A written EPR mandate,
with each Polish role kept distinct.
Poland has no authorised representative for packaging in national law. The term belongs to WEEE and, since 18 August 2025, to batteries. What exists for packaging is the EU mandate under PPWR Article 45(3), a Polish power of attorney for filings, and the practical operation of your register account. We scope the three separately and never present one as another.
Priced in a written scope after entity, channels and powers are reviewed
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The outcome
A versioned mandate and responsibility map
- Producer, representative, territory, powers and start date identified
- PPWR mandate separated from the Polish power of attorney and register access
- Signatures, filings, changes and termination evidence retained
The mandate is a private instrument; no Polish authority issues or approves it
Article 45(3) is EU law sitting on top of a Polish regime that has not caught up
Since 12 August 2026 a producer making packaging or packaged products available in another Member State for the first time, including under a distance contract, must appoint a written authorised representative for extended producer responsibility there. Poland has no receiving machinery for packaging yet, and the draft reform that would create one has not entered into force.
Where representation goes wrong
A packaging representative is claimed that does not exist
Providers offer "authorised representation for Polish packaging". In national law that institution covers WEEE and batteries only. We will not describe our role that way.
The mandate is confused with the power of attorney
The EU mandate and the Polish power of attorney used to file with the marshal are different instruments with different scopes and different termination effects.
Register access is treated as representation
Operating your BDO account is a practical service, not a legal status. It is contracted, described and revoked on its own terms.
Included in the written scope.
- Producer-profile and cross-border route analysis
- Article 45(3) applicability review with the evidence relied on
- Bilingual mandate structure and scope of powers
- Separation from the power of attorney and register access
- Change, revocation and termination procedure
- Evidence register for the signed instruments
Four controlled steps.
Document the facts
Collect the entity, products, channels, contracts and available evidence for EPR representation.
Confirm scope and dependencies
Receive a written map of assumptions, exclusions, third parties and points requiring approval.
Authorise the agreed work
Private fees, external costs and client responsibilities are confirmed before any submission or commitment.
Coordinate and retain evidence
After a valid engagement, each action, external decision and authentic receipt is stored with its date and version.
Frequently asked
Is there a Polish authorised representative for packaging?
Not in national law. The institution exists for WEEE under the 2015 Act and, since 18 August 2025, for batteries under the EU battery regulation. For packaging there is the PPWR Article 45(3) mandate and, separately, an ordinary power of attorney.
Does the mandate replace registration?
No. You remain the registered party in BDO. The mandate addresses an EU duty; it does not move the Polish obligation to us.
Does the reform change this?
It may. The draft packaging act would introduce an authorised representative for foreign producers, but it has not entered into force and its timetable has moved more than once. We will not price against an unadopted text.
Can you act as a fiscal representative?
No. That is a different institution with different liability, and it is outside this service.
Connect representation to the file
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment