On 1 April 2025, the amendment to Government Decree 271/2001 (XII. 21.) on the amount, imposition and determination of waste management fines entered into force. Under this amendment, undertakings who fail to fulfill or improperly fulfill their quarterly Extended Producer Responsibility (EPR) obligations may face strict fines.
The EPR system was introduced in July 2023. Until now, failure to meet data reporting obligations, or the improper fulfillment of obligations in general, did not result in strict sanctions. The amendment aims to ensure that undertakings comply with their EPR obligations as accurately and punctually as possible.
Under the amendment, an undertaking that fails to report data on the quantity of circular products it places on the market — thereby failing to fulfil its EPR fee payment obligation — will pay a fine determined by multiplying the actual quantity and half of the unit fee set for the given product stream.
If an undertaking provides false data concerning the quantity of circular products and thereby pays less EPR fees than are due, the fine calculation is based on the difference between the actual and reported quantity, multiplied by half of the unit fee.
If an undertaking commits the above-mentioned violations for multiple products, the different fine amounts are added together.
If the material stream of the circular product cannot be clearly identified from the undertaking’s records, the authority will determine the fine based on the highest EPR fee rate.
To avoid the risk of a fine, KPMG experts are available to assist with Extended Producer Responsibility obligation compliance, as well as the fulfilling of data reporting requirements.
