Packaging and EPR in Poland: A Complete Guide for Online Stores and Importers

Every company placing packaged products on the Polish market may be subject to obligations arising from the Extended Producer Responsibility (EPR/ROP) system. The obligation to register in BDO generally arises before commencing activities related to placing packaged products on the Polish market without any quantity threshold. The year 2026 brings key changes: the entry into force of the PPWR regulation and new requirements regarding the Authorised Representative.

What is Packaging under EPR Law?

The definition is broader than most sellers intuitively expect. Packaging covered by EPR includes:

  • Primary packaging: the direct product packaging: carton, bottle, foil, jar
  • Secondary packaging: packaging grouping several products together
  • Transport packaging: shipping cartons, pallets, stretch foils, bubble mailers, adhesive tapes, filling materials (polystyrene, paper, air cushions)

Materials Covered by the EPR System

  • plastics (PE foil, PET, PS, PP)
  • paper and cardboard (cartons, wrapping paper, envelopes)
  • glass
  • metals (aluminium, steel)
  • wood (pallets, crates)
  • multi-material packaging (combining several raw materials)

Who is a “Producer” Under Packaging Law?

Under the EPR/ROP system, the concept of “producer” does not refer exclusively to the manufacturer of packaging. The producer is defined as the entity that first places packaging or packaged products on the Polish market.

This applies to:

  • importers bringing products from abroad for sale in Poland
  • e-commerce companies selling products to Polish consumers
  • entities carrying out intra-Community acquisition of goods (WNT) for further resale
  • entrepreneurs packaging products under their own brand
  • foreign entities conducting distance selling

The System of Product Fees

Under Article 19 of the Polish Act on the Management of Packaging and Packaging Waste, all companies placing packaged products on the market must finance public educational campaigns regarding proper waste management. In practice, businesses satisfy this statutory mandate by paying a minimum of 2% of the net value of all packaging placed on the market during the preceding calendar year. This financial contribution must be paid directly to the bank account of the competent Marshal Office. Alternatively, the obligation can be executed through a contractual agreement with a packaging recovery organization. Because this requirement generates direct compliance costs, it is frequently overlooked by international enterprises, exposing them to retrospective penalties.

PPWR and the Authorized Representative: Critical Milestones from August 12, 2026

PPWR and the Authorized Representative: Critical Milestones from August 12, 2026

You join a Packaging Recovery Organisation and pay an annual licence fee. The organisation assumes the recycling level obligations and the related reporting. This is a convenient and secure solution for companies without their own infrastructure.

Self-Compliance Model

You calculate the mass of individual material fractions, verify the required recycling levels, and pay the product fee directly to the Marshal Office, or independently organise recovery

Educational Campaigns: A Frequently Overlooked Obligation

Under Article 19 of the Act on Packaging and Packaging Waste Management, companies placing packaged products on the market are required to conduct public educational campaigns on proper packaging waste management. In practice, this obligation is fulfilled by paying a minimum of 2% of the net value of packaging introduced in the previous year to the account of the Marshal Office. The obligation may be fulfilled independently or through a packaging recovery organisation. This is a real-cost obligation frequently overlooked by many foreign companies.

PPWR and the Authorised Representative: Breakthrough Changes from 12 August 2026

Regulation PPWR (EU 2025/40) begins to apply from 12 August 2026. The PPWR expands the role of the Authorised Representative for foreign entities placing packaging or packaged products on the EU market. In practice, many companies selling to Poland will be required to appoint a representative in Poland. The AR assumes full responsibility for registration, record-keeping, and reporting.

The Regulation also introduces a 50% empty space limit in shipping packaging. Packaging that is excessively large relative to its contents violates this requirement and may result in sanctions during inspections.

Work is ongoing on the national ROP system for packaging (project UC100), which is intended to change the way packaging waste management is financed in Poland. ROP is to be fully aligned with the PPWR timelines.

Reporting Obligations

  • Deadline: by 15 March of the following year (for the previous year)
  • To: the Marshal Office of the Masovian Voivodeship (for companies without a branch office in Poland)
  • Form: exclusively electronic, via the BDO system
  • Content: mass of packaging by material fraction, recycling levels, amounts of product fees and educational campaigns

Consequences of Non-Compliance

  • Administrative fine of 5,000 to 1,000,000 PLN
  • Marketplace platforms such as Amazon and Allegro may restrict sales or block listings in the absence of the required EPR/BDO numbers
  • Possibility of retrospectively charged interest on outstanding fees

How Can EKOKONSULT Help Your Business?

EKOKONSULT manages the entire environmental compliance process on behalf of your international enterprise. Our expert team verifies the exact mass of your packaging, selects the most cost-effective reporting pathway, calculates your educational campaign contributions, and submits all mandatory annual BDO reports before the statutory deadlines. Additionally, we actively support foreign companies in sourcing and establishing a legally compliant Authorized Representative in Poland in accordance with the upcoming PPWR regulations. Contact our specialists today before shipping your first package to the Polish market.

Frequently Asked Questions (FAQ)

Does shipping packaging purchased in Poland also fall under EPR?
Yes. Every piece of packaging that reaches the end consumer together with the product is covered by EPR: cartons, foils, bubble mailers, tapes, filling materials, without exception.
Is there a threshold below which I do not need to register?
There is no threshold exempting from registration. The obligation to register in BDO arises from the very first piece of packaging. Thresholds only concern the possibility of benefiting from de minimis aid in respect of product fees (below 1 tonne of packaging per year).
What is the de minimis aid exemption for packaging?
Companies that introduce less than 1 tonne of packaging per calendar year may benefit from an exemption from the product fee under de minimis aid. However, the obligation to submit a BDO report and maintain registration remains unchanged.
What will the PPWR change in my day-to-day operations?
The PPWR will require full records of the mass of all packaging (including transport packaging), the obligation to have an AR from 12 August 2026, and adapting packaging to the 50% empty space limit. It is worth preparing logistics processes now.