Ιn this section you can find the entire cooperation framework between HERRCO and the responsible manufacturers (businesses).
Legally Responsible Parties
With respect to the Recycling sector, 2003 was a landmark year for Greece, since Law 2939/01, as replaced by Law 4819/2021, obliged all the businesses that import, produce and place packaged products on their domestic market, to ensure the collection and recycling of their packaging. This legislation specifically refers to primary, secondary and tertiary packaging placed on the Greek market, as well as packaging waste from all sources (industry, commerce, offices, shops, services, households, etc.).
How to be contracted
In order for a company to become a HERRCO member, it must sign a one-year Participation Contract.
The above Participation Contract must be signed by all those who place packaged products on the Greek market and these include:
• Importers and/or manufacturers thereof
•Brand owners/private label products
By signing the contract, each member fulfils its legal obligation and can use the European “Green Dot” trademark on the packaging it places on the Greek market.
With a view to facilitating responsible packaging manufacturers, both in calculating their contribution to the System and in submitting their Declaration, HERRCO has developed a special application to simplify the procedures.
This application is accessible to all members of the System via the Declaration Submission link, using their username and password.
Contracted Businesses - Members
Figure 1 shows the evolution of signed contracts from the establishment of the System until the end of 2021. Up until 31 December 2021, 2821 businesses had signed a Cooperation Contract with the System. The relevant list of these businesses is communicated to the competent authorities. Click here to view the list of contracted businesses.
Figure 2 shows the size of the contribution of the Contracted entities by industry. The largest range (62%) of contributions comes from companies in the food and beverage industry.
- paper packaging and cardboard boxes from e.g., electrical appliances, juices, milk, cereals, pizza, biscuits, sugar, detergents, toothpaste, paper bags, and more
- aluminium cans from soft drinks, beers and more
- glass packaging from e.g., water, juices, soft drinks, alcoholic beverages, food jars, etc.
- plastic packaging from e.g., of water bottles, soft drinks, yoghurt, butter, oil, detergents, cleaning agents, shampoos, shower gels, deodorants, plastic bags, cling film, and more
- tin-plate packaging from evaporated milk, coffee, tuna, feed, tomato concentrate, biscuits, etc.
- Packages must be completely free of residue.
- We fold or bend packaging, as appropriate.
- We remove the caps from bottles, but we also dispose of them for recycling.
- When we get to the bin, we empty the contents of the bag inside the bin. We can then dispose of our bag for recycling.
- We protect the environment and upgrade the quality of our life.
- We reduce the volume of waste that goes to Sanitary Landfills, which prolongs their lifetime.
- We save raw materials and energy.
- New jobs are created.
- There are exchange benefits for Greece.
- We contribute to civilisation since waste management is an indicator of civilisation.
Special collection vehicles transport the contents of the blue bins to the dedicated Material Recovery Facilities (MRFs) that operate for this purpose. There, the materials are separated through a process involving mechanical separation devices and manual sorting into secondary packaging material (e.g., paper/cardboard, PET, HDPE, mixed plastics, PE film, glass, iron and aluminium), and where possible, into other recyclable non-packaging materials, such as leaflets, etc. The separated materials are then led for baling (except for glass) so that they can be recovered into useful materials by the respective plants.
Its presence indicates the financial contribution of the company concerned that markets packaging in recycling projects and should not be confused with whether a packaging material is recyclable or not.
This depends on the inclusion time schedule of the particular region, as this arises from the National planning, the agreement between the State and the System, as well as the intention of each municipality.
The Hellenic Recovery Recycling Corporation delivers the required equipment (cars/bins) to the integrated municipalities. The System only makes its proposals for the bin network. The final decision on how many recycle bins that will be placed and their locations belongs to the cooperating Municipalities. You should contact your municipality, if it is included in the program, and in particular the Cleaning Department and lodge an application for a bin. In the extended blue bin network, Municipalities take into consideration requests by citizens and companies to better serve all those involved in Packaging Recycling.
Under this Law, responsible “packaging operators” include:
A. Manufacturers and importers of raw materials.
B. Manufacturers and importers of packaged products that are placed on the Greek market, i.e., the responsible Packagers.
C. Dealers, i.e., those who market packaged products. In some cases, they are the same as packagers, for example in the case of supermarkets.
- Natural or legal persons who package goods or outsource the packaging of goods on their behalf or import packaged goods, regardless of the sale technique used, including the remote contract as defined in Article 3(1) of Law 2251/1994 (A 191) for the purpose of placing them on the Greek market.
- Natural or legal persons that manufacture or import packaging that is intended to be filled at a point of sale, including transport bags.
- Natural or legal persons established in a Member State of the European Union (EU) or in a third country, who professionally sell packaging and/or packaged goods in Greece, directly to households or users other than households by means of remote contracts as defined in Article 3(1) of Law 2251/1994.
