# Law: register of acts (IGMNiR)

EU and Polish acts relevant to non-ferrous metals and recycling: obligations, dates, authorities and official sources.

Register as of: 22.10.2026. The official text of the act prevails. On the website: https://igmnir.org/en/law/

## Waste and end-of-waste status

- [Waste Framework Directive (WFD)](https://igmnir.org/dane/prawo/en/eu-wfd/) (EU, Amendments pending): Framework for waste management in the EU: definition of waste, waste hierarchy, conditions for end-of-waste status, permits for treatment and record-keeping. Basis for the EoW criteria for Fe, Al and Cu scrap.
- [Amendment to the Waste Framework Directive (2025)](https://igmnir.org/dane/prawo/en/eu-wfd-2025-1892/) (EU, In force): Amendment to the WFD (procedure 2023/0234/COD) concerning textiles and food waste; no new obligations directly for the metal scrap sector, relevant as an amendment to the base act of the national Act on waste.
- [European List of Waste (LoW)](https://igmnir.org/dane/prawo/en/eu-low/) (EU, Amendments pending): List of waste codes (chapters 10 – wastes from thermal processes, 12, 16, 17 04, 19 10, 19 12) binding for the classification, recording and shipment of waste. From 9.12.2026 new codes for battery waste (Decision 2025/934).
- [End-of-waste criteria for iron, steel and aluminium scrap](https://igmnir.org/dane/prawo/en/eu-eow-333-2011/) (EU, In force): Criteria under which iron and steel scrap and aluminium (including aluminium alloy) scrap cease to be waste upon transfer from the producer to another holder. The act has not been amended.
- [End-of-waste criteria for copper scrap](https://igmnir.org/dane/prawo/en/eu-eow-715-2013/) (EU, In force): End-of-waste criteria for copper scrap (including copper alloys). The only EU EoW criteria for metals – alongside Regulation 333/2011; there are no EU criteria for Zn, Pb, Sn, Ni. The act has not been amended.
- [Circular Economy Act (CEA) – announced](https://igmnir.org/dane/prawo/en/eu-cea/) (EU, Proposal): Announced Commission initiative (legal basis: Art. 114 TFEU) concerning a single market for secondary raw materials; the proposal has not yet been presented.
- [Act on waste (BDO, permits, EoW)](https://igmnir.org/dane/prawo/en/pl-ustawa-odpady/) (PL, Amendments pending): Principal national act: permits for collection and treatment, end-of-waste status, storage with video monitoring, security for claims, registration and record-keeping in BDO, and administrative penalties.
- [Regulation on the waste catalogue](https://igmnir.org/dane/prawo/en/pl-katalog-odpadow/) (PL, Amendments pending): National waste catalogue (counterpart of Decision 2000/532/EC), used for the classification, recording in BDO, permits, SENT and shipment of waste. The act has not been amended; a draft new regulation is in progress.
- [Detailed requirements for waste storage](https://igmnir.org/dane/prawo/en/pl-magazynowanie-odpadow/) (PL, In force): Technical requirements for waste storage sites, including for metal scrap: separation, marking with codes, bays, ground surface, safeguards and hazardous waste zone. Issued under Art. 25(7) and (8) of the Act on waste.

