COMMISSION STAFF WORKING DOCUMENT The early warning report for Greece Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for the Member States at risk of missing the 2020 preparation for re-use/recycling target on municipal waste
Date: 2018-09-24
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Greece, application of EU law, circular economy, environmental law, environmental protection, pollution control, prevention of pollution, waste, waste management

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  EN 

   EUROPEAN COMMISSION  Brussels, 24.9.2018 SWD(2018) 418 final  […] COMMISSION STAFF WORKING DOCUMENT The early warning report for Greece Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for the Member States at risk of missing the 2020 preparation for re-use/recycling target on municipal waste {COM(2018) 656 final} - {SWD(2018) 413 final} - {SWD(2018) 414 final} - {SWD(2018) 415 final} - {SWD(2018) 416 final} - {SWD(2018) 417 final} - {SWD(2018) 419 final} - {SWD(2018) 420 final} - {SWD(2018) 421 final} - {SWD(2018) 422 final} - {SWD(2018) 423 final} - {SWD(2018) 424 final} - {SWD(2018) 425 final} - {SWD(2018) 426 final}  
 
 
1.  Introduction 

This early warning report is part of the Commission's overall implementation report and aims 
to assist Member States at risk of failing to meet the 2020 target of 50 % preparation for re-
use/recycling of municipal waste set out in Article 11(2)(a) of Directive 2008/98/EC. It builds 
on  previous  support  provided  by  the  Commission  to  help Member  States  comply1  with  EU 
law in the area of municipal waste management. This resulted in country-specific roadmaps2 
being drawn up for the relevant Member States.  

The  assessment  underpinning  the  early  warning  report  is  based  on  a  collaborative  and 
transparent process involving the Member States concerned and an in-depth analysis of their 
most  recent  policy  developments.  This  also  involved  extensive  consultation  with  the 
authorities in charge of waste management.  

The possible actions identified during this process are based on the existing best practices and 
aim  to  help  Member  States  in  meeting  the  2020  municipal  waste  preparation  for  re-
use/recycling; they therefore focus on policy measures that can be taken forward in the short 
term. These actions should be seen as complementary to those recommended in the roadmaps 
that  were  drawn  up  as  part  of  the  preceding  compliance  promotion  activities  and  to  the 
recommendations made in the Environmental Implementation Review3. 

2.  Key findings 

In 2016, Greece’s municipal waste recycling rate (including composting) reported to Eurostat 
was  17 %,  while  its  landfilling  rate  was  82 %.  Based  on  an  analysis  of  existing  and  firmly 
planned policies in the area of waste management, Greece is considered at risk of missing the 
2020 target of 50 % preparation for re-use/recycling of municipal waste. 

The  assessment4  that  underpins  the  early  warning  report  concludes  that  Greece’s  poor 
performance in waste management is due to: 

the absence of the infrastructure needed for source separation of recyclables; 
the general public’s low level of awareness;  

 
 
  a lack of financial incentives; and 
 

the absence of relevant economic instruments, e.g. landfill tax.  

The  economic  recession  and  subsequent  financial  crisis  in  Greece  have  affected  the  waste 
sector,  leading  to  a  decrease  in  waste  generation  but  also  to  a  sharp  increase  in  informal 
recycling in recent years. 

The  table  below  lists  possible  actions  to  support  Greece’s  efforts  to  improve  its  waste 
management. 

1 http://ec.europa.eu/environment/waste/framework/support_implementation_1st_phase.htm 
2 Roadmap for Greece: http://ec.europa.eu/environment/waste/framework/pdf/GR%20Roadmap_FINAL.pdf 
3 http://ec.europa.eu/environment/eir/country-reports/index2_en.htm 
4 Eunomia Research & Consulting et al. (2018), ‘Study to identify Member States at risk of non-compliance with 
the 2020 target of the Waste Framework Directive and to follow-up phase 1 and 2 of the compliance 
promotion exercise. The early warning report: Greece.’ 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Economic incentives 

1)  Implementation of the landfill tax (set to apply from 2018).  

2)  Introduction of pay-as-you-throw schemes as a means to reduce waste sent for disposal 

and to enhance public participation in the separate collection of waste. 

Accurate and internally consistent reporting 

3)  ‘Resetting’ the reported packaging figures so that they are consistent and accurate. Data 
provided by Greece on the quantity and composition of municipal waste suggest that the 
quantity  of  packaging  waste  (as  represented  by  data  on  the  packaging  placed  on  the 
market) is well below that indicated by the municipal waste data. 

4)  Introduction  of  systematic  audits  on  companies  that  provide  data  on  the  amount  of 
packaging  placed  on  the  market  (producers  or  producer  responsibility  organisations  – 
PROs). 

5)  Conducting  statistically  representative  composition  analysis  of  municipal  waste  and 
subsequent  reconciliation  between  the  datasets  on  municipal  waste  and  packaging 
waste. 

Separate collection 

6)  Reconfiguration of the interaction between the PRO for packaging (Hellenic Recovery 
Recycling Corporation – HERRCO) and municipalities. HERRCO should ideally only 
be a conduit for funds for the collection  service, while  the  municipalities should have 
their own obligations regarding separate collection. With this set-up in place, the system 
would be more responsive to a landfill tax. 
This can be done either: 

a.  by setting mandatory recycling targets for municipalities and imposing sanctions 

for failing to meet them; or 

b.  by setting a minimum service  standard for waste collection (e.g. the frequency 
of collection, the type and volume of containers, while taking  into  account the 
type  of  housing  stock,  how  rural  the  area  is,  typical  climate,  etc.)  that 
municipalities must meet. 

In  either  case,  HERRCO  should  fund,  in  full,  delivery  of  the  part  of  the  collection  service  as 
regards the packaging waste in line with an agreed funding formula. 

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EU funding 

7)  Better use of EU funds by ensuring that they support: 

a.  activities  in  the  upper  tiers  of  the  waste  hierarchy,  in  particular  recycling  and 

prevention; 

b.  capacity building at municipal level to support the development of high-quality 

recycling services (see action 9); 

c.  the  delivery  of  high-quality  recycling  services  by  local  authorities,  and 

convenient door-to-door collection systems for food waste; 

d.  the  delivery  of  treatment  for  separately  collected  bio-waste  (to  be  integrated 
with  the  development  of  collection  systems,  with  municipalities  working 
together as necessary); 

e.  the provision of green points designed to promote re-use (through ‘up front’ re-

use shops) and recycling of bulky material, including garden waste.  

8)  Less emphasis is necessary on investments in capacity for the treatment of residual 

waste. 

Technical support to municipalities 

9)  Development  of  a  system  at  national  level  that  provides  technical  support  to 

municipalities, specifically in the following areas: 

a.  choosing collection services; 
b.  services procurement; 
c.  service management; 
d.  awareness-raising campaigns; 

coupled with active sharing of good ideas and practices that can improve efficiency in terms 
of cost reduction and improvement in performance. 

Communication and awareness-raising 

10) Development of a set of national communications materials addressed to the public for 
use at local level, with clear and consistent messages. These materials should be used as 
part of awareness-raising campaigns, in leaflets, and at green points. 

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