Every Polish order,
connected to the pack that ships.
Poland draws no line between a marketplace order and one from your own store: making packaged products available on Polish territory for the first time is what creates the obligation, and the sales channel is not decisive. Separately, PPWR Article 45(3) requires a written EPR mandate for a producer making packaging or packaged products available in another Member State for the first time, including under a distance contract.
Standard packaging reference €474/year + €150 setup · registry fees, recovery-organisation charges and the product fee separate
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The EU mandate exists; the Polish machinery to receive it does not yet
Article 45(3) has applied since 12 August 2026, while Poland has no packaging authorised-representative register and no such institution in national law. We document the mandate and keep it distinct from the power of attorney used to file with the marshal.
DTC duties sit across sales, logistics and packaging
The own-shop route is assumed to be lighter
It is not. There is no voluntary channel in the Polish packaging act, and registering in your home-country scheme does not substitute for a Polish entry.
The fulfilment packaging is missing from the count
Cartons, tape, void fill, mailers and labels added at fulfilment are packaging you place on the Polish market, and they count towards the one-tonne threshold that decides whether any fee is owed at all.
The threshold is read as an allowance
One tonne of total packaging is a cliff, not a deduction. At roughly a hundred grams of packaging per parcel, ten thousand parcels a year is already at it, and crossing it makes the whole year chargeable.
Included in the written scope.
- Seller, checkout, contract, destination and fulfilment map
- Register scope assessed per channel, without a voluntary shortcut
- PPWR Article 45(3) mandate review, kept separate from the power of attorney
- Product and shipment-packaging inventory by material
- Tonnage against the one-tonne threshold, with the margin shown
- Annual order, return and weight reconciliation plan
Four controlled steps.
Map the facts
Record the entity, countries, channels, contracts and products relevant to DTC sales.
Separate the streams
Packaging, electrical equipment and batteries are assessed independently, with assumptions marked for confirmation.
Confirm the written scope
Private fees, exclusions, external costs and client approvals are set out before any work begins.
Maintain authentic evidence
Official documents, filings, invoices and changes remain linked to the entity and stream that produced them.
Frequently asked
Is registration voluntary if we only sell through our own store?
No. The obligation follows from the statutory test — first making packaged products available on Polish territory — and the sales channel is not one of its criteria. Published guidance and marshal practice have not treated the channel as decisive, and there is no volume floor for the entry itself.
Under one tonne, do we still have to do anything?
Yes. Below one tonne of total packaging the recycling levels, the product fee and the education contribution fall away as de minimis aid, granted on application by 15 March. The register entry, the number on your documents, the annual fee by the end of February and the annual report all remain.
Does our 3PL become the producer?
Not automatically. Contracts, ownership of the goods, the packaging actually added and the route to the Polish buyer all have to be documented before that question is answered.
Do we need a Polish company to register?
No. A foreign entrepreneur registers directly. Without a Polish branch the application is filed on paper with the Marshal of the Mazowieckie Voivodeship, and the register account that runs everything afterwards needs a Polish PESEL holder acting under a power of attorney.
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment