq handles your complete EPR registration and compliance. We take care of registration, reporting, and ongoing obligations so you can focus on selling.
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