AmCham Position on the Extended Producer Responsibility System (UC100)

AmCham has submitted its position to the Chancellery of the President of the Republic of Poland, Minister Karol Rabenda, and Presidential Advisor Paweł Gruza regarding the draft Packaging and Packaging Waste Act (UC100), which aims to introduce a new Extended Producer Responsibility (EPR/ROP) system.

The proposed legislation directly affects AmCham member companies that place packaged products on the market. As it stands, the draft may significantly increase operating costs and consumer prices, while not necessarily improving the effectiveness of the recycling system.

In our position, we highlight several key issues.
First, the proposed model does not give producers a meaningful role in how the system operates, limiting their participation to paying a packaging fee — in practice functioning more as a levy.
Second, the draft centralizes decision-making and the management of funds within public institutions, without clear rules on transparency or oversight.
Third, the bill does not specify how the collected funds will be used, creating uncertainty for all stakeholders.

We also draw attention to the cumulative financial burden on producers, who would simultaneously bear the costs of the ROP fee, the SUP (Single Use Plastics) fee, and the upcoming deposit-return system. Taken together, this could lead to a system that increases public charges without delivering corresponding environmental benefits.

AmCham calls for renewed dialogue with the business community and for developing a market-based ROP framework in which producers participate in both governance and system oversight. Ensuring transparency, cost-effectiveness, and alignment with proven EU practices will be critical for achieving the goals of the reform.

The full text of the position can be found here.