Poland's New EPR Act

For decades, the cost of managing packaging waste in Poland has fallen largely on municipalities and, by extension, ordinary residents. That is about to change in a fundamental way.

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On August 13, 2025, Poland's Ministry of Climate and Environment published a landmark draft act, officially known as UC100, that sets out to overhaul the country's entire approach to packaging and packaging waste management. The legislation, scheduled to enter into force on August 12, 2026, shifts the financial and operational burden squarely onto the shoulders of the producers and importers who put packaging on the market in the first place.

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This is not a minor administrative adjustment. For paper and packaging producers operating in Poland, from corrugated board manufacturers to paper-based consumer goods companies, the new Extended Producer Responsibility (EPR) framework represents one of the most significant regulatory changes in a generation. Understanding what is coming, and when, is no longer optional. It is a strategic necessity.

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The Problem Poland's New EPR Law Is Trying to Solve

Poland has made notable progress on recycling in recent years. Paper and cardboard packaging reached an 80% recycling rate by 2019, one of the strongest figures across all material categories. Overall packaging waste recycling reached 56% that same year, largely driven by paper and glass fractions. On the surface, these numbers suggest a functioning system.

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But beneath the headline figures lies a structural imbalance that has long frustrated policymakers. Producers, through existing producer responsibility organisations (PROs), currently contribute only around 10% of the total costs of managing household packaging waste, while municipalities absorb the lion's share. Poland generated 172 kg of packaging waste per capita in 2019, close to the EU-27 average of 177 kg per capita, and as consumption has grown since then, so too has the pressure on local governments to foot the bill for collection, sorting, and processing.

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This imbalance is precisely what UC100 seeks to correct. The "polluter pays" principle, long enshrined in EU environmental law, will now be applied with real financial teeth in Poland.

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How the New Poland EPR System Works

At the heart of the new legislation is a packaging fee, a per-kilogram charge levied on all packaging placed on the Polish market. The fee begins modestly at approximately 0.5 grosz (roughly €0.001) per package in 2026, phased in at 8% of the full product fee rate. It rises to 20% in 2027 and reaches its full rate in 2028, with maximum packaging fee rates capped at PLN 4.50 per kilogram. The graduated structure is intentional. It gives businesses time to adapt while signalling clearly where the system is heading.

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Critically, the fee is not flat. It is eco-modulated, meaning the rate varies by packaging type and material. This creates a direct financial incentive for companies to redesign packaging towards materials that are easier and cheaper to recycle, a principle that sits at the core of EU circular economy policy. For paper and cardboard producers, whose materials already carry strong recyclability credentials, this modulation could become a meaningful competitive advantage.

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The funds collected will be centrally managed by the National Fund for Environmental Protection and Water Management (NFOSiGW), which will distribute them to municipalities, sorting facilities, and certified recyclers.

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Under the new model, the existing network of private packaging recovery organisations will be wound down by the end of the transition period, consolidating all financial oversight under a single state entity.

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Why Industry Groups Are Pushing Back Against the Polish EPR Scheme

The proposed centralisation of the EPR system has triggered a forceful response from the packaging industry. Over fifty European packaging associations, including Cepi, the European Federation of Corrugated Board Manufacturers (FEFCO), the European Paper Packaging Alliance (EPPA), Pro Carton, and the European Carton Makers Association (ECMA), co-signed a joint statement arguing that the Polish model is designed as a taxation mechanism rather than a genuine producer responsibility scheme.

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Their concern is not merely philosophical. Critics warn that channelling accumulated fees through the state budget, rather than directly into waste management processes, risks undermining the very EU Waste Framework Directive the new law is meant to implement. They also argue that the proposed system creates regulatory divergence with the EU's Packaging and Packaging Waste Regulation (PPWR), which applies across all member states from August 2026 and operates on eco-modulation principles that reward recyclability. A system that functions as a flat tax, opponents say, does not send the right signals to producers.

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The joint statement called explicitly on Polish authorities to establish an EPR system fully aligned with the Waste Framework Directive and supportive of the recyclability objectives of the PPWR. Non-compliance with the new rules carries fines of up to PLN 2 million, equivalent to approximately $480,000 USD, for the most serious violations.

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What the EU PPWR Means for Paper Producers in Poland

Poland's EPR reform does not exist in isolation. It runs in parallel with the EU's Packaging and Packaging Waste Regulation (PPWR), which entered into force in February 2025 and applies from August 12, 2026. Together, these two frameworks create a layered compliance environment that goes well beyond fees and reporting.

