COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 312 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review       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 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 
PART I: THEMATIC AREAS ...................................................................................................................................... 4 
1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 12 
Global and EU biodiversity frameworks ............................................................................................................. 12 
Nature protection and restoration – Natura 2000 ............................................................................................. 12 
Recovery of species ............................................................................................................................................ 14 
Recovery of ecosystems ..................................................................................................................................... 15 
Prevention and management of invasive alien species ...................................................................................... 19 
Ecosystem assessment and accounting ............................................................................................................. 20 
3. ZERO POLLUTION ..................................................................................................................................................... 22 
Clean air ............................................................................................................................................................. 22 
Industrial emissions ............................................................................................................................................ 24 
Major industrial accidents prevention – Seveso ................................................................................................. 26 
Mercury Regulation ............................................................................................................................................ 27 
Noise .................................................................................................................................................................. 28 
Water quality and management ........................................................................................................................ 28 
Chemicals ........................................................................................................................................................... 33 
4. CLIMATE ACTION ..................................................................................................................................................... 36 
The EU emissions trading system ....................................................................................................................... 37 
Effort sharing ..................................................................................................................................................... 37 
Land use, land-use change and forestry ............................................................................................................. 38 
Adaptation to climate change ............................................................................................................................ 38 
PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 40 
5. FINANCING ............................................................................................................................................................. 40 
Climate finance landmarks ................................................................................................................................. 40 
Environmental financing and investments ......................................................................................................... 41 
Public financial management ............................................................................................................................. 45 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 48 
Information, public participation and access to justice...................................................................................... 48 
Compliance assurance ........................................................................................................................................ 50 
EU-supported environmental capacity building ................................................................................................. 53 
ANNEX ................................................................................................................................................................. 55 

 
 
 
 
Hungary  2 

Executive summary

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
describing 
the  main  outstanding  challenges  and 
opportunities  on  environmental  legal  implementation  in 
Hungary.  The  purpose  of  this  report 
is  to  provide 
information  on  the  implementation  performance  and 
highlight  the  most  effective  ways  to  address  the 
implementation gaps  that  impact human health and the 
environment and hamper the economic development and 
competitiveness  of  the  country.  The  report  relies  on 
detailed  sectoral  implementation  reports  collected  or 
issued  by  the  Commission  under  specific  environmental 
legislation. 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target and 
financial  implications.  In  Hungary,  such  challenges  have 
been  lingering  since  the  first  EIR  in  2017  and  require 
urgent action. 

Significant  efforts  are  needed  in  the  area  of  circular 
economy  for  Hungary  to  increase  circular  material  use 
rate and resource productivity and to reach EU averages. 
Urgent  reforms  and  investments  in  waste  management 
should  focus  on  diverting  municipal  and  construction 
waste from landfilling and improving recycling in Hungary. 
While some measures have been taken to improve waste 
management  since  the  2022  EIR,  the  latest  trends  for 
waste  are  concerning  in  Hungary.  The  landfilling  rate  is 
increasing,  while  the  recycling  rate  is  decreasing  and 
remains below the EU average. Hungary missed the 2020 
target  to  recycle  50 %  of  its  municipal  waste  by  a  great 
margin and is on a course to miss the 2025 targets of 55 % 
recycling  of  municipal  waste  and  65 %  recycling  of  all 
packaging waste. 

Biodiversity and nature is deteriorating in Hungary, and 
reinforced  actions  are  needed  to  restore  habitats  and 
species, in particular practices to support the transition to 
sustainable agriculture. 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

The air quality in Hungary continues to give serious cause 
for  concern.  While  some  emissions  have  decreased  in 
Hungary, persistent breaches of air quality requirements 
remain, with severe negative effects on human health and 
the environment. Hungary should take urgent actions  to 
reduce pollution from all sources. 

Reforms  and  investments  in  water  management  are 
increasingly  needed  in  Hungary.  Waterbodies  are  still 
exposed  to  significant  pressures  from  human  activities 
and  agriculture,  with  negative  implications  for  human 
health,  water  quality  and  quantity,  nature  conservation, 
and climate adaptation. More actions should be taken to 
implement  green 
infrastructures  and  nature-based 
solutions. There is also an urgent need to upgrade water 
utilities. Drinking water quality remains a serious source of 
concern in specific areas in Hungary, while more than 31 % 
of the urban waste water collected in the country is not 
being properly treated as required by EU law. 

The  overall  environmental  investment  need  to  enable 
Hungary to meet its objectives in the main environmental 
areas is  almost EUR 5.9 billion per year, broken down as 
follows:  circular  economy,  EUR 1.6 billion;  biodiversity 
and ecosystems, EUR 1.5 billion; pollution prevention and 
control,  EUR 1.5 billion;  and  water,  EUR 1.3 billion.  To 
meet  its  four  environmental  objectives  beyond  climate 
change, the additional investment need over the current 
levels  –  the  environmental  gap –  reaches  an  estimated 
EUR 2.4 billion per year in Hungary, representing around 
1.43 %  of  the  national  gross  domestic  product,  being 
significantly higher than the EU average (0.77 %). 

Several aspects of  environmental governance should be 
improved in Hungary, notably to ensure the compliance of 
environmental  procedures  with  legislation,  guarantee 
access to justice on environmental matters and increase 
administrative 
environmental 
policies. 

capacities 

regarding 

On the positive side, since the last EIR, some areas show 
progresses in Hungary. For instance, in 2023, Hungary has 
reported  adopting  all  management  plans  containing  the 
conservation measures for the Natura 2000 sites. Hungary 
has  also  made  some  progress  and  should  continue  its 
efforts to map and assess ecosystems and their services. 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Hungary 

 
 
 
Hungary  3 

Part I: Thematic areas 

1. Circular economy and waste management

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
circular  economy  has 
resource 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action  plan  (CEAP) (2)  measures  either 
in  place  or 
legislatively  advanced,  Member  States  will  now  have  to 
focus on a swift and effective implementation. 

consumption.  A 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were all introduced following a holistic life-cycle approach, 
with  measures  addressing  the  different  stages  of  a 
product’s life cycle, from design through use to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a  measure of one aspect of circularity: the 
share of the total amount of material used in the economy 
that is accounted for by recycled waste.  A higher CMUR 
value means that more secondary materials were used as 
a  substitute  for  raw  materials,  thus  reducing  the 
environmental impacts of extracting primary material. 

Hungary’s  circular  use  of  material  decreased  by 
1 percentage  point  between  2018  and  2023,  reaching 
5.9 % in 2023 (Figure 1). This is well below the EU average 
of 11.8 %. 

15

10

5

0

2013

2015

2017

2019

2021

2023

Hungary

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur,  last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur. 

9 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). 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 0.95 generated per kg of 
material  consumed  in  2023,  resource  productivity  in 
Hungary is well below the EU average of EUR 2.23 per kg, 
and the gap between the two has been widening. 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Hungary

EU-27

NB: The unit of measurement used is EUR/kg chain-linked volume (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015.  

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

9 December 

2024, 

(2) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 
economy action plan for a cleaner and more competitive Europe, 

to 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Hungary 

 
 
 
 
Hungary  4 

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

The green public procurement national action plan (2022–
2027) sets the goal that, by 2027, the number of domestic 
public procurements containing green aspects will reach 
at least 30 % of the total number of public procurements. 
The  strategy  also  provides  for  some  sector-specific 
regulations,  in  relation  to  some  products  and  product 
groups, applying a different (higher, even 100 %) target. 

The Public Procurement Authority informs stakeholders of 
the  possibilities  of  green  and  socially  responsible 
procurement  and  current  trends  in  EU  legislation  and 
policies.  The  authority  also  organises  training,  collects 
green  statistics  and  is  involved  in  green  procurement 
projects. The development of green public procurement is 
also supported by initiatives co-financed by national and 
EU funds (e.g. the ‘Green bus’ programme). 

The  EU  Ecolabel  and  the  eco-management  and  audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number  of  eco-management  and  audit  scheme  (EMAS)-
licensed  organisations  in  each  country  provide  some 
indication  of  the  extent  to  which  the  private  sector  and 
national stakeholders in that country are actively engaged 
in the transition to a circular economy. The EU Ecolabel is 
awarded  to  products  with  best-in-class  environmental 
is  a  voluntary  environment 
performance.  EMAS 
management 
the 
scheme 
environmental impacts of organisations. 

reducing 

aimed 

at 

As  of  September  2024,  Hungary  has  82  products  out  of 
98 977,  and  7  licences  out  of  2 983  registered  in  the  EU 
Ecolabel scheme. This shows low take-up, particularly for 
licences,  and  indicates  slight  decreases  since  the  2022 
report (9).  Moreover,  the  number  of  organisations  (27) 

Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These should be tailored to each national and local reality, 
to  harness  the  proximity  economy’s (3)  potential,  while 
following  the  principles  of  a  holistic  whole-value-chain 
approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (4)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 

In April 2024, the Organisation for Economic Co-operation 
(OECD)  published  a  paper (5) 
and  Development 
underlining  the  potential  and  the  need  for  a  circular 
economy 
Policy 
recommendations, priority sectors and cross-cutting tools 
are identified in the study. The three priority areas of the 
report are biomass and food, construction and plastics. 

framework 

Hungary. 

in 

Following  up  on  the  findings  of  this  study,  dedicated 
funding  allocated  by  the  EU  in  2019  and  the  first  policy 
proposal in 2018, a national circular economy strategy is 
being developed but has not been adopted yet. However, 
as highlighted in the OECD study, Hungary has embedded 
circular  economy  principles  within  several  key  national 
strategic frameworks, including the national development 
plan (6),  the  national  framework  strategy  for  sustainable 
development (7)  and  the  fifth  national  environmental 
programme (8).  These 
initiatives  promote  sustainable 
resource  use,  environmental  protection  and  economic 
resource  dependency, 
benefits, 
enhanced competitiveness and job creation. 

including 

reduced 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-
cycle analysis, PaaS (platform as a service), second hand) 
can help drive the demand for sustainable products that 
meet reparability and recyclability standards. 

(3) 

(4) 

(5) 

(6) 

(7) 

website, 

Economy 

Stakeholder 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
OECD, Towards a National Circular Economy Strategy for Hungary, 
OECD Publishing, Paris, 2023, https://doi.org/10.1787/1178c379-
en. 
Government  of  Hungary,  Nemzeti  Fejlesztés  2030 –  Országos 
Fejlesztési és Területfejlesztési Koncepció, Budapest, 2014. 
National  Council 
for  Sustainable  Development,  National 
Framework  Strategy  on  Sustainable  Development  of  Hungary, 

Platform 

(8) 

(9) 

2013, 

Budapest, 
https://www.parlament.hu/documents/127649/4101265/NFFT-
ENG-web.pdf/f692c792-424d-4f5a-9f9d-
9e6200303148?t=1580130885736. 
Government  of  Hungary:  Ministry  of  Energy,  5.  Nemzeti 
Környezetvédelmi 
2020, 
https://stip.oecd.org/stip/interactive-dashboards/policy-
initiatives/2023%2Fdata%2FpolicyInitiatives%2F99995825. 
European  Commission,  ‘Ecolabel  facts  and  figures’,  European 
2024, 
Commission 
https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en. 

September 

Budapest, 

Program, 

accessed 

website, 

2025 Environmental Implementation Review – Hungary 

 
 
from  Hungary  currently  registered  in  EMAS  has  not 
increased since October 2021 (10). 

In  2022,  Hungary  received  a  priority  action  to  adopt 
measures  to  increase  the  CMUR.  Since  then,  Hungary’s 
CMUR has increased by 1.0 percentage point (as of 2023). 
This represents some progress towards the 2022 priority 
action  to  take  measures  to  increase  the  CMUR,  but 
Hungary should continue its efforts. Hungary also received 
a  priority  action  to  strengthen  the  policy  framework  to 
speed  up  the  transition  to  a  circular  economy  in  all 
economic  sectors,  including  priority  sectors  such  as 
plastics,  textiles  and  construction.  Some  progress  has 
been  made  but,  as  Hungary  has  not  adopted  a  national 
circular economy strategy yet, the action is repeated. 

2025 priority actions 

•  Adopt measures to increase the circular material use 

• 

rate. 
Speed  up  the  transition  to  a  circular  economy  by 
implementing  an  updated  national  strategy  and  the 
EU framework and recommendations, in particular to 
complement it with upstream circularity measures. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste 

legislation,  which 
includes the waste hierarchy, the obligation to ensure 
separate collection of waste, landfill diversion targets, 
etc.; 

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRMs), with a view to reducing 
dependencies and building resilient value chains, and 
in  all 
stimulating  demand  for  recycled  content 
products; 

(v)  limiting energy recovery to non-recyclable materials; 

and 

Hungary  5 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
option,  disposal 
landfilling  and 
includes 
incineration without energy recovery). 

(which 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

Hungary  saw  a  significant  increase  in  waste  generation 
over 2010–2022 (Figure 3), mainly driven by mineral and 
solidified  waste,  mixed  waste  and  recyclable  waste. 
Overall,  there  appears  to  be  no  decoupling  of  waste 
generation from economic growth. 

Figure 3: Generation of waste (total and excluding major 
mineral waste), population and GDP, 2010–2022 

NB: Waste generation data for odd years are interpolated. 

accessed 

15 October 

nama_10_gdp, 

Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by  waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en; Eurostat, ‘Population change – Demographic balance and 
crude  rates  at  national  level’,  demo_grind,  accessed  15 October  2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

Hungary  does  not  seem  to  have  any  specific  policy  on 
CRMs. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (11) 

(10) 

As of October 2024. European Commission, ‘Eco-management and 
audit scheme (EMAS)’, European Commission website, November 
2021, 
http://ec.europa.eu/environment/emas/emas_registrations/stati
stics_graphs_en.htm. 

(11) 

European Commission: Joint Research Centre, Cristobal Garcia, J., 
Caro, D. et al., Techno-economic and environmental assessment of 
construction and demolition waste management in the European 
Union,  Publications  Office  of  the  European  Union,  Luxembourg, 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
Hungary  6 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing  for  reuse  and  recycling  targets  for  municipal 
waste and packaging waste 

by  the  Joint  Research  Centre  shows  that  recycling  and 
preparation for reuse are preferred over incineration and 
landfilling from an environmental perspective for most of 
the  different  streams  of  construction  and  demolition 
waste.  However,  the  economics  are  often  unfavourable 
for  recycling  and  preparation  for  reuse  compared  with 
incineration and landfilling. If available technology were to 
be  applied,  it  is  estimated  that  the  increase  in  recycling 
and  preparation  for  reuse  would  lead  to  an  additional 
33 Mt of greenhouse gas (GHG) emission savings annually 
(more  than,  for  example,  the  combined  annual  GHG 
emissions from Estonia, Latvia and Luxembourg). 

The rate of recycling and preparation for reuse of mineral 
construction and demolition waste in Hungary in 2022 was 
22.2.%,  compared  with  the  EU  average  of  79.8 %. 
Measures  to  further  increase  the  rate  of  recycling  and 
preparation  for  reuse  of  construction  and  demolition 
waste  include  separate  collection  at  the  source –  for 
instance,  through  digitalised  pre-demolition  audits (12) 
(‘resource 
producer 
responsibility (EPR) and other economic instruments; and 
upstream  measures  such  as  increasing  the  recycled 
content 
in  construction  products  and  the  circular 
design (13) of construction works. 

assessments’); 

extended 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

This  section  focuses  on  the  management  of  municipal 
waste (14),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (15)  identifying  the  general 
trends in waste management and the  Member States at 
risk of missing 2025 waste targets (see Figure 4). Hungary 
is at risk of missing both the municipal waste target and 
the packaging waste target. Hungary is also at risk of not 
meeting the 2035 target of having a maximum of 10 % of 
municipal waste landfilled. 

2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

(12) 

(13) 

  Member  States  not  at  risk  of  missing  the  55 % 
preparing  for  reuse  and  recycling  target  for 
municipal waste and the 65 % recycling target for 
packaging waste 

  Member States at risk of missing the preparing for 
reuse and recycling target for municipal waste but 
not  at  risk  of  missing  the  recycling  target  for 
packaging waste 

  Member States at risk of missing both targets 
  Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not on track to meet recycling targets for municipal waste and packaging 
waste’, briefing No 28/2022, Copenhagen, 2023. Reference data © ESRI. 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to use this 
possibility  have  to  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan  laying  down  the  steps  they  envisage  to  reach  the 
postponed targets within a new time frame. Regarding the 

(14)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators,  and  bulky  waste, 
including  mattresses  and 
furniture;  and  (ii)  mixed  waste  and  separately  collected  waste 
from  other  sources,  where  such  waste  is  similar  in  nature  and 
composition  to  waste  from  households  (Directive  2008/98/EC, 
Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(15) 

2025 Environmental Implementation Review – Hungary 

 
 
 
2025 targets, 11 Member States, including Hungary, have 
used this prerogative. 

and  recycling  rate  in  2021.  The  2022  data  under  this 
reporting obligation are not available yet. 

