EPR Guidelines for Tires in Greece: The Complete Compliance Guide

As global pressure to adopt sustainable waste management intensifies, Greece has implemented strict Extended Producer Responsibility (EPR) guidelines for various waste streams, including end-of-life tires (ELTs). If your business manufactures, imports, or sells tires in Greece, understanding and adhering to these regulations is legally required.

This guide breaks down everything you need to know about EPR for tires in Greece, from the legal frameworks to the registration process, and how Complico Consulting GmbH can ensure your seamless compliance.

1. Introduction to EPR in Greece

Extended Producer Responsibility (EPR) is an environmental policy approach in which a producer's responsibility for a product is extended to the post-consumer stage of its life cycle. In Greece, the EPR system for tires ensures that manufacturers and importers bear the financial and organizational burden of collecting, transporting, and recycling end-of-life tires. By shifting the cost of waste management back to the producers, Greece aims to incentivize the design of resource-efficient products, reduce illegal tire dumping, and support a robust circular economy, in line with broader GPSR compliance obligations for products sold in the EU.

2. Legal Framework and Regulations in Greece

The framework for waste management and EPR in Greece is predominantly governed by:

• Law 4819/2021: The overarching integrated framework for waste management, transitioning the country into a more aggressive circular economy.
• Law 2939/2001: The foundational legislation that originally introduced EPR obligations and established the Hellenic Recycling Agency (HRA - EOAN).
• JMD ΥΠΕΝ/ΔΔ Α/36464/547 (2023): Specific ministerial decisions clarifying the obligations of tire importers to participate in a collective management system.

In Greece, the sole approved Producer Responsibility Organization (PRO) for end-of-life tires is Ecoelastika (Eco-Elastika S.A.). The national regulatory body overseeing the system is the Hellenic Recycling Agency (EOAN), which manages the National Register of Producers (E.M.P.A.).

3. Who Must Register for EPR Tires in Greece ?

The "Polluter Pays" principle means the obligation falls on the entity placing the product on the Greek market for the first time. You are considered a liable producer/importer if you:

• Import and sell tires (new, used, or retreaded) on the Greek market, often through an Importer of Record (IOR/EOR) service.
• Import and sell vehicles (new or used) equipped with tires on the Greek market.
• Manufacture tires domestically within Greece.

Whether you are a local distributor, a foreign manufacturer selling directly, or an online retailer, you must comply with these obligations.

4. EPR Categories for Tires

To accurately track and finance tire recycling, Ecoelastika classifies tires into specific categories based on vehicle type and size. The primary categories are:

• Category A: Passenger cars and motorcycles.
• Category B: Commercial trucks and buses.
• Category C: Agricultural machinery.
• Category D1 & D2: Earthmoving, industrial, and heavy-duty vehicles.

Note: Extremely large tires (exterior diameter > 1600 mm) and certain compact industrial tires may be excluded from the standard environmental fee structure but still require proper documentation.

5. EPR Registration Process in Greece for Tires

Achieving compliance involves a mandatory two-step process:

1. EMPA Registration: You must register your company with the National Register of Producers (E.M.P.A.) via the Hellenic Recycling Agency (EOAN) portal. Upon successful registration, you will receive a unique Producer Registration Number (PRN).
2. PRO Contract: You must sign a partnership contract with Ecoelastika, the designated PRO for tires in Greece. This contract guarantees that your end-of-life products will be properly managed, collected, and recycled.

6. Authorized Representative Requirements

If you are a foreign producer (a company without a registered legal entity or branch in Greece) selling directly to end-users via distance communication (e-commerce), Greek law mandates that you appoint an Authorized Representative (AR).

The AR must be a legal or natural person established in Greece.

They will hold legal responsibility for fulfilling your EPR obligations, including managing EMPA registrations, submitting reports, and paying eco-contributions on your behalf.

7. Reporting Obligations and Deadlines

Accurate and timely reporting is critical to maintaining compliance:

• Quarterly Sales Declarations (PRO): Importers must record their imported tires/vehicles quarterly via the EcoContribution app. These declarations must be submitted within the first 10 days of the month following the end of each quarter.
• Annual Reporting (EMPA): An annual summary report of the quantities placed on the market must be submitted to the National Producers' Register (EMPA) to verify compliance.

8. EPR Fees and Eco-Contributions

Producers must pay an environmental fee (eco-contribution) to Ecoelastika for every tire placed on the market. These fees cover the cost of collection, transport, and recycling. Rates are set by the PRO and approved by the Hellenic Recycling Agency (EOAN). Current indicative rates per item are:

• Category A: €1.15
• Category B: €6.74
• Category C: €0.48
• Category D1: €28.75
• Category D2: €17.25

Important Invoicing Rule: The environmental fee must be distinctly and visibly separated on the sales invoices at all stages of sale, allowing end-users to see the exact cost of the environmental contribution. For a full breakdown of our own service costs, see our pricing page.

9. Labeling Requirements and Compliance

While tires do not require a specialized national EPR logo printed on the rubber itself, Greek authorities require standard EU tire labeling (for fuel efficiency, wet grip, and noise). Furthermore, the visible separation of the eco-contribution fee on the invoice acts as a primary form of "compliance labeling" to the end-consumer. If packaging is used for the tires, standard Greek packaging EPR rules (and appropriate symbols like the Mobius loop) may apply, similar in principle to packaging EPR rules in France and Germany.

10. Penalties for Non-Compliance

Failure to register with EMPA, partner with Ecoelastika, or pay the requisite eco-contributions is a direct violation of Greek environmental law. Penalties include:

• Financial Fines: Imposed by the Hellenic Recycling Agency (EOAN) and environmental inspectorates, often calculated based on the estimated volume of unregistered products.
• Market Blockage: Non-compliant companies can be legally barred from placing their products on the Greek market.
• Reputational Damage: Your company may face public listing as a non-compliant "freerider."

Given the complexity of EPR compliance for tires in Greece, many international sellers choose to work with a dedicated compliance partner to avoid registration errors and missed deadlines. If you need help with EMPA registration, contracting with Ecoelastika, or managing your quarterly declarations, contact our compliance team for tailored support, or explore our full range of compliance services.