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Selling to Poland? BDO, EPR and PPWR with practical support from Permitra
For international online shops and clients referred by Packaging Compliance. We identify your obligations in Poland, organise registration and packaging data, and guide you through annual reporting. We also explain when you need an EPR representative and how to prepare PPWR compliance documentation.
One sale, three areas of responsibility
A registration in your home country, a recycling scheme agreement or a packaging declaration of conformity does not replace Polish obligations. When selling to Poland, registration, extended producer responsibility and packaging conformity must be assessed separately. Companies do not all fulfil the same roles. [1][2]
Registration and company details
We determine the appropriate registration scope and how applications and updates should be handled.
Packaging in Poland
Record keeping, annual reporting, the appropriate compliance route and any required representative.
Packaging conformity
Manufacturer, importer and distributor roles, documentation, declarations and the applicable labelling.
In practice, a foreign seller can be a producer for EPR purposes without manufacturing packaging. At the same time, it may be a distributor rather than the manufacturer responsible for drawing up the PPWR declaration. We distinguish these roles before preparing documents, including when you sell ready-made products from other brands. [1]
When does selling to Poland require a BDO and EPR assessment?
The starting point is the actual flow of goods and packaging, rather than just the country of establishment or the shop’s language. Direct sales by a foreign business to end users in Poland deserve particular attention: both consumers and businesses using products for their own purposes. Article 45(3) of the PPWR requires an EPR representative for producers established in another EU Member State and covered by Article 3(1), point (15), subpoints (c) and (d). [1][2]
- Your own shop, Amazon, eBay or another marketplace: we check who the seller is and who first makes packaged products available in Poland. Using a platform does not automatically transfer obligations.
- B2B sales: we distinguish a Polish distributor buying for resale from a professional end user. Issuing an invoice to a business does not establish an exemption.
- A warehouse, FBA or 3PL provider in Poland: we analyse incoming goods, repacking and dispatch. We separately identify transport packaging remaining at the warehouse and packaging reaching customers.
- Supplies through a Polish importer or distributor: we establish roles from contracts and the delivery process, to avoid assigning obligations to the wrong business or counting the same weight twice.
Environmental registration does not automatically require setting up a Polish company. Neither German LUCID nor a register in another country replaces BDO. Tax obligations and other product requirements need a separate assessment. [1][2][3]
What do you gain by working with Permitra?
You receive practical support with your packaging obligations in Poland. Under the annual package, our work continues after you receive your BDO number: we help you understand the data, identify gaps and prepare your report on time.
The right decisions from the start
We explain the obligations arising from your sales model and what you need before applying.
Data you can prepare
You receive a spreadsheet and instructions. We help turn SKU information, weights and sales reports into the required breakdown.
Gaps identified before reporting
We check that materials, quantities and market coverage are complete and consistent, and request missing information.
Deadlines under control
We set a timetable for data delivery and reporting, and identify the required actions.
Contact with Polish authorities
We handle routine correspondence concerning the packaging obligations covered by the package.
Support when things change
When you report a new warehouse, product or sales model, we explain what needs reassessment.
What does this mean day to day? If your data include cardboard boxes but omit film and void fill, we identify the missing items. If you approach the 1 Mg threshold, we explain what to check before choosing your compliance route. If you open a Polish warehouse or add products containing batteries, we identify new obligations to assess before using your existing approach.
We provide telephone support in Polish and English. You can email us in any language; we handle routine correspondence with Polish authorities in Polish within the package’s scope. You provide complete, accurate data and report changes to your business. We check completeness and consistency, clarify questions and carry out the agreed tasks. We agree the scope and data delivery deadlines at the start of our cooperation.
Prices: registration and annual packaging support
When you commission the service, we confirm the start of the 12-month support period and the reporting year covered by the package. The contract period and the calendar reporting year are not the same.
The prices below cover standard packaging services in Poland. All EUR amounts exclude VAT. Before you place an order, we confirm your sales model, representation requirements and service scope.
| Service | Package with annual support | Registration only |
|---|---|---|
| Registration | EUR 150 excluding VAT, one-off | EUR 250 excluding VAT, one-off |
| 12 months of support | EUR 399 excluding VAT | Not included |
| First year — Permitra services | EUR 549 excluding VAT in total | EUR 250 excluding VAT for registration |
| From the second year | EUR 399 excluding VAT per year | Further support commissioned separately |
| Data review and annual report | Preparation and submission included | Client’s responsibility after registration |
| De minimis documentation | Included if eligibility conditions are met | Client’s responsibility |
| Routine official correspondence | For the packaging obligations covered | During the registration procedure |
| EPR representative | EPR representation within the agreed package where required; written mandate | Requirement assessed before registration |
| Extended PPWR documentation | Quoted separately | Quoted separately |
The annual package includes monitoring relevant Polish requirements and deadlines, a data spreadsheet with instructions, review of the information supplied, preparation and submission of the annual BDO packaging report, de minimis documentation where eligibility conditions are met, and routine official correspondence concerning the packaging obligations covered by the service.
