What is Greece EPR Packaging

Extended Producer Responsibility (EPR) in Greece is a waste management strategy that requires producers to take responsibility for the entire life cycle of the packaging they place on the Greek market. The legal framework is primarily defined by Law 4819/2021, which updated and integrated previous regulations such as Law 2939/2001 and Law 4496/2017. This legislation aligns Greek national law with EU Directives on packaging and packaging waste, ensuring that the financial burden of collection, sorting, and recycling is shifted from the public sector to the commercial entities responsible for the packaging. The national regulatory authority overseeing this system is the Hellenic Recycling Organization (EOAN).

Does this apply to e-commerce & online sales

Yes, EPR regulations apply to all forms of e-commerce and distance selling. Foreign companies selling products directly to Greek consumers (B2C) via online shops or marketplaces are legally considered producers. This includes responsibility for the primary packaging of the product as well as any shipping materials, such as cardboard boxes or plastic mailers, used to deliver the goods to the end-user in Greece. Online marketplaces also face increasing pressure to verify that their third-party sellers are compliant with national EPR requirements.

Who is the “producer” under Greece EPR?

Under Greek legislation, a "producer" is any natural or legal person who, regardless of the selling technique used, places packaged products on the Greek market for the first time. This includes:

1. Manufacturers based in Greece who package their own products.

2. Importers who bring packaged goods from other EU member states or third countries into Greece.

3. Distance sellers (foreign entities) selling directly to Greek end-users.

4. Distributors, if they place products on the market under their own brand name.

Who must register for EPR packaging in Greece

Every producer must register with the National Register of Producers (EM-PA), which is managed by EOAN. Registration is a mandatory prerequisite for legally placing packaged goods on the market. Furthermore, producers are required to organize an individual recycling system or, as is the standard practice, join a licensed Producer Responsibility Organization (PRO) to fulfill their recovery and recycling targets.

Greece EPR Packaging Registration Threshold

Greece does not have a "de minimis" threshold for registration; the obligation to register with EM-PA and join a PRO begins from the first unit of packaging placed on the market. Regardless of annual turnover or the volume of packaging waste generated, all companies meeting the definition of a producer must comply with the registration and reporting requirements. There are no exemptions based on small quantities for the administrative act of registration.

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Packaging Covered (and Excluded)

The EPR system covers all types of packaging placed on the Greek market, categorized as follows:

• Primary (Sales) packaging: Packaging that reaches the final consumer (e.g., a bottle or box).

• Secondary (Grouped) packaging: Packaging used to group products at the point of sale.

• Tertiary (Transport) packaging: Packaging used for the transport of goods (e.g., pallets and shrink wrap).

Materials include plastic, paper/cardboard, metal (aluminum and steel), glass, and wood. Exclusions are rare and generally only apply to packaging for specific medical or hazardous items that fall under separate specialized disposal regulations.

Producer Responsibility Organization (PRO)

To fulfill their recovery obligations, producers must contract with a licensed Collective Alternative Management System (SSED). The primary and most widely used PRO in Greece is the Hellenic Recovery Recycling Corporation (HERRCO), also known as EEAA. Other specialized systems exist for specific packaging types or industrial sectors. The PRO manages the collection and recycling infrastructure and reports back to EOAN on behalf of its members.

EPR Registration in Greece

The registration process for a foreign company typically involves the following steps:

1. Appointment of an Authorized Representative (for foreign companies without a local VAT number).

2. Enrollment in a licensed PRO (e.g., HERRCO) and signing a participation contract.

3. Payment of the initial administrative and contribution fees.

4. Online registration in the National Register of Producers (EM-PA) via the EOAN portal.

5. Receipt of a unique Producer Registration Number, which must be displayed on commercial documents as required.

Authorized Representative

Foreign companies located outside of Greece that sell products via distance selling must appoint a legal or natural person based in Greece as their Authorized Representative. This representative assumes the legal responsibility for fulfilling the producer's EPR obligations in the country, including registration with EOAN, reporting data, and ensuring that environmental contributions are paid to the chosen PRO.

What Data Must Be Reported

Producers are required to report detailed data on the packaging placed on the Greek market, including:

• Total weight in kilograms.

• Material composition (e.g., PET, HDPE, Corrugated Cardboard, Aluminum).

• The intended use of the packaging (B2B vs. B2C).

• Documentation verifying the accuracy of the weight data (invoices or technical specifications).

First Reporting Period & EPR Reporting Deadlines

Reporting is generally conducted on a quarterly or annual basis, depending on the contract with the PRO. However, the statutory annual report for the National Register of Producers (EM-PA) must typically be submitted by the end of February for the preceding calendar year. Producers must adhere to these deadlines to remain in "active" status on the national registry.

Labels & Marketing Claims

In accordance with Law 4819/2021 and Law 4736/2020 (for Single-Use Plastics), specific marking requirements apply. While the "Green Dot" symbol is commonly used and recognized in Greece via HERRCO, it is not a mandatory legal requirement for all packaging. However, certain single-use plastic items must carry specific "Plastic in Product" labels. It is also common practice to include the Producer Registration Number on sales invoices to demonstrate compliance to retailers and authorities.

EPR Eco Fees & Eco-Modulation

Fees are paid to the PRO based on the weight and material type of the packaging. Greece is increasingly implementing eco-modulation, where fees are adjusted (malus or bonus) depending on the recyclability of the material and the use of recycled content. For instance, composite materials that are difficult to recycle typically attract higher fees than mono-materials like cardboard or glass.

Risks, Penalties & Common Mistakes

Non-compliance with EPR regulations in Greece carries significant legal and financial consequences:

• Administrative fines ranging from 500 EUR to 500,000 EUR, depending on the severity and duration of the violation.

• Withdrawal of the company’s license to sell in the Greek market.

• Public "naming and shaming" on the EOAN registry of non-compliant producers.

• Common mistakes include failing to register transport packaging (pallets/shrink wrap) and missing the February reporting deadline for EM-PA.

What E-Commerce Sellers Should Do Now

1. Appoint an Authorized Representative if you have no physical presence in Greece.

2. Join a licensed PRO such as HERRCO to cover your recycling obligations.

3. Register your company in the National Register of Producers (EM-PA) and obtain your registration number.

4. Set up an internal reporting system to track the weight of all packaging materials shipped to Greek customers.

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FAQ

Is EPR registration required if I only sell a small number of items?

• Yes, there is no minimum threshold; compliance is mandatory from the very first item placed on the market.

Can I use my German or French EPR registration for Greece?

• No, EPR is a national obligation. You must register specifically in Greece with EOAN.

Is the Green Dot mandatory on my packaging in Greece?

• No, it is not legally mandatory, but it is highly recommended and requires a contract with HERRCO.

Who handles the reporting if I sell via Amazon or eBay?

• The seller is typically responsible for the packaging, though marketplaces increasingly require proof of your Greek Producer Registration Number.

How often do I need to report my packaging data?

• Annual reporting to EM-PA is mandatory, but your PRO may require more frequent (quarterly) data submissions.