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Permitra • BDO / EPR Poland • 2026
BDO Registration in Poland for Foreign Companies – EPR, PPWR and Marketplace Sales
Selling products to customers in Poland can create environmental compliance obligations even when your company has no office, branch or warehouse in Poland. For many foreign manufacturers, importers, private-label brands and e-commerce sellers, the key Polish register is BDO – the Database on Products, Packaging and Waste Management.
Since 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) applies across the EU. Online marketplaces are also collecting EPR information more actively. On Allegro, sellers with producer status are expected to provide an EPR registration number for each relevant country and confirm packaging compliance.
The crucial point is that BDO registration is not triggered simply because you use Allegro or another marketplace. The obligation depends on your products, packaging, supply chain and the role your company plays when products are first placed on the Polish market.
What are BDO and EPR in Poland?
BDO is the Polish electronic database and register used for environmental obligations concerning products, packaging and waste.
Depending on the activity, registration may relate to packaging and packaged products, electrical and electronic equipment, batteries and accumulators, tyres, lubricating oils, vehicles and certain other regulated streams.
EPR – Extended Producer Responsibility – is the broader principle under which the entity placing products or packaging on a market may remain financially and organisationally responsible for their end-of-life management. In Poland, BDO is one of the central tools used to identify entities subject to these obligations.
For a foreign e-commerce company, packaging is often the first issue to verify, but the analysis should never stop there. A product containing a battery or an electronic component can trigger additional registration sections and sector-specific duties.
Which foreign businesses should check whether they need BDO?
The correct answer depends on the actual commercial flow. The same product can lead to different obligations depending on who imports it, who owns the brand, where the goods are located before the sale and who is the first entity placing the packaged product on the Polish market.
| Business model | Typical BDO/EPR risk |
|---|---|
| Direct online sales from another EU country to Polish consumers | High – verify packaging/EPR and product categories |
| Import of packaged products from outside the EU into Poland | High |
| Own brand / private label products | High |
| Sales through Allegro or another marketplace | Depends on the supply chain and producer status |
| Products containing batteries or electronics | Additional EPR/BDO streams may apply |
| Goods bought from a Polish supplier and resold in Poland | Often lower, but shipping packaging and own-brand issues must still be checked |
| Dropshipping | Must be analysed – responsibility depends on the actual importer/seller and flow |
Allegro, PPWR and EPR numbers in 2026
PPWR has applied since 12 August 2026. The regulation harmonises many packaging requirements at EU level, but it does not simply replace national EPR registrations. Businesses selling cross-border still need to determine the EPR registration required in each destination country.
Allegro’s official seller guidance states that sellers with packaging producer status should provide an EPR registration number separately for each country to which they dispatch products and accept a packaging conformity declaration. In Poland, the relevant EPR number is linked to the BDO register.
Allegro also points out that a seller can fall within the producer definition when it packs goods itself, sells packaged products under its own brand, imports packaged goods, or sells packaged products cross-border directly to customers. Allegro also provides a dedicated Legal obligations area where sellers can manage EPR information.
Important: a marketplace request is not a substitute for legal analysis. The goal is not to obtain a BDO
number “just in case”, but to register the company in the correct sections and understand what must be done afterwards.
A BDO number is usually only the first step
Receiving a BDO number completes the registration stage. It does not necessarily complete the company’s environmental obligations. Depending on the scope, the business may need to maintain packaging records, submit annual product and packaging reports, fulfil recycling or recovery obligations, calculate product fees, finance public environmental education, cooperate with a recovery organisation, pay the annual BDO fee and update the register when the business model changes.
This is why an incorrect “registration only” approach can cause problems a year later. If the wrong BDO sections are selected or packaging data is not collected from the beginning, the annual report may be difficult to prepare correctly.
What if we place less than 1,000 kg of packaging on the Polish market?
Polish packaging rules provide a de minimis mechanism for businesses that place no more than 1 Mg
(1,000 kg) of packaging on the market in a calendar year, subject to statutory conditions. It can relieve selected packaging obligations, including certain product-fee and public-education burdens.
However, the 1,000 kg threshold is not a general exemption from BDO registration. The company still needs to determine its status, keep reliable packaging data and, where it wants to use the relief, submit the required de minimis information within the applicable deadline – generally by 15 March.
