What is Hungary EPR Batteries

Hungary's battery EPR framework combines the directly applicable Regulation (EU) 2023/1542 — the EU Battery Regulation — with a distinct national EPR system introduced by Government Decree 80/2023 (III. 14.), which came into force on 1 July 2023. This national system replaced the previous environmental product fee structure and established a concession-based EPR framework covering batteries, packaging, textiles, electrical and electronic equipment, and wooden furniture.

The national legal basis includes Government Decree 80/2023 (the EPR Decree), which sets the detailed rules for producer registration, reporting, and fee payment. In January 2025, Act LXXXIX of 2024 introduced a series of modifications that eliminated a dual compliance system that had operated since 2023, under which producers were simultaneously subject to both the old environmental product fee and the new EPR fee.

The sole concession holder responsible for organising, operating, and financially managing Hungary's EPR framework is MOHU MOL Hulladékgazdálkodási Zrt. (MOHU). All producers must register with MOHU and report through OKIR — Hungary's national environmental information system — on a quarterly basis. The supervisory authority is the National Waste Management Authority (NWMA), which operates within the Ministry of Energy.

Does This Apply to E-Commerce & Online Sales

Yes. Hungary's EPR framework explicitly captures online retailers and distance sellers. The obligation applies from the first kilogram placed on the Hungarian market — there are no volume thresholds or exemptions for small volumes or companies without a Hungarian VAT number.

A foreign brand selling batteries or battery-containing products directly to Hungarian consumers via an online store is treated as a producer under Government Decree 80/2023 and must comply with all registration, reporting, and fee payment obligations. Foreign businesses selling directly to Hungarian consumers are required to appoint a Hungarian authorised representative to manage these obligations on their behalf.

All vendor invoices for products subject to EPR — including batteries — must include the statement: "The seller is liable for the EPR fee." This is a mandatory invoicing requirement under the EPR Decree.

Who is the "Producer" under Hungary EPR?

Under Government Decree 80/2023, the obligated party is the first placer on the Hungarian market — the entity that first makes the battery available on the Hungarian market in the course of commercial activity. This covers:

1. Manufacturers established in Hungary who produce and sell batteries domestically.
2. Importers bringing batteries into Hungary from outside Hungary for the first time under their own name.
3. Private label owners whose brand name appears on batteries manufactured by third parties.
4. Foreign brands selling directly to Hungarian consumers via e-commerce, where the foreign seller is the first to place the product on the Hungarian market.
5. Foreign producers placing products on the Hungarian market via an authorised representative.

Where a Hungarian distributor or importer first places a battery on the Hungarian market, that entity assumes the producer obligation. Where the foreign brand is the first placer — including through direct online sales — the foreign brand holds the obligation and must appoint a Hungarian authorised representative.

Who Must Register for EPR Batteries in Hungary

All producers must register with both of the following before placing batteries on the Hungarian market:

1. MOHU Partner Portal — MOHU's electronic platform where producers complete EPR producer registration, define their circular products using KF codes, and receive a MOHU producer ID. The MOHU producer ID is proof of EPR registration in Hungary.

2. OKIR / OKIRKAPU — Hungary's national environmental information system, maintained by the National Waste Management Authority (NWMA). All quarterly declarations are submitted through OKIR, and the data submitted forms the basis for MOHU invoices.

Registration must be completed before placing products on the Hungarian market. Hungary allows companies to begin selling after submitting their registration, on the condition that any missing reports or fees are subsequently reconciled. However, operating without registration exposes companies to fines and potential suspension of market access.

Hungary EPR Battery Registration Threshold

Hungary's EPR framework applies from the first kilogram. There are no volume thresholds or turnover exemptions. All producers placing batteries on the Hungarian market — regardless of size, volume, or whether they hold a Hungarian VAT number — are subject to the same registration, reporting, and fee payment obligations.

This is a strict approach compared to some other EU Member States. Even a foreign company sending a single shipment of battery-containing products to a Hungarian consumer falls within scope.

Records must be maintained for at least five years for audit purposes by the NWMA.

