Waste Industry Groups Demand Return to “Fair EPR” Model over UC100 Bill

Poland’s Municipal Industry Chamber and Waste Management Chamber have issued a joint critique of the UC100 packaging waste bill, calling for a transparent model that prioritizes direct cost relief for residents.

Systemic Flaws in the UC100 Proposal

The Municipal Industry Chamber (IBK) and the Polish Waste Management Chamber (PIGO), representing the majority of waste sector operators, have formally challenged the UC100 draft legislation. They argue the bill is systemically flawed, creating a high risk of regulatory chaos, market disputes, and failure to achieve the primary goal of Extended Producer Responsibility (EPR)—lowering waste management costs for households.

Lack of Clarity and Predictability

The draft fails to define essential operational rules, pushing fundamental questions—such as cost calculation methods and fund distribution mechanisms—into secondary regulations or legally ambiguous documents. This opacity creates uncertainty, encourages administrative arbitrariness, and invites potential political and legal conflict.

Failure to Deliver Financial Relief

IBK and PIGO assert that the current proposal does not guarantee real savings for residents. They maintain that funds provided by producers must directly and transparently reduce waste bills, rather than being diverted to other purposes, a mechanism currently absent from the legislation.

Inadequate Consultation Process

The organizations are highly critical of the public consultation process. Despite industry experts submitting comprehensive improvement proposals, key concerns from market practitioners were ignored, and the time allocated for consultation was insufficient given the bill’s significant impact.

Proposal for a “Fair EPR” Model

The chambers propose replacing the UC100 draft with their “Fair EPR” concept. This model relies on transparent financing, clear allocation of responsibility, and ensuring producers cover the actual costs of collecting and managing packaging waste. This approach, which draws on international best practices, has received broad support from local governments and market participants.

Commitment to Future Cooperation

Representatives of both organizations have declared their readiness to continue working with authorities to develop a stable, predictable, and socially acceptable waste management system for Poland based on the “Fair EPR” framework.