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Hungary — EPR Compliance Guide

This guide is part of our pan-European EPR compliance coverage across 29 EU/EEA countries.

Population
10 million
Registration System
MOHU (formerly OHÜ)
Responsible Authority
MOHU MOL
Maximum Fine
HUF 10,000,000 (~€25,000)

Key Legislation

Act CLXXXV of 2012 on Waste

Hungary EPR — Act CLXXXV of 2012 on Waste. The regulatory authority is MOHU MOL, operating through the MOHU (formerly OHÜ) system.

Who Must Register

All producers, importers, online sellers, and fulfillment service providers placing packaged goods on the Hungary market must register with a PRO and fulfill EPR obligations. Non-Hungary sellers must appoint an Authorized Representative.

National Concession System

Since July 2023, Hungary operates a centralized national concession system for waste management, replacing the previous competitive PRO market. MOHU (MOL Hulladékgazdálkodási Zrt.) holds the sole national concession. All producers must register with MOHU:

  • MOHU — Sole national concession holder (MOL Hulladékgazdálkodási Zrt.)

Registration: mohu.hu — MOHU portal

Reporting & Deadlines

Reporting & Deadlines: Quarterly by 20th of following month. Packaging data must be reported by material type and weight. Reports are submitted through MOHU Portal.

Penalties for Non-Compliance

Maximum Fine: HUF 10,000,000 (~€25,000). Non-compliance with Hungary EPR regulations can result in fines, marketplace listing deactivation, and legal consequences. Amazon and other marketplaces may independently verify compliance and suspend non-compliant sellers.

What Marketplace Sellers Need to Know

Product fee payment mandatory — single state PRO system

If you sell on Amazon, eBay, or other marketplaces and ship products to Hungary, you are responsible for EPR compliance in this market. The "pay on behalf" model is ending — marketplaces will no longer handle this for you. Register now to avoid listing deactivation.

Step-by-Step Registration Guide

Hungary uses a single-concessionaire model — MOHU is the only operator. Follow these steps to register and comply with Hungarian EPR obligations.

1

Register with MOHU

Create an account and register your company at mohu.hu. MOHU (MOL Hulladékgazdálkodási Zrt.) is the state-appointed sole concessionaire for waste management in Hungary since July 2023. There are no alternative PROs — MOHU is the only option. Non-Hungarian sellers must appoint an Authorized Representative to complete this step.

2

Sign an EPR Contract with MOHU

After registration, sign the mandatory EPR contract with MOHU covering your packaging obligations. Since MOHU is the only operator, there is no need to compare providers. The contract terms and fees are standardized. Costs depend on your packaging volumes and material types.

3

Report Packaging Data Quarterly

Submit quarterly reports of your packaging volumes to MOHU by the 20th of the month following each quarter. Reports must be broken down by material type (paper, plastic, glass, metal, wood) and weight in kilograms. Data is submitted through the MOHU portal.

4

Upload Registration to Amazon

Upload your MOHU registration details to Amazon Seller Central (and other marketplace platforms) under the EPR compliance section. Amazon requires proof of EPR compliance to keep your Hungarian market listings active. Without it, your listings may be deactivated.

5

File Annual Declaration

Submit your annual packaging declaration to MOHU covering the previous calendar year. This declaration summarizes all packaging placed on the Hungarian market, broken down by material type and weight. Ensure consistency with your quarterly reports to avoid discrepancies and potential penalties.

PPWR 2026 — What Changes for Hungary

The EU Packaging and Packaging Waste Regulation (PPWR) is a directly applicable regulation replacing the older Packaging Directive. It applies automatically across all EU member states, including Hungary. Here is what sellers should prepare for:

  • Stricter recyclability requirements — all packaging must be recyclable by design, with grades assigned to each packaging type
  • Harmonized labeling across the EU — standardized material identification and sorting instructions on all packaging
  • Hungary's MOHU concession model may need to adapt its reporting and fee structures to align with PPWR harmonization requirements
  • Minimum recycled content targets — mandatory percentages of recycled material in plastic packaging from 2030
  • Digital Product Passport — packaging data may need to be accessible via QR codes linked to a centralized EU registry

PPWR Compliance for Exporters to the EU

If your company manufactures products outside the EU and exports them to the European market, PPWR requires you to prove that your packaging meets EU sustainability standards — before your goods cross the border. ekoniq prepares the complete PPWR compliance package so you can export with confidence.

