How Regulation (EU) 2025/40 (PPWR) applies in Poland: the national extended producer responsibility (EPR) scheme, small-producer thresholds, eco-modulation, and deposit return system status. PPWR is directly applicable in Poland from August 12, 2026.
Producers meet the recycling obligation on their own or through a packaging recovery organization such as Rekopol, and register in BDO (bdo.mos.gov.pl) (Packaging Act, Dz. U. 2026 poz. 619, Arts. 10(1) and 17(2)). A government draft bill (UC100) proposes a state-run model built around NFOŚiGW; it has not been enacted, as at October 2, 2026 [SIGNALED].
No small-producer exemption: the act sets no threshold below which the product fee is waived. The fee is settled once a year and paid to the voivodeship marshal by March 15 of the following year, and producers file an annual report (Arts. 34(1), 36(2) and 45(1)).
The product fee is due only on the shortfall against the recycling targets, at per-material rates the climate minister sets by regulation within a statutory maximum of PLN 4.50 per kg, or PLN 25 per kg where beverage-packaging collection levels are missed (Arts. 34(2), 35(1), 35(1a) and 35(2)).
The deposit system has been operating since October 2025 and had collected 3.2 billion containers by August 21, 2026. If you sell beverages into Poland you must already be marking in-scope packaging with the deposit symbol and its amount, and be registered with an operator; this is not a 2029 obligation. Collection is mandatory at every shop above 200 m2 selling in-scope drinks, and at smaller shops selling reusable glass. Separately, non-EU e-commerce sellers must work through the Polish-language BDO portal and appoint a Polish Authorized Representative, so allow significant additional lead time vs. other markets.