Can a company without waste also have obligations in BDO?

This is one of the most common mistakes entrepreneurs make: equating BDO exclusively with waste. In practice, a company may not keep classic waste records and yet still be subject to registration in the BDO register. This is because the system covers not only waste management, but also a range of obligations for products and packaging placed on the market. Business.gov.co.uk and BDO explicitly point out that the register includes not only waste producers and waste holders, but also entrepreneurs introducing packaged products, batteries or accumulators, electrical and electronic equipment, tyres, lubricating oils and those running commercial units offering plastic bags covered by the recycling levy. This means that the absence of „own waste” does not yet give the right to assume that BDO can be completely disregarded.

Packaging, parcels and commercials - the three most common cases

The first very common case is a company that packages the goods itself and ships them to customers. Even if it does not keep classic waste records, it can be treated as an introducer of packaged products. The second case is an entrepreneur who is a manufacturer, importer or intra-Community buyer of packaging - here, the mere circulation of packaging can give rise to registration and fee obligations. A third typical example is a shop or wholesaler offering plastic shopping bags subject to a recycling fee. Business.gov.co.uk points out explicitly that such an entrepreneur later reports on the number of bags purchased and issued, and the very fact of offering these bags is one of the classic reasons for entering BDO. These are precisely the situations in which a company can say „I have no waste” and yet formally still have obligations on the register. 

Batteries, electronics, tyres and oils - another four situations that companies overlook

The fourth frequent case is a trader introducing batteries or accumulators, also fitted into products. The fifth is a company introducing electrical and electronic equipment. The sixth involves operators introducing tyres on the national territory. The seventh covers entrepreneurs introducing lubricating oils. All of these groups are explicitly mentioned in BDO's official materials as being subject to registration, and BDO additionally reminds us that it is these categories of entrepreneurs that are also subject to a registration fee and an annual fee. In practice, this is particularly important for importers, distributors and sellers of certain products who do not associate their activities with „waste”, but enter the system through product obligations under the legislation. This applies, for example, to companies importing toys with batteries, consumer electronics, car parts or consumables. 

When can a company really be out of BDO?

Not every business needs to have an entry. BDO indicates that some businesses can benefit from exemptions, and that some small service activities, such as office, accountancy, consultancy or hairdressing, are sometimes exempt as generators of municipal waste - as long as they do not fall under other obligations, such as product or medical waste. This is the most important practical conclusion: the answer to the BDO question does not depend on whether a company „has waste” in the colloquial sense, but on whether it carries out at least one activity listed in the legislation. Therefore, the safest approach looks like this: you first check whether your company packs, imports, sells or offers products and packaging covered by the Act, and only then assess whether you are actually off the register. This is where most companies make the mistake of only analysing office waste and ignoring packaging, commercials, batteries or equipment.

If you want to check whether your company is really out of BDO or is just wrongly assuming a lack of obligations, it is worth verifying this before a problem arises in audits or settlements. For details, see Contact page there, you can describe your business model and match the support to your company's real responsibilities.