Hungary  7 

On 22 December 2023, Hungary notified the Commission 
of  its  intention  to  postpone  the  attainment  of  the 
preparing  for  reuse  and  recycling  target  for  municipal 
waste established by the Waste Framework Directive for 
2025. In addition, Hungary notified the Commission of its 
intention  to  postpone  the  attainment  of  the  recycling 
target for plastic and glass packaging waste established by 
the  Packaging  and  Packaging  Waste  Directive  for  2025. 
Attached  to  these  notifications,  Hungary  submitted  an 
implementation plan laying down the measures necessary 
to attain the targets within a postponed time frame (i.e. 
2030 instead of 2025). According to the implementation 
plan, the main measures Hungary will put in place include 
the  introduction  of  a  35-year  concession  system,  the 
introduction of an EPR system and the use of awareness-
raising  campaigns.  The  Commission  found  that  the  plan 
submitted does not comply with the requirements set out 
in the relevant waste legislation (16). 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (17), the Packaging and 
Packaging Waste Directive (18) and the Directive on Waste 
Electrical and Electronic Equipment (WEEE) (19). 

Municipal waste 

After  a 
limited  decrease  between  2010  and  2015, 
municipal waste generation in Hungary increased slightly 
and  reached  407  per  capita  in  2022,  still  below  the  EU 
average in the same year (515 kg per capita) (see Figure 5). 

Hungary has also reported data to show compliance with 
the  preparing  for  reuse  and  recycling  target  of  55 %  for 
2025,  as  set  out  in  the  Waste  Framework  Directive.  The 
difference between these (provisional) data, following the 
reporting  obligation  of  the  Waste  Framework  Directive, 
and the data shown in Figure 5 (voluntary reporting) was 
less  than  1 percentage  point  for  the  preparing  for  reuse 

Commission Decision C(2024) 1974. 

(16) 
(17)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  repealing  certain 
https://eur-lex.europa.eu/legal-
Directives, 
content/EN/TXT/?uri=CELEX%3A02008L0098-20180705. 
European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste  (OJ  L  365, 

(18) 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

NB: As of reference year 2020, new reporting rules apply to calculating 
recycled  municipal  waste  pursuant  to  the  targets 
in 
Article 11(2)(c–e) of Directive 2008/98/EC. 
Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

laid  down 

accessed 

The recycling rate for municipal waste in Hungary reached 
33 %  in  2022,  which  is  significantly  below  the  estimated 

31/12/1994, 
content/EN/TXT/?uri=CELEX%3A01994L0062-20180704. 

https://eur-lex.europa.eu/legal-

10–23), 

p. 

(19)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012L0019. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
Hungary  8 

Figure 8: Packaging waste recycling rates, 2010–2022 

EU-27 average of 49 % in the same year (20). This is mainly 
driven by material recycling, as Hungary has low rates of 
composting and anaerobic digestion. 

Incineration plays a minor role in Hungary, with only 12 % 
of  the  generated  municipal  waste  incinerated  in  2022. 
There  is  still  a  significant  share  of  municipal  waste 
landfilled. 

Packaging waste 

Figure 7: Packaging waste generation, 2010–2022 

NB:  As  of  reference  year  2020,  the  rules  for  calculating  recycled 
packaging  waste  have  changed,  pursuant  to  Article 6(a)  of  Directive 
94/62/EC. Hungary has applied the new reporting rules since reference 
year  2020  (Ministry  of  Energy,  2024,  Information  provided  during  the 
Eionet review of the draft EEA country profile on waste management for 
Hungary). 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of  EU  waste  legislation.  They  set  out  key  provisions  and 
investments to ensure compliance with existing and new 
legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). 

Hungary’s  national  waste  prevention  programme 
is 
integrated into the national waste management plan for 
2021–2027 (22).  The  prioritised  waste  streams 
for 
prevention  measures  are  municipal  waste,  industrial 
waste,  non-hazardous  agricultural  waste,  food  waste, 
construction and demolition waste, hazardous waste and 
biodegradable waste. One focus area is promoting reuse 
practices. 

Policies to encourage separate collection and recycling 

Hungary applies a pay-as-you-throw system that is based 
frequency.  The 
on  container  size  and  collection 
nationwide  deposit  return  system  started  with  an 
introduction  phase  and  has  been  fully  operational  since 
1 July 2024. The system covers single-use plastic beverage 
bottles, glass beverage bottles and metal beverage cans, 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Hungary’s  packaging  waste  generation  has  increased 
significantly since 2010 (Figure 7). The country generated 
166 kg per capita in 2022, which is significantly below the 
estimated  European  average  of  186 kg  per  capita  in  the 
same year (21). 

Hungary’s  overall  packaging  waste  recycling  rate  has 
stagnated  since  around  2012.  In  2022,  the  overall 
packaging  waste  recycling  rate  was  45 %.  The  recycling 
rate is mainly driven by paper and cardboard and plastic 
packaging waste, as these constitute the largest shares of 
generated  packaging  waste.  Due  to  the  high  share  of 
plastic in total packaging waste and its low recycling rate, 
a  specific  focus  will  be  needed  on  increasing  plastic 
recycling  to  meet  the  targets  for  plastic  and  overall 
packaging. 

(20) 

(21) 

The  EU  average  might  have  been  influenced by  not  all  Member 
States  fully  applying  the  reporting  rules  for  municipal  waste  set 
out in the Waste Framework Directive (as amended in 2018). 
The  EU  average  might  have  been  influenced by  not  all  Member 
States fully  applying  the  reporting  rules for  packaging  waste  set 
out in Commission Implementing Decision (EU) 2019/665. 

(22) 

Hungary, 

European  Environment  Agency  (EEA),  Waste  Prevention  Country 
Profile – 
2023, 
Copenhagen, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
sheets/hungary_waste_prevention_2023. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
and  also  covers  the  return  of  refillable  beverage 
packaging.  Hungary 
levies  product  fees  on  certain 
packaging  materials.  These  fees  can  be  seen  as  a 
packaging tax (23). In July 2023, Hungary introduced new 
separate EPR fees based on collection and treatment costs 
(no  modulation).  The  environmental  product 
fee 
remained as a green tax levied on some products. 

Policies to discourage landfilling or incineration 

Hungary has had a landfill levy since 2014 of HUF 6 000/t 
(EUR 15.13/t  in  June  2022).  The  levy  is  lower  than  the 
average  EU-27  landfill  tax.  There  has  been  a  ban  on 
landfilling  untreated  municipal  waste  since  2022  and  a 
partial ban on landfilling organic waste since 2003. 

Hungary has no incineration tax in place and there is no 
tax  on  waste  exported  for  incineration.  To  be  able  to 
drastically  decrease  the  landfill  rate  and  achieve  the 
landfill  target,  Hungary  plans  to  increase  the  energy 
recovery of residual municipal waste (24). 

Hungary  is  among  the  26  Member  States  subject  to  an 
infringement proceeding (25) for failing to meet the waste 
collection  and  recycling  targets  set  out  in  the  Waste 
Framework  Directive (26),  the  Packaging  and  Packaging 
Waste  Directive (27)  and  the  Directive  on  WEEE (28).  In 
November 2024, the Commission launched infringement 
proceedings  against  Hungary  for  incorrectly  transposing 
the Waste Framework Directive and the Landfill Directive. 

In 2022, Hungary received priority actions to (i) gradually 
increase landfill taxes to phase out landfilling of recyclable 
and  recoverable  waste,  and  use  the  revenues  for 
measures  that  improve  waste  management,  in  line  with 
the  waste  hierarchy;  (ii)  focus  on  making  separate 
collection obligatory to increase recycling rates, including 
the  collection  of  biowaste,  and  develop  and  implement 
minimum service standards and support programmes for 
municipalities;  and  (iii)  improve  the  functioning  of  EPR 
systems, in line with the general minimum requirements 
on EPR (29). 

Hungary has not yet ratified the Hong Kong Convention on 
Ship Recycling. 

• 

Hungary  9 

In  terms  of  progress  since  the  2022  environmental 
implementation review (EIR) (30), Hungary has made: 

• 

• 

• 

no  progress  regarding  increasing  landfill  taxes  to 
phase  out  landfilling  of  recyclable  and  recoverable 
waste: landfill rates have stagnated and  over half of 
municipal waste is still landfilled; 
some  progress  regarding  separate  collection,  as 
several  measures  have  been  recently  introduced, 
including  a  deposit  return  scheme  for  beverage 
packaging,  while  there  is  no  progress  regarding  the 
development  and 
implementation  of  minimum 
service  standards  and  support  programmes  for 
municipalities; 
some progress regarding the EPR systems through the 
introduction  of  EPR  fees,  in  line  with  the  general 
minimum requirements on EPR. 

2025 priority actions 

• 

Implement, harmonise and gradually increase landfill 
taxes  to  phase  out  landfilling  of  recyclable  and 
recoverable waste. 

•  Ratify international conventions on ship recycling. 
• 

Improve  separate  collection  at  source  e.g.  through 
economic instruments, investing in infrastructure for 
separate  collection,  sorting  and  recycling,  and 
increasing public awareness. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps  of  the  waste  hierarchy.  In  particular,  improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Improve  municipal  waste  preparation  for  reuse  and 
recycling. 
Increase the recycling rates of packaging waste. 
Increase the collection and recycling rate of WEEE. 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 

• 

• 

• 
• 
• 

•  Develop  EPR  schemes  for  problematic  waste  and 

introduce fee modulation.  
Ensure  the  achievement  of  the  2025  waste  targets, 
the 
following 

the  recommendations  made  by 

(23) 

(24) 

(25) 

EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Hungary,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/hungary/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Hungary,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/hungary/view. 
See  European  Commission,  ‘July  infringement  package:  Key 
decisions’,  European  Commission  website,  25 July  2024, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_24_
3228. 

(26)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19 November  2008  on  waste  and  repealing  certain 
Directives (OJ L 312, 22.11.2008, p. 3), as amended. 

(27) 

European  Parliament  and  Council  Directive  94/62/EC  of 
20 December 1994 on packaging and packaging waste (OJ L 365, 
31.12.1994, p. 10), as amended. 

(29) 

(28)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment (WEEE) (OJ L 197, 24.7.2012, p. 38), as amended. 
Set out in Directive (EU) 2018/851 of the European Parliament and 
of the Council of 30 May 2018 amending Directive 2008/98/EC on 
waste (OJ L 150, 14.6.2018, p. 109). 
Commission 
implementation 
SWD(2022) 268 
lex.europa.eu/legal-
content/EN/TXT/?uri=comnat%3ASWD_2022_0259_FIN. 

Environmental 
review  2022:  Country 
report –  Hungary, 
final  of  8 September  2022,  https://eur-

staff  working 

document – 

(30) 

2025 Environmental Implementation Review – Hungary 

 
 
Commission  in  the  early  warning  reports  where 
applicable. 

Hungary  10 

2025 Environmental Implementation Review – Hungary 

 
 
Hungary  11 

2. Biodiversity and natural capital

Global and EU biodiversity frameworks 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. The EU biodiversity strategy for 2030 (BDS) aims to 
put EU biodiversity on a path to recovery by 2030. It sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
and 
as  measures 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (31)  and  a  dashboard  of  indicators (32) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (33) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20 % of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
implementation 
national 
restoration plans. 

implementation 

framework 

enable 

based 

on 

to 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity  its 
report on GBF-aligned EU targets that stem from the BDS 
and from other policy instruments under the European 
Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 

(31) 

(32) 

(33) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
see  also 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

page 

web 

In 

2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

Hungary’s national biodiversity strategy for 2030 (34) was 
approved  and  published  by  the  Hungarian  government 
on  8 August  2023 (35), 
an  extensive 
participatory  process  with 
the  engagement  of 
government  agencies,  experts  and  stakeholders  across 
sectors and policy areas. 

following 

The  strategy  translates  the  EU  and  global  biodiversity 
targets  into  Hungary’s  national  context.  It  identifies  19 
key  objectives  for  2030  in  three  strategic  areas:  (i) 
reducing  threats  to  biodiversity;  (ii)  sustainable  use  of 
biodiversity  and  benefit-sharing;  and  (iii)  tools  and 
solutions  supporting 
implementation.  Each  national 
objective includes several targets (50 in total), with more 
than  300  implementation  measures  and  corresponding 
indicators.  In  2024,  Hungary  also  uploaded  its  national 
targets to the Convention on Biological Diversity’s online 
reporting tool (36). 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
rising  to  10 %  in  2026  and  2027.  For  more  details  on 
biodiversity financing and investments for Hungary, see 
‘Biodiversity and ecosystems’ in Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (37),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 

(34) 

(35) 

https://www.biodiv.hu/en/convention-on-biological-
diversity/national-biodiversity-strategy-for-2030. 
https://kormany.hu/hirek/elfogadtak-a-3-nemzeti-
biodiverzitas-strategiat. 
https://ort.cbd.int/national-targets?countries=hu. 

(36) 
(37)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 

2025 Environmental Implementation Review – Hungary 

 
 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (38); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
is  a  cornerstone  of  the  EU’s 
Natura  2000  sites 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000 will enable the natural habitat types and the 
species’ habitats concerned to be maintained or, where 
appropriate,  restored  to  a  favourable  conservation 
status in their natural range. 

Hungary  hosts  45 habitat  types (39) and  212 species (40) 
covered by the Habitats Directive. The country also hosts 
populations of 88 bird  taxa  listed in the Birds Directive 
Annex I (41). 

As  shown  in  Figure 9,  in  2023,  21.4 %  of  Hungary’s 
territory  was  covered  by  Natura  2000  (EU  coverage: 
18.6 %),  with  special  protection  areas  (SPAs)  classified 
under the Birds Directive covering 14.8 % (EU coverage: 
12.8 %). This overlapped to a large degree with the SCIs 
under  the  Habitats  Directive,  which  covered  15.5 %  of 
Hungarian territory (EU coverage: 14.3 %). 

Considering  both  areas  covered  by  Natura  2000  and 
other  nationally  designated  protected  areas,  Hungary 
legally  protects  22.2 %  of  its  terrestrial  areas  (EU-27 
coverage: 26.1 %) (42) 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). 

Hungary  12 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating  special  areas  of  conservation  and  setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  Such  site-specific 
conservation  should  define  attributes  and  targets  that 
describe the habitats or species’ condition as favourable 
or unfavourable, addressing key pressures and threats . 
Under Article 6 of the Habitats Directive Member States 
must establish and implement measures to achieve these 
objectives.  Article 6  of  the  Habitats  Directive  requires 
Member States to establish and implement conservation 
measures for the realisation of the objectives of the site. 

In  2016,  an  EU  pilot  investigation  was  launched  by  the 
Commission  following  an  assessment  that  the  site-
specific  measures  and  objectives  in  Hungary  were  not 
fully  in  line  with  the  related  EU  guidance.  Since  then, 
Hungary  has  designated  all  SCIs  as  SACs  and,  by  early 
2024, had adopted management plans and site-specific 

(38) 

(39) 

(40) 

SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
total,  19 December  2019, 
Article 17  dashboard,  Annex I 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA, ‘Number of habitats and species per Member State’, Article 
2019, 
19 
17 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species.  This 

dashboard, 

December 

(41) 

(42) 

counting only takes into account species and habitats for which 
assessment of conservation status was requested. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  bird  taxa  for  which 
information was requested. 
Eurostat dataset env_bio4, terrestrial protected area percentage 
for 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en. 

accessed 

March 

2022, 

2025 Environmental Implementation Review – Hungary 

 
 
 
conservation  measures  and  objectives 
assessment) for all SAC and SPA sites. 

