1.1. Contact organisation
Ministry of Environment and Energy, Hellenic Recycling Agency
1.2. Contact organisation unit
General Secretariat of Waste Management Coordination (Directorate of Waste Management) - Hellenic Recycling Agency
1.3. Contact name
Confidential because of GDPR
1.4. Contact person function
Confidential because of GDPR
1.5. Contact mail address
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
1.6. Contact email address
Confidential because of GDPR
1.7. Contact phone number
Confidential because of GDPR
1.8. Contact fax number
Confidential because of GDPR
2.1. Metadata last certified
28 July 2025
2.2. Metadata last posted
28 July 2025
2.3. Metadata last update
28 July 2025
3.1. Data description
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.
3.1.1. Description of the parties involved in the data collection
Table : Institutions involved in the collection of data and distribution of tasks.
| Name of institution | Description of key responsibilities |
|---|---|
| Ministry of Environment and Energy (MEE) | Reporting data to EUROSTAT, cross checks |
| Hellenic Recycling Agency (EOAN) | Collection and verification of recycling data reported by PROs, calculation of PoM data, packaging waste generation. |
| PROs | Providing data, annual report |
| Waste recycling facilities, companies undertaking transboundary shipments | Providing data, annual report |
3.2. Classification system
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.
3.2.1. Classification of treatment operations
The R/D codes of the Annexes I and II of the Directive 2008/98/EC are used.
3.3. Coverage - sector
Data from inustries, traders, packaging producers, waste treatment facilities, municipalities are included.
3.4. Statistical concepts and definitions
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.
3.4.1. Types of reuse system in place for each material type
Not available data.
3.4.2. Other recovery of waste
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.
3.4.3. Information on temporary storage of packaging waste
The quantities mentioned refer to the produced and in the same year treated packaging waste.
3.5. Statistical unit
Packaging Producers, importers, exporters, establishments, households, packaging waste treatment facilities.
3.6. Statistical population
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.
3.7. Reference area
Greece.
3.8. Coverage - Time
Reference year 2023.
The available data begin from 1997.
3.9. Base period
Not applicable.
Tonnes.
Calendar year
6.1. Institutional Mandate - legal acts and other agreements
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.
6.2. Institutional Mandate - data sharing
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.
7.1. Confidentiality - policy
European General Data Protection Regulation (GDPR).
7.2. Confidentiality - data treatment
Not applicable.
8.1. Release calendar
See item 9.
8.2. Release calendar access
See item 9
8.3. Release policy - user access
Please find information at these websites:
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.
10.1. Dissemination format - News release
Please find more information at these websites:
10.2. Dissemination format - Publications
Please find information at these websites:
10.3. Dissemination format - online database
Please find information at these websites:
10.4. Dissemination format - microdata access
Not applicable.
10.5. Dissemination format - other
Please find information at these websites:
10.6. Documentation on methodology
The quality report as submitted to EUROSTAT (incorporated to the current metadata file).
10.7. Quality management - documentation
The quality report as submitted to EUROSTAT (incorporated to the current metadata file).
11.1. Quality assurance
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.
11.2. Quality management - assessment
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.
12.1. Relevance - User Needs
Not applicable.
12.2. Relevance - User Satisfaction
Not applicable.
12.3. Completeness
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.
13.1. Accuracy - overall
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)
13.1.1. Statistical surveys used regarding packaging waste generation and treatment
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.
| Component of packaging waste | Year | Statistical units | Percentage of population surveyed | Data (tonnes) | Confidence level | Error margin | Details of adjustments from the survey year to the current year | Other details |
|---|---|---|---|---|---|---|---|---|
| Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
Not applicable for 2023.
13.1.2. Statistical surveys used regarding reusable packaging
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.
| Packaging material | Year | Statistical units | Percentage of population surveyed | Data (tonnes) | Confidence level | Error margin | Details of adjustments from the survey year to the current year | Other details |
|---|---|---|---|---|---|---|---|---|
| Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
Not applicable for 2023.