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Under the PPWR, all packaging placed on the European market must be recyclable. By 2030, transport and e-commerce packaging must not exceed 50% empty space, a provision with direct implications for the paper-based logistics sector, where oversized corrugated boxes have long been a target of criticism. The regulation also sets a minimum 30% recycled content requirement for PET packaging by 2030 and promotes reusable packaging systems across all categories.

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For the paper industry, these requirements are largely achievable given paper's inherently strong recyclability profile. But achieving them consistently, at scale, and in compliance with new reporting obligations will require deliberate investment and planning.

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Key Targets, Timelines, and What Polish Packaging Businesses Must Do Now

Poland's draft act sets out ambitious waste reduction targets aligned with PPWR goals: a 5% reduction in per capita packaging waste by 2030, 10% by 2035, and 15% by 2040. These are not aspirational. They carry legal weight. Companies in the food, cosmetics, and e-commerce sectors face the steepest immediate compliance challenges, as these are industries with particularly high packaging intensity and complex supply chains.

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For paper and packaging producers specifically, the key dates are already in motion. Certain provisions of the New Act came into force on January 1, 2026. The full act applies from August 2026. The two-year transition period runs until approximately 2028, after which the new EPR system becomes fully operational and existing PROs cease to exist. From that point on, there is no legacy infrastructure to fall back on.

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Compliance experts are advising businesses to begin packaging portfolio audits immediately, mapping material types, weights, and recyclability ratings across all product lines.

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Companies that integrate EPR compliance into their broader sustainability strategy now, rather than waiting for full implementation in 2028, will be better positioned to absorb rising fee costs and avoid penalties. Those that redesign packaging towards lower-weight, higher-recyclability formats stand to benefit directly from the eco-modulation mechanism, paying lower fees than competitors who fail to adapt.

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The Business Opportunity Inside Poland's Packaging Waste Regulation

It is easy to frame Poland's new EPR Act purely as a compliance burden, with additional fees, new reporting requirements, tighter material standards, and the uncertainty of a centralised state-run funding model. But there is a more constructive reading of what is happening.

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Paper and cardboard already account for some of the strongest recycling performance in Poland's packaging sector, with an 80% recycling rate as of 2019. The shift to eco-modulated fees, if implemented in a way that genuinely rewards recyclability, should work in the paper industry's favour relative to plastics and composite materials. Companies that have already invested in sustainable packaging design, closed-loop supply chains, and recycled fibre sourcing are entering this regulatory era with a structural advantage.

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Poland's waste management market as a whole is projected to grow at a compound annual rate of over 4.6% through 2026, driven by regulatory pressure, infrastructure investment, and rising industry awareness. The EPR transition is part of that growth story. For producers who treat it as a market-shaping force rather than a compliance burden, the next few years offer a genuine opportunity to strengthen both competitive position and environmental credentials.

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The revolution in Poland's packaging waste system is no longer coming. It is already underway.

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Frequently Asked Questions About Poland's New EPR Act

What is the Poland EPR Act 2026?

The Poland EPR Act (UC100) is a new law on packaging and packaging waste management that shifts financial responsibility for waste collection, sorting, and recycling from municipalities to producers and importers. It enters into force on August 12, 2026.

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What is the packaging fee under Poland's new EPR law?

The packaging fee starts at approximately 0.5 grosz per package in 2026 and scales up gradually, reaching a maximum rate of PLN 4.50 per kilogram by 2028. The fee is eco-modulated based on packaging material and recyclability.

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How does Poland's EPR Act affect paper and cardboard producers?

Paper and cardboard have an 80% recycling rate in Poland, giving the sector a strong baseline. Eco-modulated fees should favour recyclable materials like paper over harder-to-recycle alternatives. However, producers must still register, report, and comply with new obligations from 2026 onwards.

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What are the fines for non-compliance with Poland's packaging waste law?

Administrative fines can reach up to PLN 2 million (approximately $480,000 USD) for the most serious violations, including failure to meet reporting obligations or placing non-compliant packaging on the market.

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What is the difference between Poland's EPR Act and the EU PPWR?

The PPWR is an EU-wide regulation setting minimum recyclability and recycled content standards for all packaging. Poland's EPR Act is national legislation that implements a financing and collection system. Both apply from August 2026 and must be complied with simultaneously.

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