COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2022 Country Report - GREECE Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Greece, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 254 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2022    Country Report - GREECE         Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions The EU Environmental Implementation Review 2022: Turning the tide through environmental compliance     {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Greece  1 

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

More information on the European Union is available at http://europa.eu. 

Photographs:  

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

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Table of Contents 

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

PART I: THEMATIC AREAS ...................................................................................................................................... 5 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 5 
Measures towards a circular economy ................................................................................................................ 5 
Waste management ............................................................................................................................................. 7 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 10 
Nature protection and restoration ..................................................................................................................... 10 
Marine ecosystems............................................................................................................................................. 16 
Ecosystem assessment and accounting ............................................................................................................. 17 
3. ZERO POLLUTION ..................................................................................................................................................... 19 
Clean air ............................................................................................................................................................. 19 
Industrial emissions ............................................................................................................................................ 20 
Prevention of major industrial accidents – SEVESO ........................................................................................... 22 
Noise .................................................................................................................................................................. 23 
Water quality and management ........................................................................................................................ 24 
Chemicals ........................................................................................................................................................... 27 
4. CLIMATE ACTION ..................................................................................................................................................... 29 
Key national climate policies and strategies ...................................................................................................... 29 
Effort sharing target ........................................................................................................................................... 30 
Key sectoral developments ................................................................................................................................. 30 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 32 

5. FINANCING ............................................................................................................................................................. 32 
Environmental investment needs in the EU ....................................................................................................... 32 
EU environmental funding  2014-2020 .............................................................................................................. 33 
EU environmental funding 2021-2027 ............................................................................................................... 35 
National environmental protection expenditure ................................................................................................ 37 
Green budget tools ............................................................................................................................................. 38 
Overall financing compared to the needs .......................................................................................................... 40 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 41 
Information, public participation and access to justice...................................................................................... 41 
Compliance assurance ........................................................................................................................................ 42 
Effectiveness of environmental administrations ................................................................................................ 44 
Reforms through the Commission’s Technical Support Instrument ................................................................... 45 
TAIEX Peer to Peer Projects ................................................................................................................................ 45 

Environmental Implementation Review 2022 – Greece 

 
 
 
Greece  3 

Executive summary

In  previous  Environmental 
Implementation  Reviews 
(EIRs),  the  main  challenges  identified  for  Greece  for  the 
implementation  of  EU  environmental  policy  and  law 
were: 

 

 

 

to  address  waste  management  issues,  in  particular 
the  closure  of  illegal  landfills  and  the  treatment  of 
hazardous waste; 
to  improve  nature  protection  by  putting  in  place  an 
efficient 
raising 
protection 
incentives  for 
awareness  and  creating  the  right 
sustainable investments;  
to complete the implementation of the Urban Waste 
Water Treatment Directive; 
 

national 

system, 

its  environmental  administrative 
to  simplify 
structures  and  procedures,  which  can  cause 
significant  delays  and  bottlenecks,  while  at  the 
same  time  strengthening 
its  administrative 
capacity,  that  sometimes  turn  out  to  be  the 
main  obstacles  to  implementing  environmental 
legislation. 

Greece  still  faces  major  structural  problems  with  waste 
limited  progress  has  been 
management  and  only 
recorded. 
increasing 
  Waste  generation  has  been 
somewhat,  while  recycling  rates  have  improved  only 
marginally.  While  the  national  waste  management  plan 
has  been  updated,  the  regional  plans,  which  are 
necessary for implementating waste management  policy 
on the ground, have been significantly delayed.  

The number of illegal landfills  in operation or in need of 
rehabilitation  has  continued to  decrease  over  the  years. 
However,  the  remaining  illegal  landfills  will  be  very 
difficult  to  close  unless  new  facilities  are  built,  while 
keeping  in  mind  that  an  overcapacity  of  treatment 
facilities  of  residual  waste  will  not  help  Greece’s 
transition towards a circular economy. Greece has to step 
up  its  efforts  to  put  in  place  an  adequate  network  of 
facilities that would effectively manage all the hazardous 
waste  produced  in  the  country.  In  addition,  treatment 
facilities and the separate collection of waste streams in 
the  country  are  insufficient  and  most  organic  waste  is 
landfilled  without  prior  stabilisation.  The  Commission 
therefore initiated in November 2021 a new infringement 
procedure  against  Greece  for  failing  to  comply  with  the 
Landfill Directive  and the Waste Framework Directive.  

legal  and 
Some  progress  has  been  made  on  the 
institutional steps necessary  to increase waste recycling, 
notably  with  the  introduction  of  a  new  landfill  tax1  in 

national  legislation,  outlined  in  the  waste  management 
reform foreseen in Greece’s recovery and resilience plan 
(RRP). The tax, which is due to be introduced in 2022,is a 
significant  step  in  the  right  direction.  However,  the 
overall  administrative  capacity  of 
the  sector  has 
weakened  over  the  years  and  according  to  the 
Commission’s  2018  ‘early  warning  report’,  Greece  is  at 
risk  of  not  meeting  the  2020  municipal  waste  recycling 
target of 50 %. 

