Imagine your products suddenly being delisted from the Polish market simply because you lack an EPR registration number. This isn't alarmist speculation but a potential reality when new Extended Producer Responsibility (EPR) regulations take effect in 2025. As Poland's EPR framework becomes increasingly stringent, how can businesses ensure compliance and avoid unnecessary losses?
The Core of Poland's EPR System
Poland's Extended Producer Responsibility (EPR) system, operating under the EU Packaging Directive (94/62/EC), holds producers accountable for their products' entire lifecycle, particularly packaging waste management. This economic instrument encourages environmentally friendly packaging choices and higher recycling rates to reduce environmental impact and promote circular economy principles.
The EPR framework in Poland primarily covers three key areas:
- Packaging and packaging waste: The central component regulating packaging materials and recycling processes
- Electrical and electronic equipment (EEE): Governing proper disposal of electronic waste to prevent environmental contamination
- Batteries and accumulators: Regulating battery production, distribution, and recycling
Who Must Comply?
These business types must register for EPR in Poland:
- Manufacturers producing and selling goods in Poland
- Importers bringing packaged products into Poland
- E-commerce sellers (including marketplace vendors) selling packaged goods
- Private label owners using branded packaging in Poland
Notably, no minimum sales threshold exempts businesses from compliance—even small-scale e-commerce operators must adhere to EPR requirements.
Non-Compliance Consequences
Violations carry significant risks:
- Fines ranging from €1,083 to €21,666, with higher penalties for repeat offenses
- Product delisting from Polish markets
- Additional 50% surcharges on late eco-contribution payments
2025 Regulatory Changes
The EU's Packaging and Packaging Waste Regulation (PPWR) introduces stricter requirements:
- Reduced packaging: Mandatory "minimization principle" limiting packaging to essential dimensions
- Higher recycling standards: 100% recyclability requirement for packaging materials
- Digital tracking: Mandatory submission of packaging material data for monitoring
E-Commerce Implications
With platforms like Amazon requiring sellers to complete EPR registration by August 18, 2025, cross-border e-commerce businesses must prioritize compliance to avoid marketplace restrictions.
Preparing for Compliance
Businesses should implement these strategies:
- Complete EPR registration early to secure necessary identification numbers
- Redesign packaging using sustainable, easily recyclable materials
- Engage compliance specialists for regulatory navigation
- Establish internal tracking systems for packaging materials and quantities
Beyond regulatory requirements, proactive EPR compliance offers businesses opportunities to demonstrate environmental responsibility and strengthen brand reputation among Polish consumers.