COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 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 Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-04-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Greece, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2019  SWD(2019) 138 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019    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 Environmental Implementation Review 2019:  A Europe that protects its citizens and enhances their quality of life   {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 113 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 120 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 134 final} - {SWD(2019) 135 final} - {SWD(2019) 136 final} - {SWD(2019) 137 final} - {SWD(2019) 139 final}  
 
 
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:  p. 11  —  ©iStock/Poike;  p. 14  —  ©iStock/SHansche;  p. 16  —  ©iStock/saiko3p;  p. 20  — 
©iStock/marchello74; p. 29 — © iStock/alexandr6868 

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2019 

Reproduction is authorised provided the source is acknowledged. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

EXECUTIVE SUMMARY ................................................................................................................................... 3 

PART I: THEMATIC AREAS .............................................................................................................................. 4 

1. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW 
CARBON ECONOMY .............................................................................................................................. 4 

Measures towards a circular economy ................................................................................................. 4 
Waste management .............................................................................................................................. 6 
Climate change ...................................................................................................................................... 8 

2. 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .................................................. 10 

Nature and biodiversity ....................................................................................................................... 10 
Maintaining and restoring ecosystems and their services .................................................................. 11 
Estimating natural capital ................................................................................................................... 11 
Invasive alien species .......................................................................................................................... 12 
Soil protection ..................................................................................................................................... 13 
Marine protection ............................................................................................................................... 14 

3. 

ENSURING CITIZEN’S HEALTH AND QUALITY OF LIFE ........................................................................ 15 

Air quality ............................................................................................................................................ 15 
Industrial emissions ............................................................................................................................. 16 
Noise     ................................................................................................................................................ 17 
Water quality and management ......................................................................................................... 18 
Chemicals ............................................................................................................................................ 19 
Making cities more sustainable ........................................................................................................... 20 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 22 

4. GREEN TAXATION, GREEN PUBLIC PROCUREMENT, ENVIRONMENTAL FUNDING AND INVESTMENTS 22 

Green taxation and environmentally harmful subsidies ..................................................................... 22 
Green public procurement .................................................................................................................. 23 
Environmental funding and investments ............................................................................................ 23 

5. STRENGTHENING ENVIRONMENTAL GOVERNANCE ............................................................................... 27 

Information, public participation and access to justice ...................................................................... 27 
Compliance assurance ......................................................................................................................... 28 
Effectiveness of environmental administrations................................................................................. 29 
International agreements ................................................................................................................... 30 
Sustainable development and the implementation of the UN SDGs .................................................. 31 

2 

 
 
 
 
Environmental Implementation Review 2019 – Greece 

Executive summary 

Greece  and 
Review (EIR)  

the  Environmental 

Implementation 

In  the  2017  EIR,  the  main  challenges  identified  for 
Greece  for  the  implementation  of  EU  environmental 
policy and law were:  

 

 

 

issues, 

to  address  waste  management 
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; and  
to  complete  the  implementation  of  the  Urban 
Waste Water Treatment Directive.  

Complex  administrative  structures  and  procedures  in 
Greece,  which  can  cause  significant  delays  and 
bottlenecks,  are  sometimes  the  main  obstacle  to 
implementing environmental legislation. 

Following the publication of  the 2017 EIR,  Greece has 
not yet organised an EIR national dialogue that would 
help address the above challenges.  

Progress on meeting challenges since the 2017 EIR  

The  2019  EIR  shows  that  there  has  been  some 
progress  on waste  management,  as  the  strategic 
framework for waste is now  in place and the national 
and  regional  waste  management  plans  have  been 
adopted. Moreover, the number of illegal landfills that 
are  still  operational  or  in  need  of  rehabilitation  has 
decreased  over  the  years.  However,  the  remaining 
landfills  will  be  very  difficult  to  close  unless  new 
facilities are built. Greece needs to make a major effort 
to  put  in  place  an  adequate  network  of  facilities  that 
would  effectively  manage  all  the  hazardous  waste 
produced  in  the  country.  Some  progress  has  been 
made on the legal and institutional steps necessary to 
increase  waste  recycling  and  expand  the  extended 
producer’s  responsibility  (EPR)  schemes.  However, 
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  has 
significantly 
extended  its  marine  Natura  2000  network  recently.  It 
has  adopted  legislation  to  put  management  bodies  in 
place  for  all  its  Natura  2000  sites  and  has  started  to 

implement a comprehensive LIFE integrated project for 
nature.  These  positive  steps  should  be  followed  up 
with  concrete  action  on  the  ground  to  effectively 
address  the  challenges 
in  the  previous 
report. 

identified 

the 

steps, 

such  as 

On  urban  wastewater  treatment,  there  have  been 
some  positive 
systematic 
assessment  and  strategic  re-organisation  of  the 
country’s investment needs. These efforts should lead 
to  the  necessary  infrastructure  being  quickly  put  in 
place,  particularly 
(i.e. 
population  centres  or  places  of  economic  activity) 
covered by an open infringement procedure. 

the  agglomerations 

in 

Examples of good practice  

 

dialogue 

between 

  Concrete  steps  towards  a  comprehensive  circular 
economy  policy  strategy  include:  (i)  a  recently 
adopted  national  circular  economy  action  plan, 
which  sets  out  short-term  measures  and  long-
term  priorities;  (ii)  a  2017  recycling  law  that 
adjusts  existing  legislation  to  circular  economy 
principles; and (iii) a  circular  economy forum that 
encourages 
relevant 
stakeholders  to  encourage  business  models  and 
innovations  that  are  adapted  to  a  circular 
economy. 
The  local  (municipal)  waste  management  plans, 
which  have  been  incorporated  in  the  regional 
plans, set the separate collection of bio-waste as a 
basic  goal.  Greece  has  planned  for  a  significant 
proportion  of  EU  funds  to  be  allocated  to  waste 
management  measures 
infrastructure, 
particularly  integrated  waste  treatment  facilities 
and source separation schemes. 
Incentives exist to encourage the purchase of cars 
lower  CO2  emissions  and  new  vehicles 
with 
purchased 
in  Greece  are  among  the  most 
environmentally friendly in the EU. 

and 

 

  On  environmental  governance,  the  Council  of 
State  takes  a  progressive  approach  to  access  to 
justice  in  environmental  matters.  In  addition,  all 
administrative  processes,  including  environment-
related  ones,  have  become  significantly  more 
transparent  thanks  to  the  ‘Diavgeia’  transparency 
programme («Clarity»). 

3 

 
Environmental Implementation Review 2019 – Greece 

Part I: Thematic Areas 

1. Turning the EU into a circular, resource-efficient, green and 

competitive low carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting up of a related stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2. 

The  circular  (secondary)  use  of  materials  in  Greece  was 
only  2.4 %  in  2014  (EU-28  average  11.4 %).  Greece 
performs below EU-28 average on the number of people 
employed  in  the  circular  economy  (1.65 %  of  total 
employment  in  2016  compared  to  the  EU-28  average  of 
1.73 %). 

In  the  2017  Special  Eurobarometer  on  attitudes  of  EU 
citizens towards the environment, 91 % of Greek  people 
said  they  were  concerned  about  the  effects  of  plastic 
products on the environment (EU-28 average 87 %). 94 % 
said  they  were  worried  about  the  impact  of  chemicals 
(EU-28 average 90 %)3. Greek society appears to strongly 
support  circular  economy  initiatives  and  environmental 
protection measures. 

Since  the  2017  EIR,  the  status  of  and  policy  support  for 
the  circular  economy  grew  and  concrete  steps  were 
taken towards a comprehensive policy strategy. 

In  April  2018,  the  Government  Council  for  Economic 
Policy (KYSOIP) endorsed the national ‘action plan on the 
circular  economy’  including  short-term  and  long-term 

priorities. In addition, Greece will introduce indicators to 
monitor the impact of the circular transition. 

Greece also endorsed a new recycling law (4496/2017) in 
November  2017,  which  adjusted  existing  legislation  to 
circular economy principles. 

Greece  also  actively  promotes  dialogue  among 
stakeholders  to  bring  about  change  on  the  ground.  The 
circular  economy  dialogue  forum  gathers  businesses, 
SMEs, researchers, social entrepreneurs, etc., to promote 
circular business models and innovation. 

In general, environmental policy in Greece still focuses on 
encouraging the use of renewable energies and adopting 
energy  efficiency  measures,  which  can  spur  eco-
innovation. These measures, along with the new national 
and  regional  waste  management  plans,  can  help  the 
transition towards a circular economy. 

Greece  performs  below  the  EU  average  on  resource 
productivity4 (how efficiently the economy uses material 
resources  to  produce  wealth),  with  1.45  EUR/kg  (the 
average  is  2.04)  in  20175.  Figure  1  shows  that  Greece’s 
resource productivity has increased slightly compared to 
2014. 
Figure 1: Resource productivity 2010-20176 

The  Operational  Programme  on  Competitiveness, 
Entrepreneurship  and  Innovation  under  the  National 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, 2017, Special 486 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’. 

4 Resource productivity is defined as the ratio between gross domestic 
product (GDP) and domestic material consumption (DMC). 
5 Eurostat, Resource productivity 
6 Eurostat, Resource productivity. 

4 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

(NSRF)  2014-2020 
Strategic  Reference  Framework 
allocates  EUR  28.8  million  to  promoting 
innovative 
technologies  for  environmental  protection  and  resource 
efficiency  in  waste  management,  water  management, 
soil contamination and air pollution. The support includes 
businesses  research  &  development  (R&D)  activities  to 
develop  and  apply  anti-pollution  technologies  and 
monitoring  mechanisms.  Another  EUR  28.3  million  is 
allocated to supporting green growth and eco-innovation 
in  both  the  private  and  public  sectors.  The  co-funded 
activities  include  measures  to  increase  ‘technological 
know-how’  on  environmental  protection  and  the  eco-
design of products.  

As of September 2018, Greece had 3348 products and 32 
licences  registered  in  the  EU  Ecolabel  scheme,  out  of  a 
total of 71707 products and 2167 licences in the EU. 

SMEs and resource efficiency 

Greek  SMEs  continue  to  score  below  the  EU-28  average 
in  the  environmental  aspects  of  the  small  business  act 
(see  Figure  2).  Although  the  proportion  of  SMEs 
benefiting  from  public  support  measures  for  their 
resource-efficiency  actions  has  significantly  increased 
from  4 %  to  25 %  compared  to  the  previous  reference 
period,  further  efforts  are  needed,  as  this  rate  is  still 
among  the  lowest  in  the  EU.  Although  some  relevant 
measures have been adopted since 2008, such as ‘Green 
for 
‘Green  Business’,  there 
Tourism’  or 
improvement 
the  development  of 
in  promoting 
innovative eco-efficient processes, products and services 
and their uptake by SMEs.  

is  room 

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and green markets’7 asked companies about both recent 
resource-efficiency actions they had taken and additional 
resource-efficiency  actions  they  planned  to  take  in  the 
next  2  years.  The  Eurobarometer  then  compared  these 
responses  with  the  responses  given  to  the  same 
questions  in  2015.  An  increasing  number  of  companies 
claim  to  have  invested  in  resource  efficiency.  Greek 
companies  in  many  sectors  are  slowly  approaching  the 
EU-28  averages  in  this  area.  Looking  at  companies’ 
intentions,  this  trend  is  set  to  continue,  particularly  for 
renewable energy use (28 %; +9 % compared to 2015  vs 
an  EU-28  average  of  22 %).  Greek  companies  are  not 
particularly  ambitious  on  saving  materials,  minimising 
waste and recycling and their gap with the EU average for 
these indicators is still substantial. 

At 14 %, the proportion of Greek companies that rely on 
external  support  in  their  efforts  to  be  more  resource 
efficient is below the EU average of 22 % (EU range 3 %-
38 %). For advice, 59 % say that that they rely on private 
sector consultancy, but both business associations (24 %; 
+20 %)  and  public  administrations  (12 %;  +12 %)  have 
recovered from the crisis and gained in importance in this 
respect. 

Among Greek companies, 46 % find grants and subsidies 
to  be  helpful.  Moreover,  Greek  companies  appreciate 
technical  and  financial  consultancy  (each  27 %)  more 
than the EU average (22-23 %). 
Figure 2: Environmental performance of SMEs8 

As it recovers from the crisis, the Greek business sector is 
becoming more ambitious on resource efficiency and on 
developing  green  products  and  services.  Public  sector 
increasingly  seen  as 
and  business  associations  are 
valuable  partners 
sector 
consultancy. 

in  addition 

to  private 

Eco-innovation 

Greece  ranked  22nd  on  the  2018  European  Innovation 
Scoreboard9, while its performance was better in the Eco-
innovation Index for 2017 (Figure 3), scoring 20th with 77 
points. 

7 Flash Eurobarometer 456 ‘SME, resource efficiency and green 
markets’ January 2018. The 8 dimensions were Save energy; Minimise 
waste; Save materials; Save Water; Recycle by reusing material 
internally; Design products easier to maintain, repair or reuse; Use 
renewable energy; Sell scrap materials to another company. 

8 European Commission, 2018 SBA fact sheet - Greece, p. 12. 
9 European Commission, European innovation Scoreboard 2018. 

5 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Figure 3: 2017 Eco-innovation index (EU=100)10  

which promotes eco-innovation and other activities. 

Research activities in Greece depend heavily on EU funds. 
The NSRF is expected to allocate around EUR 5.18 billion 
in  2014-2020  for  environmental  activities,  of  which  EUR 
1.2  billion  will  go  towards  strengthening  research, 
technological development and innovation. 

Fund 

Entrepreneurship 

The  National 
and 
for 
Development  (ETEAN)  will  prioritise  supporting  the 
sustainability,  energy  efficiency  and  renewable  energy-
related  activities  of  businesses.  The  waste  management 
plan  also  promotes  R&D  and  the  uptake  of  innovative 
in  eco-design,  packaging  and  waste 
technologies 
management11. 

