After many months of conceptual work, we read in an appeal to the Prime Minister - the Ministry of Climate and Environment published a fresh bill on packaging and packaging waste (UC100), intended to implement the rule of Extended maker work (ROP) into Polish law. In the presented draft, the Ministry completely deviated from its first concept of the ROP model based on proven experience in many European countries, and proposes the implementation of the model, which was proposed by the Government of Law and Justice, then widely criticized by all participants of the strategy and then opposition parties, now forming the ruling coalition in Poland. These rules are to apply from January 2026.
The Enterprise Council argues that the implementation of the ROP rules is crucial for manufacturers of packaging products not only due to the requirements imposed on the associate States of the European Union but besides for applicable reasons. They are intended to improve the recycling levels presently achieved, while ensuring that packaging itself is environmentally friendly and, above all, that the costs of collecting and processing these packagings are adequately covered.
We are so forced to note that the Ministry of Climate and Environment adopted the most extremist and controversial model in the bill. It introduces a paratax (packaging fee) on all packaging and packaging products, bringing producers to the function of passive payers of the fresh public tribute. The full stream of funds from producers is to be managed by the National Fund for Environmental Protection and Water Management, distributing this money between various marketplace participants (self-governments, municipal installations, waste companies and recyclers). Packaging recovery organizations, which today, on behalf of producers, carry out all tasks according to the laws in force in Poland, are to be eliminated.
So alternatively of creating the legal conditions for producers to carry out their fresh duties, the ministry wants to subject the state bureaucracy to another area of the economy. alternatively of creating an efficient and effective mechanics that benefits everyone, The Ministry wants to cover another area of the economy with an inefficient fiscal system. The introduction of a fresh taxation on packaging and packaging products will neither improve the quality of separate collection nor increase recycling. It will increase the prices of all products in these packages: food, cleaners, hygiene products and even medicines.
We besides believe that the solutions proposed in the draft UC100 are incompatible with EU law, including the revised Waste Directive and the Packaging and Packaging Waste Regulation (PPWR). Poland will become the only country in the European Union, where the rules will deprive producers of any real work for the implementation of the levels of separate collection and recycling of waste which arise after products placed on the marketplace by these producers. All work will be passed on to society, which will besides bear the costs of these solutions in the form of higher commodity prices and possible further penalties for Poland's failure to fulfil EU environmental obligations.
With this in mind, we ask the Prime Minister to halt further legislative work on the UC100. We believe that work on solutions for the implementation of Extended maker work rules should start from the beginning with the participation of all stakeholders and without subjugating any marketplace participants to the interests of others – the appeal states.
Business Council is a forum of cooperation of representatives of the 9 largest organisations representing entrepreneurs and employers in Poland. Originally established on 17 November 2003, it was revived on 24 March 2020 to rescue the Polish economy threatened by pandemic and recession. The Council represents nearly 330 000 employers with more than 8 million employees. The Presidency of the Council shall be word of office. The Council is presently chaired by the ABSL. Members: Association of Business Services Leaders (ABSL), Business Centre Club, Federation of Polish Entrepreneurs, Confederation of Leviathan, National Chamber of Commerce, Polish Business Council, Employers of Poland, Association of Polish Banks, Association of Polish Crafts.
Confederation of Leviathan
