Product and recycling fee. Who pays and when?

Service Business

Entrepreneurs who place packaging or packaging products on the market in Poland are subject to the obligations of the marketer. One of these obligations is to ensure statutory levels of recycling and recovery of packaging - if the entrepreneur fails to meet this obligation, he pays the product fee. The same entrepreneur, e.g. selling in a brick-and-mortar store, may at the same time incur a different fee, a recycling fee. In this article, we'll explain who pays the fee and when.

Product fee - who pays?

The product fee is a penalty for failure to achieve the statutory levels of recycling and recovery of packaging that the entrepreneur places on the market in our country.

The product fee is paid by entrepreneurs who independently fulfill the statutory obligations of the introducer. These include:

  • online sellers who pack the goods sent to customers,

  • importers who import already packed products from abroad to Poland,

  • manufacturers who produce products under their own brand and pack them in packaging,

  • eateries that serve packaged food.

You will pay the product fee even on 1 introduced package - the legislator does not provide for any lower limits in this regard!

Product fee - examples

Example 1: I sell products on the Internet, I ship them in cartons, which I order from the manufacturer. Additionally, I put a filling in the form of a bubble wrap into the carton. I wrap the carton with stretch foil and stick the address label. I will pay the product fee for each element of the packaging, i.e. cardboard, bubble wrap, stretch foil and an address label.

Example 2: I am a local fruit juice producer. Pour the juices into glass bottles with an aluminum cap. We put a sticker with our logo on the bottle. I am the introducer and I will pay the product fee for the bottle, cap and sticker with the logo. If I send the goods to customers in the country, I will also pay for collective packaging in which I will pack the juice bottles.

Product fee - how to calculate?

The amount of the product fee is calculated from the formulas included in Annex 2 to the Act of June 13, 2013 on packaging and packaging waste

For the formulas, we must substitute the unit rate for 1 kg of a given type of packaging and its total weight, which we introduced to the market in a given calendar year or the previous year, if we also introduced packaging or packaging products in the previous calendar year.

The rates of product fees for individual types of packaging are specified in the REGULATION

MINISTER OF THE ENVIRONMENT of 16 December 2014, item 1972. They are as follows:


Packaging material

Unit rate per kg



PLN 2.70



PLN 1.40


steel, including steel sheet

0.80 PLN


paper and cardboard

PLN 0.70



PLN 0.30



PLN 0.30


the remaining

PLN 1.00


The product fee is paid by the entrepreneur to the account of the Marshal's Office of the voivodship, competent for the seat of the company, by March 15 for packaging or packaged products placed on the market.

Product fee - how to avoid it?

The entrepreneur may avoid the product fee, provided that he transfers his statutory obligations to ensure the recycling and recovery of packaging or products in packaging to a specialized entity, eg the TOM-DOLEKO-EKOLA Packaging Recovery Organization. The organization will replace the high product fee with a lower rate for the signed contract, in addition, under the contract to be signed, the organization takes over a number of statutory obligations that rest with the entrepreneur.

Recycling fee who pays?

The recycling fee is a fee that is charged by every trader who runs a retail or wholesale unit where he offers his customers plastic shopping bags for product packaging.

The recycling fee is not charged to the purchaser of a very light plastic shopping bag, provided that it is used for direct food packaging.

Recycling fee - examples

Example 1: I run a shop where I sell a large proportion of my products by weight, e.g. coconut cookies. I pack them in the so-called skidding (less than 15 micrometers thick). In this case, I do not pay a recycling fee for making them available to the customer as they are hygienically required and serve as the primary packaging for bulk food.

Example 2: I run a general grocery store where the customer can pack the products in a paid plastic bag (over 50 micrometers thick). In this case, I am obliged to collect a recycling fee from each plastic bag sold to the customer.

Recycling fee - how to calculate?

The entrepreneur collecting the recycling fee is obliged to enter into the BDO register, section VI, table 7, keep records of the number of purchased and issued light and other plastic shopping bags in a given calendar year in paper or electronic form, and submit an annual report in this regard by BDO.

The maximum rate of the recycling fee results from the act and is currently PLN 1 per light plastic shopping bag. In accordance with the ordinance of the Minister of the Environment of December 8, 2017 on the recycling fee, from 01/01/2018 the rate is PLN 0.20 + VAT per item.

The recycling fee for plastic bags placed on the market is paid to a separate bank account of the Marshal's Office by the 15th day of the month following the quarter in which it was collected.

Recycling fee - how to avoid it?

Contrary to the product fee, the recycling fee is paid by the entrepreneur directly to the account of the Marshal's Office. In this regard, the legislator did not, unfortunately, provide for the possibility of assigning this obligation to e.g. recovery organizations.

Partner article, external text