For small marketplace sellers this distinction is important: a company can have only a few hundred kilograms of packaging per year and still need a valid BDO registration.
Can a foreign company register in BDO without a Polish branch?
Yes. The BDO system expressly provides for foreign entities without a branch in Poland. The application includes a foreign-address option and allows foreign identification data to be entered.
In practice, the procedure can be more demanding because the authority must verify the foreign entity, its representation and the exact scope of activity. A correctly prepared power of attorney and supporting company documents can materially reduce unnecessary correspondence.
Do not confuse two different concepts: a procedural power of attorney used to handle a BDO application is not automatically the same as an authorised representative for EPR required under specific EU product rules or PPWR situations. This should be checked separately, particularly for companies established outside the EU.
Official BDO fees and important dates in 2026
The official BDO registration and annual fee is currently PLN 200 for micro-enterprises and
PLN 800 for other enterprises for the categories subject to the fee. The annual fee is generally due by the end of February, except in the year in which the registration fee was paid.
For entities subject to annual reporting on products and packaging, 15 March is a key annual deadline for the previous calendar year. A change in registered data or scope may also require an update application.
These are official public charges and deadlines. Professional service fees for analysis, registration, representation, records or reporting are separate.
How Permitra supports foreign companies
Permitra can handle the Polish procedure from the initial qualification through registration and ongoing compliance. Our work can be limited to obtaining the correct BDO entry, or extended to annual EPR support.
A typical cooperation can include:
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What should you send us for the initial assessment?
- ✓ full legal company name, registered address and country
- ✓ company registration/VAT number
- ✓ description of products sold in Poland
- ✓ information on whether products are sold under your own brand
- ✓ country from which goods are dispatched to Poland
- ✓ information on who imports the goods into Poland
- ✓ types of packaging used for the product and for shipment
- ✓ estimated annual packaging weight by material, if available
- ✓ information on batteries, electronics, tyres, oils or other regulated product categories
- ✓ marketplaces and sales channels used in Poland
Selling in Poland? Verify BDO before the marketplace or authority asks you to fix it.
Send us a short description of your company, products and sales model. We will determine the likely BDO/EPR scope and prepare the next steps for registration in Poland.
FAQ
Does every foreign seller need a BDO number?
No. The obligation depends on the products, packaging and supply chain. However, direct cross-border sales of packaged goods to Poland, imports, own-brand products and regulated product categories should always be checked.
Do I need BDO only because I sell on Allegro?
No. The legal obligation comes from environmental law and your producer/importer status. Allegro collects EPR data from sellers who fall within the relevant rules.
We use less than 1,000 kg of packaging per year. Are we exempt?
Not automatically. The 1 Mg threshold can provide de minimis relief from selected packaging obligations, but it is not a general exemption from BDO registration.
Can a company with no Polish branch obtain BDO registration?
Yes. BDO supports registration of foreign entities without a Polish branch. The correct representation and documentation must be provided.
Is the BDO number enough after registration?
Often no. Records, annual reports, product fees, recovery/recycling obligations, public education duties or cooperation with a recovery organisation may also apply.
What can happen if a company operates without a required BDO entry?
The official BDO guidance states that conducting business without a required entry can result in an administrative fine from PLN 5,000 up to PLN 1,000,000.
Does PPWR replace BDO?
No. PPWR applies directly across the EU from 12 August 2026, but national EPR registration and reporting mechanisms still need to be checked. In Poland, BDO remains central to EPR compliance.
Can Permitra also handle annual reporting after registration?
Yes. The service can be limited to registration or extended to packaging records, annual BDO reporting, de minimis documentation and ongoing compliance support.
Official sources and further reading
- BDO – official registration rules
- BDO – official registration and annual fees
- BDO – official annual fee deadline
- BDO – official questions and answers
- Polish Packaging and Packaging Waste Act – official consolidated text
- Regulation (EU) 2025/40 (PPWR) – EUR-Lex
- European Commission PPWR guidance
- Allegro Help – PPWR requirements for sellers
- Allegro Help – EPR numbers for packaging
The exact obligations depend on the products, packaging, supply chain, producer status and country of establishment.