Poland’s relationship with single-use packaging is shaped by two intersecting forces: a growing domestic food-service industry and binding obligations stemming from EU environmental legislation. The Single-Use Plastics Directive (Directive 2019/904/EC) set the framework, and Poland transposed its requirements through national legislation that came into force progressively between 2021 and 2024.
The EU Single-Use Plastics Directive and Its Scope
Directive 2019/904/EC targets ten product categories that are the most commonly found in marine litter counts across EU member states. The directive differentiates between three types of measure: outright prohibition, consumption reduction targets, and product design and labelling requirements.
Products prohibited from being placed on the market include:
- Cotton bud sticks with a plastic shaft
- Cutlery (forks, knives, spoons, chopsticks)
- Plates
- Straws
- Beverage stirrers
- Sticks attached to and supporting balloons
- Expanded polystyrene food containers and cups
- Oxo-degradable plastic products
Beverage cups and food containers made from other materials (including paper cups with a thin plastic lining) are subject to consumption reduction measures rather than prohibition. Member states were required to set national targets or measures achieving a measurable reduction in use.
Polish Transposition: The Act of 14 April 2023
Poland’s primary transposition instrument for the SUP Directive is the Act of 14 April 2023 on certain single-use plastic products (ustawa z dnia 14 kwietnia 2023 r. o niektórych produktach jednorazowego użytku z tworzyw sztucznych). This legislation is supplemented by implementing regulations specifying fee rates and administrative procedures.
The Act introduced a levy system for beverages sold in plastic cups and food sold in food containers. Food service operators above a turnover threshold are required to:
- Charge customers a fee for each single-use plastic cup or food container used
- Offer an alternative in a reusable container or a non-plastic container, where technically feasible
- Remit collected fees to the regional fund for environmental protection
The fee amounts are defined by regulation and are subject to revision. As of the time of writing, the applicable amounts are published by the Polish Ministry of Climate and Environment. Operators should verify current rates directly with the ministry or their regional environmental authority (urząd marszałkowski).
What Counts as Biodegradable Under Polish and EU Law
Polish and EU legislation use the term “biodegradable plastic” carefully and with reference to specific standards. For the purposes of the SUP Directive, “plastic” is defined as a material consisting of a polymer to which additives may have been added, and which can function as the main structural component of final products — with the exception of natural polymers that have not been chemically modified.
This means that paper-based materials and unmodified natural fibres (such as cellulose film that has not been chemically treated) fall outside the definition of “plastic” for regulatory purposes. Packaging made of these materials is generally not subject to the SUP restrictions, though it may still be subject to labelling or EPR obligations depending on the product category.
Industrial compostability is defined in Poland by reference to EN 13432, which specifies that a material must biodegrade by at least 90% within six months under controlled composting conditions at elevated temperatures. Products marketed as “compostable” without certification to EN 13432 or equivalent are considered misleading under Polish consumer protection law.
Extended Producer Responsibility in Poland
Poland’s EPR system for packaging predates the SUP Directive. The Act on Packaging and Packaging Waste (as amended) requires producers who place packaged goods on the Polish market to achieve recovery and recycling targets for the packaging they introduce. Targets are set per material type (paper and board, plastics, glass, metal) and expressed as a percentage of the mass placed on the market in a given calendar year.
| Material Category | Minimum Recycling Target (indicative) | Monitoring Body |
|---|---|---|
| Paper and board | Set annually by regulation | Regional environmental authority |
| Plastics | Set annually by regulation | Regional environmental authority |
| Glass | Set annually by regulation | Regional environmental authority |
| Metal (aluminium/steel) | Set annually by regulation | Regional environmental authority |
Producers that do not meet recycling targets are required to pay a product fee (opłata produktowa), calculated per kilogram of packaging not recovered. Many producers fulfil their obligations through membership in an authorised recovery organisation (organizacja odzysku), which pools targets and recovery costs across multiple producers.
Market Developments: Paper-Based Alternatives in Polish Food Service
Since the phased implementation of the SUP Directive, Polish food service businesses have shifted toward paper-based cups, cardboard trays, and moulded-pulp containers. These alternatives are now widely available through packaging distributors operating in Poland and are manufactured both domestically and imported from producers in Western and Central Europe.
Paper cups for hot beverages typically consist of a paperboard base with a thin polyethylene coating on the interior to prevent liquid migration. This coating, while necessary for functional performance, makes the cups technically non-recyclable in standard paper recycling streams, though specialist collection schemes for PE-lined cups exist in some Polish cities. Fully coatingless cups made with aqueous barrier treatments have entered the market as an alternative, but their performance under high-temperature and extended-hold conditions varies by product.