Global Agriculture Information Network

**Date:** 08/30/04

**GAIN Report Number:** GR4021

GR4011

**Greece**

**Food and Agricultural Import Regulations and Standards**

**Country Report**

**2004**

**Approved by:**

![](media/image1.wmf)Ann Murphy

U.S. Embassy, Rome

**Prepared by:**

Danae Synodinou

**Report Highlights:**

This report provides information to U.S. exporters on labeling,
packaging, ingredient contents and other relevant information pertaining
to food and agricultural imports into Greece. It also provides points of
contacts for Greek government and food laboratories.

Includes PSD Changes: No

Includes Trade Matrix: No

Annual Report

Rome \[IT\]

\[GR\]

Table of Contents

[**Disclaimer 3**](#disclaimer)

[SECTION I. FOOD LAWS 3](#section-i.-food-laws)

[SECTION II. LABELING REQUIREMENTS
4](#section-ii.-labeling-requirements)

[A. General Requirements 4](#a.-general-requirements)

[B. Requirements Specific to Nutritional Labeling
6](#b.-requirements-specific-to-nutritional-labeling)

[SECTION III. Packaging and Container Regulations
7](#section-iii.-packaging-and-container-regulations)

[SECTION IV. FOOD ADDITIVE REGULATIONS
7](#section-iv.-food-additive-regulations)

[SECTION V. PESTICIDE AND OTHER CONTAMINANTS
8](#section-v.-pesticide-and-other-contaminants)

[SECTION VI. OTHER REGULATIONS AND REQUIREMENTS
9](#section-vi.-other-regulations-and-requirements)

[SECTION VII. OTHER SPECIFIC STANDARDS
10](#section-vii.-other-specific-standards)

[SECTION VIII. COPYRIGHT/TRADEMARK LAWS
10](#section-viii.-copyrighttrademark-laws)

[SECTION IX. IMPORT PROCEDURES 10](#section-ix.-import-procedures)

[APPENDIX I -- GOVERNMENT REGULATORY AGENCY CONTACTS
10](#appendix-i-government-regulatory-agency-contacts)

[APPENDIX II. OTHER IMPORT SPECIALIST CONTACTS
11](#appendix-ii.-other-import-specialist-contacts)

# Disclaimer

**This report was prepared by the Office of Agricultural Affairs of the
USDA/Foreign Agricultural Service in Athens for U.S. exporters of
domestic food and agricultural products. While every possible care was
taken in the preparation of this report, information provided may not be
completely accurate either because policies have changed since its
preparation, or because clear and consistent information about these
policies was not available. It is highly recommended that U.S. exporters
verify the full set of import requirements with their foreign customers,
who are normally best equipped to research such matters with local
authorities, before any goods are shipped. FINAL IMPORT APPROVAL OF ANY
PRODUCT IS SUBJECT TO THE IMPORTING COUNTRY'S RULES AND REGULATIONS AS
INTERPRETED BY BORDER OFFICIALS AT THE TIME OF PRODUCT ENTRY**

# SECTION I. FOOD LAWS

Greece as a member of the European Union (EU) follows the EU directives
and regulations. Labeling and ingredient legislation for all food and
agricultural products is based on EU rules and regulations. It is
therefore recommended that U.S. importers read in conjunction with this
report the Food and Agricultural Import Regulations and Standards
(FAIRS) report produced by the U.S. Mission in Brussels at
[www.useu.be/agri/usda.html](http://www.useu.be/agri/usda.html).
Nevertheless, Greece maintains specific labeling and ingredient rules
for some food products, which are described in detail in the Greek Food
Code published by the General State Chemical Laboratory (GSCL). There is
no electronic version of the Greek Food Code, a hard copy can be
obtained in Greek, from the General State Chemical Laboratory. Thus, it
is essential for the U.S. exporters to have a Greek agent with a
suitable background, to undertake the clearance procedures. The GSCL is
the Greek agency responsible for labeling and product ingredient
regulations, and it also performs the laboratory tests for granting
importation approval to foodstuffs subject to approval.

The current Food Code was published in 2003 and is amended by a number
of decrees to incorporate new legislation. The Food Control Agency
(EFET), is responsible for enforcing the regulations and collecting
samples from selling points to check compliance with food legislation to
ensure food safety and protection of consumer health in accordance with
EU Dir 89/397. Locally produced and imported food items are regularly
checked by random sampling not only for absence of prohibited
ingredients but also in terms of fair trading practices and consumers'
expectations, as product label should not mislead or confuse the
consumer. Labeling must not make false claims nor should any product
present a risk to public health.

Contact information for GSCL and EFET follows:

General State Chemical Laboratory Food Control Agency (EFET)

Directorate of Foods Mr. Nikos Katsaros, President

Ms. Asimina Papathanasiou, Director 5 Karystou Str., GR-115 53 Athens

16, A. Tsoha Str, GR-115 21 Athens Tel.: ++30-210-6971-500

Tel.: ++30-210-6479-251 Fax: ++30-210-6971-501

Fax: ++30-210-6467-725 email: info@efet.gr

Email: <gxk-foodiv@ath.forthnet.gr> Web site: http://www.efet.gr

Greek Food regulations apply to both domestically produced and imported
food products. Imported food and beverage products complying with rules
and regulations as would any other product sold in the EU market,
require no special permit nor they are subject to special rules or
regulation regarding their commercialization in Greece.

If a U.S. food product, other than food supplements, conforms to any
single EU member state's rules and regulations it can be transshipped
and sold in all other EU member states. However, approval by the Supreme
Chemical Committee (SCC), General State Chemical Laboratory, is needed
when a food product does not correspond to Food Code specifications, in
accordance with SCC Decision 366/97, Official Journal of the Greek
Republic 597/B/17.7.97, and in cases where preparation, processing and
packaging use one of the following:

a\) Additives such as antioxidants, colours, emulsifiers, stabilizers,
gelling agents and thickeners, flavourings, preservatives, sweeteners,
enzymes that are not listed in EU Regs 94/34, 94/34 and 95/2;

b\) Materials and objects that will come into contact with foods,
substances or materials and are not included in the Greek Food Code list
of allowed materials;

c\) New techniques and technologies prohibited by the Food Code;

d\) Novel foods or new ingredients;

e\) Foods enriched with nutritional elements (vitamins, traces,
aminoacids)

SCC approval is granted on application and the procedure takes
approximately 3 months for products already circulated in other EU
member states, and 5 months for new to EU products.

Greece has been in compliance with EU Regs 1829/2004 and 1830/2004, and
requires all foods and feeds containing GMO ingredients, either
detectable or non-detectable, to be labeled accordingly.

Exporters are advised to have an experienced agent or joint venture
partner, with a suitable background, experience and extensive
sales/services network, who can offer full support to the end-user. The
Greek importer has the responsibility for the marketability of any
imported products into Greece. The importer is responsible for any
violations of the Greek Food Code and is the person who is prosecuted in
case of failure to observe food laws.

# SECTION II. LABELING REQUIREMENTS

# 

## A. General Requirements

All imported food products should comply with the Greek Food Code.
Missing a required indication stated in the Greek Food Code prohibits a
good from being sold in the Greek market. Greece requires that labels be
in the Greek language. Multi-language labels are acceptable. Stick-on
labels are accepted. Sample size products should bear the "Not for Sale"
indication.

Labeling, presentation and advertising foodstuffs applies for retail
sale as well as hotels, restaurants, hospitals and other institutional
establishments. Labeling, including picture or symbol referring to and
attached to a foodstuff, must not deceive the consumer as regards its
characteristics, attribute characteristics to the product which does not
have, present a common characteristic as unique, or attribute
preventative or therapeutic properties to the product. Indications such
as "No colours", "No preservatives" or similar should appear on the
product only if the products do not contain such substances in raw
materials, or do not proceed from production process, manufacturing
process, addition or residues.

Labeling should not attribute to foodstuffs capacity to preventing,
treating or curve human diseases. This rule does not apply to dietetic
foods and natural mineral water.

