Global warming accelerates - Earth's average temperature will rise by 1.5 degrees C in three years' time
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CO2 emissions up, carbon budget down
An annual update of key climate system indicators has revealed that in just three years the Earth's average temperature could rise by 1.5 degrees C compared to the pre-industrial era. As scientists point out, the main reason for this is the ever-increasing emissions of CO2, methane and other greenhouse gases.
In 2020, scientists calculated that humanity could emit a maximum of 500 billion more tonnes of CO2 to maintain at least a 50% chance of stopping global warming below 1.5 degrees C. The then defined "carbon budget" in 2025. has shrunk to just 130 billion tonnes of CO2. In developing the latest findings, the researchers used an improved method of calculating key indicators, which further revealed the scale of the problem. With global emissions of around 40 billion tonnes of CO2, So we have about 3 years left until this "budget" is exhausted and to exceed the symbolic threshold of 1.5 degrees C.
According to one of the report's lead authors, Professor Piers Forster, Director of the Priestley Centre for Climate Futures at the University of Leeds, "Everything is going in the wrong direction". Every year, scientists note an increase in emissions from fossil fuel combustion, industrial activities, land cultivation and deforestation.
"We are seeing some unprecedented changes, and we are seeing that the warming of the Earth and the rise in sea levels are also accelerating. [...] These changes have been predicted for some time and we can directly transfer them to very high levels of emissions", Forster added.
At the same time, the report's authors emphasise that rapid and decisive emissions reductions (such as those pledged at COP28 at the end of 2023) could slow the rate of increase in global average temperatures by up to half over the next 20 years.
Learn about Interzero's contribution to climate and resource conservation >>
The Paris Agreement is not working - the Earth's average temperature has exceeded its target level
Across the globe, attempts have been made for years to reduce emissions and associated global warming. In 2015, under the Paris Agreement 195 countries of the world have committed to develop long-term action plans to reduce greenhouse gas emissions in such a way as to limit global warming to less than 2 degrees Celsius, with a target of 1.5 degrees Celsius relative to the pre-industrial era. Less than 10 years later, in 2024, global average temperatures were recorded for the first time to exceed the assumed 1.5 degree increase relative to the late 19th century.However, scientists emphasise that one year of overruns does not yet mean a breach of the Paris Agreement. They point out, however, that human activity was the main cause of the high temperatures last year.
"Temperatures have been rising year on year since the last IPCC report in 2021, showing that climate policy and the pace of climate action have not kept pace with what is needed to curb the ever-increasing impacts of the" - Professor Foster pointed out - ".Continued record high greenhouse gas emissions mean that more and more of us are experiencing dangerous levels of climate change impacts."
The climate is currently warming at a rate of around 0.27 degrees C per decade. Between 2015 and 2024, the rate of warming was more than double that of the 1970s and 1980s and an estimated 25% higher than in the late 2000s and 2010. Without significant emission reductions, around 2030, we will exceed the Paris Agreement ceiling of 1.5 degrees C. The next threshold, 1.6 or 1.7 degrees C, on the other hand, could be exceeded in the next nine years.
Read also: Net zero at risk - will the EU achieve climate neutrality by 2050?
Combating the effects of climate change drains the Polish budget
The effects of global warming are already taking their toll on the Polish taxpayer. The IOŚ-PIB has estimated that due to extreme weather events, every year Poland loses around 6 billion PLN. Cumulative losses for the period 2001-2019 amounted to as much as PLN 119 billion. Particularly severe for Poland are prolonged droughts, the frequency of which in 2010-2019 increased by as much as double compared to previous decades. This is followed by river floods, storms and intense rainfall, heat waves and tornadoes.
From 2050 onwards, climate change could cost Poland up to PLN 124 billion a year, equivalent to 2.2% GDP. This will happen if Europe and the world slow down the green transition towards low-carbon economies. With consistent implementation of the climate targets set there is an opportunity to reduce annual expenditure to 1.5% GDP, or 84 billion PLN. Current public spending on climate and air protection, on the other hand, amounts to... 0.2% GDP. As the report's authors report, this is more than 2 times less than fossil fuel subsidies and more than 3 times less than budget revenues from the sale of emission allowances.
"We are already suffering the real losses of progressive climate change, although in the public debate we often still treat it as a topic of the future" - says Alexander Sniegocki, co-author of the report The costs of climate change in Poland. Why does Poland need an active climate policy?, president of the Reform Institute and head of economic analysis. "Without investment in resilience and adaptation, Poland will not only be poorer, but also less safe and increasingly helpless against the effects of avoidable phenomena.".
International Court of Justice will examine states' climate protection obligations
From the above paragraphs and the scientific statements quoted, one can conclude that countries are still not making adequate efforts to combat climate change. Steadily rising emissions and global temperatures, as well as insufficient investment in pro-climate measures, clearly suggest that the current and future state of the environment is not a priority for those in power. However, this may soon change - The International Court of Justice is currently working on an advisory opinion that will set out the climate protection responsibilities of states and the consequences of not fulfilling these obligations.
The ICJ began proceedings in March 2023 at the request of the UN General Assembly. The issue of clarifying the obligations of states was raised by Vanuatu, which could be very affected by changes related to global warming. While the ICJ's opinion will not be binding on UN states, the can significantly influence the future direction of their climate policies. If the ICJ decides that tackling global warming and reducing emissions are the legal obligations of states, the will provide activists, NGOs and lawyers with strong arguments in legal processes against countries, companies and lobbyists, among others. Such an opinion can be a turning point in global climate policy, setting new legal standards and becoming one of the bases for judgments by national courts. Indeed, ICJ opinions are interpretations of international law, including human rights, which are inviolable and inalienable.
The Court is currently accepting positions submitted by States, the UN and NGOs. Due to the vast amount of material to be analysed, An opinion is not expected until the end of 2025 at the earliest.
