Who must register with BDO? Find out if your company is obliged to do so

If you are wondering who has to register with BDO, the answer is that the obligation does not apply to every entrepreneur, but to those entities that are engaged in waste management activities or market certain products and packaging. In practice, entry to the BDO register most often applies to companies that manage waste, produce waste covered by the registration obligations or market packaged products, packaging, electrical and electronic equipment, batteries and accumulators, vehicles, tyres or lubricating oils. At the same time, the legislation provides for exceptions, so the mere fact of carrying out an economic activity does not yet automatically imply an obligation to register. Importantly, in the case of activities requiring registration on application, the entrepreneur should submit an application prior to the commencement of such activities.

Which companies are most often required to have an entry in BDO

From a practical perspective, the BDO obligation most often applies to online shops and mail order companies that package goods for sale, importers and packaging manufacturers, workshops, production facilities, construction companies and entities that collect, transport or process waste. This is why phrases related to e-commerce, construction and the beauty industry appear so frequently in current search results. However, it is worth remembering that the name of the industry alone does not always determine the matter. Beauty is a good example: once the new record-keeping rules come into force from 1 January 2025, the Ministry of Climate and Environment has maintained its previous position that the obligation must be assessed by the type and scale of activity and the waste generated. In the construction industry, there is also an important rule: when a contractor performs a service of construction, demolition, renovation, cleaning, maintenance or repair, as a rule, the waste generator is the service provider, unless the contract states otherwise.

Who does not have to register with BDO

This is one of the most important questions typed into Google, as many entrepreneurs mistakenly assume that BDO applies to every company. Meanwhile, individuals and organisational entities that are not entrepreneurs and that use waste for their own purposes, entities carrying out non-professional collection of selected packaging waste and used consumer goods, as well as entities transporting waste generated by themselves, among others, are not subject to the entry. In practice, this also means that not every office, small service business or sole trader will automatically be covered by the register. If your business only generates municipal waste and not waste resulting from the service or production process, the obligation to register may not arise at all. It is therefore safest to judge BDO not by the size of your business, but by this, what waste is generated and whether the company markets products or packaging covered by the legislation.

When to apply to BDO and what are the penalties for non-registration

If your activity requires registration on application, an application to the BDO must be submitted before the start of the activity subject to entry. It is not worth postponing this, as the sanctions are real: for operating without the required entry, there is an administrative fine from PLN 1,000 to PLN 1,000,000, and for transporting waste without an entry from PLN 2,000 to PLN 10,000. It is also worth knowing that not every entrepreneur registered with the BDO pays a registration fee and an annual fee. Such an obligation applies only to selected groups, including those introducing electrical and electronic equipment, batteries, vehicles, packaging, packaged products, tyres and lubricating oils; the rates are PLN 200 for a micro-entrepreneur and PLN 800 for others. In addition, from 1 January 2025, records must be kept for all hazardous waste regardless of its quantity, which for some companies means that they will have to revisit whether their previous BDO assumptions are still valid.

Frequently asked questions

If you would like to check whether your company is indeed subject to BDO registration, please contact us or go to „Contact” on page. We will help you assess the obligation, reduce the risk of error and prepare the right application without unnecessary costs.