We can arrange EPR representation in Poland as part of the agreed package where your sales model requires it. We prepare a written mandate, define responsibilities and agree when support begins. The representation scope is confirmed in our offer.
Where a representative is required, we establish a compliant route before the application is submitted. The registration-only option does not remove the representation requirement and is not sufficient for every foreign seller. [2]
Which costs are outside the service price?
- Official BDO registration or annual fee: PLN 200 for micro-enterprises, or PLN 800 for other entities subject to the fee. Micro-enterprise status must be checked; low packaging weight does not determine it. The annual fee is payable by the end of February. It is not due in the year in which the registration fee was paid. [3]
- Any product fee, costs of meeting recycling and recovery obligations, public education campaigns, producer responsibility organisations or other external providers, depending on the appropriate compliance route chosen for the client.
- Overdue reports and corrections for previous years, additional product streams, other countries and the extended PPWR technical documentation module are quoted separately after assessment.
EUR 399 is the fee for 12 months of support, rather than an official BDO fee or a recycling fee. Batteries, electrical equipment, single-use plastics (SUP), deposit return systems, tyres and oils may require separate services. We do not automatically recommend a producer responsibility organisation to every small business: first we assess the available options, including de minimis eligibility.
How do we start, and what do we need from you?
You do not need to know Polish application forms. To start, we need a description of your business and documents enabling us to identify the appropriate roles.
- Describe your sales: country of establishment, when sales to Poland started, channels, B2C/B2B, customer types and warehouse locations. Identify who sells, dispatches and repacks the goods.
- Prepare your company details: name, address, company registration and tax numbers, a current registry document, authorised signatory and contact details. If you already have BDO registration, provide the number and previous reports.
- Gather packaging data: materials, unit weights, numbers of products or shipments to Poland, information on exports, returns and additional packaging. Prepare de minimis documents if that route may apply.
- We send you confirmation of the scope, a list of missing information and documents to sign. Where EPR representation is required, we address it before applying.
- We prepare and handle the agreed procedure. Under the annual package, we also set the data and reporting timetable. After submitting your report, we provide confirmation.
The statutory BDO registration period is up to 30 days after receipt of a complete application. Requests for further information and individual circumstances can affect the process. We do not guarantee a number within a set number of days or approval in advance. Registration must precede activities requiring it. If sales have already started, we also assess earlier periods first. [3][5]
How can you calculate packaging without weighing every parcel?
The export exclusion requires evidence and dispatch out of Poland in the same year; record keeping and reporting still apply. [4]
Together, we establish a repeatable record-keeping method: the number of units sold or shipments multiplied by the documented weight of each packaging item. Data can be based on representative measurements, supplier specifications and SKU records. The method must be reproducible and distinguish materials and the relevant markets.
Include product, grouped and shipping packaging: for example boxes, bottles, jars, film, tape, void fill and appropriately allocated transport packaging. We classify paper and cardboard, plastics, glass, wood, aluminium, steel and composite packaging according to reporting requirements. Records of packaging placed on the market are different from warehouse waste records.
Update weights when changing suppliers or box sizes. For a Polish warehouse, we distinguish packaging removed on receipt, additional shipping materials and packaging of goods sent outside Poland. A single total of orders across all markets is insufficient.
Up to 1 Mg of packaging: check de minimis, keep records
The exemption can cover the recycling obligations, product fee and public education campaigns specified by Polish law. It is not a general exemption from PPWR requirements. [4]
If the total weight of packaging placed on the Polish market in a year does not exceed 1 Mg, or 1000 kg, you may qualify for the Polish de minimis exemption from specified statutory obligations. You must satisfy the state aid conditions, check the available allowance and submit the required documents by 15 March of the following year. This is not an automatic exemption for every small shop. [4]
This route does not remove registration, record-keeping or reporting duties. Nor does it replace an EPR representative where required by PPWR. The separate threshold of less than 10 tonnes in Article 44 PPWR concerns simplified reporting data and is not Poland’s de minimis exemption threshold. [1][4]
Under the annual package, we assess de minimis eligibility using your data and prepare the appropriate documents. If the weight threshold is exceeded or the aid conditions are not met, we explain the alternative route and external costs.
Calendar: what should you track during the year?
Throughout the year
Records, supporting documents and notification of changes to sales or packaging.
By the end of February
Annual BDO fee, where applicable. Exception: the year the registration fee was paid.
