On 1 January 2025, an amendment to the regulation of the Minister of Climate and Environment came into force, which significantly reduced the rates of the product fee for glass packaging collected under the deposit system. Under the new regulations, For each kilo of reusable glass bottles, introducers will pay:

• £0.01 (instead of £0.10) in 2025,
• £0.05 (instead of £1) in 2026,
• £0.25 (instead of £5) in 2027 and beyond.

Recall that the previous legislation provided for uniform rates for all types of packaging covered by the deposit system. So what is the reason for this change?

The amendment to the Regulation was intended to making rates more realistic product levy. As highlighted in the explanatory memorandum of the draft new regulation, the weight of a glass bottle is many times that of a PET bottle or can of identical capacity. Based on the data cited by the Ministry of Climate and Environment, the weights of the half-litre containers covered by the deposit system are respectively:

• PET bottle - 13 g,
• beverage can - 14 g,
• glass bottle - 315 g.

This means that for every 1 kg of packaging:

• 77 PET bottles,
• 71 cans,
• just 3 glass bottles.

In line with the principle that litter the number of packages, not their weight, the product levy rates for glass packaging have been significantly reduced.

Learn about Interzero's comprehensive services for bail participants >>

The reduction of the product fee for glass packaging was dictated not only by economic issues, but also by environmental ones. The use of reusable packaging has a positive impact on the environment and brings us closer to making GOZ a reality. The use of returnable glass bottles reduces the scale of production of new bottles, thus reduces carbon emissions, electricity consumption and raw materials.

Maintaining the current uniform rates of the product fee for all of these types of packaging could cause introducers to move away from their use and replace 'expensive' reusable glass with much 'cheaper' single-use plastics. Abandoning reusable glass bottles, on the other hand, would be a a step backwards that would move us further away from the transition to a closed-loop economy.

See also:

• 9 month delay in bail system. What does this mean for the packaging industry?
• Sielaff bottle dispensers - the best machines for a bail system

Sources:

• Ordinance of the Minister of Climate and Environment of 24 December 2024 amending the Ordinance on the rates of product fees for individual types of packaging, https://isap.sejm.gov.pl/isap.nsf/download.xsp/WDU20240001960/O/D20241960.pdf
• https://legislacja.rcl.gov.pl/projekt/12389300/katalog/13079739#13079739

Under the provisions of the amendment, from 1 January 2025. each municipality is obliged to organise separate collection of textile wastewhich include, among other things, used clothing and footwear, home textiles (bedding, curtains) and other fabric products. The minimum that municipalities must provide is the possibility of returning all textile waste to the local PSZOK.

At present, there are no top-down plans to introduce an additional sixth bin dedicated exclusively to textile waste or to oblige municipalities to collect this waste fraction from properties. However, municipalities are free to organise additional collection of textile wasteFor example, collecting it directly from households or setting up additional collection points. A similar solution has recently been trialled by the city of Częstochowa, which allows its residents to collect their textile waste free of charge by telephone appointment.

The introduction of an obligation of separate collection of textile waste results from the transposition into Polish law of the provisions of Directive 2008/98/EC of the European Parliament and of the Council of 19.11.2008 on waste and repealing certain Directives. Article 11(1) of the Directive obliges all EU Member States to carry out separate collection of at least the following fractions: paper, metal, plastics, glass and textiles. The latter fraction has been compulsorily collected throughout the EU precisely since 1 January 2025.

Let us recall that The European Union continues to work on implementing legislation to increase the efficiency of textile waste collection and impose additional obligations on textile producers, called the extended producer responsibility regime. Under the ROP provisions, textile introducers are to be charged for the costs associated with the collection, segregation and recycling of the waste produced from them.

Selective collection of textile waste means new obligations not only for municipalities, but also for their residents. From the new year it is prohibited to dispose of textiles in the mixed waste bin. Penalties for non-compliance with the new rules or for incorrectly sorting waste can range from 200 to 400% of the basic waste collection fee. It should be noted that these penalties are not a one-off - if residents of the property continue to fail to comply with the statutory obligations, financial penalties may also be charged in subsequent months.

We are already familiar with the mechanism of such penalty fees - similar consequences will also be imposed on us for incorrect sorting of other waste fractions for which separate collection is mandatory (glass, metal and plastics, paper, bio waste). Why are we reminding you of this? Well, a survey we conducted in 2023 showed that only 62% Poles sort waste into all the required fractions, and even fewer, 43%, declare that they can do it correctly. More findings can be found in research report We are getting into trouble.

