Waste oil management: principles of the reform and the draft act

Waste oil management: principles of the reform and the draft act


Period of implementation of the project: 

2018- 2021


The main goal of the project was to provide a proposal of legislative intervention, addressing the issue of the gray market of waste oils, which could be accepted by both the public administration and key stakeholders. Baseline studies identified key problems with execution of the current obligations. In particular, illegal import on a large scale enables avoidance of the extended producer responsibility (EPR) obligations. Furthermore, waste oils are free and high-calorific fuels, while their incineration leads to significant air pollution (smog), and there is no way to effectively control all the end users.


The work was carried out in a trialogue with key market players on which the new obligations would be imposed and with the public administration authorities involved in further implementation. Broader public consultations were initiated with the publication of the report.

Three key solutions were proposed. 

  1. Аll oils and greases should be covered by the obligation to obtain the relevant concessions, just as liquid fuels. This would result in the implementation of all further control and supervision tools and ensure that the entire volume of such substances is covered by the EPR scheme. 
  2. А deposit fee should be introduced in order to make sure that the illegal incineration of waste oils by end-users is no longer economically beneficial. This solution has already been effectively implemented for waste accumulators. 
  3. Waste treatment hierarchy needs explicit clarification with regard to waste oils. The waste holder (e.g. the entity that collects waste oils) should be allowed to transfer the waste for other forms of reuse only after the waste has been verified as unsuitable for regeneration.


At the current stage, a complete legislative bill has been published. It was announced by the key administrative stakeholders: Ministry of Development, Ministry of Finance and Ministry of Climate. The project was supported by the key market stakeholders forming the POPIHN chamber of commerce. The Ministry of Development announced its intention to finalize the legislative work within a few months.

Implementation of the project should give the authorities full information about the volume of oils and greases present on the market and therefore on the volume of waste requiring reuse and recycling in the EPR scheme. It should significantly reduce the number of cases where waste oil is illegally incinerated by citizens, thereby significantly lowering the emission of harmful substances to the air. Ultimately, the expected increase in waste oil regeneration will reduce the demand for primary raw material, in accordance with the circular economy principles.

Category: Planet

Company: Domański Zakrzewski Palinka sp.k.

damanski logo

About the company: 

DZP is the largest independent Polish law firm. For 27 years our experts have advised both Polish and foreign clients from all business sectors. We currently have over 170 legal and tax experts based in our offices in Warsaw, Poznań and Wrocław.

Sustainable Development Goals



United Nations Global Compact

Ministry of Development

Polish Chamber of Commerce “Ekorozwój”

Ministry of Climate

Energy Regulatory Office

Ministry of Finance

Polish Oil Trade and Industry Organization