EPR in Greece: EMPA, EOAN & HERRCO fees

Greece keeps a broad set of packaging and product rules on the statute book, but the working reality moves more slowly than the law suggests, so the useful question for an online seller is less "what does Greek law cover?" and more "what is actually operational, and where do I have to act now?" The answer begins in one place: the National Producer Registry (EMPA), run by the Hellenic Recycling Agency (EOAN), which is the single entry point for almost every regulated stream in the country. You register there, join the right scheme for each material you place on the market, and file periodic declarations. A handful of duties that already exist in Greek law - a beverage deposit-return system, and tobacco-filter and fishing-gear schemes - are adopted but not yet running, and this guide keeps the paper obligations and the live ones apart so your effort lands where it counts.

The register that runs Greek EPR: EMPA under EOAN

Almost everything routes through the National Producer Registry (EMPA). It is the single national registration point, supervised by the Hellenic Recycling Agency (EOAN), and it is where your legal standing as a producer lives. Packaging falls under Law 4819/2021, and other streams sit under their own EU-derived rules, but the front door is the same for all of them.

Two details trip up new sellers. First, EMPA registration and joining a scheme are separate steps. EMPA issues your producer number; you then contract a producer responsibility organisation (a PRO) to fund the physical recovery of your waste and to receive your material contributions. Second, one company does not register once and cover everything. Electronics, batteries, tyres and construction each register as distinct producer categories under your profile, so a seller with a mixed catalogue carries several parallel registrations. Once your account is live, your duty becomes a reporting rhythm: you, or your representative, submit periodic declarations of the exact quantities and weights you place on the Greek market.

For a non-Greek seller, the groundwork is administrative. You will need a Greek tax number to enter the database, and in practice most foreign sellers appoint a locally based representative to lodge the applications and handle the recurring filings. Treat the representative requirement as stream-specific rather than universal, and confirm it for each category you sell into before you commit.

Why Greek law offers no threshold to exempt small sellers

The obligation falls on any manufacturer, importer or distance seller that places packaged goods on the Greek market for the first time. If you fulfil orders to Greek consumers from a warehouse abroad, that is you. Greece does not publish a de minimis weight or turnover threshold that we would quote here, so the safe working assumption is that the duty attaches when you place packaging on the market rather than once you cross a sales line. Getting clear on which EPR duties apply to you is the first move before you ship into the country.

If you sell packaged goods to consumers in Greece, register in EMPA and join a packaging scheme before you rely on volume: Greek law does not offer a published threshold that exempts small sellers.

Packaging: HERRCO and the material-weight contribution

Packaging is the stream most sellers meet first. Under Law 4819/2021, both household and commercial packaging are regulated, and after you secure your EMPA number you contract an approved PRO to manage recovery. The primary packaging scheme is the Hellenic Recovery Recycling Corporation (HERRCO). You submit regular declarations of the packaging you have introduced, broken down by material, and your financial contribution is calculated from the material type and its weight. Lightweight, easily recycled materials cost less per kilogram than heavier or harder-to-process ones, so the make-up of your packaging directly shapes the bill.

The other streams EOAN actually runs

Beyond packaging, several streams are genuinely operational and register through EMPA under EOAN oversight. Electrical and electronic equipment has been regulated since 4 July 2012 under the WEEE Directive 2012/19/EU. Battery producers register under the EU Batteries Regulation (EU) 2023/1542, whose producer-responsibility rules apply from 18 August 2025 and cover standalone cells as well as batteries built into devices. Single-use plastic items have carried duties since 3 July 2021 under the Single-Use Plastics Directive 2019/904. End-of-life vehicles have been in scope since 21 October 2000, and tyres and waste oils run under national schemes, all registering in EMPA.

Construction and demolition materials deserve a note because they are rare across the EU. Greece runs producer responsibility for them, but the obligated parties are usually contractors and project managers rather than the kind of product seller reading this, and collection is handled through regional collective systems. Unless you place construction materials on the market yourself, it is unlikely to touch your compliance.

This is also where the gap between law and practice shows. Tobacco filters and plastic fishing gear are provided for in Greek law but were not confirmed operational in mid-2026, so treat them as coming rather than running. Textiles are firmly scheduled but not yet live: a national scheme must be operating from 17 April 2028 under Directive (EU) 2025/1892, which amends the Waste Framework Directive. Greece does not currently run active schemes for furniture, graphic paper, toys, DIY and garden tools, sports and leisure equipment or recreational boats.

HERRCO's per-weight fees, and EOAN's unpublished penalties

Your Greek bill has three parts: the registry side of EMPA, the scheme contribution you pay a PRO, and, for most foreign sellers, the annual fee for a local representative. For packaging, the scheme contribution is the variable that moves with your catalogue, since HERRCO prices by material and weight. Electronics and batteries carry their own scheme fees, set by the category and volume of equipment you introduce, so a mixed catalogue means several fee lines rather than one.

Greece does not publish scheme fee bands or penalty figures at a level of detail we would quote, but the enforcement authority is clear: EOAN holds oversight and can act against producers who place goods on the market without a valid EMPA registration. Budget for the recurring reporting and representation cost as an operating line, not a one-off, because the declarations repeat on a fixed cadence.

The deposit-return system: adopted, not yet operational

Greece has adopted a deposit-return system for single-use beverage containers, under which a consumer pays a small deposit at purchase and reclaims it on returning the empty container. It is worth being precise about its status, because it is easy to overstate. As of a parliamentary question in late May 2026, the system was still not operational: the operator's operational plan had not been submitted to EOAN for approval, and the appointed operator, DRS Hellas, faced questions over the transparency of its tender. So the honest reading is adopted on paper, not yet running.

Two practical points follow. First, a deposit-return system is separate from your packaging EPR obligations; a deposit is refundable and returns to the consumer, whereas your PRO contribution funds recovery and does not. Registering with HERRCO does not discharge any future deposit duty, and vice versa. Second, because there is no confirmed operational date, the sensible stance is to watch for the launch rather than build labelling or collection changes around it now.

Milestones, current and pending

Greece's calendar mixes long-standing EU streams with duties that are scheduled but not yet live. The dates below are the ones that anchor your planning.

Working out your packaging weights by material and keeping every declaration on time is exactly the part that eats into running a store. Turn your product data into filing-ready reports to keep your Greek registrations current and your listings live.

---

Sources:

• The National Producer Registry EMPA
• The Hellenic Recycling Agency EOAN
• The EU Batteries Regulation 2023/1542
• The WEEE Directive 2012/19/EU
• The Single-Use Plastics Directive 2019/904
• The textiles Directive (EU) 2025/1892