compliance teamProduct fee or recovery organisation: what you actually pay in Poland
Step 1
Measure tonnage by material
Step 2
Price the statutory fee as the ceiling
Step 3
Request written organisation quotes
Step 4
Record the chosen route and its evidence
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
The product fee is what you owe for doing nothing
The recycling levels are the obligation; the product fee is charged on the shortfall against them, material by material. For 2026 the levels are 66 per cent for all packaging combined, 77 per cent for paper and cardboard, 72 per cent for ferrous metals, 71 per cent for glass, 53 per cent for aluminium, 51 per cent for plastics and 26 per cent for wood.
The rates are set per kilogram of shortfall: 2.70 zł for plastics, 1.70 zł for multi-material packaging, 1.40 zł for aluminium, 1.00 zł for other packaging, 0.80 zł for steel, 0.70 zł for paper and cardboard, and 0.30 zł for glass and for wood. Statutory ceilings sit above them, and the fee is not collected where the annual total across all packaging stays at or below 100 zł.
A recovery organisation takes over the levels, not the file
Recovery organisations are private joint-stock companies with a statutory minimum share capital of 2,500,000 zł, and around twenty-six of them appear in the public register. Under article 17 the organisation assumes the obligation to achieve the annual recycling levels, evidenced by the recycling documents it procures; contracts commonly cover the educational-campaign obligation as well.
It does not take over the register entry, the registry number duty, the annual report, the annual fee or the de minimis application. You contract it in your own name, you pay it directly, and you remain the obligated entity throughout. Those retained duties are precisely the part a foreign seller cannot easily perform alone.
Nobody publishes a tariff, so nobody should quote you one
No Polish recovery organisation publishes rates. They quote per tonne and per material on request, and describe their pricing as moving with recyclate markets. A firm Polish per-tonne figure offered without a written quote is an estimate wearing a number.
The honest planning ceiling is the statutory product fee, because it is published and calculable from your own tonnage. Size the exposure with it, then obtain written quotes and compare. Remember the separate educational-campaign contribution: at least two per cent of the net value of the packaging placed on the market in the previous year, either spent on qualifying campaigns or paid to the marshal.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The marshal, the register, recovery organisations and marketplaces control their own procedures, timing and decisions.