Poland’s Ministry of Climate and Environment has proposed assigning the National Fund for Environmental Protection and Water Management (NFOŚiGW) the role of a producer responsibility organization (PRO). This entity would, on behalf of producers, fulfill obligations under the Extended Producer Responsibility (EPR) framework within a closed financial loop. However, representatives of the Polish Federation of Food Producers and the waste recovery sector warn that this model could hinder Poland’s ability to meet EU requirements for selective waste collection, potentially resulting in financial penalties—and, ultimately, higher consumer prices.
“The Ministry’s proposal is overly simplistic. It essentially means that instead of producers being held accountable, they would pay a quasi-tax to a public institution that would distribute the funds according to its own opaque criteria,” said Jakub Tyczkowski, CEO of Rekopol, a packaging recovery organization, in an interview with Newseria. “This isn’t EPR in practice; it’s a national-level redistribution system for packaging waste management funds, disconnected from true producer responsibility.”
The proposed EPR model, which has sparked strong opposition among companies placing packaged products on the market and among packaging recovery organizations, envisions phasing out current PROs by 2028. After this transition period, producers will still be allowed to fulfill their EPR obligations independently if they obtain a permit from the Minister of Climate. However, most recovery-related responsibilities would shift to the state-managed NFOŚiGW.
“Interestingly, even parts of the waste management industry are unhappy with the plan. I’m not sure if local governments fully understand what implementation would really look like. Opinions are deeply divided,” added Tyczkowski.
Andrzej Gantner, Director General and Vice President of the Polish Federation of Food Producers, emphasized that no EPR system in Europe exempts producers from covering the costs of selective collection and recycling preparation.
“We are fully aware and prepared to bear these costs. What matters is how the money is spent. In most EU countries, EPR relies on flexible collaboration among PROs, local governments, recyclers, waste companies, and producers. The goal is to achieve high levels of recycling at reasonable costs, driven by market forces,” Gantner explained.
According to Gantner, the model proposed by the ministry resembles those in countries like Croatia and Hungary, which are based on state-run monopolies. In such systems, producers act as passive taxpayers with no control over whether the funds lead to actual selective collection or meet recycling targets.
“Our fear is that a model dictated by bureaucrats—managed by the NFOŚiGW and regulated via decrees from the ministry—will lead to only one outcome: Poland failing to meet EU recycling targets, facing financial penalties, and the state’s only solution being to raise fees on producers. That, in turn, will raise prices for consumers,” he warned. “We strongly oppose this bureaucratic, monopolistic system that’s detached from market dynamics.”
Tyczkowski emphasized that if EPR is implemented correctly—via business-to-business relationships—the costs will be managed within the supply chain, and consumers will not feel the impact. But if the system becomes overly administrative, like some examples in the EU, consumers may notice price hikes, especially for food products.
He explained that as the EPR system matures, waste management costs will gradually shift from municipal “waste fees” paid by residents to product prices at the point of sale. Producers will pass part of the new EPR fees onto consumers.
“It may be just a few cents per package, but considering the volume of packaging on store shelves, the financial flow involved will be enormous,” the Rekopol CEO noted.
In an inflexible system like the one currently proposed, potential penalties for missing targets could drive price hikes far beyond the base fee itself.
“Extended Producer Responsibility is critically important for the food industry because it covers responsibility for the packaging we introduce, funding for selective collection, and preparation for recycling,” said Gantner. “Our industry is responsible for about 60% of all packaging on the market, and for us, packaging is not merely decorative. It ensures food safety, quality, durability, and helps prevent waste.”
In summary, the food sector is not resisting the principle of responsibility but is calling for a well-designed EPR system that promotes efficiency, market mechanisms, and transparency. The current government proposal, critics argue, risks undermining the very goals it claims to support—and could come at the cost of both compliance and consumer wallets.