2019 priority actions 

 

 

 

Strengthen  the  policy  framework  to  speed  up  the 
transition  towards  the  circular  economy  by  all 
economic sectors, for instance for water and energy 
savings,  waste  reduction,  the  recycling  of  materials 
and/or  the  uptake  of  the  secondary  raw  materials 
market.   
Improve  eco-innovation  performance,  for  example, 
through  better  use  of  environmental  standards  and 
international 
licences  and  other  European  or 
instruments. 
Incentivise  the  savings  of  energy  and  water  and 
increase the level of recycling among SMEs. 

Waste management 

Turning waste into a resource is supported by: 
legislation,  which 
implementing  EU  waste 
(i)  fully 
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; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  management  of  municipal 
waste12  for  which  EU  law  sets  mandatory  recycling 
targets13. 

11 European Commission, Eco-Innovation Observatory: Eco-innovation 
Country Profiles 2016-2017. 
12 Municipal waste consists of mixed waste and separately collected 
waste from households and from other sources, where such waste is 
similar in nature and composition to waste from households. This is 
without prejudice to the allocation of responsibilities for waste 
management between public and private sectors. 
13 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in 2018 by Directive (EU) 2018/851, and more ambitious recycling 
targets were introduced for the period up to 2035. 

Since 2010, Greece has considerably improved, as shown 
in  Figure  4.  Greece  has  reduced  the  gap  with  the  EU 
average by more than 30 points. 

Figure 4: Greece’s Eco-innovation performance 

Environmental  policy  in  Greece  focuses  on  encouraging 
the  use  of  renewable  energies  and  applying  energy 
that 
efficiency  and  waste  management  measures 
promote  eco-innovation.  The  innovation  capacity  of  the 
Greek economy depends largely on imported technology 
and know-how. Its strengths relate to organisational and 
technical 
marketing 
improvements.  The  small  size  of  Greek  companies  also 
discourages developing and commercialising innovations 
further. 

innovations 

rather 

than 

The  policy  framework  to  support  innovation  is  expected 
to improve significantly thanks to the 2014 action plan to 
implement 
for 
Research,  Technological  Development  and  Innovation, 

the  2015-2021  National  Strategy 

10 Eco-innovation Observatory: Eco-Innovation scoreboard 2017. 

6 

 
 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

encourage  recycling  over  disposing  of  waste.  The 
available  economic  instruments  are  insufficient  and  the 
schemes currently in place are ineffective. The 2012 pay-
as-you-throw (PAYT) scheme to reduce waste in landfills 
and  encourage  people  to  separate  their  waste  for 
separate collection is not yet being applied. 

Figure  6:  Recycling  rate  of  municipal  waste  in  2010-
201717 

In  view  of  the  recently  adopted  post-2020  recycling 
targets for municipal waste (55 % by 2025, 60 % by 2030 
and  65 %  by  2035)  Greece  will  have  to  put  more  effort 
into  shifting  waste  away  from  landfilling  and  towards 
recycling. 

There  are  major  structural  problems  with  waste 
management in Greece. Municipal waste generation has 
remained at the same level in recent years, being slightly 
above  the  2017  EU  average  (504  kg  vs  around  487 
kg/y/inhabitant)  (see  Figure  5).  Very  little  has  changed 
since  the  2017  EIR.  Greece  disposes  the  majority  of  its 
municipal waste in landfills (80 %, vs EU average of 24 %), 
with  only  19 %  being  recycled  (EU  average  46 %).  The 
landfill  rate  has  decreased  modestly  and  the  recycling 
rate has slightly increased. 

Figure 5: Municipal waste by treatment in Greece 2010-
201714 

Additional  measures  need  to  be  taken  to  divert 
biodegradable  waste  from  landfills  and  to  put  in  place 
and monitor infrastructure and schemes for door-to-door 
separate 
favouring 
Incentive 
prevention and participation to separate collection (PAYT 
schemes)  do  not  yet  exist,  while  specific  incentives  for 
local authorities to develop separate collection are under 
development.  

collection. 

systems 

As  shown  in  Figure  6,  Greece  is  at  risk  of  not  achieving 
the  target  of  50 %  municipal  waste  recycling  by  2020. 
‘early 
The Commission  has  therefore  published  an 
warning report’15 for Greece, setting out specific priority 
actions to bridge the implementation gap.   Greece must 
also  make  a  significant  effort  to  comply  with  the  post-
2020 recycling targets16. 

Greece  adopted  a  landfill  tax  law  in  2012,  but  its 
application has been postponed until 2019 at the earliest. 
In the meantime, the landfill gate fee, which is currently 
low,  together  with  the  cheap  illegal  landfills  do  not 

14Eurostat, Municipal waste by waste operations. 
15 European Commission, Report on the implementation of waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
waste, SWD(2018)418 accompanying COM(2018)656. 
16 Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 
legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
in future Environmental Implementation Reports. 

On the positive side, Greece has made legal and practical 
progress  in  increasing  waste  recycling  and  expanding  its 
EPR schemes. For example, it has reduced waste disposal 
to  non-compliant  landfills.  In  2015,  this  dropped  to  less 
than 4 % of the total waste disposed. An operational plan 
for  EPR,  which  will  introduce  funding  for  different  EPR 
packaging  schemes,  is  about  to  be  applied.  The  local 
(municipal)  waste  management  plans,  which  have  been 
incorporated  in  the  regional  plans,  set  the  separate 
collection  of  bio-waste  as  a  basic  goal.  Greece  has 
planned  to  allocate  a  large  proportion  of  EU  funds  to 
waste  management  measures  and 
infrastructure  —
source 
integrated  waste 
separation  schemes,  in  particular.  However,  there  are 
doubts on whether spending on residual waste treatment 
at  the  lower  levels  of  the  waste  hierarchy  is  too  high 
compared  to  spending  on  infrastructure.  Care  must  be 
taken  not  to  move  from  landfilling  to  poor  quality 
Mechanical  and  Biological  Treatment  installations  (49 
MBTs are currently foreseen). 

facilities  and 

treatment 

17 Eurostat, Recycling rate of municipal waste. 

7 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Despite the national waste management plan’s ambitious 
goal to reach a bio-waste recycling rate of 40 %, reaching 
more  than  8-10 %  by  2020  seems  unlikely,  especially 
without adequate treatment infrastructure. 

Greece’s ‘early warning report’ highlights the importance 
of  helping  local  authorities  to  increase  the  skills  of  their 
staff.  It  gives  recommendations  for  making  the  EPR 
schemes  more  effective  and  also  underlines  that  the 
quality of the packaging data reported by the producers 
needs  to  be 
it  recommends  the 
effective use of EU funds to support separate collection, 
recycling and composting. 

improved.  Finally, 

2019 priority actions 

 

  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.  

The EU emissions trading system (EU ETS) covers all large 
greenhouse  gas  emitters  in  the  industry,  power  and 
aviation  sectors  in  the  EU.  The  EU  ETS  applies  in  all 
Member States and has a very high compliance rate. Each 
year,  installations  cover  around  99  %  of  their  emissions 
with the required number of allowances. 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation. Greece had significantly lower emissions than 
its annual emission allocations (AEAs) in each of the years 
2013-2017. For 2020, Greece's national target under the 
EU Effort Sharing Decision is to reduce emissions by 4 % 
compared  to  2005.  For  2030,  Greece's  national  target 
under  the  Effort  Sharing  Regulation  will  be  to  reduce 
emissions  by  16  %  compared  to  2005.  According  to  its 
latest  own  projections,  Greece  is  expected  to  over-
achieve its 2020 target under the effort  sharing decision 
by  18%  (-22%  vs  a  target  of  -4%)  and  its  2030  target 
under the effort sharing regulation by 7%.  

Figure 7: Change in total greenhouse gas emissions 1990-
2017 (1990=100%)19. 

  Avoid  building  excessive 

types 

infrastructure  for  the 
residual  waste,  e.g.  mechanical 

treatment  of 
biological treatment (MBT) facilities or incinerators. 
Improve  and  extend  separate  collection  of  waste, 
including  for  bio-waste.  Establish  minimum  service 
standards  for  separate  collection  (e.g.  frequency  of 
collections, 
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, 
line  with  the  general 
in 
minimum requirements on EPR18. 

containers, 

etc.) 

of 

 

 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

18 Set out in Directive (EU) 2018/851 amending Directive 2008/98/EC. 

The  country's  carbon  intensity  level  is  nevertheless  still 
high  compared  to  other  Member  States.  Additional 
efforts are therefore encouraged. For  emissions covered 
by the EU ETS: In Greece approx. 145 installations and 20 
aircraft operators are registered in the EU ETS. The total 
revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS  over  the  years  2013-2017  were  EUR 
820  million.  92%  of  the  auctioning  revenues  have  been 
spent on climate and energy purposes.  

19Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

8 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Figure 8: Targets and emissions under the Effort  Sharing 
Decision and Effort Sharing Regulation20. 

corresponds  to  0.4%  of  the  EU-28  accounted  sink  of  -
115.7 Mt CO2-eq.  

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making  and  adaptation 
in  key 
vulnerable sectors. By adopting a coherent approach and 
providing for improved coordination, it seeks to enhance 
the preparedness and capacity of all governance levels to 
respond to the impacts of climate change.  

Greece  adopted  its  National  Adaptation  Strategy  (NAS) 
by  law  in  2016.  The  Greek  NAS  is  an  overarching  policy 
document,  which  defines  the  goals,  principles  and 
priorities  for  adaptation.  The  Greek  NAS  also 
lists 
potential  adaptation  measures  and  actions  for  fifteen 
(15)  environmental  and  socio-economic  sectors  that  are 
likely  to  be  significantly  affected  by  climate  change  in 
Greece.  These  sectors  are:  biodiversity  and  ecosystems, 
agriculture  and 
fisheries, 
aquaculture,  water  resources,  coastal  areas,  tourism, 
energy, human health, the built environment, transport, 
cultural  heritage,  industry,  mining,  and  the  insurance. 
The NAS provides guidance,  insight and priorities,  which 
should be further detailed at regional level and translated 
into Regional Adaptation Action Plans.  

security, 

forestry, 

food 

The  law  also  foresees  the  establishment  of  a  National 
Climate  Change  Adaptation  Committee  to  act  as  the 
formal coordination and advisory body of the Ministry of 
Environment and Energy at National level for adaptation 
policy design, coordination and implementation.  

Work  is  ongoing  to  develop  Regional  Adaptation  Action 
Plans. Each Regional Adaptation Action Plan will examine 
the  potential  measures  and  actions  included  in  the 
National  Adaptation  Strategy,  based  on  the  particular 
regional  characteristics,  priorities  and  needs  and  will 
develop the regional priorities. Wherever there is a case 
for  sector  or  sub-regional  analysis,  specific  actions  per 
sector  or  sub-regional  area  will  be  indicated.  To  date, 
there  is  no  monitoring  of  the  integration  of  climate 
change in sectoral policies, nor is there a framework that 
assesses adaptation actions that are being implemented. 
Greece  will launch such a  system in 2019  making use of 
EU funding programmes (LIFE integrated Projects). 

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  needed  to  send  by  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked themes  such as agriculture-nature-water and 
transport-air-health.  

Transport  represents  almost  a  quarter  of  the  EU’s  GHG 
emissions and is the main cause of air pollution in cities. 
Transport  emissions  in  Greece  increased  by  6  %  from 
2013 to 2016. 

Figure 9: Greenhouse gas emissions by sector (Mt. CO2-
eq.). Historical data 1990-2016. Projections 2017-203021. 

According  to  the  F-gas  regulation,  Member  States  must 
implement  training  and  certification  programmes  and 
rules  for  penalties  and  notify  these  measures  to  the 
Commission by 2017. Greece has notified both measures.  

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
A  preliminary  accounting  exercise  for  2013-2016  shows 
net  credits  of,  on  average,  -0.5  Mt  CO2-eq,  which 

20 Proxy GHG emission estimates for 2017Approximated EU greenhouse 
gas inventory 2017 (European Environment Agency). Member States 
national projections, reviewed by the European Environment Agency. 
21 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

9 

 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

2. Protecting, conserving and enhancing natural capital 

Nature and biodiversity 

in  the  EU  by  2020. 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity 
full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
and  forest  sectors  help  to  maintain  and 
improve 
biodiversity. 

It  requires 

Biodiversity strategy 

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. 

Setting-up a coherent network of Natura 2000 sites 

The Birds and Habitats Directives require Member States 
to establish a coherent national network of Natura 2000 
sites.  The  Commission  assesses  compliance  with  this 
requirement  individually  for  each  species  and  habitat 
type  occurring  on  the  national  territory  of  the  Member 
States.  The latest  update of this assessment  was  carried 
out  by  the  Commission  with  the  assistance  of  the 
European Environment Agency. On the basis of this latest 
update,  Greece’s  terrestrial  Natura  2000  network  under 
the Birds and Habitats Directives is now considered to be 
complete. 

Greece  has  designated  446  Natura  2000  sites,  including 
265  sites  of  Community  importance  (SCIs)  under  the 
Habitats  Directive  and  207  Special  Protection  Areas 
(SPAs) under the Birds Directive. These sites cover 27.4 % 
of the national land area of Greece (EU average 18.2 %), 
and a significant proportion of its marine area22. 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

The terrestrial part of the Greek Natura 2000 network is 
largely complete. The latest  big expansion of the marine 
part of the network is expected to address the remaining 
designation insufficiencies of both SCIs and SPAs23. 

For  239  SCIs,  the  6  year  deadline  set  in  the  Habitats 
Directive  to  designate  them  as  Special  Areas  of 
Conservation  and  establish  appropriate  conservation 
objectives  and  measures  has  now  expired.  As  of  April 
2018, Greece had not fulfilled these obligations. 

 Although  SPAs  have  horizontal  protection  measures 
under  national  legislation,  some  key  implementing  acts 
that apply the law are still missing. 

Greece has adopted a  sound and comprehensive law on 
biodiversity24  and  a  national  biodiversity  strategy25  but 
neither has been properly implemented. 