(pending 

protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Hungary  13 

In  the  2022  EIR,  Hungary  received  priority  actions  to 
complete  and  adopt  the  management  plans  for  all 
Natura  2000  sites  and  finalise  the  revision  of  the 
conservation  measures  and  site-specific  conservation 
objectives  to  bring  them  in  line  with  Commission 
guidance.  Under  the  EU  pilot  investigation,  Hungary 
reported adopting all the management plans containing 
the conservation measures for the Natura 2000 sites on 
4 August 2023; the plans were published on the official 
target 
website.  Hungary  reported  completing  all 
documents  containing  the  conservation  objectives  on 
12 February 2024. 

2025 priority action 

• 

Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
the  Nature  Restoration 
implementation  of 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (43). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 

(43) 

(44) 

European 

EEA,  https://www.eea.europa.eu/publications/state-of-nature-
in-the-eu-2020State of Nature in the EU: Results from reporting 
under  the  Nature  Directives  2013–2018,  Publications  Office  of 
the 
2020, 
Union, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  ‘Conservation  status  and  trends  of  habitats  and  species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-

Luxembourg, 

December 

accessed 

2019, 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

Hungary  has  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  reporting  good  conservation 
status  was  13.33 %.  This  is  less  than  in  the  previous 
reporting  period  (2007–2012),  when  the  share  was 
19.57 %. For protected species, the share of assessments 
indicating  good  conservation  status  was  34.91 %  in 
2013–2018,  down  from  the  35.89 %  reported  in  the 
previous reporting period (2007–2012). Less than 8 % of 
the  assessments (44)  for  forest  habitats  listed  under 
Article 17  of  the  Habitats  Directive  show  a  favourable 
conservation status (45). For birds, 51 % of the breeding 
species 
stable 
population  trends  (despite  the  previously  increasing 
trend,  the  share  dropped  from  19 %  in  the  previous 
reporting  period  to  14 %).  For  key  wintering  species, 
21.05 % 
stable 
showed 
population trends. 

increases  or 

increases  or 

short-term 

short-term 

showed 

in  bad 
At  the  same  time,  the  share  of  habitats 
conservation status increased to 48.89 %, and the share 
of  species  in  bad  conservation  status  also  increased, 
rising to 11.79 %. The main pressures on habitats come 
from natural processes, agriculture and climate change. 
As  Hungary  is  mainly  covered  with  natural  and  semi-
natural  grasslands,  agriculture  is  a  significant  pressure 
overall. Meanwhile, the main pressures on species come 
from agriculture, climate change and forestry. 

(45) 

nature-in-the-eu/article-17-national-summary-
dashboards/conservation-status-and-trends. 
European  Commission:  Directorate-General  for  Environment, 
The State of Nature in the EU – Conservation status and trends of 
species and habitats protected by the EU Nature Directives 2013–
2018,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, 
https://op.europa.eu/en/publication-detail/-
/publication/e733191f-5c65-11eb-b487-01aa75ed71a1. 

2025 Environmental Implementation Review – Hungary 

 
 
Figure 10:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
2021, 
19 December 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

Hungary  14 

2025 priority actions 

• 

Strengthen  the  integration  of  biodiversity  actions 
into  other  policies  (e.g.  on  energy,  agriculture, 
fisheries, forestry, urban and infrastructure planning 
and 
promote 
and 
communication between stakeholders. 

sustainable 

tourism) 

•  Reinforce  action  for  habitats  and  species  with 
for 
unfavourable  conservation  status  through, 
example, 
increased 
connectivity,  better  policy 
coordination  and 
integration, and increased funding. 

restoration  measures, 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
is  no 
fertilisers)  while  ensuring 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The “Vision for agriculture and food” (46), adopted by the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective. 

The  CAP  and  national  CAP  strategic  plans  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
implementing  EU 
and  plays  a  significant  role 

in 

(46) 

https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

While certain CAP result indicators focus on the national 
measures  favouring  sustainable  agriculture  practices 
that  regenerate  the  ecosystems,  the  impact  of  these 
measures is difficult to assess, as the uptake of the eco-
schemes is voluntary for farmers. 

The utilised agricultural area in Hungary increased from 
5 338 020 ha in 2012 to 5 352 280 ha in 2017, but then 
decreased to 5 081 050 ha in 2022 (47). 

fragments  of  non-
Landscape  features  are  small 
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
covered  by  agricultural 
land.  Based  on  the  Land 
landscape  features 
Use/Cover  Area  Frame  Survey 
estimates, the share of agricultural land covered by non-
productive landscape features in Hungary is 4.1 %, below 
the EU average. At the EU level, landscape features cover 
5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (48) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  area  or  landscape  features  in  their 
farms.  However,  the  amended  regulations  set  out  an 
obligation  for  Member  States  to  establish  and  provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 
fallow,  and  for  the  establishment  of  new  landscape 
features, on arable land. 

The recently adopted Nature Restoration Regulation (49) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 

(47) 

(48) 

(49) 

Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/d
efault/table?lang=en. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 

Hungary  15 

ecosystems (50). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
only  6.31 %  of  Hungary’s  land  area  is  used  for  organic 
farming. This is lower than the EU average of 10.50 % (51). 
Hungary  is  currently  contributing  less  than  average  to 
achieving the target of 25 % of the EU’s agricultural land 
being used for organic farming by 2030. 

Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
2022 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

In 2022, Hungary received a priority action to ensure that 
land used for organic farming significantly contributes to 
the 25 % target of the EU’s agricultural land being used 
for organic farming by 2030. While the trend is positive, 
Hungary  is  still  among  the  Member  States  with  the 
lowest share of organic farming. Therefore, this priority 
action is reiterated in the 2025 EIR to encourage Hungary 
to increase its contribution to the 2030 target. 

In the 2022 EIR, Hungary also received priority actions to 
decrease the pressure on habitats and species (including 
birds), in particular  from agriculture, which  is the  most 

(50) 

(51) 

in  cropland  mineral  soils’  and 

Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

2025 Environmental Implementation Review – Hungary 

 
 
 
significant  pressure  on  nature  and  biodiversity;  and  to 
step up efforts to implement the recommendations set 
out in Hungary’s CAP SP, especially those on improving 
rural  areas.  The  available  data  do  not  allow  for  the 
assessment  of  potential  progress  in  this  field.  Hungary 
will also need to step up its conservation and restoration 
efforts to meet the ambitions of the new regulation. 

2025 priority actions 

• 

• 

• 

and 

address 

practices 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
to 
environmental needs of Hungary. 
Implement  and  scale  up  the  uptake  of  organic 
farming practices. 
Promote  the  active  management  of  grasslands 
through extensive grazing to maintain the condition 
of these semi-natural habitats. 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
security  and  climate 
resilience,  adaptation  and 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (52) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 

(52) 

(53) 

of 

final 

5 July 

2023, 

Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
2023, 
5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

Hungary  16 

the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Hungary (53). 

soil  organic 

loss  of 

carbon, 

The greatest contributor to Hungary’s unhealthy soils is 
the loss of soil organic carbon in mineral soils (54), which 
affects 41 % of the land, representing 70 % of cropland 
and  grassland  areas.  Intensive  agriculture  practices  are 
one  of  the  main  pressures  on  soil  health.  24 %  of  the 
national territory experiences unsustainable soil erosion 
by  water,  wind,  tillage  and  harvest,  and  14 %  of  the 
national territory has a high or very high susceptibility to 
topsoil compaction. 

In  the  2022  EIR,  Hungary  received  a  priority  action  to 
remediate degraded areas of soil and consider formally 
committing to land degradation neutrality targets under 
Convention 
the  United  Nations 
Combat 
Desertification 
to  Hungary’s 
(UNCCD).  According 
national  report  to  the  UNCCD,  Hungary  has  not  set  an 
LDN  target  yet  (55).  Therefore,  the  priority  action  is 
repeated. 

to 

2025 priority action 

•  Reduce the excessive area of sealed and artificialised 
soil  and  remediate  degraded  areas  of  soil.  If 
appropriate, consider formally committing to targets 
for  land-degradation  neutrality  under  the  relevant 
United 
Combat 
Desertification agreement. 

Convention 

Nations 

to 

(54)  De  Rosa,  D.,  Ballabio,  C.,  Lugato,  E.  et  al.,  ‘Soil  organic  carbon 
stocks in European croplands and grasslands: How much have we 
lost in the past decade?’, Global Change Biology, Vol. 30, No 1, 
2023, e16992, https://doi.org/10.1111/gcb.16992. 

(55)  UNCCD,  Hungary  country  report  2022  (PRAIS4),  15  February 
2023,  p.14,  https://www.unccd.int/our-work-impact/country-
profiles/hungary#:~:text=Hungary%20country%20report%2020
22%20(PRAIS4);  UNCCD,  Voluntary  LDN  targets,  accessed  on  4 
https://www.unccd.int/our-work/country-
2025, 
March 
profiles/voluntary-ldn-targets. 

2025 Environmental Implementation Review – Hungary 

 
 
Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

Hungary hosts 12 grassland habitat types, of which 6 are 
priority  habitats (56).  All  grassland  habitats  were  and 
continue to be in unfavourable conservation status, with 
no marked improvements since the last reporting period 
and bleak future prospects. Abandonment has long been 
a  major  cause  of  the  degradation  of  grassland  habitats 
(together with land-use change). 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

Hungary, as a land-locked country, hosts five bog, mire 
and  fen  habitat  types,  of  which  three  are  priority 
habitats (57);  one  coastal  and  halophytic  habitat 
(Pannonic  salt  steppes  and  salt  marshes);  and  five 
freshwater habitats. Most  of these are in unfavourable 
conservation  status,  with  no  significant  improvements 
since the last reporting period or expected in the future 
except for habitat type 7210 (Calcareous fens). 

Hungary  17 

Wetlands were mainly affected by change in floodplains, 
inadequate  flood  management  programmes,  riverbed 
alterations and water drainage. Climate change, and thus 
changes in hydrology and droughts, is also becoming an 
increasingly important pressure. 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
forests  that  contribute 
diverse  and  resilient  EU 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
Directives, 
is  a 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several Commission guidelines on forestry management 
were  published  in  2023.  They  covered  biodiversity-
friendly  afforestation,  reforestation  and  tree  planting; 
closer-to-nature  forest  management;  and  defining, 
mapping, monitoring and strictly protecting primary and 
old-growth  forests.  Further  guidance  on  payment 
schemes 
for  ecosystems  services  has  also  been 
published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (58) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (59).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

Hungary  hosts  13  forest  habitat  types,  of  which  5  are 
considered  priority  habitats (60).  In  Hungary,  forests 

(56) 

(57) 

These are 6110 (rupicolous  calcareous or basophilic grasslands 
of the Alysso-Sedion albi), 6210 (semi-natural dry grasslands and 
scrubland facies on calcareous substrates (Festuco-Brometalia)), 
6230 (species-rich Nardus grasslands, on siliceous substrates in 
mountain areas (and submountain areas in continental Europe)), 
6240  (sub-Pannonic  steppic  grasslands),  6250  (Pannonic  loess 
steppic grasslands) and 6260 (Pannonic sand steppes). 
These are 7110 (active raised bogs), 7210 (calcareous fens with 
Cladium  mariscus  and species of  the  Caricion  davallianae)  and 
7220 (petrifying springs with tufa formation (Cratoneurion)). 

(59) 

(60) 

(58)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
2023, 
forests, 

COM(2023)728, 

November 

22 

https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

Union, 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
These  are  91G0  (Pannonic  woods  with  Quercus  petraea  and 
Carpinus  betulus),  91H0  (Pannonian  woods  with  Quercus 
pubescens),  91E0  (alluvial  forests  with  Alnus  glutinosa  and 

Luxembourg, 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
covered 22.7 % of the country (61) in 2020. The situation 
of forest habitats protected under the Habitats Directive 
is particularly worrying as more than half of the assessed 
forests  have  a  bad  status (62).  Plantation  forests  with 
invasive alien species (IAS) continue to be an important 
threat to forest habitats and biodiversity, notably black 
locusts,  which  is proving  difficult  to  eradicate.  In  2022, 
Hungary  also  adopted  a  decree (63)  establishing 
logging  activities  to  address 
derogation  rules  for 
increased  firewood  needs.  This  decree  raised  some 
concerns  regarding  its  potential  impacts  on  protected 
forests conservation and the Commission is monitoring 
the situation. 

Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (% 
assessments), 2013–2018 

Source: Commission staff working document – New EU forest strategy 
final  of  16 July  2021,  p. 24,  eur-
for  2030,  SWD(2021) 652 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

. 

(61) 

(62) 

Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae)), 
91I0 (Euro-Siberian steppic woods with Quercus spp.) and 91N0 
(Pannonic inland sand dune thicket (Junipero-populetum albae)). 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. The land cover 
statistics show the percentage covered by forests compared with 
other land uses. 
European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
p. 13,https://publications.jrc.ec.europa.eu/repository/handle/J
RC124671. 

(63)  Government Decree No 287/2022 (VIII. 4.) on applying different 

(64) 

(65) 

rules to meet firewood needs during an emergency. 
Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 

Hungary  18 

The  EU  Timber  Regulation  (EUTR) (64)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (65)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
force (66).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR. 

into 

2025 priority action 

• 

Improve conservation status of forests by promoting 
forest  managment  and  ensuring 
sustainable 
compliance  with  the  Habitats  Directive  before 
granting/renewing permits for forest logging. 

Prevention and management of invasive alien 
species 

IAS  are  a  major  cause  of  biodiversity  loss  in  the  EU. 
Besides  inflicting  direct  and  indirect  damage  on  nature 
and  the  economy,  some  IAS  also  carry  and  spread 
infectious  diseases,  posing  a  threat  to  humans  and 
wildlife.  Regulation 
IAS 
Regulation) aims to prevent, minimise and mitigate the 
adverse impacts of IAS on biodiversity. It focuses action 
on a list of IAS of EU concern (the ‘Union list’), which is 
regularly updated (67). 

(EU)  No 1143/2014 

(the 

The third update of the Union list entered into force on 2 
August 2022. The fourth update is in preparation. 

The IAS Regulation (68) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 

and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(67) 

(66)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
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 
https://eur-
4.11.2014, 
L 317, 
lex.europa.eu/eli/reg/2014/1143/oj/eng. 

p. 35), 

(68) 

(OJ 

2025 Environmental Implementation Review – Hungary 

 
 
 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (69).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (70),  and  at 
USD 423 billion annually at the global level (71). 

The total number of IAS of Union concern in the country 
is 41. This includes 33 species recorded in the previous 
EIR (2021) and 8 additions. Of these additions, two were 
already on the Union concern list in 2021, and six were 
added later under Commission Implementing Regulation 
(EU) 2022/1203. 

Figure 14:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Hungary, 2024 

(69)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(71) 

(70)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

on 
Science-Policy 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

(Intergovernmental 

Ecosystem 

and 

(72)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
framework 
biodiversity 

Hungary  19 

In 2022, Hungary received priority actions to (i) step up 
implementation  of  the  IAS  Regulation  and  (ii)  continue 
collecting  data  on  IAS  and  improve  the  surveillance 
system. Hungary has fulfilled these priority actions. 

ratified 

Hungary  has  not  yet 
International 
Convention  for  the  Control  and  Management  of  Ships’ 
Ballast Water and Sediments of 2004 (BWM Convention), 
which  introduces  global  regulations  to  control  the 
transfer of potentially invasive species. 

the 

2025 priority actions 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

•  Ratify  the  International Convention for  the  Control 
and  Management  of  Ships'  Ballast  Water  and 
Sediments of 2004 (BWM Convention). 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

Similarly, target 14 of the GBF (72) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (73). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (74)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

(73) 

(74) 

for 

Summary 

Assessment – 

(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 
Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 

11 July 

2022, 

final 

of 

2025 Environmental Implementation Review – Hungary 

 
 
 
An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (75). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

In 2025, Hungary plans to launch a project to develop the 
strategic  foundations  for  planning  green  infrastructure 
based  on  ecosystem  services,  with  the  use  of  renewed 
datasets,  based  on  the  results  of  a  previous  project  (in 
2016–2022) financed by the cohesion policy. The project 
aims  to  assess  and  compare  the  status  of  ecosystems, 
examine changes, map ecosystem services and support 
green infrastructure planning. 

Hungary  20 

In 2022, Hungary received the following priority actions. 

•  Continue supporting the mapping and assessment of 
ecosystems  and  their  services,  and  ecosystem 
through  appropriate 
accounting  development, 
indicators 
integrating  ecosystem  extent, 
for 
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. 

Some progress has been made on the first priority action 
and Hungary should continue to take action to map and 
assess ecosystems. Regarding the second priority action, 
there  is  still  no  Hungarian  business  and  biodiversity 
network  member  of  the  EU  Business  &  Biodiversity 
Platform. 

