EPR in Poland

What is Extended Producer Responsibility (EPR)? 

Awareness over the environmental cost of consumer consumption has grown significantly in recent times, leading many countries to begin implementing a range of Extended Producer Responsibility regulations – commonly known as EPR.

Many consumers are already familiar with the concept of producers taking some form of responsibility for their products, often for upkeep and maintenance (for example, warranty services).  EPR regulations take this one step further, by making producers responsible for the entire lifecycle of their products. 

Focusing on the entire lifecycle of a product often refers to disposal and waste management, where significant environmental costs are often incurred.  EPR schemes usually aim to do this by requiring producers to fund the proper disposal and/or recycling of their products. 

EPR regulations in Poland

The EU Directives underpin Poland’s EPR regulations, meaning that the categories and definitions will be broadly similar.  

There are currently three EPR categories in Poland.

1. Packaging

Packaging refers to both primary, secondary and tertiary packaging.  This includes:

• Product packaging (i.e. to cover/protect merchandise)
• Shipping packaging, including materials filled at point of sale (e.g. cardboard shipping boxes)
• Packaging used for bulk shipping and transportation (e.g. pallets/shipping containers)

Materials covered include plastics, wood, aluminium, steel, glass, paper, cardboard and fibres.

The relevant legislation for Packaging can be found here and here.

2. WEEE

WEEE refers to Waste Electrical and Electronic Equipment. 

Equipment will be classed as WEEE if:

• It relies on electric currents or electromagnetic fields to function
• It serves the function of generating, transferring and/or measuring electric/electromagnetic currents or fields
• It is designed for use with a voltage of up to 1000V (AC) or 1500V (DC)

WEEE equipment is categorised into 6 separate categories as per the requirements of the EU Directive:

1. Temperature exchange equipment
2. Screens, monitors and equipment containing screens with a surface > 100cm²
3. Lamps
4. Large equipment
5. Small equipment
6. Small IT and telecommunication equipment

The relevant legislation for WEEE can be found here. 

3. Batteries

Three types of batteries are covered:

• Portable
• Automotive
• Industrial

The relevant legislation for Batteries can be found here.

Who is required to comply with the EPR regulations?

Generally, businesses across all stages can be considered a ‘producer’ under the EPR regulations, including:

• Producers – domestic producers manufacturing and/or selling in Poland
• Importers – businesses importing into Poland
• Retailers – domestic businesses selling imported goods produced abroad in Poland
• Distributers – businesses selling products to stores in Poland
• International distributers – businesses selling to companies in Poland

Some variations may apply for specific EPR categories.

Compliance with EPR

In some cases, you may need to appoint a local Authorised Representative (AR) in order to apply for EPR.  

You will also need to appoint a Producer Responsibility Organisation (PRO) in order to fulfil waste management/disposal of products.   

Need to apply for EPR in Poland, or not sure if you need to apply? Get in touch with us for a free one-to-one consultation at info@tbaglobal.com.