Management  plans  and  accompanying  legal  tools  have 
been  developed  for  a  number  of  sites,  mainly  through 
LIFE  or  European  Regional  Development  Fund  (ERDF) 
financing.  However,  very 
few  have  been  formally 
adopted and implemented. A major project under ERDF, 
starting  in  2018,  is  expected  to  prepare  or  update 
management plans and legal acts covering all 446 Natura 
2000 areas by the end of 2020. 
According to Greece’s latest report26 on the conservation 
status  of  habitats  and  species  covered  by  the  Habitats 
Directive,  only 
for 
Mediterranean habitat types and 33 % for species show a 
good  conservation  status.  However,  for  12 %  of  species 
the status is unknown27. 

assessments 

63 %  of 

the 

A  major  challenge  to  protect  and  manage  Natura  2000 
sites  effectively  is  to  set  up  a  national  system  for  the 
and 
administration 
comprehensive  management, 
(including  strategy, 
functioning  of  protected  areas 
structure,  management 
responsibilities, 
financing,  enforcement  and  monitoring).  The  recent  law 
that  aims  to  put  in  place  management  bodies  for  all 
Natura  2000  sites  should  provide  significant  benefits  in 
this respect. 

schemes, 

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 

22 Sites of Community Importance (SCIs) are designated pursuant to the 
Habitats Directive whereas Special Areas of Protection (SPAs) are 
designated pursuant to the Birds Directive; figures do not add up due to 
the fact that some sites are designated as both SCIs and SPAs. Special 
Areas of Conservation (SACs) means SCIs subsequently designated as 
SACs by the Member States. 
23For each Member State, the Commission assesses whether the species 
and habitat types on Annexes I and II of the Habitats Directive, are 
sufficiently represented by the sites designated to date. This is 
expressed as a percentage of species and habitats for which further 
areas need to be designated in order to complete the network in that 

country. The current data, which were assessed in 2014-2015, reflect 
the situation up until December 2013. 
24 The Hellenic Republic, Law 3937/2011. 
25 The Hellenic Republic, Ministerial Decision 40332/2014. 
26 The Hellenic Republic, Period 2007-2012. The core of the ‘Article 17’ 
report is the assessment of conservation status of the habitats and 
species targeted by the Habitats Directive. 
27The Hellenic Republic, Conservation status is assessed using a 
standard methodology as being either ‘favourable’, ‘unfavourable-
inadequate’ and ‘unfavourable-bad’, based on four parameters as 
defined in Article 1 of the Habitats Directive. 

10 

 
                                                                 
 
                                                                                                        
 
Environmental Implementation Review 2019 – Greece 

promoting  these  benefits;  (iii)  insufficient  scope  for 
supporting sustainable land management and integrating 
it in other policies; and (iv) difficulties with enforcing the 
law.  The  LIFE  integrated  project,  launched  in  2017, 
should significantly help address these challenges. 

Due  to  these  shortcomings,  many  complaints  and 
infringement  cases  are  under  way  on  issues  such  as:  (i) 
the degradation of designated sites;  (ii) the poor quality 
of  ‘appropriate  assessments’  under  Article  6(3)  of  the 
Habitats Directive; (iii) the lack of strategic assessments; 
and  (iv)  insufficient  protection  of  species  and  habitats 
(which is also due to illegal activities).  

 

 

that 

communication 

conservation  measures 

policies  and  promote  better 
between actors. 
Increase  the  capacity  of  competent  authorities 
(central,  regional,  site  management  bodies)  to:  (i) 
increase 
apply 
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. 
Improve  the  quality  of  appropriate  assessments  at 
level  and  ensure  that  their 
plan  and  project 
environmental impact is adequately monitored. 

Maintaining and restoring ecosystems and 
their services 

The EU biodiversity strategy aims to maintain and restore 
ecosystems  and  their  services  by 
including  green 
infrastructure  in  spatial  planning  and  restoring  at  least 
15 %  of  degraded  ecosystems  by  2020.  The  EU  green 
infrastructure  strategy  promotes  the  incorporation  of 
green infrastructure into related plans and programmes. 

The EU has provided guidance on the further deployment 
of  green  and  blue  infrastructure  in  Greece29  and  a 
country page on the Biodiversity Information System for 
Europe  (BISE)30.  This  information  will  also  contribute  to 
the  final  evaluation  of  the  EU  Biodiversity  Strategy  to 
2020. 

The 2014 National Biodiversity Strategy of Greece refers 
to green infrastructure. However, green infrastructure is 
not  yet  mainstreamed  into  other  policy  areas,  such  as 
disaster  risk  reduction  or  urban  development.  Several 
projects  and  initiatives  have  the  potential  to  support 
connectivity and help implement green infrastructure. 

There  is  a  lack  of  urban  green  space  in  Greece.  The 
preservation  of  coastal  and  marine  areas  is  also  a 
challenge.  This  is  due  to  factors  such  as:  (i)  a  high 
concentration  of  human  activity  and  land  use;  (ii)  a  lack 
of  political  will;  (iii)  no  comprehensive  planning  for  the 
preservation  and  management  of  these  areas;  (iv) 
inadequate  control  mechanisms;  and  (v)  a 
lack  of 
coordination between the relevant authorities. 

The  main  causes  of  biodiversity  loss  in  Greece  relate  to 
past  and  current  policies  on  unsustainable  land  use, 
(especially 
transport, 
agriculture, 
coastal),  production  and  consumption  patterns  and 
climate change. 

fisheries, 

tourism 

restoring 
in  maintaining  or 
Progress 
conservation status of species and habitats 

favourable 

Member  States  report  only  once  every  6  years  on  the 
progress  made  under  both  Directives28.  Overall,  it  is 
acknowledged that improvements in the status of species 
and habitats have recently been reported in Greece. 

2019 priority actions 

  Define  clear  conservation  objectives  for  the  Natura 
implement  the 

2000  sites  and  complete  and 
management plans and legal tools for all the sites. 
  Complete  and  implement  the  management  plans 
and  legal  tools  for  all  the  sites.  Ensure  that  all 
extended  or  newly  established  management  bodies 
operate  effectively,  with  clear  responsibilities  and 
sufficient resources and funding. 

  Better  integrate  biodiversity  concerns  into  other 

28 Conservation status data used in the 2019 EIR are from the 2007-
2012 reporting period under the Habitats Directive, i.e. the same that 
should also have been used in the 2017 EIR. However at the time of the 
drafting of that report Greece had not submitted yet those data, hence 
the ones from 2001-2006 were used. 

29 European Commission, The recommendations of the green 
infrastructure strategy review report and the EU Guidance on a 
strategic framework for further supporting the deployment of EU-level 
green and blue infrastructure. 
30 Biodiversity Information System for Europe. 

11 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services31 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

The  political  significance  of  Mapping  and  Assessment  of 
Ecosystems  and  their  Services  (MAES)  has  increased  in 
Greece since 2014 and specific preparatory actions have 
started.  The  Hellenic  Ecosystem  Partnership  (HESP) 
coordinates the ecosystem services assessment efforts in 
Greece.  It  aims  to:  (i)  produce  maps  of  ecosystem 
services at national level;  (ii)  create a strong network of 
research, practice and policy; and (iii) raise awareness on 
the value of ecosystems and their services. The HESP also 
collaborates  with  other  MAES  working  groups  (the 
ecosystem  services  partnership 
the  Mediterranean 
working group and the marine working group). 

The HESP adapted its conceptual framework to fit in with 
the  aim  of  the  national  ES  assessment.  It  is  currently 
implementing  its  action  plan  that  runs  until  2020  to 
assess ecosystem services in Greece. It aims to complete 
the  bio-physical  assessments 
in  2018  and  provide 
outcomes to support decision making between now  and 
202032. 

The LIFE integrated project ‘4 Natura’ kicked off in 2017. 
The  project  includes  a  mapping  and  assessment  of  the 
country’s ecosystem types and the services they provide. 
It also includes MAES case-studies in selected regions. 

A series of MAES workshops took place in Greece in 2018 
and two MAES technical guidance documents for Greece 
were published to support them33. 

While there is plenty of academic research on ecosystem 
services  in  Greece,  awareness  of  other  societal  groups, 
including decision-makers, is very limited. The role of the 
state remains difficult to assess. 

At  the  MAES  working  group  meeting  in  Brussels  in 
September  2018,  Greece  was  announced  to  have  made 
substantial progress since January 2016 on implementing 
MAES (see Figure 11). This assessment, which is updated 
every  six  months,  is  underpinned  by  the  ESMERALDA 
(Enhancing  ecoSysteM  sERvices  mApping  for  poLicy  and 

Decision  mAking)  project34 
implementation questions. 

and  based  on  27 

Figure 10: Implementation of MAES (September 2018) 

Business  and  biodiversity  platforms,  networks  and 
communities of practice are key tools for promoting and 
facilitating  natural  capital  assessments  among  business 
and  financial  service  providers,  for  instance  via  the 
Natural  Capital  Coalition’s  protocol35.  The  assessments 
contribute  to  the  EU  biodiversity  strategy  by  helping 
private  businesses  better  understand  and  value  both 
their  impact  and  dependence  on  nature.  Biodiversity 
platforms  have  been  established  at  EU  level36  and  in  a 
number of Member States. 

Greece has not yet established such a platform. 

Invasive alien species 

Under  the  EU  biodiversity  strategy,  the  following  are  to 
be achieved by 2020:  
(i) invasive alien species identified;  
(ii) priority species controlled or eradicated; and  
(iii)  pathways  managed  to  prevent  new  invasive  species 
from disrupting European biodiversity.  
This  is  supported  by  the  Invasive  Alien  Species  (IAS) 
Regulation, which entered into force on 1 January 2015. 

The grid on Greece’s distribution of invasive alien species 
(IAS) (see Figure 12), which has been verified by Greece, 
shows  that  of  the  37  species  on  the  first  EU  list,  eight 
have been observed in the environment. All eight IAS are 
established  in  Greece,  although  none  is  widespread. 
According to the data, Greece appears to be invaded to a 
lesser  extent  than  its  neighbouring  countries,  but  this 
could  be  due  to  poorer  data  availability,  as  the  listed 
species  were  not  subject  to  surveillance  before  the 
adoption of the EU list. 

31 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 
32 Ecological and Sustainability data journal, The need for the 
implementation of an Ecosystem Services assessment in Greece: 
drafting the national agenda  
33 Biodiversity information System for Europe, MAES-related 
developments in Greece  

34 EU project, Esmeralda  
35 Natural Capital Coalition, Natural Capital Protocol 
36 Business and Biodiversity, The European Business and Biodiversity 
Campaign aims to promote the business case for biodiversity in the EU 
Member States through workshops, seminars and a cross media 
communication strategy. 

12 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Greece37 

Soil protection 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure a  sustainable use of soils.  This  entails preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must  take  into  account  their  direct  and  indirect  impact 
on land use. 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU. 
Figure 12: Proportion of artificial land cover, 2015 38 

Between  the  entry  into  force  of  the  EU  list  and  18  May 
2018,  Greece  had  not  notified  any  new  appearances  of 
IAS  of  EU  concern,  according  to  Article  16(2)  of  the  IAS 
Regulation. 

According  to  the  baseline  distribution,  Greece  is  one  of 
the few Member States with a local population of Indian 
house  crow  (Corvus  splendens)  and  the  species  is  still  in 
in  Europe.  Similarly,  coypu 
early 
(Myocastor coypu) still seems in an early invasion stage in 
Greece. 

invasion  stage 

On  the 
IAS  Regulation,  Greece  has  notified  the 
Commission of its competent authorities responsible  for 
implementation  (Article  24(2)).  It  is  not  yet  clear  how 
Greece  will 
implement  the  provisions  on  penalties 
applicable to infringements (Article 30(4)). 

2019 priority actions 

 

 

 

Swiftly  adopt  national  legislation  to  comply  with 
obligations  required  by  Article  30(4)  of  the  IAS 
Regulation and notify the Commission in this regard. 
Investigate the apparent lack of data and seek ways 
of improving its surveillance system. 
Try to eradicate the species at an early invasion stage 
to avoid considerable long-term management costs. 

Greece’s artificial land coverage is below the EU average 
(3.3  %  vs  4.1 %).  The  population  density  is  82.4/km2, 
which is also below the EU average of 11839. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission40  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 
taking place on approximately 2.8 million sites in the EU. 

37 Tsiamis K; Gervasini E; Deriu I; D`amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

38 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 
39 Eurostat, Population density by NUTS 3 region. 
40 Ana Paya Perez, Natalia Rodriguez Eugenio (2018), Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe” 

13 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

At EU level,  650 000 of these sites have been registered 
in national or regional inventories. 65 500  contaminated 
sites  have  already  been  remediated.  Greece  has  not 
reported  the  national  progress  in  the  management  of 
contaminated sites and brownfields to the working group 
of 
Information  and 
Observation Network (EIONET) that is responsible for this 
matter. 

the  European  Environment 

(Barcelona  Convention)  plays 

For  Greece,  the  Convention  for  the  Protection  of  the 
Marine  Environment  and  the  Coastal  Region  of  the 
Mediterranean 
an 
important  role in achieving goals required by the MSFD. 
These  marine  strategies  comprise  different  steps  to  be 
developed  and  implemented  over  six-year  cycles.  The 
latest  step  required  that  Member  States  set  up  their 
programme  of  measures  and  report  to  the  Commission 
on it by 31 March 2016. 

In  the  case  of  Greece,  the  Commission  could  not  assess 
whether 
its  measures  were  appropriate  to  reach 
GES given that the country reported them too late for the 
Commission to include them in this assessment exercise. 

2019 priority action 

 

Ensure  timely  reporting  of  the  different  elements 
under  the  Marine  Strategy  Framework  Directive  so 
that  Greece  can  be  part  of  future  Commission 
assessments. 

Soil erosion by water is a natural process, but this natural 
process can be aggravated by climate change and human 
activities  such  as  inappropriate  agricultural  practices, 
deforestation,  forest  fires  or  construction  work.  High 
levels  of  soil  erosion  can  reduce  productivity 
in 
agriculture  and  can  have  negative  and  transboundary 
impacts  on  biodiversity  and  ecosystem  services.  High 
levels  of  soil  erosion  can  also  have  negative  and 
transboundary  effects  on  rivers  and 
lakes  (due  to 
increased  volume  of  sediments  and  transport  of 
contaminants).  
According  to  the  RUSLE2015  model41,  Greece  has  an 
average soil loss rate by water of 4.13 tonnes per hectare 
per  year  (t ha−a yr−y),  compared  to  the  EU  mean  of  2.46 
t ha−a yr−y. This indicates that soil erosion in Greece is not 
in  line  with  the  EU  average.  Note  that  these  figures  are 
the  output  of  an  EU-level  model  based  on  rainfall, 
support  practices, 
slope 
characteristics,  and  can  therefore  not  be  considered  as 
locally  measured  values.  The  actual  rate  of  soil  loss  can 
vary strongly  within a Member State depending on local 
conditions. 

soil  and 

cover, 

land 

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. 

