We know the assumptions of the Extended Producer Responsibility (EPR) system, which the Ministry of Climate and Environment has been working on for some time. However, the eagerly awaited ROP model differs significantly from what entrepreneurs and environmental experts had expected.

At the end of February, statements by members of the advisory team for systemic solutions for waste management, which operates under the Ministry of Climate and Environment, appeared in the media, from which the concept of the ROP model being developed by the Ministry of Climate and Environment emerged more and more clearly, and in recent days the Ministry in the Polish Parliament presented its assumptions. What will be its main assumptions?

• One system operator

According to the Ministry's plan, the operator of the ROP system is to become the National Fund for Environmental Protection and Water Management, whose main task will be to ensure that the required recycling levels for packaging waste are met.

• Costs for introducers

The costs of packaging waste management will be borne by the introducers of packaged products. The Ministry envisages setting, by way of a regulation, fixed rates of the public charge, which will be transferred by the introducers through marshal offices to the NFOŚiGW account. The fee rates will be lower the more the packaging demonstrates its recyclability.

• Disbursement of the proceeds of the levy by NFOŚiGW

The funds from the financial contributions made by the introducers will be distributed between:

• municipalities, depending on the weight of packaging waste collected and in addition as compensation for the maintenance of the municipal waste collection system,
• treatment facilities, depending on the weight of packaging waste sorted and sent for recycling,
• recycling facilities for waste with a negative market value, depending on the mass of waste recycled.

Part of the funds will also go to environmental education and to cover the investment gap of the packaging waste management system.

• Responsibility for achieving recycling levels on the part of NFOŚiGW

The sole responsibility for ensuring that the recycling levels set by the EU are achieved will rest with the sole and, in addition, state-owned operator of the system, the NFOŚiGW. Under the current system, producers can transfer this responsibility to any recovery organisation of their choice.

• The role of local authorities

Municipalities will continue to be responsible for organising the collection and for managing the collected municipal waste. In return for these activities, the municipalities will receive (as well as the installations) compensation at a fixed amount to facilitate long-term planning.

Other assumptions of the draft ROP

• further introducers and further installations will be able to join the system at any time,
• the system operator will not acquire ownership of the waste at any stage of its management,
• waste holders will not be obliged to hand over their waste to specific recipients (installations),
• the various stakeholder groups will be represented on the dialogue council set up for the ROP system.

Paradoxically, the Ministry's proposed ROP system may consequently lead to problems in meeting waste recycling targets packaging.

This is because the proposal of the Ministry of the Environment transfers the responsibility for achieving these recycling levels from entrepreneurs (introducers) to the state (NFOŚiGW). Titled the producer's liability is therefore limited to financial liabilitywhich consists of setting aside a pre-determined amount in the company's monthly budget and transferring it to the correct account. In contrast, the organisational responsibility of introducers and the need to ensure, in accordance with the Waste Directive, the efficiency of the ROP system have been completely disregarded.

Similar solutions are currently in place in only 2 EU countries (Hungary and Croatia), and in both of them, businesses are faced with the high costs of operating the systems and the state with the real risk of not meeting the 2025 targets set by Directive 94/52/EC.

The public charge envisaged in the ministerial ROP model will be nothing more than a new environmental para-tax and a will not meet the condition of cost-effectiveness announced by the IOC. Moreover, such the solution will be contrary to Directive 2008/98/EC on waste, and thus with the legal act that de facto obliged Poland to introduce the ROP provisions. The Directive requires that the financial contributions paid by introducers to fulfil their obligations under the ROP should not exceed the costs necessary to provide waste management services in a cost-effective manner. These costs should be determined transparently between the stakeholders themselves and not top-down, as proposed by the IOC.

According to Konrad Nowakowski, President of the Polish Chamber of Packaging Recovery and Recycling:

The proposed ROP model does not achieve the basic objectives of environmental policy - it does not contribute to increased recycling or the development of a circular economy. In practice, it becomes another tax imposed on businesses, with no mechanisms to ensure that the funds are used efficiently.

