BDO and EPR in Poland: What Every Company Selling on the Polish Market Must Know

If your company ships products to Polish consumers through your own online store, Allegro, Amazon, or any other e-commerce channel you are most likely required to register in the BDO system.

Failure to register means a risk of a fine of up to 1,000,000 PLN and immediate blocking of your account on sales platforms. This article explains from scratch what BDO is, who it applies to, and exactly what you need to do before you send your first package to Poland.

What is BDO?

BDO (Baza Danych o Produktach i Opakowaniach oraz o Gospodarce Odpadami, i.e. the Database of Products, Packaging and Waste Management) is a nationwide electronic registry maintained by the Marshal of the Voivodeship competent for the registered seat of the entrepreneur, and managed by the Ministry of Climate and Environment. The system has been operational since 2018.

BDO serves three functions: it is a registry of entities, a reporting tool, and proof of lawful operation. Importantly for foreign companies: in 2026, BDO is strictly integrated with marketplace platforms (Allegro, Amazon).

What is EPR and How Does It Relate to BDO?

EPR (Extended Producer Responsibility) is a legal principle imposing on the producer or importer responsibility for the product throughout its entire life cycle. In Poland, EPR is implemented through BDO, which is why the BDO number = EPR number for the Polish market.

Note: EPR is a country-specific system. Selling to Germany requires registration in LUCID, to the Czech Republic in ISOH/ISPOP, to France in the UIN ADEME registry. The Polish BDO does not substitute registration in other EU countries.

Who is Required to Register in BDO?

The obligation applies to every company placing the following on the Polish market:

  • products in packaging (primary, secondary, transport packaging)
  • electrical and electronic equipment (WEEE)
  • batteries or accumulators
  • single-use plastic products (SUP)
  • tyres, lubricating oils, vehicles

Key fact: the obligation does not depend on the country of incorporation or the volume of sales. There is no de minimis threshold exempting from registration. The obligation arises from the very first sale to a Polish consumer.

How to Register in BDO as a Foreign Company?

Company with a Branch Office in Poland

Submit the application electronically via bdo.mos.gov.pl to the Marshal Office competent for the seat of the branch. A Trusted Profile (Profil Zaufany) or qualified electronic signature is required.

Company Without a Branch Office in Poland

The competent authority is the Marshal of the Masovian Voivodeship in Warsaw. This centralises the processing of all foreign company applications in one office. The application must be submitted in paper form (printed, signed). To use the BDO system electronically after receiving the entry, a PESEL number is required. If you do not have one, you may appoint a proxy (pełnomocnik) acting on your behalf.

Registration and Annual Fees: 2025/2026 Rates

The rates apply from 1 January 2025 pursuant to the Regulation of the Minister of Climate and Environment (Journal of Laws 2024, item 1901):

  • Micro-entrepreneurs: 200 PLN
  • Other entities: 800 PLN
  • Annual fee deadline: by the end of February each year
  • Important: in the year of initial registration, only the registration fee is paid. There is no double payment.

Consequences of Failure to Register

  • Administrative fine of 5,000 to 1,000,000 PLN (WIOS)
  • Risk of arrest or court-imposed financial penalty
  • Immediate blocking of listings on Allegro and Amazon without warning
  • Inability to cooperate with Polish recovery organisations

How Can EKOKONSULT Help Your Business?

EKOKONSULT provides a comprehensive BDO onboarding service designed to guide foreign business enterprises through every phase of the Polish environmental registration process. Our specialist team conducts structural audits to verify your exact legal obligations and compiles all necessary registration documentation. Furthermore, we act as your official legal representative before the competent Polish administrative authorities. Contact our expert team today to verify if your current e-commerce operations fall under the scope of mandatory Polish environmental laws.

Frequently Asked Questions (FAQ)

Does BDO apply to companies selling through their own online store?
Yes. Every company selling packaged products to Polish consumers is treated as a market introducer and must be registered in BDO. It does not matter whether you sell via a marketplace, your own store, or ship directly from a warehouse abroad.
Do I need to travel to Poland in person to register in BDO?
No. Foreign companies may appoint a proxy. EKOKONSULT offers this service. The entire process can be carried out remotely by sending documents electronically.
How long does BDO registration take for a foreign company?
The Marshal Office of the Masovian Voivodeship has 30 days to process the application. With a paper application, this may take longer. We recommend submitting the application at least 6 to 8 weeks before your planned launch of sales.
Does holding a Polish VAT number exempt a company from BDO registration?
No. BDO and VAT are two independent legal systems. VAT registration does not substitute BDO registration.