Regulations
What falls due when
The three regulations run on separate schedules but draw on the same supplier data. The timeline below reflects the texts as they currently stand.
Ongoing
EPR, on a quarterly rhythm
EPR is not a one-off deadline but a continuing obligation. Reporting via the OKIR gateway by the 20th of the month following the quarter, then payment against the MOHU invoice within 15 days of receipt. Data can be amended until 31 March of the following year.
Deadlines
Without authorised declarant status, CBAM goods cannot be released for free circulation. Annual de minimis threshold: 50 tonnes.
The transitional TARIC additional code was usable on the customs declaration where an authorisation application had been filed.
Reg. (EU) 2025/40 applies directly, without national transposition. The PFAS restriction on food-contact packaging applies from this date.
Applies to large and medium operators. A due diligence statement and geolocation data per consignment, with no volume threshold.
The delayed-report function is available until this date; portal access ends on 1 January 2027.
National penalty rules must enter into force by this date at the latest.
Certificate sales open on 1 February 2027, covering the 2026 import year. From then on, at each quarter end, certificates must cover at least 50 percent of the embedded emissions of goods imported since the start of the year, down from the 80 percent originally planned.
The regulation becomes applicable to micro and small enterprises.
Filing the declaration for 2026 imports and surrendering certificates.
Uniform packaging labelling requirements apply; recycling requirements follow from 2030.
A Commission proposal would extend scope to steel- and aluminium-intensive semi-finished and finished goods.
Comparison
The three regulations side by side
Three separate logics, three authorities, three systems. The common ground is the data created at customs clearance.
| Aspect | EPR | CBAM | EUDR |
|---|---|---|---|
| Legal basis | Gov. Decree 80/2023 (III. 14.) | Reg. (EU) 2023/956, as amended by the Omnibus | Reg. (EU) 2023/1115, as amended in 2025 |
| Authority | National waste management authority, MOHU as concession holder | National Climate Protection Authority (NKVH) | NÉBIH |
| System | OKIR gateway and MOHU Partner Portal | CBAM Registry | TRACES NT |
| Who is covered | The first party placing a circular product on the domestic market; through packaging, most importers | Importers of five product groups above 50 tonnes per year | Operators in seven commodities and their derivatives, phased by company size |
| Frequency | Quarterly reporting and fee payment | Annual declaration, with quarterly certificate coverage | Per consignment, before release for free circulation |
| Data needed | Material type and weight by circular product code | Embedded emissions from installation-level data | Plot geolocation and proof of lawful production |
| Main risk | Incorrect KF classification, retroactive fee correction | Missing authorisation, which halts customs clearance | Missing reference number, which halts customs clearance |
This timeline reflects the current text of each instrument. Deadlines and product scope are in motion for all three regulations, so it is worth leaving slack when planning. It does not constitute legal, tax or customs advice.
Check coverage by product scope: Scope Check