The EPR system has been amended for the benefit of small food producers and primary agricultural producers
The new year has brought simplified administration and a one-time annual EPR payment obligation for small food producers and primary agricultural producers who do not reach the revenue ceiling. Thanks to the cooperation of the National Chamber of Agriculture and the Ministry of Energy, the government decree on the extended producer responsibility system has been amended.

(Photo: Pixabay)
Taking into account the proposals of the National Chamber of Agriculture (NAK), Government Decree 80/2023. (III. 14.) on the detailed rules for the operation of the extended producer responsibility system has been amended. Thanks to the cooperation of the Ministry of Energy and the NAK, numerous simplifications have come into effect for small food producers and primary agricultural producers who do not reach the revenue ceiling regarding the declaration and payment of EPR fees. Thanks to the amendment, small producers involved in small-scale, local and marginal food production and sales, as well as primary agricultural producers who do not reach the income ceiling specified in the regulation, can choose simplified administrative rules. The simplification means a single, simplified data provision per year, according to the material of the main packaging component, in addition to an annual extended producer responsibility fee payment in accordance with the general fee schedule.
In the case of choosing simplified administration, registration with the national waste management authority is not required
Regardless of this, the provision of the data specified in the law on the electronic interface operated by the concession company is also mandatory for small producers and primary producers. During the annual data provision, the National Environmental Information System (OKIR) requires the data provision to specify the category of the main packaging component material flow for the given consumer, collective or transport packaging, and the extended producer responsibility fee must be paid based on this. This means that a small producer who, for example, only sells honey in glass – with a paper label and a metal lid – only pays the extended producer responsibility fee based on the glass material flow. At the same time, a small producer who sells several bottles of honey in a paper box at the same time is also liable for the extended producer responsibility fee for the paper box as collective packaging, in addition to the consumer glass packaging.
NAK
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