Packaging EPR in Hungary

What counts as packaging

Packaging in the EPR sense is not just the retail box on the shelf. It covers everything you use to contain, protect and transport the goods, including:

• Sales packaging — the box, bottle, jar, blister or pouch the product is sold in;
• Protective and filling material — bubble wrap, air pillows, paper filler, foam inserts;
• Closures and fixings — adhesive tape and strapping;
• Transport packaging — outer cartons, stretch film and pallets.

The critical point for resellers and webshops is that the goods and their packaging are assessed separately. Your supplier may have placed the product itself on the Hungarian market — but the packaging you add when you fulfil the order was placed on the market by you. That is why a business selling nothing but non-EPR goods can still have a packaging obligation.

The eight material categories

Packaging is classified purely by material, each with its own code and its own rate per kilogram. The 2026 rates apply from 1 January 2026 and are unchanged from the level set on 1 October 2025:

The spread is nearly tenfold, so the material mix is not a detail. It is also worth knowing that the 1 October 2025 increase hit packaging materials very unevenly — textile packaging rose by roughly 221% and glass by roughly 139% — which is why cost models built on older figures tend to be badly wrong. For how the fee is invoiced, what VAT applies and how the total is calculated, see our fees guide.

Building the weight data

The EPR fee is declared kilograms × the rate per kilogram, so the entire exercise reduces to knowing the weight of each packaging material you placed on the market in the quarter. There is no percentage estimate you are allowed to fall back on, and no "10% rule" — that is a persistent myth.

In practice the workable method is to build the data once, at product level, and then let sales volumes do the arithmetic:

1. Product database. For each article number record the origin (domestic, import or own production), the customs tariff number, and the material and weight of each packaging layer — in most cases up to three layers is enough to describe a product properly.
2. Sales. Record what was actually placed on the market in the quarter, by article number and unit count.
3. Shipping packaging. Track separately what leaves the warehouse around the products — outer cartons, film, pallets — by material and weight.

Multiply through and you have the kilograms per material code. Do it once properly and each subsequent quarter becomes data entry rather than a project.

What your records must show

The mandatory records must show, broken down by KF code, the name, quantity and origin (domestic or imported) of the circular products placed on the market. They must be retained for five years.

What makes the difference in an inspection is not the spreadsheet but what sits behind it: delivery notes, supplier product databases, packaging invoices — evidence that the weights you declared are real. Numbers you cannot substantiate are a weak position, because understated data carries a fine of 50% of the concealed fee difference.

Single-use plastics and the bag exception

Some items that feel like packaging are legally in a different stream. Single-use and other plastic products (SUP01) — food containers, flexible pouches for ready meals, beverage containers up to three litres with their caps, cups, lightweight plastic carrier bags, wet wipes, balloons, filtered tobacco products and fishing gear — carry their own rate of 113 HUF/kg.

The one to watch is the plastic carrier bag. Since 15 January 2025 it has been reclassified as an "other plastic product" rather than packaging, and it is the only product still subject to both EPR and the older environmental product fee.

Exemptions

The exemption that matters most for packaging is export. You are exempt where you or your buyer sell the product abroad. Where the buyer exports, the exemption is conditional: the export must cover at least 60% of the circular products purchased, and you need the buyer’s declaration on file. Warehouse arrangements before release for free circulation are also exempted.

What does not exempt you: small volume. There is no general de minimis for packaging EPR. The HUF 1,000 figure is only a MOHU invoicing roll-over — below it the amount is carried forward rather than invoiced, but the quarterly declaration is still due.

PPWR: a separate question about the same box

Since 12 August 2026 the EU Packaging and Packaging Waste Regulation, (EU) 2025/40, has applied. It is a different instrument from Hungarian EPR and asks a different question about the same box: EPR asks what you pay for the packaging you place on the market, PPWR governs the packaging itself. Meeting one does not discharge the other — we cover it separately in our PPWR guide.