Hungary — Authorised representative: Sources disagree?

The authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.

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Packaging EPR in Hungary

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Checked 2026-09-16 · 4 sources · 1 open question

Register: DOUBLE registration: MOHU Partner Portál (concession company) AND the producer register at OKIR Kapu (Országos Hulladékgazdálkodási Hivatal)
Authority: Országos Hulladékgazdálkodási Hivatal (OKIR); MOHU MOL Hulladékgazdálkodási Zrt. is the concession holder
Law: EPR rendelet 80/2023. (III. 14.) Korm. rendelet, § 6, § 11, § 23; Ht. 2. §MOHU registration alone does NOT discharge the duty — § 23 requires entry in the producer register through OKIR Kapu as well, and § 6 requires the data report to the concession company. Two systems, two registrations. 🔑 From 1 Jan 2025 the environmental product fee (környezetvédelmi termékdíj) was abolished for material streams that are inside EPR; it remains for streams outside it. Reusable packaging owes the fee only on its first placing on the Hungarian market (§ 22/C), and packaging inside the mandatory deposit system owes no EPR fee (§ 15(2)). A buyer who declares that at least 60 % will be exported within 365 days takes the fee off the seller (§ 22). Packaging removed from an imported product counts as own use when it becomes waste in Hungary (§ 17(3)), so the unpacker pays. Invoices, except in retail, must carry: "A kiterjesztett gyártói felelősségi díj megfizetése az eladót terheli." (§ 21(2)).
Who registers: Two separate registrations
Authorised representative: Only for distance selling to consumersmeghatalmazott képviselő — OPTIONAL for a producer established abroad (§ 10(1)), but MANDATORY for one selling into Hungary as an e-commerce service (§ 10(2)). The representative must be established in Hungary, hold a Hungarian tax number and a written mandate, and is liable for the producer's duties (§ 10(3)).
Household packaging schemes: MOHU MOL Hulladékgazdálkodási Zrt.
Industrial packaging schemes: MOHU MOL Hulladékgazdálkodási Zrt.

What is not settled

Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.

The same in every EU country

PPWR Art. 44 — registration is a precondition for placing packaging on that market
PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
set nationally, Art. 68; national rules due by 12 Feb 2027
Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029

Sources

mohu.hu scheme
mohu.hu scheme
epr.hu authority
njt.jog.gov.hu authority

Countries with the same answer

Portugal Live
Austria Live
Czech Republic Live
Lithuania Live
Luxembourg Live
Malta Live

We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.

Tarafex

The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.

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