Greece Battery EPR Fees 2026: Rates and Registration

Businesses placing batteries on the Greek market in 2026 must account for producer registration, approved waste-battery management arrangements, and financial contributions linked to the batteries they supply.

There is no single universal Greek battery EPR fee. The amount depends on battery category, chemistry, quantity, and the approved compliance scheme responsible for managing the associated waste batteries.

Importantly, Greece has a documented 2026 tariff decision. On 6 April 2026, the Hellenic Recycling Agency (EOAN) approved updated battery categories and financial contributions for the collective compliance scheme COMBATT.

These rates provide concrete budgeting figures for several categories, including industrial batteries, vehicle batteries, electric-vehicle batteries, and batteries used in light means of transport. However, they are contributions payable under the COMBATT scheme, not a separate government tax or a universal national price list.

This guide explains those verified rates alongside registration, reporting, authorized-representative requirements, and other costs producers should consider.

Greece Battery EPR Costs in 2026 at a Glance

Fee distinction: COMBATT contributions are approved by EOAN but collected by the compliance scheme. They should not be presented as statutory fees paid directly to the regulator.

The EOAN tariff decision reviewed for this article does not expressly state whether its figures include or exclude VAT. Producers should confirm the tax treatment on their applicable contract and invoice.

Battery Extended Producer Responsibility requires businesses responsible for placing batteries on the market to finance or organize the management of those batteries when they become waste.

In Greece, this operates through the national alternative management framework supervised by the Hellenic Recycling Agency (EOAN).

The main regulatory framework includes:

•  Regulation (EU) 2023/1542 on batteries and waste batteries.

•  Greek Law 4819/2021 on waste management and producer responsibility.

•  National rules governing the National Producers Register, known as EMPA.

•  The approvals and operating conditions of Greek battery compliance schemes.

The EPR provisions of the EU Batteries Regulation began applying on 18 August 2025, making them part of the established compliance framework throughout 2026.

Producers must ensure that their batteries are covered by an authorized management arrangement and that the required registrations, declarations, and contributions are maintained.

Battery producer responsibility does not apply only to companies physically manufacturing batteries in Greece.

Under the EU Batteries Regulation and EOAN's producer guidance, the legally responsible producer may include:

•  A manufacturer placing batteries on the Greek market under its own name or trademark.

•  A brand owner selling batteries made by another company under its brand.

•  An importer introducing batteries into Greece from another EU Member State or a non-EU country.

•  A distributor that first makes batteries available on the Greek market and meets the legal producer definition.

•  A foreign online seller supplying batteries directly to final users in Greece.

•  A business placing batteries on the market within equipment, light means of transport, or vehicles.

For example, a Greek business importing rechargeable batteries from another EU country for its first Greek sale may be the responsible producer even though it does not manufacture the products.

Conversely, a retailer that purchases batteries from an already compliant Greek producer is not automatically required to register again for those same batteries merely because it resells them.

Companies should establish producer responsibility for each supply chain rather than assuming that the manufacturer is always the obligated party.

The EU Batteries Regulation distinguishes five categories:

A battery can be subject to EPR whether sold separately, supplied as a replacement, or incorporated into another product.

Accurate classification matters because Greece's approved scheme rates may distinguish battery applications, chemistry, voltage, capacity, and weight.

Is battery producer registration mandatory?

Yes. Obligated battery producers must register in Greece's National Producers Register (EMPA), managed by EOAN.

The official portal is the National Producers Register — EMPA.

A typical registration process involves:

1. Creating or accessing a producer account in EMPA.

2. Entering the company's identification and contact information.

3. Identifying the regulated product categories.

4. Establishing a contract with the appropriate approved compliance scheme.

5. Submitting the required declarations.

6. Having the relevant scheme confirm the active contract and reported quantities.

7. Obtaining the producer registration number and certificate after EOAN verification.

The registration process should be completed before batteries are first placed on the Greek market.

Is EMPA registration free in 2026?

EOAN's published registration instructions do not identify a separate, fixed 2026 government registration tariff.

