Stricter sanctions, reduced administration – the EPR background rules have been amended

By: Trademagazin Date: 2025. 02. 20. 10:22

At the end of 2024, the legislative amendments announced in the Hungarian Gazette significantly transformed the existing regulations on extended producer responsibility (EPR) and product fees. The changes are multifaceted, as they not only reduce the administrative burden on companies but also clarify the sanctioning system related to the EPR framework and redefine the relationship between the product fee and EPR.

Gábor Zoltán

In Hungary, the extended producer responsibility (EPR) system came into effect on July 1, 2023. Since its introduction, the new waste management regulations have imposed a dual administrative burden on affected companies, as they were required to comply with both the product fee obligations and the related quarterly declarations in addition to the EPR system. A legislative amendment announced in December 2024 eliminated this duality as of January 1, 2025, by removing from the product fee those products that also fall under the EPR framework.

“Perhaps the most important outcome of the year-end changes is that the legislator introduced a sanctioning system related to EPR fee payments by amending the government decree on waste management fines. The significance of this lies in the fact that although EPR fees are subject to rules similar to taxes, they are classified as service fees rather than taxes, meaning that the usual tax penalties were not previously applicable.”

– added Gábor Zoltán, Partner at Deloitte’s Tax Department.

Kovács István

According to the amended government decree, if a manufacturer fails to provide data or submits incorrect data regarding the quantity of circular economy products it places on the market, the fine imposed will amount to half of the missing EPR fee. If the deficiency cannot be precisely determined by material type (e.g., biodegradable plastic or paper), then the highest applicable fee rate for the affected packaging must be used.

“Further changes and significant reliefs were introduced through the December amendment to the EPR decree. For example, a favorable change for manufacturers is that they now have an additional month to modify data reports for specific quarters.”

– added Kovács István, Manager at Deloitte’s Tax Department.