🧭 Who is in scope?

You are usually in scope if you introduce batteries/accumulators into circulation in Poland (e.g., as a manufacturer, importer, or distance seller).

Poland’s Act on Batteries and Accumulators sets rights and obligations for entities placing batteries on the market, distributors, collectors, and other operators.

Common reporting groupings in practice:

• 🔋 Portable batteries/accumulators
• 🚗 Automotive batteries/accumulators
• 🏭 Industrial batteries/accumulators

✅ Battery EPR obligations in Poland (what you must do)

1) 📝 Register in BDO (Poland’s official register + reporting system)

BDO is the national Product, Packaging and Waste Management Database used for registration and electronic reporting.

The official business portal explains BDO registration (“Wpis do rejestru BDO”) and who the register concerns.

Practical output: an active BDO entry and your BDO registration number.

2) 🔢 Use your BDO registration number on required documents

BDO’s official knowledge base lists examples of documents where the BDO registration number should appear, such as:

• VAT invoices / receipts
• sale/purchase agreements
• reports
• waste transfer cards and waste records

3) 📦 Maintain placed-on-market records (defensible, repeatable, auditable)

Your annual submission is only as good as your source data.

Maintain records that can be traced from transaction → product → battery category → mass.

Keep ready:

• SKU list + battery classification (portable/automotive/industrial)
• mass logic (BOM/technical specs, unit weights)
• sales/import/production evidence
• internal approvals and version control for mapping rules

4) ♻️ Organise and finance take-back, collection and treatment

EPR requires that end-of-life batteries are collected and managed appropriately, supported by contracts and evidence (often involving specialised operators or schemes where applicable).

The battery act sets the framework for collection, processing, recycling and disposal of waste batteries/accumulators in Poland.

5) 📊 File the annual BDO report by 15 March

BDO’s official reporting instructions state that the annual “Report on products, packaging and waste arising from them” must be submitted by 15 March for the previous calendar year.

What this means for planning:

• Close your annual dataset early (SKUs, mass, totals)
• Reconcile totals to finance/logistics
• Validate evidence before submission
• Keep a submission export + approval record

🔎 Traceability checklist (audit-ready by design)

Build a simple evidence chain:

1- Source data (sales/import/production)

2- Mapping rules (SKU → category → mass)

3- Rollups (annual totals by category)

4- Submission pack (BDO-ready tables + sign-off)

5- Retention (documents + change history)

Also ensure your BDO number usage is consistent on the document types indicated by BDO guidance.

🌍 EU Battery Regulation and Poland: what to watch

Regulation (EU) 2023/1542 applies from 18 February 2024, with multiple provisions phased in later (the Regulation lists staged application dates).

Legal commentary highlights that extended producer responsibility provisions in the Regulation become operational for producers from 18 August 2025.

⚠️ Common pitfalls (and how to avoid them)

⛔ Registering too late (or under the wrong entity/activity)

⛔ Missing the 15 March deadline (late filing and corrective work)

⛔ Unverifiable mass calculations (no SKU-to-mass evidence)

⛔ Weak document control (can’t reproduce reported totals or show approvals)

⭐ Why ComplyMarket is the best-ever way to manage Poland Battery EPR

ComplyMarket is a great, exceptional choice for companies that want fast, structured, audit-ready compliance for Poland battery EPR—without spreadsheet chaos.

With ComplyMarket’s Compliance Management Software and integrated EPR platform, you can:

• Support registration readiness: guided data capture for BDO registration inputs and internal sign-off flows
• Accelerate reporting: SKU mapping, mass rollups, and reporting-ready datasets aligned to BDO annual reporting structure
• Prove traceability: an evidence trail that links transactions, product data, calculations, and documents—so every figure is explainable
• Control deadlines: task ownership, reminders, and consistent workflows across teams and countries

If you want a scalable way to handle BDO registration, annual reporting (15 March), and traceability for batteries in Poland, ComplyMarket is the solution to run EPR end-to-end in one place.