The current financial liability mechanism in the form of a product fee significantly affects the motivation of these entities towards not only eco-design, but also ensuring the required recycling levels. Fixed, predetermined fee rates, the introduction of which is envisaged by the ICE model, will not give those introducing packaged products any influence on the functioning of the system. Nor will they take into account the dynamically changing costs of waste management.

The effect of continuing the project on the basis of the ministerial assumptions may even be the abandonment of research and development work currently being carried out by entrepreneurs to develop packaging with minimal environmental impact. The investment expenditures incurred would not be returned to the producers in the future - instead of the expected return on investment, a predetermined fee would be imposed on the producers, which would in no way reward "green" packaging.

The contradiction of the ministerial ROP model with EU legislation does not only manifest itself at the level of cost-effectiveness. As experts point out, a centrally administered system, with the NFOŚiGW becoming the monopoly, is incompatible with Article 8a of Directive 2008/98/EC on waste. These provisions provide for the possibility of setting up multiple organisations in each Member State to carry out ROP obligations on behalf of product manufacturers, while requiring Member States to designate one or more authorities to supervise in such a situation.

In addition, the preamble of the recently enacted Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (PPWR) indicates that producers should be able to collectively fulfil their ROP obligations through authorised producer responsibility organisations. Member States may instead authorise multiple liability organisations - as indicated in recital 130, competition between these organisations can lead to greater benefits for consumers.

In the ministerial proposal of the ROP, there will be a state system administrator acting on the basis of statutory authority rather than authorisation, but no producer responsibility organisations will be created, contrary to recital 130 above.

Following the announcement of the ministerial concept of ROP, business representatives called in large numbers for the Ministry of Climate and Environment to stop drafting a bill based on this model and initiate a public discussion on the creation of an optimal model for the Polish economy, the organisation of which will be influenced by those introducing packaged products.

As industry experts point out, the introduction of the ROP system, in the form proposed by the IOC, would entail the end of the activities of all packaging recovery organisations (PROs), which are currently not only entities fulfilling the statutory obligations of producers. Their role is much broader - the majority of OOOs offer comprehensive, integrated solutions for companies aimed at optimising waste management, minimising the carbon footprint of packaging, products and services, as well as expert support in fulfilling other obligations under environmental regulations. The OOO's activities thus create a series of synergies that bring real benefits to the economy, the environment and citizens. Indeed, let us not forget that it is the recovery organisations that carry out public education campaigns on behalf of their clients and have been making efforts for years to ensure that action in favour of recycling and the GOZ is taken not only by businesses and decision-makers, but also by increasingly aware consumers.

26 February 2025. The European Commission has unveiled its announced sustainability simplification package. Omnibus I is the first of the expected packages, which aim to increase the competitiveness and investment attractiveness of EU companies.

Omnibus I is a package of proposals aimed at simplifying EU legislation, increasing the attractiveness of EU businesses and unlocking additional investment opportunities. According to EC estimates, it will result in 25% reduction in administrative burden for those required to report on sustainability, with the burden to be reduced by as much as 35% in the SME sector.

The changes outlined in the Omnibus I package will mainly concern:

• sustainable finance reporting,
• due diligence on sustainability reporting,
• EU taxonomy,
• Carbon Boundary Adjustment Mechanism (CBAM),
• European investment programmes.

According to the EC's calculations, the implementation of the announced proposals will yield savings of EUR 6.3 billion and will result in an increase in private and public investment of €50 billion. As announced by the head of the EC, Ursula von der Leyen, further simplifications are already' on the way'.

The simplification package adopted by the EC implies several key changes:

• Postpone by two years (to 2028) the reporting requirements for companies currently covered by the CSRD, which are obliged to report from 2026 or 2027.
• By 80%, the number of entities covered by the sustainability reporting obligation will be reduced.
• Sustainability reporting will mandatory only for large entities with more than 1,000 employees and a balance sheet total of more than EUR 25 million or net revenue of more than EUR 50 million.
• By limiting the information reported in the value chain, the ESG reporting requirements imposed on the largest companies will not burden small entities.