Therefore, this research did not establish a statutory charge for submitting a battery producer registration directly through EMPA. However, the absence of a published tariff should not be confused with a confirmed exemption from all compliance costs.

A producer may still incur scheme contributions, representative fees, or optional registration-assistance charges.

Businesses should distinguish between registration with the government register and commercial participation in a battery compliance system.

Does registration require annual renewal?

EMPA issues a producer registration number and a certificate linked to the relevant product coverage.

EOAN explains that a printed registration certificate is valid for three months after printing and can be printed again while the applicable compliance-scheme agreement remains active.

This three-month document validity should not be mistaken for a quarterly registration fee or an obligation to purchase a new registration every three months.

Foreign companies must assess whether they need an authorized representative established in Greece.

Under Article 56(3) of Regulation (EU) 2023/1542, producers established in another EU Member State or a third country that sell batteries directly to Greek end users through distance contracts must appoint an authorized representative for EPR.

EOAN's producer-registration guidance also describes the authorized-representative procedure for producers whose registered office is outside Greece.

The representative may perform agreed registration and compliance functions under a written mandate. However, the producer must still provide accurate product and transaction information and ensure that its legal obligations are fulfilled.

Authorized-representative fees are commercial charges, not a fixed Greek government EPR tariff. Costs can depend on the services covered, product categories, reporting frequency, and contractual responsibilities.

A December 2025 European Commission proposal would suspend certain mandatory representative appointments until 2035. As of October 2026, that proposal remains under the EU legislative process and should not be treated as an enacted exemption.

Producers generally fulfil their waste-battery obligations by participating in an approved collective scheme. An appropriately authorized individual management system may also be available.

EOAN identifies the following battery-related collective systems:

EOAN records the approval of RE-BESS IFAISTOS on 12 November 2025, so it is important not to rely on historical lists containing only three organizations.

Scheme approval does not mean every organization covers every battery category. Producers should verify the current authorization scope before contracting.

For portable batteries, AFIS confirms that producer contributions support its collection, transport, storage, and recycling arrangements. A reliable publicly accessible 2026 contribution tariff was not established in this research; portable-battery producers should request current written pricing.

The most useful verified fee information comes from EOAN Board Decision 230.4 of 6 April 2026.

The decision updates COMBATT's authorized battery categories and sets contributions based on the quantities placed on the market.

The following figures are from that decision. They are EOAN-approved COMBATT contributions, not universal tariffs automatically payable by every battery producer in Greece.

LMT Battery Contributions

The decision's low-grade lithium grouping includes LFP and certain manganese-based chemistries, while its superior-grade grouping includes LCO, NMC, and NCA chemistries.

These terms are used as tariff classification labels. They should not be interpreted as general judgments about product quality or performance.

SLI Battery Contributions

For lead-acid starter batteries, the rate is determined by capacity in ampere-hours rather than total battery weight.

Industrial and Electric Vehicle Battery Contributions

Higher-capacity industrial lead-acid batteries may use other bands or a separate formula. For qualifying individual 2 V cells and associated battery assemblies, the decision provides:

Number of 2 V cells × ampere-hours × €0.002 = contribution

The exact configuration must be confirmed before using that formula.

Special Treatment for Certain M1 and N1 EV Batteries

The decision also distinguishes batteries associated with qualifying M1 and N1 vehicles managed under the Greek end-of-life vehicle system, EDOE.

For the specified batteries, the applicable COMBATT registration or recording charge is €0.10 per battery, rather than the ordinary EV battery management contribution.

This arrangement applies only where the battery falls within the relevant approved vehicle-management coverage. It is not a general €0.10 rate for every electric vehicle battery sold in Greece.

Special 2026 Financial Arrangements for Large-Scale BESS

A significant feature of the April 2026 decision concerns certain large-scale, grid-connected battery energy storage systems classified under COMBATT's BESS-B2B category.

The decision provides two distinct obligations:

1. Recording and monitoring contribution: €0.10 per kilogram placed on the market.

2. Financial security for future waste management: calculated using €1.75 per kilogram.

The second amount is a guarantee basis, not simply another fee payable immediately as an ordinary recycling contribution.

