COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - HUNGARY Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Hungary, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 259 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       Country Report - HUNGARY               Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Hungary  1 

This report has been written by the staff of the Directorate-General for Environment, European Commission. Comments 
are welcome. Please send them to ENV-EIR@ec.europa.eu. 

More information on the European Union is available at http://europa.eu. 

Photographs: 

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Hungary  2 

Table of contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 9 
Nature protection and restoration ....................................................................................................................... 9 
Ecosystem assessment and accounting ............................................................................................................. 15 
3. ZERO POLLUTION ..................................................................................................................................................... 17 
Clean air ............................................................................................................................................................. 17 
Industrial emissions ............................................................................................................................................ 18 
Preventing major industrial accidents – Seveso ................................................................................................. 21 
Noise .................................................................................................................................................................. 22 
Water quality and management ........................................................................................................................ 23 
Chemicals ........................................................................................................................................................... 27 
4. CLIMATE ACTION ..................................................................................................................................................... 29 
Key national climate policies and strategies ...................................................................................................... 29 
Effort sharing target ........................................................................................................................................... 29 
Key sectoral developments ................................................................................................................................. 30 
Use of revenue from the auctioning of EU ETS allowances ................................................................................ 31 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 32 

5. FINANCING ............................................................................................................................................................. 32 
Environmental investment needs in the European Union .................................................................................. 32 
EU environmental funding 2014-2020 ............................................................................................................... 33 
EU environmental funding 2021-2027 ............................................................................................................... 35 
National environmental protection expenditure ................................................................................................ 37 
Green budget tools ............................................................................................................................................. 38 
Environmental financing versus financing needs ............................................................................................... 40 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 42 
Information, public participation and access to justice...................................................................................... 42 
Compliance assurance ........................................................................................................................................ 44 
Effectiveness of environmental administrations ................................................................................................ 45 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 46 
TAIEX EIR peer to peer projects .......................................................................................................................... 47 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
Hungary  3 

Executive summary

In  previous  environmental 
implementation  reviews 
(EIRs),  the  Commission  identified  three  main  challenges 
for Hungary's implementation of EU environmental policy 
and law. These three challenges were to: 

  consider  using  effective  economic  instruments  to 
on 
improve  waste  management, 
implementing  separate  collection  obligations  to 
increase the recycling rate and improve the extended 
producer responsibility systems; 

focusing 

  reduce  particulate  emissions  from  solid-fuel  burning 
in households, and introduce short-term measures to 
reduce car emissions in urban areas; meet the targets 
set in the new National Emissions Ceiling Directive for 
2020- 2029 and any year from 2030; 

  adopt  management  plans  for  all  Natura  2000  sites 

and ensure their proper implementation. 

There  has  been 
little  to  no  progress  on  waste 
management.  After  an  upward  trend,  municipal  waste 
generation  slightly  decreased  in  2020.  However,  the 
recycling  rate  has  also  decreased  at  the  same  time. 
Hungary remains below the EU average, and more effort 
is needed to reach EU post-2020 targets. 

On water management, there has been limited progress. 
Hungary’s  water  bodies  are  exposed  to  many  pressures 
from  human  activities  and  agriculture,  with  negative 
implications  on  human  health,  water  quality  and 
quantity,  nature  conservation,  and  climate  adaptation. 
There has been a significant decrease in releases of heavy 
metals,  but  levels  remain  high  for  other  pollutants. 
Hungary  still  registers  bad  water  quality  in  several  parts 
of  the  country  and  is  among  the  Member  States  facing 
the  most  significant  challenges 
in  tackling  nutrient 
pollution from agriculture. Further efforts are needed to 
comply with EU laws, notably the Drinking Water and the 
Urban Waste Water Treatment Directives. 

Two  river  restoration  projects  in  the  Mosoni-Danube 
River  area  and  Nagy-Pándzsa  are  good  practices  of 
nature-based  solutions.  Both  projects  aimed  to  reduce 
flood  risks  and  improve  ecology  for  the  water  bodies  to 
achieve  good  ecological  status.  These  good  practices 
should be carried out in other river restoration projects. 

Nature  protection  of  habitats  and  species  is  below  the 
EU  level.  The  conservation  status  for  protected  species 
and habitats, particularly forests, is deteriorating, leading 
to significant losses of natural resources and biodiversity. 
The  situation  for  protected  forested  areas  is  severe  as 
more  than  half  of  the  assessments  show  a  bad 
conservation status. While Hungary completed its Natura 
2000 network in 2011, further action should be taken to 
align  conservation  measures  and  objectives  with  EU 

requirements to restore areas and decrease pressure on 
the environment, particularly from agriculture. 

Hungary  made  good  use  of  the  LIFE  programme  to 
improve  air  quality  –  one  of  the  country’s  biggest 
environmental  priorities.  One  project,  LIFE  IP  North-HU-
Trans,  is  currently  implemented  to  reduce  industrial 
emissions and pollution from energy production. Another 
project,  LIFE  IP  HungAIRy,  aims  to  improve  air  quality 
through an air quality plan targeting the reduction of air 
pollutant  emissions  from  different  sectors.  Air  pollution 
harms  human  health  and  ecosystems,  mainly  through 
acidification, eutrophication, and ozone damage, leading 
to  biodiversity  loss  and  reduced  agricultural  yields.  Air 
quality in  Hungary  continues  to  be  a  cause  for  serious 
concern.  While 
levels  of  several  pollutants  have 
decreased  in  recent  years,  persistent  breaches  of  air 
quality  standards  continue,  notably  exceedances 
in 
particulate  matter  (PM10)  and  nitrogen  dioxide  (NO2) 
values. The Court of Justice of the European Union (CJEU) 
condemned  Hungary 
in  February  2021  for  having 
systematically  and  persistently  exceeded  the  daily  limit 
value for PM10 in the air  quality zones of  the  Budapest, 
Sajó Valley, and Pécs regions since 2005. 

On climate change, there is a high risk that Hungary will 
not meet post-2020 emission reduction commitments. 

In environmental governance, Hungary has no dedicated 
environment ministry. Responsibilities for environmental 
issues are split between three different ministries. 

EU financing continues to provide substantial support to 
implementation  gap.  From  the 
the  environmental 
European  Structural  and 
Investment  Funds  (ESIFs), 
Hungary  received  EUR  3.2839  billion  to  cover  direct 
environmental  investments  in  2014-2020.  From  this:  (i) 
EUR  401.4  million  was  allocated  to  waste  management; 
(ii)  EUR  1.1498  billion  to  water  management;  (iii)  EUR 
352.7 million to land rehabilitation; (iv) EUR 214.9 million 
to  biodiversity  and  nature;  (v)  EUR  17.6  million  to  air 
quality;  and  (vi)  EUR  1.1474  billion  to  climate  and  risk 
management.  Total  EU  environmental  financing  (from 
the  European  Investment  Bank)  is  estimated  to  have 
reached EUR 5.5 billion in 2014-2020. 

Hungary is due to receive over EUR 21.7 billion from the 
2021-2027  cohesion  policy.  In  2014-2020,  Hungary’s 
overall  environmental  financing  for  investments  was 
estimated  to  be  an  annual  1.52%  of  GDP  (above  the  EU 
average  of  0.7%).  The  overall  environmental  investment 
needs in the  coming period are estimated to be at least 
1.66%  of  GDP.  This  suggests  a  potential  environmental 
financing  gap  of  over  0.14%  of  GDP  that  should  be 
addressed  by  focusing  on  the  country’s  environmental 
implementation priorities. 

Environmental Implementation Review 2022 – Hungary 

 
 
Hungary  4 

Part I: Thematic areas 

1. Circular economy and waste management

Measures towards a circular economy 

Figure 1: Circular material use rate (%), 2010-20201 

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve  the  EU’s  2050  climate  neutrality  target  and  to 
halt  biodiversity 
loss.  The  Action  Plan  announces 
initiatives  along  the  entire  life  cycle  of  products,  aiming 
to reduce the EU's consumption footprint and to double 
the EU's circular material use rate by 2030. It targets how 
products  are  designed,  promotes  circular  economy 
processes,  encourages  sustainable  consumption,  and 
aims to ensure that waste is prevented and the resources 
used are kept in the EU economy for as long as possible. 

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity  rate  exist  between  countries.  To  help  achieve 
the  goal  in  the  EU  circular  economy  action  plan  of 
doubling  the  EU’s  circular  material  use  rate  by  2030, 
ambitious  measures  targeting  the  whole  product  life 
cycle are needed at Member State level. Such  measures 
range  from  sustainable  product  design  that  makes  it 
possible 
reparaibility, 
upgradability  and  recyclability  of  products,  to  other 
measures 
increasing 
circularity  in  production  processes;  (iii)  recycling;  (iv) 
boosting eco-innovation; and (v) increasing the uptake of 
green public procurement. 

‘remanufacturing’; 

the  durability, 

increase 

like: 

(ii) 

to 

(i) 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw  material  markets. As  shown 
in  Figure  2,  with  EUR  0.89  generated  per  kg  of  material 
consumed  in  2020,  resource  productivity  in  Hungary  is 
still below the EU average of EUR 2.09 per kg. 

Figure 2: Resource productivity, 2010-20202 

Hungary’s  circular  (secondary)  use  of  material  was  6.4% 
in  2016  and  8.7%  in  2020,  compared  to  the  2020  EU 
average  of  12.8%.  Although  below  the  EU  average,  the 
country  has  shown  a  steady  increase  in  the  use  of 
secondary material over the past years. 

1 Eurostat, Circular Economy Monitoring Framework. 
2 Eurostat, Resource productivity. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
 
                                                                 
Circular economy strategies 

launch  of 

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole life cycle of products. This 
is  because  such  strategies  are  one  of  the  most  effective 
ways to progress towards a more circular economy. Since 
the 
the  European  Circular  Economy 
Stakeholder  Platform  in  20173,  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies  and  roadmaps.  In  2018,  the  proposal  for 
preparing a circular economy action plan was introduced 
for  Environmental 
by 
Development and Strategy, and an interministerial expert 
group was set up. 

the  Hungarian  Department 

The  2019  EIR  for  Hungary  pointed  out  that  the  national 
minimum  service  standards  do  not  require  separate 
door-to-door  collections  to  be  rolled  out,  and  the 
recycling targets for service operators are unlikely to act 
as an incentive. There has only been limited progress on 
this, as well as on waste management strategy in general. 
If  some  measures  are  planned,  but  they  have  not  been 
implemented yet. 

Hungary  has  been  developing  several  pieces  of 
legislation.  This  includes:  (i)  a  regulation  reducing  the 
impact of certain plastic products on the environment in 
line with the directive on single-use plastics4; (ii) end-of-
waste  legislation  (including  for  textile  and  paper);  (iii) 
legislation  on  by-product  status;  (iv)  an  extended 
producer  responsibility  regulation;  and  (v)  legislation  to 
provide  proof  of  the  removal  of  abandoned  waste  from 
immovable  property  and  of  transport  to  an  appropriate 
waste treatment  facility. However, these measures have 
not yet been adopted or implemented. When it comes to 
sectorial  strategy  for  construction,  Hungary  does  not 
foresee one. 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social  and  technological  innovation.  This  is  because  the 
full potential of the circular economy can only be reached 
when  it  is  implemented  across  all  value  chains.  Eco-
innovation is an important enabling factor for the circular 
economy.  New  approaches  to  product  design  and  new 
business  models  can  help  produce  systemic  circularity 
innovations, creating new business opportunities. 

Hungary  ranked  25th  in  the  list  of  EU  countries  with  a 
total score of 69 in the 2021 Eco-Innovation Scoreboard, 

Hungary  5 

showing  that  the  country  needs  to  do  more.  In  all  five 
components  of  the  2021  Eco-Innovation  Index,  Hungary 
performs  below  the  EU  average,  namely  eco-innovation 
activities, 
socio-economic 
outcomes,  eco-innovation  input  and  resource  efficiency 
outcomes. 

eco-innovation  outputs, 

Figure 3: Eco-innovation performance, 2010-20195 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 
purchasing  power  representing  14%  of  EU  GDP.  Public 
procurement  can  drive  the  demand  for  sustainable 
products 
recyclability 
standards.  For  now,  reporting  on  the  uptake  of  green 
public procurement is voluntary. 

repairability  and 

that  meet 

Hungarian public procurement rules are laid down in the 
Public  Procurement  Act  (CXLIII)  of  2015.  It  allows  public 
authorities  to  take  environmental  aspects  into  account 
during their public procurement procedures, but it is not 
mandatory. 

in  public 
To  promote  environmental  objectives 
procurement procedures, the Hungarian government set 
out 
to  create  a  national  green  public 
procurement  strategy.  However,  this  strategy  is  still  in 
preparation. 

the  aim 

The  Public  Procurement  Authority  informs  stakeholders 
about  the  possibilities  of  green  and  socially  responsible 
procurement  and  current  trends  in  EU  legislation  and 
policy. The Authority also organises training and, collects 
green  statistics  and  is  involved  in  green  procurement 
projects.  The  development  of  green  public  procurement 

3 Circular Economy Stakeholder Platform 
4 Directive (EU) 2019/904 

5  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory’, Eco-innovation index. 

Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
 
                                                                 
Hungary  6 

(ii) reducing waste generation and waste generation per 
capita in absolute terms; 
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste9,  for  which  EU  law  sets  mandatory  recycling 
targets. 

resource  efficiency  and 

Preventing products and materials from becoming waste 
for  as  long  as  possible  is  the  most  efficient  way  to 
improve 
the 
environmental  impact  of  waste.  Waste  prevention  and 
re-use are the most preferred options  and are therefore 
at  the  top  of  the  ‘waste  hierarchy’.  The  amount  of 
municipal  waste  generated  is  a  good  indicator  of  the 
effectiveness of waste prevention measures. 

reduce 

to 

limited  decrease  between  2010  and  2015, 
After  a 
municipal  waste  generation 
in  Hungary  has  slightly 
increased  since  then.  It  reached  387 kg  per  capita  in 
2019.  However,  in  2020,  this  decreased  again  to  364 kg 
per capita, well below the EU average (505 kg per capita) 
(see  Figure  4).  Although  more  time 
is  needed  to 
determine the trend, Hungary does seem to be on track 
to  decouple  total  waste  generation  from  economic 
growth. 

is  also  supported  by  initiatives  co-financed  by  national 
and EU funds (e.g. the ‘green bus programme’). 

EU Ecolabel and the EU eco-management and audit 
scheme (EMAS) 

The number of EU Ecolabel products and EMAS-licensed6 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy. 

to 

As of September 2021, Hungary had 89 products (out of 
83 590 in the EU) and 9 licences (out of 2 057 in the EU) 
registered  in  the  EU  Ecolabel  scheme,  showing  a  low 
licences7.  Moreover,  27 
take-up  of  products  and 
organisations,  amounting  to  54  sites  from  Hungary,  are 
currently  registered  in  EMAS,  the  Commission’s  EMAS8. 
Since  the  2019  EIR,  56  new  products  have  been 
registered in the EU Ecolabel scheme, while the number 
of  licences  has  fallen  by  six.  As  regards  EMAS,  the 
situation remained stable. 

In the 2019 EIR, Hungary received two priority actions for 
the  circular  economy.  In  view  of  the  limited  progress, 
these  actions  are  maintained  but  with  a  stronger  focus 
on improving the circular material use rate. 

2022 priority actions 

  Strengthen  the  policy  framework  to  speed  up  the 
uptake  of  the  circular  economy  by  all  economic 
sectors,  including  priority  sectors  such  as  plastics, 
textiles and construction. 

  Adopt measures to increase the circular  material use 

rate. 

Waste management 

Turning waste into a resource is supported by: 
legislation,  which 
implementing  EU  waste 
(i)  fully 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.; 

6  EMAS  is  the  Commission’s  eco-management  and  audit  scheme,  a 
programme  that  encourages  organisations  to  behave 
in  a  more 
environmentally sustainable way. 
7 European Commission, Ecolabel Facts and Figures. 
8  As  of  May  2018.  European  Commission,  Eco-management  and  audit 
scheme. 

9 Municipal waste consists of: (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 
plastics,  biowaste,  wood,  textiles,  packaging,  electrical  waste  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
waste,  including  mattresses  and  furniture;  and  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar  in  nature  and  composition  to  household  waste  (Directive 
2008/98/EC, Art. 3 2b). 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
                                                                 
Figure 4: Municipal waste by treatment in Hungary, 
2010-202010 

Hungary has made steady progress over the past decade 
in  increasing  its  recycling  rate  (up  from  20%  in  2010  to 
33% in 2020) and diverting municipal waste from landfill. 
However,  the  recycling  rate  is  still  well  below  the  EU 
average  of  48.1%  in  2020.  Figure  5  shows  that  Hungary 
needs to step up investment in recycling to meet the EU 
2020 and 2025 recycling targets. 

Figure 5: Recycling rate of municipal waste, 2010-202011 

Hungary  7 

target  of  recycling  50 %  of  municipal  waste.  The  report 
listed priority measures that Hungary should take to close 
the  implementation  gap.  In  the  meantime,  the  landfill 
rate increased to 196 kg per capita in 2019. Therefore, it 
seems  that  meeting  the  post-2020  targets  will  require 
greater effort from Hungary. 

The  Commission  is  currently  finalising  its  analysis  of  the 
progress  on  the  recommendations  from  the  2018  Early 
Warning reports, as a well as progress towards achieving 
the  2025  waste  recycling  targets.  The  Commission  will 
present  the  report  at  the  end  of  2022,  and  make 
recommendations, as appropriate. 

