Start with the scope

EPR puts the cost of waste treatment on whoever places the product and its packaging on the market. CBAM prices the carbon emitted during production. EUDR asks whether that production caused deforestation. Different product scope, different authority, different frequency, but all three start from the same customs data.

EPR. If you import packaged goods and place them on the Hungarian market, you are usually obliged, whether or not the product itself is on the circular product list. CBAM covers five product groups above 50 tonnes a year; EUDR covers seven commodities and their derivatives.

For EPR, the first party placing goods on the domestic market, which on import is usually the importer. For CBAM, the representative under indirect customs representation, otherwise the importer. For EUDR, whoever first places the product on the EU market.

The usual consequence is not a fine but a hold-up: without an authorisation or a reference number, goods cannot be released for free circulation. With EPR it tends to surface as a retroactive fee correction and a penalty.

Because the rules treat anyone who first places a foreign-made product on the domestic market in the course of business as obliged. Packaging is a circular product in its own right, so the obligation applies even when the product itself is not listed.

In two places: with the waste management authority, and on the MOHU Partner Portal. Without the second one the fee invoice is not accessible and there is no direct line to the concession holder.

Quarterly, by the 20th of the month following the quarter, via the OKIR gateway, broken down by circular product code. The authority passes the data to MOHU, which issues the invoice on that basis.

If the product is not placed on the domestic market but moves on unchanged, the obligation generally does not arise. The conditions are strict and documentation-bound, so this needs an item-by-item review.

It is the permission without which, since 1 January 2026, CBAM goods cannot be released for free circulation. It is issued by the National Climate Protection Authority and its conditions largely match the AEO criteria.

The obligations apply to those importing at least 50 tonnes of CBAM goods per calendar year. The threshold has to be tracked during the year, because from the moment it is crossed the lack of an authorisation becomes an obstacle.

The greenhouse gas emitted during production of the imported goods, per tonne. The data arises at installation level, so it has to be requested from the supplier, usually on the Commission template.

No. The transitional quarterly reporting obligation has ended; the last report covered Q4 2025. In the definitive period there is an annual declaration with quarterly certificate coverage.

The DDS is the statement in which an operator declares that it has carried out due diligence and that the product is deforestation-free and lawfully produced under the law of the place of production. It is filed per consignment in TRACES NT, before release for free circulation.

The coordinates of the plot where the goods were produced. Polygons for larger areas, points for smaller ones. Implementing details are still moving, so it is worth asking suppliers for the fuller data structure.

Five years, and it must be produced on request. In practice that means supplier evidence has to be stored in an organised, retrievable form.

Under the text in force it applies to large and medium operators from 30 December 2026 and to micro and small enterprises from 30 June 2027. Supplier data collection takes months, so preparation pays off even if the date moves again.

It depends on the number of lines. For a few hundred rows of import data, usually a week; for more complex structures, two. The output is a coverage list by tariff code, with volumes and the threshold calculation.

The last twelve months of import lines with tariff code, quantity, net weight, country of origin and supplier. This is usually available from your customs agent or your ERP system.

Yes, that is the usual arrangement. The agent handles the declarations and TARIC codes; we handle the underlying data, the registrations and the dealings with authorities. We agree the boundary at the outset.

Based on scope and the number of lines involved, with the extent and the deadline fixed in advance. We quote after reviewing the import data, and we do not work on open-ended hourly billing.