BDO is the Polish Database on Products and Packaging and Waste Management. The system includes a register of businesses subject to certain environmental obligations and electronic modules used for submitting reports.

Registration requirements do not apply exclusively to companies established in Poland. A foreign business selling products to Polish customers may also be required to obtain a BDO registration number if its activities fall within the scope of applicable Polish legislation.

The applicable requirements depend on the types of products, the sales model and the company’s role in the supply chain. Each case should therefore be assessed individually.

EPR stands for Extended Producer Responsibility. It covers the obligations of businesses that place certain products or packaged products on the market.

Foreign companies selling products to Poland should pay particular attention to the following areas:

• packaging and packaged products,
• electrical and electronic equipment,
• batteries and accumulators,
• products containing electrical components, batteries or accumulators,
• other products covered by specific environmental legislation.

A single product may fall within several EPR areas. For example, an electronic device containing a battery and supplied in packaging may need to be considered under the requirements for packaging, electrical and electronic equipment, and batteries.

Packaging is one of the most common areas in which foreign companies selling products in Poland may be subject to environmental obligations.

The relevant requirements may apply to:

• sales packaging,
• grouped packaging,
• transport packaging,
• cardboard boxes and paper packaging,
• plastic film and protective materials,
• wooden pallets and crates,
• other materials used to package and deliver products to Poland.

A company may need to collect information about the type and weight of each packaging material placed on the Polish market. Maintaining reliable packaging records is important because these figures may later be required for BDO reporting.

Foreign companies selling electrical or electronic devices to Poland may be subject to obligations relating to waste electrical and electronic equipment, commonly referred to as WEEE.

The correct classification may depend on factors such as:

• the type and intended use of the equipment,
• the way the product is powered,
• whether it is intended for consumers or professional users,
• the sales and distribution model,
• the relevant equipment category.

Incorrect classification may result in an incomplete BDO registration or inaccurate reporting. Products should therefore be reviewed before the company begins selling them in Poland.

Environmental obligations may also apply to batteries and accumulators sold separately or incorporated into electrical and electronic equipment.

A company selling battery-powered products should determine whether its obligations cover:

• the electrical or electronic equipment,
• the incorporated battery or accumulator,
• the packaging in which the product is supplied.

These areas may require separate entries in the BDO register and separate data for reporting purposes.

Before starting sales, a company should establish:

1. which products will be offered in Poland,
2. whether the products contain electrical components, batteries or accumulators,
3. which packaging materials will be used,
4. whether sales will be B2B, B2C or both,
5. whether products will be sold directly, through a distributor or through an online marketplace,
6. which entity will place the products on the Polish market,
7. when sales to Poland will begin.

This information makes it possible to determine whether BDO registration may be required and which registration and reporting areas should be considered.

Obtaining a BDO registration number may only be the first step. Depending on the applicable product category, a company may also need to:

• keep records of the products and packaging placed on the Polish market,
• monitor product quantities and packaging weights,
• submit the required BDO reports,
• update its registration if the scope of its activities changes,
• submit outstanding reports or correct previously submitted reports,
• fulfil additional obligations applicable to specific product categories.

A company should therefore establish a reliable process for collecting the required data from the beginning of its sales activities in Poland.

TERRA assists foreign businesses that sell or plan to sell products in Poland. Our support may include:

• reviewing the company’s products and sales model,
• identifying potential environmental obligations in Poland,
• registering the company in the BDO system,
• updating an existing BDO registration,
• determining the relevant registration and reporting areas,
• preparing and submitting BDO reports,
• preparing and submitting outstanding reports for previous reporting periods,
• representing the company, within the agreed scope, in BDO-related matters.

The scope of support is determined individually, based on the company’s activities and the products it places on the Polish market.

Environmental obligations should be reviewed before sales begin. Early verification can help a company determine the appropriate registration scope, organise the necessary product and packaging data and avoid incomplete or incorrect reporting.