## Transboundary shipments of waste

- [Waste Shipment Regulation (WSR)](https://igmnir.org/dane/prawo/en/eu-wsr/) (EU, Amendments pending): Procedures for shipments of waste within the EU and exports outside the EU, mandatory electronic exchange (DIWASS), restrictions on exports to countries to which the OECD Decision does not apply, and audits of receiving facilities. The Basel Convention and the OECD Decision form the background of the regime.
- [DIWASS – electronic data exchange on shipments](https://igmnir.org/dane/prawo/en/eu-wsr-2025-1290/) (EU, In force): Rules on access to the DIWASS central system (GUI, API, eFTI), registration of operators and authentication of documents in shipments of waste, including the Annex VII document for ‘green list’ scrap.
- [Export of ‘green list’ waste to non-OECD countries](https://igmnir.org/dane/prawo/en/eu-1418-2007/) (EU, In force): Table of the positions of non-OECD countries on imports of ‘green list’ waste (inter alia metal scrap): prohibition, procedure of notification and consent, or no control. Applies transitionally until replaced by the list under Art. 41 WSR.
- [List of non-OECD countries permitted to import waste (draft)](https://igmnir.org/dane/prawo/en/eu-wsr-wykaz-art41/) (EU, Proposal): Delegated act specifying the non-OECD countries and types of waste (including metal scrap) whose export from the EU will remain permitted after 21.05.2027. Outside the list, exports of non-hazardous waste outside the OECD will be prohibited.
- [Delegated Regulation C(2026) 7390 – green list (BEU06–BEU12, EU49)](https://igmnir.org/dane/prawo/en/eu-wsr-zielony-wykaz/) (EU, Adopted): Seven new green-list entries for shipments within the Union, including aluminium and steel waste from building, construction and demolition (BEU07), treated e-waste (BEU09), permanent magnets (BEU10) and metals from end-of-life vehicles (BEU11). Deletion of GC010 and GC020, new entry EU49 in Annex IV.
- [Act on international shipments of waste](https://igmnir.org/dane/prawo/en/pl-ustawa-mpo/) (PL, Amendments pending): National implementing provisions for the EU waste shipment regime: the Chief Inspectorate of Environmental Protection (GIOŚ) as competent authority, permits, financial guarantee, illegal shipment and penalties. The text still refers to Regulation 1013/2006 – it has not been aligned with Regulation (EU) 2024/1157.
- [SENT Act (as regards waste)](https://igmnir.org/dane/prawo/en/pl-sent-ustawa/) (PL, In force): Obligation to notify transport in the SENT register for waste covered by the waste shipment rules and certain domestic waste; from 28.10.2026 exclusion of 19 metal waste codes.
- [Waste covered by SENT – regulation on goods](https://igmnir.org/dane/prawo/en/pl-sent-rozp-towary/) (PL, In force): Specifies the waste covered by SENT: waste subject to the waste shipment rules irrespective of quantity and selected waste in domestic transport. From 28.10.2026, 19 metal waste codes excluded, inter alia 17 04 01–17 04 07, 19 12 03.
- [Draft Act on transboundary shipments of waste](https://igmnir.org/dane/prawo/en/pl-projekt-utpo/) (PL, Proposal): Draft by the Minister of Climate and Environment replacing the 2007 Act and aligning national law with Regulation (EU) 2024/1157: DIWASS instead of electronic delivery, higher minimum penalties, new powers of the Chief Inspectorate of Environmental Protection (GIOŚ).