Marine protection 

EU coastal and marine policy and legislation require that 
by  2020  the  impact  of  pressures  on  marine  waters  be 
reduced  to  achieve  or  maintain  good  environmental 
status (GES) and ensure that coastal zones are managed 
sustainably. 

The Marine Strategy Framework Directive (MSFD)42 aims 
to  achieve  good  environmental  status  (GES)  of  the  EU’s 
marine  waters  by  2020.  To  that  end,  Member  States 
must develop a marine strategy for their marine waters, 
and cooperate with the EU countries that share the same 
marine (sub)region.  

41 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 
soil loss by water erosion in Europe, (2015) Environmental Science and 
Policy, 54, pp. 438-447. 
42 European Union, Marine Strategy Framework Directive 2008/56/EC 

14 

                                                                 
 
 
Environmental Implementation Review 2019 – Greece 

3. Ensuring citizen’s health and quality of life 

Air quality 

EU clean air  policy and legislation require the significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality  recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  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  air  quality  legislation  and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation43,  which  establishes  health-based 
quality 
standards and objectives for a number of air pollutants. 

The  emission  reductions  between  1990  and  2014 
mentioned  in  the  previous  EIR  continued  between  2014 
and 2016. During this period, emissions of sulphur oxides 
(SOx) fell by 19.74 %, emissions of ammonia (NH3) fell by 
5.52 %,  emissions  of  volatile  organic  compounds 
(NMVOCs)  fell  by  0.17 %,  emissions  of  fine  particular 
matter  PM2.5  fell  by  10.11 %  and  emissions  of  nitrogen 
oxides (NOx) fell by 2.2 % (see Figure 13 on the total PM2.5 
and NOx emissions per sector). 

Despite  the  reduction  in  emissions  since  1990,  the 
country  needs  to  make  additional  efforts  to  meet  its 
emission  reduction  commitments  (compared  with  2005 
levels)  set  by  the  new  National  Emissions  Ceilings 
Directive44 for 2020-2029 and for any year as of 2030. 

At the same time, air quality in Greece continues to be a 
cause  of  concern.  For  2015,  the  European  Environment 
Agency  estimated  that  about  12 000  premature  deaths 
fine  particulate  matter45 
were 
concentrations, over 6 100 to ozone46 concentrations and 
2 300 to nitrogen dioxide47 concentrations48. 

attributable 

to 

Figure 13: PM2.5 and NOx emissions by sector in Greece49 

Greece  has  not  reported  data  on  compliance  with  the 
environmental  objectives  for  2016  and  2017.  For  2017, 
exceedances  related  to  the  annual 
limit  value  for 
nitrogen  dioxide  (NO2)  were  registered  in  1  out  of  4  air 
quality  zones  (Athens)  and  in  1  out  of  4  zones  for  fine 
particulate  matter  (PM2.5).  Exceedances  have  also  been 
registered  related  to  particulate  matter  (PM10)  in  3  (out 
of 4) air quality zones.  

See  Figure  15  on  the  number  of  air  quality  zones 
exceeding NO2, PM2.5, and PM10 levels. 

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201750 

43 European Commission, 2016. Air Quality Standards 
44 Directive 2016/2284/EU 
45 Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to particles with a diameter of 10 (2.5) micrometres or 
less. PM is emitted from many anthropogenic sources, including both 
combustion and non-combustion sources. 
46 Low level ozone is produced by photochemical action on pollution. 
47 NOx is emitted during fuel combustion e.g. from industrial facilities 
and the road transport sector. NOx is a group of gases comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
48 EEA, Air Quality in Europe – 2018 Report, p.64.(Please see details in 
this report as regards the underpinning methodology. 

The  persistent  breaches  of  air  quality  standards  (for 
PM10), which have severe negative effects on health and 
the environment, are being followed up by the European 
in  all 
Commission  through 

infringement  procedures 

49 2016 NECD data submitted by Member State to the EEA. 
50 EEA, EIONET Central Data Repository, Primary data (dataset E1a).  

15 

 
 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Member  States  concerned,  including  Greece.  The  aim  is 
to  ensure  that  adequate  measures  are  put  in  place  to 
bring all zones into compliance. 

The region  of Western Macedonia is participating  in the 
‘Coal Regions in Transition’ initiative. 

According to a special report from the European Court of 
Auditors51,  EU  action  to  protect  human  health  from  air 
pollution has not had its expected impact. There is a risk 
that  air  pollution  is  being  underestimated  in  some 
instances, because it may not always be monitored in the 
right  places.  Member  States  are  now  required  to  report 
both  real-time  and  validated  air  quality  data  to  the 
Commission52. 

2019 priority actions 

 

Take,  in  the  context  of  the  National  Air  Pollution 
Control  Programme 
towards 
reducing the main emission sources - and meet all air 
quality standards. 

(NAPCP),  actions 

  Upgrade  and  improve  the  air  quality  monitoring 
network,  and  ensure  timely  reporting  of  air  quality 
data. 

  Accelerate  the  reduction  of  nitrogen  oxide  (NOx) 
emissions and nitrogen dioxide (NO2) concentrations. 
This  will  require,  for  example,  further  reducing 
transport emissions, particularly in urban areas (and 
may  require  proportionate  and  targeted  urban 
vehicle access restrictions). 

  Accelerate  reductions  in  particulate  matter  (PM2.5 
and  PM10)  emissions  and  concentrations.  This  will 
require,  for  example,  further  reducing  emissions 
from  energy  production  and  heat  generation  using 
solid  fuels,  or  promoting  efficient  and  clean  district 

51 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 
52 Article 5 of Commission Implementing Decision 2011/850/EU of 12 
December 2011 laying down rules for Directives 2004/107/EC and 
2008/50/EC of the European Parliament and of the Council as regards 
the reciprocal exchange of information and reporting on ambient air 
quality (OJ L 335, 17.12.2011, p. 86) requires Member States to provide 
Up-To-Date data. 

heating. 

  Build on the ‘Coal Regions in Transition’ initiative to 
reduce the use of coal for domestic heating to limit 
air pollutant emissions. 

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; and  
(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 Directive53 (IED). 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project54. 

In Greece, around 370 industrial installations must have a 
permit  according  to  the  IED.  In  2015,  the  industrial 
sectors  in  Greece  with  the  most  IED  installations  were 
‘other activities’ (39 % — mostly the intensive rearing of 
poultry  or  pigs,  food  and  drink  production  and  surface 
treatment),  non-hazardous  waste  management  (18 %), 
and minerals (16 %). 

Figure  15:  Number  of  IED  industrial  installations  by 
sector, Greece (2015)55 

53 Directive 2010/75/EU covers industrial activities carried out above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of industrial and agricultural sectors (e.g. intensive rearing of pig and 
poultry, pulp and paper production, painting and cleaning). 
54 European Commission, Industrial emissions policy country profile – 
Greece. 
55 European Commission, Industrial emissions policy country profile – 
Greece. 

16 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

The  industrial  sectors  known  to  be  the  most  harmful  to 
the environment in Greece in terms of air emissions are: 
(i)  ‘energy-power’  for  all  pollutants  except  ammonia 
(NH3)  and  non-methane  volatile  organic  compounds 
(NMVOCs);  (ii)  ‘energy-refining’  for  NMVOCs,  Nickel  (Ni) 
and  Zinc  (Zn)  emissions;  (iii)  ‘minerals’  for  ammonia 
(NH3) and mercury (Hg); and (iv) ‘non-ferrous metals’ for 
chromium (Cr), lead (Pb) and nickel (Ni). There is a lack of 
data  for  emissions  in  ‘other  activities’.  The  breakdown 
per pollutant reported by Greece to the E-PRTR 56 in 2015 
is shown below. 

Figure 16: Emissions to air from IED sectors and all other 
air emissions, Greece (2015) 

BAT  emission  levels  in  environmental  permits,  pollution 
has decreased considerably and continuously in the EU. 

For  example,  by  applying  the  recently  adopted  BAT 
emission levels for large combustion plants, emissions of 
sulphur dioxide will be  cut  on average by between 25 % 
and  81 %,  nitrogen  oxide  between  8 %  and  56 %,  dust 
between 31 % and 78 % and mercury between 19 % and 
71 % at EU level. The extent of the reduction depends on 
the situation in individual plants. 

The  key  challenges  for  the  IED  industrial  sectors  that 
were 
identified  and  discussed  with  the  competent 
authorities are: (i) to reduce emissions in highly polluting 
installations  in  the  energy-power  sector,  including  the 
Agios  Dimitrios  and  the  Kardia  lignite  power  plants;  and 
(ii)  to  address  illegal  landfills  in  the  waste  management 
sector. 

2019 priority actions 

  Review permits to ensure that they comply with the 

 

newly adopted BAT conclusions. 
Strengthen  control  and  enforcement  to  ensure 
compliance with the BAT conclusions. 
in  power  sector 

installations, 
especially in the Agios Dimitrios, Kardia and Amindeo 
lignite power plants. 

  Address  pollution 

Noise 
The  Environmental  Noise  Directive57  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health-related  issues 
in the EU58. 

implementation  of 

the  Environmental  Noise 
The 
Directive  is  significantly  delayed  in  Greece,  based  on  a 
limited  set  of  data59.  The  noise  mapping  for  all 
agglomerations  (i.e.  population  centres  or  places  of 
economic activity), major roads and the major airport has 
not  yet  been  completed  and  neither  have  the  action 
plans for noise management. 

These  instruments,  adopted  after  a  public  consultation 
had  been  carried  out,  should  include  the  measures  to 
keep noise low or reduce it.  

57 Directive 2002/49/EC. 
58 WHO/JRC, 2011, Burden of disease from environmental noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 
World Health Organisation, Regional Office for Europe, Copenhagen, 
Denmark. 
59 European Environment Agency, Noise Fact Sheets 2017. 

Regarding  water  emissions,  energy-power,  energy-
refining,  chemicals  and  metals  were  identified  as  the 
most polluting sectors. The metals sector was the biggest 
producer  of  hazardous  waste,  and  the  energy-power 
sector was the biggest producer of non-hazardous waste.  

The enforcement approach under the IED creates strong 
rights for citizens to have access to  relevant information 
and  to  participate  in  the  permitting  process  for  IED 
installations. This empowers NGOs and the general public 
to  ensure  that  permits  are  appropriately  granted  and 
their conditions respected.  

Best available techniques (BAT) reference documents and 
BAT conclusions are developed through the exchange of 
industrial 
information  between  Member 
associations,  NGOs  and  the  Commission.  This  ensures  a 
good  collaboration  with  stakeholders  and  a  better 
application of the IED’s rules. 

States, 

Thanks  to  the  national  competent  authorities’  efforts  to 
apply the legally binding BAT conclusions and associated 

56 The European Pollutant Release and Transfer Register (EPRTR) is the 
Europe-wide register that provides key environmental data from 
industrial installations in Europe  

17 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

2019 priority actions 

  Complete  the  noise  mapping  and  action  plans  for 

noise management. 

  Complete missing noise maps. 

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  a  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. 

The  existing  EU  water  legislation60  puts  in  place  a 
protective  framework  to  ensure  high  standards  for  all 
water  bodies  in  the  EU  and  addresses  specific  pollution 
sources  (for  example,  from  agriculture,  urban  areas  and 
industrial  activities).  It  also  requires  that  the  projected 
impacts  of  climate  change  are 
into  the 
risk 
corresponding  planning 
management  plans  and  river  basin  management  plans, 
including  programme  of  measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

instruments  e.g. flood 

integrated 

Water Framework Directive 

Greece has adopted and reported the second generation 
of  River  Basin  Management  Plans  under  the  Water 
Framework  Directive,  albeit  with  a  long  delay.  The 
European  Commission  has  therefore  not  yet  conducted 
an assessment and not been able to assess the status and 
development since the first EIR report. 

Nitrates Directive 

from 

sources” 

Following  the  transposition  of  Directive  91/676/EEC  for 
“the  Protection  of  waters  against  pollution  caused  by 
nitrates 
(JMD 
agricultural 
16190/1335/1997),  30  areas  were  defined  as  vulnerable 
to pollution caused by nitrates  from agricultural sources 
zones.  For  7  of  these  vulnerable  zones  (Thessalia  plain, 
Copais  plain,  Argolis  plain,  Pineios  river  basin  in  Ilia, 
Strymonas river basin, Thessaloniki – Pella, Imathia plans, 
Arta-Preveza  plain)  action  plans  are  being  enacted  and 
implemented according to the provisions of the Directive, 

60 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the Nitrates 
Directive (91/676/EEC) and the Floods Directive (2007/60/EC). 

18 

aiming to prevent the undermined degradation of waters 
in  these  areas.  For  the  update  of  existing  and 
development  of  new  action  plans 
for  all  nitrate 
vulnerable zones, and in order to ensure compliance with 
the Directive, and with the ruling of the Court C-149/14, 
a  relevant  project  was  launched  in  April  2017,  in  the 
framework  of  the  Rural  Development  Programme  2014-
2020, and is currently at the final elaboration stage. 

