EPR introduction in Hungary 31st July 2023

Hungary introduced an extended EPR obligation starting 1 July 2023. The country already had implemented EPF or green tax fee on those businesses first introducing packaging material, electronic equipment, battery cells, or chemical products in the Hungarian market.

The main difference with the EPF is that fees are significantly higher, and some product categories may differ. Also, the EPF is managed by the tax authorities, however, the EPR fee is handled by the Green authority and administered by an authorized company.

The Hungarian EPR obligation impacts eleven categories of goods: packaging, single-use and other plastic products, electrical and electronic goods, batteries, motor vehicles, tires, office and advertising paper, cooking oil, certain textile products, and certain wood furniture.

Extended Producer Responsibility is an environmental policy promoted at the EU level requiring companies to pay an eco-contribution when trading with certain products that have an impact on the environment. In consequence, producers shall participate in bearing the waste management costs of those products considered environmentally harmful once their life cycle ends.

How to comply with EPR obligations in Hungary?

  • Similar to what is done in other EU countries – like France or Germany, the Hungarian EPR is managed by a company authorized by the Government called MOL Waste Management Zrt – MOHU.
  • The amount to pay will depend on the net mass of each product category declared. Authorities have published a tariff list applicable to each category per Kg.
  • Products subject to EPR fee are classified according to a specific 8-digit code structure, also known as the KF code.
  • The EPR declaration and payment is made on a quarterly basis to MOHU. The first reporting period will be Q3 2023.
  • The deadline to submit the EPR declarations is by the 20th of the month following the reporting period. Once the return is submitted, MOHU will issue an invoice to be paid within a 15 days deadline.
  • Businesses subject to the fee must register in MOHU and in OKIRKAPU systems. Registration in MOHU is required for the company to issue the quarterly invoices, while the registration in the OKIRKAPU system is necessary for the quarterly filings.
  • The EPF system will remain in place after the introduction of the new EPR. However, the EPR fee paid to MOHU can be deducted when submitting the EPF declarations to the tax authority. In practice, since the EPR fees are higher than the EPF, usually there will be not payment connected to the EPF declaration.
  • It is important to keep accurate records about the goods that enter in Hungary, and the categories of those goods.
  • Foreign companies subject to EPR obligation must appoint a Hungarian representative.