Greece
Extended Producer Responsibility (EPR) for Packing in Greece
Greece transposed the EU Packaging Directive with Law 2939/2001, over-hauled by Law 4819/2021 and most recently tweaked by Law 5151/2024, obliging every company that places packaging on the Greek market to finance its collection and recycling . Oversight sits with the Hellenic Recycling Agency (EOAN), while the biggest collective scheme is HERRCO (Hellenic Recovery – Recycling Corporation) Together they form the backbone of EPR Greece compliance and drive national Greece packaging recycling targets.Who must register for EPR packing in Greece
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Greek manufacturers / packers of packaged goods.
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Importers or intra-EU acquirers bringing packaged products into Greece.
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Distance sellers with no Greek establishment selling B2C; these must act via an authorised representative
What the package includes
All primary, secondary and transport packaging made of paper & cardboard, plastics (incl. PET, HDPE, films), glass, metals (steel, aluminium), wood and composites is in scope of EPR packaging Greece once first placed on the marketThreshold
Greece applies no de-minimis exemption: a single item of packaging triggers duties under EPR registration Greece. Audit-grade “declaration-of-completeness” thresholds exist only for very large producers (>80 t glass, 50 t paper, 30 t plastics/metals) but registration itself is universalEPR registration procedure in Greece
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Create an account in the National Producers Registry (ΕΜΠΑ) on the EOAN portal and list all brands/packages.
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Sign a contract with an approved collective system – most producers join HERRCO – and pay the one-off enrolment plus material-specific eco-fees.
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Submit an initial weight forecast and keep monthly/quarterly internal records.
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File the annual packaging report in ΕΜΠΑ (see deadline below) and settle any fee adjustments.
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Retain all data for five years; EOAN may audit at any time.
Authorized representative
Since Law 4819/2021, any non-Greek business selling packaged goods directly to Greek consumers must appoint an authorised representative domiciled in Greece to fulfil all Hellenic Recycling Agency EPR duties (registration, reporting, fee payment) on its behalfReporting Deadline
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Annual packaging declaration (covering calendar year N-1)
• File the declaration with ΕΜΠΑ by 31 March of year N.
• Legal reference: Ministerial Decision 181504/2016, §§ 5-6. -
Ongoing weight updates to HERRCO
• Submit monthly or quarterly weight data, according to the schedule set in your contract with HERRCO.
• Governed by HERRCO’s standard terms and conditions.
Who Assumes Responsibility?
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Greek manufacturers / packers are fully responsible for their packaging as soon as the product is first placed on the Greek market.
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Importers or intra-EU acquirers assume full liability at customs clearance or arrival—unless the packaging is already covered by an upstream licence.
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Foreign distance sellers become liable—through a Greece-based authorised representative—whenever they make a direct B2C sale to a consumer in Greece.
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Producer Responsibility Organisations (e.g., HERRCO or an individual system) take on the operational duties of collection, recycling and reporting from the moment the membership contract is signed.
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EOAN (Hellenic Recycling Agency) maintains the producer register and enforces compliance, issuing producer numbers and conducting audits.
Duties of Each Group Who Is Responsible
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Producers / importers: register in ΕΜΠΑ, join a PRO, pay eco-fees, file annual data, keep records and display the EOAN producer number on invoices.
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Authorised representative: hold Greek VAT/Tax ID, maintain mandate, submit all declarations & payments, receive EOAN correspondence.
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PROs (e.g., HERRCO): meet material-specific recycling targets (65 % by 2025, 70 % by 2030), audit member data, finance nationwide blue-bin network and forward statistics to EOAN.
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EOAN / Ministry of Environment & Energy: approve systems, publish compliant-producer lists and levy fines up to €100 000 for serious breaches.