EUROPEAN COMMISSION Brussels, 8.9.2022 SWD(2022) 254 final COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2022







Country Report - GREECE















Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review 2022: Turning the tide through environmental compliance







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This report has been written by the staff of the Directorate-General for Environment, European Commission. Comments are welcome, please send them to: ENV-EIR@ec.europa.eu

More information on the European Union is available at http://europa.eu . Photographs: For reproduction or use of these photos, permission must be sought directly from the copyright holder. ©European Union, 2022 Reproduction is authorised provided the source is acknowledged. Table of Contents Executive summary Part I: Thematic areas 1. Circular economy and waste management Measures towards a circular economy Waste management

2. Biodiversity and natural capital Nature protection and restoration Marine ecosystems Ecosystem assessment and accounting 3. Zero pollution Clean air Industrial emissions Prevention of major industrial accidents – SEVESO Noise Water quality and management Chemicals 4. Climate action Key national climate policies and strategies Effort sharing target Key sectoral developments Part II: Enabling framework: Implementation tools 5. Financing Environmental investment needs in the EU EU environmental funding 2014-2020 EU environmental funding 2021-2027

National environmental protection expenditure Green budget tools Overall financing compared to the needs 6. Environmental governance Information, public participation and access to justice Compliance assurance Effectiveness of environmental administrations Reforms through the Commission’s Technical Support Instrument TAIEX Peer to Peer Projects

Executive summary In previous Environmental Implementation Reviews (EIRs), the main challenges identified for Greece for the implementation of EU environmental policy and law were: ·to address waste management issues, in particular the closure of illegal landfills and the treatment of hazardous waste; ·to improve nature protection by putting in place an efficient national protection system, raising awareness and creating the right incentives for sustainable investments; ·to complete the implementation of the Urban Waste Water Treatment Directive; ·to simplify its environmental administrative structures and procedures, which can cause significant delays and bottlenecks, while at the same time strengthening its administrative capacity, that sometimes turn out to be the main obstacles to implementing environmental legislation. Greece still faces major structural problems with waste management and only limited progress has been recorded. Waste generation has been increasing somewhat, while recycling rates have improved only marginally. While the national waste management plan has been updated, the regional plans, which are necessary for implementating waste management policy on the ground, have been significantly delayed. The number of illegal landfills in operation or in need of rehabilitation has continued to decrease over the years. However, the remaining illegal landfills will be very difficult to close unless new facilities are built, while keeping in mind that an overcapacity of treatment facilities of residual waste will not help Greece’s transition towards a circular economy. Greece has to step up its efforts to put in place an adequate network of facilities that would effectively manage all the hazardous waste produced in the country. In addition, treatment facilities and the separate collection of waste streams in the country are insufficient and most organic waste is landfilled without prior stabilisation. The Commission therefore initiated in November 2021 a new infringement procedure against Greece for failing to comply with the Landfill Directive and the Waste Framework Directive. Some progress has been made on the legal and institutional steps necessary to increase waste recycling, notably with the introduction of a new landfill tax in national legislation, outlined in the waste management reform foreseen in Greece’s recovery and resilience plan (RRP). The tax, which is due to be introduced in 2022,is a significant step in the right direction. However, the overall administrative capacity of the sector has weakened over the years and according to the Commission’s 2018 ‘early warning report’, Greece is at risk of not meeting the 2020 municipal waste recycling target of 50 %. On nature protection, Greece’s Natura 2000 network is now considered to be complete. Nevertheless, site-specific conservation objectives and measures have not been put in place due to insufficient data. Moreover, management plans are lacking and the percentage of habitats in good condition has decreased over the years. A major challenge to protect and manage Natura 2000 sites effectively is to set up a national system for the comprehensive management, administration and functioning of protected areas. The recent law that aims to put in place management bodies for all Natura 2000 sites should provide significant benefits in this respect.

On urban wastewater treatment, there have been some positive steps, such as the systematic assessment and strategic re-organisation of the country’s investment needs. However, there are significant delays in the projects that need to be carried out, particularly in the agglomerations (i.e. population centres or places of economic activity) in Eastern Attica, for which Greece has been paying fines for several years. On the simplification of administrative structures and procedures for environmental implementation, a positive step for Greece is the streamlining of environmental assessments under the Environmental Impact Assessment Directive, the Habitats Directive and the Industrial Emissions Directive. The weak administrative capacity of the environmental authorities in the country is considered a serious obstacle. EU financing continues to provide substantial support to bridge the environmental implementation gap. Greece is due to receive over EUR 30 billion from its RRP (2021-2026) in grants and loans and EUR 20 billion from the cohesion policy (2021-2027). The reforms set out in the Greek RRP to set up two new regulatory authorities in the waste and water sectors, are expected to have a positive impact in the respective areas. Greece’s environmental investments amounted to 0.72% of GDP in 2014-2020, relying on both EU- and national financing. In 2021-2027, the country’s environmental investment needs are estimated to reach over 1.12% of GDP, suggesting an environmental financing gap of at least 0.4% of GDP. The absorption of EU funds for environmental measures remains a cause for concern, with particular problems in the areas of waste management and nature protection. Greece has paid more than EUR 184 million in fines since 2014, as imposed by the Court of Justice of the EU for violations of EU waste and urban wastewater norms.

Part I: Thematic areas 1. Circular economy and waste management Measures towards a circular economy The new Circular Economy Action Plan adopted in March 2020 is one of the main building blocks of the European Green Deal. The EU’s transition to a circular economy will reduce pressure on natural resources and will create sustainable growth and jobs. It is also a prerequisite to achieve the EU’s 2050 climate neutrality target and to halt biodiversity loss. The Action Plan announces initiatives along the entire life cycle of products, aiming to reduce the EU's consumption footprint and to double the EU's circular material use rate by 2030. It targets how products are designed, promotes circular economy processes, encourages sustainable consumption, and aims to ensure that waste is prevented and the resources used are kept in the EU economy for as long as possible. The circular material use rate is a good indicator of an economy’s circularity, as it includes all the materials that are fed back into our economy. Large differences in the circularity rate exist between countries. To help achieve the goal in the EU circular economy action plan of doubling the EU circular materialuse rate by 2030, ambitious measures targeting the whole product life cycle are needed at Member State level. Such measures range from sustainable product design that makes it possible to increase the durability, reparability, upgradability and recyclability of products, to other measures, like: (i) remanufacturing; (ii) increasing the circularity in production processes; (iii) recycling; (iv) boosting eco-innovation; and (v) increasing the uptake of green public procurement. Greece’s circular (secondary) use of material stood at 2.4% in 2016, and 5.4% in 2020 compared to an EU average of 12.8%. Despite an increase in the recent years, Greece remains far below the EU average for this indicatorhttps://www.ianos.gr/i-draki-de-mirazonte-0520108.



Figure 1: Circular material use rate (%), 2010-2020 Resource productivity expresses how efficiently the economy uses material resources to produce wealth. Improving resource productivity can help to minimise negative impacts on the environment and reduce dependency on volatile raw material markets. As shown in Figure 2, with EUR 1.77 generated per kg of material consumed in 2020, resource productivity in Greece is slightly below the EU average of EUR 2.09 per kg. However, with the steady increase in its resource productivity over the last decade, Greece follows an encouraging trend. Figure 2: Resource productivity 2010-2020 Circular economy strategies The Commission encourages Member States to adopt and implement national/regional circular economy strategies covering the whole life cycle of products, as they are one of the most effective ways for countries to progress towards a more circular economy. Since its launch in 2017, national, regional and local authorities have used the European Circular Economy Stakeholder Platform to share their strategies and roadmaps. In April 2018, the Government Council for Economic Policy (KYSOIP) endorsed the national action plan on circular economy, including short-term measures and long-term priorities. The following sectors were identified as priorities: construction & demolition; water; reuse preparation; repairs and maintenance; bio-economy sectors; textiles and chemicals. In light of the new EU circular economy action plan, in November 2021, Greece approved its own action plan in this area, with a corresponding roadmap approved by the Council of Ministers.

The national action plan is expected to include a series of actions to be implemented up to 2025. The planned actions will focus on: production, consumption, waste management and general governance and administrative issues; products and services that are resource intensive and where the potential for circularity is high  e.g. electronics and ICT); batteries and vehicles; packaging; plastics; textiles; construction and buildings; food waste and water use. Although Greece does not have specific sectoral strategies for plastics, constructions and textiles, the action plan sets out initiatives addressing these sectors. Greece’s new National Waste Management Plan as well as its RRP outline several planned reforms, namely: revising the waste management law to put in place sustainable landfilling and recycling; incentives for municipalities to achieve higher recycling rates; enforcing the separate collection of waste; extending the ‘Producer’s responsibility’ scheme; upgrading the operation of recycling sorting facilities; and simplifying the legislation on “green points”. Eco-innovation A successful transition to a circular economy requires social and technological innovation. This is because the full potential of the circular economy can only be reached when it is implemented across all value chains. Eco-innovation is an important enabling factor for the circular economy. New approaches to product design and new business models can help to produce circularity innovations, creating new business opportunities. Greece ranked 17th on the 2021 Eco-Innovation Scoreboard, with a score of 102, making it an ‘average’ eco-innovation leader. Greece performed below the EU average on all five components of the 2021 Eco-innovation Index (eco-innovation activities, eco-innovation outputs, socio-economic, eco-innovation input and resource efficiency outcomes). Figure 3: Eco-innovation performance, 2010-2019