Depending on the applicable conditions, the producer can secure the obligation through a pledged account, bank guarantee, or qualifying corporate guarantee.

This distinction is particularly important for renewable-energy developers and industrial storage suppliers budgeting for large projects.

2026 tariff note: The EOAN decision is dated 6 April 2026. It should not automatically be assumed that these updated classifications and figures applied from 1 January 2026. Producers should confirm the communicated effective date and applicable contract version for quantities placed on the market earlier in the year. The decision does not specify VAT treatment.

How Are Greece Battery EPR Fees Calculated?

For battery categories assessed by weight, the calculation is:

Battery weight placed on the Greek market (kg) × applicable contribution rate (€/kg) = producer contribution

For categories assessed by unit:

Number of batteries × applicable contribution per unit = producer contribution

A producer supplying several battery types must classify and calculate each category separately.

Worked 2026 Example: SLI and LMT Batteries

Assume a company supplies the following qualifying products under the COMBATT rates approved in April 2026:

The €436 is an illustrative scheme-contribution calculation, not a personalized compliance quotation. It excludes any applicable VAT, representative services, and other contractual costs.

For a separate example involving 2,000 kg of qualifying large-scale BESS batteries, the €0.10/kg recording contribution equals €200, while the €1.75/kg guarantee basis equals €3,500 of required security. These should be recorded separately in the project budget.

Two businesses operating in Greece may face different compliance costs because their products and obligations are not identical.

Important factors include battery chemistry, application category, weight, number of units, capacity, and the applicable approved scheme.

The battery's supply route also matters. A foreign direct seller requiring a representative has a different administrative cost structure from a domestic producer managing registration internally.

Large stationary storage batteries can additionally create security and financing obligations that are not comparable with ordinary portable battery contributions.

Producers should therefore maintain a separate EPR budget for each battery category and request a quotation or tariff confirmation from the scheme covering that category.

Greek battery producers must maintain reliable records of the quantities placed on the national market.

Relevant information can include:

•  Battery category and chemistry.

•  Number of units and net battery weight.

•  Capacity and voltage where required.

•  Batteries sold separately or incorporated into products.

•  Reporting period and quantities first placed on the Greek market.

•  Scheme contracts, declarations, invoices, and supporting evidence.

EMPA requires annual producer reporting, while collective schemes can impose additional reporting and payment cycles.

For example, COMBATT's published producer agreement requires quantities to be reported within 10 calendar days following the end of each calendar quarter.

The agreement specifies quarterly contribution payments by 30 April, 31 July, 31 October, and 31 January.

These are COMBATT contractual conditions, not deadlines that can automatically be applied to AFIS, Re-Battery, or other schemes.

EOAN's default annual EMPA reporting deadline is 31 March for the preceding calendar year, unless EOAN changes the deadline.

Producers should reconcile EMPA declarations with scheme submissions and accounting data so that all three reflect the same placed-on-market activity.

Key Battery EPR Dates for 2026

New producers should not wait for an annual reporting deadline to register. Registration and an appropriate compliance arrangement are required before placing regulated batteries on the market.

Failure to meet battery EPR obligations can create problems with legal market access and supply-chain verification.

EOAN identifies the EMPA registration certificate as a prerequisite for placing covered products on the Greek market. Producers may also need to demonstrate compliance when supplying distributors, business customers, or public procurement channels.

Non-compliance can lead to regulatory enforcement under the applicable legal framework. However, penalty amounts depend on the relevant infringement and legal provision; there is no sound basis for presenting one universal fine for every battery EPR violation.

Maintaining current registration and scheme evidence is therefore essential.

Practical Greece Battery EPR Compliance Checklist for 2026

1. Determine producer status: Identify which legal entity first places each battery product on the Greek market.

2. Classify batteries: Assign each product to the correct portable, LMT, SLI, industrial, or EV category.

3. Confirm foreign representation: Assess whether an authorized EPR representative is required.

4. Select the compliance route: Verify the relevant approved scheme's current category coverage or an authorized individual system.