Bathing Water Directive 

In  2017,  out  of  Greece’s  1 598  bathing  waters,  95.9 % 
were of excellent quality, 0.7 % of good quality and 0.1 % 
of sufficient quality (compared to 97.0 %, 0.6 % and 0.1 % 
respectively  in  2016)  (see  Figure  18).  Moreover,  there 
was  no  bathing  water  of  poor  quality61.  Detailed 
information on Greece’s bathing waters is available on a 
national  web  portal62  and  on  an  interactive  map  viewer 
designed  and  hosted  by  the  European  Environment 
Agency63. 
Figure 17: Bathing water quality 2014–201764 

Urban Waste Water Treatment Directive  

Regarding  Greece’s  overall  compliance  with  the  Urban 
Waste Water Treatment  Directive,  100  % of wastewater 
is collected. However, 89.6 % of the load is connected to 
is  treated  through 
collection  systems  and  10.4 % 
individual  or  other  appropriate  systems  (for  instance 
septic  tanks,  storage  units  or 
individual  treatment 
plants).  Among  the  455  agglomerations  reported  on  by 
Greece,  217  are  exclusively  connected  to  individual  or 
other appropriate systems (these have generated a  load 
of  between  2 000  and  28 000  per  population).  The  high 
for  which 
rate  of  connection 

to  such  systems, 

61 European Environment Agency, 2017. European bathing water quality 
in 2016 , p. 17. 
62 Ministry of Environment and Energy, Special Secretariat on Water, 
Bathing water profile  
63 European Environment Agency, State of bathing waters  
64 European Environment Agency, 2018. European bathing water quality 
in 2017, p. 21. 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

is 

lacking,  must  be  considered  when 
information 
analysing the overall compliance. Concerning treatment, 
98.8 % of the wastewater collected undergoes secondary 
treatment  with  99.6  %  undergoing  more  stringent 
treatment. 
An investment of around EUR 1 568 million65 is needed to 
ensure that wastewater in the remaining agglomerations 
is  properly  collected  and  treated.  A  technical  assistance 
project for Greece by the European Commission is under 
way to systematically assess  and strategically reorganise 
the  country’s  investment  needs  for  urban  wastewater 
treatment. 

Floods Directive 

The Floods Directive (FD) established a framework for the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant floods. 

Greece  has  adopted  and  reported  its  Preliminary  Flood 
Risk  Assessments  and  its  Flood  Hazard  and  Risk  Maps 
under  the  FD.  The  first  Flood  Risk  Management  Plans 
were reported by Greece to the European Commission in 
October/November 2018. The European Commission has 
not yet conducted an assessment of the Plans. 

2019 priority actions 

 

Ensure 
timely  adoption  of  next  River  Basin 
Management  Plans  and  Flood  Risk  Management 
Plans in accordance with the Directives. 

  Move  forward  quickly  with  the  preparation  of  new 
the 

fully  compliant  with 

Action  Programmes 
provisions of the Nitrates Directive. 

issue  of 

individual  sanitation  systems, 

  Concerning  urban  wastewater  treatment,  consider 
the 
in 
particular  possible  replacement  with  collecting 
plants  whenever 
systems 
appropriate,  e.g.  in  agglomerations  with  enough 
population density.  

treatment 

and 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse  effects  on  human  health  and  the  environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
substitutes,  including  non-chemical  options,  is  being 
prepared. 

65 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017)749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

19 

legislation66  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market. 

In  2016,  the  European  Chemicals  Agency  published  a 
report  on  REACH  and  the  CLP  Regulation67  that  showed 
that  enforcement  activities  are  still  evolving.  Member 
States  cooperate  closely  within  the  Forum  for  Exchange 
of  Information  on  Enforcement68.  This  cooperation  has 
shown that there is scope to increase the effectiveness of 
enforcement  activities,  particularly 
registration 
obligations  and  safety  data  sheets  where  the  level  of 
non-compliance is still relatively high. 

for 

While progress has been made, there is room to further 
improve and harmonise enforcement activities across the 
EU,  including  controls  on  imported  goods.  Enforcement 
in  some  Member  States,  particularly 
remains  weak 
regarding  controls  on 
imports  and  supply  chain 
obligations.  The  enforcement  architecture  is  complex  in 
most  EU  countries  and  enforcement  projects  reveal 
differences in compliance between Member States. 

A  2015  Commission  study  already  emphasised  the 
importance  of  harmonised  market  surveillance  and 
enforcement  when  implementing  REACH  at  Member 
State  level,  deeming  it  to  be  a  critical  success  factor  in 
the operation of a harmonised single market69. 

In March 2018, the Commission published an evaluation 
of  REACH70.  The  evaluation  concludes  that  REACH 
delivers  on  its  objectives,  but  that  progress  made  is 
slower  than  anticipated.  In  addition,  the  registration 
dossiers are often incomplete. The evaluation underlines 
the need to enhance enforcement by all actors, including 
registrants,  downstream  users  and 
in  particular  for 
importers,  to  ensure  a  level  playing  field,  meet  the 
objectives  of  REACH  and  ensure  consistency  with  the 
actions envisaged to improve environmental compliance 
and  governance.  Consistent  reporting  of  Member  State 
enforcement activities  was considered  important  in that 
respect.  

In  Greece,  the  Ministry  of  Economy  and  Finance  is 
responsible for enforcement. Inspection duties fall to the 
general chemical state laboratory’s environment division. 
Their  experts  must  inspect  companies  that  produce, 

66 Principally for chemicals: REACH (OJ L 396, 30.12.2006, p.1.); for 
Classification, Labelling and Packaging, the CLP Regulation (: OJ L 252, 
31.12.2006, p.1.), together with legislation on biocidal products and 
plant protection products. 
67 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
68 ECHA, on the basis of the projects REF-1, REF-2 and REF-3.  
69 European Commission. (2015). Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs. Brussels: European 
Commission. 
70 COM(2018) 116. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

import  and  distribute  substances,  mixtures  and  articles 
within  the  REACH  framework.  Border  controls  of  goods 
produced  by  these  companies  are  carried  out  by  a 
network  of  GCSL  officials 
trained 
chemists/chemical  engineers)  in  cooperation  with  the 
customs authorities71. 

specially 

(25 

Companies  are  usually  notified  about  upcoming 
inspections.  Inspections  take  place  annually  and  are 
carried out by the GCSL’s regional chemical departments 
in  coordination  with,  and  under  the  supervision  of,  the 
environment division. 

Companies are informed of the inspections’ findings. If a 
company 
is  found  to  be  non-compliant  with  the 
legislation, it receives sanctions according to the national 
legislation. 

Making cities more sustainable 

EU policy on the urban environment encourages cities to 
put  policies  in  place  for  sustainable  urban  planning  and 
design.  These  should  include  innovative  approaches  to 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

living 

in  Europe 

in  urban  areas 

The  population 
is 
projected to rise to just over 80% by 205072. Urban areas 
pose  particular  challenges  for  the  environment  and 
human  health,  but  they  also  provide  opportunities  for 
using  resources  more  efficiently.  The  EU  encourages 
municipalities to become greener through initiatives such 
as  the  Green  Capital  Award73,  the  Green  Leaf  Award74 
and the Green City Tool75. 

Financing greener cities 

Greece  has  indicatively  earmarked  5 %  of  its  European 
Regional Development Fund (ERDF) allocation and 8 % of 
its  European  Social  Fund  (ESF)  allocation  to  sustainable 
urban development76. 

Greece participates in the European Urban Development 
Network  (UDN)77,  which  includes  more  than  500  cities 
across  the  EU  responsible  for  carrying  out  integrated 
actions  based  on  sustainable  urban  development 
strategies financed by ERDF in 2014-2020. 

Of  the  UDN’s 
initiatives,  the  ERDF  supports  urban 
innovative  actions  (UIA)  to  test  new  and  unproven 
solutions for urban challenges. The UIA has a total ERDF 
budget  of  EUR  372  million  for  2014-202078.  Greece  has 
received  funding  for  two  projects  taking  place  in  the 
municipalities of Athens and Heraklion. 

Participation in EU urban initiatives and networks 

Greek  municipalities  are  involved  in  EU  initiatives  on 
environmental protection and climate change. 

A  total  of  15  municipalities  are  involved  in  the  URBACT 
initiative  to  support  sustainable  urban  development 
through  18  different  thematic  networks79.  However,  all 
18  networks  are  currently  led  by  municipalities  in  other 
Member States. 

Several  Horizon  2020  network  projects  have  also 
contributed  to  the  sustainability  of  Greek  cities.  CIVITAS 
includes 46 municipalities and one region in Greece that 
work together for cleaner and better transport in cities80. 

156 Greek cities are also involved in the EU Covenant of 
Mayors  initiative81,  coordinated  by  four  regions,  the 
Centre for Renewable Energy Sources and Saving and the 
Technical Chamber of Greece82. As of July 2018, 15 cities 
have implemented their action plans and are monitoring 
the  results.  Another  106  cities  have  at  least  presented 
their climate action plan and the commitments they aim 
to meet by 2020 or 2030. 

These welcome urban initiatives and networks contribute 
to  a  better  urban  environment.  In  2017,  31.7 %  of  the 
their 
Greek  population 
neighbourhood was affected by pollution, grime or other 
environmental  problems,  up  from  29.9 %  in  2016  and 
30.1 % in 2015. These figures are significantly higher than 
the  EU-28  average  (20 %  in  2017,  18.9 %  in  2016  and 

in  cities  said 

living 

that 

71 ECHA, National Inspectorates – Greece  
72 European Commission, Eurostat, Urban Europe, 2016, p.9. 
73 European Commission, European Green Capital.  
74 European Commission, European Green Leaf Award.  
75 European Commission, Green City Tool.  
76 Greece, Partnership Agreement 2014-2020, 2014, p. 171. 
77 European Commission, The Urban Development Network. 

78 European Commission, Urban Innovative Actions. 
79 URBACT, Associated Networks by country. 
80 European Commission, Horizon 2020 Civitas Project. 
81The Covenant of Mayors for Climate and Energy.  
82 The Covenant of Mayors for Climate and Energy, Covenant 
community.  

20 

                                                                 
  
 
                                                                 
Environmental Implementation Review 2019 – Greece 

19.2 % in 2015)83. 

Nature and cities 

About  7 %  of  Greece’s  Natura  2000  network 
in 
functional urban areas84, which  is below the EU average 
of 15 % (see Figure 19). 

is 

There is a lack of urban green space in Greece. According 
to the World Health Organisation, the ideal ratio of green 
spaces  is  9m2  per 
inhabitant.  The  Organisation  for 
Economic  Cooperation  and  Development  (OECD)  has 
calculated  Athens’  total  green  space  at  0.96  m2  per 
inhabitant,  while  the  Aristotelian  University  calculates 
Greece’s  second  largest  city,  Thessaloniki,  to  be  only 
slightly  better  with  2.14  m2  of  green  space  per 
inhabitant85. 

Figure  18:  Proportion  of  the  Natura  2000  network  in 
Functional Urban Areas (FUA)  

Urban sprawl 

Large parts of Europe are affected by urban sprawl. The 
value  of  WUP  (weighted  urban  proliferation)  for  all  of 
Europe (32 countries considered, i.e. EU-28  +  4) in 2009 
was  1.64  UPU/m2  (where  the  urban  sprawl  values  for 
Europe  ranged  from  0.1  to  6.6  UPU/m2,  with  a  higher 
number  meaning  more  urban  sprawl).  Greece  (0.72 
UPU/m2  in  2009)  is  among  the  five  countries  with  the 
lowest  urban  sprawl  values,  with  an  increase  of  around 
9%  from  2006  to  2009,  while  the  overall  increase  was 
5 %86,87. 

Traffic congestion and urban mobility 

Many  subjects  addressed  in  this  report  are  to  some 
extent  related  to  traffic  volumes  and  congestion, 
especially air quality and noise. 

The  total  number  of  road  vehicles 
in  Greece  has 
increased up to 5.16 million in 2016, a slight but constant 

83 European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 
84 European Commission, Definition of Functional Urban Areas. 
85 Biodiversity Information System for Europe, Country profile Greece  
86 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
87 EEA, Urban Sprawl in Europe, Annex I, 2016, pp.4-5. 

21 

increase  since  201388.  The  amount  of  hours  spent 
annually  by  the  average  driver 
in  road 
congestion has decreased from 37.63 in 2014 to 35.63 in 
2016, which remains one of the highest figures in the EU 
(fourth)89.  

in  Greece 

Athens  and  Thessaloniki  are  the  only  Greek  cities  with 
high  congestion  levels,  between  25  and  50%.  Compared 
to other EU cities, Athens is the 18th most congested city 
(out  of  215  cities  on  the  list),  while  Thessaloniki  is  the 
94th90.  
The modal split for inland passenger transport91 was 81 % 
for cars  (EU-28 83.4 %)  17 %  for buses and trolley buses 
(EU-28  9.1 %)  and  2 %  for  trains  (EU-28  7.6 %)92. 
Therefore,  cars  are  still  the  favoured  mode  of  transport 
for  longer  distances,  with  Greece  having  one  of  the 
highest proportions of passenger transport by bus/trolley 
in the EU. 

Air pollution is partially a consequence of traffic. The age 
of the vehicle fleet is therefore of importance. The Greek 
truck  fleet  consists  of  vehicles  that  are  mainly  old, 
relatively  small  and  purchased  mainly  for  own-account 
activities93.  There  is  as  well  a  high  rate  of  empty  runs 
(33 % of distance travelled compared to 22 % in the EU). 
Moreover,  large  trucks  (over  25.5  tonnes)  account  for 
only  10%  of  the  fleet  in  Greece  and  the  share  of  old 
trucks grew to 30% in 2015 (from 18% in 2008)94. 

Several projects are taking place in the country to tackle 
issues connected to traffic congestion. Some of them are 
aiming at improving the port infrastructures, while others 
are trying to improve road congestion and better connect 
Greece with neighbouring countries95.  

In  terms  of  urban  mobility,  Greece  is  participating  in 
several  projects,  such  as  the  already  mentioned  CIVITAS 
initiative and the Thessaloniki's Urban Mobility Center96. 
The  University  of  Thessaly  organised  the  4th  Conference 
on  Sustainable  Urban  Mobility  in  Skiathos  Island  on  24 
and  25  May  2018,  where  participants  disseminated 
knowledge  and  exchanged  good  practices  in  the  area  of 
urban transportation.  

