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Waste Management in Poland, Hungary, Romania and Czech Republic

The approach towards Waste Managment varies amongst most European Union members. It is important that a company, the activity of which results in waste production, adheres to specified environmental obligations.
Maria Hyży-Grimau

Wherever a company is based, it is advised to be acquainted with local regulations, particularly due to the significant fines authorities may issue for non-compliance.


In Poland, all companies generating waste are obliged to maintain Waste Records in the BDO Database. Entities producing small amounts of waste may be exempt from this obligation, as specified by the Decree of the Minister of Climate of December 23, 2019, on types of waste and amounts of waste for which there is no obligation to keep waste records (Journal of Laws 2019 item 2531). As an example, entrepreneurs producing less than 50kg of fluorescent lamps, or less than 100kg of used equipment per year (such as printers or computers), are not obliged to keep waste records.

Based on the Waste Records, a company is required to file an annual report on waste generated and waste management. These reports must be submitted in the online system of Database on Products and Packaging and Waste Management (BDO) by March 15 of the following year (as established by the Law on Waste art. 76).

The annual report on waste generated and waste management, along with the waste records, must be entered in the BDO online system. During the transition phase, these records could be kept in paper form. As of January 1, 2021, records must be maintained via the BDO online database.

The transition to an online record system is tantamount with more precise and frequent inspections. A company is most at risk by being registered in the BDO system and not keeping waste records nor preparing annual waste reports.

Non-compliance with the aforementioned regulations may result in fines ranging from 5 000 PLN to 1 000 000 PLN.

Fines are issued separately for a failure to abide by each individual requirement.


The deadline for submitting the annual waste management return is March 15th of the successive year.


A company carrying out waste management activities (subject to permit) or exceeding a certain amount of produced waste, is obliged to submit a waste declaration. The waste declaration and the records it requires are regulated by Government Decree 309/2014 (XII. 11.) on waste registration and reporting obligations.

A waste declaration is required when the following annual quantities (per site) of generating waste are exceeded (all waste categories must be declared if any of the following limits have been reached):

  • 200 kg for hazardous waste;
  • 2000 kg for non-hazardous waste;
  • 5000 kg for non-hazardous construction and demolition waste.

The list above does not include waste collected by the public service provider. No declaration is required for waste collected by the public service provider.

Failure to abide by these regulations may result in significant fines.

The deadline for submitting the annual waste management return is 1st of March of the successive year.


All companies in Romania (such as manufacturers, offices, producers of goods) generating waste through their activities need to maintain Waste Management Records

Waste Management Record obligations require identifying the category of waste generated by the company. Furthermore, a company must maintain monthly waste records, prepare annual reports, deliver waste to collectors authorized for transport; store, treat and recycle waste as to reduce its harmful impact on health and environment; and capitalize on resources by reusing recoverable parts. Waste producers are also required to collect waste separately.

Recording waste management must be carried out by someone trained in this regard (Environmental Manager). In case a company’s activity requires authorization from environmental authorities, it is mandatory that the individual in charge of waste management underwent and completed specialized courses.

Waste management activity is regulated in Romania by GEO 92/2021 and by GD 856/2002.

Non-compliance with these regulations may result in fines ranging from 20 000 lei to 40 000.

Fines are issued separately for the failure to abide by each individual requirement.


The deadline for submitting the annual waste management return is March 31st of the successive year.

Czech Republic

Legal entities and natural persons authorized to conduct business in the Czech republic, the activity of which results in waste production, are obliged to regularly maintain waste records. Therefore, entrepreneurs must keep records on the type and amount of waste being produced. Records must be kept separately for each individual operation and type of waste. Entrepreneurs are obliged to sort all produced waste and act as to prevent its production. Waste must be stored in separate containers depending on waste type.

Another obligation for business entities is to ensure the disposal of all waste. Entrepreneurs, unlike residents, cannot use containers for sorted waste located in cities and municipalities without a permit. To do so, entities must negotiate the use of these containers on the basis of a contract with the given municipality, or they are obliged to arrange for an external waste service provider.

Entrepreneurs are obligated to fill an annual report on production and waste management. Act No. 541/2020 Coll. on waste (concreted by decree No. 273/2021 Coll. on details of waste management) defines the obligation for business entities which exceed a given amount of waste. This amount varies according to the type of waste being produced (e.g., more than 600 kg hazardous waste). The annual report must be submitted by the end of February of the successive year through the Integrated System for the Fulfillment of Reporting Obligations (ISPOP). Entities must first register in the system. If the entity produces waste, it must create an identification sheet and equip hazardous waste management sites with this document. When transporting waste, it is necessary to have the registration sheet on hand.

The deadline for submitting the annual waste management return is 28th of February of the successive year.

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