The new 2026 waste catalogue – an overview of the planned changes

The Ministry of Climate and Environment has drawn up a proposal for a new waste catalogue, which is due to come into force before the end of 2026. However, businesses need not fear a complete overhaul of the catalogue – the changes proposed by the Ministry of Climate and Environment cover only 6 of the 114 sub-groups and focus on waste related to batteries.

The most significant changes in the new waste catalogue

In September 2026, a draft of a new regulation by the Minister for Climate and the Environment concerning the waste catalogue was published on the Government Legislation Centre’s website. The aim of the amendment is to bring the Polish waste classification into line with EU requirements relating, amongst other things, to battery recycling. The regulations are due to come into force on 9 December 2026, replacing the existing 2020 regulation in its entirety.

The most significant changes are planned for groups 9, 10, 19 and 20, and for sub-group 16 06 of the waste catalogue:

• in Group 9 the classification of waste from single-use cameras has been clarified containing batteries,
• Group 10 has been expanded to include types of waste generated during the recycling of used batteries,
• Subgroup 16 06 has been completely overhauled – introduced 9 new codes for used batteries and 14 codes for waste generated from their production, as well as a more detailed classification of waste, which takes into account types of batteries with different chemical compositions,
• A separate waste code has been added to sub-group 19 02 for solid salts and solutions containing heavy metals from battery recycling,
• in the newly formed subgroup 19 14 Waste codes have been included for the most important intermediate fractions produced during the thermal or mechanical treatment of used batteries and waste from battery production,
• Lithium batteries collected as part of the municipal waste stream have been assigned a separate code within Group 20.

There will be no changes in the other groups.

The draft of the new regulation on the waste catalogue was published on 10 September 2026. A public consultation ran until 30 September 2026, following which the draft was referred to the Council of Ministers’ Committee on Digitalisation. In accordance with § 9 of the draft regulation The new waste catalogue is due to come into force on 9 December 2026.

Why is a new waste catalogue being drawn up?

The regulation proposed by the Ministry of Climate and Environment is intended to to bring the Polish waste catalogue into line with Commission Delegated Decision (EU) 2025/934 of 5 March 2025, which updates the EU list of wastes battery-related. As indicated in the regulatory impact assessment, the proposed amendments are intended to respond to market developments, the emergence of new chemical compositions and technological advances in battery production and recycling. Without an update to national legislation, the Polish waste classification would be inconsistent with the EU list.

More detailed codes are intended to enable a more accurate determination of the origin, composition and stage of processing of waste. The catalogue will distinguish more clearly between used batteries, waste generated during their manufacture, and fractions obtained through recycling processes. Some waste will also be marked with an „*”, indicating that it is hazardous. This is intended to minimise the risk to the environment and facilitate the appropriate selection of treatment technologies, storage conditions and transport requirements.

New waste codes in the catalogue – an overview of the key changes

The draft provides for the addition of new codes, the removal of some existing entries and changes to their descriptions.

Group 16 – changes to the waste catalogue

Alkaline batteries will be classified as hazardous waste – the current code is 16 06 04 Alkaline batteries (except 16 06 03) will be replaced by the code 16 06 04* Used alkaline batteries (other than those listed under 16 06 03).

The name of subgroup 16 06 will be changed z Batteries and accumulators on Waste arising from the manufacture, distribution and use of batteries. Some of the descriptions of the existing codes in this sub-group will also be amended:

• 16 06 01* Lead-acid batteries and accumulatorse → Used lead-acid batteries
• 16 06 02* Nickel-cadmium batteries and accumulators → Used nickel-cadmium batteries
• 16 06 03* The word „used” will be added – the new description will read Used batteries containing mercury
• 16 06 06* Selectively collected electrolyte from batteries and accumulators → ”Electrolyte collected separately from used batteries’

The general code will be removed 16 06 05 – Other batteries and accumulators. At the same time, sub-group 16 06 will be expanded to include more detailed codes:

• 16 06 07* Used lithium batteries
• 16 06 08* Used nickel batteries other than nickel-cadmium batteries, e.g. NiMH, Na-NiCl₂
• 16 06 09* Used zinc batteries, including silver oxide batteries
• 16 06 10* Used sodium batteries containing hazardous substances, with the exception of sodium-sulphur batteries
• 16 06 11* Used sodium-sulphur batteries
• 16 06 12 Other spent sodium batteries, other than 16 06 10 and 16 06 11
• 16 06 13* Mixed used batteries
• 16 06 14* Other used batteries containing hazardous substances
• 16 06 15 Used batteries not otherwise specified, other than 16 06 12 and 16 06 14

The draft regulation provides for the addition of 14 new codes for waste from battery production:

• 16 06 22* Waste from the manufacture of lead-acid batteries containing substances hazardous (e.g. lead-based paste)

• 16 06 23 Waste from the manufacture of lead-acid batteries, other than those listed on 16 June 22