## Industrial emissions and permits

- [Industrial Emissions Directive (IED 2.0)](https://igmnir.org/dane/prawo/en/eu-ied/) (EU, Amendments pending): Integrated permit based on BAT conclusions for copper, zinc, lead, aluminium and precious metal smelters and for remelting of NF scrap (Annex I, point 2.5); since the 2024 amendment also extraction and processing of metal ores (point 3.6) and battery manufacturing.
- [BAT conclusions – non-ferrous metals industries (NFM)](https://igmnir.org/dane/prawo/en/eu-bat-nfm/) (EU, In force): Binding emission levels (BAT-AEL) and techniques for the production of Cu, Al (including alumina and anodes), Pb/Sn, Zn/Cd, precious metals, ferro-alloys, Ni/Co and carbon and graphite, from primary and secondary raw materials.
- [Seveso III Directive (major accidents)](https://igmnir.org/dane/prawo/en/eu-seveso/) (EU, In force): Establishments storing or using dangerous substances above the thresholds in Annex I (hazard categories and named substances) are subject to the obligations of lower-tier or upper-tier establishments.
- [Environmental Liability Directive (ELD)](https://igmnir.org/dane/prawo/en/eu-eld/) (EU, In force): Strict liability for damage to water, land, species and habitats for activities listed in Annex III (inter alia IED installations, waste management operations, shipments of waste).
- [EIA Directive (environmental impact assessment of projects)](https://igmnir.org/dane/prawo/en/eu-eia/) (EU, Amendments pending): Installations for the production of NF metals from ore, concentrates or secondary raw materials (Annex I, point 4(b)) and open-cast mining > 25 ha (Annex I, point 19) require an EIA; smelting of NF metals – Annex II, point 4(d) (screening).
- [Industrial Emissions Portal Regulation (IEPR, replacing E-PRTR)](https://igmnir.org/dane/prawo/en/eu-iepr/) (EU, Applies from 01.01.2028): Annual reporting of pollutant releases, transfers of waste and waste water and – a new element – consumption of water, energy and raw materials by installations listed in Annex I; data published on the EU portal.
- [Environmental Protection Law – integrated permits, fees, penalties](https://igmnir.org/dane/prawo/en/pl-pos/) (PL, Amendments pending): Principal act for NF metal installations: integrated permit (transposition of the IED), emission measurements, fees for use of the environment, administrative fines, National PRTR Register.
- [POŚ – prevention of major industrial accidents (Seveso)](https://igmnir.org/dane/prawo/en/pl-pos-awarie/) (PL, Amendments pending): Lower-tier or upper-tier establishment (ZZR/ZDR) depending on the quantity of dangerous substances – notification, major-accident prevention programme, safety report, emergency plans.
- [EIA Act – decision on environmental conditions](https://igmnir.org/dane/prawo/en/pl-oos/) (PL, Amendments pending): A new or extended smelter, mine or waste treatment plant requires an environmental decision before the building permit or the licence for the extraction of minerals.
- [Act on the prevention and remedying of environmental damage](https://igmnir.org/dane/prawo/en/pl-szkody/) (PL, In force): Transposition of the ELD: operation of installations holding an integrated or emission permit, waste management and waste transport constitute activities posing a risk of damage (liability without fault).
- [Act on the emissions management system (KOBiZE National Database)](https://igmnir.org/dane/prawo/en/pl-kobize/) (PL, In force): Every entity whose activity causes emissions reports its annual emissions to the National Database kept by KOBiZE; the report is the basis for the fee for use of the environment. The Act also covers national CBAM procedures.
- [Act on the Inspection for Environmental Protection (inspections)](https://igmnir.org/dane/prawo/en/pl-ios/) (PL, Amendments pending): The Regional Inspectorate of Environmental Protection (WIOŚ) monitors compliance with legislation and decisions (permits, emission measurements); IED installations are inspected every 1–3 years, Seveso establishments every year or every 3 years.
- [Water Law – water-law permits for industrial waste water](https://igmnir.org/dane/prawo/en/pl-prawo-wodne/) (PL, Amendments pending): The discharge of industrial waste water into waters or into the ground and the introduction of waste water containing particularly harmful substances into third-party sewerage systems require a water-law permit and fees for water services.
- [Draft POŚ amendment implementing IED 2.0 (UC99)](https://igmnir.org/dane/prawo/en/pl-projekt-ied2/) (PL, Proposal): Transposition of Directive 2024/1785: EMS, transformation plan, BAT-AEPL, derogations in a crisis, compensation, new installations (extraction of Cu, Pb, Zn, Ni and other ores, batteries ≥ 15,000 t/year).