Contrary to what you might think, since January we have not been obliged to return all used textiles to the PSZOK. Used textiles in good condition can be donate to charities (e.g. PCK, Caritas, single mothers' homes, shelters for the homeless) or dispose of in the second-hand clothes container.

Alternative collection points for textiles are also offered by their manufacturers, giving consumers the opportunity to donate old clothes or shoes in their shops. In most cases, these can be products of any brand, which will then be recycled, upcycled or re-marketed in second-hand shops.

As representatives of the waste and recycling industry, we strongly encourage you to act in the spirit of our idea Together for a world without waste which implies not only the proper handling of textile waste, but also the prevention of its generation. How can this be done? Discover 5 ways to go green for fashion and a sustainable wardrobe.

The change that will affect all businesses on the BDO register is increase in annual and registration fee. It is dictated, among other things, by the increasing costs of maintaining, running and developing BDO.

From 2025, the BDO fee rates will be:

• 200 z for micro-entrepreneurs (increase from PLN 100),
• PLN 800 for other entrepreneurs (an increase from PLN 300).

As a reminder, the deadline for paying the annual fee for a calendar year is the end of February - so in 2025 it will be 28 February. The annual fee at the new amount must be paid by this date.

Read more about BDO fee increases in 2025.

From 2025, the introduced an obligation to keep records of all hazardous waste produced by entrepreneurs. This means that existing exemptions will disappearwhich were readily used by those generating small amounts of hazardous waste, including beauticians and hairdressers. Entrepreneurs running beauty and hairdressing salons can have their registration at BDO Interzero - fast, convenient and in 100% online.

Read more about the new responsibilities of the beauty industry in the article: Beauty and hairdressing salons required to register with BDO >>

The recording obligation will cover hazardous waste with the following codes:

• 3 02 08* Other engine, gear and lubricating oils,
• 15 01 10* Packaging containing residues of or contaminated by dangerous substances,
• ex 15 01 11* Metal packaging containing hazardous porous reinforcing components other than asbestos, including empty pressure containers,
• 16 02 13* Discarded equipment containing hazardous components other than those mentioned in 16 02 09 to 16 02 12,
• 16 06 03* Batteries containing mercury.

Do you generate such hazardous waste? Find out if you need to register your company with BDO in 2025!

From January 2025. the obligation to separate construction and demolition waste into 6 fractions will come into force. The most recent change, however, is the move away from the need to ensure that R & D waste is segregated at the point of generation -. the trader will be able to pass on the obligation to segregate them to another entity with the relevant permits and entries in the BDO, provided that the relevant contract is signed.

In the previous version of the legislation, the legislator obliged every generator of construction and demolition waste to segregate it at source. As a result of the amendments to the Waste Act, the possibility to segregate waste outside the place of its generation was introduced, but without relieving the entrepreneur of the responsibility for ensuring the implementation of this obligation.

Find out about the new rules for managing construction and demolition waste in 2025.

In 2025. it will not be possible to issue DPR and EDPR documents in the BDO system.. The introduction of the Confirmation Module, which was to allow the digital generation of these documents, has been postponed until 1 January 2027. From this date, businesses will gain the ability to electronically issue DPRs and EDPRs for packaging and products and certificates for electrical and electronic equipment and for batteries and accumulators.

In the period 2025-2026, the documents proving recycling will continue to be issued on paper.

From 2025. the limits on the disbursement of funds from the National Fund for Environmental Protection and Water Management for purposes related to the operation of the BDO will be raised. This is to ensure continued seamless access to BDO, as well as maintaining the current level of cyber security and funding the development of the system.

Furthermore, the proceeds from the registration and annual fees for BDO entry will be direct revenue for the NFEPD.

Only 8% stand-alone introducers achieved the minimum statutory recycling levels in 2022. - according to the IOŚ-PIB report Packaging and packaging waste management in Poland in 2022. During the same period, recovery organisations met or even exceeded annual recycling targets for all types of packaging waste.

Of the introducers who chose to ensure recycling of their generated packaging waste themselves, as many as 11 234 entities were obliged to achieve the required recycling rates, which in 2022 were:

• 30% for plastic waste,
• 51% for aluminium waste,
• 55% for ferrous metal waste,
• 66% for paper and cardboard waste,
• 62% for glass waste,
• 19% for waste wood,
• 59% for all the above types of packaging waste combined.