The following information is compulsory for all foodstuffs and should
appear on the label:

**Product name:** This may be either a name of a description. The
product name cannot be replaced by a commercial or industrial mark or by
commercial nomenclature. The product name should contain or be
accompanied by the nature of the product (i.e. powder, frozen) if the
omission of this indication may confuse the consumer. Irradiated
foodstuffs should be marked accordingly.

**List of ingredients in descending order by weight**: A list of
ingredients, including additives used for the production of the product,
which exists in the end product. The list should start with the word
"ingredient". In mixtures of vegetables and/or fruits containing equal
quantities of vegetables and fruits, vegetables and/or fruits can be
listed in random sequence. List of ingredients is not necessary for
fresh fruits and vegetables, carbonated beverages, vineyard, cheese,
butter, milk in ferment, products consisted of a single ingredient under
the condition that the product name is the same with the ingredient.
Certain ingredients may be named by the name of their category group
rather than the specific name. These include refined vegetable oils
excluding olive oil, refined fats, flour blends, starch, fish, cheese,
spices, herbs, gum bases, crumbs, sugar, dextrose, glucose syrup, milk
protein, cocoa butter, crystallized fruits (not exceeding 10% of the
product's weight), vegetable mixes (not exceeding 10% of the product's
weight), and wine.

**Quantitative ingredient declaration:** The quantification of an
ingredient or a group of ingredients used for the production of the
product is stated if the ingredient is present in the name of the
product.

**Net quantity of prepackaged food**: The net quantity of prepackaged
foods is expressed in metric units (liter, centiliter, milliliter,
kilogram, gram). For pre-packed products that are sold by piece, the
indication of the net quantity is not necessary if the items included in
the package can be easily counted or if the number of pieces is stated
on the label.

**Shelf-life date -- Expiration date**: This can either be written as
"Best until ....." or "Best before ....". The date should include in
order day, month, year. Declaration of minimum shelf-life is not
necessary for fresh fruits and vegetables (including potatoes), vins de
liquers, alcoholic beverages of more than 10% alcohol, non-alcoholic
beverages packaged in more than 5 liters packages destined to the hotel,
restaurant or institutional (hri) sector, bakery products, vineyard,
salt, crystal sugar, chewing gums and portioned ice cream.

**Storage and usage conditions:** Instructions of use when needed to
ensure proper use of the product.

**Alcohol content:** Alcoholic beverages under tariff codes 22.04 and
22.05 containing more than 1.2% alcohol need to be shown as "Alcohol (or
alc.) ...% VOL". The alcohol content is measure at 20 degrees Celcius.

**Producer's or Packer's or Importer's name and address in any EU member
country**

**Country of Origin of the Product:** This can either be the country of
production or origin of the product, according to EU regulations.

**Lot identification**: Lot here is used to identify products produced,
processed and packaged, in similar conditions. The letter L precedes the
lot number except in the cases where it is clearly distinguishable from
other indications stated on the label. The lot number should be evident
and visible (color fast). The lot number is assigned by one of following
persons, who need to be located within an EU country: The producer, the
processor, the packer or the initial vendor of the product.

## 

## B. Requirements Specific to Nutritional Labeling

## 

Nutritional labeling in Greece is optional. However, it is required when
nutritional value is presented or advertised (EU Directive 90/496) in
order to prevent misleading information on labels.

Nutritional information, if provided, must provide information from
Groups 1 or 2 in the following order:

When the nutritional claim relates to sugars, saturated fatty acids,
fibre or nitrates Group 2 information is to be provided.

Nutritional labeling may include quantities of:

• Starch

• Polyalcohol

• Hydrocarbons

• Fats

• Cholesterol

• Vitamins and

• Inorganic acids

Statement of energy and nutrient content is numerical and in specific
units per 100 grams or 100 milliliters. Units used in the label are:
Energy: Kj and Kcal; proteins, hydrocarbons, fasts, fibre, sodium in
grams; cholesterol in milligrams, vitamins and inorganic acids may also
state their recommended daily intake.

Nutritional labeling must be presented in Greek also in tabular form
with the numbers aligned and if space does not permit this form, linear
form is accepted.

