In 2023, Hungary introduced the Extended Producer Responsibility (EPR) system, which places the financial responsibility for the waste management of circular products on producers. The EPR system encompasses a wide range of product streams, including packaging, single-use and other plastic products, electrical and electronic equipment, batteries and accumulators, motor vehicles, tyres, office paper, advertising paper, cooking oil and fat, textile products and wooden furniture. Producers, or in the case of foreign manufacturing, the first domestic distributor of such products, are required to comply with registration, reporting and EPR fee payment obligations.
From dual obligations to sole EPR compliance
A significant recent change in the regulatory framework is the
removal of the dual obligations that previously applied to certain
products. Prior to the recent amendments, products such as
packaging, batteries, electrical and electronic equipment, tyres,
office paper and advertising paper were subject to both the
environmental product fee and the EPR system. These parallel
responsibilities created an excessive compliance burden for the
affected businesses while securing no additional tax income for the
state budget.
With the recent revisions, the environmental product fee payment
obligation has been eliminated for these products, and producers
are now only required to comply with the EPR system. While this
simplifies the regulatory landscape by removing overlapping
obligations, it also places greater emphasis on ensuring compliance
with the EPR rules.
Changes in sanctions for non-compliance
Failure to meet the EPR registration, reporting or fee payment
obligations can result in substantial financial penalties.
Businesses that fail to register are required to pay retroactive
EPR fees for the products placed on the market before
registration.
Another key change introduced by the amendments is the imposition
of stricter sanctions for non-compliance with EPR reporting and fee
payment obligations. Effective from 1 April 2025, if a producer
fails to meet its reporting and fee payment obligations, or if
false data is provided leading to a lower fee payment, the
competent waste management authority may impose a fine. This fine
will be determined by multiplying the difference between the actual
quantity and the reported quantity by half of the unit fee
established for the relevant product stream. Thus, fines can
quickly escalate, especially for businesses with large product
volumes.
Timely registration, accurate reporting and diligent EPR fee
payments are essential to avoid significant fines and penalties. As
Hungary's EPR system continues to evolve, seeking legal advice
and proactively managing compliance will be critical to mitigating
financial and reputational risks.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
