Hungary EPR Number: What the Marketplace Is Actually Asking For

There is no separate Hungarian EPR number

In several countries the extended producer responsibility scheme gives you a dedicated, EPR-specific identifier — a LUCID number in Germany, a UIN in France. Hungary did not do it that way.

Here, EPR was built on top of the existing environmental register. When you register as an obligated party, you do not receive a new "EPR number" — you receive a KÜJ, and that is what you give to the marketplaces.

KÜJ = Környezetvédelmi Ügyfél Jel, literally environmental client number. It is a nine-digit number that identifies your company in the Hungarian environmental authority's records. It is not a product identifier and not a licence. This is what the marketplace accepts as your EPR number.

If the marketplace form says "EPR registration number (packaging)", the KÜJ goes there. And it is the same KÜJ for every product stream — you do not get one number for packaging and another for electronics. Hungary has one EPR registration per company, and one KÜJ attached to it, covering packaging, electrical and electronic equipment, batteries, textiles and the rest together. That differs from the practice in several other member states, which is why the per-material fields on marketplace forms confuse people.

What OKIR is, and how the KÜJ comes out of it

OKIR = Országos Környezetvédelmi Információs Rendszer, the National Environmental Information System. It is the central electronic system of the Hungarian environmental authority: environmental users are registered here, the registration happens here, and the mandatory quarterly reports are filed here.

The logic is this:

The KÜJ is the evidence of your OKIR registration.

So the KÜJ is not a separate thing you apply for somewhere else. The KÜJ proves that you have been entered into OKIR as an environmental client. No OKIR registration, no KÜJ, nothing to give the marketplace. If the platform wants documentary proof rather than a bare number, the authority's notice of the KÜJ being issued is the document to upload.

The registration also records which circular product streams you are liable for. The most common ones are:

• packaging (this catches almost every distance seller);
• electrical and electronic equipment;
• batteries and accumulators;
• tyres;
• office paper and advertising paper;
• textile products;
• wooden furniture;
• cooking oil and fat;
• motor vehicles.

If all you ship to Hungary is goods in a box, with film and filler, you are still liable — the packaging alone is enough to trigger the obligation.

MOHU: the second registration, which some marketplaces also ask for

OKIR is the authority side. MOHU (MOHU MOL Hulladékgazdálkodási Zrt.) is the commercial side: it holds the Hungarian waste management concession and in practice is the only operator of the domestic EPR system. There is no choice of compliance scheme in Hungary and no competition between operators — MOHU is the single counterparty.

You register and file your data in OKIR. On the basis of those figures MOHU invoices the extended producer responsibility fee, a HUF/kg rate set per product stream and material type. On the MOHU side there is an approval step in the second phase of registration — until that clears, the partner relationship is not complete.

Some marketplaces are satisfied with the KÜJ alone. Others also ask for confirmation of the MOHU registration. It is worth closing both, not just one.

What sellers find out too late: without a Hungarian representative it does not work

This is the most important part of this article, because it is where most do-it-yourself attempts fail.

If your company has no Hungarian seat or establishment and you supply Hungarian end users by distance selling, you are an obligated party under Hungarian law — but you have to discharge those obligations through a Hungarian authorized representative.

The reasons are partly legal and very much practical:

1. Hungarian public administration is electronic and closed. You cannot simply log in to OKIR from abroad. Administration requires Hungarian Ügyfélkapu / Cégkapu identification, which a foreign legal entity cannot create. There is no interface on which a German or Chinese company registers on its own, without a Hungarian party acting for it.

2. You need a Hungarian delivery address and contact. The authority communicates in Hungarian, through official Hungarian channels. Requests to supply missing documents, orders, inspection notices — they all arrive there, on short deadlines. With nobody to receive and handle them, the deadline runs out without you ever knowing.

3. The power of attorney is a formal document. Representation requires a signed power of attorney submitted to the authority. It is not a generic template you download: it is generated for your company, pre-filled with your data, and carries a document-specific identifier in the top right corner. All you do is check it, print it, sign it by hand, stamp it and send it back.

4. Reporting requires Hungarian technical knowledge. The quarterly report has to state, per product stream and material type and to the kilogram, what you shipped to Hungary. The classification logic — what counts as packaging, how to break down composite packaging, which item is product packaging and which is transport packaging — is set by Hungarian law.

The representative is therefore not administrative comfort; it is the condition of access to the system. With one in place the process is simple: you sign the power of attorney and supply the figures, and everything else is handled for you.

Deadlines to watch

Registration: shortly after you start the activity that creates the obligation. In practice: as soon as the first parcel leaves for Hungary.

Quarterly reporting through OKIR:

EPR fee: MOHU invoices quarterly on the basis of the data reported, and its invoices are payable within 15 days of receipt.

One thing to keep in mind: the obligation also exists retroactively. If you have been shipping to Hungary since 2023 and are only registering now, reports have to be filed for the earlier closed quarters as well. Better to settle that before the authority asks.

What happens if you do not have it?

• Marketplace: listings suspended, sales into Hungary stopped. This usually hits before the authority does.
• Commercially: you lose the Hungarian market while your competitors stay on it.

Summary checklist

1. Establish which product streams you are liable for (packaging almost certainly).
2. Appoint a Hungarian authorized representative.
3. Sign the power of attorney.
4. OKIR registration → KÜJ number.
5. MOHU registration.
6. Give the KÜJ to the marketplaces.
7. Quarterly reporting and EPR fee payment on an ongoing basis.
8. Settle the retroactive quarters if you were already shipping earlier.

In one sentence: in Hungary the "EPR number" the marketplace asks for is the KÜJ, which is the result of your OKIR registration; the MOHU registration may be asked for on top of it, and as a foreign seller you need a Hungarian representative for both.