Batteries Covered (and Excluded)

Hungary's national EPR system covers batteries and accumulators as a product category under Government Decree 80/2023, classified using 8-digit KF codes (circular product codes). From 1 January 2026, KF codes for batteries and accumulators are being revised, potentially requiring updates to product classifications, buyer declarations, and takeover contracts.

The EU Battery Regulation's five categories also apply in Hungary from 18 August 2025:

Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys.

Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles.

Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Fee increases for vehicle batteries took effect from 1 October 2025.

Industrial batteries Batteries used in industrial applications and stationary energy storage. Individual fulfilment — instead of collective fulfilment through MOHU — is available for industrial and automotive batteries where the product qualifies under the EPR Decree.

Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles.

Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely under the EU Battery Regulation
• Batteries in nuclear installations — excluded

Producer Responsibility Organization (PRO)

MOHU MOL Hulladékgazdálkodási Zrt. (MOHU) is the sole concession holder for Hungary's EPR system. By law, MOHU is treated as the organisation fulfilling the EPR obligation on behalf of all collective producers. No separate contract between the producer and MOHU is required for collective fulfilment — registration on the MOHU Partner Portal and OKIR constitutes the compliance arrangement.

Individual fulfilment — where the producer manages their own waste management system — is available only for specific product groups. For batteries, MOHU explicitly notes eligibility for industrial and automotive batteries where the product qualifies under the EPR Decree. For portable and consumer batteries, collective fulfilment through MOHU is the standard route.

MOHU issues quarterly invoices to producers based on the data submitted through OKIR. Invoices must be paid within 15 days of issuance.

EPR Registration in Hungary

The registration process for battery producers in Hungary is as follows:

1. Determine the correct 8-digit KF code(s) for your battery products. This step requires careful classification — errors in KF codes lead to reporting errors and potential fines.
2. If established outside Hungary, appoint a Hungarian authorised representative before initiating any registration.
3. Create an account on the MOHU Partner Portal and complete EPR producer registration, providing company details, product information, and KF code assignments. Sign the MOHU service contract and pay the one-off enrolment fee.
4. Receive your MOHU producer ID — proof of EPR registration in Hungary.
5. Register in OKIR / OKIRKAPU, Hungary's national environmental information system, which is mandatory for submitting quarterly declarations.
6. Submit quarterly declarations through OKIR by the 20th day of the month following each quarter.
7. Pay MOHU invoices within 15 days of issuance.
8. Maintain KF-code-based records for at least five years for NWMA audit purposes.

Note: From 1 January 2026, KF codes for batteries are being revised. Producers must update their product classifications and any associated buyer declarations or takeover contracts.

Authorized Representative

Foreign companies selling batteries or battery-containing products directly to Hungarian consumers are required by law to appoint a Hungarian authorised representative (meghatalmazott képviselő). This is not optional — it is a mandatory requirement under the Hungarian EPR framework for all non-resident producers.

The authorised representative must hold a Hungarian tax number and acts as the official liaison with MOHU and the NWMA. The representative submits quarterly reports, manages fee payments, and receives official correspondence from the NWMA on behalf of the foreign producer. Ultimate legal responsibility remains with the foreign seller — outsourcing to a representative does not transfer liability.

The MOHU Partner Portal registration can only be completed by or through the authorised representative for non-resident companies.

What Data Must Be Reported

Producers must submit quarterly declarations through OKIR / OKIRKAPU covering:

• Total weight (kilograms) of batteries placed on the Hungarian market during the quarter, classified by 8-digit KF code
• Battery category breakdown aligned to both the Hungarian KF code system and, from August 2025, the five EU Battery Regulation categories
• Supporting documents for batteries in specific categories, as defined in Annex 3 of Government Decree 80/2023
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities, as required under the EU Battery Regulation

Data entered in OKIR forms the basis for MOHU invoices. Any inaccuracies or underreporting are subject to fines from 1 April 2025 onwards, calculated as the difference between declared and actual quantities multiplied by half the applicable unit rate.

Quarterly reporting data may be amended from 1 January to 30 April of the following year.

