Why Does the Waste Transfer Note Matter When Selling Scrap Metal?
Every company that generates scrap metal in the course of its operations — whether it is a car workshop, manufacturing plant, construction firm, or service business — is legally considered a waste producer under Polish law. Steel scrap, cast iron, non-ferrous metals, structural components, and end-of-life machinery are all classified as waste subject to record-keeping. This obligation stems from the Waste Act of 14 December 2012 and applies to every entity required to register in the BDO system (the Database of Products, Packaging and Waste Management).
The document that confirms the transfer of waste to another entity — such as a scrap yard — is the Waste Transfer Note (KPO). Issuing and approving it correctly in the BDO system is not merely a box-ticking exercise; it is part of your official documentation and may be inspected by the Environmental Protection Inspectorate. Below, we outline how this process works in practice.
Who Is Required to Issue a KPO?
The obligation to issue a KPO rests with the waste transferor — typically the company that has generated the scrap and wishes to hand it over to a scrap yard. The conditions that trigger this obligation are:
- holding an active entry in the BDO register (BDO registration number),
- generating waste in connection with a business activity,
- transferring waste to an entity that holds the appropriate permit for collecting or processing waste.
A scrap yard such as Scrap Metal Poznań — EURO-SCRAP Group operates under the relevant administrative decisions and holds its own BDO number as a waste collector. This means that as the waste producer, it is your responsibility to initiate the note, while the scrap yard is responsible for confirming it.
KPO Step by Step — From Waste Generation to Approval
Step 1. Log In to the BDO System
Go to rejestr-bdo.mos.gov.pl and log in to the waste records module using a trusted profile, e-ID, or BDO system account. Make sure you are operating under the correct place of business activity (i.e., the waste generation site).
Step 2. Create a New Waste Transfer Note
In the records panel, select 'Waste Transfer Note' and click 'Add KPO'. The form requires you to enter:
- the waste code and type — e.g. 17 04 05 (iron and steel), 17 04 01 (copper, bronze, brass), 17 04 07 (mixed metals),
- the waste mass — expressed in tonnes (Mg), to three decimal places,
- the details of the receiving entity — i.e. the BDO number and address of the scrap yard,
- the planned transport date.
Step 3. Approve the KPO as the Producer and Dispatch the Transport
Once the form is complete, you approve the note as the waste producer — the system then assigns it a number. From this point, the driver collecting the scrap must have access to the KPO number or a printed copy of the note. If you are using the scrap yard's own transport (e.g. the HDS crane truck service provided by EURO-SCRAP), the HDS driver may confirm the waste handover themselves, provided they hold the appropriate authorisation and their own BDO transporter number.
Step 4. Weighing on a Certified Scale
The waste mass entered in the KPO must correspond to the actual weight of the scrap transferred. At the scrap yard located at ul. Górecka 6 in Poznań, a certified weighbridge with a capacity of 50 tonnes is available, which issues a weight ticket showing the precise mass. It is this measured figure — not an estimate — that should be entered into the KPO as the actual mass transferred. If an estimated weight was used when creating the KPO before loading, it must be corrected after weighing, before the scrap yard confirms receipt.
Step 5. Confirmation of Receipt by the Scrap Yard
After accepting and weighing the scrap, the scrap yard — as the waste receiver — confirms receipt in the BDO system. The note's status changes to 'approved by the receiving party'. Only at this point is the KPO complete and constitutes a fully valid record document for both sides of the transaction.
Step 6. Archiving and Entry into Waste Records
An approved KPO automatically feeds into your annual waste records in the BDO system. Based on it, you complete your annual waste generation report, which must be submitted by 15 March for the preceding year. Transfer notes must be retained for 5 years from the date of issue.
The Most Common Mistakes When Issuing a KPO for Scrap Metal
- Incorrect waste code — for example, entering a code from group 16 (end-of-life vehicles) instead of group 17 (construction and demolition waste) or group 12 (metal machining waste). Always verify against the waste catalogue.
- Estimated mass left uncorrected — if you entered a mass before weighing, update it after receiving the weight ticket, before the scrap yard confirms the note.
- Missing BDO number for the transporter — if the scrap is collected by a transport company or the scrap yard's HDS vehicle, that entity must appear in the KPO as the transporter with its own BDO number.
- KPO not confirmed by the receiving party — a note completed only by the waste producer, without confirmation from the scrap yard, is not a complete document and may be challenged during an inspection.
- Confirmation deadline exceeded — the receiving party is obliged to confirm receipt in the BDO system promptly, no later than 10 working days from the date of waste handover.
When Is a Company Not Required to Issue a KPO?
Not every scrap seller is obliged to issue a KPO. Private individuals not engaged in business activity, as well as small-scale producers exempt from BDO registration (e.g. entities generating only municipal waste), may hand over scrap without BDO documentation — in such cases, a standard proof of purchase issued by the scrap yard is sufficient. If you are unsure whether your company is subject to the waste recording obligation, it is worth reviewing your environmental decision or consulting with the waste-receiving entity.
How EURO-SCRAP Supports Businesses Through the BDO Process
The scrap yard in Poznań at ul. Górecka 6 serves both individual customers and businesses from the Greater Poland region that regularly dispose of furnace-grade and non-furnace steel scrap, engineering and commercial cast iron, and non-ferrous metals. For companies, a key advantage is that after weighing on the 50-tonne weighbridge, they receive a weight ticket — the document that forms the basis for entering the precise mass in both the KPO and the invoice. The service covers both self-delivery and container placement (5–36 m³) on the client's premises, as well as scrap collection by HDS crane truck from Poznań and across the Greater Poland region.
Businesses in the region can also take advantage of local collection services — for example, companies near Konin can use scrap metal collection in Kleczew, while those near Gniezno have access to scrap metal collection in Witkowo. South of Poznań, there is a service point covering scrap metal collection in Plewiska and Skórzewo, and to the east of the region — scrap metal collection in Kórnik and Gądki. This means the KPO can be issued against the correct receiving location, simplifying documentation for businesses operating outside Poznań city centre.
Summary — Key Takeaways
- The KPO is issued by the waste producer before handing over scrap to the scrap yard.
- The waste code, mass, and receiving entity details must accurately reflect the actual situation.
- The mass entered in the KPO should be based on weighing at a certified scale — the weight ticket serves as confirmation.
- The note is only complete once it has been confirmed by the scrap yard in the BDO system.
- Waste records documentation must be retained for 5 years.
If you would like to find out more about the types of metals accepted by EURO-SCRAP and how pricing works, visit the full EURO-SCRAP scrap metal and non-ferrous metals buying offer.