On  23  February  2021,  Hungary  adopted  new  rules  on 
waste  management,  in  line  with  its  2020  climate  and 
nature protection action plan. The legislative changes are 
aimed at moving to a circular economy, eliminating illegal 
landfills, stricter penalties for those who dispose of waste 
illegally,  setting  up  a 
‘deposit-return  system’  and 
rationalising waste economic activity. The new legislation 
also  aims  to  promote  a  more  efficient  performance  and 
coordination  of  waste  management  tasks  via  the 
implementation  of  a  new  concession  model.  In  this 
model,  the  tasks  set  out  by  the  government  (from  the 
collection of waste to its pre-treatment for recovery) will 
be  carried  out  by  a  single  private  company.  The 
concession  company  will  commit  to  meeting  the  EU 
waste  management  targets,  broken  down  by  year,  by 
making  the  necessary  investment  without  increasing 
costs to households. 

However,  stakeholders  have  expressed  concerns  about 
this new legislation, in particular how the new concession 
model  further  nationalises  the  waste  management 
sector. 

Implementation of the 2018 waste legislative package 

Hungary  has  notified  the  turning  of  the  2018  waste 
package13 
law  to  the  Commission.  A 
into  national 
conformity assessment is now ongoing. 

Waste  management  plans  and  waste  prevention 
programmes  are  critical  for  a  sound  implementation  of 
legislation.  They  set  out  key  rules  and 
EU  waste 
investment  to  ensure  compliance  with  existing  and  new 

The  Commission’s  Early  Warning  report12  listed  Hungary 
as  one  of  the  countries  at  risk  of  missing  the  EU  2020 

10 Eurostat, Municipal waste by waste operation, April 2022. 
11 Eurostat, Recycling rate of municipal rate, April 2022. 

12  European  Commission,  Report  on  the  implementation  of  waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
waste, SWD(2018)422 accompanying COM(2018)656. 
13  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up to 
2035. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
                                                                 
 
                                                                                                        
 
Hungary  8 

legal  requirements  (e.g.  waste  prevention,  separate 
collection  for  specific  types  of  waste,  recycling  and 
landfill targets). Hungary’s revised plans and programmes 
were due on 5 July 2020. 

Hungary  has  amended 
its  waste  management  plan 
(published in the Official Journal on 7 October 2021) and 
notified the Commission. It is currently being assessed by 
the Commission. 

An  infringement  procedure  is  pending  against  Hungary 
for failing to comply with the Waste Framework Directive 
and  the  Habitats  Directive  because  of  waste  treatment 
activities  carried  out  at  the  red  mud  tailings  pond  in 
Almásfüzitő. The case is under assessment. 

Hungary has not yet ratified the Hong Kong International 
Convention  for  the  Safe  and  Environmentally  Sound 
Recycling  of  Ships  and  the  International  Convention  for 
the Control and Management of Ships’ Ballast Water and 
Sediments. 

In  the  2019  EIR,  Hungary  received  three  priority  actions 
for waste. As there is little to no progress, and in light of 
the  2022  Early  Warning  report,  the  actions  are 
maintained. 

2022 priority actions 

  Gradually 

increase 

landfill  taxes  to  phase  out 
landfilling  of  recyclable  and  recoverable  waste.  Use 
the  revenue  for  measures  that 
improve  waste 
management, in line with the waste hierarchy. 

  Focus  on  making  separate  collections  obligatory  to 
increase  recycling  rates,  including  the  collection  of 
bio-waste.  Develop  and  implement  minimum  service 
standards 
for 
support 
municipalities. 
Improve 
systems, 
requirements14. 

the  extended  producer 
in 

responsibility 
the  general  minimum 

programmes 

line  with 

and 

 

14 Set out in Directive (EU) 2018/851 amending Directive 2008/98/EC. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
Hungary  9 

2. Biodiversity and natural capital

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and  sets  out  new  targets  and  governance  mechanisms 
to achieve healthy and resilient ecosystems. 
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network; 
(ii) strictly protect at least a third of the EU’s protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests; 
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately. 
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 

The EU’s Birds and Habitats Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy  for 2030 and are the cornerstone of European 
legislation aimed at conserving the EU’s wildlife, natural 
habitats, and ecosystems15. 

Hungary’s draft national biodiversity strategy for 203016 
went to public consultation in October 2021 and has yet 
to be adopted by Parliament. 

The draft strategy identifies 19 main objectives for 2030 
to  be  achieved  through  250  measures,  each  with 
corresponding indicators. 

Nature protection and restoration 

Natura  200017,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  Birds  and  Habitats  Directives’  objectives 
ensuring  the  long-term  protection,  conservation  and 
survival  of  Europe’s  most  valuable  and  threatened 

15 These  should  be  strengthened  by  the Nature  Restoration  Law,  in 
line with the new EU biodiversity strategy. 
16 Készül a 2030-ig szóló Nemzeti Biodiverzitás Stratégia! | Biodiversity 
Clearing-House Mechanism and Biosafety Clearing-House 
17  Natura  2000  comprises  sites  of  community  importance  (SCIs) 
designated under  the  Habitats Directive  as  well  as  special  protection 
areas  (SPAs)  classified  under  the  Birds  Directive.  Figures  of  coverage 
and  no-coverage  do  not  add  up  to  100%  due  to  the  fact  that  some 
SCIs  and  SPAs  overlap.  Special  areas  of  conservation  (SACs)  are  SCIs 
designated by Member States. 

species  and  habitats  and  ecosystems  they  underpin. 
Setting up a coherent Natura 2000 network, designating 
of sites of community importance (SCIs) as special areas 
of conservation (SACs)18, setting conservation objectives 
and  measures  for  the  Natura  2000  sites  are  key 
milestones in meeting the objectives of the Directives. 

Setting up a coherent network of Natura 2000 sites 

Hungary  hosts  45  habitat  types19  and  212  species20 
covered  by  the  Habitats  Directive.  The  country  also 
hosts populations of 88 bird taxa listed in Annex I to the 
Birds Directive21. 

By  2021,  21.4%  of  Hungary’s  territory  was  covered  by 
Natura  2000  (EU  average:  18.5%).  Special  protection 
areas  (SPAs)  classified  under  the  Birds  Directive  were 
covering 14.8% (EU average: 12.8%). This overlapped to 
a 
large  degree  with  the  SCIs  under  the  Habitats 
Directive,  which  covered  15.5%  (EU  average:  14.2%)  of 
Hungarian territory. 

Hungary  legally  protects  22.2%  of  its  terrestrial  areas 
(EU-27 average: 26.4%)22 and  strictly protects  1.28% of 
the  EU’s  protected  areas,  as  classified  under  the 
International  Union 
for  Conservation  of  Nature 
(categories 1A and 1B). 

18 SCIs are designated under the Habitats Directive, whereas SPAs are 
designated  under  the  Birds  Directive.  Figures  of  coverage  and  no-
coverage do not add up  to 100% due to the fact that some SCIs and 
SPAs overlap. SACs are SCIs designated by Member States. 
19 European Environment Agency, Article 17 dashboard, Annex I total, 
2019. 
20  European  Environment  Agency,  Article  17  dashboard,  Annex  II  + 
Annex  IV  excluding  those  in  Annex  II  +  Annex  V  excluding  those  in 
Annex  II,  2019.  This  counting  only  takes  into  account  species  and 
habitats for which assessment of conservation status was requested. 
21 European Environment Agency, Article 12 dashboard, Annex I, 2020. 
This counting only takes into account birds taxa for which information 
was requested. 
22  European  Environment  Agency,  Protected  areas,  terrestrial 
protected area percentage (2021), March 2022. 

Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
                                                                 
Figure 6: Terrestrial protected area coverage, 202123 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

Hungary  10 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article 12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
towards  maintaining  or  restoring 
favourable 
the 
conservation status of species and habitats. 

Hungary submitted its report on the conservation status 
of  habitats  and  species  covered  by  Article 17  of  the 
Habitats  Directive.  Between  2013  and  2018,  the  share 
of assessments for habitats in good conservation status 
in  2018  was  13.33%.  This  is  less  than  in  the  previous 
reporting  period  (2007-2012)  when  the  share  was 
19.57%. On protected species, the share of assessments 
in good conservation status in 2018 was 34.91%, down 
from  35.89%  reported  in  the  previous  reporting  period 
(2007-2012). Of the forest habitats protected under the 
EU  nature  directives,  less  than  8%  show  a  favourable 
conservation status25. On birds, 51% of breeding species 
showed  short-term  increases  in  their  numbers  or  had 
stable population trends  (the  increasing trend dropped 
to 14% from 19% in the previous reporting period). For 
key  wintering  species,  21.05%  showed  short-term 
increases or stable population trends. 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation status increased to 48.89%, and the share 
of  assessments  for  species  in  bad  conservation  status 
also  increased,  rising  to  11.79%.  The  main  pressure 
comes  from  agriculture,  natural  processes  and  climate 
change,  and  ‘extraction  and  cultivation  of  biological 
living resources’ (including illegal killing and poaching). 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202124 

Designating SACs and setting conservation objectives 
and measures 

Hungary has already designated all SCIs as SACs, and by 
the  end  of  2021,  all  but  two  sites  had  management 
plans  and  conservation  objectives.  By  the  end of  2022, 
all  SACs  and  SPAs  will  have  management  plans. 
However, the conservation measures and objectives are 
not yet fully in line with the relevant guidance  because 
they  are  not  specific  enough,  measurable  or  time-
bound.  Their  revision  was  started  under  an  EU  pilot 
investigation  launched  by  the  Commission  and  should 
be concluded by 2024 for all sites. 

23  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
24  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

25 State of Nature Report, European Environment Agency, 2021. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
                                                                 
 
                                                                 
Figure 8: Assessments on conservation status for 
habitats for the 2007-2012 and 2013-2018 reporting 
periods26 

Figure 9: Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods27 

Hungary  11 

necessary  conservation  measures  for  the  sites.  There 
has  been  some  progress  on  this,  but  it  is  essential  to 
continue  efforts  in  light  of  the  conservation  status  of 
habitats  and  species.  There  has  been  limited  progress 
on  the  other  action  to  develop  and  promote  of  smart 
and streamlined implementation approaches (to ensure 
the  necessary  knowledge  and  data  are  available)  and 
strengthen  communication  with  stakeholders.  As  a 
result, this action is proposed again. 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture. 
The  biodiversity  and  farm  to  fork  strategies  have  set 
four important targets for 2030: 
(i) a 50% reduction in the overall use of – and risk from 
– chemical pesticides; 
(ii)  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
(iii)  a  50%  reduction 
losses  of  nutrients  from 
fertilisers while ensuring there is no deterioration of soil 
fertility (which will result in  a 20% reduction in the use 
of fertilisers); 
(iv)  bring  back  at  least  10%  of  agricultural  area  under 
high-diversity  landscape  features  and  increase  areas 
under organic farming to at least 25%. 

in 

With an estimated 6,03% of land under organic farming, 
Hungary  is  below  the  EU  average  of  9.07%  (2020  data, 
Eurostat). 

The  conservation  status  of  habitats  and  species 
deteriorated  further  during  the  last  reporting  period 
(2013-2018).  The  proportion  of  those  in  favourable 
status  decreased,  while  those  in  unfavourable  status 
increased. In particular, there was a significant increase 
of habitats in bad status. 

In  the  2019  EIR,  Hungary  received  two  priority  actions 
for  nature  and  biodiversity.  One  action  was  to 
implement  clearly  defined  conservation  objectives  and 

26  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.  Please  note when  comparing 
the  figures  shown  for  2007-2012  and  2013-2018  that  these 
differences  may  also  be  affected  by  changes  of  methods  or  better 
data availability. 
27 See previous footnote. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
                                                                 
 
 
Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202028 

Hungary  12 

One factor  in the  degradation  of soil ecosystems  is the 
area  of  soil  that  is  sealed  or  artificialised30.  In  Hungary 
(see Figure 11), the land taken31 per year in 2012-2018 
can be seen as a measure of one significant pressure on 
nature  and  biodiversity.  At  the  same  time,  land  use 
change  constitutes  an  environmental  pressure  on 
people living in urbanised areas.  

In  2021-2018,  Hungary  ranked  above  the  EU  average 
with  a  net  land  take  of  92.4  m²/km²  (EU-27  average: 
83.8 m²/km²)32. More precisely, land take in  Hungary is 
150.5  m2/km2  while  re-cultivation  is  58,1  m2/km2  (see 
Figure 11). 

its  reporting  on 

In  2018,  Hungary  updated 
land 
degradation  according  to  the  next  performance  review 
and 
reporting 
system 
implementation 
platform33  with  measures 
intended  to  reduce  the 
degradation identified. 

(PRAIS3) 

According  to  the  Commission  recommendations  for 
Hungary’s  CAP  strategic  plan29,  rural  areas  in  Hungary 
are  under  pressure  from  environmental  and  climate 
factors.  There  are  several  reasons  for  the  general 
degradation  of  the  situation: 
intensive  agricultural 
practices,  increases  in  greenhouse  gas  and  ammonia 
emissions,  rising  nitrate  concentrations,  and  climate 
change challenges. To counter loss of natural resources 
and biodiversity, Hungary should take action in line with 
the  biodiversity  strategy  to:  (i)  restore  non-productive 
assets  and  natural  areas  (in  particular  wetlands  and 
grasslands); (ii) ensure sustainable forest  management; 
(iii) develop organic farming (with business models that 
generate  revenue  and  encourage  changes  in  farming 
practices); and (iv) implement a more integrated policy 
soil  and  nutrient  policies,  manure 
(combining 
management, 
and 
climate 
biodiversity and landscape management). 

change  mitigation, 

Soil ecosystem 

soil 

new 

strategy, 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
on 
adopted 
EU 
The 
17 November 2021,  stresses  the 
importance  of  soil 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives  as  well  as  land-degradation  neutrality  by 
2030. 
This entails: 
(i) preventing further soil degradation; 
(ii)  making  sustainable  soil  management  the  new 
normal; 
(iii) taking action for ecosystem restoration. 

28 Eurostat, Area under organic farming, February 2022. 
29 EUR-Lex - 52020SC0397 - EN - EUR-Lex (europa.eu) 

30 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non-built-up  areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car parking areas and linear features, such as streets, roads, railways, 
runways,  bridges)  and  other  artificial  areas  (including  bridges  and 
viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dumpsites). 
31 ‘Land taken’ means land that is sealed or artificialised. 
32  Land  take  in  Europe  –  European  Environment  Agency  (europa.eu), 
Figure 6. 
33 All Reports | Prais3 (unccd.int) 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
                                                                 
Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201834 

The  country  had  already  remediated  or  applied 
aftercare measures on 347 sites. 

Hungary  13 

Soil erosion by water is a natural process, which can be 
aggravated by climate change and human activities such 
as  inappropriate  agricultural  practices,  deforestation, 
forest  fires  or  construction.  High  levels  of  soil  erosion 
can reduce land productivity in agriculture and can have 
negative  and  transboundary  impacts  on  biodiversity, 
ecosystem  services,  and  rivers  and  lakes  (increased 
volume  of  sediments,  transport  of  contaminants). 
According  to  the  RUSLE2015  model,  Hungary  has  an 
average  soil  loss  rate  by  water  of  1.62  tonnes  per 
hectare per year, which is lower than the EU average of 
2.46 t ha. These figures are the output of a model run at 
EU  level  and  should  not  be  considered  as  values 
measured on-site. The real soil loss rate can vary greatly 
within a country depending on local conditions. 

Soil  organic  matter  plays  a  big  role  in  the  carbon  cycle 
and  in  climate  change.  Soils  are  the  second-largest 
carbon sink in the world after oceans. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  Fit  for  55  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is  to  ensure  healthy,  diverse,  and  resilient  EU  forests 
that  contribute  significantly 
the  strengthened 
to 
biodiversity and climate ambitions.  
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 

Of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favourable conservation status37. The  share of  forested 
areas in the EU with a bad conservation status increased 
from 27% in 2015 to 31% in 2018. 

In  Hungary,  forests  cover  23.92%  of  the  country38.  The 
situation of forest habitats protected under the Habitats 
Directive  is  particularly  worrying  as  more  than  half  of 
the assessed forests have a bad status39. 

Through  the  land  degradation  neutrality  (LDN)  target 
setting  programme,  the  Global  Mechanism  (GM)  and 
the  secretariat  of  the  United  Nations  Convention  on 
Combating  Desertification  (UNCCD)  are  supporting 
interested  countries  with  their  national  LDN  target 
setting process. This includes support in setting national 
baselines,  targets  and  associated  measures  to  achieve 
LDN. The SUN ustainable Development Goal target 15.3 
restore 
‘By  2030,  combat  desertification, 
states: 
degraded  land  and  soil,  including  land  affected  by 
desertification, drought and floods, and strive to achieve 
a  land  degradation-neutral  world’.  However,  Hungary 
has not yet committed to setting LDN targets under the 
UNCCD35. 

Contamination  can  severely  reduce  soil  quality  and 
threaten human health and the environment. The latest 
information  from  Member  States36  estimated  that 
potentially  polluting  activities  have  taken  place  or  are 
still taking place in approximately 2.8 million EU sites. At 
EU level, 650 000 of these sites have been registered in 
inventories.  Around  65 500 
national  or 
contaminated  sites  have  already  been  remediated. 
Hungary  registered  5 375  sites  where  potentially 
polluting activities had taken place or were taking place. 

regional 

34  European  Environment  Agency,  Land  take  in  Europe,  December 
2021. 
35 The LDN Target Setting Programme | UNCCD 
36  Ana  Paya  Perez,  Natalia  Rodriguez  Eugenio  (2018),  Status  of  local 
soil contamination in Europe: Revision of the indicator ‘Progress in the 
management Contaminated Sites in Europe’. 

37 European Environment Agency, State of Nature in the EU. 
38  European  Environment  Agency,  Forest  information  system  for 
Europe. 
39 JCR, Mapping and assessment of primary and old-growth forests in 
Europe, p. 13. 

Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
                                                                 
Figure 12: Conservation status of forests protected 
under the Habitats Directive in the EU-27, 2013-201840 

(EUTR)41 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested timber. In line with the EUTR, Member States’ 
competent  authorities  must  conduct  regular  checks  on 
operators  and  traders  and  apply  penalties  for  non-
compliance.  With  the  amendment  of  Article 20  of  the 
EUTR,  reporting  every  2  years  has  been  changed  to 
annual  reporting  and  covers  the  calendar  year  as  of 
2019. 

From  March  2017  to  February  201942,  Hungary  carried 
out  77  checks  on  domestic  timber  operators.  It  also 
carried out seven checks on operators importing timber. 
Over the reporting period,  it  is estimated that Hungary 
had  46  946  operators  placing  domestic  timber  type  on 
the single market and 2 920 operators placing imported 
timber types on the single market. 

The  new  Deforestation  Regulation  will  repeal  and 
replace  the  EUTR,  and  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  legality  of 
timber. 

Invasive alien species (IAS) 

in 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
use, 
sea 
(alongside 
overexploitation, climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 

land 

and 

40  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
41 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
42 COM/2020/629 final. 

Hungary  14 

and wildlife.  
The implementation of the EU IAS Regulation and other 
relevant legislation must be stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%. 

The  core  of  Regulation  (EU)  1143/2014  on  IAS  (the  IAS 
Regulation)43 is the list of IAS of Union concern.  

The  total  number  of  IAS  of  Union  concern  is  currently 
66,  of  which:  30  are  animal  species;  36  are  plant 
species;  41  are  primarily  terrestrial  species;  23  are 
primarily  freshwater  species;  1  is  a  brackish-water 
species; and 1 is a marine species.  

consistent 

include  a 

According  to  a  2021  review44  of  the  application  of  the 
IAS  Regulation,  implementation  of  the  Regulation  is 
already  starting  to  deliver  on  its  objectives.  These 
objectives 
for 
addressing  IAS  at  EU  level  and  increased  awareness  of 
the IAS problem. At the same time, the review identified 
some challenges and areas for improvement. Given that 
the deadlines for implementing the different obligations 
of the IAS Regulation  were between July 2016 and July 
2019,  it  is  too  early  to  draw  conclusions  on  many 
aspects of the Regulation’s implementation. 

framework 

A 2021 report45 on the baseline distribution shows that 
of the 66 species on the EU list, 33 have been observed 
in  the  environment  in  Hungary.  The  distribution  is 
shown in Figure 13. 

43  Regulation  (EU)  No 1143/2014  of  the  European  Parliament  and  of 
the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species. 
44  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU) 
No 1143/2014  of  the  European  Parliament  and  of  the  Council  of 
22 October  2014  on  the  prevention  and  management  of  the 
introduction  and  spread  of  invasive  alien  species,  COM(2021)  628 
final, 13.10.2021. 
45  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D’Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines, 
the  European  Union, 
EUR 30689  EN,  Publications  Office  of 
Luxembourg,  2021, 
ISBN  978-92-76-37420-6,  doi:10.2760/11150, 
JRC123170. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
                                                                 
Hungary  15 

2022 priority actions 

  Complete  and  adopt  the  management  plans  for  all 
Natura  2000  sites  and  finalise  the  revision  of  the 
site-specific 
conservation 
conservation  objectives  to  bring  them  in  line  with 
Commission guidance.  

measures 

and 

  Ensure  proper  protection  and  management  of  the 
Natura  2000  sites  to  curb  the  deterioration  of 
habitats  and  species  and  put  them  on  the  path 
towards favourable conservation status.  

  Decrease  the  pressure  on  habitats  and  species 
in  particular  from  agriculture, 
(including  birds), 
which is the most significant pressure on nature and 
biodiversity.  

  Ensure that land under organic farming  significantly 

contributes to the 2030 25% target. 

  Step up efforts to implement the recommendations 
set out in Hungary’s CAP strategic plan, especially on 
improving rural areas. 

  Remediate  degraded  areas  of  soil  and  consider 
formally  committing  to  LDN  targets  under  the 
UNCCD agreement. 

  Step up implementing the IAS Regulation. 
  Continue  collecting  data  on  IAS  and  improve  the 

surveillance system. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision  making  at  all  levels 
and to develop natural capital accounting. The EU needs 
a  better-performing  biodiversity-observation  network 
and  more  consistent  reporting  on  the  condition  of 
ecosystems.  

A thorough national habitat mapping was carried out in 
Hungary  between  2003  and  2006,  and 
it  can  be 
considered  as  a  preliminary  study  for  MAES-HU.  The 
quality of natural and semi-natural habitats (ecosystem 
state) was also assessed and mapped. 

As  part  of  the  environment  and  energy  efficiency 
operational  programme  for  2014-2020,  the  ‘Strategic 
assessments  supporting  the  long-term  conservation  of 
natural  values  of  community  interest  as  well  as  the 
national implementation of the EU biodiversity strategy 
to  2020’  project  has  been  fulfilled,  including  mapping 
and assessing ecosystems and their services. The project 
ran from November 2017 to April 2022. 

Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for Hungary, 2021 

A good example of a project dealing with IAS is the LIFE 
project LIFEforBUGS&BIRDS46. Since 2021, this project is 
improve  grassland  quality  and  remove 
working  to 
unwanted  game  species  from  habitats  by  controlling 
invasive alien shrubs. 

The Department of Nature Conservation of the Ministry 
of  Agriculture  maintains  two  webpages  on  IAS.  The 
Hungarian action plan on IAS47 has been prepared and is 
currently being implemented. 

Direct  eradication measures to suppress  IAS have been 
performed  throughout  Hungary,  mainly  in  protected 
areas  or  Natura  2000  sites.  Most  protective  measures 
have targeted the control of milkweed (222 ha in 2019), 
hogweed  species (3 ha  in 2019), Himalayan balsam (36 
ha in 2019) and Egyptian geese. 

In  the  2019  EIR,  Hungary  received  one  priority  action 
requiring the country to investigate the apparent lack of 
data and improve the IAS surveillance system. There has 
been  some  progress,  and  monitoring  efforts  should  be 
continued,  notably  by  ensuring  the  implementation  of 
the  Hungarian  action  plan  in  line  with  Article 13(4)  of 
Regulation (EU) No 1143/2014. 

46  LIFEforBUGS&BIRDS,  innovative  management  of  Pannonic  salt 
steppes and loess steppic grasslands for the benefit of plants, insects 
and birds. Project website. 
47 In line with Article 13(4) of Regulation (EU) No 1143/2014. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
The  project  made  an  online  national  ecosystem  map 
publicly  available  in  November  201948.  Building  on  this 
ecosystem  map,  national  ecosystem  condition  maps 
were  prepared  using  available  databases49.  The  project 
also  mapped  and  assessed  12  ecosystem  services 
identified  with  stakeholders50.  Lastly,  12 
initially 
selected  ecosystem  services  were  linked  with  different 
groups  of  stakeholders,  with  different  experiences  in 
human well-being. The synthesis of results and input to 
policy was carried out in 2020. 

A  number  of  ongoing 
ecosystem services51. 

research  projects 

target 

To  assess  progress 
in  ecosystem  mapping  and 
assessment, the Commission sends out a questionnaire 
twice  a  year  containing  27  implementation  questions. 
information,  and 
Hungary  has  provided  updated 
encouraging  progress  has  been  recorded  since  January 
2016 (see Figure 14). 

Figure 14: ESMERALDA MAES Barometer, January 2016 
- March 202152 

To  assess  the  progress  on  the 
implementation  of 
ecosystem  accounting,  the  Commission  conducts  a 
survey  of  Member  States  by  sending  out  a  survey 
containing 13 questions (see Figure 15). 

Hungary  16 

Figure 15: Ecosystem accounting barometer, 
September 202153 

In the 2019 EIR, Hungary received one priority action on 
the  support  to  mapping  and  assessing  ecosystems  and 
their  services  and  the  evaluation  and  development  of 
natural-capital  accounting  systems.  There  has  been 
some  progress  and  continued  effort  in  that  direction 
should be pursued.  

2022 priority actions 

  Continue supporting the mapping and assessment of 
ecosystems and their services and  the development 
of  ecosystem  accounting.  This  should  be  done 
through  appropriate 
integrating 
ecosystem  extent,  condition  and  services  (including 
some  monetary  values) 
into  national  accounts. 
Continue  supporting  the  development  of  national 
business  and  biodiversity  platforms, 
including 
natural-capital  accounting  systems  to  monitor  and 
value the impact of business on biodiversity. 

indicators 

for 

48 http://alapterkep.termeszetem.hu 
49 The mapping of ecosystem condition has been carried out based on 
a set of 45 environmental indicators. The methodology applied and a 
detailed  analysis  of  the  45  indicators  is  available  on  the  project 
website: https://termeszetem.hu/hu. 
50  A  cascade  system  has  been  used  as  a  methodological  framework, 
including  four  levels,  such  as:  (1)  the  state  of  ecosystems;  (2)  the 
capacity of ecosystem services; (3) the services actually used; and (4) 
the  maintenance  or  improvement  of  well-being.  Evaluation  and 
assessment have been performed at all four levels. 
51 https://biodiversity.europa.eu/countries/hungary/maes-1 
52 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem assessment: summary for policymakers, p. 80, May 2021. 

53  MAIA  Portal,  Mapping,  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting  (SEEA-EEA)  as  the  methodological  basis  for  ecosystem 
integrated  and  comprehensive 
accounting.  The  SEEA  EA 
statistical framework, which is based on five core accounts: ecosystem 
extent, condition, services, and monetary ecosystem asset. 

is  an 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
                                                                 
 
 
 
 
 
                                                                 
Hungary  17 

3. Zero pollution

Clean air 

its 

EU  clean-air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean-air legislation and defining strategic targets 
and actions for 2030 and beyond.  
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005. 

The  EU  has  developed  a  comprehensive  suite  of  air 
quality  legislation,  which  sets  health-based  air  quality 
standards54  and  emission  reduction  commitments55  by 
Member State for a number of air pollutants.  

Air quality in Hungary continues to give cause for serious 
concern. The latest available annual estimates (for 2019) 
by the European Environment Agency56 point to Hungary 
suffering  about  10  400  premature  deaths  (or  117  800 
years  of  life  lost  (YLL))  attributable  to  fine  particulate 
matter  concentrations57,  440  premature  deaths  each 
year  (5  200  YLL)  attributable  to  ozone  concentration58, 
and  880  premature  deaths  each  year  (10  000  YLL) 
attributable to nitrogen dioxide59 concentrations6061.  

The  emissions  of  several  air  pollutants  have  decreased 
significantly  in  Hungary  in  recent  years,  while  GDP 
growth  has  continued  (see  Figure  16).  According  to  the 
latest  air  pollutant  emission  projections  as  submitted 

54 European Commission, 2016. Air Quality Standards. 
55 European Commission, Reduction of National Emissions. 
56 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details  in  this  report  on  the  underpinning  methodology, 
p. 106. 
57  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5)  refers to  particles with a diameter  of  10  (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
58 Low-level ozone is produced by photochemical action on pollution. 
59  NOx  is  emitted  during  fuel  combustion  e.g.  from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
60 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details  in  this  report  on  the  underpinning  methodology, 
p. 106. 
61  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive 
a sum. 

volatile  organic 

under  Article  10(2)  of  the  National  Emission  reduction 
Commitments  Directive  (NECD)62,  Hungary  projects  to 
reach emission reduction commitments for sulfur dioxide 
(SO2),  non-methane 
compounds 
(NMVOC), and nitrogen oxides (NOx) for 2020 to 2029but 
only SO2 for 2030 onwards. The projections, however, do 
not  show  meeting  the  2020-2029  and  2030  onwards 
emission  reduction  commitments  for  ammonia  (NH3) 
and fine particulate matter PM2.5 and the 2030 onwards 
emission  reduction  commitments  for  NOX  and  NMVOC. 
Latest  data 
the 
Commission’s  review,  indicate  that  in  2020  the  country 
complied  with  the  emission  reduction  commitments  for 
SO2,  NMVOC  and  NOx  but  did  not  comply  with  the 
commitments for NH3 and PM2.5. 

submitted  by  Hungary,  before 

Hungary  submitted  its  national  air  pollution  control 
programme (NAPCP) to the Commission on 18 May 2020. 

Figure 16: Emission trends of main pollutants/GDP in 
Hungary, 2005-201963 

62 Directive 2016/2284/EU. 
63 European Environment Agency. 

Environmental Implementation Review 2022 – Hungary 

 
                                                                 
 
 
 
                                                                 
Figure 17: PM2.5 and NOX emissions by sector in 
Hungary, 201964 

In  2020,  exceedances  above  the  limit  values  set  by  the 
Ambient  Air  Quality  Directive  were  registered  for 
particulate matter emissions in one zone. In several other 
for  ozone 
air  quality  zones, 
concentration were also not met65. 

target  values 

the 

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are  being  followed  up  by  the  Commission  through 
infringement  procedures  (mainly  for  PM10  and  NO2 
exceedances)  covering  all  Member  States  concerned, 
including Hungary.  

For exceedances of PM10 limit values, the CJEU delivered 
a judgment (C-637/18; COM vs Hungary) confirming non-
compliance  with  Directive  2008/50/EC.  The  aim  of  this 
legal action is to put in place appropriate measures that 
bring  all  air  quality  zones  into  compliance.  Hungary 
prepared an air quality protection action plan, which was 
adopted  by 
(Decision 
No 1403/2021.  (VI.  30.)).  In  recent  years,  PM10  values 
have improved. 

the  government 

in  2021 

Hungary  18 

(i) 

ratified: 

the  amended 
Hungary  has  not  yet 
Gothenburg Protocol; (ii) the Heavy Metals Protocol; (iii) 
the  Persistent  Organic  Pollutants  Protocol  under  the 
United  Nations  Economic  Commission 
for  Europe 
(UNECE)  Air  Convention;  and  (iv)  Annex  VI  to  the 
International  Convention  for  the  Prevention  of  Pollution 
from Ships (MARPOL). 

On  16  November  2021,  Hungary  participated  in  an  EIR 
peer-to-peer  event  on  technology  and  measures  to 
reduce  ammonia  emissions.  On  9  February  2022,  the 
country  participated  in  another  peer-to-peer  event  on 
the EU zero pollution action plan, which gave advice and 
guidance,  particularly  on  the  plan’s  implementation  and 
compliance aspects66. 

In the 2019 EIR, Hungary received five priority actions for 
clean  air.  The  first  action  on  the  developing  a  suitable 
NAPCP  has  been  fully  implemented.  There  has  been 
limited  progress  on  the  action  to  reduce  the  main 
emission  sources  under  the  NAPCP  and  meet  all  air 
quality  standards.  There  has  also  been  limited  progress 
to  reduce  NO2  concentrations,  as  described  above.  On 
reducing 
and 
concentrations,  there  has  been  some  progress,  as 
described  above.  On  reducing  the  use  of  coal  for 
domestic  heating,  there  has  been  some  progress.  There 
has  been 
reducing  NMVOCs 
emissions,  as  described  above.  Hungary  also  received  a 
general  priority  action 
in  2019  to  sign  and  ratify 
outstanding international agreements. 

particulate  matter 

limited  progress 

emissions 

in 

2022 priority actions 

  As part of the NAPCP, take action to reduce emissions 

from the main emission sources. 

  Ensure  full  compliance  with  EU  air  quality  standards 
and  maintain  downward  emissions  trends  for  air 
pollutants to reduce adverse air pollution impacts on 
the  public’s  health  and  the  economy,  with  a  view  to 
reaching WHO guideline values in the future. 
ratification  of: 

amended 
Gothenburg  Protocol;  (ii)  the  Heavy  Metals  Protocol; 
(iii)  the  Persistent  Organic  Pollutants  Protocol  under 
the  UNECE  Air  Convention;  and  (iv)  Annex  VI  to  the 
for  the  Prevention  of 
International  Convention 
Pollution from Ships (MARPOL). 

  Accelerate 

the 

(i) 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to:  

64 See previous footnote. 
65 European Environment Agency, Eionet Central Data Repository. 

66 TAIEX - Environmental Implementation Review - PEER 2 PEER. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
                                                                 
Hungary  19 

Figure 18: Number of IED industrial installations per 
sector in Hungary, 201870 

(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial  Emissions  Directive67  (IED).  The  Commission 
tabled  a  proposal  in  April  202268.  The  revision  seeks  to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies. 

The  overview  of  industrial  activities  below  regulated  by 
the  IED  is  based  on  data  reported  to  the  EU  registry 
(2018)69. 

In  Hungary,  around  1 240  industrial  installations  are 
required  to  have  a  permit  based  on  the  IED.  The 
distribution of installations is shown in Figure 18. 

The  industrial  sectors  in  Hungary  with  the  most  IED 
installations  in  2018  were:  (i)  the  intensive  rearing  of 
poultry  and  pigs  (51%);  (ii)  the  waste  management 
sector,  including  landfills  (13%);  (iii)  the  production  and 
processing of metals (8%); (iv) the chemicals sector (7%); 
(v) the food and drink industries (5%); and (vi) the power 
sector (5%). 

industrial  sectors 

The 
identified  as  contributing  the 
largest  burden  to  the  environment  for  emissions  to  air 
were: 

 

 

 

 

the  power  sector  for  sulfur  oxides  (SOx),  nitrogen 
oxides  (NOx),  arsenic  (As),  mercury  (Hg),  nickel  (Ni) 
and zinc (Zn); 
‘other  activities’  (mostly  intensive  rearing  of  poultry 
or  pigs  and  the  food  and  drink  industries)  for  non-
methane  volatile  organic  compounds  (NMVOCs)  and 
ammonia (NH3); 
the  metal  production  sector  for  cadmium  (Cd), 
chromium (Cr) and copper (Cu); 
the waste  management  sector for particulate  matter 
(PM2.5) and dioxins. 

The breakdown is shown in Figure 19. 

