The introduction of an EPR (Extended Producer Responsibility) system in Poland will cause the system changes in waste management. It will therefore be crucial whether the new solutions – beyond just financing the management of packaging waste – will address the current needs and challenges of this sector. Equally important are the directions and mechanisms that will be implemented in connection with the planned regulations. This raises questions such as: What is the current state of waste management in Poland? What are the biggest challenges in this area? What solutions are needed? What opportunity, if any, does Poland’s previous lack of an EPR system present? Is EPR only about producers covering part of waste management costs? What should be the focus? What characteristics should the Polish EPR model possess? What mechanisms should it trigger? How can EPR become a “driving force” for the entire Polish waste management system? Can the waste management model change with EPR? What might be the direction of these changes?
Lack of an EPR system – an opportunity for the system change
The state of waste management in Poland often draws negative opinions and comments, and the needs in this area are huge. Improving the situation is not only desired but, in many aspects, truly expected and required. The highly debatable deposit-refund system, in its currently proposed form, won’t fix the industry. The core issue isn’t the effectiveness of collecting and recycling PET bottles or aluminum cans, but rather broader systemic problems. In this context – considering the industry’s unsatisfactory state – the lack of an implemented Extended Producer Responsibility (EPR) system until now could be seen as an opportunity for systemic change and speeding up the achievement of waste management goals.
Poland needs well-thought-out, bold, and effective systemic solutions in waste management. According to data from the Institute of Environmental Protection – National Research Institute (IOŚ-PIB) for 2022, the recycling rate for municipal waste is only about 27%, whereas the target for 2025 is 55%. Similarly, IOŚ-PIB reported that packaging waste recycling reached approximately 54% in 2022, compared to the required 65% by 2025. This means that, on average, only about 50-55% of packaging waste meant to be recycled actually gets recycled.
Waste management goals are growing beyond reach
Producers are manufacturing products and packaging in quantities that align with their business operations and the increasing demands of the market. It’s unrealistic to expect them to produce less. Consequently, the amount of waste is growing, not shrinking. At the same time, there is no real motivation to produce packaging that would be easy to recycle. At once, waste management targets are rising to levels that exceed the possibility of achieving them. The needs in this area are therefore getting bigger and bigger. However, the Polish waste management system isn’t keeping pace, and this statement applies not only to technological infrastructure.
Needs exceed technological capacity for waste processing
Despite Poland having several dozen automated municipal waste sorting facilities, the infrastructural needs for sorting both mixed and selectively collected waste remain huge. This is clearly illustrated by the technological level of Polish facilities. It’s estimated that only about 20-30% of them are capable of effectively preparing waste for recycling using advanced technologies. This means that current technological capabilities significantly don’t meet actual needs.
Poland still lacks adequate infrastructure, or its level of advancement is insufficient. As a result, investments are crucial for both building new facilities and expanding and modernizing existing sorting plants. In recent years, only a few new waste sorting plants have been built, and the pace of infrastructure development isn’t keeping up with growing demands. These demands are measured by the year-on-year increase in municipal waste, as well as the rising recycling targets that need to be achieved.
Complicated administrative procedures block investment
It’s clear we need to speed up the construction of infrastructure that supports waste recovery and recycling. Yet, complicated administrative procedures are making these investments difficult to implement. A project that takes five years to prepare and implement is now considered efficient. But that’s far too long to speed up investments in much-needed technological infrastructure. So, not only are there no active mechanisms to support investment processes, but existing administrative procedures actively slow them down.
For example, getting an environmental permit alone takes an average of one to two years. Similarly, the procedures for getting an integrated permit are lengthy, often blocking the operation of technological facilities that have been built to specifications, approved by the relevant authorities, and equipped with machinery already under warranty. These administrative obstacles don’t just prolong the investment process by years; they also significantly reduce the motivation to commit to and undertake new projects.
Market conditions don’t support operations or investment planning
Market conditions also are not of any support to further investments. Unstable raw material prices and Poland’s system of recycling confirmation documents (DPRs) make long-term planning difficult. When DPR prices are high, they motivate facilities to sort and recover raw materials more effectively, because it is profitable. However, when DPR prices drop to minimal values (like they did at the end of 2024), the economic motivation to efficiently sort fractions vanishes.
This mechanism not only does lead to operational instability, but also increases investment uncertainty. In a dynamic raw material market, DPR price swings further complicate assessing the profitability of new investments. The current DPR system, therefore, doesn’t ensure the stable achievement of waste management goals – neither at the local commune level nor nationwide.
Despite their growing potential, private entities aren’t fully utilizing it due to system instability, market dynamics, and regulatory uncertainty. In short, there’s a lack of stable conditions and factors ensuring the profitability of operational activities, which are crucial for companies making investment decisions based on economic calculations.
Stability and operational profitability are critical not just for private entities but also for public sector facilities. The absence of predictable market and regulatory conditions slows down and blocks the development of the entire waste management system.
