Greece Packaging EPR Fees 2026: Rates and Registration

Businesses placing packaging or packaged products on the Greek market in 2026 must consider Extended Producer Responsibility (EPR) compliance costs, including recycling scheme contributions, registration administration, reporting, and potentially authorized representation.

Greece does not impose one universal packaging EPR fee on every producer. Costs depend on the packaging materials, quantities introduced to the Greek market, the approved compliance arrangement, and applicable contractual conditions.

The Hellenic Recycling Agency (EOAN) oversees producer registration through the National Producers Register (EMPA). Businesses generally need an appropriate packaging recycling arrangement and must declare the quantities for which they are responsible.

For financial planning, an important distinction is necessary: HERRCO has published material-based contribution rates in its 2025 annual report, but a separately verified 2026 tariff could not be established from the available public documents reviewed. Those historical rates provide a useful benchmark, not a confirmed 2026 quotation.

This guide explains which charges apply, how they are calculated, what producers must report, and how the EU Packaging and Packaging Waste Regulation (PPWR) affects obligations during 2026.

2026 fee note: No single nationwide €/kg or €/tonne tariff covers all packaging. Before budgeting, request the effective 2026 contribution schedule, applicable VAT treatment, joining conditions and payment terms from the selected scheme.

Greece's packaging EPR framework is primarily established through Law 4819/2021, alongside relevant national implementing measures and EU legislation.

The system places financial and administrative responsibilities on businesses that introduce packaging or packaged products to the Greek market.

Its principal components are:

• EOAN: The Hellenic Recycling Agency, which oversees the national framework and approved alternative waste-management systems.
• EMPA: The National Producers Register, where obligated producers register and report.
• Approved packaging schemes: Organizations or approved individual systems that arrange and finance packaging waste management.
• Producers: Businesses legally responsible for packaging placed on the market.

A company must establish its producer responsibility, participate in an appropriate compliance arrangement, provide packaging declarations, and maintain supporting records.

Registration alone does not settle the producer's recycling obligations. Likewise, paying a recycling scheme does not automatically replace the requirement to maintain accurate EMPA registration and declarations.

For a broader overview of the regulatory process, see ComplyMarket's Greece Packaging EPR Compliance and Registration Services.

Greek packaging EPR obligations depend on who introduces the relevant packaging to the market, rather than simply who manufactures the packaging itself.

Potentially obligated businesses include:

• Manufacturers that package products for sale in Greece.
• Importers introducing packaged goods into Greece.
• Brand owners commissioning packaged products.
• Businesses filling or arranging the filling of packaging.
• Manufacturers or importers of certain packaging intended to be filled at the point of sale.
• Foreign businesses selling packaged goods directly to Greek customers through distance-selling arrangements.

A distributor is not automatically the obligated producer in every transaction. The correct determination depends on the importer, seller, contractual arrangements and actual product flow.

For example, a Greek importer purchasing finished packaged goods from outside Greece may be responsible for the imported packaging.

However, a foreign online seller supplying Greek end users directly may itself have obligations even without a Greek subsidiary.

Businesses should document the responsible legal entity for each sales channel. Otherwise, they risk omitted declarations or assigning the same responsibility incorrectly between suppliers and customers.

Greek packaging EPR is not limited to plastic bottles or household packaging.

The scope can include sales packaging, grouped packaging, transport packaging and relevant service packaging.

Packaging materials include paper and cardboard, plastics, glass, aluminium, ferrous metals, wood and composites.

An important Greece-specific rule concerns packaging filled at the point of sale, such as certain bags and wrapping materials. Since 23 July 2021, responsibility for qualifying service packaging has generally shifted to its manufacturers or importers rather than the business filling it at the point of sale.

Commercial and industrial packaging should not automatically be excluded. Packaging removed at a warehouse, for example, may still fall within the Greek declaration scope.

Is EMPA registration mandatory?

Yes. Obligated packaging producers must register through Greece's National Producers Register, administered by EOAN.

EOAN's official guidance describes a sequence involving company registration, an approved scheme contract, quantity declarations and verification.

The process generally involves:

1. Creating the producer's company record in EMPA.
2. Entering the relevant company identification and activity information.
3. Concluding an agreement with the appropriate approved packaging scheme.
4. Declaring the scheme and relevant packaging quantities.
5. Obtaining scheme verification and the producer registration number.

Once the required information is verified, the producer receives its registration number and can access its registration certificate.

The official portal is EMPA - National Producers Register.

How much does EMPA registration cost?