Green public procurement Public procurement accounts for a large proportion of European consumption, with public authorities’ purchasing power representing around 14% of EU GDP. Public procurement can help drive the demand for sustainable products that meet reparability and recyclability standards. Greece adopted its first green public procurement (GPP) action plan in 2021. The action plan recommends that to all public authorities use EU GPP criteria for procuring goods, services and public worksIt also sets mandatory and non-mandatory targets to use EU GPP criteria in the following categories: copying and graphic paper; computers and monitors; imaging equipment; lubricants (regenerated and biodegradable); road transport, road lighting and traffic signals; furniture; textiles; public space maintenance; waste water infrastructure; electrical and electronic equipment used in the healthcare sector; office building design, construction and management; and road design, construction and maintenance. Finally, setting up a monitoring system for green, sustainable and/or innovative public procurement is a key priority for 2022. EU Ecolabel and the Eco Management and Audit Scheme (EMAS) The number of EU ecolabel products and EMAS-licensed organisations in a given country provides some indication of the extent to which the private sector and national stakeholders in that country are actively engaged in the transition to a circular economy. It also shows how committed public authorities are to supporting instruments designed to promote the circular economy. As of September 2021, Greece had 3 559 products out of 83 590, and 20 licences out of 2 057 registered in the EU ecolabel scheme, ranking its EMAS take-up on the low side. Moreover, 35 organisations from Greece are currently registered in EMAS. Since 2019, there have been 211 new product registrations but licence registrations have gone down by 12. As Greece has adopted a circular economy action plan, this particular priority action from the 2019 EIR has been fulfilled. Given that Greece’s circular material use rate is far below EU average, a new priority action on this is proposed. 2022 priority action ·Adopt measures to increase the circular material use rate. Waste management Turning waste into a resource is supported by: (i) fully implementing EU waste legislation, which includes the waste hierarchy, the need to ensure separate collection of waste, the landfill diversion targets, etc.;

(ii) reducing waste generation and waste generation per capita in absolute terms; (iii) limiting energy recovery to non-recyclable materials and phasing out landfilling of recyclable or recoverable waste. This section focuses on the management of municipal waste , for which EU law sets mandatory recycling targets. Preventing products and materials from becoming waste for as long as possible is the most efficient way to improve resource efficiency and to reduce the environmental impact of waste. Waste prevention and reuse are the preferred options, and are therefore at the top of the waste hierarchy. The amount of municipal waste generated is a good indicator for the effectiveness of waste prevention measures. After a downward trend, municipal waste generation in Greece started to increase from 2013 onwards (the pattern reflects the post-recession period). Waste generation stood at 524 kg/year/inhabitant in 2019, relatively close to the EU average (502 kg/year/inhabitant), as Figure 4 shows. This indicates that Greece’s economic growth is not yet decoupled from its generation of waste. Figure 4: Municipal waste by treatment in Greece, 2010-2019 Figure 4 also shows municipal waste by treatment, in terms of kilos per capita. Little progress has been made since the 2019 EIR. Greece most of its municipal waste in landfills (78 %), with only 21 % being recycled (EU average 48 %). The landfill rate has decreased modestly and the recycling rate has slightly increased. Moreover, based on the information available to the Commission, it appears that a significant number of irregular and substandard landfills continue to operate in Greece and present serious risks for human health and the environment. First of all, three illegal waste dumping sites are not yet closed and rehabilitated and 17 such sites are closed but not rehabilitated. Following two rulings of the Court of Justice of the EU, Greece is paying fines (EUR 66.5 million so far) for these breaches. Greece has also been condemned by the CJEU for its inefficient management of hazardous waste and has paid EUR 49.6 million in fines so far. In addition, studies and investigations launched by the European Commission have revealed that Greece lacks sufficient treatment facilities as well as separate collection for glass and biodegradable waste. It also appears that most organic waste is landfilled without prior stabilisation . Therefore, in November 2021 the Commission initiated an infringement procedure against Greece for failing to comply with the Landfill Directive and the Waste Framework Directive . Greece has made very slow progress over the past decade (and, even regressed between 2011 and 2016) on increasing its recycling rate and diverting municipal waste from landfilling. In 2019, the recycling rate for municipal waste stood at 21% (16% recycled and 5% composted), well below the EU average of 48%. Figure 5 shows that Greece needs to step up investment in recycling to meet the EU 2020 and 2025 recycling targets. Figure 5: Recycling rate of municipal waste, 2010-2019 The Commission's Early Warning report' cited Greece among the countries at risk of missing the EU 2020 target of recycling 50 % of municipal waste. The report listed key priority measures that Greece should take to close the implementation gap. The Commission is currently finalising its analysis of progress on the 2018 ‘early warning’ report recommendations and on progress towards achieving the 2025 waste recycling targets, which will be presented in the form of a report at the end of 2022 with recommendations where appropriate. Implementation of the 2018 waste legislative package Greece has notified its transposition of the 2018 waste package to the Commission. A conformity assessment is now ongoing. Waste management plans and waste prevention programmes are instrumental for a sound implementation of EU waste legislation. They set out key provisions and investments to ensure compliance with existing and new legal requirements (e.g. waste prevention, separate collection for a number of specific waste streams, recycling and landfill targets). The revised plans and programmes were due by 5 July 2020. Greece has adopted and notified to the Commission its updated national waste management plan (ESDA), which is under assessment, but has not notified its updated regional waste management plans. Greece also adopted its new National Waste Prevention Programme in June 2021 for the period up to 2030.

2022 priority actions Given the limited progress since the 2019 EIR, and in light of the upcoming Early Warning report for 2022, the priority actions are rolled over and a new one is added on the adoption of the waste management plans. ·Address the issues of closure and rehabilitation of illegal landfills and of the treatment of hazardous waste as matters of absolute priority. ·Properly enforce and increase landfill taxes to phase out landfilling of recyclable and recoverable waste. Channel those revenues towards measures that improve waste management in line with the waste hierarchy. ·Avoid building excessive infrastructure for the treatment of residual waste, e.g. mechanical biological treatment (MBT) facilities or incinerators. ·Improve and extend separate collection of waste, including for biowaste. Establish minimum service standards for separate collection (e.g. frequency of collections, types of containers, etc.) in municipalities to ensure high capture rates of recyclable waste. Use the available economic instruments, e.g. pay-as-you-throw and mandatory recycling targets for municipalities with penalties for non-compliance (e.g. fines). ·Improve the efficiency of the extended producer responsibility systems, in line with the general minimum requirements on EPR. ·Ensure regional waste management plans in line with the revised Waste Framework Diretive are in place.



2. Biodiversity and natural capital The 2030 EU biodiversity strategy adopted in May 2020 aims to put the EU’s biodiversity on a path to recovery and sets out new targets and governance mechanisms to achieve healthy and resilient ecosystems. In particular, the strategy sets out ambitious targets to: (i) protect a minimum of 30% of the EU’s land area and 30% of its sea area and integrate ecological corridors, as part of a true trans-European nature network; (ii) strictly protect at least a third of the EU’s protected areas, including all remaining EU primary and old-growth forests; (iii) effectively manage all protected areas, defining clear conservation objectives and measures, and monitoring them appropriately. The strategy also sets out an EU nature restoration plan – a series of concrete commitments and actions to restore degraded ecosystems across the EU by 2030, and manage them sustainably, addressing the key drivers of biodiversity loss. The Birds and Habitats Directives, which are reinforced by the Nature Restoration Law, are key legal tools to deliver on the strategy’s targets. They are the cornerstone of EU legislation aimed at conserving the EU's wildlife Greece adopted its first national biodiversity strategy and action plan in 2014. It aims to halt biodiversity loss and the degradation of ecosystem services by 2026. Nature protection and restoration Natura 2000, the largest coordinated network of protected areas in the world, is the key instrument to achieve the objectives of the Birds and Habitats Directives. These objectives are: (i) to ensure the long-term protection, conservation and survival of Europe’s most valuable and threatened species; and (ii) to maintain or restore the favourable conservation status of these species and habitats. Key milestones towards meeting the objectives of the Birds and Habitats Directives are: (i) the setting up of a coherent Natura 2000 network; (ii) the designation of sites of community importance (SCIs) as SAC , and (iii) the setting of site-specific conservation objectives and measures for all Natura 2000 sites. Setting up a coherent network of Natura 2000 sites

Greece hosts 89 habitat types and 296 species covered by the Habitats Directive. The country also hosts populations of 160 bird species listed in the Birds Directive’s Annex I . Greece has designated 446 Natura 2000 sites, including 265 SCIs under the Habitats Directive and 207 Special Protection Areas (SPAs) under the Birds Directive. By 2021, 27.3% of Greece’s land area was covered by Natura 2000 (EU coverage 18.5%), with SPAs classified under the Birds Directive covering 21% (EU coverage 12.8%) and SCIs under the Habitats Directive covering 16.6% (EU coverage 14.2%) of the Greek territory. According to the latest assessment of the SCI part of the Natura 2000 network, Greece’s Natura 2000 network is now considered to be complete. Today the Natura 2000 network covers 19.6% of the total sea area of the country. Considering both Natura 2000 and other nationally designated protected areas, Greece legally protects 35.20% of its terrestrial areas (EU 27 coverage 26%) and 4.62% of its marine areas (EU 27 coverage 12%). Figure 6: Marine & terrestrial protected area coverage, 2021







Figure 7: Natura 2000 terrestrial protected area coverage, 2021 Designating Special Areas of Conservation (SACs) and setting conservation objectives and measures The 6-year deadline set by the Habitats Directive to establish appropriate conservation objectives and measures has expired for 239 sites in Greece. Moreover, site-specific conservation objectives and conservation measures have not been established due to insufficient primary data. Furthermore, until 2020 Greece has defined management plans for only three SCIs, whereas for some areas presidential decrees or Joint Ministerial Decisions have been issued which define permitted and forbidden activities. For these reasons, the Commission had decided to bring the infringement procedure opened on this matter before the Court of Justice of the EU. In April 2021, Greece adopted national conservation objectives for those habitats and species for which data were available. But it still has to set out the necessary site-specific conservation objectives and measures for the already designated sites. Progress in maintaining or restoring favourable conservation status of species and habitats To measure the performance of Member States, Article 17 of the Habitats Directive and Article 12 of the Birds Directive require reporting on the progress made towards maintaining or restoring the favourable conservation status of species and habitats.According to the report submitted by Greece on the conservation status of habitats and species covered by Article 17 of the Habitats Directive for 2013-2018, 48.31% of habitats were in good conservation status in 2018, down from 61.36% in the previous reporting period (2007-2012). On protected species, 35.02% were in good conservation status in 2018, indicating a slight improvement compared to the 33.33% reported for 2007-2012. On birds, 77% of breeding species showed short-term increasing or stable population trends (for wintering species this figure was 50%). At the same time, the share of habitats in bad conservation status increased to 5.62% and the share of assessments for species in bad conservation status remained stable at 12.46%. The main pressures both for species and habitats are development, construction and use of residential, commercial, industrial and recreational infrastructure and areas and agriculture.