Declaration of a product as "low in hydrocarbons and/or sugars" is
allowed if the content in absorbable carbohydrates is less than 0.25%.
Declaration of a product as "reduced calories" is allowed if the
calories are reduced by at least 30% compared with the original
foodstuff. This category covers products such as "light", "line" or
"slim". Declaration of a product as "low in calories" is permitted if a
single intake yields a maximum of 15 calories to the body and 30
calories as the daily intake.

**Dietetic Foods - Special Food Products**

Foodstuffs for infants, and people with health problems fall under this
category. These products in addition to the regulations pertaining to
regular foodstuffs need to specify for what group of people they are
intended, in addition to caloric value and nutrient content. Foodstuffs
included in this category are:

• Baby foods

• Milk for babies

• Low calorie products to control weight

• Food for diabetics

• Low sodium foods including low/no sodium salt

• Non-gluten foods

• Special foods for athletes

• Other food products of special medical purposes

Every declaration or advertisement for dietetic products must by
explicit. The National Pharmaceutical Organization (EOF) is the
responsible agency to impose and implement regulations on dietetic foods
and food supplements.

# SECTION III. Packaging and Container Regulations

Foodstuff packaging must guarantee that the product is protected against
all external influences. Packaging is to be carried out under strict
conditions of cleanliness with only approved materials. The composition
of food packaging material must not influence or be influenced by the
foodstuff, not cause changes in smell, taste or the appearance of the
foodstuff and not transmit harmful substances.

Regulations for materials in contact with food have been EU-harmonized
and Greece complies with EU Reg 89/109, specifying the common rules for
materials that come into contact with foodstuffs. Materials must bear
either an indication "for food use", or a specific symbol designed in
Council Directive 80/590/EEC. For additional information please see
[www.useu.be/agri/packaging.html](http://www.useu.be/agri/packaging.html).

# SECTION IV. FOOD ADDITIVE REGULATIONS

A food additive is any substance, not used as an ingredient,
irrespectively of nutritional value, added to a food for technical
reasons, as an effective constituent directly or indirectly. An additive
is allowed only when proved advantageous for the consumer. To determine
possible unfavorable effects, additives are subject to appropriate tests
and toxicological evaluation, including cumulative effects. Food
additives should be clearly visible on the product label.

The Greek Food Code is governed by EU regulations on food additives. The
Greek Food Code and EU prohibit the usage of food additives not listed
in the following table:

Foodstuff Additive Categories

  ----------------------------------- -----------------------------------
  Coloring Agents                     Sweeteners

  Preservatives                       Expansion Powder

  Anti-oxidants                       Anti-foaming agents

  Emulsifiers                         Coating materials

  Emulsifying salts                   Flour enhancing agents (improvers)

  Coagulating substances              Hardeners

  Coagulants                          Hydroscopic agents

  Taste enhancing agents              Blocking agents

  Oxidants                            Enzymes

  Acidity correctives                 Volume augmentation agents

  Anti-coagulants                     Propulsive and packing gases

  Modified starches                   
  ----------------------------------- -----------------------------------

Food additives are placed in categories according to function, but may
be used for other purposes. There are positive lists for additives,
colorings and sweeteners that can freely be used in all foods, except
for certain product categories (i.e. traditional products), and there
are also some specific lists of preservatives, antioxidants and other
additives which have limited use in certain food products. A list of
allowed additives can be found in the Greek Food Code and can also be
obtained by the General State Chemical Laboratory.

In consideration of scientific and technical progress, the SCC may allow
use of an unlisted additive provided that a) permission is given for
maximum of two years, b) the foodstuffs containing it will be subject to
official control, and c) a special indication may be stipulated on the
labeling. Prior to expiration of the two-year period, application may be
made for listing the additive under procedures of EU Dir 89/107.

