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Hungary Packaging EPR · PPWR 2026

Hungary EPR Authorized Representative & Packaging Compliance MOHU. OKIR. KF Codes. HUF Regulatory Cash.

Hungary operates packaging EPR through a central concession model. Foreign e-commerce Producers can require a Hungary-established meghatalmazott képviselő, followed by MOHU producer registration, National Waste Management Authority registration, KF-code records, quarterly reporting and HUF-denominated EPR payments.

Foreign E-commerce AR MOHU OKIR / KÜJ 2026 HUF/kg Tariffs Quarterly Reporting 5-Year Records REpont · DRS HUF Calculator

The Hungary route

What actually happens before a foreign seller places packaged goods on the Hungarian market?

Hungary is not a PRO-shopping market. First identify the Producer and AR requirement, then move through MOHU, authority registration, KF-code classification, reporting and payment.

Producer → AR → MOHU → OKIR → Report & Pay.

You provide the legal entity, establishment, Hungarian sales route, packaging materials, quantities and any DRS exposure. We determine the Producer, route the authorised-representative requirement, structure MOHU and authority registration, map KF codes, calculate the HUF regulatory requirement and maintain the recurring evidence file.

01 You

Define the Hungarian transaction

E-commerce, direct consumer sale, professional end user, local importer, distributor, private label or marketplace.

Input: commercial facts
02 We analyse

Determine the PPWR Producer

Post-12 August 2026, use the PPWR Producer logic and then map the result into Hungary's national EPR infrastructure.

Output: obligated entity
03 Representation

Decide the Hungarian AR route

A foreign e-commerce Producer uses a Hungary-established representative with a Hungarian tax number under the national EPR decree.

Output: written representation route
04 Registration

MOHU first → authority second

Complete EPR producer onboarding on the MOHU Partner Portal, then enter the National Waste Management Authority registration route.

Output: operational EPR registration
05 Operate

KF ledger → report → invoice → pay

Maintain KF-code records, report quarterly to the authority, allow data transfer to MOHU and settle the resulting HUF invoice.

Output: recurring Hungary file
FOREIGN E-COMMERCE

The Hungarian AR requirement is explicit.

A foreign-established Producer placing circular products in Hungary through an electronic-commerce service must fulfil the national EPR obligations through an authorised representative.

ONE COLLECTIVE ROUTE

Ordinary packaging does not require PRO shopping.

MOHU is the concession company performing collective EPR fulfilment. Separate individual fulfilment is limited to specified non-packaging product streams.

DRS / REPONT

Beverage deposit is a separate cash layer.

Covered non-reusable beverage containers carry a 50 HUF deposit plus DRS joining and service fees. The same DRS packaging mass must not simply be double-charged as ordinary EPR packaging.

Next · Understand the Hungarian terms →

First understand the Hungarian names

Eight terms. Eight different compliance functions.

EPR

Extended Producer Responsibility

Kiterjesztett gyártói felelősség

The Hungarian system under which Producers finance the waste-management obligations associated with circular products.

AR

Authorised Representative

Meghatalmazott képviselő

Hungary-established natural or legal person with a Hungarian tax number, appointed in writing for the foreign Producer.

MOHU

Concession company

MOHU MOL Hulladékgazdálkodási Zrt.

The central organisation performing collective EPR on behalf of Producers and invoicing the statutory EPR fee.

OKIR

Authority gateway

OKIRkapu

Electronic environmental administration infrastructure used for authority registration and related Hungarian EPR procedures.

KÜJ

Environmental customer identifier

Környezetvédelmi Ügyfél Jel

An environmental customer identifier used within Hungary's environmental administration architecture.

KF

Circular-product code

Körforgásos kód

Eight-digit classification logic used to record and report EPR-covered products within the Hungarian system.

DÍJ

EPR fee

Kiterjesztett gyártói felelősségi díj

The regulated HUF-per-kilogram contribution paid to MOHU based on reported quantities and the applicable annual tariff.

DRS

Deposit-return system

REpont / visszaváltási rendszer

Separate system for covered beverage containers, including product registration, service fees and refundable deposit cash.

Hungary has both a national EPR system and a PPWR overlay.

