In Poland, hazardous waste transport is governed by two sets of rules at once: the Waste Act (registration in the BDO waste register, the waste transfer note and the ODPADY sign on the vehicle) and the ADR agreement, if the waste is also dangerous goods. Instead of the old waste transport permit, a carrier now needs a BDO registration. For errors in documents and transport without registration, the Act provides for fines of up to 1,000,000 PLN, and they can also hit the company that commissions the transport.
This guide is for waste producers who arrange the collection of their waste, for carriers and for environmental officers at production plants, workshops, healthcare facilities and construction sites. We cover carrier requirements, documents, vehicle marking, fines and the rules for shipping waste abroad that apply from 21 May 2026. The legal status is as of 12 October 2026.
What is hazardous waste?
Hazardous waste is waste marked with an asterisk in the waste catalogue. The asterisk indicates at least one hazardous property, such as toxicity, flammability, corrosivity, infectiousness, reactivity or ecotoxicity. The legal basis is the Polish Waste Act of 14 December 2012 and the Regulation of the Minister of Climate on the waste catalogue.
Every type of waste has a six-digit code. For hazardous waste, the code is followed by an asterisk: for example, 13 02 05* stands for mineral-based non-chlorinated engine, gear and lubricating oils. The code determines who may transport and accept the waste, because each carrier’s BDO entry lists the specific codes it may handle.
| Waste category | Examples | Catalogue codes |
|---|---|---|
| Chemical waste | Paints, varnishes, solvents, acids, alkalis | 08 01*, 06 01* |
| Oil waste | Used engine oils, hydraulic oils | 13 01*, 13 02* |
| Electrical waste | Fluorescent tubes, accumulators, mercury-containing batteries | 16 06*, 20 01 21* |
| Medical waste | Infectious waste, used needles, instruments | 18 01* |
| Construction waste | Asbestos-containing materials | 17 06 01*, 17 06 05* |
| Other | Used filters, packaging contaminated with hazardous substances | 15 02 02*, 16 01 07* |
Two legal regimes: the Waste Act and ADR
Every waste shipment is subject to the Waste Act and the 2016 regulation on detailed requirements for waste transport. That is where the BDO registration, the waste transfer note (KPO) and the ODPADY (“waste”) sign on the vehicle come from. These requirements apply whether or not the waste is hazardous.
If the waste is also dangerous goods within the meaning of ADR, hazardous waste transport is additionally subject to the rules on the carriage of dangerous goods. The Waste Act refers to them directly (Article 24(2) of the Waste Act and the Act of 19 August 2011 on the carriage of dangerous goods). In that case the driver needs an ADR certificate, the load needs suitable packaging, and the vehicle needs orange plates, a transport document and instructions in writing.
| Set of rules | When it applies | Legal basis |
|---|---|---|
| Waste Act | Transport of all waste | Waste Act (consolidated text, Journal of Laws, Dz.U. 2023 item 1587) and Regulation of the Minister of the Environment of 7 October 2016 (Dz.U. 2016 item 1742) |
| Waste Act and ADR | Waste that is also dangerous goods (has a UN number) | ADR 2025 (Dz.U. 2025 item 642) |
| EU rules on top | Cross-border shipments of waste | Regulation (EU) 2024/1157, applicable from 21 May 2026 |
Whether ADR applies depends on the classification of the specific waste, not on the catalogue code alone. Used oil with the code 13 02 05* may, for example, be classified as UN 3082 (environmentally hazardous substance, liquid), but it is the consignor who assesses this based on the properties of the waste. Legal texts: Dz.U. 2025 item 642 (ADR 2025) and Regulation (EU) 2024/1157.
Do you need a permit to transport waste in Poland?
No. Since 24 January 2018, instead of a waste transport permit, a carrier needs an entry in the BDO register. That is when the regulation on waste transport requirements came into force, and paper permits were replaced by an electronic register in the Database on Products and Packaging and on Waste Management (BDO).
