Entering the Polish Market? A Complete Environmental Compliance Guide for Foreign Companies (2026)

Poland is the sixth largest economy in the EU and one of the fastest growing e-commerce markets in Central Europe. The year 2026 is a turning point: the PPWR deadlines, the new battery law, and SUP all converge. Environmental compliance is today a condition of selling, not a formality. This article is a step-by-step checklist for every foreign company entering the Polish market.

Sales Model and the Scope of Obligations: B2C vs B2B

B2C Model: Sales to Polish Consumers

In the B2C model, a foreign seller is generally treated as an entity placing products on the Polish market. The seller reports all categories: packaging, WEEE, batteries, SUP. In B2C e-commerce, an AR for WEEE and batteries is also mandatory.

B2B Model: Sales to Polish Companies

In B2B relationships the situation is more flexible. Under the Act on Packaging Management, the introducing entity is the one that carries out an intra-Community acquisition of goods (WNT). If a Polish company buys goods from a foreign supplier for further resale, the Polish company generally assumes the role of introducer and reports packaging in its own BDO. The foreign company may then be exempt from some obligations. An exception applies to WEEE equipment, where the foreign producer may appoint an AR, relieving the Polish distributor of the burden.

Checkpoint 1: BDO: Basic Registration

  • What: entry in the BDO Registry
  • Who must: every company without exception, from the first sale to a Polish consumer
  • When: before the first sale
  • Where: Marshal of the Masovian Voivodeship (companies without a branch office in Poland)
  • Time: up to 30 days (realistically 6 to 8 weeks for foreign companies)
  • Annual cost: 200 PLN (micro-enterprises) or 800 PLN
  • The BDO number must appear on documents drawn up in connection with the activity covered by the entry, including invoices.

Checkpoint 2: Packaging EPR

  • Scope: primary, secondary, and transport packaging (cartons, foils, tapes, filling materials)
  • Educational campaigns: 2% of the net value of packaging introduced (Article 19 of the Packaging Management Act)
  • Report: by 15 March
  • AR from 12 August 2026: PPWR expands the role of the Authorised Representative (AR) for foreign entities supplying packaging or packaged products to the EU market. In practice, many companies selling to Poland will be required to appoint an AR in accordance with national EPR rules.
  • PPWR limit: maximum 50% empty space in shipping packaging, with technical exceptions.

Checkpoint 3: WEEE (if applicable)

  • Scope: household appliances, electronics, IT, lighting, power tools, telecommunications
  • AR: mandatory for every foreign B2C e-commerce seller (Article 26 of the WEEE Act)
  • Collection level: minimum 65% from 2021
  • Report: by 15 March

Checkpoint 4: Batteries (if applicable)

  • Scope: portable, industrial, automotive batteries, products with built-in batteries
  • AR: mandatory from 18 August 2025
  • New 2026 requirements (EU 2023/1542): labelling, battery replaceability, due diligence for companies with turnover exceeding 40 million EUR
  • Collection target: 63% by 31 December 2027 (73% by 2030). Intensify collection now.

Checkpoint 5: SUP: Single-Use Plastics

  • Applies to: disposable plastic cups, food containers, wet wipes, tobacco products with filters
  • Fees: 0.20 PLN per item (cups), 0.25 PLN per item (containers), collected from the customer
  • BDO registration: mandatory; no registration = fine of up to 1,000,000 PLN
  • Failure to collect the fee: administrative fine of up to 20,000 PLN

Checkpoint 6: Deposit-Refund System (if applicable)

  • Applies to: beverages in PET bottles (0.1 to 3 litres), aluminium cans, returnable glass bottles
  • Obligation: participation through a deposit-refund system operator
  • Fine for non-participation: up to 3 PLN per kg of packaging; for failure to achieve collection levels: 1 PLN per kg

Checkpoint 7: KOBiZE (only if you have assets in Poland)

KOBiZE (National Centre for Emissions Management) is a separate emissions registry, independent of BDO. The reporting obligation applies exclusively to companies that have in Poland:

  • a vehicle fleet billed under a Polish NIP tax number
  • an office, warehouse, or retail outlet with its own boiler or air conditioning

If a foreign company conducts exclusively mail-order sales without an office or fleet in Poland, it is not subject to the KOBiZE obligation. Report deadline: end of February each year.

Important: do not register in KOBiZE as a precaution

Foreign companies often register in KOBiZE “out of caution”. This is a mistake: if you do not have a fleet or installation in Poland, registration is unnecessary and may generate unwanted reporting obligations.

Checklist: What to Do Before the First Shipment

Checklist: entering the Polish market

  1. BDO: application submitted, BDO number entered in the Allegro/Amazon panel and on invoices
  2. Packaging: mass records, recovery organisation or self-compliance, educational campaigns (min. 2%)
  3. WEEE (if applicable): BDO registration Division VI, contract with recovery organisation, AR appointed
  4. Batteries (if applicable): BDO registration, AR appointed (from 18 August 2025), new labels
  5. SUP (if applicable): BDO registration in the SUP category, collecting fees of 0.20/0.25 PLN
  6. Deposit-refund system (if applicable): contract with system operator
  7. Calendar: 15 March (BDO report), end of February (annual BDO fee, KOBiZE if applicable)

How Can EKOKONSULT Help Your Business?

EKOKONSULT provides professional, end-to-end environmental compliance management for international enterprises expanding into the Polish market. We conduct free initial compliance audits to determine your exact obligations across all EPR streams, handle your entire electronic BDO registration, manage your SUP accounting, and compile your annual reports before the statutory deadlines.

With over eighteen years of specialized industry experience, our English-speaking consultants actively support foreign enterprises in navigating the complex Polish regulatory framework and establishing compliant contracts with local recovery organizations. Contact our specialist team today to schedule your complimentary initial consultation.

Frequently Asked Questions (FAQ)

Where to start?
A free verification of obligations with an expert, to establish which EPR categories (packaging, WEEE, batteries, SUP) apply to your products. Then BDO registration, AR appointment if required, and entering the number on the platforms.
Do I need to set up a Polish company to sell to Poland?
No. A foreign company sells to Polish customers without a Polish entity. You must fulfil environmental obligations (BDO, EPR, AR) and possibly tax obligations (VAT OSS or Polish VAT registration).
How long does it take to fully arrange compliance?
BDO registration: 6 to 8 weeks for foreign companies. Joining a recovery organisation: a few days. AR appointment: contract negotiation time. The entire process when managed efficiently: 4 to 8 weeks.
Does a foreign company without an office in Poland need to report to KOBiZE?
No, if the company does not have a vehicle fleet or heating installations in Poland. Mail-order sales through external couriers do not generate a KOBiZE obligation.
What does the PPWR change for companies shipping products to Poland from 2026?
From 12 August 2026: obligation to have an AR (even for companies from the EU), 50% empty space limit in packaging, new reporting requirements. It is worth adapting packaging and logistics processes before this date.