No separate official government filing fee for standard EMPA producer registration was identified in EOAN's publicly available registration instructions reviewed for this article.

This is different from the commercial cost of joining a packaging recycling scheme.

Businesses should therefore distinguish between:

• The cost, if any, of a government registration transaction.
• Mandatory contributions payable to the recycling scheme.
• Optional fees for a consultant or compliance provider preparing registration documents.
• Potential scheme-specific onboarding charges.

No annual government renewal fee should be assumed without an applicable official tariff. Producers must nevertheless maintain an active registration and supporting compliance arrangements.

Foreign producers selling packaged goods into Greece must assess whether an authorized representative established in Greece is required.

EOAN's registration guidance accommodates the appointment of a locally established representative under a written mandate.

There is also an important regulatory change during 2026.

From 12 August 2026, Regulation (EU) 2025/40, the PPWR, generally applies. Its cross-border producer-representation provisions establish authorized representative requirements across EU Member States.

The European Commission has proposed suspending the cross-border representative requirement for small businesses. As of October 2026, that proposal should not be treated as an enacted exemption. The Commission has advised a pragmatic enforcement approach while the legislative process continues.

The representative's role can involve registration and EPR obligations covered by the mandate. Producers remain responsible for ensuring that the underlying packaging information and compliance arrangements are accurate.

Authorized representative fees are commercial charges, not a standardized Greek government fee. The amount depends on the provider, legal responsibility, contractual scope and reporting support included.

Businesses should confirm their precise status before assuming every foreign sales model requires the same arrangement.

Greek packaging compliance can be fulfilled through an appropriate approved collective scheme or, where authorized, an individual compliance system.

EOAN identifies several packaging-related systems.

HERRCO

The Hellenic Recovery Recycling Corporation, commonly known as HERRCO or EEAA, operates the widely recognized packaging recycling scheme associated with Greece's blue-bin collection network.

It contracts with obligated producers and collects contributions to finance packaging waste management.

Antapodotiki Anakyklosi

Antapodotiki operates a packaging recovery and recycling system using a reward-oriented collection model.

Producers should verify whether its approved scope and contractual arrangements are appropriate for their packaging activities.

KEPED

KEPED is listed by EOAN as a packaging system specifically covering lubricating-oil packaging.

It should not be treated as a general alternative for every category of packaging.

Individual compliance systems

EOAN also identifies approved individual packaging systems, including one associated with AB Vasilopoulos.

An existing company's individual system is not automatically available for unrelated producers to join.

The important distinction is that HERRCO is not the only named packaging system, but each producer must use an approved compliance route appropriate to its activities.

1. Official registration charges versus scheme contributions

Greek packaging EPR expenditure is generally driven by the contribution required under the relevant compliance arrangement.

A scheme may charge for packaging quantities placed on the Greek market, based on its tariff structure and contractual terms.

These contributions help finance collection, sorting, recovery and recycling activities.

They are not equivalent to a government registration fee, municipal waste charge or packaging tax.

2. Published HERRCO packaging contribution benchmarks

HERRCO's 2025 annual report, made available in June 2026, provides the following material-based contribution schedule.

Important: The figures below are explicitly 2025 HERRCO provider rates. They have not been independently verified as the effective 2026 tariff and must not be presented as official nationwide 2026 rates.

The same report identifies a €0.0004 contribution per packaging unit, alongside weight-based contributions in the relevant calculation.

For the reported year, HERRCO also identifies a weight-only contribution for plastic carrier bags at €70.50 per tonne.

These amounts are provider-specific. They are not statutory tariffs that every approved scheme must charge.

HERRCO's earlier published collaboration agreement specifies that contributions exclude VAT. However, businesses must verify the VAT treatment and all applicable charges in the contract and invoices governing 2026.

HERRCO's website links to a collaboration agreement uploaded in May 2026. Because the full financial terms of that version could not be independently verified here, a confirmed 2026 price table is not reproduced.

3. Scheme onboarding and other contractual charges

Producers should not assume that their financial obligations consist exclusively of the material-based contribution.

Earlier HERRCO contract documentation included conditions under which an initial contribution applied to previously marketed packaging.

The applicability and calculation of any such charge in 2026 require confirmation against the current agreement.

A commercial quotation should therefore clarify:

• Whether an entrance or onboarding contribution applies.
• Whether a minimum annual contribution exists.
• Which packaging categories and quantities are chargeable.
• Whether any additional administrative services are billed.
• Whether reported quantities are reconciled against advance payments.
• Whether quoted amounts include or exclude VAT.

