The end-February trap: how an unpaid annual fee deletes you from the register
Step 1
Record the correct fee band
Step 2
Diarise the end-February payment
Step 3
Retain the payment receipt
Step 4
Confirm the entry is still live
| 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 |
One date, and no reminder you can rely on
The annual fee is due by the end of February each year, except in the year the registration fee was paid. It is 200 zł for a micro-enterprise and 800 zł otherwise, paid to the marshal's account, and the band follows the statutory micro-enterprise definition rather than a preference.
It is the smallest amount in the whole Polish regime and it arrives in the quietest part of the compliance year, weeks before the March reporting work starts. Nothing about its size signals what happens when it is missed.
Unpaid, the entry is removed
Where the fee is not paid the marshal calls for payment with a short deadline and then opens proceedings to delete the entity from the register under article 64 of the waste act. Deletion is an administrative act, not a warning letter.
The consequences compound. Operating without an entry where one is required is itself subject to an administrative fine imposed by the environmental inspectorate, and the registry number published to Amazon and Allegro no longer corresponds to a live entry — which is exactly what platform verification is designed to detect.
Hold the date as a calendar item with an owner
A foreign entity has no Polish accountant watching this, often no Polish bank account and frequently no direct access to the register. Record the payer, the account, the amount, the basis for the fee band and the reference, then reconcile the receipt against the entry.
The duty also outlives any service relationship. Termination should state in writing that from that date the client itself must pay the February fee or the entry will be removed — that is liability management, not politeness.
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.