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Hungary:  Extended Producer Responsibility (EPR) Obligations

Hungary:  Extended Producer Responsibility (EPR) Obligations

As of July 1, 2023, Hungary has implemented the Extended Producer Responsibility (EPR) system. The associated obligations apply not only to Hungarian manufacturers but also to the first-time introduction of so-called affected products made abroad into Hungary. All companies that import the products listed below from abroad into Hungary and sell them domestically for the first time fall under the EPR obligations. The introduction, according to the EPR regulation, also includes the personal use of affected products if the product becomes waste after use in the country.

Affected products include:

  • Packaging (e.g., paper, plastic, metal, wood)
  • Certain disposable and other plastic products (e.g., food containers, beverage bottles, drink cups, wet wipes)
  • Electrical and electronic devices (e.g., heat exchangers, specific computer devices, light fixtures)
  • Batteries (e.g., device batteries, accumulators, car batteries)
  • Motor vehicles
  • Tires (rubber tires, retreaded rubber tires)
  • Office paper (e.g., copy paper, file folders, notebooks)
  • Promotional paper (e.g., books, newspapers, print materials)
  • Frying oil, frying fat (e.g., sunflower seeds, rapeseed, olive oil of the mentioned tariff positions)
  • Specific textile products (e.g., certain knitted or crocheted clothing, blankets, carpets, shoes - classified by customs tariff number)

EPR obligations for companies:

  • Registration on the website of the licensed company (MOHU MOL Zrt.)
  • Submitting a registration application to the Waste Management Authority (deadline May 31, 2023)
  • Maintaining a registry and transmitting data as per legal requirements
  • Paying the Extended Producer Responsibility fee
  • Issuing invoices with the text specified in the legislation

A foreign company introducing an affected product into the domestic market can meet its EPR obligations through a domestic representative, which requires a written authorization. A webshop introducing an affected product in Hungary can only fulfill its obligations under the EPR regulation through a domestic representative.


Hungarian authorities can impose a fine on an EPR-covered company that does not apply for registration with the Waste Management Authority. If the company does not comply with the registration obligation even after the fine, the authority prohibits the sale of affected products until obligations are met.

Changes in the Eco-Tax

After July 1, 2023, foreign webshops selling environmentally taxable products (e.g., electronic devices, beauty or personal care products, soaps, cleaning agents, batteries, accumulators, mineral oil lubricants) to Hungarian end consumers are subject to the eco-tax law. This means they must register with the Hungarian tax authority, keep records, submit tax declarations, and pay taxes. An essential regulation is that foreign webshops must pay an eco-tax on the packaging of all products sold to Hungarian end consumers.

The eco-tax obligation is imposed on the webshop introducing the products (or their environmentally taxable accessories, components, and packaging) first into the Hungarian market.

Obligations for foreign online shops in Hungary

  • Reporting obligation: Companies active on July 1, 2023, must register with the Hungarian tax authority by July 15, 2023. Companies starting their operations later must register within 15 days of starting their activity using a registration form.
  • The taxpayer must maintain a record of environmentally taxable products (e.g., introduced electronic products, packaging waste produced abroad and dismantled in Hungary). The record must be suitable for identifying data in the tax declaration. Hence, the relevant products should be separately listed by "KT" code (Environmental Product Code), "CsK" code (Packaging Catalog Code Number), based on weight, and in some cases, on a per-piece basis.
  • Tax declarations, tax payment obligations: The eco-tax payment obligation must be reported to the tax authority by the 20th of the month following the respective quarter by electronically submitting the "KTBEV" form. The due eco-tax must be paid within the deadline set for the declaration. 

Companies can also meet these obligations through an authorized representative in Hungary. My Compliance is happy to assist you in meeting your new obligations in Hungary.

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