YES

Pursuant to Art. 20 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065 (http://isap.sejm.gov.pl/isap.nsf/download.xsp/WDU20150000881/U/D20150881Lj.pdf) personnel performing the following activities:

• leakage checking of devices containing at least 5 tonnes of CO2 equivalent of f-gases or more, unless such
• devices are hermetically sealed, marked as such and contain less than 10 tonnes of CO2 equivalent;
• recovery;
• installation (installation);
• repair, maintenance or servicing;
• liquidation
• are obliged to have an appropriate certificate for the personnel.

Regardless of the above, in accordance with Art. 29 of the above Act, an entrepreneur who conducts activities consisting of installing, maintaining or servicing, repairing and decommissioning stationary refrigeration, air conditioning or heat pumps, is required to have a certificate for entrepreneurs.

The act imposes separate obligations on the entrepreneur with regard to the acceptance of supplies of fluorinated greenhouse gases, the application of procedures for the performance of activities, the implementation of a system for documenting activities and the possession of appropriate technical equipment.

NOT

UDT does not have local properties, so you can apply to any branch. Submitting the application to the nearest UDT branch will certainly speed up the inspection and issuing the certificate.

YES
The requirements in this regard are specified in Art. 29 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065.

An entrepreneur who conducts the activity of installing, maintaining or servicing, repairing and decommissioning stationary refrigeration, air conditioning or heat pumps, as well as fire protection systems containing fluorinated greenhouse gases, is required to have a certificate for entrepreneurs.

The indicated provision of the Act is formulated in a general manner and does not impose restrictions on the content of fluorinated greenhouse gases in the device or system.

On the basis of: Article 3 sec. 2 COMMISSION IMPLEMENTING REGULATION (EU) 2015/2067 of 17 November 2015 establishing, pursuant to Regulation (EU) No 517/2014 of the European Parliament and of the Council, minimum requirements and conditions for mutual recognition of certification of natural persons with regard to stationary refrigeration equipment, air conditioning and heat pumps and refrigeration units for refrigerated trucks and trailers, containing fluorinated greenhouse gases, as well as company certification for stationary refrigeration, air conditioning and heat pump equipment containing fluorinated greenhouse gases

Personnel installing equipment containing 3 kg or more of fluorinated greenhouse gas should be F-Gas Category I certified.

For personnel who only perform leakage checks (without interfering with the cooling system), it is enough to have a category IV certificate.

The certificate applies to all devices containing fluorinated gases, regardless of the filling

People filling portable tanks are required to have a certificate for the fillers. Certificates of qualifications in this area are issued in accordance with:

• the Act of December 21, 2000 on technical inspection (Journal of Laws of 2019, item 667)
• Regulation of the Minister of Economy of 18 July 2001 on the procedure for checking qualifications required for the operation and maintenance of technical devices (Journal of Laws No. 79, item 849), amended by the Regulation of the Minister of Entrepreneurship and Technology of 21 May 2019 on the method and procedure for checking the qualifications required for the operation and maintenance of technical devices and the method and procedure for extending the period of validity of qualification certificates, issued on the basis of art. 23 sec. 5 of the act on technical inspection.

Exams for fillers are carried out by the Office of Technical Inspection. The detailed subject of the exam for applicants to check the qualifications required for filling portable pressure tanks with a capacity of more than 350 cm3 is available on the UDT website.

NOT

Pursuant to Article 37 point 1 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065, a certificate is not required for servicing the A / C systems on some motor vehicles. It is only required to have a training certificate for people carrying out the recovery of controlled substances and fluorinated greenhouse gases from these systems.

The  Act of May 15, 2015 on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065 does not require authorisation to install, repair, service and maintain and liquidate mobile devices, with the exception of refrigerated trucks and refrigerated trailers.

The obligation to have a license with regard to mobile equipment exists only in the case of performing recovery operations. In order to be able to recover the refrigerant from mobile devices, it is necessary to have a certificate for personnel in the appropriate scope, i.e. category I, II or III (issued by the Office of Technical Inspection).

Minimum technical equipment to be used by the staff, for the relevant categories referred to in Article 3 sec. 2 of the Commission Implementing Regulation (EU) 2015/2067 of 17 November 2015 establishing, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council, minimum requirements and conditions for mutual recognition of certification of natural persons with regard to stationary refrigeration equipment, air conditioning and heat pumps and refrigeration units of refrigerated trucks and trailers, containing fluorinated greenhouse gases, as well as the certification of enterprises with regard to stationary refrigeration, air conditioning and heat pumps containing fluorinated greenhouse gases, covers the scope of Annex 1 to the REGULATION OF THE MINISTER OF DEVELOPMENT AND FINANCE of 7 December 2017 on the minimum technical equipment suitable for the performance of the activities certified for personnel on fluorinated greenhouse gases and controlled substances.

According to the currently valid F-Gas Act, a company certificate is required to purchase fluorinated gas.

What about devices?

Directive 517/2014, Art. 11 (5): Non-hermetically sealed equipment filled with fluorinated greenhouse gases shall only be sold to the end-user if evidence is provided that installation is to be carried out by a body certified in accordance with Art. 10.

Amendment: ,, Art. 13a 1. The evidence referred to in Art. 11 sec. 5 of Regulation (EU) No 517/2014, there is an installation service contract, containing in particular: the name of the device to be installed and information about the name and certificate number for entrepreneurs performing the installation service for the end user, if such a contract is concluded between the end-user and a legal person, or the name and certificate number for the staff of the natural person performing the installation service for the end-user where such contract is concluded between the end-user and the legal entity.

NOT

A company that employs a person certified for personnel to service only its own refrigeration equipment does not conduct business in this area, so it does not need to have a certificate for entrepreneurs.

Pursuant to Art. 29 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065 entrepreneurs who conduct activities consisting in installing, maintaining or servicing, repairing and decommissioning stationary refrigeration, air conditioning or heat pumps, as well as fire protection systems containing fluorinated greenhouse gases, are required to have a certificate for entrepreneurs, indicated respectively in Regulation (EU) No. 2015/2067 or in Regulation (EC) No 304/2008.

