Legally Obligated Enterprises

The year 2003 has been a landmark for our country with regard to Recycling since Law 2939/01 obliged all enterprises, which import, produce and supply packaged goods to the domestic market, to see to the collection and Recycling of the packaging they use.

In particular, the said legislation regulates primary, secondary and tertiary packaging used in the Greek market, packaging waste from all sources (industry, commerce, offices, stores, agencies, households, etc.), as well as other products such as vehicle tyres, batteries, electric or electronic devices, furniture, etc.

Affiliated companies: The power of the system

How to join


Any company wishing to become a Member of HE.R.R.Co has to sign a Participation Agreement, which is valid for one year.

The aforementioned Participation Agreement must be signed by all those who supply packaged goods to the Greek market and are:

  • Importers and/or producers thereof
  • Holders of Private Label Products/Brand Owners.

Upon the signing of the agreement, each Member must fulfill its legal obligations and may become a holder of the European-wide “green dot” on packaging items distributed in the Greek market.

Submission of Declaration

In seeking to assist packagers, both with regard to calculating their contribution to the System, as well as with regard to the submission of their Declaration, HE.R.R.Co has developed a special application which simplifies these processes.

All Members of the System have access to this application, through the link Submit Declaration using their personal username and password.

Affiliated Members – Companies

Chart 1 presents the progress of signed agreements, starting from the foundation of the System till the end of 2015.

By December 31 of 2016, the companies that have signed a Collaboration Agreement with the System were 1,890 in total.

The relevant list of companies is communicated to the competent authorities.

Chart 2 depicts the extent of contribution per activation field on behalf of the affiliates.

The majority of contributions (62%) results from companies active in the food and beverage sector.

Frequently Asked Questions

If you have further questions, please contact us.

According to Law 2939 the responsible “packaging operators” are:
A. Producers and importers of raw materials.
B. Producers and importers of packaged products which are supplied to the Greek market, namely Packagers.
C. Transfer Agents, namely those who trade in packaged goods. In some cases these are the same as Packagers, as in the case of Super Markets for instance.

According to a decision by the competent Alternative Management Supervision Committee (EPED), the Agreement with the System of HE.R.R.Co is to be signed by:
• Importers & producers of packaged products/goods.
• Holders of Private Label Products/Brand Owners. The responsibility for such products is undertaken by the Brand Owner rather than the producer or importer.

Exports and multi-use packaging subject to re-use are excluded.

According to a decision by the European Court of Justice (29/4/2004 in Luxembourg), the provisions of the European Directive 2004/12/ΕC and the clarifications by the competent Alternative Management Supervision Committee (EPED), materials filled at the point of sale, such as carrier bags, wrapping paper, aluminium foil etc., are considered packaging materials. In addition, according to a decision by the competent Alternative Management Supervision Committee (EPED), the contribution for these packaging materials is incurred by the company supplying them to the end consumer.

According to the provisions of the applicable Law (Article 2, paragraph 1 and Article 3, paragraph 1, section a), the framework of operation of the System and the related decisions of the competent departments of the MEPPPW, all packaging managers must declare all packaging materials (primary, secondary and tertiary) of all products/goods supplied to the Greek market and the waste of packaging linked with their activities and derived from any material (raw material and/or processed material) and from all sources (households, commerce, industry, etc.).

The following are excluded:
• Packaging items of products in respect of which a security scheme is applied, namely an individualized system.
• Packaging items containing engine lubricants and lubricants for the transmission and steering system. A special Collective System has been approved with regard to these packaging items.
• Hazardous packaging waste.
• Packaging which is destroyed (it is accompanied by a destruction protocol) along with its content.
• Packaging of exported products.

Please note the following:
• In the event of import of products/goods, which are de-packaged at the importer facilities, the result being that the tertiary and/or secondary packaging thereof is disposed of (e.g. cartons, pallets, etc.), while the products/goods in question are in turn re-packaged and supplied to the Greek market in new packaging, then the importer must declare all packaging used (e.g. the packaging imported, de-packaged and re-packaged for distribution).
• The operator must declare and contribute for the packaging of goods/products which have stopped being subject to re-use and have therefore been converted into waste.

The criminal, administrative and other sanctions foreseen are described in detail in Article 20 of Law 2939/01 and refer to all three categories of packaging operators.

In order to become a member of the Collective Alternative Management System (CAMS-RECYCLING) of HE.R.R.Co, any interested party must sign the Participation Agreement to the System which has been approved by the competent authorities.

The Participation Agreement to the System of HE.R.R.Co has been submitted, on the one hand, to the competent bodies of the state and approved, and, on the other hand, it has already been signed by the already affiliated packaging operators as it stands, and therefore, it is not possible to make any alterations to it. However, you are welcome to state your remarks and we will reply to them.

No, the contributions are not fixed, however the possibility of readjusting them is foreseen (Article 4.2 of the Agreement). In this way, we ensure that the System remains flexible in respect of changes in the prices for the distribution of secondary materials to the market, which are taken into account in the calculation of the total recycling cost. Another possible reason for readjusting the financial contributions is that the state might lay down a requirement for the implementation of projects in which use is made of packaging materials beyond those we have proposed in the folder submitted, which was approved by the MEPPPW. On grounds related to the equitable treatment of operators and the protection of competition, it is required that a single pricing system be adopted for the services provided by HE.R.R.Co in the context of the services System. What is more, the determination of the amount of contribution must correspond to the criteria set forth by the law, while the prices of the financial contribution are to be approved by the competent bodies of the state. For these reasons, the readjustment of contributions cannot become the subject of bilateral negotiation between HE.R.R.Co and each operator. In addition, HE.R.R.Co S.A. shall notify all contracting parties in the event that the Table of Annex C1 of the Agreement is readjusted.

