Deposit system in Poland  

The deposit system is a revolution that will directly affect millions of consumers in Poland, creating one of the largest and most coordinated environmental operations in the country’s history. Single-use beverage containers will be included in the system: 

  • PET bottles up to 3 litres, 
  • metal cans with a capacity of up to 1 litre, 
  • reusable glass bottles with a capacity of up to 1.5 litres. 

At the beginning of January 2024, an amendment to the deposit system came into force, which officially postponed the system’s start date to 1 October 2025.  

The deposit will be collected at each stage of the sale and sellers will be obliged to collect it from each buyer, not only from end users. 

The balance of the unclaimed deposit, which will be calculated at the end of the calendar year, will be the difference between the deposit collected and the deposit returned. The funds from the unclaimed deposit will be used to fund the deposit system. Each municipality is to be provided with one collection point for packaging and waste covered by the deposit system. The agreement to join the system will be able to be concluded by entities offering beverage packaging products with a representative entity in either paper, electronic, or documentary form. The application for authorisation to operate the system must include a detailed description of the methods for accounting the deposit, monitoring the activity, and the steps being taken to start the system. In addition, declarations of clean criminal records of the representing entities and their managers as well as a financial settlement plan will be required.  

PPWR Regulation  

On 11 February 2025, the Packaging and Packaging Waste Regulation (PPWR) entered into force. It will apply 18 months after entry into force – since 12 August 2026. Each Member State will be required to reduce the amount of packaging waste generated per capita compared to the amount of waste in 2018 by at least 5% by 2030, 10% by 2035, and 15% by 2040. PPWR also introduces an obligation to use harmonised labels to make it easier for consumers to sort waste and make purchasing choices.  From 2030, all packaging placed on the EU market must be recyclable, regardless of the material from which it is made. Moreover from 2030, packaging must be designed in a way that keeps weight and volume to a minimum while maintaining functionality. Additionally from 18 months after the entry into force of the Regulation, PFAS in food contact packaging will be prohibited.

New EU legislation on combating deforestation

From 30 December 2025, Regulation (EU) 2023/1115 of the European Parliament and of the Council against deforestation and forest degradation will come into force.  This day the EU Regulation 995/2010 (EUTR) is repealed but will remain in force until 31 December 2028 for timber and timber products produced before 29 June 2023. The amendments introduce an obligation to identify the origin of raw materials and thus their legality. Documentation will be required to prove that the raw materials in the supply chain do not contribute to deforestation. It will be necessary to document the production and delivery process – every stage must be transparent, and in compliance with standards – as well as the work with suppliers to obtain accurate data on the origin of raw materials.  

Ecodesign in the EU  

As of July 2024, Regulation (EU) 2024/1781 of the European Parliament and the Council, which establishes the ecodesign framework for sustainable products, is in force. It is intended to improve resource efficiency by producing more durable and recyclable products and thereby reduce environmental impact.

The European Commission’s first work plan is due to be adopted by 19 April 2025; it will set out a list of product groups, for which it intends to adopt delegated acts that will indicate specific ecodesign requirements. The Commission will give priority to product groups such as iron, steel, aluminium, textiles (including clothing and footwear), furniture (including mattresses!), tyres, detergents, paints, lubricants, chemicals, energy-related products, ICT products, and electronic devices. They will have to meet new energy and material efficiency standards. By 19 July 2025, the first implementing act is due to be adopted on the details and format for reporting information on unsold consumer products disposed of by economic operators. A first delegated act is also due by 19 July 2025 to update the list of unsold consumer products subject to the destruction ban from 19 July 2026 (currently including footwear and clothing commodity codes).  

Implementation of the CSRD directive in Poland  

With the beginning of 2025, the Act of 6 December 2024 amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Supervision and certain other acts, implementing the CSRD in Poland, entered into force.

The amendment introduced a new chapter on sustainability reporting with reference to the European Sustainability Reporting Standards (ESRS), the scope of information reporting (including, but not limited to, a description of the business model, strategy, sustainability objectives, ESG policies, due diligence processes and risks associated with the entity’s operations), mandatory verification of sustainability reports by auditors and sanctions provided for failure to comply with the reporting obligations, including fines or restricted liberty for responsible persons.  

Construction sector - Regulation 2024/3110 (CPR2)  

As of 8 January 2025, the new Regulation 2024/3110 (CPR2) on construction products, which replaces the previous provisions of Regulation (EU) No. 305/2011, entered into force. A transitional period for the implementation of the regulation is foreseen for 15 consecutive years. CPR2 introduced:

  • new definitions such as declared use of the product, key parts, used product, performance, essential characteristics, reprocessed product, product category, – harmonised rules for describing the performance of construction products,
  • enhanced market surveillance and also
  • a digital product passport for every construction product.  

Manufacturers, importers, and distributors of construction products will have to adapt to digital forms of information sharing and meet more stringent environmental requirements.