🧩 Who must comply (typical producer scenarios)

You are usually in scope if you first place packaging / packaged products on the Greek market, including when you:

• Manufacture, fill, or pack products in Greece and sell them in packaging
• Import packaged goods into Greece (B2B or B2C)
• Place transport packaging on the market as part of distribution activities

🏛️ Legal basis and competent bodies

• Law 4819/2021 sets the national framework for packaging and packaging waste, aligned with EU rules (including the transposition of Directives 2018/851 and 2018/852 and compatibility with the Packaging Directive 94/62/EC).
• Hellenic Recycling Agency (EOAN / HRA) is responsible for key roles including collection and verification of packaging data and calculation of “put on market” (PoM) data in the national reporting system.
• Producer Responsibility Organisations (PROs) provide data and annual reporting; their verification is part of the national control model.

🧾 Registration: EMPA (National Producers Register)

Packaging producers register via the EMPA portal (National Producers Register).

Why it matters: the national PoM calculation is based on the National Producers Registry held by EOAN/HRA.

🤝 Compliance route: join an approved packaging PRO (most common)

Most companies meet packaging EPR obligations through a collective system (PRO) that covers the collection and recycling of packaging waste and supports verification and reporting processes.

📊 Reporting requirements (what, when, how)

What you report

Packaging placed on the market (PoM) is typically reported by material and packaging type/level, supported by internal records and evidence.

When you report

Each year, by 31 March, registered producers report in the National Producers Registry the quantities of packaging put on the market for the previous year, and the relevant PRO verifies the data before it is accepted.

Verification and audits (plan for auditability)

PROs and EOAN/HRA apply verification controls such as spot checks, cross-checks, and audits. Producers may be subject to random third-party auditing by their PRO to verify PoM quantities.

♻️ Packaging scope and eco-fees (what drives cost)

• EPR schemes in Greece cover packaging waste from household and non-household sources and across all packaging materials.
• Greece applies advanced fee modulation for plastic packaging, meaning higher fees can apply to hard-to-recycle plastic types or combinations.
• Greek packaging obligations explicitly reference primary, secondary, and tertiary (transport) packaging placed on the Greek market.

🔍 Traceability: the evidence chain you should maintain

To keep reporting defensible and audit-ready, maintain a traceable link from commercial activity to declared weights:

SKU master → packaging BOM (material + weight) → shipments/sales to Greece → PoM totals → PRO verification → EMPA submission

Recommended evidence set:

• Packaging specifications and supplier declarations
• Packaging BOM with version control (change log)
• Import/shipping documents and invoices
• Calculation workbook or system logs that reproduce totals

🛠️ Service deliverables for Greece Packaging EPR

📝 Registration & setup

• Scope assessment (who is the producer, what flows count as PoM)
• EMPA registration support and data readiness pack

📊 Reporting & fee readiness

• Packaging data model (materials, packaging levels, plastics modulation readiness)
• PoM calculation + reconciliation (monthly/quarterly controls → annual close)
• Annual reporting package aligned to the 31 March cycle

🧾 Traceability & audit file

• Evidence vault design (what to store, how to link to reported figures)
• Audit-ready outputs (material totals, exceptions, and supporting documents)
• Ongoing controls to reduce “number drift” across reporting periods

❓ FAQ

What is the key annual deadline?
31 March each year for reporting the previous year’s packaging PoM in the National Producers Registry (with PRO verification).

What happens if a producer is not registered?
As an anti–free-rider measure, it is provisioned that non-registered producers cannot participate in public procurements run by national or local authorities.

Why is traceability so important?
Because verification may include spot checks, cross-checks, and audits, and producers can be subject to random third-party auditing by their PRO to confirm PoM quantities.

⭐ Why ComplyMarket for Greece Packaging EPR

ComplyMarket is a great and exceptional choice for Greece packaging EPR because it brings registration workflow support, structured reporting, and end-to-end traceability into one integrated Compliance Management platform—reducing manual effort while keeping packaging data audit-ready.

With ComplyMarket, teams can centralize packaging BOMs, automate PoM calculations, manage evidence, and run consistent reporting cycles—making it the best-ever solution for companies aiming to comply confidently with Greece’s packaging EPR requirements.