# /news-insights/poland-bdo-packaging-registration-eco-modulation-non-resident-sellers-2026  —  Poland BDO 2026: Packaging Registration, Eco-Modulation and Non-Resident Seller Obligations
# https://o1.eu/news-insights/poland-bdo-packaging-registration-eco-modulation-non-resident-sellers-2026
# Operator One — Merchant of Record for European marketplaces.

## Metadata
- Canonical URL: https://o1.eu/news-insights/poland-bdo-packaging-registration-eco-modulation-non-resident-sellers-2026
- Published: 2026-06-14
- Updated: 2026-09-13
- Publisher: Operator One (https://o1.eu)

## Summary
Poland BDO in 2026: registration costs PLN 200 or 800, fines reach PLN 1,000,000, and PPWR adds a Polish representative duty for distance sellers.

## Full article
By Operator One Editorial — 2026-06-14

## Key takeaways

- BDO registration in Poland costs PLN 200 for micro-entrepreneurs and PLN 800 for all other entrepreneurs under the Minister of Climate and Environment regulation published as Dz.U. 2024 item 1901, applicable from 1 January 2025, with the same amount due as an annual fee by the end of February.
- Conducting activity that requires a BDO entry without that entry exposes a seller to an administrative fine of PLN 1,000 to PLN 1,000,000 under Article 194(1)(5) and 194(3) of the Polish Waste Act of 14 December 2012.
- From 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 (PPWR) requires a producer established outside Poland that sells packaged products directly to Polish end users to appoint a Polish authorised representative for extended producer responsibility by written mandate.
- A foreign company without a Polish branch applies for BDO registration in writing to the Marshal of the Mazowieckie Voivodeship, who must make the entry within 30 days of a complete application, and files the annual BDO report by 15 March under Article 76(1) of the Polish Waste Act.
- Allegro stated on 6 August 2026 that it would not yet block accounts or sales for missing BDO or EPR numbers, but PPWR Article 45(4) already requires online platforms to collect a producer's registration number before letting it sell to consumers.
- Poland's planned new packaging EPR model, draft act UC100, had not been adopted by the Council of Ministers as of 9 September 2026, so the Polish Act of 13 June 2013 on packaging management still governs packaging obligations.

Poland's Database on Products and Packaging and Waste Management, known locally as BDO (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami), is in 2026 no longer a back-office compliance footnote for cross-border sellers. Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) has applied since 12 August 2026, and it adds two things that matter directly to marketplace sellers shipping into Poland: a duty for sellers not established in Poland to appoint a Polish authorised representative, and a duty for online platforms to collect sellers' registration numbers. Poland's own reform of packaging fees, by contrast, is still a draft.

This piece sets out what the Polish BDO regime requires of a non-resident seller in September 2026, what PPWR changed, what is still only proposed, and where the practical friction points sit.

## What BDO is, and why it matters at listing time

BDO is the Polish register and database, whose system is run by the Institute of Environmental Protection, National Research Institute, in cooperation with the Ministry of Climate and Environment, in which entities introducing certain products must be entered. The register entry itself is made and kept by the voivodeship marshal (marszałek województwa); a foreign entrepreneur without a Polish branch applies to the Marshal of the Mazowieckie Voivodeship in Warsaw. According to the BDO fee guidance, the registrable activities subject to fees include introducing electrical and electronic equipment, batteries and accumulators, vehicles, packaging (as producer, importer or intra-community acquirer), products in packaging, tyres and lubricating oils in Poland.

Under Article 50(1) of the Polish Waste Act of 14 December 2012, an entity must apply for and obtain a BDO entry before starting a registrable activity. Under Article 53(1) of the same act, the marshal makes the entry without delay and no later than 30 days after receiving an application without formal defects.