13.2. Sampling error
Not applicable for 2023.
13.3. Non-sampling error
Not applicable for 2023.
14.1. Timeliness
Unfortunately there are delays in the submission.
14.2. Punctuality
Unfortunately there are delays in the submission.
15.1. Comparability - geographical
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).
15.2. Comparability - over time
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.
15.3. Coherence - cross domain
When there are differences in quantitative data comparing different sources, further cross check and verification takes place.
15.4. Coherence - internal
Not applicable for 2023.
15.4.1. Explanation for any component with a greater than 10 % variation
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.
| Material | Variation (%) | Main reason for variation |
|---|---|---|
| All | Not available | 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. |
Not applicable.
17.1. Data revision - policy
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.
17.2. Data revision - practice
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.
18.1. Source data
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).
18.1.1. Waste samples from waste analysis
The waste samples for waste analysis are taken from:
| Approach | Details about the flows of waste covered |
|---|---|
| Directly from the bin | There has been no waste analysis undertaken |
| From the waste trucks | There has been no waste analysis undertaken |
| Other approaches | There has been no waste analysis undertaken |
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.
18.1.2. Source of waste flow data for estimation
| Sources | Materials covered | |
| Waste collectors | Yes | All packaging materials |
|---|---|---|
| Waste treatment operators | Yes | All packaging materials |
| Municipalities | Yes | All packaging materials |
| Others | No | No |
18.2. Frequency of data collection
Annually.
18.3. Data collection
See chapters 18.3.1 - 18.3.6.
18.3.1. Description of the methodology and verification of data on packaging waste generated in case waste analysis is used
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.
18.3.2. Description of the methodology to report on composite packaging
All composite packaging were included in the data of the key material.
18.3.3. Description of methods for determining packaging waste treatment
| Packaging waste material | Total | Plastic | Wood | Ferrous metals | Aluminium | Glass | Paper and Cardboard | Other |
|---|---|---|---|---|---|---|---|---|
| Data collection methods | ||||||||
| Administrative reporting | No | No | No | No | No | No | No | No |
| Surveys | No | No | No | No | No | No | No | No |
| Electronic registry | Yes | Yes | Yes | Yes | Yes | Yes | Yes | Yes |
| Waste analysis | No | No | No | No | No | No | No | No |
| Data from waste operators | Yes | Yes | Yes | Yes | Yes | Yes | Yes | Yes |
| Data from municipalities | No | No | No | No | No | No | No | No |
| Data from extended producer responsibility schemes | Yes | Yes | Yes | Yes | Yes | Yes | Yes | Yes |
| Other | No | No | No | No | No | No | No | No |
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.
18.3.4. Explanation of the scope and validity of surveys to collect data on the generation and treatment of packaging waste
Not applicable for 2023.
18.3.5. Explanation of the scope and validity of surveys to collect data on reusable packaging
Not applicable for 2023.
18.3.6. Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash
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.
| Data | Description of the measurement method to obtain the data |
| Total amount of metal concentrate extracted from incinerator bottom ash | Not applicable |
|---|---|
| Average level of metallic content in the total amount of metal concentrate, including the reliability of any surveys undertaken | Not applicable |
| Proportion of waste entering incineration plants that is packaging waste, including the reliability of any surveys undertaken | Not applicable |
Not applicable for 2023.
18.4. Data validation
See following chapters
18.4.1. Detailed description of the system for quality control and traceability for packaging waste pursuant to Article 6a(3) and (8) of Directive 94/62/EC
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.
18.4.2. Traceability of waste treated outside the member State and ensuring its treatment in conditions broadly equivalent to the requirements of EU environmental law
| Packaging waste material | Subject to final treatment in the Member State (yes/no) | Shipped to another EU Member State (yes/no) | Exported outside the EU (yes/no) | Description of specific measures for quality control and traceability of packaging waste, in particularly as regards monitoring and validation of data |
| Plastic | Yes |
Yes | Yes | No |
|---|---|---|---|---|
| Wood | Yes | No | No | No |
| Ferrous metals | Yes | Yes | No | No |
| Aluminium | Yes | Yes | No | No |
| Glass | Yes | Yes | No | No |
| Paper and cardboard | Yes | Yes | Yes | No |
| Others | No | No | No | No |
18.4.3. Description of measures to ensure broadly equivalent waste treatment
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.
