Letter to the NFOŚiGW president regarding recycling in Poland

Producers in Poland are raising concerns about the proposed UC100 bill, arguing it fundamentally misinterprets the concept of extended producer responsibility (ROP) and could lead to financial burdens for citizens. They contend that the bill introduces a fiscal, quasi-tax mechanism rather than a market-driven system as intended by EU directives.

In a letter addressed to the president of the National Fund for Environmental Protection and Water Management (NFOŚiGW), producers dispute claims made in a recent interview. They assert that current waste management costs are determined by market rates between waste management firms and recovery organizations, not a tax system. They also question the extent to which producer fees influence municipal waste management charges.

A significant concern is that the UC100 bill lacks a mechanism to reduce municipal "garbage fees" based on producer payments to NFOŚ. This, producers warn, could result in citizens, including the "elderly lady" mentioned by a fund representative, paying twice: once through unchanged municipal fees and again through higher prices for packaged goods like food and cleaning supplies.

Producers have long expressed a desire for a comprehensive ROP system in Poland, aligned with the EU's "net cost" principle. However, they view the UC100 bill as a departure from this, establishing a rate determined by a ministerial regulation outside transparent market rules and oversight. They advocate for an ROP model that extends beyond mere financial collection to actively involve packaging manufacturers, users, waste management, and recycling industries, fostering a holistic approach to the packaging-waste chain.