BDO and transport companies - when does a carrier need to have an entry?

Q: Does every transport company have to have a BDO?

No. The obligation applies to companies waste transporters , and not all hauliers operating in the transport market.

For transport companies, the most important principle is simple: BDO does not apply to every haulage company, but it does apply to waste transporters. This means that if an entrepreneur is only involved in the transport of ordinary goods, consignments or non-waste cargo, the mere fact of operating a transport company does not automatically create an obligation to register with BDO. However, if the activity includes the transport of waste, the obligation to register arises and should be fulfilled before the start of such activity. The official information of the BDO explicitly indicates that a waste transporter is obliged to obtain a registration entry in the BDO on the basis of a registration application, and the registration rules remind that the entrepreneur should apply for a prior to the commencement of operations covered by the obligation of entry.

When a transport company must have a BDO

A transport company must have a BDO when it actually performs waste transport as part of their activity. This applies to both domestic hauliers and foreign entities transporting waste across the territory of Poland, even if the place of commencement and termination of the transport is outside the country. In practice, this means that a classic logistics, courier or freight forwarding company does not need an entry just because it operates in the transport sector, but a haulier collecting and transporting waste for clients does. BDO also clearly indicates that waste transporters belong to the groups listed in the register upon request by the Marshall of the province, which further organises the status of such entities in the system.

When a carrier does not have to register with BDO

This is one of the most frequently searched questions, because many entrepreneurs assume that, since there is a car and waste collection in the company, an entry is always necessary. Meanwhile, the official registration rules make it clear that an entity is exempt from the registration obligation transporting their own waste. In practice, this means that if a company has generated the waste itself in the course of its own activities and merely transports it further, this particular exception may exempt it from registration as a transporter. However, this does not automatically mean that it is exempt from BDO in general, as the company may still be subject to registration under another title, for example as a registered waste generator. Therefore, when dealing with transport companies, it is always necessary to distinguish between two states: transporting other people's waste, which in principle requires an alert, and carriage of own waste, which is a statutory exception to the obligation to register in this role.

What obligations a waste transporter has in the BDO system

For the transport company, the BDO entry itself is only the beginning of the obligations. The official BDO knowledge base indicates that when waste is transferred through the system, the entity that generated the waste issues a Waste Transfer Note (KPO), and the entity acting as transporter generates an acknowledgement of the issuance of this card in the BDO system; a similar logic applies to the collection of municipal waste, where the service of collection of municipal waste should be used KPOK, and the transport operator should have confirmation of the generation of the card during the transport. From a practical perspective, this means that a waste transport company must not only have the correct entry, but also function correctly in the BDO workflow. It is worth remembering that the sanctions are real: the official BDO knowledge base indicates that transporting waste without an entry in the BDO Register is punishable by an administrative fine of PLN 2 000 to PLN 10 000, and for failure to deliver the waste to the correct place from the PLN 1 000 to PLN 100 000.

Frequently asked questions

Does every transport company have to have a BDO?

No. The obligation applies to companies waste transporters, and not all hauliers operating in the transport market.

Does transporting your own waste require an entry in the BDO?

Not in a transporting role. Official registration rules indicate that transporting their own waste is not subject to registration on this account.

When do I need to apply for BDO entry?

Prior to the start of an activity subject to registration, i.e. prior to the start of a waste shipment requiring registration.

What role does the transport company have in the KPO?

The transporter generates in the BDO system an acknowledgement of the issuing of the KPO and then participates in the waste transfer process according to the documentation in the system.

What is the penalty for transporting waste without an entry in the BDO?

The official BDO knowledge base indicates an administrative fine of PLN 2 000 to PLN 10 000

Are you in doubt as to whether your haulage company should be registered with BDO, whether the haulage in your business model relates to waste and what documentation obligations need to be met? Contact us Ekopro Group will help you assess your responsibilities, sort out paperwork and answer your BDO-related questions. Go to „Contact” and make use of our support.