Many municipalities will not achieve the EU-required levels of preparing for re-use and recycling of municipal waste in force between 2023 and 2025. Local authorities are already protecting themselves against the financial consequences of failing to meet their obligations, and industry representatives are saying straightforwardly: residents should prepare for increases in waste collection fees of up to 10-20 per cent.

Recycling rates in municipalities still too low

The spectre of severe consequences of insufficient waste management hangs over local authorities - the penalties they face are caused by failure to achieve the minimum statutory levels of municipal waste recycling. The problem does not only concern individual municipalities scattered across Poland - its scale is much larger. In 2024, in the Lubuskie Voivodeship alone, as many as 64 of the 82 municipalities failed to achieve the 45 per cent recycling rate.

In a survey conducted in February 2025 by the Association of Municipalities and Districts of Greater Poland, more than 80 per cent of the municipalities surveyed stated that they were unlikely to achieve the recycling minimum target for this year. Thanks to the efforts of the climate and environment ministry, The EC has exceptionally agreed to reduce the recycling rate planned for 2025 by 5 pp, to 50 per cent of the. For some municipalities, however, even the preferential 50 per cent threshold is a distant dream. Piotr Szewczyk, Chairman of the RIPOK Council, points out that the problem will only grow in the near future:

„This 45 per cent that we have to achieve for 2024 is still achievable in our technical conditions and with this kind of separate waste collection. The problem will be in the following years.”

Meanwhile minimum requirements are increasing year on year - in accordance with Article 3b(1) of the Act on Maintaining Cleanliness and Order in Municipalities:

• In 2023, municipalities were required to recycle 35 per cent of the mass of municipal waste.
• From 2024, the minimum recycling rate increased to 45 per cent.
• The next leap was 2025, when municipalities had to recycle 55 per cent of the weight of municipal waste collected.

Of course, the problem with municipal waste recycling does not affect all municipalities. Some municipalities have far exceeded the legal minimum, achieving 60-70 per cent recycling annually. In 2024, the national record recycling rate was as high as 88 per cent.

The problem has been growing for years - the EU and the NIK have been sounding the alarm for a long time

The real risk of not meeting EU requirements has not been known for a while - already in 2018. The EC had sounded the alarm that Poland might not achieve the 50 per cent preparation for re-use and recycling rate required under the then legislation. At the time, the EC's fears were confirmed, and hundreds of municipalities across Poland have received heavy financial penalties. A few years later, the problems with municipal waste management were reported by the NIK - in a report published in mid-2025. Information on the results of inspections of GOZ implementation indicated:

According to NIK, there is a high risk that Poland will not achieve the level of preparation for reuse and recycling of municipal waste required by the EU, i.e. a minimum of: 55 per cent by 2025 (or a lower level as a result of the postponement of the target at Poland's request), as well as a significant risk of failing to achieve the level of their landfilling (maximum 30 per cent by weight in 2025-2029, up to 20 per cent in 2030-2034, up to 10 per cent from 2035). This may result in appropriate penalties being imposed on municipalities (by way of a decision by the provincial environmental inspector), as well as on Poland by the Court of Justice of the European Union.

Even though the required recycling levels will increase at a much slower rate from 2026 onwards (by 1 pp per year, up to 65 per cent in 2035 and beyond), it is still likely that some municipalities will not be able to achieve them.

Penalties for municipalities included in waste collection fees

Problems in municipal waste management are also recognised by waste companies, which, like municipalities, want to prepare for the penalties they face. And the fines will not be small - in 2025. For each tonne of waste below the statutory minimum recycling and PDPU, municipalities will pay more than £433. As Piotr Szewczyk points out, entrepreneurs operating municipal waste systems already include the costs of possible penalties in their contracts with municipalities:

„This share is currently between 10 and 20 per cent, and these are the increases we face in the near future if we don't do anything about it.”

These will not be the first increases, the CSO reported, budget expenditure on municipal waste management increased by up to 70 per cent between 2019 and 2024, from PLN 560 to PLN 970 per tonne. The highest jump in charges was recorded in the Lower Silesian Voivodship (by PLN 494) and the lowest in the Świętokrzyskie Voivodship (by less than PLN 230).

In the absence of a ROP, all additional costs are likely to be passed on to residents in the form of further increases in waste collection fees.

Read also: The controversial ROP bill - aims, objectives and criticisms

The bail system and storage levels will also drive up collection costs

The worries of local authorities do not end with municipal waste recycling - the same Article 3b of the Act on Maintaining Cleanliness and Order in Municipalities in point 2a obliges them to reduce municipal waste landfill.

Municipalities are obliged not to exceed a storage level of:

• 30 per cent by weight - for each year between 2025 and 2029;
• 20 per cent by weight - for each year between 2030 and 2034;
• 10 per cent by weight - in 2035 and beyond.

Meanwhile, the CSO reports that in 2024. nationwide, exactly 30% of municipal waste generated is landfilled[i]. In the current market situation, reducing landfill levels by a further 20 pp in just 10 years seems unlikely. According to Piotr Szewczyk, penalties imposed on municipalities for failing to meet statutory levels could result in a 3-5 per cent increase in the value of contracts with waste companies.

Another factor that will negatively affect the municipal waste budget will be the take-off of the deposit system, which will „deprive” municipalities of access to valuable yellow-bag raw materials - aluminium and PET bottles.

„In the event that the entire stream is taken over by the bail system, ultimately after a transitional period, we have estimated the loss of revenue from not receiving these raw materials at our facilities, as well as from not selling these raw materials and not gaining revenue from DPRs, to be approximately PLN 570 million, which translates into an approximately PLN 1.4 increase in waste management costs per capita,” explained the RIPOK Council chairman.

