One of the most common points of confusion for foreign sellers is that Hungary has two different systems that sound similar: EPR, paid to MOHU, and the older environmental product fee (in Hungarian, termékdíj), paid to the tax authority NAV. Since 1 January 2025 they have largely separated, so for most products you now deal with only one. This guide explains which is which, and what — if anything — you pay twice.
- Two separate systems: EPR is paid to MOHU; the environmental product fee (termékdíj) is paid to NAV.
- Since 1 January 2025, the double obligation was removed for the main streams (packaging, electronics, batteries, tyres, office/advertising paper) — these are now EPR-only.
- The product fee remains only for a narrow residual list (certain "other" petroleum, plastic and chemical products).
- Single-use plastic bags are the one product still subject to both EPR and the product fee (since 15 January 2025).
- For a typical e-commerce seller, the dominant — often only — obligation is EPR.
Two systems, two authorities
Hungary runs two parallel schemes that both aim to make producers pay for the environmental impact of their products, but they are administered separately:
- EPR (Extended Producer Responsibility) — paid to MOHU, the concession operator, based on the weight of what you place on the market, reported quarterly through the OKIR system. This is today the main scheme.
- The environmental product fee (termékdíj) — a tax-style charge paid to NAV, the tax authority, filed through the tax system. This is the older scheme, now much reduced.
Because the names and purposes overlap, sellers often assume they are the same thing, or fear they are being charged twice. Usually they are not.
What changed on 1 January 2025
Until the end of 2024, several product groups carried both obligations, and the EPR fee could be deducted from the product fee (the product fee was largely an administrative burden). From 1 January 2025, the double obligation was removed for the main streams — packaging, electrical and electronic equipment, batteries, tyres, and office/advertising paper. For these, the product-fee filing ended and only EPR remains, paid to MOHU.
What remains under the product fee
The environmental product fee did not disappear entirely. It continues to apply to a narrow residual list — essentially certain "other" petroleum products, "other" plastic products, and "other" chemical products — which are still declared to NAV. For the vast majority of e-commerce sellers, none of these apply.
The plastic-bag exception
There is one notable exception. Since 15 January 2025, single-use plastic bags were reclassified as an "other plastic product" and remain subject to both EPR and the product fee — the only product in that position. If you place single-use plastic carrier bags on the Hungarian market, you should treat them as a special case and check both obligations.
Which one applies to you?
For a typical foreign e-commerce seller shipping packaged goods, electronics or batteries to Hungarian consumers, the answer is straightforward: your obligation is EPR, paid to MOHU. The product fee only becomes relevant if you deal in one of the narrow residual product groups, or in single-use plastic bags. If you are unsure which system a specific product falls under, it is worth checking product by product — the classification, not the general category, decides it.
Frequently asked questions
Is EPR the same as the environmental product fee (termékdíj)?
No. They are two separate systems. EPR is paid to MOHU and is the main obligation for most sellers. The environmental product fee is paid to NAV and now applies only to a narrow residual list of products.
Do I pay both EPR and the product fee?
For the main streams (packaging, electronics, batteries, tyres, office/advertising paper), no — since 1 January 2025 these are EPR-only. The main exception is single-use plastic bags, which remain subject to both.
Which authority do I pay?
EPR is invoiced by and paid to MOHU, based on your quarterly OKIR declaration. The environmental product fee is filed with and paid to NAV, the tax authority.
What happened to the old double obligation?
It was removed for the main streams from 1 January 2025, so those products moved to EPR-only. Previously the EPR fee could be deducted from the product fee; now the two are largely separate systems.