Reducing the burden on SMEs also involves on reducing the frequency of periodic evaluations and monitoring partners from annual to five-year intervals. However, if there is a legitimate need, the ESG reporting entity will be able to perform an ad hoc assessment.

Importantly, Omnibus I upholds the possibility of voluntary ESG reporting for entities that will in future fall within the scope of the CSRD. In this way, the EC wants to ensure that companies have access to sustainable financing, the obtaining of which in many cases involves non-financial reporting.

What is ESG? Find out the simplest definition

In addition to narrowing the range of entities covered by the effects of the CSRD, the European Commission also intends to reduce the costs associated with the preparation of ESG reports. Omnibus I promises businesses a reduction in the expense of attesting ESG reporting. This is all thanks to waiving attestation at a sufficient level of assurance (reasonable assurance.) Instead, only limited assurance will be required.

The Omnibus package also included information on the simplification of ESRS standards by reduction of ESG disclosures. Furthermore, the EC announced that so-called sectoral standards, i.e. sets of guidelines taking into account the specificities of individual industries, will also not be adopted. Entrepreneurs will also gain the possibility to report on activities that are partly in line with the EU taxonomy. This approach is intended to support a gradual transformation towards sustainability.

What else will change with the introduction of the Omnibus?

• There will be a substantial simplification of reporting templates. Omnibus I announces a reduction in their number by as much as 70%.
• Small importers will be excluded from the CBAM (so-called carbon tax) mechanism and the obligation of quarterly reporting. For other importers, the mechanism will be simplified.

The Omnibus I simplification package proposed by the EC constitutes a sort of trade-off between climate and economic objectiveswhich the Community intends to achieve. The loosening of reporting rigour and climate policy is a response to the current economic and political situation, which requires the creation of conditions for more dynamic economic development. The proposed direction of change is likely to result in creating a more business-friendly environment which will help businesses in the EU to grow, innovate and create more jobs.

A series of simplifications and reliefs are also followed by financial incentives. The Commission has proposed a series of amendments aimed at enabling greater use of EU investment programmes InvestEU and EFIS, among others. It is expected to mobilise around EUR 50 billion in additional public and private investment, make it easier for Member States to support innovative companies and simplify administrative requirements, which have hitherto been a heavy burden on the SME sector in particular.

The detailed scope of the Omnibus I package can be found in on the European Commission website (eng.).

Shopkeepers and wholesalers who offer plastic bags to their customers are required to pay a recycling fee. How much is the plastic bag levy in 2025 and by when do you have to pay it? Find out the most important information about the recycling levy.

The recycling fee covers all bags for plastic shopping with the exception of so-called rip-offs, which are very lightweight bags made of material less than 15 micrometres thick:

• necessary for hygiene reasons,
• used as primary packaging for food sold in bulk (as long as they prevent food waste).

This means that the recycling charge is not levied on, for example, carrier bags on a roll or plastic bags used to package fresh bread, fruit and vegetables, meat, cheese, etc.

Each trader running a shop or a wholesale business (retail or wholesale unit) where plastic shopping bags are offered to customers, is obliged:

• collection of the recycling levy from purchasers (customers),
• payment of the fee collected recycling into the relevant bank account within the agreed deadlines,
• record keeping covering the number of bags purchased and issued (light bags, i.e. 15 to 40 microns, and other bags, i.e. 50 microns and over) either on paper or electronically. Owners of several retail outlets must keep separate records for each outlet,
• submit an annual report on the number of plastic bags purchased and issued to customers (so-called packaging and product reports).

From 1 September 2019, the rate of the recycling levy is 20 worse for each piece plastic shopping bags, regardless of their thickness.

The recycling fee may be the total cost of purchasing such a bag or may be added to the price of the bag set by the retailer.

The recycling charge shall be settled quarterly. It shall be paid by the 15th day of the month following the quarter in which the fee was collected.

In 2025, the recycling fee must be paid:

• For Q1 - by 15 April 2025,
• For Q2 - by 15 July 2025,
• for Q3 - by 15 October 2025,
• For the fourth quarter - by 15 January 2026.

