One sale, three areas of responsibility

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 (EPR) and packaging conformity must be assessed separately. Businesses do not all hold the same roles. [1][2]

A foreign seller may be a producer for EPR purposes without manufacturing packaging. It may also be a distributor rather than the manufacturer responsible for preparing the PPWR declaration. We distinguish these roles before preparing documents, including when you sell other brands’ finished products. [1]

When does selling to Poland require a BDO and EPR assessment?

The starting point is the actual movement of goods and packaging, rather than just the country where your business is established or shop language. Direct sales by foreign businesses to end users in Poland need particular attention: this includes consumers and businesses using the product themselves. Article 45(3) PPWR requires an EPR representative for producers covered by Article 3(1), point (15)(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 your obligations.
• B2B sales: we distinguish a Polish distributor buying for resale from a professional end user. An invoice issued to a business does not establish an exemption.
• A Polish warehouse, FBA or 3PL provider: we analyse inbound supplies, repacking and dispatch. We separately identify transport packaging remaining in the warehouse and packaging reaching customers.
• Supplies through a Polish importer or distributor: we determine roles from contracts and the supply chain, avoiding obligations being assigned to the wrong business or the same weight being counted twice.

Environmental registration does not automatically require you to establish a Polish company. Registration elsewhere in the EU, including Germany’s LUCID, does not replace 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 packaging obligations in Poland. With annual support, our work continues after you receive your BDO number: we help you understand the data, identify gaps and prepare your annual report on time.

What does this mean in practice? If your table includes boxes but omits film and void fill, we identify the missing components. If you are approaching 1 tonne, we explain what to check before choosing your compliance route. If you open a Polish warehouse or add products containing batteries, we identify additional obligations to assess before using the previous process.

We speak Polish and English by phone. You can email us in Polish, English or German; we handle standard correspondence with the Polish authority in Polish within the agreed scope. You provide complete, accurate data and report changes to your business. We check completeness and consistency, explain uncertainties and carry out the agreed tasks. We agree the scope and data submission dates at the start of our cooperation.

Prices: registration and annual packaging support

When you place your order, we confirm the start of the 12-month service period and the reporting year covered. The contract period and the calendar year for reporting are different.

The following prices cover standard packaging support in Poland. All EUR amounts exclude VAT. Before accepting the assignment, we confirm your sales model, representation requirements and service scope.

The annual package includes monitoring relevant Polish requirements and deadlines, a data table with instructions, checking the information provided, preparing and submitting the annual BDO packaging report, de minimis documentation where eligible, and standard official correspondence concerning packaging obligations covered by the service.

We can provide EPR representation in Poland within the agreed package if your sales model requires it. We prepare a written mandate, define responsibilities and agree when support starts. The representation scope is confirmed in our offer.

If a representative is required, we establish a compliant route before applying. The registration-only option does not remove this requirement and is not sufficient for every foreign seller. [2]

Which costs are outside the service price?

• The official BDO registration or annual fee is PLN 200 for microenterprises or PLN 800 for other businesses subject to it. Microenterprise status must be checked; low packaging weight does not determine it. The annual fee is due by the end of February and is not payable in the year in which the registration fee was paid. [3]
• Any product fee, recycling and recovery costs, public education campaigns, recovery organisation or other third-party costs depend on the appropriate route selected for your business.
• Overdue reports and corrections for previous years, additional product streams, other countries and extended PPWR technical documentation are quoted separately after assessment.

EUR 399 pays for 12 months of support. It is not an official BDO fee or recycling charge. Batteries, electrical equipment, single-use plastics (SUP), deposit return schemes, tyres and oils may require a separate scope. We do not automatically recommend a recovery organisation to every small business: we first check available options, including de minimis eligibility.

Getting started: what do we need from you?

You do not need to know the Polish forms. We start with a description of your business and documents allowing us to assign the correct roles.

