Navigating EPR & CBAM: Joint Sustainable Growth & Tax Committee Roundtable

On December 2, our Sustainable Growth and Tax Committee held a joint committee meeting on the latest developments of CBAM and EPR. The meeting featured Ágnes Gulyás-Béky and Dávid Bolla (National Climate Protection Authority, Ministry of Energy), István Kovács (Deloitte), Kristóf Péntek (KPMG), Erzsébet  Blahunka (Aumovio), Zoltán Selyem (Bosch) and Róbert Molnár (Bosch).

The session provided an overview of the CBAM mechanism, its link to the EU ETS, and the authorization requirements that will apply from 2026. It reviewed the October 21 amendment, which introduced new simplifications and a mass-based 50-tonne de minimis threshold to ease the administrative burden for smaller importers. The experts explained the registration process, the data collection and management rules, the role of verification, and the obligations related to CBAM certificates, while also sharing practical insights on expected costs and areas where companies need clearer technical guidance, such as emissions calculation and supplier data reliability. The presentation further outlined the Hungarian authorization procedure, reporting timelines, sanctions and the compliance tasks importers must prepare for ahead of the 2026 definitive phase. The meeting then turned to EPR, offering an overview of current obligations and the upcoming Packaging and Packaging Waste Regulation (PPWR), which will take effect in August 2026 and will require accurate data and strong internal processes for smooth implementation.

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