What is BDO and who is affected by waste records
BDO stands for Database on products, packaging and waste management - a nationwide online register operated by the Ministry of Climate and Environment. Entrepreneurs with waste-generating activities should register in the BDO system (available on the official website [BDO.gov.pl]) and obtain an individual registration number. In accordance with the law on waste (consolidated text Dz.U. 2023 item 1587), the waste holder is obliged to keep quantitative and qualitative records of the waste produced.
The obligation to keep records does not apply to certain groups, such as property owners (household waste), small farmers, vehicle dismantling stations or individuals generating construction waste during renovations. In other cases, setting up an account with BDO and keeping records is mandatory. Accurate waste records are also the basis for annual reporting on waste management.
How to keep records of waste in BDO (KEO, KPO, KPOK)
Record-keeping in the BDO system is carried out using electronic forms. Traders register waste by creating record sheets (KEO) and handover sheets (KPO or KPOK).
In this way, every stage of waste handling - from generation to transport to treatment - is documented in the system. This allows stock levels to be monitored on an ongoing basis and facilitates reporting.
Step by step: creation of a KEO
A waste record card (KEO) is a form that records the waste generated by an entity's activities. In the BDO system (module „Waste records”) option „New waste record card” is selected. Indicate the waste code (from the catalogue), tick the prefix if any ex (if applicable), enter the description and type of waste and the initial state of the waste mass (in tonnes) on 1 January of the year in question. The sheet applies to one waste code and is valid for the entire accounting year.
Once the card has been created, further entries can be added: these relate to waste produced, extracted (if the company has mining operations), accepted from other entities and submitted for further treatment. Each entry gives the date, the weight of the waste (in tonnes) and additional details (e.g. the source of the waste). Thanks to the electronic records, the data is saved in real time and can be used to automatically generate annual reports and statements.
Issuance and circulation of KPO/KPOK
The waste transfer note (WTP) is drawn up by the party handing over the waste - e.g. the company handing over the waste for transport or directly to the treatment facility. The KPO is produced by before transporting the waste and concerns one type of waste. In BDO we select „New waste transfer note”.”
and enter the following data: date of transfer, details of consignor and consignee (their names, addresses and BDO registration numbers), waste code and weight. After saving, the card becomes Planned.
The transporter prints a confirmation from the system and carries out the transport. After the waste has been delivered, the waste collector changes the status of the card in BDO to Realised and confirms the take-over of the load by entering the final weight (if different from the original). If necessary, the KPO card can be corrected or cancelled (e.g. deleted if the shipment has not been completed). In this way, all changes in the status of the waste are tracked in BDO.
For municipal waste, the principles are analogous, using KPOK cards (municipal waste transfer note). The KPOK card is drawn up by the entity collecting municipal waste from residents (e.g. rubbish collection company, PSZOK) before the collection of a given batch of waste. The KPOK form contains analogous data to the KPO (sender, recipient, waste code, weight) and additional information specific to municipal waste. Confirmation of receipt proceeds in the same way - the collector approves the receipt of the load in the system.
Attention: According to Article 69(4) of the Waste Act, if the waste is transferred by an entity covered by the BDO records and the recipient is a company or a person exempted from the records, a KPO card need not be issued. The responsibility for recording the transfer then falls on the waste generator.
Exemptions and simplified records (limits of 100 kg/year and 5 t/year)
The waste legislation provides exceptions to full record-keeping for smaller generators. Among others, homeowners (municipal waste), home renovators (construction waste) and small farms (up to 75 ha) are exempted from the obligation to keep records. For the rest of the companies, record-keeping remains mandatory.
The Act also provides the opportunity to simplification of records for companies generating small amounts of waste. Pursuant to Article 71(2) of the Waste Act, the simplification of records (involving only KPO/KPOK cards) is available to those who, during the year, produce up to 100 kg of hazardous waste or up to 5 tonnes of non-hazardous waste (other than municipal waste). Companies within these limits can only keep records through transfer cards, without setting up separate KEO cards. Once the limits are exceeded, the company switches to full record-keeping with KEO cards.
Example Practical: A construction company generating a large amount of construction rubble (waste code 17 01 07) must keep full records - create a KEO card for the rubble and issue KPO cards each time it receives waste. On the other hand, a small car repair shop producing e.g. 80 kg of used engine oil (hazardous waste) per year is within the limit of simplified records (less than 100 kg/year)
and documents the waste with KPO cards only. Similarly, an entrepreneur producing about 4 tonnes of paint per year can keep simplified records (limit of 5 t/year), but after 5 t/year he will have to keep full records with KEO cards.
