Poland EPR Guide | Lovat Compliance

Extended Producer Responsibility (EPR) for Packaging in Poland

Since January 1, 2020, Poland has instituted an Extended Producer Responsibility (EPR) system in line with directives 94/62/EC for packaging. The primary objectives of this system are to standardize national practices in packaging and packaging waste management while concurrently curbing their environmental impact.

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Responsibility in Poland

The Packaging Act, together with its accompanying regulations, holds various entities accountable for compliance, including:

Producers
Importers
Distributors
Online sellers

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Definition of Packaging under the Packaging Act

The Packaging Act of Poland classifies the following materials as packaging:

Paper and cardboard
Steel
Aluminum
Glass
Plastic
Wood

Thresholds

There are no lower quantity thresholds to exempt anyone introducing packaged products from their obligations. Even sending a single parcel or a solitary product item obliges compliance.

Producer’s Responsibilities under EPR in Poland

Producers dealing with EPR products must undergo registration with the relevant authority to acquire a packaging registration number. This process entails:

1) EPR Registration in Poland

Producers must register via e-portal Database of products and packaging and about waste management (BDO). BDO is implemented by the Institute of Environmental Protection-National Research Institute in cooperation with the Ministry of Climate and Environment.
Producers have to obtain an EPR number managed by Polish authorities.

2) Fee Payments

Producers are also required to levy eco-contributions corresponding to each material type. Fees range from 22 to 65 euros annually and must be remitted for the applicable year by the end of February.

3) EPR Reporting in Poland

Producers must submit annual reports detailing their packaging quantities.

Authorized Proxy

Producers must designate an authorized proxy situated in Poland to fulfill packaging law obligations on their behalf.

Reporting Deadline

In Poland, the deadline for submitting yearly reports is March 15th, covering the previous calendar year.

Sanctions for Violation

In cases of non-compliance:

Voivodship marshals, the local government authorities, may mandate packaging fee payments via administrative decisions. Failure to pay or incomplete payments can result in fines ranging from 1083 to 21666 euros.
Failing to remit fees within 14 days following the final decision empowers the marshal to impose an additional packaging fee equal to 50% of the unpaid amount.

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EPR for ЕЕЕ in Poland

In Poland, businesses engaged in manufacturing, importing, distributing, or selling products online are required by law to adhere to regulations concerning the appropriate disposal of diverse categories of electrical and electronic devices, as outlined in the September 11, 2015 Act on WEEE (Waste Electrical and Electronic Equipment).

Who is considered responsible?

Companies involved in the production, importation, distribution, or online sale of goods are required to comply with distinct environmental guidelines.

What are the EEE categories?

Presently, Poland specifies the following categories:

Large domestic appliances
Cooling appliances
Display equipment
IT Equipment
Small appliances
Gas discharge lamps
Photovoltaic panels

Thresholds

The threshold exemption does not apply; every company introducing products to the market must register.

Registration procedure

Registering for compliance with Electrical and Electronic Equipment (EEE) regulations in Poland involves a series of steps:

Choose an accredited Producer Responsibility Organization (PRO).
Register for BDO.
Complete and submit the necessary legal documents for company registration.
Formulate a cooperation agreement.
Settle the relevant licensing fee.
Acquire an Extended Producer Responsibility (EPR) number for the company.
Furnish annual reports.

Authorized representative

Foreign companies need to choose a representative in Poland. This representative, called the Authorized Representative (AR), operates on behalf of the foreign company. The AR makes sure that the foreign company follows Polish laws and rules.

Reporting Deadline

Producers of Electrical and Electronic Equipment are required to submit reports every quarter. The deadline for submission is the last day of the month following the end of the respective quarter.

Sanctions in case of violation

Not following the rules in the Waste Act can lead to punishments like fines or administrative penalties. Administrative fines range from a minimum of 1,000 PLN.