Environmental audit and the BDO register
BDO environmental audit: verification of waste codes, records, KPOs and preparation of the company for inspection by the WIOŚ.
BDO environmental audit: verification of waste codes, records, KPOs and preparation of the company for inspection by the WIOŚ.
BDO 2026 report: 15 March deadline, submission procedure, errors, penalties and report for multi-branch companies
Ongoing BDO service, waste records, KPOs and reports. Find out when it is worth outsourcing BDO to EKOPRO experts.
For Polish e-commerce, the most important principle is simple: selling online to another EU country is very often enough to trigger local packaging obligations, even if the company does not have a warehouse, branch or employees there. In practice, this is the case if the country in question recognises the online retailer, importer, first distributor or distance seller as the „producer” or entity responsible for the packaging placed on its market.
The biggest mistake entrepreneurs make is to look for a single „BDO Act” that will explain everything from start to finish. In practice, there is no such single act. BDO is a legal and IT system based primarily on the Waste Act, but supplemented by implementing legislation and sectoral laws on packaging, products and certain activities.
If Polish e-commerce sells goods in Poland, the starting point is to assess the obligations in BDO. In practice, BDO most often applies to shops that introduce packaged products into the country, as well as to producers, importers and intra-Community purchasers of packaging. The official BDO registration rules indicate that the obligation to register applies to entities listed in the Waste Act, and in the case of activities requiring registration, the entrepreneur himself submits the application electronically.
The biggest mistake entrepreneurs make is to treat plastic bags as a minor selling point rather than as a source of specific environmental obligations. In practice, the very act of offering customers plastic shopping bags covered by the recycling fee brings the shop or wholesaler into the BDO area. Official sources from Biznes.gov.pl explicitly point out that such a trader must obtain an entry in the BDO register, keep records of the number of bags purchased and issued and submit an annual report in the system.
When selling into Germany, the key principle is simple: it is not the one who physically packages the package as a service provider who is responsible for LUCID obligations, but as a general rule the one who places the packaged goods on the German market as an obligated party. The ZSVR emphasises that any company that commercially distributes packaged goods in Germany or imports packaged goods into Germany must be registered in the LUCID Packaging Register, irrespective of its country of establishment

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