The table below summarises the key differences between full and simplified records:
| Feature / Requirement | Complete waste records | Simplified waste records |
| Items covered | Most companies generating waste (outside of defined exemptions) | Operators generating ≤100 kg of hazardous waste or ≤5 t of other waste per year (excluding municipal) |
| Documents in the system | Waste record sheets (KEO/KEOK) and transfer notes (KPO/KPOK) for each waste code | Waste transfer notes (KPO/KPOK) only - without separate KEO cards |
| Contents of the records | Detailed registration of each operation (quantity, date, source) in KEO cards | Waste data shall be recorded on the basis of mass totals from KPO/KPOK cards (no current entries in KEO) |
| Reporting | Obligation to submit an annual report about waste management in BDO | Obligation to register and reporting remains, but records are simplified |
| Practical example | Production company generating a variety of waste (e.g. chemical, construction) | Small service company generating small amounts of waste (e.g. up to 5 t/year) |
Nhe most common errors and penalties (articles 66-72 of the law on waste)
In practice, maintaining correct waste records requires meticulousness. The most common mistakes include incorrect use of simplified records, omitting certain wastes from the registers, using one card for several branches or entering the weight in the wrong units (e.g. kg instead of tonnes). Companies also often forget to put the BDO registration number on the documents. For example, if you enter „500” in the kilograms field instead of 0.5 tonnes in the record card, the system will treat this as 500 tonnes - which will significantly overstate the waste. Such an error will be detected when the data is verified.
The law provides for severe sanctions for record keeping failures. Inspection authorities may impose an administrative penalty of several thousand to PLN 1 000 000 for BDO violations (e.g. failure to register, failure to keep records, entering data that is not in accordance with the facts). A fine of PLN 20,000 to PLN 5,000 is imposed for failing to include a compulsory report, while a fine of between PLN 20,000 and PLN 5,000 is imposed for failing to issue or erroneously confirming a KPO card. PLN 1 000 To PLN 1 000 000. In addition, the responsibility
Criminal and administrative penalties (fines or even imprisonment) may be imposed on those who deliberately falsify da.
FAQ - Frequently asked questions and answers
Does my company need to register with BDO and keep waste records?
Every entrepreneur who generates waste in the course of his or her business activities (with the exceptions specified in the Act) must register with BDO and keep records of waste. This means having a BDO registration number and producing the relevant KEO and KPO sheets each time waste is handled. Failure to register with BDO or to keep records constitutes a breach of the law and may result in penalties.
What is simplified waste accounting and when can it be used?
Simplified waste recording consists of documenting waste exclusively by means of transfer notes (KPO/KPOK) - without setting up separate record sheets (KEO). This entitles generators to 100 kg per year of hazardous waste or to 5 tonnes per year of non-hazardous waste (other than municipal waste). In practice, companies falling within these limits only keep KPO/KPOK cards. Once the limit is exceeded, the company must switch to full records with KEO cards.
What are the KEO, KPO and KPOK cards and when to set them up?
Cards KEO (Waste Record Cards) are internal company documents used to record waste of a particular type during the year. Cards KPO (Waste Transfer Cards) document the transfer of waste between entities - they are created by always before transport waste to another holder. Cards KPOK are analogous, but apply to municipal waste. In practice, in the BDO system, the relevant card type (KEO, KPO or KPOK) has to be selected and the data entered: shipper, consignee, code and weight of the waste. Once the load has been accepted, the next entity confirms this in the system, closing the documentation chain.
What are the penalties for lack of records or errors in BDO documentation?
Failure to register in the BDO register or keeping records contrary to the facts is an offence. The VIO may impose a fine from PLN 5,000 To PLN 1 000 000. Failure to submit the mandatory report (by 15 March) is punishable by a fine of PLN 20-5,000, while the absence of a KPO card (or its erroneous confirmation) is punishable by a fine from PLN 1 000 To PLN 1 000 000. Deliberate falsification of data or evasion can attract criminal liability (fine or even imprisonment).
How long to keep documents and when to report?
Record-keeping documents (KEO cards, KPOs, etc.) must be kept for at least 5 years from the end of the year in which they were generated. The annual waste management report is submitted electronically to BDO by 15 March for the previous year. Data for the report is taken directly from the BDO system, so it is important to keep records reliably throughout the year.
EkoPro Group support
EkoPro Group supports entrepreneurs in waste recording and operation of the BDO system. We offer comprehensive support - from the registration of the company in BDO, through the maintenance of KEO, KPO and KPOK cards to the preparation of the required reports. Thanks to our experts, your waste records will be kept on time and error-free.
Feel free to contact us - our specialists are available to assist you at any stage (contact form and contact details available on the EkoPro Group website).