2025 priority action 

• 

Support  the  development  of  the  national  business 
and biodiversity network. 

(75) 

The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 

financial institutions through workshops, seminars, reports and 
a cross-media communication strategy. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
Hungary  21 

3. Zero pollution

Clean air

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (76).  These  set  health-based  EU  air  quality 
standards (77)  and  stipulate  Member  States’  national 
emission  reduction  commitments (78)  for  several  air 
pollutants. 

The air quality in Hungary continues to give serious cause 
for  concern  in  some  parts  of  its  territory.  The  latest 
available  annual  estimates  (for  2022)  by  the  EEA (79)  for 
Hungary attribute: 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Hungary since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (83)  in  2024, 
Hungary has met its emission reduction commitments for 
2020–2029 for air pollutants  nitrogen oxides (NOx), non-
methane  volatile  organic  compounds  (NMVOC)  and 
sulphur dioxide (SO2). However, Hungary has not met its 
commitments  for  ammonia  (NH3)  or  PM2.5.  According  to 
the latest projections submitted under Article 10(2) of the 
NECD in 2023, Hungary is projected to meet its emission 
reduction commitments for 2030 onwards for SO2, but not 
for NOx, NMVOC, NH3 and PM2.5. 

Hungary  submitted  its  first  national  air  pollution  control 
programme (NAPCP) to the Commission on 18 May 2020. 
An update was due four years afterwards. Hungary needs 
to  update 
its  policies  and  measures  to  reduce  air 
emissions. 

• 

• 

• 

(76) 

(77) 

(78) 

(79) 

(80) 

8 600  deaths  each  year  (or  90 000  years  of  life  lost 
(YLL)) to fine particulate matter (PM2.5) (80), placing it 
among  the  Member  States  with  the  most  YLL  (per 
100 000 inhabitants) due to PM2.5 exposure; 
1 300  deaths  each  year  (or  13 400 YLL)  to  nitrogen 
dioxide  (NO2) (81),  placing  it  among  the  Member 
States  with  the  most  YLL  (per  100 000  inhabitants) 
due to NO2 exposure; 
2000  deaths  each  year  (or  21 400 YLL)  to  ozone (82), 
making Hungary the Member State with the second 
highest number of YLL (per 100 000 inhabitants) due 
to ozone exposure. 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(81)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(82) 

(83)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Hungary 

 
 
Figure 15:  Emission  trends  of  main  pollutants /  GDP  in 
Hungary (%), 2005–2022 

Figure 16: PM2.5 and NOx emissions by sector in Hungary 
(%), 2022 

Hungary  22 

250%

200%

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5

6,05%

7,39%

NOₓ

0,57%

47,25%

77,50%

14,13%

6,35%

0,73%

1,97%

9,86%

9,35%

18,84%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
https://www.eea.europa.eu/en/topics/in-depth/air-
25 June 
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In 2023, no exceedances above the limit values set by the 
Ambient Air Quality Directive (AAQD) (84) were registered 
in  Hungary.  However,  the  target  values  for  ozone 
concentrations have not been met in two air quality zones, 
as  well  as  the  target  value  for  benzo(a)pyrene  (BaP) 
concentration in two air quality zones (85). 

Persistent  breaches  of  air  quality  requirements  have 
severe  negative  effects  on  health  and  the  environment. 
Therefore, 
the  European  Commission  opened  an 
infringement procedure against Hungary for exceedances 
of PM10 limit values. The Court of Justice of the European 
Union  delivered  a  judgment (86)  in  2021  confirming  the 
non-compliance with the AAQD in three geographic areas 
(Budapest, Sajó Valley and Pécs). As the air quality zone of 
the  Sajó  Valley  has  been  far  from  respecting  the  limit 
values  in  recent  years,  a  procedure (87)  is  still  ongoing 
against Hungary for failing to comply with the judgment. 

(84)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 
EEA, 
Eionet 
(https://cdr.eionet.europa.eu/). 

Repository 

11.6.2008, 

Central 

L 152, 

p. 1), 

Data 

(85) 

(OJ 

(86) 

(87) 

Judgment  of  3 February  2021,  Commission  v  Hungary  (Valeurs 
limites – PM10), C-637/18, EU:C:2021:92. 
A letter of formal notice was issued under Article 260 of the Treaty 
on  the  Functioning  of  the  European  Union;  see  European 
Commission, ‘July infringement package: Key decisions’, European 
Commission 
2024, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_24_
3228. 

website, 

25 July 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
As Hungary reported compliance for the Sajó Valley after 
the judgment, the Commission is monitoring the change in 
air quality in the zones concerned. 

Infringement  procedures  have  also  been  opened  for 
Member  States  not  meeting  the  emission  reduction 
commitments 
including  procedures 
against Hungary (88) for NH3 and PM2.5. 

for  2020–2029, 

Hungary has not yet ratified Annex VI to the International 
Convention  for  the  Prevention  of  Pollution  from  Ships 
(Marpol). 

In the 2022 EIR, Hungary received three priority actions. 
The first priority action was to further reduce emissions in 
the context of the NAPCP. Hungary has not made progress 
on this, as the latest reported data show continued non-
compliance  with  the  2020–2029  emission  reduction 
commitments  for  NH3  and  PM2.5  and  also  project  non-
compliance with the emission reduction commitments for 
NOx,  NMVOC,  NH3  and  PM2.5  for  2030  onwards.  The 
second priority action was to ensure full compliance with 
EU air quality standards and maintain downward emission 
trends. Based on the latest data, Hungary has made some 
progress  in  this  regard.  Since  2019,  downward  emission 
trends  have  been  reported  for  all  main  pollutants. 
However,  exceedances  above  target  values  remain  for 
ozone and BaP, requiring further action. The third priority 
action  received  by  Hungary  was  to  ratify  the  amended 
Gothenburg Protocol, the Protocol on Heavy Metals and 
the  Persistent  Organic  Pollutants  Protocol.  These  have 
been  ratified.  Hungary  was  also  encouraged  to  ratify 
Annex VI to Marpol, which has not been achieved. Thus, 
substantial  progress  has  been  made,  but  Annex VI  to 
Marpol remains to be ratified. 

2025 priority actions 

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

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

•  Accelerate  the  ratification  of  relevant  international 

conventions and protocols. 

Hungary  23 

Industrial emissions 

- 
- 

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

protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 
prevent and manage waste; 
improve  energy  and  resource  efficiency,  including 
water; 
contribute to decarbonisation. 

- 
The  cornerstone  of  the  policy  is  the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (89). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (90). 

In Hungary, there were about 1 300 installations covered 
by  the  IED  in  2022,  almost  half  of  them  (49 %)  being 
installations  for  the  intensive  rearing  of  poultry  or  pigs. 
The  other  main  sectors  the  waste  management  sector 
(16 %)  and  the  chemical  and  metals  sectors  (about  8 % 
each). 

Figure  17  shows  the  damage  to  health  and  the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives  an  indication  of  the  emissions  ‘intensity’.  Hungary 
has the  14th highest damage  value  in the EU but comes 
9th for emissions intensity, above the EU average of EUR 
27.5/EUR 1 000 GVA. The main industrial contributors to 
emissions to air (91) are the energy sector and the mineral 
sector  for  NOx emissions, the waste management  sector 
for  dust  emissions,  the  energy  sector  for  SO2  emissions, 
and the energy and metals sectors for heavy metals. 

(88) 

European  Commission,  ‘November  infringement  package:  Key 
decisions’,  European  Commission  website,  16 November  2023, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_23_
5380. 

(89)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 
emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-

(90) 

(91) 

content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
EEA, 
Portal, 
Industrial 
European 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 
European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

Emissions 

2025 Environmental Implementation Review – Hungary 

 
 
Figure 17:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

Figure 19:  Industrial  releases  and  intensity  of  heavy 
metals to water per Member State, 2022 

Hungary  24 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 20: Relative releases to water from industry in 
Hungary (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Chemicals

Ferrous metal

Total nitrogen Total organic
carbon (TOC)

Total
phosphorus

Electricity and heat production

Other manufacturing

Other waste management

Pulp, paper and wood

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

NB:  Cd,  cadmium;  Hg, mercury;  Ni,  nickel;  Pb,  lead;  TOC,  total  organic 
carbon; total N, total nitrogen; total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Hungary  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as the 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity (expressed in GVA). Hungary has the 16th highest 
emissions of heavy metals to water and is in 15th position 
(below  the  EU  average  of 
for  emission 
0.864 kg/EUR 1 billion  GVA).  As  shown  in  Figure 20,  the 
main  industrial  contributors  to  emissions  to  water  in 
Hungary  are  the  waste  management  sector  for  heavy 
metals,  nitrogen,  phosphorus  and  total  organic  carbon, 
and the pulp and paper sector for phosphorus. 

intensity 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
(NGOs),  alongside 
non-governmental  organisations 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
revised  directive, 
that  worst 
the  provisions 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

set 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
 
The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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

In  2022,  Hungary  received  priority  actions  to  continue 
addressing  pollution  from  large  combustion  plants.  As 
mentioned  above,  the  energy  sector  is  still  the  main 
contributor  for  emissions  to  air  of  NOx,  SO2  and  heavy 
metals. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i) 

(ii) 

control major-accident hazards involving dangerous 
substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (92). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 

Hungary  25 

Retrieval  System)  for  2022–2024 (93)  and  the  report  by 
Hungary on the implementation of the Seveso III Directive 
for 2019–2022 (94). 

In 2024, of the 276 Seveso establishments in Hungary, 151 
were categorised as lower-tier establishments and 125 as 
upper-tier establishments (UTEs), based on the quantity of 
hazardous  substances  likely  to  be  present.  UTEs  are 
subject to more stringent requirements. The change in the 
in 
number  of  Seveso  establishments 
Figure 21. 

is  presented 

Figure 21: Number of Seveso establishments in Hungary, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
2014/896/EU 
Implementing  Decision 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member  States  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. 

According to Hungary, in 2022, an EEP was required for 93 
UTEs out of 110 in total. EEPs were drawn up and tested 
for all 110 UTEs. The summary is shown in Figure 22. 

(92)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(93) 

(94) 

https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024. 
As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Hungary 

 
 
 
Figure 22: Situation regarding EEPs in Hungary, 2022 

Figure 23: Share of UTEs for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

Hungary  26 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The  following  types  of  information  are  permanently 
available  for  all  Seveso  establishments  in  Hungary:  (i) 
information  for  the  public  referred  to  in  Annex V  to  the 
Seveso III  Directive,  especially  about  how  the  public 
concerned will be warned if there is a major accident; (ii) 
information about appropriate behaviour in the event of a 
major accident; and (iii) the date of the last site visit. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in Figure 23. This provision on knowledge is an important 
provision of the Seveso III Directive, as awareness by the 
public  of 
the 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

(95) 

Regulation (EU) 2024/1849 of the european parliament and of the 
council  of  13 june  2024,  amending  regulation  (EU)  2017/852  on 
mercury  as  regards  dental  amalgam  and  other  mercury-added 

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The infringement procedure launched by the Commission 
against Hungary in 2020 for failing to correctly transpose 
the Seveso III Directive into national law is still ongoing. 

2025 priority action 

• 

Ensure full and correct transposition of the Seveso III 
Directive. 

Mercury Regulation 

The  Mercury  Regulation  (95)  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 

products subject to export, import and manufacturing restrictions, 
(OJ 
https://eur-
lex.europa.eu/eli/reg/2024/1849. 

2024/1849, 

10.7.2024), 

L, 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

Based on the latest set of information analysed, Hungary 
has not  completed its noise mapping of agglomerations, 
roads, railways and airports. 

Hungary  27 

Measures  should  have  been  put  in  place  in  Hungary  to 
ensure  a  socially  and  economically  sound  phase-out, 
including an adequate reimbursement of the alternatives 
to dental amalgam through the health insurance scheme 
and the training of dental practitioners.  The Commission 
is  monitoring  whether  the  phase-out  has  taken  place 
under the terms and conditions of the regulation. Hungary 
will also need to ensure that the manufacture and export 
lamps  are  prohibited  by  the 
of  mercury-containing 
deadlines set out in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (96) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (97). 

In Hungary, environmental noise is estimated to cause at 
least  730  cases  of  ischaemic  heart  disease  annually (98) 
and  some  70 800  people  to  suffer  from  disturbed  sleep 
(99). 

(96)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(98) 

(97)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 
These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Indicators  under  the 
Industrial  Pollution  (ETC/ATNI),  Noise 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 

Since  Hungary  failed  to  report  to  the  Commission  all 
relevant 
information  on  the  strategic  noise  maps, 
including  the  noise  exposure  of  the  population,  the 
European  Commission  decided  to  open  an  infringement 
procedure against Hungary. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

2025 priority actions 

•  Complete noise mapping. 
•  Complete  and  implement  action  plans  on  noise 

management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens and the 
environment 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 (100) is the cornerstone of 
EU  water  policy  in  the  21st  century (101).  The  Water 
other  water-related 
Framework 
and 
directives (102) 
the  basis  of  sustainable  and 

Directive 
form 

European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise. 

Bilthoven, 

(99)  More information on the adverse health effects of noise pollution 
at:  

is 
https://www.eea.europa.eu/themes/human/noise/noise-2 

available 

(100)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32000L0060. 

(101)  https://environment.ec.europa.eu/topics/water_en. 
(102)  These 

include 

the  Groundwater  Directive 

(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
Directive 
lex.europa.eu/eli/dir/2008/105/oj), 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 

Floods 

the 

2025 Environmental Implementation Review – Hungary 

 
 
 
Hungary  28 

There has been no improvement in the quantitative status 
of groundwater bodies, but a slight improvement in their 
chemical status. 

Figure 24:  Ecological 
waterbodies in each RBMP cycle (%) 

status/potential  of 

surface 

Only  11.3 %  of  waterbodies  are  of  good  ecological 
status/potential.  This  is  a  slight  improvement  from  the 
second RBMPs; however, Hungary remains below the EU-
27 average (104). Efforts to improve monitoring have been 
made, one result of which is that no surface waterbody is 
of  unknown  ecological  status/potential.  No  data  were 
provided  for  the  expected  status/potential  of  surface 
waterbodies by 2027. 

Figure 25: Chemical status of surface waterbodies in each 
RBMP cycle (%) 

integrated  water  management  in  the  EU.  They  aim  to 
achieve  a  high  level  of  protection  of  water  resources, 
prevention  of  further  deterioration  and  restoration  to 
good status. These objectives are very important for the 
EU’s  competitiveness,  strategic  autonomy  and  security, 
yet  have  become  even  more  challenging  in  the  face  of 
climate change affecting our precious water resources. 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
will report its findings to the European Parliament and to 
the Council on 4th February 2025 (103). 

Hungary  has  1 072  surface  waterbodies  and  185 
groundwater bodies, all within one river basin district: the 
Hungarian  Danube  River  Basin  District.  Approximately 
55 %  of  surface  waters  are  designated  as 
‘heavily 
modified’ and about 16 % as  ‘artificial’. Heavily modified 
and  artificial  waterbodies  must  reach  good  ecological 
potential rather than good ecological status, which means 
that all measures must be taken to mitigate the adverse 
impact  of  the  sustainable  human  development  activities 
causing the waterbody to be  heavily modified / artificial, 
whilst not significantly affecting these activities. 

in 

the 

show 

change 

ecological 
Figures 24–27 
status/potential  and  chemical  status  of  surface  waters, 
and the quantitative and chemical status of groundwater 
in 2010, 2015 and 2021. It follows from the assessment of 
the  third  RBMPs  that  there  has  been  only  a  minor 
improvement in the ecological status/potential of surface 
waterbodies,  and  no  improvement  in  their  chemical 
status,  since  the  second  RBMPs  (covering  2015–2021). 

the 

Treatment 

Drinking  Water 

(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
(https://eur-
new 
the 
lex.europa.eu/legal-
Nitrates 
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=celex%3A31991L0676), the Marine Strategy 
(https://eur-lex.europa.eu/legal-
Directive 
Framework 
content/en/TXT/?uri=CELEX%3A32008L0056) 
IED 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

Directive 

and 

the 

the 

The  percentage  of  surface  waterbodies  with  good 
chemical  status  has  not  improved  since  the  second 
RBMPs, remaining at 46 %. Efforts to improve monitoring 

(103)  Commission Staff Working Document – EU overview, Third river 
basin management plans, second flood hazard and risk maps and 
second  flood  risk  management  plans,  Member  State:  Hungary, 
accompanying the document report from the Commission to the 
Council  and the  European  Parliament  on the  implementation  of 
the  water  framework  directive  (2000/60/ec)  and  the  floods 
directive  (2007/60/ec),  SWD(2025)  13  final  of  4  February  2025, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2025%3A29%3AFIN&qid=173874
6144581. 

