Ministry of Environment and Energy, Hellenic Recycling Agency

General Secretariat of Waste Management Coordination (Directorate of Waste Management) - Hellenic Recycling Agency

Hellenic Ministry of Environment and Energy

General Secretariat of Waste Management Coordination

Directorate of Waste Management

119, Mesogeion Av., GR- 115 26 Athens,  GREECE

Hellenic Recycling Agency

207, Mesogeion Av., GR- 115 25 Athens,  GREECE

28 July 2025

28 July 2025

28 July 2025

Data have been mainly collected from the Annual Reports of the approved PROs of packaging waste (4 for 2023). Data provided in the Annual Reports are submitted to HRA in a specific Template (approved by HRA (BoD) in 2024 and applicable for the first time for 2023 data) providing more detailed information and data transparency. Data sources are also based on the National Producers Registry (Hellenic Recycling Agency, HRA) and the Electronic Waste Registry (Ministry of Environment and Energy). The new calculation rules have been used, although an assignment of a study for developing the concrete and final methodology for calculating packaging recycling data in accordance with the rules of Directive 94/62/EC is ongoing. Regarding ALR please see also point 18.5.6.

Table : Institutions involved in the collection of data and distribution of tasks.

The codes of European list of waste are used, as well as the R/D codes of the Annexes I and II of the Directive 2008/98/EC.

The R/D codes of the Annexes I and II of the Directive 2008/98/EC are used.

Data from inustries, traders, packaging producers, waste treatment facilities, municipalities are included.

Recycled wood packaging waste reported is the sum of (a) material recycling, corresponding to the amount of parts of non-usable pallets introduced in the production of new pallets and (b) other forms of recycling, corresponding to the amount used in the production of organic fertiliser or soil conditioner (c) preparation for reuse.

It is not applicable to take into account the amount of metals in incineration bottom ash (IBA) for the calculation of the targets.

Not available data.

Referring to energy recovery, quantities regarding packaging waste used in the production of waste derived fuel (RDF) in MBT facility cannot be verified.As there has been no verification of the data in relation to the quantities of packaging waste used to produce RDF, zero value is set.

The quantities mentioned refer to the produced and in the same year treated packaging waste.

Packaging Producers, importers, exporters, establishments, households, packaging waste treatment facilities.

For Waste generation:
a)Total packaged products placed on the national market for the first time by all economic operators

For Treatment:
c) Treatment plants treating nationally generated packaging waste" or "sorting plants", but data are also derived from companies exporting packaging waste.

Greece.

Reference year 2023.

The available data begin from 1997.

Not applicable.

Tonnes.

Calendar year

Law 4819/2021 (OGG 129 A) “Integrated framework for waste management - Transposition of Directives 2018/851 and 2018/852 … and related urgent arrangements”, legal national act setting the legislative framework for packaging and packaging waste, in line with the Directive 94/62/EC as amended.

Law 4819/2021 (OGG 129 A) “Integrated framework for waste management - Transposition of Directives 2018/851 and 2018/852...and related urgent arrangements”, legal national act setting the legislative framework for packaging and packaging waste, in line with the Directive 94/62/EC as amended. 

Statistics on packaging and packaging waste are in accordance with the Commission Decision 2005/270/EC.

European General Data Protection Regulation (GDPR).

Not applicable.

See item 9.

See item 9

Please find information at these websites:

• EOAN.
• Sterea apovlita.

Once a year, after data elaboration, verification is completed and the relevant report is submitted to EUROSTAT. The official deadline for data submission to EUROSTAT is on the 30th June, 18 months after the end of the reference period.

Please find more information at these websites:

• Empa EOAN.
• Sterea apovlita.
• EOAN.

Please find information at these websites:

• EOAN.
• Sterea apovlita.

Please find information at these websites:

• EOAN.
• Sterea apovlita.
• YPEKA.

Not applicable.

Please find information at these websites:

• EOAN.
• Sterea apovlita.

The quality report as submitted to EUROSTAT (incorporated to the current metadata file).

The quality report as submitted to EUROSTAT (incorporated to the current metadata file).