Who needs a BDO registration
Registration is mandatory for anyone who transports other parties’ waste on a professional basis (Article 50(1)(5)(b) of the Waste Act). This applies both to carriers specialising in waste and to ordinary haulage companies that accept such an order.
When you can transport waste without registration
You can transport waste you have produced yourself without a registry entry (Article 51(2)(4)). The exemption covers only the register. The requirements of Article 24 of the Act still apply, meaning safe transport and delivery of the waste to the designated site, and for waste covered by ADR, the ADR rules as well.
How to get a BDO registration step by step
Applications are filed only electronically through the BDO system (Article 53(2)). They are handled by the marshal of the voivodeship (the head of the regional government) competent for the company’s registered office, who makes the entry without delay and within 30 days at the latest, provided the application has no formal defects (Article 53(1)). The register lists the waste codes the carrier may transport, and each new code requires an application to amend the entry. A foreign business without a branch in Poland applies to the Marshal of the Mazowieckie Voivodeship.
How much a BDO registration costs a carrier
A carrier that only transports waste pays neither a registration fee nor an annual fee. The fees under Article 57 of the Act (200 PLN for micro-enterprises and 800 PLN for other businesses, with the annual fee due by the end of February) apply only to businesses placing products and packaging on the market and to packaging manufacturers and importers, not to waste carriers.
How to check a carrier’s registration
You can check the registration number and the scope of the entry in the public register on the bdo.mos.gov.pl platform. Do it before you sign the contract. A company that hands over waste to an entity without the required registration is itself liable to a fine (Article 194(1)(3a)).
Requirements for hazardous waste carriers
Hazardous waste transport is checked mainly by the ITD (Polish Road Transport Inspection) and the environmental protection inspectorate. They check the documents, the marking and the vehicle itself. A vehicle carrying waste may be stopped by the National Revenue Administration, the Border Guard, the Police, the Road Transport Inspection and the Environmental Protection Inspection (Article 24a of the Waste Act).
Documents in the vehicle
The driver carries a confirmation generated from BDO on the basis of the waste transfer note (Article 69(1a)). The 2016 regulation (§ 8) also lists as transport documents the invoice for the waste, the basic characterisation of the waste, the movement document for cross-border transport, or another document stating the type of waste and the details of the party commissioning the transport. The carrier puts its BDO registration number on all documents related to the service (Article 24(5)).
If the waste is subject to ADR, the cab must also contain the transport document, the ADR instructions in writing, the driver’s ADR certificate valid for the class of goods and, where required, the vehicle’s certificate of approval.
Vehicle marking
A vehicle carrying waste must display at the front a white plate measuring 400 x 300 mm with the word ODPADY in black capital letters at least 100 mm high, within a black border at least 15 mm wide. If there is not enough room for a plate of this size, a 300 x 120 mm plate with 80 mm lettering and a 12 mm border may be used. The plate must be durable and legible (§ 9 of the regulation). It is not required for waste exempt from record-keeping or for non-hazardous waste up to 100 kg (§ 11), so with hazardous waste it is needed in practically every case.
For waste covered by ADR, orange warning plates and placards showing the hazard class are added. In cross-border transport, a white 400 x 300 mm plate with a black letter A at least 200 mm high may be used instead of the ODPADY plate (§ 10). It is worth checking the requirements of the destination country before departure.
Vehicle and body
Waste carried in bulk requires a leakproof body, and containers and packages must be secured so that nothing shifts or leaks. For ADR transport, the vehicle must carry the equipment required for the class in question, including fire extinguishers, spill containment materials and the driver’s personal protective equipment.
Delivering waste to the designated site
The party commissioning the transport designates the destination and the receiver of the waste (Article 24(3)), and the carrier must deliver it exactly there (Article 24(4)). Changing the unloading site without the client’s consent is a breach of the rules.
Confirming the transport in BDO
Once the transport is completed, the carrier confirms it in BDO without delay (Article 69(3b)). Only then is the waste transfer note workflow complete.