Regulation (EU) 2025/40 generally applies from 12 August 2026, while Hungary's existing EPR, packaging, MOHU and authority infrastructure continues as the national operating layer. Do not call every legacy national registration a final harmonised Article 44 Producer Register unless the authority expressly confirms that status.

Next · Determine the Producer →

01 · Who carries the obligation?

Determine the PPWR Producer before entering the Hungarian EPR machinery.

Hungary already had a national first-domestic-placement EPR model. From 12 August 2026, packaging Producer analysis must also be reconciled with the directly applicable PPWR.

ROUTE A

Foreign e-commerce → Hungarian user

A foreign seller transfers a circular product from abroad through an electronic-commerce service to a Hungarian household or other Hungarian user. Hungarian law expressly treats this as a placing-on-the-market event for EPR-fee purposes.

Foreign Producer + AR route
ROUTE B

Foreign supplier → Hungarian importer

Where an independent Hungarian operator imports the relevant packaged product and first places it on the Hungarian market, the Hungarian importer can carry the national Producer obligations. Verify the real commercial chain.

Import-chain analysis
ROUTE C

Own brand / private label

PPWR can move the economic-operator analysis toward the company under whose name or trademark the packaging or packaged product is made available. Do not assume the physical factory is automatically the EPR Producer.

PPWR brand-owner analysis

National EPR logic still matters after PPWR.

Hungary's EPR Decree expressly includes a transfer from abroad by electronic commerce to domestic households or other users within its placing-on-the-market logic. The PPWR Producer determination and the Hungarian operational EPR route therefore have to be reconciled, not treated as competing alternatives.

Hungary EPR Authorised Representative

Hungary already has a concrete national foreign-Producer representation rule.

The key distinction is whether the foreign Producer places the product in Hungary through electronic commerce.

80/2023 (III.14.) · SECTION 10

Electronic commerce makes the representative mandatory.

A foreign-established Producer placing circular products in Hungary may generally fulfil the decree obligations through an authorised representative. Where the foreign Producer places those products in Hungary as an electronic-commerce service, the obligations are fulfilled through the authorised representative.

EPR Decree · §10 ↗ MOHU Producer Notice ↗
FOREIGN NON-E-COMMERCE

National representation can be used.

Section 10(1) permits a foreign-established Producer to fulfil its obligations through the qualifying Hungarian representative.

FOREIGN E-COMMERCE

Representation is mandatory.

Section 10(2) expressly requires the foreign e-commerce Producer to fulfil the EPR-decree obligations through the representative.

HUNGARIAN ESTABLISHMENT

The representative must be established in Hungary.

The national decree requires domestic establishment and a Hungarian tax number.

PERSON OR ENTITY

Natural or legal person can qualify.

The representative can be a qualifying natural person or legal person, provided the Hungarian conditions are met.

WRITTEN AUTHORITY

Appointment must be in writing.

Section 10 requires a written authorisation designating the representative.

RESPONSIBILITY

The representative is responsible for performance.

Section 10(3) expressly places responsibility for fulfilment of the Producer's decree obligations on the representative.

Important legal distinction: Hungary's existing `meghatalmazott képviselő` mechanism and the directly applicable PPWR EPR-authorised-representative framework must be mapped together. The national e-commerce rule is already operational; it should not be described merely as a future PPWR concept.
Beyoğlu positioning: this page does not claim that Beyoğlu Professional is already established in Hungary as the statutory authorised representative. We coordinate Producer analysis, Hungarian AR onboarding, written-authorisation workflow, MOHU / authority registration, HUF regulatory funding and recurring evidence.

02 · Registration

Hungary uses a two-layer operational registration route.

MOHU producer onboarding comes first. The National Waste Management Authority registration follows.

NATIONAL EPR REGISTRATION · PPWR TRANSITION
Layer 1: MOHU Partner Portal.

Layer 2: National Waste Management Authority registration, operationally associated with the OKIR environmental administration infrastructure.

Authority registration number: the Producer receives a registration number when the registration application is received; a compliant application is entered into the authority register within 15 days.

