UC100 is the reference for the draft Polish act on packaging and packaging waste – the national instrument meant to accompany the EU’s PPWR (Regulation (EU) 2025/40) and to rebuild the Polish system of extended producer responsibility (EPR). One costly myth has grown up around this act: that you “have to wait” for it before the PPWR starts to bind your company. That is not true. The PPWR is a regulation – it works directly and applies from 12 August 2026, whatever stage UC100 has reached. The Polish act settles a different layer: who enforces, what the penalties are, how the packaging charge and EPR work, and how all of it locks together with the deposit return system. This article, refreshed as things move, explains where UC100 stands today and what its shape means operationally for a Polish company. We write about it not as a law firm would (“what the rule says”), but as a manufacturer of reusable packaging: what to do about it, and what not to put off.

Key takeaways

  • UC100 is the draft’s number in the Council of Ministers’ programme of legislative work – behind it sits the draft national act on packaging and packaging waste, led by the Ministry of Climate and Environment.
  • The PPWR binds without UC100. As Regulation (EU) 2025/40 it applies directly from 12.08.2026. The requirements for the packaging itself (re-use, recycled content, empty space, PFAS) do not wait for the Polish act.
  • UC100 governs the national layer: the competent authority and the system operator, penalties, the packaging charge and the rebuild of EPR, plus changes to the deposit return system (running since 1.10.2025) – this is where the real uncertainty sits.
  • Status as at 11.08.2026: the draft is past public consultation and review, in the work of the Council of Ministers’ committees (the Committee for European Affairs); not adopted by the Council of Ministers, not before the Sejm. The most recent dated version of the text on the RCL: 8.07.2026.
  • Stated entry-into-force date: 12.08.2026 (per the regulatory impact assessment and the final provision of the July 2026 version; the earlier March version gave 1.01.2027 in its impact assessment) – a date recorded in the draft and carrying a high risk of slipping, because the draft has not yet been through the Council of Ministers or the Sejm. We do not treat it as a forecast.

  • What to do now: do not put the PPWR obligations on hold waiting for UC100; track UC100 in parallel for EPR, penalties and reporting. The action plan is at the end.

     

What UC100 is – and what it covers

“UC100” is not the name of the act but its number in the Council of Ministers’ list of legislative and policy work. The “UC” prefix marks a draft act that implements European Union law. Behind that number sits the draft act on packaging and packaging waste, led by the Ministry of Climate and Environment. The project card in the Rządowy Proces Legislacyjny states plainly that the draft implements Regulation (EU) 2025/40 (PPWR) and the Waste Framework Directive (2008/98/EC). The draft does several things at once. First, it aligns Polish law with the PPWR wherever the regulation calls for national decisions – above all designating the authorities and setting the sanctions and oversight mechanisms. Second, it rebuilds the extended producer responsibility (EPR) system for packaging. Third, it amends earlier legislation – including the ustawa o gospodarce opakowaniami i odpadami opakowaniowymi of 2013, the Polish act on the management of packaging and packaging waste – and the deposit return system, which went live on 1 October 2025. That distinction is the heart of the whole article, so it is worth putting plainly.

 

The PPWR works without UC100 – the distinction that matters most

In the Polish debate you often hear that “we are waiting for the act”. That sentence conflates two entirely different layers of law – we described the same kind of confusion in the context of EPR in the article EPR vs PPWR – two charges, not one. The PPWR is a regulation. An EU regulation binds directly and uniformly in every Member State, with no national implementing act. Most PPWR provisions apply from 12 August 2026, and the hardest thresholds – among them the re-use of transport packaging (Article 29), recycled content (Article 7) and the empty-space limit (Article 24) – from 1 January 2030. Those requirements reach your company whatever happens to UC100. We set out the full PPWR timeline in the introductory article on the PPWR. UC100 is a national act. A regulation does not settle everything – it deliberately leaves some decisions to the Member States. That is precisely UC100’s domain: which authority is competent, what oversight and sanctions look like, how the packaging charge and the rebuilt EPR are constructed, and how all of it works with the deposit return system. Put another way: the PPWR says what the packaging and the loop have to be like; UC100 says, in large part, who enforces that in Poland and how, and how much you pay under EPR. The practical conclusion for a compliance team is uncomfortable but simple: putting PPWR preparations off “until UC100 is passed” is a trap. The product obligations run on their own, EU clock. The Polish act may add reporting and financial obligations – but their absence today does not suspend the PPWR.

 

What UC100 changes operationally (in the current draft)

The points below describe the direction taken by the post-consultation version of the draft (March 2026). It is still a draft – its content may change in the course of government and parliamentary work, so we treat every element as provisional and check it at source with each update to this article.

