MOHU Amends Waste Collection Rules from July 1: Fees Introduced for Construction Debris at Recycling Centers

The definition of a consumer is expanding, limits on dropping off waste via power of attorney are being introduced, proof of property vacancy criteria are loosening, and construction and demolition waste will be accepted at a gross fee of 36 HUF/kg. These rules from MOHU MOL Hulladékgazdálkodási Zrt., effective July 1, 2026, modify both the company’s General Terms and Conditions (GTC) and separate guidelines for recycling center users.

What Changed and Why Does It Matter?

MOHU MOL Hulladékgazdálkodási Zrt.—Hungary’s concession waste management service provider—is updating its GTC for public waste management sub-activities effective July 1, 2026. Simultaneously, it is releasing a dedicated guide on the fees and terms for disposing of construction and demolition waste at residential recycling centers. The GTC revisions are summarized in Appendix 1 (List of Amendments) and affect six structural units.

Some changes directly benefit customers: the conditions for proving property vacancy are relaxing, and the scope of who qualifies as a consumer in dispute resolution processes against MOHU is expanding. Other modifications address previous regulatory gaps—specifically concerning waste disposal via power of attorney and the management of construction and demolition debris, which were not previously regulated in detail.

1. Expanded Definition of Consumer: Condominiums and SMEs Included

The most significant substantive change is the expansion of the term “consumer.” In the current GTC, a consumer referred exclusively to natural persons based on Act CLV of 1997 on Consumer Protection. The July 1 amendment broadens this framework significantly.

Under the new text, the following entities also qualify as consumers in conciliation board proceedings—except for cases falling under EU Regulation No 524/2013 on online dispute resolution for consumer disputes—provided they buy, order, receive, use, or accept goods, or are the recipients of commercial communications or offers related to goods:

• Civil organizations (pursuant to specific legislation),

• Ecclesiastical legal entities,

• Condominiums,

• Housing cooperatives,

• Micro, small, and medium-sized enterprises (SMEs) that utilize public utility services or purchase, use, or accept products within the framework of retail activities under the Act on Commerce.

Furthermore, businesses qualifying as corresponding buyers under EU Regulation 2018/302 will also be treated as consumers.

Direct Impact: Condominiums, housing cooperatives, and smaller businesses can now utilize consumer protection remedies, such as turning to the regionally competent conciliation board to resolve disputes with MOHU.

2. “Szelektív Zsák” (Selective Waste Bag): A Distinct Concept

The GTC establishes a new independent definition for the Szelektív Zsák (Selective Bag). It is defined as any transparent bag used for the collection of separately collected waste that does not obstruct the identification of its contents—specifically excluding the Zöldhulladékos Zsák (Green Waste Bag).

The previous GTC version lacked an independent, detailed definition. The new text sets out two mandatory criteria: transparency and non-obstruction of content identification. The Green Waste Bag, which marks a distinct collection category, is explicitly excluded to prevent the mixing of the two bag types.

3. Property Title Deed: 30-Day Validity Limit

The amendment introduces the definition of a Tulajdoni lap (Property Title Deed) into the interpretative provisions. Under the GTC, a Property Title Deed is an official public document issued from the authentic land registry that is no older than thirty (30) days from the date of use. This concept is crucial for customer identification and property-linked request management to ensure that land registry records remain current during administration.

4. Mixed Waste Bins: Temporary Bagged Collection Permitted

The amendment to Section 2.1.2.7 establishes rules for the temporary period during which a mixed waste bin (Vegyes Gyűjtőedényzet) is being replaced. The new text states that until the bin is replaced in accordance with Section 2.1.2.6, mixed waste may be collected in any type of bag—provided that the volume of waste to be removed is proportional to the bin size specified in Section 2.1.2.6. This provision provides a temporary solution if a bin is damaged or lost.

5. Proving Property Vacancy: Minimal Consumption Accepted Instead of Zero

The modification of Section 4.3.1.10 introduces a highly practical benefit for customers. Previously, property vacancy had to be proven to the Regional Service Provider within 60 days following the end of the suspension period by presenting a utility bill showing zero consumption.

The new text relaxes this requirement: documents issued by the respective utility provider showing minimal consumption are now acceptable, up to the following limits:

• For water consumption: a maximum of $0.5 \text{ m}^3\text{/month}$

• For electricity consumption: a maximum of $50 \text{ kWh/month}$

The consequence of failing to provide proof remains unchanged: if the customer fails to prove vacancy as prescribed, the public waste management service fee will be billed retroactively for the affected period. The 60-day deadline for submitting proof also remains unchanged.