Shopkeepers and wholesalers who are obliged to charge a recycling fee are also required to obtain an entry in the BDO register. An application for entry must be submitted prior to the commencement of operations commercial. For selling plastic bags to customers without the required entry in the BDO, a trader can be fined between PLN 5,000 and PLN 1 million!

Want hassle-free paperwork? Entrust your BDO registration to the experts at Interzero!

After registration with BDO you will receive a registration numberand the province marshal will create an individual account for your company in the system and send you a login and password. An account in the BDO register is necessary for the submission of the annual report on the number of bags with a thickness of 15 to 49 micrometres and 50 micrometres and above purchased and issued to customers - this obligation can only be fulfilled electronically!

Find out the answers to the most common questions about the plastic bag recycling charge.

Entities that discharge gases or dust into the air and landfill waste are required to submit annual reports and calculate the fees due. These obligations stem from the Environmental Protection Law and apply not only to companies, but also to institutions, individuals and other entities that use the environment.

The environmental report is a document prepared annually by companies, institutions and individuals using the environment. It contains information on the extent to which the entity concerned has used the environment and the level of chargesthat he should bear as a result.

A report on the use of the environment may consist of one or more lists - the number and type of lists depends on the type of activity carried out by the entity concerned and the extent to which it has used the environment.

A report on the use of the environment must be submitted entities which in a given calendar year:

• introduce gases or dust into the air originating from various processes (e.g. boiler house, use of company internal combustion vehicles, poultry rearing or breeding),
• had emission allowances issued,
• dumped waste.

These entities include:

• entrepreneurs (also foreign),
• organisational units that are not businesses (e.g. foundations, associations, schools),
• persons engaged in agricultural production activities, e.g. farming, animal husbandry, horticulture, vegetable farming, forestry and inland fishing,
• other natural persons who use the environment to the extent that a permit is required.

Importantly, there is no obligation to submit a report if the calculated annual fee for one type of environmental use does not exceed PLN 100.

The environmental use report for a calendar year must be submitted by 31 March of the following calendar year.

This means that the deadline for submitting the environmental use report for 2024 is 31 March 2025. We would like to remind you that the deadline for payment of the fees calculated in the report expires on the same day!

Find out more about the environmental levy >>

A report on the use of the environment shall be submitted to the marshal of the province having jurisdiction over the place of use of the environment:

• in person (during a visit to the marshal's office),
• by letter,
• electronically (via ePUAP), signing the document with a qualified signature or trusted profile.

Environmental users may also entrust the preparation and submission of the environmental inventory to Interzero's experts. We have been fulfilling reporting obligations for our clients for many years. We therefore have a long track record and a wealth of experience in providing comprehensive, professional services to various environmental users. Write to us at our e-mail address or use the contact form. We will help you identify your responsibilities and file the necessary documents on your behalf: quickly, reliably and without taking up your time.

Explore our full range of environmental reporting >>

If you use the environment, then You can also prepare the report yourself by filling in:

• mandatory: a list containing a summary of information on the scope of use of the environment (if the fee for use of the environment exceeds PLN 100),
• if you introduce gases or dust into the air: a list containing information on the amounts and types of gases or dust which are introduced into the air,
• if you have emission allowances: an inventory containing information and data on the volume of greenhouse gas emissions covered by the emissions trading scheme and the number of emission allowances and the amount of fees payable,
• if you store waste: a list containing information on the waste deposited.

Current you will find models for these lists in the annexes to the Regulation Minister of Climate of 11 December 2019 on lists containing information and data on the scope of use of the environment and the amount of fees payable (Journal of Laws 2019, item 2443).

The EcoPłatnik application, which is made available by some Marshal Offices, helps to prepare the report. However, once the report has been prepared, it must be submitted in one of the forms mentioned above.

Find out the answers to the most common questions about the environmental use report.