## Climate, CO₂ and energy

- [EU ETS Directive (2003/87/EC)](https://igmnir.org/dane/prawo/en/eu-ets/) (EU, Amendments pending): Covers the production of primary aluminium and alumina (CO2, PFC), secondary aluminium and the production or processing of non-ferrous metals where combustion units exceed 20 MW, as well as metal ore roasting and sintering. Lays down free allocation, surrender of allowances and penalties.
- [Free allocation (Delegated Regulation 2019/331) and benchmarks 2026–2030](https://igmnir.org/dane/prawo/en/eu-ets-far/) (EU, Amendments pending): Lays down applications for allocation, division into sub-installations and benchmarks (inter alia aluminium, pre-bake anode, heat, fuel). For 2026–2030: aluminium 1.423 allowances/t, anode 0.290 allowances/t, heat 31.2 allowances/TJ, fuel 28.1 allowances/TJ.
- [Monitoring and reporting of emissions (Implementing Regulation 2018/2066, MRR)](https://igmnir.org/dane/prawo/en/eu-ets-mrr/) (EU, In force): Detailed emission monitoring methodologies; for non-ferrous metals – Annex IV, section 6; for primary aluminium – sections 7 (CO2, mass balance) and 8 (PFC from anode effects).
- [Commission Guidelines – compensation for indirect emission costs (ETS post-2021)](https://igmnir.org/dane/prawo/en/eu-ets-pomoc-kp/) (EU, In force): Conditions for State aid for CO2 costs passed on in electricity prices. Table 1 (80%): NACE 24.42 aluminium, 24.43 Pb/Zn/Sn, 24.44 copper, 24.45 other non-ferrous metals; Table 2 (75%): inter alia 07.29 mining of non-ferrous metal ores, 24.31, 24.34 wire.
- [CBAM (Regulation 2023/956 as amended by Regulation 2025/2083)](https://igmnir.org/dane/prawo/en/eu-cbam/) (EU, Amendments pending): Imports of aluminium (CN 7601, 7603–7614, 7616; excluding scrap 7602) require the status of authorised CBAM declarant and settlement of embedded emissions with certificates. Copper, zinc and lead – outside the scope.
- [Energy Efficiency Directive (2023/1791, EED)](https://igmnir.org/dane/prawo/en/eu-eed/) (EU, In force): The criterion for the obligations of undertakings becomes energy consumption, not size: > 85 TJ/year – certified energy management system, > 10 TJ/year – energy audit every 4 years and action plan.
- [EU ETS review – proposal COM(2026) 616](https://igmnir.org/dane/prawo/en/eu-ets-przeglad/) (EU, Proposal): The proposal shapes the ETS after 2030: linear reduction factor, conditional free allocation, slower phase-out of allocation for CBAM sectors (including aluminium) and continuation of indirect cost compensation.
- [Industrial Accelerator Act (IAA) – proposal](https://igmnir.org/dane/prawo/en/eu-iaa/) (EU, Proposal): The proposal creates lead markets for low-carbon and EU-origin products; aluminium is the only non-ferrous metal listed in the requirements of Annex II.
- [Act on the emission allowance trading system](https://igmnir.org/dane/prawo/en/pl-ets/) (PL, In force): Implements the EU ETS in Poland: emission permits, monitoring plans, reports, surrender of allowances and administrative fines for non-ferrous metal installations (Annex 1, items 7–9).
- [CBAM implementing provisions (Act of 21.11.2025)](https://igmnir.org/dane/prawo/en/pl-cbam/) (PL, In force): Adds Chapters 9a–9b to the Act on the emissions management system: access to the CBAM registry via PUESC, procedure for granting authorised CBAM declarant status and penalties for transitional-period reports.
- [Act on the compensation scheme for energy-intensive sectors](https://igmnir.org/dane/prawo/en/pl-rekompensaty/) (PL, Amendments pending): Compensation for CO2 costs in electricity prices for, inter alia, PKD (Polish Classification of Activities) 24.42 aluminium, 24.43 Pb/Zn/Sn, 24.44 copper, 24.45 other non-ferrous metals; the Act applies an aid intensity of 0.75 and an emission factor of 0.81 tCO2/MWh.
- [Act on energy efficiency – energy audit of undertakings](https://igmnir.org/dane/prawo/en/pl-efektywnosc/) (PL, Amendments pending): An energy audit of the undertaking every 4 years is required for undertakings other than SMEs. Directive 2023/1791 (thresholds of 10 TJ and 85 TJ) has not yet been transposed – draft UC77.
- [Excise duty – exemption for energy in metallurgical processes](https://igmnir.org/dane/prawo/en/pl-akcyza-energia/) (PL, In force): Exempts from excise duty electricity used for chemical reduction and in electrolytic, metallurgical and mineralogical processes, as well as coal and gas products used in those processes (rate on electricity PLN 5.00/MWh).