Foodstuffs in which a limited number of food additives can be used
include:

• Chocolates and chocolate products

• Fruit juices and juice mixtures (including pineapple and grape juice)

• Marmelades and jellies

• Partially dehydrated milk

• Frozen, deeply frozen, chilled non-processed vegetables (including
potatoes)

• Fruit compote

• Rice

• Fats

• Refined olive oil

• Ripened Cheese

• Mozzarella Cheese

• Canned fruits and vegetables

• Gehakt

• Pre-packed ground meat

• Bread

• Fresh pasta

• Wine

• Beer

• Butter

• Foie gras

# SECTION V. PESTICIDE AND OTHER CONTAMINANTS

Maximum residue levels (MRLs) are set at the EU level. The Greek
Ministry of Food and Agricultural Development, Plant Protection
Division, monitors, enforces and is responsible for "risk assessments"
of MRLs on fresh, unprocessed products as well as dairy and livestock
products. Processed foodstuffs are monitored and enforced by the Food
Control Agency (EFET).

Greece complies with following EU Directives and Regulations on MRLs:

90/642/EU for fruits and vegetables

86/362/EU for grains

86/363/EU for food products of animal origin

2000/24/EU - Amendment

2002/63/EU - Amendment

Please see [www.europa.eu.int](http://www.europa.eu.int/) for a product
list. For additional information on MRLs in Greece, please review
GR4011, dated 7/14/04.

Pesticides need to be registered in the National Catalogue. In order for
a pesticide to be approved and registered, an application must be turned
in by the importer, to the Supreme Committee of Pesticides, Ministry of
Food and Agricultural Development, requesting approval. Pesticide
registration procedures take 2-5 years. Greece accepts WHO Codex
International List.

# SECTION VI. OTHER REGULATIONS AND REQUIREMENTS

Each EU member state is responsible for carrying out inspections on a
regular basis. Random checks are performed at import or at later stages
of trading. Imported foods are not subject to registration. Foodstuffs
entering Greece for the first time are inspected to get approval. The
ingredient list that must accompany the product is the one that
determines its clearance and what duties imposed. The application for
approval must include a statement indicating the name of the product,
type of packaging, processing method, the exact composition of the
product and food safety control methods used. If all are in compliance
with Greek Food Code the product is granted clearance. The clearance
procedure costs about €150 or approximately \$181 and is handled by an
expediter.

Products including allowed additives not included in the catalogue, non
approved packaging material, have used new technologies in the
processing method, novel foods in accordance with SCC Decision 366/97,
and foodstuffs enriched with nutritional elements must obtain approval
from the SCC in order to be commercialized in Greece. The cost of this
procedure is €320, approximately \$390. The procedure takes 5 months for
products new to EU countries and 3 months for products already
commercialized in other EU member states.

Specific agricultural and food products which are subject to inspection
and to Greek trade restrictions include:

-   **Poultry, Meat, Fish, Dairy, Egg**: Products of third country
    origin must originate from plants included in the list of EU
    approved plants.

-   **Enriched/Bleached flour**: Greek regulations prohibit the import
    of any products made or including enriched/bleached flour.

-   **Nuts**: Imported nuts are subject to a random aflatoxin test at
    entry stage or at selling points. At port, usually one out of ten
    containers are sampled to be tested for aflatoxin. Phytosanitary
    certificates for row nuts imported into Greece are required in
    accordance with EU legislation in effect.

-   **Seeds:** Greek authorities require non-presence of transgenic
    material for imported cotton seeds, while for corn seeds the
    tolerance level set is 0.5% for EU approved corn varieties. Wheat
    seeds are checked for Karnal bant.

Food samples must undergo all hygiene or labeling requirements.

For additional information please refer to:
<http://www.useu.be/agri/usda.html>

# SECTION VII. OTHER SPECIFIC STANDARDS

-   **Traceability and Labeling Requirements:** Greece is in compliance
    with EU Regs 1829/2004 and 1830/2004 which require all foods and
    feed containing biotech ingredients, either detectable or
    non-detectable to be labeled accordingly, without specifying the
    percentage of content. The allowable adventitious presence for EU
    approved varieties of genetically engineered substances for use in
    food and feed is set at 0.9%. Above this level, all products must be
    labeled as containing biotech. Meat, milk and other dairy products
    originating from animals fed with GM feed do not require biotech
    labels.

\- **Consumer Packing**: In accordance with EU Reg 89/109; 16/2002;
2001/16/EU

# SECTION VIII. COPYRIGHT/TRADEMARK LAWS

# 

Greece's legislation on trademark/copyright is harmonized with EU
legislation. The trademark in order to be registered, must be new (not
previously used), with distinctive quality (not generic) and something
not already in common usage.