Read also: Will rubbish charges go up?

Source: https://samorzad.pap.pl/kategoria/srodowisko/branza-odpadowa-szykuje-sie-na-kary-za-recykling-stawki-dla-gmin-wzrosna-o-20

https://www.nik.gov.pl/plik/id,30907,vp,33980.pdf

[i] CSO, Environmental protection 2025, https://stat.gov.pl/obszary-tematyczne/srodowisko-energia/srodowisko/ochrona-srodowiska-2025,1,26.html

In September 2025, the legislative bodies of the European Union adopted an amendment to the Waste Directive, which requires member states to significantly reduce the amount of food waste generated. Community countries have until mid-2027 to implement the new legislation and until 31 December 2030 to meet the exacting standards.

Binding food waste reduction targets from 2030.

On 26 September 2025, Directive (EU) 2025/1892 of the European Parliament and of the Council of 10 September 2025 amending Directive 2008/98/EC on waste entered into force. The purpose of its adoption was to further reducing the amount of waste generated in all EU countries inter alia, by optimising waste management and strictly adhering to the waste hierarchy.

The amendment establishes binding targets for reducing food waste, which must be achieved no later than the end of 2030. EU Member States have been given 20 months to put mechanisms in place to achieve:

• 10% food waste reduction in the production and processing sectors food,
• per capita 30% reduction of food waste at the downstream stages of distribution and use food (in retail and other food distribution, in restaurants and food services and in households).

These targets will be calculated based on the average annual amounts of food waste generated between 2021 and 2023.

Food waste in the EU a generator of social, economic and climate losses

The motivation for adopting the revision of the Waste Directive was not only environmental, but also social and economic. IN THE EU approximately 59 million tonnes of food go into the bins every year, or 132 kg per inhabitant. According to Eurostat, more than half of this mass (72 kg) is wasted in households. At the same time, almost 33 million Community citizens cannot afford a full meal every other day. These figures and the scale of the phenomenon explain why, in recent months, the EU has placed so much emphasis on donating unsold food to redistribution institutions and on making food donations. In addition to humanitarian considerations, food waste also has an impact on the EU economy and climate. Wasted food means losses of up to EUR 132 billion per year and is responsible for 16% of total greenhouse gas emissions from the food system in the EU[i].

Read also: Segregation of bio-waste to be improved - only 9% of food waste is separately collected

30% per capita, or more than 1 million tonnes - that's how much we need to reduce food waste by

According to Eurostat, more than 4.6 million tonnes of food are wasted in Poland each year, of which:

• 1.3 million tonnes during food production and processing,
• 3.3 million tonnes in retail and distribution, restaurants and households.

For Poland, therefore, the introduction of a 30 per cent reduction target for the weight of food waste means that around 1 million tonnes of this waste must be prevented.

How to produce less food waste? The EU gives guidance and leaves the rest in the hands of governments

The EU legislator not only sets ambitious targets, but also proposes measures to achieve them. On the way to meeting the set levels of food waste reduction, EU Member States must at least:

• develop and support actions to promote a change in habits to be more sustainable, including information campaigns to build awareness and improve knowledge on food waste prevention,
• review the food market in order to eliminate practices that contribute to the production of food waste,
• foster cooperation between actors in the food value chain,
• encourage donations and other forms of food redistribution, to avoid unsold products being used for purposes other than human consumption,
• facilitate the development of competencies and the acquisition of financing, especially for the smallest players present on the food production, processing and distribution market,
• foster innovation, which aims to prevent the production of food waste.

In addition to following the guidelines provided in the body of the Directive, Member States may also take their own initiatives for preventing food waste. In addition, they should carry out continuous monitoring of the effectiveness of the implemented solutions using the methodology proposed by the EC in a separate implementing act.

Exemptions and protection for the smallest entities - who will not be covered by the new rules?

The revised Directive requires that the responsibility for meeting the targets set should be shared proportionally among all actors present along the food supply chain, i.e. in primary production, processing and manufacturing, retail and other food distribution. This group also includes companies and institutions operating restaurants and catering services. The EU legislator has emphasised that the involvement of these actors should be commensurate with their capabilities and role in the supply chain. This is to prevent excessive burdens being placed on the smallest market players, especially micro and small enterprises. Following this line of thought, micro-enterprises and farmers will not be covered by the new legislation. The latter are further protected from the unfair practices of large buyers (mainly retail chains), who have often refused to accept contracted agricultural products, resulting in food waste and unintentional losses on the part of food producers.

Also included in the revised Waste Directive are provisions to bring textile waste under extended producer responsibility. Find out more: There will be ROP for textiles - new responsibilities for clothing companies ever closer

[i] Food waste, https://www.consilium.europa.eu/pl/policies/food-waste/

From 1 July 2026, the European Union will impose new temporary customs duties on all parcels worth less than EUR 150 from third countries. In this way, the Community wants to curb the massive influx of cheap goods and balance the competition between local distributors and Asian e-commerce platforms. In parallel, the EU is working on a larger reform package that will comprehensively regulate customs duties on small parcels.

Customs duty on parcels from China - amount and calculation rules

12 December 2025. The Council of the EU has decided that from 1 July 2026, all small consignments originating from third countries and addressed to consignees in the European Union will be subject to a fixed tariff of EUR 3. The new regulations will cover so-called small consignments, i.e. parcels with a value of less than EUR 150, which have so far benefited from customs exemptions.