On the basis of data from the BDO register, EIA-PIB experts calculated that only 8% stand-alone introducers achieved these minimum levels of. The percentage of independent introducers who managed to meet the statutory minimum is shown in the chart below:

Source: Report Economy of packaging and packaging waste in Poland in 2022.

At the opposite end of the spectrum are recovery organisations that in 2022 met the statutory recycling targets for metal, glass, paper and cardboard packaging waste and exceeded the required recovery rate for plastic packaging waste[i].

Failure by an entrepreneur to achieve the statutory recycling levels for packaging waste results in the need to charge and pay a product fee, which is a kind of environmental tax. To avoid the obligation to pay the fee, the entrepreneur may transfer his recycling obligation to a recovery organisation packaging waste generated from the packaging and packaged products it introduces. This will ensure that the introducer pays only a fixed, low amount for the contract with the recovery organisation and does not have to worry about ensuring waste recycling.

Calculate how much you can save on the product levy >>

Interzero takes over the recycling obligations of businesses in terms of:

• packaging waste,
• batteries and accumulators,
• post-consumer products: tyres, oils and greases,
• electrical and electronic equipment.

As a result, each the entrepreneur can comprehensively delegate all his/her responsibilities to us resulting from the marketing of packaging and products. Find out what obligations your company is subject to!

By signing a single contract, you will be sure to meet your company's obligations to ensure statutory levels of recovery, recycling and preparation for re-use.

[1]Packaging and packaging waste management in Poland in 2022, https://ios.edu.pl/wp-content/uploads/2024/09/gospodarka-opakowaniami-i-odpadami-opakowaniowymi-w-polsce-w-2022-r-2.pdf

Approximately 4.5 million tonnes of food are wasted in Poland each year, and as much as 60% of this is wasted in households. Why? The most common reasons declared by respondents for throwing food away are:

• expiry date - 60%,
• shopping too much - 26%,
• improper storage - 26%,
• purchase of unpalatable products - 25%,
• purchase of poor quality products - 17%,
• excessive meal portions - 18%,
• no idea how to use the products - 10%[i].

The amount of food thrown away increases dramatically over the Christmas and New Year period. It is estimated that as many as 83% people throw away food during this time. The 24th of December has even been unofficially dubbed Christmas Food Waste Day - in Poland alone, as much as 9,200 tonnes of food ends up in bins on that day[ii].! Can this be remedied?

For environmental reasons, we encourage, above all, moderation, which is one of the most important components of the our recipe for Christmas peace. We assume, however, that since you have arrived here, you have just you are struggling to manage your food after Christmas and you are looking for the best solution for you and nature.

The remedy for most of these problems is foodsharing. The movement encourages donating surplus food to people who are happy to accept it and literally save it from going to waste. There is only one condition - the food must still be fit for consumption.

One way to do festive foodsharing is to use food pantries, also known as community fridges. Dining halls are communal fridges, cupboards and sometimes small rooms that allow food to be exchanged. Not only can you leave fresh produce or dishes in them, but you can also take what others have left on the shelves.

What to donate to the eatery? Only food that we would eat ourselves. Importantly, it may be past its best-before date - dry and loose products, tinned foods, condiments and sometimes even properly stored dairy products are often fit for consumption after the date indicated on the packaging. Donating food to an eatery However, it is worth following a few rules:

• products should be placed in clean packaging and sealed tightly,
• a note should be placed on the home-cooked dishes with their composition and date of preparation,
• products can be left previously opened, but the date of opening should be indicated (mainly for food that spoils quickly),
• if a dish needs to be stored at a low temperature, it absolutely must be placed in the fridge!

Against the odds, Eateries are not the domain of large cities - you'll find them in small towns too!

See the nationwide map of eateries

Go to the map of eateries in Warsaw

Don't see your location here? Try searching for it on an online search engine, for example - the network of eateries is constantly expanding, so there may be outlets in your area that are not yet marked on the map.

Eateries aren't the only places you can donate food to after Christmas (and not just after Christmas). See where else you can share your food!

• Food Banks

These are charitable institutions that accept any type of food and then distribute it to those in need. All food products (including non-perishable products, e.g. bread, dairy products, meat, fruit and vegetables) can be donated to such a bank at least 2 days before the expiry date. There are 31 such banks in Poland. View map of Food Banks.