# SECTION IX. IMPORT PROCEDURES

# 

Food products must conform to the regulations required by the Greek Food
Code and EU legislation.

Food and beverage products of U.S. origin complying with EU rules and
regulations would not require special permits (nor they are subject to
special rules or regulations) for commercialization in Greece. However,
biotech products, as previously discussed, are handled quite strictly.
If a U.S. food product, other than food supplements, conforms to any
single EU member state's rules and regulations it can then be
transshipped and sold in any other EU member state. For additional
information on EU Import Regulations and Procedures, please refer to:
[www.useu.be/agri/label.html.]{.underline}

Food products entering Greece are examined upon their entry by Customs
Authorities (Port Customs Authorities, Health Authorities) who inspect
the import documents. Health authorities may perform tests and relative
analysis of samples. Import procedures can be completed and the product
may enter the market within 48 hours from the time of arrival at port if
no specific problems arise from the import inspection. Health
certificates accompanying foodstuffs must in the Greek language.

To enter the Greek market, it is very important to have an agent or
joint venture partner, with a suitable background, who would handle all
importing procedures.

# APPENDIX I -- GOVERNMENT REGULATORY AGENCY CONTACTS

# 

**General State Chemical Laboratory**

Directorate of Foods

Ms. Asimina Papathanasiou, Director

16, A. Tsoha Str, GR-115 21 Athens

Tel.: ++30-210-6479-251

Fax: ++30-210-6467-725

Email: <gxk-foodiv@ath.forthnet.gr>

**Food Control Agency (EFET)**

Mr. Nikos Katsaros, President

5, Karystou Str., GR-115 53 Athens

Tel. ++30-210-6971-500

Fax: ++30-210-6971-501

Email: <info@efet.gr>

# Ministry of Food and Agricultural Development

# Plant Production Division

Mr. George Papavasiliou

3-5 Ippokratous Str., GR-101 64 Athens

Tel. ++30-210-212-4501

Fax: ++30-210-3617-103

# Ministry of Food and Agricultural Development

Pesticides Department

Mr. Konstantinos Karamitros

3-5 Ippokratous Str., GR-101 64 Athens

Tel. ++30-210-212-4525

Fax: ++30-210-3632-168

#  Ministry of Food and Agricultural Development

# Veterinary Division

Dr. Vasilios Stylas

6, Kapnokoptiriou Str., GR-104 33 Athens

Tel. ++30-210-212-5753

Fax: ++30-210-8229-188

# Ministry of Food and Agricultural Development

# Veterinary Division, Public Health

Dr. Sotirios Moshovitsis

6, Kapnokoptiriou Str., GR-104 33 Athens

Tel. ++30-210-212-5759

Fax: ++30-210-8836-020

**The National Pharmaceutical Organization (EOF)**

284 Mesogion Ave, GR-155 62 Halandri, Athens

Tel. ++30-210-6545-533

Fax: ++30-210-6512-663

# Piraeus Port Authority

10, Akti Miaouli Str., GR-185 37 Piraeus

Tel. ++30-210-4520-910

Fax: ++30-210-4520-852

# APPENDIX II. OTHER IMPORT SPECIALIST CONTACTS

# 

Partial list of accredited laboratories

# AGENT

Mr. Petros Paschalis

46 Alexandroupoleos Str., GR-115 27 Athens

Tel/Fax: ++30-210-7473-971

**SURVEILLANCE S.A.**

Mr. M. Meleagros

3 Alkmanos Str., GR-15 28 Athens

Tel. ++30-210-7229-287

Fax: ++30-210-7220-969

**SKYLAB-MED S.A.**

Ms. V. Tychopoulou

26 Amyklon Str., GR-152 31 Halandri, Athens

Tel/Fax:++30-210-6773-625

**AGROLAB S.A**.

Mr. N. Efthymiadis

P.O. Box 88, GR-570 22 Sindos, Thessaloniki

Tel. ++30-2310-795-027

Fax: ++30-2310-796-623