Hungary EPR

What is Hungary EPR Packaging

Extended Producer Responsibility (EPR) in Hungary is a waste management system that makes producers financially responsible for the collection and recycling of circular products. This framework, which significantly changed on July 1, 2023, is primarily governed by Government Decree 80/2023 (III. 14.). It transitions Hungary toward a concession-based model where a single entity manages the waste stream for the entire country.

Does this apply to e-commerce & online sales

Yes. Distance sellers and online marketplaces located outside of Hungary that ship packaged goods directly to Hungarian end-users (B2C) are fully subject to EPR rules. This includes responsibility for both the product packaging and any transport/shipping materials (e.g., mailer bags, cardboard boxes) used to deliver the items.

Who is the “producer” under Hungary EPR?

In the Hungarian system, the "producer" is the entity that first places a circular product or packaging on the domestic market. This includes:

1. Manufacturers based in Hungary.

2. Importers who bring packaged products into Hungary.

3. Foreign webshops and distance sellers shipping directly to Hungarian consumers.

4. Entities using circular products for their own business activities (e.g., self-import of equipment).

Who must register for EPR packaging in Hungary

Registration is a mandatory two-step process. Producers must register with:

1. MOHU MOL Hulladékgazdálkodási Zrt. (MOHU): The national concession company that manages the waste collection system.

2. National Waste Management Authority (OKIR): The governmental registry for environmental data.

Registration must be completed before any products are placed on the market.

Hungary EPR Packaging Registration Threshold

Hungary has no de-minimis threshold for registration. The obligation to register, report, and pay fees begins with the first parcel or item sent to a Hungarian customer. While there are no volume-based exemptions for registration, a "small-fee" regime exists: if a producer's total annual EPR fee is below 50,000 HUF, they may be permitted to switch from quarterly to annual reporting.

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Packaging Covered (and Excluded)

The EPR system covers all categories of packaging, including:

• Sales packaging (primary)

• Grouped packaging (secondary)

• Transport packaging (tertiary)

Materials include plastic, paper, cardboard, metal, glass, wood, and composites. Specific materials like advertising media paper and office paper also fall under this regime.

Producer Responsibility Organization (PRO)

Unlike other EU countries with multiple competing PROs, Hungary utilizes a centralized concession system managed by MOHU. All producers are required to sign a service contract with MOHU, which acts as the sole operator for the collective fulfillment of waste management obligations.

EPR Registration in Hungary

1. MOHU Partner Portal: Create an account on the MOHU platform and sign the concession contract.

2. OKIR Registration: Submit an application to the National Waste Management Authority via the OKIR system to receive a registration number.

3. KF Code Assignment: Map your products to the correct KF codes (Circular Product Codes) required for reporting.

Authorized Representative

Foreign companies (non-residents) that do not have a registered office in Hungary must appoint a local Authorized Representative to fulfill their EPR obligations. This representative acts as the legal liaison with MOHU and the National Waste Management Authority, ensuring that reports are submitted and fees are paid on time.

What Data Must Be Reported

Reporting is highly granular and requires tracking:

• Total weight in kilograms.

• KF Codes (Circular Product Codes) identifying material and category.

• The quantity of each packaging type placed on the market.

• Records must be maintained for at least 5 years.

First Reporting Period & EPR Reporting Deadlines

Reporting is typically conducted quarterly. Data must be submitted by the 20th day of the month following the end of the quarter:

• Q1: April 20

• Q2: July 20

• Q3: October 20

• Q4: January 20

Labels & Marketing Claims

Hungary follows standard EU packaging identification codes (e.g., 01 PET, 20 PAP). Additionally, producers participating in the Deposit Return System (DRS) for beverage containers must use the mandatory "Vigyél Vissza" (Take Me Back) logo and specialized barcodes.

EPR Eco Fees & Eco-Modulation

Fees are calculated per kilogram based on the material type. As of August 12, 2026, new eco-modulation rules will link fees directly to the recyclability of the packaging. Easily recyclable materials will receive lower rates, while problematic materials (red-rated) will face significant surcharges.

Risks, Penalties & Common Mistakes

Non-compliance in Hungary is strictly monitored:

• Fines: Can reach half of the unit fee multiplied by the unreported quantity.

• Retroactive Fees: Failure to register results in back-dated EPR fee requirements for all historical sales.

• Trade Suspension: The authority may suspend the sale of products that are not compliant.

• Common Mistake: Assuming that VAT registration via OSS exempts a company from local EPR registration.

What E-Commerce Sellers Should Do Now

1. Audit your packaging to determine KF code classifications.

2. Appoint a local Authorized Representative in Hungary.

3. Register on the MOHU Partner Portal and with the OKIR registry.

4. Implement a system to track sales weight by quarter for accurate reporting.

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FAQ

Is EPR mandatory for online shops shipping from abroad?

• Yes, foreign distance sellers must comply from the first shipment.

Can I report once a year?

• Only if your total annual fees are below 50,000 HUF and you receive permission.

Do I need an Authorized Representative?

• Yes, for foreign companies without a local Hungarian seat, an AR is legally required.

Is the Green Dot symbol required?

• No, it is not mandatory in Hungary.

What is the difference between EPR and Green Tax?

• Since July 2023, the EPR fee has largely replaced the previous environmental product fee for many categories, though administration for both may still overlap.