## Chemicals and worker health

- [REACH – registration, safety data sheets, restrictions, authorisations](https://igmnir.org/dane/prawo/en/eu-reach/) (EU, Amendments pending): A smelter or processor manufacturing or importing metals, alloys and compounds ≥1 t/year registers them with ECHA; the supplier provides safety data sheets, and the Annex XVII restrictions concern, inter alia, lead, cadmium, nickel and arsenic.
- [CLP – classification, labelling and packaging (lead Repr. 1A)](https://igmnir.org/dane/prawo/en/eu-clp/) (EU, Amendments pending): Determines the classification of massive metals and powders and of concentrates; massive lead (≥1 mm) has a harmonised classification of Repr. 1A, Lact., Aquatic Chronic 1, which carries over into labelling, safety data sheets and occupational health and safety rules.
- [CLP amendment 2024/2865 – labels, new classification rules](https://igmnir.org/dane/prawo/en/eu-clp-2024-2865/) (EU, Amendments pending): Amends the classification rules (inter alia multi-constituent substances), label format requirements, digital labelling, advertising and distance sales; the dates of application were postponed by Regulation (EU) 2025/2439.
- [POPs Regulation – persistent organic pollutants](https://igmnir.org/dane/prawo/en/eu-pops/) (EU, In force): Concerns the recycling of cable scrap, e-waste and shredder residues (inter alia PBDE, PCDD/F): waste containing POPs above the Annex IV thresholds must be destroyed or irreversibly transformed.
- [CMRD – carcinogens, mutagens and reprotoxic substances](https://igmnir.org/dane/prawo/en/eu-cmrd/) (EU, Amendments pending): Principal act protecting workers exposed to arsenic, cadmium, nickel compounds, Cr(VI), beryllium and lead; binding OELs (Annex III), BLV for lead (Annex IIIa), registers and health surveillance.
- [Directive 2024/869 – lead (OEL, BLV) and diisocyanates](https://igmnir.org/dane/prawo/en/eu-cmrd-2024-869/) (EU, In force): Lowers the lead OEL from 0.15 to 0.03 mg/m³ (non-threshold reprotoxic substance) and the binding BLV from 70 to 30, and from 2029 to 15 µg/100 ml; concerns lead smelting and refining, battery recycling, Cu and Pb alloy foundries.
- [Directive 2022/431 – reprotoxic substances, nickel compounds, lead into the CMRD](https://igmnir.org/dane/prawo/en/eu-cmrd-2022-431/) (EU, In force): Extends the CMRD to reprotoxic substances (inter alia lead), introduces OELs for nickel compounds, acrylonitrile and benzene and transfers the values for lead from Directive 98/24/EC to Annexes III and IIIa of the CMRD.
- [Directive 98/24/EC – chemical agents at work](https://igmnir.org/dane/prawo/en/eu-cad/) (EU, In force): General framework for chemical risk assessment at every establishment; since 2024 the values for lead have been transferred to the CMRD, and binding values for diisocyanates remain in Annex I.
- [CMRD 6 – cobalt, PAHs, isoprene, 1,4-dioxane, welding fumes](https://igmnir.org/dane/prawo/en/eu-cmrd6/) (EU, Adopted): Introduces OELs for cobalt and its inorganic compounds (inter alia Ni/Co refining, battery recycling) and for PAHs with a transitional period, inter alia for aluminium producers and other non-ferrous metallurgical processes.
- [Act on chemical substances and their mixtures](https://igmnir.org/dane/prawo/en/pl-ustawa-chemikalia/) (PL, In force): Designates the authorities and criminal penalties for infringements of REACH and CLP in Poland and imposes national obligations, inter alia an inventory of hazardous substances and labelling of tanks.
- [Labour Code – chemical agents and CMR (Arts 221, 222, 227)](https://igmnir.org/dane/prawo/en/pl-kp-chemikalia/) (PL, In force): Statutory basis for the employer’s obligations concerning chemical substances and CMR: labelling, inventory and safety data sheets, substitution, registers of work and workers, measurements and maximum admissible concentrations (NDS).
- [Regulation on Polish occupational exposure limits (NDS/NDN; lead 0.03 mg/m³)](https://igmnir.org/dane/prawo/en/pl-nds/) (PL, In force): Sets the maximum admissible concentration (NDS) values binding in PL; transposes Directive 2024/869 as regards lead and diisocyanates (Dz.U. 2026 poz. 447) and Directive 2022/431 as regards nickel compounds (Dz.U. 2024 poz. 1017).
- [Regulation of the Minister of Health – CMR agents in the working environment (registers)](https://igmnir.org/dane/prawo/en/pl-cmr-rozp/) (PL, In force): Covers reprotoxic substances (inter alia lead) and requires registers of work and of workers exposed to CMR, annual information to the State Sanitary Inspection (PIS) and the National Labour Inspectorate (PIP), and retention of registers for up to 40 years.
- [Regulation of the Minister of Health – OHS and chemical agents (PbB 30/15)](https://igmnir.org/dane/prawo/en/pl-bhp-czynniki-chemiczne/) (PL, In force): Transposes Directive 98/24/EC and, as regards the biological limit value for lead, Directive 2024/869: mandatory PbB monitoring, value of 30 and, from 2029, 15 µg/100 ml.
- [Regulation on medical examinations of employees (lead – § 13a)](https://igmnir.org/dane/prawo/en/pl-badania-lekarskie/) (PL, In force): Sets the thresholds for preventive examinations in the case of exposure to lead in line with Directive 2024/869, and a transitional provision for workers with elevated PbB before 9.04.2026.
- [Regulation of the Minister of Health – tests and measurements of harmful agents](https://igmnir.org/dane/prawo/en/pl-pomiary/) (PL, In force): Specifies the frequency of measurements of airborne concentrations at workstations, including lead, arsenic, cadmium and nickel compounds, as well as requirements for laboratories and records.

