Extended producer responsibility (EPR)

The Hungary - Extended Producer Responsibility (EPR / KGYF) (l10n_hu_epr) module implements the Hungarian extended producer responsibility (kiterjesztett gyártói felelősség, Government Decree 80/2023. (III. 14.)): it keeps the EPR register of the products placed on the Hungarian market by KF code, prints the invoice clauses, and prepares the quarterly data report (OKIRkapu data package KG:KGYF-NÉ) as an XML file validated against the official schema. It can be installed from the Apps menu or by ticking Hungarian EPR in the eYssen ERP settings.

The EPR covers packaging, single-use plastic products, electrical and electronic equipment, batteries, vehicles, tyres, office paper, advertising paper, frying oil and fat, textiles and wooden furniture. The fee is collected by the concessionaire MOHU MOL Hulladékgazdálkodási Zrt. The products still subject to the environmental product fee are handled by the KVTD module.

Note

  • The data report is uploaded to OKIRkapu by the user: OKIRkapu has no machine interface, the module generates the file.

  • The fee is not posted by the module. MOHU invoices it quarterly on the basis of the data report; record the MOHU invoice as a vendor bill and link it to the report to compare the amounts.

How the obligation works

  • The producer is whoever places a product on the Hungarian market for the first time: the domestic manufacturer, or the importer or EU purchaser at its first domestic sale (80/2023. Korm. r. 16. §). A company buying from a Hungarian supplier and reselling is not liable.

  • Every separable component of a packaging (bottle, cap, label, film, carton) has its own KF code and fee (11. § (5)).

  • The producer reports the quantities by KF code quarterly, by the 20th day of the month following the quarter, to the national waste management authority through OKIRkapu (27. §). MOHU invoices the fee on this basis; it is payable within 15 days of receipt (21. § (1)).

  • Records are kept for at least 5 years and must be traceable item by item (26. §, 28. §).

KF codes

The KF code has 8 characters:

Characters

Meaning

Where it comes from in Odoo

1–2

Product stream (11 packaging, 12 single-use plastic, 13 EEE, …)

EPR component of the product

3–4

Material stream (e.g. 01 PET, 20 corrugated board)

EPR component of the product

5–6

Group (e.g. 10 consumer packaging, 20 transport packaging)

EPR component of the product

7

Obligation code: 1 collective, 2 individual, A / B customer declaration

Company setting and customer declaration

8

Origin: 1/2/3 domestic, 5/6/7 brought in from abroad, 8 own use

Origin and role of the component

Example: 11202013 is corrugated board (20), non-reusable transport packaging (20), collective fulfillment (1), packaging produced in Hungary (3).

Configuration

Settings

Go to Accounting ‣ Configuration ‣ Settings, section Hungarian EPR (Extended Producer Responsibility):

  • EPR Producer: the company is a producer and keeps an EPR register.

  • EPR Register Method:

    • Placing on the market (customer invoices): the register lines are created from the domestic customer invoices.

    • Stock-in (vendor bills, 26/A. §): the register lines are created from the vendor bills of goods bought from abroad. This method can be chosen from the first day of a quarter, with an opening inventory.

  • EPR Register Start: invoices with an earlier fulfillment date do not create register lines.

  • EPR Fulfilment: Collective (through the concessionaire) or Individual. Individual fulfillment is only possible for EEE, batteries and vehicles (7–9. §); for every other product stream collective fulfillment is reported.

  • OKIRkapu data: the KÜJ Number (environmental client identifier), the EPR Registration Number, the EPR Contact Person (a contact with address, phone and e-mail) and the EPR Contact Position. They are required for the XML.

  • Print EPR Clauses on Invoices: prints the clauses of 21. § on the customer invoices.

The company address and the Hungarian VAT Number of the company are also used in the data report.

screenshot: finance-fl-hungary-epr-settings
menu
Accounting ‣ Configuration ‣ Settings
shows
Settings page scrolled to the "Hungarian EPR (Extended Producer Responsibility)" section with "EPR Producer" ticked, the method, start date and fulfillment, the OKIRkapu data and "Print EPR Clauses on Invoices".
highlight
The "OKIRkapu data" block (red frame).
data
Demo company "YourCompany HU"; KÜJ 123456789; contact "Kovács Anna", position "ügyvezető".
module
l10n_hu_epr
notes
English UI, light theme, 1440px width, crop to the section. Use a fictitious KÜJ number.

KF codes, fee codes and rates

  • Accounting ‣ Configuration ‣ EPR ‣ KF Codes lists the valid first six characters of the KF codes (80/2023. Korm. r. 2. melléklet) with the material stream, the group and the fee code. The list is loaded with the module and updated with it.