What we deliver (15–18 documents):

✓ Full Technical Documentation (Annex VII, Module A)

✓ EU Declaration of Conformity (Annex VIII)

✓ Recyclability assessment of all packaging

✓ Substance restriction verification (PFAS, heavy metals)

✓ Recycled content declaration

✓ Packaging minimisation statement

✓ Labeling guidance (material codes, sorting pictograms, QR)

✓ Accredited lab testing coordination (SGS, Intertek, Bureau Veritas)

✓ EPR registration in target EU countries

✓ Authorised Representative appointment (Article 45)

Request PPWR Compliance Quote Read Full PPWR Guide →

Common Mistakes to Avoid

Not Knowing Hungary Switched to a Monopoly Model

In July 2023, Hungary replaced its competitive PRO market with a single-concessionaire model. MOHU is now the only option for EPR compliance. Sellers who are still looking for alternative PROs or using outdated information from the pre-2023 system are wasting time and risk non-compliance.

Trying to Register with Old PROs

The previous recovery organizations that operated in Hungary before July 2023 no longer exist or accept new registrations. Any existing contracts with old PROs are no longer valid. All producers must register exclusively with MOHU. If a third party offers registration through a different organization, it is not legitimate.

Not Appointing an Authorized Representative

Non-Hungarian sellers cannot register with MOHU directly — they must appoint an Authorized Representative (AR) based in Hungary. The AR handles MOHU registration, contract signing, quarterly reporting, and communication with authorities on your behalf. Failing to appoint an AR means you cannot legally comply with Hungarian EPR.

Confusing Product Fee with EPR Registration

Hungary's product fee (termékdíj) and EPR registration with MOHU are two separate obligations. The product fee is an environmental tax paid to the National Tax and Customs Administration (NAV) on certain products including packaging. EPR registration with MOHU covers your packaging recovery obligations. You must comply with both.

Frequently Asked Questions

What is MOHU and why is it the only option?

MOHU (MOL Hulladékgazdálkodási Zrt.) is the state-appointed sole concessionaire for waste management in Hungary since July 2023. The Hungarian government replaced the previous competitive PRO market with this single-operator model. All packaging producers, importers, and sellers must register with MOHU — there are no alternatives. The concession covers the entire country.

What happened to the old PROs in Hungary?

All previous recovery organizations that operated in Hungary ceased operations when the country transitioned to the MOHU concession model in July 2023. Any existing contracts with old PROs are no longer valid. If you had a contract with a previous PRO, you must establish a new relationship with MOHU to remain compliant.

How long does Hungary EPR registration take?

MOHU registration typically takes 2-4 weeks from submission. Contract signing can follow shortly after. The total process usually takes 3-5 weeks. Non-Hungarian sellers who need an Authorized Representative should allow additional time for appointment formalities. Processing times may vary depending on MOHU workload.

What is the product fee (termékdíj) in Hungary?

The product fee (termékdíj) is a mandatory environmental tax on certain products including packaging materials. It is paid to Hungary's National Tax and Customs Administration (NAV) and is separate from your MOHU EPR registration. The fee rates depend on material type and weight. Both obligations — product fee and MOHU registration — must be fulfilled to be fully compliant.

Do I need an Authorized Representative for Hungary?

Yes, if your company is not established in Hungary, you must appoint an Authorized Representative (AR) based in Hungary. The AR registers with MOHU on your behalf, signs the EPR contract, submits quarterly and annual reports, and communicates with OKTF and NAV. ekoniq provides AR services across all EU countries including Hungary.

How much does Hungary EPR compliance cost?

Costs depend on your packaging volumes, material types, and whether you need an Authorized Representative. MOHU contract fees are standardized and based on the weight and type of packaging materials you place on the Hungarian market. The product fee (termékdíj) is an additional cost paid separately to NAV. Contact us for a personalized quote.

Which authority oversees EPR in Hungary?

The OKTF (Országos Környezetvédelmi és Természetvédelmi Főfelügyelőség — National Environmental and Energy Authority) is the regulatory body overseeing EPR compliance in Hungary. MOHU operates as the state-appointed concessionaire under OKTF supervision. The product fee is administered separately by NAV (National Tax and Customs Administration).

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