Polish law defines entrepreneurs in two legal provisions, namely in art. 43 (1) of the Civil Code and in art. 4 of the Act on the freedom of economic activity, which stipulate that the entrepreneur is an entity conducting business or professional activity on its own behalf.

In conclusion, in the light of the above-mentioned regulations, only entrepreneurs conducting business or professional activity for other parties are required to have a certificate for entrepreneurs.

NOT

The Act of May 15, 2015 on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065 does not specify requirements for distributors in this regard. Similarly, if a company purchases a device containing fluorinated greenhouse gases for further distribution and not for service purposes, it is not required by law to have F-gas certificates.

YES

Pursuant to Art. 43 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065:

“Certificates or attestations issued in other Member States of the European Union are recognised when the holder of the certificate or attestation has a sworn translation of the certificate or attestation into Polish”.

An enterprise can apply for an enterprise certificate after an employee employed by the enterprise has obtained a personal certificate. If the owner of the company is also its sole employee (sole proprietorship) then he presents his personal F-gas certificate.

In order to obtain this type of certificate, it is necessary for the entrepreneur to submit an application to the Office of Technical Inspection.

This is described in detail in Art. 30 of the F-Gas Law:

Art. 30.

1. A certificate for entrepreneurs is issued by a certification body for entrepreneurs.
2. A certificate for entrepreneurs may be obtained by an entrepreneur who:
   1) meets the requirements appropriate to the type of business, specified in Regulation (EC) 303/2008 or
   Regulation (EC) No 304/2008, in particular:
   a) has and applies business procedures at the principal place of business and at all branches,
   b) has a system for documenting activities performed by appropriately certified personnel at the principal                place of business and in all departments,
   c) has the technical equipment at the main place of business and in all branches that meets the minimum 2)          requirements appropriate to the scope of the business;
   2) being a natural person, he has not been convicted by a final judgment for an offense against the environment in connection with his activity, or persons belonging to the entrepreneurs organs being a legal person or an organisational unit other than a legal person have not been convicted for such a crime;
   3) submits an application to the certification body for entrepreneurs for a certificate for entrepreneurs.
3. The certificate for entrepreneurs is issued for an indefinite period.

Operating without a certificate for an entrepreneur is punishable by an administrative fine of PLN 4,000 to PLN 15,000 (Article 48 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases).

Pursuant to Art. 22 section 1 and section 2 of the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065, the personnel certificate is issued for an indefinite period.

However, the certificate is subject to withdrawal and removal from the register of issued certificates for personnel in the event of the final conviction of a person holding this certificate for an offense against the environment.

NO

The Certificate for personnel, in accordance with the Act of May 15, 2015. on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065, should be possessed by personnel performing the following activities:

• leak testing of equipment containing 3 kg or more of fluorinated greenhouse gases and equipment containing 6 kg or more of fluorinated greenhouse gases, with hermetically sealed systems which are labelled as such;
• recovery;
• installation (installation);
• maintenance or servicing.

Therefore, if the owner of the company does not professionally perform the above activities, he is not obliged to have a certificate for the personnel.

According to Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, “electrical switchgear” means switchgear and its connection with connected control, measurement, protection and regulation equipment, as well as assemblies of such apparatus and equipment with interconnections, fittings, housing and auxiliary components, which are intended for use in connection with the generation, transmission, distribution and processing of electricity.

Circuit breakers, transformers, disconnectors, and other SF6-filled devices as defined above are also part of the electrical switchgear.

Accordingly, to perform the activities of installing, maintaining, repairing, servicing, decommissioning, and recovering SF6 gas from the listed equipment also requires a personal certificate Cat. electrical switchboards.

According to Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, reclamation means “reprocessing of a recovered fluorinated greenhouse gas in order to achieve working properties corresponding to those of the original substance, taking into account the intended use.”

The intended application is the electric power industry, so the primary properties of SF6 gas are recognized based on IEC 60376.

After regeneration, the regenerated SF6 should be subjected by the regeneration company to specialized laboratory tests to check its technical parameters in order to confirm whether the regenerated gas meets the quality criteria of the standards specified in the standard.

Recycling only involves carrying out a basic cleaning process and reusing the recovered fluorinated greenhouse gas afterwards.

Only gas that has undergone a complete remanufacturing process can be considered a full-fledged product with technical parameters equal to the rigorous characteristics of a new product.

According to Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, “virgin” SF6 means sulfur hexafluoride that has not been previously used.

Primary SF6 can be used to fill electrical equipment, but a personnel certificate Cat. electrical switchboards.

Recovered SF6 is no longer a virgin substance, but waste.

According to Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, “the amount of SF6 contained in the switchgear” means the rated filling of the isolated gas compartment of the equipment.

The rated filling of the gas compartment must be specified in the technical documentation drawn up by the manufacturer of the type of switchgear.

Document PN – EN IEC 60 376 “Requirements for technical sulfur hexafluoride (SF6) and complementary gases for its mixtures used in electrical equipment” specifies the quality of technical sulfur hexafluoride and complementary gases such as nitrogen and tetrafluoromethane for use in electrical equipment. The standard also describes the techniques used to analyze SF6 before it is introduced into electrical equipment, covering both laboratory instrumentation and portable instrumentation used at the site of the electrical equipment.

Document PN – EN IEC 60 480 “Requirements for sulfur hexafluoride (SF6) and its mixtures for reuse in electrical equipment” specifies criteria for the reuse of sulfur hexafluoride after recovery from electrical equipment (e.g., for maintenance, end-of-life) and reclamation. The standard includes several appendices on the description of various methods for analyzing SF6 gas, issues related to recovery and neutralization of decomposition products, cryogenic regeneration of SF6, and recommendations on storage and transportation of SF6.

