Greece — packaging EPR

Does it apply to me?

Greek packaging law places responsibility on persons that package goods, import packaged goods, or place packaged goods on the Greek market. HERRCO's published guidance goes further than most national texts and expressly includes natural or legal persons established in another EU member state or a third country that professionally sell packaged goods directly to Greek households or other users through distance contracts.

You ship to Greek consumers, no Greek establishment

Yes. Register in EMPA, join an approved system, appoint a representative, declare.

You're established elsewhere in the EU

Caught, under both the Greek producer definition and Art. 45(3) first sentence.

You're established outside the EU

Caught as a producer — the Greek definition names third countries expressly. Whether Greece also took the Art. 45(3) second-sentence option on the representative is unconfirmed, so assume it is owed.

You only sell a little

No help. No general low-volume exemption was identified for registration or system participation, and HERRCO states that audits may cover businesses of any size.

You sell through a marketplace

Read the marketplace rule before anything else. It is the part of Greek law most likely to affect you first.

The obligation covers packaging from all sources and materials — sales, grouped and transport packaging alike. There is no version of this where only the retail box counts.

EMPA and EOAN

The official register is the National Producer Register, universally called EMPA, operated by EOAN — the Hellenic Recycling Agency. Producers create an online account and register the applicable product category.

On Art. 44(3) — whether a representative may register in your place — Greece has not published an answer. The fact that producers create their own EMPA account points towards personal registration, but that is an inference from a portal design, not a legal position, and we are not going to dress it up as one. Ask EOAN before you assume either order.

The marketplace rule

Croatia has a version of this and so, in a softer form, does Art. 45(4)–(6) of the PPWR. Greece's is worth singling out because of what it does to the platform's incentives. A marketplace that cannot see your EMPA evidence is not merely failing to police you — it is potentially carrying your obligation itself. Platforms respond to that the way you would expect: they ask early, they ask for documents, and they suspend listings rather than correspond.

So the practical order of operations for a marketplace seller in Greece is the reverse of the intuitive one. You do not sell, get asked, and then register. You register, save the evidence, and have it ready before the first request — because the request tends to arrive as a deadline rather than a question.

HERRCO

A producer must arrange alternative management of its packaging: either an approved individual system, or — realistically — a participation contract with an approved collective system. HERRCO operates the nationwide Collective Alternative Management System (RECYCLING) and accepts responsible packagers, importers and foreign distance sellers.

Participation covers your contribution toward collection and recycling. It does not move the registration, the declarations or the payment obligation off you — HERRCO is explicit that the producer remains responsible for correct registration, declarations and payment.

The representative

From 12 August 2026 Art. 45(3) requires a producer established outside Greece that makes packaging available directly to Greek end users to appoint an EPR authorised representative established in Greece. No threshold, no election.

Greece had not published a complete appointment procedure, an official form or a public directory when we checked. So the mandate is a private document, and what goes in it is up to you. Cover, explicitly:

• Support with the EMPA registration and keeping the entry current
• Membership of the collective system
• Submission of packaging declarations
• Payment of contributions
• Correspondence with EOAN

In a market where the administration runs in Greek, the representative is doing considerably more real work than in, say, Denmark. Price it accordingly, and pick on capability rather than on fee.

What it costs

Greece is the least budgetable country in this group. We would rather print an honest table of blanks than a plausible-looking number lifted from a comparison site — and if you get a real quotation, it is one of the more useful things you could send us.

Reporting

Members submit packaging declarations through the system's declaration application using their account credentials. All relevant primary, secondary and tertiary packaging placed on the Greek market should be included unless a specific exclusion applies.

Keep material-weight calculations, sales records, invoices, system declarations and proof of EMPA registration. HERRCO may audit declaration data irrespective of company size, which is a deliberate statement and worth reading as one.

The language problem

We would normally leave this to a footnote. In Greece it belongs in the body, because it changes what the job actually is.

The register and most of the administrative material are primarily in Greek. Not partially, not with an English mirror that lags — primarily. For a foreign micro-business that turns a form-filling exercise into a dependency: you will need practical support from your representative or your system provider, and the quality of that support is the difference between Greece being a two-week task and a two-month one.

Labelling

HERRCO members may use the Green Dot trademark under the participation contract. As everywhere, the mark indicates financial participation in a recovery system — it does not mean the packaging is recyclable. Do not print it before the contract grants you the right to.

No general Greece-only recycling mark was identified as mandatory for ordinary shipping packaging. Product-specific rules, single-use-plastic markings and deposit-return packaging must be checked separately where they apply to you.

The EU harmonised sorting label under Art. 12(1) applies from 12 August 2028 at the earliest, with its artwork fixed by implementing acts. Do not design for it yet.

If you don't

Greek waste legislation — principally Law 2939/2001 on packaging and alternative management, and Law 4819/2021 on the integrated waste framework — provides both administrative and criminal penalties. We have not verified a specific figure for a packaging registration failure and will not invent one.

In practice the mechanism you are most likely to meet is commercial rather than criminal: a marketplace acting on the responsibility-shift rule, and HERRCO auditing a declaration. Both arrive faster than an authority does.

And underneath, Art. 44(4): until the register entry exists you may not make packaging available on the Greek market at all.

"It's been suspended"

Until something is adopted and enters into force, Art. 45(3) applies as written, and it has applied since 12 August 2026. See our note on it.

Known traps

Sources

The Greek authority and register establish the framework. HERRCO is used for the practical route and for the producer definition covering foreign distance sellers — it is the approved collective system, which makes it useful and not neutral.

1. EOAN — Hellenic Recycling Agency Official. The national EPR authority, operator of the National Producer Register and the body that approves alternative-management systems
2. EMPA — National Producer Register Official. Account creation, product-category registration and the evidence of registration that a marketplace will ask for
3. HERRCO — Hellenic Recovery Recycling Corporation Scheme source. Source for the producer definition expressly covering persons established in another member state or a third country selling by distance contract to Greek households, for coverage of sales, grouped and transport packaging, for contributions being set in the participation contract rather than published, for audits irrespective of company size, and for the Green Dot being a mark of financial participation
4. Law 2939/2001 and Law 4819/2021 The Greek packaging and alternative-management statute and the integrated waste-management framework, which together carry the administrative and criminal penalties
5. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Read in full, 14 August 2026. Source for Art. 3(1)(15)(c)–(d) on the distance-selling producer, Art. 44(2) and 44(4) on registration, Art. 44(3) on delegated registration, Art. 45(3) on the representative, Art. 45(4)–(6) on marketplaces and Art. 12(1) on the 2028 harmonised label
6. COM(2025) 983 — Environmental Omnibus proposal The proposal that would suspend the EPR representative duty for EU-established producers to 2035. A proposal, not law
7. European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full

Help us finish this desk

This draft was assembled on 15 August 2026 from EOAN, EMPA, HERRCO guidance and a contributed country profile. It has not been checked by anyone who has actually registered in Greece from outside it, and it has no keeper.

Four things we specifically don't know. What HERRCO actually charges a foreign micro-seller — the single most useful number anyone could send us. The declaration deadline in a real participation contract. Whether EMPA can be operated in English, or at all, by a non-Greek company. And whether Greece took the third-country option for the representative, given that its producer definition already names third countries.