• Facebook groups and local forums

Food sharing is also enabled by social media and local groups, which you will find under names such as:

• Online dining, foodsharing, freeganism,
• I will donate, attention, the rubbish truck is coming (or simply: rubbish truck),
• we do not waste food.

• Branches of Caritas Polska

Caritas has long been active in helping those in need while at the same time tackling food waste. Local Caritas branches often accept unwanted food that is left over in the fridge after Christmas or an event, for example. It is worth contacting your nearest Caritas branch and donating the food to them, which will then be distributed to those in need.

• Facilities for people in crisis of homelessness

Surplus food from the holidays is also readily accepted by night shelters and shelters for people in crisis of homelessness. You can find a list of all such establishments by voivodeship on the website of the Ministry of Family Affairs, Labour and Social Policy.

Sometimes food has to be thrown away - it's spoiled, over-salted, burnt, there can be many reasons. However, it is worth doing this with your head. Properly sorted waste from the table, fridge or kitchen cupboard can still be recycled organically, i.e. composted or fermentation.

Where to throw food away? Most food is disposed of in the brown bin for bio-waste. This is where unwanted, spoiled or out-of-date food should go, but with some exceptions. Leftover meat, sausages and bones are mixed wasteas are eggs, cheese and other animal products. Mixed meals containing animal products, e.g. salads or sauces, are also not bio-waste. Check what we throw away and what we don't throw away in bio-waste.

An alternative to the bio-waste bag is the composter: domestic, kitchen or electric. It allows you to turn bio-waste into natural and completely free plant fertiliser, which can be produced in as little as 24 hours! Such opportunities include Oklin composter from the Smart range.

[i] Zero recycling point in Poland, https://portalkomunalny.pl/wp-content/uploads/2024/12/raport-punkt-zero-recyklingu-w-polsce.pdf

[ii]. Christmas, festivities and... into the bin. We throw away 1.6 kg of Christmas food per person, https://www.rp.pl/przemysl-spozywczy/art41538111-swieta-swieta-i-do-kosza-wyrzucamy-1-6-kg-swiatecznego-jedzenia-na-osobe

The most important provisions of the amendment are abolition of the obligation to segregate, i.e. separate collection of construction and demolition waste on site and defining responsibility for sorting out the waste fractions.

Each contractor generating construction and demolition waste will be required to segregate at least 6 fractions at the point of generation:

• wood waste,
• metal waste,
• glass waste,
• plastic waste,
• gypsum waste,
• mineral wastes, including concrete, bricks, tiles and ceramic materials and stones.

The draft amendment to the Waste Act was created in response to interpretative doubts and potential problems with the organisation and cost of selective reported by representatives of the construction industry. The previous version of the legislation, which was due to come into force on 1 January 2025, lacked a clear statement on whom the obligation to selectively collect and collect construction and demolition waste falls. The need to sort them for 6 fractions on site would also result in a sharp increase in the cost of exporting such waste, which in turn could contribute to its illegal dumping and dumping directly into the environment.

According to the provisions of the Act amending the Waste Act, an entrepreneur generating construction and demolition waste will be able to hand them over to another authorised operator who will take over the obligation to separate them into a minimum of 6 fractions off-site generation. Importantly, the transfer of waste to another entity does not completely relieve the generator of construction and demolition waste of its responsibility to fulfil the segregation obligation. If this obligation is not fulfilled through the fault of the entity that has taken over the waste, both entities (generator and transferee) will be jointly and severally liable.

The new rules are due to come into force from 1 January 2025.

In the explanatory memorandum of the bill, its authors emphasised the need for entrepreneurs to adhere to the so-called waste hierarchy:

providers of construction, demolition, renovation services (building contractors) are obliged to prevent waste.[i]

As a first step, therefore, measures should be taken to prevent construction and demolition waste. Selective waste collection should only take place when the materials in question are no longer reusable. The sorting itself, on the other hand, is intended to ensure suitability for preparation for reuse, recycling and other recovery. Regardless of where they are sorted (on-site or off-site), the individual fractions of construction and demolition waste should then be handed over to specialised entities for further management. For this purpose, it is often necessary to commission a professional collection of construction and demolition waste from a designated address offered by, among others, the waste collection company Interzero.