4. How to obtain confirmed 2026 rates

To establish the actual 2026 budget, request the applicable contribution schedule directly from the selected approved scheme.

The request should identify the producer, packaging materials, annual units, component weights, reporting period and intended compliance route.

Ask the scheme to confirm the effective tariff date, any mid-year changes, payment schedule and treatment of packaging introduced before the contract was signed.

A quotation based on another producer's contract or an older annual report is not a reliable substitute for these terms.

Where the applicable scheme uses both weight-based and per-unit contributions, the calculation can be expressed as:

Packaging contribution = Total contribution by material weight + Applicable contribution by packaging unit

Each material must be assessed using its correct reporting category.

For the weight component:

Packaging weight in tonnes x applicable scheme rate per tonne = material contribution

Where a per-unit element applies:

Number of chargeable packaging units x applicable unit rate = unit contribution

Producers must avoid multiplying product weight by a packaging tariff. The relevant quantity is the weight of packaging placed on the Greek market, not the weight of the packaged product.

Composite materials, reusable packaging and special packaging categories may require more specific classification or contractual treatment.

Worked Example: Packaging Contribution Calculation

The following example demonstrates the calculation method using published 2025 HERRCO figures solely as a historical planning benchmark. It is not a verified 2026 invoice or quotation.

Assume a business introduces 100,000 individual products into Greece. Each product uses one 30-gram paperboard packaging unit.

Step 1: Determine packaging weight

100,000 units x 30 grams = 3,000,000 grams

Total paperboard packaging = 3 tonnes

Step 2: Calculate the material contribution

3 tonnes x €55.50 per tonne = €166.50

Step 3: Calculate the unit contribution

100,000 units x €0.0004 = €40.00

Step 4: Calculate the illustrative total

€166.50 + €40.00 = €206.50

This excludes VAT, other packaging components, potential contractual charges, representation costs and other services.

For an actual 2026 calculation, the producer must replace these historical values with the verified contribution rates applicable to its own agreement.

Two companies selling similar products in Greece may have different packaging EPR costs.

The main reasons include material selection, packaging weight, number of components, sales volumes, classification, and the terms of their approved compliance arrangement.

A glass container and a paperboard carton may have different weight-based contributions. A product with several packaging components may also require more detailed calculations than a product using a single material.

The PPWR introduces a broader EU framework affecting packaging sustainability and EPR obligations. However, businesses should not assume that Greece already applies a specific new 2026 eco-modulated tariff without confirmation from the responsible scheme.

Commercial providers can also charge different amounts for representation, data preparation or reporting assistance.

Accurate material data is therefore central to cost control.

Greece's plastic carrier bag levy

Greece applies a separate environmental levy of €0.07 per qualifying plastic carrier bag before VAT, subject to the relevant legal exclusions.

This is a statutory charge collected from consumers through the applicable tax process.

It must not be confused with the commercial packaging recycling contribution paid to a PRO.

Businesses handling plastic carrier bags may therefore need to consider both regulatory mechanisms.

Deposit return systems

Greece has also been developing a deposit return system for eligible beverage containers.

DRS Hellas provides information on the planned national deposit system.

However, its presence does not establish that every proposed deposit or producer contribution was already operational throughout 2026.

As of the October 2026 research date, a fully effective national operating tariff for producers could not be confirmed from the reviewed official material.

Businesses supplying beverage containers should monitor the approved launch conditions, product scope, deposit amounts, labeling requirements and scheme participation rules.

A refundable consumer deposit must not automatically be categorized as a packaging EPR fee.

PPWR application from 12 August 2026

The PPWR generally applies from 12 August 2026, although individual obligations have different implementation timelines.

It affects the broader European packaging framework, including producer obligations and the development of more harmonized registration and reporting systems.

Existing Greek EMPA requirements continue to matter during this transition. Businesses should not assume that the PPWR immediately replaces the national register or eliminates existing scheme contracts.

Greek packaging producers must maintain accurate information about the packaging introduced to the domestic market.

Relevant records include the producer's legal identity, approved scheme arrangement, packaging material categories, quantities, and supporting declarations.

EOAN's published guidance establishes 31 March each year as the standard deadline for annual EMPA reporting covering the previous calendar year, unless changed by an EOAN board decision.

The recycling scheme may impose different declaration and payment dates under its contract.

For this reason, the national EMPA deadline should not be treated as the only date on the producer's compliance calendar.

Companies should reconcile declarations against sales data, packaging specifications, imports and the quantities reported to their scheme.

Greek packaging producer obligations are legally enforceable under the applicable national framework.