Municipal waste sorting plants to lose dozens of percent of income from raw material sales due to deposit-refund system
In this context, the prospect of introducing a deposit-refund system from October 2025 emerges. It’s an illusion to believe this system will fix Poland’s waste management economy – it’s commonly known that it won’t solve the industry’s problems. The system itself is very costly, and it also destabilizes and generates costs in its surroundings.
The most significant consequences of introducing the deposit-refund system will be incurred by municipal waste sorting plants, which prepare waste for recycling (explained in: “Municipal waste sorting facilities facing new challenges in Poland: increasing recycling rates, the deposit return system, and the Extended Producer Responsibility”). As a result of its implementation, they will lose dozens of percent of their annual revenue from raw material sales. This will lead to serious economic consequences and further block the achievement of waste management goals. The increased cost of waste processing at these facilities will be passed on to municipalities, which will bear a double financial burden: not only the increased cost of waste processing, but also penalties for failing to meet the required levels of waste prepared for recycling. Under the Act of November 21, 2024, this penalty will amount to half the rate applicable in 2025, that is, PLN 382.54, for each ton short of the required recycling level.
Managing the caloric fraction is the biggest cost for waste sorting facilities
Another unresolved problem is the caloric fraction, which currently costs 800-1000 PLN per ton to manage. The costs associated with managing the caloric fraction represent by far the largest financial burden for municipal waste sorting plants. Other significant cost groups, far smaller than the caloric fraction’s management, include employee wages and electricity consumption. These high costs for managing the caloric fraction significantly impact the overall cost of the waste management system, directly translating into higher fees for residents. Developing waste-to-energy (thermal processing) facilities could significantly improve the situation by enabling the management of the caloric fraction and lowering overall system costs. Although this topic is frequently discussed, the pace of implementing necessary changes remains too slow.
Ultimately, residents will pay for all these expenses – including the inefficient system – as their waste management fees continue to rise.
The recycling industry awaits real support and development opportunities
The prospects for the recycling sector also aren’t optimistic; the industry is still waiting for appropriate regulations and support to enable its growth. Recycling represents the demand side in the secondary raw materials market, relative to waste sorting facilities. Real support and development for recycling are not only an opportunity to achieve higher recycling rates, but also a way to improve the situation in the secondary raw materials market.
Weak demand for sorted secondary raw materials lowers the efficiency of waste sorting processes, further weakening the entire waste management system. Without a stable recycling market, it’s hard to hope for an improvement in the waste sector.
To the problems discussed, we must also add neglect in eco-design, which complicates raw material recycling. Improper material composition of packaging, multi-material designs, or color choices make waste harder to process. Another issue is the lack of necessary, detailed, consistent, and reliable data, which would significantly improve analyses and effective operation management in waste management.
Growth happens through change – implementing the right EPR model is the opportunity
We can assess this situation in two ways. The first is a negative assessment. We can criticize the situation, look for guilty ones, and simply wait for something to happen. The second approach allows us to view the situation as a challenge that we can use as an opportunity to introduce a genuine economic policy in waste management, focused on specific goals and their effective achievement. There’s strong evidence that precisely such a clear and unambiguous policy is missing.
Growth happens through change. The chance to improve the current state of waste management in Poland lies in implementing the correct EPR system. This is an opportunity to introduce a mechanism that can become a driving force for the entire waste management system.
It’s not just about producers bearing part of the waste management costs. The key is to use the EPR system to create an effective mechanism of support and motivation that will strengthen the development of the waste industry. This approach will enable the waste sector to become more solid in managing waste processes, focusing on achieving its set goals.
The Polish EPR: three key dimensions
With this approach, it will be crucial to focus on three dimensions and categories of the Extended Producer Responsibility (EPR) system planned for introduction in Poland: the system itself, efficiency, and economic policy.
System
This is important because EPR is a mechanism concerning all market participants and processes related to waste:
- Producers of products and their packaging, which eventually become waste.
- Consumers who purchase products.
- Municipalities responsible for waste collection and maintaining cleanliness.
- Waste sorting facilities that separate raw material fractions from municipal waste and prepare them for recycling.
- Recyclers who process secondary raw materials into new products.
- The state, which sets targets, conducts economic policy, creates the necessary conditions for its implementation, and has a supervisory function.
Efficiency
This area is about the efficient achievement of environmental goals and the optimization of associated costs. An efficient system is one where its individual elements collectively contribute to the overall success.
Economic Policy
The EPR model, being systemic and impacting interconnected elements, can become a powerful tool for introducing broad changes in waste management. The state’s economic policy is essential because waste management is an area where the market alone cannot solve problems.
Desired features of the Polish EPR system
A proper and effective EPR system should possess the following characteristics:
- Be aimed at the effective achievement of waste management goals.
- Cover the entire system, including all key participants and waste-related processes (the structural aspect).
- Be based on supporting desired processes and motivating participants toward appropriate market actions (the functional aspect).
- Ensure economic stability and profitability of operational activities.
- Serve as a tool for implementing state policy.
An EPR system with these characteristics, ensuring economic stability and operational profitability for municipalities, waste sorting facilities, and recyclers – combined with a coherent policy for co-financing waste management investments and eliminating administrative barriers – offers an opportunity to significantly speed up infrastructure development and shape market participant behaviors essential for achieving environmental goals, which requires comprehensive actions.