  • Accounting ‣ Configuration ‣ EPR ‣ EPR Fee Codes and Rates lists the fee codes (M01 plastic packaging, P01 paper packaging, V01 metal packaging, SUP01 single-use plastic, E01–E06 EEE, A11–A51 batteries, …) with dated rates in HUF/kg, net of VAT, and their concession and municipal elements. The rates of 2025 and 2026 are loaded with the module; when a new fee decree is published, close the old rate and add the new one.

Products

On the EPR tab of the product form:

  • EPR Liability: According to the company method (default), Always liable (also when bought from a Hungarian supplier, stock-in method) or Not liable (another company placed it on the market).

  • One line per EPR component of one unit of the product:

    • Component: e.g. bottle, cap, label, shrink film, carton box;

    • KF Code (1-6): search by code, material or group; the Fee Code is shown next to it;

    • Weight per Unit (kg): the mass in one unit of measure of the product (six decimals);

    • Role: Packaging, Product placed on the market on its own or Component or accessory of another product. KF codes of the packaging stream can only be used for packaging;

    • Origin: Produced in Hungary or Brought in from abroad (EU or third country);

    • Origin Code (computed): the 8th character of the KF code;

    • Variant (optional, with variants): lines of a variant replace the lines without variant for that variant.

  • For electrical and electronic equipment, batteries, tyres, textiles, furniture and the other product streams, add a line for the product itself (role on its own or component), next to the lines of its packaging.

EPR Weight per Unit (kg) and EPR Fee per Unit (HUF) show the totals of one unit at the current rates.

screenshot: finance-fl-hungary-epr-product
menu
Inventory ‣ Products ‣ Products ‣ (product) ‣ EPR tab
shows
Product form with the "EPR" tab: liability, weight and fee per unit, and two component lines (bottle and carton box) with KF code, fee code, weight, role, origin and fee per unit.
highlight
The component lines (red frame).
data
Product "Mineral water 0.5 l × 12"; bottle 110110 (M01) 0.24 kg imported packaging; carton box 112020 (P01) 0.30 kg domestic packaging.
module
l10n_hu_epr
notes
English UI, light theme, 1440px width, crop to the tab.

Customer declarations

A customer who ships at least 60% of the products abroad (22. §), or who uses frying oil or fat as raw material (22/A. §), can declare it. Sales covered by the declaration are reported with obligation code A or B, without fee, and the declaring customer is listed in the data report.

Record the declarations in Accounting ‣ Configuration ‣ EPR ‣ Customer Declarations:

  • Registration Number: the filing number of the declaration at the authority (printed on the invoice);

  • Customer (Declarant) and Type;

  • Valid From and Valid To: at most 3 years (22/B. §);

  • Sent to the Authority On: the declaration is effective from the day it was sent to the authority (26. § (6));

  • KF Codes (1-6): the codes covered by the declaration (required). A 22/A. § declaration can only cover frying oil and fat.

Customers who asked for the clause A kiterjesztett gyártói felelősségi díj megfizetésre kerül. (21. § (5)) are marked with EPR Clause Requested in the Accounting tab of the contact.

Invoices

When an invoice is posted, a register line is created for every EPR component of its products: quantity = invoiced quantity converted to the unit of the product × weight per unit, fee = quantity × rate valid on the fulfillment date. The lines are shown on the EPR tab of the invoice (visible to invoicing users and accountants).

  • Deliveries abroad (shipping address outside Hungary) are not reportable (16. § (4)).

  • Sales covered by an effective customer declaration are reported without fee, with obligation code A or B.

  • With the stock-in method, purchases from Hungarian suppliers are not reportable unless the product is Always liable.

  • Credit notes reverse the lines of the original invoice in proportion to the credited quantity, with the same KF code, rate and declaration. If a credit note or a corrective invoice only corrects the price, tick No EPR Effect on it; the field can also be changed after posting.

  • If the EPR components of a product are completed later, select the posted invoices in the list view and use Actions ‣ Rebuild EPR lines (accounting administrators). Lines of a closed data report are not changed.

Important

Only invoices create register lines. Point of Sale orders without an invoice, foreign packaging removed in Hungary (own use, origin code 8, 17. § (3)) and the opening inventory of the stock-in method are entered as manual lines in the EPR register.