The marketplace layer is changing because of EU law rather than platform policy alone. Article 45(4) of Regulation (EU) 2025/40 requires online platforms within Section 4 of Chapter III of the Digital Services Act (Regulation (EU) 2022/2065) that let consumers conclude distance contracts with producers to obtain, before allowing those producers to use their services, the producer's registration number in the member state where the consumer is located and a self-certification of EPR compliance. The position on the largest Polish platform in September 2026:

- Allegro said in an official community post of 6 August 2026 that it would not block accounts or sales after 12 August 2026 because of missing EPR PPWR (BDO) numbers, citing ongoing legislative work on member state registers. It asks sellers to enter EPR numbers and producer declarations in the Obowiązki prawne (legal obligations) section of Sales Center, and says it will verify numbers per market once registers operate, with advance notice of any sanctions.
- Other marketplaces serving Poland, including Amazon.pl and Kaufland.pl, are subject to the same PPWR Article 45(4) collection duty where they fall within that scope; their exact verification mechanics are set by each platform and should be checked in the seller account.

In practice, a Polish BDO number now belongs in the same pre-launch compliance set as VAT arrangements for Polish sales, French packaging EPR and Germany's LUCID packaging register for any brand planning to sell across EU marketplaces.

## The planned shift toward a new packaging EPR model

Poland's current packaging regime is the Act of 13 June 2013 on packaging and packaging waste management. Under it, entities introducing products in packaging must reach statutory recovery and recycling levels, either themselves or through a packaging recovery organisation (organizacja odzysku opakowań), and a product fee (opłata produktowa) applies to shortfalls, at rates per packaging type set by the Minister of Climate and Environment regulation of 9 December 2023. It is not a flat per-tonne contribution.

The reform that would move Poland toward a fuller extended producer responsibility model is the draft Act on packaging and packaging waste, reference UC100, first published by the Ministry of Climate and Environment on 13 August 2025 to adapt Polish law to Regulation (EU) 2025/40. In the version the Ministry described at publication:

- A packaging fee phased in over a two-year transition. The fee was proposed at 8 percent of the product fee rates in 2026 and 20 percent in 2027, with the system operating in full from 2028.
- A central role for the state fund. The National Fund for Environmental Protection and Water Management (NFOŚiGW) would receive producer payments and distribute them to municipalities based on resident numbers and system efficiency.

These are proposals, not law. The Government Legislation Centre (RCL) record for UC100 shows the draft still passing through Council of Ministers committees on 9 September 2026, with adoption by the Council of Ministers, EU notification and submission to the Sejm still outstanding. Material-specific eco-modulated rates, recyclability bonuses and penalties are therefore not being invoiced under Polish law in 2026, and any timeline in the August 2025 draft may change before enactment.

Separately, PPWR itself sets EU-wide packaging requirements that apply in Poland without national transposition, including the producer and authorised-representative rules described below.

## Non-resident seller obligations in practice

A company not established in Poland that introduces packaged goods to Polish end users has four live obligations in 2026:

- Register in BDO before the first sale. A foreign entrepreneur without a Polish branch submits a written, signed application directly to the Marshal of the Mazowieckie Voivodeship; one with a Polish branch applies electronically to the marshal competent for the branch. Registration is not free: the fee is PLN 200 for micro-entrepreneurs and PLN 800 for others, with the same annual fee due by the end of February in later years, and non-payment leads to removal from the register.
- Appoint a Polish authorised representative where PPWR requires it. Under Article 45(3) of Regulation (EU) 2025/40, a producer within Article 3(1)(15)(c) or (d), meaning one established in another member state or a third country that makes packaging or packaged products available for the first time in Poland directly to end users, must appoint an authorised representative for extended producer responsibility in Poland by written mandate. This applies to EU-established distance sellers, not only non-EU sellers. The Mazowieckie Marshal's Office stated on 17 August 2026 that foreign BDO applications for packaging or batteries filed after 12 August 2026 are assessed against this obligation and, where it applies, must be filed by the authorised representative. For batteries, the parallel rule is Article 56(3) of Regulation (EU) 2023/1542.
- Meet recovery and recycling obligations under the 2013 packaging act, typically through a packaging recovery organisation, or pay the product fee on shortfalls.
- Report annually. The report on products, packaging and waste management for the previous calendar year is filed electronically through BDO to the competent marshal by 15 March under Article 76(1) of the Polish Waste Act.

