Hungary EPR: MOHU registration and fees

Hungary runs a concession, not a compliance market

Most EU packaging EPR regimes work the way Germany's does: the state licenses several competing producer responsibility organisations and you shop between them. Hungary does not. Since 1 July 2023 the entire national waste management system has been run under a single 35-year state concession awarded to MOL, operated through MOHU MOL Hulladékgazdálkodási Zrt. There is one scheme, one price list and one invoice. Choosing a cheaper compliance scheme is not an option that exists in Hungary, which is exactly why sellers arriving from the German or French systems keep looking for a step that is not there.

The concession model also splits the paperwork in a way that trips people up. MOHU is the concessionaire: it holds your service contract, it takes over the waste management obligation, and it issues the quarterly invoice. It is not the regulator. Registration as an obligated producer, the register of circular products, the quarterly data return and enforcement all sit with the national waste management authority, through the state environmental information system OKIR. Two organisations, two portals, two accounts — and you need both before your first Hungarian sale. A MOHU contract with no authority registration behind it is not compliance, and neither is the reverse.

The legal spine is Act CLXXXV of 2012 on Waste, with the operating detail in Government Decree 80/2023 (III. 14.) on extended producer responsibility. Fee rates live in a separate ministerial decree — originally Decree 8/2023 (VI. 2.) EM, most recently amended with effect from 1 October 2025 — which is why rates can move without the underlying rules changing at all.

Who counts as the first placer on the Hungarian market

The obligation follows the phrase first domestic supplier: the first business to supply a circular product in Hungary, or to use one for its own purposes. For a Hungarian manufacturer that is the packer. For imported goods it is whoever brings them in — the importer, the intra-EU acquirer, or the foreign online shop that ships straight to a Hungarian household. That last case has been explicitly in scope since 1 July 2023, and it is the case most cross-border sellers get wrong, because there is no local entity, no warehouse and often no Hungarian VAT registration to make the obligation feel real.

There is no minimum quantity. Hungary sets no tonnage or turnover threshold for EPR: every obligated producer registers, reports and pays regardless of volume, and there is no small-seller carve-out to hide behind. B2B, B2C and own use are treated alike, so pallets to a Hungarian distributor and single parcels to a consumer both count.

Crucially, registration is now possible — and mandatory — without a Hungarian VAT number. Early in the regime, foreign companies without a Hungarian tax number were effectively stuck; that gap was closed, and a foreign distance seller can be entered in the register on the strength of a company extract and a bank document showing the company's name and address (no balances need be visible). In practice almost every foreign producer works through a Hungarian authorised representative, because the authority requires a power of attorney signed by hand — with a company stamp — before it will issue your environmental client ID. That is a physical document workflow, not a web form, and it is the main reason foreign sellers outsource this particular country.

The scope goes well beyond packaging. The same registration covers electrical and electronic equipment, batteries and accumulators, tyres, motor vehicles, office and advertising paper, cooking oils and fats, certain textiles and wooden furniture. If you sell a battery-powered gadget in a cardboard box with a plastic inlay, you have three streams to classify, not one.

Why everyone searches for EPR fees Hungary: the termékdíj overlap

Hungary already had an environmental product fee — the termékdíj, or green tax — long before EPR arrived, administered by the tax authority. When EPR started in mid-2023 the two ran side by side over the same goods, with the EPR fee deductible against the product fee, so producers paid what was effectively the same charge in two directions and filed with two different authorities. That period generated most of the contradictory advice still ranking today, and it is why the fee question is searched more than the registration question.

It has since been simplified, and the date matters. From 1 January 2025 the dual obligation was abolished for the products covered by EPR: packaging, electrical and electronic equipment, batteries, tyres, office paper and advertising paper no longer carry the environmental product fee, only the EPR fee. The green tax was not deleted — it narrowed to products outside the EPR system, such as lubricants, some other plastic and chemical products, and, among packaging items, plastic carrier bags, which remain product-fee liable and are billed by the tax authority rather than MOHU.

The practical reading for a 2026 seller: budget one charge, not two, on your packaging — but if you ship plastic carrier bags into Hungary, check the product fee separately, and treat any guidance written before 2025 that describes paying both as out of date rather than as a rule you have missed.

KF codes: the eight digits that decide your bill

Every circular product is classified with a KF code — an eight-digit code for körforgásos termékek, the Hungarian circular-product nomenclature. The KF code, not your product description, determines the fee rate applied per kilogram, and it is what you report quarterly. It sits alongside the older KT and CsK codes used for the product fee, which is a genuine source of error: they are different code sets and mapping across them by eye does not work.

The work is therefore front-loaded into a catalogue. Before you can report anything you need a line for every item you ship — outer box, mailer, void fill, tape, labels, the product's own retail packaging, and separately the product itself where it is an EEE item, a battery, a textile or wooden furniture — each with its KF code and its unit weight in kilograms. Weights can come from your ERP, from supplier data, from purchase documents or from weighing a sample; whichever you choose, keep the evidence, because the authority verifies the data before MOHU invoices against it.

Get the code wrong and you either overpay silently or underpay and expose yourself to a fine calculated on the shortfall. The spread is wide enough to matter: at the published rates a kilogram of wooden packaging costs 22 HUF and a kilogram of plastic packaging costs 219 HUF — a factor of ten for a classification decision.