(104)  https://water.europa.eu/freshwater/europe-freshwater/water-

framework-directive/ecological-status-of-surface-
water/ecological-status-by-country. 

2025 Environmental Implementation Review – Hungary 

0 20 40 60  0 100 1st2nd3rdS B chemical status for HUGood ailing to achieve goodUnknown 
 
 
 
 
have  been  made,  one  result  of  which  is  that  no  surface 
waterbody is of unknown chemical status. No data were 
provided for the expected status of surface waterbodies 
by 2027. 

Failure to achieve good chemical status is mostly due to a 
small  number  of  persistent,  bioaccumulative  and  toxic 
substances  (polybrominated  diphenyl  ethers,  mercury, 
polyaromatic  hydrocarbons,  perfluorooctane  sulfonate 
and  its  derivatives,  heptachlor  and  heptachlor  epoxide) 
and  substances  that  are  not  persistent,  bioaccumulative 
and toxic (arsenic, cadmium, lead, nickel and hydrocarbon 
fluoranthene). 

Figure 26: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

The  percentage  of  groundwater  bodies  with  good 
quantitative status in Hungary has not improved since the 
second  RBMPs,  remaining  at  80 %,  below  the  EU 
average (105). No information was reported on the status 
expectations  for  2027.  However,  17.2 %  of  groundwater 
bodies  with  good  quantitative  status  are  identified  as 
being at risk of deteriorating to poor status. 

There  are  no  reported  causes  for  the  failure  to  achieve 
good quantitative status. 

Figure 27: Chemical status of groundwater bodies in each 
RBMP cycle (%) 

Hungary  29 

There  has  been  a  slight  increase  in  the  percentage  of 
groundwater bodies with good chemical status since the 
second  RBMPs,  with  the  value  rising  to  80.5 %.  No 
information was reported  on the status expectations for 
2027. However, 10.8 % of groundwater bodies with good 
chemical  status  are 
identified  as  being  at  risk  of 
deteriorating to poor status. 

The main pollutants causing groundwater bodies to fail to 
achieve good chemical status are nitrates and sulphates. 
The main pollutants showing sustained upward trends in 
groundwater  bodies  are  nitrates,  ammonium  and 
sulphates. 

Until the end of 2027, Member States can still apply time-
related  exemptions,  subject  to  providing  evidence  of 
compliance  with  the  strict  criteria  set  out  in  the  Water 
Framework  Directive.  After  2027,  the  possibilities  for 
applying exemptions will be much more limited. 

The  2022  EIR  identified  the  following  priority  action: 
assess new physical modifications to waterbodies in line 
with Article 4(7) of the Water Framework Directive. These 
assessments  were  to  consider  alternative  options  and 
propose suitable mitigation measures. Some progress has 
been  made  with  regard  to  this  priority  action,  Hungary 
must continue its efforts to realise it. 

A noteworthy point of good practice is that the reported 
significant pressures are well covered by the key types of 
operational measures. Hungary performed a prioritisation 
of  the  measures  prior  to  their  selection,  favouring 
measures  targeting  the  prevention  of  deterioration  of 
status,  based  on  their  relevance  and  effectiveness. 
Regrettably,  Hungary  did  not  provide  quantitative  gap 
indicators  of  the  expected  gap  in  assessments  of  good 
status for 2027, although all pressures have been clearly 
linked to the measures. Hungary makes a considerable use 
of exemptions (106), thus it is important that it continues 
the efforts to transparently justify them and ensures that 
all  measures  necessary  for  achieving  good  status  or 
potential by the end of 2027 are identified and initiated 
during  this  cycle  to  avoid  unjustified  exemptions  under 
Article 4(4) and (5) of the WFD. 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted. 

(105)  https://water.europa.eu/freshwater/europe-freshwater/water-
framework-directive/groundwater-quantitative-status. 

(106)  Commission Staff Working Document  – EU overview, Third river 
basin management plans, second flood hazard and risk maps and 
second  flood  risk  management  plans,  Member  State:  Hungary, 
accompanying the document report from the Commission to the 

Council  and the  European  Parliament  on the  implementation  of 
the  water  framework  directive  (2000/60/ec)  and  the  floods 
directive  (2007/60/ec),  SWD(2025)  13  final  of  4  February  2025, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2025%3A29%3AFIN&qid=173874
6144581. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
• 

• 

flows, 
Improve  river  continuity  and  ecological 
boosting efforts on nature-based solutions to reduce 
hydromorphological pressures. 
Ensure  periodic  reviews  of  permits  for  discharges, 
including 
abstractions  and  other  water  uses, 
hydropower pressures. 

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

and saline discharges. 

•  Better justify exemptions to the achievement of good 

• 

status. 
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems. 

•  Develop  more  robust  programmes  of  measures, 
tackle  obstacles  identified  in  the  implementation  of 
measures  and  ensure  adequate 
for 
implementation, including through better use of cost 
recovery and the polluter-pays principle. 

financing 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and risk maps and the preliminary flood risk assessments 
drawn up during the second cycle (2016–2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

Hungary’s  second  FRMP  sets  out  its  main  objective  and 
identifies additional principles and objectives for flood risk 
management.  Hungary  proposed  49  new  potential 
projects,  providing  information  on  their  prioritisation, 
based  on  the  cost–benefit  analysis,  the  method  used  to 
select  them  and  their  costs.  Estimates  of  the  costs  are 
provided  for  many  but  not  all  measures.  The  FRMP 
considers nature-based solutions but provides few details 
on nature conservation in its measures. Reference is made 
to  climate  change  impacts  and  to  adaptation.  Hungary 
reported  half  of  its  measures  as  completed,  a  major 
increase between the first and second FRMPs. 

2025 priority actions 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding. 

(107)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(108)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 

(109)  OJ L, 

Hungary  30 

•  Consider future climate scenarios in the FRMPs. 
•  Better explain the choice and implementation of flood 
prevention  and  protection  measures  (prioritisation, 
monitoring, costs of measures). 
Improve  public 
involvement. 

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (107), (ii) a methodology for measuring microplastics 
in drinking water (108) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (109). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019. 

the  Commission 

In  summary,  the  compliance  for  all  parameter  groups  in 
Hungary  was  at  least  97.77 %  in  2017,  98.00 %  in  2018, 
and  97.87 %  in  2019.  Despite  this  rate,  the  quality  of 
drinking water (supplied by large water providers) remains 
a serious source of concern in specific areas of Hungary. In 
2016, 
infringement 
procedure  against  Hungary  for  failing  to  meet  EU 
parametric  values  for  arsenic,  boron  and  fluoride  in  the 
drinking water of several municipalities. While the number 
of reported non-compliant zones has decreased, Hungary 
is  still  far  from  achieving  compliance  in  the  remaining 
settlements. 

launched  an 

From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 
per- and polyfluoroalkyl substance monitoring data in the 
future. 

2024/369, 

OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 

2025 Environmental Implementation Review – Hungary 

 
 
Hungary  31 

2025 priority action 

• 

Take  action  to  ensure  full  compliance  with  the 
Drinking Water Directive. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 28  shows  that  in  2023  Hungary  was  among  the 
Member  States  with  the  lowest  percentage  of  bathing 
waters  of  excellent  quality:  out  of  the  283  Hungarian 
bathing  waters,  only  177  (62.5 %)  were  of  excellent 
quality,  62 (21.9 %) bathing waters were of good quality 
and 10 (3.5 %) bathing waters were of sufficient quality. At 
least  6 bathing waters (2.1 %) were found  to be  of poor 
quality and 28 bathing waters (9.9 %) were not classified. 

biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 
implementation  of  the  Nitrates 
The  report  on  the 
Directive covering 2020–2023 will be available in 2025. 

The analysis of Hungary’s RBMPs has identified nutrients 
from  agriculture  as  an 
important  pressure  on 
groundwater /  surface  waters  that  is  affecting  these 
waters’ good status and as one of the main factors in not 
meeting the WFD objectives. 

In  2022,  Hungary  received  a  priority  action  on  tackling 
nutrient  pollution,  especially  nitrates  from  agriculture, 
through  the  implementation  of  the  Nitrates  Directive. 
Since  the  report  on  the  implementation  of  the  Nitrates 
Directive  covering  2020–2023  will  become  available  in 
2025, the 2022 EIR priority action cannot be assessed and 
is repeated. 

2025 priority action 

Figure 28:  Bathing  water  quality  per  Member  State, 
Albania and Switzerland (%), 2023 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
agriculture,  through  the 
implementation  of  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the  effects of untreated urban waste water.  It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Overall, in Hungary, the compliance rate was 59 % in 2020. 
A  total  of  151  agglomerations,  generating  5 164 127 
population  equivalent  of  urban  waste  water,  did  not 
comply with the requirements of the directive. 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (110)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the Nitrates Directive (111), dating back to 2021, warns that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 

(110)  https://eur-lex.europa.eu/legal-

(111)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

2025 Environmental Implementation Review – Hungary 

 
 
 
Hungary  32 

Figure 29:  Proportion  of  urban  waste  water  that  fully 
complies with the UWWTD (%), 2020 

groups.  Hungary  has  until  31 July  2027  to  transpose  the 
new directive into its national legal system. 

With  regard  to  the  implementation  of  the  2022  priority 
action  related  to  the  implementation  of  the  UWWTD, 
there has been limited progress, so it is proposed again. 

2025 priority action 

• 

the  necessary  measures 

full 
Take 
implementation  of  the  current  UWWTD,  taking  into 
account the new requirements of the recast directive. 

to  ensure 

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 strategy for 
sustainability  towards  a  toxic-free  environment (114), 
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. 

The  EU’s  chemicals  legislation (115)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (116)  on  the 
implementation 
these 
regulations (117).  It  is  apparent  from  the  Commission’s 

enforcement 

and 

of 

p. 1), 

chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(116)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(117) 

Source:  European  Commission,  12th  technical  assessment  of  UWWTD 
2024 
Publications  Office 
implementation 
https://op.europa.eu/en/publication-detail/-/publication/4c97f846-
44b2-11ef-865a-01aa75ed71a1/language-en. 

EU, 

the 

of 

- 

The Commission decided to refer Hungary to the Court of 
in  June  2021.  On 
Justice  of  the  European  Union 
7 December  2023,  Hungary  was  condemned  by  the 
court (112) for failing to comply with the  requirements of 
the  UWWTD.  It  is  essential  that  Hungary  takes  the 
necessary measures to comply with the UWWTD. 

This  is  all  the  more  important  as  the  directive  has  been 
revised (113) in order to, among other things, strengthen 
existing  treatment  standards and  establish  an  additional 
treatment of micropollutants in urban waste water. Other 
new  requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  EPR  system  to 
ensure sustainable financing of micropollutant treatment 
by  the  most  polluting  industries  and  ensuring  access  to 
sanitation,  especially  for  vulnerable  and  marginalised 

(112) 

Judgment  of  7 December  2023,  Commission  v  Hungary  (Collecte 
des  eaux  urbaines 
résiduaires),  C-587/22,  EU:C:2023:963 
(https://curia.europa.eu/juris/liste.jsf?num=C-587/22). 

(113)   Directive (EU) 2024/3019 of the European Parliament and of the 
Council  of  27  November  2024  concerning  urban  wastewater 
treatment (recast).  

(114)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(115)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 

2025 Environmental Implementation Review – Hungary 

 
 
 
in  the 
report  that  there  are  still  many  disparities 
implementation  of  the  REACH  and  CLP  Regulations, 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies 
and (ii) more non-compliant products are being placed on 
the EU market. 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (118) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (119). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (120).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (121).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Hungary has devised and fully implemented enforcement 
strategies for both the REACH and CLP Regulation (122). 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 

Hungary  33 

absence  of  new  country-specific  data  on  enforcement 
since 2022. 

inspectors 

In  2022,  160 
(for  all  chemicals-related 
regulations and other areas) were assigned to REACH and 
CLP Regulation enforcement in Hungary (123). 

In  2020,  Hungary  participated  in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (124).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

Figure 30: Compliance of imported products – results of 
the REF-8 project (%) 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliances.  Therefore,  the  non-compliance  rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 

the 

European 

(118)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(119)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

(120)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(121)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

(122)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(123)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 74, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(124)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
p. 20, 
and 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Hungary 

 
 
 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

Figure 31:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

Hungary  34 

the  REF-8  coordinated 
in 
Hungary’s  participation 
enforcement project was above the EU average. However, 
the  EU  average  is  rather  low  because  of  the  lack  of 
involvement  of  certain  large  Member  States.  In  this 
project  and  others  conducted  with  the  help  of  the 
European Chemicals Agency in the past few years, online 
sales  have  been  proved  to  correspond  consistently  to 
higher non-compliance rates in checks performed across 
the EU, in particular when related to imported products. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
the 
European  Chemicals  Agency, 
coordinated  enforcement  projects,  called  REF 
projects. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislation. 

including 

in 

• 

• 

2025 Environmental Implementation Review – Hungary 

 
 
 
Hungary  35 

4. Climate action

Forestry (126). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The key strategic document at country level is the National 
Energy and Climate Plan (NECP) (127). Hungary submitted 
its final plan in October 2024 after the deadline set by the 
Regulation  on  the  Governance  of  the  Energy  Union  and 
Climate  Action  (128).  The  European  Commission  assessed 
the  updated  plan  and  the  extent  to  which  Hungary  has 
followed the recommendations for the draft version. The 
findings from the assessment are: 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease by 25% in 2030 compared to 2005, which is 
above its target of 19%. 

•  Hungary is in line with its Land Use, Land-Used Change 

and Forestry (LULUCF)  target.  

•  Hungary has a gap towards the target for the share of 

• 

renewable energy. 
There  are  still  gaps  in  energy  efficiency  targets  that 
must be closed. 

To minimise the impacts of climate policies on vulnerable 
people  and  sectors,  Hungary  is  using  the  Just  Transition 
Fund,  Modernisation  Fund  and  will  use  Social  Climate 
Fund from 2026 (for more information, see Chapter 5 on 
Financing). 

Figure 32: Total GHG  emissions (excluding international 
aviation) (%), 1990–2022 

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals  set  out  in  the  European  Green 
law,  and  the  European 
in 
Deal  have  been  agreed 
Commission  recommended  a  new  intermediate  climate 
target of a 90 % reduction in emissions by 2040. In 2024, 
the  Member  States  submitted  updated  national  energy 
and climate plans for 2021–2030, reflecting the increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 

its  Member  States  need 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running  total  in  2022  of  – 32.5 % (125).  However,  the  EU 
their 
and 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  net  GHG 
emissions of Hungary decreased by 42%, making it one of 
the countries with an above-average decrease. 

to  step  up 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes: (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with a dedicated Social Climate Fund to 
help  citizens  during  the  transition;  (ii)  increasing  targets 
under  the  Effort  Sharing  Regulation;  and  (iii)  a  revised 
for  Land  Use,  Land  Use  Change  and 
Regulation 

(125)  EU  net  domestic  emissions,  including  the  land  use,  land-use 
change and forestry (LULUCF) sector and excluding international 
aviation. 

(126)  A  full  overview  of  the  Fit  for  55  package  is  available  at 
https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

(127)  More  information  about  NECP  is  on  the  dedicated  website 
https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en. 

(128)  Article  14  of  Regulation  2018/1999  on  the  Governance  of  the 

Energy Union and Climate Action. 

2025 Environmental Implementation Review – Hungary 

 
 
 
Hungary  36 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around  40% of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (129) 
and, from 2024, maritime transport also. 

The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the  right  to  emit  1 t  of  CO2  eq.  (carbon  dioxide 
equivalent)),  in  auctions  or  through  trading  allowances 
with  others.  The  cap  is  reduced  annually  to  ensure  that 
overall  emissions  in  the  sectors  covered  decrease  over 
time. 

The emissions under the ETS decreased by 48% from 2005 
to 2023. 