During data elaboration cross cheks are carried out from other sources, such as the Electronic Waste Register, data from the transboundary shipment of waste (Annex VII or notification procedure).

HRA also carries out checks on PROs data submitted, mainly by verification of the data provided in a detailed Template [since 2024] through Electronic Waste Register. Large PROs (such as HERRCO) also check the recycling material outcome by quality statistical control methods.

During data elaboration cross cheks are carried out from other sources, such as the Electronic Waste Register, data from the transboundary shipment of waste (Annex VII or notification procedure).

HRA also carries out checks on PROs data submitted, mainly by verification of the data provided in a detailed Template [since 2024] through Electronic Waste Register. Large PROs (such as HERRCO) also check the recycling material outcome by quality statistical control methods.

Not applicable.

Not applicable.

An assignment of a study for developing the concrete and final methodology for calculating packaging recycling data in accordance with the rules of Directive 94/62/EC is ongoing. 

Given that no statistical surveys were performed in 2023, accuracy assessment is constrained in the estimation of the packaging placed on the market data, which are calculated on the basis of the data of the National Producers Registry (NPR) held by Hellenic Recycling Agency (HRA), and the fluctuation from previous year for each packaging material is then calculated. The current year's (2023) quantities of packaging per material are adjusted and estimated (a) on the basis of the quantities submitted in the official national report for packaging of the previous years (2022) and (b) taking into consideration the variation / fluctuation (as percentage) from the previous two year's (2021 & 2022) declared quantities in the NPR compared to the current year (2023). Relevant projections and estimations are necessary to take into cosideration quantities of packaging placed on the market by not registered producers (free riders).

As a measure against free riders, it is provisioned by law 4412/2016 that non registered producers cannot participate in any public procurements run by national or local authorities.

The quantities of the recycled packaging waste is based on the data included in the annual reports of the approved Producers Responsible Organisations (PROs) for packaging waste (4 for year 2023). The quantities are verified by HRA (see 18.3.3)

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in previous questions.

Not applicable for 2023.

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in other concepts.

Not applicable for 2023.

Not applicable for 2023.

Not applicable for 2023.

Unfortunately there are delays in the submission.

Unfortunately there are delays in the submission.

Data are comparable within the geographical areas of the greek territory (data provided by the largest PRO HERRCO contracting municipalities for packaging waste in the whole country).

There are differences in the quantities of packaging waste per material (especially paper) recycled within the country, in another MS or third countries, compared to the quantities submitted in 2020 that need further cross check. We are in the process of further investigation.

When there are differences in quantitative data comparing different sources, further cross check and verification takes place.

Not applicable for 2023.

Explanation detailing the causes of the tonnage difference (in relation to which waste streams, sectors or estimates have caused the difference, and what the underlying cause is) for any component of packaging waste generated and recycled which shows greater than a 10 % variation from the data submitted for the previous data year.

Not applicable.

An assignment of a study for developing the concrete and final methodology for calculating packaging recycling data in accordance with the rules of Directive 94/62/EC is ongoing. 

An assignment of a study for developing the concrete and final methodology for calculating packaging recycling data in accordance with the rules of Directive 94/62/EC is ongoing. 

Data have been mainly collected from the Annual Reports of the PROs. Data sources are also based on the National Producers Registry (Hellenic Recycling Agency, HRA) and the Electronic Waste Registry (Ministry of Environment and Energy). 

The waste samples for waste analysis are taken from:

For the year 2023 there has been no waste analysis undertaken.

Regarding the Waste Composition Analysis, a (programme) contract with the university institutions (5 universities), with a validity period of 18 months, is in the process of being concluded, on the basis of which a nationwide study will be carried out for the analysis of waste composition (the relevant methodological approach will be analyzed, scientifically documented sampling protocols will be defined, while seasonal variations will also be assessed). In this analysis, among others, data will also be collected / calculated for packaging. As a timetable, the study is expected to be completed within 2026 and based on its results, the data for the year 2021 and the following years will be estimated, applying also balancing for the estimation of waste generation.