By 15 March
Polish report for the preceding year and the required de minimis documents.
Before changing your sales model
Assess changes to the warehouse, market, customer, product or responsible entity.
Article 44(7)–(8) PPWR provides for reporting by 1 June. Establishment of the register under Article 44(1) is linked to entry into force of the first implementing act. This does not establish a second mandatory Polish report immediately or change the national deadline of 15 March. We monitor the applicable procedure and deadlines. [1][5]
EPR representative: the right role and a written mandate
Article 45(3) PPWR requires the specified categories of producers established in another EU Member State to appoint an EPR representative by written mandate in the Member State of first supply. For producers established in third countries, Member States may impose a corresponding requirement; for sales to Poland, we therefore check the applicable Polish provisions and administrative practice. This is relevant to many international shops shipping to Poland. The representative must be appointed by written mandate and established in the Member State covered by the representation. The official BDO notice confirms that, where representation is required, the representative submits the application or update. [1][2]
We distinguish an agent for administrative procedures, an EPR representative under Article 45 and a manufacturer’s authorised representative for conformity under Article 17 PPWR. Authority to submit a form does not replace an EPR mandate, and an EPR mandate does not automatically transfer a packaging manufacturer’s obligations. [1]
Need an EPR representative in Poland? We help arrange representation and guide you through the written mandate and ongoing support for the obligations covered by our cooperation. We explain which documents to sign, what data to provide and what to do when your business changes.
PPWR: packaging documentation, beyond the form
Regulation (EU) 2025/40 generally applies from 12 August 2026, but individual requirements have their own dates and transitional provisions. We therefore assess the requirements applicable to the packaging type and the date it was placed on the market, without treating all future labels or recyclability targets as already mandatory. [1][6]
The manufacturer is responsible for conformity assessment, technical documentation and the EU declaration of conformity under Articles 15, 38 and 39 and Annexes VII and VIII. Internal production control does not mean that a PDF without evidence is sufficient. Importers and distributors have their own verification duties; importing from outside the EU alone does not automatically make the importer a manufacturer. Packaging modifications, own branding and special micro-enterprise rules require separate assessment. [1]
Through an extended module, quoted separately, we can help you:
- identify roles for each packaging type and create an organised inventory;
- ask suppliers for composition, specifications, material data and conformity evidence;
- organise the technical documentation and identify missing information;
- prepare a draft declaration and appropriate language versions using complete data;
- check identification requirements, contact details and applicable labelling dates;
- establish retention and updating rules after changes to materials, suppliers or design.
The declaration must identify the packaging covered and reflect actual conformity evidence. This does not automatically require a separate document for every parcel. The required language depends on the market. The manufacturer retains technical documentation and the declaration for 5 years for single-use packaging and 10 years for reusable packaging, from placement on the market. Testing needs depend on the requirement and the quality of available evidence; we do not promise either mandatory testing of every parcel or complete conformity without testing. [1]
Permitra supports document preparation and organisation. We do not certify materials or replace the manufacturer’s responsibility for the accuracy of the declaration. This module is not automatically included in the EUR 399 annual BDO/EPR service.
FAQ — questions from businesses selling to Poland
Do I need a Polish company, branch, VAT number or PESEL?
Environmental registration alone does not require establishing a Polish company or branch. A Polish VAT number and PESEL personal identification number are not automatic conditions for a foreign company’s BDO registration. System access and representation are assessed separately; tax obligations require their own assessment.
Is registration or a recycling agreement in my home country enough?
They do not replace Polish market obligations. We determine the Polish registration number and EPR compliance route, taking the actual sales chain into account.
Will a marketplace or fulfilment provider handle everything for me?
Do not assume this without checking. A platform may require a registration number, while a warehouse may add packaging of its own. We identify each party’s roles and the scope of its service.
I only sell B2B. Does that change my obligations?
Yes, but it does not create an automatic exemption. A business buying for its own use may be an end user. Supplies to a distributor buying for resale need a different assessment.
I do not manufacture boxes. Why would I be an EPR producer?
An EPR producer is a legal role linked to making packaging or packaged products available in a particular market. It is not always the business physically manufacturing packaging. The PPWR manufacturer role must be classified separately.
Does the 1 Mg threshold mean an exemption from BDO?
No. The 1000 kg threshold may allow a specific de minimis exemption if the conditions are met and documents submitted. Records, registration and reporting remain required; we also assess representation duties.
Must I immediately sign an agreement with a producer responsibility organisation?
This is not the appropriate first route for every business. We first assess packaging weight, de minimis conditions and obligations. If another solution is required, we explain it and its costs.
What exactly does EUR 549 cover in the first year?
