Packaging Regulations in Poland Under EU Framework

The Polish Packaging Act

The primary national instrument governing packaging in Poland is the Act on Packaging and Packaging Waste (Ustawa z dnia 13 czerwca 2013 r. o gospodarce opakowaniami i odpadami opakowaniowymi, Journal of Laws 2013, item 888, as amended). This law transposes EU Directive 94/62/EC into Polish law and establishes obligations for producers, importers, and distributors of packaged products.

The Act defines "packaging" broadly to include all products made from any material that are used to contain, protect, handle, deliver, or present goods — covering consumer packaging, secondary packaging, and transport packaging.

Obligations for producers and importers

Entities that produce or import packaged goods in Poland are required to:

Achieve minimum annual recycling and recovery rates for each packaging material type (paper, glass, metals, plastics, wood).
Register in the BDO register (Baza Danych o Odpadach) maintained by the Ministry of Climate and Environment.
Submit annual reports on packaging placed on the market and recycling/recovery volumes achieved.
Either establish their own take-back and recycling system meeting statutory targets, or transfer this obligation to an authorised recovery organisation (organizacja odzysku opakowań).
Pay a product fee (opłata produktowa) where recycling targets are not met.

EU Directive 94/62/EC and recycling targets

Directive 94/62/EC (as amended, most recently by Directive 2018/852/EU) sets minimum recycling targets for packaging waste across the EU. Poland, as an EU member state, must achieve these targets and may set higher national targets.

By 2025, Poland must recycle at least 65% of all packaging waste by weight, with material-specific minimums: 75% for paper and cardboard, 70% for glass, 50% for metals, 50% for plastics, and 25% for wood.

Progress against these targets is reported annually to the European Commission. Poland's recycling performance has improved steadily but remains below several of the 2025 thresholds for plastics and wood, according to Eurostat data published in 2025.

Extended Producer Responsibility (EPR)

Poland's EPR scheme requires producers and importers of packaged goods to finance the collection and recycling of the packaging they place on the market. This obligation can be fulfilled through:

Individual compliance

A producer may establish its own collection and recycling infrastructure, provided it meets statutory recycling rates and maintains documentary evidence. This route is uncommon due to the high fixed costs.

Collective compliance via an authorised recovery organisation

Most producers transfer EPR obligations to an authorised recovery organisation (organizacja odzysku opakowań). These organisations pool contributions from multiple producers and contract with recyclers to achieve the required recycling volumes. In Poland, active organisations include Rekopol, Intereko, and Pro-EKO.

The fee paid to the recovery organisation is calculated based on the type and weight of packaging placed on the market. Fee schedules are set by each organisation and updated annually.

The EU Packaging and Packaging Waste Regulation (PPWR)

The EU Packaging and Packaging Waste Regulation (PPWR), proposed by the European Commission in November 2022 and finalised in 2024, replaces Directive 94/62/EC with directly applicable EU regulation. Unlike a directive, the PPWR does not require national transposition — it applies automatically across all member states, including Poland.

Key changes under PPWR

Reuse targets: Minimum mandatory reuse targets for several packaging categories, including transport packaging and e-commerce packaging, phased in between 2030 and 2040.
Design for recycling: All packaging must be recyclable by 2030, with defined performance grades. Packaging assessed as grade D (not recyclable) will be prohibited from the market.
Restrictions on unnecessary packaging: Packaging with no functional purpose (e.g., cosmetic void in e-commerce boxes) is restricted. Space fill ratios are specified for grouped, transport, and e-commerce packaging.
Single-use plastic restrictions: PPWR builds on the existing SUP Directive, adding restrictions on additional plastic packaging formats.
Harmonised EPR: EPR fee structures across EU member states will be partially harmonised to prevent distortion in the single market.

Timeline for Polish producers

The PPWR entered into force in 2024. Key provisions apply from 2028–2040. Polish producers should assess their current packaging portfolio against the recyclability requirements and reuse targets, as non-compliant packaging will need to be redesigned before the applicable deadlines.

BDO registration

The BDO database (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami) is the central national register for waste-related obligations in Poland. All producers and importers of packaged goods are legally required to register before placing products on the market.

Registration is managed online at rejestr-bdo.mos.gov.pl. Annual updates to the registration are required, and annual reports on packaging placed on the market must be submitted through the BDO system by 15 March of the following year.

Single-use plastics (SUP)

EU Directive 2019/904 (the Single-Use Plastics Directive), transposed into Polish law by the Act of 14 April 2023 (Ustawa o niektórych produktach jednorazowego użytku z tworzywa sztucznego), prohibits the placing on the market of specified single-use plastic products including:

Cotton bud sticks with plastic stems
Cutlery, plates, straws, beverage stirrers made of plastic
Expanded polystyrene food and beverage containers

For food and beverage packaging not subject to outright prohibition, the directive requires labelling and, for bottles above 3 litres, tethered caps by 2024.