Overview
BDO Poland 2026 – the central database for products, packaging, and waste management (Polish: "Baza Danych o Produktach i Opakowaniach oraz o Gospodarce Odpadami", abbreviated BDO) – remains essential for manufacturers, importers, distributors, and service providers. BDO fees for 2025/2026: PLN 200 for micro-enterprises (fewer than 10 employees and annual turnover or balance sheet total ≤ EUR 2 million) and PLN 800 for all other companies, payable by the end of February to the Voivodeship Marshal's Office (Polish: "Urząd Marszałkowski"). Annual reports must be submitted electronically by March 15 (next working day if the weekend falls on a weekend). The verification module (Polish: "Moduł Potwierdzeń") has been operational since January 1, 2025, for plastic fishing gear (Polish: "narzędzia połowowe z tworzyw"); full electronic verification for packaging (DPR/EDPR, Polish: "Dokument Potwierdzający Recykling / Eksport") is planned for 2027. The deposit return scheme (Polish: "system kaucyjny") started on October 1, 2025, for selected beverage packaging. ROP Poland 2026 (Extended Producer Responsibility, EPR) introduces a packaging levy (Polish: "opłata opakowaniowa") – 8% of the state-set product fee (Polish: "opłata produktowa", zł/kg) according to Government Draft UC100; specific rates will be determined by regulation. Sanctions of up to PLN 1 million (Article 194 of the Waste Management Act, Polish: "Ustawa o odpadach"). This article explains the BDO number for Poland, KPO/KEO Poland, risks, and checklists. (148 words)
Fundamentals of the Polish Waste Register (BDO Poland 2026)
The Waste Register forms the digital core of packaging law in Poland 2026 and waste management. It ensures the seamless tracking of products, packaging, and waste in accordance with Article 50, Paragraph 1 of the Waste Act (Polish: "Ustawa o odpadach" of December 14, 2012; Polish Journal of Laws "Dziennik Ustaw", Dz.U. 2024 poz. 1914, as amended). Every legal entity or individual entrepreneur who imports packaging, generates, transports, stores, or recycles waste requires a BDO number. The system integrates four core modules: the BDO Register (Polish: "Rejestr BDO") for registration, waste accounting (Polish: "Ewidencja Odpadów"), reporting (Polish: "Spravozdawczość"), and the verification module (Polish: "Moduł Potwierdzeń"). Without a BDO number, the activity is considered illegal and can trigger BDO sanctions. Registration is exclusively online via bdo.mos.gov.pl using electronic identification – a trusted profile (Polish: “Profil Zaufany”) or the ePUAP platform (Polish: “ePUAP”). The Provincial Marshal's Office (Polish: “Urząd Marszałkowski”) typically reviews applications within 30 days.
Who is subject to the registration requirement?
Obligated parties include importers of packaging, batteries, and electrical appliances, as well as producers/processors of waste. Micro-enterprises (as defined) are exempt, provided no imports take place. Foreign companies must register through a Polish branch or representative office. The BDO number must be included on all relevant documents (e.g., invoices), where applicable.
Note regarding identifiers: Tax Identification Number (Polish: "NIP") and Statistical Number (Polish: "REGON").
Practical checklist for initial data collection
Create an account on the portal → Submit NIP/REGON, address, and job description → Pay the registration fee (Polish: "opłata rejestrowa") → Receive your BDO number. Report any changes (e.g., address) within 30 days.
BDO Fees 2025/2026: Detailed cost structure and payment terms
By regulation (effective January 1, 2025), both the registration fee (Polish: "opłata rejestrowa") and the annual fee (Polish: "opłata roczna") are PLN 200 for micro-enterprises and PLN 800 for all other businesses. Payment is due by the end of February to the Provincial Marshal's Office (Polish: "Urząd Marszałkowski") – bank transfer quoting the BDO number. For tax purposes: deductible as business expenses (CIT/PIT); no input tax deduction (no VAT charged). Failure to pay will result in late fees/enforcement proceedings.
