Delays in implementing GOZ in Poland - NIK report reveals reasons
The Supreme Audit Office has published a post-audit report that identifies numerous shortcomings in the implementation of GOZ in Poland between 2018 and 2022. These have led to a significant decline in the circularity index of the Polish economy and a failure to achieve the waste management targets set by the EU.
Transformation towards GOZ correct, but not fully effective
In its report, the NIK assessed the degree of implementation of the circular economy, taking as a benchmark the data and activities planned in the Roadmap for the transition towards a circular economy, adopted by the Polish government in September 2019. The NIK analysis, however, covered the period from 2018 to 2022.
In the opinion of the Supreme Audit Office:
- Action by state and local authorities have contributed to the fundamental objectives of contained in The GOZ roadmap.
- Due to insufficient cooperation between ministries and the lack of coordination and monitoring of activities by the Minister of Development and Technology, activities were not fully effective or timely.
- Of the 41 planned actions by the end of November 2023, only 28 had been completed. The remaining 13 actions had not been implemented, including four that had not even started.
What's more, Map was not properly updated. The original plan covered the period 2021-2023, after which it ceased to be a valid government document.
Delays in the implementation of EU law and a decline in the circularity index the main allegations in the NIK report
The main reasons for delays in the implementation of GOZ, the NIK report sees, among other things, in the untimely implementation of EU environmental legislation. These include 3 key directives from the point of view of the country's waste management:
- Waste Directive 2008/98/EC (as amended by Directive 2018/851),
- Packaging Directive 94/62/EC (as amended by Directive 2018/852),
- plastic directive (SUP) 2019/904.
To date, we have not seen the full transposition of the aforementioned acts - the law on ROP is only in the early stages of the legislative path, and the SUP regulations require several key amendments, which the EC called on Poland to implement in June 2025.
The introduction to the NIK report also includes information on a decrease in the circularity index of the Polish economy from 10.5% in 2018 to 7.5% in 2023. Over the same period, the EU indicator remained stable at 11.6% in 2018 and 11.8% in 2023. Reasons cited as reasons for this include. significant decrease in the use of recycled materials (from 76 million tonnes in 2018 to 46 million tonnes in 2023), the lack of full transposition of EU environmental legislation and the failure to accelerate the process of successive elimination of waste with adverse environmental impact. As a consequence, Poland has not met the EU targets for GOZ implementation.
Local authorities' actions are correct, but tangible results are lacking
The NIK audit took place not only at government level, but also at local government level. No major irregularities were found in the 8 municipalities visited - local authorities have been active in implementing GOZ by fulfilling the obligations imposed on them by legislation, mainly in the field of municipal waste management. Despite this in 4 of these municipalities the required level of preparation for re-use and recycling was not achievedand most of them were dominated by forms of municipal waste management less favourable from the point of view of the GOZ: landfilling and incineration.
The NIK report also reveals that the area of municipal waste management at municipal level requires financial support from the state. It is currently in deficit in most municipalities.
The local problems were also reflected in the waste management of the country as a whole, with Poland failing to achieve the minimum recycling and PDPU (Prepare for Reuse) levels for paper, metal, plastic and glass waste between 2020 and 2022. NIK also points out that there is a high risk of not achieving the target minimum in subsequent years. What's more, it is becoming increasingly real that the EU's required maximum landfill rate for municipal waste will not be met.
9 billion tax on plastic - costly lack of plastic recycling
Failure to meet EU targets for recycling, preparation for re-use and landfilling of municipal waste may give rise to penalties imposed by the CJEU in the future. NIK also points out that Poland's realistically achieved recycling levels may be lower than shown. This is all due to the poor quality of the data collected and obtained from the BDO, which form the basis of the calculations.
Poland is already paying high fees from the so-called plastic tax calculated on the weight of plastic packaging waste that has not been recycled. According to the Ministry of Finance, between 2021 and 2024, Poland paid around PLN 9 billion to the EU budget from the plastic tax.
What does the EU review of environmental policy implementation 2025 say about this?
The publication of the NIK report coincided with the release of the results of the fourth review of the implementation of environmental policy (EIR) in EU Member States. The most important event for Poland was identified as a significant reduction in the use of plastic bags for purchases per capita. This rate fell from 23 units per capita per year in 2019 to 6.6 units in 2022.
The review highlighted that since joining the Community, Poland has made significant progress in environmental protection. However, our country still faces many challenges, the key ones being the improvement of air quality and the gradual implementation of GOZ.
- The current air quality raises a number of issues and concerns, mainly due to exceedances of the limit values for NO2 and PM10 concentrations and the target values for ozone, arsenic and benzo(a)pyrene.
- Poland is at risk of failing to meet the targets set out in the Framework Directive, i.e. 55% PDPU and municipal waste recycling and 65% packaging waste recycling.
European Commission intensifies action to support transition to GOZ
2 July 2025. The European Commission has announced the launch of a series of initiatives to accelerate the European Union's transition to the GOZ. These are a prelude to the development of a circular economy act, scheduled for adoption in 2026, the Commission said in its communication:
The future act will support the EU's goals under the Competitiveness Compass and Clean Industrial Order to double the share of recycled materials in the EU economy by 2030 and become a global leader in the circular economy.
The new package of activities includes:
- digitisation of the EU waste shipment system - going completely paperless from 21 May 2026,
- Consultation on the harmonisation of the classification of the so-called green list of waste,
- an evaluation of the WEEE Directive on waste electrical and electronic equipment and the gaps in collection and recycling of electro-waste that were perceived after the introduction of the Directive.
Sources:
- NIK, Implementing the circular economy. Information on the results of the audit, https://www.nik.gov.pl/plik/id,30907,vp,33980.pdf
- Review of the implementation of the Environmental Policy 2025, https://op.europa.eu/webpub/env/eir-country-reports-summaries/en/poland.html
- Key actions initiated to develop a circular economy, https://ec.europa.eu/commission/presscorner/detail/pl/ip_25_1710