The new solution applies only to shipments shipped to the EU by non-EU sellers, who are registered in the EU's Import One-Stop Shop (IOSS) system, which is used to handle imports, mainly VAT settlements. According to the EU Council, this mechanism will cover approximately 93% of all e-commerce flows coming into the Union, making it a very broad-based solution.

The new duty of EUR 3 will not replace VAT and will not affect the rules for charging and collecting it. It will be a separate duty which will is intended to partially level the playing field between EU and non-EU sellers, hitherto enjoying privileged market access.

It is worth emphasising that the new duty is also not a so-called handling or administrative fee, which is sometimes discussed in the context of the reform of the EU customs system and the financing of consignment handling. The EUR 3 rate introduced is a fully-fledged import duty, based on the provisions of EU customs law.

Transitional solution until full customs reform in the EU

Introduction of EUR 3 customs duties are temporary in nature - they will remain in force until the EU customs target system is implemented, It is intended to completely remove the duty-free threshold for consignments with a declared value of less than €150 and to facilitate the work of Member States' customs authorities. A key element of the system will be the EU Customs Data Centre - a central platform to calculate and enforce customs duties for all small consignments entering the EU.

Pending the implementation of the new regulations, the EC has committed to carry out regular assessments of the functioning of the customs duty system on small consignments, including considering the appropriateness of extending the tariff also to consignments from traders not registered in the IOSS.

Why has the EU decided on a new duty?

It was intended that new customs duties covering shipments of less than EUR 150 would not be introduced until 2028. Under pressure from the representatives of the Member States, including French Economy Minister Roland Lescure and Italian Economy Minister Giancarlo Giorgetti, the Council nevertheless decided to end the exemption early and impose provisional tariffs as early as 2026.

The hitherto existing duty exemption for consignments up to a value of EUR 150 has, according to the EU institutions, been the source of many systemic problems. Among the most frequently cited are:

• unfair competition towards EU sellers and manufacturers,
• risks to consumer health and safety,
• high level of customs fraud, including the undervaluation of goods,
• negative impact on the environment, related to the mass splitting of shipments into individual parcels.

The need to include small shipments in tariffs is also supported by hard data - according to the EC, in 2024. 4.6 billion parcels with a declared value of less than EUR 150 entered the EU, which amounts to approximately 12 million parcels per day. This is twice as many as in 2023 and three times as many as in 2022.[i] According to experts, the value of up to 65% of such parcels is deliberately undervalued to avoid customs duties. In addition, recently as many as 91% of e-commerce parcels worth less than €150 originated from China, illustrating the scale of the phenomenon.

In the face of these threats to the domestic economy, some Member States were considering introducing their own levies on low-value parcels originating from outside the Community. At the end of 2025, the Italian government announced the establishment of an additional charge of €2 levied on each consignment worth less than €150. Italian Prime Minister Giorgia Meloni indicated that the new levy was intended to increase budget revenues and counteract the flooding of the market with cheap products from foreign e-commerce platforms. According to Italian estimates, the levy was expected to generate €122.5 million for the state budget in 2026 and up to €245 million per year from 2027.

Small shipments, big threat - the Union has no time to waste

The actions of the EU and Member States clearly show that small e-commerce shipments are no longer treated as a marginal element of international trade. With billions of parcels per year, they pose a real challenge to the Community customs system, environmental protection and fair competition.

The temporary duty of €3, which will take effect in 2026, is the first step towards a full inclusion of all goods imported into the EU under uniform customs rules - regardless of their value.

Sources:

1. Customs: Council agrees to levy customs duty on small parcels as of 1 July 2026, https://www.consilium.europa.eu/en/press/press-releases/2025/12/12/customs-council-agrees-to-levy-customs-duty-on-small-parcels-as-of-1-july-2026/

[i] Chamber of the Electronic Economy, Report: Chinese e-commerce platforms and the Polish economy, https://eizba.pl/wp-content/uploads/2025/12/Raport-e-Izby-Chinskie-platformy-e-commerce-a-polska-gospodarka.pdf

The carbon footprint of a PET bottle collected under the deposit system will be several times higher than the carbon footprint of the same bottle collected under the municipal system. Depending on the efficiency of the system and other factors, emissions will increase from 4 g CO₂/pc. up to 11 g CO₂/pc, and as much as 22 g CO₂/pc. On an annual basis, this will represent an increase in total carbon emissions of 96,000 tonnes.

BioVeradi expert report: deposit system triples the carbon footprint of a PET bottle

The introduction of a deposit system in Poland will result in a significant increase in the carbon footprint of the PET bottle - this is the conclusion of the Expert reports Carbon footprint developed by Beata Beata Waszczyłko-Miłkowska, Ph.D., and Jolanta Kamińska-Borak, Ph.D., of BioVeradi. In addition to the positive effect, e.g. the projected improvement in the efficiency of selective collection and recycling and the reduction of environmental litter, the deposit system will also have „side effects”, the scale of which can be seen by analysing the data from the report.

According to the authors' calculations, the emissions associated with the current municipal household waste collection system amount to approx. 4 g CO₂ per bottle. However, in the scenario of a fully functioning deposit system (100% collection), the carbon footprint of a single bottle reaches more than 11 g of CO₂. This result can only be achieved in the most optimistic of the analysed variants, in which not a single PET bottle with a deposit symbol ends up in the yellow bag. As the experience of countries where deposit systems have been in place for many years shows, it is virtually impossible to achieve 100% collection rates, especially in the initial period of operation. For this reason, in Expertise estimates for a 50 and 77 per cent collection rate within the system were also included.