  • A central, state-run EPR model. The draft moves away from a model of many recovery organisations towards a centralised one: the packaging charge would be collected and redistributed to municipalities and recyclers by the Narodowy Fundusz Ochrony Środowiska i Gospodarki Wodnej (the Polish National Fund for Environmental Protection and Water Management). The choice of a central operator was one of the most widely commented elements of the consultation – we describe it as an open question that further work will settle.
  • A charge per kilogram, with eco-modulation. The packaging charge is to be calculated on the mass of packaging placed on the market, with the rate differentiated by material type and how environmentally friendly it is – packaging that is easy to recycle and reusable is to be rewarded with a lower rate.
  • Regional oversight. Powers to audit how the charge is accounted for and reported are to go to the voivodeship marshals, the heads of Poland’s regional self-government.
  • Administrative penalties. The draft provides for a schedule of administrative fines for breaches of obligations – from gaps in record-keeping to placing packaging that does not meet the requirements on the market. The specific amounts changed between versions of the draft, so we do not quote them until they follow from the act as passed.
  • Reporting in the BDO. EPR reporting is to rest on packaging data reported in the BDO (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami, the Polish database on products, packaging and waste management); the charge will be calculated from that data.
  • A link to the deposit return system. UC100 also amends the rules on the deposit return system (running since 1.10.2025). We do not go into the detail – we flag the dependency, because both sets of rules will have to meet in a single packaging record.

For a company this means one thing: UC100 may change national record-keeping, reporting and charging obligations – but it touches neither the requirements for the packaging itself nor the way its conformity is confirmed. That distinction is often muddled, so we state it outright. Conformity assessment and the declaration of conformity follow directly from the PPWR (Articles 38–39 and Annex VII) and no national act will change them – the technical documentation, the assessment procedure and the declaration itself look the same whatever happens to UC100. The only variable is the settlement and reporting layer towards the national EPR system. That is why, operationally, it is worth keeping the two fronts apart. A caveat on rates. The legal framework for EPR is in the draft, but the specific packaging-charge rates and the pace at which they climb towards full cost are assumptions in the draft, not law in force. We do not present them as a certainty and we do not multiply anything by some “×N”. We will know the real cost of EPR once the act is passed and the implementing instruments are issued.

 

Two different clocks: the PPWR and UC100

The most common muddle is over dates. The PPWR and UC100 run on separate calendars – one of the reasons why “waiting for the act” is misleading. The PPWR clock (EU, certain – dates from the text of the regulation on EUR-Lex):

  • 22.01.2025 – publication of Regulation (EU) 2025/40 in the Official Journal of the EU.
  • 11.02.2025 – entry into force.
  • 12.08.2026 – start of application for most provisions; repeal of Directive 94/62/EC; PFAS thresholds for food-contact packaging (Article 5).
  • 1.01.2030 – the hard thresholds: re-use of transport packaging from 40% (Article 29), minimum recycled content (Article 7), a maximum of 50% empty space (Article 24), recyclability classes conditioning market access (Article 6). By 2030 the Member States are also to cut packaging waste by 5% against 2018 (Article 43) – a target placed on the states rather than directly on companies, but delivering it will press on the whole market.

The UC100 clock (national, shifting – as at 11.08.2026, per the project card on the RCL):

  • 13.08.2025 – the draft enters the Rządowy Proces Legislacyjny (RCL).
  • public consultation (2025) – the draft drew more than 1,500 comments (according to press reports).
  • 20.03.2026 – the post-consultation version, closing the agreement and review stages.
  • 8.07.2026 – a new version of the text, together with the explanatory memorandum and the regulatory impact assessment, prepared for the Committee for European Affairs; in parallel, the stage before the Council of Ministers’ Committee for Digital Affairs opens.
  • 14.07.2026 – publication of the report on the consultation and review, together with the sponsor’s response to the comments.
  • 29.07.2026 – stakeholder positions arrive at the committee stage.
  • 11.08.2026 – the draft is still at the government stage: the stages for the Standing Committee of the Council of Ministers, the Council of Ministers itself and the Sejm all remain empty.
  • 12.08.2026 – the entry-into-force date recorded in the final provision and in the regulatory impact assessment of the July version, with exceptions spread over 2027–2030. We give it as the state of play, not a forecast – at the current stage of work (before the Council of Ministers and before the Sejm), meeting that date is unlikely.

Note the asymmetry: the PPWR clock is predictable and already running (12.08.2026), while the UC100 clock is movable. Compliance planning is best anchored to the certain one.

 

What we do not know today (and what may change)

Honesty with the compliance reader matters more here than a smooth narrative. As at 11 August 2026:

  • We do not know when UC100 will be passed. The Council of Ministers has not adopted it yet; it is not before the Sejm. We deliberately do not forecast a date.
  • The 12.08.2026 date in the draft is unrealistic. It is a date from the draft, not from an act – and the draft has not yet been through the Council of Ministers or the Sejm.
  • The shape of the EPR model is not settled. The choice of a central operator was widely commented on in the consultation; the final solution may differ from the July version.
  • Final text ≠ draft text. All the roles and mechanisms described above come from the draft and may change before the day it is passed.

