Report on products in packaging

For enterprises importing products from abroad

Reports on products, packaging and waste management

The reporting obligation applies to all enterprises that introduce products in packaging onto the Polish market (e.g. importers of products in packaging from abroad, producers of products in packaging, producers of cosmetics, bakeries, etc).

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.

When do you need support?

The province environmental protection inspectorates and the province marshal’s offices exercise oversight involving filing of annual reports on products, packaging and waste management of all firms subject to BDO reporting obligations.

Launch of the BDO database makes it easier for administrative authorities to verify compliance by specific enterprises.

Do I need it?

Reporting on products, packaging and waste management applies to the following entities:

Manufacturers, importers or intra-Community acquirers of packaging from paper, paperboard, plastics, glass or wood
Enterprises introducing into trade products in packaging, exporting or making intra-Community supply of products in packaging, such as bakeries, confectioner’s, dairies, bottlers of beverages or mineral water, cosmetics producers, glassworks, manufacturing plants packing their products, importers and intra-Community acquirers of goods in packaging, exporters of goods in packaging, and many others
Operators of a store or warehouse in which customers pack their purchases in shopping bags subject to a recycling fee
Entities introducing onto the domestic market products, i.e. oils, tires, lubricants (e.g. a tire importer or manufacturer) or goods containing them (e.g. entities involved in intra-Community acquisition or import of vehicles or machinery)

Producers of vehicles, enterprises operating in the area of intra-Community acquisition or import of vehicles (e.g. car dealers importing vehicles from abroad)
Entities introducing electrical or electronic equipment onto the market, authorized representatives (within the meaning of the Act on Used Electrical or Electronic Equipment), e.g. manufacturers of electronic devices for healthcare, industrial automation, the energy industry, importers and intra-Community acquirers of electrical and electronic equipment (e.g. household appliances such as white goods and brown goods)
Entities whose activity includes production, import or intra-Community acquisition of batteries (including those installed in products or vehicles, e.g. import of toys, watches, cars or machinery containing batteries)
Organizations involved in recovery of waste, packaging, or electrical and electronic equipment.

Our Offer

We analyse the situation of your company in terms of the need to file reports on products, packaging and waste management.
We collect data needed for entry in the BDO register.
We maintain your documentation at every stage of cooperation, meeting deadlines and determining the required annual fees and registration fees for payment to the account of the province marshal’s office.
We support you in the process of establishing cooperation and handling contracts with recycling and recovery companies.
We calculate product fees (when recycling and recovery were not conducted in the preceding year).

Contact

Miłosz Saramak

CEE Growth and Marketing Director

m.saramak@krgroup.pl

(+48) 22 511 58 32

FAQ

Our firm dispatches cosmetics directly to customers. Does that mean we have to prepare a report on products, packaging and waste management?

Yes. Because the cosmetics are packed prior to shipment, there is a duty to prepare and file an annual report with BDO. The report should reflect all types of packaging used—e.g. in this case plastic, paper or paperboard (depending on the materials used).

What obligations in the area of product fees will be imposed on a small firm, XYZ, based in France and conducting online sales of cosmetics, fragrances and interior design items to individual consumers in Poland? The firm does not have a warehouse in Poland.

In connection with the shipment of products sold to individual consumers in Poland, firm XYZ becomes an entity introducing products in packaging onto the market.

The first obligation of XYZ is registration in the BDO system (Database on Products, Packaging and Waste Managment) prior to beginning to conduct activity in Poland (i.e. prior to shipping products sold to customers).

After registration in BDO, the entity will obtain a number and access to the database, and will be able to fulfil the second obligation, i.e. submitting an annual report on products, packaging and waste management by 15 March for the prior year.

It should be borne in mind that every entity introducing products in packaging onto the market has a packaging recovery and recycling duty. If the required level of recovery and recycling is not achieved in a given year, the importer is required to pay a product fee.

To summarize, in the example given above, firm XYZ should register in the BDO system, prepare annual reports, and ensure that the required level of recovery and recycling of packaging is met, or pay a product fee to the account of the province marshal’s office in Warsaw.

Foreign retail chain XYZ operates brick-and-mortar stores in Poland, providing stocking of goods to the subsidiary in Poland based on a consignment warehouse model. Who will bear the obligation of filing reports on products, packaging and waste management?

In the model presented, products in packaging are introduced into Poland by the foreign firm XYZ. The products are stored in the Polish warehouse of the subsidiary’s store, and until the time of sale, e.g. of tools, the products remain the property of foreign firm XYZ.

Thus the entity introducing products in packaging onto the Polish market is foreign firm XYZ, which will bear all obligations connected with filing reports on products, packaging and waste management, as well as the duty to achieve a certain level of recovery and recycling.