EPR fee in Hungary 2026: rates table, KF codes, deadlines – who has to report?

In Hungary, the EPR fee (EPR-díj, extended producer responsibility fee) is paid by whoever first places packaging or another “circular product” on the Hungarian market – a manufacturer, importer, EU buyer or webshop. For packaging in 2026 the fee is HUF 22–219/kg by material (plastic 219, paper and board 173); quantities are reported quarterly on OKIRkapu by the 20th of the month after the quarter, and MOHU invoices on that basis (Government Decree 80/2023 (III. 14), §§ 16, 20, 21 and 27; Ministerial Decree 33/2025 (XI. 28) EM, Annex 4).

This article is for information, not tax or legal advice: it reflects Hungarian law as of 11 November 2026. Ask your accountant.

Who has to pay and report?

Quick check: Does Hungarian EPR apply to me? – a few clicks and you'll know whether you owe the EPR fee.

A producer is whoever makes the product or, for goods made abroad, first places it on the Hungarian market (Waste Act – Ht. – § 2 (1) 16; 80/2023, § 16). Typical cases:

• Domestic production: whoever first sells or hands over the packed product in Hungary.
• Imports and EU purchases: if you resell the goods in their original packaging, you are the first placer; if you unpack and use them, that is own use – you pay either way (§ 17 (3); MOHU packaging guide).
• Foreign webshop selling to Hungarian customers: this counts too (§ 16 (2)), and an authorised representative (meghatalmazott képviselő) with a Hungarian tax number is mandatory (§ 10 (2)).
• Webshop shipping packaging: boxes, mailer bags and fillers are packaging; under the Hungarian rule, whoever packs into them places new packaging on the market. Disputed since August 2026 (see below).
• Hungarian supplier: if its invoice says “A kiterjesztett gyártói felelősségi díj megfizetése az eladót terheli.” (the fee is borne by the seller), it has paid (§ 21 (2)).

Documented export is not placing on the market (§ 16 (4)). There is no quantity threshold. Besides packaging, electronics, batteries, tyres, paper, textiles and wooden furniture are also covered (80/2023, Annex 1).

EPR fee rates 2026

The 2026 rates are set by Annex 4 of Decree 33/2025 (XI. 28) EM, from 1 January 2026. They exclude VAT and apply to collective compliance – the default, where MOHU (the waste concession company) handles the waste (80/2023, § 23 (3)).

No mid-year change in 2026 so far (Jogtár, 10 November 2026); the last one was on 1 October 2025, when F01 (wood, 19 → 22 HUF/kg), C01, U01 and K01 rose. Use the rate in force on the day the obligation arises. The 2027 rates had not been published by 10 November 2026; they are due by 30 November each year (80/2023, § 19 (1)).

How the KF code is built

Quantities are reported per KF code (KF-kód, circular product code), eight characters long (80/2023, Annex 1, point 2):

Unpacked, 11211017 means: 11 packaging, 21 board, 10 non-reusable consumer, 1 collective, 7 imported packaging. The first six characters set the fee code (Annex 2): 1120–1129 is P01, i.e. HUF 173/kg. A common trap: plastic food containers, cups and carrier bags in stream 12 still get M01, not SUP01 (MOHU invoice FAQ).

Items marked A–D in position 7 are fee-exempt but still reported, e.g. reusable packaging or goods the buyer declares 60%+ exported (§§ 22–22/D).

Deadlines and process

1. Request a KÜJ number (environmental client ID) on OKIRkapu.
2. Register on the MOHU Partner Portal (“EPR Gyártói Regisztráció”) first (§ 6 a)) – without it, no invoice comes.
3. Register with the national waste management authority (OHH) on OKIRkapu before starting the activity (§ 23 (1)).
4. Each quarter, submit the “KG: KGYF-NÉ” data package on OKIRkapu, in kg per KF code, by the 20th of the following month (§ 27 (1)) – not to the tax authority (NAV).
5. MOHU invoices with 27% VAT; pay within 15 days of receipt (§ 21 (1); MOHU invoice FAQ).