• The highest carbon footprint of a PET bottle occurs in the 50% variant of system efficiency bail and is 16 g CO₂. It is mainly due to the parallel operation of 2 systems: the municipal and the deposit systems, which leads to duplication of waste logistics processes.
• With the statutorily required level of separate collection of PET bottles under the deposit system, the calculated carbon footprint of a single pack is 12 g of CO₂ and is 3 times higher than the current carbon footprint recorded in the municipal system.

As the report's authors report, the biggest contributor to the increase in emissions in the deposit system are the processes involved in collecting PET bottles (reverse logistics, use of bottle dispensers). The contribution of consumer transport alone to CO₂ of the bail system averages around 45%!

Communal collection generates less CO₂ than the deposit system.

The BioVeradi report is the first study of its kind to examines in detail the post-consumer phase (i.e. collection, transport and sorting of waste) and takes into account all the most common types of PET bottles marketed in Poland (from 0.33 l to 2 l).

The authors of the report not only present previously unknown data, but also call for their findings and calculations to be taken into account by regulators and legislators:

The result remains consistent: the municipal system gives a stable, low and acceptable level of emissions, while the introduction of a deposit system increases the carbon footprint and causes a negative environmental effect. This fact should be explicitly taken into account in the decision-making process on the shape of future waste management in Poland.

The expert report is based on a comprehensive calculation model that allows the impact of various factors, e.g. logistics, consumer and technology, on the total carbon footprint of a package to be assessed. 109 scenarios were analysed differing, among other things:

• efficiency of the deposit system (50, 77 and 100% collection of PET bottles up to 3 l),
• the share of individual car transport in delivering empty bottles to collection points (30, 50 and 75%),
• the share of bottle machines in the collection (50 and 75%),
• the level of allocation of returnable transport (PET bottles and beverage cans account for 30, 50 and 100% of the weight of freight carried, respectively),
• the number of logistical stages (2 and at least 3 stages).

In none of the scenarios presented did the bail system prove to be more advantageous than the municipal system emissions in terms of CO₂ - Even with 100% effectiveness of the deposit system, the lowest emissions would be 172 g CO₂/kilo PET bottles, while with 100% effectiveness of the municipal system they would reach 144 g CO₂/kilo PET bottles. It is worth noting that this most optimistic deposit scenario assumes the complete abandonment of the use of the car to deliver bottles to collection points, which is unrealistic in the current situation, especially in sparsely urbanised areas.

Other conclusions from Expert reports Carbon footprint

• Each year in Poland uses an average of 13.5 billion PET bottles. Changing the collection method from a municipal system to a deposit system may increase the total CO₂ from around 55,000 tonnes to around 150,000 tonnes per year.
• Regardless of the scenario analysed, emissions in the municipal system remain relatively constant. In contrast, bail system emission levels are largely determined by consumer behaviour.
• Even not using transport will not equate the carbon footprint of a PET bottle in the deposit system (5 to 9 g CO₂) with the footprint in the 100% municipal system (4 g CO₂).
• Due to the reliance of personal transport and waste logistics on vehicles with fossil fuel engines, possibility reduction in the carbon footprint of PET bottles collected through the deposit system is significantly reduced.

Source:

1. Dr.-Ing. B. Waszczyłko-Miłkowska, Dr.-Ing. J. Kamińska-Borak, Expertise Carbon Footprint, https://bioveradi.pl/wp-content/uploads/2025/10/BioVeradi-sp.z-o.o.-Slad-weglowy-pdf.pdf

Directive 2024/3019 will take care of water purity

From 1 January 2025, Directive (EU) 2024/3019 of the European Parliament and of the Council on the treatment of urban waste water (the so-called Wastewater Directive) applies, which obliges EU Member States to make numerous changes to the way they manage waste water. This is the first revision of the EU's urban wastewater treatment legislation in 33 years and aims to address current challenges in wastewater management.

One of the key elements of the Wastewater Directive is the introduction of extended producer responsibility (ROP) for micropollutants in wastewater. As intended by the EU legislator, a key element of the ROP will be the obligation to cover the 80% costs associated with the construction and operation of the fourth stage treatment facility by those responsible for introducing the majority of micropollutants into municipal wastewater. This group mainly includes pharmaceutical and cosmetics manufacturers. The remaining 20% of investment and operating costs will be covered in the existing way, i.e. from the budgets of local governments (usually municipalities).

Micropollutants and new challenges for the treatment system

According to the European Commission, pharmaceutical and cosmetic product residues are currently the main source of micropollutants in municipal wastewater. These substances, even at very low concentrations, can damage aquatic ecosystems, disrupt the endocrine balance of organisms and accumulate in food chains.

In order to remove them effectively, so-called fourth-stage cleaning is needed, which includes ozonation, activated carbon adsorption, membrane filtration and advanced oxidation processes (AOPs). However, adapting existing treatment plants to the requirements of this method is very costly - involving significant investment in infrastructure, followed by high operating and maintenance costs. As intended by the EU legislator, The costs of this clean-up phase will be passed on to producers at a minimum of 80%.

Read also:  When is it necessary to submit a notification for the upgrading of an existing wastewater treatment plant? Key information about the notification of an installation that does not require a permit

The amount of producers' mandatory ROP contributions will depend on:

• the quantities of substances present in the wastewater that are identical to those used by the company in question in its products,
• the degree of harmfulness of these substances.

At the same time, pharmaceutical and cosmetics manufacturers will be required to fund at least 80% costs of monitoring micropollutants and collecting and reporting data on products and their residues.