67  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
68  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
69 European Environment Agency, European Industrial Emissions Portal. 

70  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
 
 
                                                                 
Figure 19: Emissions to air from IED sectors and rest of 
national total air emissions in Hungary, 201871 

Figure 20: Relative releases to water from industry in 
Hungary, 201874 

Hungary  20 

In  in  its  report  Costs  of  air  pollution  from  European 
2008-201772, 
industrial 
European 
facilities 
identified  one  thermal  power 
Environment  Agency 
station,  Mátrai  Eromu  Zrt.,  among  the  30  industrial 
facilities  in  Europe  with  the  highest  absolute  damage 
costs  from  emissions  of  the  main  air  pollutants  and 
greenhouse gases in 201773. 

the 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from:  (i)  the  energy  and  the 
chemicals  sector  for  total  nitrogen;  (ii)  landfills  and  the 
food  and  drink  industries  for  total  organic  carbon;  and 
(iii)  ferrous  metals  processing  and  other  heavy  metals 
sectors.  The  breakdown,  based  on  E-PRTR  data, 
is 
presented in Figure 20.  

The  EU  approach  to  enforcement  under  the  IED  creates 
direct  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted  and  that  conditions  of  these  permits  are 
complied  with.  As  part  of  environmental  inspection, 
competent  authorities  carry  out  site  visits  to 
IED 
installations  to  take  samples  and  to  gather  necessary 
information. In line with Article 23(4) of the IED, site visits 
must be carried out between once a year and once every 
3 years, depending on the environmental risks posed by 
the  installations.  In  2018,  Hungary  carried  out  966  site 
visits.  The  largest  number  of  visits  were  to  installations 
for the intensive rearing of poultry or pigs (46% of visits), 
landfill  sites  (11%  of  visits),  and  the  production  and 
processing of metals (10%). 

71  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
72  European  Environment  Agency  (2021).  Costs  of  air  pollution  from 
European  industrial  facilities  2008-2017.  Eionet  Report  -  ETC/ATNI 
2020/4. The ranking is based on the approach accounting for the value 
of a life year (VOLY), table 44, p. 141. 
73  European  Environment  Agency  (2021).  Costs  of  air  pollution  from 
European  industrial  facilities  2008-2017.  Eionet  Report  -  ETC/ATNI 
2020/4. The ranking is based on the approach accounting for the value 
of a life year (VOLY), table 42, p. 129 and table 44, p. 141. 

74  European  Environment  Agency,  E-PRTR,  European 
Industrial 
Emissions  Portal.  The  heavy  metals  are  presented  both  as  a  weighted 
sum  of  eco  toxicity  and  human  toxicity  factors  to  illustrate  both  the 
ecological  and  human  impact  (based  on  USEtox)  (data  retrieved  on  3 
November 2021). 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
 
 
                                                                 
Figure 21: Number of inspections of IED installations in 
Hungary in 201875 

The  development  of  best  available  techniques  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED76. Since the last 
EIR report, the Commission adopted BAT conclusions for: 
(i)  waste  incineration;  (ii)  the  food,  drink,  and  milk 
industries;  and  (iii)  surface  treatment  using  organic 
solvents including wood and wood products preservation 
with chemicals. 

The  Commission  relies  on  the  efforts  of  competent 
national authorities to implement the legally binding BAT 
in 
conclusions  and  associated  BAT  emission 
in  a 
environmental  permits.  This 
considerable and continuous reduction in pollution. 

should 

result 

levels 

Hungary  has  used  the  LIFE  programme  to  co-finance 
projects to tackle industrial emissions and pollution from 
energy production, including the two examples below. 

  The  LIFE  IP  North-HU-Trans77  project  started  in  2020 
with a total budget of EUR 14.88 billion (including an 
EU  contribution  of  EUR  8.9  billion).  It  aims  to 
implement  an  effective  roadmap  for  the  low-carbon 
transition  of  the  largest  coal  region  in  Hungary.  This 
includes  the  decarbonisation  of  the  Mátra  power 
plant,  the  second-largest  in  the  Hungarian  electricity 
production system. 

  The  LIFE  IP  HungAIRy78  project  aims  to  improve  air 
quality. It  started in 2019  with a total budget  of EUR 
16.29 billion (including an EU contribution of EUR 9.5 
billion). 

75  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 
76 European Commission BAT reference documents 
77  LIFE  IP  North-HU-Trans,  Secure  and  start  to  implement  an  effective 
roadmap for the low-carbon transition of the single largest coal region 
in Hungary, project website. 
78  LIFE-IP  HungAIRy  Improving  air  quality  at  eight  Hungarian  regions 
through  the  implementation  of  air  quality  plan  measures,  project 
website. 

Hungary  21 

In  the  2019  EIR,  Hungary  received  two  priority  actions. 
The first action was to review permits and to strengthen 
control  and  enforcement  to  ensure  compliance  with 
newly  adopted  BAT  conclusions.  This  has  been  followed 
up by the Commission through the reporting by Hungary 
to  the  EU  registry,  and  no  non-compliant  permits  were 
reported in 2018. On the action to address air and water 
pollution  caused  by  industrial  emissions,  there  has  been 
limited progress in the power sector, as described above. 

2022 priority action 

  Continue addressing pollution from large combustion 

plants. 

Preventing major industrial accidents – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals; 
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment; 
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents. 
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 
(the Seveso-III Directive)79. 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  to  the  eSPIRS  database  (2018)80  and  the 
report by Hungary on the implementation of the Seveso 
III Directive for 2015-201881. 

In  Hungary,  of  the  255  Seveso  establishments,  141  are 
categorised  as  lower-tier  establishments  and  114  as 
upper-tier  establishments  (UTEs),  based  on  the  quantity 
of hazardous substances likely to be present in them. The 
UTEs  are  subject  to  more  stringent  requirements.  The 
is 
change 
presented in Figure 22. 

in  the  number  of  Seveso  establishments 

79  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
80 European Commission, Seveso Plants Information Retrieval System.  
81 As provided for under Article 21(2) of the Seveso III Directive. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
 
                                                                 
Figure 22: Number of Seveso establishments in Hungary, 
2011, 2014 and 201882 

Many  Seveso  establishments  are  required  to  draw  up 
external  emergency  plans 
(EEPs).  These  EEPs  are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment  and  the  population  should  a  major 
industrial accident occur at them.  According to Hungary, 
an EEP is required for 98 UTEs. In 2018, 114 UTEs had an 
EEP, and 114 of these EEPs had been tested over the last 
3 years. A summary of EEPs in Hungary is shown in Figure 
23. The establishment of EEPs is essential to allow proper 
the 
preparation,  and  effective 
necessary  actions  to  protect  the  environment  and  the 
population 
accident 
a  major 
should 
nevertheless happen. 

implementation  of 

industrial 

Figure 23: Situation regarding EEPs in Hungary, 201883 

Hungary  22 

(ii) 

information  about 

the  appropriate 
accident; 
behaviour  in  the  event  of  a  major  accident;  and  (iii) 
information containing the date of the last site visit. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure  24.  This  is  an  important  rule  in  the  Seveso  III 
Directive  as  the  public’s  knowledge  of  this  information 
may  reduce  the  consequences  of  a  major  industrial 
accident. 

Figure 24: Share of UTEs for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Hungary, 2011, 2014 and 
201884 

include 

launched  an 

infringement 
In  2020,  the  Commission 
procedure  against  Hungary  for  failing  to  correctly  turn 
the  Seveso  III  Directive  into  national  law.  he  identified 
issues 
imprecise  definitions, 
improving  checks,  cross-border  cooperation  and  less 
stringent  requirements  on  information  to  the  public.  In 
2020,  Hungary  amended  its  legislation  and  notified  it  to 
the Commission. 

incorrect  or 

The  following  types  of  information  are  permanently 
available  for  100%  of  the  Seveso  establishments  in 
Hungary:  (i)  information  to  the  public  referred  to  in 
Annex V of the Seveso III Directive especially about how 
the  public  concerned  will  be  warned  if  there  is  a  major 

82 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 
83 See previous footnote. 

Noise 

The  Environmental  Noise  Directive  provides  for  a 
common  approach  to  avoid,  prevent,  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping and planning. A key target under the 2030 zero 
pollution  action  plan  is  to  reduce  by  30%  the  share  of 
people 
transport  noise 
compared to 2017. 

chronically  disturbed  by 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 

84 See previous footnote. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
Hungary  23 

in  the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress85. 

water resources, prevention of further deterioration and 
restoration to good status.  

limited  set  of  data86, 
In  Hungary,  based  on  a 
environmental  noise  is  estimated  to  cause  at  least  400 
premature  deaths  and  1  100  cases  of  ischaemic  heart 
disease  annually87.  Moreover,  some  100  000  people 
suffer  from  disturbed  sleep.  In  Hungary,  the  number  of 
people exposed to noise  dropped by 17% between 2012 
latest  full  set  of 
and  2017.  On  the  basis  of  the 
information  analysed,  noise  mapping  of  urban  areas, 
roads and railways is complete. 

By  March 2022, all  Member  States  had  to report on  the 
third  generation  of  river  basin  management  plans 
(RBMPs). Member States are required under the WFD to 
draw  up  RBMPs  for  all  river  basins  on  their  territory. 
Hungary has reported on time. The Commission will now 
assess  the  reported  status  of  river  basins  and  progress 
made  in  these  river  basins,  checking  how  the  findings 
identified in the Commission’s assessment of the second 
generation of RBMPs91 have been addressed.  

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal,  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining,  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

Water Framework Directive 

The  Water  Framework  Directive 
the 
cornerstone of EU water policy in the 21st century89. The 
legislation90  set  the 
WFD  and  other  water-related 
integrated  water 
sustainable  and 
framework 
management, which aims at a high level of protection of 

(WFD)88 

for 

is 

85 WHO 2018, Environmental Noise Guidelines for the European Region. 
86  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
87  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based on  : (i) the  data  reported  by  the  Member  States 
on noise exposure  covered  by  Directive  2002/49/EC; (ii) ETC/ATNI, 
2021, Noise indicators  under  the  Environmental Noise Directive  2021: 
Methodology  for  estimating  missing  data,  ETC/ATNI  Report  No 
2021/06, European Topic Centre on Air Pollution, Transport, Noise and 
Industrial  Pollution;  and  (iii)  the  methodology  for  health  impact 
calculations, ETC/ACM,  2018,  Implications  of  environmental noise on 
health  and  wellbeing  in  Europe,  Eionet  Report  ETC/ACM  No  2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation. 
88 The Water Framework Directive (2000/60/EC). 
89 The EU Water Policy. 
90  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the 
(2010/75/EU),  and  the  new 
Regulation on minimum requirements for water reuse (2020/741). 

Industrial  Emissions  Directive 

which 

Report92, 

The  Commission  published  in  December  2021  the  6th 
Implementation 
assesses 
implementation  of  the  WFD  and  the  Floods  Directive. 
This report includes an interim assessment on progress of 
the implementation of the programmes of measures and 
monitoring  of 
the  new  priority  substances.  The 
assessment  report  for  Hungary93  showed  that  the 
measures implemented (135 measures accross 33 groups 
of action) are, in most cases, contributing to reaching the 
objectives of the second generation RBMPs and the WFD. 
However, 
that  agricultural 
measures  are  not  advancing  to  meet  the  targets  of  the 
WFD – Hungary is planning large-scale irrigation projects 
to  refurbish  of  existing  infrastructure  and  expand  the 
irrigated area. 

the  assessment 

found 

Based  on  the  second  generation  of  RBMP  reporting  and 
data  published  in  202094,  8.3%  of  all  Hungarian  surface 
water  bodies95  reached  good  ecological  status  (with 
13.5%  of  surface  water  bodies  having  unknown  status), 
and  only  45.7%  have  good  chemical  status  (with  46.5% 
having  unknown  status). 20.5%  of  groundwater  bodies 
failed to achieve good chemical status, and 20.0.% are in 
poor quantitative status. 

Figure  25  illustrates  the  proportion  of  surface  water 
bodies  in  Hungary  and  other  European  countries  that 
failed to achieve good ecological status. 

91  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
92 See the 6th Implementation Report of the WFD and Floods Directive. 
93  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Hungary, 2022. 
94 WISE Freshwater (europa.eu). 
95  Surface  water  bodies  are  rivers,  lakes,  and  transitional,  coastal,  and 
territorial waters. 

Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
                                                                 
Hungary  24 

Under  the  IED,  Hungary  showed  a  significant  decrease 
over the last decade (80.4%) in  releases of heavy metals 
like Cd, Hg, Ni, and Pb. It also saw a big decline (55.5%) in 
Total  Organic  Carbon  released  to  water  over  the  same 
period98. 

is  4  300.30  hm3 

The  total  water  abstracted  annually  (corresponding  to 
2019  as  the  baseline  year)  in  Hungary  from  surface  and 
groundwater  sources 
(European 
Environment  Agency,  2022).  The  percentage  for  water 
abstraction per sector is 3.29% for agriculture, 14.96% for 
public  water  supply,  79.03%  for  electricity  cooling,  and 
2.73% for manufacturing (see Figure 27). Hungary uses a 
register to monitor water abstractions. Small abstractions 
in Hungary do not require permits but must be declared. 
Nevertheless,  not  all  abstractions  are  registered.  In 
Hungary,  there  are  several  types  of  water  abstraction 
records  kept  by  water  protection  authorities,  water 
management directorates, and notaries of municipalities. 

Figure 27: Water abstraction by sector in Hungary99 

Figure 25: Proportion of surface water bodies (rivers, 
lakes, transitional waters and coastal waters) in less 
than good ecological status per river basin district96 

Figure  26  presents  the  percentage  of  surface  water 
bodies  in  Hungary  and  other  European  countries  not 
achieving good chemical status. For Hungary, this is 7.8% 
if  one  includes  water  bodies  failing  due  to  substances 
(uPBTs  –  persistent, 
behaving  as  ubiquitous  PBTs 
bioaccumulative  and  toxic).  Without  uPBTs,  6%  of 
Hungarian  surface  water  bodies  fail  to  achieve  good 
chemical status. 

Figure 26: Percentage of surface water bodies not 
achieving good chemical status97 

In Hungary, the water exploitation index plus (WEI+)100 is 
1.19%,  which  is  less  than  the  20%  that  is  generally 
considered to indicate water scarcity101. 

98  European  Environment  Agency,  Water  pollutant  releases  changes 
from 2010 to 2019 for the EU Member States, June 2021. 
99European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
100  The  water  exploitation  index  plus  (WEI+)  is  a  measure  of  total 
freshwater use as a percentage of the renewable freshwater resources 
(groundwater and surface water) at a given time and place. It quantifies 
how much water is abstracted and how much water is returned to the 
environment after use. 
101  By  May  2022,  EEA  will  develop  a  seasonal  WEI+  at  river  basin  and 
NUTS2  level,  which  provides  a  more  complete  picture  of  water  stress 
and water scarcity for each Member State. 

96  European  Environment  Agency,  Percentage  of  water  bodies  not  in 
good ecological status or potential, per river basic district, 2021. 
97  European  Environment  Agency,  Percentage  of  water  bodies,  not  in 
good  chemical  status,  with  uPBT,  per  river  basic  district,  December 
2019. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
                                                                 
 
 
 
                                                                 
Hungary  25 

Figure 28 presents the WEI+  index in Hungary and other 
EU  countries.  Hungary  is  ranked  19th  in  the  EU  on  the 
WEI+ (with 1st indicating a country that has a high water 
exploitation capacity and therefore a country with water-
scarcity problems). 

successful 

River  restoration  projects  in  Hungary  are  considered  to 
be 
risk 
management, in particular, the river restoration projects 
(using  nature-based  solutions)  in  the  Mosoni-Danube 
River area and in Nagy-Pándzsa104. 

rehabilitation  and 

flood 

in 

Figure 28: Water exploitation index plus (WEI+) in the 
EU, 2017102 

Drinking Water Directive 

On  the  Drinking  Water  Directive105,  no  new  assessment 
of the quality of  drinking water  has been available  since 
the 2019 EIR. 

Since 2016, as part of a pending infringement procedure, 
the  Commission  has  been  calling  on  Hungary  to  ensure 
safe  drinking  water  for  the  population.  EU  rules  require 
is  free  from  micro-organisms, 
that  drinking  water 
parasites  and  any  substances  that  constitute  a  potential 
danger  to  human  health.  The 
last  progress  report 
submitted in January 2022 shows that, to date, 11 zones 
are  still  non-compliant  with  EU  parametric  values  for 
arsenic  and  boron.  The  report  also  indicates  that  the 
deadline  for  the  infrastructure  work  needed  to  resolve 
the issue was extended too afterwards.  

The  recast  Directive106  entered  into  force  on  12  January 
2021, and Member States have until 12 January 2023 to 
turn  it  into  national  legislation.  Hungary  will  have  to 
comply with these revised quality standards. 

Bathing Water Directive 

In  2020,  of  the  264  Hungarian  bathing  waters,  69.7% 
were  of  excellent  quality  (see  Figure  29)107.  Detailed 
information  on  Hungarian  bathing  waters  is  available 
from  a  national  portal108  and  via  an  interactive  map  of 
the European Environment Agency109. 

Floods Directive 

As  mentioned  earlier,  the  Commission  adoped  the  6th 
Implementation  Report 
in  December  2021,  which 
assesses  the  implementation  of  both  the  WFD  and  the 
Floods Directive. The report includes a review and update 
of  the  preliminary  flood  risk  assessments  (PFRAs)  drawn 
up  by  Member  States  during  the  second  cycle  (2016-
2021). 