This page does not label the existing Hungarian national EPR register as the final harmonised PPWR Article 44 register without an explicit authority confirmation.
MOHU Partner Portal ↗ MOHU · EPR System ↗ MOHU · Producer Information Notice ↗ EPR Decree · Registration Rules ↗
01
Determine the legal Producer

Confirm the entity that must enter the Hungarian EPR route.

02
Resolve the Hungarian AR

For the foreign e-commerce route, have the qualifying Hungarian representative and written authorisation ready.

03
Obtain / confirm environmental identifiers

Prepare the data required for the Hungarian environmental administration, including the KÜJ route where applicable.

04
Register on the MOHU Partner Portal

Complete EPR producer registration, including representative information for the foreign-Producer route.

05
Apply to the National Waste Management Authority

Authority registration must be completed before the relevant activity begins, subject to the specific statutory exceptions.

06
Activate the KF-code reporting ledger

Start recording the covered product and packaging quantities in the classification required for recurring Hungarian reporting.

What proves that the Hungary onboarding route exists?

Hungary's evidence architecture is more operational than a single public number. Keep the registration, representative, classification and MOHU relationship together.

MOHU Producer registration

Partner Portal evidence confirms the Producer has entered the MOHU operating layer.

AUTHORITY Registration number

Preserve the authority registration application, number and resulting registration evidence.

AR Written authorisation

Foreign e-commerce Producers should retain the appointment and representative details.

KF Classification ledger

The regulatory evidence must support the quantities later submitted by KF code.

03 · Hungarian EPR System

Ordinary packaging follows the central MOHU collective route.

Hungary does not require a normal packaging SME to compare competing PROs. MOHU is the concession company that fulfils collective EPR obligations on behalf of Producers.

Ordinary packaging

Collective fulfilment through MOHU — no separate collective contract required.

MOHU's current Producer notice states that a separate contract between the Producer and MOHU is not necessary for collective fulfilment, because MOHU is designated by law as the organisation fulfilling those EPR obligations on the Producer's behalf.

ROUTE 01

Ordinary packaging

Use the MOHU collective EPR route, classify by KF code, report the quantities and pay the statutory HUF/kg fee.

STANDARD PACKAGING
ROUTE 02

Foreign e-commerce Producer

Add the qualifying Hungary-established authorised representative before operating the MOHU and authority workflow.

AR + MOHU
ROUTE 03

DRS beverage packaging

Add REpont product registration, joining fee, service fee and 50 HUF deposit cash.

DRS ADD-ON
ROUTE 04

Other circular-product streams

SUP, electronics, batteries, tyres, textiles and other EPR streams require their own classification.

STREAM REVIEW
No fake PRO comparison: individual fulfilment under the Hungarian EPR Decree is available only for specified product groups such as electrical/electronic equipment, certain industrial or automotive batteries and vehicles. Ordinary packaging is therefore presented here through the MOHU collective route.

04 · Regulatory Charges, Contributions & Taxes

Hungary has a statutory HUF/kg EPR tariff — plus separate AR, DRS and tax layers.

2026 packaging rates are prescribed by ministerial decree. They are not Beyoğlu fees and are not commercial PRO quotes.

PACKAGING EPR · 2026

MOHU collective EPR fee

HUF / kg

Statutory material-specific collective EPR contribution paid to MOHU using the current annual tariff.

Plastic · M01 219 HUF/kg
Paper/cardboard · P01 173 HUF/kg
Metal · V01 186 HUF/kg
Other · X01 129 HUF/kg
Wood · F01 22 HUF/kg
Textile · C01 148 HUF/kg
Glass · U01 107 HUF/kg
Composite · K01 191 HUF/kg
Payee: MOHU
Basis: reported kg × tariff
Frequency: normally quarterly invoicing
Payment: 15 days from invoice receipt
VAT: 27% under current NAV EPR guidance
2026 official tariff ↗
HUNGARIAN EPR AR

Meghatalmazott képviselő

Provider-specific

Private representation fee for the qualifying Hungary-established representative. It is not a MOHU or government tariff.

Payee: Hungarian representative
Legal nature: private statutory-representation service
Price: provider / contract specific
VAT: invoice-specific
Beyoğlu revenue: separate
AR legal basis ↗
REPONT / DRS

Deposit + joining + service fees

50 HUF / unit deposit

Covered non-reusable beverage containers carry a statutory deposit plus separate 2026 DRS joining and service charges.

