30 September 2025
Product regulation and compliance update series
September 2025Draft Act on the Transboundary Movement of Waste
On 9 September 2025, the principles of the draft Act on the Transboundary Movement of Waste were published on the website of the Chancellery of the Prime Minister.
Context
The draft aims to implement Regulation (EU) 2024/1157 of the European Parliament and of the Council of 11 April 2024 which replaces the previously applicable Regulation (EC) No. 1013/2006. Although the new provisions formally repeal the previous regulation, during the transition period – until 21 May 2026 – the existing rules on notification procedures and obtaining permits for the import, export and transit of waste through Polish territory as well as the notification procedures will continue to apply.
Key assumptions
In the context of the upcoming legislative changes, the draft of the new act aims to adapt the national system to the requirements of Regulation (EU) 2024/1157 and introduce a more integrated, digital and controlled model for managing cross-border waste shipments. The most important assumptions of the draft regulations are presented below:
- replacing the current document exchange system with the DIWASS (Digital Waste Shipment System) platform.
- introducing prior permits for a broader range of waste types.
- allowing for the revocation of permits for waste collection or treatment in case of regulatory violations.
- increasing the lower limit of penalties for illegal waste shipments.
- equipping the Chief Inspectorate for Environmental Protection (in Polish: Główny Inspektorat Ochrony Środowiska, GIOŚ) with new tools – including the ability to reject incomplete notifications, request the early return of waste at an early stage, and pursue reimbursement claims against violators.
- enabling GIOŚ and authorities authorized to control waste shipments to request any entity involved in the international shipment of goods to prove that the materials being transported are not waste or that the shipment of waste is not illegal.
Next steps
The draft act is currently undergoing legislative work at the Chancellery of the Prime Minister. It is a “C” type draft i.e., one that implements European Union law, in this case Regulation (EU) 2024/1157, which entered into force on 20 May 2024.
Draft Act on the Production, Labelling and Control of Food Prepared with Organic Ingredients in Collective Catering, and on the Amendment of the Act on Organic Farming and Organic Production
On 9 September 2025, the assumptions for the draft Act on the Production, Labelling and Control of Food Prepared with Organic Ingredients in Collective Catering and on the Amendment of the Act on Organic Farming and Organic Production were published in the list of legislative and programmatic work of the Council of Ministers.
Context
The draft aims to address the lack of official rules for using and labelling organic food in collective catering. Currently, consumers cannot easily identify which establishments use organic food, as there is no official quality label, no central register of such establishments, and no clear regulations on the use of terms like “eco,” “bio,” or “organic”.
Key solutions
The draft introduces several measures to organize the rules for producing, labelling, and controlling organic food in mass catering, including:
- introducing an organic label and rules for its use – a three-tier labeling system (bronze, silver, gold) based on the percentage of organic food in the establishment’s purchases.
- creating a register of mass catering establishments.
- regulating the use of terms related to organic production.
- establishing a procedure for registration – establishments will need to submit calculations of their organic food share, commercial documents, and declarations, which will be reviewed by the Provincial Inspector of Agricultural and Food Quality (in Polish: Wojewódzki Inspektor Jakości Handlowej Artykułów Rolno-Spożywczych, WIJHARS).
- ongoing supervision by WIJHARS – inspectors will carry out official checks on the use of the organic label and related markings.
- introducing penalties for non-compliance – to prevent misuse and ensure fair competition.
Next steps
The draft is scheduled to be adopted by the Council of Ministers in the second quarter of 2026.
Draft law on Construction Products
On 23 September 2025 the assumptions for the draft law on construction products were published in the list of legislative and programmatic work of the Council of Ministers.
Context
The draft act responds to the need to align Polish law with new EU regulations on construction products. Its primary goal is to implement two EU legal acts: Regulation (EU) 2024/3110 which establishes harmonized rules for the marketing of construction products, and Regulation (EU) 2019/1020 on market surveillance and product compliance. This new act is intended to replace the current Act of 16 April 2004 on Construction Products.
Regulation 2024/3110 introduces new definitions, such as replacing the term “product group” with “product family” and modifying the definition of a construction product. These changes require updates to national legislation. Moreover, Member States must establish penalties for violations and notify the European Commission of the adopted measures by 8December 2026.