88 Eurostat, Passenger cars per 1 000 inhabitants, 2018. 
89 European Commission, Hours spent in road congestion annually.  
90 TOMTOM, TOMTOM Traffic Index. 
91 The relation between mode of transport and kilometres travelled 
(excluding bicycles and other alternative methods). 
92 Eurostat, Passenger transport Statistics by modal split. 
93 European Parliament, Traffic and Tourism in Greece, 2018, pp. 1-9.  
94 National Bank of Greece, Survey of Greek SMEs - Land logistics sector, 
Feb 2017, p. 9. 
95 Ministry of Infrastructure and Transport, ITS Progress Report for 
Greece, 2017. 
96 City of Thessaloniki, Thessaloniki's Urban Mobility Center. 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Part II: Enabling framework: implementation tools 

4. Green taxation, green public procurement, environmental funding 
and investments 

Green taxation and environmentally harmful 
subsidies 

incentives, 

Financial 
taxation  and  other  economic 
instruments  are  effective  and  efficient  ways  to  meet 
environmental  policy  objectives.  The  circular  economy 
action  plan  encourages  their  use.  Environmentally 
harmful  subsidies  are  monitored  in  the  context  of  the 
European  Semester  and  the  energy  union  governance 
process. 

in 2016 and budget transfers for allowances amounted to 
over EUR 1.5 billion. 

Figure  19:  Environmental  tax  revenues  as  %  of  GDP 
(2017)101 

revenue 

from  environment-related 

Greece’s 
taxes 
remains  among  the  highest  in  the  EU.  Environmental 
taxes  accounted  for  3.97 %  of  GDP  in  2017  (EU-28 
average  2.4 %)  (see  Figure  20)  and  energy  taxes  for 
3.18 %  of  GDP  (EU  average  1.84 %)97.  In  the  same  year, 
environmental tax revenues in Greece were 9.5 % of total 
revenues from taxes and social security contributions (EU 
average 5.97 %). 

Greece’s  tax  structure  results  in  a  significantly  lower 
proportion  of  revenues  from  labour  tax  in  total  tax 
revenues  than  the  EU  average.  Greece’s  labour  tax 
revenues  were  39.5 %  in  2016,  while  the  implicit  tax 
labour  was  41 %98.  Consumption  taxes 
burden  on 
remained  relatively  high  (38 %,  11th  in  EU-28),  showing 
that there is some potential for shifting taxes from labour 
to consumption, particularly to environmental taxes. 

There  are  examples  of  sound  fiscal  measures  for  the 
environment.  However,  implementation  of  the  relevant 
legislation has been limited in several cases. For example, 
although the landfill tax has  been in place since  January 
2014,  it  had  not  yet  been  implemented  as  of  January 
201899. 

Meanwhile, fossil fuel subsidies increased considerably in 
the  past  decade,  mainly  due  to  a  number  of  public 
programmes  supporting  household  heating  and  power 
generators on remote islands. Other household subsidies 
for  fossil  fuel  use  are  in  place  in  Greece,  along  with 
several  excise  tax  refunds  for  agriculture,  domestic 
shipping, fishing, tourist boats and for the use of coal and 
coke100.  These  exemptions  added  up  to  EUR  260  million 

Greece  has  not  made  progress  on  reducing  the  ‘diesel 
differential’  (difference  in  the  price  of  diesel  versus 
petrol) since 2005. In 2016 there was a remarkable 101 % 
gap between petrol and diesel tax rates, while in 2005 it 
was  only  21 %102.  Tax  rates  on petrol  and  diesel  in  2016 
remained similar to those in  2015 (EUR 0.67 per litre for 
petrol and EUR 0.33 for diesel)103. 

97 Eurostat, Environmental tax revenues, 2018. 
98 European Commission, Taxation Trends Report, 2017. 
99 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Landfill tax in Greece. 
100 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 

101 Eurostat, Environmental tax revenues, 2018. 
102 European Environment Agency 2016, Environmental taxation and EU 
environmental policies, p.27. 
103 European Commission, Taxes in Europe Database, 2018. 

22 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Favourable tax treatment for company cars is not a cause 
for concern in Greece104 and no significant fiscal changes 
were introduced in 2017105. 

CO2-based  motor  vehicle  taxes  are  in  place  in  Greece. 
Vehicle  registration  tax  is  based  on  CO2  emissions  with 
rates  varying  depending  on  the  pollution  levels.  The 
annual  circulation  tax has  also  been  based  on  emissions 
since  2010  and  cars  with  emissions  lower  than  90  g/km 
are exempt106. 

Incentives  to  encourage  people  to  buy  cars  with  lower 
CO2 emissions were common in 2016. These were linked 
to annual circulation taxes, road tolls, congestion or low 
emission  zone  charges  and  to  buying  cleaner  vehicles. 
However,  none  of  the  incentives  was  connected  to  the 
priority  use  of  public  infrastructures107.  New  vehicles 
bought  in  Greece  are  among  the  most  environmentally 
friendly  in  the  EU,  with  average  CO2  emissions  of  106.3 
grams per kilometre (EU average 118 grams in 2016)108.  

The use of alternative fuels in new passenger cars sold in 
Greece  has  decreased  over  the  past  few  years.  In  2016, 
the  proportion  of  new  passenger  cars  using  alternative 
fuels  was  half  that  of  2011109.  On  a  positive  note,  the 
share of battery-powered electric vehicles has increased 
progressively since 2013. 

Green public procurement 

The  EU  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
GDP).  A  substantial  proportion  of  this  money  goes  to 
sectors  with  a  high  environmental 
impact  such  as 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 

104 European Commission, Taxation of commercial cars in Belgium, 
2017, p.3. 
105 FleetEurope, Major changes to company car taxation in Europe. 
106 ACEA, CO2 based motor vehicle taxes in Europe . 
107 European Environmental Agency, Appropriate taxes and incentives 
do affect purchases of new cars, 18 May 2018. 
108 European Environment Agency, Average CO2 emissions from new 
passenger cars sold in EU-28 Member States plus Norway, Iceland and 
Switzerland in 2016. 
109 European Commission, Transport in the European Union Current 
Trends and Issues, 2018, pp.27-28. 

and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria110. 

A  European  Parliament  study  shows  that  Greece’s  GPP 
action plan has been insufficiently implemented111. 

Nevertheless,  some  initiatives  are  taking  place  at  local 
level. Amaroussion was the first municipality in Greece to 
be  registered  under  the  EMAS  scheme  in  2006;  and 
under  ISO  14001:2004  in  2010.  It  also  received  the 
National  EMAS  Award  (2009)  for  applying  green  criteria 
in  its  purchasing  practices.  Public  procurement  criteria 
are amended by the Municipality to purchase goods and 
services  that  are  environmentally  friendly.  Amendments 
are made based on the results of regular market research 
carried out to identify “green” products available on the 
Greek  market;  information  is  then  used  to  develop 
technical specifications112. 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
economic, 
rural 
development and maritime policy. 

social  and 

territorial 

cohesion, 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources113.  Use  of  the  European 
Structural  and  Investment  Funds  (ESIFs)114  is  essential  if 
countries  are  to  achieve  their  environmental  goals  and 
integrate 
into  other  policy  areas.  Other 
instruments such as Horizon 2020, the LIFE programme115 
and the European Fund for Strategic Investments (EFSI)116 
may also support the implementation and spread of good 
practices. 

these 

110 In the Communication ‘Public procurement for a better 
environment’ (COM (2008) 400) the Commission recommended the 
creation of a process for setting common GPP criteria. The basic 
concept of GPP relies on having clear, verifiable, justifiable and 
ambitious environmental criteria for products and services, based on a 
life-cycle approach and scientific evidence base. 
111 European Parliament, Green Public Procurement and the Action Plan 
for the Circular Economy, 2017, pp. 79-80. 
112 European Commission, Collection of Good Practices on GPP, 2012-
2017. 
113 See, for example, Action plan on financing sustainable growth 
(COM(2018) 97).  
114 i.e. the European Regional Development Fund (ERDF), the Cohesion 
Fund (CF), the European Social Fund (ESF), the European Agricultural 
Fund for Rural Development (EAFRD) and the European Maritime and 
Fisheries Fund (EMFF). The ERDF, the CF and the ESF are referred to as 
the ‘cohesion policy funds’. 
115 European Commission, LIFE programme. 
116 European Investment Bank, European Fund for Strategic 
Investments, 2016. 

23 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

European Structural and Investment Funds 2014-2020 

Greece  has  been  allocated  EUR  21.61  billion  from  ESIF 
funds for the period 2014-2020 through 20 national and 
regional  programmes.  This  means  that  with  its  national 
contribution of EUR 4.6 billion, Greece has a total budget 
of  EUR  24.98  billion  to  invest  in  various  areas,  such  as 
creating jobs and growth, increasing the competitiveness 
of  SMEs,  protecting  the  environment,  helping  the 
transition  to  a  low  carbon  economy  and  improving 
transport and energy infrastructure. 

Figure  20:  ESIF  2014-2020  –  EU  allocation  by  theme, 
Greece (EUR billion)117 

Cohesion policy 

In 2014-2020, Greece has been managing 18 Operational 
Programmes  under  EU  cohesion  policy.  Of  these,  13 
regional  programmes  and  two  national  programmes 
receives funding from the ERDF and the ESF; one national 
programme  receive  funding  from  the  ERDF  and  the 
cohesion  fund;  one  national  programme  will  receive 
funding from the ESF; and a national technical assistance 
programme  will  receive  funding  from  the  ERDF,  the  ESF 
and the cohesion fund. 

For  2014-2020,  Greece  has  been  allocated  EUR  16.5 
billion (current prices) in total cohesion policy funding. 

funds  are  a  key  asset 

EU 
environmental  protection 

for  comprehensive 
in  the  EU118.  One  of  the 

117 European Commission, European Structural and Investment Funds 
Data By Country. 
118 ‘The objectives of the ESI Funds shall be pursued in line with the 
principle of sustainable development and with the Union’s promotion 
of the aim of preserving, protecting and improving the quality of the 
environment, as set out in Article 11 and Article 191(1) TFEU, taking 
into account the polluter pays principle’ Article 8, Reg. (EU) No 
1303/2013. 

24 

Commission’s  investment  priorities  for  Greece  in  2014-
2020 is ‘environmental protection and the transition to a 
climate-friendly economy’119. These investments will also 
help the transition towards a circular economy. 

Innovation and the low carbon economy are key areas to 
consider  when  estimating  environmental  spending.  The 
ERDF  and  cohesion  fund  allocate  EUR 1.9  billion  to  the 
low  carbon  economy  as  well  as  EUR  339  million  to 
climate  adaptation  and  EUR  3  billion  to  environmental 
measures120. In addition, around 5 % of the ERDF budget 
is used for sustainable urban development. 

The  ERDF  supports  projects  like  the  extension  of  the 
Athens  metro  network,  which  has  changed  the  face  of 
public  transport  in  the  Capital.  The  metro  extension  has 
reduced  congestion,  cut  traffic  emissions  and  reduced 
traffic  accidents.  It  has  also  upgraded  and  injected  new 
life  into  the  neighbourhoods  next  to  the  new  metro 
stops. 

Rural development 

The  latest  financial  data  available  (relating  to  the  2007-
2013  period)  show  that  the  use  of  rural  development 
allocations  in  Greece  was  92.9%,  lower  than  the  EU 
average (97.3%) 121. 

The EAFRD allocated EUR 4.7 billion to Greece for 2014-
2020. 

On integrating environmental concerns into the common 
agricultural policy (CAP), the two key areas are: (i) to use 
the  rural  development  funds  to  pay  for  environmental 
land  management  and  other  environmental  measures, 
while  avoiding  financing  measures  which  could  damage 
the environment; and (ii) to ensure that the first pillar of 
the CAP is implemented effectively for cross-compliance 
and first pillar ‘greening’. 

On  Pillar  1  of  the  CAP,  30 %  of  the  national  direct 
envelope is allocated to the greening payment. Given the 
prevalence  of  small  farms  and  permanent  crops  in 
Greece, the impact of greening is limited. 

Greece uses around EUR 387 million of its EAFRD funds to 
meet  its  agri-environmental  commitments  and  EUR  600 
million to support organic farming. However, many Greek 
environmental measures remain near the baseline. 

An  additional  EUR  7.5  million  are  used  to  meet  the 
country’s obligations under its Natura 2000 management 
plan.  Greece  should  also  make  the  best  possible  use  of 
rural  development  funds  to  prevent  forest  fires  and 
repair the damage they cause. 

119European Commission, Partnership agreement with Greece - 2014-20  
120 European Commission, Partnership agreement with Greece - 2014-
20 
121 COM/2017/0554. 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

The  Greek  development  programme  (RDP)  outlines  the 
country’s priorities for using the EUR 5.7 billion in funding 
available  for  2014-2020.  This  funding  includes  EUR  4.7 
billion  from  the  EAFRD  and  EUR  1  billion  of  national  co-
funding122. 

A main focus of Greece’s RDP is to preserve and improve 
ecosystems. Of the available funds, 19.20 % will be spent 
on  preserving  the  biodiversity  of  farmland,  18.72 %  on 
improving water management and 25.38 % on improving 
soil management and/or preventing soil erosion. 

The  direct  payment  budget  for  2015-2020  is  EUR  14.9 
billion,  30  %  of  which  is  being  allocated  to  greening 
practices that benefit the environment123. 

European Maritime and Fisheries Fund 

Greece  receives  around  EUR  523  million  in  co-financing 
for  fisheries  and  the  maritime  sector,  including  an  EU 
contribution of EUR 388 million. This has helped finance 
sustainable  fisheries  (Priority  1  of  the  Operational 
Programme)  and  sustainable  aquaculture  (Priority  2) 
measures. Under Priority 1, EUR 186.2 million (35.57 % of 
the  total  Operational  Programme  allocation)  aims  to 
make  the  Greek  fisheries  sector  viable  and  sustainable 
and  to  protect  fishing  and  marine  resources.  Under 
Priority  2,  EUR  89.7  million  (17.15 %  of  the  allocation) 
aims  to  create  environmentally  sustainable,  resource 
efficient,  innovative,  competitive  and  knowledge-based 
aquaculture124. 