The Polish EPR system should trigger mechanisms that address the current diagnosis of the waste management situation, leading to:
- Increased recycling rates for municipal and packaging waste.
- Improved packaging and product design, which will simplify further recovery and recycling processes.
- Increased technological level of Polish municipal waste sorting facilities and waste recycling plants.
- Improved economic conditions for facility operations, regardless of whether a deposit-refund system is introduced. The goal is for economic conditions to improve as a result of the EPR system’s implementation, in a way that motivates facilities to invest and act toward achieving waste management goals.
- Improved investment and operational conditions for recyclers, who are the market recipients of sorted raw material fractions and ultimately transform them into new products.
- Improved quality of audits and controls for market participants.
- Improved record-keeping and reporting, resulting in a more accurate picture of the waste management situation, which will enable proper management processes, system improvement, and effective state economic policy.
The necessary mechanism for the development of a twin industry – waste management
If we want to maintain an economic growth model based on increasing production and consumption – a model that results in a growing waste management problem – it’s essential to develop a strong twin industry. This would be a kind of “the second face” of the economy: the waste management industry, covering waste collection, recovery, and recycling. In such a scenario, the development of the waste industry must keep up with the growth of the manufacturing industry, ensuring that waste generated from consumed goods doesn’t burden the environment.
For this to happen, producers’ responsibility for packaging and products cannot end the moment they are placed on the market. It should be expressed as financial responsibility for both the quantity and quality of products and their packaging. Currently, the costs of managing waste resulting from consumption are shifted to the public sector – municipalities and the state – which fund waste management. In practice, this means residents and taxpayers are the ones to pay for it. Meanwhile, an underfunded and inefficient waste management system, lacking appropriate economic systemic solutions, cannot keep up with growing needs and legal requirements.
The goods production industry generates profits for producers and satisfaction for consumers. The waste industry, on the contrary, generates costs and obligations. In a market model, waste management costs should therefore be integrated into the price of the product and included in its final value. They should be a burden for both sides of the market exchange – producers and consumers – that is, those who generate waste. This would allow for a reduction in the involvement and financial participation of the public sector (municipalities and the state) in waste management.
The state must take real responsibility for the system’s efficiency
The state’s role should focus on creating appropriate legal conditions, building the system, and performing a supervisory function. What is more, the state should bear responsibility for the efficiency of the entire system, for example, for achieving the required recycling levels. In such a model, a municipality would mainly focus on effective selective waste collection and resident education. However, because a municipality is only one part of the waste management system, it should not be held responsible for the final results. Implementing such a solution would mean a departure from the current model where municipalities play a key role in waste management and are responsible, among other things, for recycling rates – even though, in practice, they have little influence over them, as they neither produce nor process waste.
Economically linking production and consumption to waste management – the key to funding
The waste management industry is essential for developing a circular economy, for the environment, and for our quality of life. It must develop and adapt proportionally to the growth of the goods production industry to prevent a deficit in waste management capacity. If the costs of managing waste from used products and their packaging are included into the price of those goods, then the development of this twin waste industry can be funded in parallel with increasing production and consumption, which would significantly reduce the burden on public finances and residents.
Waste management costs rise as the production and consumption of goods increases. However, in a market model, these costs can be included into the product’s price and become a source of funding for managing the resulting waste. This allows the waste industry to develop naturally and autonomously – in a market-driven way – in proportion to needs. As waste management costs are integrated into product and packaging prices, and as production and consumption increase (that is, with economic growth), the waste management system will be resourced with the funds necessary to handle waste. In this manner, the waste industry can become strong, efficient, and capable of meeting the challenges of waste management. The key to this is economically linking the production and consumption of goods with the management of the waste generated after their use.
Will Poland use the opportunity to implement a good EPR model?
The Extended Producer Responsibility (EPR) system presents an opportunity to implement such a model in Poland, provided it’s structured correctly. Crucially, this involves creating appropriate revenue mechanisms for the EPR system and a compensation model for the entities responsible for different stages of waste management. Following the Czech example, such a system should be based on the operational efficiency of the participating entities.
So, will Poland use this chance to create a driving force for its waste management economy?
Sources:
- Sprawozdania marszałków województw z realizacji zadań z zakresu gospodarowania odpadami komunalnymi w 2022 r., Instytut Ochrony Środowiska – Państwowy Instytut Badawczy, 2024, https://ios.edu.pl/wp-content/uploads/2024/08/sprawozdania-marszalkow-wojewodztw-2022-v-003.pdf, dostęp 14.09.2024.
- Rynek recyklingu odpadów opakowaniowych w Polsce w 2022 roku, Instytut Ochrony Środowiska – Państwowy Instytut Badawczy, 2024, https://ios.edu.pl/wp-content/uploads/2024/10/rynek-recyklingu-odpadow-opakowaniowych-w-polsce-w-2022-roku-04c-forum-04-1.pdf, dostęp 25.02.2024.
