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Good to know New regulation on waste for which no records need to be kept

New regulation on waste for which no records need to be kept

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​​​​​​​​​​​​​​​​by Joanna Lech

27 May 2025


Regulation of the Minister of Climate and Environment on types and quantities of waste for which no waste records have to be kept* has been in force in Poland since 1 January 2025.

Key changes


The regulation amends, among other things, the existing catalogue/list of wastes which have not required regulation with the BDO waste database so far.

Hazardous waste removed from the list


The new regulation brings national legislation in line with EU legislation which requires keeping records of all types of hazardous waste.

This means that since 1 January 2025, all hazardous waste, regardless of the quantity, must be recorded.

List of wastes exempt from recording


The regulation contains a list of wastes which do not need to be entered in the waste records. They include, without limitation:

  • Plant-tissue waste (code: 02 01 03) – no limit on quantity
  • Animal faeces (code: 02 01 06) – no limit on quantity
  • Paper and cardboard packaging (code: 15 01 01) – up to 0.5 Mg/year.

Alignment with EU laws


The regulation aims to harmonise the national and EU legislation to ensure better control and proper management of hazardous waste. 

Who has to register with the BDO waste database?


The obligation to register with the BDO waste database applies in particular to:

  1. marketers of equipment and authorised representatives in Poland,
  2. marketers of batteries and accumulators,
  3. marketers of vehicles,
  4. manufacturers, importers and intra-Community purchasers of packaging,
  5. marketers of packaged products in Poland,
  6. marketers of tyres in Poland,
  7. marketers of lubricating oils in Poland,
  8. producers of non-household waste,
  9. operators of retail or wholesale units offering plastic shopping bags covered by the recycling fee referred to in Article 40a of the Packaging and Waste Packaging Management Act of 13 June 2013.​

Penalties for failure to register with the BDO


Running a business without the required or up-to-date entry in the BDO register may result in an administrative fine of up to as much as 1,000,000 zloty.

Summary


The new regulation introduces significant changes to recording of waste, particularly in the context of hazardous waste. At Rödl& Partner, we support businesses in adapting their procedures to the new requirements, as well as in verifying whether or not the waste they generate requires entry or updated entry in the BDO waste database. 


* Regulation of the Minister of Climate and Environment of 5 November 2024 on types and quantities of waste for which no waste records have to be kept (Journal of Laws of 2024, item 1644).​

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Joanna Lech

Attorney at law (Poland)

Senior Associate

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