👥 Who must comply (typical “producer” cases)

You generally fall under Battery EPR in Hungary if you are the first entity placing batteries on the Hungarian market, such as:

• Hungarian manufacturers selling domestically
• Importers placing batteries on the market in Hungary
• Foreign producers placing products on the Hungarian market via an authorised representative (where applicable)

🧩 Battery scope and fulfilment options

Collective fulfilment (most common)

• No separate contract is required for collective fulfilment.
• MOHU is treated by law as the organisation fulfilling the EPR obligation on behalf of collective producers.

Individual fulfilment (limited)

Individual fulfilment is available only for specific product groups.

For batteries, MOHU explicitly notes eligibility for industrial or automotive batteries and accumulators (where the product qualifies under the EPR Decree).

📝 Step 1 — Registration (do this before selling)

1) Register with MOHU (Partner Portal)

Before authority registration, you must register on MOHU’s electronic platform (“Partner Portal”) and complete EPR producer registration.

2) Register with the National Waste Management Authority (NWMA)

Before starting any activity with in-scope products, producers must apply for NWMA registration (with limited exceptions for certain small producers). MOHU registration comes first.

✅ Typical inputs you should prepare

• Company identifiers (tax data, KÜJ ID where applicable)
• Contact persons
• Fulfilment type (collective/individual)
• If individual fulfilment: KF codes and estimated annual quantities per KF code

🧾 Step 2 — Records & traceability (KF-code based)

You must maintain KF-code-based records with the data content required by the EPR Decree to support reporting and enable item-level traceability during audits. Records must be retained for at least 5 years.

📊 Step 3 — Reporting (deadlines that matter)

• Frequency: quarterly (with an annual option for qualifying small producers)
• Deadline: submit to NWMA by the 20th day of the month following the quarter using the authority form
• Data transfer: NWMA transfers producer records to MOHU by the 25th of the month following the quarter

💶 Step 4 — EPR fees, invoicing, and payment

How the fee is calculated

MOHU invoices producers based on authority-reported quantities and the unit fee set by ministerial decree (quantity × unit fee for the product stream).

Payment timing

Producers pay the fee quarterly within 15 days of receiving MOHU’s invoice/accounting document. MOHU can issue e-invoices via the Partner Portal.

Mandatory invoice wording (commercial documents)

Invoices for placing circular products on the market must include: “EPR fee is payable by the distributor” (with stated exceptions).

On request, documentation must also include: “EPR fee will be paid”.

Corrections and disputes

• You can request a fee review within 15 days of invoice receipt by submitting correct data to MOHU and NWMA.
• You may amend quarterly reporting data from 1 January to 30 April of the following year.

🔄 Changes to plan for (2025–2026)

KF (EPR) code revision from 1 January 2026

PwC Hungary reports that KF (EPR) codes will be revised effective 1 January 2026, and codes for batteries and accumulators will change—potentially requiring updates to buyer declarations and takeover contracts.

EPR fee increases from 1 October 2025

KPMG notes fee increases effective 1 October 2025, first applying to products placed on the market in Q4 2025, including a listed increase for vehicle batteries.

✅ What this service covers (registration → reporting → audit readiness)

• Scope confirmation: battery type, producer role, and fulfilment route (collective vs eligible individual)
• Registration pack: MOHU Partner Portal onboarding + NWMA registration preparation
• KF-code mapping and data model: product-to-KF alignment and change control for the 2026 code revision
• Quarterly reporting workflow: dataset preparation aligned to the 20th-day deadline
• Fee governance: invoice reconciliation, payment tracking (15 days), and correction/dispute support
• Traceability design: 5-year record retention and audit-ready evidence structure

⭐ Why ComplyMarket

ComplyMarket is a great partner for Battery EPR in Hungary because it combines hands-on support with Compliance Management Software and an integrated EPR platform for registration, reporting, and traceability.

With ComplyMarket, you can:

• Centralize MOHU/NWMA onboarding data and maintain a single source of truth for producer profiles.
• Maintain a controlled KF-code product master (critical for the 1 January 2026 code changes) to prevent mapping/reporting errors.
• Automate placed-on-market tracking and keep audit-ready records aligned to the 5-year retention expectation.
• Produce quarterly reporting packs aligned to the 20th-day deadline and reconcile MOHU invoices inside one workflow.

If you want the best practical path to Hungary Battery EPR compliance—without spreadsheet chaos—ComplyMarket’s platform is built to scale.