Failure to register, maintain the required scheme arrangement, or declare packaging correctly can lead to administrative and other legal consequences.

Law 4819/2021 provides for sanctions associated with breaches of producer responsibility duties.

Businesses may also encounter difficulties demonstrating compliance to distributors, commercial customers or online marketplaces.

Rather than relying on a generic penalty figure, producers should examine the specific breach, applicable law and enforcement decision.

Maintaining accurate declarations and an active registration is generally more effective than attempting to reconstruct historical quantities after an inspection.

Practical Greece Packaging EPR Compliance Checklist for 2026

• Identify the obligated producer. Review legal entities, import activity, direct sales and distribution arrangements.
• Map packaging flows. Include sales, grouped, transport and qualifying service packaging.
• Classify materials. Record packaging units, component weights and material categories.
• Confirm representation requirements. Consider Greek rules and PPWR changes affecting cross-border producers.
• Select an appropriate approved scheme. Confirm that its authorization covers the relevant packaging.
• Complete EMPA registration. Obtain and maintain the producer registration certificate.
• Request verified 2026 contribution rates. Check VAT, contractual charges and payment conditions.
• Submit consistent declarations. Reconcile scheme data and EMPA annual reports.
• Maintain evidence. Retain specifications, declarations, invoices, registration records and relevant communications.

1. What are Greece's packaging EPR fees in 2026?

There is no single official national packaging EPR rate. Contributions depend on the approved compliance arrangement, packaging material, quantity and contract. Published HERRCO 2025 rates provide historical reference values, but the effective 2026 tariff must be confirmed directly.

2. Is packaging EPR registration free in Greece?

No separate official government filing tariff was identified in the EOAN registration guidance reviewed. However, mandatory recycling scheme participation generally involves financial contributions, and optional commercial registration services may also have fees.

3. Is HERRCO participation mandatory for every producer?

No. HERRCO is a recognized packaging recycling scheme, but other approved systems and legally authorized individual arrangements exist. Producers must select an arrangement appropriate to their products and obligations.

4. How are packaging recycling fees calculated?

Where the scheme uses material and unit contributions, the calculation depends on the reported packaging weight by material and the number of chargeable units. The current scheme's contract determines the applicable rates and calculation details.

5. Do foreign online sellers need Greek packaging EPR registration?

Foreign sellers supplying packaged goods directly to Greek end users can qualify as obligated producers. They should assess EMPA registration, scheme participation, their sales model and authorized representative requirements.

6. Do all foreign producers need an authorized representative in 2026?

Not automatically under the same conditions. The answer depends on establishment, market activity, national requirements and the PPWR rules applicable from 12 August 2026. The proposed small-business change also requires monitoring.

7. What is the Greek EMPA annual reporting deadline?

EOAN states that annual reports are normally due by 31 March for the preceding calendar year, unless an EOAN board decision changes the deadline. Scheme-specific payment and declaration schedules may differ.

8. Are small producers automatically exempt from Greek packaging EPR?

No blanket exemption should be assumed simply because a business introduces a small quantity of packaging. The PPWR includes possibilities for simplified treatment of small producers, but the applicable Greek rules and scheme requirements must still be checked.

Greek packaging EPR budgeting requires more than multiplying packaging weight by an assumed national recycling rate.

Producers should distinguish EMPA registration, commercial recycling contributions, potential representation charges, and any separate environmental taxes or deposits.

HERRCO's historical published contribution schedule helps illustrate the calculation process, but the verified, effective 2026 scheme tariff must be obtained before costs are finalized.

The most reliable approach is to identify the responsible producer, classify the packaging accurately, verify the current contractual fee structure, and maintain consistent reporting records.

Managing packaging EPR across Greece and other European markets requires accurate producer information, packaging data, regulatory monitoring and reliable reporting processes.

ComplyMarket supports businesses through country-specific obligation assessments, producer registration coordination, packaging classification, regulatory requirement management and compliance documentation.

Its services can help companies organize material and weight data, coordinate appropriate recycling arrangements, monitor deadlines, prepare declarations and maintain supporting evidence.

For businesses operating across multiple markets, this creates a more consistent approach to compliance and reduces reliance on disconnected spreadsheets or manually maintained requirements.

Explore ComplyMarket's EPR Management Services or its dedicated Greece Packaging EPR Compliance Services.

Companies with additional product responsibilities can also review Greece WEEE EPR Services and Greece Battery EPR Services.

Contact ComplyMarket to discuss your Greek packaging registration, reporting requirements and 2026 EPR compliance planning.