Sources:
- M. Foster et al, Indicators of Global Climate Change 2024: annual update of key indicators of the state of the climate system and human influence, https://essd.copernicus.org/articles/17/2641/2025/
- Poynting, Three years left to limit warming to 1.5C, leading scientists warn, https://www.bbc.com/news/articles/cn4l927dj5zo
- Scientists find three years left of remaining carbon budget for 1.5°C, https://climate.leeds.ac.uk/news/scientists-find-three-years-left-of-remaining-carbon-budget-for-1-5c/
- New report: Poland is paying billions for the effects of climate change - and will pay more and more, https://www.clientearth.pl/najnowsze-dzialania/artykuly/nowy-raport-polska-placi-miliardy-za-skutki-zmiany-klimatu-i-bedzie-placic-coraz-wiecej/
- Stefańczyk, A. Śniegocki, M. Wojtyło, Climate change costs in Poland. Why Poland needs an active climate policy, https://www.clientearth.pl/media/hljdm1s3/koszty-zmiany-klimatu-w-polsce.pdf.
- Can the UN force countries to do more to tackle climate change?, https://www.f5.pl/zmiany-klimatu/czy-onz-moze-zmusic-kraje-do-wiekszych-wysilkow-na-rzecz-przeciwdzialania-zmianom-klimatu
Government implements EU battery regulation. We know the assumptions of the draft law
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The battery regulation has entered into force, we are still waiting for the Polish law
Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 on batteries and waste batteries entered into force on 24 February 2025. The new regulation broadens the information obligations of producers towards consumers, obliges specific labelling of batteries and emphasises recycling and circularity.
The battery regulation obliges battery manufacturers to, among other things:
- implementation of due diligence procedures in supply chains,
- labelling and marking of batteries,
- the use of recycled materials to manufacture new batteries,
- to produce a carbon footprint declaration for the batteries produced,
- ensure the separate collection and treatment of batteries,
- achieving the collection rates for portable and LTM batteries set out in the regulation,
- accepting waste batteries from end-users free of charge.
Most of these obligations come into force on 18 August 2025. As the deadline for the implementation of the regulations approaches, the Ministry of Climate and Environment has drafted the assumptions of the Battery Act, which has been published in the Government's legislative work list (project number UC107). The draft law is intended to ensure the effective application of the regulation's provisions in Poland. The current Act of 4 April 2009 on batteries and accumulators will be repealed in its entirety.
There will be a Polish ROP for batteries and new BDO functionalities
One of the key objectives of the Polish law is introduction of an obligation for battery producers to conclude a contract with a producer responsibility organisation (PRO Producer Responsibility Organisation). This is particularly important in the context of the large number of importers from outside the European Union - the new rules are intended to counter the phenomenon of 'free riders', i.e. companies avoiding environmental obligations.
The national act will also provide a legal framework for the operation of producer responsibility organisations, including a procedure for authorising the fulfilment of extended producer responsibility obligations for batteries. The liability organisation will be required to conclude agreements with collectors and waste battery treatment facilities. Its activities will not only be monitored by the relevant authorities, but will also be subject to a mandatory external audit at least every three years.
The Battery Regulation requires Member States to designate one or more bodies to fulfil extended producer responsibility obligations and to establish a register of battery producers. In Poland, this register will be the BDO already in place, which will include information on the types of batteries first made available by a producer on the Polish market and how it complies with its ROP obligations.
Obligation to appoint an authorised representative for foreign introducers
Under the Battery Ordinance all manufacturers selling batteries to end-users from other Member States and by means of distance communication are obliged to designate authorised representative for ROP in each of these Member States. This obligation derives directly from the Regulation and will be applied directly as early as 18 August 2025. It applies to introducers of all types of batteries, including those built into appliances, light transport or other vehicles.
Product fee for batteries and accumulators under new rules
According to the IEA's plans, the draft Battery Act will clarify the rules for collecting, storing and processing used batteries, including those used in electric vehicles and industrial installations. It will also specify the rules for calculating and paying the product levy for a battery that will be imposed on producers failing to meet minimum collection rates. We can also expect an update of the current product fee rates for batteries - the new Battery Act will set a minimum and maximum rate for this fee, and the actual rates for waste portable batteries and waste LMT batteries will be set in an implementing act issued on the basis of statutory delegation.
A deposit fee charged to customers when they purchase SLI batteries will also be introduced, with the obligation to return it after the used cell has been returned. The unclaimed deposit fee will go into a special account of the provincial marshal.
Authorised representative of the manufacturer - who is he and who must appoint him?
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EU rules impose an increasing number of obligations on businesses in relation to extended producer responsibility. One of these is the need to appoint an authorised representative in individual Community markets. As the Interzero Group, we offer this service to all companies operating within the EU. However, before get to know our offer, check what you need to know about the manufacturer's authorised or authorised representative.
Who is an authorised representative and what is their role?
An authorised representative is a natural or legal person established on the territory of an EU Member State who is a representative of a foreign manufacturer (manufacturer, introducer) in the Member State concerned. Authorised representative shall act under the written authority of granted to it by the manufacturer and fulfils the obligations relating to the placing of goods on the market in the Member State concerned (ensures that products comply with EU requirements, provides information and documentation on product compliance on request of authorities, cooperates with supervisory authorities on conformity assessment, inspection and enforcement, ...). These obligations may arise, for example, from local extended producer responsibility legislation or from legislation issued in implementation of the SUP Directive and the PPWR Regulation.
Example 1: Company X is based solely in Poland. It has recently started selling its products to customers in the Czech Republic, Slovakia and Hungary - it is therefore perceived as a foreign manufacturer in these markets and is entitled to appoint an authorised representative, e.g. for extended producer responsibility.
Who is required to appoint an authorised representative?
Both EU legislation and national regulations in many Member States oblige certain manufacturers to appoint a local authorised representative. This usually applies to companies that are not established in the Member State concerned and sell their goods (mainly packaging, batteries, electrical equipment) to individual customers located in that country by means of distance communication. Failure to appoint an authorised representative when required may result in fines. An authorised representative can be a natural or legal person established in the EU.
