Connect the PPWR representative rule to Poland’s existing BDO route.

No. Poland already runs BDO under national law and has done for years; an entry produces a nine-digit registry number covering packaging and any stream added later. The producer registers foreseen by the PPWR depend on a Commission implementing act that has not yet been adopted, and national registers follow it rather than precede it.

No. The mandate under Article 45(3) is EU law sitting on top of the Polish regime. Registration, the registry number on documents, the end-of-February annual fee and the 15 March report all continue to come from Polish statute.

No. Making packaged products available on Polish territory for the first time is what creates the obligation, and official guidance treats the way the sale is conducted as not decisive. There is no volume floor for registration itself.

Not in national law. Providers selling “authorised representation for Polish packaging” are describing something that does not exist yet; the term belongs to waste electrical and electronic equipment and, since 18 August 2025, to batteries. What exists for packaging is the Article 45(3) mandate plus an ordinary power of attorney. A draft Polish act would introduce a statutory representative, but it has not entered into force.

No. Whoever first makes the goods available on Polish territory is the obligated party, and delivery terms move that line: a delivered-duty-paid sale can leave it with the foreign seller, while an ex-works sale puts the intra-Community acquisition on the Polish buyer. No published Polish guidance resolves it, so we review the contracts rather than assert a rule.

No. At or below one tonne of total packaging in a calendar year, and on application as de minimis aid, the recycling levels, the product fee and the public-education contribution fall away. Registration, the registry number on documents, the annual fee by the end of February and the annual report by 15 March all remain. The threshold is a cliff, not an allowance: crossing it makes the whole year chargeable.

Allegro told sellers on 6 August 2026 that it would not block accounts or sales after 12 August for want of an EPR number. It has had a field for the BDO number since 2023 and says it will verify per-market numbers once the national registers foreseen by the regulation launch. Treat any specific blocking date circulating elsewhere as unverified.

No. We can prepare evidence for an agreed scope; the marshal decides the entry, and Amazon and Allegro apply their own current fields, review and account decisions.