Waste transfer note (KPO) in BDO
The waste transfer note is an electronic document in BDO that confirms the transfer of waste between companies. For commissioned hazardous waste transport, the note is mandatory. Since 1 January 2020, waste records, including KPO notes, have been kept only electronically.
Three parties are involved in the note workflow. The transferor, usually the waste producer, issues the KPO in BDO before the transport starts (Article 69(1)) and is responsible for the accuracy of the data: the waste code and weight and the details of the carrier and the receiver. The carrier generates a confirmation for the driver and confirms the transport after delivering the waste. The receiver, i.e. the waste facility, confirms acceptance of the waste in BDO (Article 69(3)).
Record-keeping from 2025. Since 1 January 2025, the regulation of 5 November 2024 (Dz.U. 2024 item 1644) no longer exempts any hazardous waste from record-keeping. Every company that produces even small quantities of used oils, mercury-containing batteries or paints keeps records in BDO and hands over the waste on the basis of a KPO.
A carrier that provides only the transport service keeps simplified records, i.e. only the waste transfer notes (Article 71(2)). It does not submit the annual waste report, which applies to waste producers and to companies that collect and treat waste (Article 75(1)).
ADR rules and hazardous waste transport
The current version of the ADR agreement is ADR 2025, published in Poland in Dz.U. 2025 item 642. The ADR rules are revised every two years, so the next version, ADR 2027, will come into force on 1 January 2027.
An important change in ADR 2025 concerns asbestos waste (UN 2212 and UN 2590). The new special provision 678 allows it to be carried in bulk bags in vehicles or containers meeting the VC1, VC2 and AP12 conditions, only from the place where it arises to the place of disposal, with an appropriate entry in the transport document (summary: HSENI).
Dangerous goods safety adviser (DGSA) in waste transport
A company that carries, consigns, packs or loads dangerous goods, including waste covered by ADR, appoints a dangerous goods safety adviser (DGSA). This also applies to waste producers consigning waste for transport and to the facilities that receive it.
The adviser monitors compliance with ADR, trains staff, prepares the annual report and investigates accidents. This can be an employee holding a DGSA certificate or an external adviser serving several companies. The certificate is valid for 5 years. No adviser is needed when shipments fall within the exemptions in section 1.1.3 of ADR, but most companies dealing with waste exceed these limits.
Shipping waste abroad from 21 May 2026
Until 21 May 2026, shipments of waste between countries were governed by Regulation 1013/2006. From that date, Regulation (EU) 2024/1157 applies (notice from GIOŚ, the Polish Chief Inspectorate of Environmental Protection). In Poland, the competent authority is the Chief Inspector of Environmental Protection, and a BDO registration alone does not entitle anyone to carry out cross-border shipments.
International hazardous waste transport, i.e. exports and imports, requires the procedure of prior written notification and consent by the authorities of the countries of dispatch, transit and destination. Waste on the so-called green list is shipped under the simpler information procedure, with an Annex VII document. The new regulation moves the exchange of documents to the EU’s electronic DIWASS system, and the parties to a shipment are identified by their EORI number (Deloitte, new rules).
Fines for breaches in hazardous waste transport
Administrative fines under the Waste Act are imposed by the provincial (voivodeship) environmental protection inspector (Article 196). For most transport-related breaches, the fine ranges from 1,000 PLN to 1,000,000 PLN (Article 194(3)).
| Breach | Provision | Fine |
|---|---|---|
| Transporting waste without the required BDO registration | Art. 194(1)(5) | 1,000 to 1,000,000 PLN |
| No BDO registration number on documents | Art. 194(1)(5a) | 1,000 to 1,000,000 PLN |
| No records (including KPO) or data that do not match the facts | Art. 194(1)(5b) | 1,000 to 1,000,000 PLN |
| Transport not compliant with Article 24 (e.g. no plate, no documents) | Art. 194(1)(2a) | 1,000 to 1,000,000 PLN |
| Handing over waste to a company without the required registration (fine for the client) | Art. 194(1)(3a) | 1,000 to 1,000,000 PLN |
| Failure to deliver waste to the site designated by the client | Art. 194b | 1,000 to 100,000 PLN |
ADR breaches detected during roadside checks are penalised separately under the Act on the carriage of dangerous goods. According to a summary by the Polish trade portal Przemysł i Środowisko, fines for individual breaches range from 200 to 10,000 PLN. The most serious cases, such as abandoning waste, can lead to criminal liability.