[i] https://orka.sejm.gov.pl/Druki10ka.nsf/0/A065E318FFC3BE21C1258BC70041F23F/%24File/766-uzasadnienie.docx

The introduction of mandatory ESG reporting in Poland will have a significant impact on companies that meet the criteria set out in the EU CSRD. As in other EU countries, these companies will be obliged to prepare annual sustainability reports. These reports will have to comply with the legal requirements and standards set out in the EU regulation. ESG documentation will be placed on a par in terms of form with financial reports and its content will have to be approved by independent auditors. Failure to comply with the obligation to produce a report may lead to serious consequences, including criminal liability.

Companies on which ESG reporting will not be directly imposed will also be affected by the enactment of the Union Regulation. Why? We suspect that many of them will need to collect and analyse environmental impact data anyway. Arguably, these will be essential documents for contractors or companies within the same group of companies that will be subject to the reporting requirement. It is possible that support will be required from partners to provide relevant data. This is why we already encourage representatives of small and medium-sized companies to take an interest in the ESG topic. Without implementing a proper operational strategy - the business could be seriously affected in a few years' time. Customers are also more likely to turn to products and services from transparent providers.

The Interzero team, knowing that both small and larger companies will need expert help to put ESG into practice, has prepared an e-book for you. It is a document that contains all the necessary information. It is written in simple, accessible language. In it, we explain what the CSRD is, introduce the reporting timeline, show you how to communicate on the topic of sustainability, and outline the operational steps you need to take to prepare your business for ESG. Fill in the form on our websiteand you will get access to it completely free of charge. Your education is one of the most important factors for the development of your business.

News about the enactment of reporting is just the tip of the iceberg. We know how much the Polish business model will now change and we want our clients to be prepared for this. As a company, we believe in technology and innovation. That is why we want to guide all those interested in the topic of ESG smoothly and calmly. We would like to remind you that reporting will be mandatory:

• from 2025 - for large companies (more than 250 employees and/or EUR 50 million turnover and/or EUR 25 million total assets),
• from 2026 - for listed SMEs.

Environmental Sustainability Dashboard - ESG non-financial reporting tool - our proprietary consulting solution. The tool will streamline your data collection and monitoring processes - so you can accurately track ESG indicators. It is a solution for companies that want to be ready for mandatory reporting. Clients get access to an online platform and full environmental impact assessment advice.

According to calculations by IOŚ-PIB experts, products packed in 6,740 thousand tonnes of packaging were put on the market in 2022. Data from 532 installations were taken into account, with a total of 4 023.8 thousand tonnes of waste entering the market in 2022. More than 10% of this mass consisted of so-called non-target materials (materials that are not recycled in a given recycling process into products, materials or substances that are not waste). After adjustment, the total the weight of recycled packaging waste was 3 608.9 thousand tonnes, including:

• 2,022.5 thousand tonnes of paper and cardboard packaging waste.
• 565.1 thousand tonnes of plastic packaging waste,
• 635,000 tonnes of glass packaging waste,
• 268,900 tonnes of wood packaging waste,
• 117,400 tonnes of metal packaging waste.

According to the methodology adopted by the authors of the report, The recycling rate for total packaging waste was 60.4%, an increase of 1.4 more than the minimum provided for in the Decree of the Minister of Climate and the Environment of 19 December 2021 on the annual recycling levels of packaging waste by year until 2030.

Recycling rates for total packaging waste were calculated in 2 options. The first one was based on data from introducers (entities that have entrusted statutory obligations to organisations) and stand-alone (entities responsible on their own). From this data, the recycling levels of individual packaging waste for 2022 were as follows:

• metals - 93.9%,
• wood - 20.9%,
• plastics - 40.7%,
• glass - 65.3 %,
• paper and cardboard - 89.1%.

According to this option, minimum annual recycling targets for packaging waste have been achieved for all types of packagingfrom which the waste originated.

The second variant calculation presented in the report was based on the methodology of IOŚ-PIB. The recycling levels calculated in this way for almost all packaging waste (except plastics) are at a lower level:

• metals - 36.6%,
• wood - 16.7%,
• plastics - 45.8%,
• glass - 45 %,
• paper and cardboard - 83.9%.

According to calculations based on the methodology of the EIA-PIB, in 2022, the introducers did not meet the minimum recycling levels for ferrous metal and aluminium packaging waste (amounting to 55% and 51% respectively) and wood (amounting to %).

Regardless of the option, the lowest recycling rate was recorded for wood waste.

