Does BDO concern you? Who is it that does not need to register and who should do so? Registration with the Waste Data Base (BDO) has become an obligation that affects a wide range of businesses in Poland. It is not just another formality to be fulfilled - its purpose is to improve waste management and environmental protection.
BDO - who does not have to register?
Registration with the Waste Data Base (BDO) is a requirement for many companies, but not everyone has to comply with this obligation. There are a number of exceptions that exempt certain entities from the need to register. These include:
- natural persons and organisational entities which are not entrepreneurs - who use waste exclusively for their own purposes.
- entities owning land on which municipal sewage sludge is applied - for the purpose of growing plants for the production of compost or non-food and fodder crops.
- non-professional collectors of packaging waste and used consumer goods - such as medicines and their packaging.
- transporters of self-generated waste - are also exempt from this obligation.
- farmers who are waste generators and farm an area of less than 75 ha.
Sole traders and entrepreneurs who generate only municipal waste are exempt from the registration obligation and are covered by the municipal waste collection system. Examples include small services, administrative and office activities, law firms and accounting offices. It is worth remembering that waste generated in staff welfare areas is treated as household municipal waste and their generators are also exempt from registration with BDO.
Companies that contract for construction, demolition, renovation, tank or equipment cleaning, cleaning, maintenance and repair services are exempt from registering with BDO as long as the waste generator is the entity providing these services. The exception is if the contract states otherwise.
Manufacturing and industrial companies that generate waste listed in the Decree of the Minister of Climate of 23 December 2019., also do not have to register, provided that the quantities of such waste do not exceed certain limits. This regulation covers 46 groups of waste, including animal faeces, concrete waste, concrete rubble, wood, glass and plastics, and some hazardous waste, such as used appliances containing hazardous components.
BDO - who needs to register?
BDO - who must register? Registration with the Waste Data Base is mandatory for the various entities defined in Article 50(1). the law of 14 December 2012 on waste. The decision to register is determined both by the area in which the company operates and the scope of its activities. Entities required to apply for entry in the BDO Register include:
- manufacturers and importers of oils, lubricating preparations and pneumatic tyres - who place these products on the domestic market, recycle, recover, export or intra-Community supply.
- automotive companies - those placing vehicles on the domestic market, operating vehicle collection points, dismantling stations and shredders.
- companies related to electrical and electronic equipment - those placing this equipment on the market, those collecting, processing, recycling and recovering the equipment, as well as recovery organisations.
- importers and manufacturers of batteries and accumulators - and treatment facilities for these products.
- Packaging companies - those that manufacture, export, import packaging, recycle packaging waste and market packaged products.
- waste carriers - and waste handlers.
- entities responsible for maintaining order and cleanliness in municipalities - operating points of selective municipal waste collection or having an entry in the register of regulated activities for municipal waste collection.
- companies generating waste other than that listed in the relevant Ministerial Climate Regulations - or in quantities greater than the specified limits.
Sole traders and rubbish - do you need to register with BDO? The system applies to large corporations as well as small businesses. Examples include beauty salons, doctors' surgeries, grocery shops, craft workshops and construction companies. Regardless of the size of the company, if it is required to keep waste records, it must be registered with BDO.
When is an ex officio entry made?
The provincial marshal automatically includes in the register companies that have obtained integrated permits, waste production permits, waste collection or processing permits, decisions approving the extraction waste management programme, permits for operating an extraction waste disposal facility and concessions for underground waste storage.
To check whether an entity is subject to mandatory registration, you can use the interactive form available on the BDO website, which allows the registration obligation to be established quickly and precisely. If you wish to delegate the system to an external company, the EKOPRO Group has the following services available BDO service for companies. We will make sure that all obligations are correctly fulfilled. We also provide environmental consulting.