Annually.

See chapters 18.3.1 - 18.3.6.

Regarding the Waste Composition Analysis, a (programme) contract with the university institutions (5 universities), with a validity period of 18 months, is in the process of being concluded, on the basis of which a nationwide study will be carried out for the analysis of waste composition (the relevant methodological approach will be analyzed, scientifically documented sampling protocols will be defined, while seasonal variations will also be assessed). In this analysis, among others, data will also be collected / calculated for packaging. As a timetable, the study is expected to be completed within 2026 and based on its results, the data for the year 2021 and the following years will be estimated, applying also balancing for the estimation of waste generation.

 All composite packaging were included in the data of the key material. 

Additional information about the methodology, including the combination of methods used:

As foreseen in the national legislation, HRA (EOAN) evaluates the data for packaging waste from the annual reports, submitted by the approved PROs (4 for this year 2023) and submits a relevant report to the Ministry of Environment and Energy, within its respective competence. The verification process of the quantities of packaging waste collected and lead to recycling process is based on a) spot checks and inspections b) cross checks by HRA on data provided in the annual reports, the detailed information included in the specific Template required from the PROs for first time for 2023 data and the Electronic Waste Registry (held by the Ministry of Env and Energy).
During the reference year 2023, HERRCo (the largest PRO that contributes about 90% in the total amount of packaging recycling) carried out periodically checks and inspections on the quality and quantity of packaging waste collected and sold in order to be recycled. HERRCo cooperates with the Sorting Centres (CSRMs) on the basis of mutual agreements, which include, inter alia, the obligation of the CSRMs to provide data on the waste sorted and the right of HERRCo to carry out checks and inspections to verify the accuracy and completeness of these data. These checks and inspections are physical, of incoming and outgoing flows of materials, and administrative, such as the examination of entry and sale documents. HERRCo also verifies the efficiency of the sorting process, runs tests for production composition, as well as measurments on product quality (determination of non-targeted materials in the output of sorting facilities). Inspections take place by internationally recognised inspections bodies.

Not applicable for 2023.

Not applicable for 2023.

Calculation of recycling of metals from incinerator bottom ash : Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash in accordance with the Commission Implementing Act adopted in accordance with Article 37(7) of Directive 2008/98/EC.

Not applicable for 2023.

See following chapters

The quantities of packaging waste recycled were based on the data included in the annual reports of the approved Producers Responsible Organisations (PROs) for packaging waste. The submission of these annual reports to  HRA (EOAN) is a legal obligation of each approved PRO. The verification process of the quantities of packaging waste collected and lead to recycling process is based on a) spot checks and inspections by the PROs when applicable) b) cross checks by HRA on data provided in the annual reports, the detailed information included in the specific Template required from the PROs (for first time for 2023 data) and the Electronic Waste Registry (held by the Ministry of Env and Energy).

Transboundary shipment of packaging waste  is in accordance with Regulation (EC) no 1013/2006, mainly article 18 and Annex VII of this Regulation or notification procedure, where required.

Responsible operators, waste treatment facilities and exporters submit the required reports (including data for packaging waste treated) in the Electronic Waste Registry, according to our national legislation. Moreover, cross cheks are carried out within the framework of the transboundary shipment of waste where additional clarifications are requested mainly from the collectors - carriers but also the facilities (of the country), in the context of the administrative procedure (by mail) and the monitoring of the transports with Annex VII of Regulation 1013/ 2006.

In case of export of packaging waste for recycling, cross check is accomplished through the weighing of the waste and by receiving the document of Annex VII of the Waste Shipment Regulation (EC) no. 1013/2006, signed by the recycling facility, thus ensuring that the waste has been delivered and recycled.

The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.

The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.

See following chapter 18.5.1-18.5.6.

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered.

The requested shares are not easily measured/ estimated. See chapter 18.5.2.

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered.

