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★Mark us as a preferred sourceAccording to a fresh analysis examining the Extended Producer Responsibility (EPR) systems of the 27 EU Member States, it is not the size of the fees but the structure of the system that determines success. Hungary, with an overall recycling rate of 42.8%, ranks as the second-worst performer in the EU. The study attributes this lagging performance not to regulatory gaps, but to missing collection and sorting infrastructure.
Commissioned by the European Packaging and Waste Association (EUROPEN), CIRCPACK by Veolia conducted a comprehensive analysis of the EPR systems across all 27 EU Member States. Published in June 2026, the study assesses how prepared Member States are for the mandatory recycling targets under the Packaging and Packaging Waste Regulation (PPWR), which enter into force in 2030 and 2035. The picture is mixed: while some nations surpass targets using systems built over decades, others—including Hungary—face significant deficits.
How Wide is the Gap Within the EU?
In 2023, the EU generated 79.7 million tons of packaging waste, averaging 177.8 kg per capita, and recycled 64.1% of it. However, the disparity between countries is immense: Belgium leads at 79.7%, while Romania stands at just 37.3%. This gap of more than 40 percentage points has not narrowed substantially over the past decade.
Plastics perform the worst. The EU household average for rigid plastics is 34.1%, while flexible (film-like) plastics stand at a mere 13.1%. According to the study, flexible plastic remains the largest unresolved bottleneck in the entire system.
Three System Models: But the Type Does Not Dictate Success
The study distinguishes between three types of EPR systems and compares their performance:
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Single-PRO systems: A single Producer Responsibility Organization handles household packaging (e.g., Belgium, the Netherlands, Italy). Average recycling rate: 71.8%.
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Competitive, Multi-PRO systems: Multiple organizations compete for manufacturers (e.g., Germany, Spain). Average recycling rate: 62.2%.
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State-managed systems: Fees flow directly into a state fund (Hungary, Croatia). Average recycling rate: 47.4%.
While the numbers suggest a clear hierarchy, the central message of the analysis is that the quality of governance matters far more than the model type. Belgium and Italy (Single-PRO) sit in the top tier alongside Germany and Spain (Multi-PRO)—all within a ten percentage point margin. The variance within individual models is greater than the variance between them.
What Sets High-Performing Systems Apart?
The study identifies four factors that truly predict success:
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Fee Structure over Fee Level: Finely differentiated (granular) eco-modulation—where fees vary by material, format, and recyclability—outperforms basic fee structures by 16.5 percentage points. High fees alone do not help; waste volume correlates with per capita GDP.
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Physical Infrastructure: No packaging category is currently on track to meet the 2035 “at-scale recyclability” requirement in every Member State. Physical capacity is the true limiting factor, which no fee design can solve on its own.
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Transparency: Member States with high transparency recycle an average of 13.4 percentage points more packaging than those without (69.6% vs. 56.2%).
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Financial Traceability: The largest systemic deficiency is that the allocation of fee revenues downward from PROs is typically opaque. Belgium remains one of the few exceptions where revenues can be traced all the way to service providers.
Hungary: Strong Steel, Weak Plastic and Glass
Hungary is one of the five in-depth case studies featured in the report—and ranks as the weakest among them. In July 2023, the government granted a 35-year concession to MOHU (MOL Group) for national waste management, replacing the previous fragmented PRO framework. Additionally, a nationwide Deposit Return Scheme (DRS) for plastic bottles, metal cans, and glass has been operational since January 2024.
Hungary’s overall recycling rate stands at 42.8% (Eurostat, 2023 data), far below the EU targets of 65% for 2025 and 70% for 2030. However, performance varies drastically by material stream:
| Material | Hungary’s 2023 Recycling Rate | 2030 PPWR Target |
| Steel (Ferrous) | 85.7% | 80% ✓ Achieved |
| Paper and Cardboard | 70.3% | 85% |
| Plastic | 23.0% | 55% |
| Glass | 22.8% | 75% |
| Aluminum | 18.4% | 60% |
| Overall | 42.8% | 70% |
Steel is the only material stream that already exceeds the 2030 threshold. While paper and cardboard perform relatively well, critical failures in glass, aluminum, and plastic drag the overall average down. The aluminum figures are particularly telling: while Hungary stands at 18.4%, Italy achieves 70.3%, Germany 68.0%, and Spain 51.2%.
The Issue Lies in Execution, Not Regulation
The study consistently argues that the Hungarian deficit is primarily operational, not regulatory. Collection infrastructure has historically focused on traditional materials (glass, paper, cardboard). Separate collection and format-specific sorting of flexible plastics remain limited, leaving key material streams in an “early development” or “restricted” status. A fee signal—no matter how well-designed—cannot yield results while the operational layer required to transform waste into recycled material is still being built.
Furthermore, the current Hungarian fee system operates on a strict cost-recovery basis. Manufacturers receive no discounts for incorporating recycled content or designing for recyclability, leaving a gap in incentives for circular packaging design. In terms of transparency, Hungary received a “low” rating because the latest publicly available data is more than two years old.
Future Outlook
The study remains cautious with its forecasts, identifying Hungary as the Member State where short-term outlooks are the most difficult to evaluate. Recent data must be treated with reservations; the 18% reduction in waste volume reported in 2023 could stem from macroeconomic shocks and reporting disruptions rather than systemic improvements.
Nevertheless, two developments appear probable: recycling rates are expected to rise because the baseline is low and the 2026 investment commitments are public. However, the extent of this increase depends on whether MOHU pairs infrastructure expansion with the transparency required by EU rules, and whether manufacturers can clearly see how their fees are being utilized.
According to the study, the four common traits of top-performing systems—granular fee structures, consolidated operational responsibility, format-level data, and transparent methodologies—are attainable for any Member State without additional costs. For Hungary, the primary question is not the state-managed model itself, but whether this newly centralized framework can successfully build the physical collection and sorting infrastructure before the strict 2030 obligations take full effect.
Official Sources and References:
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Source: CIRCPACK by Veolia – “EPR system performance in the European Union” (Commissioned by EUROPEN, June 2026). Data is based on the Eurostat 2023 reporting period and the study’s proprietary material-specific database.
