Waste management consultancy – Extended Producer Responsibility (EPR)

The Hungarian waste management system has radically transformed with the introduction of the EPR fee.

In line with EU waste management directives, Hungarian waste management rules changed significantly from July 2023.  In addition to the environmental product charge, companies had to get familiar with a new term, as the extended producer responsibility affects a wide range of businesses. All companies concerned need to prepare in good time for the radical changes in the waste management system, as the new system imposed registration, record-keeping, and payment obligations on them.

The EU waste policy’s clear objective  is that the waste management activities required at the end of a product's life cycle – such as collection, treatment, recycling, and disposal – should be the responsibility of the producers of the product, including the payment obligations.

This is called the Extended Producer Responsibility (EPR) system. The Hungarian implementation follows the EU Directive and, through the introduction of extended producer responsibility, places related financing obligations on the producer of the product.

This fee is known as EPR fee in Hungary, and its due date in 2023 is the 20th of October.

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Which companies need to prepare for the new waste management system and the related fee?

• Companies engaged in production and trading.
• All companies involved in export/import activities.
• Service companies, including, in particular, those providing health care services.
• All companies that are currently subject to the product charge.

The EPR fee will be payable upon first domestic transfer of ownership of circular products, at the rate set out in the decree.

What is included in RSM’s comprehensive waste management consultancy and compliance service?

• Our experts review whether the extended producer responsibility provisions apply to the company or service provider.
• If the company is subject to the fee, our experts assist you in the EPR registration and in the establishment of a waste management product fee register.
• Our consultancy services include finding ways to optimize your EPR system.
• As part of our compliance consultancy, we can assist you with EPR filing and related obligations.
• Review of EPR records maintained by the company.
• Consultancy on regulatory reporting and compliance with the EPR filing obligation, as well as performing all administrative obligations.
• Keeping the company’s EPR records and preparing EPR returns based on data reported by the company.
• In addition to keeping records - if required - filing EPR returns and monitoring of the company's EPR obligations can also be included.
• For non-resident companies, fulfilling EPR obligations as an authorized representative.

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Frequently Asked Questions

EPR fee, EPR reporting: what is it and who is affected?

In line with the European Union’s waste management directives, Hungarian waste management rules also changed significantly from July 2023. In addition to the environmental product charge, companies had to become familiar with a new concept, as extended producer responsibility affects a wide range of business entities. All companies concerned had to prepare for changes in the waste management system, as the new EPR scheme imposed new registration, record-keeping and fee payment obligations on businesses.

A key principle of EU waste policy is that waste management activities required at the end of the life cycle of certain products – such as collection, treatment, recycling and disposal – should be the responsibility and financial obligation of the manufacturers and producers of those products.

In the field of extended producer responsibility, the Hungarian approach follows the relevant EU directive and, through the implementation of the EPR scheme, places the financing obligation on the manufacturer or producer of the product. In Hungary, the EPR fee and the related EPR reporting obligation introduced in 2023 became applicable from 20 October 2023.

When should EPR reporting be submitted, and what happens afterwards?

Companies subject to EPR must submit data on the circular products they place on the market on a quarterly basis. Based on the quarterly data reporting, MOHU will subsequently assess and invoice the payable EPR fee. In practice, EPR is therefore not limited to a one-time registration: proper internal records, correct product classification and accurate data reporting are all essential conditions for companies to comply with their obligations lawfully and with minimal risk.

What are the consequences if a company fails to complete EPR registration or submits incorrect data reporting?

Failures related to EPR involve serious compliance, inspection and penalty risks. Companies that place EPR-subject products on the market but fail to register, do not maintain proper records, or submit incorrect data may be required not only to settle the unpaid fee, but may also face penalties. In the event of incorrect or omitted data reporting, the sanction may reach up to 50% of the unpaid or underpaid EPR fee. It is therefore particularly important for affected companies to identify their EPR exposure in time and to fulfil the related administrative obligations continuously and in a properly documented manner.