COMMISSION STAFF WORKING DOCUMENT The early warning report for Hungary Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target
Date: 2023-06-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Hungary, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

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  EN 

   EUROPEAN COMMISSION  Brussels, 8.6.2023  SWD(2023) 189 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Hungary          Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions   identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target          {COM(2023) 304 final} - {SWD(2023) 175 final} - {SWD(2023) 176 final} - {SWD(2023) 180 final} - {SWD(2023) 181 final} - {SWD(2023) 182 final} - {SWD(2023) 183 final} - {SWD(2023) 184 final} - {SWD(2023) 185 final} - {SWD(2023) 186 final} - {SWD(2023) 187 final} - {SWD(2023) 188 final} - {SWD(2023) 195 final} - {SWD(2023) 196 final} - {SWD(2023) 197 final} - {SWD(2023) 198 final} - {SWD(2023) 199 final} - {SWD(2023) 200 final}  
 
 
1.  Introduction 

The early warning report aims to assist Member States at risk of failing to meet: (i) the 2025 target of 55% for 
the preparing for re-use and the recycling of their municipal waste (this target is set out in Article 11(2)(c) of 
Directive 2008/98/EC); and (ii) the 2025 target of 65% for the recycling of their packaging waste (this target 
is set out in Article 6(1)(f) of Directive 1994/62/EC). It also provides an update on how Member States are 
performing against the 2035 target to send no more than 10% of their municipal waste to landfill (this target 
is set out in Article 5(5) Directive 1999/31/EC).  
This report builds on previous support provided by the Commission to help Member States comply with EU 
law on municipal waste management, including, where relevant, the early warning report from 20181. 

The assessment underpinning the early warning report identified 18 Member States at risk of missing the 2025 
preparing for re-use and recycling target for municipal waste, 10 of which are also at risk of missing the 2025 
recycling target for all packaging waste. 

This assessment is based on a collaborative and transparent process involving the Member States concerned, 
the European Environment Agency2, and an in-depth analysis of the most recent policy developments in the 
Member States. This process also involved extensive consultation with the Member State authorities in charge 
of waste management. The possible actions identified during this process are based on existing best practices 
and aim to help Member States meet the 2025 targets, and as such they focus on policy measures which can 
be  taken  in  the  short  term.  These  actions  should  be  seen  as  complementary  to  those  recommended  in  the 
roadmaps  which  were  drawn  up  as  part  of  preceding  compliance-promotion  activities  and  to  those 
recommended in the Environmental Implementation Review3. 

2.  Key findings 

Based on the analysis of collected data and existing policies in the area of waste management,  Hungary is 
considered to be at risk of missing: (i) the 2025 target of 55% for the preparing for re-use and the recycling of 
its  municipal  waste; and (ii)  the  2025 target  to  recycle  65%  of  its  packaging  waste.  The  distance  between 
Hungary’s current landfilling rate and its 2035 target to landfill no more than 10% of its municipal waste is 
also of concern. 

Municipal waste generation in Hungary was significantly below the EU average in 2019 (387 kg/person vs an 
EU  average  of  502  kg/person).  Packaging  waste  generated  in  2018  was  also  below  the  EU  average 
(142 kg/person vs  an EU average of  177 kg/person). This might indicate that some quantities of generated 
municipal waste and packaging waste are not being reported. 

In 2020, the recycling rate for municipal waste reported by Hungary was 32% (which was 23 percentage points 
below the 2025 target), while the landfill rate was 54% (more than twice the EU average). In addition to the 
absolute  level  of  recycling,  general  recycling  trends  in  Hungary  are  also  of  concern.  This  is  because  the 
recycling  rate  decreased  from  34.7% in  2016 to  32%  in  2020,  while  the landfill  rate  increased  by  about  3 
percentage points over the same period.  

1 An early warning report was issued for Hungary in 2018 (SWD(2018) 419 final). In total, eight recommendations were 
drafted within the assessment. According to the Hungarian authorities, two of the report’s recommendations therein are 
considered implemented, four partially implemented, and two not implemented 
2 EEA and ETC/CE (2022). Early Warning Assessment Related to the 2025 Targets for Municipal and Packaging Waste 
(https://www.eea.europa.eu/publications/country-profiles-early-warning-assessments) 

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One of the main reasons for this performance is the excessively low rates of composting and digesting. The 
current  capacity  for  separate  collection  and  treatment  of  biowaste  can  only  handle  a  small  share  of  total 
biowaste generated in Hungary. The amount of municipal waste sent to landfill also remains too high. 

In 2019, the overall recycling rate for packaging reached 47.3%, which is a considerable distance from the 
2025 target of 65%. This situation is of particular concern due to identified issues with the quality of data on 
packaging  (inconsistencies  in  the  calculation  rules).  In  2020  the  recycling  rate  for  all  packaging  waste 
increased to 52.4%. 

Significant improvements are needed to bring Hungary’s performance in waste management into line with the 
EU’s waste hierarchy. Some of the main challenges facing waste management in the country include: 

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the  country’s  plan  to  transition  to  a  single  nationwide  waste  management  concession,  which  will 
involve a complete reorganisation of the sector and reassignment of responsibilities, and could result 
in further delays to achieving the waste targets4;  
low capture rates of recyclable waste in the separate collection system (23-44% for dry recyclables 
and less than 5% for biowaste5); 
limited recovery of biowaste and limited efficiency of facilities for treating biowaste; 

insufficient waste treatment infrastructure, notably insufficient capacity to sort and recycle separately 
collected packaging waste and comingled dry recyclables. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Hungary’s  efforts to  improve  its  performance  in  waste 
management, three main recommendations are listed below. 

1.  Support preparing for re-use of municipal waste and re-use systems for packaging. 
2.  Ensure that the planned transition to a new, single and nationwide concession for waste management 
is conducted in an efficient and transparent manner. The transition should ensure the support of key 
local stakeholders and follow a pace that makes it possible to overcome any potential pitfalls in the 
process.  

3.  Extend separate collection of waste at the source across the country (especially the separate collection 
of  biowaste).  Increase  public  awareness  of  waste  separation  and  waste  prevention.  Implement 
economic instruments such as pay-as-you-throw schemes, and increase landfill tax to both incentivise 
separate collection at source and minimise landfilled waste.  

4.  Further develop waste-treatment infrastructure associated with the higher steps of the waste hierarchy. 
In  particular  increase the  efficiency  of  – and  treatment  capacity  for  –  biowaste,  and  support  home 
composting.  

The table below lists a number of possible actions to support Hungary’s efforts to improve its performance in 
waste management. 

4  According to the Council Recommendation  of 12 July 2022 on the 2022 National Reform Programme  of Hungary‚ 
waste management was reorganised by the government in several steps. The changes limited competition in the sector, 
with 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32022H0901(17)&from=EN.  
5 36 000 tonnes of separately collected biowaste reported to EEA in 2022. 

efficiency 

declining 

recycling 

effect 

rates: 

side 

and 

the 

of 

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4.  Good practices 

The following measures implemented by Hungary are considered good practices that could be replicated and 
that could help Member States to achieve the above-mentioned targets. 

A centre for food-waste prevention – A nationwide system for preventing food waste was set up in 2021. This 
system,  which  was  set  up  through  Hungarian  legislation6,  entails  the  creation  of  a  dedicated  Food-Saving 
Centre. The Centre acts as both a coordinating body and an intermediary between grocery stores and various 
organisations  to  help  distribute  food  items  which  are  nearing  their  expiration  dates,  thus  preventing  waste 
generation. Organisations distributing food include public entities (municipalities or governments), member 
organisations of the Charitable Council, or other religious and private entities.  

Collection of wastepaper at schools – This is a well-established initiative in Hungary, which has been in place 
for several decades7. As part of this initiative held twice a year, teachers and students are encouraged to collect 
all wastepaper generated at educational institutions. Collected wastepaper is weighed on site and subsequently 
handed over for recycling. The initiative has a competitive element to it, encouraging children to strive for the 
title of the class that collects the most wastepaper. 

