Answers from Agricultural Ministry and National Food Chain Safety Office on Waste and animal by-product proposals for prevention, regulations for the sake of small-scale

The Agricultural Ministry responded in 12 pages in details while National Food Chain Safety Office responded 1,5 pages on the questions we published earlier on our homepage (click here for the questions ). Herewith we made a summary from the responds:

I. Waste Management
1. Determine more precisely waste prevention, waste status
Agricultural Ministry agreed that in the Hungarian legal practice the expression of “discarding” in the definition of waste is difficult to be applied, however the waste definition has objective and subjective meaning so these two well settles all possibilities and further correction to the waste definition is not necessary. However, the Circular Economy Package of the EU intends to amend six EU directives, including the Waste Directive, which involves amendment to the definitions as well. The finalisation of those amendments are expected in 2017.
2. Execution decrees have to be passed regulating prevention, such as deposit, reuse, rules of life-circle analyses
Government revised the potential to introduce compulsory deposit in 2015 and concluded that the costs of its introduction are higher compared to the environmental benefit results.
2013/179/EU Commission Recommendation of April 2013 on the use of common methods to measure and communicate the life cycle environmental performance of products and organisations is a good tool to rule Hungarian regulations, but Ministry stressed none of the Member Sattes made such regulations yet.
Ministry agreed that reuse legislation could help speeding reuse centres in Hungary, however present regulations do not block civil organisations taking over used products for further use. This taking over should not be regarded as handling such products as waste even if it needed to be prepared, so such activity does not require waste management permit.
3. Re-determine reuse regulations from the differentiated small-scale prospective
Ministry is on the opinion that the definition of reuse should not be amended in order to allow such reuse which alters the function of the product since such change in function is apparent, since the altered product also serves consumer needs as original product did so. And further such amendment would increase administrative burdens.
4. A differentiated end of waste rules, prevention rules should be passed on European level (as present regulations allow so) in relation to specific material/product groups
Ministry answered that in the preparation works of the Circular Economy Package it was unravel that many Members States are struggling to enact EoW rules, however there are provisions in the Waste Act in paragraphs 9 (1), 88 (29) which settles EoW rules.
5. Waste management rules has to determine lighter rules for small-scale producers in a differentiated manner
Waste Directive allows conduct certain activities without permit if regulation contains the most important parameters. However such activities are rather limited so Ministry’s goal, generally, is to radically simplify permitting procedure.
II. Product Fee
6. We propose to exempt all artisan, handmade products used for packaging purposes, as artisan soap makers were already exempted.
Ministry responded that even present regulations do not classify folk art pottery products, graven  or painted wooden boxes as packaging means, even if they can be used for packaging purposes, since the fundamental elements of the product, which is the basis of the Custom Tariff classification, is the artisan element and not the packaging purpose. In the case such product is propeorly classified under the Custom Tariff, it is not subject to product fee. Taking as example: the wooden fancy good is classified under Custom Tariff 4420 which is not listed as subject to product fee payment.
III. Animal by-products
7. Adopting lighter rules for wool and animal hair treated on traditional way, even to accept traditional treatment as animal by-product treatment
Office just quoted article 23 of 1069/2009/EC according to which handling wool must be registered.
Ministry said that no derogation is allowed according to EU regulations.
IV. Food and cosmetics (soap)
8. Upon the workshop proposal we support that such product produced according to food regulations should be allowed to use for cosmetic purposes.
Both Ministry and Office said that they do not have competence on cosmetic products even if made from food. Cosmetic products, even made out of food, are subject to 1223/2009/EC regulation.
Kislépték is still on the opinion that if a food produced and sold according to food and food hygiene regulations there is no good reason to order chemistry examination for making out of it cosmetic product and to order the producer to have chemistry education. Kislépték shall request a statement from Brussels. If you agree with our goals please donate our work. Please make payment to our bank account HU50 1174 2049 2034 3394 0000 0000, OTP Bank SWIFT code: OTPVHUHB.

V. Food waste
9. We recognise the potential risk of slop, however, we propose to consider on marginal (and not on international) level the following possibilities:
Both Ministry and Office responded that slop with animal content is strictly forbidden to use for any purposes and their treatment requires permit because of the high pest risk.

Ministry mentioned that the Good Hygiene Practice of Catering already provides guidelines for the charity use of rest food. Any civil organisation uses them for charity reasons are regarded to be food business operators.

▪ Answers from Agricultural Ministry respond

▪ National Food Chain Safety Office

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