From 1 January 2021, the entry of the entrepreneur into the electronic Database of Products, Packaging and Waste Management will be the only acceptable form of keeping records.

Pursuant to the Act of 14 December 2012 on waste (Journal of Laws of 2020, item 797; last amended, Journal of Laws of 2020, item 875), keeping the BDO waste register in the form of paper cards of waste record is not possible in 2021. All entities registered in the BDO system are required to keep records in electronic format.

There will be serious penalties for failure to keep records of waste in an electronic version:

• a fine of PLN 5,000 - PLN 1,000,000 - for conducting a business without the required entry into the register;
• removal from the register - for submitting an application that is inconsistent with the facts;
• a fine of PLN 5,000 - PLN 1,000,000 - for failure to include the registration number on documents related to the business activity covered by the entry; 
• a fine of PLN 2,000 - PLN 10,000 - for transporting waste without entry;
• arrest or fines - for waste management inconsistent with the information entered into the register;
• arrest or a fine - for failure to apply for entry into the register or its change.

Who does the entry in the BDO register apply to?

The obligation to enter into the BDO Register applies to entrepreneurs which:

• produce waste and keep records of this waste,
• bring into the territory of the country products in packaging, tires, lubricating oils, vehicles, batteries or accumulators, electrical and electronic equipment,
• manufacture or import packaging or buy them as part of intra-community transactions (from EU companies),
• pre-treat waste or otherwise interfere with its structure,
• transport waste,
• sell waste or act as an intermediary in waste management.

In the case of BDO, the size of the company does not matter. One-man companies, which are required to keep records of waste, must also enter into the Register.

The punishable obligation provided by the act is also to store, share and submit documents and data, as well as to have a document generated from BDO during the transport of waste.

The registration fee for micro-entrepreneurs is PLN 100, for other entrepreneurs it is PLN 300.