6 Act XLVI of 2008 on the Food Supply Chain and on the Control and Supervision of the Food Supply Chain § 38/H. 
7 Act CLXXXV of 2012 on Waste Management Activities and the Collection of Waste 12 § (2a). 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Ensure that the planned transition to a new, single and nationwide concession for waste management 
is conducted in an efficient and transparent manner. The transition should ensure the support and 
involvement of key local stakeholders and follow a pace that makes it possible to overcome any 
potential pitfalls in the process.  

2)  Address  data-quality  issues,  especially  issues  related  to  the  application  of  consistent  calculation 
rules for municipal waste recycling rates and packaging waste recycling rates. For instance, it should 
also account for packaging waste generated through online sales and free riders. 

3)  Set national standards for the quality of compost and digestate produced from biowaste treatment 
plants.  This  should  help  to  create  strong  demand  for  those  products  for  fertilising  purposes. 
Standards should be developed in close dialogue with the farming community. 

4)  Set mandatory objectives or indicators for separate  waste collection at the level of the  bodies in 
charge of collecting and managing municipal waste in order to monitor, enforce and achieve higher 
capture rates. This could be complemented with a system of performance-bound financial rewards 
and penalties dependant on the achievement of the targets. Information on the performance of those 
entities could also be made available to the general public to raise awareness (e.g. by publishing on 
a website). 

Prevention 

5)  Take measures to increase re-use and to prevent the generation of non-recyclable municipal waste. 

6)  Ensure that the results of the annual monitoring of the country’s waste-prevention programme are 
widely  available  to  the  public  to  strengthen  transparency  and  accountability.  It  should  foster 
coordination  between  central  government  and  local  government  to  achieve  the  EU’s  waste-
prevention objectives. 

Separate collection 

7)  Hungary  should  develop,  enforce  and  monitor  minimum  national-service  standards  for  separate 
waste collection (including biowaste). This could include specifying, for example: (i) the type and 
volume of containers to be used; (ii) the minimum and maximum frequency of collections; and (iii) 
the type of vehicles that may be used for collections. These standards should take into account the 
type  of  housing  stock,  climate,  seasonality,  etc.  Hungary  should  ensure  that  the  necessary 
infrastructure for separate collection is put in place. 

Waste treatment  

8)  Support  preparing  for  re-use  of  municipal  waste  and  develop  waste  treatment  infrastructure 
associated with the higher steps of the waste hierarchy. Firm plans and concrete actions are needed, 
such as supporting home composting and increasing the efficiency of – and treatment capacity for 
– biowaste to fully cover the generated biowaste. 

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Communication and awareness raising 

9)  Carry  out  awareness-raising  activities  specifically  tailored  to  different  target  groups  (e.g. 
households, commercial waste generators, schoolteachers, and students) to increase participation in 
separate collection.  A  set of  national communication  materials  should  be  developed that:  (i)  are 
addressed  to  the  general  public,  farmers,  and  pupils  for  use  at  local  level;  (ii)  have  clear  and 
consistent messages; and (iii) have a particular focus on biowaste, home composting, and sound 
management of waste (e.g. sorting). 

Extended producer responsibility and economic instruments 

10) Implement a pay-as-you-throw system for businesses and households to both attain higher capture 
rates  for  recyclable  fractions  and  reduce  residual  waste.  Local  authorities  could  be  supported 
through guidance on how to design incentive mechanisms and how to introduce – or learn from – 
pilot projects.  

11)  Use economic instruments (e.g. raising landfill taxes to a sufficient magnitude; they are currently 
about EUR 15 per tonne) to incentivise waste management focused on the higher steps of the waste 
hierarchy. This will help to make reuse, preparation for reuse, and recycling economically attractive 
and reduce dependency on landfilling. The economic incentive should be designed and sufficiently 
large to create a ‘steering effect’. Landfill taxes that increase over time in correlation to specific 
targets are considered the most effective. 

12) Stepping up efforts to establish reuse systems for packaging will bring environmental benefits and 

help Member States in complying with the EU packaging recycling targets. 

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