First Reporting Period & EPR Reporting Deadlines

Hungary's national EPR system for batteries commenced on 1 July 2023. The EU Battery Regulation's full EPR obligations took effect from 18 August 2025. Key dates and deadlines:

• 1 July 2023: Hungary's national EPR framework comes into force. Batteries included in scope from this date.
• Q3 2023: First reporting period under the national EPR system.
• 20th of the month following each quarter: Quarterly declaration deadline via OKIR.
  • Q1 (January–March): submit by 20 April
  • Q2 (April–June): submit by 20 July
  • Q3 (July–September): submit by 20 October
  • Q4 (October–December): submit by 20 January
• 15 days after invoice issuance: MOHU invoice payment deadline.
• 1 April 2025: Stricter enforcement rules for inaccurate or missing declarations introduced.
• 1 October 2025: Fee increases for vehicle batteries take effect.
• 1 January 2026: KF codes for batteries revised. Producers must update product classifications.
• 30 April (annual): Deadline to amend quarterly reporting data from the previous year.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side, up to a maximum of 5 × 5 cm.

Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb.

Capacity marking Portable and rechargeable batteries must display capacity information.

QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027.

CE marking Mandatory from 18 August 2024.

Mandatory invoice statement All vendor invoices for batteries subject to EPR must include the text: "The seller is liable for the EPR fee." This is a Hungarian-specific requirement under Government Decree 80/2023.

Language requirements Consumer-facing information on batteries sold in Hungary must be provided in Hungarian.

Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Hungary.

EPR Eco Fees & Eco-Modulation

Hungary's EPR fees for batteries are set by the EPR Decree and administered by MOHU. Fees are calculated as the product of the weight (kilograms) of batteries placed on the market and the unit fee per KF code category. MOHU issues invoices quarterly based on OKIR declarations.

Key fee developments:

• Fee increases for vehicle batteries took effect from 1 October 2025, first applying to products placed on the market in Q4 2025.
• The EPR fee paid to MOHU can be deducted when submitting environmental product fee declarations to the Hungarian tax authority, avoiding double payment.

Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all EU Member States. Hungary's specific eco-modulation framework under the new EU Battery Regulation has not been separately published as of April 2026, as the fee structure is primarily governed by the national KF code system.

Risks, Penalties & Common Mistakes

1. Failing to register before placing batteries on the market. Registration with both MOHU and OKIR is mandatory before first sale. If NWMA orders a producer to pay a waste management fine for failure to register and the producer still fails to comply, the NWMA may suspend market access for the product until registration is completed and outstanding fees are paid.
2. Not appointing a Hungarian authorised representative. Foreign companies must appoint a representative before registering. Operating without one is a compliance breach.
3. Incorrect KF code classification. KF codes must be correctly assigned to each battery product. Errors cause reporting inaccuracies, which are subject to fines from April 2025. The 1 January 2026 KF code revision requires all producers to review and update their classifications.
4. Missing the quarterly reporting deadline. Declarations must reach OKIR by the 20th of the month following each quarter. Late or missing declarations attract penalties.
5. Missing the 15-day MOHU invoice payment deadline. MOHU invoices must be paid within 15 days of issuance. Late payment is a breach of the service contract.
6. Omitting the mandatory invoice statement. All vendor invoices for batteries must include "The seller is liable for the EPR fee." Missing this is a non-compliance with the EPR Decree.
7. Underreporting quantities. From 1 April 2025, fines for underreporting are calculated as the difference between declared and actual quantities multiplied by half the applicable unit rate.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Hungarian consumers — the obligation applies from the first kilogram, regardless of volume.
2. Identify and appoint a Hungarian authorised representative before initiating any registration or sales activity.
3. Determine the correct 8-digit KF codes for your battery products, and prepare for the KF code revision effective 1 January 2026.
4. Register on the MOHU Partner Portal (mohu.hu), sign the service contract, and receive your MOHU producer ID.
5. Register in OKIR / OKIRKAPU and set up your quarterly reporting workflow aligned to the 20th-day deadline.
6. Ensure all vendor invoices for batteries include the mandatory statement: "The seller is liable for the EPR fee."
7. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Hungarian-language consumer instructions.
8. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

Is battery EPR mandatory in Hungary?