The Connecting Europe Facility 

The Connecting Europe Facility (CEF) is a key EU funding 
instrument  developed  specifically  to  direct  investment 
into 
digital 
infrastructures. It aims to address identified missing links 
and bottlenecks and promote sustainability. 

transport, 

European 

energy 

and 

One  CEF-funded  project  in  Greece  is  the  ‘SuperGreen’ 
action,  which  creates 
innovative  and  commercial 
technological systems that increase the use of alternative 
fuels in the country’s shipping sector. The CEF funds 20% 
of  the  project’s  costs,  which  amount  to  EUR  19.7 
million125. 

Horizon 2020 

Greece  has  benefited  from  Horizon  2020  funding  since 
the programme started in 2014. As of January 2019, 815 
participants  have  been  granted  a  maximum  amount  of 
the  Societal 
for  projects 
EUR 224.6  million 

from 

122 European Commission, Rural development 2014-2020: Country files: 
Greece  
123 European Commission, CAP in Greece, 2017. 
124 European Commission, European Maritime and Fisheries Fund, 
Country files 
125 European Commission, The Connecting Europe Facility, SuperGreen’ 
action.  

25 

Challenges 
environmental issues126 127.  

work 

programmes 

dealing 

with 

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  Greece,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  231  million  destined  to 
climate  action  (26.2 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  30  million  for 
biodiversity-related  actions  (3.4 %  of  the  Horizon  2020 
contribution to the country)128. 

LIFE programme 

Since  its  launch  in  1992,  the  LIFE  programme  has  co-
financed  a  total  of  240  projects  in  Greece  at  a  total 
investment of EUR 327 million. The EU provided EUR 175 
million  of  this  amount.  Of  these  projects,  153  have 
focused  on  environmental  innovation  (under  the  LIFE 
environment  and  resource  efficiency  priority)  and  70  on 
nature  conservation  (under  the  nature  and  biodiversity 
priority). 

For  2014-2017  the  EU  has  allocated  EUR  24  million  to 
Greek  projects129.  One  of  them  is  entitled  ‘ForestLife’. 
With  a  requested  EU  contribution  of  around  EUR  1 
million130, this project aims to build cooperation, develop 
skills  and  share  knowledge  for  Natura  2000  forests  in 
Greece. Other examples include a project to develop and 
demonstrate  a  waste  prevention  tool  to  support  local 
authorities  (the  ‘WASP’  tool)  and  a  project  to  improve 
in  the  Kastoria  prefecture 
bear-human  coexistence 
(ARCTOS/KASTORIA)131. 

European Investment Bank 

In 2013-2017, EIB financing in Greece totalled EUR 7 869 
billion.  Of  this,  EUR  72.7  million  went  towards  waste 
management  and  EUR  95.5  million  towards  water  and 
sewerage  projects132.  In  2018  alone,  the  EIB  group  (the 
European Investment Bank and the European Investment 
Fund)  loaned  Greek  businesses  and  public  institutions 

126 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
127 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
128 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 
129 Commission services based on data provided by EASME. 
130 European Commission, LIFE ForestLife. 
131 European Commission, Life Programme, LIFE by country : Greece. 
132 European Investment Bank, The European Investment Bank in 
Greece 2013-2017. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

EUR 1.87 billion, as shown in Figure 22. Of this, EUR 91.5 
million (5 %) went to environmental projects133. 
Figure 21: EIB loans to Greece in 2018 134 

European Fund for Strategic Investments 

The  EFSI  is  an  initiative  to  help  overcome  the  current 
investment gap in the EU. The EFSI has mobilised EUR 2.7 
billion  in  Greece  as  of  January  2019.  The  secondary 
investment  triggered  by  those  funds  is  expected  to  be 
EUR 11.1billion135. 

National environmental financing 

Greece  spent  EUR  2  752  billion  on  environmental 
protection in 2016, an increase of 8 % from 2015136. 41 % 
of these payments were for waste management activities 
(the  annual  average  percentage  of  environmental 
spending  allocated  to  waste  management  in  the  EU  is 
49.7 %).  EUR  256  million  was  allocated  to  wastewater 
management (9 % of the total) and EUR 1.327 billion was 
allocated to reducing pollution (48 % of the total). EUR 2 
million  of  environmental  expenditure  was  allocated  to 
protecting biodiversity and the landscape (0.1 % of total). 
Between  2012  and  2016,  the  general  government 
funding  for  environmental  protection  was  EUR  13.1 
billion137. 

As it has been mentioned throughout the report, one of 
the  main  challenges  for  Greece 
is  to  ensure  that 
environmental  financing  remains  at  an  adequate  level. 
Existing financial gaps in areas such as nature protection 
are  delaying 
implementation  of  EU 
environmental  law  and  policies.  Therefore,  ensuring 
financial  resources  to  reduce  the  implementation  gap 
should be considered a priority for the country. 

the  correct 

2019 priority action 

 

Secure efficient use of available EU funds for nature 
the  Prioritised  Action 
conservation,  based  on 
Framework (PAF). 

133 European Investment Bank, Greece and the EIB  
134 EIB, Greece and the EIB, 2018. 
135 EIB, EFSI project map. 
136 Eurostat, General Government Expenditure by function, 2018. 
137 Eurostat, General Government Expenditure by function, 2018. 

26 

 
                                                                 
 
 
Environmental Implementation Review 2019 – Greece 

5. Strengthening environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  
(i) access to information;  
(ii) public participation in decision making; and  
(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and  business  that  environmental  information  is  shared 
efficiently  and  effectively138.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment139. It includes the right to bring 
legal challenges (‘legal standing’)140. 

Environmental information 

system 

for  providing 
Greece  has  a  centralised 
environmental  data.  The  Ministry  of  Environment  and 
Energy’s  portal141 
is  the  main  portal  for  all  such 
information.  Information  on  chemicals  and  industrial 
emissions  is  missing  from  the  national  portals  and 
metadata  and  historical  datasets  on  EU  environmental 
legislation  are  not  available.  Data  on  the 
INSPIRE 
specifications  is  only  available  on  the  INSPIRE  portal, 
which  is  linked  to  the  environment  portal.  Regarding 
usability, most of the available information can be found 
by using the search function. 

Greece’s implementation of the INSPIRE Directive leaves 
room  for  improvement.  The  country’s  performance  has 
been  reviewed  based  on 
implementation 
report142  and  its  most  recent  monitoring  data  from 
2016143. (Greece was late in providing monitoring results 
for 2017). Greece needs to make more effort to identify 
and  document  spatial  data  and  to  make  the  data 

its  2016 

138 The Aarhus Convention, the Access to Environmental Information 
Directive 2003/4/EC and the INSPIRE Directive 2007/2/EC together 
create a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
139 The guarantees are explained in Commission Notice on access to 
justice in environmental matters, OJL 275, 18.8.2017 and a related 
Citizen’s Guide. 
140 This EIR looks at how well Member States explain access to justice 
rights to the public, and at legal standing and other major barriers to 
bringing cases on nature and air pollution. 
141 The Ministry of Environment and Energy’s portal  
142 INSPIRE EL country sheet 2017. 
143 INSPIRE monitoring dashboard 

accessible  through  services.  Greece  also  needs  to  make 
more  effort  to  prioritise  environmental  datasets  in  the 
implementation  of 
In 
particular,  it  needs  to  prioritise  datasets  identified  as 
high-value spatial datasets144. 

environmental 

legislation. 

Figure  22:  Access  to  spatial  data  through  view  and 
download services in Greece (2017)  

Public participation 

are 

legal  acts  related  to  public 
In  Greece,  the  main 
participation 
(OGJ 
3422/2005 
Law 
303A/13.12.2005)145, Law 4014/2011 and 4042/2012 and 
the  Joint  Ministerial  Decision  (JMD)  1649/45/2014  (OJG 
45B/15.01.2014). Together they implement the different 
pillars  of  the  Aarhus  Convention. 
In  practice,  two 
information  on  public 
platforms  provide  centralised 
participation:  (i)  the  ‘Open  Governance’  website146  on 
public  consultations;  and  (ii)  the  digital  environmental 
register (DER)147 where the public can see files submitted 
online  by  permit  applicants  with  all  the  necessary 
background data. Unfortunately, the DER is still not fully 
operational,  preventing  the  public’s  access  to  the 
necessary  information  and  impeding  the  participatory 
process148. 

The Eurobarometer  figures  from 2017  show that people 
in  Greece  agree  strongly  (88 %  of  respondents)  that  an 
individual can play a role in protecting the environment. 
This is the same as the 2014 Eurobarometer. 

Access to justice 

While  Greece’s  Ministry  of  Energy  and  Environment 
(MoEE)  website  provides  general  information  on  the 
public’s  right  to  access  to  justice,  the  site  is  not  user-
friendly. 

144 European Commission, List of high value spatial data sets 
145 Law 3422/2005 (OGJ 303A/13.12.2005). 
146 Ministry of Administrative Reform and E-Governance, Open 
government web portal  
147 The Hellas Republic, The digital environmental register  
148 WWF Hellas (2017), General remarks on the implementation of the 
Aarhus Convention, in Greek 

27 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Greece 

Greece  has  liberal  standing  rules  and  the  Council  of 
State’s  case-law  has 
long  been  considered  to  be 
pioneering  on  environmental  protection.  There  are  no 
significant  barriers  to  bringing  nature  or  air  pollution 
cases before the court. 

2019 priority actions 

 

Improve  access  to  spatial  data  and  services  by 
making  stronger  links  between  the  central  INSPIRE 
website and regional portals. Identify and document 
all  spatial  datasets  required  for  the  implementation 
law149.  Make  the  data  and 
of  environmental 
documentation  at  least  accessible  ‘as  is’  to  other 
public  authorities  and  the  public  through  the  digital 
services set out in the INSPIRE Directive. 

  Better inform the public about their rights to access 
to  justice,  notably  in  relation  to  air  pollution  and 
nature. 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste150.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion151;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring152; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement153.  
Citizen  science  and  complaints  enable  authorities  to 
liability154 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring  

Online information is given to farmers on how to comply 
with  obligations  on  nitrates  and  nature.  The  quality  of 
indicator  of  how  actively 
this 
authorities  promote  compliance  in  areas  with  serious 
implementation gaps. In Greece, there is a general lack of 

information 

is  an 

149 European Commission, INSPIRE. 
150 The concept is explained in detail in the Communication on ‘EU 
actions to improve environmental compliance and governance’ 
COM(2018)10 and the related Commission Staff Working Document, 
SWD(2018)10. 
151 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
152 This EIR focuses on inspections of major industrial installations. 
153This EIR focuses on the availability of enforcement data and co-
ordination between authorities to tackle environmental crime. 
154 The Environmental Liability Directive 2004/35/EC, creates the 
framework. 

online practical information targeted at farmers on these 
subjects. 

industrial 

inspect  these 

Major 
installations  can  present  serious 
pollution  risks.  Public  authorities  are  required  to  have 
plans  to 
installations  and  to  make 
individual  inspection  reports  available  to  the  public155. 
The 
‘National  Plan  and  Programme  of  Regular 
Environmental Inspections’ (June 2017) identified a total 
of  1 291 
industries  across  the  country  subject  to 
environmental  inspections.  It  also  defined  the  specific 
features  of  the  inspection  programme  to  be  applied  in 
2017 and 2018 (and the years to come). 

Citizen science and complaint handling 

Engaging  the  general  public  through  citizen  science,  can 
promote knowledge about the environment and help the 
authorities in their work. No online information could be 
found about the use of citizen science in Greece. 

The availability of clear online information about how to 
make  a  complaint  is  an  indicator  of  how  responsive 
authorities  are  to  complaints  from  the  public.  The 
government  does  not  have  a  dedicated  website  which 
information  on  how  to  file  environmental 
provides 
complaint-handling 
the 
complaints. 
mechanism is fragmented and it is difficult for citizens to 
know  whom  to  address,  although  some 
individual 
authorities do provide information. 

addition, 

In 

Enforcement 

appropriate. 

identifies  problems,  a  range  of 
When  monitoring 
The  Hellenic 
be 
responses  may 
Environmental Inspectorate’s annual reports include data 
on  the  outcomes/results  of  inspections,  any  significant 
fines 
information  on  the 
prosecution  of  environmental  crimes  and  on  the  follow-
up  to  cross-compliance  breaches  on  nitrates  and  nature 
is lacking. 

imposed.  However,  wider 

is  especially  challenging. 

Tackling  waste,  wildlife  crimes  and  other  environmental 
It  requires  close 
offences 
cooperation  and  coordination  arrangements  between 
inspectors,  customs  authorities,  police  and  prosecutors. 
Although  Greek 
inspectors,  police  and 
prosecutors a potential role in combating environmental 
crime,  there  is  no  information  available  on  the  practical 
arrangements for their cooperation and coordination. 

law  gives 

Environmental liability 

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 
prevent  and  remedy  environmental  damage.  The  2017 

155 Article 23, Industrial Emissions Directive, 2010/75/EU. 

28 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

focused  on  gathering  better 

information  on 
EIR 
environmental  damage,  on 
financial  security  and 
guidance.  The  Commission  is  still  collecting  evidence  on 
the progress made. 

2019 priority actions 

 

  Better inform the public about ensuring compliance, 
monitoring  and  enforcement.  At  a  minimum  this 
should involve: (i) ensuring that practical information 
for Greek farmers on how to comply with obligations 
on  nitrates  and  nature  is  available  online;  and  (ii) 
providing  better  online  information  to  citizens  on 
where and how to submit environmental complaints;  
Publish  more 
information  on  the  outcomes  of 
criminal enforcement action and on the follow-up to 
detected cross-compliance breaches on nitrates and 
nature. 
Provide more information on the practical aspects of 
cooperation  and  coordination  between  inspectors, 
police,  prosecutors 
combat 
environmental crime. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

and  others 

to 

 

 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

environmental 
Those 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other  within  a  system  of  multi-level 
governance. 

is 
The  Ministry  of  Environment  &  Energy  (MoEE) 
responsible for producing a  global environmental policy, 
preparing  plans  and  programmes  and  monitoring  them. 
The  Ministry 
in  charge  of  transposing  EU 
environmental Directives into national law. 

is  also 

At  the  decentralised  level,  the  regional  and  municipal 
authorities  have  certain  environmental  competences  for 
their  geographical  areas.  Regional  and  municipal 
authorities  assure  the  practical  application  of  various 
environmental  measures  such  as  water  quality,  waste 
management  and  impact  assessments.  At  the  central 
level  an  environmental  inspectorate  has  been  operating 
since 2004. 