1. Describe your sales: country of establishment, when you began selling to Poland, channels, B2C/B2B, customer types and warehouse locations. Identify who sells, dispatches and repacks the goods.
2. Prepare company details: name, address, registration and tax numbers, an up-to-date registration document, authorised signatory and contact details. If you already have BDO, provide the number and previous reports.
3. Collect packaging data: materials, unit weights, quantities of products or shipments to Poland, exports, returns and additional packaging. Prepare de minimis documents if this route may apply.
4. We provide confirmation of scope, a list of missing information and documents to sign. Where EPR representation is required, we arrange it before applying.
5. We prepare and manage the agreed proceedings and, under annual support, set a data and reporting schedule. After submitting the report, we provide confirmation.

The statutory BDO registration period is up to 30 days from receipt of a complete application. Requests for additional information and individual issues may affect progress. We do not guarantee a registration number within a fixed number of days or approval in advance. Register before starting an activity requiring registration. If sales are already underway, we also assess earlier periods. [3][5]

How can you calculate packaging without weighing every parcel?

The Polish export exclusion requires evidence and dispatch abroad in the same year; record-keeping and reporting remain required. [4]

Together, we establish a repeatable record-keeping method: units sold or shipments × documented weight of the relevant packaging. Data can use measurements of representative types, suppliers’ specifications and SKU lists. The method must be reproducible and distinguish materials and the relevant markets.

Include product, grouped and shipping packaging: 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 under reporting requirements. Records of packaging placed on the market are different from warehouse waste records.

Update the weight when the supplier or box size changes. For a Polish warehouse, we distinguish packaging removed on arrival, additional shipping materials and packaging on goods dispatched outside Poland. A single combined order count for every market is insufficient.

Up to 1 tonne of packaging: check de minimis relief and keep records

Relief may cover the recycling obligations, product fee and public education campaigns specified in Polish law. It is not a general exemption from PPWR requirements. [4]

If the total packaging weight introduced in Poland during the year does not exceed 1 tonne (1,000 kg), you may qualify for Polish de minimis relief from the specified statutory obligations. You must meet state aid conditions, check the available allowance and submit 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 obligations. It also does not replace an EPR representative where required under PPWR. The separate threshold of less than 10 tonnes in Article 44 PPWR concerns simplified reporting data, not the Polish de minimis exemption threshold. [1][4]

When assessing aid, we also consider the single undertaking, including relevant links between businesses. Under Regulation (EU) 2023/2831, the general limit is EUR 300,000 per Member State over any three-year period. We check aid already received and the applicable cumulation rules. [9]

With annual support, we assess de minimis eligibility using your data and prepare the appropriate documents. If you exceed the weight threshold or do not meet aid conditions, we explain the alternative route and external costs.

Your annual compliance calendar

Article 44(7)–(8) PPWR provides for reporting by 1 June. Establishment of the register under Article 44(1) is linked to the entry into force of the first implementing act. This does not confirm a second mandatory report in Poland today or replace the national 15 March deadline. We monitor the applicable procedure and dates. [1][5]

EPR representation: the right role and a written mandate

Article 45(3) PPWR covers specified categories of producers supplying end users directly in another Member State. This is relevant to many EU online shops shipping to Poland. The representative must be appointed by written mandate and established in the country covered by the representation. The official BDO notice confirms that, where representation is required, the representative submits the application or update. The Commission describes a proposed suspension of some representation obligations as a proposal under examination, not an exemption already in force. [6][1][2]

We distinguish an agent handling administrative tasks, the EPR representative under Article 45 and the manufacturer’s authorised representative for conformity under Article 17 PPWR. Authority to file a form does not replace an EPR mandate, and an EPR mandate does not automatically transfer the packaging manufacturer’s obligations. [1]

Need an EPR representative in Poland? We help arrange representation, a 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 rules. We assess requirements for the packaging type and placing-on-the-market date, rather than treating all future labels or recyclability targets as already applicable. [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 generating a PDF without evidence is sufficient. Importers and distributors have their own verification duties; importing from outside the EU does not automatically make the importer the manufacturer. Packaging changes, own branding and specific microenterprise rules need separate assessment. [1]

In an extended module, quoted separately, we can help you:

• identify roles for each packaging type and build an organised inventory;
• prepare supplier enquiries about composition, specifications, material data and conformity evidence;
• organise 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 procedures after changes to material, supplier or design.

