Who is subject to mandatory registration with BDO?

If an entity is required to keep waste records, it must register with the BDO in order to obtain a nine-digit registration number from the Marshal of the Province for entities introducing products, products in packaging and managing waste, including medical and veterinary waste. A registration number must be obtained not only by large production plants or companies dealing with waste management, but also, for example, dental offices, veterinary offices, tattoo parlours, beauty salons, medical offices, clinics and hospitals.

The BDO is a register of entities:

  • managing waste, including producers of medical waste,
  • introducing products (tires, oils, vehicles, batteries, accumulators, electrical and electronic equipment, disposable plastic products),
  • introducing products in packaging,
  • running retail or wholesale trade units offering plastic shopping bags covered by the recycling fee.


An entry in the BDO register can be obtained on the basis of an application to the relevant Marshal of the Province or ex officio. Entities generating waste that do not have a waste generation permit or an integrated permit must submit an application for entry in the register.

Some entities are exempt from this obligation because the Marshal of the Province makes an ex officio entry in the BDO for entities managing waste that:

  • have obtained a waste generation permit,
  • have obtained an integrated permit,
  • have obtained a waste collection permit or a waste processing permit,
  • have obtained a decision approving a mining waste management program or a permit to operate a mining waste disposal facility,
  • have obtained a concession for underground waste storage based on the Act of 9 June 2011 - Geological and Mining Law
  • have obtained an entry in the register of regulated activities in the field of collecting municipal waste from property owners.

Activities of entities whose registration in the BDO requires the submission of an application:

  • A producer of medical waste and other waste obliged to keep waste records,
  • A person transporting waste,
  • A seller of waste,
  • A broker in waste trade,
  • A holder of waste exempt from the obligation to obtain a permit for waste processing,
  • A person operating a ship recycling plant,
  • Activities resulting from the Act of 11 May 2001 on the obligations of entrepreneurs in the scope of managing certain waste and on the product fee (Journal of Laws of 2016, item 1478)


The following are not subject to entry in the BDO register (Art. 51 of the Waste Act):

  • Natural persons and organizational units that are not entrepreneurs, using waste for their own needs, in accordance with Art. 27 sec. 8 of the Waste Act,
  • Entities possessing the surface of the land on which municipal sewage sludge is used for "agricultural" purposes, exempt from the obligation to obtain a permit for waste processing,
  • Entities conducting activities other than business activities in the field of waste management, which collect packaging waste and waste in the form of used consumer goods, including pharmacies collecting medicines and medicine packaging, stores accepting used consumer goods, schools, educational and upbringing facilities or offices and institutions with waste collection systems (non-professional waste collection activities),
  • Waste producers who are farmers managing an area of ​​​​agricultural land below 75 ha, unless the activity in the field of waste generation requires a permit,
  • In the field of waste transport - entities that independently transport the waste they produce.