18.4.4. Verification of data on packaging waste generated
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.
| Packaging waste material | Cross-check (yes/no) | Time-series check (yes/no) | Audit (yes/no) | Verification process | |
| Plastic | No | Yes | Yes | Producers are subject to random third party auditing by their PRO, in order to verify PoM quantities. Methodology based on time series. |
|
|---|---|---|---|---|---|
| Wood | No | Yes | Yes | Same as above |
|
| Ferrous metals | No | Yes | Yes | Same as above |
|
| Aluminium | No | Yes | Yes | Same as above |
|
| Glass | No | Yes | Yes | Same as above |
|
| Paper and cardboard | No | Yes | Yes | Same as above |
|
| Others | No | Yes | Yes | Same as above |
|
18.4.5. Verification of data on packaging waste recycling
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.
| Packaging waste material | Cross-check (yes/no) | Time-series check (yes/no) | Audit (yes/no) | Verification process |
| Plastic | Yes | Yes | Yes | Cross checks of data reported by the PRO and Sorting Facilities through the Electronic Waste Registry |
|---|---|---|---|---|
| Wood | Yes | Yes | Yes | Same as above |
| Ferrous metals | Yes | Yes | Yes | Same as above |
| Aluminium | Yes | Yes | Yes | Same as above |
| Mixed waste | Yes | No | Yes | Same as above |
| Others | Yes | Yes | Yes | Same as above |
18.5. Data compilation
See following chapter 18.5.1-18.5.6.
18.5.1. Methods for determining packaging waste generation
| Approach | % of waste generated based on this approach |
| Approach 1 Put on the Market (POM) based on EPR data, complemented with estimates to ensure full coverage of the EPR data |
The requested shares are not easily measured/ estimated. See chapter 18.5.2. |
|---|---|
| Approach 2 POM based on sources other than EPR (e.g. based on production and import statistics and factors to estimate the amount of packaging associated to these product flows) |
Not applicable. |
| Approach 3 Waste analysis |
Not applicable. |
| Other approaches | See 18.5.1.3. |
18.5.1.1. Approach 1 - Put on the Market (POM) based on EPR
Primary sources and their shares in the total.
| Sources for calculation of PoM | % of packaging total covered | Threshold of this source(*) | |||||||
| Total | Plastic | Wood | Ferrous metals | Aluminium | Glass | Paper and Cardboard | Other | ||
| EPR scheme data | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 |
|---|---|---|---|---|---|---|---|---|---|
| Administrative reporting different from EPR | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 |
| Surveys | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 |
| Electronic registry | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 |
| Other | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 | See 18.5.2 |
(*) 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.
18.5.1.2. Approach 2 - Put on the market (POM) calculated from production and reign trade statistics and using coefficients of packaging for the sold goods in question
Primary sources and their shares in the total.
| Sources for calculation of PoM | % of packaging total covered | Threshold of this source(*) | |||||||
| Total | Plastic | Wood | Ferrous metals | Aluminium | Glass | Paper and Cardboard | Other | ||
| Production statistics | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
|---|---|---|---|---|---|---|---|---|---|
| Foreign trade statistics | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
| Specific surveys | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
| Electronic registry | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
| Other | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered.
18.5.1.3. Approach 3 - Waste analysis
Packaging waste generated estimated by waste analysis
| Type of waste | Number of samples taken | Total volume or weight of samples taken | What proportion does the sample represent of the total waste generated (in %) |
Frequency of sample | |
| Volume in cubic metres | Weight in tonnes | ||||
| Mixed household and similar waste | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
|---|---|---|---|---|---|
| Separately collected municipal waste | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
| Separately collected business waste | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
| Others | Not applicable | Not applicable | Not applicable | Not applicable | Not applicable |
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
18.5.2. Information on estimates for packaging placed on the market
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).