Example 1: Electronics retailer Company A is based in Poland, but also sells its products to individual customers in Germany and Austria. For this purpose, it uses its own online shop and several sales platforms. Company A does not need an authorised representative in Poland - it is established in the country and can fulfil its obligations as an introducer on its own. However, it needs to establish an authorised representative for EPR in Germany and Austria - otherwise it will not be able to legally sell its goods to foreign customers.
Example 2: Polish Company B manufactures small domestic appliances in its own factory, which it then sells to electronics wholesalers in Spain, Portugal and Greece. Company B only operates in the B2B sector, so it does not need to appoint an authorised representative in any of these markets. Importantly, at the same time, it has the right to appoint an authorised representative in each country, which it can exercise at any time.
Example 3: Chinese company Z sells packaged products via online platforms Temu and AliExpress. Its customers are mainly individuals residing in EU countries. Company Z will therefore need to appoint an authorised representative for EPR and PPWR in all Member States where its customers are located and where regulations are already in place.
Check your packaging licensing obligations in EU countries
Why was the need to appoint an authorised representative introduced?
The aim was primarily ensuring compliance with national and EU law. In this way each EU Member State has gained the ability to enforce obligations on traders placing goods on its market. Foreign traders can no longer evade their environmental obligations without any consequences or hide behind ignorance of local law - if they want to sell directly to consumers, they must appoint (usually for a fee) a representative to take care of cyclical reporting, payment of environmental fees, management of waste from the goods introduced, etc.
The need to appoint an authorised representative is also beneficial in terms of:
- Environmental - the foreign manufacturer must take extended responsibility for the products introduced and bring them into line with local regulations (e.g. SUP, PPWR); this reduces the amount of waste generated and ensure the proper management of waste already generated,
- competitive - all traders offering their goods to customers must comply with identical legal obligations and bear the resulting costs. The risk of placing goods on the market at an undervalued price due, for example, to their failure to comply with restrictive European regulations and the manufacturer's failure to pay all the required environmental fees disappears,
- consumer - the consumer (individual consumer) is assured that all the services offered to him/her the products comply with local regulationsand their manufacturer (importer, intra-Community supplier) will take care of the subsequent management of the resulting waste.
Authorised or authorised representative? What is the difference?
None. The concept of an 'authorised representative' is more frequently encountered in EU legislation and the institution of an 'authorised representative' in Polish legislative acts (however, this is not an absolute rule). In principle, The two institutions are the same and differ only in name.
It doesn't matter whether your company has to appoint an authorized or authorised representative - in any case it is a local representative who will fulfil your specific legal obligations in relation to various goodswhich you market in the Member State concerned.
Authorised manufacturer's representative for PPWR
PPWR Regulation obliges certain companies to appoint an authorised producer representative in each Member State in which they are not established and into which they introduce packaging or packaged products. This obligation covers manufacturers, importers or distributors established in a Member State or in a third country and making available for the first time on the territory of another Member State, directly to end users:
- packaging transport packaging, service packaging or packaging for primary production (disposable or reusable),
- packaged products other than those mentioned above.
Other manufacturers have the right to appoint an authorised representative in the EU markets into which they place their packaging and packaged products. In this way these generators can delegate their time-consuming and knowledge-intensive responsibilities to a professional local entity.
The PPWR also establishes the minimum scope of the power of attorney that the manufacturer shall give to its authorised representative. This should include
- retention of the EU declaration of conformity and technical documentation for a period of 5 years after introduction for single-use packaging and 10 years after introduction for reusable packaging,
- cooperation with national authorities in cases where packaging is found not to comply with local regulations issued in implementation of the PPWR,
- providing the national authorities with all the information and technical documentation necessary to demonstrate the conformity of the packaging,
- making documents available, at the request of the authority, within 10 days of receipt of the request,
- termination of the authorisation if the generator acts in a manner contrary to its obligations under the PPWR.
The parties may also broaden the scope of the duties covered by the power of attorney, but not without limitation. Regulation Indeed, the PPWR prohibits transferring to an authorised representative the obligation to prepare technical documentation and to provide guarantees that the packaging and packaged products introduced have been designed in accordance with the requirements imposed by the law of the Member State concerned.
Authorised representative of a manufacturer for extended producer responsibility (EPR) in the European Union
The RPP Regulation is only part of the EU extended producer responsibility legislation. By Directive 2018/851 of the European Parliament and of the Council of 30 May 2018 amending Directive 2008/98/EC on waste, the general legal framework for the operation of ROP schemes has been set. More Member States have now implemented or are in the process of implementing extended producer responsibility schemes, which also include the institution of an authorised (authorised) representative.
This directive grants all manufacturers placing packaging and products covered by the EPR legislation on the market in a Member State the right to voluntarily appoint an authorised representative for EPR.
You can read more about the institution of the local representative in the article: Authorised representative of the manufacturer - a new obligation for e-commerce businesses in the EU
What about the mandatory appointment of a local representative? The obligation (or lack thereof) depends on the regulations in force in each Member State. For example, in Austria, all traders selling packaging, packaged products, electrical and electronic equipment or batteries and accumulators by means of distance communication to the general public are obliged to have an authorised representative. By contrast, an example of much stricter EPR regulation is Spain, where not only online sellers, but all foreign manufacturers must appoint an authorised representative.
Find out more:
Authorised representative in Poland
Authorised representative in Germany
Authorised representative in Austria
Authorised representative in Spain
Authorised representative in Slovenia
Authorised representative in Croatia
Authorised representative in Italy
What kind of packaging do consumers want? The EKObarometer report identifies the key features
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Ecology and ergonomics priorities in the choice of packaging for everyday products
In the latest edition of the EKObarometer report, an entire chapter was devoted to packaging and its design. To begin with, respondents were asked what factors they pay attention to when choosing packaging for everyday products.
- 24% respondents do not pay attention to the product packaging at all.
- For consumers who pay this attention, the most important things are: the use of easily recyclable, environmentally friendly materials and ergonomics, handiness and comfort of use Each of these 2 responses was indicated by 32% respondents.
- 12% consumers, however, prioritise the aesthetics of the packaging.