How to arrange hazardous waste transport correctly?
A waste producer is responsible for who it hands its waste over to, even if it does not transport anything itself. When you commission hazardous waste transport, you are responsible for the waste code, the transfer note and the choice of carrier. Choosing the wrong carrier or making an error in the transfer note costs the client just as much as the carrier. Below are five steps worth going through for every order.
1. Determine the waste code
Check in the waste catalogue which six-digit code matches your waste. An asterisk after the code means hazardous waste. Spent alkaline batteries have the code 16 06 04, while mercury-containing batteries have 16 06 03*. The code determines the choice of carrier and receiver.
2. Check whether ADR applies
Establish whether the waste is dangerous goods within the meaning of ADR. If it is, the carrier must provide a driver with an ADR certificate and a vehicle equipped for the class concerned, and you, as the consignor, are responsible for classification, packaging and the transport document.
3. Verify the carrier
On bdo.mos.gov.pl, check whether the company has an active registration for waste transport and whether it covers your codes. You can check a road haulier’s licences in the KREPTD (the national register of road transport operators) kept by the GITD (General Inspectorate of Road Transport).
4. Issue the KPO and specify the destination
Before the waste is collected, issue a waste transfer note in BDO with the code, weight, vehicle registration number and the details of the carrier and the receiver. Tell the carrier where the waste is to be delivered (Article 24(3)).
5. Choose an authorised receiver
The facility that receives the waste must hold a permit to collect or treat waste with the code in question. Handing over waste to a site without such a permit does not release the producer from liability.
Note for clients. The provincial environmental protection inspector may fine a company that handed over waste to an entity without the required BDO registration, even if it was the carrier that broke the rules (Article 194(1)(3a)).
Dangerous goods transport with Antrans BiS
Antrans BiS carries packaged ADR dangerous goods throughout Europe, for example as part of chemical transport and the transport of oils and liquids. If you are planning a waste shipment, include in your enquiry the waste code, quantity, type of packaging, UN number (if any) and the collection address and destination facility. We will check whether we can carry out the transport and prepare a transport quote.
Legal basis and sources: Waste Act (Dz.U. 2023 item 1587), regulation on waste transport requirements (Dz.U. 2016 item 1742), regulation on exemptions from record-keeping (Dz.U. 2024 item 1644), ADR 2025 (Dz.U. 2025 item 642), GIOŚ on Regulation 2024/1157.
Related articles: Transport documents in road haulage in 2026 | ADR instructions in writing | Transport company: what it does and how to choose a carrier | How to start a transport company in Poland in 8 steps
Hazardous waste transport: frequently asked questions
We answer questions about permits and BDO registration, transporting your own waste, ADR, responsibility for the KPO, vehicle marking, shipments abroad and fines.
Do you need a permit to transport waste in Poland?
No. Since 24 January 2018, instead of a permit you need an entry in the BDO register covering waste transport. The application is filed electronically via BDO with the marshal of the voivodeship, who makes the entry within 30 days. The register lists the waste codes the carrier may transport. Shipping waste abroad also requires consent under a procedure run by GIOŚ.
Does a transport company need a BDO registration?
Yes, if it transports other parties’ waste. A waste carrier must be entered in the BDO register (Article 50(1)(5)(b) of the Waste Act), and a carrier that only provides transport pays no registration or annual fee for it. A company that transports only waste it has produced itself does not need an entry.
Can you transport your own waste yourself?
Yes, waste you have produced yourself can be transported without a BDO registration (Article 51(2)(4) of the Waste Act). You still have to transport it safely, mark the vehicle in line with the regulation and deliver it to an authorised receiver. If the waste is dangerous goods within the meaning of ADR, the ADR rules also apply.