How will the ROP system for micropollutants work?

Extended producer responsibility for wastewater micropollution will include:

• manufacturers of medicinal products for human use covered by Directive 2001/83/EC of the European Parliament and of the Council,
• manufacturers of cosmetic products covered by Regulation (EC) No 1223/2009 of the European Parliament and of the Council.

By producer the Directive means not only the manufacturer of the product, but also its importer, distributor and seller (including distance sellers using their own online shop or sales platform). All of these operators will soon have to partner with producer responsibility organisations to collect and manage the financial contributions made under the ROP. These organisations are to operate on similar principles as in other ROP schemes (e.g. for packaging or electro-waste) and transfer the funds to the treatment plant operators.

The following may be exempted from the ROP obligations exempted operators who place on the market less than 1 tonne of substances per year or prove that their products are biodegradable and do not generate micropollutants. By the end of 2027, the European Commission will develop common criteria for assessing biodegradability and environmental risks, which will form the basis for these exceptions.

The new role of the producer responsibility organisation (PLO)

Producer responsibility organisations will become the financial and operational pillar of the new system. They will:

• collect data on products, their quantities and composition,
• charge ROP according to the type of substance used,
• transfer funds for the modernisation and operation of the treatment plant,
• conduct financial audits and report results,
• carry out education and information activities.

Member States, including Poland, will have to establish national procedures for the recognition and supervision of producer responsibility organisations, which requires the implementation of new national legislation implementing the provisions of the directive.

Challenges for the pharmaceutical and cosmetics industry

For pharmaceutical and cosmetics manufacturers, the new regulations mean not only financial obligations, but also the need to adapt production, reporting and testing processes.

Companies will have to:

• analyse the composition of their products for substances that fall under the scope of sewage micropollutants,
• develop a system for reporting data on substances and their biodegradability,
• modify the financial models to include ROP costs,
• invest in research into biodegradable and less harmful product ingredients,
• develop a „green by design” strategy, minimising the environmental footprint of products.

It is worth emphasising at this point that the adaptation of activities to the requirements of the Wastewater Directive is not the only challenge for this group of entrepreneurs, especially for cosmetics manufacturers. In parallel, they must ensure that their packaging complies with the requirements of the PPWR and eco-modulation, and adapt to the extended producer responsibility systems for packaging operating in individual Community countries.

Read also: Cosmetics industry facing PPWR - mandatory eco-design of cosmetics packaging

Timetable for implementation of the Wastewater Directive (EU) 2024/3019

• 1 January 2025 - entry into force of the Directive,
• 31 July 2027 - deadline for transposition of the Directive into national law,
• 31 December 2027 - Adoption of implementing acts establishing EU biodegradability and hazard criteria,
• 31 December 2028. - start of operation of national ROP systems,
• 2033-2045 r. - Successive implementation of fourth stage treatment.

Sources:

1. Directive (EU) 2024/3019 of the European Parliament and of the Council of 27 November 2024 concerning urban waste water treatment, https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=OJ:L_202403019

Raw material updates and a new list of scarce raw materials

As relayed to PAP, the climate ministry has announced that, as part of the implementation of the National Raw Materials Policy (PSP), a document is being produced Raw material updates - methodology for determining the most important raw materials for the Polish economy with new raw material lists. It will include an overview of scarce raw materials, their importance for the economy and an assessment of the degree of import dependence.

Work on Raw material updates started in 2024 and is still expected to be completed in 2025.The IOC pointed out that the PSP implemented so far was based on data from 2018, so it is necessary:

verification of the current methodology for designating critical and strategic raw materials for the Polish economy and update of the list of raw materials according to the adopted modified methodology.

Among the raw materials classified as scarce in the document will be antimony, germanium, graphite, lithium and manganese. Poland does not have deposits of these, which is why they are all imported at 90 or even 100 per cent. A similar situation also applies to platinum, titanium and vanadium.

According to data from the Polish Economic Institute (PIE) for 2023, our country has 30 so-called critical dependencies in the import of raw materials from China. The consequences of an interruption in their supply could be severe, ranging from an increase in the cost of industrial production to the halting of key industries, especially the automotive, energy and electronics sectors.

Find out more about strategic and critical raw materials >>

What is the National Raw Materials Policy?

It is a document that establishes a strategy for the management and stewardship of all minerals and mineral deposits It refers to the entire value chain of owned resources and is directly linked to the National Environmental Policy 2030 and the Energy Policy of Poland until 2040. The current PSP was adopted by the government on 1 March 2022.

China increases control over rare earth market

Critical raw materials such as lithium, cobalt, graphite and germanium are crucial to the development of modern technologies - from renewable energy and electromobility to electronics and the defence industry. Their availability is becoming increasingly limited and Poland - like other EU countries - is heavily dependent on imports.

Most of the critical raw materials imported in recent years to Poland came from China. It is the Middle Kingdom that is currently regarded as the quasimonopolist in the global rare earths market. Although their deposits are also found in other countries of the world, the only China has the industrial and technological base to extract them. From 2023, however, the Chinese government began to impose restrictions on the export and use of certain raw materials. At the moment, on the list of restrictions already includes 16 items. Furthermore, on 9 October 2025, China made it mandatory for all companies using Chinese rare earth elements in their products to apply for a licence to market these products. Recent reports suggest that applications from arms companies and companies producing dual-use products and technologies are to be automatically rejected.

Turmoil in the global rare earths market has prompted the EU to create a European Critical Raw Materials Act, which is designed to gradually build the raw material independence of Community countries and strengthen the resilience of supply chains by, among other things, strengthening relations with third countries with deposits of rare earth elements.