Invoice clauses

The printed customer invoice shows, before the payment terms (not on retail sales to consumers without a tax number):

  • A kiterjesztett gyártói felelősségi díj megfizetése az eladót terheli. when the company declares and pays the fee of the invoice (21. § (2));

  • A kiterjesztett gyártói felelősségi díj a vevő nyilatkozata alapján nem került megfizetésre (a nyilatkozat iktatási száma: …). for sales covered by a declaration (21. § (3));

  • A kiterjesztett gyártói felelősségi díj megfizetésre kerül. if the customer asked for it and no other clause applies (21. § (5)).

With the stock-in method, the clause of 21. § (2) is printed on the domestic sales of the products with EPR components.

EPR fee in the expected cost

With Supplier Product Management installed, the module Supplier Product Management - Hungarian EPR (supplier_product_management_l10n_hu_epr) is installed automatically. It fills the EPR Fee per Unit of the vendor pricelist lines from the EPR components of the product: weight per unit × current rate of the fee code, summed over the components and converted to the unit of the pricelist line. The fee becomes part of the expected cost of the line.

The fee is filled only when the company pays it for goods bought from that vendor, following the same rules as the register:

  • no fee if the EPR register is not active or the product’s EPR Liability is Not liable (another company placed it on the market);

  • with Always liable, or with the placing-on-the-market method, the fee is always counted;

  • with the stock-in method, the fee is counted for vendors abroad, not for Hungarian vendors.

The fee is recalculated when the vendor, the product or its EPR components change; it can be overwritten by hand on the line.

Register and data report

Register

Accounting ‣ Reporting ‣ EPR ‣ EPR Register lists the register lines with date, KF code, fee code, product and component, invoice, partner, quantity, rate, fee and status (Fee payable, Reported without fee, Not reportable). Group by KF code, fee code, product stream or quarter, or open the pivot view.

Quarterly data report

Accounting ‣ Reporting ‣ EPR ‣ EPR Data Reports:

  1. Create a report with the year and the quarter. The Deadline (20th day of the month after the quarter) is shown.

  2. Click Compute. The register lines of the quarter are summed by KF code:

    • deliveries in the Summary tab as placed on the market rows (data package block KG_KGYF_NE_TERMEK_FORG), with the declaring buyers of the A and B codes;

    • credit notes as returned rows with positive quantities (block KG_KGYF_NE_TERMEK_VISSZA);

    • the Expected Fee tab: quantity × rate by fee code and rate, net of the returns.

    Quantities are in kg with three decimals; codes netting to zero are left out. Without any line the report is a Zero Report.

  3. Check the warnings: draft invoices of the quarter, lines of earlier quarters that are in no report (late credit notes), returned products, missing rates, declarations without buyer address, Point of Sale orders without invoice, and missing OKIRkapu data.

  4. Export XML (OKIRkapu) computes the draft report again, builds the KG:KGYF-NÉ XML and validates it against the official XSD (version 1.16). Export XLSX downloads the summary, the expected fee and the detailed register.

  5. Click Close: the register lines of the quarter are locked.

  6. In OKIRkapu, create the data package with Új adatcsomag XML-ből, upload the XML, check it and submit it. Record Submitted On and OKIR Filing Number, then click Mark as Submitted.

  7. When the MOHU invoice arrives, add it to MOHU Invoices in the Expected Fee tab: Invoiced by MOHU (net) and Difference show the comparison. A complaint with the correct data can be filed within 15 days of receipt (21. § (7)).

screenshot: finance-fl-hungary-epr-report
menu
Accounting ‣ Reporting ‣ EPR ‣ EPR Data Reports ‣ (report)
shows
Data report form of a quarter in the Closed state with the Export XML (OKIRkapu), Export XLSX and Mark as Submitted buttons, the totals, and the Summary tab listing KF codes with quantity, fee and declaring buyers.
highlight
The "Export XML (OKIRkapu)" button and the summary rows (red frame).
data
"EPR 2026 Q1"; rows 11011017 4.800 kg, 11202013 3.000 kg, 112020A3 3.000 kg (buyer "Minta Kft."), returned 11011017 0.960 kg.
module
l10n_hu_epr
notes
English UI, light theme, 1440px width, crop to the form sheet.

Corrections

The data of a submitted quarter can be corrected once a year, between 1 January and 31 March of the following year, or with a complaint against the MOHU invoice within 15 days (27. § (6), 21. § (7)). Create a new report for the quarter with Correction ticked and fill in Disputed MOHU Invoice or Authority Case Number. The correction takes a snapshot of all register lines of the quarter; the lines stay linked to the original report.

Note

The following cases are not supported by the module: the yearly report of small producers (KG:KGYF-ÉV), take-over contracts, deposit-return (DRS) products, the lump sum for wine bottles and vehicles, and the handling data of individual fulfillment.