In  2023,  half  of  GHG  emissions  from  Hungary’s  ETS 
installations came from power generation, a bit below the 
EU average, 57 %. Of the total emissions from all industry 
sectors, the chemical industry emitted almost  one third, 
cement  and  lime  production  about  15 %,  the  metals 
industry  7 %,  and  other  industries  48 %.  Between  2019 
and 2023, the power sector registered a higher emissions 
reduction  (35 %)  than  the 
industry  sectors  (28 %). 
Between 2013 and 2023, GHG emissions declined by 45 % 
in  power  generation  but  only  by  5 %  in  the  industry 
sectors, driven by the metals industry. This resulted  in a 
combined GHG reduction of 30 % in this period. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (130).  Member  States  should 
have  notified  full  transposition  the  provisions  of  the 
revised  EU  ETS  Directive  related  to  the  new  ETS2  into 
national 
law  by  30 June  2024.  Hungary  did  not 
communicate  full  transposition  into  national  law  by  this 
deadline.  The  Commission 
therefore  opened  an 
infringement procedure against Hungary on 25 July 2024, 
by  sending  a  letter  of  formal  notice  for  failing  to  fully 
transpose the provisions into national law. 

Hungary  had  two  months  to  respond  and  address  the 
shortcomings raised by the Commission. In the absence of 
a  satisfactory  response,  the  Commission  may  decide  to 
issue a reasoned opinion. 

The  Commission  also  opened  infringement  procedures 
against Hungary on 25 January 2024, by sending a letter of 
formal  notice  for  failing  to  fully  transpose  previous 
revisions of ETS Directive (131) into national law. Hungary 
has  since  notified  partial  transposition  of  either  one  or 
both  revisions  to  the  Commission.  In  the  absence  of  a 
complete  transposition,  the  Commission  may  decide  to 
issue a reasoned opinion. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation  (ESR) (132)  covers  GHG 
(excluding  CO₂ 
emissions 
emissions  from  aviation),  buildings,  agriculture,  small 
industry, and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. Hungary’s target is – 18.7 %. 

In  addition  to  the  2030  targets,  Member  States  have 
annual GHG emissions limits (annual emission allocations), 
reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations 
in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  Hungary  is  on  track  to  achieve  its  2030  ESR 
target. 

Projected  emission  reduction  is  6.3  percentage  points 
above the 2030 target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 34 % of all effort sharing emissions in 
2022.  The  sector  is  a  very  high  concern  for  Hungary 
because  emissions  have  increased  by  23 %  since  2015. 
Hungary  has  still  much  to  do  to  curb  this  rise.  In  2022, 

(129)  Flights between the EU Member States including departing flights 
to Norway, Iceland, Switzerland, and the United Kingdom. 

(130)  Directive 

(EU)  2023/959  amending  Directive  2003/87/EC 
establishing  a  system  for  greenhouse  gas  emission  allowance 
trading within the Union and Decision (EU) 2015/1814 concerning 
the establishment and operation of a market stability reserve for 
the  Union  greenhouse  gas  emission  trading  system,  OJ  L  130, 
16.5.2023, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG. 

(131)  Directive 

(EU)  2023/959  amending  Directive  2003/87/EC 
establishing  a  system  for  greenhouse  gas  emission  allowance 
trading within the Union and Decision (EU) 2015/1814 concerning 
the establishment and operation of a market stability reserve for 

the  Union  greenhouse  gas  emission  trading  system,  OJ  L  130, 
16.5.2023, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG; 
and  Directive  (EU)  2023/958  amending  Directive  2003/87/EC  as 
regards  aviation’s  contribution  to  the  Union’s  economy-wide 
emission reduction target and the appropriate implementation of 
a global market-based measure, OJ L 130, 16.5.2023, https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023L0958. 

(132)  Regulation  (EU)  2018/842  on  binding  annual  greenhouse  gas 
emission  reductions  by  Member  States  from  2021  to  2030 
contributing  to  climate  action  to  meet  commitments  under  the 
Paris Agreement and amending Regulation (EU) No 525/2013, OJ 
L 156, 19.6.2018, https://eur-lex.europa.eu/eli/reg/2018/842. 

2025 Environmental Implementation Review – Hungary 

 
 
electric  vehicles  represented  only  0.8 %  of  its  passenger 
car fleet  (EU average is 1.2 %). In 2023, Hungary’s 3 250 
publicly accessible charging points provided one charging 
point  for  every  nine  e-vehicles,  compared  to  the  EU 
average of 1:10. Buses and coaches and rail accounted for 
20 %  of  passenger  transport,  with  passenger  cars 
accounting for only 78 % (EU average: 85 %). Rail accounts 
for  a  significant  25 %  of  freight  transport,  while  66 %  of 
is  transported  by  road  (EU  average:  75 %). 
freight 
However, only 41 % of Hungary’s rail network is electrified 
(EU average: 56 %). 

Buildings accounted for 26 % of all effort sharing emissions 
in  2022.  Emissions  of  the  sector  are  stagnating  with  no 
significant  development 
since  2015.  The  energy 
performance  of  buildings  is  very  low  and  regulated 
residential  energy  prices  provide 
incentive  for 
renovations.  Final  energy  consumption  in  residential  did 
not decrease between 2018 and 2022, while the national 
long-term  renovation  strategy  plans  a  reduction 
in 
building  energy  consumption  by  20 %  during  the  same 
period. 

little 

Figure 33: Effort-sharing emissions by sector (%), 2022 

Hungary  37 

Hungary‘s target in 2030 is to enhance carbon removals by 
additional  – 0.9  Mt  (million  metric  tonnes)  of  CO2 
equivalent compared to the yearly average of the period 
2016–2018. The latest available projections show a gap to 
target  of  0.1  Mt  of  CO2  equivalent  in  2030.  Therefore, 
Hungary needs to apply additional measures to reach its 
2030 target. 

Adaptation to climate change 

Halting all GHG emissions would still not prevent climate 
impacts that are already occurring. Therefore, adaptation 
to  climate  change  is  also  a  key  component  of  climate 
policy. 

Hungary has no regions identified as a hotspots of climate 
risks most affected by climate change (133). 

Climate  change  poses  challenges  to  Hungary’s  forests, 
soils,  water-related  activities  (due  to  both  droughts  and 
floods), and other areas. Threats include the impairment 
of  forests’  carbon  removal  capacity  and  declining 
agricultural productivity. Water management in changing 
climatic  conditions  requires  particular  attention  due  to 
risks of electricity disruption as floods, heat and drought 
impact the energy production. 

Hungary adopted its national climate law in 2020. National 
adaptation strategy was adopted in 2007 and updated in 
2018.  In  2020,  regional  adaptation  plans  were  adopted. 
its 
faces 
Nevertheless,  Hungary 
governance  and  coordination  structures  that  hamper 
effective  planning,  climate  adaptation  solutions  and 
investment,  the  monitoring,  evaluation  and  review  of 
policies,  coordination  between  different  sectors  of 
government,  and  the  preparation  and  updating  of  sub-
national policies. 

shortcomings 

in 

Land use, land-use change and forestry 

The LULUCF sector plays a significant role in achieving the 
EU’s climate neutrality goal. In the EU, this sector absorbs 
more GHGs than it emits, removing significant volumes of 
carbon  from  the  atmosphere.  Thus,  it  is  the  only  sector 
with negative emissions. 

The European Commission identified four priority actions 
regarding climate action in the 2022 edition of the review. 
Hungary has not progressed in improving energy efficiency 
and  improving  sustainable  transport.  The  progress  in 
deployment  of  renewables  is  limited.  Overall  share  of 
renewables remains way below the EU average and below 
the share in 2012 and 2013. There is a hostile regulatory 
environment for wind energy. Since 2021 under the Green 
District  Heating  Programme,  biomass  production 
is 
promoted for heating and cooling purposes. According to 
the  measure,  this  biomass  must  meet  the  sustainability 
criteria. 

2025 priority action 

Hungary  has  seen  modest  improvements  in  its  LULUCF 
sector carbon removals since 2018. 

• 

Implementing  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the  Effort 

(133)  European  Climate  Risk  Assessment  (EUCRA).  2024.  Available  at 

https://climate-adapt.eea.europa.eu/en/eu-adaptation-
policy/key-eu-actions/european-climate-risk-assessment. 

2025 Environmental Implementation Review – Hungary 

 
 
 
Sharing Regulation (ESR) and the Land Use and Land-
Use Change and Forestry (LULUCF) Regulation. More 
detailed priority actions are set out in the assessment 

of the final National Energy and Climate Plan (NECP) 
(134). 

Hungary  38 

(134)  European Commission, National energy and climate plans. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
Hungary  39 

Part II: Enabling framework – implementation tools

5. Financing

The  EU  budget  supports  climate  investment  in  Hungary 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022, Hungary’s revenues from auctioning reached 
EUR 979 million in total, with 60 % of it spent on climate 
and energy, corresponding to EUR 538 million. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 5.8 billion per year in 
Hungary. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 3.4 billion per year; thus, there is a 
gap of EUR 2.4 billion per year. 

Of  the  environmental 
investment  gap,  EUR 1 billion 
concerns biodiversity and ecosystems, EUR 0.6 billion the 
water objective, EUR 0.5 billion pollution prevention and 
control and EUR 0.3 billion circular economy. 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR  657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
recovery and resilience facility (RRF) EUR 275.7 billion, and 
CAP EUR 145.9 billion (135). 

In  Hungary,  the  EU  cohesion  policy  (considering  EU 
contribution amounts) provides EUR 7.2 billion for climate 
action in 2021–2027 (with around two thirds of this via the 

ERDF),  with  a  further  EUR 22 million  from  the  European 
Maritime, Fisheries and Aquaculture Fund (136). 

The  RFF  contributes  to  climate  finance  in  Hungary  with 
EUR 7 billion  up  to  2026,  representing  66.9 %  of  the 
recovery and resilience plan (RRP) (137). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 1.5 billion was assigned to 
Hungary in the reference period (138). 

National  financing, 
system revenues 

including  EU  emissions  trading 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets,  amounted  to  EUR  226 million  in  2020,  EUR 
288 million  in  2021  and  EUR  465 million  in  2022  in 
Hungary,  totalling  EUR  979 million  in  the  three-year 
period.  In  Hungary,  50 %  of  the  revenues  are  spent  on 
climate  and  energy  (any  revenues  not  spent  are  carried 
over  to  future  years)  and  the  remainder  goes  to  the 
national  general  budget.  Amounts  included  in  the  latter 
can  be  spent  on  climate  change  and  energy  but  are  not 
covered here. 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level (139). 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (140). 

therefore, 

and, 

(135)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96, 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(136)  See 

the 

Cohesion 

Open 

Data 

Platform,  

(https://cohesiondata.ec.europa.eu/). 

(137)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
Scoreboard,    (https://ec.europa.eu/economy_finance/recovery-
and-resilience-scoreboard/index.html). 

(138)  A 

list  of 

is  provided  by 
(https://www.eib.org/en/projects/loans/index.htm). 

financed  projects 

the  EIB,  

(139)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(140)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

 Environmental Implementation Review 2022 – Hungary 

 
 
Hungary  40 

Other MFF sources 

RRF (d) (2021–2026) 

258.3 (c) 

3 193.9 

NB: The table and figures of this report reflect the original EU Budget of 
EUR 21.7 billion, as adopted in December 2022. However, an amount of 
EUR 1.04 billion was lost to Hungary by the end of 2024, as a result of 
Article  2(1)  of  Council  Implementing  Decision  (EU)  2022/2506  of  15 
December  2022  (142)  and  pursuant  to  Article  7(3)  of Regulation  (EU, 
Euratom)  2020/2092  on  a  general  regime  of  conditionality  for  the 
protection of the Union budget (143), in the absence of remedies taken by 
Hungary.  As of 1 January 2025, the total EU budget effectively allocated 
is EUR 20.7 billion. 

Sources: 

(a) 

(b) 

(c) 

(d) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I.  Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
information: 
its  publication  date.  Source  and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 

instrument  for  the 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RR   dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Hungary,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the  financial 
instrument  for  the  environment  (LIFE) 
programme  (EUR  5.4 billion)  (144),  Horizon  Europe  (EUR 

Environmental financing and investments 

This  section  describes  Hungary’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (141). 

The environment overall 

Investment needs 

investment  needs  to  be 
The  overall  environmental 
sufficient to enable Hungary to meet its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be almost EUR 5.8 billion per year (in 2022 
prices). 

The  estimated  requirement  is  balanced  across  the  four 
environmental  objectives,  reaching  EUR 1.6 billion  per 
year for circular economy, EUR 1.5 billion per year for both 
biodiversity and ecosystems and pollution prevention and 
control,  and  EUR 1.3 billion  per  year  for  the  water 
objective (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 3.4 billion  in  Hungary  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 7.3 billion for Hungary in total, during 2021–2027 (or 
around EUR 1 billion per year). 

Table 1: Key environmental allocation from EU funds to 
Hungary (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

European  Maritime,  Fisheries  and 
Aquaculture Fund 

Allocations 

4 940.8 (a) 
3 758.2 
1 095.7 
86.9  

2 046.8 (b) 
987.1 
1 059.7 

22.0 

(141)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gaps  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(142)  https://eur-lex.europa.eu/legal-

content/EN/ALL/?uri=CELEX:32022D2506 
(143)  https://eur-lex.europa.eu/eli/reg/2020/2092/oj 
(144)  https://cinea.ec.europa.eu/programmes/life_en 

2025 Environmental Implementation Review – Hungary 

 
 
 
95.5 billion)  (145),  the  Connecting  Europe  Facility  (EUR 
33.7 billion) (146) and funds that can be mobilised through 
the InvestEU programme (147). 

Hungary’s  RRP  supports  climate  objectives  through 
funding  of  EUR  6.98 billion  (66.9 %  of  total),  with  an 
additional  EUR 0.04 billion  (0.4 %  of  total)  for  the 
environment. 

EIB  provided 

EUR 627.8 million 

in 
around 
The 
environment-related  financial  contributions  to  Hungary 
from  2021  to  mid  2024,  most  of  which,  EUR 560 million 
(89 %),  was  in  the  area  of  sustainable  energy,  transport 
and  industrial  projects,  which  provides  significant  co-
benefits  to  reducing  air  pollution,  environmental  noise 
and other pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Hungary, the 
total national environmental protection expenditure was 
EUR 2.1 billion  both  in  2020  and  in  2021,  representing 
around 1.4–1.5 % of the GDP. 

Of  the  total  environmental  expenditure,  the  national 
(investment)  on  environmental 
capital  expenditure 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Hungary,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 884 million in 2020, rising to EUR 818 million in 2021, 
representing around 0.5–0.6 % of GDP. 

investment 

protection 

protection 

investment 

Splitting by institutional sector, 46 % of Hungary’s national 
(capital 
environmental 
expenditure) comes from the general government budget, 
with 34 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  20 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
environmental  protection 
from 
specialist  private-sector 
governments,  40 % 
producers and 22 % from the general business sector (148). 

investment  comes 

from 

Hungary’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 3.4 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  44 %,  with  around 

Hungary  41 

56 % national financing. The total public financing (EU plus 
national public) represents 70 % of the total. 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 2.4 billion 
per  year  in  Hungary,  representing  around  1.43 %  of  the 
national  GDP,  being  significantly  higher  than  the  EU 
average (0.77 %). 

Figure 34: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of Hungary’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
Hungary per year, 2021–2027 

Environmental 
objective 

Investment gap per year 

Million EUR 
(2022 
prices) 

% of 
total 

% of 
GDP 

Pollution prevention 
and control 

Circular economy and 
waste 

512 

316 

21.0 

0.30 

13.0 

0.19 

(145)  European  Commission,  Horizon  Europe,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

(146)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % will be made available, on a competitive basis, to all Member 
States  eligible  for  the  Cohesion  Fund.  The  remaining  70 %  will 
respect the national envelopes until 31 December 2023. 

(147)  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  the  investment  of  financial  partners such as  the  EIB  group 
and others. 

(148)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea, 
https://ec.europa.eu/eurostat/cache/metadata/en/env_ac_epea
_esms.htm. 

2025 Environmental Implementation Review – Hungary 

 
 
 
610 

25.0 

0.36 

The gap 

Hungary  42 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Total 

1 000 

41.0 

0.59 

2 438 

100.0 

1.44 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Hungary’s investment 
needs  are  estimated  to  reach  EUR 1.5 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1.2 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
reach 
needs 
EUR 260 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (149).  Industrial  site  remediation 
year. 
requires  an  estimated  EUR 31 million  per 
Microplastics pollution and the chemicals strategy require 
around EUR 20 million per year (each) (150). 

environmental 

reduce 

noise 

to 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 946 million per year in Hungary in 2021–2027. Most 
of  the  financing  concerns  clean  air  (EUR 818 million  per 
year).  Protection  from  environmental  noise  receives 
around  EUR 352 million  per  year,  with  a 
further 
EUR 19 million for site remediation. 