5. Complete EMPA registration: Obtain the registration number and appropriate certificate before market entry.

6. Maintain product data: Record chemistry, weight, units, capacity, and whether batteries are incorporated into other products.

7. Apply verified contribution rates: Use the correct provider-specific tariff and applicable effective date.

8. Submit reports and payments: Follow both EMPA requirements and contractual scheme deadlines.

9. Preserve compliance evidence: Keep declarations, certificates, mandates, invoices, and reconciliation records.

Greece battery EPR costs cannot be reduced to one registration charge or a single nationwide recycling fee.

For 2026, businesses should separately identify:

•  Any official registration charge, if confirmed by EOAN.

•  Contributions payable to their approved compliance scheme.

•  Additional representative or administrative service costs.

•  Reporting and data-management expenses.

•  Any category-specific financial guarantees.

The April 2026 EOAN decision provides verified COMBATT contribution rates for several battery categories. It also establishes distinctive financial arrangements for large-scale BESS batteries.

These figures make budgeting more practical, but they must be matched to the correct battery category, scheme, contract, and effective period.

1. How much are battery EPR fees in Greece in 2026?

There is no single nationwide charge. For example, the April 2026 COMBATT decision establishes rates of €1.93/kg for certain LMT lithium batteries and €0.72/kg for certain EV lithium batteries. Other battery categories and schemes have different arrangements.

2. Is battery EPR registration free in Greece?

No separate official 2026 EMPA registration charge was identified in the published EOAN instructions reviewed. However, this does not mean battery compliance is free: scheme participation and other services may generate costs.

3. Is joining a battery PRO mandatory in Greece?

Producers must arrange compliant waste-battery management. Participation in an appropriately approved collective scheme is a common route, but an authorized individual compliance system may also be possible.

4. Which battery recycling scheme should my company use?

The answer depends on battery classification and each scheme's approval. AFIS covers portable batteries, while other approved systems include COMBATT, Re-Battery, and RE-BESS IFAISTOS. Confirm category coverage before signing a contract.

5. Do foreign online sellers need an authorized representative?

Foreign producers selling batteries directly to Greek end users through distance contracts fall under the representative requirement in Article 56(3) of the EU Batteries Regulation, subject to any subsequently enacted changes. Appointment charges are commercial, not fixed national EPR fees.

6. How are Greece battery EPR fees calculated?

Depending on the relevant tariff, producers multiply declared kilograms by the applicable €/kg rate or the number of units by the per-unit contribution. Certain industrial batteries have capacity-based formulas, while qualifying large-scale BESS batteries have additional guarantee requirements.

7. When must Greek battery EPR reports be submitted?

EOAN's general annual EMPA deadline is 31 March for the previous year unless adjusted. Compliance schemes may require additional submissions. COMBATT's published agreement specifies quarterly declarations within 10 calendar days of quarter-end.

8. Are the COMBATT rates the same as government recycling taxes?

No. They are financial contributions under an approved collective compliance system. EOAN approval establishes the scheme's authorized contribution structure, but the payments are made to the scheme rather than treated as a separate government tax.

Managing battery producer responsibility across European markets requires more than storing registration certificates.

Businesses must determine where they qualify as producers, identify country-specific obligations, classify batteries accurately, maintain scheme relationships, report placed-on-market quantities, and track changes in regulatory requirements.

ComplyMarket supports these activities through structured EPR compliance management, product data maintenance, regulatory requirements, documentation, and evidence workflows.

For businesses operating in Greece, this can help organize battery category and weight information, producer registration records, approved scheme details, compliance deadlines, and supporting evidence.

Companies managing additional streams can also connect these activities with their wider Extended Producer Responsibility Management processes.

For further information about national registration and reporting, see ComplyMarket's Greece Battery EPR Compliance Service.

Businesses with products covered by multiple EPR streams can also review the related Greece Packaging EPR and Greece WEEE EPR services.

Contact ComplyMarket to discuss how to organize country-specific EPR requirements, maintain reliable producer data, and improve visibility over battery compliance obligations across your markets.