EPR in Hungary: obligations for e-commerce sellers 

Introduction

Companies selling products to the Hungarian market are increasingly facing obligations arising from Extended Producer Responsibility (EPR). In cross-border sales, many businesses focus primarily on tax matters, such as VAT or OSS, and on organizing logistics, while overlooking waste management regulations. In practice, the lack of analysis of environmental obligations is one of the most common causes of compliance issues when selling to other EU countries.
In Hungary, the importance of these regulations has increased significantly since 2023, when a new waste management model based on a state concession was introduced. As part of this reform, a central role in organizing the system was taken over by MOHU MOL Hulladékgazdálkodási Zrt., which is responsible for the operation of the national waste collection and treatment system, as well as for collecting EPR fees from producers.
Many sellers only learn about these obligations when a sales platform requires proof of environmental registration or an identification number that allows them to sell products on the Hungarian market.
This guide has been prepared with manufacturers, importers, and online sellers targeting customers in Hungary in mind.

Definition of EPR

Extended Producer Responsibility (EPR) is a regulatory system in which companies placing products on the market participate financially in organizing the collection, sorting, and recycling of waste generated from these products. The objective of this mechanism is to shift part of the waste management costs from public administration to the entities placing the products on the market.
In practice, this means that a company selling products in packaging or placing goods such as electronics or batteries on the market must participate in financing the waste management system for waste generated at the end of these products' life cycle.
In Hungary, the EPR system covers several categories of waste-generating products. In the case of online sales, this most commonly applies to:

• packaging
• electrical and electronic equipment (WEEE)
• batteries and accumulators

The system also covers other product categories, such as tyres, oils, or selected plastic products. Placing such products on the market entails the obligation to register in national systems, maintain records of the quantities of products introduced, and pay fees to fund the waste management system.
Placing such products on the market entails the obligation to register in national systems, maintain records of the quantities of products introduced, and pay fees to fund the waste management system.
Who is subject to these obligations?
A key element of the EPR system is determining which entity is considered a producer under environmental regulations. In Hungary, a producer can be not only a company manufacturing products within the country but also an enterprise that places products on the Hungarian market for the first time as part of its economic activity.
EPR obligations may therefore apply to:
producers established in Hungary
importers bringing goods from outside the European Union
enterprises acquiring products from other EU Member States
distributors selling products under their own brand online sellers shipping products directly to consumers in Hungary.
In the cross-border sales model, the structure of the transaction is of key importance. If an enterprise sells goods directly to a customer in Hungary and organizes their delivery to the end recipient, it may be considered an entity placing the product on the national market.

Legal basis for obligations

The extended producer responsibility system in Hungary is based on national waste management regulations and a reform introduced in 2023.
The most important legal acts include, among others:

• the Waste Act (Waste Act CLXXXV of 2012)
• executive regulations concerning specific product categories
• Government Decree No. 80/2023 introducing the new EPR system

This reform established a concession model in which the operational management of the waste management system was entrusted to a single operator responsible for organizing the collection and processing of waste on a nationwide scale.

Competent authority

The EPR system in Hungary operates based on the cooperation of several public institutions. The most important operational role is played by the company:
MOHU MOL Waste Management Plc.
MOHU is the concessionaire responsible for organizing the national waste management system and for calculating EPR fees.
The environmental data reporting system is maintained through the national information system:
OKIR – National Environmental Information System.
Environmental protection authorities, on the other hand, are responsible for supervising the system and enforcing regulations.

Registers

Entities placing products covered by the EPR system on the Hungarian market must register in the appropriate environmental systems before starting sales.
This process primarily includes:

• registration of the company in the MOHU system
• registration in the OKIR reporting system

During registration, the company must also specify the category of products placed on the market by assigning appropriate classification codes, known as KF codes. These codes allow for assigning products to the correct EPR categories and determining the method of reporting and calculating fees.