We are able to pay more for products in packaging that meets our key requirements. By how much? Most often between 1 and 5% of the product price. Interestingly, we are most willing to pay extra for the greater convenience of the packaging (42%) and only secondarily for the use of environmentally friendly, easily recyclable materials (38%). Few of us want to pay extra for aesthetics - a categorical NO to more expensive but nicer packaging was said by as many as 51% respondents.
Facilities that good packaging should have
According to the participants of the EKObarometer survey, good packaging should present key information about the product packed in it in a simple way. This will enable consumers to consciously choose what they need and use the purchased product comfortably. And what does this mean in practice?
Respondents indicated that good packaging should have:
- unambiguous information on the intended use of the productu (70%) and the use of easy-to-understand pictograms (62%),
- larger subtitles (65%), legible text and simple fonts (70%) and greater contrast between subtitles and graphics (61%),
- opening systems (65%) and elements enabling a comfortable grip and manipulation of packaging (64%).
As many as 63% of the survey participants indicated as "rather important" or "very important" the inclusion of information on the packaging about its correct segregation. Slightly less important (58%) was comprehensible information about the environmental impact of the product. Consumers therefore want to make informed decisions and actions, but they still put their comfort first. Why? One hypothesis is suggested to us by the research report itself.
Packaging needs and difficulties of the silver generation
For the first time in an ECObarometer survey, respondents were asked about packaging design standards in the context of the special needs of senior citizens. Only 11% respondents were of the opinion that the current packaging of everyday products takes full account of convenient use by people with poorer vision, reduced manual dexterity and reduced hand mobility.
Data and forecasts from the Central Statistical Office (CSO) indicate that the number of seniors will increase year on year. In 2022, Poland will have 7.35 million people aged under. 65 years of age, and in 2060 there will be between almost 9 and over 11 million of them. There is no doubt that manufacturers should take into account the needs of such a large group of consumers when developing not only the products themselves, but also their packaging. This is the opinion of as many as 35% respondents. Another 45% of them openly say that facilities for opening and using products are important for all age groups, not just seniors. The EKObarometer report thus indicates that When it comes to packaging, Poles want inclusiveness - not a separate 'senior citizen' packaging design, not minimisation at all costs, but creating packaging in a way that takes into account the needs of each social group and eliminates rather than creates barriers to accessing everyday products.
"Silvers" are a group with underestimated financial potential, globally people aged 50 and older in 2020. [...] accounted for approximately 34% of global GDP. - says Magdalena Sułek-Domańska, Lecturer in Sustainable Marketing at The Chartered Institute of Marketing, among others. - Thus, given the financial and numerical potential of the oldest consumers, it becomes justifiable for companies not only to apply eco-design principles, but also to design in the spirit of the silver tsunami design. This is all the more so because older people are more likely than the majority of the population to be willing to pay more for a product with economical and/or ergonomic packaging.
Designing inclusive, accessible packaging for all social groups can become a manufacturer's competitive advantage and differentiate its products on the shop shelf. Having such a distinctive feature will be particularly important in view of the changes that will be introduced in just a moment regulation of the PPWR.
The anticipated homogenisation and standardisation of the appearance of the packaging of competing brands' products may cause a real earthquake in the market for the cosmetics and household chemicals surveyed by EKObarometer. Even a small step to meet the needs of a social group as large as silvers can empower the manufacturer The company has a strong position on the market and is the first choice for senior citizens. Especially since we are willing to pay from 1 to 5% and even 11 to 20% more for ergonomic and convenient packaging.
The challenge: eco-design in the age of the silver tsunami
Combining eco-design with ergonomics that takes into account the needs of the silver generation will be a major challenge for manufacturers. The minimisation of packaging, introduced by the aforementioned PPWR regulation, is likely to prompt producers to abandon systems that facilitate opening (e.g. stoppers with ribs or tabs) and additional handles and grips. At the same time, designers will strive to 'slim down' the walls of packaging and reduce the volume and weight of their caps.
All the more so because, as Magdalena Sułek-Domańska points out:
Eco-design principles indicate the need to reduce the weight of packaging or the size of labels. Meanwhile, packaging flexibility or too-small fonts are indicated as elements that make it difficult to use everyday products.
What hinders the use of packaging?
Also of interest in the context of seniors (but not only) are the respondents' answers regarding factors that hinder the use of packaging. They indicated as "hindering" and "hindering to a great extent", among others:
- openings requiring the use of force (52%),
- too small or illegible font on the label (51%),
- cumbersome opening and closing system (50%),
- Blending of text with background (47%),
- incomprehensible (e.g. foreign language) lettering on packaging (47%),
- packaging too thinthat tear quickly, e.g. the bottle 'breaks' in your hands (43%),
- the shape of the packaging making it difficult to grasp and pour (40%),
- packaging too large (33%) and too small (31%).
The seventh edition of the ECObarometer report thus highlights a problem with the use of packaging that affects not only the silver generation, but also other age groups. This should be a clear signal to packaging manufacturers and designers that Minimisation must be followed by improved ergonomics in packaging. Seeking to minimise at all costs can be counterproductive and discourage consumers. For this reason, it is important that packaging design not only takes into account the requirements of the PPWR regulation and the specifics of the packaged product itself, but also takes into account the expectations and demands of consumers. All these aspects are linked by our Made4Circle service, which focuses on developing packaging that is environmentally friendly and easy to recycle, yet convenient for the customer.
Sources:
- CSO, Population forecast for 2023-2060, https://demografia.stat.gov.pl/BazaDemografia/Prognoza_2023_2060.aspx
- ECObarometer report, 7th edition, https://ekobarometr.pl/lib/z55kyx/RaportSW132_EKObarometr_VII_SWR-mc0jns97.pdf
SUP law to be amended - EC urges Poland to address shortcomings
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Limited scope of entities and inadequate calculation of fees are the main objections of the EC against the Polish SUP Act
In its letter of formal notice to Poland, the European Commission points to 2 key deficiencies that prejudge the non-compliance of the national law with the EU SUP Directive:
- Flawed definition of "producer"
The definition of 'producer' contained in the Polish Act of 14 April 2023 amending the Act on the obligations of entrepreneurs with regard to the management of certain waste and on the product fee, as well as some other acts, does not cover all activities performed by entities producing and marketing single-use products. As a consequence, the scope of application of the provisions on single-use plastic products is limited - not all entities that should fulfil producer obligations under the SUP Directive have been obliged to do so in the Polish act.