Registering step by step

Step 1 — appoint a representative and get your power of attorney signed. A foreign company almost always acts through a Hungarian authorised representative. The power of attorney must be signed by hand and stamped; the authority reviews it, typically within about three working days, and approval carries your environmental client ID (KÜJ). Nothing else can start before this.

Step 2 — register as an obligated producer with the national waste management authority through OKIR. You declare the circular product streams you place on the Hungarian market, and whether you discharge the obligation collectively (the normal route, through the concessionaire) or individually. This registration, not the MOHU contract, is what makes you visible to the regulator.

Step 3 — register on the MOHU Partner Portal and sign the service contract. Enrolment is manual and approval takes roughly a week (checked 2026-08). A foreign company is asked for two documents: a company extract and a bank document showing the company's name and address. You define your KF codes here too, and you receive a MOHU producer identifier that acts as your proof of registration when a marketplace or a Hungarian customer asks.

Step 4 — build the catalogue and file. The registration must be in place before you start the activity; where an activity is already running, the rule of thumb applied in practice is registration within 15 days of starting it. Then keep records — five years is the working retention period cited by practitioners — and file every quarter.

The quarterly cycle and what it costs (checked 2026-08)

The rhythm is the same every quarter: submit the data return to the authority by the 20th day of the month following the quarter — 20 April, 20 July, 20 October and 20 January — reporting kilograms per KF code. The authority verifies the return, MOHU issues an invoice on the verified data, and the invoice is payable within 15 days of receipt. Nothing about this is annual: there is no once-a-year declaration to catch up on, and a quarter you forget is a quarter you have to correct.

On the money: the rates below are the published EPR fees per kilogram. Plastic, paper and metal packaging were left unchanged by the 1 October 2025 amendment; glass, wooden, composite and textile packaging went up. KPMG Hungary's tax alert of 5 January 2026 confirms that the 2026 decree brought no rate increase, so the rates that took effect on 1 October 2025 are the ones in force through 2026 — but additional fee codes were introduced for certain battery types. A worked example: a seller shipping 3,000 kg of corrugated outer boxes and 400 kg of plastic mailers and inlays in a year pays roughly 3,000 × 173 + 400 × 219 ≈ 606,000 HUF, about 1,660 euros at 365 HUF to the euro — before any representative's service fee. For a cross-EU comparison of what the same tonnage costs in other member states, use the packaging EPR fees tool linked below.

Enforcement got teeth in 2025. Since 1 April 2025 the waste management authority can fine a producer that fails to report, fails to pay, or reports false data leading to underpayment; where quantities are under-reported the fine is calculated as the difference between the actual and the declared quantity multiplied by half the unit fee for that stream, payable on top of the fee itself, and practitioners also report a ceiling of 200,000 HUF per individual infringement. Because the fine scales with the shortfall, the expensive failure mode is not a late first registration — it is a mis-coded catalogue quietly under-declaring for eight quarters.

Sources (checked 2026-08)

Legal framework: Act CLXXXV of 2012 on Waste and Government Decree 80/2023 (III. 14.) on the detailed rules of extended producer responsibility, as summarised by the CMS Expert Guide on plastics and packaging laws (Hungary) and by PKF Hungary — first domestic supplier definition, foreign e-commerce in scope from 1 July 2023, MOHU as concessionaire and invoice issuer, the national waste management authority as registrar and verifier, KF codes, the 20th-day quarterly return and the 15-day payment term.

Fee rates: Ministerial Decree 8/2023 (VI. 2.) EM as published and tabulated by Grant Thornton Hungary (plastic 219, paper and cardboard 173, metal 186, wooden 19, composite 168, other packaging 129 HUF/kg); the amendment effective 1 October 2025 (Decree 28/2025 (IX. 22.) EM) as reported by WTS Klient, Accace, LeitnerLeitner and Forvis Mazars (wooden packaging 19 to 22, glass 77 to 107, composite 168 to 191, textile packaging 67 to 148 HUF/kg); KPMG Hungary tax alert of 5 January 2026 — no 2026 rate increase, additional battery fee codes.

Product fee and penalties: Schoenherr and CEE Legal Matters — abolition of the EPR / environmental product charge dual obligation from 1 January 2025, the narrowed green tax (plastic carrier bags among the survivors), and the fine regime from 1 April 2025 calculated on half the unit fee of the under-declared quantity; the 200,000 HUF per-infringement ceiling as reported by amavat and Lovat. Registration mechanics: eprhungary.com (OKIR and MOHU Partner Portal, hand-signed power of attorney, KÜJ issued in about three working days, roughly one week for MOHU approval, company extract plus bank document for foreign companies), Go4Recycling (registration without a Hungarian VAT number, no thresholds), Helpers Finance and amavat (quarterly deadlines, payment terms, KF codes revised for batteries and accumulators from 1 January 2026). MOHU producer information notice, mohu.hu document library. Exchange rate about 365 HUF per euro, early August 2026.

Check your specific case

• Packaging EPR fees per EU country
• WEEE producer EU registration helper
• EU Battery Regulation 2023/1542 compliance

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