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Environmental reporting obligations and fees

by Joanna Lech

16 January 2023

February and March is the reporting and accounting period for environmental protection.

Please pay special attention to the obligation to:

submit a report to the National Centre for Emissions Management at the Institute of Environmental Protection (KOBIZE),
submit a list to the marshal office,
pay due environmental fees, if any,
and reporting obligations to be fulfilled through the database of products, packaging and waste management (BDO) and related fees.

Entities using the environment, whose activities cause emissions are required to:

submit a list containing information on the use of the environment to the locally competent marshal office – by 31 March;
pay due environmental fees – by 31 March;
submit a report to KOBiZE – by 28 February;

The above obligations apply in particular to entities:

combusting fuels in combustion engines (e.g. by using vehicles or construction machinery);
combusting fuels in boilers or generators;
carrying out technological processes (e.g. painting, varnishing, welding, smoking);
using air conditioning equipment;
whose activities include the handling of fuels;
landfilling waste;
engaged in crop or animal production.

Failure to timely submit the list is punishable by a fine. In addition, in the event of failure to submit the list or providing information and data or the amounts of fees payable that give rise to concerns, competent authorities may impose fees by decision and may enforce them.

Entities entered in the BDO register are required to:

1. pay the annual fee for entry in the BDO register – by the end of February.

This obligation applies to:

marketers of equipment and authorised representatives,
marketers of batteries and accumulators,
marketers of vehicles,
manufacturers, importers and intra-Community purchasers of packaging,
marketers of packaged products in Poland,
marketers of tyres in Poland,
marketers of lubricating oils in Poland.

The annual fee for:

micro-enterprises is PLN 100;
enterprises other than micro-enterprises is PLN 300.

The annual fee must be paid to a separate bank account of the competent marshal office.

2. prepare the annual report(s) and, if applicable, pay the product fee – by 15 March.

The reports need to be prepared and submitted to the competent marshal office using an individual account in the BDO.

Failure to submit the report is an offence punishable by a fine.

Please be also reminded that you need to place your BDO number on, among others, the following documents: VAT invoices, cash register receipts, contracts and reports.

Failure to comply with the requirement to place your BDO number on documents is punishable by an administrative fine ranging from PLN 1,000 to PLN 1,000,000.

Do you have doubts about your environmental obligations? Contact our experts.

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Joanna Lech

Attorney at law (Poland)

+48 882 786 780

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