Waste transport in BDO: the waste transfer card (KPO), the waste records card (KEO) and carrier obligations

KPO (karta przekazania odpadów, the waste transfer card) is a document that the party transferring the waste prepares in BDO before transport begins; the receiving party confirms taking over the waste, and the carrier confirms the end of transport. KEO (karta ewidencji odpadów, the waste records card) is a register of receipts and disposals of a given type of waste held by the waste holder. Since 2020 both documents have been kept in the electronic Database on Products and Packaging and Waste Management (BDO), and the transitional period with paper ended on 30 June 2020.

Who is who in the chain

If the transferring and receiving parties are one company (transfer to its own collection or processing sites), that same entity adds the mass and the date and time of transfer in BDO.

Step by step: what a single transport looks like

1. The transferring party checks that it has an account and an entry in BDO, and determines the waste code from the catalogue.
2. Before departure it prepares the KPO. The card relates to waste with a specific code.
3. The carrier provides the driver with a confirmation generated from BDO; the driver must have it during transport, and it makes it possible to verify the data on the card against the actual situation.
4. On arrival the receiving party confirms receipt and enters the actual mass if it differs from the declared one, together with the date and time of receipt.
5. The carrier confirms the transport immediately after it ends.
6. The data from the KPO feed the waste records cards (KEO) of both parties.

What about the KEO

A waste holder keeps a records card separately for each type of waste. Special cards apply to, among others, municipal sewage sludge, waste electrical and electronic equipment and end-of-life vehicles; sellers and intermediaries who are not waste holders keep hazardous waste records cards. Records and the data on the basis of which they were prepared are kept for 5 years, counted from the end of the year in which they were created.

Who the simplified records apply to

Records on the KPO only are kept by, among others:

• producers of hazardous waste in quantities of up to 100 kg per year;
• producers of waste other than hazardous and municipal waste in quantities of up to 5 tonnes per year;
• carriers providing only a waste transport service.

The records obligation does not apply to, among others, producers of municipal waste and farmers farming agricultural land of less than 75 ha (unless they are subject to entry in the register for another reason).

Municipal waste: the KPOK

An entity collecting municipal waste from property owners uses a separate municipal waste transfer card (KPOK), prepared before collection begins, separately for each load of a given type. The rules for confirming receipt and transport are analogous to those for the KPO.

BDO failure and the transitional period

The Act of 23 January 2020 added an emergency mode: when the system is not working, documents are prepared on paper or electronically outside BDO according to the templates in the annexes, the driver must then carry the card or a copy of it, and the data must be entered into BDO immediately after the failure ends (within 30 days at the latest). For traffic at the beginning of the year, paper documents were permitted until 30 June 2020, and these had to be entered into BDO by 31 July 2020. Reports for 2019 were submitted in 2020 by the extended deadline of 30 June.

Transport of hazardous waste

In addition to the records obligations, there are the requirements of the rules on the carriage of dangerous goods (ADR), which regulate, among other things, marking, vehicle equipment and driver qualifications. For a biogas plant this concerns rare fractions, but with mixed deliveries (e.g. from production waste) it is worth verifying before the first run.

Example: three parties, one transport

A farmer (producer) hands waste from food production to a biogas plant, and an external carrier transports it. The role of the transferring party is played by whoever is the holder of the waste. The Act permits not preparing a KPO when one of the holders is not subject to the obligation to keep waste records (e.g. a farmer farming agricultural land of less than 75 ha). In case of doubt it is better to prepare the card, because it clarifies the responsibility of all parties. In this situation the carrier confirms the transport in BDO and the biogas plant confirms receipt.

Mini-checklist for the driver

• the BDO confirmation for the given transport (it corresponds to a specific card);
• the carrier’s registration number;
• for hazardous waste — the documents and equipment required by the ADR rules;
• consistency of the waste code and type with the actual load;
• the planned unloading site matching the card.

Common mistakes

• one card for several waste codes;
• no confirmation of receipt by the recipient or of transport by the carrier;
• mass on the weighbridge and in the KPO not matching, without a correction in BDO;
• no entry of the carrier in the register, or using a carrier’s services without verifying their number;
• failure to enter emergency documents into the system.

What to check first

1. Whether your BDO account has the correct types of activity and waste codes entered.
2. Whether the carrier has a registration number and whether the driver has the BDO confirmation.
3. Whether the KEO agrees with the KPO and the weighbridge.
4. Whether you know who the simplified records apply to.

This text is for information only and does not constitute legal advice; before an investment or formal decision, check the current wording of the regulations and consult a lawyer or the competent authority.