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In today's dynamic economy, companies of all sizes are constantly looking for ways to expand their business and increase profits. Imports from China provides an attractive pathway to access a wide range of products. The lower production costs there translate into more competitive prices, which creates great opportunities for many businesses. However, while the benefits of importing from China are undeniable, it is important for companies to properly understand and comply with the necessary regulations and procedures. One of these important steps is registration with (BDO). The register is concerned with waste management and registration with the system is mandatory for all importers.
What is BDO?
BDO stands for Waste Database. All importers who introduce packaged products, packaging, batteries and accumulators, electronic and electrical equipment, vehicles, tyres, oils and lubricants into Poland are required to register in the system.
The system aims to bring more control in the State over the waste that enters the country.
Who is affected by the BDO registration obligation?
The obligation to register with BDO applies to companies that:
- Companies that market packaged products, packaging, batteries and accumulators, electronic and electrical equipment, lubricants, oils, vehicles, tyres
- Companies that generate and manage waste
- Entities including importers / producers who purchase packaging
- Retailers or wholesalers offering plastic bags
To find out if you are required to register with BDO complete the questionnaire below and check: -> https://bdo.mos.gov.pl/ankieta/
How do I register with BDO?
- The first step to enter the BDO register is to pay the annual fee to the Marshal's Office. The fee must be paid by the end of February each year.
The rate for:
micro-entrepreneurs - PLN 100.00,
entrepreneurs other than micro-entrepreneurs - PLN 300.00.
( A micro-entrepreneur is an entity that has less than 10 employees and a turnover of EUR 2 MILLION net per year )
Please state in the title of the transfer:
- the name, address and tax identification number of the payer
- annual fee for 2024
Example: Union Cargo, Madalińskiego 09-191 Nowy Sącz, NIP: 5313546481, annual fee for 2024
In the link below you will find the data for the Marshal Offices in the respective province:
You will then need to find the account number for the payment on the website of the authority concerned. The best way is to enter BDO in the search engine on the website.
2. you must register in the system: https://rejestr-bdo.mos.gov.pl/
There, we create a new account and confirm our identity with a trusted profile or E-ID. We then proceed to create a new application. Instructions on how to do this can be found in the link below:
(3) Once completed, the application must be accompanied by a receipt for the fee you paid to the office.
4. within 30 days if there are no errors in the application, we will receive information about the registration. If there is an error, the office will contact us within 7 days to correct it.
BDO number
The BDO number has nine digits and is individually assigned after the office has made an entry in the register. It should be included on business-related documents such as commercial invoices, contracts and receipts.
What are the penalties in the absence of a BDO entry?
- Penalty for lack of registration in the BDO register - from PLN 5000 to PLN 1 million.
- penalty for lack of BDO number on documents issued by the entity (invoices, contracts, receipts) - from PLN 5000 to PLN 1 million
How to keep records in BDO ? What do I need to do next ?
Once registered with BDO, the importer must comply with a number of other BDO-related things:
- The most important thing is BDO record keeping. The records are kept in an electronic system and we are required to enter the weight of the packaging and the products we place on the market. The records are kept on a monthly basis.
- An annual report on the amount of waste produced must be submitted once a year by 15 March
- Product charge - Also by 15 March, a product fee must be paid for each package or product placed on the market.
The exact price list can be found in the link below - the amount depends on the material of execution
- Fee for educational campaigns - are paid once a year by the end of December and amount to 2 % net of the value of the packaging placed on the market. The fee is sent to the account of the Marshal's Office.
Also, it is possible for an entity to carry out such an educational campaign on its own by just allocating no less than 2 % of net value per pack introduced. It can do through posters, videos, etc.
- BDO annual fee - PLN 100 or 300 - paid as at the beginning for entry in BDO, to the same account number. ( see above for information on who will pay what fees)
Who does not have to keep BDO records?
Some entities may be exempt from BDO records. However, I need to market smaller quantities than:
- Glass packaging → up to 500 kg per year
- Paper packaging → up to 500 kg per year
- Multi-material packaging → up to 500 kg per year
- Wood packaging → up to 1000 kg per year
- Textile packaging → up to 500 kg per year
- Plastic packaging → up to 500 kg per year
Product fee avoidance
It is possible to avoid the product fee if you do not exceed the annual weight of the packaging as above or if you sign a contract with an organisation that recycles.
Organisations that deal with this do so on a fee basis, but this is often more favourable than paying a product fee. Therefore, the possibility of such cooperation should be considered.
BDO at import
BDO for car imports
Those who import cars into Poland become importers of batteries, accumulators, oils, lubricants and tyres.
Requirements:
- registration in the BDO system
- Payment of the annual fee of PLN 100 or 300 (information on who must pay what amount above)
- signing the contract with min. 3 disassembly stations or 1 disassembly station and 2 vehicle collection stations.
- signing a contract with an entity that deals with the disposal and treatment of waste batteries and accumulators.
Bdo for the importation of batteries and accumulators
If batteries and accumulators are imported into Poland, the trader is obliged to do the following:
- registration in the BDO system
- Payment of the annual fee of PLN 100 or 300 (information on who must pay what amount above)
- Keeping records in the BDO system on a monthly basis
- Submission of a waste report once a year by 15 March
- Payment of a product fee for each battery or accumulator placed on the market. According to the tariff as in the link below:
It is possible to avoid the product fee by signing a contract with a company that deals with the treatment and disposal of batteries and accumulators.
- Earmarking 2% from the value of the packaging marketed for an environmental and recycling education campaign.
Bdo on import of electronic and electrical equipment
If we are marketing electronic or electrical equipment then we will need to do the following things:
- registration in the BDO system
- Payment of the annual fee of PLN 100 or 300 (information on who must pay what amount above)
- Keeping records in the BDO system on a monthly basis
- Submission of a waste report once a year by 15 March
- Payment of a product charge for each battery or accumulator placed on the market, including those incorporated into a product. According to the tariff as in the link below:
It is possible to avoid the product fee by signing a contract with a company that deals with the treatment and disposal of batteries and accumulators.
- Earmarking 2% from the value of the packaging marketed for an environmental and recycling education campaign.
BDO for imports of tyres and oils
When importing tyres and oils, the trader is obliged to:
- registration in the BDO system
- Payment of the annual fee of PLN 100 or 300 (information on who must pay what amount above)
- Keeping records in the BDO system on a monthly basis
- Submission of a waste report once a year by 15 March
- Payment of a product fee for each kilogram of tyre or oil placed on the market. According to the tariff as in the link below:
It is possible to avoid the product fee by signing a contract with a company that deals with the treatment and disposal of batteries and accumulators.
- Earmarking 2% from the value of the packaging marketed for an environmental and recycling education campaign.