The source of the data presented in the report is the BDO register. Gap takers, i.e. producers or distributors who place plastic packaging or packaged products on the market and do not report them to a producer responsibility organisation or public authority or otherwise take financial or financial and organisational responsibility for the management of plastic packaging waste or report smaller quantities than they actually place on the market, are not included in the calculations.

The analysis prepared by the EIA-PIB takes into account waste with codes:

• 15 01 01 - paper and cardboard packaging,
• 15 01 02 - plastic packaging,
• 15 01 03 - wood packaging,
• 15 01 04 - metal packaging,
• 15 01 05 - multi-material packaging,
• 15 01 06 - mixed packaging waste,
• 15 01 07 - glass packaging.

The actual amount of packaging waste generated in Poland and recycled was calculated as follows - adding up the weights of waste recycled in Poland and recycled abroad, reducing the result by the weight of waste imported to Poland for recycling.

On 24 October 2024, a draft decree of the Ministry of Climate Change was published on the website of the Government Legislation Centre, which provides for an increase in the rates of the registration fee and the annual fee applicable from 2018.

From 2025 these will amount to:

• PLN 200 for micro-entrepreneurs,
• PLN 800 for other entrepreneurs.

This represents an increase of 100% and 166% respectively. The increase will cover all entitieswhich have a statutory obligation to register with BDO.

Check whether your company is required to register with BDO!

In accordance with the provisions of the Waste Act, BDO fee rates have been set in the range of PLN 50 to PLN 2,000. Their amount should not constitute an obstacle to registration or the exercise of economic activityespecially for micro, small and medium-sized entrepreneurs.

Prepared by the Ministry of Climate and Environment The draft was then submitted for opinion among others by employers' organisations and by the Joint Committee of Government and Local Self-Government. Due to the need to ensure the entry into force of the proposed regulations from 1 January 2025, the deadline for giving an opinion on the draft regulation was only five days.

According to the climate ministry's calculations, thanks to the BDO fee increase The total revenue from the registration fee and annual fee for the period 2025-2034 will be:

• for the state budget PLN 243.5 million,
• for the provincial budget (provincial marshals) PLN 134.8 million.

Over the projected 10-year period, medium and large enterprises will have to bear a total of PLN 194.662 million in additional costs, and micro and small enterprises PLN 70.942 million.

The reasons for the increase in the BDO registration fee and annual fee are explained in the explanatory memorandum to the draft regulation. As the climate department points out, fee rates have not been updated for more than 6 years. During this period cumulative inflation was 43.9%, which has meant that the real income from the registration fee and the annual fee has actually decreased. Furthermore, as of 2018. there has been a significant increase in costs associated with maintaining, running and developing the BDO, which has contributed to a reduction in the resources that can be allocated to the proper functioning of the Products and Packaging and Waste Management Database.

The registration fee and BDO annual fee rates proposed in the draft regulation take into account the aforementioned increase in costs both on the part of the voivodship marshals and on the part of the state budget. Let us recall that the fees payable by entrepreneurs for entry and maintenance of the register shall be collected by the Marshall of the Voivodship. They represent in 35.65 % the income of the provincial budget (the provincial marshal), who is responsible for maintaining the register, and in 64.35 % the income of the state budget and the Ministry of Climate and Environment, who are the BDO Administrator.

The course of the legislative process can be followed on the website of the Government Legislation Centre.

The catalogue of entities obliged to register with the BDO, and thus also to pay the annual and registration fees, is enumeratively defined in the Waste Act.

The following are obliged to pay the registration fee and the annual fee:

• equipment introducers and authorised representatives,
• the introducer of batteries or accumulators,
• vehicle introducer,
• producers, importers and intra-Community purchasers of packaging,
• introducing packaged products on the national territory,
• the importer of tyres on the national territory,
• introducing lubricating oils on the national territory.

For some businesses, increased BDO rates are not the only concern. From 2025, an obligation to keep records of hazardous waste has been introduced and, at the same time, the existing exemption enjoyed by small waste generators has been abolished. These changes will primarily affect the beauty industry, including hairdressers, barbers, make-up artists, make-up artists, nail, eyelash or eyebrow stylists. For more information follow the link. 

From 2025, an obligation to segregate construction and demolition waste into 6 fractions has also been introduced. The most important change is the abandonment of the obligation to segregate R & D waste at the place where it is generated - the entrepreneur can outsource this to another authorised entity with permits and an entry in the BDO, provided that an appropriate agreement is concluded. For more information, see the entry at the link. 