The  report103  showed  that  after  the  first  cycle’s  PFRA 
report, Hungary significantly revised its areas of potential 
significant  flood  risk  (APSFRs).  As  a  result,  419  new 
APSFRs were identified and reported in the second cycle, 
which provides for better granularity in their analysis and 
designation. However, further consideration needs to be 
given  to  how  long-term  developments  will  be  likely  to 
affect  flood  risks  in  APSFRs.  The  assessment  identified 
many other areas for further improvement, such as more 
clarity  on  criteria  for  defining  the  significant  impact  of 
flood  events  and  making  the  PFRA  report  publicly 
available.  

In  Hungary,  close  to  one  quarter  of  the  territory  is 
exposed to floods.  

Hugngary has not yet reported on the second generation 
of  Flood  Risk  Management  Plans  (FRMPs)  under  the 
Floods  Directive.  The  Commission  will  assess  progress 
since  the  adoption  of  the  first  flood  risk  management 
plans and publish a new report, as it did in 2019.  

102 European Environment Agency, Water exploitation index plus, 2022. 
103  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification  of  Areas  of  Potential  Significant  Flood  Risk  under  the 
Floods Directive: Member State: Hungary, 2022. 

104 EC, 2021 
105 OJ L 330, 5.12.1998, p. 32-54. 
106 OJ L 435, 23.12.2020, p. 1-62. 
107  European  Environment  Agency,  2021.  State  of  bathing  water  – 
European Environment Agency (europa.eu), p. 17. 
108 Hungary’s national bathing water portal. 
109  European  Environment  Agency,  State  of  bathing  waters  in  2020  – 
European Environment Agency (europa.eu). 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
 
                                                                 
Figure 29: Bathing water quality in Europe in the 2020 
season110 

50 mg/l. A very high number of surface waters have been 
identified as eutrophic. 

Hungary  26 

Hungary has a relatively low livestock density, the surplus 
of nitrogen is below the average for the EU, and there is a 
deficit  of  phosphorus.  However,  Hungary  records  bad 
water quality in several parts of the country and is among 
the  Member  States  facing  the  biggest  challenges  in 
tackling nutrient pollution from agriculture. 

The  Hungarian  action  programme  was  published  for  the 
first time in 2001 and was reviewed in 2017 and 2019. 

Urban Waste Water Treatment Directive 

Figure 30: Hungary, Bathing water quality, 2017-2020111 

In  recent  years,  Hungary  has  had  difficulties  in  meeting 
its  obligations  under  the  Urban  Waste  Water  Treatment 
Directive  (UWWTD). The overall  compliance  rate is  52%, 
which  is  lower  than  the  EU  average  in  2018.  3.1%  of 
urban wastewater in Hungary is not collected, and 11.5% 
for  biological 
does  not  meet 
treatment113. 

requirements 

the 

Figure 31: Proportion of urban wastewater that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal) in compliant urban areas of the 
UWWTD (‘compliance rate’), 2018114 

Nitrates Directive 

According  to  the  last  implementation  report  on  the 
Nitrates  Directive112,  groundwater  quality  in  Hungary  is 
generally good. However, there are some hotspots where 
nitrate concentration is increasing and with levels above 

In  recent  years,  there  have  been  improvements 
in 
compliance  with  the  UWWTD,  for  which  the  use  of  EU 
funding  has  been  essential.  In  2017,  the  Commission 
launched  an  infringement  procedure  against  Hungary 
failing to comply with the UWWTD. As of 2021, 22 urban 
areas are  still not  compliant  with the Directive, as these 
areas do not  provide all their residents  with a  collection 
system  for  urban  wastewater  or  an  alternative  with  the 
same  level  of  environmental  protection.  As  it  is  not 

110 European Environment Agency, Bathing Water Quality in 2020, 2022. 
111  European  Environment  Agency,  European  Bathing  Water  Quality 
in 2017, 2018, 2019, 2020. 
112 Implementation of the Nitrates Directive in the EU. 

113 Hungary (europa.eu). 
114 European Commission, WISE Freshwater, 2021. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
properly collected, the wastewater cannot be treated as 
required  by  EU  law.  In  addition,  Hungary  is  in  breach  of 
ensuring  more  stringent  treatment  for  five  other  urban 
areas.  Therefore,  the  Commission  decided  to  refer 
Hungary to the CJEU in June 2021. 

In the 2019 EIR, Hungary received four priority actions for 
water  management.  There  has  been  significant  progress 
on the first action to assess the status of all water bodies. 
The  action  is  proposed  again  to  encourage  further 
efforts.  On  the  action  to  ensure  that  abstractions  are 
subject  to  effective  permits,  metering  and  checks,  there 
is  no  information  available.  On  the  action  to  complete 
the  implementation  of  the  UWWTD,  there  has  been 
limited progress, so it is proposed again. On clarifying the 
method 
the 
assessment  of  costs  and  benefits  of  the  flood  risk 
management plan) there is no information available. 

for  prioritising  measures 

(including 

2022 priority actions 

  Assess new physical modifications  to water bodies in 
line with  Article 4(7) of the  WFD.  These assessments 
should  consider  alternative  options  and  propose 
suitable mitigation measures. 

  Continue  current  efforts  to  prevent  further  nitrates 

pollution in groundwater. 

  Review  the  designation  of  nitrate  vulnerable  zones 
and  include  areas  where  there  is  a  lot  of  pressure 
from  agriculture  and  where  drainage  reinforces  the 
eutrophication of waters. 

  Better  coordinate 
nature policies. 

implementation  of  water  and 

  Fully  implement  the  UWWTD  for  all  urban  areas  by 

building up the necessary infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment. 
In 
October  2020,  the  Commission published  its  chemicals 
'Towards  a  Toxic-Free 
strategy  for  sustainability  - 
Environment'115  which  led  to  some  systemic  changes  in 
EU  chemicals  legislation.  The  strategy is  part  of  the  EU's 
zero-pollution  ambition  –  a  key  commitment  of  the 
European Green Deal. 

115 COM(2020) 667 final. 

Hungary  27 

legislation116  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the single market. 

in 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’). 
In  December  2020,  the  Commission  assessed  Member 
States’  reports of  these  Regulations117, 
line  with 
Article 117(1)  of  the  REACH  Regulation  and  Article 46(2) 
of  the  CLP  Regulation.  According  to  the  latest  available 
data, national enforcement structures have not changed 
much  in  recent  years.  However,  it  is  apparent  from  the 
latest report in 2020 that there are still many disparities 
in the implementation of the REACH and CLP Regulations, 
and  notably  in  the  area  of  law  enforcement.  Recorded 
compliance  levels  in  Member  States  seem  to  be  quite 
stable over time, but with a slight worsening trend, wich 
is  likely  due  to  :  (i)  enforcement  authorities  being  more 
effective 
in  detecting  non-compliant  products  and 
companies;  and  (ii)  more  non-compliant  products  being 
put on the EU market. 

In August 2021, the Commission published a measurable 
assessment of the enforcement118 of the REACH and CLP 
Regulations using a set of indicators on different aspects 
of enforcement. 

Hungary  has  devised  and  fully  implemented  REACH  and 
CLP enforcement strategies119, including: 

  annual  work  plans  at  national  level  –  regions  can 

 
 

adopt priorities tailored to local level; 
focus on REACH-EN-FORCE projects topics; 
inspections  reported  quarterly  to  the  National  Public 
Health  Centre  –  an  evaluation  of  the  enforcement 
strategy is based on these reports. 

In  Hungary,  160  inspectors  (for  all  chemicals  regulations 
and  other  areas)  are  assignated  to  REACH  and  CLP 
enforcement120. In  the  reporting  period  (2019),  20 574 
REACH  checks  were  carried  out.  The  low  percentage  of 
non-complianct  cases  out  of  the  total  number  of  REACH 

116  Mainly  for  chemicals:  REACH  (OJ  L  396,  30.12.2006,  p. 1.);  for 
Classification,  Labelling  and  Packaging,  the  CLP  Regulation  (OJ  L  252, 
31.12.2006,  p. 1.),  together  with  legislation  on  biocidal  products  and 
plant protection products. 
117  European  Commission,  Final  report_REACH-CLP  Member  States 
reporting_2020.pdf (europa.eu). 
118  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators, 2021. 
119European  Commission,  Final  report_REACH-CLP  Member  States 
reporting_2020.pdf (europa.eu), p. 76. 
120 European Commission, Final Report, on the operation of REACH and 
CLP,  Final  report_REACH-CLP  Member  States  reporting_2020.pdf 
(europa.eu), p. 74. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
                                                                 
and  CLP  checks  is  far  below  the  average121.  Hungary  is 
among the countries with the highest number of appeals 
filed  against  national  enforcement  decisions 
in  the 
previous reporting period (2015-2019). 

The  number  of  enquiries  received  by  helpdesks  in  2019 
was 143 for REACH and 196 for CLP. In Hungary, the main 
enquiries  were  about  REACH  the  registration,  chemical 
safety  reports  and  safety  data  sheets  (SDS),  import 
obligations  and  general  questions  on  SDS.  On  CLP,  the 
main  enquiries  concern  labelling  and  classifications.  The 
competent  Hungarian  authority  raised  awareness  using 
websites, social media, events, fairs, leaflets, newsletters, 
and articles. 

The 2019 EIR did not set any priority actions for Hungary 
for chemicals. 

Figure 32: Percentage of non-compliance cases out of 
the total number of REACH and CLP checks during 2019 
per Member State and compared to the EU average122 

Hungary  28 

2022 priority action 

 

 Upgrade administrative capacities in implementation 
and  enforcement  towards  a  policy  of  zero  tolerance 
to instances of non-compliances. 

report_REACH-CLP  Member  States 

121  Final 
(europa.eu), p. 87-88. 
122 European Commission, Final  report  on the operation of REACH and 
CLP, p. 87-88, 2022. 

reporting_2020.pdf 

Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
 
 
 
Hungary  29 

4. Climate action

to 

(NDC) 

law  also 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
limits  the 
2030  compared  to  1990.  The 
contribution  that  carbon  removals  can  make  towards 
emission  reductions 
in  2030  to  ensure  a  sufficient 
mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
the 
nationally  determined  contributions 
UNFCCC in December 2020.  
The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from  transport,  the  maritime  sector,  and  fluorinated 
gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010123  and  sets  binding  GHG  emission 
standards for different vehicle categories124.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF have been included in the EU emission-reduction 
efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
their  national  adaptation 
required 
policies125,  as  the  EU  Climate  Law  recognises  adaptation 
as a key component of the long-term global response to 
climate change. Member States will be required to adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

report  on 

to 

Key national climate policies and strategies 

Hungary  has  an  integrated  national  energy  and  climate 
plan  for  2021-2030.  The  country  is  bound  to  reach 
climate neutrality in line with the EU general target. The 

123  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements  for  fuels  used  in  road  transport  in  the  EU  to  protect 
human health and the environment, and to make road travel across the 
EU safer. 
124 Directive 98/70/EC. 
125 Article 29 of Regulation (EU) 2018/1999. 

national objective is to reduce emissions by  7%  by 2030 
and become climate-neutral by 2050.  

The  national  adaptation  strategy  has  been  revised  to 
maintain  the  natural  and  socio-economic  conditions  of 
Hungary.  The  strategy  responds  flexibly  to  climate 
change  and  prevents  risks  and  minimises  damage 
through an innovative framework supporting sustainable 
development.  

Between 1990 and 2019, economy-wide greenhouse gas 
emissions  decreased  by  32%.  In  2020,  Hungary’s  total 
greenhouse gas emissions (excluding the land use sector) 
amounted to 64 Mt CO2-eq, or 68% of its 1990 levels. 

Figure 33: Total greenhouse gas emissions (incl. 
international aviation) in Hungary, 1990-2020 

Effort sharing target  

For emissions not covered by the  EU’s emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets126 under the Effort Sharing Regulation127 (ESR) for 
the  period  2021-2030.  Under  EU  legislation,  Hungary’s 
2020 target makes it possible to increase greenhouse gas 
emissions  in  the  non-ETS  sectors  (buildings,  road  and 
domestic  maritime  transport,  agriculture,  waste,  and 
small industries) by 10% and reduce emissions by 7% by 
2030  compared  to  2005  levels.  Hungary  significantly 
overachieved  its  2020  target.  With  additional  measures 
being considered, Hungary is projected to overachieve its 
2030 effort sharing target by 15 percentage points. 

126 Effort sharing 2021-2030: targets and flexibilities (europa.eu) 
127 Regulation (EU) 2018/842 

Environmental Implementation Review 2022 – Hungary 

 
                                                                 
 
 
                                                                 
Hungary  30 

Figure 34: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in Hungary, 
2020 and 2030 as percentage change from 2005 

transport  sector,  and  comprehensive  measures  are 
needed to reverse this trend. 

Figure 36: Greenhouse gas emissions by sector in 
Hungary128 – historical emissions 1990-2019, projections 
2021-2030129 

Figure 35: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/ deficit of AEAs under the 
Effort Sharing Decision in Hungary, 2013-2020 

Key sectoral developments 

In road transport, the greenhouse gas intensity of vehicle 
fuels in Hungary decreased by 3%. The country needs to 
act  swiftly  to  meet  the  current  EU  reduction  target  of  a 
6%  decrease  by  2020.  There  are  several  types  of 
measures  that  the  Member  States  can  take  to  achieve 
this,  for  example:  (i)  further  expanding  the  use  of 
electricity  in  road  transport;  (ii)  supporting  the  use  of 
biofuels,  and  advanced  biofuels 
(iii) 
incentivising  the  development  and  deployment  of 
renewable fuels of non-biological origin; and (iv) reducing 
upstream emissions before refining processes. 

in  particular; 

Road  transport  in  2019  in  Hungary  represented  22%  of 
the  country’s  total  greenhouse  gas  emissions.  Emissions 
of greenhouse gases from road transport have increased 
by 24% compared to 2005. Over the last 5 years, Hungary 
has experienced a  strong increase in emissions  from the 

To reduce emissions in the buildings sector, modernising 
buildings and heating systems is needed. After the most 
recent  assessment  of  the  national  energy  and  climate 
plan,  the  Commission  recommended  supporting  energy 
efficiency  investment  in  residential  housing  and  public 
buildings. 

Greenhouse gas emissions in agriculture are increasing. 

-3.8 Mt  CO2-eq 

In  the  land  use,  land  use  change  and  forestry  (LULUCF) 
sector,  Hungary  expects  to  see  decreasing  net  removals 
of CO2 equivalent by 2030. Reported quantities under the 
Kyoto  Protocol  for  Hungary  show  net  removals  of,  on 
for  2013-2019.  Hungary 
average, 
therefore contributes 1.1% to the EU-27’s annual average 
carbon  ‘sink’  of  -344.9  Mt  CO2-eq.  Using  a  separate 
measurement  scheme,  carbon  accounting  for  the  same 
period  shows  net  credits  of  -2.7  Mt  CO2-eq  on  average, 
which  corresponds  to  2.3%  of  the  EU-27  accounted  sink 
of 
-115.0 Mt  CO2-eq.  Reported  net  removals  and 
accounted net credits show a strongly fluctuating pattern 
with a small increase over the 7-year period. 

in 

to 

the 

figure  correspond 

128  The  sectors 
following 
Intergovernmental  Panel  on  Climate  Change  (IPCC)  sectors:  Energy 
supply:  1A1,  1B  and  1C;  Energy  use  in  manufacturing  industries:  1A2; 
Industrial  processes  and  product  use:  2;  Transport:  1A3;  Other  energy 
use:  1A4,  1A5  and  6;  Agriculture:  3;  Waste:  5;  International  aviation: 
1.D.1.a. 
129 European Environmental Agency, Total GHG trends and projections. 

the 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
 
 
 
                                                                 
Figure 37: Reported and accounted emissions and 
removals from LULUCF in Hungary130 

Hungary  31 

Use of revenue from the auctioning of EU ETS 
allowances 

from 

revenue 

Total 
the  auctioning  of  emission 
allowances  in  Hungary  under  the  EU  ETS  in  2012-2021 
were  almost  EUR  1.3  billion.  In  Hungary,  50%  of  the 
revenue  is  spent  on  climate  and  energy,  and  the  other 
50% goes to the national budget. 

2022 priority actions 

  Make  the  most  of  the 

large  energy  efficiency 
potential  in  Hungary,  especially  in  buildings  and  the 
transport sector.  

  Accelerate  further  deployment  of  renewables  and 
promote  renewables  in  the  electricity  and  heating 
sectors  (including  measures  to  boost  electricity 
production  with  solar  photovoltaics),  and  upgrade 
existing  infrastructure.Improve  sustainable  transport 
and  support  electro-mobility,  charging  infrastructure 
and other alternative fuels. 

  Ensure sustainability of biomass energy. 

130  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the Explanatory note 
on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol. 

Environmental Implementation Review 2022 – Hungary 

 
 
 
 
 
 
                                                                 
 
 
 
Hungary  32 

Part II: Enabling framework: Implementation tools

5. Financing

Environmental investment needs in the 
European Union 

on  the  levels  of  circularity  implemented.  The  annual 
biodiversity financing gap is estimated at around EUR 20 
billion. 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps.  
Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)131  will  also  be 
reflected in the EU budget. 

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
is  taken)  for  climate,  energy  and 
additional  action 
transport were estimated in 2021 at EUR 390 billion year 
(EU-27)132 with a further EUR 130 billion a year to deliver 
the  EU’s  core  environmental  objectives133.  The  costs  of 
climate  adaptation  can  also  be  significant  and  are 
estimated to reach a total of EUR 35-62 billion (narrower 
scope)  or  EUR  158-518  billion  (wider  scope)  a  year134. 
Those  investment  needs  do  reflect  the  implementation 
objectives  to  2020  and  to  2030  (except  for  climate 
adaptation, the costs of which are expected to last over a 
longer time horizon).  

