According to a notice from a Polish customs agency dated June 18, 2026, and shared with trade-e-bility, customs authorities and other relevant bodies – including the Trade Inspection Authority – will introduce stricter controls to verify compliance with the new packaging regulations. Particular attention will be given to the BDO registration number and the EU Declaration of Conformity (DoC) for the packaging materials used. Companies registered in Poland in the areas of waste management, products, and packaging must provide their BDO number on shipping documents and commercial invoices. Failure to complete the required registration may result in customs clearance being delayed, suspended, or even denied.
In addition, companies must be able to provide an EU Declaration of Conformity for their packaging materials. This documentation confirms, among other things, that the materials used comply with applicable requirements, including the absence of PFAS and compliance with heavy metal limit values. In addition to document checks, physical inspections of packaging are also planned.
Differences in PPWR Responsibilities
For companies, it is also important to understand the legal distinction between imports from non-EU countries and the procurement of goods within the European Union. When products are imported from third countries, such as China, the importer assumes full responsibility for PPWR compliance and for reporting packaging waste quantities in the BDO system. The importer must also obtain the necessary technical documentation directly from the producer. The situation differs for goods sourced from another EU Member State. While the reporting process in the BDO system is generally similar, responsibility for packaging certification and the packaging structure under the PPWR typically remains with the producer that first placed the product on the European market.
Packaging Compliance as the Key to Smooth EU Imports
To minimise risks during import procedures, companies should establish compliant processes at an early stage. It is therefore advisable to contractually require foreign suppliers to provide detailed packaging weight specifications with each invoice, broken down by material categories such as plastic, paper, and wood. Likewise, the required PPWR declarations of conformity and laboratory test reports confirming compliance requirements, such as the absence of PFAS, should be available before shipment – not only requested after goods have already arrived at ports such as Gdynia or Hamburg. For retailers, producers, and importers operating in Poland, complete and accurate packaging documentation is becoming an essential factor for ensuring smooth supply chains and meeting the new PPWR requirements.
Do you need support with sales to Poland? Magdalena Barylska will be happy to assist you.