That is natural for a “living” article. So we update it roughly every 4 weeks and check the position at source each time.

 

What to do now – a plan for compliance and operations

Since the PPWR runs on its own clock and UC100 keeps shifting, a sensible order looks like this:

  1. Treat the PPWR obligations as active from 12.08.2026 – regardless of UC100. The starting point is a packaging inventory and a readiness assessment; for transport packaging, our analysis of Article 29 PPWR helps here.
  2. Keep the two fronts apart. Run the “product” front (packaging, loop, re-use) by the PPWR. Monitor the “national” front (EPR, the charge, penalties, reporting) by UC100.
  3. Track UC100 at source, not in the headlines. A reliable picture comes from the project card in the Rządowy Proces Legislacyjny (RCL), announcements from the Ministry of Climate and Environment and – once the draft gets there – the course of work in the Sejm.
  4. Prepare the record-keeping behind EPR. Whatever the final shape of the act, the direction is fixed: packaging data in the BDO. The sooner the records are complete, the cheaper the adjustment.

  5. Start with a readiness audit. If you want to see in one afternoon where your company stands against the PPWR (and where it is waiting on national decisions), start with the PPWR knowledge hub.

     

Our view: UC100 may be simpler than we fear

A closing comment, not advice. The mainstream describes UC100 mainly through risk: penalties, costs, uncertainty. We look at it differently. Poland is rolling out re-use systems and a broad deposit scheme later than the German-speaking markets, which have worked with Mehrweg systems for over three decades (the German packaging ordinance, VerpackV, dates from 1991). That is not only a burden – it is the late entrant’s advantage: you can draw on ready-made patterns for the return loop, washing, record-keeping and pooling instead of inventing them from scratch. As a manufacturer present on the German market since 1985, we see those patterns every day; we will set out five lessons from the Mehrweg/VerpackG system for Polish companies in a separate article. From a container manufacturer’s perspective, the most important thing is not whether UC100 turns out perfect, but whether a company gets the physical loop ready before the PPWR clock (2026 → 2030) does its work. The national act will add the settlement detail. The infrastructure has to be there either way. How we calculate the economics of returnable packaging. Moving to reusable packaging is not a matter of buying once and forgetting: the fleet wears out and has to be replaced, which is a real, recurring cost rather than a one-off outlay. That is why we treat the comparison between returnable and single-use packaging directionally (break-even: from roughly which year the return loop becomes cheaper), with no hard payback in months, no ROI percentages and no “you save X PLN” slogans. EPR costs, once they arrive, will be an assumption laid over that calculation, not law. Pooling is market context and an option on the customer’s side – bekuplast is a manufacturer of returnable packaging, not a pooling operator. We show the methodology openly in the article on the TCO calculator, and the pallet-pooling scenarios in a separate article.

 

FAQ

What is UC100? UC100 is the number under which the Council of Ministers’ programme of legislative work tracks the draft Polish act on packaging and packaging waste – the instrument implementing the EU’s PPWR Regulation (EU) 2025/40 and rebuilding the EPR system. The draft is led by the Ministry of Climate and Environment.

Do I have to wait for UC100 before applying the PPWR? No. The PPWR is an EU regulation and binds directly – most of its provisions apply from 12 August 2026, regardless of the Polish act. UC100 governs the national layer (EPR, penalties, the competent authority), not whether the PPWR applies at all.

When will UC100 come into force? As at 11 August 2026 the act has not been passed – the draft is at the government stage, in the work of the Council of Ministers’ committees. The July 2026 version points to entry into force on 12 August 2026 with exceptions spread over the following years, but that is a date from the draft, not from law in force, and at the current stage of work it is unlikely. We check the status at source and update this article.

How does UC100 differ from the PPWR? The PPWR (an EU regulation) sets the requirements for the packaging itself and the loop (re-use, recycled content, empty space, PFAS) and works directly. UC100 (a draft national act) settles what the regulation leaves to the states: the authorities, penalties, the packaging charge, the shape of EPR and the link to the deposit return system.

How does UC100 differ from EPR and the deposit return system? EPR (extended producer responsibility) is a mechanism for financing the treatment of packaging waste; the deposit return system (running since 1.10.2025) covers the return of beverage packaging. UC100 is a single act that rebuilds EPR for packaging and amends the rules on the deposit return system.

Where can I check the current status of UC100? In the Rządowy Proces Legislacyjny (the project card on the RCL pages), in announcements from the Ministry of Climate and Environment and – once the draft gets there – in the course of work in the Sejm. We report the current position in the “As at…” section at the top of the article.