Polski 
Deutsch 
Español 
Français 
Italiano 
Nederlands 
Čeština 
Română 
Lietuviškai 
Українська 
Permitra • BDO • 2026–2027
BDO for foreign waste carriers – registration, transit and obligations in Poland
Carrying waste into Poland, out of Poland or simply through it? We explain when a foreign company needs a BDO registration, how that registration differs from consent for a shipment, what the authorities check at the roadside and where a non-Polish company runs into practical barriers.
- Polish Waste Act
- Regulation (EU) 2024/1157
- SENT
The short answer
Yes, even for transit only
A company that provides waste transport services on Polish territory must, before it starts operating, obtain registration in the BDO register as a waste carrier (Art. 50(1)(5)(b) and Art. 50(2) of the Waste Act (ustawa o odpadach)). Being established abroad does not exempt it from this obligation. The obligation also covers driving through Poland when both loading and unloading take place abroad.
BDO registration is a registration of the carrier. It is not consent for any particular shipment.
Before the Polish leg of the route
Three separate questions
- The company: is it registered in BDO as a waste carrier?
- The shipment: Annex VII or consent under the notification procedure?
- The route: does the import or transit require a SENT notification?
What BDO registration is – and what it is not
BDO is Poland’s Database on Products and Packaging and on Waste Management (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). It includes a register kept by the marshals of the voivodeships, Poland’s regional authorities (marszałkowie województw). Activities that require registration, including waste transport, may only be carried out by a registered entity (Art. 50(3) of the Waste Act). On registration, the company receives an individual registration number and an account in the system (Arts 54 and 55).
A carrier providing a waste transport service must show its registration number on the documents relating to that service (Art. 24(5)). However, the mere fact that a company’s number appears in the BDO search engine settles nothing. What matters is whether the registration covers waste transport. Registration as a waste producer or as a seller is not enough.
- the documents and consents for a specific cross-border shipment (Annex VII or the prior written notification and consent procedure),
- a SENT notification, where the carriage is subject to it,
- registrations and permits required in other countries on the route,
- authorisation to carry out road haulage.
Import, export, transit and domestic carriage
The registration obligation is tied to carrying out waste transport on Polish territory. It makes no difference whether the Polish leg ends at the consignee, starts at the loading point or is only one section of an international route. Transit was expressly confirmed as covered in a notice from IOŚ-PIB, the institute that operates the system (Instytut Ochrony Środowiska – Państwowy Instytut Badawczy), published in the BDO system on 29 January 2021. The other obligations depend on the direction of carriage.
| Route | BDO registration | Shipment document | SENT |
|---|---|---|---|
| Import (e.g. Germany → Poland) | Required | Annex VII or notification and consent documents | As a rule, yes |
| Export (e.g. Poland → Czechia) | Required | Annex VII or notification and consent documents | Depends on the load |
| Transit (e.g. Lithuania → Germany) | Required | Annex VII or notification and consent documents | As a rule, yes |
| Domestic carriage (Poland → Poland) | Required | Waste transfer note (KPO) in BDO | Depends on the load |
The waste transfer note (karta przekazania odpadów, KPO) is a document of Poland’s national waste records. It is used for carriage from a place in Poland to a place in Poland. For imports, exports and transit, the shipment is documented by Annex VII or by the documents of the notification and consent procedure.
The Act exempts from registration anyone transporting waste they have produced themselves (Art. 51(2)). This exemption does not extend to a haulier carrying a customer’s waste.
Foreign companies: entry in the register and the BDO account
The law provides a separate procedure for foreign businesses (Art. 53(2a) and (3) of the Waste Act). The competent authority depends on whether the company has a branch in Poland.
Marshal of the Masovian Voivodeship
The Marshal of the Masovian Voivodeship (Marszałek Województwa Mazowieckiego) registers a company without a Polish branch on the basis of a written application signed by the business or a person representing it. The registration itself does not require a branch or a Polish electronic identity.
Marshal competent for the branch
A company with a branch applies for registration through the person authorised to represent the branch, to the marshal of the voivodeship where the branch has its registered office.
Obtaining the number is only the beginning. All further actions in the system, including changes to the registered details, which the Act requires to be reported through the individual account (Art. 59), require logging in through the National Electronic Identification Node (Węzeł Krajowy Identyfikacji Elektronicznej, WKIE). According to the BDO system, the person logging in does not have to be a Polish citizen. They do, however, need a Trusted Profile (Profil Zaufany) or bank-based identification, and in either case a Polish PESEL number (the Polish personal identification number). The company may act through a person authorised to represent it or through an attorney who has a PESEL number.
Registration can be obtained without Polish electronic tools. Without a person who has a PESEL number, however, the company cannot update its details in the register or perform any other action in the system. It is worth sorting this out before the application is filed, not after the first change of details.
An attorney acting in a carrier’s registration matter has a different role from the authorised representative of a foreign seller in obligations relating to products and packaging. One does not replace the other.
On the road: documents and vehicle marking
The Waste Act and the regulation on detailed requirements for waste transport (rozporządzenie w sprawie szczegółowych wymagań dla transportu odpadów) impose obligations on carriers regardless of where they are established.
Type of waste and the client
Waste must be carried with a document confirming its type and the details of the party commissioning the transport (§ 8 of the regulation). In a cross-border shipment, this role is performed by the waste shipment documents.