Who counts as the producer is defined in Article 3(1)(15) of Regulation (EU) 2025/40: a manufacturer, importer or distributor established in a member state that first makes packaged products available within that same member state, or one established in another member state or a third country that makes them available for the first time in Poland directly to end users. The obligation follows the legal entity that makes the goods available, not the platform. A marketplace operator selling third-party goods is not the producer for those goods; its PPWR duty is to collect the producer's registration information.

## What the BDO online portal is actually like

The BDO system at bdo.mos.gov.pl is built for domestic users. Points confirmed by the BDO guidance for foreign entrepreneurs:

- Polish-language interface. Field labels, notices and the step-by-step instructions on the BDO site are published in Polish.
- Login runs through the National Electronic Identification Node (WKIE). After registration, updating the entry, keeping records and reporting require logging in via WKIE, confirmed either through a Profil Zaufany (trusted profile) or a bank connected to WKIE. The person does not need Polish citizenship, but in both routes needs a Polish PESEL number, which a foreigner who cannot register residence in Poland can obtain on application.
- Proxy route. Foreign entrepreneurs from EU member states and third countries can instead act through an authorised person or proxy who holds a PESEL number, which is why a Polish representative often operates the account.
- Written application for foreign entities without a branch. The initial application to the Marshal of the Mazowieckie Voivodeship is made in paper form, printed and signed, not through the portal.

## Where this fits in the broader compliance picture

For a brand selling across the EU through marketplaces, Polish BDO sits in the same operational layer as France's packaging EPR identifiers and Germany's LUCID packaging register, plus country-by-country battery and electrical equipment registrations. Regulation (EU) 2025/40 now gives that layer a common EU frame: producer registers in every member state, authorised representatives for distance sellers under Article 45(3), and platform collection of registration numbers under Article 45(4). Poland also runs a deposit return system (system kaucyjny) for beverage packaging, launched on 1 October 2025, covering single-use plastic bottles up to 3 litres and metal cans up to 1 litre at a PLN 0.50 deposit and reusable glass bottles up to 1.5 litres at PLN 1.00, which is a separate obligation from BDO.

For more context on adjacent regimes, see our compliance glossary (https://o1.eu/compliance-glossary) and the country-by-country breakdown under marketplaces (https://o1.eu/marketplaces).

## How to register in Polish BDO, step by step

- Confirm your role. Check whether you are a producer under Article 3(1)(15) of Regulation (EU) 2025/40 and an entity introducing products in packaging under Article 50(1) of the Polish Waste Act, and list every stream you place on the Polish market (packaging, electrical equipment, batteries).
- Appoint an authorised representative if required. If you are established outside Poland and sell directly to Polish end users, appoint a Polish authorised representative for extended producer responsibility by written mandate under Article 45(3) of Regulation (EU) 2025/40.
- Submit the BDO application. Without a Polish branch, send a written, signed application to the Marshal of the Mazowieckie Voivodeship, or have your authorised representative file it where PPWR requires; the marshal must enter you within 30 days of a complete application.
- Pay the registration fee. Pay PLN 200 as a micro-entrepreneur or PLN 800 otherwise to the marshal's office account, then the same annual fee by the end of February in later years.
- Set up system access. Arrange a WKIE login through a Profil Zaufany or connected bank, which requires a PESEL number, or act through a proxy who holds one.
- Arrange recovery and recycling. Contract a Polish packaging recovery organisation or plan to meet recovery and recycling levels and any product fee under the Act of 13 June 2013.
- Enter the number on marketplaces. Add your BDO number and producer self-certification to each marketplace seller account, for Allegro in the Obowiązki prawne section of Sales Center.
- File the annual report. Submit the report on products, packaging and waste management through BDO to the competent marshal by 15 March for the previous calendar year.

## Frequently asked questions

### Do I need a BDO number to sell packaged goods to consumers in Poland?

Yes, in most cases. Article 50(1) of the Polish Waste Act of 14 December 2012 requires entities that introduce products in packaging in Poland to obtain a BDO register entry before starting that activity. From 12 August 2026, Article 3(1)(15)(d) of Regulation (EU) 2025/40 (PPWR) also treats a company established in another member state or a third country that sells packaged products directly to end users in Poland as a producer with extended producer responsibility there.