The draft also incorporates provisions from Regulation 2019/1020, focusing on market surveillance and compliance of construction products sold online – addressing the growing importance of e-commerce in the construction sector.
Key solutions
The draft act proposes measures to streamline the rules for placing construction products on the market, conformity assessment, and market surveillance, in line with EU law. Key elements include:
- alignment of definitions with EU terminology, including the term “product family,” and specifying that harmonized construction products placed on the national market must comply with Regulation 2024/3110.
- introduction of market surveillance rules for construction products sold remotely (e.g., online).
- unification of market surveillance procedures for both harmonized and non-harmonized construction products under Regulation 2019/1020.
- removal of the National Register of Challenged Construction Products due to the low number of entries.
- inclusion of penalty provisions to enforce Regulation 2024/3110 and adjustment of financial penalties, increasing them by 50% to account for inflation since the Act of 16 April 2004 on Construction Products came into force.
Next steps
The draft is scheduled to be adopted by the Council of Ministers in the third quarter of 2026.
Parliament adopts new EU rules to reduce textile and food waste
On 9 September 2025, the European Parliament adopted new rules aimed at reducing textile and food waste in the European Union.
Context
In July 2023, the European Commission proposed changes to waste legislation, focusing on food and textile waste. Every year, the EU generates nearly 60 million tons of food waste (an average of 132 kg per person) and 12.6 million tons of textile waste (12 kg per person).
Key solutions
The updated legislation sets binding targets to reduce food waste and prevent textile waste. Key measures include:
- Member States must reduce food waste by 10% at the processing and production stage, and by 30% per person in retail, catering, and households sectors (compared to the 2021–2023 average) by 31 December 2030.
- textile producers will be required to cover the costs of collecting, sorting, and recycling their products under Extended Producer Responsibility (EPR) Each Member State must implement these systems within 30 months of the directive’s entry into force.
Next steps
The law will now be signed by both co-legislators and then published in the EU Official Journal. Member States will have 20 months from the entry into force of the law to transpose the provisions into national law.
September Reports from the Trade Inspection Authority
Below is a summary of two reports from the Trade Inspection Authority (in Polish: Inspekcja Handlowa, IH), published last month on the website of the Office of Competition and Consumer Protection (in Polish: Urząd Ochrony Konkurencji i Konsumentów, UOKiK).
Bicycles and Scooters
On 5 September 2025, UOKiK published the results of an inspection carried out by the Trade Inspection Authority. The inspection focused on the safety of children's vehicles, including tricycles, balance bikes, and scooters.
Key findings:
- 15 out of 30 models had issues such as missing safety warnings or lack of user instructions;
- 14 models raised concerns about potential injury risks or potential health effects. Problems included:
- improper spacing between wheels and other parts,
- front wheels that were too small,
- detachable parts with unsafe shapes or sizes.
In cases where design flaws or missing documentation were found, administrative proceedings were launched, which may result in penalties.
For products with only formal issues (e.g., missing labels or documents), businesses agreed to take corrective actions under IH supervision.
Hair Dryers
On 19 September 2025, UOKiK published the results of another inspection by the Trade Inspection Authority, this time focusing on hair styling devices available on the Polish market.
Key findings:
- 4 out of 30 models had formal issues, such as:
- incorrectly prepared declarations of conformity,
- missing user manuals,
- incomplete product identification (e.g., missing model number).
- All devices passed safety tests. None of the hair dryers posed a risk of overheating, electric shock, or moisture damage. Their construction was found to be safe.
Electric Irons
On 26 September 2025 on the website of the Office of Competition and Consumer Protection published the results of an inspection conducted by the Trade Inspection Authority. The aim was to verify the labeling of electric irons and assess their construction in terms of heat generation and resistance to high temperatures and heat.
Key findings:
- Formal irregularities were found in 1 out of 15 models of electric irons – the issue was an improperly prepared declaration of conformity, which meant there was no proof that the product met the applicable requirements.
- Laboratory tests of all iron models ended with positive results. The devices were tested for user safety under conditions of elevated temperature. The scope of the tests included heat generation and resistance to high temperature and heat.