According to Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, “operator” means the natural or legal person exercising actual control over the technical operation of the product or equipment in question.

“Actual control” means day-to-day control of the device, full access, decision-making in financial and technical matters.

The entity becomes an operator when the equipment is delivered to the site of use or (in the case of installation) when it is completed and filled with SF6.

If there is no way to determine the operator, it becomes the owner.

The operator of the device will never be the company servicing the device, unless it itself operates it at its premises or owns it.

In short: operator = TIN number

According to Art. 14 paragraph. 2. The Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, the obligation to keep records is the responsibility of the equipment operator.

However, it should be remembered that electrical switchgear is not subject to leakage control, and thus to the obligation to keep records in the Central Operator Registry system if it meets at least one of the following conditions:

1. (a) their tested leakage rate is, according to the manufacturer’s technical specifications, less than 0.1% per year, and they are labeled accordingly;
2. (b) are equipped with a pressure or density monitoring device; or
3. (c) contain less than 6 kg of fluorinated greenhouse gases.

According to Art. 10 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, the acquisition of a fluorinated greenhouse gas for activities requiring a personnel certificate may be carried out by an individual who holds the appropriate personnel certificate.

Any entity can purchase SF6 in inches of resale without a personnel certificate, but is required to file a statement with the gas distributor.

The statement must state that the purchased SF6 will not be used for activities requiring personnel certification, but will be resold to another entity.

As defined in Art. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, by “maintenance or servicing” activity means, among other things, supplying fluorinated greenhouse gases to the system.

According to the above definition, personnel certification is required for gas filling activities.

Repairing leaks is also a maintenance or service activity, so performing it also requires a personnel certificate.

According to Art. 29 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, entrepreneurs performing activities for third parties involving the installation, maintenance or servicing, repair or decommissioning of stationary refrigeration, air conditioning and heat pump equipment are required to hold an enterprise certificate.

The obligation also applies to stationary fire protection systems containing fluorinated greenhouse gases.

For electrical switchgear, personnel certification is sufficient.

NO

Persons performing filling operations on portable pressure vessels with a capacity of more than 350 cc are required to hold a certificate for fillers. Certificates of qualification in this regard are issued in accordance with:

• By the Law of December 21, 2000. On technical supervision (Journal of Laws of 2019, item 667),
• Decree of the Minister of Entrepreneurship and Technology dated May 21, 2019. On the manner and procedure for verifying the qualifications required for the operation and maintenance of technical equipment and the manner and procedure for extending the validity of qualification certificates,

and conducted by the Office of Technical Inspection.

According to Art. 10 paragraph. 10 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, European Union member states are required to recognize certificates issued in another member state.

In addition, EU regulations dictate that member states may not restrict the freedom to provide services or freedom of establishment because of the issuance of a certificate in another member state.

However, the serviceman should have a sworn translation of his certificate into the official language of the country where he will use the document.

Recognition of certificates in other countries applies only to European Union member states.

According to Art. 22 paragraph. 1 and 2 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, the personnel certificate is issued indefinitely.

However, the certificate may be revoked in the event of a final conviction of the holder of the certificate for an environmental crime.

The certificate is valid throughout the European Union.

According to Art. 20 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, personnel installing, servicing, maintaining, repairing or decommissioning electrical switchgear containing fluorinated greenhouse gases or recovering fluorinated greenhouse gases from stationary electrical switchgear are required to hold the appropriate personnel certification.

The personnel certificate is issued before the Office of Technical Inspection, on the basis of a positive result of the examination, obtained by the personnel at the examination body.

The certificate is perpetual and valid throughout the European Union.

YES

According to Art. 20 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, personnel installing, servicing, maintaining, repairing or decommissioning electrical switchgear containing fluorinated greenhouse gases or recovering fluorinated greenhouse gases from stationary electrical switchgear are required to hold the appropriate personnel certification.

The provision does not exempt personnel working with equipment with a fill level of less than 6 kg of SF6 gas from the certification requirement.

According to Art. 8 paragraph. 1 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, the recovery of SF6 is carried out only to ensure the recycling, reclamation or destruction of this gas.

Before refilling the device with SF6 gas, it is necessary to recycle or regenerate it.

The gas after the recycling process can be reused only in the device from which it was recovered.

According to Art. 180a of the Environmental Protection Law, waste generation permit.
is required for waste generation of more than 1 Mg per year for hazardous waste, which is what we classify recovered SF6 as.

A permit is also required for the processing, storage and transportation of waste.
In the case of transporting, the permit does not apply to transporting self-generated waste.

According to Art. 3 paragraph. 1 pt. 32 of the Waste Law, the owner of the waste in the form of recovered sulfur hexafluoride is the service company performing the recovery operation.

Recovered SF6 should be immediately handed over to an entity that collects and processes the waste.

The owner of the waste is required to issue a Waste Transfer Card in the Waste Database system indicating the waste receiving unit. The owner of the waste can transport the recovered SF6 to a storage site without having a waste transportation permit.

According to Art. 4 paragraph. 1 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases electrical switchgear that meets at least one of the following conditions:

• their tested leakage rate is, according to the manufacturer’s technical specifications, less than 0.1% per year, and they are labeled accordingly;
• are equipped with a pressure or density monitoring device;
• contain less than 6 kg of fluorinated greenhouse gases;
• are not subject to leakage control.

At the same time, these devices are not subject to registration in the Central Register of Operators and the need to maintain Equipment Cards.

According to Art. 5 paragraph. 2 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, operators of electrical switchgear containing fluorinated greenhouse gases in quantities of 500 tons of_CO2 equivalent or more and installed as of January 1, 2017, shall ensure that such equipment is equipped with a leak detection system.

The leak detection system must alert the operator or service company of any leak.

These systems must be inspected at least once every 6 years to ensure their proper operation.

According to Art. 10 paragraph. 11 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, any entity that outsources a servicing activity to another entity is required to make sure that the entity has the necessary certification to perform the required activities.

