For a number of companies in Poland, registration in the waste register and submission of waste generation reports is mandatory. Organizations involved in the production and supply of products, packaging, or waste management are required to register in the BDO registry (bazę danych o produktach i opakowaniach oraz o gospodarce odpadami), submit reports, and pay fees. We discuss the general conditions for registering companies to report on waste in their operations in our article.

What is the BDO Register?

The BDO Register is a register of organizations involved in product supply, product packaging, and waste management. The register is part of the Database of Product Production, Packaging, and Waste Management (BDO, bazę danych o produktach i opakowaniach oraz o gospodarce odpadami).

Registration in the register enables the collection of waste information and ensures the electronic fulfillment of registration, record-keeping, and reporting obligations in order to reduce illegal waste dumping and improve waste recycling.

Who should register in the BDO?

The BDO Register includes organizations involved in waste management, including:

• waste generators,
• organizations involved in waste collection, processing, and transportation,
• waste sellers and waste intermediaries.

The obligation to register with the BDO applies to companies that:

• generate waste and maintain records of this waste,
• place packaged products, tires, lubricants, vehicles, batteries or accumulators, or electrical and electronic equipment into circulation,
• manufacture or import packaging, or acquire it in intra-Union transactions (from EU companies).

Organizations apply for inclusion in the BDO Register in accordance with the Waste Act (ustawa o odpadach). The industry and scale of an organization's activities determine whether it is required to apply for inclusion in the BDO Register. The BDO Register portal offers an interactive form for determining whether or not to register in the BDO Register.

Who is exempt from registering with the BDO?

The BDO Register does not include:

• individuals and organizations, other than entrepreneurs, who use waste for their own needs,
• entities owning land on which household sludge is used to grow crops,
• enterprises engaged in non-professional activities in the packaging waste sector,
• farmers who are waste generators and operate on an area of less than 75 hectares,
• stores and wholesalers that do not offer plastic shopping bags to customers or offer only very lightweight bags that are not subject to recycling fees (so-called "recycling bags"),
• individuals or entrepreneurs who, as part of their activities, generate only waste whose composition and nature are classified as municipal waste and are subject to the municipal waste collection system,
• construction and renovation waste (unless specified in the contract, the organization is a waste generator),
• certain categories and volumes of waste exempt from registration.

An organization's registration in the BDO Register is completed electronically by submitting an application on the portal using the link provided above.

Organizations added to the BDO Register at their own request may begin their activities only after receiving the entry. The Voivodeship Marshal has 30 days to review the application for inclusion in the BDO Register.

Once entered into the register, the following deadlines apply:

• Notifying a change in data – 30 days from the date of the change,
• Submitting a request for deletion – 14 days from the date of final cessation of business activity.

Registration and annual fees. Some entrepreneurs must pay a registration fee for inclusion in the BDO register and an annual fee.

The fees are:

• 200 PLN – registration/annual fee applicable to microentrepreneurs,
• 800 PLN – registration/annual fee for non-microentrepreneurs.

What is a BDO registration number?

All entrepreneurs registered with the BDO are assigned a unique BDO registration number by the relevant voivodeship marshal. Companies that pay the registration fee and annual contribution must indicate this number in documents related to their activities involving the import of packaging, products, and waste. This applies, in particular, to VAT invoices, receipts, sales contracts, reports, delivery notes, and waste documents.

What are the responsibilities of organizations included in the BDO register?

An organization included in the BDO register is required to maintain waste records through an account in the BDO system.

Entrepreneurs generating waste or selling packaged products must submit annual reports to the BDO system.

What are the penalties for failure to register with the BDO?

Penalties for failure to comply with the provisions of the Waste Owners' Registry Act may include a fine or seizure imposed by the court, as well as administrative fines imposed by the provincial environmental inspector.

The link to the government information portal provides detailed information about the BDO.