Meeting  the  deadlines  and  requirements  set  in  the  EU 
environmental  legislation  still  seems  to  be  an  issue  of 

concern.  Difficulties  can  be  explained  by  relatively  few 
(and decreasing in recent years) human resources to deal 
with  the  huge  body  of  EU  environmental  legislation, 
combined  with  the  bottlenecks  created  by  lengthy  and 
complicated  administrative  procedures  which  often 
involve  many  actors  from  various 
levels  of  public 
administration. 

The number of open infringement  cases is  very high  (23 
infringement cases, of which  12 are at 258 stage and 11 
are  at  260  stage).  In  general,  there  are  no  significant 
problems  on  the  quality  of  the  transposition  of  the  EU 
Directives.  The  problems  are  generally  related  to  their 
implementation.  The  Court  of  Justice  has  imposed  fines 
on Greece for non-compliance with EU law provisions in 
fields  of  solid  waste  and  urban  wastewater 
the 
treatment.  Penalty  payments  remain  due  as  long  as  the 
judgments  of  the  Court  are  not  fully  executed  by  the 
Member State. 

Coordination and integration 

Environmental 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised 
(EIA) 
Directive156  provides  an  opportunity  for  countries  to 
streamline their regulatory framework on environmental 
assessments. Greece  has  fully  transposed  the  revised 
Directive, despite not meeting the deadline of May 2017.  

Impact  Assessment 

the 

streamlining  of 
The  Commission  encourages 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps 
for 
projects.  Streamlining  helps  to  reduce  unnecessary 
It  also  accelerates  decision 
administrative  burden. 
making,  without  compromising  the  quality  of  the 
environmental  assessment  procedure157.  Greece  has 

in  environmental  assessments 

156 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 
157 The Commission issued a guidance document in 2016 regarding the 
setting up of coordinated and/or joint procedures that are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive, Water Framework Directive, and the Industrial Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 

29 

 
                                                                 
Environmental Implementation Review 2019 – Greece 

started  streamlining  environmental  assessments  under 
the  EIA  Directive,  the  Habitats  Directive  and  the 
Industrial Emissions Directive.  

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

large  or  small, 

Since 1 October 2010, all Ministries, administrations and 
public  authorities  must  upload  every  administrative  act 
— 
including  appointment  decisions, 
awards  of  grants,  transfers  of  personnel,  decisions  on 
state 
the 
‘http://diavgeia.gov.gr’  website,  through  the  ‘Diavgeia’ 
(‘Clarity’)  transparency  programme.  Clarity  is  one  of  the 
Ministry 
Administrative 
Interior 
Reconstruction’s major transparency initiatives. 

subsidies 

citizens, 

etc., 

and 

the 

on 

to 

of 

for 

Recently  introduced  electronic  services  are  used  during 
the  public  consultation  processes  and 
filing 
complaints.  Examples  of  electronic  services  include:  (i) 
web  platforms  used  by  the  special  secretariat  for  water 
(EGY)  of  the  MoEE  during  the  consultation  process  for 
Greece’s river basin management plans and the flood risk 
management  plans;  (ii)  the  ‘Open  Governance’  website 
where citizens can be informed about  and participate in 
(iii)  the  digital  environmental 
public  consultations; 
registry  (DER)  platform;  (iv)  the  website  on  approved 
environmental  permits  (AEPO);  and  (v)  the  Region  of 
Attica’s online platform for submitting complaints. 

In the DESI Report 2018, Greece had a score of 40 out of 
100 on digital public services, lower than the EU average 
of 58158. 

Enabling financing and effective use of funds 

Information  on  public  funding  opportunities  to  improve 
the  environment  is  published  on  the  ‘green  growth’ 
section of the MoEE’s website and on the financial tools 
webpage.  Funding  opportunities  are  also  publicised  on 
the  Green  Fund’s  and  the  NSRF’s  websites.  Funding  is 
applicable  for  all  seven  environment  areas.  Information 
on EU projects is also published in various places, such as 
the MoEE website, the Greek task force LIFE programme 
website and the Greek INTERREG website.  

2019 priority actions 

 

Simplify  environmental  administrative  procedures 
and improve cooperation between public authorities 
(at  national,  regional  and  local  levels)  involved  in 
applying environmental policies. 

  Greece can further improve its overall environmental 
governance 
citizen 
as 
engagement,  compliance  and  enforcement,  as  well 
as administrative capacity and coordination). 

transparency, 

(such 

International agreements 

The  EU  Treaties  require  the  EU  environmental  policy  to 
promote  measures  at  international  level  to  deal  with 
regional or worldwide environmental problems. 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 
Assembly  in  May  2018159.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
laws and international agreements.  

Currently,  Greece  has  signed  but  not  yet  ratified  a 
number of treaties, namely: 

- 

- 

- 

- 

- 

- 

- 

in 

to 

and 

diversity 

biological 

the  Barcelona 

integrated  coastal  zone 

the  offshore  protocol 
Convention; 
the  protocol  concerning  Specially  Protected 
Areas 
the 
Mediterranean; 
the  protocol  on 
management; 
three  agreements  under  the  Convention  on 
Long-range Transboundary Air Pollution160; 
the  Kiev  protocol  on  Pollutant  Release  and 
Transfer Register; 
the  African-Eurasian  Migratory  Water  bird 
Agreement; and 
the  Protocol  on  Strategic  Environmental 
Assessment to the Espoo Convention. 

Moreover,  Greece  has  not  signed  or  ratified  the 
International Convention for the Regulation of Whaling. 

Forests:  EU  Timber  Regulation  (EUTR)161/  Forest  Law 
Enforcement,  Governance 
(FLEGT) 
Regulation162 

Trade 

and 

158 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 

159 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  
160Namely: the Gothenburg Protocol to Abate Acidification, 
Eutrophication and Ground-level Ozone; the Persistent Organic 
Pollutants Protocol; and the Heavy Metals Protocol. 

30 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Greece 

Between March 2015 and February 2017, Greece carried 
out  88 %  of  the  237  checks  that  were  planned  for 
operators of domestic timber, and 85 % of the 86 checks 
planned for operators importing timber. This is relatively 
low  when  compared  to  the  estimated  1  930  Greek 
operators placing domestic timber on the EU market and 
the  604 
in  Greece 
importers  of  timber.  Although 
infringements  of 
the  EUTR  are  punishable  by 
imprisonment,  with  a  potential  10  year  prison  sentence 
for 
illegal  timber,  no  such 
penalties have been issued to date against operators that 
breach the rules. 

individuals  transporting 

On cooperation (Article 12 of the EUTR), Greece reports 
to have collaborated both with its competent authorities 
and  with  EU  institutions.  It  currently  participates  in  the 
Mediterranean network on EUTR implementation. 

Experts from the EUTR competent authority participated 
in  a  TAIEX-EIR  Peer  2  Peer  workshop  to  strengthen 
cooperation among the competent authorities from eight 
Mediterranean  EU  countries.  The  aim  was  to  improve 
and  harmonise  the  implementation  of  the  EUTR  in  the 
Mediterranean region. Experts from the Netherlands and 
Denmark shared their experiences from the Nordic-Baltic 
network of EUTR competent authorities. 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)163  

Despite  the  provisions  of  the  EU  ABS  Regulation,  which 
transposes the required compliance measures under the 
Nagoya  Protocol 
law,  Greece  has  still  not 
appointed  competent  authorities  for  genetic  resources. 
Furthermore,  it  has  not  laid  down  rules  for  penalties  or 
submitted the mandatory reports. 

into  EU 

the  Convention  on 
trade: 
International  wildlife 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)164 

In  line  with  the  obligations  laid  down  in  the  Basic 
Regulation165  which  transposes  the  major  obligations  of 

161 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010 
162 Regulation (EC) No 2173/2005 of 20 December 2005 on the 
establishment of a FLEGT licensing scheme for imports of timber into 
the European Community. 
163 Regulation (EU) No 511/2014 of the European Parliament and of the 
Council of 16 April 2014 on compliance measures for users from the 
Nagoya Protocol on Access to Genetic Resources and the Fair and 
Equitable Sharing of Benefits Arising from their Utilisation in the Union 
Text with EEA relevance. 
164 The Convention on International Trade in Endangered Species of 
Wild Fauna and Flora (CITES). 
165 Council Regulation (EC) No 338/97 on the protection of species of 
wild fauna and flora by regulating trade therein. 

the  Convention  on  International  Trade  in  Endangered 
Species  of  Wild  Fauna  and  Flora  (CITES)  into  EU  law, 
Greece has established relevant national authorities and 
is processing (requests for) import, (re-) export and intra-
EU trade documents on a regular basis. 

Reports  on  seizures  of  illegal  wildlife  shipments  (in 
particular  those  reported  every  6  months  to  TRAFFIC 
under  its  contract  with  the  Commission,  and  those 
exchanged  through  the  EU-TWIX  platform),  show  the 
activity of customs authorities. To ensure the action plan 
is  fully  implemented,  Greece  has  published  national 
guidelines to help enforcement officers with their checks, 
especially with identifying protected species. 

2019 priority action 

 

Increase  efforts  to  sign  and  ratify  the  remaining 
relevant multilateral environmental agreements. 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
helps  to 
legislation  and 
policies. 

implement  environmental 

The  first  National  Sustainable  Development  Strategy 
(NSDS) was adopted by the Council of Ministers in 2002. 
In 2010, the “Program of Development Interventions for 
the  Real  Economy”  was  elaborated,  aligned  with  the  EU 
“Europe  2020”  Strategy,  with  a  focus  on  resource 
efficiency  and  the  shift  to  a  low  carbon  economy  that 
served,  until  2013,  as  the  country’s  strategic  reference 
for sustainable development, but not as an NSDS.  

Since  December  2016,  with  regard  to  the  SDGs 
implementation at national level,  the competent  central 
authority  for  the  coordination  and  monitoring  of  the 
implementation of the SDGs is the Office of Coordination, 
Institutional,  International  and  European  Affairs  of  the 
General Secretariat of the Government (GSG) (as defined 
Inter-
in  Article  43  of  Law  4440/2016).  An  active 
ministerial Coordination Network for the SDGs has been 
re-establish  under  the  coordination  of  the  GSG  which 
meets  rather  frequently  contributing  thus  to  horizontal 
and vertical integration of the SDGs across policy-making 
activities of all line Ministries.  

Greece presented for the first time its National Voluntary 
review  of  the  implementation  of  the  SDGs  at  the  UN 
HLPF in July 2018166. 

The  2018  VNR  report  of  Greece  covers  all  17  Goals 
through eight National Priorities for adapting the SDGs to 

166The Hellenic Republic, National review on the implementation of the 
2030 agenda for sustainable development  

31 

                                                                                                        
 
                                                                 
Environmental Implementation Review 2019 – Greece 

national  needs  and  circumstances,  also  in  line  with  the 
recently adopted National Growth Strategy: 

 

 

Fostering  a  competitive,  innovative  and  sustainable 
economic growth (linked to SDG 9) 
Promoting  full  employment  and  decent  work  for  all 
(linked to SDG 8) 

entrepreneurs;  (ii)  public  and  private  sector  employees; 
and  (iii)  other  categories  of  interests  groups  such  as 
farmers, self-employed people, professionals, consumers, 
environmental agencies, disabled people's confederation, 
gender equality and multi-child associations, and regional 
and local government.  

  Addressing  poverty  and  social  exclusion,  and 
providing  universal  access  to  quality  health  care 
services (linked to SDGs 1, 2, 3) 
  Reducing  social  and  regional 

inequalities  and 
ensuring  equal  opportunities  for  all  (linked  to  SDGs 
5, 10) 
Providing high-quality and inclusive education (linked 
to SDG 4) 
Strengthening 
sustainable 
management  of  natural  capital  as  a  base  for  social 
prosperity  and  transition  to  a  low-carbon  economy 
(linked to SDGs 6, 7, 11, 12, 13, 14, 15) 

the  protection  and 

 

 

  Building  effective,  accountable  and  transparent 

 

institutions (linked to SDGs 16, 17)  
Enhancing  open,  participatory,  democratic  process 
and promoting partnerships (linked to SDGs 16, 17)  

These  eight  overarching  National  Priorities  have  been 
defined in an open dialogue within all government  units 
and  with  a  wide  array  of  stakeholders,  through  an  in-
depth mapping exercise carried out in 2017. 

implementation, 

With regard to data and indicators for the monitoring of 
the  SDGs 
the  Hellenic  Statistical 
Authority  (ELSTAT)  as  coordinator  of  the  Hellenic 
Statistical System (ELSS) is responsible for the production 
of official statistics in Greece in this regard. As a national 
set  of  indicators  particularly  for  the  implementation  of 
the  SDGs  has  not  yet  been  developed,  the  national 
statistical Annex of the VNR Report of Greece, is based on 
the 100 indicators (from the overall 232 indicators of the 
global SDG indicators’ framework) measured by Eurostat 
(Sustainable  Development 
in  the  European  Union: 
Monitoring  Report  on  Progress  towards  the  SDGs  in  an 
EU  context,  Eurostat,  November  2017)  presenting  the 
most relevant ones for Greece. 

in 

the 

actively 

engaged 

With  regard  to  stakeholders' 
involvement,  the  GSG 
encourages  and  facilitates  consultation  with  multiple 
SDGs 
stakeholders 
implementation  process,  including  regional  and  local 
authorities.  In  particular,  an  ongoing  dialogue  is  taking 
place  with  some  of  the  major  national  stakeholders, 
through  the  platform  provided  by  the  Economic  and 
Social  Council  of  Greece  (ESC),  the  constitutionally 
recognized  institution  for  conducting  social  dialogue  in 
Greece.  The  ESC  is  working,  following  the  model  of  the 
European Economic and Social Committee (EESC), on the 
basis of a tripartite structure representing the interests of 
three  main  groups  involved,  directly  and  indirectly,  in 
achieving  the  SDGs  at  different  levels:  (i)  employers-

32