This requirement also applies to the service of recovering SF6 gas from equipment.

This requirement does not apply to leakage control.

Art. 12 of the Regulation of the European Parliament and the Council on fluorinated greenhouse gases imposes mandatory labeling on containers and equipment containing SF6.

The exact information that the label should contain is specified in Art. 12 paragraph. 3 of the aforementioned regulation.

The same information must also be included in the device manual!

If the container contains recycled or remanufactured SF6 then the label must indicate this.

Regeneration of SF6 gas (i.e., according to the Regulation of the European Parliament and of the Council (EU) No. 517/2014 – processing of recovered F-gas to achieve properties corresponding to those of the original substance) is possible in case of such contaminants as moisture, air, CF4, decomposition products. Regeneration should be carried out in accordance with the recommendations of the PN-EN IEC 60480 standard. For the removal of air from SF6 gas, the standard recommends the use of a cryogenic process, which involves significantly lowering the temperature of SF6 to allow it to liquefy. In this situation, the air contained in the SF6 still remains in the gaseous state and is pumped away from the liquid sulfur hexafluoride. Such a process allows the sulfur hexafluoride to be restored to its original parameters, in accordance with PN-EN IEC 60376.

According to Art. 18, para. 2 of the Decree of the Minister of Economy, Labor and Social Policy dated December 23, 2003. On occupational safety and health in the production and storage of gases, filling tanks with gases and the use and storage of carbide (Journal of Laws 2004 No. 7, item 59), portable tanks, with the exception of portable tanks for dissolved acetylene, transferred for filling, should have a gas overpressure of at least 0.5 bar.

Leaving a small overpressure (known as residual gas) is designed to prevent air, moisture and other contaminants from entering the cylinder.

According to Art. 4 paragraph. 3. Regulation of the European Parliament and the Council on fluorinated greenhouse gases, leakage control of electrical switchgear should be carried out at the following frequency:

Note, however, that electrical switchgear is not subject to leakage inspection if it meets at least one of the following conditions:

(a) their tested leakage rate is, according to the manufacturer’s technical specifications, less than 0.1% per year, and they are labeled accordingly;

(b) are equipped with a pressure or density monitoring device; or

(c) contain less than 6 kg of fluorinated greenhouse gases.

According to Art. 3 paragraph. 3 of the Regulation of the European Parliament and of the Council on fluorinated greenhouse gases, after the repair removing the leakage, a leakage check must be carried out within 1 month to be sure that the repair was effective.

Repair of leaks is the responsibility of the operator of the device, who is obliged to ensure repair without undue delay.

No personnel certification is required to perform leakage inspections of SF6-filled electrical switchgear.

According to Art. 14 paragraph. 2. The Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, the obligation to keep records is the responsibility of the equipment operator. A service technician can operate an unregistered device without legal consequences.

Responsibility for the absence of a card in the CRO system is the sole responsibility of the device operator.

According to Art. 39 of the Law on Substances that Deplete the Ozone Layer and Certain Fluorinated Greenhouse Gases, each entity that uses or recovers SF6 is required to submit a report to the Reporting Database by February 28 for the previous year.

Reporting to BDS applies to service companies (but also to switchgear operators and others) if:

• import SF6 from the EU or outside the EU or export SF6 to the EU or outside the EU,
• import switchgear containing SF6 from the EU or outside the EU or export it to the EU or outside the EU,
• use SF6 in switchgear manufacturing or other processes,
• recycle, regenerate or destroy SF6,
• perform service on equipment containing SF6.

Yes, the recovery, recycling and refilling of the device with SF6 gas must be reported in the Report Database.

In this case, complete the point 6. “Recover, recycle, recondition or destroy in-house” in the “Recovery” field and in the “Recycling” field and point 5. “Use” in the field “Maintenance or service of stationary/mobile electrical switchgear” – type “Recovered, recycled or reclaimed substance”.

The report in the Report Database is filled out once a year, by February 28 for the previous year.

The fee for sulfur hexafluoride emissions is announced annually by the Minister of Climate.

For 2021, the fee appears in the Climate Minister’s announcement of September 9, 2020. On the rates of environmental fees for 2021. Look for it in Appendix 2.

Device tabs are assumed for:

1. stationary refrigeration, air conditioning and heat pump equipment
2. refrigeration units mounted on refrigerated trucks and refrigerated trailers according to Art. 2 points 26 and 27 of Regulation 517/2014
3. electrical switchboards according to Art. 2 point 36 of Regulation 517/2014
4. devices containing F-gases as organic solvents
5. Rankine cycles according to Art. 2 point 34 of Regulation 517/2014.

Fire Protection System Cards are assumed for stationary devices that are fire protection systems.

These cards are currently issued for devices that contain ≥ 3 kg of controlled substances as defined in Art. 3 point 4 of the EU Regulation No 1005/2009 or ≥ 5 tons of CO2 eq F-gases defined in art. 2 point 1 of the EU Regulation 517/2014.

The person responsible for inserting the device card is the operator, i.e. the natural or legal person who actually controls the technical operation of the device. Typically, this is the operator of the device, the owner of the device, or the administrator of the facility where the device is located.

NOT

To set up device cards, the operators account administrator or the “contact person” designated by him does not need to have a certificate.

YES

You can grant such a power of attorney – such a person then becomes the Administrator of the operators account. Only one person indicated in the power of attorney can act as the Administrator. He does not have to be an employee of the Operators company.

YES.

The operator of the operator account must then add this person to the CRO.
Such an employee then becomes the contact person of the operators account.
The number of contact persons indicated in the CRO is limited to 3.
You can freely add, block and remove the mentioned persons. The contact person must be an employee of the operators company.

In devices with several circuits, device cards should be created for each system separately if its filling is at least 3 kg of controlled substances or at least 5 tons of CO₂ equivalent of fluorinated greenhouse gases.