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1135.  Almost  40%  of 
the  environmental  investment  needs  relate  to  dealing 
with  pollution,  which  accounts  for  almost  65%  of  the 
total  gap  if  combined  with  water  management.  The 
investment  gap  in  circular  economy  and  waste  and  is 
estimated  between  EUR  13-28  billion  a  year,  depending 

Table 1: Estimated breakdown of the EU’s 
environmental investment needs, by environmental 
objective , 2021-2030 (per year)136 

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

& 

& 

Biodiversity 
ecosystems137 

Research, 
development 
innovation 

Total 

Estimated investment gap (EU-27, 
p.a.)  

EUR billion 

42.8 

26.6 

13.0 

21.5 

6.2 

% 

39% 

24% 

12% 

20% 

6% 

110.1 

100% 

Environmental investment needs in Hungary 

There  is  a  clear  shift  of  investment  priorities  in  Hungary 
to  support  climate,  energy  and  transport  policies.  There 
is  also  a  great  need  in  Hungary  for  investment  in  water 
and  waste 
infrastructure,  biodiversity  and  nature. 
Climate 
investment  priorities  address  the  needs  or 
‘investment gaps’ in several economic sectors such as the 
and 
energy 

renovation  of  housing, 

e-mobility 

131  The  Convention  on  Biological  Diversity  (cbd.int);  Post-2020  Global 
Biodiversity Framework | IUCN. 
132  SWD(2021)621,  accompanying  proposal  COM(2021)557  to  amend 
the REDII Directive (EU) 2018/2001. 
133 SWD(2020) 98 final/2. 
134  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018)385). 
135  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives. 

136 European Commission, DG Environment, ‘Study supporting EU green 
investment  needs  analysis’  (ongoing,  2021-2023)  and DG  Environment 
internal analysis ‘Environmental investment  needs  and financing  in the 
EU’s green transition’, July 2020. 
137  To  meet  the  needs  of  the  2030  biodiversity  strategy  (Natura  2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for  nature  (COM/2020/380  final)  while  EUR 30-35  billion  may  be 
needed  to  fully  cover  the  strategy  (including  restoration),  indicating  a 
gap  of  EUR 10-20  billion  a  year  compared  to  current  baseline 
expenditure. 

 Environmental Implementation Review 2022 – Hungary 

 
                                                                 
 
 
 
                                                                 
following 
transportation 
environmental investment needs have been identified by 
sector. 

infrastructures. 

The 

Pollution prevention and control 

The  EU’s  first  Clean  Air  Outlook138  under  the  clean  air 
programme  estimated  that,  to  reach  the  emissions 
reduction requirements in the NECD by 2030139, total air 
pollution  control  costs  for  Hungary  would  be  equivalent 
to  EUR 874  million  a  year.  This  includes  EUR 592  million 
for  capital  investment  (assuming  Hungary  achieves  the 
2030 climate and energy targets). 

The  second  Clean  Air  Outlook140  suggests  that  the 
EU would  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NECD for 2030 if: (i) all relevant legislation adopted up to 
2018  is  implemented  (including  all  air  pollution  targets 
and the 2030 climate and energy targets set in 2018); and 
(ii)  Member  States  also  implemented  the  measures 
announced 
in  their  national  air  pollution  control 
programmes.  The  only  exception  is  for  ammonia  for  15 
Member States, excluding Hungary.  

Water management 

is 

is  expected  to  become  more 

According  to  the  OECD  study  Financing  a  Water  Secure 
Future  (2022)141,  Hungary  ranks  first 
in  terms  of 
population  connected  to  water  supply,  the  quality  and 
extent of the wastewater infrastructure are closer to the 
EU  average.  Climate  change 
likely  to  affect  the 
availability  and  quality  of  water  in  Hungary  because  the 
like 
climate 
in  the 
Mediterranean.  Water  resources 
in  Hungary  already 
show  regional  and  seasonal  variations,  which  may 
escalate with climate change and cause changes in water 
consumption  patterns.  Droughts  can  be  observed, 
especially in the Great Plains – extreme droughts resulted 
in  financial  losses  of  around  1.4%  of  GDP  in  2012142. 
However,  an  increase  in  the  frequency  and  intensity  of 
heavy  precipitation  will 
in 
inhabited areas. 

increase  costly 

floods 

Hungary  33 

EU  funding  has  provided  a  significant  share  of  public 
funding  over  the  past  decade143.  It  is  estimated  that 
Hungary will need to invest an additional cumulative EUR 
2.237  billion  by  2030  over  the  baselines  for  drinking 
water  and  sanitation  –  corresponding  to  an  investment 
need (capital expenditure) of around EUR 223.7 million a 
year, with over 90% of that for wastewater144. Moreover, 
the recent 6th WFD and Floods Directive implementation 
study146 
report145  and 
financial 
accompanying 
relevant  source  of 
information in this domain. 

the 
it,  are  also  a 

-  economic 

Waste and circular economy 

According to a Commission study147, if Hungary is to meet 
its  recycling  targets  for  municipal  waste  and  packaging 
waste,  it  still  needs  to  invest  an  additional  EUR  348 
million  (around  49.7  million  a  year)  over  its  baselines  in 
2021-2027.  Investment  is  needed  in  collection,  recycling 
reprocessors,  biowaste 
sorting 
facilities,  and  waste  registry  digitalisation.  This  does  not 
include  the  investment  necessary  in  other  key  waste 
streams (plastics, textiles, furniture) or the investment to 
increase  circularity  and  waste  prevention  across  the 
economy. 

treatment,  waste 

Biodiversity and ecosystems 

The  recently  submitted  priority  action  framework  (PAF) 
for Hungary shows that nature protection costs (including 
Natura 2000) in 2021-2027 are EUR 361.6 million a year, 
of  which  EUR  168  million  (around  half)  constitutes  one-
off  costs148.  This  excludes  additional  costs  to  implement 
the  biodiversity  strategy  to  2030,  including  those  for 
increased protection and restoration. 

EU environmental funding 2014-2020 

The  multiannual  financial  framework  (MFF)  for  2014-
2020  allocated  almost  EUR  960  billion  (in  commitments, 

138 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU’s  air  quality  and  emissions 
objectives, 2018. 
139  Covering  the  reductions  of  and  the  emission  ceilings  for  five 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
140  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis  (IIASA),  Support  to  the  development  of  the  Second  Clean  Air 
Outlook, 2020 and Annex. 
141 OECD, Financing a Water Secure Future, 2022. 
142  OECD,  Hungary  -  Country  fact  sheet-  Financing  Water  Supply, 
Sanitation and Flood Protection. 

143 OECD, Financing a Water Secure Future, 2022. 
144  OECD,  Hungary  -  Country  fact  sheet-  Financing  Water  Supply, 
Sanitation and Flood Protection. 
145 WFD and FD Implementation Reports – DG Environment – European 
Commission. 
146  European  Commission,  Directorate-General 
for  Environment, 
Economic  data  related  to  the  implementation  of  the  WFD  and  the  FD 
and the financing of measures, Final report. Publications Office, 2021. 
147  European  Commission,  Study  on  investment  needs  in  the  waste 
sector  and  on  the  financing  of  municipal  waste  management  in  the 
Member States, 2019. 
148  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
 
                                                                 
2011 prices)149 for the EU to spend over this period. The 
commitment 
in  the  2014-2022  MFF  to  the  green 
transition included a 20% climate spending target. It also 
included  funding  opportunities  for  the  environment,  in 
particular, under the European Structural and Investment 
(ESI)  Funds150.  The  2014-2020  MFF  budget  was 
subsequently  topped  up  with  over  EUR  50  billion  (in 
current  prices)  from  the  REACT-EU  programme  for 
cohesion policy action against COVID-19151.  

Hungary received EUR 26.8 billion from the ESI  Funds  in 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR 3.3 billion, with a further EUR 1.9 billion identified as 
indirect  environmental  investment,  totalling  EUR  5.1 
billion.  Figure  39  gives  an  overview  of  (planned) 
individual ESI Funds earmarked for Hungary (EU amounts, 
without national amounts). 

Hungary  34 

Figure 38: ESI Funds allocated to Hungary, including 
environmental investments, 2014-2020152 

Table 2: Direct and indirect Environmental investments 
under the ESI Funds in Hungary, 2014-2020153 

Instrument 

Under cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
waste 
air quality 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Allocations  
for the environment  
(EUR million) 

4 792.1 
3 001.1 
1 115.8 
401.4 
17.6 
208.0 
352.7 
905.6 
1 791.0 
247.4 
440.7 

Policy 

Funds 

(COWI, 

2017), Regulation 

fields  and  coefficients  under  Regulation 

152  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
(EU)  No  215/2014. Cut-off  date 
for  data:  December  2021. 
Environmental investments here are captured via the combined use of 
(EU)  No 
intervention 
1303/2013 and Regulation  (EU)  2021/1060 allowing for  a  more  precise 
identification  and  valuation  of  relevant environmental investments. 
N.B.  Indirect  environmental  investments  are  valued  using  the  Annex  I 
environmental  coefficients  of  the Regulation 
(EU)  2021/1060 (as 
opposed to full value). 
153  European  Commission,  DG  Environment  -  Data analysis. The  values 
the  specific 
of  environmental 
environmental  areas  may  differ 
values 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis covered the full range of ESI 
Funds. 

identified  here 
the 
from 

in 
tracking 

investments 

149 Council Regulation (EU, Euratom) No 1311/2013. 
150  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI),  the  European  Agricultural  Fund  for  Rural  Development  (EAFRD) 
and the European Maritime and Fisheries Fund (EMFF). 
151 Regulation (EU) 2020/2221. 

 Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
  
                                                                 
other energy154 
sustainable transport 
sustainable tourism 

Under EAFRD/rural development 
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

41.5 
902.2 
159.2 

345.1 
275.8 
34.0 
241.8 
69.3 
9.9 
59.3 

6.9 
6.9 
6.9 

5 144.1 
3 283.9 
1 860.3 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme, Horizon 2020, or European Investment Bank 
(EIB)  financing.  This  amounts  to  an  estimated  total  of 
EUR  5.5  billion  of  EU  environmental  financing  for 
Hungary in 2014-2020. 

It 

is  entirely  dedicated 

The  LIFE  programme155 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best-practice  actions  for  green 
solutions to be deployed. In 2014-2020, Hungary received 
EU  support  for  seven  LIFE  projects  (for  nature  and 
environment) worth EUR 31.2 million (out of 1 028 EU27 
LIFE  projects  with  a  total  EU  contribution  of  EUR  1.74 
billion)156.  In  2019,  two  LIFE-integrated  projects  started. 
LIFE  IP  GRASSLAND157  aims  to  improve  the  conservation 
status  of  grasslands  and  related  species  (with  an  EU 
contribution  of  EUR  10,3  million),  and  LIFE  IP  HungAIRy 
aims  to  improve  air  quality  (with  an  EU  contribution  of 
EUR 9.5 million).  

In  2014-2020,  Horizon  2020  allocated  about  EUR  11.6 
million  to  Hungary  for  the  environment,  representing 
3.1%  of  the  country’s  total  allocation158.  The  Horizon 
2020 funds directed at Hungarian environmental projects 

154  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
Regulation (EU) 2021/1060, Annex I. 
155 European Commission, LIFE Programme. 
156 Source: LIFE (europa.eu). 
157 LIFE-IP GRASSLAND, Long term conservation of Pannonian grasslands 
and  related  habitats  through  the  implementation  of  Prioritised  Action 
Framework (PAF) strategic measures, project website. 
158  EASME,  Horizon  2020  Environment  and  resources  data 
hub. 

Hungary  35 

focused, in particular, on the circular economy, research 
and innovation, raw materials, nature and resources. 

received  EUR  283.8  million 

From  the  European  Fund  for  Strategic  Investments, 
Hungary  did  not  receive  any  environmental  funding  out 
of its total allocation (EUR 364.9 million)159. From the EIB, 
Hungary 
for  direct 
environmental  investments  specifically  for  water  and 
sewerage  and  some  limited  funding  for  waste.  This  is 
4.9%  of  the  total  EIB  loans  for  Hungary  (EUR  5.8 
billion)160. The country ranks 15th in the amount of total 
EIB lending it received in this period. 

In  2020,  the  EIB161  provided  EUR  24.2  billion  in  funding 
across  Europe  to  fight  climate  change,  37%  of  its  total 
financing.  It  also  provided  EUR  1.8  billion  (3%  of  its 
financing) for broader environment lending162. 

EU environmental funding 2021-2027 

including 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU spending programme will mobilise 
EUR  2.018  trillion  (in  current  prices)  to  support  the 
recovery 
long-term 
from  COVID-19  and  the  EU’s 
priorities, 
protection163. 
Following the Green Deal’s164 pledge to ‘do no harm’ and 
Interinstitutional  Agreement  on  the  2021-2027 
the 
MFF165, 30% of the EU budget will support climate efforts, 
while biodiversity will receive 7.5% as of 2024 and 10% as 
of  2026.  Reaching  the  biodiversity  targets  requires 
increased programming of financial resources, specifically 
under the 2021-2027 cohesion policy and the 2023-2027 
CAP.  

environmental 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)166. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard)167.  Reinforced  by  the  renewed  sustainable 

that 

finance 

several  programs 

159 Approved and signed EFSI financing - EIB, 2015-2020. 
160 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal. 
161  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just Transition Mechanism. The EIB Group stands as a key implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
162 EIB, Activity Report, 2021. 
163  European  Commission,  2021-2027 
NextGenerationEU. 
164 COM/2019/640 final. 
165 Interinstitutional Agreement, OJ L 433I. 
166 European Commission, EU taxonomy for sustainable activities. 
167 EU Green Bond Standard - 2021/0191 (COD). 

long-term  EU  budget  & 

 Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
                                                                 
to 

investment 

climate  and 

(2020)168,  sustainable 

finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change169  can  help  close  the  insurance  protection  gap  , 
leaves  many  risks  from  uninsured 
which  currently 
climate-related  events170.  The  EIB  will  align  50%  of  its 
lending  for  climate  and  environmental  projects  by 
2025171 with a EUR 250 billion contribution to the Green 
Deal investment plan by 2027. 

Table  3  gives  an  overview  of  the  EU  funds  earmarked 
specifically  for  Hungary  in  2021-2027.  These  funds  are 
supplemented by other EU funding programmes available 
to all Member States. 

Table 3: Key EU funds allocated to Hungary (current 
prices), 2021-2027 

Instrument 

Cohesion policy 
ERDF 
CF 
ESF+ 
ETC (ERDF) 

Country funding allocation 
(million EUR) 

Total: 21 727.9172 
13 359.5 
2 602.2173 
5 507.4 
258.8174 

Just Transition Fund 

261.1175 

EAFRD/rural 
development  
under  2023-2027  CAP 
strategic plans176 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

2 084.3177 

37.7178 

168 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy.  
169 COM(2021) 82 final. 
170 The strategy would support improved coverage of the insurance gap 
including through the natural catastrophe markets as reflected with the 
EIOPA  (European  Insurance  and  Occupational  Pensions  Authority) 
dashboard  on  the  insurance  protection  gap  for  natural  catastrophes. 
See:  The  pilot  dashboard  on  insurance  protection  gap  for  natural 
catastrophes | Eiopa (europa.eu). 
171 EIB Climate Bank Roadmap 2021-2025, November 2020. 
172  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
173  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
174 
transnational and ETC cross-border cooperation. 
175  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
176 European Commission, CAP strategic plans.  
177 Regulation (EU) 2021/2115, Annex XI. 
178 Regulation (EU) 2021/1139, Annex V. 

initial  allocations  per  Member  State 

including  ETC 

Interreg 

Hungary  36 

In  Hungary,  programming  for  most  EU  funds  (cohesion 
policy 
funds,  EAFRD  and  the  European  Maritime, 
Fisheries  and  Aquaculture  Fund)  and  of  the  RRF  are 
ongoing.  Therefore,  the  policy  objectives  and  priorities 
are not yet available.  

The Hungarian RRP has not been adopted yet. 

Figure 39: Climate expenditure in RRPs, 2021-2026179 
(without data for Hungary, the Netherlands and Poland) 

Under  NextGenerationEU,  the  Commission  will  issue  up 
to  EUR  250  billion  of  EU  green  bonds  (one  third  of  all 
bonds  issued  under  NextGenerationEU)  until  2026  that 
will  comply  with  the  general  spirit  of  the  ‘do  no 
significant  harm’. However, this EUR 250 billion in green 
bonds  will  not  be  subject  to  the  currently  developed 
delegated acts related to the EU Taxonomy. They will not 
fully  align  with  the  proposed  EU  standard  for  green 
bonds. 

in  2021-2027, 

there  are  also 

In  addition  to  EU  funds  earmarked  specifically  for 
funding 
Hungary 
programmes  that  can  be  accessed  at  EU  level  and  are 
open  to  all  Member  States.  These  include  the  LIFE 
programme180 (EUR 5.4 billion), Horizon Europe (EUR 95.5 
billion)181,  the  Connecting  Europe  Facility182  (EUR  33.7 
billion)183  and  the  funds  to  be  mobilised  via  InvestEU184. 

179 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
180 European Commission, LIFE Programme. 
181  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
182  The  CEF  (Transport)  also  includes  EUR 11.3  billion  transferred  from 
the  Cohesion  Fund.  30%  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  the  Member  States eligible  for 
the  Cohesion  Fund.  The  remaining  70%  will  be  attached  to      national 
envelopes  until  31 December  2023.  Any  amount,  under  national 
envelopes  that  is  unspent  by  that  date  will  support  all  the  Cohesion 
Fund’s Member States. 
183 Regulation (EU) 2021/1153. 
184  The  InvestEU  Fund  is  set  to  mobilise  over  EUR  372  billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to back 

 Environmental Implementation Review 2022 – Hungary 

 
 
  
 
                                                                 
 
 
 
                                                                 
 
including 

transition, 

These  other  sources  of  funding  will  also  support  the 
green 
research  and 
innovation  activities 
for  environmental  protection 
(Horizon  Europe)185,  clean  transport  and  energy  (the 
sustainable 
Connecting 
infrastructure (InvestEU)187. 