Overview table: BDO fees in comparison
| Fee category | Micro-enterprises (<10 employees; turnover/total assets ≤ 2 million EUR) | All other companies | maturity | payee |
|---|---|---|---|---|
| Registration fee (Polish: “opłata rejestrowa”) | 200 PLN | 800 PLN | During registration | Voivodeship Marshal’s Office (Polish: “Urząd Marszałkowski”) |
| Annual fee (Polish: “opłata roczna”) | 200 PLN | 800 PLN | Until the end of February annually | Voivodeship Marshal’s Office (Polish: “Urząd Marszałkowski”) |
System financing: fees + grants from the National Environmental Fund (Polish “Narodowy Fundusz Ochrony Środowiska i Gospodarki Wodnej”, NFOŚiGW) amounting to approximately PLN 94 million (2025-2027).
Tax optimization tips
Archive fee receipts in an audit-proof manner and book them as expenses; pay separately for multiple locations in each voivodeship.
Registration process in the BDO register: step-by-step
Digital registration via eID; upload company register extract – Court Register (Polish "KRS")/Business Register (Polish "CEIDG"), power of representation, proof of business activities. Processing takes approximately 30 days (no statutory 7-day limit). In case of rejection: appeal within 14 days. The BDO number (e.g., 000XXXXXX) is valid as long as data is maintained.
Common pitfalls and solutions
Avoid incomplete applications; use API interfaces to ERP systems (e.g., SAP, Comarch).
Example: Manufacturing company
Without a BDO number → inspection, business interruption, loss of tax deductibility for disposal costs. What if: Pre-registration → stable processes, compliance.
Waste accounting (Ewidencja): KPO vs. KEO in BDO Poland 2026
The accounting system is fully electronic and mandatory.
KPO – Waste Transfer Card (Polish: “Karta Przekazania Odpadu”): documents each transfer/transport to a third party.
KEO – Waste Accounting Card (Polish: “Karta Ewidencji Odpadów”): continuously records internal storage/processing operations.
Comparison table: KPO vs. KEO
| criterion | KPO (Handover/Transport) | KEO (Internal Accounting) |
|---|---|---|
| Purpose | Proof of transfer | Registration of internal processes |
| frequency | At every handover | Daily/monthly |
| Contents | Sender, recipient, quantity, code | All movements within the work |
| Consequences for mistakes | Penalty per case | Fine for inaccuracy |
| integration | Automatically with BDO number | ERP-compatible |
Recommendation: Implement software interfaces to avoid discrepancies → fewer BDO sanctions.
Industry example: Logistics company
Missing KPO during transport → penalty for non-compliance, VAT risks. What if: Automated generation → compliance ensured.
Sprawoz representation in the BDO: Dates & Best Practices
Annual reports (Polish: "Sprawozdawczość") on quantities, quotas, and costs are due by March 15th (next business day if a holiday/weekend) via the BDO account. Zero reports are only issued if explicitly required. Data access from KPO/KEO is automated.
Timetable 2026
- Preparation: January 2026
- Submission deadline: March 15, 2026 (or next working day)
- Correction deadline: usually 14 days after official request.
Confirmation module: Status & preparation for 2027
Confirmation module (Polish: "Moduł Potwierdzeń") for plastic fishing gear (Polish: "narzędzia połowowe z tworzyw") has been mandatory since January 1, 2025. It replaces paper with electronic mass verification documents (Polish: "zaświadczenia o masie"). Paper documents for DPR/EDPR (Polish: "Dokument Potwierdzający Recykling / Eksport") remain permissible until December 31, 2026; full digitization is planned for 2027. Plan for ERP system adjustments now.
ROP Poland 2026 (EPR): Producer Responsibility & Levies
The ROP reform (draft law UC100 of August 13, 2025) will take effect on January 1, 2026. The packaging levy (Polish: "opłata opakowaniowa") amounts to 8% of the product fee (Polish: "opłata produktowa", zł/kg; Regulation of the Ministry of Climate and Environment – Polish: "Ministerstwo Klimatu i Środowiska", MKiŚ – of December 9, 2023). Funds are allocated to municipalities based on population. 20% in 2027, full funding in 2028.
Deposit system in Poland: Interlinking with BDO
Since October 1, 2025, mandatory deposit collection is required for PET bottles (<3 l, 0.50 PLN deposit), metal cans (<1 l, 0.50 PLN deposit), and reusable glass (<1.5 l, 1 PLN deposit). Retailers larger than 200 m² are required to install reverse vending machines. A BDO number is mandatory for operators.