The money from the contributions of the parties are allocated for the execution of projects aiming at the attainment of the goals set by the state, and projects for which the Collective System of HE.R.R.Co has been approved. The System develops its projects according to its business plan and the implementation time schedule as this has been agreed on with the MEPPPW. We should bear in mind that the implementation of the project presupposes the signing of agreements with the cooperating Local Authorities in each region concerned. The Collective System of HE.R.R.Co develops its projects according to its business plan and the implementation time schedule as agreed on and approved by the MEPPPW, with a view to achieving the objectives set by Law 2939/01. Collection and recovery of packaging waste is already carried out in the operating recycling projects, by the Collective Alternative Management System of HE.R.R.Co and the cooperating Municipalities, within the boundaries of their respective regions.

Under the meaning of Law 2939/01, the objective target of packaging operators (industry, commerce, etc.) is the more effective recovery of the resources they are obliged to contribute for the purposes set forth by the law. In order to ensure the effective recovery of resources, it is essential that the funding mechanism of alternative management be monitored and managed, as foreseen by the Law, and in line with the practices adopted throughout the entire EU (Green Dot Organizations, e.g. DSD, ECOEMBALLAGES, etc.). Please note that HE.R.R.Co was established by the enterprises responsible under Law 2939/01, in order to self-manage the legal obligation of commerce and industry. Therefore, membership on behalf of interested companies ensures: a. optimum cost and b. the certainty that financial resources are allocated exclusively to projects.
Consequently, no dividend is foreseen, in other words there is no profit gained from the undertaking as a whole, which is why the possibility of acquiring a shareholding in the share capital of HE.R.R.Co is open to any company interested.

Community Directive 94/62/EC applies to all Member States of the European Union. Ever since the beginning of the previous decade, systems similar to HE.R.R.Co have been in place in all European Union countries; what is more, these systems use the “Green Dot” sign, the licence for which you will obtain as well only upon signing the Agreement.

The Agreement sets out the auditing system of HE.R.R.Co which pertains to all companies regardless of their “size” (Article 5). It sets out the possibility of auditing up to twice per year, without this being definite; an audit is rather foreseen if and provided that there is need to ascertain the accuracy of the data contained in the tables you submit by way of your “Declarations”.

Finally, in the event that the chartered auditor of your company certifies in his or her annual report the accuracy of the data contained in your “Declarations” to the System, then HE.R.R.Co may proceed to performing an audit only if the said certification is disputed.

According to the Agreement of both HE.R.R.Co in our country and the corresponding systems in the European Union signed by any party, the said party is obliged to declare and pay a contribution for the packaging materials supplied to the domestic market. Exports are excluded and pertain to the country in which the materials are consumed and the corresponding System of that country. Consequently, with regard to the packaged products/goods imported in Greece no contribution has been paid to any European System; yet, a contribution is payable to HE.R.R.Co.

The financial contribution as it is set forth in the Partnership Agreement with HE.R.R.Co covers the use of the “Dot” as well. The use of the “Dot” has been exclusively granted to HE.R.R.Co by its owner and HE.R.R.Co in turn may grant its licence to the contracting parties, which may place it on the packaging referred to in their “Declaration”.

HE.R.R.Co S.A. is a multi-shareholder corporation of enterprises which was established in line with the standards of corresponding systems in other EU countries. (e.g. ECO-EMBALLAGES in France, DSD in Germany, CONAI in Italy, FOST-PLUS in Belgium, ECOEMBES in Spain, SOCIEDADE PONTO VERDE in Portugal, etc.). Furthermore, it has been stated in writing that the possibility of acquiring a shareholding in its share capital structure is open. This is confirmed by the fact that there has already been an increase in the share capital of HE.R.R.Co and four new enterprises have joined in as shareholders.

Instruction sheets are not considered packaging components and therefore they are not taken into account when it comes to financial contributions.

The contributions to HERR.Co constitute expenses of the operators and are deducted from the tax payable, in other words they are registered as expenses in the category expenditure for Subscriptions-Contributions under the code 64-05-ΧΧ.

The Collective System of HE.R.R.Co develops its projects according to its business plan and its implementation time schedule, as agreed and approved by the MEPPPW, with a view to attaining the objectives set by Law 2939/01. The collection and recovery of packaging waste is already carried out in the operating recycling projects by the Collective Alternative Management System and the cooperating Municipalities, within the boundaries of their own regions.

Under the concept of Collegiality, in accordance with Law 2939/01, the System of HE.R.R.Co enables all contracting parties to fulfill their legal obligation in a lawful manner, without this presupposing the collection and recovery of packaging waste by each contracting party individually but rather collectively, through all of the System’s projects throughout Greece.

Being a member of CAMS-RECYCLING which is organized by HE.R.R.Co SA, enables each affiliated packaging operator to fulfill their legal obligations for as long as the System operates under the licence granted by the MEPPPW. Consequently, the contributions paid by each contracting company to HE.R.R.Co S.A., are not related to the removal of waste produced, but rather account for its share in the costs involved in achieving the business plan approved by the MEPPPW. The financial contributions of parties to the Collective Alternative Management System (CAMS-RECYCLING) of HE.R.R.Co pertain to the alternative management of packaging waste produced as a result of all their activities (industry, commerce, offices, stores, services, households or any other source) and they should not be confused with the “fees” paid by companies to Municipalities for the management of their waste in its entirety.

The alternative management of packaging from household waste and the commercial sector is already being carried out in the regions of the projects where the System of HE.R.R.Co is in operation.

In seeking to expand its activities HE.R.R.Co has engaged in partnerships with private recyclers operating in the field of collecting and recycling packaging waste from the Industrial and Commercial sector.