Figure 8: Assessments on conservation status for habitats for 2007-2012 and 2013-2018 Figure 9: Assessments on conservation status for species for 2007-2012 and 2013-2018 reporting periods There seems to be a general lack of progress in maintaining or restoring the favourable conservation status of species and habitats protected under the nature directives. A major challenge to protect and manage Natura 2000 sites effectively is to set up a national system for the comprehensive management, administration and functioning of protected areas (including strategy, structure, management schemes, responsibilities, financing, enforcement and monitoring). In particular, Greece has to execute the CJEU ruling of December 2020 in case C-849/19 by adopting all the necessary measures for establishing appropriate conservation objectives and conservation measures for all SCIs that are on its territory. The currently ongoing process is significantly delayed. However, the recent law, adopted in May 2020, aims at remedying the situation by putting in place management bodies for all Natura 2000 sites and by establishing a central organisation (Natural Environment & Climate Change Agency). This new governance system is yet to be put in place and become fully operational. Major obstacles to achieving the objectives of the Nature Directives include: (i) the lack of awareness (among authorities, stakeholders and the public) about Natura 2000 and its benefits; (ii) a lack of incentive to invest in promoting these benefits; (iii) insufficient scope for supporting sustainable land management and integrating it into other policies; and (iv) difficulties with enforcing the law. Due to these shortcomings, many complaints and infringement cases are pending on issues such as: (i) the degradation of designated sites (e.g. case C-517/11 on lake Koroneia pollution) ; (ii) the poor quality of ‘appropriate assessments’ under Article 6(3) of the Habitats Directive as well as the lack of strategic assessments (e.g. on windfarm planning and subsequent authorisation of projects); and (iii) insufficient protection of species and habitats including against illegal activities (e.g. concerning the caretta caretta species in Kyparissia ). Bringing nature back to agricultural land and restoring soil ecosystems Agricultural land The biodiversity strategy works alongside the new farm to fork strategy and the new common agricultural policy (CAP) to support and achieve the transition to fully sustainable agriculture. The biodiversity and farm to fork strategies have set four important targets for 2030: - a 50% reduction in the overall use of – and risk from – chemical pesticides; - a 50% reduction in the use of more hazardous pesticides; - a 50% reduction in losses of nutrients from fertilisers while ensuring there is no deterioration of soil fertility (which will result in 20% the reduction in the use of fertilisers); - bring back at least 10% of agricultural area under high-diversity landscape features and increase areas under organic farming to at least 25%. As shown in the Figure 10 below, with an estimated 10.15% of its area under organic farming, Greece stands above the EU average of 9.07% (2020 data, Eurostat) , showing a good potential for growth towards the EU-level Green Deal target of 25% of agricultural land by 2030. Figure 10: Share of total utilised agricultural area

According to the Commission’s recommendations on Greece’s CAP strategic plan, total ammonia emissions in Greece have been steadily decreasing since 2013, in contrast with the rest of the EU. 91% of the ammonia emissions in 2018 came from agricultural sources. The steady increase in permanent grassland surfaces (from 16% of total agricultural area in 2010 to 39% in 2017) contributs positively to the overall GHG emissions trend. In contrast, soil quality is an issue in Greece. The share of agricultural area at risk of soil erosion stands at 10.2%, above the EU average of 6.6%, and is much higher than in the north-west and the south. Wind erosion is also an issue in the Aegean islands. Specific Mediterranean characteristics mainly contribute to increased risk of soil erosion, with rainfall patterns and drought leading to loss of soil organic matter while sloping land, especially for pasture, increases the risk of soil erosion. The type of cultivated crops and other management practices such as reduced tillage, cover crops and agroforestry can help to protect the soil. Water quality and quantity are one of the biggest challenges for Greek agriculture. Irrigated areas represented 24% of the total utilized agricultural area in Greece in 2016. Pressures stemming from agricultural practices affect the majority of relevant habitat types, but mostly water ecosystems, and are associated with agricultural runoff, drainage, change of land use and of natural succession, pumping of groundwater, surface water and mixed water. Though in recent years there is a slight upsurge in traditional farming, the overall tendency of intensive and large-scale monocrop agriculture puts significant pressure on natural resources, namely water (scarcity and pollution) and soil (erosion, low soil organic carbon and pollution). It also has negative impacts on the landscape and leads to habitat fragmentation. With 10% of area under organic farming in 2019, Greece is above the EU-27 average, showing a good potential for growth towards the EU level Green Deal target of 25% of agricultural land by 2030. Soil ecosystem Soil is a finite and extremely fragile resource. It is increasingly degrading in the EU. The new EU soil strategy, adopted on 17 November 2021, stresses the importance of soil protection, of sustainable soil management and of restoring degraded soils to achieve the Green Deal objectives as well as and land degradation neutrality by 2030. This entails: (i) preventing further soil degradation; (ii) making sustainable soil management the new normal; (ii) taking action for ecosystem restoration. One factor in the degradation of soil ecosystems is the area of soil that is sealed or artificialised. In Greece (Figure 11) the land taken per year in 2012-2018 can be seen as a measure of one significant pressure on nature and biodiversity – land-use change. At the same time, land-use change constitutes an environmental pressure on people living in urbanised areas. Greece ranks just above the EU average on net land take (83,9 m2/km2 vs 83,8 m2/km2). In 2018, Greece updated its reporting on land degradation according to the latest PRAIS3 reporting platform with actions intended to achieve the degradation identified. Figure 11: Land take and re-cultivation in EU27 (m2/km2), 2012-2018 However, Greece has not yet committed to setting land degradation neutrality targets under UNCCD.

As stated in the 2019 EIR, soil organic matter plays an important role in the carbon cycle and in climate change. Soils are the second largest carbon sink in the world after the oceans. Forests and timber The EU forest strategy for 2030 adopted in July 2021 is part of the ‘Fit for 55’ Package. The strategy promotes the many services that forests provide. Its key objective is to ensure healthy, diverse and resilient EU forests that contribute significantly to the strengthened biodiversity and climate ambitions. Forests are important carbon sinks and conserving them is vital if the EU is to achieve climate neutrality by 2050. Out of the 27% of EU forest area protected under the Habitats Directive, less than 15% of assessments show a favourable conservation status. Bad conservation status increased from 27% to 31% in the EU compared to 2015. Forests cover 28.53% of Greece’s territory and more than 30% of the assessments of EU-protected forest habitats reveal a bad to poor status, of which 60% shows an improving trend and the remaining 40% a constant trend. Figure 12: Conservation status of forests protected under the Habitats Directive in EU Member States, 2013-2018 (% assessments) The European Union Timber Regulation (EUTR) prohibits the placing on the EU market of illegally harvested timber. In accordance with the EUTR, EU Member States’ competent authorities must conduct regular checks on operators and traders, and apply penalties for non-compliance. With the amendment of Article 20 of the EUTR, reporting every 2 years has been changed to annual reporting, and covers the calendar year as of 2019. Between March 2017 and February 2019, Greece carried out 488 checks on domestic timber operators. It also carried out 132 checks on operators importing timber. It is estimated that Greece had 1 600 operators placing domestic and 1 228 operators placing imported timber types onto the internal market over the reporting period. The new Deforestation Regulation will repeal and replace the EUTR, as it will essentially integrate and improve the existing system to check the legality of timber. Invasive alien species (IAS) IAS are a key cause of biodiversity loss in the EU (alongside changes in land and sea use, overexploitation, climate change and pollution). Besides inflicting major damage on nature and the economy, many invasive alien species also facilitate the outbreak and spread of infectious diseases, posing a threat to humans and wildlife. The implementation of the EU Invasive Alien Species Regulation and other relevant legislation must be stepped up. The biodiversity strategy for 2030 aims to manage established invasive alien species and decrease the number of ‘red list’ species they threaten by 50%. The core of Regulation (EU) 1143/2014 on Invasive Alien Species (the IAS Regulation) is the list of invasive alien species of Union concern. The total number of IAS of Union concern is currently 66, of which: 30 are animal species;36 are plant species; 41 are primarily terrestrial species; 23 are primarily freshwater species; 1 is a brackish-water species; and 1 is a marine species. According to a 2021 report on the review of the application of the IAS Regulation, its implementation is already starting to deliver on its objectives, such as a coherent framework for addressing IAS at EU level and increased awareness of the problem of invasive alien species. At the same time, the above report identified some challenges and areas for improvement. Given that the deadlines for implementing the various obligations of the IAS Regulation applied gradually between July 2016 and July 2019, it is premature to draw conclusions on several aspects of the implementation of the IAS Regulation. According to a 2021 report on the baseline distribution, of the 66 species on the list, 7 have been observed Greece. (See Figure 13.) Figure 13: Number of IAS of EU concern, based on available georeferenced information for Greece, 2021