## Raw materials, mining and supply chain

- [Critical Raw Materials Act (CRMA)](https://igmnir.org/dane/prawo/en/eu-crma/) (EU, Amendments pending): Framework for the security of supply of strategic and critical raw materials – inter alia copper, bauxite/alumina/aluminium, nickel and cobalt (Annex I): strategic projects, monitoring of supply chains, preparedness of large companies, recovery from extractive waste.
- [Conflict minerals (3TG)](https://igmnir.org/dane/prawo/en/eu-mineraly-konfliktowe/) (EU, In force): Supply chain due diligence for Union importers of ores and concentrates and of metals containing tin, tantalum, tungsten and gold (Annex I) above annual import volume thresholds; recycled metals are excluded (Art. 1(6)).
- [Corporate Sustainability Due Diligence Directive (CSDDD)](https://igmnir.org/dane/prawo/en/eu-csddd/) (EU, Applies from 26.07.2029): Obligation to identify and address adverse human rights and environmental impacts in own operations, subsidiaries and the chain of activities. Following the Omnibus I package (Directive 2026/470) – only the largest companies.
- [Geological and Mining Law](https://igmnir.org/dane/prawo/en/pl-pgg/) (PL, Amendments pending): Licensing of prospecting, exploration and extraction of minerals (metal ore deposits covered by mining ownership), operation of mining plants, extraction fee, mining supervision.
- [Tax on the extraction of certain minerals (copper, silver)](https://igmnir.org/dane/prawo/en/pl-podatek-kopaliny/) (PL, In force): Tax on the quantity of copper and silver in the concentrate produced (or in the run-of-mine ore), with a rate dependent on the average metal price (LME, LBMA, NBP exchange rate); from 2026 reduced coefficients and a deduction of capital expenditure.
- [Act on the KAS – authority for conflict minerals](https://igmnir.org/dane/prawo/en/pl-kas-mineraly/) (PL, In force): Designation of the Head of the National Revenue Administration (KAS) as the authority performing the tasks under Regulation 2017/821 (3TG), and the procedure for ex post checks of Union importers and fines.