Facility)186 

through 

Europe 

and 

National environmental protection 
expenditure 

Total  national  expenditure  on  environmental  protection 
(including all relevant current and capital expenditure)188 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  EU-27  GDP.  This  percentage  has  remained  quite 
stable over time. Although the largest absolute amounts 
of expenditure are concentrated in a few countries, most 
countries  spend  between  1-2%  of  their  GDP  on 
environmental  protection,  with  Hungary  spending  1.7% 
of its GDP. 

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR  56.3  billion  in  2018,  falling  to  EUR  54.5  billion  in 
2020,  representing  around  0.4%  of  EU-27  GDP.  Most 
Member  States 
in 
environmental protection – Hungary invested 0.5% of its 
GDP. In 2014-2020, this totalled around EUR 376 billion in 
environmental  investment  in  the  EU-27,  and  EUR  6.7 
billion for Hungary. 

invested  0.2-0.5%  of  their  GDP 

Hungary  37 

Figure 40: Direct and indirect Environmental protection 
investments in the EU-27 (EUR million and % of GDP), 
2018189 

in 

environmental  protection 

from  specialist  producers 

institutional  sector,  around  37%  of  Hungary’s 
By 
investment 
(capital 
expenditure)  came  from  the  general  government,  41% 
came 
(of  environmental 
protection services, e.g. waste and water companies) and 
22% 
in 
environmental protection. At EU level, the spread is more 
balanced:  37%  comes  from  governments,  33%  from 
specialist  producers,  and  30%  from  businesses  not 
specialised in environmental protection. 

from  businesses  not 

specialised 

came 

the  investment  of  financial  partners  such  as  the  European  Investment 
Bank (EIB) Group and others. 
185 European Commission, Horizon Europe. 
186 European Commission, Connecting Europe Facility. 
187 European Union, InvestEU. 
188  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  although 
international 
expenditure  beyond  strictly  domestic  expenditure.  Data  source: 
Environmental Protection Expenditure Accounts (EPEA), Eurostat. EPEA 
accounts are based on the CEPA 2000 classification, excluding climate, 
energy and circular economy. 

including  final  consumption, 

include  some 

it  may 

level, 

189 Eurostat, Environmental Protection Expenditure Account, 2021. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                                                        
 
 
 
 
                                                                 
Figure 41: EU-27 Member States’ environmental 
protection investments (Capex) by institutional sectors 
(Total economy = 100%), 2018190 

Hungary  38 

waste, with a further 6% supporting sustainable land use, 
with  links  to  ecosystem  conservation  and  restoration. 
These  data  are  based  on  the  climate  bonds  taxonomy, 
which is broadly similar to the EU Taxonomy193. Of the EU 
green  bond  issuance  in  2020,  Hungary  issued  EUR 1.92 
billion in bonds (data available for 16 Member States, see 
Figure 43). 

Figure 42: Annual EU green bond issuance in 2020 (EUR 
billion)194 

A  breakdown  of  investment  by  environmental  topic  is 
partially  available,  but  only  at  the  level  of  institutional 
sectors  (rather  than  at  economy  level),  due  to  different 
reporting patterns across the sectors.  

protection 

investments  went 

At  Hungary’s  general  government  level  in  2018,  70%  of 
environmental 
to 
wastewater,  18%  to  waste  management  and  8%  to 
biodiversity.  For  the  country’s  specialist  producers  of 
to 
environmental  protection 
wastewater, and  48% to  waste management,  and 4% to 
water and soil protection. For businesses not involved in 
the  specialist  production  of  environmental  protection 
services, investment shares included 36% in air pollution, 
12%  each  in  wastewater,  waste,  and  biodiversity,  and 
around 15% in pollution from sources other than air . 

services,  48%  went 

In  2020,  the  total  annual  issuance  of  European  green 
bonds (including some non-EU countries)191 was USD 156 
billion  (EUR 137  billion)192,  up  from  USD 117  billion 
(EUR 105 billion) in 2019. Looking only at EU-27 Member 
States, green bond issuance in 2020 was EUR 124 billion. 
issued  by 
In  2014-2020,  83%  of  the  green  bonds 
European  countries 
in  energy, 
buildings,  or  transport,  while  8%  supported  water  and 

served  objectives 

190 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
191  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  Most  green  bonds  issued  are 
green ‘use of proceeds’ or asset-linked bonds. The very first green bond 
was  issued  in  2007  with  a  AAA-rated  issuance  from  multilateral 
institutions, the European Investment Bank (EIB) and the World Bank. 
192 At Eurostat’s annual average EUR/USD exchange rates. 

Green budget tools 

Green taxation and tax reform 

Hungary’s  revenue  from  environmentally-related  taxes 
was  2.18%  of  GDP  in  2020  and  remains  close  to  the  EU 
average (2.37%) (see Figure 44). 

Within  this,  energy  taxes  accounted  for  1.67%  of  GDP 
(below  the  EU  average  of  1.74%),  transport  taxes 
accounted  for  0.3%  (below  EU  average  of  0.42%),  and 
pollution and resource taxes accounted for 0.21% (above 
the  EU  average  of  0.08%). 
the  same  year, 
environmental  taxes  came  to  6.01%  of  total  revenue 
from tax and social security contributions (slightly above 
the EU average of 5.57%). 

In 

193 Interactive Data Platform; Climate Bonds Taxonomy. 
194 Climate Bonds Initiative, 2022. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
 
 
                                                                 
Figure 43: Environmental taxes in the EU27, 2020195 

Environmentally-harmful subsidies 

Hungary  39 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms200. Fossil fuel subsidies are costly for government 
budgets and undermine the green transition. They often 
work against incentives for green investments and do not 
contribute  to  levelling  the  playing  field.  Since  2015, 
annual  fossil-fuel  subsidies  have  been  around  EUR  55 
billion  in  the  EU.  They  rose  by  4%  between  2015  and 
2019, however, some countries, such as Latvia, Lithuania, 
Sweden, Greece and Ireland, managed to decrease them. 
Subsidies  on  petroleum  products  in  sectors  such  as 
transport  and  agriculture  continued  to  grow  in  this 
period. However, subsidies on coal and lignite decreased, 
due  to  the  diminishing  role  of  solid  fuels  in  electricity 
generation.  

As a share of GDP, fossil fuel subsidies ranged from 1.2% 
in  Hungary  (where  they  amounted  to  EUR  1.8  billion  in 
2019) to less than 0.1% in Malta in 2019 (the EU average 
is 0.4%). In 2020, the EU27’s total fossil fuel subsidies fell 
to EUR 52 billion (due to reduced consumption caused by 
COVID-19-related  restrictions).  However,  without  action 
by Member State, these subsidies are likely to rebound as 
economic  activity  picks  up201.  Figure  45  shows  further 
details on fossil fuel subsidies in Hungary. 

Figure 44: Trends in natural gas, petroleum products 
and coal subsidies in Hungary202 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition. Tax reforms can contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations196. The Green Deal promotes the ‘polluter 
pays  principle’197  which  stipulates  that  polluters  should 
bear  the  cost  of  measures  to  prevent,  control  and 
remedy pollution. The polluter pays principle is facilitated 
by  the  Commission’s  Technical  Support  Instrument  (TSI) 
project on greening taxes. 

simultaneously 

account  of 

There  is  potential  to  increase  environmental  taxation  in 
Hungary.  For  instance,  the  tax  on  biomass  fuels  could 
improve  air  quality  or  a  beverage  container  tax  could 
incentivise  beverage  packaging  producers  to  achieve 
higher  recycling  rates198.  According  to  the  Commission 
study  Green  taxation  and  other  economic  instruments 
(2021),  Hungary  applies  polluter  pays  economic 
instruments  on  air,  water  and  soil  pollution  –  there  are 
charges on emissions (of nitrogen oxides, sulfur dioxides 
and non-toxic dust) and water abstraction199. 

195 Eurostat, Environmental taxes accounts (env_eta). 
196  European  Commission,  The  European  Green  Deal,  COM  (2019/640 
final), p.17. 
197  Article 191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union states that: ‘Union policy on the environment (…) shall be based 
on  the  precautionary  principle  and  on  the  principles  that  preventive 
action should be taken, that environmental damage should as a priority 
be rectified at source and that the polluter should pay’. 
198 European Commission, Ensuring that polluters pay, Hungary. 
199  European  Commission, Green 
instruments, 2021. 

taxation  and  other  economic 

% GDP 

2013  2014 

2015 

2016  2017 

2018 

2019 

2020 

Natural gas 

0.09 

0.08 

0.13 

0.07 

0.08 

0.09 

0.07 

0.12 

Petroleum 

0.15 

0.15 

0.13 

0.11 

0.11 

0.09 

0.08 

0.03 

200  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform potential for the EU 28, 2016. 
201  See  table  on  EU  FFS  data  in  2019,  which  is  based  on  (for  info) 
COM(2021) 950 and Annex. 
202 OECD, Fossil Fuel Subsidy Tracker. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
 
                                                                 
products 

Coal 

0.06 

0.06 

0.08 

0.04 

0.04 

0.04 

0.03 

0.04 

Railway  companies  in  Hungary  are  refunded  the  excise 
tax  they  pay  on  diesel  fuel  intended  for  passenger  and 
freight  services.  This 
is  an  example  of  a  partly 
environmentally  friendly subsidy. It funds environmental 
research  and  development,  but  CO2  emissions  from  the 
production and use of coal remain. 

Current green budgeting practices 

‘Green  budgeting’  encompasses  various  climate  and 
environmental  tagging203  and  tracking  practices 
in 
budgets. Some Member States already use certain green 
budgeting  practices204.  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues  to 
increase  transparency  on  how  green  the  budgetary 
policies are. This is aimed at  improving policy coherence 
and  support  green  policies  (including  climate  and 
environmental objectives)205. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 
legislation  and  criteria206.  The  Commission  developed  a 
green budgeting reference framework207 and launched a 
TSI project on green budgeting in 2021  to help Member 
States  develop  national  green  budgeting  frameworks  to 
improve  policy  coherence  and  support  the  green 
transition.  Hungary  participates  in  the  EU  Commission’s 
green budgeting project, which started in 2021. 

Environmental financing versus financing 
needs 

The EU’s overall financing for environmental investments 
is estimated to have been 0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from  0.3%  (Ireland)  to  1.91%  (Bulgaria), 

203  Tagging  is  explained  in  European  Commission,  Green  budgeting 
practices in the EU: a first review , 2021 (p.7). 
204 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 
205  European  Commission,  European  Commission  Green  Budgeting 
Reference Framework.. 
206 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
207  European  Commission,  Green  Budgeting  Reference  Framework, 
based  on  the  review  of  the  OECD  Paris  Collaborative  on  Green 
Budgeting initiative, 2017. 

Hungary  40 

depending  on  the  level  of  environmental  challenges  in 
different  Member  States.  The  overall  EU  environmental 
investment  needs  in  2021-2027  are  estimated  to  range 
between  0.9-1.5%  of  the  projected  GDP  in  that  period, 
suggesting  a  potential  environmental  financing  gap  of 
0.6-0.8%  of  GDP  (EU 
level),  compared  to  previous 
financing levels208. 

Figure 45: Total environmental financing (2014-2020) 
and estimated needs (2020-2030) in the EU-27 (% of 
GDP)209 

Hungary’s  financing  for  environmental  investments  is 
estimated  to  have  been  almost  1.52%  of  GDP  in  2014-
2020,  with  around  40%  of  financing  from  the  EU.  The 
country’s environmental investment  needs in 2021-2027 
are  estimated  to  be  over  1.66%  of  its  GDP  (reflecting 
needs  where  country  breakdown 
is  available).  This 
suggests  an  environmental  financing  gap  of  at  least 
0.14% of GDP. This is likely to be higher when taking into 
account needs currently only estimated at EU level (e.g., 
water protection, circularity, biodiversity strategy). 

In the 2019 EIR, Hungary received one priority action to 
the  main 
provide  adequate 
environmental challenges it was facing, including through 

funding 

tackle 

to 

208  DG  Environment  data  analysis.  EU  financing  sources  covered:  ESI 
Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon 2020,  LIFE,  EFSI  (EU 
amount),  EIB  loans.  National  financing:  total  national  environmental 
protection  capital  expenditure  (investments)  -  Eurostat  EPEA  dataset. 
Cut-off date for data: end 2021. N.B.  Total financing may be higher, in 
investments,  requiring  further 
particular  through  further 
analysis in the future. 
209 Eurostat, ESI Funds Open Data, 2021. 

indirect 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
 
                                                                 
 
 
 
 
                                                                 
Hungary  41 

mobilising investment  and using of EU funds.  The action 
is  proposed  again  because,  although  there  has  been 
progress, further efforts are still needed. 

2022 priority actions  

  Prepare  an  environmental  financing  strategy  to 
maximise  opportunities  for  closing  environmental 

implementation  gaps, 
environmental taxes.  

including  by 

increasing 

  Tackle  the  main  environmental  challenges  affecting 
the  country,  through  adequate  funding,  including 
investments 
through  the  mobilisation  of  private 
(which  currently makes up 40% of total investments) 
and the use of EU funds. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
 
6. Environmental governance

high-value 
environmental legislation214. 

spatial 

datasets 

Hungary  42 

for 

implementing 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention: 
(i) access to information; 
(ii) public participation in decision making; 
(iii) access to justice in environmental matters. 
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively210.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment211. It includes the right to bring 
legal challenges (‘legal standing’)212. 

Environmental information 

This section focuses on Hungary’s implementation of the 
INSPIRE  Directive.  The  INSPIRE  Directive  aims  at  setting 
spatial  data 
up  a  European 
for 
infrastructure 
sharing environmental 
information  between 
spatial 
public authorities across Europe. It is hoped that this will 
help policy-making across boundaries and facilitate public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
transparent and readily available. 

Hungary’s  implementation  of  the  INSPIRE  Directive  is 
poor.  Hungary’s  performance  has  been  reviewed  based 
on  the  country's  2021  country  fiche213.  No  progress  has 
been made in data identification and documentation, and 
implementation  levels  are  poor.  More  effort  is  needed 
to:make  the  data  more  widely  accessible;  improve  the 
conditions  for  data  reuse;  prioritise  environmental 
datasets in implementation, especially those identified as 

210  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive(Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation. 
211 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
212  This  EIR  focuses  on  the  means  implemented  by  Member  States  to 
guarantee  rights  of  access  to  justice,  legal  standing  and  to  overcome 
other major barriers to bringing cases on nature and air pollution. 
213 INSPIRE knowledge base Hungary, 2021. 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020215 

2016 

2020 

Legend 

Effective  coordination  and  data 
sharing 

Ensure effective 
coordination 

sharing 

Data 
without 
obstacle 

■ 

■ 

■ 

■ 

INSPIRE performance indicators 

i. Conformity of 
metadata 

ii.  Conformity 
of  spatial  data 
sets216 

iii.  Accessibility 
of  spatial  data 
through 
sets 
view 
and 
download 
services 

iv.  Conformity 
of 
network 
services 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 
Implementation 
of  this  provision  is 
well  advanced  or 
(nearly)  completed. 
Outstanding 
issues 
are  minor  and  can 
be addressed easily. 
Percentage: >89% 

■ 
Implementation 
of this provision has 
started  and  made 
some  or  substantial 
progress  but  is  still 
not  close  to  being 
complete. 
Percentage: 
89% 

31–

■ 
Implementation 
of  this  provision  is 
falling  significantly 
Serious 
behind. 
efforts 
are 
necessary  to  close 
the  implementation 
gap. 
Percentage: 
<31% 

Public participation 

Further  effort  is  needed  to  promote  public  participation 
in  processes  under 
Environment 
the 
Assessment (SEA) and Environmental Impact Assessment 
legal 
(EIA)  Directives  beyond 
requirements  for  notifying  procedures  and  making  it 
possible to provide comments.Structured information on 

implementing 

Strategic 

the 

214 European Commission, List of high value spatial data sets. 
215 INSPIRE knowledge base Hungary 2021. 
216  In  2016,  the  deadlines  for  implementation  of  the  spatial  data 
interoperability  were  in  the  future:  23.11.2017  for  Annex  I  data  and 
21.10.2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
most  countries  provide  in  the  existing  circunstances  data-sets  in 
addition to the INSPIRE harmonised data sets. 

Environmental Implementation Report 2022 – Hungary 

 
                                                                 
 
  
 
                                                                 
public  participation  in  environmental  matters  can  be 
found  on 
the  Commissioner  of 
Fundamental  Rights217.  A  centralised  website218  also 
offers easy access to the public to information. .  

the  website  of 

to 

However,  some  documents,  such  as  those  submitted  by 
developers 
identified  by 
remedy  deficiencies 
authorities in EIA reports are not published and can only 
be consulted at the offices of the relevant environmental 
authority219. A statistical database on public participation 
in  SEA  and  EIA  procedures  could  provide  valuable 
information  to  assess  public  activity  in  environmental 
procedures  to  facilitate 
implementation  of  Directive 
2011/92/EU and Directive 2001/42/EC. 

in 

The  2019  EIR  recommended  Hungary  to  facilitate  public 
implementing  EU  environmental 
participation 
limited 
legislation.  Since  2019,  Hungary  has  made 
progress,  and  there  are  still  some  measures  to  be 
implemented 
improve  more  effective  public 
participation. 

to 

Access to justice 

An  NGO  has  legal  standing  if  an  administrative  activity 
affects its registered activity. The registered activity must 
be  one  that  protects  any  fundamental  right  or  enforces 
any public interest in a geographical territory for at least 
one yearIn general, NGOs do not have to prove their legal 
standing  in  an  environmental  court  case  or  in  cases 
related  to  the  environment.  However,  NGOs  have  to 
meet  some  conditions  related  to  their  legal  status  and 
operations. 