6. Recycling Centers: Limits on Power of Attorney and Construction Waste Restriction

Amendments to Sections 3.1. d) and e) of Appendix 6.A clarify the terms of using recycling center services in two areas:

• 3.1. d) – Proof for a different property: If a resident wishes to drop off waste linked to a property other than the one on their address card, they must present a receipt or document proving payment of the latest public service fee for that specific additional property.

• 3.1. e) – Rules for waste drop-off via power of attorney (new provision): Dropping off waste using a power of attorney is permitted, but to ensure the full availability of residential recycling center services, only one of the following options is allowed per visit:

  1. A person delivering their own waste along with the waste of another person via a valid power of attorney, or

  2. A person delivering waste on behalf of two other individuals simultaneously, based on powers of attorney received from them.

Critical Restriction: The GTC explicitly states that dropping off construction and demolition waste via a power of attorney is strictly prohibited.

This point e) is an entirely new provision intended to distribute recycling center capacities fairly among actual property users and to prevent abuse of the authorization system—particularly regarding construction and demolition waste, where dropping volumes and economic incentives are more substantial.

7. Disposal of Construction and Demolition Waste: Gross 36 HUF/kg, Only for Natural Persons

Starting July 1, 2026, MOHU will regulate the fees, terms, and invoicing methods for dropping off construction and demolition waste at recycling centers through a separate guide. These rules apply to recycling centers that are contractually authorized to accept such waste.

Who Can and Cannot Drop Off Waste?

Construction and demolition waste can only be dropped off by natural persons who are property users. Business entities are prohibited from disposing of construction and demolition waste at residential recycling centers. To identify users, presenting an ID card and an address card is mandatory; in the absence of these or if the user refuses identification, MOHU is legally required to reject the waste intake. Disposal via a power of attorney is not permitted.

Disposal Fees

The payment obligation applies to two specific waste codes:

• HAK 17 09 04 (mixed construction and demolition waste other than those mentioned in 17 09 01, 17 09 02, and 17 09 03): gross 36 HUF/kg

• HAK 17 01 07 (mixtures of concrete, bricks, tiles, and ceramics other than those mentioned in 17 01 06): gross 36 HUF/kg

The allowed delivery volume (quota) is unlimited. The fee rates are determined by MOHU Zrt., which must publish them on its website and on the websites of recycling center operators at least 30 calendar days before they take effect.

Invoicing and Payment

The disposal fee is payable retrospectively. MOHU will determine the mass of the delivered waste (in kg) via weighing, then generate and send an invoice to the customer. The amount must be settled by the deadline indicated on the invoice via the attached check or by bank transfer. On-site payment is not available, and invoices are not printed at the recycling centers.

Consequences of Non-Payment

In the event of overdue invoice balances, MOHU Zrt. is authorized to transfer the debtor’s identification data (name, place and date of birth, mother’s maiden name, residential and data addresses) to a debt collection company or to assign the claim. The legal basis for this data transfer is Article 6(1)(f) of the GDPR (legitimate interest of the data controller). This data processing may begin following the publication of the relevant notice on the MOHU website.

For invoice complaints and arrears management, MOHU’s billing customer service is responsible (Phone: +36 1 776 7777, Email: kukaszamla@mohu.hu). Formal handling requires a written record of the reasons along with documents supporting the validity of the complaint.

Technical Clarifications

The amendment includes two technical updates. Section 2.9 refines the reference to recycling center collection rules, pointing to Part A of Appendix 6 of the GTC. In Section 3.1.2 j) i), the text describing MOHU’s right to refuse collection is supplemented with the word “standardized”—meaning waste collection can be refused if the waste is not placed in a collection bin standardized for the Regional Service Provider’s transport vehicles.

When Does It Take Effect and Where Is It Available?

The modified GTC will enter into force on July 1, 2026, and applies to all services provided within the framework of the public waste management sub-activity, including regions managed by regional service providers.

The full, detailed differences between the text of the GTC in effect from January 1, 2026, and the GTC in effect from July 1, 2026, are contained in a separately attached comparative document referenced in Appendix 1.

Official Sources and References:

• MOHU MOL Hulladékgazdálkodási Zártkörűen Működő Részvénytársaság: General Terms and Conditions – Provision of Services Within the Public Waste Management Sub-activity. Effective: From July 1, 2026 | Document Date: June 1, 2026. Company Registration No: 01-10-142036 | Headquarters: 1117 Budapest, Galvani utca 44. Source Chapter: Appendix 1 – List of Amendments (Pages 58–59). Available: mohu.hu

• MOHU MOL Hulladékgazdálkodási Zártkörűen Működő Részvénytársaság: Disposal Fees, Terms, and Invoicing Rules for Construction and Demolition Waste at Recycling Centers. Effective: From July 1, 2026.