Expected Inspections of Producers Subject to EPR Obligations in 2026

According to the 2026 waste management inspection plan, this year producers subject to Extended Producer Responsibility (EPR) can expect comprehensive inspections of their registration, record‑keeping, data reporting, and fee‑payment obligations.

Businesses Concerned

The inspection may cover any producer engaged in the following activities:

• First domestic placing on the market of products subject to EPR;
• Distance selling carried out by a taxable person to private individuals;
• Self‑use of products;
• Withdrawal of products from a tax or product‑fee warehouse.

It is important to highlight that the inspection may also affect entities that are not producers themselves, but who acquire EPR‑regulated products from abroad and then place them on the Hungarian market for the first time or use them for their own purposes.

Scope and Conduct of the Inspection

The authority primarily examines the fulfilment of the following obligations and whether the data reported by the affected producers reflect reality.

Registration and record‑keeping obligations:
Producers subject to EPR must apply for registration with the national waste management authority for data‑reporting purposes and ensure the necessary registration on the MOHU platform.

Record‑keeping obligations:
After registration, producers must maintain records of their product and material streams subject to EPR in accordance with the legal requirements.

Data‑reporting obligations:
Based on the data in their records (product name, weight, 8‑digit KF code), producers must submit quarterly data reports by the 20th day of the month following the reporting quarter.

According to the 2026 inspection plan, in addition to random selection, targeted selection criteria may include data reports showing significant quantitative deviations compared to previous submissions, or reports that have been modified multiple times.

Inspections may be conducted by requesting the producer’s EPR records electronically, or by on‑site inspections. During on‑site inspections of retail stores, the authority may also contact the producer indicated on the product.

Due to the significant growth of e‑commerce, inspections will increasingly focus on economic operators selling goods online, particularly regarding registration and data reporting. Additional focus areas include businesses applying individual compliance, customer declarations, or assumption of obligations, as well as transactions involving these legal mechanisms.

Sanctions

Special attention should be paid to inspections and potential consequences this year, as the EPR sanctioning system effective from July 2025 clearly defines the conditions for fines and sets out the specific penalty amounts.

For example, in the case of false data reporting, if the producer pays the fee based on a lower quantity of circular products than the actual amount, the fine equals the difference between the actual and reported quantities multiplied by half of the applicable EPR fee rate for that product stream.

To avoid sanctions, it is advisable to seek expert assistance to determine obligations and to establish an appropriate record‑keeping system. Should you have any questions regarding the extended producer responsibility system, please feel free to contact Deloitte’s expert colleagues.