### How much does BDO registration cost in Poland?

BDO registration in Poland is not free. Under the Minister of Climate and Environment regulation published as Dz.U. 2024 item 1901, applicable from 1 January 2025, the registration fee is PLN 200 for micro-entrepreneurs and PLN 800 for all other entrepreneurs. The same amounts recur as an annual fee payable by the end of February, except in the year the registration fee was paid. Non-payment leads to removal from the BDO register.

### What is the BDO annual report deadline in Poland?

The annual Polish report on products, packaging and waste management is due by 15 March for the previous calendar year under Article 76(1) of the Polish Waste Act of 14 December 2012. It is filed electronically through the BDO system to the competent voivodeship marshal. For a foreign company without a Polish branch, that is the Marshal of the Mazowieckie Voivodeship in Warsaw, which also keeps its register entry.

### What happens if I sell into Poland without registering in BDO?

Under Article 194(1)(5) and Article 194(3) of the Polish Waste Act, conducting activity covered by Article 50(1) without the required BDO register entry carries an administrative fine of PLN 1,000 to PLN 1,000,000. Failing to pay the annual BDO fee leads to removal from the register. Separately, Article 45(4) of Regulation (EU) 2025/40 requires online platforms to collect a producer's registration number for the consumer's member state before allowing it to sell there.

### Does a foreign company need a Polish authorised representative for BDO packaging registration?

Often yes, from 12 August 2026. Article 45(3) of Regulation (EU) 2025/40 requires a producer established in another member state or a third country that sells packaged products directly to end users in Poland to appoint, by written mandate, an authorised representative for extended producer responsibility in Poland. The Mazowieckie Marshal's Office stated on 17 August 2026 that foreign BDO applications for packaging or batteries filed after 12 August 2026 are assessed against that obligation.

### Is Allegro blocking seller accounts without a BDO number?

Not as of September 2026. In an official community post dated 6 August 2026, Allegro said it would not block accounts or sales after 12 August 2026 for missing EPR PPWR (BDO) numbers, because member state registers under Regulation (EU) 2025/40 are still being set up. Allegro asks sellers to enter EPR numbers and producer declarations in the Obowiązki prawne section of Sales Center and says it will verify numbers per market once registers operate.

### Is Poland's new packaging EPR fee model already in force in 2026?

No. Poland's new packaging EPR model is the draft Act on packaging and packaging waste (UC100), first published by the Ministry of Climate and Environment on 13 August 2025. The Government Legislation Centre record shows it still in Council of Ministers committee stages on 9 September 2026, not adopted by the government and not sent to the Sejm. Until a new act is passed, the Polish Act of 13 June 2013 on packaging management continues to apply.

### Who holds the Polish BDO obligation when a Merchant of Record is the seller?

The obligation sits with the entity that makes the packaged goods available in Poland, not with the marketplace. Where a Merchant of Record sells the goods to Polish consumers in its own name, it is the producer under Regulation (EU) 2025/40 and needs its own BDO entry and, if not established in Poland, a Polish authorised representative. BDO entries do not transfer between legal entities, so a brand that also sells its own stock keeps its own obligations.

### Does Poland's deposit return system also apply to drinks packaging?

Yes, as a separate Polish regime alongside BDO. According to the Ministry of Climate and Environment, packaging carrying the deposit logo began appearing in Polish shops from 1 October 2025. The system covers single-use plastic bottles up to 3 litres and metal cans up to 1 litre at a PLN 0.50 deposit, and reusable glass bottles up to 1.5 litres at PLN 1.00. Brands selling beverages into Poland need to plan for it in addition to BDO.