- Without prejudice to case d, in the case of imports of goods from third territories or third countries into the EU using an electronic interface such as a platform, a web portal or similar means, in particular with the use of facilities of fulfilment service providers, the responsibility for fulfilling the manufacturer’s obligations under an EPRP (Extended Producer Responsibility Programme) shall be borne by the tax representative, where applicable, in accordance with the provisions of Law 2859/2000 (Α 248).
- In the case of the remote selling of goods through a web-based platform, which fall under an EPRP (Extended Producer Responsibility Program), the manufacturer’s obligation to fulfil the obligations resulting from an EPRP (Extended Producer Responsibility Program) shall be borne by the web-based selling platform; unless the seller of the good presents to the web-based platform a certificate of registration to the National Producer Registration Body (NPRB).
Are materials filled at the point of sale, such as bags, wrapping paper, aluminium foil etc., considered packaging? If so, who is responsible for paying the contribution for such packaging?
Users of packaging to be filled at the points of sale (e.g., bakeries, fast food restaurants, etc.) will cease to be liable as of 23/07/2021 and such packaging will be declared by the manufacturers/importers. Therefore, users will make a declaration for the period prior to 23/07/2021, while the packaging should be declared by the manufacturers/importers after this date.
Criminal, administrative and other penalties are described in Law 4819/2021 and relate to the three categories of responsible packaging operators.
No, the contributions are not fixed, but they may be adjusted (Article 4.2 of the Contract). This ensures the System’s flexibility to changes in the marketing prices of the secondary materials, which are included in the calculation of the total recycling cost. Another possible reason for adjusting the financial contributions would be the requirement by the State to implement other packaging material recovery projects in addition to those proposed in the folder we have lodged and have been approved by YPEN. Reasons for the operators’ equal treatment and competition protection (that are not expected to fulfil an obligation because it would otherwise lead to a break in the economics of recycling) require uniform pricing of the services provided by HERRCO services under the System. Besides, the determination of the contribution must comply with the criteria laid down by law, while the financial contribution prices are approved by the competent authorities of the State. For these reasons, the adjustment of the contributions cannot be bilaterally negotiated between HERRCO and the respective responsible operator. Furthermore, HERRCO shall inform all parties if the Table in Annex C1 to the Contract is updated.
The money from the Responsible parties’ contributions is intended for the implementation of the projects with a view to achieving the goals set by the State for which the HERRCO Collective System has been approved. The System develops its projects in accordance with its business plan and its implementation time schedule as it has been agreed with YPEN. We should keep in mind that project implementation requires the signing of contracts with the relevant cooperating OTAs. The HERRCO Collective System develops its projects in accordance with its business plan and its implementation time schedule as it has been agreed and approved by YPEN, with a view to achieving the objectives set by Law 2939/01. The collection and recovery of packaging waste is already implemented in the operating recycling projects by the HERRCO Collective Alternative Management System and the cooperating Municipalities, within the borders of their respective regions.
The objective of the responsible – within the meaning of the Law – packaging operators (industry, commerce, etc.) is to make more efficient use of the funds that they are required to contribute for the purposes laid down by law. The efficient use of the funds is ensured through auditing and managing the alternative management financing mechanism as provided for by Law, but also this practice is implemented in the rest of the EU (Green Dot Organizations, e.g., DSD, ECOEMBALLAGES, etc.). We remind you that HERRCO has been established by the parties responsible under the Law, with the aim of self-managing the legal obligation of commerce and industry. The participation of the responsible companies thus ensures: a. The optimal cost and b. The certainty that funds are allocated exclusively to projects.
Therefore, there is no dividend, i.e., no profit is derived from the venture, and this is why the companies’ participation in HERRCO’s share capital is open to any interested company.
How does HERRCO ensure the validity of the data that each company declares through the “Declaration” and the personal information in the System?
The Contract describes HERRCO’s auditing system which concerns all the responsible companies irrespective of their “size” (Article 5). It describes the ability to perform an audit up to twice a year without this being definitive, but only if a need arises to determine the correctness of the data contained in the tables you submitted with your “Declarations”.
Finally, if your company’s certified auditor certifies the correctness of the information contained in your “Declarations” to the System, then HERRCO may perform an audit only when there is doubt regarding the certification.
The responsible company imports products into Greece and pays contributions to the respective System in the European countries from which the products are imported. Why should they also pay contributions to Greece?
According to the Contract signed by each responsible party both with the HERRCO System in Greece and the European Union Systems, they must declare and pay contributions for the packaging they place on the domestic market. Their exports are excluded and relate to the country in which they are consumed and the corresponding System of that country. Therefore, for packaged products/goods imported into Greece, no contributions have been paid to any European System, but contributions must be paid to the HERRCO System. The responsible parties pay a contribution to the country in which they produce waste from packaging material.
As described in the Cooperation Contract with HERRCO, the financial contribution also covers the use of the “Dot” trademark. The use of the “Dot” trademark has been exclusively granted to HERRCO by its owner, and HERRCO in turn grants the parties permission to place it on the packaging they include in their “Declaration”.