• Yes. Hungary's national EPR framework for batteries has been mandatory since 1 July 2023 under Government Decree 80/2023. The EU Battery Regulation (2023/1542) additionally applies directly from 18 August 2025. All producers placing batteries on the Hungarian market must register with MOHU and OKIR, report quarterly, and pay EPR fees — from the first kilogram, with no volume threshold.

Do foreign brands selling online into Hungary need to register?

• Yes. Foreign e-commerce sellers are explicitly captured as producers under Hungary's EPR Decree. They must appoint a Hungarian authorised representative before registering with MOHU and OKIR. The representative manages all filings, fee payments, and NWMA correspondence on behalf of the foreign producer, though legal responsibility remains with the seller.

What is the quarterly reporting deadline?

• Quarterly declarations must be submitted through OKIR by the 20th day of the month following the reporting quarter: 20 April (Q1), 20 July (Q2), 20 October (Q3), 20 January (Q4). MOHU then issues an invoice based on the submitted data, which must be paid within 15 days.

What are KF codes and why do they matter?

• KF codes are 8-digit circular product codes used in Hungary to classify products subject to EPR fees, including batteries. All reporting and fee calculations are based on KF code assignments. Incorrect codes result in reporting errors subject to fines. KF codes for batteries are being revised from 1 January 2026, requiring producers to update their product classifications before that date.

Is there a minimum volume threshold for Hungarian battery EPR?

• No. Hungary's EPR obligation applies from the first kilogram of batteries placed on the market. There are no volume thresholds, turnover exemptions, or exceptions for companies without a Hungarian VAT number. Even a single shipment of battery-containing products to a Hungarian consumer triggers the obligation.

What is Hungary EPR Textile

Hungary introduced mandatory Extended Producer Responsibility for textiles on 1 July 2023 under Government Decree 80/2023 (III. 14.) — the EPR Decree — which established a unified, concession-based EPR framework covering eleven categories of circular products, including textiles. The textile-specific rules were further defined by Government Decree 275/2023 (VI. 29.) on Textile-Waste Management Activities, issued under the umbrella of the EPR Decree. The system replaced the previous environmental product fee structure. In January 2025, Act LXXXIX of 2024 introduced amendments that eliminated a dual compliance system under which producers had simultaneously been subject to both the old environmental product fee and the new EPR fee. The sole concession holder responsible for organising, operating, and financially managing Hungary's EPR system is MOHU MOL Hulladékgazdálkodási Zrt. (MOHU), which was granted a 35-year government concession. All producers register with MOHU and report through OKIR — Hungary's national environmental information system — on a quarterly basis. The supervisory authority is the National Waste Management Authority (NWMA), which operates within the Ministry of Energy and publishes lists of compliant producers. From April 2025, Hungary tightened enforcement of its textile EPR rules. Companies that fail to submit quarterly reports or pay EPR fees on time face administrative fines in addition to outstanding fee obligations.

Does This Apply to E-Commerce & Online Sales

Yes. Hungary's EPR framework explicitly captures online retailers and distance sellers. A foreign brand selling clothing, footwear, or household textiles directly to Hungarian consumers via an online store is treated as a producer under Government Decree 80/2023 and must comply with all registration, reporting, and fee payment obligations — from the first kilogram, with no volume threshold. Foreign webshops placing circular products on the Hungarian market must fulfil their EPR obligations exclusively through a domestic authorised representative. This is a mandatory requirement and not optional for non-resident sellers. All vendor invoices for products subject to EPR — including textiles — must include the statement: "The seller is liable for the EPR fee." This is a mandatory invoicing requirement under the EPR Decree.

Who is the "Producer" under Hungary EPR

Under Government Decree 80/2023, the obligated party is the first placer on the Hungarian market — the entity that first makes the textile product available on the Hungarian market in the course of commercial activity. This covers:

1. Manufacturers established in Hungary who produce and sell textiles domestically.
2. Importers bringing textiles into Hungary from outside Hungary for the first time under their own name.
3. Private label owners whose brand name appears on textiles manufactured by third parties.
4. Foreign brands selling directly to Hungarian consumers via e-commerce, where the foreign seller is the first to place the product on the Hungarian market.
5. Foreign producers placing products on the Hungarian market via an authorised representative.