An infringement case has been launched against Greece as the country: ·failed to establish and implement a single action plan or set of action plans fulfilling the requirements specified in Article 13 of the IAS Regulation by 13 July 2019 and to submit it/them to the Commission without delay; ·failed to set up a surveillance system of IAS of Union concern, or include it in their existing system, monitoring or other procedures to prevent the spread of IAS into or within the EU by 13 January 2018 as required by Article 14(1) of the Regulation; ·failed to fulfil its Article 15(1) obligation to put in place fully functioning structures to carry out the official controls necessary to prevent the intentional introduction into the EU of IAS of Union concern. 2022 priority actions ·Define clear site specific conservation objectives for all Natura 2000 sites and put in place necessary conservation measures. ·Complete and implement the management plans and legal tools for all the sites. Ensure that all established management bodies operate effectively, with clear responsibilities and sufficient financial and human resources. ·Better integrate biodiversity concerns into other policies and promote better communication between actors. ·Increase the capacity of competent authorities (central, regional, site management bodies) to: (i) apply conservation measures that increase awareness about Natura 2000 and its benefits; (ii) raise awareness about the economic benefits of healthy ecosystems and offer incentives to invest in them; and (iii) improve enforcement to tackle illegal activities that harm wildlife, both within and outside Natura 2000 areas. ·Fill in the gaps in the monitoring system of the conservation status of protected habitats and species. ·Improve the quality of appropriate assessments at plan and project level and ensure that their environmental impact is adequately monitored. ·Step up action on implementing the recommendations set out in the Greek CAP Strategic Plan. ·Step up implementation action on the EU Invasive Alien Species Regulation. Marine ecosystems The EU biodiversity strategy for 2030 calls on Member States to better integrate biodiversity considerations into public and business decision making at all levels and to develop natural capital accounting. The EU needs a better performing biodiversity observation network and more consistent reporting on the condition of ecosystems . The Marine Strategy Framework Directive (MSFD) requires Member States to achieve good environmental status (GES) of their marine waters. To that end, Member States must draw up marine strategies for their marine waters, and cooperate with Member States sharing the same marine region or subregion. These marine strategies comprise different steps to be developed and implemented over six-year cycles. The MSFD also requires Member States by 15 October 2018 to draw up a set of GES characteristics for each descriptor (Article 9), and to provide an initial assessment of their marine waters (Article 8). The Commission then assesses whether this constitutes an appropriate framework to meet the requirements of the Directive.

The MSFD also requires that Member States assess the current environmental status of their marine waters against the defined GES characteristics. A good or very good score indicates that a Member State has good capabilities to assess their marine environment in accordance with the requirements set out in the Commission’s GES decision. Greece has not reported data on the state of the environment, definitions of GES or environmental targets. Currently, Greece has signed but not yet ratified: ·the offshore protocol to the Barcelona Convention; ·the protocol on Specially Protected Areas and biological diversity in the Mediterranean; ·the protocol on integrated coastal zone management; Moreover, Greece has neither signed nor ratified the International Convention for the Regulation of Whaling. As highlighted in the Commission’s report on the implementation of the MSFD, while regional cooperation has improved since the adoption of the MSFD, more cooperation is needed to attain full regional coherence of the marine strategies, as required by the Directive. In the EIR 2019, the Commission suggested that Greece should ensure timely reporting of the different elements under the Marine Strategy Framework Directive so that Greece can be part of future Commission assessments. However, Greece has shown no progress in this respect. Furthermore, in March 2022, the European Commission published a Communication with recommendations for Member States. The Commission assessment highlights that Member States need to step up their efforts to determine the good environmental status and the use of the criteria and methodological standards according to the Commission GES Decision. The above considerations form the basis for the 2022 priority actions. 2022 prority actions ·Report data on the state of the environment, determinations of GES and environmental targets. ·Ensure regional cooperation with Member States sharing the same marine (sub) region to address predominant pressures. ·Sign and ratify the International Convention for the Regulation of Whaling (1946). Ratify the offshore protocol to the Barcelona Convention; the protocol concerning Specially Protected Areas and biological diversity in the Mediterranean; the protocol on integrated coastal zone management. Ecosystem assessment and accounting The EU biodiversity strategy for 2030 calls on Member States to better integrate biodiversity considerations into public and business decision making at all levels and to develop natural capital accounting. The EU needs a better performing biodiversity observation network and more consistent reporting on the condition of ecosystems. Ecosystem assessment developments in Greece mainly occur under the LIFE-IP 4Natura project (2017-2025). A key deliverable is the Technical-methodological guide on the determination and assessment of ecosystem types in Greece and their national, regional and localecosystem services. The first glossary in Greek for MAES related studies was produced in 2018. MAES field surveys were also carried out for the national assessment using an agreed field protocol for assessing ecosystem condition and services. The project’s key deliverables, produced in 2020, were a map of Greece’s ecosystem services’ priority areas and a map of ecosystem types outside Natura 2000 SACs. Presentations were given in several regions level to raise awareness about ecosystem services and their relevance for policy support and decision making. Greece has provided updated information and significant progress has been recorded since January 2016 (Figure 14). This assessment is based on 27 implementation questions and updated every 6 months. Figure 14:. January - ch

Progress on ecosystem accounting implementation is assessed at national level based on 13 questions (see Figure 15).

Figure 15: Ecosystem accounting Barometer, September 2021 Ecosystem accounting in Greece is currently in its infancy. However, the policy relevance is clear. Up to now, no accounts have been finalised in Greece. However, a national ecosystem extent account, an ecosystem monetary asset account and a thematic biodiversity account, all for woodland and forest, are being developed and are expected to be published soon. On accounts for ecosystem services, a methodological framework is being designed for physical as well as for monetary accounting of water-related ecosystem services (i.e. water regulation). The data needed for setting up natural capital accounting in Greece is scarce and unavailable. Methodologies have been developed to gather missing information and to start to develop accounts on ecosystems, ecosystem services and biodiversity. The main obstacles for the SEEA EEA implementation in Greece are the lack of capacity and expertise of the involved stakeholders and state agencies, along with data gaps. Knowledge sharing among MAIA partners should address these shortcomings and provide guidance via each country’s pilot accounts. 2022 priority actions ·Continue supporting the mapping and assessment of ecosystems and their services, and ecosystem accounting development, through appropriate indicators for integrating ecosystem extent, condition and services (including some monetary values) into national accounts; continue supporting the development of national business and biodiversity platforms, including natural capital accounting systems to monitor and value the impact of business on biodiversity. ·Implement the Commission’s recommendations regarding the preparation of the marine strategies, encompasing: the assessment, the determination of good environmental status and the establishment of environmental targets.



3. Zero pollution Clean air EU clean air policies and legislation need to significantly improve air quality in the EU, moving the EU closer to the quality recommended by the WHO and curbing emissions of key air pollutants. Air pollution and its impacts on ecosystems and biodiversity should be further reduced with the long-term aim of not exceeding critical loads and levels. This requires strengthening efforts to reach full compliance with EU clean air legislation and defining strategic targets and actions for 2030 and beyond. The 2030 zero pollution action plan targets are to reduce the health impacts of air pollution by 55% and to reduce the EU ecosystems threatened by air pollution by 25%. The EU has developed a comprehensive body of air quality legislation42, which sets health-based air quality standards and emission reduction commitments by Member State for a number of air pollutants. However, air quality in Greece continues to be a serious concern. The latest available annual estimates (for 2019) by the European Environment Agency point to about 10 400 premature deaths (or 107 300 years of life lost (YLL)) attributable to fine particulate matter concentrations , 650 (6 900 YLL) to ozone concentrations and 2 310 (23.900 YLL) to nitrogen dioxide concentrations .

The emissions of several air pollutants have decreased significantly in Greece over the last years, while GDP growth continued (see graph). According to the latest projections as submitted under Article 10(2) of the National Emission reduction Commitments Directive (NECD) Greece expects to fulfill the emission reduction commitments for all air pollutants covered by the directive for 2020- 2029 and for 2030 onwards. Latest inventory data submitted by Greece, prior to review by the Commission, indicate that Greece is in compliance with the emission reduction commitments for all pollutants in 2020. Greece submitted its national air pollution control programme on 29 January 2021. Figure 16: Emission trends of main pollutants/ GDP in Greece, 2005-2019 Figure 17: PM2.5 and NOx emissions by sector in Greece, 2019 For 2020, exceedances above the EU air quality standards were registered for nitrogen dioxide (NO2) in one air quality zone and for particulate matter (PM10) in two zones. Furthermore, in several air quality zones the target values on ozone concentration are not being met. Greece has not yet ratified the amended Gothenburg Protocol, the Heavy Metals Protocol and the POPs Protocol under the UNECE Air Convention. Persistent breaches of air quality requirements, which have severe negative effects on health and the environment, are being followed up by the European Commission through infringement procedures (mainly over PM10 and NO2 exceedances) for all Member States concerned, including Greece. The European Commission has referred Greece to the Court of Justice of the EU for poor air quality due to the persisting exceedances of PM10 limit values in the agglomeration of Thessaloniki and NO2 limit values in the agglomeration of Athens (cases C-70/21 and C-633/21 respectively). The aim of these legal actions is that Greece adopts and puts in place appropriate measures in all air quality zones so that they comply with the EU limit values. In the 2019 EIR, Greece received five priority actions. The first - to take specific action under the national air pollution control programme (NAPCP) – has only seen limited progress, so it is repeated in this EIR. On the second priority action to upgrade and improve air quality monitoring and ensure timely reporting, Greece made some progress with the NAPCP being adopted. On the third and fourth - toreduce nitrogen oxides and particulate matter, including through planning, fiscal and energy choices, some progress was made, but WHO and EU standards still need to be complied with. There was some progress on the fifth and final one -to build on the ‘Coal Regions in Transition’ initiative to reduce the use of coal for domestic heating to limit air pollutant emissions, in the form of government commitments and the adoption of Greece’s Just Transition plan. Greece also received a general priority action in 2019 to sign and ratify outstanding international agreements. 2022 priority actions ·Take, in the context of the National Air Pollution Control Programme (NAPCP), actions towards reducing emissions from the main sources mentioned above. ·Ensure full compliance with the EU air quality standards and maintain downward emissions trends of air pollutants, to reduce adverse air pollution impacts on health and economy with a view to reaching WHO guideline values in the future. ·Greece is strongly encouraged to accelerate the ratification of the amended Gothenburg Protocol, Heavy Metals Protocol and POPs Protocol under the UNECE Air Convention. Industrial emissions The main objectives of EU policy on industrial emissions are to: (i) protect air, water and soil;