Does every company producing hazardous waste have to keep records in BDO?
Yes. Since 1 January 2025, no hazardous waste is exempt from record-keeping, regardless of quantity. This follows from the regulation of 5 November 2024 (Dz.U. 2024 item 1644). Even small quantities of used oils, mercury-containing batteries or paints must be recorded in BDO and handed over on the basis of a waste transfer note. Failure to keep records carries a fine of 1,000 to 1,000,000 PLN.
Does hazardous waste transport always require ADR?
No. ADR applies only when the waste is also dangerous goods, i.e. has a UN number assigned. This is decided by the classification of the specific waste based on its properties. In that case the driver needs an ADR certificate, the load needs suitable packaging, and the vehicle needs orange plates, a transport document and instructions in writing. Waste that does not meet the ADR criteria is subject only to the Waste Act.
Who is responsible for the accuracy of the KPO, the company or the driver?
The transferor, usually the producer who issues the KPO in BDO before transport, is responsible for the data in the waste transfer note. The driver carries the confirmation generated from BDO but is not responsible for an incorrect waste code or weight. The carrier is responsible for having the confirmation in the vehicle, for delivering the waste to the site designated by the client and for confirming the transport in BDO afterwards.
How do you mark a vehicle for waste transport?
A white 400 x 300 mm plate with the word ODPADY in black letters at least 100 mm high is fitted at the front of the vehicle. If there is not enough room, a 300 x 120 mm plate may be used. In cross-border transport, a white plate with a black letter A is allowed instead. For waste covered by ADR, orange plates and hazard placards are added.
Can a private individual transport hazardous waste?
Yes, residents can take hazardous household waste to a municipal collection point for separately collected waste (PSZOK) themselves. This covers, for example, leftover paint, batteries, fluorescent tubes or expired medicines. Business obligations, i.e. BDO registration and the waste transfer note, do not apply to private individuals. A company that transports waste as part of its business must always meet the full requirements.
What are the fines for transporting hazardous waste without a BDO registration?
Transporting waste without the required BDO registration carries a fine of 1,000 to 1,000,000 PLN (Article 194(1)(5) of the Waste Act). The same range applies to a missing registration number on documents, failure to keep records and transport that does not comply with Article 24, as well as to a company that handed over waste to a carrier without registration. Failure to deliver waste to the designated site carries a fine of 1,000 to 100,000 PLN. Fines are imposed by the provincial environmental protection inspector.
Do you need a separate permit to ship hazardous waste abroad?
Yes. Exporting hazardous waste requires notification and prior written consent from the authorities of the countries of dispatch, transit and destination, and in Poland the procedure is run by GIOŚ. A BDO registration alone is not enough. Since 21 May 2026, Regulation (EU) 2024/1157 has applied, replacing Regulation 1013/2006 and moving the exchange of documents to the EU’s DIWASS system.
Managing Director | Antrans BiS, Olkusz
Sebastian Szklarczyk has led the development of Antrans BiS, a transport company operating throughout Europe, for more than 15 years. He started as Head of the Freight Forwarding Department, gaining practical experience in organising international transport and managing a vehicle fleet on European routes.
As Managing Director, he is responsible for the strategic management of a company handling more than 21,000 transport operations a year on its main routes: Poland-Italy, Poland-Germany, Poland-Austria, Spain, the Benelux countries and Scandinavia. Under his leadership, Antrans BiS has expanded its fleet to 220 vehicles, including its own and partners’ vehicles, and achieved an on-time delivery rate of 98%.
Specialisms: international FTL transport throughout Europe, automotive and FMCG logistics, optimisation of European routes, road traffic regulations and driving bans in the EU, and transport documentation (CMR, VAT-UE, INTRASTAT).
On the Antrans BiS blog, he shares practical knowledge about international freight forwarding, transport regulations and the business aspects of running a transport, freight forwarding and logistics company in different European countries.