The declaration must identify the packaging covered and match 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 five years for single-use packaging and ten years for reusable packaging, from placing it on the market. Testing needs depend on the requirement and available evidence: we neither promise mandatory testing of every parcel nor full conformity without testing. [1]

Permitra helps prepare and organise documents. 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.

Declarations of conformity also concern Polish businesses

PPWR also applies to Polish businesses. Packaging conformity requirements may concern Polish manufacturers, businesses commissioning own-brand packaging and online shops, depending on their actual role. However, not every shop must issue its own declaration. Distributors selling finished goods and businesses responsible for their own shipping packaging may have different duties. [1] [7]

Before choosing a tool, we establish who is responsible for the packaging, whether you need your own declaration or supplier documents, and whether specific microenterprise rules apply. This ensures your documents reflect your business rather than just a generic form.

Packaging Compliance generator: PERMITRA5 for a 5% discount

How to use the generator and our support

1. Identify your company’s role and the document’s scope. If you are unsure whether your company should prepare the declaration, describe your sales process, packaging origin and relationship with the supplier.
2. Collect data and evidence. Prepare packaging identification, materials, specifications and documents supporting conformity. We explain what to request from the supplier.
3. Choose the right plan and use PERMITRA5. The discount applies to generator plans. Check current prices and limits on the Packaging Compliance website.
4. Complete the form and select markets. The generator prepares documents for selected countries. Fixed elements are translated automatically; your own descriptions require the relevant language versions.
5. Check the document before signing. Verify company details, the responsible person, packaging identification, declaration scope and supporting grounds. Generating a PDF does not replace this check.
6. Retain and update the documentation. Changes to materials, design or specifications may require reassessment and updated documents.

Our partnership combines a practical document preparation tool with Permitra’s help in organising obligations. We explain the sequence, identify missing data and help you plan the next step. If you need additional PPWR review or document preparation, we agree the scope and price before starting.

The generator discount does not change Permitra’s service prices. Buying the tool, annual BDO/EPR support and extended PPWR documentation support are separate services. The generator does not replace BDO registration, packaging reporting or required EPR representation.

FAQ: questions from businesses selling to Poland

Sell to Poland with a clear plan

Send us a brief company description, sales model, first delivery date to Poland and approximate packaging weight. If you do not have this data yet, explain what is available and we will help you work out how to collect it.

You receive an explanation of your obligations, confirmation of scope and costs, and a clear list of next steps. With annual support, we continue helping after registration with data, reporting, correspondence and changes affecting compliance.

Sources and updates

1. Regulation (EU) 2025/40: PPWR
2. BDO: foreign business registration and EPR representation
3. BDO: registration rules and fees
4. Polish Packaging and Packaging Waste Management Act: 2026 consolidated text, particularly Articles 6–7
5. Polish Waste Act: Articles 53, 59, 60 and 76; text and amendments in ELI
6. European Commission: PPWR implementation and application dates
7. Commission Guidance C/2026/3084: supply chain roles
8. Packaging Compliance: generator features, plans and languages
9. UOKiK: de minimis aid rules

Content updated: 7 October 2026. Permitra’s service prices follow the source article. Check the partner’s current features and prices before purchasing. This international English version is aimed at EU businesses selling to Poland and describes Polish obligations, not domestic obligations in their home countries. The individual scope depends on sales model, products and required representation and is confirmed in the offer. General information; your circumstances require an individual assessment.