EUR 150 excluding VAT for registration within the package, plus EUR 399 excluding VAT for 12 months of support. From the second year, standard support costs EUR 399 excluding VAT annually. Official fees and the other stated external costs are separate.
Does registration alone for EUR 250 include a subsequent report?
No. This option covers the standard registration procedure through to obtaining a number. After registration, the client maintains records and manages reporting, fees and deadlines unless further support is commissioned.
Can you arrange an EPR representative in Poland?
Yes. We can help with EPR representation in Poland within the agreed package. We assess the requirements for your sales model, prepare a written mandate and define the service scope and your data delivery responsibilities. Where a representative is required, appointment is addressed before applying.
What does the EUR 399 package include?
Monitoring applicable requirements and deadlines, a data spreadsheet, data review, preparation and submission of the annual report, de minimis documentation where eligible, and routine correspondence concerning the Polish packaging obligations covered. Additional streams and overdue work are quoted separately.
Is the official BDO fee included?
No. For entities subject to the fee, it is PLN 200 or PLN 800 depending on micro-enterprise status. The annual fee is not payable in the year the registration fee was paid.
Which packaging should I include?
All relevant layers and materials associated with placing packaging on the Polish market: product, grouped, shipping and transport packaging. We help establish the scope; do not limit your spreadsheet to cardboard boxes.
Must I weigh every shipment?
Records can usually be based on packaging types, documented weights and unit counts. The method must be reliable, current and reproducible. Packaging changes must be reflected.
Has the reporting deadline moved to 1 June?
No. The Polish deadline of 15 March still applies to the national report. Article 44 PPWR provides for 1 June for register reporting; we check its implementation and the applicable procedure without automatically assuming a second report.
Does every seller sign their own PPWR declaration?
Not automatically. We identify the manufacturer, importer and distributor for each packaging type. The declaration is based on conformity assessment and documentation, rather than the mere fact of selling.
Does signing a PPWR declaration fulfil all obligations?
No. The declaration requires correct identification of the responsible entity and packaging scope, supported by conformity evidence. Required BDO registration, records, EPR reporting and representation must be addressed separately. We help organise these areas and identify the actions relevant to your business.
Are PPWR documentation and testing included in EUR 399?
Not automatically. Extended support with technical documentation and declarations is quoted separately. Testing needs are assessed against the requirements and available evidence.
I previously sold without BDO registration. What now?
Provide your sales start date and historical data. We assess registration, overdue reporting and necessary corrections. New registration does not automatically remove previous obligations; historical work is quoted separately.
I have several companies or am adding another country. Is one package enough?
Separate legal entities require separate assessment. These prices cover standard packaging services for one company in Poland. Other countries and additional entities are agreed separately.
What if I change warehouses or products, or stop selling?
Notify us before using your existing approach. We check registration updates, the new scope and data. When sales end, we assess formal closure of obligations and outstanding reports and fees.
Under the national BDO procedure, changes to details or activity scope must be notified within 30 days; permanent cessation of activities requiring registration requires a deregistration application within 14 days. Notify us promptly so we can identify the appropriate procedure. Permanent cessation also requires the applicable closing reports within 7 days under Article 76(3) of the Polish Waste Act; we check which reports apply. [5]
Which languages can we use, and how do we start?
Polish and English by telephone; any language by email. Write to info@permitra.eu, mention Packaging Compliance as your referral source and describe your sales to Poland. We identify the required data, suitable option and next step.
Sell to Poland with a clear plan
Send a brief company description, your sales model, the date supplies to Poland started and approximate packaging weight. If you do not yet have these data, tell us what is available; we help establish how to collect the rest.
You receive an explanation of your obligations, confirmation of scope and costs, and a concrete list of next steps. Under annual support, we continue to help after registration with data, reporting, correspondence and changes affecting compliance.
Describe your sales — we will identify the next step
Provide your company name, country of establishment, sales channels, customers, warehouses and the date of first supplies to Poland. Mention “Packaging Compliance”. You do not need a completed weight breakdown to send an initial enquiry.
info@permitra.eu
Telephone: Polish and English · Email: any language
Sources and updates
- Regulation (EU) 2025/40 — PPWR
- BDO: foreign business registration and EPR representatives
- BDO: registration rules and fees
- Polish Packaging and Packaging Waste Management Act — 2026 consolidated text, especially Articles 6–7
- Polish Waste Act — Articles 53 and 76; text and amendments in ELI
- European Commission: PPWR implementation and application dates
- Commission guidance C/2026/3084 — supply chain roles
Legal information checked on 6 October 2026; prices follow the supplied Permitra offer. This language version concerns the Polish market and describes obligations in Poland. Individual scope depends on the sales model, products and required representation, and is confirmed in the offer.