From 1 January 2020, waste records only through the BDO

From 1 January 2020, an entry in the BDO register is a condition for keeping waste records and reporting in Poland. The Database on Products and Packaging and on Waste Management replaced the previous paper cards and reports, and waste holders — producers, collectors and transporters — must keep documentation electronically, on an individual account.

What changed

After many months of preparation, training and extended deadlines, the BDO became the mandatory channel for entities managing waste. The most important rules at the start of 2020:

• waste records and reporting are carried out exclusively electronically, on an account in the BDO;
• the condition is an entry in the register; an application in paper form could be submitted until 31 December 2019, and after that date only online;
• the Voivodeship Marshal has 30 days to consider the application and make the entry;
• an entity without an entry cannot transfer waste to collecting entities, because it has no way of issuing the required documents;
• the act provides for sanctions for breaching the obligations related to the system.

Significance for biogas plants

For biogas installations the BDO has two dimensions. First, if a biogas plant receives waste as a substrate — for example waste from the food industry, expired food or slaughterhouse waste — it is a waste holder within the meaning of the act and must keep records. Second, if a supplier transfers waste to a biogas plant, it needs a complete BDO entry on the recipient's side. In practice this meant the need to put documentation in order before the start of the year: waste codes, permits and the division of roles between the producer, the transporter and the recipient.

Also on farms using biogas plants that release digestate, and in plants processing biowaste, correct data in the BDO becomes the basis for settlements with the authorities.

What next

The system was announced as a tool for tightening the waste cycle and combating illegal dumping, but from the start it raised concerns about smooth operation and the availability of technical support for small businesses. The waste and biogas industries pointed out that efficient operation requires training and good internal practices. In the following years the database was expanded with new modules, including those on packaging and products, and with the implementation of EU waste management rules its importance for reporting was only to grow.

For new investors the practical conclusion is simple: an entry in the BDO and correct records of waste substrates are an element of project documentation on a par with the environmental permit.

Practical tips

For the operator of a biogas plant, the most important thing is to assign responsibility within the company: who sets up and operates the account, who verifies waste codes and who is responsible for the reports. It is also worth checking whether all administrative decisions on the basis of which the installation receives waste are consistent with the entry in the register, and whether contracts with suppliers contain a reference to obligations related to the BDO. Errors at the entry stage can be costly, because they block the transfer of a batch of substrate.