Sanctions & Risk Management
According to Article 194 of the Waste Management Act (Polish: "Ustawa o odpadach"), fines of 1,000–1,000,000 PLN can be imposed (e.g., for lack of registration, incorrect accounting). Fines are not tax-deductible.
Risk minimization
Monthly self-audits, training, external consulting; ERP/API integration reduces errors and audit risks.
Industry-specific requirements
Construction: KEO for all quantities; KPO for transport.
Chemicals/Production: strict monitoring of hazardous waste.
Timeline table: BDO Poland 2025-2027
| Year | Milestones |
|---|---|
| 2025 | Fees 200/800 PLN; Confirmation module (SUP); Deposit system 01.10.2025 |
| 2026 | ROP 8%; Paper EDPR until 31.12.2026 |
| 2027 | Full electronics for packaging |
Practical checklists for board members and managers
Registration: [ ] Create account [ ] Upload documents [ ] Pay fee
Daily: [ ] Maintain KEO [ ] Generate KPO
Annually: [ ] Report by March 15
Frequently Asked Questions (FAQ) about BDO Poland 2026
1. Who needs a BDO number?
Companies that import packaging or generate waste (Article 50 of the Waste Act). Micro-enterprises (as defined) are exempt if they have zero activity. Digitally available at bdo.mos.gov.pl.
2. What will the BDO fees be in 2025/2026?
200 PLN (micro-enterprises) / 800 PLN (all others) – Registration/annual fee (Polish: “opłata rejestrowa/opłata roczna”). Payment due by the end of February to the Voivodeship Marshal's Office (Polish: “Urząd Marszałkowski”). Tax deductible for income tax purposes; no input tax deduction.
3. Difference between KPO and KEO?
KPO – waste transfer card (Polish “Karta Przekazania Odpadu”) vs. KEO – waste accounting card (Polish “Karta Ewidencji Odpadów”); both electronically mandatory.
4. BDO Reporting March 15th?
Submission deadline: March 15 (next working day); automatic data transfer; late submissions may incur fees.
5. ROP 2026 – what will change?
Packaging tax (Polish “opłata opakowaniowa”) 8% of the product fee (Polish “opłata produktowa”) from January 1, 2026 (UC100).
6. Deposit system – obligations?
Deposit 0.50/1 PLN; Retailers >200 m² with vending machines; BDO number required.
7. Confirmation module – Timeline?
Since 2025 for plastic fishing gear; packaging fully digital from 2027 (DPR/EDPR).
8. Registration time?
Up to ~30 days (official practice).
9. Zero reports?
Only if explicitly ordered.
10. Maximum sanctions?
Up to 1 million PLN (Art. 194).
Summary
In summary: Companies that place packaging on the market or handle waste in Poland require a BDO number; registration is entirely online, and failure to register can lead to business closure and fines. The registration and annual fee (Polish: "opłata rejestrowa/opłata roczna") is PLN 200 for micro-enterprises and PLN 800 for all others and is due by the end of February; it is tax-deductible, but no input tax deduction is permitted. The annual BDO report (Polish: "Sprawozdawczość") is due by March 15; KPO/KEO reports are processed electronically. The verification module (Polish: "Moduł Potwierdzeń") is active and will become fully mandatory for packaging from 2027. From 2026, ROP/EPR will take effect with a packaging levy (Polish: "opłata opakowaniowa") of 8% of the product fee (Polish: "opłata produktowa"), while the nationwide deposit system has been operational since October 1, 2025. Establishing ERP/API interfaces early, defining clear responsibilities, and conducting regular self-audits/training will reduce compliance costs and minimize the risk of sanctions under Article 194 of the Waste Act.
"For a strategic overview of the biggest contractual risks in Poland in 2025 for German companies – from supply chains and default interest to liability and tax issues – we recommend our article: " Doing business in Poland in 2025: The 7 biggest contractual risks for German companies in contracts with Polish partners ".
Should you have any questions regarding BDO (Database for Products, Packaging and Waste Management) in Poland in 2026, you can contact us by email at kontakt@kancelaria-pozniak.pl or by phone at +48 665 246 969 .