## Products and producer responsibility

- [Batteries Regulation](https://igmnir.org/dane/prawo/en/eu-baterie/) (EU, Amendments pending): Requirements for batteries throughout their life cycle: minimum recycled content of Co, Pb, Li, Ni, raw materials supply chain due diligence, battery passport, EPR and targets for recycling efficiency and recovery of Cu, Pb, Li, Ni, Co.
- [WEEE Directive (waste electrical and electronic equipment)](https://igmnir.org/dane/prawo/en/eu-weee/) (EU, Amendments pending): Collection, treatment and recovery of WEEE – a significant stream of non-ferrous metal scrap (Cu, Al, precious metals); extended producer responsibility of equipment producers.
- [Directive 2000/53/EC on end-of-life vehicles](https://igmnir.org/dane/prawo/en/eu-elv-dyr/) (EU, Amendments pending): Existing framework for the collection and treatment of end-of-life vehicles, recovery and recycling targets and the prohibition of Pb, Hg, Cd and Cr(VI) in vehicle materials (Annex II – exemptions, inter alia lead in Al and Cu alloys).
- [Packaging and Packaging Waste Regulation (PPWR)](https://igmnir.org/dane/prawo/en/eu-ppwr/) (EU, Amendments pending): Directly applicable requirements for packaging (including aluminium and steel packaging): recyclability, labelling, EPR, deposit return systems for cans and bottles, aluminium recycling targets.
- [Ecodesign for Sustainable Products Regulation (ESPR)](https://igmnir.org/dane/prawo/en/eu-espr/) (EU, In force): Framework for ecodesign requirements (durability, recycled content, carbon footprint, digital product passport). Iron and steel and aluminium – priority groups of the first working plan.
- [RoHS Directive (restriction of hazardous substances in EEE)](https://igmnir.org/dane/prawo/en/eu-rohs/) (EU, In force): Limits for lead (0.1%) and cadmium (0.01%) in homogeneous materials of EEE; exemptions for lead as an alloying element in steel, aluminium and copper alloys (Annex III, point 6).
- [End-of-Life Vehicles Regulation (ELVR)](https://igmnir.org/dane/prawo/en/eu-elv/) (EU, Applies from 01.09.2028): Replaces Directive 2000/53/EC: vehicle design for recycling, recycled plastic content, assessment of the share of recycled steel and aluminium, EPR, removal requirements before shredding and control of exports of used vehicles.
- [Act on waste electrical and electronic equipment](https://igmnir.org/dane/prawo/en/pl-zsee/) (PL, Amendments pending): Transposition of the WEEE Directive: obligations of persons placing equipment on the market, distributors, collectors, treatment plants and recyclers, including collection and recovery rates and certificates in BDO.
- [Act on batteries and accumulators](https://igmnir.org/dane/prawo/en/pl-baterie/) (PL, Amendments pending): National provisions on the placing on the market of batteries and accumulators, collection, treatment and recycling (inter alia lead-acid), implementing the repealed Directive 2006/66/EC.
- [Act on the recycling of end-of-life vehicles](https://igmnir.org/dane/prawo/en/pl-pojazdy/) (PL, In force): Transposition of Directive 2000/53/EC: collection network, dismantling stations, shredders, recovery and recycling rates and certificates of destruction.
- [Act on packaging management (deposit return system)](https://igmnir.org/dane/prawo/en/pl-opakowania/) (PL, Amendments pending): Obligations of persons placing packaged products on the market (recycling, product fee) and a deposit return system covering, inter alia, metal cans up to 1 l – relevant for producers of aluminium strip and sheet and for recyclers.

## Trade, sanctions and investment screening

- [Economic sanctions against Russia (Regulation 833/2014)](https://igmnir.org/dane/prawo/en/eu-sankcje-rosja/) (EU, Amendments pending): Prohibition on imports from Russia of, inter alia, copper (matte, anodes, cathodes, scrap, wire), aluminium (unwrought, scrap, semi-finished products), nickel, zinc, Cu/Ni/Pb ores and steel products. Latest amendment: Regulation 2026/1848 (21st package, in force from 24.07.2026).
- [Sanctions against Belarus (Regulation 765/2006)](https://igmnir.org/dane/prawo/en/eu-sankcje-bialorus/) (EU, Amendments pending): The list of goods subject to the import prohibition from Belarus corresponds to the ‘metals’ scope of the sanctions against Russia (Cu, Al, Ni, Pb, Zn, scrap, ores); a separate prohibition for steel products.
- [Export control of dual-use items (Regulation 2021/821)](https://igmnir.org/dane/prawo/en/eu-dual-use/) (EU, In force): Export from the EU of certain alloys and metals (inter alia high-strength Al alloys, beryllium, hafnium, zirconium, rhenium, maraging steels) requires an authorisation; control also covers brokering and technical assistance.
- [FDI screening framework (Regulation 2019/452)](https://igmnir.org/dane/prawo/en/eu-fdi-2019/) (EU, In force): Mechanism for cooperation between Member States and the Commission in the screening of FDI from outside the EU; the assessment criteria include the supply of critical inputs, including raw materials.
- [Foreign subsidies distorting the internal market (FSR)](https://igmnir.org/dane/prawo/en/eu-fsr/) (EU, In force): Prior notification to the Commission of concentrations and of tenders in large public procurement procedures by undertakings receiving financial contributions from third countries.
- [Foreign investment screening – new Regulation 2026/1386](https://igmnir.org/dane/prawo/en/eu-fdi-2026/) (EU, Applies from 17.01.2028): Mandatory national screening mechanism with a requirement of prior authorisation, inter alia for investments in undertakings extracting, processing or recovering CRMA strategic raw materials.
- [Act on the control of certain investments](https://igmnir.org/dane/prawo/en/pl-kontrola-inwestycji/) (PL, In force): Two regimes: control of acquisitions in entities on the Council of Ministers’ list and control of acquisitions by non-EU/EEA investors in protected entities (Arts 12a–12k), inter alia public companies.
- [Act on counteracting support for aggression against Ukraine](https://igmnir.org/dane/prawo/en/pl-ustawa-sankcyjna/) (PL, Amendments pending): National sanctions list of the Ministry of the Interior and Administration (MSWiA), freezing of funds, KAS fines and criminal liability for infringement of the prohibitions in Regulations 833/2014 and 765/2006, including the prohibitions on imports of metals.
- [Act on foreign trade in goods of strategic importance](https://igmnir.org/dane/prawo/en/pl-obrot-strategiczny/) (PL, In force): National provisions supplementing Regulation 2021/821: authorisations for the export of dual-use items (e.g. metal alloys in category 1C), records and annual reporting on trade.