Entries to cards can be made by persons possessing a personal F-gas certificate who performed a given activity on the device as well as account administrators and their contact persons (this change was introduced after the amendment to the act).

Contact persons and administrators of operators accounts will be able to make entries even if they do not have certificates, but ONLY on the basis of protocols of performed activities signed by service technicians who performed them and who had to have certificates (if they were required for the activities performed).

Responsibility for the correctness of the entry of activities in the device card in the CRO rests with the service technician.

Only those activities that relate to interference with the cooling circuit are entered into the device card, e.g. installation, replenishment, recovery, refrigerant replacement, opening of the circuit and leakage control.

NO

The entry in the Cards cannot be changed or deleted, but a following corrective entry can be made.

NOT

It is not possible to enter retrospective activities, because at the time of entry, the activity is automatically saved with the current date.

The Device Card and the Fire Protection System Card are prepared within 15 days from the date of delivery of the device or fire protection system to the place of its operation, and if the device or fire protection system requires installation – within 15 days from the date of completion of its installation and filling with a controlled substance or a fluorinated greenhouse gas.

You have 15 working days from the date of performance to enter an activity in the device card.

Designated employees of the Industrial Chemistry Research Institute and the Environmental Protection Inspector have access to the cards, but only during the inspection.

If one company ceases to be a device operator, it closes the cards with the reason stated as “device operator change” and closes the account in the CRO database.

They can also print pdf versions of cards and pass them to the new operator so that the new operator has information about what happened with these devices earlier.

The new operator is required to register in the CRO database, must set up an account and cards for these devices on his account.

NOT

The card with updated entries should be saved in a pdf file and stored in the place of operation of the device to be made available during the WIOŚ inspection.

In order to make it easier for the account administrators of operators to prepare for creating new or updating existing Cards in the “Documents” tab on the CRO website www.cro.ichp.pl (the tab is available only for CRO users after logging in to the CRO website) and in the F-gases tab- CRO on the BOWOiK website www.ichp.pl/F-gazy-CRO (generally available tab) there is a table containing a list of substances and mixtures that are F-gases, their global warming potential (GWP) and the amount of each of these F-gasesin kg corresponding to 5 tonnes of CO₂ eq.

Tables containing the quantity (in kg) of the substance or mixture of F-gases and controlled substances that are subject to registration in the CRO PG database

YES

Pursuant to Art. 47 paragraph. 11 of the Act of May 15, 2015 on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065, a failure to submit the report to the Reports Database within the time limit specified in the Act results in a fine in the amount of PLN 600 to PLN 4500.

At the same time, a milder treatment can be expected in line with Art. 51 sec. 6, which says that “If the circumstances of the case and the evidence show that the breach occurred as a result of events or circumstances which the infringing entity could not prevent, the competent authority shall refrain from imposing an administrative fine and discontinue the proceedings.”

In addition, point 7  states that “An administrative fine cannot be imposed if 3 years have elapsed since the infringement was committed.”

Statutory (Article 39, Article 40, Article 41 of the Act of May 15, 2015 on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, pursuant to Journal of Laws of 2020, item 2065) the obligation to submit annual reports includes, among others entities that use ozone-depleting substances or fluorinated greenhouse gases, including their use in the production, installation, servicing or maintenance of equipment, and carry out their recovery, recycling, reclamation or destruction. The report for the previous year is submitted by February 28, in the form of an electronic document, via the database kept by the Industrial Chemistry Research Institute at www.bds.ichp.pl

The principles of maintaining the database are defined in the ordinance of the Minister of the Environment. A database registration is required prior to the submission of the first report.

The report must show the type of controlled substances, new substances and fluorinated greenhouse gases, their chemical and trade names and the quantity of these substances:

• purchased or obtained free of charge in the territory of the Republic of Poland,
• recovered on their own,
• pre-cleaned in-house as part of recycling,
• regenerated on their own,
• sold or transferred free of charge in the territory of the Republic of Poland,
• used in individual sectors, with the type of use,
• subject to destruction on their own, stored on 1 January and 31 December of the year to which the report relates,
• lost during the reporting year – with the amount of controlled substances, new substances and fluorinated greenhouse gases lost due to leakage and other causes.

NOT

The report on ozone depleting substances and fluorinated greenhouse gases should be submitted in electronic form via the Reporting Database, regardless of whether it results in a fee for the use of the environment and regardless of the amount of this amount.

Failure to submit the report or its untimely submission may result in an administrative fine (Art. 47 of the Act on substances that deplete the ozone layer and on certain fluorinated greenhouse gases).

The waste management report should be submitted by 15 March of a given year for the previous year. We submit the report via the waste database (BDO).

Importers of F-gases (HFCs) and importers of equipment containing these substances have to be properly reported. The current Regulation requires that from producers, importers and exporters of F-gases in an annual quantity above 1 ton or 100 tonnes of CO₂ equivalent. (Article 19, section 1, 4, 6 of REGULATION (EU) No. 517/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No. 842/2006)

Importantly, the reporting obligation also applies to companies that place on the market products and equipment containing fluorinated greenhouse gases in the amount exceeding 500 tonnes of CO₂ equivalent. The report must state the type of appliances, their number and the amount of refrigerant they contain.

Companies that place F-gases on the market in quantities of more than 10,000 tonnes of CO₂ equivalent per year must submit their reports for verification by an accredited independent auditor. The documentation must be kept for at least 5 years and made available to the European Commission and relevant national authorities upon request.

An entity is obliged to prepare and submit reports in BDS when such entity:

• Imports ODS or FGC to the territory of the Republic of Poland
• exports ODS or FGC from the territory of the Republic of Poland
• imports to the territory of the Republic of Poland products, stationary or mobile devices, stationary or mobile fire protection systems, fire extinguishers or air conditioning systems in some motor vehicles containing ODS or FGC
• exports from the Republic of Poland products, stationary or mobile devices, stationary or mobile fire protection systems, fire extinguishers or air conditioning systems in some motor vehicles containing ODS or FGC
• uses ODS or FGCs in the production of fire protection equipment or systems, mobile fire protection equipment or systems, fire extinguishers or air conditioning systems in certain motor vehicles containing ODS or FGC
• uses ODS or FGCs in the installation, servicing or maintenance of fire protection equipment or systems, mobile fire protection equipment or systems, fire extinguishers or air conditioning systems in certain motor vehicles containing ODS or FGCs
• uses ODS or FGCs in other processes
• recovers, recycle, regenerate or destroy ODS or FGCs.

