After the EPR scheme, the next element of the circular products, the mandatory deposit-refund system, a.k.a. as deposit-return scheme (DRS), will soon be in effect. 

Mandatory deposit-return scheme in Hungary coming into force

 Although the complete enforcement of Government Decree 450/2023 (X.4) will not take place until 1 January, certain provisions of the Decree have already entered into force on 1 November 2023 and manufacturers will be subject to obligations from 15 November 2023.

What is effected by the deposit-return scheme

The DRS system will affect glass, metal and plastic bottles and cans (0.1 to 3 litres capacity), except for milk and milk-based drinks packaging. 

In addition to the products that are compulsorily covered by the scheme, manufacturers may also voluntarily treat certain products as subject to a return fee. 

The rate of the DRS fee is fixed by law at HUF 50 per item for non-reusable products subject to the mandatory DRS.

Participants of the deposit-return scheme

The participants in the DRS are: manufacturers, distributors, consumers, public authorities (e.g. the national waste management authority) and MOHU Zrt. as the concession company.

Among the obligations of producers, the following should be highlighted. Manufacturers must register their products on the electronic platform of MOHU Zrt. at least 45 days before placing them on the market. In addition, they are also obliged to pay a monthly DRS fee for the mandatory products subject to the deposit-return scheme placed on the market, and a quarterly connection and service fee to MOHU Zrt. who will take over the DRS products from distributors and consumers.

In some cases, distributors are obliged to operate an automatic reverse machine in exchange for a handling fee under an agreement with the concession company, or to take back the products from consumers (grocery stores must operate a reverse machine in areas larger than 400 square metres and in municipalities with a population of more than 1,000 people)..

Consumers are essentially refunded the DRS fee paid in advance for the products they drop off at the exchange points, which they will receive a voucher for (usable for later purchases). To do so, they must return the product intact and with a legible marking.

MOHU Zrt. receives the DRS fee from the manufacturers and takes care of the implementation and operation of the system. The public authorities (e.g. the national waste management authority) monitor the operation of the system.

The relationship between EPR, product charges (green tax) and DRS is somewhat clarified in the legislation: where connection and service charges are payable, no EPR charges are due. 

However, for DRS products, the environmental product charge (green tax) cannot be deducted for now.

Ildikó Hajnal-Balázs

Senior Tax Consultant | Accace Hungary

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+36 141 235 30

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