The draft for a new extended producer responsibility (EPR) system presented by the Ministry of Climate and Environment has stirred controversy among packaging recovery organizations and producers. The main concern is that, instead of creating a multi-layered system for managing packaging waste, the plan effectively establishes a new tax regime. Companies would have to pay a centrally set fee to the National Fund for Environmental Protection and Water Management (NFOŚiGW), which would become a “super-agency,” while producers lose influence over the efficiency of collection and processing. Industry groups are therefore urging that the project be “thrown out.”
In mid-August, the Ministry outlined the assumptions of the new producer responsibility system. It says the rules would introduce genuine financial responsibility for waste arising from producers’ packaging, in line with the “polluter pays” principle, benefiting municipalities, citizens, and the environment. The ministry argues the system would push producers toward more eco-friendly, easier-to-recycle packaging—and the fewer packages placed on the market, the lower the fee to be paid.
“We’ve had a new EPR bill for a few days now. We read it closely. It is unmistakably the introduction of a tax system in Poland—there’s no debate about that. On top of that, it nationalizes money that is currently managed by recovery organizations. Something run today by private entities would be run by a public institution. Are we going back to the 1950s? That’s the impression I get,” said Jakub Tyczkowski, CEO of Rekopol, in an interview with Newseria.
The Ministry stresses the EPR law does not introduce a new tax. It merely shifts fees to the start of the cost chain, which—according to officials—should lower municipal waste-management costs and stabilize household waste bills. Producer organizations disagree.
“We won’t be getting any new EPR at all—just a new tax on all packaged products. Do new taxes motivate anyone to do anything? That’s rhetorical. The only effect will be higher prices that consumers will feel immediately. The ministry’s idea that residents will pay a little less to the municipality, while as consumers they pay more in the store, is absurd—it’s the same person. If the ministry thinks the 50 grosz reduction in a monthly waste bill will offset the price increases that same person faces at the checkout, it doesn’t understand economics,” said Krzysztof Baczyński, President of the Employers’ Union of the Packaging Industry and Products in Packaging (EKO-PAK). “We are not against EPR, but the ministry’s draft, UC100, is simply a cash grab—a new tax to be paid by all Poles.”
“This is an expanded packaging tax that all of us—producers and consumers—will pay through product prices. It has nothing to do with real EPR, where producers take responsibility for the entire product and packaging life cycle, for selective collection targets and their increase, for recycling levels, and for ensuring quality collection so that as many fractions as possible are gathered and recycled. This bill has nothing to do with that,” added Andrzej Gantner, Director General and Vice President of the Polish Federation of Food Industry (PFPŻ). “The bill tells us outright: we must pay whatever the ministry says, under vague, non-transparent rules set between the ministry and the National Fund, which—remarkably—is to act as an EPR organization, despite being entirely unprepared for that role.”
The Ministry maintains that the packaging fee will not noticeably affect store prices. In the first year it would be at most half a grosz per package, and after full implementation in 2028, it would remain at only a few grosz.
“In reality it’s not about how much the price of a single package rises, but how much consumers’ costs rise because the prices of all packaged goods rise. Two numbers in this bill are clear. First, the resident’s monthly municipal waste bill is meant to drop by about 50 grosz. Second, by 2028 consumers will be paying over PLN 5 billion in this ‘tax’ through product prices. So, 50 grosz in monthly savings versus PLN 5 billion paid at the checkout—bureaucracy and perhaps the National Fund are the only winners here,” Gantner said. “The bill envisions total, 100% power for the National Fund over everything—over us as producers, who will just pay what we’re told, and over municipalities, which will somehow have to claw back their investments in packaging-waste management.”
“This is strikingly similar to healthcare and the National Health Fund. Do higher health contributions improve healthcare quality? No. Will a new tax on all packaged products improve selective collection? We can answer that ourselves: will higher burdens on consumers improve what’s in household bins?” Baczyński asked.
“In virtually all EU countries—bar perhaps one—EPR systems are built around producer responsibility organizations (PROs). Why? Because their role isn’t just to cover costs—i.e., pass money from producers to those who bear the costs, like municipalities, collectors, sorters, or recyclers. The role of PROs is to understand the entire chain—from the moment packaging is created to when it’s recycled, and beyond. That means understanding each market participant’s needs and calibrating incentives so that the whole chain runs smoothly,” Tyczkowski noted.
In his view, the UC100 draft leaves no meaningful role for existing recovery organizations. “All these roles are to be taken over by the National Fund. I find it hard to believe that a civil servant will ponder whether the system is efficient,” said the head of Rekopol.
“As entities placing packaging on the market, we have obligations under the EU’s PPWR regulation. This proposal strips us of any tools to meet those obligations—the state is supposed to do it for us, and we’re simply to pay and stop worrying. But in five years, when some of our packaging is banned from the market, will that be our problem—or the state’s?” asked the EKO-PAK president.
According to Gantner, many crucial details remain unknown from the food industry’s perspective. “We only know there will be fees. We don’t know the costs for specific packaging fractions, or how ‘difficult’ packaging—common in food—will be treated. We keep stressing that food packaging exists to ensure safety and quality. If the government plans to impose a flat, unreflective ‘food safety tax,’ we are firmly opposed.”
He added that for the food sector—which places over 60% of all packaging on the market—the proposal means paying not only for selective collection but also for access to recyclate for other industries. The reason is that sector costs would not be netted off, as there is no mechanism allowing producers’ fees to be reduced by revenues from collected material.
“This is exceptionally unfair to food producers. It flatly contradicts 30 years of Poland’s economic transformation. It runs counter to the free market. It’s a festival of bureaucracy, centralism, and statism. In our view, the bill should be thrown out,” Gantner concluded.
Experts discussed the ministry’s proposals during the panel “Extended Producer Responsibility — a New Fiscal-Bureaucratic Burden or an Investment in the Circular Economy?” at the Economic Forum in Karpacz.
