BDO registration for foreign companies selling products in Poland

Selling products to customers in Poland may create environmental and extended producer responsibility (EPR) obligations, even when the seller has no registered office, branch or employees in Poland.

The sales channel is not decisive. The same rules may apply when products are sold through the company’s own online shop, Allegro, Amazon, eBay, another marketplace, direct B2C or B2B sales, fulfilment or dropshipping.

If a foreign company places products and their packaging on the Polish market, it may be required to register in BDO – the Polish Database on Products, Packaging and Waste Management. Registration in a Czech, Slovak, German or other national EPR system does not replace Polish registration. Each country applies its own registration, reporting and recycling rules.

For a typical online seller, the main obligation is usually registration as a company placing packaged products on the Polish market. Depending on the product range, additional obligations may apply to electrical and electronic equipment, batteries, tyres, oils or other regulated products.

Obtaining a BDO number is only the first step. The company may also have to keep packaging records, calculate packaging weights by material, cooperate with a packaging recovery organisation, submit annual reports and keep its registration data up to date.

Frequently asked questions

Does a foreign company selling in Poland need a BDO number?

In many cases, yes. This may apply when the company is the first entity to place the products and their packaging on the Polish market, in both B2C and B2B sales.

Does this apply only to Allegro sellers?

No. Allegro is only one sales channel. The same obligations may apply to a company selling through its own website, Amazon, eBay, another marketplace or directly to Polish customers.

Is an EPR registration in another country sufficient?

No. A Czech registration covers the Czech market, a German LUCID number covers Germany, and BDO covers Poland. There is no single EPR number valid throughout the EU.

Does the company need a registered office or branch in Poland?

No. A foreign company can register without establishing a Polish company or branch. The procedure does, however, require correctly prepared documents and communication with the competent Polish authority.

Is a Polish representative or authorised agent needed?

A foreign company may appoint an authorised agent to prepare the application, communicate with the authority, respond to requests, obtain access to BDO, submit updates and prepare annual reports. In practice, this is usually the most convenient solution.

Must the BDO number be obtained before sales begin?

As a general rule, the required registration should be obtained before starting the regulated activity. The company should not wait until Allegro or another marketplace requests the number.

Does a small number of orders exempt the company?

Not automatically. Low turnover or only a few shipments per month do not remove the obligation. The assessment depends on the products, packaging and the entity that first places them on the Polish market.

Which packaging must be included?

All packaging delivered to the Polish customer may be relevant: product boxes, shipping cartons, paper and plastic envelopes, bags, stretch film, bubble wrap, filling materials, tape, bottles, jars, cans, wooden and multi-material packaging.

Must the manufacturer’s original packaging also be included?

Yes, if it is placed on the Polish market together with the product. The whole packaging system should be reviewed, not only the outer shipping parcel.

Does every parcel have to be weighed?

Usually not. A reliable model can be based on standard packaging types. Their weight is multiplied by the number of shipments. The method should be consistent and documented.

Is the BDO number enough to sell legally?

No. The company may also have to keep records, submit annual reports, fulfil recycling obligations, cooperate with a recovery organisation, pay relevant fees and update the registration.

Is an agreement with a packaging recovery organisation required?

In many cases, it is the simplest way to fulfil recycling obligations. The organisation’s fees are normally separate from the cost of BDO registration and administration.

Does every company need such an agreement?

Not always. This depends on the types and weights of packaging, the scale of activity and the chosen compliance method.

How often is the BDO report submitted?

Once a year for the previous calendar year. Packaging data should nevertheless be collected throughout the year.

Is a report required even if sales were low?

It may still be required. The reporting obligation should be verified even when the number of orders was small.

Does the company need a Polish VAT number?

Not necessarily. VAT and BDO are separate legal areas.

Must the BDO number be entered on Allegro?

Allegro may request it, but entering the number in the account does not replace statutory records and reporting.

Does the absence of a message from Allegro mean there is no obligation?

No. The obligation arises from Polish law, not from a marketplace notification.

Does BDO also apply to B2B sales?

It may. It is necessary to determine which party first places the products on the Polish market.

What about a warehouse or fulfilment centre in Poland?

Using a logistics provider does not automatically transfer all obligations. Ownership, import, sales, packaging and first placement on the market must be analysed.

Can dropshipping create BDO obligations?

Yes. The roles of the seller, owner, shipper and entity packaging the goods must be determined.

What if the company sells electronics or batteries?

Additional BDO sections, separate records, further reports, specialist compliance agreements and consumer information duties may apply.

What documents are usually required?

Company name and address, registration number, EU VAT number, current commercial register extract, details of authorised representatives, product and sales model description, start date of sales to Poland, packaging description and power of attorney.

Do the documents have to be translated into Polish?

The authority may require translations. Before starting, we indicate which documents are needed and in what form.

How long does registration take?

It depends on the completeness of the documents, correct BDO sections, the power of attorney, fee payment and possible additional requests from the authority.

What if the company is already selling in Poland without BDO?

The start date, products, shipment numbers, packaging weights, correct registration scope and any outstanding reports or fees should be reviewed as soon as possible.

Can the number be obtained only for Allegro?

BDO is not merely a marketplace number. The registration must reflect the company’s actual activity and creates ongoing obligations.

Must the BDO registration be updated?

Yes, for example after changes to the company name, address, legal form, representatives, product range, packaging or sales model.

How can Permitra help?

Permitra can take over the complete process: activity analysis, product review, determination of the correct BDO scope, document and power-of-attorney preparation, application submission, representation before the authority, official correspondence, obtaining the BDO number, setting up packaging records, weight calculations, selection of a recovery organisation, annual reporting, registration updates and ongoing advice.

We do not stop after registration. We make sure the client feels properly supported and secure throughout the process. Before and after purchasing the service, you may ask us as many questions as necessary.

Are you selling products in Poland?

Contact us if you are planning to enter the Polish market, sell through your own online shop, Allegro or another marketplace, have been asked for a BDO number or need a partner to take over the entire process.

You can focus on sales and business development. We will take care of the documents, registration, communication with the authority and ongoing BDO obligations.