In Hungary, the EU MFF provides an estimated 38.7 % of 
the clean air financing (mostly via cohesion policy), with a 
further 41.4 % from the RRF, adding up to around 80 % of 
the  total.  EIB  financing  contributes  7.9 %  and  national 
sources reach 11.9 % (151). 

(149)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf. 

Environmental 

Noise 

2023 

(150)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(151)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Hungary 
needs  to  provide  an  additional  EUR 512 million  per  year 
(0.30 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

implementation  of 

the  NECP  with 

According to the latest (2023) NAPCP review report (152), 
Hungary  did  not  comply  with  ammonia  reduction 
requirements in 2020 and 2021 (or with those for PM2.5), 
while  it  is  not  at  risk  of  non-compliance  with  ammonia 
concerning 
reduction 
the  NECD’s  2030  emission 
commitments, based on the  policies and measures in its 
NAPCP  that  take  into  account  climate,  energy  and  CAP 
plans and financing baselines. 

Circular economy and waste 

Investment needs 

Hungary’s  investment  needs  in  circular  economy  and 
waste  reach  EUR 1.6 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 1.3 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 0.3 billion  necessary 
for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (153). 

Current investments 

Circular economy investments across the economy reach 
around EUR 1.1 billion per year in Hungary in 2021-2027, 
with  a  further  EUR 256 million  provided  for  waste 
management that does not constitute circular economy. 

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(152)  European Commission, ‘National air pollution control programmes 
website, 
European 

Commission 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

(153)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

2025 Environmental Implementation Review – Hungary 

 
 
Around 2.7 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 2.7 % from 
the  RRF,  adding  up  to  5.4 %  of  the  total.  EIB  loans 
identified  in  support  of  circularity  and  waste  represent 
0.6 %  of  the  total.  The  share  of  national  sources  is 
absolutely  overwhelming,  reaching  94 %  of  the  total 
financing (154). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Hungary  needs  to  increase 
investments  by  an  estimated 
circular  economy 
additional 
EUR 254 million 
EUR 62 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
EUR 316 million  per  year, 
representing  0.19 %  of 
Hungary’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 66 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 187 million constitutes further investment need 
to unlock Hungary’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 1.3 billion (in 2022 prices) in Hungary. This comprises 
investment needs both for the water industry and for the 
protection and the management of water. The largest part 
of  the  total  annual  need,  EUR 680 million,  relates  to  the 
management  of  waste  water  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 202 million  is  necessary  for  drinking-water-related 
investments  and  around  EUR 384 million 
the 
protection and management of water (155). 

for 

(154)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(155)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
2  May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(156)  This may decrease in reality (due to a loss of EUR 1 billion of EU 
funding by Hungary by the end of 2024) by around EUR 40 million 
per year, as the average share of environmental investment within 
the amounts from ERDF, CF and JTF to Hungary is around 30%.  

Hungary  43 

Current investments 

Water investments in Hungary are estimated to be around 
EUR 659 million  per  year  (in  2022  prices)  in  2021–2027 
(156).  Of  this,  EUR 367 million  supports  wastewater 
management, EUR 162 million drinking water and around 
the  Water 
EUR 129 million 
Framework  Directive 
and 
protection). 

the  other  aspects  of 

(water  management 

Of the total financing,  22.9 % is provided by the EU MFF 
(mostly  through  cohesion  policy),  with  a  further  0.2 % 
from the RRF, reaching 23.1 % combined. EIB financing is 
around  0.1 %  of  the  total,  while  the  bulk  of  financing 
comes from national sources (77 %) (157). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Hungary’s water investment gap reaches EUR 610 million 
per year (0.36 % of GDP), with over half related to waste 
water  (313 million  per  year).  Drinking  water  measures 
require  an  additional  EUR 40 million  per  year  and  the 
other aspects of the Water Framework Directive around 
EUR 255 million  per  year  over  the  existing  levels  of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 1.5 billion per year (in 2022 prices) in 
Hungary 
includes  the  following 
financing needs: 

in  2021–2027.  This 

• 

•  Hungary’s PAF (158) concerning the Natura 2000 areas: 
EUR 362 million per year, mostly running costs; 
additional BDS costs (159): EUR 737 million per year on 
top of the PAF; 
sustainable 
EUR 383 million per year. 

management 

costs (160): 

soil 

• 

(157)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 
(158)  European Commission, ‘ inancing Natura 2000 – Prioritised action 
website, 

European 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

Commission 

(159)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(160)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
2023, 
COM(2023) 416 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 

5 July 

final 

of 

2025 Environmental Implementation Review – Hungary 

 
 
Hungary  44 

Current investments 

Public financial management 

The current level of biodiversity financing is estimated to 
be EUR 482 million per year (in 2022 prices) in 2021–2027. 
75.2 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

25.2 % of the total financing is estimated to come from EU 
cohesion  policy,  57 %  from  CAP,  3.1 %  from  Horizon 
Europe  and  around  1.2 %  from  LIFE.  The  EU  MFF 
altogether  accounts  for  87 %  of  the  financing.  The  rest, 
13 %, comes from national sources (161). 

Hungary  does  not  dedicate  a  share  of  RRF  funding  to 
supporting  measures  for  biodiversity  directly.  Hungary 
has, however, programmed 17.6 % of its CAP budget for 
2021–2027  measures  dedicated  to  support  biodiversity, 
which  is  slightly  under  the  EU  average  (18.6 %).  Lastly, 
6.4 %  of  Hungary’s  cohesion  policy  EU  contribution 
amount (disregarding ESF+) is estimated to contribute to 
biodiversity, above the EU average (5.9 %). 

Figure 35: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States  already  use  green  budgeting  tools  for  identifying 
and  tracking  green  expenditures  and/or  revenues  (162). 
Green budgeting practices provide increased transparency 
on the environmental implications of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (163). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021 to 2024 (164), in which Hungary participated. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (165)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

formed  the 

Total environmental taxes amounted to EUR 4.25 billion in 
Hungary  in  2023,  representing  2.16 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 1.75 % 
of GDP, which is above the EU average of 1.6 %. Transport 
taxes, at 0.3 % of GDP, were slightly under the EU average 
(0.4 %), while taxes on pollution and resources, at 0.11 %, 
were  above 
In  2022, 
environmental  taxes  in  Hungary  accounted  for  5.4 %  of 
total revenues from taxes and social security contributions 
(around the EU average of 5.0 %) (166). 

the  EU  average 

(0.08 %). 

Figure 36: Environmental taxes per Member State, 2022 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Hungary’s 
investment gap is estimated to be around EUR 1 billion per 
year, corresponding to 0.59 % of its GDP. 

(161)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(163)  European  Commission, 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(162)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(164)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(165)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
https://op.europa.eu/en/publication-detail/-
p. 1), 
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

(166)  Eurostat, ‘Environmental taxes accounts’, env_eta. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
 
Hungary  45 

issuance 
(EUR 1 billion). 

in 

2023 

amounted 

to  USD 1.1 billion 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 %  to 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  supranational 
issued  by 
financial  corporates,  29.1 %  by  sovereign  governments 
and  23.1 %  by  non-financial  corporates.  8.3 %  of  the 
issuances was linked to government-backed entities, 6.4 % 
to developments banks and 1.4 % to local governments. 

issuances)  was 

Figure 37: Value of green bonds issued per Member 
State (billion EUR), 2021, 2022, and 2023

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
the  enabling 
action  programme  objectives  and 
conditions (169). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According to a 2024 study (167), Hungary applies economic 
instruments such as emission charges (related to air and 
water quality, noise and landfilling), product charges (for 
batteries,  plastic,  aluminium  or  tyres)  and  user  charges 
(for  visits  to  national  parks,  or  water  abstraction  and 
disposal).  It  has  missed  opportunities  to  apply  emission 
charges to specific pollutants, such as NOx or manure. Such 
measures  could  significantly  help  Hungary  to  meets  its 
commitments  to  reduce  emissions,  notably  for  NO2  and 
NH3.  Hungary  would  also  benefit  from  applying  product 
charges for specific goods, such as vehicles, oil, pesticides, 
fertilisers,  or  electric  and  electronic  products;  dedicated 
user charges, such as road pricing; or charges on activities 
such  as  hunting  and  fishing,  waste  disposal,  mineral 
extraction or logging. Such measures would help Hungary 
to meet waste management and circular economy targets, 
reduce pollution and increase nature protection. 

Green bonds and sustainable bonds 

In 2023, the total value of green bonds issued by Member 
States  was  USD 245 billion  (EUR 227 billion),  up  from 
USD 234 billion (EUR 198 billion) in 2021 (168). 

During 2021–2023 combined, Hungary issued green bonds 
(EUR 4.1 billion).  Of  this,  the 
worth  USD 4.8 billion 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 

(167)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 2, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(168)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(169)  Article 3(h) and 3(v) of the eighth environment action programme. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (170). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (171). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In  Hungary,  the  energy  subsidies  showed  a  marked 
decrease between 2015 and 2019, and then rose, with an 
unusual spike in 2022. FFS ranged from EUR 0.7 billion to 
EUR 1.0 billion  between  2015  and  2021,  jumped  to 
EUR 2.6 billion  in  2022  and  started  to  decrease  again  in 
2023 (reaching EUR 1.9 billion). 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to  less  than  0.1 %  in  Denmark  and  Sweden.  Hungary’s 
value reached 1.5 %, above the EU average (0.8 %) (172). 

Figure 38:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

Hungary  46 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

The  2022  priority  actions  for  Hungary  included  the 
following. 

• 

• 

including  by 

Prepare  an  environmental  financing  strategy  to 
maximise  opportunities  to  close  environmental 
increasing 
implementation  gaps, 
environmental taxation. 
Tackle  the  main  environmental  challenges  affecting 
the  country  through  adequate  funding,  including 
through the mobilisation of private investments and 
the use of EU funds. 

Hungary  has  similar  levels  (1.4 %  of  GDP)  of  overall 
environmental investment gap as in 2022, which requires 
further action. Therefore, the priority actions are repeated 
(but combined) for Hungary. 

2025 priority action 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(170)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

(172)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

European Union, COM(2025). 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en. 

(171)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

European Union, COM(2025). 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
 
 
Hungary  47 

6. Environmental governance

Information, public participation and access to 
justice 

implementing  environmental  legislation (177).  Hence,  a 
priority action is proposed in 2025. 

shared  efficiently  and  effectively 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
(173).  Public 
is 
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 environment, safeguard the 
rights  of  citizens,  and  ensure  accountability  of 
authorities (174).  It 
legal 
challenges (‘legal standing’) (175). 

includes  the  right  to  bring 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
information  between  public 
environmental  spatial 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

Hungary’s  performance 
implementing  the  Inspire 
Directive  has  been  reviewed  based  on  its  2023  country 
fiche (176) (see Table 3) and shows some progress. 

in 

More efforts are needed on implementation of the Inspire 
Directive to (i) make spatial data more widely accessible, 
(ii) improve the conditions for data reuse and (iii) prioritise 
environmental  datasets  in  implementation,  especially 
identified  as  high-value  spatial  datasets  for 
those 

(173)  The 

Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
Inspire 
content/EN/TXT/?uri=CELEX:32003L0004) 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(174)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 

Table 3:  Hungary  dashboard  on  implementation  of  the 
Inspire Directive, 2016–2023 

2016 

2023 

Legend 

Effective 
sharing 

coordination  and  data 

Ensure  effective 
coordination 

■  ■ 

Data 

without obstacle  ■  ■ 

sharing 

Inspire performance indicators 

(i)  Conformity  of 
metadata 

■  ■ 

(ii)  Conformity  of 

spatial datasets  ■  ■ 

(iii) Accessibility of 
datasets 
spatial 
through  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 
easily. 
addressed 
Percentage > 89 % 

■ Implementation of 
this  provision  has 
started  and  made 
some  or  substantial 
progress but is still not 
close 
being 
to 
completed. 
Percentage = 31–89 % 

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

Source:  European  Commission,  ‘Hungary’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/hungary_en. 

Public participation 

Public involvement  at both the planning and the  project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 

2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(175)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(176)  European  Commission, 

‘Hungary’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/hungary_en. 
(177)  The  European  Commission provides  a  list  of  high-value  spatial 
datasets 
(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

Environmental Implementation Report 2022 – Hungary 

 
 
 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (178) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (179). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member States in this regard (180). Hungary is yet to take 
steps  aiming  to  accelerate  permit-issuing  procedures 
taking advantage of the broad flexibilities offered by the 
EU legal framework, such as the establishment of one-stop 
shops and accelerated short deadlines for issuing permits 
for renewable energy projects. 

EIA 

and 

duration 

(screening, 

a  maximum 

The average speed in the EU for permits involving an EIA 
procedure  is  20.6 months,  with  a  minimum  duration  of 
11.4 months 
of 
75.7 months (181).  The  duration  of  each  step  in  an  EIA 
report,  public 
scoping, 
process 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The data available from Hungary shows that the average 
duration of some parts of the EIA process (e.g. screening) 
are faster than the EU average, while other parts of the 
process  (e.g.  reasoned  conclusion)  are  slower  than 
average (182). Effective use of EU procedures can positively 
influence  the  timely  approval  of  activities  underpinning 

(178)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(179)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

(180)  Commission Staff Working Document  (SWD/2022/0149 final), 18 
May 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953. 

2022, 

(181)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 

Hungary  48 

the  decarbonisation  of  the  economy  on  the  way  to  net 
zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support study has been published with information by 
Member State (183). 

Since 2019, Hungary has been subject to an infringement 
the  proper 
for  not  conforming  with 
procedure 
transposition  of  several  provisions  of  the  EIA  Directive. 
The  Commission’s  assessment 
revealed  over  24 
grievances in the transposition. 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As  outlined  in  the  2022  EIR,  both  individuals  and  legal 
entities  can  challenge  administrative  decisions  or 
omissions in Hungary if their rights or lawful interests are 
affected.  An  NGO  has  legal  standing  if  an  administrative 
activity affects its registered activity. 

Nevertheless,  there  are  some  difficulties  in  challenging 
plans  or  programmes.  If  the  act  adopting  a  plan  or 
programme  is  considered  a  legal  measure  or  a  public 
administrative  measure  without  legal  force  and  the 
relevant  conditions  are  met,  a  constitutional  complaint 
can  be  lodged  with  the  Constitutional  Court.  However, 

Impact  Assessment 

revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(182)  Details  are  not  available  regarding  the  average  duration  for  all 
steps of the procedure. Therefore, we cannot assess the average 
duration of the entire EIA procedure. 

(183)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al.,  Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

2025 Environmental Implementation Review – Hungary 

 
 
plans and programmes that are not considered such acts 
cannot be challenged. 

In  2024,  the  Commission 
infringement 
procedure (184)  against  Hungary  for  failure  to  ensure 
access to justice in environmental matters in several policy 
areas, such as nature, water, air quality, waste and noise. 

launched  an 

In  2022,  Hungary  received  four  priority  actions:  (i)  to 
significantly improve the information available on SEA and 
EIA  procedures,  ideally  through  a  central  database,  and 
ensure that all related documentation is made available, 
ideally online; (ii) to 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; (iii) to improve access to courts by the public 
concerned when it comes to challenging administrative or 
regulatory  decisions  covering  planning,  in  particular  in 
relation  to  water,  nature  and  air  quality;  (iv)  to  better 
inform the public about their right to access to justice, in 
particular  by  referring  to  the  Commission  e-justice 
factsheets on access to justice in  environmental matters 
on national judicial and administrative portals223. Hungary 
has not made any progress on these priority actions.  

2025 priority actions 

• 

for 

datasets 

•  Make  spatial  data  more  widely  accessible  and 
prioritise environmental datasets in implementing the 
Inspire  Directive,  especially  those  identified  as  high-
value 
implementing 
spatial 
environmental legislation. 
Ensure  that  relevant  information  on  EIA  and  SEA 
(including  on  public  participation 
procedures 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, through 
at least a central portal or easily accessible points of 
access, at the appropriate administrative level. 
Ensure  correct  transposition  of  the  revised  EIA 
Directive. 
Improve  access  to  courts  in  national  environmental 
cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive 
costs in some Member States. 