“ODPADY” or “A” sign
The vehicle must carry a white sign at the front reading “ODPADY” (Polish for “waste”). A vehicle intended for cross-border waste transport may instead carry a sign with the letter “A” (§§ 9 and 10). Waste that is dangerous goods is carried in accordance with ADR (Art. 24(2) of the Act).
Delivery to the designated destination
The carrier must deliver the waste to the place and holder designated by the party commissioning the transport (Art. 24(3)–(4)). If it carries waste without the required documents, the carrier itself becomes the holder of that waste (Art. 24(4a)).
The shipment: Annex VII, DIWASS and SENT
BDO registration concerns the company. The procedure for a shipment crossing a border is laid down in Regulation (EU) 2024/1157, applicable from 21 May 2026: for eligible waste destined for recovery it is Annex VII (Art. 18); in other cases, prior written notification and consent.
From the EU’s point of view, shipments to and from Great Britain are exports to, and imports from, a country to which the OECD Decision applies. Green-listed waste destined for recovery generally still moves under Annex VII (Arts 44 and 53 of Regulation 2024/1157). Exports from the EU have exceptions: plastic waste B3011, for example, requires prior written notification and consent (Art. 44(2)(c)). The shipment also crosses the EU customs border.
According to GIOŚ, Poland’s Chief Inspectorate of Environmental Protection (Główny Inspektorat Ochrony Środowiska), until 31 December 2026 Annex VII may be completed on paper, using the new template, provided the document accompanies the shipment. After that date, shipments of green-listed waste are handled in the DIWASS system (the EU’s Digital Waste Shipment System).
Since 21 May 2026, waste subject to Regulation 2024/1157 has been covered by SENT monitoring (Poland’s electronic system for monitoring the road carriage of goods), regardless of the quantity in the shipment (regulation of the Minister of Finance as amended by Journal of Laws (Dz.U.) 2025, item 1244). This mainly concerns imports into Poland and transit. The rules provide for exceptions, so the obligation has to be assessed for each specific load.
Inspections and penalties
A vehicle carrying waste may be stopped by the National Revenue Administration (Krajowa Administracja Skarbowa), the Border Guard (Straż Graniczna), the Police (Policja), the Road Transport Inspectorate (Inspekcja Transportu Drogowego) and the Environmental Protection Inspectorate (Inspekcja Ochrony Środowiska). Grounds include breach of the requirements for waste transport, carriage to an unauthorised consignee or breach of the rules on international waste shipments (Art. 24a(1)). A stopped vehicle is directed, together with its load, to a designated storage site.
Transport without BDO registration
The company carries out waste transport in Poland, including transit, without being registered as a waste carrier.
Consequence: an administrative fine (Art. 194(1)(5)).
No number on documents
The carrier is registered but does not show its registration number on the documents relating to the service.
Consequence: an administrative fine (Art. 194(1)(5a)).
Transport requirements
No marking, no document, or failure to deliver the waste to the destination designated by the client.
Consequence: an administrative fine (Art. 194(1)(2a); for failure to deliver the waste, Art. 194b) and possible detention of the vehicle.
Illegal shipment
A load without the required cross-border procedure or under the wrong procedure.
Consequence: detention of the vehicle and, in serious cases, criminal proceedings.
Grey areas and questions to settle for each company
- Is the load waste? The authorities may decide during an inspection that a carrier is transporting waste, even if the transport documents describe the load as goods, e.g. parts from dismantled vehicles.
- “The client has BDO”. The consignor’s or consignee’s registration does not cover the carrier. Each entity is responsible for the scope of its own registration.
- Domestic carriage within Poland. Carriage from a place in Poland to a place in Poland requires a waste transfer note and its confirmation in BDO, and therefore access to the account. The rules on road haulage performed by carriers from other countries are a separate matter.
- SENT exceptions and BDO registration. An exemption of a specific carriage from SENT does not exempt the company from BDO registration, and vice versa. These are two separate regimes.
- Reference to a repealed regulation. The regulation on requirements for waste transport still refers to the documents under Regulation (EC) No 1013/2006. Since 21 May 2026, their role has been performed by the documents under Regulation 2024/1157.
We cover the requirements in other countries on the route in our overview Waste transport across Europe in 2026/2027.
Frequently asked questions
Is a foreign waste carrier registration or permit enough in Poland?
No. BDO registration is a Polish registration of the carrier. Registrations and permits from other countries do not replace it.
Do I need BDO registration if I only drive through Poland?
Yes. The obligation also applies to foreign companies carrying waste through Poland when loading and unloading take place abroad. In transit, the carriage must, as a rule, also be notified to SENT.
Does a foreign company need a branch in Poland?
No. A company without a branch is registered by the Marshal of the Masovian Voivodeship. For further actions in the BDO system, however, it needs a person with a Polish PESEL number and a Trusted Profile or bank-based identification – either its own person or an attorney.
Is a waste transfer note issued for cross-border transport?
The KPO applies to carriage within Poland, from a place in Poland to a place in Poland. A shipment crossing a border is documented by Annex VII or by the documents of the notification and consent procedure.
Does BDO registration mean I can carry any shipment?
No. The registration concerns the company. Each cross-border shipment needs its own procedure under Regulation 2024/1157, and the vehicle needs the correct marking and documents.
What is the penalty for transporting waste without BDO registration?
An administrative fine under the Waste Act. Other breaches may also lead to detention of the vehicle and its load and, in serious cases, criminal proceedings.