Wood waste collection and compliance with the BDO – what are the consequences of errors, and how does Danpol assist with documentation?
Wood waste generated when unpacking shipping crates, pallets and platforms is an issue that keeps many recipients of export and import cargoes awake at night. Since the electronic BDO system (Database on Products, Packaging and Waste Management) came into force, every entity generating waste – including wood waste from transport packaging – must keep detailed records and submit reports. Errors in this regard can result in severe financial penalties. At Danpol, we have been supplying wooden packaging to industry for over 30 years and are fully aware of the challenges our customers face once the cargo has been unpacked. In this article, we explain how to correctly classify and record wood waste, and how we assist our customers in preparing the necessary documentation.
What is the BDO system and why does it apply to waste from wooden packaging?
BDO – the database on products, packaging and waste management – is an electronic system operated by the provincial marshals, in which entities that generate, transport and process waste are registered. The system has been in operation since 1 January 2020 and has replaced paper waste transfer notes.
BDO is of direct relevance to companies that receive goods in wooden packaging. Whether it is a transport crate, pallet, platform or rack – once they have fulfilled their transport function, they become waste that must be correctly classified, recorded and handed over to an authorised recipient. This applies to both single-use wooden packaging and packaging that has been damaged and is unsuitable for reuse.
Classification of wood waste from transport packaging
Correct waste classification is the first step towards compliance with the BDO. We classify wood waste from transport packaging in accordance with the waste catalogue (Regulation of the Minister for Climate of 2 January 2020). The most commonly used codes are:
Code 15 01 03 – wooden packaging
This is the basic code for waste from wooden packaging – crates, pallets, platforms, racks and cradles – which is not contaminated with hazardous substances. Most wood waste generated in industrial plants after the unpacking of transport loads should be classified under this code. This applies to both solid wood and components made of plywood or OSB used in packaging.
Code 15 01 10* – packaging containing residues of hazardous substances
This code applies to wooden packaging that has come into contact with hazardous substances – such as crates that have held chemicals, industrial oils or plant protection products. Packaging marked with an asterisk (*) is classified as hazardous waste, which entails additional record-keeping obligations and a higher disposal cost.
Code 19 12 07 – processed wood
If wood waste undergoes preliminary processing (e.g. shredding, chipping) before being sent for final recovery or disposal, it may be reclassified under this code. This mainly applies to companies that process wood waste themselves on their own premises.
Correct code assignment is crucial – an error in classification may result in an administrative penalty and the need to correct the entire record for the relevant period.
Obligations of wood waste producers under the BDO system
Any company that generates wood waste from transport packaging (i.e. virtually any recipient of goods in crates, on pallets or on platforms) is required to:
Registration in the BDO system – every waste producer must be registered in the database. Registration is carried out electronically via the BDO portal. The BDO registration number must be included on documents relating to the activities covered by the registration.
Keeping waste records – this includes waste record sheets (KEO) and waste transfer sheets (KPO). Since 2020, records have been kept exclusively electronically in the BDO system. Every transfer of wood waste to a recipient must be documented by a KPO sheet issued via the system.
Submission of annual reports – by 15 March each year, the waste producer must submit a report covering the previous year. The report must include the types and quantities of waste generated, the methods of waste management, and details of the recipients.
Handing over waste only to authorised entities – wood waste may only be handed over to a company holding the appropriate licence for waste collection or treatment. Handing over waste to an entity without a licence is unlawful and entails liability on the part of the producer.
What are the consequences of errors in the BDO records?
The legislator has provided for severe penalties for breaches relating to waste management. Penalties under the BDO system include:
Failure to register with the BDO – a fine of between PLN 5,000 and PLN 1,000,000. This applies to entities that generate waste but have not fulfilled their obligation to register with the database.
Failure to keep records or keeping records that do not reflect the actual situation is punishable by imprisonment or a fine. In the event of significant discrepancies between the records and the actual situation, the Environmental Protection Inspectorate may impose administrative penalties of up to PLN 1,000,000.
Failure to submit the annual report on time – a fine of up to PLN 5,000 for each delay. The fines increase in the event of repeated breaches.
Transfer of waste to an unauthorised entity – criminal and administrative liability of the waste producer. The waste producer remains responsible for the waste until it has been properly managed by an authorised entity.
Transporting waste without a BDO entry – a fine of between PLN 2,000 and PLN 10,000. This applies to transport operators, but liability may also extend to the waste producer who commissioned the transport from an unregistered entity.
It is worth noting that inspections by the Environmental Protection Inspectorate are becoming increasingly frequent and thorough. The BDO system allows inspectors to view records remotely – which means that discrepancies are detected more quickly than ever before.
Waste from wood treated in accordance with ISPM 15 – does it require special handling?
A question we are asked very often: does waste from ISPM 15-certified wooden packaging require separate classification or special disposal procedures? The answer is simple – no. Wood that has undergone heat treatment (HT) in accordance with the ISPM 15 standard is not classified as hazardous waste. Heat treatment is a physical process that does not introduce chemicals into the wood – unlike the historically used methyl bromide (MB) fumigation, which is now banned in most countries.
