The National Association of Waste Managers (HOSZ), representing at least 80 percent of the Hungarian waste management market, submitted an official, comprehensive proposal to László Gajdos, Minister for the Living Environment, on May 6, 2026. Representing dozens of companies, the association agrees with the government’s intent to conduct a review while raising sharp criticism and citing specific legal and economic facts—including a recent court ruling and anomalies regarding the concessionaire’s abuse of a dominant position—against the current operation of the system.
At a critical juncture for the future of the waste management sector and the competitiveness of domestic companies, the most significant interest representation body has taken action. The official electronic document, signed by Dr. Zoltán Borosnyay, LL.M., Managing Director of HOSZ, details the most severe practical and legal issues surrounding the unified concession system associated with MOL Nyrt. and the Extended Producer Responsibility (EPR) system to the ministry.
Market Weight and International Stature of HOSZ
The weight of this professional advocacy stems from the broad reach of the sending organization. Representing domestic commercial waste management service providers, the 35-year-old HOSZ currently boasts a membership of 61 companies nationwide. Together, these firms hold a market share of at least 80 percent in the Hungarian sector. The association represents domestic waste recyclers and commercial service companies in 8 out of the 12 national EPR fee councils. Furthermore, HOSZ possesses an extensive international network: it is a national member of the global Bureau of International Recycling (BIR), the Recycling Europe umbrella organization, and its specific sectoral divisions for paper and non-ferrous metal recycling.
Anomalies of the Concession Agreement and the Question of Legal Expiry
In its letter, the association recalls that the Hungarian State and MOL Nyrt. signed a concession agreement for unified waste management activities on July 28, 2022, which is currently under investigation by the European Commission. HOSZ expressed concerns from the beginning: on November 15, 2022, eight national interest representation organizations jointly turned to Prime Minister Viktor Orbán, requesting a modification of the system and the narrowing of its scope to municipal waste management public services; however, this initiative was unsuccessful.
One of the most serious legal claims in the submitted documentation is that the concession legally expired on December 31, 2022, even before it took effect. According to HOSZ’s reasoning, the concessionaire failed to conclude the necessary Capacity Guarantee Agreements and obtain the required permits for the performance of the tasks by this deadline. Consequently, six organizations officially requested the ministry’s leadership to announce the termination of the agreement on February 27, 2023. As this did not occur, HOSZ is aware that a criminal report has already been filed for official misconduct in the matter.
Abuse of Dominant Position and the Status of Metal Trading
Although commercial service providers attempted to cooperate, HOSZ claims that from the start of the concession, they experienced unprofessional attitudes, aggressive abuse of dominant position, and expansion beyond the scope of the Concession Agreement. The concessionaire has appeared vertically at every level of waste management: it supplies itself with raw materials while simultaneously acting as a financing coordinator and a direct competitor to its own subcontractors in the market. In the closed tenders for institutional task performance, the concessionaire dictated unilateral contracts that were unacceptable and unfeasible for the SME sector.
There has also been a significant overreach in the field of metal trading. Based on the legal framework, the scope of the unified concession in this area is strictly limited to municipal metal packaging waste collected during public services, metal waste disposed of during free bulky waste removals, metal waste handed over at waste yards, and metal waste falling under the scope of EPR. Due to increasing tensions, HOSZ turned to several ministries and the National Tax and Customs Administration (NAV) on May 14, 2024, urging official action against illegal waste trade and regarding the material scope of the unified concession.
Severe Disruptions and Lack of Transparency in the EPR System
The appeal highlights several fundamental flaws in the EPR system:
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Loss of Ownership and Market Distortion: Service providers have lost ownership of waste. While the concessionaire spends billions from EPR sources on incentives to acquire materials, revenues from the sale of recyclables are not accounted for when determining EPR fees. Furthermore, the concessionaire does not recognize so-called “negative price” recyclable sales.
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Raw Material Shortages for Recyclers: The raw material supply for many recycling companies is not secured in a way that threatens their very existence; as a result, several companies have already been forced to cease their activities.
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Financing Anomalies: Although the concessionaire takes a 9.11 percent return into account for subcontractors in the EPR fees established prior to the current year, in reality, this is not paid to them. In fact, for certain activities, there is no payment at all, or financing is below cost.
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Lack of Transparency: The fee councils organized by waste stream—which should play a fundamental role in establishing EPR fees—have no meaningful function in reality, and the system is characterized by a total lack of transparency.
To support these serious claims, HOSZ attached a final court ruling from the Metropolitan Court of Appeal to the letter sent to the minister, issued in the case initiated by former Radio Free Europe journalist Tamás Wiedemann (Case No. 9.Pf.20.697/2025/10-II.).
Source:
- Hulladékgazdálkodók Országos Szövetsége (HOSZ): Az egységes hulladékgazdálkodási koncesszió felülvizsgálata