- Incomplete implementation of ROP for single-use plastic products
As the EC argues, the Polish legislation issued to transpose the SUP Directive does not ensure that waste generators properly calculate and bear all the costs of managing waste from single-use plastic products under extended producer responsibility schemes.
2 months to respond and remedy deficiencies
The failure to correctly transpose the directive on single-use plastic products (Directive (EU) 2019/904) gave rise to a letter of formal notice from the Commission. Poland has since had two months to respond and remedy the shortcomings identified by the Commission.
In the absence of a satisfactory response, the Commission may decide to issue a reasoned opinion.
This is not the first indication that the SUP Directive has not been correctly transposed
The June letter of formal notice is already another EC appeal to Poland in relation to the (non-)implementation of the provisions of the SUP Directive. As a reminder, the directive obliged all member states to bring into force the laws, regulations and administrative provisions necessary to implement the directive by 3 July 2021. The Polish SUP Act was not adopted until 14 April 2023. and came into force on 24 May 2023. For almost 2 years the Commission has been urging Poland to implement the provisions of the. Now the situation is repeating itself - although this time it is not the entire directive but only selected provisions, including the ROP provisions for selected single-use plastic products.
In accordance with the provisions of SUP, Member States had until 31 December 2024 to establish an extended producer responsibility scheme covering selected single-use plastic products. (for ROP systems established before 4 July 2018 and for tobacco products with filters and filters sold for use with tobacco products - until 5 January 2023). For the time being, this system is not functioning in Poland.
Read also: The SUP Directive, a half-whistle revolution - new Interzero report.
Source:
- Infringement proceedings: main decisions taken in June, https://ec.europa.eu/commission/presscorner/detail/pl/inf_25_1241
EC withdraws Green Claims Directive that was supposed to regulate green claims
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Green Claims Directive withdrawn, but with chance of return
Reports of the planned withdrawal of the draft directive began to appear in the media in the second half of June 2025. On Friday 20 June This information was officially confirmed by a Commission spokespersonMaciej Berestecki. The Commission's decision caused quite a stir among officials, but also among consumer and environmental organisations, which were surprised by such a sudden turn of events. All the more so as it was taken almost on the eve of the start of tripartite negotiations between the European Parliament, the EU Council and the Commission, aimed at reaching a common position on the legislative proposal.
Despite a clear statement from the EC, there are still chances to return to negotiations on the final content of the directive. The European Parliament and the current Presidency of the Council of the EU declare their readiness to resume the trialogue. One possible future scenario involves modifying the draft to be in line with the legislative vision and the Commission's mission.
No to an excessive burden of obligations on micro-entrepreneurs
As originally envisaged, The directive was intended to cover all businesses offering their products on the EU market. However, for micro-enterprises with fewer than 10 employees and an annual turnover of less than EUR 2 million, it provided for far-reaching simplifications in the substantiation of environmental claims. The purpose of applying these simplifications was to maintain the current level of competitiveness of the smallest companies against the global giants.
As the Commission emphasised, Avoiding excessive burdens (including financial burdens) for micro-entrepreneurs was one of the key objectives of the project Green Claims Directive. So significant, in fact, that departure from this premise prompted the EC to withdraw the draft in its entirety. In fact, during the legislative work in the European Parliament, provisions were introduced into the content of the directive extending the obligation of each independent verification of submitted environmental claims also to entities from the micro-enterprise sector. According to the EC, these changes were contrary to the Commission's policy of simplifying legislation and reducing the administrative burden for the smallest entities.
What was the Green Claims Directive supposed to be about?
The purpose of the Green Claims Directive was to setting the conditions for making environmental statements and to clarify the methods to be used by producers when substantiating their claims. It was also clear from the wording of the draft directive obligation for green claims to be subject to verification by an independent third party. However, the preamble of the draft mentions the need to exempt micro-entrepreneurs from strict requirements for substantiation and verification of environmental claims, which, according to the Commission, could generate a disproportionate administrative burden. It was this exemption, or rather the removal of this exemption, that became the bone of contention and the reason for the EC's withdrawal from further work on the draft directive.
It will be recalled that the original draft directive was presented by the EC in March 2023. The draft's explanatory memorandum cited a study finding that 53.3% of environmental statements "contains unclear, misleading or unfounded information on the environmental performance of products across the EU and across a range of product categories". Moreover, as many as 40% of such statements were unsubstantiated. As part of the verification of the conclusions of the cited study, the EU carried out a follow-up action, the results of which largely coincided with the findings of the study:
For more than half (57.5 %) of the 344 sustainability claims that were assessed, the authorities found that the trader did not provide sufficient elements to assess the veracity of the claim. In many cases, the authorities found it difficult to determine whether the claim related to the whole product or only one of its elements (50 %), whether it related to the company or only to some of the products (36 %) and which stage of the product life cycle it related to (75 %).
The Commission also indicated that the need to regulate pseudo green marketing was part of the overall actions envisaged in the New EU Action Plan and the Green Deal. The resulting changes from the Green Claims Directive were to promote more sustainable consumption contributing to the achievement of Sustainable Development Goal 12.6, which aims to encourage companies, particularly large and multinational companies, to implement sustainability practices and include information on this in their cyclical reports.
Is the withdrawal of the Green Claims Directive a green light for false green claims?
Abandonment of further legislative work on the Green Claims Directive does not mean that consumers will be completely deprived of protection against greenwashing. This will be provided by the ECGT Directive (or 'EmpCo' in English. Empowering Consumers for the Green transition) (Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards the empowerment of consumers in the ecological transition through better protection against unfair practices and better information and transparency), which is awaiting implementation in the legislation of EU Member States. The directive expands the scope of prohibited market practices to include greenwashing and prohibits the display of claims about the environmental performance of products that are not based on clear evidence or certification schemes.