The Environmental Protection Law imposes an obligation on those using the environment to pay an environmental fee. If your company's activities have an impact on the environment, it is probably your responsibility to calculate and pay the fee. Who should pay the fee and by when? Where is the best place to check the current environmental fee rates? We suggest.

Entities using the environment are required to pay a fee for this, sometimes referred to as an environmental charge. It is a kind of compensation for environmental damage natural resources resulting from the activities of a company, an institution or an individual.

Obligation to pay an environmental fee covered activities:

• resulting in emissions of gases or dust,
• requiring the possession of emission allowances,
• involving waste disposal.

The amount of the environmental fee depends mainly on the amount and types of dust and gases introduced into the air and the amount and type of waste stored, as well as the duration of storage.

Funds raised from fees are mainly allocated to national and provincial environmental funds.

Environmental charges must be paid by environmental beneficiaries, which include:

• entrepreneurs,
• organisational entities which are not entrepreneurs,
• persons engaged in agricultural production activities,
• other natural persons who use the environment to the extent that a permit is required.

Obligated entities They must also determine the amount of the fee themselves for the calendar year in question and then pay it into the appropriate bank account. The amount of the annual environmental fee shall be calculated in the environmental report.

NOTE: an environmental fee is not payable if it does not exceed PLN 800 for one type of environmental use (e.g. for the introduction of dust and gases).

Environmental charge rates changes in each reporting year. The list of rates is published in an annual notice by the Minister for Climate and Environment.

The calculation of the fee for the introduction of gases and dust is made on the basis of the annual volume of actual emissions specified in the report to the National Database on Emissions of Greenhouse Gases and Other Substances kept by the National Centre for Balancing and Managing Emissions IOŚ-PIB (KOBiZE).

Entities that use the environment without having a legally required permit or decision must pay an increased fee. Need support in obtaining permits, authorisations or decisions? Entrust the preparation of all environmental documentation to Interzero!

The upper unit environmental charge rates in force in 2024 were as follows:

• 512.23 PLN/kg of gases or dust introduced into the air,
• 375.25 PLN/Mg (tonne) of waste placed in the landfill.

You will find the unit charge rates for the individual gases, dusts and wastes in the table attached to the the announcement of the Minister for Climate and Environment of 4 August 2023 on the rates of environmental charges for 2024. If you are paying a charge for gases or particulates introduced into the air from combustion processes in diesel internal combustion engines, then for the purposes of calculations use the updated rate from the announcements of 3 November 2023.

The upper unit rates for environmental charges in 2025 were set at the following level:

• 570.62 PLN/kg of gases or dust introduced into the air,
• PLN 418.03/Mg (tonne) of waste placed in the landfill.

You will find the unit charge rates for the individual gases, dusts and wastes in the table attached to the Notice from the Minister for Climate and Environment of 28 July 2024 on the rates of environmental charges for 2025.

The environmental fee is payable by 31 March of the current year for the previous year. This means that the environmental fee for 2024 must be paid by the deadline of until 31 March 2025. (Monday).

You should pay the environmental fee to the account of the marshal's office Competent for the place of registration of the entity using the environment (for gases and dust) or for the place of use of the environment (for others).

The financial consequences of using the environment do not apply to the smallest entities whose activities have little impact on the environment - an environmental fee is therefore not paid, if it does not exceed PLN 800 for one type of environmental use (e.g. for the introduction of dust and gases).

Entities for which the calculated fee for one type of environmental use is between PLN 100 and PLN 800 are only obliged to submit a list of the scope of environmental use. If the fee is less than PLN 100, it is not necessary to submit the list.

One of the annual obligations of those introducing packaged products, packaging and certain types of products is to prepare a report in BDO. What is the scope of the packaging report at BDO? Who has to submit it and by when? Find out the most important information about the product, packaging and waste management report.

The packaging report is a document containing information on the quantities and types of the packaging and products that the trader has placed on the market during the calendar year in questionas well as types and masses the packaging and post-consumer waste that the undertaking has recovered and recycled in this period.