Poland's strategy against Chinese domination

Restrictions on the import of rare earth elements may also affect Polish industry. For this reason, Poland is taking continuous measures to prevent supply disruptions and the associated significant market shortages. As part of the diversification of supply Poland develops cooperation with countries rich in critical raw materials, such as Mongolia, Kazakhstan, Uzbekistan, Argentina or Ukraine. The aim of these partnerships is to conduct joint geological research and create the conditions for future investment in the extraction and processing of raw materials. The Ministry of the Environment also announces development of a draft law on ensuring the economy's access to critical raw materials and submit it to the Council of Ministers in Q4 2025.

Read also: Government implements EU battery regulation. Find out more about the bill

Not just imports - recycling and domestic deposits as promising sources of critical raw materials

Although our country is largely dependent on imports, it also has a significant copper, coking coal, nickel and platinum resources. Poland accounts for about 27 per cent of EU coking coal supplies and 19 per cent of EU demand for electrolytic copper used for electronics, wires and cables. We are also successfully extracting helium - The Orlen Group recovers this critical resource, as it were, „by the way” of natural gas production. In addition to the deposits being exploited, we also have a number of new deposits that could become an additional source of scarce raw materials in the future. These include ores iron, titanium and vanadium occurring in the Suwałki region, deposits of nickel, gold, tin and arsenic in the Sudetenland and about the deposits of tungsten and molybdenum in Myszków.

Currently The Polish Geological Institute is working on the preparation of a National Programme for the Exploration of Critical Raw Materials (NPSK). The programme, which is expected to be adopted in early 2026, will set out priorities for national geological exploration and potential exploitation directions.

The IOC also points to the importance of recovering raw materials from waste - both from heaps and dumps of mining waste and from waste electrical and electronic equipment and batteries. This waste can become a valuable source of metals, supporting the construction of a closed-loop economy.

Increasing domestic exploration capacity, developing recycling and international raw material partnerships are collectively expected to strengthen Poland's economic security. In an era of increasing competition for access to critical metals and pressure for a green transition, the skilful combination of exploitation, recovery and reuse of materials can become one of the pillars of the country's future raw material independence.

Sources:

1. Poland facing a critical raw materials deficit. The government is working on a document, https://businessinsider.com.pl/gospodarka/ministerstwo-klimatu-prace-nad-lista-deficytowych-surowcow/lsk02w4
2. Odpowiedź na interpelację w sprawie monitorowania gospodarki metali rzadkich, znak: K10INT3248, https://sejm.gov.pl/INT10.nsf/klucz/ATTD6RHXD/%24FILE/i03248-o1.pdf
3. Raw material updates - methodology for determining the most important raw materials for the Polish economy with new raw material lists, https://www.pgi.gov.pl/en/component/chronoconnectivity5/?cont=lists&ccname=projekty&act=view&gcb=1890

Lack of environmental benefits and high implementation costs determined the exclusion of the

As EuPF points out, the EC's recent decision is a 'pragmatic recognition of economic realities'. It was underpinned by the findings of a Deloitte feasibility study commissioned by the European Commission's Directorate-General for the Environment (DG ENV). It showed that switching to reusable stretch films and pallet strapping tapes involves a significant increase in investment and operating costs, with no environmental benefit.

It should be emphasised that the exemption applies only to obligations under Article 29(2) and (3) PPWR regulation. EuPF reported that the decision has already been confirmed and will soon be formally adopted by means of a delegated act. The question of Article 29(1) is still open., which mandates the reuse of 40% of transport packaging in cross-border trade by 2030 and as much as 70% by 2040.

MEP intervention and EC position on the application of Article 29.

The problem of the impending implementation of the mandatory reuse of stretch film and strapping tapes was also recognised by MEP Piotr Müller (ECR), who sent an enquiry to the EC regarding the planned exemptions as early as mid-August 2025. As he stressed, maintaining the current obligations "would mean eliminating common solutions such as stretch film and PET tape, despite their low carbon footprint and high logistical efficiency, as confirmed by independent studies (e.g. IFEU 2025)". In his view the failure to fully exempt stretch film and binding bands from Article 29(1), (2) and (3) of the PPWR is promoting less environmentally friendly solutions, which in turn runs counter to the objectives of the PPWR Regulation. Müller also pointed out that the process of developing the delegated act, which could introduce possible exemptions, was taking place without sufficient transparency and without consultation with the packaging industry.

19 September 2025. The EC responded to the enquiry by stating that it was investigating the possibility of exempting certain packaging formats from Article 29(2) and (3) of the PPWR and awaiting the results of the study to make a final decision. While, in the case of the above provisions, the EC's final decision turned out to be in line with the wishes of the industry and with environmental performance in the broadest sense, already at Article 92(1), the positions of the industry and the EC differed significantly. In the aforementioned response to the enquiry, the EC made it clear that:

"the targets for the re-use of transport packaging formats listed in Article 29(1) of the Packaging Regulation are feasible, do not worsen environmental performance and do not lead to negative economic impacts for the economic operators concerned."

In view of these reports the exemption of stretch film and PET/PP tapes from Article 29(1) of the PPWR has been called into question.

IFEU and RDC data: reuse not always greener

Introducing mandatory reuse in cross-border transport (i.e. no change to the provisions of Article 29(1)) would mean that two palletising systems would have to be used - separately for the EU market (reusable packaging) and export (non-reusable packaging) - and this could undermine the competitiveness of European industry. Moreover, transporting empty reusable packaging over long distances, which is typical of cross-border trade, would significantly increase CO₂ emissions..