Read more about the obligations imposed by the ECGT Directive and the potential impact of its implementation in the article: EU directives fight greenwashing. Is this the end of environmentalism?
Source:
https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX:52023PC0166
Changes are coming to the environmental decision-making procedure
Newsletter
The amendment will change the rules for issuing environmental decisions
In the last days of April, the climate and environment ministry announced that it was working on a draft amendment to the law regulating the procedure for issuing environmental decisions. Planned changes are to concern mainly the environmental decisions required for investments that have a significant impact on the environment.
As the government website reads, the need to amend the legislation is due to:
the need to improve the quality of environmental impact assessment procedures, seal and streamline the system, identified during the review of existing legislation and identified problems in the application of current legislation.
The amendment is intended to cover almost all aspects of issuing environmental decisions, from the parties to the proceedings, through the applications and the authorities competent to issue the decision, to issues relating to the use of the decision issued.
For the moment only the aims and objectives of the proposed legislation are known. The bill is scheduled to be adopted by the government in Q3 2025.
Electronic applications will go to the district chiefs
The amendment provides for the introduction of an obligation to submit applications for environmental decisions only in electronic form. At the same time there will be a reduction in the number of annexes that the applicant or his/her representative must provide on paper.
This is not the end of the story - the competence of the authorities will also change. Currently, the competence to issue a decision is dispersed - depending on the type of project, the application is submitted to the head of the municipality, mayor or city president. Ultimately, their tasks are to be taken over by the starost. The Ministry of the Environment and Ecology argues that the move is intended to improve the quality of the proceedings. The possibility of delegating cases to the RDEP other than those arising from local jurisdiction will also disappear. As a reminder, until now, the regional directorates with the heaviest workloads were able to transfer some of the pending applications to directorates in other regions.
Consultative and conciliatory bodies with extended competences
The IOC also aims to ensure that the bodies involved in the opinion can subsequently comment on the changes and new solutions introduced during the environmental impact assessment. Furthermore, the authorities will have the opportunity to indicate a different variant of the investment than that proposed by the investor. Currently, they are only entitled to such an entitlement if the option chosen by the developer is not feasible.
The amendment also provides for clarification of the scope of documents to be submitted to the authorities providing opinions and consultations. The body responsible for drafting the document subject to strategic environmental assessment will have to make the results of the monitoring carried out available to the authorities which were involved in the opinion and agreement in the strategic assessment and to the public.
Clarification of the catalogue of parties to proceedings and broader public participation
The amendment to the Act also aims to remove doubts of interpretation concerning, inter alia, the parties to the proceedings and participants on the rights of a party. In addition, the Ministry of Climate and Environment plans to clarify which rights in rem (ownership, lease, usufruct) should be taken into account when determining the catalogue of parties. We are therefore likely to see a closed the catalogue of entities which may be parties to proceedings for an environmental decision.
A significant improvement will be increasing the number of parties subject to the use of notice by public notice. Such a change is intended to allow for more frequent, direct service of notices to parties concerning proceedings.
The amended legislation is also intended to enable the public to participate more widely in the proceedings. In specific situations (if the nature of the case warrants it), it will be possible to extend the deadline for the submission of comments and applications by the public. At the same time, the body competent to conduct the environmental impact assessment will be exempted from the obligation to consider comments and applications received after the set deadline.
New rules for old environmental decisions - what can be expected?
The assumptions of the draft amendment also provide for the introduction of provisions regulating the use of environmental decisions already issued.
- Withholding a decision or revoking immediate enforceability means stopping the investment
An important piece of information for investors is the planned change to the effects of withholding an environmental decision and revoking the rigour of immediate enforceability. Under the proposed regulations, both of these situations will involve the necessity to suspend investment works to the extent that they are reflected in the decision on environmental conditions.
- Extension of the validity of the environmental decision
The authorities are to be guided by the same standardised criteria when extending the expiry date of the decision to confirm the validity of the conditions for implementing the project.
- Validity of the decision independent of ownership rights
In order to avoid non-compliance with the obligations arising from environmental decisions by new owners of installations, the IOC plans to widen the circle of entities obliged to comply with these obligations and to ensure statutory continuity of compliance, independent of changes in ownership and the degree of implementation of the project.
Source: Draft Act amending the Act on providing information on the environment and its protection, public participation in environmental protection and environmental impact assessments, as well as certain other acts, https://www.gov.pl/web/premier/projekt-ustawy-o-zmianie-ustawy-o-udostepnianiu-informacji-o-srodowisku-i-jego-ochronie-udziale-spoleczenstwa-w-ochronie-srodowiska-oraz-o-ocenach-oddzialywania-na-srodowisko-oraz-niektorych-innych-ustaw8
Poland with the worst tyre recycling system in Europe
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The 10 deadly sins of Polish tyre recycling
Poland's tyre ROP has not worked for many years, recovery levels are not in line with EU regulations and the whole tyre recycling system in our country is dysfunctional - these are the conclusions of the report A story that goes round and round developed by the Polish Tyre Recycling Association (PSRO). At the beginning of the publication, the authors list 10 facts that show the scale of the problem.
Among all EU Member States Poland is in the infamous 1st place in terms of the number of unused tyres - we are responsible for 60% of the mass of all untreated tyres throughout the Community! We also have lowest effective recycling rate, the second least demanding ROP regulations on tyres and the second lowest real environmental charges. Consequently:
- Every 4th pneumatic tyre and all solid tyres are not recycled or recovered,
- 1 in 1,000 tyres sold is discarded into the environment,
- Every 4th pneumatic tyre is incinerated in the furnaces of cement works. Every year, around 50,000 tyres go into these furnaces!
Meanwhile, domestic tyre recycling facilities can process 100% of tyres placed on the market. Each year, we buy between 280,000 tonnes and 350,000 tonnes of tyres, while the total capacity of processing plants is over 400,000 tonnes. As PSRO reports:
250 km - this is how many new motorways and motorways each year MAY be made safer, more durable and quieter by using recycled tyre products in their construction
What does the Polish ROP system look like on tyres?
