EPR fees and related penalties have risen significantly

 As of October 1, 2025, the Extended Producer Responsibility (EPR) fees have increased, affecting several product categories and material streams. In addition to the EPR and DRS fees, the flat-rate EPR fees paid by vehicle manufacturers have also increased.

What is the EPR system, and why is it important?

The EPR (Extended Producer Responsibility) system aims to ensure that producers and distributors bear the environmental costs associated with the entire lifecycle of their products — particularly when used products and packaging become waste. The fees collected through this system help finance the circular economy and promote more sustainable production and consumption practices.

These new EPR changes bring new challenges for affected businesses

How has the Extended Producer Responsibility system changed?

It is possible for the minister to modify the EPR fee rates during the year. While this flexibility allows for quicker responses to rising costs — since the purpose of the fee increases is, in theory, to maintain the financial stability of the waste management system — it also makes business planning more unpredictable.

The most significant change is that EPR fees have increased across several material streams, particularly in the following categories:

Fee category name	EPR fee effective until September 30, 2025 (HUF/kg)	EPR fee effective from October 1, 2025 (HUF/kg)
wooden packaging	19	22
textile packaging	67	148
glass packaging	77	107
composite (multi-material) packaging	168	191
lamps	306	419
vehicle parts and batteries	238	390
vehicles	21	36
cooking oils and fats	36	62
textile products	145	164
wooden furniture	17	51

The service fees for products subject to mandatory deposit-return have changed as follows:

Fee category name	EPR fee effective until September 30, 2025 (HUF/kg)	EPR fee effective from October 1, 2025 (HUF/kg)
Non-reusable metal	186	198
Non-reusable glass	77	84

In addition, a significant increase will take effect across all categories of flat-rate EPR fees for vehicles.

Sanctions for non-compliance with EPR Obligations

Changes in the EPR fee rates affect not only the costs for manufacturers and distributors, but also the level of risk they assume in the event of non-compliance with the regulations. With the recent fee increases, inaccurate or incomplete data reporting and failure to pay EPR fees can result in increasingly significant financial penalties. Therefore, it is crucial to understand what sanctions may apply under the EPR system and the potential consequences of non-compliance.

The EPR fee is not considered a tax — it is a service fee payable to the concession company (MOHU MOL Waste Management Plc). As such, tax-related penalties do not apply to it. However, there are specific fines associated with the EPR system itself.

If a producer fails to report or provides incorrect data on the quantity of circular products placed on the market, the fine imposed will equal 50% of the unpaid EPR fee, which must be paid in addition to the missing fee itself. If the producer’s records do not clearly indicate which material stream (e.g., paper, plastic) the unreported quantity belongs to, the highest applicable fee for that product stream must be used.

Example: If a company fails to report 10,000 kilograms of packaging and cannot prove its material composition, it must be charged at the highest current rate — HUF 219/kg for plastic packaging. Based on this. The EPR fee amounts to HUF 2,190,000, the fine equals half of that amount, i.e., HUF 1,095,000, resulting in a total payable sum of HUF 3,285,000.

 

What can companies do?

Due to the recent fee increases, it is wise for companies to plan ahead for EPR-related costs and potential administrative tasks. We recommend the following steps:

• Cost planning and forecasting for the remainder of 2025 and for 2026.
• Rethinking material use and packaging, especially for product categories affected by higher fees (e.g., advertising paper and wooden furniture).
• Review record-keeping and reporting obligations to ensure data submission is accurate and timely.
• Engage experts to optimize compliance with green tax and EPR requirements.

Need help recalculating or reporting EPR fees? The LeitnerLeitner team provides clients with up-to-date knowledge and practical experience to support them in navigating the Extended Producer Responsibility (EPR) system.

The October EPR fee increase may result in significant additional costs for producers and distributors, particularly for those placing large volumes of packaging or furniture products on the market. These changes make it increasingly challenging for companies to ensure both cost-efficiency and regulatory compliance. We recommend that companies proactively review their EPR strategies and, if needed, engage experts to support financial and legal compliance.