Yesterday, President Karol Nawrocki signed an amendment to the act on the national cybersecurity system. The act, prepared by the Ministry of Digital Affairs, is a key step towards raising the systemic level of cybersecurity in Poland by changing the approach to cyber infrastructure protection, which is crucial in view of the constant increase in threats in this area. We are pleased that Poland’s security is not a partisan issue and that solutions conducive to it gained support across the political spectrum during the legislative process.

The sugar tax was introduced in Poland in 2021 with the declared aim of reducing excessive sugar consumption and supporting public health efforts. The vetoed amendment focused primarily on a radical increase in tax rates, without introducing additional mechanisms that would demonstrably support broader public health objectives.

AmCham Poland supports the President’s decision, which is consistent with the key arguments underpinning our advocacy efforts.

We have consistently emphasized that while public health and reducing excessive sugar consumption are important policy priorities, further sharp increases to the sugar tax are unlikely to deliver proportional health benefits. At the same time, such measures risk generating negative economic consequences, particularly for employment and business stability.

Our position has highlighted that revenue projections related to the sugar tax do not sufficiently take into account declines in output, employment, and tax revenues from other sources. The proposed increase risked exacerbating these trends, with additional pressure on micro- and small enterprises involved in beverage retail, as well as on domestic agri-food producers whose perspectives were not adequately reflected during the legislative process.

We have also pointed out that Poland already applies one of the highest sugar tax rates in Europe. Further increases could place Poland at the top of EU rankings both in nominal terms and when adjusted for purchasing power, raising concerns about regulatory stability, predictability, and the overall business environment.

AmCham Poland remains committed to constructive dialogue and to supporting solutions that effectively address public health challenges without undermining jobs, economic resilience, and regulatory predictability for producers and the wider market, particularly when changes are introduced with very limited adjustment periods.

AmCham Poland has been actively working with member companies on the draft Packaging and Packaging Waste Act, which introduces a new Extended Producer Responsibility (EPR/ROP) system.

In early November, AmCham submitted a detailed position paper to the Chancellery of the President of Poland (Minister Karol Rabenda, Advisor Paweł Gruza). In our submission, we emphasized that the current draft:

• significantly limits producers’ influence over how the system operates, despite placing the full financial burden on them;
• over-centralizes financial flows within the National Fund for Environmental Protection and Water Management (NFOŚiGW), without ensuring adequate transparency or safeguards;
• risks creating double financial charges on the same packaging (ROP fee + SUP fee), without guaranteeing real environmental effectiveness.

We asked that these concerns be taken into account should the bill be submitted to the President for signature. Although a fast-tracked legislative process was initially anticipated, the draft has not yet been sent to Parliament.

The position paper is available here.

• the use of Polish-American relations to strengthen Polish security,
• the need for simplifications and changes in equipment procurement procedures, and
• the prospects for the development of Polish industrial potential.

Our chambers welcome the Ministry’s initiatives aimed at improving conditions for patients with rare diseases, including efforts to expand access to diagnostics and treatment, as well as the proposal to establish Rare Disease Expert Centres (OCER). At the same time, we noted several issues which, in the current form of the draft, may raise concerns about the effectiveness and practical feasibility of the proposed solutions.

In our submission, we highlighted several key points:

• overly general and cumulatively binding criteria for obtaining OCER status, which may significantly limit the number of eligible centres—particularly smaller institutions—and risk unequal patient access to specialised care;

• the absence of a statutory deadline for issuing the implementing regulation defining OCER requirements, which may delay the application of the new rules;

• the lack of incentives for institutions applying for OCER status, despite earlier announcements by the Ministry.

We asked the Ministry to reconsider these provisions to ensure that the system is both effective and workable in practice, ultimately improving access to specialised care for patients with rare diseases.

The proposed legislation directly affects AmCham member companies that place packaged products on the market. As it stands, the draft may significantly increase operating costs and consumer prices, while not necessarily improving the effectiveness of the recycling system.

In our position, we highlight several key issues.
First, the proposed model does not give producers a meaningful role in how the system operates, limiting their participation to paying a packaging fee — in practice functioning more as a levy.
Second, the draft centralizes decision-making and the management of funds within public institutions, without clear rules on transparency or oversight.
Third, the bill does not specify how the collected funds will be used, creating uncertainty for all stakeholders.

We also draw attention to the cumulative financial burden on producers, who would simultaneously bear the costs of the ROP fee, the SUP (Single Use Plastics) fee, and the upcoming deposit-return system. Taken together, this could lead to a system that increases public charges without delivering corresponding environmental benefits.

AmCham calls for renewed dialogue with the business community and for developing a market-based ROP framework in which producers participate in both governance and system oversight. Ensuring transparency, cost-effectiveness, and alignment with proven EU practices will be critical for achieving the goals of the reform.

The full text of the position can be found here.

1. Transforming the one-time obligation for producers to supply Track & Trace devices into a continuous obligation would shift ongoing operational costs onto producers, covering thousands of independent entities beyond their control. This is seen as disproportionate and risks regulatory uncertainty.
2. A proposed 50–60% increase in UID identifier fees is economically unjustified, given the legal tobacco sector’s significant fiscal contribution and Poland’s role as the world’s second-largest exporter. The increase could weaken competitiveness and impose additional burdens without improving market supervision.

AmCham recommends retaining the current wording of Article 10d(8) and withdrawing the planned UID fee increase.

The position paper is available here.