BDO vs autohandling when does a car trader have to register?

In the case of auto-dealing, it is most important to distinguish between car sales alone a introduction of vehicles on the national territory. From BDO's perspective, the obligation to register most often arises not because the company sells cars, but because the imports or makes intra-Community acquisitions of new or second-hand vehicles and introduces them for the first time into the territory of Poland for the purpose of distribution. The official knowledge base of BDO indicates directly that the entrepreneur introducing vehicles into the territory of the country is the vehicle manufacturer or the entity conducting business activity in the field of intra-Community acquisition or import of vehicles, and the BDO survey directly leads to the registration of those who import new or second-hand vehicles or manufacture vehicles. This means that, for many auto-dealers, the key moment is not to sell the car to the customer, but to bring the vehicle to Poland in advance.

When an auto-dealer must have an entry in BDO

Auto dealers should verify the obligation to register with BDO first and foremost when they import cars from abroad, regardless of whether they are new or used. Official BDO material indicates that importing new and used vehicles leads to Chapter III Table 1, a section dedicated to entering vehicles, and the provincial marshal shall enter such entities in the register upon request. If the entrepreneur additionally operates a vehicle collection point, a disassembly station or a shredder, he also enters the areas explicitly listed in the BDO register. Importantly, the registration rules remind that in the case of activities requiring an entry, an application must be submitted prior to the commencement of operations covered by the registration obligation.

When self-trading alone does not yet imply an obligation to register

Commercial activities alone do not always imply an obligation to register with BDO. Official material shows that in the area of vehicles, the registration premise is primarily the first introduction of a vehicle on the national territory, and not each subsequent sale. This means that if a company only deals with the sale of cars already brought into Poland, this fact alone is not indicated as a separate basis for entry in the register. However, beware of mixed activities, because autohandling very often combines the sale of cars with the preparation of vehicles for sale, replacement of parts, tyres, oils, batteries or minor repairs. In such a situation, there may be separate obligations in the BDO related to waste or to other product categories, even if the domestic car trade itself does not create an obligation as a „vehicle introducer”. This is the conclusion drawn from the official catalogue of registrants and the general rules on waste management.

What obligations an auto-dealer has after registration with BDO

If the auto-dealer acts as vehicle introducer, the BDO entry alone does not end the matter. The official BDO website indicates that vehicle introducer belong to the groups covered by registration and annual fee, and from 1 January 2025, they shall be as follows PLN 200 for micro-entrepreneurs and PLN 800 for other entrepreneurs. In addition, the BDO reporting instructions indicate that vehicle introducer submit an annual report on products, packaging and the management of waste resulting therefrom, and the deadline for submission of this report is by 15 March for the previous calendar year. In practice, this means that auto-dealers importing cars should think of BDO not only as a registration number, but also as a permanent registration, fee and reporting obligation.

Frequently asked questions

Are you in doubt as to whether your auto-dealer should be registered with BDO, whether importing used cars creates an obligation to register or whether a report and fee need to be submitted? Contact us Ekopro Group will help you analyse your responsibilities, sort out your paperwork and answer your questions about BDO. Go to „Contact” and make use of our support