(ii) prevent and manage waste; (iii) improve energy and resource efficiency; (iv) clean up contaminated sites. To achieve this, the EU takes an integrated approach to the prevention and control of routine and accidental industrial emissions. The cornerstone of the policy is the Industrial Emissions Directive (IED). As announced in the European Green Deal, the Commission carried out an impact assessment for the revision of the IED in 2021 with a view to tabling a proposal in early 2022 . The revision seeks to improve the directive’s contribution to the zero pollution objective, as well as its consistency with climate, energy and circular economy policies. The below overview of industrial activities regulated by the IED is based on data reported to the EU Registry (2018) . In Greece, around 340 industrial installations are required to have a permit based on the IED. The distribution of installations is shown in the figure below. The industrial sectors in Greece with most IED installations in 2018 were the waste management sector, including landfills (29%), followed by intensive rearing of poultry and pigs (16%), the energy sector (12%) and the food and drink sector (10%). Figure 18: Number of IED industrial installations per sector in Greece, 2018 The industrial sectors known to be the most harmful to the environment in Greece in terms of air emissions are: (i) the energy sector for arsenic (As), cadmium (Cd), chromium (Cr), copper (Cu), mercury (Hg), sulfur oxides (SOx), nitrogen oxides (NOx), nickel (Ni), lead (Pb), zinc (Zn), and particulate matter (PM2.5); (ii) the production and processing of metals (in particular iron and steel) for Cu and dioxins; (iii) intensive rearing of poultry or pigs for ammonia (NH3); and (iv) surface treatment and the foοd, drink and milk sectors for non-methane volatile organic compounds (NMVOCs). See the breakdown in the graph below. Figure 19: Emissions to air from IED sectors and rest of national total air emissions in Greece, 2018 In 2017, one power station in Greece (located in Agios Dimitrios) was among the top 30 E-PRTR facilities with the highest absolute damage costs from emissions of the main air pollutants and greenhouse gases . The environmental burdens caused by industrial emissions to water is mainly from the energy sector for total nitrogen and heavy metals, and from refineries for total organic carbon (TOC). The breakdown, based on E-PRTR data, is presented in the figure below. Figure 20: Relative releases to water from industry in Greece, 2018

The EU approach to enforcement under the IED creates strong rights for the public to have access to relevant information and to participate in the permitting process for potentially polluting installations. This empowers the public and NGOs to ensure that permits are complied with. As part of environmental inspection, competent authorities undertake site visits at IED installations to take samples and to gather necessary information. According to Article 23(4) of the IED, site visits must be carried out between once a year and once every 3 years, depending on the environmental risks posed by the installations. In 2018, Greece made 47 site visits, mostly to the waste management sector, including landfills (26%), followed by installations for the energy sector (19%), the mineral sector (17%) and the food and drink sector (11%). Figure 21: Number of inspections in IED installations in Greece in 2018 The development of best-available-technique (BAT) reference documents (BREFs) and BAT conclusions ensures good collaboration between stakeholders and enables better implementation of the IED. Since the last EIR report, the Commission adopted BAT conclusions for Belgium for: (i) waste incineration; (ii) the food, drink and milk industries; and (iii) surface treatment using organic solvents including the preservation of wood and wood-products with chemicals. The Commission relies on the efforts of national competent authorities to implement the legally binding BAT conclusions and associated BAT emission levels in environmental permits. This should result in considerable and continuous reduction of pollution. In 2019, Greece received priority actions to review permits and to strengthen control and enforcement, in line with BAT conclusions. Greece reported on the action taken in this respect via the EU Registry, and the Commission is following up by checking that the information provided by Greece on the permits granted for each installation is in line with the IED. Another priority action for Greece was to address pollution in power sector installations, especially in the Agios Dimitrios, Kardia and Amindeo lignite power plants. In addition, an infringement case is ongoing on authorisations granted to large combustion plants. 2022 priority action ·Continue addressing pollution in energy sector, especially in the Agios Dimitrios coal power plant. Prevention of major industrial accidents – SEVESO The main objectives of EU policy on the prevention of major industrial accidents are to (i) control major accident hazards involving dangerous substances, especially chemicals; (ii) limit the consequences of such accidents for human health and the environment; (iii) continuously improve prevention, preparedness and response to major accidents. The cornerstone of the policy is Directive 2012/18/EU (the Seveso-III Directive) . The below overview of industrial plants regulated by the Seveso-III Directive, (‘Seveso establishments’), is based on data reported to the eSPIRS database (2018) and Greece’s report on the implementation of the Seveso-III Directive for the period 2015-2018 . Of the 210 Seveso establishments in Greece, 134 are categorised as lower-tier establishments (LTE) and 76 as upper-tier establishments (UTE) – based on the quantity of hazardous substances likely to be present. The UTE are subject to more stringent requirements. The number of Seveso establishments for various years is presented in Figure 22. Figure 22: Number of Seveso establishments in Greece, 2011, 2014 and 2018

According to the Greek authorities, an external emergency plan (EEP) is required for 76 UTE. In 2018, 62 UTE had an EEP. (See Figure 23.) Establishing EEPs is essential to properly prepare and implementthe necessary actions to protect the public and the environment in the case of a major industrial accident. Figure 23: Situation regarding EEP in Greece, 2018 The information to the public referred to in Annex V of the Seveso-III Directive – especially on how they will be warned in the case of a major accident ; the appropriate behaviour in the event of a major accident ; and the date of the last site visit – are permanently available for 70% of the Seveso establishments in Greece. This is important, as arming the public with information may reduce the consequences of a major industrial accident. Figure 24: Share of UTE for which information on safety measures and desired behaviours was made available to the public in Greece, 2011, 2014 and 2018 2022 priority action ·Strengthen control and enforcement to ensure compliance with Seveso-III Directive provisions, especially on information to the public and EEP. Noise The Environmental Noise Directive provides for a common approach to avoid, prevent and reduce the harmful effects of exposure to environmental noise although it does not set noise limits as such. Its main instruments in this respect are strategic noise mapping and planning. A key target under the 2030 zero pollution action plan is to reduce by 30% the share of people chronically disturbed by transport noise compared to 2017. Excessive noise from aircraft, railways and roads is one of the main causes of environmental health‐related issues in the EU. It can cause ischaemic heart disease, stroke, interrupted sleep, cognitive impairment and stress . In Greece, based on limited data, environmental noise is estimated to cause at least 100 premature deaths and 300 cases of ischaemic heart disease per year . In addition, some 45 000 people suffer from disturbed sleep. According to the latest full set of information that has been analysed, noise mapping of roads and agglomerations remains incomplete. Moreover, Greece still lacks action plans for 10 agglomerations and most roads. These plans, which will undergo a public consultation, should include measures to reduce noise. The two priority actions set out in the 2019 EIR are rolled over, as Greece’s progress has been limited, as detailed above. 2022 priority actions ·Complete noise mapping.

·Complete action plans for noise management in agglomerations and major roads. Water quality and management EU legislation and policy requires that the impact of pressures on transitional, coastal and fresh waters (including surface and ground waters) be significantly reduced. Achieving, maintaining or enhancing good status of water bodies as defined by the Water Framework Directive will ensure that EU citizens benefit from good quality and safe drinking and bathing water. It will further ensure that the nutrient cycle (nitrogen and phosphorus) is managed in a more sustainable and resource-efficient way. Water Framework Directive The Water Framework Directive (WFD) is the cornerstone of the EU water policy for the 21st century. The WFD and other water-related legislation set the framework for sustainable and integrated water management, which aims to ensure a high level of protection of water resources, prevention of further deterioration and restoration to good status. By March 2022, Member States have to report the third generation of river basin management plans (RBMPs) under the WFD. The Commission will assess the reported status and progress, checking how the findings identified in the assessment of the second RBMPs have been addressed. Greece has not yet reported the third RBMPs. The Commission’s 6th implementation report on the WFD, published in December 2021, assessed the progress of the implementation of the ‘programmes of measures’ and the monitoring of the new priority substances, among other developments. The progress report for Greece stated that most of the measures were planned to begin in the second half of the second cycle, and found that the level of actual implementation in the field is unknown. According to the 2nd RBMPs reporting and data published in 2020 , 63.8% of all surface water bodies in Greece are in a good ecological status (with 8.0% in an unknown status) and 88.6% are in a good chemical status (with 9.8% in an unknown status). For ground waters, 84.6% achieve good chemical status and 15.7% are in poor a quantitative status. The below figure shows the proportion of surface water bodies in the EU that failed to achieve good ecological status. Figure 25: Proportion of surface water bodies (rivers, lakes, transitional and coastal waters) in less than good ecological status per River Basin District The below figure shows the proportion of surface water bodies in the EU that failed to achieve a good chemical status. For Greece, the percentage is 1.6%, if one includes water bodies failing due to substances behaving as ubiquitous PBTs (persistent, bio-accumulative and toxic chemicals). Without PBTs, 1% of surface water bodies failed to achieve good chemical status (with 10% of unknown chemical status). Figure 26: Percentage of water bodies not achieving good chemical status Under the IED framework, it should be stressed that Greece showed a significant increase (236%) over the last decade in industrial releases of heavy metals like Cd, Hg, Ni, Pb and a decrease (55.4%) in Total Organic Carbon – TOC to water . The total water abstracted annually (corresponding to 2019 baseline) in Greece from surface and groundwater sources is 10,027. 80 hm3 (EEA, 2022). Water abstraction per sector is as follows: 80.47% for agriculture; 16.76% for public water supply; 0.97% for electricity cooling; and 1.80% for manufacturing (see the following figure). Greece uses a register to control water abstractions. Water use and water utilisation projects are subject to authorisation, while all relevant permits are registered in the National Register of Abstractions (NRA). These authorisations are reviewed, as appropriate, if an amendment is requested (change of name, use, quantity, etc.) and and in accordance with the Programme of Measures of the RBMPs. Review intervals can therefore exceed 6 years. As many permit applications are still pending, the NRA cannot provide accurate data on the number of water abstractions and on the amount of water abstracted. The increasing demand for water for multiple purposes and the intensification of severe weather conditions due to climate change have put significant strain on freshwater supplies in Greece. The registration of water abstraction is apositive step, as it also gathers information on inactive abstractions, abstractions in private networks and abstractions for the needs of forestry services in forested areas and areas designated for reforestation. Figure 27: Water abstraction per sector in Greece

