How EPR Works in Hungary — A Practical Guide for Cross-Border Sellers

Three authorities, one continuously cross-checked system

Hungarian EPR is split between three institutions:

• MOHU is a private concessionaire — the only company authorized by the Hungarian state to operate the EPR system. MOHU issues invoices, collects fees and manages the waste streams.
• The waste-management authority maintains the OKIR system (Hungary's national environmental information system), where producers submit their quarterly declarations. This is the data backbone of the whole system.
• NAV, the Hungarian tax authority, was the central authority before 2023 and still handles the residual environmental product fee, which today covers only a narrow list of products.

The authority reconciles declarations against customs, VAT and other data on an ongoing basis, so quantities that don't add up across systems are flagged.

What is genuinely different about Hungary

Most EU countries operate some form of EPR, but Hungary's system is unusually granular in two respects.

Reporting by material — separately, line by line

A typical EPR declaration in Hungary is not a single "plastic packaging: X kg" entry. Materials are broken down by type — plastics into PET, PP, PS, LDPE, HDPE and further categories; paper, glass, metal, wood and composites each have their own categories too. Each material is identified with its own KF code (the 8-digit circular-product code) for classification and record-keeping. Note that the fee rate is set per material stream — for example, a single rate applies to plastic packaging as a whole — but you must still classify each item to the correct code.

The classification is not always intuitive: the same product can fall into different material codes depending on its actual composition. We help sellers determine the right category for each of their packaging components.

Product packaging vs. transport packaging

Hungarian rules treat product (sales) packaging and transport packaging as two separate categories, each with its own codes, reported in the same declaration. Product packaging is what the consumer sees on the shelf; transport packaging is what brings the goods to the customer (cartons, pallets, stretch film).

Both must be declared. Because the authority reconciles declarations against customs and other import data, reporting only one side — for example product packaging but not the transport packaging that must have brought the goods in — is a common source of under-declaration and questions.

Two parallel obligations: EPR and the environmental product fee

It is worth keeping these two clearly separate, because foreign sellers often confuse them.

EPR (paid to MOHU) is today the main system. It covers virtually all packaging, plus a long list of product groups including electronics, batteries, tyres, textiles, furniture, cooking oil and more. Declarations are submitted quarterly through the OKIR system.

The environmental product fee (paid to NAV) is a residual, tax-style obligation. Since 1 January 2025 the double obligation was removed for the main streams (packaging, electronics, batteries, tyres, office and advertising paper), which are now EPR-only. What remains under the product fee is a narrow list — certain "other" petroleum, plastic and chemical products — plus single-use plastic bags, which since 15 January 2025 are the one product subject to both EPR and the product fee.

For a typical e-commerce seller, the dominant obligation is EPR; the product fee only becomes relevant for specific product niches.

Foreign sellers must use a Hungarian authorized representative

Under Government Decree 80/2023 (III. 14.), a foreign producer placing products on the Hungarian market via e-commerce is legally required to appoint a Hungarian authorized representative. This is a statutory obligation, not a recommendation.

Independent compliance from abroad is, in practice, not feasible:

• Filing in the OKIR system requires Hungarian electronic-administration identification (the national client-gate), which a company without a Hungarian presence cannot obtain.
• The OKIR system and all official communication operate exclusively in Hungarian.
• Registration requires a Hungarian tax number and an environmental client ID (KÜJ) that a foreign company without an establishment does not have.
• Material classification into KF codes requires familiarity with the Hungarian regulatory framework.

A Hungarian authorized representative removes all of these barriers and, by law, takes on responsibility for the seller's filings.

What we do at eprhungary.com

We act as a full-service Hungarian authorized representative for foreign e-commerce sellers. On behalf of the seller we:

• act as the legally required Hungarian authorized representative;
• register and operate the OKIR account and the MOHU registration;
• prepare and submit quarterly EPR declarations;
• handle MOHU registration and fee settlement;
• file product-fee/NAV returns where applicable;
• classify products and packaging into the correct KF codes;
• monitor changes in Hungarian environmental legislation and adapt filings accordingly.

We do not impose a rigid data template — send your volume data in whatever format is easiest, and we take care of the rest.

Getting started

If you sell into Hungary and are not yet set up for EPR, the first shipment already creates an obligation. Fill out our short questionnaire, or reach out at hello@eprhungary.hu, and we'll walk you through the next steps.