According to EuPF head Thomas De Meester, scientific and economic data support that Article 29(1) should also be exempted:

IFEU analysis shows that in many applications, reusable packaging leads to as much as 1700% higher greenhouse gas emissions, and the RDC study shows an annual cost increase of almost €5 billion in eight key sectors. With longer transport distances, emissions increase, making reuse less environmentally beneficial.

Importantly, in considering the legitimacy of the exemption, the EC is relying on the same set of scientific data, a fact that clearly resonated in its response to Peter Müller's query.

At the same time, the Commission announces a "realistic and pragmatic approach" to the development of an Article 30 implementing act that will define the methodology for calculating re-use rates. The industry looks forward to seeing what specific criteria will be adopted therein.

Industry awaits implementing act and public consultation

The European Commission's decision to exempt pallet wrapping film and strapping tape from the 100 per cent reuse target is an important signal for the plastics industry across Europe - also in Poland. Many Polish companies are active on the export market and the potential reuse obligation could force a costly reorganisation of packaging and logistics processes.

EuPF announces further efforts to harmonise the Commission's approach to all paragraphs of Article 29 and to actively participate in the consultation on the Article 30 implementing act. The organisation stresses that regulations should be based on science and not solely on political assumptions, so that they realistically support environmental objectives and a circular economy.

Sources:

1. The exclusion of stretch wrap and PET tape from the reuse obligation in the draft packaging and packaging waste regulation (PPWR) and the transparency of the consultation process, https://www.europarl.europa.eu/doceo/document/E-10-2025-003229_EN.html
2. Answer given by Ms Roswall on behalf of the European Commission, https://www.europarl.europa.eu/doceo/document/E-10-2025-003229-ASW_EN.html
3. EuPF welcomes EU reuse exemptions, https://www.recyclingtoday.com/news/eupf-plastic-film-pallet-wrap-strap-reuse-mandate-exemptions-europe/
4. Stretch films and tapes exempt from reuse. What's next for PPWR?, https://www.plastech.pl/wiadomosci/Folie-stretch-i-tasmy-zwolnione-z-ponownego-uzycia-Co-21346

The scale of the crisis in the plastic recycling industry - production declines and a wave of closures

The latest figures on the state of the European plastics recycling industry are not encouraging. Representatives of Plastics Recyclers Europe speak plainly about the deep crisiswhich could even lead to the collapse of the entire industry.

• In 2023, there is an 8.3% decrease in the volume of plastics production.
• Between 2006 and 2023 the European industry's share of the global plastics processing market fell from 22% to just 12%.
• According to forecasts, by the end of 2025 alone, plastics recycling plants with a total capacity of almost 1 million tonnes will have disappeared from the old continent.
• In H1 2025 alone, plant capacity fell by almost as much as in the whole of 2024.
• Chemical recycling scale grows slower than expected, which could jeopardise the goal of chemical recycling 3 million tonnes of plastics by 2030.

The countries that have hitherto been European leaders in plastic recycling, i.e. the Netherlands, Germany and the UK, are most affected by the crisis. Analysts forecast that Plastic recycling industry to close 2025 with zero growth. Such an abrupt deceleration calls into question the further possibilities of developing a local circular economy.

See also: Commission gives green light to chemically recycled materials >>

European industry bowing to pressure from imported recyclate

Plastics Recyclers Europe sees the reasons for the growing crisis mainly in the lack of mechanisms to protect the domestic market from an influx of cheaper imported recyclate. Also of significance are steadily rising operating costs (e.g. the cost of purchasing green energy), high raw material prices and excessive bureaucracy, which makes it difficult, for example, to obtain and renew permits. All these factors make locally produced recyclate is significantly more expensive than imported recyclatewhose quality sometimes raises serious concerns.

As it turns out, the obstacles to building a competitive European plastics industry are also regulatory uncertainty and regulatory fragmentation across Member States. This is mainly about the EPR regulations, under which each Member State has created its own separate and different system. Plastics Recyclers Europe also draws attention to the insufficient enforcement of these EPR requirements under Community legislation.

Market and legislative uncertainty is a barrier to investment in new plastics recycling plants and technologies. In mid-September 2025, the US company will ExxonMobil announces investment halt in the chemical recycling centres being set up in Antwerp and Rotterdam, which were expected to collectively process up to 80,000 tonnes of waste per year. EU policy, which, according to ExxonMobil senior vice-president Jack Williams, discriminates against the use of existing petrochemical plants over stand-alone recycling facilities, was cited as the main reason.

Joint industry appeal to EU decision-makers

Faced with a catastrophic situation in the industry, representatives of the 28 largest players in the European plastics value chain have launched an appeal to EU decision-makers, urging them to take immediate action. In a joint letter, the recycling industry outlined 6 demands to address the sector's most pressing problems.

1. Implement effective mechanisms to protect the market from imports of cheaper raw material, including strict enforcement of quality requirements and standards, including for imported recyclates.
2. Create incentives to invest in infrastructure for collecting, sorting and recycling plastics.
3. Harmonisation of EPR regulations across the Community.
4. Reviving demand for European plastics, e.g. by introducing eco-modulation of charges based on the content of high-quality recycled raw material.
5. Facilitating access to cheap, clean energy.
6. Reducing bureaucracy, especially related to obtaining and renewing permits.

