Poland’s recycling sector is facing mounting challenges as it prepares for the implementation of the deposit return system (DRS), Extended Producer Responsibility (EPR), and the EU Packaging and Packaging Waste Regulation (PPWR). However, the absence of clear national legislation aligning Polish law with EU directives has caused widespread legal uncertainty. As a result, between 2018 and 2023, one in three recycling facilities shut down. Many companies have postponed investments, awaiting regulatory clarity. The packaging industry is also affected by this state of limbo.
“The entire recycling industry has been waiting for the new EPR system. These are changes that will bring order to the recycling sector in Poland and the circular economy as a whole. We’ve been waiting since 2018,” says Sławomir Pacek, president of the Polish Recycling Association. “The EU required us to implement EPR by 2023. We’re more than two years behind, and the European Commission has already initiated a formal inquiry. The industry urgently needs this regulation to address the deepening crisis.”
In early June 2025, the Polish government added a draft law on packaging and packaging waste to its legislative agenda. The law is intended to implement the EU Waste Framework Directive, which Poland remains the only EU member not to have adopted. A lack of regulatory clarity has paralyzed the industry. According to a 2023 PwC report, nearly 30% of recycling facilities have closed since 2018, and the remaining ones have had to cut production—some by as much as 50%.
“There’s immense pressure from the EU to advance the circular economy and environmental goals. Yet there are still no supportive national regulations in place. This contradiction makes it extremely difficult for businesses,” Pacek adds. “The Ministry of Climate and Environment has finally presented a draft EPR bill, which should be enacted by July 2026 at the latest, as the PPWR will come into force in August 2026.”
According to Mikołaj Maśliński, a legal expert at MMLC Law & Consulting, businesses are burdened with obligations stemming from EU regulations, yet the legal details—especially the executive acts—are missing. “These specifics are essential to understanding how the new laws will be implemented and how much compliance will actually cost,” he explains. “This legal limbo is causing companies to delay investment decisions because they simply don’t know what to expect in the coming years.”
The PPWR introduces targets for reducing packaging waste per capita, increasing recycling rates, and mandating the use of recycled content in packaging. It also bans many single-use packaging types. Another major shift is the rollout of Poland’s DRS in October 2025, covering single-use plastic bottles up to 3 liters, reusable glass bottles up to 1.5 liters, and metal cans up to 1 liter.
“The recycling industry in Poland is fully prepared for the DRS, EPR, and PPWR. All we need is stable and swift legislation,” says Pacek. “Under the EPR, financial responsibility will be assigned to producers—especially for hard-to-recycle materials. This will encourage companies to switch to more recyclable packaging, speeding up material circulation and reducing waste.”
Under the Single-Use Plastics Directive, by 2025 PET bottles in the EU must contain at least 25% recycled plastic, and by 2030 all plastic bottles must reach 30%. These rules place significant new obligations on packaging producers.
“These obligations will only intensify under the EPR and PPWR,” Maśliński adds. “The cost of implementing DRS alone is expected to reach 3–4 billion PLN in the first year. The ongoing costs of EPR will add several billion PLN annually. For producers of food, cosmetics, and other FMCG products, this translates directly into increased operational expenses.”
Some companies have already started adopting more sustainable practices ahead of full regulatory enforcement. However, the lack of legal clarity is slowing this transition. “Firms want to introduce sustainable packaging, but also need to remain competitive,” says Maśliński. “If a product complies with 2030 rules now, it may become too expensive for the current market, putting companies at a disadvantage.”
Delays in implementing EU rules are hindering the shift to a circular economy, which is considered one of the most effective ways to reduce plastic waste and greenhouse gas emissions.
“The current global circularity rate is below 10%. We must strive to build an economy based on secondary raw materials,” says Anna Larsson, Director of Circular Economy Implementation at Reloop Platform. “This means processing post-consumer waste locally, creating regional jobs, and protecting the environment by reducing CO₂ emissions and the use of virgin resources.”
There are already positive examples. Deposit systems that collect beverage packaging and recycle it into new packaging materials are active in 18 European countries, including Greenland. In Poland, from October 2025, beverages in PET bottles up to 3 liters (deposit: 50 groszy), metal cans up to 1 liter (50 groszy), and reusable glass bottles up to 1.5 liters (1 złoty) will be covered by the system.
“Consumers are key to the success of circular systems. They buy products and ultimately decide whether materials return to the cycle,” Larsson explains. “Deposit systems provide monetary incentives, motivating consumers to return packaging instead of littering. This helps remove light beverage packaging from beaches and riverbanks, closes the loop, and ensures bottles and cans re-enter the recycling stream.”
Source: ceo.com.pl
