Country dossier / EU-27
Textile EPR in Hungary
Operational since 1 July 2023; concession model
Broad research: 6 Oct 2026 · Selected verification: 2 Nov 2026. Source review coverage is stated below.
The current national decree was reopened and still shows the consolidated 12 August 2026 state; no later amendment was identified on that instrument. Limit: The 2026 annual fee instrument and concession terms were not re-audited.
Organisations & financing route
MOHU concession
Constitution & legal approval
Central concession route; not an open-market SCRAP
Implementation timing
Operating since 1 July 2023
Next evidence trigger
Q3 2026 authority reporting · 20 October 2026; next annual fee instrument
Competent authority
National waste-management authority and competent government offices; MOHU MOL Hulladékgazdálkodási Zrt. as concession company. Confirm authority-account details under current Hungarian instructions.
Legal basis
Government Decree 80/2023 (III.14); 2026 annual fee instrument 33/2025 (XI.28) EM. Historic 8/2023 fee tables should not be used as the current rate.
Product scope
The national annex explicitly includes Chapter 64 footwear, gaiters and similar articles, excluding footwear parts (Annex 1, 1.10.11). It also lists 4203, 4205, 4304, Chapter 57 with specified artificial-turf exclusions, Chapters 61–62 and 6301–6304 excluding 9404. Use the national KF coding; textile packaging remains a separate classification. This corrects catalogue coverage of an existing rule, not a new October 2026 obligation. Source: S126 ↗.
Fees & financial basis
2026 textile T01 rate: 164 HUF/kg, consisting of 150 HUF concession-company component plus 14 HUF municipal component. Do not substitute the separate textile-packaging rate. Currency conversion is deliberately omitted; assess invoice/VAT treatment separately.
Eco-modulation
No SKU-level textile eco-modulation discount schedule verified comparable to Refashion’s. Statutory category/KF rates are not a certification bonus. Future EU-aligned changes should be monitored.
Targets & denominators
National concession and waste-management obligations apply. No directly comparable producer-level textile collection/reuse/fibre-to-fibre numerical quota verified from the retrieved fee instruments.
Registration & reporting
Producer registration and MOHU contracting/account setup; maintain KF-coded mass, domestic first supply, own use and supported export/exemption evidence. Reporting is quarterly under Hungarian rules; reconcile official authority/OKIR submissions with MOHU billing rather than treating invoices as declarations. Under Article 27(1), authority reporting is due by the 20th day of the month following the quarter; Q3 2026 is therefore due on 20 October 2026 (calendar inference). Article 10(2) requires an authorised Hungarian representative for foreign e-commerce producers. Source: S126 ↗.
Organisations & approval status
MOHU is the central concession compliance/cost route. It should be described as a concession company, not as a conventional open-market textile PRO.
Next milestones
Use the correct 2026 rate now; monitor the next annual ministerial schedule and changes aligning scope/modulation with EU law. Recheck exemptions and any product-charge interaction before taking deductions. Prioritise the Q3 authority return on 20 October 2026; the annual 2026 fee instrument could not be freshly reopened in this review. Source: S126 ↗.
Practical risks & controls
Risk: wrong KF code, textile-packaging confusion, old rate or unsupported export deduction. Mitigation: maintain item-level classification and first-placement evidence, reconcile mass quarterly and verify deductions and invoice treatment with the current instructions.
Sources and verification dates
S043 · 80/2023. (III. 14.) Korm. rendelet - Nemzeti Jogszabálytár ↗ Access limited · 19 Oct 2026S044 · 33/2025. (XI. 28.) EM rendelet - Nemzeti Jogszabálytár ↗ Access limited · 19 Oct 2026S045 · MOHU: EPR information notice for producers ↗ Reopened 19 Oct 2026S126 · Hungary: Decree 80/2023, current National Legislation Database host ↗ Reopened 2 Nov 2026Common EU framework
A constituted organisation, a pilot and an authorised compulsory system have different legal effects. Unresolved scope, approval, tariff and filing questions remain visible in this dossier. Source-page reopening is not a complete current licence audit.