Packaging waste generated estimated by waste analysis

Other approaches:

For this year no waste composition analysis was carried out. A (programme) contract with the university institutions (5 universities), with a validity period of 18 months, is in the process of being concluded, on the basis of which a nationwide study will be carried out for the analysis of waste composition (the relevant methodological approach will be analyzed, scientifically documented sampling protocols will be defined, while seasonal variations will also be assessed). In this analysis, among others, data will also be collected / calculated for packaging. As a timetable, the study is expected to be completed within 2026 and based on its results, the data for the year 2021 and the following years will be estimated, applying also balancing for the estimation of waste generation

The packaging placed on the market is calculated on the basis of the data of the National Producers Registry (NPR) held by Hellenic Recycling Agency (HRA). In particular, every year on 31 March registered producers report in the National Producers Registry quantities of packaging put on the market for the previous year. The relevant PRO verify the data by checking with records that they keep for each producer (data accepted by HRA only after the PRO's verification). The fluctuation from previous year for each packaging material is then calculated. The current year's (2023) quantities of packaging per material are adjusted and estimated (a) on the basis of the quantities submitted in the official national report for packaging of the previous years (2022) and (b) taking into consideration the variation / fluctuation (as percentage) from the previous two year's (2021 & 2022) declared quantities in the NPR compared to the current year (2023). Relevant projections and estimations are necessary to take into cosideration quantities of packaging placed on the market by not registered  producers (free riders). The quantities of packaging waste recycled were based on the data included in the annual reports of the 4 approved Producers Responsible Organisations (PROs) for packaging waste. The submission of these annual reports to  HRA is a legal obligation of each approved PRO (according to Law 4819/2021).

As a measure against free riders, it is provisioned by law 4412/2016 that non registered producers cannot participate in any public procurements run by national or local authorities.

The quantities of packaging waste recycled were based on the data included in the annual reports of the 2 approved Producers Responsible Organisations (PROs) for packaging waste. The submission of these annual reports to  HRA is a legal obligation of each approved PRO (according to Law 4819/2021).

There are several points of control in each different stage of recyclable materials collected. HERRCo is the PRO with approximately 80% of registered producers and registered quantities and approximately 90% of reported recycled materials. Therefore, a short presentation follows with control points in each step of the recovery procedure.

•  Mechanism in monitoring reported materials from Sorting Centres of Recyclable Materials (SCRM).

Control and monitoring of waste collection: The collected stream of packaging materials (from blue bins) is ldelivered to the SCRM for sorting. Responsible for the collection and transportation of the blue bins are the municipality services – HERRCo offers to contracted municipalities equipment (blue bins) and transportation means (vehicles) and the municipality itself is responsible for the collection process.

At the entrance to the SCRM, a complete record is kept of the vehicles transporting the waste and the transported quantities (documentation available in SCRM and driver). In larger SCRM (aprox. 80% of quantities reported) there is an automatic recording system, which photograph the vehicles and automatically record the weighing data.

Due to special conditions existing in Greece, since there is a lot of island municipalities with certain problems in transportation of recyclables, inspections of shipments are realized. The percentage of this sample inspections from external partners is up to 55% of the annual incoming quantities (year 2021).

The certification of packaging materials that are reported as recycling is also checked through invoices to secondary market (sales invoices, delivery documentation, weight lists) in a monthly basis. Moreover, sample recording of the sales of materials was carried out by EEAA's external auditors for SCRM, corresponding to 34% of the sales cargos recorded.

The total quantity of residues generated per SCRM is determined by the production controls mentioned above. The residue corresponding to each municipality is then calculated on the basis of the contribution of each municipality to the incoming quantities and the monthly percentage of the residue in relevant facility. Recording to residues is also kept  (delivery notes), weighing slips, transport orders) and reported to each municipality accordingly.  

• Mechanism in monitoring reported Industrial and Commercial Packaging Materials.

The procedure for certifying quantities of ICPW shall include the recording of quantities of such packaging waste declared by the contracted EPR partners.  HERRCo has appointed external inspection auditors that are authorised for the confirmation-recording of the quantities reported (inspection of incoming and outgoing quantities of ICPW) to and from the premises of the contracted Operators.