Deposit: 50 HUF / covered unit
Plastic: 18 + 219 HUF/kg
Metal: 23 + 198 HUF/kg
Glass: 1 + 84 HUF/kg
Product registration: ≥45 days before placing on market
DRS Decree ↗
NAV TAX-LAW LAYER

Environmental product charge

Case-specific

Hungary's environmental product-charge regime remains a separate tax-law layer. EPR can reduce the payable product charge under the statutory calculation, but a zero payable amount does not automatically mean that every record or return obligation disappears.

Authority: NAV
2026 return: 26KTBEV
Calculation: product / material specific
Automatic calculator: not used here
Reason: avoid false tax conclusions
NAV · 2026 product-charge return ↗
DRS double-counting rule: the Hungarian EPR Decree provides that the ordinary EPR fee is not payable for mandatory deposit-return products for which the DRS fee obligation applies. In the calculator below, mandatory DRS beverage-container mass therefore belongs in the DRS inputs, not again in the ordinary packaging-EPR inputs. Secondary, grouping or transport packaging still requires its own classification.
VAT: NAV's published EPR position treats the MOHU EPR fee as consideration for a taxable service and applies the standard 27% rate. Private AR and other third-party invoice treatment should still be verified separately for the actual cross-border transaction.

Hungary Cost & Regulatory Prefunding Calculator

Calculate the Hungarian regulatory cash requirement entirely in HUF.

Ordinary packaging, DRS, representation, tax-law amounts and Beyoğlu services remain separate accounting layers.

Hungary packaging inputs

Enter annual kilograms. Do not include the same mandatory DRS beverage-container mass again in the ordinary packaging inputs.

1 · Ordinary packaging EPR

2026 collective EPR tariff. Amounts below are HUF/kg before VAT.

219 HUF/kg
173 HUF/kg
186 HUF/kg
129 HUF/kg
22 HUF/kg
148 HUF/kg
107 HUF/kg
191 HUF/kg

2 · Mandatory DRS / REpont

Use only for covered mandatory deposit-return beverage packaging.

18 joining + 219 service
23 joining + 198 service
1 joining + 84 service
50 HUF refundable deposit / unit
The calculator deliberately does not automatically apply a VAT assumption to DRS joining/service fees. Enter the VAT cash amount shown by the actual current MOHU invoice treatment.

The 50 HUF/unit deposit is shown separately as refundable regulatory cash, not as an ordinary EPR expense.

3 · Representation, tax and other costs

Hungary country onboarding HUF 9,000
Qualifying parcel operation HUF 400 / parcel

Local commercial pricing set from the 28 August 2026 EUR/HUF reference rate and rounded to clean Hungarian customer-facing prices. These are Beyoğlu Professional service fees, not MOHU or authority charges.

05 · Reporting & Payment

Report to the authority. MOHU receives the data and invoices the fee.

This distinction matters. A collective Producer normally does not submit the quarterly quantity report directly to MOHU.

01

Maintain the KF-code ledger

Record the circular products placed on the Hungarian market in the format required by the EPR Decree, with item-level traceability.

02

Report to the authority

Standard Producers report the prior quarter to the National Waste Management Authority by the statutory deadline.

03

Authority transfers the data to MOHU

The authority forwards the relevant quantity data to the concession company, which uses it for EPR charging.

04

MOHU invoices → Producer funds and pays

MOHU applies the annual tariff to the reported quantities and issues the EPR invoice for settlement.

Standard Hungary packaging-EPR calendar

Q1

January – March

File the ordinary quarterly KF-code quantity report.

Report by: 20 April
Q2

April – June

Report the second-quarter Hungarian placed-on-market quantities.

Report by: 20 July
Q3

July – September

Report the third-quarter EPR quantities to the authority.

Report by: 20 October
Q4

October – December

Close the calendar year and submit the fourth-quarter data.

Report by: 20 January

Authority → MOHU

The National Waste Management Authority transfers the relevant Producer data to MOHU by the 25th day of the month following the quarter. MOHU then calculates the fee using the applicable statutory tariff.