Waste from crates, pallets and platforms made of ISPM 15-certified wood is typically classified under code 15 01 03 – wooden packaging. It can be sent for recycling (production of chipboard, energy pellets) or energy recovery at authorised facilities.
You can find out more about ISPM 15 certification and the requirements for export packaging in our article on IPPC-certified wooden pallets.
How does Danpol assist clients with BDO documentation?
As a manufacturer of wooden packaging, we are fully aware that our customers face the challenge of keeping proper records of waste once they have unpacked their shipment. That is why we offer guidance to help them prepare the necessary documentation. Let me emphasise this: we assist with completing the documents by providing the necessary technical data. We do not complete the documentation on behalf of our customers, as the responsibility for record-keeping lies with the waste producer.
How can we minimise the amount of wood waste?
The best waste management strategy starts with minimising waste generation. In the context of transport packaging, this can be achieved in several ways:
Optimisation of packaging design – a bespoke crate, designed for a specific load, uses less material than a universal crate with an excessive safety margin. At Danpol, we design each piece of packaging individually, tailoring the cross-sections of load-bearing components to the actual loads – without wasting material.
Returnable and reusable packaging – for recurring deliveries of the same components, it is worth considering packaging designed for reuse. Crates and pallets with reinforced fittings and replaceable wear parts can be used for a dozen or so transport cycles before they become waste.
Recovery and reuse of components – some of our customers recover pallets and platforms after unpacking and reuse them for internal transport. This is entirely legal, provided the packaging meets the safety requirements for its new use.
You can find out more about the different types of packaging and their uses on the pages for custom-made transport crates and wooden pallets.
Practical tips – how to improve the recording of packaging waste
1. Sort your waste as soon as you start unpacking – separate wood from plastic film, metal and plastics. This will make it easier to keep track of your waste and reduce collection costs, as homogeneous waste is cheaper to process.
2. Weigh your waste before handing it over – the BDO system requires you to enter the weight of the waste. Estimating ‘by eye’ leads to discrepancies between your records and the actual situation – and this could result in a fine during an inspection.
3. Issue the waste transfer note in the BDO system before the waste is handed over – the waste transfer note must be issued in the system before the waste is actually handed over to the recipient. Issuing notes with a backdated date is against the regulations.
4. Check the waste recipient’s authorisation – before the first transfer, check the BDO register to ensure that the recipient holds a valid permit for the collection or treatment of waste with the relevant codes.
5. Keep the packaging specifications provided by the supplier – the packaging material specification from the manufacturer (such as Danpol) is a valuable source of data for your records. Keep these documents together with your BDO documentation.
Frequently Asked Questions
Does a small business also have to keep records of wood waste in the BDO system?
In principle, yes – the record-keeping obligation applies to every waste producer. There are certain exemptions for small quantities of waste (up to 100 kg of hazardous waste or up to 5 tonnes of non-hazardous waste per year), but these relate to keeping simplified records, not to exemption from registration in the BDO. We recommend consulting an environmental advisor regarding specific exemptions.
Does Danpol collect wood waste from customers?
No – Danpol is a manufacturer of wooden packaging, not a waste collection company. However, we do assist customers with preparing documentation – we provide material specifications and technical data for the packaging, which facilitate the correct classification and recording of waste. We can also recommend reliable wood waste collectors in our region.
Can ISPM 15 heat-treated pallets be burned in a factory boiler?
Not without the appropriate permits. Burning wood waste (even clean wood) in boilers or furnaces requires a permit for the thermal treatment of waste or its co-incineration. Burning without a permit is an offence punishable by a fine.
How long should BDO records be kept? Waste
records (KEO and KPO) must be kept for 5 years from the end of the calendar year in which they were drawn up. Annual reports are also subject to a 5-year retention period.
Is plywood waste classified in the same way as solid wood waste?
Yes – waste from plywood used in transport packaging is classified under the same code 15 01 03 (wood packaging). Plywood is a wood-based material and, in the context of packaging waste classification, we treat it in the same way as solid wood. The same applies to OSB boards.
Does Danpol complete BDO documentation on behalf of its clients?
No – the responsibility for recording and reporting to BDO lies with the waste producer, i.e. our client. However, we assist with the preparation of documentation by providing all the necessary technical data: material specifications for packaging, weights of individual components, information on wood processing, and safety data sheets for protective films. This data forms the basis for completing the records in the BDO system independently.
Summary
Proper management of wood waste from transport packaging is a legal obligation for every waste producer. The BDO system requires accurate record-keeping, correct classification and timely reporting – and the penalties for non-compliance are severe. The key to efficient record-keeping lies in reliable data from the packaging manufacturer, and that is precisely the data we provide to our clients.
If you need material specifications for packaging for record-keeping purposes, or are looking for a supplier who understands BDO requirements, please contact us. We will provide all the information you need to keep your waste records up to date.