• Reporting Materials from Green Bin (waste stream) from MBTs

HERRCo also reports secondary materials originated from the common municipal waste stream (green bin). In this aspect, also carries out checks and inspections, as follows:

• by realizing random inventory of packaging waste for sale by during loading of secondary materials to be sold;
• by analyses on secondary products to determine the percentage of packaging in them.

Cross checks are carried out with the data submitted in the Electronic Waste Registry and the procedure of transboundary waste shipment.

More than 80% of waste wood packaging collected undergoes organic composting. Inspections, certification and reporting were carried out by internationally recognised auditing organisations through the PRO HERRCo S.A.

No such information available on the data collected by PROs and/or HRA. Only targeted materials are reported. 

Description of the sorted packaging waste to which ALRs are applied, types of sorting plants to which different ALRs apply, the methodological approach to calculating ALRs at such point(s), including the statistical accuracy of any surveys used, or the nature of any technical specifications.

There are several points of control in each different stage of recyclable materials collected. HERRCo is the PRO with approximately 80% of registered producers and registered quantities and approximately 90% of reported recycled materials. Therefore, a short presentation follows with control points in each step of the recovery procedure.

•  Mechanism in monitoring reported materials from Sorting Centres of Recyclable Materials (SCRM).

Control and monitoring of waste collection: The collected stream of packaging materials (from blue bins) is ldelivered to the SCRM for sorting. Responsible for the collection and transportation of the blue bins are the municipality services – HERRCo offers to contracted municipalities equipment (blue bins) and transportation means (vehicles) and the municipality itself is responsible for the collection process.

At the entrance to the SCRM, a complete record is kept of the vehicles transporting the waste and the transported quantities (documentation available in SCRM and driver). In larger SCRM (aprox. 80% of quantities reported) there is an automatic recording system, which photograph the vehicles and automatically record the weighing data.

Due to special conditions existing in Greece, since there is a lot of island municipalities with certain problems in transportation of recyclables, inspections of shipments are realized. The percentage of this sample inspections from external partners is up to 55% of the annual incoming quantities (year 2021).

The certification of packaging materials that are reported as recycling is also checked through invoices to secondary market (sales invoices, delivery documentation, weight lists) in a monthly basis. Moreover, sample recording of the sales of materials was carried out by EEAA's external auditors for SCRM, corresponding to 34% of the sales cargos recorded.

The total quantity of residues generated per SCRM is determined by the production controls mentioned above. The residue corresponding to each municipality is then calculated on the basis of the contribution of each municipality to the incoming quantities and the monthly percentage of the residue in relevant facility. Recording to residues is also kept  (delivery notes), weighing slips, transport orders) and reported to each municipality accordingly.  

• Mechanism in monitoring reported Industrial and Commercial Packaging Materials.

The procedure for certifying quantities of ICPW shall include the recording of quantities of such packaging waste declared by the contracted EPR partners.  HERRCo has appointed external inspection auditors that are authorised for the confirmation-recording of the quantities reported (inspection of incoming and outgoing quantities of ICPW) to and from the premises of the contracted Operators.

• Reporting Materials from Green Bin (waste stream) from MBTs.

HERRCo also reports secondary materials originated from the common municipal waste stream (green bin). In this aspect, also carries out checks and inspections, as follows:

• by realizing random inventory of packaging waste for sale by during loading of secondary materials to be sold;
• by analyses on secondary products to determine the percentage of packaging in them.

We would like to note that from the evaluation carried out, approximately 77000 tons of packaging waste were estimated, for which no data is available to confirm/verify that these quantities were sent for recycling. It was therefore considered appropriate not to include them in the recycling quantities, recognizing that the recycling rates are decreasing. In case data is verified, the updated quantities will be transmitted officially

See following points.

See chapter 18.5.4.1.

Description, where applicable, of the methodology to exclude non-packaging waste from the reported amount of recycled packaging waste and of the methodology to correct the amount of packaging waste at the measurement point in order to reflect the natural humidity rate of packaging (including by using relevant European standards). Aggregated data across facilities of a similar type is acceptable.

See chapter 18.5.4.1.

Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.

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