• 16 06 24* Waste from the manufacture of lithium batteries containing hazardous substances (e.g. cathode scrap, cathode slurry, cells, modules or battery packs that do not meet the requirements)
• 16 06 25 Waste from the manufacture of lithium batteries, other than that listed under 16 06 24 (e.g. anode cuttings)
• 16 06 26* Waste from the manufacture of nickel batteries containing hazardous substances (e.g. liquid and solid cathode material)
• 16 06 27 Waste from the manufacture of nickel batteries, other than that listed under 16 06 26
• 16 06 28* Waste from the manufacture of alkaline batteries containing hazardous substances
• 16 06 29 Waste from the manufacture of alkaline batteries, other than that listed under 16 06 28
• 16 06 30* Waste from the manufacture of zinc batteries containing hazardous substances
• 16 06 31 Waste from the manufacture of zinc batteries, other than that listed under 16 06 30
• 16 06 32* Waste from the manufacture of sodium batteries containing hazardous substances
• 16 06 33 Waste from the manufacture of sodium batteries, other than that listed under 16 06 32
• 16 06 34* Waste from battery production containing hazardous substances other than those listed under 16 06 22, 16 06 24, 16 06 26, 16 06 28, 16 06 30 and 16 06 32
• 16 06 35 Waste from battery production other than that listed under 16 06 23, 16 06 25, 16 06 27, 16 06 29, 16 06 31 and 16 06 33

Group 9 – changes to the waste catalogue

The description of waste code 09 01 11* will be amended  Single-use cameras containing batteries included in 16 06 01, 16 06 02 or 16 06 03 → Disposable cameras containing batteries listed under 16 06 01 to 16 06 04, 16 06 07 to 16 06 11 or 16 06 14.

Group 10 – changes to the waste catalogue

In Group 10, the new waste catalogue will be supplemented with 6 additional waste codes belonging to sub-group 10 08:

• 10 08 21* Slag from the recycling of spent lithium batteries containing hazardous substances
• 10 08 22 Slag from the recycling of spent lithium batteries, other than those listed under 10 08 21
• 10 08 23* Slag from the recycling of spent nickel batteries containing hazardous substances
• 10 08 24 Slag from the recycling of spent nickel batteries other than those listed under 10 08 23
• 10 08 25* Recycled slag from other spent batteries containing hazardous substances, with the exception of 10 04 01, 10 08 21 and 10 08 23
• 10 08 26 Recycled slag from other spent batteries, other than those listed under 10 08 25

Group 19 – changes to the waste catalogue

The draft removes code 19 02 11* from the waste catalogue Other wastes containing dangerous substances and introduces two new waste codes:

• 19 02 12* Solid salts and solutions containing heavy metals from battery recycling
• 19 02 13* Other wastes containing dangerous substances

Waste generated during battery recycling will therefore be classified separately, and a new code will be assigned to the general category „other waste…”.

Furthermore, A new subgroup, 19 14, will be added to group 19 Intermediate fractions resulting from the thermal or mechanical treatment of spent batteries and waste from battery production, which will include fractions containing a mixture of electrode materials (classified as hazardous waste) and alloys in bulk form with the following codes:

• 19 14 01* An intermediate fraction resulting from the thermal or mechanical treatment of spent lead-acid batteries and waste from the manufacture of lead-acid batteries, containing a mixture of electrode materials
• 19 14 02* An intermediate fraction resulting from the thermal or mechanical processing of spent lithium batteries and waste from lithium battery manufacturing, containing a mixture of electrode materials
• 19 14 03* An intermediate fraction resulting from the thermal or mechanical processing of spent nickel batteries and waste from the manufacture of nickel batteries, containing a mixture of electrode materials
• 19 14 04* An intermediate fraction resulting from the thermal or mechanical treatment of spent alkaline batteries and waste from the manufacture of alkaline batteries, containing a mixture of electrode materials
• 19 14 05* An intermediate fraction resulting from the thermal or mechanical processing of spent zinc batteries and waste from zinc battery production, containing a mixture of electrode materials
• 19 14 06* An intermediate fraction resulting from the thermal or mechanical processing of spent sodium batteries and waste from the manufacture of sodium batteries, containing a mixture of electrode materials
• 19 14 07* Faction resulting from thermal or mechanical processing used batteries and waste from battery production containing a mixture of electrode materials, other other than those listed under 19 14 01 to 19 14 06
• 19 14 08 Recycled metals from used batteries (in bulk)

Group 20 – changes to the waste catalogue

Items with codes 20 01 33* and 20 01 34 will be removed from the catalogue. The Ministry of Climate and Environment plans to the introduction of a more detailed classification of municipal waste battery fractions, to which the following codes will be assigned:

• 20 01 42* Used batteries listed under 16 06 01 to 16 06 04, 16 06 08 to 16 06 11 or 16 06 14, and mixed waste batteries containing these used batteries, including 16 06 07
• 20 01 43* Used lithium batteries listed under 16 06 07
• 20 01 44 Used batteries other than those listed under 20 01 42 and 20 01 43

What code is assigned to waste in the new catalogue? Correlation table

Anew correlation table has been included in Annex 2 to the draft regulation to help waste-generating companies correctly classify waste covered by the amendment. We encourage you to familiarise yourself with the draft and the table via the following link:  https://legislacja.rcl.gov.pl/projekt/12414454/katalog/13225631#13225631