Where a Hungarian distributor or importer first places a textile on the Hungarian market, that entity assumes the producer obligation. Where the foreign brand is the first placer — including through direct online sales — the foreign brand holds the obligation.

Who Must Register for EPR Textiles in Hungary

All producers must register with both of the following before placing textiles on the Hungarian market: 1. MOHU Partner Portal — MOHU's electronic platform where producers complete EPR producer registration, define their circular products using KF codes, and receive a MOHU producer ID. The MOHU producer ID is proof of EPR registration in Hungary. 2. OKIR / OKIRKAPU — Hungary's national environmental information system maintained by the National Waste Management Authority (NWMA). All quarterly declarations are submitted through OKIR, and the data submitted forms the basis for MOHU invoices. Registration must be completed before placing products on the Hungarian market. Hungary allows companies to begin selling after submitting their registration, provided that missing reports or fees are subsequently reconciled.

Hungary EPR Textile Registration Threshold

Hungary's EPR framework applies from the first kilogram. There are no volume thresholds or turnover exemptions for textiles. All producers placing textiles on the Hungarian market — regardless of size, volume, or whether they hold a Hungarian VAT number — are subject to the same registration, reporting, and fee payment obligations. Selling even one garment or pair of shoes triggers the obligation. The only size-related relief is MOHU's small-fee regime: if the total annual EPR fee across all product streams is HUF 50,000 or less, declarations move from quarterly to annual frequency. This reduces administrative burden for very small producers but does not exempt them from registration or fee payment. Records must be maintained for at least five years for audit by the NWMA.

Textiles Covered (and Excluded)

Hungary's textile EPR scope is defined in Annex 1, point 1.10 of Government Decree 80/2023, covering goods classified under KF codes KF 1.10.xx. The following categories are in scope:

• Clothing (Apparel)All apparel placed on the Hungarian market, including outerwear, underwear, sportswear, workwear, and children's clothing.
• FootwearAll footwear sold to consumers in Hungary, regardless of material.
• Household TextilesHousehold linen, curtains, blankets, and carpets are explicitly included in the Hungarian textile EPR scope.
• Clothing AccessoriesFashion accessories made of textile materials — including bags, belts, hats, and scarves — fall within scope under the KF 1.10.xx category.
• Sales PackagingThe packaging accompanying textile products — including boxes, poly-bags, and hang-tags — is also subject to EPR obligations under the packaging stream and must be reported separately under the applicable packaging KF codes.

Exclusions follow the general structure of Government Decree 80/2023. Second-hand textiles being resold and custom-made tailored items are generally outside the scope of EPR obligations.

Producer Responsibility Organization (PRO)

MOHU MOL Hulladékgazdálkodási Zrt. (MOHU) is the sole concession holder for Hungary's EPR system, including textiles. By law, MOHU is treated as the organisation fulfilling the EPR obligation on behalf of all collective producers. No separate PRO membership contract is required beyond registration on the MOHU Partner Portal — this registration constitutes the compliance arrangement. MOHU operates the nationwide collection infrastructure, audits member data, and forwards statistics to the NWMA. MOHU issues quarterly invoices to producers based on the data submitted through OKIR. Invoices must be paid within 15 days of issuance. Individual fulfilment — where the producer manages their own waste management system outside MOHU — is theoretically available under the EPR Decree but is not a practical option for most textile producers. Collective fulfilment through MOHU is the standard route for all textile categories.

EPR Registration in Hungary

The registration process for textile producers in Hungary is as follows:

1. Identify the correct 8-digit KF codes (KF 1.10.xx) for each of your textile product categories — clothing, footwear, household linen, accessories. Incorrect KF code assignment leads to reporting errors and potential penalties.
2. If established outside Hungary, appoint a Hungarian authorised representative before initiating any registration. Foreign webshops must fulfil EPR obligations exclusively through a domestic representative.
3. Create an account on the MOHU Partner Portal (mohu.hu), complete EPR producer registration, assign KF codes to your products, and sign the MOHU service contract.
4. Receive your MOHU producer ID — proof of EPR registration in Hungary.
5. Register in OKIR / OKIRKAPU — mandatory for submitting quarterly declarations.
6. Submit quarterly declarations through OKIR by the 20th day of the month following each quarter.
7. Pay MOHU invoices within 15 days of issuance.
8. Maintain KF-code-based records for at least five years for NWMA audit purposes.

