The Polish Ombudsman for Small and Medium-Sized Enterprises (SMEs) has raised concerns over the draft law on packaging and packaging waste (UC100), currently under review by the Ministry of Climate and Environment. According to the Ombudsman, the proposed framework for the Extended Producer Responsibility (EPR) system requires adjustments to better reflect the realities faced by micro, small, and medium-sized businesses.
Concerns of the SME Sector
The Ombudsman warned that the current EPR concept could impose excessive administrative and financial burdens on SMEs. Instead of supporting companies in fulfilling their environmental obligations, the system risks becoming a barrier to growth.
“We want the EPR system not to act as an obstacle to running a business, but to support entrepreneurs in meeting environmental requirements. That’s why we propose solutions that, on the one hand, increase the effectiveness of waste management and, on the other, protect the interests of the smallest companies,” said Agnieszka Majewska, SME Ombudsman.
Proposal for a Hybrid Model
In its submission to the Ministry, the Ombudsman suggested introducing a hybrid model, inspired by solutions used in other EU member states. Such a system would combine improved efficiency in waste management with the retention of key supervisory and control functions within public administration.
Simplified Procedures and Broader Consultations
The Ombudsman also stressed the need to simplify procedures related to contracts and applications handled by the National Fund for Environmental Protection and Water Management, which is expected to oversee the EPR system. Additionally, it called for extending the period of public consultations, citing the project’s complexity and significant consequences for businesses.
The comments focused exclusively on the EPR mechanism and did not address the deposit-refund system. The Ombudsman emphasized that it will continue to monitor the legislative process and actively support businesses during consultations to ensure that the final solutions are both ecologically effective and business-friendly.
Source: CEO.com.pl