The scheduled date for submitting the report is February 28 this year. for the previous year.

Companies that import or export ODS and F-gases to the European Union or outside the European Union are required to submit reports to the European Commission by March 31 of the year following the year to which the report relates.

Records from previous years should, as before, be kept in the archives for a period of 5 years in case of an audit.

There are two issues associated with this situation: submitting the environmental fee to the Marshals Office and submitting the KOBiZE report on emissions.

1. Pursuant to the Environmental Protection Law, the system user is responsible for emissions. In the case of refrigeration and air-conditioning equipment, the system user is most often its owner. For possible inspection, proof of payment of environmental fees for HCFC or HF emissions.
   Entities using the environment determine on their own the amount of fees due for the period in which the use of the environment took place. The fees are paid for the calendar year to the account of the competent Marshals Office by March 31 of the following year. Fees for discharging gases or dust into the air, resulting from the operation of devices, are paid to the account of the Marshals Office competent for the place of registration of the entity using the environment, and the remaining fees to the account of the Marsha’s Office competent for the place of use of the environment (Article 277 of the Act – Environmental Protection Law).
   The rates of fees for the release of gases or dusts into the air and the storage of waste applicable in 2021 were specified in the announcement of the Minister of the Environment of September 9, 2020 on the rates of fees for using the environment for 2021.
   There are no fees for using the environment, the annual amount of which for one type of use of the environment does not exceed PLN 800. However, when the annual amount of such a fee does not exceed PLN 100, the lists on the use of the environment are not submitted (Article 289 of the Environmental Protection Act). https://www.gov.pl/web/klimat/oplaty-za-kuje-ze-srodowiska
2. From January 1, 2019, entities using the environment set the amount of fees for the introduction of gases or dusts into the air based on the annual actual emissions specified in the report to the National Database on Greenhouse Gas and Other Substances Emissions (KOBiZE).
   The report is entered into the National Database through the website of the National Database, available at: www.krajowabaza.kobize.pl, after the entity using the environment has registered in the National Database. The data is entered after logging into the National Database, using an identifier (login) and access password.The report to the National Database should be submitted by the end of February each year for the previous year. In order to make it easier for entities using the environment to fulfill their statutory obligations regarding fees for emissions of pollutants into the air and waste storage, the National Centre for Balancing and Emission Management IOŚ-PIB has launched an additional functionality on its website that allows the preparation of a list containing information and data on the use of the environment and about the amount of the fees due. https://krajowabaza.kobize.pl/o-krajowej-bazie/show

In the announcement of the Minister of Climate on the rates of fees for using the environment (for the year in which the emission took place) – Annex 2 – hydrofluorocarbons.

YES
Pursuant to (EU) No. 517/2014 of April 16, 2014, in the entire European Union from January 1, 2017, the amounts of the refrigerant should be expressed in tonnes of CO2 equivalent.

There are no legal restrictions on the lifetime of installations containing R-22 (and other HCFCs).

It is forbidden to refill them with agents from the HCFC (R-22) group after December 31, 2014.

Efficient and tight devices can still be used.

A “prime” factor is one that has not been used before, i.e. it is not recycled.

Even to its technical death, if it is functional, tight and regularly serviced. On the other hand, any unsealing of the R22 installation will result in:

• high emission charges (in 2021 halogenated hydrocarbons: HCFCs: PLN 64.01 / kg),
• potential losses related to the disruption of the production and economic activity of the user of the refrigeration plant. It is recommended to change cooling systems to systems with alternative refrigerants.

The recovered factor can be submitted to PROZON of the Climate Protection Foundation.

All necessary contact details can be found in the CONTACT tab.

The refrigerant system operator (system user) is the owner of the refrigerant.

The refrigerant recovery operation performed by the service company does not transfer ownership of the refrigerant to the service company.

In the event that the refrigerant becomes waste, it is the property of the service, resultant from Article 3 (1) (32) of the Waste Act of December 14, 2012.

NO

According to Art. 11 sec. 3 and 4 OF THE REGULATION (EC) NO 1005/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of September 16, 2009 on substances that deplete the ozone layer, since January 1, 2015, this refrigerant cannot be used for for the maintenance or servicing of existing refrigeration and air conditioning equipment and heat pumps.

Devices containing R22 may function until their technical death. It cannot be transferred to another person or entity for further trading.

The best solution from the point of view of environmental protection, correct documentation and legal compliance is to transfer the recovered refrigerant for regeneration to the PROZON Climate Protection Foundation.

REGULATION (EU) No 517/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 16, 2014. on fluorinated greenhouse gases, sets dates for a gradual reduction in the use of

NO

Pursuant to Art. 10 point 4 of the Act of May 15, 2015, on substances that deplete the ozone layer and on certain fluorinated greenhouse gases, on the basis of Journal Of Laws of 2020, item 2065, it is prohibited to transfer, for a consideration or free of charge, fluorinated greenhouse gases to natural persons for their own needs, with the exception of the provision of installation, maintenance or servicing of equipment as part of the service.

Each producer and importer placing F-gases on the EU market is subject to the obligation to comply with the permitted amount of these substances. These quotas will be most easily allocated to those that are already active and have reported on such activities. New applicants are also eligible to apply for an F-gas quota.