With no sales, a registered producer still files a nil report. Corrections: within 15 days of the MOHU invoice (§ 21 (7)), or once between 1 January and 31 March of the following year (§ 27 (6)).

A worked example

A fictitious webshop imports a food supplement from Germany and resells it unchanged to Hungarian consumers: an HDPE jar in a board box. In Q4 2026 it sells 1,000 units.

1. Obliged? Yes: it resells imported goods unchanged, so it's the first placer.
2. Weight per unit (weighed): jar 38 g, box 12 g.
3. KF codes: jar 11021017 → M01; box 11211017 → P01.
4. Kilograms: 1,000 × 38 g = 38 kg plastic; 1,000 × 12 g = 12 kg board.
5. Fee: 38 × 219 = HUF 8,322; 12 × 173 = HUF 2,076; total HUF 10,398 excl. VAT.
6. MOHU invoice: 10,398 + 27% VAT (2,807.46) = 13,205.46, rounded HUF 13,205.
7. Report by 20 January 2027, in two lines: 11021017 – 38 kg, 11211017 – 12 kg.

The decree sets no rounding rule; weights go in to three decimals, and the MOHU invoice is what counts. An own shipping box would be a third line (characters 5–6: 20).

Product fee 2026: what is left?

Since 1 January 2025, packaging, batteries, electronics, tyres and paper are no longer subject to the environmental product fee (környezetvédelmi termékdíj), only to the EPR fee. What remains (Act LXXXV of 2011 – Ktdt. – Annex 2):

“F” is the EPR fee paid on the bag in HUF/kg. The product fee is declared to NAV (form KTBEV) and paid quarterly by the 20th of the month after the quarter, rounded to thousands of forints (NAV 2026). A shampoo webshop pays both: product fee on the product, EPR fee on its packaging.

Fines and the 2026 EU change

A repeat within three years doubles the fine, a third time triples it (§ 2 (4)); the fee is still due. The “HUF 200,000 + 50%” in older articles is the rule replaced in July 2025.

PPWR. The EU Packaging Regulation ((EU) 2025/40) has applied directly since 12 August 2026, with its own producer definition: whoever first makes packaging available in a member state, or unpacks it other than as an end user (Article 3, point 15). Hungary's amendments (Government Decree 412/2025) took effect the same day. Still unclear:

• the relief for packaging filled at the point of sale (food boxes, carrier bags) – 80/2023, § 11 (1)–(2) – is blank in the consolidated text; advisers say restaurants and webshops are now directly liable, but we could not verify the transitional rule officially;
• for transport packaging, whoever first places the empty packaging on the market may be liable. Per the trade press, the authority is reviewing this and follows Decree 80/2023 until then (Adózóna, 3 October 2026).

If you'd rather not do this in Excel

EPR-napló (“EPR log”) is COGMA's own product: you record each product's packaging layer by layer once; sales come from NAV Online Invoice (NAV Online Számla), your webshop (WooCommerce) or Excel/CSV. Each quarter it calculates kilograms per KF code, the EPR fee and the product fee, closes the quarter and gives you a checklist for OKIRkapu, where you still enter the data by hand. Accounting firms can manage several companies with one login.

Frequently asked questions

Sources

• Legislation (in force, accessed 10 November 2026): Government Decree 80/2023 (III. 14), Decree 33/2025 (XI. 28) EM, Act CLXXXV of 2012 (Ht.), Government Decree 156/2025 (VI. 23), Act LXXXV of 2011 (Ktdt.); 2025 rates: Decree 22/2024 (XI. 28) EM.
• MOHU: EPR invoice FAQ (February 2024) and packaging guide (2023); OKIRkapu – in Hungarian, accessed 10 November 2026.
• NAV: Environmental product fee information booklet (23 January 2026) – accessed 10 November 2026.
• Regulation (EU) 2025/40 (PPWR); Adózóna: PPWR and EPR obligations (3 October 2026, in Hungarian) – accessed 10 November 2026.