Embracing Change: Hungary’s New Waste Management Landscape

Becher & Torma
Mar 22, 2024
3 min read

Updated: Mar 27, 2024

In the latter half of 2023, Hungary's waste management system underwent significant transformation.

One of the most pressing issues of our time is the mismanagement of waste. Over recent decades, the collective volume of waste generated by households, institutions, and industries has surged. However, a significant portion of this waste fails to undergo reuse, recycling, or energy recovery processes. As a result, it continues to burden our environment, posing a threat to our collective future.

Recognizing this pressing issue, the European Union has set forth strict directives urging member states to prioritize waste reuse and integration into the circular economy.

In the latter half of 2023, Hungary's waste management system underwent significant transformation in line with European Union waste regulations. Under the new concession system, the Extended Producer Responsibility (EPR) framework places financial responsibility on manufacturers throughout a product's lifecycle, from its creation to its management as waste.

1. WHAT IS EPR? __________________________________________________________

The introduction of the EPR system is aimed at promoting the circular economy model. In Hungary, the EPR system operates through the MOHU MOL Waste Management Ltd., with the concessionaire responsible for fulfilling waste management obligations

collectively.

One important element of the EPR system is the obligation to pay EPR fee.

2. WHO IS AFFECTED? _____________________________________________________

The following entities are obliged to pay EPR fee:

▪ The producer of the circular product,

▪ The entity that first introduces the circular product into circulation within the territory of Hungary as part of its economic activity (if the product is not produced within the territory of Hungary).

3. WHICH PRODUCTS ARE AFFECTED? ______________________________________

Manufacturers bear financial responsibility for waste management following the

transformation of their products into waste.

EPR fee responsibility arises in connection with ‘circular products’. The term ‘circular

products’ involves:

▪ packaging materials,

▪ disposable plastic products,

▪ electrical and electronic equipment,

▪ batteries, accumulators,

▪ vehicles,

▪ tires,

▪ office and promotional paper,

▪ used cooking oil and fat,

▪ specific textile products,

▪ wooden furniture.

4. WHEN DOES THE PAYMENT OBLIGATION ARISE? ________________________________

The EPR fee is payable following the ‘commercialization’ of circular products in Hungary.

For the purposes of payment of the EPR fee, inter alia, the following are considered as

‘commercialization’:

▪ the first domestic ownership transfer of a circular product, whether free of charge or

for consideration, including the ownership transfer as an accessory or component of

another product,

▪ the ownership transfer of a circular product from abroad to Hungary as an

electronic commerce service to domestic households or other users, including the

ownership transfer as an accessory or component of another product,

▪ private use, or

▪ the removal of the product from a tax warehouse.

5. ENSURING COMPLIANCE: REGISTRATION AND REPORTING _______________________

EPR obligations involve registration, record-keeping, and payment responsibilities.

Affected entities must register on the MOHU Waste Management Portal to facilitate direct communication. Additionally, individual fulfillers can initiate contracts for individual

performance here.

Regarding activities subject to EPR fee, manufacturers or their authorized representatives must apply for registration with the waste management authority before commencing operations. Subsequently, they must submit quarterly quantitative data reports to the authority.

6. EPR FEE VS. ENVIRONMENTAL PRODUCT FEE __________________________________

Despite the substantial coverage of EPR fee, the environmental protection product charge (EPPC), subject to similar regulation as the EPR fee, remains in place. Administrative obligations such as record-keeping and declaration persist under the EPPC, even though EPR fee covers a significant portion of goods subject to the EPPC.

7. OUR SERVICES ____________________________________________________________

Becher &Torma's experienced professionals provide comprehensive EPR advisory services to support clients in ensuring maximum compliance with regulatory expectations.

Our services include:

▪ Expert Assessment: Our expert colleagues examine whether a product is subject to EPR obligation and determine if EPR requirements apply to the specific company or service provider.

▪ Registration, Compliance, Reporting and Declaration Assistance: Our experts assist in completing the EPR registration, as well as in establishing the EPR fee registry. As part of

compliance advisory, we assist in fulfilling EPR declarations and other obligations and provide advisory services regarding the entire administrative process related to authority data reporting and EPR declarations.

▪ Representation for Foreign Companies: We act as authorized representatives for fulfilling EPR obligations for foreign economic entities.

▪ Optimization Analysis: Within the scope of our consulting services, we assess potential optimization opportunities related to EPR.

If you have any questions, please contact our colleagues directly：