Authorized Representative

Foreign companies selling textiles directly to Hungarian consumers are required by law to appoint a Hungarian authorised representative (meghatalmazott képviselő). This is a mandatory requirement — foreign webshops must fulfil their EPR obligations exclusively through a domestic representative, as stated explicitly in Government Decree 80/2023 and confirmed by the Hungarian tax authority. The authorised representative must hold a Hungarian tax number and acts as the official liaison with MOHU and the NWMA. The representative submits quarterly reports, manages fee payments, and receives official correspondence from the NWMA. A written authorisation is required. Ultimate legal responsibility remains with the foreign brand — appointing a representative does not transfer liability. If the representative submits incorrect data or misses deadlines, the penalties apply to the seller.

What Data Must Be Reported

Producers must submit quarterly declarations through OKIR / OKIRKAPU covering:

• Total weight (kilograms) of textile products placed on the Hungarian market during the quarter, classified by 8-digit KF code (KF 1.10.xx subcategories for clothing, footwear, household textiles, accessories)
• Supporting documents for products in specific categories, as defined in Annex 3 of Government Decree 80/2023
• Separate reporting for sales packaging accompanying textile products, classified under the relevant packaging KF codes

Data entered in OKIR forms the basis for MOHU invoices. Any inaccuracies or underreporting are subject to fines from 1 April 2025, calculated as the difference between declared and actual quantities multiplied by half the applicable unit rate. Quarterly reporting data may be amended from 1 January to 30 April of the following year.

First Reporting Period & EPR Reporting Deadlines

Hungary's national EPR system for textiles commenced on 1 July 2023. The first reporting period was Q3 2023. Key recurring deadlines:

• Q1 (January–March): Submit declaration by 20 April; pay MOHU invoice within 15 days
• Q2 (April–June): Submit by 20 July; pay within 15 days
• Q3 (July–September): Submit by 20 October; pay within 15 days
• Q4 (October–December): Submit by 20 January; pay within 15 days
• 1 January to 30 April (annual): Window to amend quarterly declarations from the previous year
• Small-fee producers (total annual EPR fee ≤ HUF 50,000): annual declaration instead of quarterly

Labels & Marketing Claims

Hungary does not impose EPR-specific product labelling requirements for textiles equivalent to France's Triman logo obligation. However, the following apply:

• Fibre Composition LabellingAll textile products sold in Hungary must carry fibre composition labels under EU Regulation (EU) No 1007/2011. Labels must be in Hungarian.
• Language RequirementsConsumer-facing product information — including care instructions, fibre content, and size labelling — must be in Hungarian for products sold to Hungarian consumers.
• Mandatory Invoice StatementAll vendor invoices for textiles subject to EPR must include the text: "The seller is liable for the EPR fee." This is a mandatory requirement under Government Decree 80/2023. Some sources indicate the English version is also acceptable: "The seller is liable for paying the extended producer responsibility fee."
• Environmental ClaimsThe Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated environmental claims — including vague terms such as "eco-friendly" or "sustainable" — will be prohibited across the EU including Hungary.

EPR Eco Fees & Eco-Modulation

Hungary's textile EPR fees are weight-based, calculated per kilogram of textile products placed on the market. The fee rate for textiles:

• 145 HUF per kilogram — rate applicable from 2023
• 164 HUF per kilogram — increased rate from 2025, first applying to Q4 2025 market placements

MOHU calculates fees based on quarterly OKIR declarations and issues invoices accordingly. Fees are applied uniformly per kilogram across textile categories using the KF 1.10.xx code structure, without differentiation by fibre type or recyclability under the current framework. Eco-modulation — adjusting contributions based on product environmental performance — is required under the forthcoming EU Waste Framework Directive framework for textile EPR. Hungary's specific eco-modulation criteria for textiles have not been separately published as of April 2026.