According to the WEI+ , Greece’s level of water scarcity stands at 39.37%, just below the 40% threshold for ‘severe’ water scarcity. Figure 28 below shows how Greece compares to the EU average. Greece has the 2nd highest level of water scarcity in the EU. Figure 28 : Water exploitation index plus (WEI+) inside EU, 2017 Floods Directive As mentioned, the Commission published the 6th implementation report on the FD in December 2021, which included a review and update of the preliminary flood risk assessments during the second cycle (2016-2021). The assessment report identified the additional work on the change in rainfall intensity due to climate change as a good practice. Moreover, methodologies have been worked out for the revision of the APSFRs and for defining past floods with significant adverse impacts and potential adverse consequences of future floods. Explicit consideration of the effects of long-term developments (e.g. land use change), beyond climate change, should be added to these methodologies. Greece has not adopted and reported the second generation of flood risk management plans (FRMPs) under the Floods Directive. The European Commission will assess the progress made since the first plans were adopted and will publish a new report, as was done in 2019. Drinking Water Directive On the Drinking Water Directive , no new assessment of the quality of drinking water is available since the 2019 EIR. The quality of drinking water in Greece has not been highlighted as an area of concern. The recast Directive entered into force on 12 January 2021, and Member States have until 12 January 2023 to transpose it into their national legal system. Greece will have to comply with these reviewed quality standards. Bathing Water Directive On the Bathing Water Directive, Figure 29 shows that in 2020 97.1% of Greece’s 1 634 bathing waters were of excellent quality . Detailed information on Greeκ bathing waters is available on the national portal and on an interactive map developed by the European Environment Agency . Figure 29: Bathing water quality in Europe in the 2020 season

Figure 30: Greece, bathing water quality 2017-2020 Nitrates Directive

The Commission’s latest implementation report on the Nitrates Directive , covering 2016-2019 , warns that nitrates are still causing harmful pollution to EU water. Excessive nitrates in water are harmful to both human health and ecosystems, causing oxygen depletion and eutrophication. Where national authorities and farmers have cleaned up waters, it has had a positive impact on drinking water supply and biodiversity, as well as on sectors such as fisheries and tourism that depend on them. Nevertheless, excessive fertilisation remains a problem in many parts of the EU. Greece has a low livestock density and the surplus of nitrogen is in line with the EU average, while there is almost no surplus of phosphorus. It has a well-developed network of monitoring stations. The latest report includes data for year 2018-2019 only, missing 2016-2017. There are a number of hotspots, with a nitrate concentration above 50 mg/l. A high number of surface waters are eutrophic. Groundwater quality has been improved between the reporting periods 2012-2015 and 2016-2019, since the recorded levels of nitrates fell by 14.2% for average concentrations above the limit of 50 mg/l NO3 and by 7.5% above 40 mg/l NO3 (EEA, CDR, Nitrates Report 2020). A high number of groundwater monitoring stations with nitrate concentrations above 50 mg/l and of surface waters found to be eutrophic are located outside of nitrate vulnerable zones (NVZ). A revised action programme was published in 2019. Urban Waste Water Treatment Directive Greece has, over the years, encountered serious and structural difficulties in meeting its obligations under the Urban Waste Water Treatment Directive (UWWTD). Overall, 96% of urban waste water in Greece is treated according to the requirements of the UWWTD. This is above the EU average of 76% in 2018. On the amount of urban wastewater that needs to be collected according to the UWWTD, Greece has met its targets. However, further efforts are needed to provide biological treatment to an additional 3.8% and biological treatment with nitrogen and/or phosphorus removal to 0.6%. Greece reuses 2% of treated urban wastewater for irrigation in agriculture and for other uses. Figure 31: Proportion of urban waste water that meets all requirements of the UWWTD (collection, biological treatment, biological treatment with nitrogen and/or phosphorus removal) in compliant urban areas of the UWWTD (‘compliance rate’) Despite the steady improvement in compliance over the years, for which EU funding has been fundamental, the incomplete implementation of the UWWTD has already led to several Court of Justice rulings against Greece. Greece has had to pay heavy fines in two urban waste water cases (collection and treatment of wastewater in five agglomerations in Eastern Attica and in four agglomerations in Western Attica). To date, it has paid approximately EUR 67 million for these two cases. It has also been condemned by the Court in another case, for lack of adequate collection and treatment of wastewater in various small agglomerations. The 2019 EIR for Greece included three priority actions on water management. Considering that progress has been limited, the following actions are suggested. 2022 priority actions ·New physical modifications of water bodies should be assessed in line with Article 4(7) of the WFD. In these assessments alternative options and adequate mitigation measures should be considered. ·To adopt the 2nd FRMPs and 3rd RBMPs. ·Efforts should be done to improve the coordinated implementation between water, marine and nature policies. ·Verify the designation of NVZ, considering that not all the ground waters with nitrate concentrations above 50 mg/l and surface waters found to be eutrophic are included in the NVZ’s. Extend the monitoring data to include the four years of the reporting period and report the trends. ·Complete implementation of the Urban Waste Water Treatment Directive for all agglomerations, by building up the necessary infrastructure. Chemicals The EU seeks to ensure that chemicals are produced and used in a way that minimises any significant adverse effects on human health and the environment. In October 2020, the Commission published its chemicals strategy for sustainability - ‘Towards a Toxic-Free Environment’ which led to some systemic changes in EU chemicals legislation. It is part of the EU zero pollution ambition, which is a key commitment of the European Green Deal. The EU’s chemicals legislation1 provides baseline protection for human health and the environment. It also ensures stability and predictability for businesses operating within the internal market. Since 2007, the Commission has gathered information on the enforcement of the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (‘the REACH Regulation’) and the Regulation on Classification, Labelling and Packaging (‘CLP Regulation’).. In December 2020, the Commission assessed the Member States reports on the implementation and enforcement of these Regulations , in line with Article 117(1) of the REACH Regulation and Article 46(2) of the CLP Regulation. According to the latest available data, national enforcement structures have not changed much in recent years. However, it is apparent from this report that there are still many disparities in the REACH-CLP implementation and notably in the area of the law enforcement. The recorded compliance levels in Member States seem to be quite stable over time, but with a slight worsening trend, which is likely due to: (i) enforcement authorities being more effective in detecting non-compliant products/companies; and (ii) more non-compliant products being put on the EU market. In August 2021, the Commission published a quantitative assessment of the enforcement of the two main EU Regulations on chemicals (the REACH Regulation and the CLP Regulation) using a set of indicators on different aspects of enforcement.

Responsibility for checking compliance with REACH in Greece lies with the following authorities : ·Independent Authority for Public Revenue, Directorate-General ·General Chemical State Laboratory - GCSL (Directorate of Energy, Industrial and Chemical Products); and all the regional chemical services. Greece has fully implemented both the REACH and the CLP enforcement strategies , notably: ·An annual inspections plan; ·Prioritisation of enforcement based on results of previous controls, annual REF and pilot projects, new obligations or an extension of the obligations that already apply to new products, complaints and national target groups; ·Yearly reporting on enforcement activities. As a rule, all infringements of REACH are classed as ‘serious’ or ‘very serious’ environmental administrative offences. If the infringement is sufficiently serious, the competent authority may decide to impose further penalties in addition to a fine. That authority may also, where necessary, order the provisional seizure of assets and documents. In Greece, 70 staff members are allocated to REACH and CLP enforcement . Almost 2 000 REACH controls were carried out in the reporting period (2019). Most were proactive (inspections) rather than reactive/non-routine (i.e. investigations in response to complaints, accidents and referrals) . Figure 32: Percentage of non-compliance cases out of the total number of REACH and CLP controls during 2019 per Member State and compared to the EU average 2022 priority action ·Upgrade the implementation and enforcement administrative capacities towards a ‘zero tolerance’ to non-compliances.



4. Climate action In line with the Paris Agreement and as part of the European Green Deal, the European Climate Law sets the EU target of reaching climate neutrality by 2050 and reducing greenhouse gas (GHG) emissions by 55% by 2030 compared to 1990. The law also limits the contribution that carbon removals can make towards emission reductions in 2030, to ensure a sufficient mitigation effort.