Main EPR obligations in Hungary: 

Registration

The first step in fulfilling EPR obligations is identifying the product categories covered by the system and registering in the appropriate national systems.
In practice, this means:

• registration of the company in the MOHU system
• registration in the OKIR system
• assigning the correct KF codes for products

After completing the process, the enterprise can begin reporting the quantities of products placed on the market.

Authorized Representative

In the case of foreign companies selling products directly to customers in Hungary, it is often necessary to use the services of a local representative.
An authorized representative is an entity based in Hungary that represents the producer in fulfilling environmental obligations. Their tasks may include conducting the registration process, preparing environmental reports, maintaining the required documentation, and communicating with administrative authorities.
For many foreign e-commerce sellers, cooperating with a local compliance partner is the simplest way to organize compliance with the EPR system.

Confirmation of registration

After completing the registration process, the company receives identifiers in the environmental systems. These documents serve as proof of fulfilling registration obligations and are increasingly required by marketplace platforms as a condition for selling products on the Hungarian market.

Reporting and recording

Companies covered by the EPR system must maintain detailed records of products and packaging placed on the Hungarian market. This data forms the basis for preparing environmental reports submitted in the OKIR system.
Reporting takes place in quarterly cycles. The standard deadlines for submitting reports are:

• January 20
• April 20
• July 20
• October 20

Based on the submitted reports, the system operator issues invoices for the due EPR fees, which producers must settle within a specified period.

Charges

Entities placing products covered by the EPR system on the market are obliged to finance the waste management system by paying EPR fees.
These fees are calculated by the system operator – the company MOHU – based on data reported by producers. The amount of the fees depends primarily on the product category, the type of material, and the weight of the products placed on the market.

Product and packaging labelling requirements

Hungarian regulations also provide for obligations regarding the labeling of products and packaging. These markings are intended to facilitate waste segregation and provide users with information on the proper handling of products after their end-of-use.
Most commonly, these include symbols identifying the packaging material, the crossed-out wheeled bin symbol for electrical and electronic equipment, and markings concerning batteries and accumulators.

Information obligations for purchasers

Entities placing products on the Hungarian market should provide users with information regarding the correct handling of waste. This information can be provided in the product manual, on the packaging, in the product documentation, or in digital communication, for example, via information posted on the product page or in an email sent after purchase.

Waste streams and exemptions

The EPR system in Hungary covers many categories of waste-generating products, in particular packaging, electrical and electronic equipment, as well as batteries and accumulators.
In practice, EPR obligations can arise as soon as the first product is placed on the Hungarian market. Regulations do not provide for broad exemption thresholds based solely on small quantities of products.

Consequences of non-compliance

Non-compliance with EPR obligations in Hungary can lead to administrative sanctions and financial penalties. Companies that fail to complete the required registration or do not report the quantities of products placed on the market may be subject to administrative proceedings conducted by the relevant environmental protection authorities.
For online sellers, lack of compliance with environmental regulations can also lead to operational issues, such as sales restrictions or the blocking of listings on marketplace platforms that require confirmation of EPR registration.

Support in fulfilling EPR obligations

Rulity Consulting supports companies selling to Hungary in the practical organization of compliance with the EPR system.
The cooperation process begins with a detailed analysis of the product portfolio and sales model to determine which waste streams are triggered by the company's activities. For most online sellers, this primarily concerns packaging, but depending on the assortment, it may also include electrical and electronic equipment or batteries.
Based on this analysis, the appropriate path for fulfilling obligations is determined. It includes identifying the required registrations in the MOHU and OKIR systems, assigning the correct KF codes for products, and implementing reporting procedures.
In practice, properly planning the compliance process at the very beginning of sales allows for avoiding regulatory problems and reducing the risk of sales interruptions resulting from the lack of required environmental registrations.

FAQ – Frequently Asked Questions (Hungary)

Do you need support with registration on the Hungarian market? Rulity Consulting will help you through the verification process and ensure reporting accuracy.