Risks, Penalties & Common Mistakes

1. Failing to register before placing textiles on the market. Registration with both MOHU and OKIR is mandatory before first sale. If the NWMA orders a producer to pay a fine for failure to register and the producer still fails to comply, the NWMA may suspend market access for the product until registration is completed and outstanding fees are paid.
2. Not appointing a Hungarian authorised representative. Foreign webshops must fulfil obligations exclusively through a domestic representative. Operating without one is a compliance breach under Government Decree 80/2023.
3. Incorrect KF code classification. KF codes must be correctly assigned per product category. Errors lead to reporting inaccuracies subject to penalties. Clothing, footwear, household linen, and accessories each have distinct KF 1.10.xx subcodes.
4. Missing the quarterly reporting deadline. Declarations must reach OKIR by the 20th of the month following each quarter. From April 2025, late or missing declarations attract administrative fines.
5. Missing the 15-day MOHU invoice payment deadline. MOHU invoices must be paid within 15 days of issuance.
6. Omitting the mandatory invoice statement. All vendor invoices for textiles must include "The seller is liable for the EPR fee." Missing this is a non-compliance with the EPR Decree.
7. Not reporting packaging separately. Sales packaging accompanying textile products — boxes, poly-bags, hang-tags — must be reported and fees paid under the packaging stream, separately from the textile stream.

What E-Commerce Sellers Should Do Now

1. Confirm whether your business places textiles — clothing, footwear, household linen, or accessories — on the Hungarian market, including via direct e-commerce to Hungarian consumers.
2. Identify and appoint a Hungarian authorised representative before initiating any registration or sales activity.
3. Determine the correct 8-digit KF codes (KF 1.10.xx) for your textile product categories.
4. Register on the MOHU Partner Portal (mohu.hu), sign the service contract, and obtain your MOHU producer ID.
5. Register in OKIR / OKIRKAPU and set up your quarterly reporting workflow aligned to the 20th-day deadline.
6. Ensure all vendor invoices for textiles include the mandatory statement: "The seller is liable for the EPR fee."
7. Check whether your total annual EPR fee qualifies for the small-fee regime (≤ HUF 50,000 total across all streams), which allows annual instead of quarterly declarations.
8. Report sales packaging accompanying your textiles separately under the applicable packaging KF codes.

FAQ

Is textile EPR mandatory in Hungary?

• Yes. Hungary's textile EPR has been mandatory since 1 July 2023 under Government Decree 80/2023 and Government Decree 275/2023. All producers placing clothing, footwear, household textiles, and accessories on the Hungarian market must register with MOHU and OKIR, report quarterly, and pay EPR fees — from the first kilogram, with no volume threshold or turnover exemption.

Do foreign brands selling online into Hungary need to register?

• Yes. Foreign e-commerce sellers are explicitly captured as producers under Hungary's EPR Decree. They must appoint a Hungarian authorised representative before registering with MOHU and OKIR. Foreign webshops must fulfil their EPR obligations exclusively through a domestic representative — this is a mandatory legal requirement, not a recommendation.

What is the current EPR fee rate for textiles?

• The textile EPR fee is 164 HUF per kilogram from 2025, increased from 145 HUF/kg at scheme launch. The fee is applied per kilogram of textiles placed on the Hungarian market, based on quarterly OKIR declarations. MOHU issues invoices based on submitted data, payable within 15 days.

What textile products are covered by the Hungarian scheme?

• The scope covers apparel, footwear, clothing accessories, household linen, curtains, blankets, and carpets — as defined in Annex 1, point 1.10 of Government Decree 80/2023. Sales packaging accompanying these products must also be reported separately under the packaging stream.

Is there a minimum volume threshold for Hungarian textile EPR?

• No. The obligation applies from the first kilogram — selling even one garment triggers registration and reporting requirements. The only size-related relief is the small-fee regime: if total annual EPR fees across all streams are HUF 50,000 or less, declarations may be submitted annually rather than quarterly.