Quotas are available to producers and importers of F-gases registered in the territory of the European Union or having exclusive representatives here. Each such entity may place HFC substances on the market in an amount not higher than the allocated limit. New applicants must submit a declaration to the European Commission on the types and quantities of HFCs they intend to place on the market in the following year. The Commission sets a deadline for submitting these documents. Before submitting the declaration, you must register in the electronic system.

In the first stage, each new candidate receives an allocation in accordance with the declaration, but no more than that resulting from the even distribution of the overall quota among all applicants. Candidates who receive lower quotas than proposed may apply for additional allocation in the second step according to the same proportional rules. The procedure may be repeated until all applicants are satisfied, or the overall F-gas quota has been exhausted to a level equivalent to 500 tonnes of CO₂.

YES

According to Art. 8 of EU Regulation No. 517/2014, operators of equipment shall ensure that the recovery of gases from such equipment is carried out by natural persons holding the relevant certificates provided for in Article. 10, to ensure the recycling, reclamation or destruction of these gases.

This, after recovery, it is necessary to carry out one of the three operations listed above. It is illegal to directly recirculate the refrigerant back into the refrigeration circuit of the system.

EU 517/2014 Article 12 Labeling and information on products and devices

1. Products and equipment that contain or rely on fluorinated greenhouse gases may not be placed on the market unless they are labeled. This only applies to:

• refrigeration equipment;
• air-conditioning equipment;
• heat pumps;
• fire protection devices;
• electrical switchboards;
• aerosol dispensers that contain fluorinated greenhouse gases, with the exception of metered dose inhalers for the administration of pharmaceutical ingredients;
• all fluorinated greenhouse gas containers;
• solvents based on fluorinated greenhouse gases;
• organic Rankine cycles.

Which HFC devices need to be labeled?

The following should be marked:

(a) refrigeration products and equipment that contain perfluorocarbons or preparations containing perfluorocarbons;
b) refrigeration and air conditioning products and equipment (other than in motor vehicles), heat pumps, systems fire protection and fire extinguishers, if given type products or equipment contain hydrofluorocarbons or preparations containing hydrofluorocarbons;
(c) switchgear that contains sulfur hexafluoride or preparations containing sulfur hexafluoride; and
(d) all fluorinated greenhouse gas containers.

If we switch to EU Regulation 517/2014, the list will be longer:

Art. 12: 1.

Products and equipment that contain or rely on fluorinated greenhouse gases may not be placed on the market unless they are labeled. This only applies to:

a) refrigeration equipment;
b) air-conditioning equipment;
c) heat pumps;
d) fire protection devices;
e) electrical switchboards;
f) aerosol dispensers that contain fluorinated greenhouse gases, with the exception of metered dose inhalers for the
administration of pharmaceutical ingredients;
g) all fluorinated greenhouse gas containers;
h) solvents based on fluorinated greenhouse gases;
i) organic Rankine cycles.

The following records must appear:

Information that the equipment contains or uses fluorinated greenhouse gases or that its operation relies on them;
Industry labelling accepted for fluorinated greenhouse gas, or possibly chemical name;
From January 1, 2017 – the amount of F-gas contained in the device, or required by the device for operation, including the mass of the refrigerant, CO2 equivalent and the potential for contributing to the GWP of this operating medium.

This information must be included in the operating instructions for the device and, in the event of a GWP of 150 or more, also in advertising and offers. In the case of “hermetically sealed systems” * this must be stated on the label. The same applies to electrical switchgear with a stated leakage rate of less than 0.1% per year. The regulation contains specific labeling requirements for foamed plastics, polyol mixtures, recovered and treated F-gases, marketed for destruction or direct export, for the military, for the chemical, pharmaceutical and semiconductor industries.

The label must be clearly legible and indelible and located close to service access areas intended for the filling or recovery of fluorinated greenhouse gas, or on that part of the product or equipment containing the fluorinated greenhouse gas.

Labels must be written in the official language of the country in which the device is to be placed on the market. Additionally, the European Commission may adopt specific implementing provisions regarding the appearance of labels and implementing legal acts introducing amendments to the labeling obligation.

* “Hermetically sealed equipment” means equipment in which all parts containing fluorinated greenhouse gas are made tightly sealed by welding, brazing or other similar permanent connection, which may also include sealed valves or sealed service entrances that allow proper repair or disposal. and which have a tested leakage rate of less than 3 grams per year at a pressure of at least a quarter of the maximum allowable pressure;

Pursuant to Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006, art. 3 points 3, after repairing the leak, re-inspect within 1 month to make sure that the repair was effective.

In order to obtain the current model of a document confirming the leakage inspection, please contact PROZON employees directly.

How often should the devices be checked for leakage?

In accordance with the provisions of the Act of 15 May 2015 on ODS and F-gases (Journal of Laws of 2020, item 2065), we do not have to carry out leakage checks for devices containing controlled substances or fluorinated greenhouse gases in the amount below 3 kg (5 tons of CO₂ eq ) and hermetically sealed equipment containing less than 6 kg of fluorinated greenhouse gases (10 tonnes CO₂ eq).

Required frequency of leakage checks for equipment containing F-gases according to Regulation (EU) 517/2014

*does not apply to electrical switchgear

It is also worth remembering that these devices are subject to inspection for leaks within one month after the leak has been repaired, to ensure that the repair was effective.

YES.

A service technician can operate such a device without any legal liability. The operator who needs to insert the card is responsible for the lack of a card.