## Taxation of scrap and metal trade

- [VAT Directive – reverse charge for scrap and metals (Arts 199, 199a)](https://igmnir.org/dane/prawo/en/eu-vat-odwrotne/) (EU, Amendments pending): Optional reverse charge for supplies of scrap and waste (Art. 199) and of raw and semi-finished metals (Art. 199a – temporary). Poland currently does not use these options (Art. 17(1)(7) of the VAT Act repealed).
- [VAT in the Digital Age – ViDA (Directive 2025/516)](https://igmnir.org/dane/prawo/en/eu-vida/) (EU, In force): Mandatory e-invoicing and digital reporting for intra-EU B2B transactions from 1.07.2030; national e-invoicing systems (e.g. KSeF) permitted without derogation.
- [VAT Act – split payment and joint and several liability](https://igmnir.org/dane/prawo/en/pl-vat-mpp/) (PL, Amendments pending): Annex 15 covers, inter alia, unwrought Al, Pb, Zn, Sn, Cu and Ni, Cu bars and wire (items 46–55), waste and scrap of base metals (item 56) and metal secondary raw materials (item 87). Guarantee deposit (Arts 105b–105d) repealed.
- [National e-Invoicing System (KSeF)](https://igmnir.org/dane/prawo/en/pl-vat-ksef/) (PL, Amendments pending): Obligation to issue structured invoices in KSeF with transitional periods depending on the value of sales; fines from 1.01.2027.

## Sustainability reporting

- [‘Stop-the-clock’ Directive (CSRD/CSDDD)](https://igmnir.org/dane/prawo/en/eu-stop-the-clock/) (EU, In force): Two-year postponement of CSRD reporting for the so-called second and third waves and one-year postponement of the CSDDD deadlines; the CSDDD deadlines were amended again by Directive 2026/470 (single date of application – 26.07.2029).
- [Corporate Sustainability Reporting Directive – CSRD](https://igmnir.org/dane/prawo/en/eu-csrd/) (EU, In force): Reporting of environmental impacts (emissions, resources, circular economy) in the management report in accordance with the ESRS, with assurance; following Omnibus I the scope has been limited to the largest undertakings.
- [EU Taxonomy (Regulation 2020/852) and simplification 2026/73](https://igmnir.org/dane/prawo/en/eu-taksonomia/) (EU, In force): Undertakings subject to the CSRD disclose the proportion of taxonomy-aligned turnover, CapEx and OpEx; from 2026 a 10% materiality threshold and simplified DNSH criteria.
- [European Sustainability Reporting Standards (ESRS)](https://igmnir.org/dane/prawo/en/eu-esrs/) (EU, Amendments pending): Content of ESG disclosures (inter alia climate, pollution, resource use and circular economy). Simplified ESRS replace Annexes I and II from 2027; for 2026 – choice of version.
- [Omnibus I – change in the scope of the CSRD and CSDDD (Directive 2026/470)](https://igmnir.org/dane/prawo/en/eu-omnibus-i/) (EU, Applies from 01.01.2027): Raising of the CSRD thresholds to > 1,000 employees and > EUR 450 million turnover, protection of suppliers in the value chain (≤ 1,000 employees), abandonment of reasonable assurance.
- [Accounting Act – sustainability reporting](https://igmnir.org/dane/prawo/en/pl-rachunkowosc-csrd/) (PL, Amendments pending): Transposition of the CSRD (Chapter 6c). Stop-the-clock: Group II from 2027, Group III from 2028. Group I undertakings with ≤ 1,000 FTEs or ≤ PLN 1.9 billion revenue may refrain from reporting for 2025–2026.