Significant increase in EPR fees

As of 1 October 2025, significant changes have been introduced to the extended producer responsibility (EPR) fees in Hungary. According to EM Decree 28/2025 (IX. 22.) amending EM Decree 22/2024 (XI. 28.) on the establishment of waste management-related institutional fees, their application conditions and payment rules for 2025, fee levels have been substantially increased across multiple product and material streams.

This amendment results in a direct cost increase for all producers and distributors placing the affected products on the Hungarian market for the first time (including the usage for own purposes). The measure is driven by the objective of strengthening the circular economy as well as the financing needs of the national waste management system.

Moreover, the legislator did not provide the affected parties with sufficient time to prepare, as the decree announced on 22 September entered into force already at the beginning of October. From a technical perspective, the EPR fee does not qualify as a tax-type obligation, and therefore the statutory guarantee requiring at least 30 days between the announcement and the entry into force of a tax increase is, apparently, not applicable.

Key sectors impacted

While the increase affects almost all industries, the following are particularly exposed:

Automotive sector – the flat-rate EPR fee per vehicle has almost doubled,
Electronics sector – e.g., lamps subject to a +37% increase,
Furniture and textile industry – EPR fee for wooden furniture tripled,
Any business using packaging materials – as certain packaging categories are also subject to material increases.

Key EPR fee changes

Waste stream / Product category	2024 Fee (HUF/kg)	From 1 October 2025 (HUF/kg)	Change (%)
Wood packaging	19	22	+16%
Textile packaging	67	148	+121%
Glass packaging	77	107	+39%
Composite (multi-material) packaging	168	191	+14%
Advertising paper	94	204	+117%
Wooden furniture	17	51	+200%
Textile products	145	164	+13%
Used cooking oil and fat	36	62	+72%
Lamps (lightbulbs, fluorescent tubes)	306	419	+37%
Vehicle components and batteries	238	390	+64%
Vehicles (flat-rate)	21 HUF/kg	36 HUF/kg	+71%

No changes apply to plastic, paper and metal packaging categories, nor to other product categories not listed above, such as monitors, small and large household appliances, portable and industrial batteries, office paper, and tires.

According to MOHU, the fee increases are driven by higher-than-expected waste management costs. At the same time, the National Trade Association emphasizes in its statement that the focus should primarily be on improving the operational efficiency of the MOHU, as the current and any future EPR fee increases are expected to have a significant inflationary impact, the burden of which will ultimately be borne by consumers.

Next steps

We would like to emphasize that the new EPR fees must already be applied in the upcoming quarterly EPR returns. For Q4 2025 (October-December) – with a filing deadline of 20 January 2026 – only the increased fees may be reported, and MOHU will issue invoices accordingly.

Although the National Waste Management Authority has not yet carried out increased audits regarding EPR compliance, the likelihood of this continuing is decreasing, and audits are expected to begin over the course of next year.

Therefore, we recommend preparing in advance for higher EPR charges expected in the upcoming months. Given that the fee increase is likely to have a significant business impact, it is advisable to assess the implications for the companies and, where appropriate, adjust budgeting and cost planning accordingly. As for the fees applicable in 2026, only assumptions can be made at this stage, since the recently amended regulation explicitly governs the 2025 fee levels.