The catalogue of packaging and products to which the report on products, packaging and the management of waste from them applies includes:

• wrapping, transport and packaging, including plastic bags covered by the recycling levy,
• Tyres,
• oils and greases,
• vehicles,
• electrical and electronic equipment (including waste),
• batteries and accumulators,
• selected single-use plastic products,
• fishing gear.

The exact scope of the report on products, packaging and the management of waste arising from them depends on the type of activity carried out by the company in a given calendar year.

Among others, the following are required to submit a packaging and product report to BDO for 2024:

• producers and exporters of packaging,
• manufacturers, exporters, importers and traders making intra-Community deliveries of packaged products,
• those introducing single-use plastic products covered by the SUP Act,
• wholesalers of oils, lubricants and tyres (including automotive shops and wholesalers),
• retailers of household appliances, consumer electronics and other electrical goods,
• vehicle dealers and importers,
• shops and wholesalers that offer plastic shopping bags to customers,
• bail system operators (representative entities),
• authorised representatives of producers of electrical and electronic equipment.

The full catalogue of entities obliged to submit an annual report on products, packaging and the management of waste arising from them can be found in Article 73 of the Waste Act.

Entrepreneurs who are required to submit a report must be registered with BDO and assigned an individual registration number! If your company has not yet obtained an entry, Take advantage of our support in registering with BDO.

The packaging and product report shall be submitted by 15 March of the current year for the previous year.

In 2025. deadline for submission of the report on products, packaging and the management of waste arising therefrom for 2024 falls on Monday 17 March 2025 r. - 15 March is a Saturday and therefore a public holiday, which postpones the deadline to the next working day, which is precisely 17 March 2025.

Businesses that have ceased operations are required to submit a packaging report within seven days of the date of termination.

A report on products, packaging and the management of waste arising from them must be submitted electronically, through an individual account in the BDO system. The report sent will go to the marshal of the province with jurisdiction over the place of business.

You can fill in your BDO report on products, packaging and the management of their waste yourself or with the help of Interzero experts.

• How to submit the BDO 2024 report yourself?

Log in to your account in the BDO system. From the menu on the left, select "Reporting"and then press the "Reporting on products, packaging and waste management". Once in the list of reports, click on the button "+ New report. You will be redirected to a form containing fields in which you should enter your company details.

• How do I hand over reporting in BDO to Interzero's environmental experts?

Want save time and avoid costly mistakes? Do you prefer to focus on your business and leave the paperwork to the experts? We would be happy to take over your reporting duties at BDO. Fill in our contact form i describe the support you need. Our expert will contact you immediately to get to know your expectations and discuss the details of the cooperation.

Choosing Interzero you gain peace of mind, security and the assurance of reliable, timely performance of your duty reporting. You will also have access to the My Interzero portal, with the help of which you can quickly and conveniently provide us with the quantities and weights of the packages and products you have entered. We will take care of the rest!

Do you also have other reporting obligations? Find out what other reports we can prepare on your behalf!

Each report on products, packaging and the management of waste arising from them shall include a set of information identifying the submitting entity (i.e. your company) and information on the type of products and packaging being introduced.

The specific scope of the BDO packaging report will depend on the category of covered businesses your company falls into.

The section identifying the entity (Section I of the report) includes:

• the name of the entity,
• address of residence or registered office,
• BDO registration number,
• VAT number (if applicable),
• European tax identification number (only for certain introducers of batteries and accumulators).

In the following sections you will find information on products and packaging introduced. Check the indicative scope of the reports for:

• Packaging and packaging waste
• Plastic bags
• Oil, grease and tyres
• Plastic disposables
• Vehicles
• Electrical equipment
• Batteries and accumulators

Remember, that the exact scope of its report on packaging, products and waste management you can check after logging in to your account in the BDO system.

Find out the answers to the most common questions about the report on products, packaging and the management of their waste.

Chemical recycling, also known as feedstock recycling, is a waste treatment method using heat or chemical agents. Experts see it as an opportunity to manage contaminated and heterogeneous fractions that cannot be recovered by mechanical recycling methods.

The beauty industry has to comply with new regulations on hazardous waste records from 2025.