Hungary began actively enforcing EPR penalties on 1 April 2025 under Government Decree 156/2025. The sanctions are real and can add up quickly: a quantity-based fine of 50% of the fee you failed to declare or pay, plus fixed administrative fines of up to HUF 500,000 for a producer — and these accumulate per product stream. This guide explains who enforces, how the fines are calculated, and the exposure if you have not registered.
- Enforcement is run by the waste-management authority (OHH) — not MOHU — which cross-checks customs, Intrastat, VAT and product-fee data to find unregistered producers.
- The quantity-based fine is 50% of the fee: 50% of the real fee if you fail to report or pay at all, or 50% of the concealed difference if you under-declare.
- Fixed administrative fines under Decree 156/2025 reach HUF 500,000 per infringement for a producer/distributor (HUF 200,000 for a waste producer).
- Fines accumulate per product stream and per infringement; a repeated infringement within 3 years is an aggravating factor.
- Upper limits are high: up to HUF 50 million for a natural person and HUF 500 million for a legal person.
Who enforces — and how they find you
Sanctions are imposed not by MOHU (which operates the system and issues the fee invoices) but by the waste-management authority (OHH) — the territorial and national authority. Importantly, the authority does not wait to stumble across you: it cross-checks customs, Intrastat, VAT and product-fee data to identify producers that placed goods on the Hungarian market but never registered or reported. For a cross-border seller, the assumption that "they won't notice" is not safe.
The quantity-based fine (50%)
The core financial penalty is tied to the fee you should have paid:
- Total failure to report or pay: a fine of 50% of the real EPR fee (your actual quantity × half the unit rate) — on top of the fee itself.
- Under-declaration (false or lower data): a fine of 50% of the concealed difference ((real − declared) × half the unit rate).
- Failure to report when there was no waste flow: a fixed HUF 50,000.
Fixed administrative fines (Decree 156/2025)
On top of the quantity-based fine, there are fixed administrative penalties for breaching registration, record-keeping and certification duties:
| Infringement | Producer / distributor | Waste producer |
|---|---|---|
| Failure to register / report / certify | HUF 500,000 | HUF 200,000 |
| Improper (deficient) performance | HUF 250,000 | HUF 100,000 |
| Late submission of a take-over contract | HUF 100,000 | |
A foreign e-commerce seller placing goods on the market is treated as a producer/distributor, so the higher figures apply.
How the fines add up
Two features make the exposure larger than a single headline number suggests. First, the fixed items accumulate per product stream and per infringement — a seller affected by several streams (packaging, electronics, batteries) can face the fine multiple times. Second, a repeated infringement within 3 years of an earlier decision becoming final is an aggravating factor. The overall caps are HUF 50 million for a natural person and HUF 500 million for a legal person.
Limitation periods
The authority's power to sanction is time-limited: a subjective 6-month period from when the authority becomes aware of the infringement, and an objective 3-year period from when it was committed. Note that the fee obligation itself can still be enforced within those limits — the limitation on penalties does not erase the underlying fee.
How to reduce your exposure
If you have been selling to Hungary without registering, the cheapest course is almost always to register and back-file as soon as possible. Declarations can be submitted retroactively, and reconciling past periods voluntarily is far less costly than waiting for the authority's cross-checks to catch up — especially given that the fee, the 50% fine and the fixed items can otherwise all land together. An authorized representative can handle the back-filing and keep your ongoing reporting compliant.
Frequently asked questions
How much is the fine for not registering for EPR in Hungary?
For a producer/distributor, the fixed administrative fine for failing to register or report is up to HUF 500,000 per infringement, and it accumulates per product stream. On top of that, a quantity-based fine of 50% of the unpaid fee applies.
How is the Hungary EPR fine calculated?
The quantity-based fine is 50% of the fee: 50% of the real fee if you fail to report or pay, or 50% of the concealed difference if you under-declare. Fixed administrative fines are separate and set by Decree 156/2025.
Can Hungary fine a foreign company?
Yes. The obligation arises from placing goods on the Hungarian market, regardless of where the company is established. The authority cross-checks customs, VAT and other data to identify unregistered foreign producers.
What is the maximum EPR fine in Hungary?
The upper limits are HUF 50 million for a natural person and HUF 500 million for a legal person. Individual fixed and quantity-based fines accumulate per product stream and per infringement up to those caps.
Can I still fix it if I have not registered yet?
Yes. Register and back-file as soon as possible — declarations can be submitted retroactively. Regularising past periods voluntarily is much cheaper than waiting for enforcement, when the fee and fines can land together.