Proposed reforms to Poland’s extended producer responsibility (EPR/ROP) system — drafted by the Ministry of Climate and Environment — are facing strong opposition from packaging producers and recovery organizations, whose operations would be effectively eliminated under the new model. Their main concern is that centralizing all financial flows under the National Fund for Environmental Protection and Water Management (NFOŚiGW) would make the waste management system less efficient and push costs onto consumers. A similar state-run model is currently in place in Croatia — where collection rates are below the EU average.
“The biggest controversy in the UC100 model is the shift from today’s pluralistic, private recovery organization system to a single state operator, which would be NFOŚiGW. It’s a 180-degree reversal that would wipe out recovery organizations, which for years have helped thousands of Polish businesses meet environmental obligations. This would be harmful not just to companies, but to the efficiency of the entire system,”
says Piotr Mazurek of the Lewiatan Confederation.
Bill would centralize €1.1 billion annually under NFOŚiGW
The draft ROP bill assumes that all fees paid by packaging producers would go directly to NFOŚiGW, which would then redistribute funds to municipalities and waste-management firms. The government estimates money flows of up to 5 billion PLN (€1.1 billion) per year.
Experts warn this could lead to excessive bureaucracy and major cash-flow delays.
“We’re heading towards a quasi-tax model — money flows from producers to the state and only then out to waste operators. The question is if, when and how much will actually flow? With current NFOŚiGW procedures it might take two or three years — while the system needs financing monthly or quarterly to function,”
warns Jakub Tyczkowski, CEO of Rekopol, Poland’s largest packaging recovery organization.
Producers: we’re ready to pay more — but not blindly
Packaging producers are not protesting the need to pay more — only the lack of control and transparency.
“Producers fully understand this will cost more. But they want to know what happens to their money — and influence how much they pay. In this model they will have no control. ROP has been reduced to a pure cash transfer: just pay and walk away,”
says Tyczkowski.
Fee levels under the proposal:
- Glass — 0.17 PLN/kg
- Multimaterial packaging — 1.68 PLN/kg
- Plastics — up to 1.76 PLN/kg
Recovery organizations warn this is de facto a hidden tax, the cost of which will ultimately be passed on to consumers through higher product prices.
Business think tanks warn: state model is least effective in Europe
The Warsaw Enterprise Institute (WEI) and Lewiatan point to regional evidence:
- Hungary — fully centralized state system → lowest packaging recycling rate in the EU (39.9%)
- Czech Republic — producer-led pluralistic system → recycling rate above 70%
- Croatia — state model → ~52%, well below EU average (67%)
“Only Croatia runs a fully state-managed EPR system — and it’s one of the EU’s worst performers. State-run models are typically expensive, inflexible and environmentally ineffective,”
notes Piotr Mazurek.
Experts call for partnership — not nationalization
Lewiatan stresses that the current draft goes against dominant EU practice, where multiple producer-led recovery organizations compete, which increases efficiency and innovation.
“EPR money is a tool to achieve environmental goals, and recovery organizations understand the entire packaging chain — from ecodesign advice for producers to regional differences in municipal collection efficiency. A central office in Warsaw simply won’t be able to manage that reality,”
says Jakub Tyczkowski.