## Where a Merchant of Record carries the Polish obligation

When Operator One acts as Merchant of Record (https://o1.eu/merchant-of-record), it is the legal seller to Polish consumers, with listings showing the client as brand and Operator One as seller. For those sales, the Polish packaging obligations attach to Operator One as the producer under Regulation (EU) 2025/40: its own BDO entry, recovery and reporting obligations, and, because Operator One is not established in Poland, a Polish authorised representative for extended producer responsibility under Article 45(3). EPR registrations are per country and per stream and do not transfer between legal entities, so a brand that also sells its own stock into Poland keeps its own BDO obligations for those flows. CE marking, conformity assessment and technical documentation for the products themselves stay with the manufacturer. See the compliance glossary (https://o1.eu/compliance-glossary) for the terms used here.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex (https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng); Polish Waste Act of 14 December 2012, consolidated text Dz.U. 2023 item 1587 (https://api.sejm.gov.pl/eli/acts/DU/2023/1587/text.pdf); Regulation on BDO registration and annual fees, Dz.U. 2024 item 1901 (https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20240001901); BDO: new registration and annual fee rates (https://bdo.mos.gov.pl/news/nowe-stawki-oplaty-rejestrowej-i-oplaty-rocznej/); BDO: registration of foreign entrepreneurs (https://bdo.mos.gov.pl/news/rejestracja-przedsiebiorcow-zagranicznych-w-bdo/); BDO: authorised representative for foreign entities (17 August 2026) (https://bdo.mos.gov.pl/news/informacja-w-sprawie-rejestracji-podmiotow-zagranicznych/); Mazowieckie Marshal's Office: BDO fees service card (https://mazovia.pl/pl/bip/zalatw-sprawe/e-uslugi/karty-uslug/6-oplaty-srodowiskowe/610-oplata-rejestrowa-i-oplata-roczna--rejestr-podmiotow-wprowadzajacych-produkty-produkty-w-opakowaniach-i-gospodarujacych-odpadami---bdo.html); RCL legislative record for draft UC100 (https://legislacja.rcl.gov.pl/projekt/12401003); Ministry of Climate and Environment: draft UC100 (https://www.gov.pl/web/klimat/projekt-ustawy-o-opakowaniach-i-odpadach-opakowaniowych-uc100--droga-do-zmniejszenia-ilosci-odpadow); Ministry of Climate and Environment: deposit return system (https://www.gov.pl/web/klimat/system-kaucyjny--to-prostsze-niz-myslisz); Allegro: PPWR from 12 August (6 August 2026) (https://spolecznosc.allegro.pl/t5/zaawansowani-sprzedawcy/rozporz%C4%85dzenie-ppwr-od-12-sierpnia-co-warto-wiedzie%C4%87/td-p/1209976).

## FAQ (structured)
Q: Do I need a BDO number to sell packaged goods to consumers in Poland?
A: Yes, in most cases. Article 50(1) of the Polish Waste Act of 14 December 2012 requires entities that introduce products in packaging in Poland to obtain a BDO register entry before starting that activity. From 12 August 2026, Article 3(1)(15)(d) of Regulation (EU) 2025/40 (PPWR) also treats a company established in another member state or a third country that sells packaged products directly to end users in Poland as a producer with extended producer responsibility there.

Q: How much does BDO registration cost in Poland?
A: BDO registration in Poland is not free. Under the Minister of Climate and Environment regulation published as Dz.U. 2024 item 1901, applicable from 1 January 2025, the registration fee is PLN 200 for micro-entrepreneurs and PLN 800 for all other entrepreneurs. The same amounts recur as an annual fee payable by the end of February, except in the year the registration fee was paid. Non-payment leads to removal from the BDO register.

Q: What is the BDO annual report deadline in Poland?
A: The annual Polish report on products, packaging and waste management is due by 15 March for the previous calendar year under Article 76(1) of the Polish Waste Act of 14 December 2012. It is filed electronically through the BDO system to the competent voivodeship marshal. For a foreign company without a Polish branch, that is the Marshal of the Mazowieckie Voivodeship in Warsaw, which also keeps its register entry.

