We have arrived at the next phase of the extended producer responsibility (EPR) system, which was introduced in 2023 and analysed in our series of articles, since the deadline for complying with EPR data provision obligations passed on 20 October 2023.
Data on the first circular products placed on the domestic market by producers were to be submitted via the OKIR interface between July and August 2023. The Government Office (Waste Management Authority) transferred such data to MOHU, the concession holder.
Based on the data received, MOHU started to issue the first invoices on the EPR fee to producers. The concession-holder will issue an invoice on the fee element due to them, and an accounting document on the fee element to be paid to the municipalities; it will hold the latter on a separate account and, once received, it will transfer the amount to the relevant local municipality.
Such documents include the KF codes provided by the producers in the course of data provision and the EPR fee codes assigned to them, as well as the quantitative data. Based on the experience to date, MOHU has determined the fee codes and the amount of the EPR fee to be paid by the relevant producer in accordance with the EPR Regulation; however, we strongly recommend checking each item on the documents.
Should the EPR fee be determined based on the provision of incorrect data by the producer, you may request the concession-holder to revise the fee to be paid by sending the correct data simultaneously to the concession-holder and the national waste management authority (Government Office of Pest County) within 15 days after receiving the invoice. Submission of a revision request has a suspensory effect on the payment of the invoice.
The fee indicated on the accounting documents must be paid to the bank account numbers of MOHU indicated on such documents within 15 days after receipt, in accordance with the relevant provision of the EPR Regulation. Pursuant to MOHU’s request, the serial number of the relevant accounting document must be indicated in the comment section.
Based on the first invoices, we can see that the EPR fees are quite high, in accordance with our expectations. Since the fees are not expected to decrease within the foreseeable future, it is of utmost importance that all tax payers develop their EPR processes in the most efficient way possible. In the EPR system, there are several possibilities for simplification and exemption, and according to our experience, it is often the wrong interpretation of the legislation that causes undue fee increases.
If you need any professional assistance, the Andersen team is ready to help at any time.