• 

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 

(184)  European  Commission, 

infringements  package:  Key 
decisions’,  European  Commission  website,  23 May  2024, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_24_
2422. 

‘May 

(185)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 

Hungary  49 

air and nature, to manage waste (185) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools. 

As mentioned in the 2022 EIR, the annual parliamentary 
reports of the Prosecutor General provide statistics on the 
number of registered environmental crimes235. 

crime, 

including 

environmental 

No information seems to be available on the platform for 
tackling 
sharing 
information and training resources, established through a 
memorandum  of  understanding  signed  in  2021  by  the 
Ministry  of  Agriculture,  the  National  Tax  and  Customs 
Authority,  the  Hungarian  National  Police  Headquarters, 
the Ministry for Innovation and Technology, the National 
Directorate-General 
the 
Ministry  of  the  Interior,  the  Pest  County  Government 
Office and the National Food Chain Safety Office. 

for  Disaster  Management, 

The  Commission  has  received  complaints  relating  to  the 
environment  in  Hungary.  The  Commission  notes  the 
concerns raised by the issuing of permits to projects that 
were  prioritised  because  of  national  or  military  interest. 
Procedures  streamlined  under  the  national  emergency 
procedure  became  subject  to  critique  from  civil  society, 
and the Commission is looking into the matter of permits 
issued to civil projects under military procedures. 

The 2022 EIR recommended that Hungary (i) provide clear 
information  on  how  the  public  and  interest  groups  can 
report environmental issues or incidents, and encourage 
the  public  to  make  such  reports;  (ii)  make  information 
available  on  the  enforcement  of  environmental  law, 
including on the prosecution of environmental crimes and 

compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
(https://eur-
Commission 
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

2025 Environmental Implementation Review – Hungary 

 
 
the outcome of criminal proceedings; and (iii) improve the 
information  available  on  environmental  inspections  and 
their results, ideally drawing together information from all 
public 
compliance 
these  actions  concerning 
responsibilities.  However, 
compliance  promotion,  monitoring  and  criminal  and 
administrative enforcement are not assessed here due to 
a lack of systematic information. 

bodies  with 

environmental 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203) (186) and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
in  place  and  more  systematic 
measures  are  put 
information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
to  combat  environmental  crime  more 
measures 

(186)  Directive  2024/1203/EU  on  the  protection  of  the  environment 
https://eur-

criminal 

law, 

through 
lex.europa.eu/eli/dir/2024/1203/oj/eng. 

(187)  https://www.impel.eu/en. 
(188) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(189)  https://www.environmentalprosecutors.eu/. 
(190)  https://www.eufje.org/index.php?lang=en. 
(191)  Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage (https://eur-

Hungary  50 

including  by 

effectively,  in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (187),  EnviCrimeNet (188),  the  European  Network  of 
Prosecutors for the Environment (189) and the EU Forum of 
Judges  for  the  Environment (190).  The  European  Union 
Agency for Law Enforcement Cooperation and  European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)  (191)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface  waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (192), which will be  finalised in 2025, and which 
was  supported  by  an  external  study (193),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 

lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626). 
(192)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(193)  European Commission: Directorate-General for Environment and 
Fogleman,  V.,  Study 
in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Hungary 

 
 
 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some  of  which  may  have  been  handled  under  the  other 
liability instruments. 

The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
encourage 
financial  security 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 

the  development  of 

From  26 June  2019  to  31 December  2021,  Hungary 
reported  one  occurrence  of  an  imminent  threat  of 
environmental damage, namely biodiversity damage, and 
14 occurrences of environmental damage under the ELD. 
In  the  previous  reporting  period,  there  were  563 
occurrences of environmental damage reported under the 
ELD. Hungary  experienced the largest  decrease between 
the  two  reporting  periods  among  Member  States.  The 
substantially diminished numbers may be at least partially 
attributed  to  the  different  methods  of  reporting  the 
occurrences. For the second reporting period, the central 
ELD competent authority in Hungary screened data from 
authorities  on  189  environmental  damage  cases, 
concluding  that  only  14  were  ELD  occurrences.  The 
occurrences  reported  by  Hungary  for  the  first  reporting 
period were not similarly screened. In addition, the second 
reporting period covered only three years. 

Hungary has not introduced mandatory financial security 
for  ELD  liabilities.  Environmental  insurance  policies  for 
remediating on-site and off-site pollution from a sudden 
and  accidental  incident  on  an  insured  site  are  available. 
They do not provide cover specifically for ELD liabilities, for 
gradual pollution or for environmental damage other than 
pollution. Demand for such policies is low. Environmental 
extensions to general liability policies that provide cover 
for  remediating  off-site  pollution  from  a  sudden  and 
accidental incident on an insured site are available. Most 
extensions have a sublimit on liability. Demand for them is 
greater than demand for environmental insurance policies 
but is still low. 

(194)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(195)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-

Hungary  51 

The 2022 EIR, in relation to  the  ELD, recommended that 
Hungary provide clear information on how the public and 
interest  groups  can  report  environmental 
issues  or 
incidents  (while  encouraging  the  public  to  make  such 
reports) and information on environmental liability cases 
involving  environmental  damage. 
and  other  cases 
in  relation  to  the  ELD,  the  2022  EIR 
Additionally, 
recommended  that  Hungary 
implement  a  financial 
security  system  for  environmental  liability  to  meet  the 
costs  of  environmental  damage.  The  progress  on  these 
priority actions is limited. Therefore, efforts to implement 
them should continue along with those related to the 2025 
priority action. 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interactions  with  the 
other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 
expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (194) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
the  European 
for 
Commission  are  the  TSI (195)  and  the  TAIEX-EIR  PEER  2 
PEER tool (196). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The Commission’s TSI had annual calls in 2021, 2022, 2023, 
2024  and  2025.  The  following  environment-related 
projects have been selected for Hungary: 

funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(196)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – Hungary 

 
 
• 

•  Developing a supervisory framework for financial risks 
stemming from biodiversity-related losses in Hungary 
Central Bank of Hungary (2022) (197); 
Provision  of  capacity-building  within  the  ‘Magyar 
Fejlesztési Bank (Hungarian Development Bank) Plc.’ 
for  the  effective  and  efficient  distribution  of 
sustainability-linked loan programmes (2023); 
Integration  of  environmental  dimensions  in  public 
finances – Implementing the ‘do no significant harm’ 
(DNSH)  principle 
in  public  funding  programme, 
Ministry of Culture and Innovation  (2023); 
Industrial  ecosystems,  Ministry  of  Culture  and 
Innovation (2023); 

• 

• 

•  Climate adaptation, Ministry of Interior (2023); 
• 

Effects  of  compliance  with  the  ESG (198)  framework 
and  principles  on  suppliers,  Ministry  of  Culture  and 
Innovation (2023); 

•  Accelerating  climate  adaptation  measures  in  water 

management, Ministry of Interior (2024); 

•  Reinforcing  SMEs’  competitiveness  and  green 
transition in export activities, HEPA Hungarian Export 
Promotion Agency (2025). 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
events are those requested by the European Commission 
to  present  new  and  upcoming  environmental  legislation 
and policy in all Member States (199). 

Workshops involving Hungary are as follows: 

Hungary  52 

•  Decentralised  bio-waste  recycling 

(9–11 October 

• 

2023); 
Future  challenges  in  the  air  protection  in  Europe 
(24 November 2022).  

•  Online  platforms:  EU  Batteries,  Packaging  and 
Packaging Waste Regulation (28-29 October 2024). 
•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024). 

In 2022, Hungary received a priority action to continue to 
improve  environmental  governance, 
in  particular 
administrative  capacity  and  coordination  at  the  national 
level. This recommendation is notably related to the fact 
the 
to 
that  Hungary  has  no  ministry  dedicated 
environment.  As  the  successive  reorganisations 
left 
responsibility 
in  several 
for  environmental  policies 
ministries, the priority action is repeated. Currently, two 
ministries  are  dealing  with  the  environment:  the  main 
ministry  with  responsibility  for  the  environment  is  the 
Ministry  of  Energy  (environmental  policy,  air  quality, 
noise, SEA, EIA, remediation, climate, water utilities, water 
management,  water  protection  and  flood  prevention), 
while  the  Ministry  of  Agriculture  is  the  main  contact  for 
nature  protection 
for  agriculture  and 
irrigation). This  set-up requires increased cooperation to 
solve  environmental  problems  and  therefore  Hungary 
should ensure good coordination between the authorities 
and provide the appropriate resources for environmental 
issues. 

(and  water 

2025 priority action 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

(197)  https://www.oecd.org/en/events/2024/06/taiex-tsi-mnb-oecd-
ec-launch-event-technical-implementation-of-the-supervisory-
framework-for-assessing-nature-related-financial-risks-to-the-
hungarian-financial-sector.html. 
‘ESG’  means ‘environmental, social and governance’. 

(198) 
(199)  Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality: 
implementation  of  the  NEC  Directive  to  further 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 

and implementation of the revised directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noise  limit 
values and EU reduction targets (5 June 2024); Best practice use of 
environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19–20 September 
2022); and  Renewable energy projects: permit granting processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Hungary 

 
 
 
 
 
Hungary  53 

Annex

2025 priority actions 
Circular economy and waste management 
Transitioning to a circular economy 

•  Adopt measures to increase the circular material use rate. 
• 

Speed  up  the  transition  to  a  circular  economy  by  implementing  an  updated  national  strategy  and  the  EU 
framework and recommendations, in particular to complement it with upstream circularity measures. 

• 

Implement, harmonise and gradually increase landfill taxes to phase out landfilling of recyclable and recoverable 
waste. 

Waste management 

•  Ratify international conventions on ship recycling. 
• 

• 

Improve separate collection at source e.g. through economic instruments, investing in infrastructure for separate 
collection, sorting and recycling, and increasing public awareness. 
Increase reuse of products and scale up waste recycling infrastructure associated with the higher steps of the 
waste hierarchy. In particular, improve collection and increase treatment capacity for bio-waste. 
Improve municipal waste preparation for reuse and recycling. 
Increase the recycling rates of packaging waste. 
Increase the collection and recycling rate of WEEE. 
Invest in waste prevention measures to reduce the total amount of waste generated. 

• 
• 
• 
• 
•  Develop EPR schemes for problematic waste and introduce fee modulation.  
• 

Ensure the achievement of the 2025 waste targets, following the recommendations made by the Commission in 
the early warning reports where applicable. 

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

• 

• 

Ensure the effective implementation of Natura 2000 management plans and sufficient administrative capacity 
and  financing  both  for  Natura  2000  and  the  implementation  of  the  Nature  Restoration  Regulation.  Ensure 
implementation of Prioritised Actions Framework 2021-2027 (PAFs). 

Strengthen  the  integration  of  biodiversity  actions  into  other  policies  (e.g.  on  energy,  agriculture,  fisheries, 
forestry,  urban  and  infrastructure  planning  and  sustainable  tourism)  and  promote  communication  between 
stakeholders. 

Recovery of species  

•  Reinforce action for habitats and species with unfavourable conservation status through, for example, restoration 

measures, increased connectivity, better policy coordination and integration, and increased funding. 

Recovery of ecosystems 

• 

• 
• 

Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of 
Hungary. 
Implement and scale up the uptake of organic farming practices. 
Promote the active management of grasslands through extensive grazing to maintain the condition of these semi-
natural habitats. 

•  Reduce the excessive area of sealed and artificialised soil and remediate degraded areas of soil. If appropriate, 
consider  formally  committing  to  targets  for  land-degradation  neutrality  under  the  relevant  United  Nations 
Convention to Combat Desertification agreement. 
Improve conservation status of forests by promoting sustainable forest managment and ensuring compliance with 
the Habitats Directive before granting/renewing permits for forest logging. 

• 

Prevention and management of invasive alien species  

• 

Step  up  implementation  of  the  IAS  Regulation,  including  with  regard  to  enforcement  and  the  capacity  of 
inspection authorities. 

2025 Environmental Implementation Review – Hungary 

 
Hungary  54 

•  Ratify the International Convention for the Control and Management of Ships' Ballast Water and Sediments of 

2004 (BWM Convention). 

• 

Support the development of the national business and biodiversity network. 

Ecosystem assessment and accounting  

Zero pollution 
Clean air 

•  As part of the NAPCP, take action to reduce emissions of air pollutants. 
• 

Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under the 
revised AAQD. 

•  Accelerate the ratification of relevant international conventions and protocols. 

Industrial emissions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce industrial releases to water and their intensity. 
• 

Engage  with  industry  and  environmental  NGOs  to  ensure  proper  contribution  to  and  implementation  of  BAT 
conclusions and ensure timely updates to permits following the publication of BAT conclusions. 
Ensure effective public participation and access to justice in relation to the IED. 

• 

• 

Ensure full and correct transposition of the Seveso III Directive. 

Major industrial accidents prevention – Seveso 

•  Complete noise mapping. 
•  Complete and implement action plans on noise management 

Noise 

Water quality and management 

• 

• 

Improve  river  continuity  and  ecological  flows,  boosting  efforts  on  nature-based  solutions  to  reduce 
hydromorphological pressures. 
Ensure  periodic  reviews  of  permits  for  discharges,  abstractions  and  other  water  uses,  including  hydropower 
pressures. 

Improve the classification of water bodies and strengthen monitoring systems. 

•  Reduce pollution from nutrients, chemicals, metals and saline discharges. 
•  Better justify exemptions to the achievement of good status. 
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the implementation of measures 
and  ensure  adequate  financing  for  implementation,  including  through  better  use  of  cost  recovery  and  the 
polluter-pays principle. 
FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider pluvial 
flooding. 

• 

•  Consider future climate scenarios in the FRMPs. 
•  Better  explain  the  choice  and  implementation  of  flood  prevention  and  protection  measures  (prioritisation, 

• 
• 
• 

• 

monitoring, costs of measures). 
Improve public consultation and stakeholder involvement. 
Take action to ensure full compliance with the Drinking Water Directive. 
Tackle  nutrient  pollution,  especially  nitrates  from  agriculture,  through  the  implementation  of  the  Nitrates 
Directive. 
Take the necessary measures to ensure full implementation of the current UWWTD, taking into account the new 
requirements of the recast directive. 

Chemicals 
•  Upgrade  the  administrative  capacities  in  implementation  and  enforcement  to  move  towards  a  policy  of  zero 

tolerance of non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the European 
Chemicals Agency, including in the coordinated enforcement projects, called REF projects. 
Increase customs checks and checks of products sold online with regard to compliance with chemicals legislation. 

• 

• 

2025 Environmental Implementation Review – Hungary 

 
Hungary  55 

Climate action 

• 

Implementing  all  polices  and  measures  that  are  needed  to  achieve  targets  laid  down  in  the  Effort  Sharing 
Regulation (ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed priority 
actions are set out in the assessment of the final National Energy and Climate Plan (NECP) (200). 

Financing 
•  Use  more  national  funding  (for  instance  by  increasing  taxes  in  favour  of  the  environment  and  reducing 

environmentally harmful subsidies), EU funding and private funding to help close the investment gap. 

Environmental governance 
Information, public participation and access to justice 
•  Make  spatial  data  more  widely  accessible  and  prioritise  environmental  datasets  in  implementing  the  Inspire 

• 

• 
• 

• 

• 

Directive, especially those identified as high-value spatial datasets for implementing environmental legislation. 
Ensure that relevant information on EIA and SEA procedures (including on public participation opportunities and 
on publication of final decisions) is electronically accessible in a timely manner, through at least a central portal 
or easily accessible points of access, at the appropriate administrative level. 
Ensure correct transposition of the revised EIA Directive. 
Improve access to courts in national environmental cases by the public concerned and eliminate practical barriers, 
such as length of proceedings and excessive costs in some Member States. 

Compliance assurance 

Encourage  the  use  of  training  programmes  provided  by  the  Commission  (or  developed  at  the  national  level) 
covering the ELD and its interactions with the other national liability-related instruments, to ensure more efficient 
ELD  implementation,  improve  the  expertise  of  the  competent  authorities  and  raise  awareness  among  all 
stakeholder groups. 

EU-supported environmental capacity building 

Improve overall national environmental governance, in particular administrative capacity to support the green 
transition and coordination at the regional and local levels. 

(200)  European  Commission,  National  energy  and  climate  plans.  Available  at  https://commission.europa.eu/energy-climate-change-

environment/implementation-eu-countries/energy-and-climate-governance-and-reporting/national-energy-and-climate-plans_en. 

2025 Environmental Implementation Review – Hungary