Q: What happens if I sell into Poland without registering in BDO?
A: Under Article 194(1)(5) and Article 194(3) of the Polish Waste Act, conducting activity covered by Article 50(1) without the required BDO register entry carries an administrative fine of PLN 1,000 to PLN 1,000,000. Failing to pay the annual BDO fee leads to removal from the register. Separately, Article 45(4) of Regulation (EU) 2025/40 requires online platforms to collect a producer's registration number for the consumer's member state before allowing it to sell there.

Q: Does a foreign company need a Polish authorised representative for BDO packaging registration?
A: Often yes, from 12 August 2026. Article 45(3) of Regulation (EU) 2025/40 requires a producer established in another member state or a third country that sells packaged products directly to end users in Poland to appoint, by written mandate, an authorised representative for extended producer responsibility in Poland. The Mazowieckie Marshal's Office stated on 17 August 2026 that foreign BDO applications for packaging or batteries filed after 12 August 2026 are assessed against that obligation.

Q: Is Allegro blocking seller accounts without a BDO number?
A: Not as of September 2026. In an official community post dated 6 August 2026, Allegro said it would not block accounts or sales after 12 August 2026 for missing EPR PPWR (BDO) numbers, because member state registers under Regulation (EU) 2025/40 are still being set up. Allegro asks sellers to enter EPR numbers and producer declarations in the Obowiązki prawne section of Sales Center and says it will verify numbers per market once registers operate.

Q: Is Poland's new packaging EPR fee model already in force in 2026?
A: No. Poland's new packaging EPR model is the draft Act on packaging and packaging waste (UC100), first published by the Ministry of Climate and Environment on 13 August 2025. The Government Legislation Centre record shows it still in Council of Ministers committee stages on 9 September 2026, not adopted by the government and not sent to the Sejm. Until a new act is passed, the Polish Act of 13 June 2013 on packaging management continues to apply.

Q: Who holds the Polish BDO obligation when a Merchant of Record is the seller?
A: The obligation sits with the entity that makes the packaged goods available in Poland, not with the marketplace. Where a Merchant of Record sells the goods to Polish consumers in its own name, it is the producer under Regulation (EU) 2025/40 and needs its own BDO entry and, if not established in Poland, a Polish authorised representative. BDO entries do not transfer between legal entities, so a brand that also sells its own stock keeps its own obligations.

Q: Does Poland's deposit return system also apply to drinks packaging?
A: Yes, as a separate Polish regime alongside BDO. According to the Ministry of Climate and Environment, packaging carrying the deposit logo began appearing in Polish shops from 1 October 2025. The system covers single-use plastic bottles up to 3 litres and metal cans up to 1 litre at a PLN 0.50 deposit, and reusable glass bottles up to 1.5 litres at PLN 1.00. Brands selling beverages into Poland need to plan for it in addition to BDO.

## Steps (structured)
1. Confirm your role: Check whether you are a producer under Article 3(1)(15) of Regulation (EU) 2025/40 and an entity introducing products in packaging under Article 50(1) of the Polish Waste Act, and list every stream you place on the Polish market (packaging, electrical equipment, batteries).
2. Appoint an authorised representative if required: If you are established outside Poland and sell directly to Polish end users, appoint a Polish authorised representative for extended producer responsibility by written mandate under Article 45(3) of Regulation (EU) 2025/40.
3. Submit the BDO application: Without a Polish branch, send a written, signed application to the Marshal of the Mazowieckie Voivodeship, or have your authorised representative file it where PPWR requires; the marshal must enter you within 30 days of a complete application.
4. Pay the registration fee: Pay PLN 200 as a micro-entrepreneur or PLN 800 otherwise to the marshal's office account, then the same annual fee by the end of February in later years.
5. Set up system access: Arrange a WKIE login through a Profil Zaufany or connected bank, which requires a PESEL number, or act through a proxy who holds one.
6. Arrange recovery and recycling: Contract a Polish packaging recovery organisation or plan to meet recovery and recycling levels and any product fee under the Act of 13 June 2013.
7. Enter the number on marketplaces: Add your BDO number and producer self-certification to each marketplace seller account, for Allegro in the Obowiązki prawne section of Sales Center.
8. File the annual report: Submit the report on products, packaging and waste management through BDO to the competent marshal by 15 March for the previous calendar year.