The ROP system for tyres was introduced by the Act of 11 May 2001 on the obligations of entrepreneurs with regard to the management of certain waste and the product fee. It obliged manufacturers and importers to the achievement of the annual targets for recovery and recycling of tyres - they currently amount to:
- 75% for recovery,
- 15% for recycling.
Failure to comply with these obligations means that a product charge of PLN 2.20 per kg of tyres. Find out the most important information about the product levy on cars and tyres for the autocommerce >>.
Each manufacturer and importer is free to choose whether it wants to fulfil the obligations as an introducer on its own or whether it prefers to entrust these to a recovery organisation. Interzero takes over all the duties of tyre introducers, including those of car dealers and other traders. Find out why you should hand over your tyre recovery and recycling duty to Interzero!
Tyre collection and recycling system to be improved - what should the new tyre ROP be?
The PSRO report indicates that the Polish ROP and tyre recycling system not implements the polluter-pays principle", and it is not the responsibility of manufacturers and importers, but of municipalities (including PSZOKs) and tyre recyclers carrying out collections. It is necessary to reverse this mechanism and shift the responsibility to those introducing the. According to the PSRO, this will require, among other things:
- Increase annual levels of recycling (to 50%) and recovery (to 100%) of tyres.
- To also cover solid tyres, which are currently excluded from the ROP, under the extended manufacturer's liability scheme.
- Sealing the tyre recovery and recycling system.
- Adhering to the statutory waste hierarchy - promoting recycling before incineration.
In addition, the authors of the report draw attention to the need for implementation into Polish law of the provisions of the Waste Directive (2008/98/EC) and the Directive amending the Waste Directive (2018/851/EU), which would aim to give priority to recycling over other forms of recovery and to prevent the incineration of separately collected waste (including tyres).
What does tyre recycling look like?
Mechanical recycling (also known as raw material recycling) of waste tyres is the most environmentally beneficial way of managing them. It consists of a multi-stage grind (cutting, crushing, grinding), resulting in rubber pellets.
As the authors of the report point out, submitting tyres for mechanical recycling reduces their carbon footprint by 4 to 5 times compared to incineration. It also significantly reduces water consumption and environmental impact by 76-80%.
How do I send my tyres for recycling? Book a professional waste tyre collection at Interzero! Fill in the short form and get the best offer for tyre disposal >>
What is produced from tyre recycling?
The mechanical recycling process of waste tyres does not only recover rubber granules, but also steel wire and textile cord. The pellets are used, among other things, for the manufacture of:
- bituminous surfaces, e.g. for playgrounds, running tracks and playing fields,
- anti-vibration pads,
- industrial carpets,
- road surfaces (as a component of asphalt).
The recovered steel is remelted and returned to circulation. Textile cord is currently used as an alternative fuel; however, work is underway to use it in thermal insulation materials and in construction and road building.
Used tyres can also be retreadedwhich will make them reusable without having to process them in their entirety. Old tyres are also used to build retention walls in civil engineering (e.g. as barriers on race tracks) and water engineering (e.g. as bumpers).
Sources:
- Polish Tyre Recyclers Association, A story that goes round and round. A report on the long-standing dysfunctions of the tyre recycling system in Poland, including how 25 000 tyres a year end up in wild landfills, https://psro.eu/wp-content/uploads/2024/10/Raport-PSRO-2024.pdf
EUDR: What companies should know about the new EU deforestation regulation
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What is the EUDR?
The aim of the EUDR is to prevent the import of products into the EU market that contribute to global deforestation. In particular, the regulation concerns raw materials such as palm oil, soy, coffee, cocoa, beef (meat), rubber and woodbut also processed products containing these raw materials, such as chocolate, paper or furniture. The EUDR requires companies to ensure that all affected products have clearly not caused deforestation and comply with the legal requirements of the country of production.
For what purpose was the EUDR created?
The EU contributes significantly to global deforestation because there is a demand in the Union for many agricultural products from deforested areas. Not only are forests an important reservoir of CO2 and habitat for many animal species, they are also the basis of life for many indigenous peoples. The EUDR is intended to help stop the conversion of forests to agricultural land and reduce the pressure on natural resource extraction. Another important aspect is the protection of biodiversity and the prevention of illegal displacement of communities and indigenous peoples.
Which products does this apply to?
The EUDR applies to various commodities and their derivatives, including:
- Palm oil
- Soy
- Coffee
- Cocoa
- Beef (but not milk)
- Rubber
- Wood products (including paper, furniture, charcoal)
These products must be or free from deforestation, or include a detailed due diligence statement that proves that deforestation did not lead to the product. It does not matter whether the products were produced in the EU or in other countries - the EUDR applies worldwide.
What requirements are placed on companies?
Companies must prove that their products meet the following conditions:
- Non-deforestation: raw materials must not come from land where deforestation has taken place after 31 December 2020. Furthermore, logging must be carried out in a way that does not harm the forest ecosystem.
- Compliance with the legislation of the producer country: In addition to EU requirements, manufacturers must comply with the national environmental, labour and human rights legislation of the producing country.
- Due diligence statement: The companies' main obligation is to draw up and submit a due diligence declaration. In this declaration, companies must demonstrate that they have gathered all relevant information on the origin and production methods of their products and that the risks of deforestation and forest degradation have been assessed.
How does due diligence work?
Companies that place raw materials or products on the EU market must ensure that their products are free from deforestation through a three-step due diligence process:
- Information gathering: Companies need to collect product information such as origin, quantity and production methods. Geolocation data are used, among other things, to trace the origin of raw materials.
- Risk assessment: Based on the data collected, companies must carry out a risk assessment. Whether the product comes from a country with a high risk of deforestation is taken into account. Products from high-risk countries are subject to stricter requirements that require more detailed analysis and additional risk mitigation measures.