HERRCO S.A. is a multi-shareholder company established under the standards of the respective systems of the responsible parties in the other EU countries (e.g., ECO-EMBALAGES in France, DSD in Germany, CONAI in Italy, FOST-PLUS in Belgium, ECOEMBES in Spain, SOCIEDADE PONTO VERDE in Portugal, etc.). It has also been stated in writing that the participation in its shareholder structure is open. This is confirmed by the fact that there has already been an increase in the share capital of HERRCO and the inclusion of four new shareholders.
The package leaflets are not considered part of the packaging and are therefore not included in the financial contributions.
Contributions payable to HERRCO are expenses of the responsible operators and are deductible, i.e., they are entered in expenses under expenditure for Subscription fees – Contributions, code 64-05-XX.
The HERRCO Collective System develops its projects in accordance with its business plan and its implementation time schedule as it has been agreed and approved by YPEN, with a view to achieving the objectives set by Law 2939/01. The collection and the recovery of packaging waste is already implemented in the operating recycling projects by the Collective Alternative Management System and the cooperating Municipalities, within the borders of their respective regions.
Within the meaning of Collectivity under Law 2939/01, the HERRCO System renders all contracting parties lawful, without requiring the collection and recovery of the discarded packaging from each responsible party individually, but from all the System projects Collectively throughout Greece.
I already ensure, at individual level, that my waste is disposed of by paying municipal ‘fees’. Why should I also pay for the System?
Participation in CAMS – RECYCLING, which is organized by HERRCO, ensures that each participating packaging operator fulfils its legal obligations for the period that the System operates under the YPEN authorization. Therefore, the contributions that are paid to HERRCO by each contracting company do not relate to the collection of the waste it produces, but to the share of the cost of achieving the business plan approved by YPEN.
The financial contributions that are payable to the HERRCO Collective Alternative Management System (CAMS – RECYCLING) by the responsible parties relate to the alternative management of packaging waste deriving from all their activities (industry, commerce, offices, shops, services, households, or any other source) and should not be confused with the “fees” that a company pays to the Municipality for the management of all its waste.
Alternative management of packaging from household waste and the commercial sector is already applied in the project areas of the HERRCO system.
With a view to expanding its activities, HERRCO has cooperated with private recyclers operating in the collection and recycling of packaging waste from the Industrial and Commercial sectors.
According to the provisions of the Law (Articles 2(1) and 3(1)(a)), the operating framework of the System and the relevant decisions of the competent services of the Hellenic Ministry of Environment and Energy (YPEN), each responsible packaging operator must declare all packaging (primary, secondary, and tertiary) of all products/goods it places on the Greek market and packaging waste related to its activity derived from any material (raw material and/or processed material) and from all sources (residences, commerce, industry, etc.).
Packaging of products to which a deposit-refund system (DRS) applies, i.e., an individual system.
Packaging containing lubricants used in engines and the transmission and steering system. A special Collective System has been approved for such packaging.
Hazardous packaging waste.
Destroyed packaging (accompanied by destruction protocol)
We specify the following:
In the case of imports of products/goods which are unpacked at the premises of the responsible importer, resulting in the disposal of their tertiary and/or secondary packaging (e.g. cardboard boxes, pallets etc.) and then repacked and placed on the Greek market in new packaging, the responsible importer must declare the total packaging (e.g. that it imported, unpacked and repacked for marketing).
The responsible operator must declare and pay a contribution for the packaging of goods/products that can no longer be reused and have thus become waste.
The collection process of the Recycling bins falls under the responsibility and within the competence of the Municipalities that cooperate with the Collective Alternative Management System CAMS – RECYCLING (“System”) that are organized by HERRCO. The System delivers such equipment (vehicles, bins) to OTAs to be used in accordance with the System’s cooperation framework with the OTAs, which has been approved by the competent authorities. The Municipalities are responsible for the operation of the programme and the collection of the bins. You should contact your Municipality and its Cleaning Department and inform them of your observation.
The proper use of recycling vehicles and in general the recycling bin collection process falls under the responsibility and within the competence of the Municipalities that cooperate with the Collective Alternative Management System CAMS – RECYCLING (“System”) that is organized by HERRCO. The System delivers such equipment (vehicles, bins) to OTAs to be used in accordance with the System’s cooperation framework with the OTAs, which has been approved by the competent authorities. Therefore, the first step that a concerned citizen needs to take if they notice such a phenomenon is to communicate with the Municipality (Cleaning Department). Of course, if the System receives these observations from citizens, they are forwarded to the Municipality in question and the reasons for such a phenomenon and any solutions are sought in order to eliminate it completely.
Recycling is going very well in Greece. We are at the same level, if not better, than to the level that the respective foreign countries were in, in the respective starting years of the recycling projects, while HERRCO projects already meet the EU goals, with the exception of glass for which specific measures are being taken. The coordinated and methodical efforts taken by HERRCO have contributed, so that around 10.4 million residents throughout Greece are able to recycle today. Each year, more than 500,000 tons of recyclable materials are transferred to recycling rather than landfills and have contributed to alleviate the severe problem of finding new waste disposal sites.