The short answer: whoever is the first to place a circular product or packaging on the Hungarian market. Not just factories — importers, wholesalers, webshops, private-label sellers and sole traders are all caught, and your company’s country of registration is irrelevant. What trips most sellers up is the assumption that a small volume means no obligation. It does not: Hungary has no general minimum quantity. This guide sets out exactly what triggers liability, what the three figures mistaken for a threshold really are, and the narrow set of cases where you genuinely are not liable.
- Liability is triggered by first placing a circular product on the Hungarian market — your seat, turnover and VAT status do not decide it.
- Placing on the market includes the first domestic transfer of ownership (paid or free), cross-border e-commerce sales into Hungary, and own-purpose use.
- There is no general de minimis exemption. HUF 1,000 is an invoicing roll-over; the small-producer rule is a reporting relief; the "10% rule" does not exist at all.
- The real exemptions are narrow: export (with a 60% test and a buyer declaration where the buyer exports), genuinely private use, and warehouse arrangements before release for free circulation.
- Even a reseller of already-marketed goods is normally liable for the shipping packaging it adds.
What triggers liability
Hungary’s EPR scheme started on 1 July 2023. Liability does not attach to your company’s registered seat, to your turnover, or to whether you hold a Hungarian VAT number. It attaches to a single event: being the first to place a circular product on the Hungarian market.
Under the Hungarian rules, placing on the market means any of the following:
- the first domestic transfer of ownership of a circular product — whether you sell it or hand it over free of charge;
- selling into Hungary from abroad as e-commerce; and
- own-purpose use of the product.
Two consequences follow that catch people out. Free samples and giveaways are still a transfer of ownership. And goods you buy in and consume yourself, rather than resell, can still trigger the obligation through own-purpose use.
Who counts as a "producer"
The Hungarian term translated as "producer" is far wider than "manufacturer". In practice the following are all typically liable:
- Webshops — if you pack the goods and ship them, the shipping packaging alone makes you liable.
- Importers and wholesalers — bringing goods in from another EU country counts as placing on the market just as much as importing from outside the EU.
- Manufacturers and private-label distributors — including anyone selling goods under their own brand.
- Sole traders, including those on simplified Hungarian tax regimes.
The governing principle is simply that whoever places the item on the market first, pays. That is why "my supplier already paid EPR" is only half an answer: it may well be true for the goods, but the packaging you add to fulfil the order — box, filler, tape, stretch film, pallet — is yours, and you are the first to place it on the Hungarian market. Genuinely borderline supply chains deserve a case-by-case check rather than a rule of thumb.
Is there a minimum threshold?
No. There is no general quantitative de minimis exemption from Hungarian EPR. Three separate figures get mistaken for one, so it is worth separating them cleanly:
| Figure | What it actually is | What it is not |
|---|---|---|
| HUF 1,000 | An invoicing roll-over threshold (since 1 January 2025). Below it MOHU does not issue an invoice but carries the amount forward until it reaches HUF 1,000. | Not a reporting exemption. Your quarterly declaration is still due. |
| 5× the annual minimum wage | The small-producer relief: a business under that annual revenue may keep simplified records and report once a year, by 20 January. | Not a fee exemption. You still owe the fee. |
| The "10% rule" | Nothing. It does not exist in Hungarian EPR. | Every liable product must be recorded and declared by weight. |
When you are not liable
There are genuine exemptions, but they are narrow and each has conditions:
- Export. You are exempt where you — or your buyer — sell the product abroad. Where the buyer is the one exporting, the exemption requires that the export covers at least 60% of the circular products purchased, and that the buyer provides a declaration to that effect. Without that declaration on file, the exemption is not something you can rely on in an inspection.
- Private individuals and genuinely non-business own use do not create an obligation. Note the contrast with own-purpose use inside a business, which does.
- Tax warehouse and product-fee warehouse arrangements, and sales made before release for free circulation, are exempted.
What is not on this list is just as important: there is no exemption for being small, for being foreign, for selling only through a marketplace, or for holding an OSS or IOSS VAT registration.
If you are a foreign seller
Because the trigger is placing on the market rather than establishment, a company with no Hungarian presence at all can be fully liable — it must register, report and pay. On top of that, a foreign producer that places goods on the Hungarian market as e-commerce must appoint a Hungarian authorized representative, who must be established in Hungary, hold a Hungarian tax number, and who becomes liable for the obligations. For other foreign producers it is optional but close to indispensable in practice. We cover the requirement, the liability shift and the appointment process in detail in our dedicated guide below.
What to do if you are liable
If the above describes you, three things follow. You register with the authority through the OKIR system, declaring your product streams by KF code — not with MOHU, which is the party that later invoices the fee. You then report quarterly, and pay MOHU’s invoice within 15 days of receiving it.
The cost of doing nothing is not theoretical: EPR fines have been applied since 1 April 2025, imposed by the waste management authority — not by MOHU — which identifies missing producers by cross-checking customs, Intrastat, VAT and product-fee data. Failure to declare or pay carries a fine of 50% of the actual EPR fee, and fixed administrative items run up to HUF 500,000 for a producer or distributor, accumulating per product stream and per infringement.
Frequently asked questions
My company has no Hungarian entity. Do I still need EPR?
Yes, if you place circular products or packaging on the Hungarian market. The obligation follows the act of placing on the market, not your company’s seat. If you sell into Hungary as e-commerce, you must also appoint a Hungarian authorized representative.
I only ship a few parcels a month to Hungary. Am I exempt?
No. Hungary has no general minimum quantity exemption. A small producer whose annual revenue does not exceed five times the annual minimum wage may report only once a year, by 20 January, but the fee is still owed.
I sell goods that are not themselves EPR products. Am I clear?
Usually not. If you pack and ship the order, the shipping packaging — box, filler, tape, film, pallet — is itself liable, and you are the first to place it on the Hungarian market.
Does my OSS or IOSS VAT registration cover EPR?
No. VAT one-stop-shop registrations and EPR are entirely separate obligations. Being registered for OSS or IOSS does nothing for your EPR position.
My supplier already paid EPR on these goods. Do I pay again?
Whoever places the item on the Hungarian market first is the one who pays, so for goods already placed on the market by your supplier the answer is generally no. Your own shipping packaging is a separate matter and remains yours. Individual supply chains need an individual check.
We export most of what we buy. Are we exempt?
There is an export exemption. Where the buyer is the one exporting, it applies on condition that the export covers at least 60% of the circular products purchased and the buyer provides a declaration to that effect.