Annual reporting is an obligation of, among others, waste producers required to maintain waste records. Reports are filed for the calendar year in the online system of BDO (Database on Products, Packaging, and Waste Management) by 15 March for the preceding year.
Under the relevant regulation of the Minister of Environment of 12 December 2014, entities producing waste in quantities not exceeding those stated in the regulation are not required to maintain waste records in any respect. For businesses not needing to maintain waste records, there is also no obligation to file an annual report on waste production or register in the BDO system.
Under Art . 69(4) of the Waste Act, if one of the entities (producer or recipient) has no obligation to prepare a waste transfer note, a note does not have to be prepared. However, this does not automatically release the producer from the obligation to maintain a waste register and prepare an annual report.
There is another exemption under Art. 71 of the Waste Act for businesses producing hazardous waste in quantities of up to 100 kg annually or non-hazardous waste in quantities of up to 5 tonnes annually. In that case, enterprises can maintain a simplified record, in the form of a waste transfer note, without a waste register. However, this does not release these entities from entry in BDO and filing of an annual report.
There is an exception for the situation in which both conditions are met at the same time (exemption under the regulation and exemption under the act). In that scenario, the enterprise is also released from maintaining full records, preparing an annual report, and registering in BDO.