Ten entities have established the Employers' Association of the Circular Economy and Recycling (ZPGOZiR) and have started the process of registering it in the National Court Register. The new organisation is intended as a response to increasing regulatory complexity, the fragmentation of the sector's voice and the need for a permanent, knowledge-based dialogue on the future of the circular economy and recycling system in Poland. The Association is founded on entities involved in actual processing and material recovery, and its development is to be open and staged. The mission of ZPGOZiR is to create regulatory and market conditions that ensure system efficiency, resource security and stable development of the circular economy and recycling sector.
ZPGOZiR has been designed as an operational organisation focused on a tangible contribution to regulatory dialogue. Its operating model is based on three pillars: legislation, analytics and communication. This means constant monitoring of legal changes, building fact-based arguments and a structured presentation of the sector's positions to the administration, regulators, the market and the public. The Association aims to be a permanent dialogue partner in matters that determine the feasibility of the system, processing quality, data transparency and predictability of business conditions in the sector. In the founders' view, the processing stage is gaining particular importance today, as this is where, in practice, the effectiveness of the system is verified, including collection and recovery rates, economic efficiency and the actual environmental effect. ZPGOZiR intends to strengthen the understanding of the role of processing as an element of infrastructure of public importance, crucial for the resilience of the economy and Poland's resource security.
Operational processing perspective at the centre of the dialogue
The new organisation emphasises the importance of the processing stage as the point where both the strengths and limitations of current system solutions become visible. It is at the level of processing and recycling plants that the regulatory assumptions concerning separate collection, recovery and recycling targets, as well as the quality of waste streams directed to further material recovery, are verified. In this context, processing is treated as part of system infrastructure of public importance, rather than merely the final stage of the value chain.
The founders of ZPGOZiR stress that stable and transparent operating frameworks for the circular economy are increasingly important for the country's resource security. This also applies to sectors that intensively use secondary raw materials, including plastics processing, which relies on the availability of recyclates with predictable quality and quantity parameters.
Mission and pillars of ZPGOZiR's activities
According to the founders, the Association is to focus on issues that directly affect the feasibility of the circular economy system, processing quality and data reliability. The organisation declares that its activities will be based on a three-pillar model covering legislation, analytics and communication.
In the field of legislation, ZPGOZiR announces continuous monitoring of legal changes, analysis of their impact on the sector and preparation of solution proposals based on the operational experience of its members. The aim is to formulate comments on draft regulations in such a way that they are ambitious yet realistic and implementable at the level of processing plants.
In terms of analytics, the Association wants to base its positions on data and facts derived from actual processing operations. This should allow a better reflection of the market situation and the functioning of the system in practice, including in the context of collection rates, recycling efficiency and the quality of secondary raw materials placed on the market.
The third pillar of activity is to be communication, understood as a structured presentation of the sector's positions to system stakeholders, including public administration, regulators, market participants and the public. The Association wants to act as a dialogue partner on issues of systemic importance that affect the predictability of business conditions in the circular economy and recycling sector.
Founders' perspective: practice of processing plants
In the statements of the members of the Founding Committee, the need to include the operational perspective in the debate on the shape of legislation is highlighted. Mirosław Baściuk, a member of the Founding Committee of ZPGOZiR in organisation, points to the importance of stable regulatory frameworks for the functioning of the sector and the country's resource security.
"ZPGOZiR was created to build a permanent, structured and knowledge-based voice for the sector and to co-create solutions for the circular economy system. We believe that effective regulatory dialogue should be based on operational experience and real information from processing. This is where you can see how the system works in practice. Stable and transparent circular economy frameworks are now important not only for market development but also for Poland's resource security," says Mirosław Baściuk.
Baściuk has over 20 years of experience in the recovery and recycling sector. He has built and managed processing plants and created from scratch take-back organisations for electrical and electronic equipment and packaging. Such experience is important for the practical assessment of the feasibility of regulatory solutions and their impact on the day-to-day operation of installations.
Katarzyna Olszewska-Bolko, a member of the Founding Committee of ZPGOZiR in organisation, points to the importance of day-to-day operational experience in assessing the effectiveness of system mechanisms.
"We want to bring an operational perspective to the debate on the circular economy, resulting from day-to-day process management, logistics and plant operations. It is at this level that you can see which solutions work in practice and which require adjustment. This makes it possible to design regulations that are ambitious, realistic and feasible at the same time," emphasises Katarzyna Olszewska-Bolko.
Olszewska-Bolko has nearly 20 years of experience in the recycling and waste management sector. She specialises in operational and logistics management and in building structures in the waste electrical and electronic equipment processing sector. Her perspective is in line with the Association's declared focus on solutions that can be implemented in the practice of processing and recycling plants.

Openness to different waste streams and market participants
At the stage of establishing the organisation, the founders' main experience concerns the area of waste electrical and electronic equipment (WEEE) and battery processing. However, from the outset ZPGOZiR assumes development in other circular economy streams and in horizontal areas that affect the entire system regardless of the type of material processed.
The Association declares openness to additional processing plants, recyclers, system operators, secondary raw material market participants, industries using recyclates, as well as technology and infrastructure companies. Cooperation is to be based on shared system objectives, readiness for responsible dialogue and acceptance of the central role of efficient processing in the entire circular economy system.
Key regulatory challenges identified by ZPGOZiR
The founders of ZPGOZiR identify several areas that require further streamlining and in-depth regulatory dialogue. These include, among others, the lengthiness of administrative proceedings, inconsistent interpretation of legal provisions and the further development and functionality of the BDO system. The need to ensure the proportionality of sanctions and to increase the transparency of the entire system is also highlighted.
In the organisation's view, strengthening the awareness of the role of processing as part of system infrastructure is also of key importance. This covers both environmental and economic aspects, including the impact of the quality and stability of processing installations on resource security and the ability to achieve the required recovery and recycling levels.
The Association announces efforts to support regulatory stability, structured dialogue with the administration and regulators and improvements in data quality, which form the basis for responsible market and public decisions. Reliable and consistent data from the processing stage are important both for reporting recycling levels and for planning investments in infrastructure and processing technologies, including material recycling of plastics.
Need for a structured sector voice
Henryk Derewenda, a member of the Founding Committee of ZPGOZiR in organisation, points to the previous fragmentation of the sector's voice and its consequences for the shape of regulations.
"For years the sector has often acted with a fragmented voice. Today, there is a need for an organisation that will structure key systemic issues and translate entrepreneurs' experience into concrete solutions for the system. We want to build an Association that is open, responsible and rooted in market realities," adds Henryk Derewenda.
Derewenda is an entrepreneur with more than 20 years of experience in the waste management and WEEE processing sector. He specialises, among other things, in the processing of refrigeration equipment and in organising collection systems for waste electrical and electronic equipment. Including such a perspective is intended to better translate market practice into the design of systemic solutions.
The founders of ZPGOZiR emphasise that the organisation's objective is to build a responsible, substantive and long-term dialogue on the circular economy and recycling system. This is to be done with respect for the principles of competition and with a view to greater transparency, feasibility and resilience of the entire system. The Association is to serve as a cooperation platform for entities that wish to actively co-shape the rules of market functioning, including in the field of processing and recycling of waste containing plastics.