The EU and its Member States submitted updated Nationally Determined Contribution (NDC) to the UNFCCC in December 2020. The EU is working across all sectors and policies to cut GHG emissions and make the transition to a climate neutral and sustainable economy, as well as addressing the unavoidable consequences of climate change. EU climate legislation incentivises emissions reductions from power generation, industry, transport, the maritime sector and fluorinated gases (F-gases) used in products. For road transport, EU legislation requires the GHG intensity of vehicle fuels to be cut by 6% by 2020 compared to 2010 and sets binding GHG emission standards for different vehicle categories. Under the F-gas Regulation, the EU’s F-gas emissions will be cut by two-thirds by 2030 compared with 2014 levels. From 2021 emissions and removals of GHG from LULUCF have been included in the EU emission reduction efforts. The EU adaptation policy is an integral part of the European Green Deal. From 2021, Member States are required to report on their national adaptation policies as the European Climate Law recognises adaptation as a key component of the long-term global response to climate change. Member States will be required to adopt national strategies and the EU will regularly assess progress as part of its overall governance on climate action. The updated EU adaptation strategy, published in February 2021, sets out how the EU can adapt to the unavoidable impacts of climate change and become climate resilient by 2050. Key national climate policies and strategies Greece has an integrated national energy and climate plan (NECP) for 2021-2030, which builds on other energy and climate plans and is consistent with the long-term strategy for 2050. The overall goal of the government’s strategy is the transition towards climate neutrality by 2050 in a sustainable, fair, and cost-efficient manner. Under its Recovery and Resilience Plan (RRP), Greece allocates 37.5 % of the budget to climate objectives and outlines crucial reforms and investments to further the transition to a more sustainable, low-carbon and climate-resilient economy. It covers a number of areas, including clean energy, building and renovating, sustainable mobility, resilient infrastructure and sustainable agriculture. Greece adopted its national adaptation strategy in 2016 The 13 Regional adaptation action plans have been drafted and are expected to be adopted by the regional councils in 2022. The EU-funded integrated project LIFE-IP AdaptInGR (2019-2026) supports the implementation of the strategy and action plans through activities to enhance climate data, build capacity, facilitate sectoral mainstreaming, improve monitoring and raise awareness ( www.adaptivegreece.gr ). Between 1990 and 2020, GHG emissions decreased by 28% in Greece. Figure 33: Total GHG emissions (incl. international aviation) in Greece, 1990-2020 Effort sharing target For emissions not covered by the EU’s emissions trading scheme (ETS), Member States have binding national targets under the Effort Sharing legislation. The country is estimated to largely overachieve its current 2030 target. Under EU legislation, Greece has a target to reduce GHG emissions in the non-ETS sectors (buildings, road and domestic maritime transport, agriculture, waste and small industries) by 4% by 2020 and 16% 2030, compared to 2005. The country’s non-ETS emissions in 2019 were much lower than its 2020 target. In its NECP, Greece intends to exceed its current non-ETS target for 2030 of -16%. Figure 34: Emissions and targets under the Effort Sharing Decision/ Effort Sharing Regulation in Greece, 2020 and 2030 as percentage change from 2005

Figure 35: Emissions, annual emission allocations (AEAs) and accumulated surplus/ deficit of AEAs under the Effort Sharing Decision in Greece, 2013-2020 Key sectoral developments In road transport, the GHG intensity of vehicle fuels in Greece decreased by 3.5% between 2010 and 2019. The country needs to act swiftly to meet the current EU-wide reduction target by 6%. There are several types of action that Member States can take in this regard, for example: (i) further expanding the use of electricity in road transport; (ii) supporting the use of biofuels, in particular advanced biofuels; (iii) incentivising the development and deployment of renewable fuels of non-biological origin; and (iv) reducing upstream emissions before refining processes. Road transport accounted for 17% of Greece’s total GHG emissions in 2019. Emissions have decreased by 20% compared to 2005. Figure 36: GHG emissions by sector in Greece – historical emissions 1990-2020, projections 2021-2030 To reduce emissions from buildings, Greece has set a target to renovate 3% of the total floor area of public buildings per year and to upgrade 40 000 homes per year by 2030 (equal to 12-15% of total housing stock by 2030). According to Greece’s long term renovation strategy, final energy demand in buildings will be reduced by 8% compared to 2015 levels through targeted policy measures. In the land use, land use change and forestry (LULUCF) sector, Greece projects a further decrease of net removals by 2030. Reported quantities under the Kyoto Protocol for the LULUCF sector in Greece show net removals of, on average, -2.0 Mt CO2-eq for 2013-2019. In this regard, Greece contributes with 0.6% to the annual average sink of -344.9 Mt CO2-eq of the EU-27. Accounting for the same period depicts net credits of, on average, -0.4 Mt CO2-eq, which corresponds to 0.4% of the EU-27 accounted sink of ‑115.0 Mt CO2-eq. Reported net removals are nearly unchanged over the 7-year period, but accounted net credits show a more accentuated pattern with an increase in 2018. Figure 37: Reported and accounted emissions and removals from LULUCF in Greece Use of revenues from the auctioning of EU ETS allowances. The total revenues from the auctioning of emission allowances under the EU ETS in 2012-2021 came to nearly EUR 3.4 billion. In Greece, revenues are earmarked and fully spent on domestic climate change and energy projects. 2022 priority actions ·Increase renewable energy. There is room for Greece to further exploit its renewable energy potential, resulting in a lower carbon intensity, resource diversification (including green hydrogen production). The Reliance on heavy-polluting lignite-fired power plants and natural gas remains an issue in Greece. ·Enhance sustainable transport ·Energy efficiency remains a key issue, with a modest level of ambition for final energy consumption and a low level of ambition for primary energy consumption.

Part II: Enabling framework: Implementation tools 5. Financing Environmental investment needs in the EU Financing environmental measures is essential for their success. Although most financing comes from national sources, various EU funds contribute significantly, helping to close the financing gaps. Post-2020, environmental measures will also be supported by the EU’s Covid-19 recovery fund (via the RRF) and the “do no significant harm” (DNSH) principle which runs across the EU budget. Tthe renewed commitments made at the COP 26 (Glasgow, Oct.-Nov. 2021) and the Biodiversity Convention (COP15, April-May 2022) will also be reflected in the EU budget. Overall environmental investment gaps (EU-27) The EU’s investment needs for the green transition cover a range of interlinked areas. The additional investment needs over the baselines (i.e. the gap between what is needed and what is forecast to be invested if no additional action is taken) for climate, energy and transport were estimated in 2021 at EUR 390 billion a year (EU27) with a further EUR 130 billion a year to deliver the EU’s core environmental objectives . Those investment needs reflect the implementation objectives to 2020 and to 2030 (except for climate adaptation, the costs of which are expected to last over a longer time horizon). A preliminary update of the EU’s core environmental investment gap is provided in Table 1 . Almost 40% of the environmental investment needs relate to dealing with pollution, which accounts for nearly two-thirds of the total gap if combined with water management. The investment gap in circular economy and waste is estimated to be between EUR 13-28 billion a year, depending on levels of circularity implemented. The annual biodiversity financing gap is estimated at around EUR 20 billion. Table 1: Estimated breakdown of the EU27’s environmental investment gaps, by environmental objective, 2021-2030 (per year) Environmental objective Estimated investment gap (EU-27, p.a.) EUR billion % Pollution prevention & control 42.8 39% Water management & industries 26.6 24% Circular economy & waste 13.0 12% Biodiversity & ecosystems 21.5 20% R & D & I and other 6.2 6% Total 110.1 100% Environmental investment needs in Greece Completing and improving waste and wastewater management infrastructure is considered the top priority for environmental investment in Greece. This is followed by investments to compy with the Nature Directives and to monitor and mitigate air pollution. Furthermore, the following environmental investment needs have been identified by sector: Pollution prevention & control The EU’s first Clean Air Outlook under the clean air programme estimated that the total air pollution control costs for Greece to reach the NECD emission reduction requirements by 2030 amount to EUR 1 338 million per year, including, EUR 926 million a year for capital investment (assuming the achievement the 2030 climate and energy targets). The second EU’s Clean Air Outlook suggests that the EU would largely achieve the reductions that correspond to the obligations under the NEC Directive for 2030 if: i) all relevant legislation adopted up to 2018 was implemented (including all air pollution targets and the 2030 climate and energy targets set in 2018); ii) and Member States also implemented the measures announced in their national air pollution control programmesThe only exception is for ammonia for 15 Member States , excluding Greece. Water management According to the OECD study ‘Financing a Water Secure Future’ (2022) , Greece relies mainly on conventional resources for its water supply (e.g. groundwater). A small fraction (2%) of its total drinking water supply comes from desalination. Projections shows that Greece could face among the highest potential health risks due to non-safe drinking water in the EU by 2050. Also, leakage within the distribution system is substantial. Freshwater shortage and sea level rise are the greatest climate change-related risks faced by the country. Major drought episodes are projected to become more frequent and severe, with particularly intense summer droughts. Greece faces challenges in financing future investment needs for water supply and sanitation as well as flood protection, particularly for areas where EU funding is not available . Up to 2030, the cumulative additional investment needed for Greece is estimated at EUR 1.7 billion (around 170 million per year) over baselines, of which around 90% relates to wastewater . Moreover, the recent (6th) Water Framework Directive- and Floods Directive Implementation Report and the financial - economic study accompanying it, are also a relevant source of information in this domain. Waste & circular economy According to a Commission study, to meet the recycling targets for municipal waste and packaging waste, Greece needs to invest an additional EUR 385 million (around EUR 55 million per year) in 2021-2027 on collection, biowaste treatment, recycling reprocessors, waste sorting facilities and waste registry digitalisation. Biowaste treatment facility replacement costs (EUR 9.4 million in 2021-2027 or EUR 1.3 million per year) are included in this amount, though it excludes the investment necessary for other key waste streams (plastics, textile, furniture) and to increase circularity and waste prevention across the economy.

