Hazardous waste records - what will change in 2025?
As of 1 January, a new regulation of the Minister of Climate and Environment came into force, which indicates the waste exempted from the registration obligation. It shows that the relief for certain hazardous waste has been abolished and now companies must register any such waste, regardless of its weight. How will these changes affect waste management in Poland?
Need help with your waste records?
Why are hazardous waste records so important?
Proper recording of waste allows monitoring its quantity and type, which is crucial for effective environmental management. Unfortunately, illegal dumping of hazardous waste in Poland remains a serious problem, and available data indicate its continuing scale in recent years.

Number of cases disclosed:
- 2019: 76 cases of illegal dumping of hazardous waste.
- 2020: 132 cases.
- 2021: 125 cases.
- By September 2022: 100 cases.
These data come from the 2023 report of the Supreme Audit Office (NIK)The report of tvn24 cited a report on illegal landfills. It was emphasised that there is no complete inventory of such landfills, which makes it difficult to assess the situation accurately.
Hazardous waste records - regulatory changes
Comparing previous regulation of 2019 with its replacement the 2024 Regulation of the Minister for Climate and the Environment, significant changes can be seen. Previously, certain hazardous wastes were exempted from record-keeping if the quantity did not exceed certain limits. The new legislation abolishes these exemptions, meaning that from 1 January 2025, any amount of hazardous waste must be recorded. This change is driven by the need to increase transparency and control over waste management and to prevent illegal dumping.
The following hazardous waste codes have been removed from the list of exempted wastes:
- 13 02 08* - Other engine, gear and lubricating oils
- 15 01 10* - Packaging containing residues of or contaminated by dangerous substances
- 16 01 07* - Oil filters
- 16 06 01* - Lead-acid batteries and accumulators
- 17 05 03* - Soil and ground containing hazardous substances
How to comply with the new regulations?
To avoid problems of erroneous recording, companies should take concrete steps:
- Above all, regularly following legal changes and adapting activities to new requirements.
- Introduction of new waste management processes in line with new regulations.
- Ensuring that those responsible for record-keeping are aware of current legislation and can apply it.
- Regular reporting and recording of waste in the system to avoid sanctions.
- Use with the help of specialists such as Ecology24in order to avoid errors and streamline the record-keeping process.
New regulations increase the obligations of businesses, which can be challenging, especially for smaller companies. Adapting to regulatory changes may require extra effort, but it ensures compliance with the law and minimises the risk of sanctions. It is worthwhile to ensure that waste is properly recorded, as this translates not only into environmental safety, but also into the stability and credibility of the company.