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Mandatory Deposit Refund System starts in Hungary in 2024

Mandatory Deposit Refund System starts in Hungary in 2024

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Mandatory Deposit Refund System (DSR) comes into effect as of 1 January 2024 in Hungary. The newly introduced legislation clarifies the key points of the system and the specific obligation of the parties concerned.

As a general rule, from a consumer’s perspective, deposit refund schemes charge users an extra fee when they buy a product, which is refunded if the product packaging is returned for recycling or reuse. Similar, but not unified schemes have already been implemented throughout the EU with Hungary joining in as of 1 January 2024.

The Mandatory Deposit Refund System will apply generally to the non-reusable or reusable packaging of ready-to-drink or concentrated beverage products, in the form of bottles or cans, plastic, metal or glass material, with a capacity of 0.1 to 3 litres (but excluding milk and milk-based beverage products). Small producers under 5000 covered products a year are exempted from the DSR obligation. Producers are also free and encouraged to extend the DRS voluntarily to additional items not covered by the mandatory DRS.

DRS will be operated and monitored by MOHU, a subsidiary of MOL Nyrt. as concessionaire.

Producers are required to register their products 45 days prior to placing those on the market and to pay connection fee and service fee for reusable products subject to a mandatory return fee, and a connection, service and return fee for non-reusable products to MOHU. With the introduction of DSR, EPR (extended producers’ responsibility) legislation has been also amended so that the EPR fee does not apply, where a DSR fee is due.

Distributors are required to accept and refund the products under DSR. In practice, for stores selling food with a sales area of more than 400 sqm, the return and refund should be made available via automatic reverse vending machine. Such machines, based on the request of the distributor, are to be provided by MOHU. The mandatory deposit of HUF 50 per non-reusable product will be charged and invoiced to and paid by the consumers and will be refunded upon return (deposit for reusable products will be set by the manufacturers).

The registration of producers and application for reverse vending machines was due earlier this year, but the registration for products is still open by 15 November 2013 and for voluntary DRS continuously going forward. 

By Bálint Zsoldos, Head of Tax, KCG Partners Law Firm

Hungary Knowledge Partner

DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa, and Asia Pacific. This positions us to help clients with their legal needs around the world.

With more than 60 lawyers, including 14 partners, and a staff of over 140, DLA Piper Hungary is one of the largest international law firms operating in Hungary. What makes us stand out is that we offer not only legal services but also tax and business advisory support in a fully integrated manner. We maximize synergies between legal, tax, and business advisory services to offer a unique service for our clients, particularly in regulated industries such as energy, infrastructure, life sciences, banking, and telecommunications.

We are a true full-service firm, providing our private and public sector clients with advice on all aspects of their business. This includes transaction-related advice, people and employment, commercial dealings, litigation, information technology, media and communications, intellectual property, insurance, tax, real estate, and restructuring plans.

DLA Piper Hungary has received numerous professional awards and is consistently ranked among the top law firms in Hungary by international rankings. We are ranked #1 by Mergermarket among the law firms active in Hungary based on the volume of M&A deals handled between 2005 and 2024.

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