Payment

The ordinary EPR fee is paid to MOHU on the basis of its invoice, generally within 15 days after receipt. Very small net quarterly amounts below HUF 1,000 can be accumulated under the statutory invoicing rule, with year-end invoicing if still below the threshold.

Record retention

Producer KF-code records must be retained for at least five years. This is an evidence-retention period, not an exemption threshold.

REpont operates on another timing layer.

A mandatory deposit-return product must be submitted for product registration at least 45 days before placing it on the market. For non-reusable mandatory DRS products, deposit amounts are then settled on the separate monthly statutory route.

Registration failure can become a market-access problem.

The EPR Decree provides that where the authority has already imposed a waste-management fine for failure to complete the required Producer registration and the Producer still does not register, the authority can suspend placing the circular product on the market until the registration obligation and the relevant outstanding fees are fulfilled. This page therefore does not reduce Hungarian compliance to a late-fee calculation.

06 · Who Does What?

Producer, Hungarian AR, MOHU, the authority and Beyoğlu have different functions.

SME

Producer / seller

Supplies the underlying commercial and packaging facts and remains responsible for their correctness.

Legal entity
Hungarian sales route
Material / mass data
Product facts
Regulatory prefunding
AR

Hungarian representative

Qualifying locally established representative for the foreign Producer under the national EPR route.

Hungarian establishment
Hungarian tax number
Written authority
EPR-decree obligations
Registration operations
MOHU

Concession company

Performs collective EPR and handles the central financial operating layer.

Partner Portal
Collective fulfilment
EPR calculation
EPR invoicing
REpont / DRS operations
NWMA

National authority

Maintains the national registration and reporting layer under the EPR Decree.

Producer registration
Registration number
Quarterly data
Data transfer to MOHU
Enforcement
BP

Beyoğlu Professional

Operates the coordination and compliance-workflow layer without treating regulatory money as our revenue.

Producer assessment
AR coordination
KF / cost mapping
Prefunding planning
Evidence workflow

What should remain in the Hungary evidence file?

Hungary's system is built around connected registrations, KF-code data, recurring authority reporting and MOHU financial evidence. Keep the chain together.

Producer-status assessment
Hungarian AR decision
Written AR authorisation
AR Hungarian tax data
MOHU Partner Portal registration
KÜJ / environmental identifiers
Authority registration number
KF-code mapping
Packaging ledger
Quarterly reports
MOHU EPR invoices
EPR payment proof
Applicable tariff version
NAV product-charge records
REpont product registration
Marketplace evidence package

Hungary primary sources

Verify the Hungarian operating route directly.

Producer representation, registration, MOHU, 2026 tariffs, reporting, VAT, DRS and national PPWR harmonisation each have their own source.

PPWR · Regulation (EU) 2025/40 EU Producer definition, Chapter VIII, Article 44 and Article 45. EUR-Lex ↗
MOHU · EPR System Producer route, Partner Portal, reporting and invoicing process. MOHU ↗
MOHU Producer Information Notice English operating notice covering collective fulfilment, authorised representatives, registration and reporting. Official PDF ↗
DRS / REpont Decree 50 HUF deposit, product registration, producer obligations and deposit-return operation. 450/2023 Decree ↗
Packaging Decree Current national packaging and packaging-waste rules incorporating PPWR terminology. 442/2012 Decree ↗
NAV · EPR VAT Tax authority position confirming current 27% VAT treatment of the EPR fee. NAV ↗
NAV · 2026 Product Charge Current 2026 environmental-product-charge filing infrastructure. 26KTBEV ↗
Product-Charge Registration 2026 NAV registration and change-notification form. 26TKORNY ↗

Hungary regulatory review: 28 August 2026. AR establishment, MOHU and authority onboarding, KF classification, DRS product status, NAV product-charge treatment, invoice VAT and future PPWR Article 44 implementation details should be reverified before each live onboarding.

Hungary is not a PRO-shopping exercise. It is a registration, classification and reporting workflow.

Producer determination, Hungarian authorised representation, MOHU, authority registration, KF codes, HUF/kg EPR fees, REpont, regulatory prefunding and marketplace evidence can be managed as one country operating process.

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