- Risk mitigation: Once a company identifies the risk of deforestation, it must take steps to reduce this risk. This can be done by switching to more sustainable sources of raw materials or by controlling suppliers.
When does the regulation come into force?
The EUDR will enter in life in stages:
- From 30 December 2025.: The regulation applies to large and medium-sized enterprises.
- From 30 June 2026.: Small and micro enterprises will also have to comply with the EUDR.
This approach aims to give companies sufficient time to prepare for the new regulations. Companies must submit due diligence statements and all relevant documentation through the EU TRACES digital information system.
Challenges and criticism
While the EUDR is an important step towards protecting the world's forests, there are also challenges and criticisms around it. Some companies are concerned that the additional documentation requirements and associated bureaucracy will mean considerable effort. Small companies in particular face the challenge of implementing extensive requirements without the necessary infrastructure.
Furthermore, it is uncertain exactly how the various requirements will be implemented and how the regulation will affect companies' procurement costs. It remains to be seen how the regulation will affect international trade, especially if companies in less regulated countries can resort to less stringent regulations.
What does this mean for companies?
Companies need to prepare for the new regulations by being transparent about their supply chains and ensuring that all relevant data on the origin and production of their products is available. To comply, companies should take steps to vet their suppliers and document their due diligence obligations at an early stage.
EUDR ensures that companies operate in a more sustainable manner in the long term and take responsibility for their supply chains. Those who adapt in time can not only make sure they meet the new requirements, but also actively contribute to environmental protection.
Conclusions
EU Deforestation Regulation (EUDR) is a key step in the fight against global deforestation and poses new challenges for businesses. From 2025, companies will not only have to place non-deforestation products on the EU market, but also provide extensive evidence of the origin and sustainability of their products. This regulation helps to protect forests and their biodiversity worldwide and to combat global climate change.
Companies that prepare for EUDR requirements at an early stage have a clear competitive advantage when it comes to implementing sustainable supply chains.
We encourage you to read the article EUDR, or what do forests, consumption and EU regulations have in common? >>
EU to tighten regulations for granulate processing companies. There is an agreement to reduce microplastic spills
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Preventing granular leakage as a priority of new EU regulations
The purpose of introducing new legislation at EU level is to creation of procedures for dealing with plastic pelletswhich will apply at all stages of the supply chain, both on land and at sea.
- Microplastics are everywhere - in the oceans, seas and even in food. Up to 7,300 truckloads of plastic granules enter the environment every year. The EU has today taken a groundbreaking step to reduce this pollution - adopting measures to prevent the release of granules and to ensure their proper handling, including in maritime transport," stresses Paulina Hennig-Kloska, Minister for Climate and Environment.
As the communication reads, each pellet processing installation will have to establish a risk management planwhich will address how to deal with uncontrolled, accidental spillage of microplastics into the environment. It will therefore be the responsibility of the operators to develop procedures for packaging, unloading and loading of the granules, in addition to proper training of personnel and preparation of the necessary equipment.
The planned regulations are already another on the way to reducing environmental pollution from microplastics. As a reminder, in 2023, Commission Regulation (EU) 2023/2055 introduced a series of restrictions on the sale of products to which microplastics are intentionally added (e.g. cosmetics, cleaning products, fertilisers, medical devices, synthetic surfaces in sports facilities). You can read more about this in the article: EU glitter ban.
Equal obligations for EU and non-EU companies, simplification for the smallest entities
Under the new rules obligations concerning the handling of plastic granulate will apply not only to companies based in the EU, but also to non-EU operatorswhich operate on the territory of at least one Member State. This refers mainly to carriers (both inland and maritime transport) and logistics operators providing, inter alia, transport, storage or warehousing services.
According to the EU Council's official website, the scope of obligations for operators will depend on the size of the organisation and the weight of the pellets processed.
- Major players processing more than 1,500 tonnes of pellets per year, will have to be certified by an independent body.
- For smaller companies, also processing more than 1,500 tonnes of pellets per year, there will be a provision for simplified one-stop certification procedure carried out within 5 years of the entry into force of the Regulation.
- Companies handling less than 1,500 tonnes of pellets per year and micro-enterprises will only have to issue their own declaration of conformity.
To ensure compliance with EU regulations, companies not established in the EU will have to appoint an authorised representative in the EU, who will carry out all tasks on their behalf with regard to the microplastics processed and transported. The institution of an authorised representative (ACR) Authorised representative, AR) is no novelty - it already exists both in EU legislation and in the legal orders of most Member States.
Special conditions for maritime transport
Companies transporting pellets and regranulate by sea will also have a the obligation to ensure the quality of packaging and to provide information on transportin accordance with the guidelines of the International Maritime Organisation. This is all the more important because maritime transport accounts for as much as 38% of pellet transport throughout the EU[i]and spills that occur during freight often have a disastrous impact on the environment.
Read more about the ecological consequences of unintentional microplastic emissions in the article: Toxic microplastics in the water - meet nurdle, the mermaid tears you find on the beach.
[i] Data for 2022, https://www.gov.pl/web/klimat/porozumienie-w-sprawie-walki-z-zanieczyszczeniem-mikroplastikiem
When will we see the new regulations?
The interim agreement will now have to be approved by the Council of the EU and the European Parliament. It will then be formally adopted by both institutions (after legal and linguistic review) and published in the Official Journal of the EU.
The new micro-platform legislation will take the form of a regulation. This means that they will apply directly, without the need for transposition into Member States' legal orders. Regulation will enter into force 2 years after publication. In order to facilitate compliance in maritime transport, there is a possibility to defer its application for one year (compared to the other provisions set out in the Regulation).
Sources:
- Plastic pellet losses: Council and Parliament agree on new rules to reduce microplastic pollution, https://www.consilium.europa.eu/en/press/press-releases/2025/04/08/plastic-pellet-losses-council-and-parliament-agree-on-new-rules-to-reduce-microplastic-pollution/
- Agreement on combating microplastic pollution, https://www.gov.pl/web/klimat/porozumienie-w-sprawie-walki-z-zanieczyszczeniem-mikroplastikiem