According to Kamil Majerczak of PreZero, the investment gap in Poland’s waste management system may be as high as PLN 40 billion. He stresses that Poland needs investment in sorting plants, recycling facilities and specialised waste treatment installations. Without them, even a well-functioning separate waste collection system will be ineffective. Representatives of the waste sector, business and food producers warn that the current draft legislation on extended producer responsibility does not clearly answer how the industry’s investment needs are to be financed.
“When we think about the efficiency of the waste management system in Poland and link this issue with investment, there is still a great deal to be done. There are various estimates of the investment gap, which ranges from PLN 20 billion to PLN 40 billion,” Kamil Majerczak, CEO of PreZero in Poland, told the Newseria news agency. “Poland lacks waste treatment installations, and I am not talking about basic treatment, but about specialised processing.”
As he adds, the most urgent needs concern the thermal treatment of non-recyclable fractions, bio-waste processing, sorting plants, recycling and installations for hazardous waste. Time is running out, because ambitious targets for recycling and reducing landfilling will be assessed in the 2030 and 2035 perspective.
“If we are to meet specific requirements at that time regarding what should happen to waste and how much waste should be recycled, the perspective of the next nine years is slowly becoming very urgent. These investments are multi-year projects which require a great deal of time from planning to implementation, which is why we should already be carrying them out now,” Majerczak points out.
Industry criticises the draft extended producer responsibility model
The industry is critical of the draft legislation on extended producer responsibility, or EPR, which in its view does not clearly define either the obligations of market participants or the flow of money. The draft in question is the new proposal from the Ministry of Climate and Environment, published in March 2026. The ministry emphasises that the current waste management model is ineffective and therefore requires change. In addition, the costs of the system are currently borne mainly by residents, while the financial responsibility of producers of packaging and packaged products remains limited.
“The draft introduces a revolution in the packaging waste management system,” explains Piotr Mazurek, Deputy Director of the Energy and Circular Economy Department at the Lewiatan Confederation. “The new extended producer responsibility model proposed in ministerial draft UC100 will turn the system completely upside down, including by eliminating recovery organisations.”
This is one of the changes proposed by the Ministry of Climate and Environment that has sparked major controversy. Packaging recovery organisations act as intermediaries between companies placing packaging on the market and entities responsible for collection, sorting and recycling. According to experts, disrupting these relationships would mean building the system from scratch.
The ministry proposes that some of the responsibilities of recovery organisations be taken over by the National Fund for Environmental Protection and Water Management. The fund would manage financial resources from EPR, namely revenue from packaging fees paid quarterly by producers for every kilogram of packaging, and distribute them, among others, to municipalities, municipal and packaging waste collectors, waste processors and recyclers.
According to companies from the packaging sector, this would mean that they would lose any influence over the course of the entire process. They stress that Poland needs an EPR model that ensures investment financing, increases recycling rates and does not dismantle the functioning elements of the current system.
“The model presented by the ministry is a bad and insufficient model, one that in no way brings us closer to achieving recycling targets, nor does it bring us closer to relieving residents of the costs of waste management,” says the CEO of PreZero. “The recommendation of the waste industry is this: let us return to the models that were previously on the table, which addressed these challenges much better. That is what we should focus on now.”
“The model proposed in draft UC100 — a state-run, centralised model — differs from the effective, well-functioning extended producer responsibility models operating in other European countries,” says Piotr Mazurek. “We know from the data that such centralised models are not effective, and that money flowing into the system is spent in a very non-transparent and inefficient way.”
The industry is concerned, among other things, about the discretionary role of the fund in distributing resources and about extended payment deadlines, which could lead to liquidity problems for sorting plants and municipalities, among others.
Producers are ready to pay more, but expect transparency
As the Lewiatan expert emphasises, businesses are ready to bear higher packaging-related costs, but they expect an effective, competitive and transparent system. This aspect is also highlighted by Andrzej Gantner, Director General and Vice-President of the Polish Federation of Food Industry Employers. The food sector is one of the key participants in the packaging market and already bears high costs under the current system.
“Food producers place more than 60% of all packaging on the market,” says Andrzej Gantner. “Today, it is difficult to say that this is a fully effective and satisfactory system. Last year, we paid more than PLN 1.4 billion for this system in the form of recycling confirmation documents. We keep repeating that we take responsibility for our packaging. We are ready to cover the costs of separate collection and preparation for recycling of our packaging, but only on the condition that the packaging actually collected separately is processed into recyclate, and does not end up in landfills or incineration plants.”
The food industry declares its readiness to assume greater responsibility, but stresses that food packaging must above all protect the product and the consumer, while also reducing food waste. For this reason, it cannot always be easily simplified or replaced with other materials.
“Investment in recycling, modern installations and chemical recycling certainly makes sense, but on the other hand we keep stressing that all this must take place on the basis of net cost. Very often, we will not be able to use these recyclates, because due to food safety requirements we can use only certain materials. Therefore, if we are to finance separate collection and if we want streams of raw material for recycling to be created not from several fractions but from 22 fractions, we also want those who later benefit from that recyclate to cover part of our costs. This is the principle of net cost, and we are counting on it finally being applied,” emphasises the Director General of the Polish Federation of Food Industry Employers.
Food producers must also take into account the new provisions of the PPWR regulation on packaging and packaging waste management. These concern, among other things, eco-design, with the aim of making all packaging recyclable in the long term.
“Food producers are implementing eco-design procedures and are trying to make their packaging as recyclable as possible,” explains Andrzej Gantner. “On the other hand, the specific nature of food means that, unfortunately, we must use quite a large amount of difficult, multi-material or barrier packaging.”
Full EPR implementation planned from 2029
Draft UC100 assumes that 2027–2028 will be a transitional period, with full implementation of the EPR system from 2029. Revenue from the packaging fee is expected to exceed PLN 4.3 billion in 2029.
The future EPR model was discussed during a conference organised to mark the 25th anniversary of Rekopol Packaging Recovery Organisation.