EUROPEAN UNION LAW (supplemented for the legal status as of December 31, 2021)

• REGULATION (EU) No. 517/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No. 842/2006
• COMMISSION IMPLEMENTING DECISION (EU) 2017/1984 of 24 October 2017 establishing, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council on fluorinated greenhouse gases, the reference values for the period from 1 January 2018. by 31 December 2020 for each manufacturer or importer that has lawfully placed hydrofluorocarbons on the market from 1 January 2015, notified in accordance with this regulation
• SPACE IMPLEMENTING REGULATION (EU) 2016/879 of 2 June 2016 establishing, pursuant to Regulation (EU) No 517/2014 of the European Parliament and of the Council, detailed arrangements for the declaration of conformity for the placing on the market of refrigeration, air conditioning and heat pump equipment filled with hydrofluorocarbons and these declarations have been verified by an independent auditor
• COMMISSION REGULATION (EC) No 1497/2007 of 18 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, standard leakage checking requirements for stationary fire protection systems containing certain fluorinated greenhouse gases
• SPACE IMPLEMENTING REGULATION (EU) 2015/2065 of 17 November 2015 specifying, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council, the form of notification of training and certification programs of the Member States SPACE IMPLEMENTING REGULATION (EU) 2015/2068 of 17 November 2015 establishing, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council, the form of labels for products and equipment containing fluorinated greenhouse gases
• SPACE IMPLEMENTING REGULATION (EU) 2015/2066 of 17 November 2015 establishing, pursuant to Regulation (EU) No 517/2014 of the European Parliament and of the Council, minimum requirements and conditions for mutual recognition of certification of natural persons performing installation, servicing, maintenance , repair or decommissioning of electrical switchgear containing fluorinated greenhouse gases or that recovers fluorinated greenhouse gases from stationary electrical switchgear
• COMMISSION REGULATION (EC) No 1516/2007 of 19 December 2007 establishing, pursuant to Regulation (EC) No 842/2006 of the European Parliament and of the Council, standard leakage checking requirements for stationary refrigeration and air conditioning equipment and heat pumps containing some fluorinated greenhouse gases
• COMMISSION IMPLEMENTING REGULATION (EU) 2017/1375 of 25 July 2017 amending Implementing Regulation (EU) No 1191/2014 specifying the format and manner of submitting the report referred to in Art. 19 of the Regulation (EU) No 517/2014 of the European Parliament and of the Council on fluorinated greenhouse gases
• SPACE IMPLEMENTING REGULATION (EU) No. 1191/2014 of 30 October 2014 specifying the format and manner of submitting the report referred to in Art. 19 of the Regulation (EU) No 517/2014 of the European Parliament and of the Council on fluorinated greenhouse gases
  Corrigendum to Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006
• SPACE IMPLEMENTING REGULATION (EU) 2015/2067 of 17 November 2015 establishing, in accordance with Regulation (EU) No 517/2014 of the European Parliament and of the Council, minimum requirements and conditions for mutual recognition of certification of natural persons with regard to stationary refrigeration equipment, air conditioning and heat pumps and refrigeration units for refrigerated trucks and trailers, containing fluorinated greenhouse gases, as well as company certification for stationary refrigeration, air conditioning and heat pump equipment containing fluorinated greenhouse gases Polish legal acts (supplement for the state as of December 31, 2021)

Announcement of the Marshal of the Sejm of the Republic of Poland of October 8, 2020 on the publication of the uniform text of the Act on substances that deplete the ozone layer and on certain fluorinated greenhouse gases

• REGULATION OF THE MINISTER OF THE ENVIRONMENT of 21 December 2017 on the Central Register of Operators, Item 2419 • ACT of July 12, 2017 amending the Act on substances that deplete the ozone layer and on certain fluorinated greenhouse gases and certain other acts
• REGULATION OF THE MINISTER OF DEVELOPMENT and FINANCE of November 7, 2017 on the indication of the entity performing the function of the certification body for entrepreneurs and the certification body for personnel
• REGULATION OF THE MINISTER OF DEVELOPMENT and FINANCE of 11 October 2017 on the additional examination required for refrigeration units of trucks and refrigerated trailers
• REGULATION OF THE MINISTER OF DEVELOPMENT AND FINANCE of December 7, 2017 on the minimum technical equipment appropriate for the performance of activities certified for personnel in the field of fluorinated greenhouse gases and controlled substances Pos. 2410
• REGULATION OF THE MINISTER OF DEVELOPMENT and FINANCE of December 7, 2017 on the minimum technical equipment, procedures and system for documenting activities related to the conduct of activities, consisting in installing, maintaining or servicing, repairing or decommissioning equipment containing fluorinated greenhouse gases Pos. 2417
• REGULATION OF THE MINISTER OF DEVELOPMENT AND FINANCE of December 7, 2017 on the examination and certification of personnel in the field of fluorinated greenhouse gases and controlled substances Pos. 2402
• REGULATION OF THE MINISTER OF DEVELOPMENT AND FINANCE of December 12, 2017 on the method of controlling compliance with the conditions for obtaining a certificate for entrepreneurs Pos. 2376
• REGULATION OF THE MINISTER OF DEVELOPMENT and FINANCE of December 7, 2017 on the template of the application for a certificate for entrepreneurs, the template of this certificate and its description, and the amount of unit fees charged by the certification body Pos. 2421

All entities listed in art. 50 sec. 5 of the Waste Act (Journal of Laws of 2020, items 797, 875, 2361): Article 50.1. The voivodship marshal makes an entry in the register upon the request of: 5) within the scope of this Act:

a) waste holders processing waste and exempt from the obligation to obtain a waste processing permit, with the exception of those listed in Article 45, paragraph 1, points 2 and 3,
b) transporting waste,
c) sellers of waste and waste brokers, unless they are entered in the register pursuant to points 1 and 3 or ex officio,
d) operating ship recycling facilities,
e) waste producers who are obliged to keep records of waste, with the exception of waste holders listed in Article 51 (1) (1) and (2);

he website  https://bdo.mos.gov.pl/ has a detailed training schedule for each month.
In case of problems, you can contact the BDO hotline https://bdo.mos.gov.pl/kontakt/.

Unless the contract between the operator of the device and the service company provides otherwise, pursuant to Art. 3 sec. 1 point 32 of the Act on waste, the producer of the waste (in the form of the recovered factor) is the service company performing the service.

The aste Act of December 14, 2012 [Journal Of Laws of 2013, item 21]

REGULATION OF THE MINISTER OF CLIMATE of September 11, 2020 on detailed requirements for the storage of waste