Jobs in green industry and EU climate goals are at stake

According to representatives of the plastics recycling industry, the failure of the European institutions to react quickly will lead to a further decline in production and reduction in the scale of recycling, resulting in more bankruptcies and closures of processing plants. It will also derail decades of investment in innovation and the circular economy and lead to the loss of thousands of green jobs.

The collapse of the European plastics recycling sector will also mean serious delays in meeting the EU's environmental and climate goals. Without a stable local recycling base, Europe will not be able to deliver on the European Green Deal nor maintain its leadership position in the transition towards a circular economy.

Experts stress that the window of time to take the necessary action is closing fast. If the European Union does not introduce immediate systemic solutions, the effects of the current crisis will be irreversible - for both the economy and the environment. The industry therefore appeals to decision-makers: the time to react is now.

Sources:

1. Plastics Value Chain Demands Immediate Action to Save EU Industry, https://www.plasticsrecyclers.eu/news/plastics-value-chain-demands-immediate-action-to-save-eu-industry/
2. Wave of Surging Plastic Recycling Plant Closures Hits Europe, https://www.plasticsrecyclers.eu/news/wave-of-surging-plastic-recycling-plant-closures-hits-europe/
3. Is the European recycling industry truly doomed?, https://packagingeurope.com/news/is-the-european-recycling-industry-truly-doomed/13334.article
4. Blenkinshop, Exxon pauses European plastic recycling plans over draft EU rules, https://www.reuters.com/sustainability/land-use-biodiversity/exxon-pauses-european-plastic-recycling-plans-over-draft-eu-rules-2025-09-17/

Reasons for expiry of the waste management decision

Waste management decisions are the cornerstone of the waste industry. As early as 31 December 2025, however, many of them may expire. This follows from the provisions of the Waste Management Act (Article 226a) and the Environmental Protection Act (Article 193(1c))which indicate this very date as the cut-off date, and this even for entrepreneurs who have applied for new permits and licences at least three months before the expiry of the period for which the earlier decisions were issued.

From 2022. the Marshall Offices, which handle the majority of such cases, cannot cope with the flood of applicationsand decision-making procedures drag on for years. Meanwhile, the deadline for the expiry of decisions is approaching inexorably - all entrepreneurs who fail to obtain new permits and approvals must expect to have to suspend their activities after the New Year.

Amendments to laws will extend the validity of decisions. Until when?

Following appeals from, among others, representatives of the steel industry, the Ministry of the Environment drafted an amendment to the Waste Management and Environmental Protection Acts, which envisaged the following automatic renewal of expiring decisions. By how much? The SME Ombudsman called for postponing the deadline by 3 years, i.e. until 31 December 2028. In the first version of the bill, the Ministry of Climate and Environment proposed a 2-year period (until 31 December 2027). In the course of the legislative work, the Ministry of Climate and Environment withdrew from this idea and instead of 2 years gave entrepreneurs only 6 additional months to obtain a new decision. The law currently under way extends the validity of permits and authorisations only until 30 June 2026.

As the explanatory memorandum to the bill reads:

As of 31 December 2024, there were approximately 1,410 applications pending to bring administrative decisions into line with the Fire Act. This represents approximately 13 % of all applications submitted. The largest number of administrative proceedings is on the part of provincial marshals (according to the aforementioned state, these bodies had 1,070 applications pending). Taking into account the scale of the proceedings conducted by the provincial marshals, a detailed analysis of the adaptation stage was carried out, which shows that as of 1 January 2026, approximately 307 applications for adaptation of the decision will remain to be considered.

Will we have time to adopt the amendment?

The bill, which is being processed under the number UDER39, did not reach the Council of Ministers until the end of September 2025. At this point, therefore, there is no certainty that the new legislation will be adopted and enter into force on the planned date (i.e. 1 December 2025). If the parliament does not deal with the matter soon, the spectre of an interruption in waste collection will become real after 1 January 2026. Experts predict that the need for some waste companies to suspend operations may cause serious waste management problems at the municipal level - The cost of transport and thus the charges for residents may increase. In the worst-case scenario, waste will cease to be collected from properties.

It is not only entrepreneurs, but also local authorities, who are already calling for the legislative work to be speeded up and the deadline for previous decisions to be extended not by six months, but by a minimum of one year. However, the Ministry of the Environment is closing the door to any conjecture:

30 June 2026 is the cut-off (final) date for the extension of existing administrative decisions. After this date, it will no longer be possible to extend the aforementioned decisions. In the event that the time for which the existing decision was issued has expired and the procedure for issuing a new decision is not completed before 1 July 2026, the earlier decision will expire by operation of law on that date. This effect will take place irrespective of the date of the application for a new permit.

Paralysis of Marshal Offices main cause of problems

The massive influx of applications for permits and licences is due to several factors. Firstly, in 2024 and 2025, the 10-year expiry date of many decisions issued in 2014-2015 was coming to an end. Secondly, the introduction of the Fire Act forced waste management operators to adapt their decisions to the new fire protection requirements. In both of these situations the number of pending applications has increased exponentially, which, combined with the ongoing handling of first-time applicants, has led to a prolonged paralysis of marshal offices.

Faced with this situation the validity of previous decisions has already been extended once. In 2022, the aforementioned Article 226a was introduced into the Waste Act and Article 193(1c) was introduced into the Environmental Protection Law, which automatically postponed the expiry date of all decisions to 31 December 2025, provided that the entity concerned applied for a new decision at least 3 months before the expiry of the previous one. Will the additional 6-month period planned by the Ministry of the Environment prove sufficient? And will the parliament accept the ministry's proposal in this shape and timeframe?

The fate of the ministerial bill can be followed on the website of the Government Legislation Centre.