Nevertheless,  there  are  some  difficulties  in  challenging 
plans or programmes. 

the 

legality  of 

is  possible  by 

laws  and/or  public 
Challenging 
administrative  measures  by  a  natural  person  or  by  an 
organisation 
lodging  a  constitutional 
complaint  with  the  Constitutional  Court.  The  Court  can 
annul a contested legal measure if the measure adopting 
the  plan  or  programme  is  contrary  to  fundamental  law 
and thus infringes fundamental rights (e.g., the right to a 
healthy environment). 

There is also a system of regular supervision of regulatory 
legislation,  but  it  is  difficult  for  the  public  and  NGOs  to 
access  it.  Instead,  the  public  and  NGOs  can  only  bring  a 
measure to the attention of those bodies or officials who 
are  entitled  to  initiate  an  extraordinary  supervision 

Hungary  43 

procedure.  The  supervisory  body  may  review  both  the 
decision  and  the  procedure  of  the  environmental 
authority. It can do so as a result of the body’s status. The 
client  or  other  interested  parties  may  also  draw  its 
attention to the fact. 

There  is  some  information  on  access  to  justice,  usually 
only in Hungarian maintained by the government220. The 
most  important  national legislation can be found on the 
official  website  of  the  Official  Journal221  and  in  the 
national database of laws222. 

In  the  2019  EIR,  Hungary  received  three  priority  actions 
for  information,  participation  and  justice.  There  is  no 
information  available  about  the  first  action  to  improve 
access  to  spatial  data  and  services  by  making  stronger 
linkages  between  the  country’s  INSPIRE  portals,  there  is 
no information available. There has been limited progress 
on  the  second  action  to  facilitate  public  participation  in 
implementating  EU  environmental  legislation.  On  the 
action on environmental NGOs’ rights to bring challenges 
on environmental issues, there has been  some progress, 
but  further  improvements  are  needed  for  plans  or 
programmess.  There  have  also  been  improvementson 
information  about  access  to  justice  on  environmental 
matters. 

2022 priority actions 

  Significantly improve the information available on SEA 
and  EIA  procedures, 
ideally  through  a  central 
database, and ensure that all relevant documentation 
is made available, ideally online. 

  Collect  and  publish  data  on  the  level  of  public 
participation 
in  SEA  and  EIA  procedures,  and 
encourage  public  participation  by  making  clear  and 
useable information available on how to comment on 
proposals. 
Improve  access  to  courts  by  the  public  concerned 
when 
it  comes  to  challenging  administrative  or 
regulatory  decisions,  in  particular  in  planning  related 
to water, nature and air quality. 

 

  Better inform the public about their access to justice 
rights,  in  particular  by  referring    on  national  judicial 
and administrative portals to the Commission eJustice 
fact  sheets  on  access  to  justice  in  environmental 
matters223. 

217 Társadalmi részvétel a környezetvédelmi ügyekben. 
218 Hirdetmények. 
219 National EIA law does not require these documents to be published 
online,  although  these  documents  possibly  contain 
information 
required under Articles.3 and 5 or Annex II or IV of the EIA Directive. 

220 Access to justice in environmental matters. 
221 Magyar Közlöny. 
222 Nemzeti Jogszabálytár. 
223 Access to justice in environmental matters. 

 Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
                                                                 
Hungary  44 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect water, air and nature, and manage waste224.  
It includes support measures provided by the authorities 
such as: 
(i) compliance promotion225;  
(ii) inspections and other  checks that they carry out, i.e. 
compliance monitoring226;  
(iii)the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement227.  
Citizen  science  and  complaints  enable  authorities  to 
liability228 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

(OKIR),  but 

information  system231 

are  just  one  of  a  number  of  activities  in  these  plans, 
andthe information is often not provided in an accessible 
or  useable  form  (for  example,  scanned  documents  are 
provided  that  cannot  be  searched).  Information  past 
inspections  can  be  found  in  the  national  environmental 
protection 
the 
database 
is  not  user-friendly  and  requires  some 
knowledge  of  specific  search  terms  to  use.  Decisions 
taken  by  the  environmental  authority  in  cases  of  non-
compliance,  and  a  summary  of  individual  cases  are 
published  in  OKIR  ,  but  no  aggregated  information  is 
available.  There  is  no  single  source  of  information  on 
environmental  inspections  and  enforcement  decisions, 
and 
there  are  big  differences  between  county 
government  offices  in  making  the  information  available 
and in the formats made available. 

Compliance promotion and monitoring 

Complaint handling and citizen science 

Since  the  2019  EIR  was  published,  a  new  dataset,  the 
Ecosystem  Map  of  Hungary  has  been  set  up.  There  is  a 
wide  range  of  online  information  and  tools  for  farmers 
and  land  managers  on  how  to  implement  the  Birds  and 
Habitats Directives. In addition to detailed information on 
protected  areas  and  species  and  management  plans  for 
protected  sites,  specific 
is 
available.  Online  resources  include  the  website  of  the 
Hungarian  Chamber  of  Agriculture229,  which  provides 
several  products,  including  a  guide  to  nature-friendly 
farming.  

information  for  farmers 

information 

On the Nitrates Directive, a  handbook  is available  which 
explains  the  legislation,  including  through  case  studies. 
Public  sector 
is  complemented  by  the 
environmental NGO MME (Birdlife Hungary)230. The NGO 
provides an online tool to let farmers generate, store and 
print  the  management  specifications  for  their  own  land 
from the management plans of four Natura 2000 sites in 
the Kiskunság region.  

Environmental  inspection  schedules  are  available  and 
annual inspection plan published by the relevant  county 
government  office.  However,  environmental  inspections 

224  The  concept  is  explained  in  detail  in  the  Communication  on  EU 
actions  to 
improve  environmental  compliance  and  governance 
COM(2018)10  and  the  related  Commission  staff  working  document, 
SWD(2018)10. 
225 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
226 This EIR focuses on inspections of major industrial installations.  
227  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
228  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
229 Nemzeti Jogszabálytár. 
230 www.naturaterv.hu. 

The  public  has  a  formal  right232  to  alert  the  relevant 
authorities to incidents of environmental damage or the 
risk  of  environmental  damage.  However,  there  is  no 
consistency between the systems which make it possible 
for  the  public  to  do  this.  In  practice,  it  is  necessary  to 
know  which  authority  is  responsible  for  a  particular  law 
(e.g.  county government offices, district offices, national 
authorities,  municipalities,  police  or  specific  sectoral 
organisations). The systems put in place by the different 
authorities  for  receiving  environmental  complaints  and 
dealing with them vary. There does not appear to be any 
official  website  with  online  guidance  or  dedicated  to 
environmental  complaints.  NGOs,  such  as  Greenpeace 
Hungary, have attempted to fill this gap233. 

The  lack  of  a  coordinated  approach  to  -complaints  from 
the  public  means  there 
is  no  data  on  complaints 
received,  action  taken  to  investigate  them,  and  the 
outcomes.  There  are  some  one-off  examples  of  citizen 
science in action. For example, since the 2019 EIR234, it is 
now possible for the public to report sightings of specific 
species  of  biodiversity  interest  and  the  Waste  Radar. 
However,  there  is  little  evidence  of  the  government 
encouraging  the  public  or  NGOs  to  take  part 
in 
implementing and enforcingenvironmental legislation. 

231 Használati útmutató. 
232 Article 97 (2) of the Environmental Protection Act. 
233 See for example Greenpeace. 
234 Vadonleső. 

 Environmental Implementation Review 2022 – Hungary 

 
                                                                 
 
 
                                                                 
Enforcement  

there 

Statistics  on  environmental  crime  and  its  enforcement 
are limited.  An aggregated number of  the  main types of 
environmental crimes is available on the Ministry of  the 
Interior’s  online  database.  However, 
is  no 
breakdown  of  environmental  offences  or  waste-related 
offences.  A  dedicated  environmental  crime  database 
does not  exist,  and data  on  the  results of criminal court 
proceedings are not published. The outcome of individual 
environmental crime cases can be  found on the website 
of  the  courts,  but  no  overall  summary  is  available.  The 
annual  parliamentary  reports  of  the  Prosecutor  General 
provide 
registered 
environmental crimes235. Some progresshas been made – 
the  National  Environmental  Security  Task  Force  was 
established in 2021. 

the  number  of 

statistics  on 

including  the  police,  are 

legally 
Public  authorities, 
required  to  cooperate 
in  environmental  protection 
issues.  In  2021  a  memorandum  of  understanding  was 
signed  between  seven  bodies  setting  up  a  cooperation 
platform236  for  tackling  environmental  crime,  including 
sharing  information  and  training  resources.  The  bodies 
are  the  Ministry  of  Agriculture,  the  National  Tax  and 
Customs  Authority,  the  Hungarian  National  Police 
and 
Headquarters, 
Technology, 
for 
Disaster  Management,  the  Ministry  of  the  Interior,  the 
Pest  County  Government  Office,  and  the  National  Food 
Chain Safety Office. Details on how the platform operates 
have not been published. 

Innovation 
the  National  Directorate-General 

the  Ministry  of 

Environmental Liability Directive (ELD) 

Hungary  implemented  a  project  to  process  and  publish 
cases  of  damage  (under  the  ELD)  in  the  Environmental 
Liability Database. The project was led by the Ministry of 
Agriculture and involved the regional authorities in 2020-
2021237.  The  main  source  of  information  analysed  is  the 
Deputy  Ombudsman  for  Future  Generations’  opinion  on 
environmental liability238 from 2019, which concludes that 
a  series  of  major  changes  are  necessary  both 
in 
legislation  and  in  the  implementation  of  environmental 
liability  laws.  These  initiatives  have  been  examined  and 
developed  further  by  an  inter-ministerial  working  group 
in  2020-2022.  A  mandatory  financial  security  system  for 
liabilities  under  the  ELD  has  not  been  fully  introduced 

Hungary  45 

yet.  However,  as  of  now,  this  system  mostly  deals  with 
waste  management  where  the  Act  on  Waste  requires, 
under  certain  circumstances,  the  licensee  to  have  a 
financial  deposit,  bank  guarantee  or  environmental 
insurance. 

In  the  2019  EIR,  Hungary  received  three  priority  actions 
for compliance assurance. There has been no progress on 
the  first  action  related  to  public  information  about 
promoting  compliance,  monitoring  and  enforcement. 
There  has  been  some  progress  on  the  action  to  ensure 
there  is  more  information  on  how  professionals  dealing 
with environmental crime work together.  More progress 
needs  to  be  made  on  the  action  related  to  financial 
security  for  liabilities,  ELD  guidance  and  publication  of 
information on environmental damage. 

2022 priority actions 

  Provide  clear  information  on  how  the  public  and 
interest  groups  can  report  environmental  issues  or 
incidents,  and  encourage  the  public  to  make  such 
reports. 

  Provide  information  to  the  public  on  environmental 
liability cases and other cases involving environmental 
damage. 

 

law, 

including 

  Make  information  available  on  the  enforcement  of 
information  on  the 
the 

environmental 
prosecution  of  environmental  crimes  and 
outcome of criminal proceedings. 
Improve  the  information  available  onenvironmental 
inspections and their results, ideally drawing together 
information  from  the  different  public  bodies  with 
environmental  compliance  responsibilities.  This  will 
improve enhance transparency and public knowledge.  
  Set  up  a  financial  security  system  for  environmental 
liability to meet the costs of environmental damage. 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
legislation at EU, national, regional, and local levels need 
to have the knowledge, tools, and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

235 Prosecution service of Hungary. 
236 Európai Környezeti Információs és Megfigyelő Hálózat. 
237  The  results  of  this  project  was  published  on  Európai  Környezeti 
Információs  és  Megfigyelő  Hálózat  as  a  ZIP-document  “az  ELD  hatálya 
alá tartozó káresemények térképe (Google Earth fedvény)”. 
238 Jővő Nemzedekek Érdekeinek Vedelmet Ellato Biztoshelyettes. 

Overall,  an  improvement  in  the  implementation  of  EU 
in  the  different  sectors  can  be 
environmental 
law 
in 
observed,  but  there  remains  a 
particular  for  air  quality  and  water  management.  While 
the  number  of  complaints  and  infringements  related  to 

long  way  to  go 

 Environmental Implementation Review 2022 – Hungary 

 
 
                                                                 
 
 
the  environment  are  below  the  EU  average,  the  time 
needed 
identified  breaches  of  EU 
environmental laws is slow. 

resolve 

to 

There has been progress in implementing environmental 
assessments. However, the legislative package aiming to 
speed  up  licensing  ‘projects  of  national  interest’  has 
raised  some  concerns,  and  its  implementation  is  being 
followed closely. 

Hungary  has  no  dedicated  environment  ministry.  The 
three  ministries  dealing  with  the  environment  are  the 
Ministry  for  Innovation  and  Technology  (for  energy  and 
including  the  circular  economy  and  waste 
climate, 
management), 
(for 
the  Ministry  of  Agriculture 
environmental policy, nature, air quality, noise, SEA, EIA, 
remediation  and  other  environmental  issues),  and  the 
Ministry of the Interior (for water management, including 
drinking  water  and  flood  prevention).  These  ministries 
should  work  closely  and  together  solve  environmental 
problems.  Hungary  should  ensure  good  coordination 
between  the  different  authorities  and  provide  the 
appropriate 
issues. 
to 
Moreover,  upskilling  and  reskilling  staff  on  green  issues 
should  be  organised,  including  field  trips,  to  determine 
the specific situation and needs of affected areas. 

environmental 

resources 

In the 2019 EIR, Hungary received one priority action to 
improve  environmental  governance  (e.g.  transparency, 
citizen  engagement,  compliance  and  enforcement,  and 
administrative  capacity  and  coordination).  There  has 
been limited progress so the action is proposed again. 

2022 priority action 

  Continue  to  improve  environmental  governance,  in 
and 

administrative 

capacity 

particular 
the 
coordination at national level. 

Coordination and integration  

As mentioned in the 2019 EIR Report, turning the revised 
EIA Directive239 into national law provides an opportunity 
to streamline the regulatory framework of environmental 
assessments.  Hungary  has  turned  the  revised  Directive 
into  national 
the  Commission’s 
assessment, as part of a horizontal exercise revealed over 
20 points, in how the Directive was turned into national 
law,  that  may  constitute  grievances  (including  incorrect 
publication  requirements  (in  particular  for  building 
involvement,  and 
permit  procedures),  civil  society 

law.  However, 

239 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 

Hungary  46 

incorrect  categorisation  of  certain  activities,  which 
should  be  subject  to  EIAs).  Hungary’s  reply  to  this 
assessment  shows  a  willingness  to  adopt  amendments 
for  most  of  the  issues  but  also  maintains  the  country’s 
position  on  a  few  points.  According  to  exchanges 
between  Hungarian  and  Commission  departments,  as  of 
February  2021  the  amendments  outlined  in  the  reply 
were  under  preparation.  In  May  2021,  Hungary  notified 
amending legislationto the Commission. 

The Commission encourages  streamlining environmental 
assessments to reduce duplication and avoid overlaps in 
environmental  assessments  applicable 
to  projects. 
Moreover,  streamlining  helps  to  reduce  unnecessary 
administrative burdens and accelerates decision-making, 
provided it is done  without  compromising the quality of 
the environmental assessment procedure240. Hungary has 
introduced  streamlining  environmental  assessments 
under the EIA and Habitats Directives before the revision 
of  the  EIA  Directive.  Joint  procedures  have  been  drawn 
up for the EIA Directive, the Water Framework Directive 
and the Industrial Emissions Directive. 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 

The  Commission  has  provided  expert  advice  to  help 
design  more  than  1200  reform  projects  in  27  Member 
States  since  2017.  It  has  done  so  first  through  the 
structural  reform  support  programme,  and  since  2021, 
through the TSI, its successor programme. The TSI’s main 
objective  is  to  promote  the  EU’s  economic,  social  and 
territorial cohesion by supporting Member States’ efforts 
to implement the necessary reforms to achieve economic 
and  social  recovery,  resilience  and  more  economic  and 
social convergence241. 

The  Commission’s  TSI  supported  several  environment-
related  projects  in  Hungary.  Under  the  2020  TSI,  the 
Commission supported a project to develop the  national 
circular  economy  strategy  (NCES)  and  action  plan  and 
another 
to  promote  green  and  blue  municipal 
infrastructure.  As  for  the  TSI  2021,  three  other  projects 
‘Strengthening  green  procurement’, 
were  selected: 
‘Government 
‘Strengthening  water  monitoring’  and 
strategy  and  action  plan  for  sustainable  development  in 
Hungary’. In 2022, a request  was approved to develop a 

240 The Commission issued a guidance document in 2016 on setting up 
coordinated and/or joint procedures that are simultaneously subject to 
assessments  under  the  EIA  Directive,  Habitats  Directive,  Water 
Framework  Directive,  and the  Industrial  Emissions  Directive,  OJ  C  273, 
27.7.2016, p. 1. 
241 European Commission, Technical Support Instrument. 

 Environmental Implementation Review 2022 – Hungary 

 
 
 
                                                                 
 
                                                                 
Hungary  47 

supervisory framework for financial risks stemming from 
biodiversity-related losses in Hungary. 

TAIEX EIR peer to peer projects 

The  TAIEX  EIR  peer  to  peer  tool242  was  launched  by  the 
Commission  to  facilitate  peer-to-peer  learning  between 
environmental authorities. 

Besides  the  previously  mentioned  events  on  ammonia 
reducing  technology  and  measures  in  November  2021 
and  the  EU  action  plan  ‘Towards  Zero  Pollution  for  Air, 
Water  and  Soil’ 
in  February  2022,  Hungary  also 
participated  in  another  EIR  peer-to-peer  event  on  the 
inclusion  of  green  criteria  in  public  procurement  on 
9 September 2020. 

242 TAIEX - Environmental Implementation Review - PEER 2 PEER. 

 Environmental Implementation Review 2022 – Hungary