18.5.3. Presence and calculation of estimates and indication of added volume in % of the total
| Packaging waste material | Total | Plastic | Wood | Ferrous metals | Aluminium | Glass | Paper and Cardboard | Other |
| Validation | ||||||||
| Corrections for underreporting of units covered by the above sources | No | No | No | No | No | No | No | No |
|---|---|---|---|---|---|---|---|---|
| Estimates for units below the threshold (de minimis) | No | No | No | No | No | No | No | No |
| Estimates for other units legally exempt from reporting | No | No | No | No | No | No | No | No |
| Estimates for freeriders | Yes | Yes | Yes | Yes | Yes | Yes | Yes | Yes |
| Private imports /exports by private parcels | No | No | No | No | No | No | No | No |
| Private imports /exports (from journeys) | No | No | No | No | No | No | No | No |
| Internet imports and exports i.e. on-line sales | No | No | No | No | No | No | No | No |
| Other corrections | No | No | No | No | No | No | No | No |
18.5.4. Measurement points for recycling applied
| Packaging waste material |
Description of measurement points used (at calculation point or at the output of sorting operation with subtraction of non-target materials as appropriate, end-of-waste criteria, etc.), including variation at regional and local level |
| Plastic | Output of sorting operation, after substraction of impurities/non targeted materials + certification of packaging ICPW quantities |
|---|---|
| Wood | Calculation point |
| Ferrous metals | Input in recycling facilities |
| Aluminium | Output of sorting operation after substraction of impurities/Non-targeted material + information from industry |
| Glass | Adjusted input to the glass sorting operation |
| Paper and cardboard | Output of the final sorting/ traders' facilities after substraction of impurities/non targeted materials |
| Others | No |
18.5.4.1. Detailed description of the methodology to calculate the amount of non-target materials removed between the measurement and the calculation points, where applicable
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.
18.5.4.2. Detailed description of how compostable packaging recovered at biowaste treatment plants has been identified and recorded in the data
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.
18.5.5. Methodology to determine recycled amounts from composite packaging or packaging composed of multiple materials
No such information available on the data collected by PROs and/or HRA. Only targeted materials are reported.
18.5.6. Use of Average Loss rates (ALRS)
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.
| Sorted waste material and sorting plant type | ALR applied (in %) | Description |
|---|---|---|
| All materials ALRs not applicable | Not applicable | Not applicable |
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
18.6. Adjustment
See following points.
18.6.1. Adjustment for impurities and humidity
| Factors | Total | Plastic | Wood | Ferrous metals | Aluminium | Glass | Paper and Cardboard | Other |
| Correction factors for impurities and humidity in % of waste | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 |
|---|---|---|---|---|---|---|---|---|
| How the correction factors are derived | See 18.5.4.1 | |||||||
| If no correction of impurities and humidity is applied, how they are accounted | See 18.5.4.1 | |||||||
See chapter 18.5.4.1.
18.6.2. Attribution of waste to packaging and non-packaging types and correction for humidity
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.
| Packaging waste material | Facility type | Share of packaging waste (%) | Description of the methodologies applied to obtain the percentage |
|---|---|---|---|
| See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 | See 18.5.4.1 |
See chapter 18.5.4.1.
18.6.3. Attribution of waste
Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.
| Packaging waste material | Facility type | Share of waste from the Member State (%) | Description of the methodologies applied to obtain the percentage |
|---|---|---|---|
| All | Not available | Not available | The data reported refer only to packaging waste generated in Greece, either treated within the country or abroad. Imports are not included. |
No comment.
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.
28 July 2025
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.
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.
Calendar year
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)
Tonnes.
See following chapter 18.5.1-18.5.6.
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).
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.
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.