Contained in the draft PPWR regulations will affect all businesses introducing packaged products. Cosmetics manufacturers are also included in this group. Let us recall that the current Packaging and Packaging Waste Directive does not introduce any specific requirements for the entire life cycle of cosmetic packaging. However, we are about to experience a real packaging revolution in the cosmetics industry.

With the entry into force of the provisions of the PPWR, the following requirements will apply to the cosmetics industry:

• minimising packaging,
• suitability of packaging for recycling,
• mandatory use of recyclates,
• the need to restrict certain packaging formats (e.g. mini hotel products),
• mandatory labelling of packaging as to sorting and reusability,
• reuse of transport and collection packaging,
• an obligation to reduce the use of biodegradable and compostable packaging.

The draft packaging regulation adopted by the EP obliges manufacturers of cosmetic packaging to reduce its weight and volume as much as possible. However, this must be done without compromising the safety of the products packaged in them or the functionality of the packaging itself. This functionality is understood through the following criteria:

• Product protection,
• production and filling processes,
• logistics,
• information requirements,
• hygiene and safety,
• legal requirements,
• recycled content, recyclability and reusability.

From the market multi-layered, double-walled, false bottom packaging will therefore disappear and other elements whose sole purpose is to increase the volume visually.

Minimisation of volume will also have an impact on transport and bulk packaging, in which the the void ratio will be up to 40%.

The recyclability of cosmetics packaging will be assessed according to criteria to be implemented in two stages. In phase I, presumably from 1 January 2030, each packaging will have to meet EU design criteria for recycling (Design for Recycling), which take into account the state of the art, collection and sorting. In phase II, implemented from 1 January 2035, packaging will have to meet DfR criteria and an additional criterion demonstrating their 'large-scale' recyclability.

The PPWR regulation will therefore make it necessary to eco-design of all packaging, i.e. designing it for later recycling.

Cosmetics packaging will be categorised into different recyclability classes, the highest of which will be class A, indicating a recyclability of 95% or more by weight of packaging. Packaging whose recyclability will be less than 70% by weight (Class E or below), will not be able to be placed on the market in the EU. The amount of the product fee (eco-modification) will also be linked to the recyclability class.

The draft PPWR regulation also provides for Mandatory use of plastics recovered from post-consumer waste (recyclates) for cosmetic packaging. The way in which it will be determined (per unit of packaging, per manufacturer's product portfolio or per other unit) has not yet been definitively confirmed, nor have the levels of use of recyclate proposed to the cosmetics industry. Initially, these were to be 10% of recyclate by 2030 and 55% by 2040. Whether these proposals will be maintained or increased is likely to be known by the end of this year.

In order to meet the projected regulations, leading players in the cosmetics industry are constantly expanding their range of products in recycled or recycled-infused packaging. Such ecological cosmetic packaging They are also often minimised.

Not all types of packaging will see a major overhaul - some of them will be completely banned. We are talking about miniature hotel cosmetics. This packaging format has been assessed by the European Commission as excessive or unnecessary.

Once the PPWR comes into force, however, travel mini cosmetics up to 100 ml will remain on drugstore shelves - only hotel products will be banned. However, it is well known that the EC may expand the catalogue of banned packaging in the future.

The PPWR regulation also aims to harmonisation of the labelling on packaging. They will have to clearly indicate the material composition packaging to make it easier for consumers to sort their packaging waste. Reusable packaging, meanwhile, will feature a QR code or other information to facilitate reuse.

With the introduction of the new labelling, information that could confuse or mislead consumers will be prohibited on the labels and throughout the packaging.

All requirements under the draft PPWR are designed to reduce the consumption of primary raw materials, slow down the rate of growth of packaging production and increase the proportion of recycled materials in almost all packaging, not only cosmetic packaging. The effect of their implementation is to bring the whole EU closer to the goal of a low-carbon, closed-loop economy.

PPWR regulations cover the entire life cycle of packaging, placing particular emphasis on designing for later recycling and closing the raw material cycle. This is due, among other things, to the fact that plastic packaging is highly carbon intensive, and in terms of fossil fuel consumption recycling of the resulting waste is five times more beneficial than incineration with energy recovery[i].

The final text of the PPWR was adopted by the European Parliament on 24 April 2024. As expected, the Council will confirm the adoption of the regulation by the end of this year at the latest, and the new rules will take effect from 2026.