Biodiversity & ecosystems The recently submitted prioritised action framework (PAF) for Greece shows that nature protection costs (including Natura 2000) in 2021-2027 amount to EUR 1 039.5 million. This represents an annual cost of about EUR 148.5 million, of which EUR 24.7 million are one-off costs . This excludes additional costs to implement the biodiversity strategy for 2030, including on increased protection and restoration. The main conservation priorities are to: (i) improve knowledge at national and local level on the conservation status of species and habitat types; (ii) improve the conservation status of species; (iii) address interactions and conflicts between wildlife and human activities; (iv) mitigate the effects of climate change on protected species, habitats and areeas; (v) create green infrastructure; (vi) conserve genetic resources; (vii) address the effects of invasive alien species with an emphasis on the marine environment and habitat species; and (viii) mitigate the effects of large infrastructure (e.g. wind farms, hydrocarbon extraction research, etc.) on Natura 2000 sites and on community species / habitat types of interest. EU environmental funding 2014-2020 The multiannual financial framework (MFF) for 2014-2020 allocated almost EUR 960 billion (in commitments, 2011 prices) for the EU to spend over this period. The commitment in this 2014-2020 MFF included a 20% climate spending target and funding opportunities for the wider environment, in particular, under the European Structural and Investment (ESI) Funds . The 2014-2020 MFF budget was subsequently topped up with over EUR 50 billion (in current prices) from the REACT-EU programme for cohesion policy action against COVID-19 . Greece received EUR 23.1 billion from the ESI Funds over 2014-2020 to invest in job creation and a sustainable and healthy European economy and environment. The planned direct environmental investment amounted to EUR 3.3 billion with a further EUR 896.4 million identified as indirect environmental investment value, totalling to EUR 4.2 billion. Figure 39 shows an overview of (planned) individual ESI Funds earmarked for Greece (EU amounts, without national amounts). Figure 38: ESI Funds allocated to Greece, including environmental investments, 2014-2020 Table 2: Direct and indirect environmental investments under the ESI Funds in Greece, 2014-2020 Instrument Allocations for the environment (EUR million) Under Cohesion policy (ERDF + CF) Direct environmental investments water waste air quality biodiversity and nature land rehabilitation climate and risk management Indirect environmental investments renewable energy energy efficiency other energy sustainable transport sustainable tourism business development, R&I 3 306.7 2 426.8 1 159.7 763.5 39.9 85.7 17.6 360.3 879.9 43.1 220.6 33.0 517.0 47.3 19.0 Under EAFRD/rural development Direct environmental investments water climate and risk management Indirect environmental investments renewable energy energy efficiency 744.5 729.8 505.8 224.1 14.7 10.7 4.0 Under EMFF Direct environmental investments environment protection & resource efficiency Indirect environmental investments business development, R&I 133.1 131.3 131.3 1.8 1.8 Under ESI Funds total Direct environmental investments Indirect environmental investments 4 184.4 3 288.0 896.4 Funding for the environment from the ESI Funds has also been supplemented by other EU funding programmes and financing available to all Member States, such as, the LIFE programme, Horizon 2020 and financing from the European Investment Bank (EIB), that add up to an estimated total environmental financing of EUR 4.7 billion for Greece in 2014-2020. The LIFE programme is dedicated to environmental and climate objectives, financing the demonstration and roll-out of green solutions. In 2014-2020 , Greece received EU support for 26 LIFE projects (for nature and environment) for an amount of EUR 53.6 million (out of 1 028 EU27 LIFE projects with the total EU contribution of EUR 1.74 billion) . In 2014-2020, Horizon 2020 allocated about EUR 74.3 million toGreece (notably, for circular economy, climate action, earth observation, water, and natural resources and ecosystems projects) about 4.4% of Greece’s total allocation . From the European Fund for Strategic Investments (EFSI), none of Greece’s total allocation (EUR 1.8 billion) was spent on environmental projects. Greece received EUR 343.2 million from EIB for direct environmental investments, specifically, for water and sewerage and waste, out of the total EIB loans for Greece (EUR 12.7 billion) . The country ranks 7th in the EU in terms of total EIB lending. In 2020, the EIB provided EUR 24.2 billion in funding across Europe to fight climate change at EU level (corresponding to 37% of its total financing) and EUR 1.8 billion for the environment (representing 3% of its financing) . EU environmental funding 2021-2027 The 2020 European Green Deal investment plan calls for EUR 1 trillion in green investments (public and private) to be made across the EU by 2030. The 2021-2027 MFF and the NextGenerationEU (NGEU) spending programme will mobilise EUR 2 018 trillion (in current prices) to support the recovery from COVID-19 and the EU's long-term priorities, including environmental protection. Following the EU Green Deal’s pledge to ‘do no harm’ pledge and the Interinstitutional Agreement on the 2021-2027 MFF , 30% of the EU budget in 2021-2027 will support climate efforts, while biodiversity will receive 7.5% as of 2024 and 10% as of 2026 of the MFF, that requires increased programming of financial resources for biodiversity, specifically under the 2021-2027 Cohesion policy and the 2023-2027 CAP to reach those targets. Sustainable finance significantly increases transparency on environmental sustainability (a goal promoted by the EU Taxonomy) . It also strengthens non-financial reporting requirements and facilitates the issuance of green bonds (by developing the EU Green Bond Standard ). Reinforced by the renewed sustainable finance strategy (2020) , sustainable finance will increase investment flows to climate and the environment. The new strategy on adaptation to climate change can help close the insurance protection gap, which currently leaves many risks from climate-related events uninsured . The EIB will align 50% of its lending for climate and environmental objectives by 2025 with an EUR 250 billion contribution to the Green Deal investment plan by 2027. Table 3 gives an overview of the EU funds earmarkedfor Greece for 2021-2027 . These funds are supplemented by other EU funding programmes available to all Member States.

Table 3: Key EU funds allocated to Greece (current prices), 2021-2027 Instrument Country funding allocation (Million EUR) Cohesion policy ERDF CF ESF+ ETC (ERDF) Total: 20 448.2 11 451.7 3 023.4 5 844.8 128.3 Just Transition Fund 830.2 EAFRD/rural development under CAP Strategic Plans 2023-2027 2 784.8 European Maritime, Fisheries and Aquaculture Fund (EMFAF) 375.0 Recovery and Resilience Facility (RRF) 2021 – 2026 17 769.9 (grants) 12 727.5 (loans) In Greece, the programming for most EU funds (cohesion policy funds, EAFRD and EMFAF) is ongoing. However, negotiations have been concluded under the RRF. Greece’s RRP sets out measures for a strong recovery and preparing Greece for the future. The reforms and investments outlined in the plan will help Greece become more sustainable, resilient and better prepared for the challenges and opportunities of the green and digital transitions. To this end, the RRP sets out 106 investment measures and 68 reforms, which will be supported by EUR 17.77 billion in grants and EUR 12.73 billion in loans. 37.5% of the plan will support climate objectives. The RRP supports the green transition through investments of EUR 1.3 billion in the energy-efficient renovation of more than 100,000 residences, including low-income households. On green and sustainable transport, the RRP envisages more than 8 000 electric charging points and 220 green urban transport buses in Athens and Thessaloniki, a major investment in railways and a thorough reform of the transport sector. Investments of more than EUR 600 million in reforestation, biodiversity, flood mitigation and irrigation network upgrades aim to support environmental protection and are complemented by a waste management reform to promote sustainable landfilling and recycling and improve governance . Figure 39: Climate expenditure in RRPs, 2021-2026



Under NGEU, the Commission will issue up to EUR 250 billion in EU green bonds (one third of all bonds issued under NGEU) until 2026 that will comply with the general spirit of the “do no significant harm” (DNSH) principle. However, this EUR 250 billion in green bonds will not be subject to the currently developed delegated acts related to the EU Taxonomy and will not fully align with the proposed EU green bond standard. In addition to the EU funds earmarked for Greece for 2021-2027 , various other EU funding programmes are open to all Member States, for example: the LIFE programme (EUR 5.4 billion); Horizon Europe (EUR 95.5 billion) ; the Connecting Europe Facility (EUR 33.7 billion) ; and the InvestEU . These instruments will also support the green transition, including research and innovation activities for environmental protection (Horizon Europe) , clean transport and energy (the Connecting Europe Facility) and sustainable infrastructure (InvestEU) . National environmental protection expenditure Total national expenditure on environmental protection (including all relevant current and capital expenditure ) in the EU27 was EUR 272.6 billion in 2020, representing 2% of the Union’s GDP. This percentage has remained quite stable over time. Although the largest absolute amounts of expenditure are concentrated in a few countries, most countries spend 1-2% of their GDP on environmental protection, including Greece (1.2%). Of this spending, capital expenditure (Capex) on environmental protection (i.e. investment) amounted to EUR 56.3 billion in 2018, falling to EUR 54.5 billion in 2020, representing around 0.4% of the EU27 GDP. Greece invested 0.2% of GDP on environmental protection, in line with most other Member States (0.2-0.5% of their GDP). In 2014-2020, this amounted to around EUR 3.48 billion in environmental investment in (EU27 total: EUR 376 billion). Figure 40: Direct and indirect environmental protection investments in EU27 (EUR million and % of GDP), 2018 By institutional sector, around 87.8% of Greece’s environmental protection investments (capital expenditure) came from the general government, 8.5% from specialist producers (of environmental protection services, e.g. waste and water companies) and only 3.7% from industry (businesses) whose environmental activities are usually ancillary to their core activities. At EU level, in 2018, 37.2% came from governments, 32.5% from specialist producers and 30.3% from industry (business). Figure 41: Environmental protection investments (Capex) in EU27 by institutional sector (Total economy = 100%), 2018

A breakdown of investment by environmental topic is only available at institutional sector level (rather than at economy level), due to different reporting patterns ￼. At general government level in Greece, 71% of environmental protection investments were for waste management and 29% for wastewater. The country’s specialist producers mainly focused on waste management (84%), with a further 8% spent on wastewater and 8% on water and soil protection. The business sector’s environmental investments were for: wastewater (35%), waste management (20%), air protection (10%), while a significant share (35%) was not specifically classified. The total annual European green bond issuance amounted to USD 156 billion (EUR 137 billion ) in 2020, up from USD 117 billion (EUR 105 billion) in 2019 (these figures include some non-EU European countries). For EU27 , the 2020 green bond issuance came to EUR 124 billion. In 2014-2020, 83% of the green bonds issued by European countries went towards energy, buildings or transport objectives , 8% supported water and waste, and 6% supported land use – with links to ecosystem conservation & restoration, as the Climate Bonds Taxonomy is broadly similar to the EU Taxonomy . Greece contributed to the EU27’s total 2020 green bond issuance with a value of EUR 582.6 million.

Figure 42: Annual EU green bond issuance in 2020 (EUR billion) Green budget tools Green taxation and tax reform Greece’s revenue from environmental taxes amounted to EUR 6 226 million in 2020, accounting for 3.77% of GDP (above the EU average of 2.24%), as shown in Figure 44. Of this amount, energy taxation accounted for the highest share, 77.5%, compared with 22.4% for transport and less then 0.1% for pollution/resources tax. Figure 43: Environmental ta