The product fee for packaging is one of the many environmental obligations of businesses. What is it paid on? When does the payment deadline expire? Who pays the product fee and what are the penalties for failure to report? Find out whether this obligation also applies to your company and how you can avoid the product fee!

What is a product charge? Definition and legal basis

The product charge, also known as the packaging charge, is a the type of environmental levy to be paid by the operators who place on the market packaging or certain products. It is paid by entrepreneurs who have not achieved the minimum statutory levels of recovery and recycling of packaging or products placed on the market.

The provisions establishing the product fee are mainly contained in the Act of 13 June 2013 on packaging and packaging waste management, the Act of 11 May 2001 on the obligations of entrepreneurs with regard to the management of certain waste and the product fee and the Act of 24 April 2009 on batteries and accumulators. They are also contained in regulations issued on the basis of statutory delegations.

What products and packaging are covered by the product charge?

According to the legislation, the product fee covers:

• all types of packaging regardless of the material from which it is made,
• Tyres,
• oils and lubricant preparations,
• batteries and accumulators.

The condition for these products and packaging to be subject to the product charge is that they are introduced onto the Polish market by an entrepreneur, known as the introducer.

Who pays the product charge - list of entities

Payment of the product charge is an obligation entrepreneurs who, in a given calendar year, placed packaging or products on the Polish market mentioned in the previous paragraph. This group includes, among others:

• entrepreneurs making intra-Community acquisitions of packaged products,
• importers who import packaged products into Poland from outside the EU,
• car dealers and the motor trade (new and used vehicles),
• online shops that pack goods in shipping boxes,
• manufacturers who produce packaged products under their own designation (trademark),
• entrepreneurs outsourcing the manufacture of private label products,
• shops larger than 500 m²which sell products packaged on site (e.g. meat or delicatessen products by weight).

Product charge rates - how much will you pay for packaging and products?

Amount of product fee charged depends on the type and quantity of products or packaging introduced by the trader to be placed on the market throughout the calendar year, as well as on the statutory recovery and recycling levels for the year. Each product and each packaging material is subject to a different rate and has a different minimum level of recovery and recycling.

While the rates of the product fee have remained constant in previous years, the minimum levels of recovery and recycling are constantly being increased. For this reason, entrepreneurs who settle the product fee themselves have to collect more and more waste from packaging or products every year, which entails increasing costs for such collections and all waste logistics.

By when must the BDO product fee be paid?

An entrepreneur introducing packaged products is obliged to pay a product fee by 15 March each year for the previous year. In contrast, the fee for products (oils, tyres, batteries and accumulators) is payable by 31 March.

On the same dates, entrepreneurs are obliged to submit a report on products, packaging and the management of waste arising from them. Failure to submit reports on time and to settle the product fee may result in a financial penalty of up to PLN 1,000 to as much as PLN 1 million being imposed on the company!

Can the product charge be avoided?

The product fee is the consequence of an entrepreneur's failure to comply with the obligation to recover and recycle packaging waste and waste products. In order to avoid it, this obligation to meet by achieving the minimum recovery and recycling levels set by the legislator. Each company can do this on its own, for example by organising the collection of waste and transporting it to a recycler, or by delegating its environmental responsibilities to a recovery organisation. For such a service, the organisation charges a fixed annual fee, which is usually much lower than the amount of the product fee.

Benefits of the transfer of responsibilities to the recovery organisation Interzero

From the entrepreneur's point of view, The transfer of the recovery and recycling obligation to the recovery organisation Interzero has many advantages:

• a fixed, low annual fee,
• full predictability of the costs associated with the product charge,
• seamless implementation of the recycling obligation,
• no annual reporting obligation,
• the possibility of concluding a contract online,
• fulfilment of the obligation to implement public education campaigns,
• certainty and security in the event of possible company inspections.

What else do you gain by working with Interzero?

At the beginning of our cooperation, we will help you identify your legal obligations and the status of their implementation to date. Your company has been introducing packaging and products but has not been submitting annual reports to the Marshal's Office? No worries, we will take care of the outstanding reports and show you how to pay all the fees. All you need to do is sign a contract with us in 3 easy steps!

Go to the survey and see if your company can avoid the product fee!