On  nature  protection,  Greece’s  Natura  2000  network  is 
now  considered  to  be  complete.  Nevertheless,  site-
specific  conservation  objectives  and  measures  have  not 
been  put  in  place  due  to  insufficient  data.  Moreover, 
management  plans  are  lacking  and  the  percentage  of 
habitats in good condition has decreased over the years. 
A  major  challenge  to  protect  and  manage  Natura  2000 
sites  effectively  is  to  set  up  a  national  system  for  the 
and 
comprehensive  management, 
functioning of protected areas. The recent law that aims 
to  put  in  place  management  bodies  for  all  Natura  2000 
sites should provide significant benefits in this respect. 

administration 

On urban wastewater treatment, there have been some 
positive  steps,  such  as  the  systematic  assessment  and 
strategic  re-organisation  of  the  country’s  investment 
needs.  However,  there  are  significant  delays  in  the 
projects  that  need  to  be  carried  out,  particularly  in  the 
agglomerations  (i.e.  population  centres  or  places  of 
economic activity) in Eastern Attica, for which Greece has 
been paying fines for several years. 

for 

for  Greece 

  environmental 

On  the  simplification  of  administrative  structures  and 
procedures 
implementation,  a 
positive  step 
the  streamlining  of 
environmental  assessments  under  the  Environmental 
Impact  Assessment  Directive,  the  Habitats  Directive  and 
the 
The  weak 
administrative  capacity  of  the  environmental  authorities 
in the country is considered a serious obstacle. 

Emissions  Directive. 

Industrial 

is 

EU financing continues to provide substantial support  to 
bridge the environmental implementation gap. Greece is 
due  to  receive  over  EUR  30  billion  from  its  RRP  (2021-
2026)  in  grants  and  loans  and  EUR  20  billion  from  the 
cohesion  policy  (2021-2027).  The  reforms  set  out  in  the 
Greek  RRP  to  set  up  two  new  regulatory  authorities  in 
the  waste  and  water  sectors,  are  expected  to  have  a 
in  the  respective  areas.  Greece’s 
positive 
environmental  investments  amounted  to    0.72%  of  GDP  
in 2014-2020, relying on both EU- and national financing. 
In  2021-2027,  the  country’s  environmental  investment 

impact 

1 The landfill  tax has been introduced with law 4819/2021 (article 38), 
the  new  national  legislative  framework  for  waste  management  and 

recycling,  transposing  Directives  (EU)  2018/851  and  2018/852  into 
national legislation. 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
                                                                                                        
needs  are  estimated  to  reach  over    1.12%  of  GDP, 
suggesting  an  environmental  financing  gap  of  at  least 
0.4%  of  GDP. 
  The  absorption  of  EU  funds  for 
environmental  measures  remains  a  cause  for  concern, 
the  areas  of  waste 
with  particular  problems 
management and nature protection. 

in 

Greece has paid more than EUR 184 million in fines since 
2014,  as  imposed  by  the  Court  of  Justice  of  the  EU  for 
violations of EU waste and urban wastewater norms. 

Greece  4 

 Environmental Implementation Review 2022 – Greece 

 
 
Greece  5 

Part I: Thematic areas 

1. Circular economy and waste management 

Measures towards a circular economy 

Figure 1: Circular material use rate (%), 2010-20202 

The  new  Circular  Economy  Action  Plan  adopted  in 
March  2020  is  one  of  the  main  building  blocks  of  the 
European  Green  Deal.  The  EU’s  transition  to  a  circular 
economy will reduce pressure on natural resources and 
will  create  sustainable  growth  and  jobs.  It  is  also  a 
prerequisite to achieve the EU’s 2050 climate neutrality 
target  and  to  halt  biodiversity  loss.  The  Action  Plan 
announces  initiatives  along  the  entire  life  cycle  of 
products,  aiming  to  reduce  the  EU's  consumption 
footprint  and  to  double  the  EU's  circular  material  use 
rate  by  2030.  It  targets  how  products  are  designed, 
promotes  circular  economy  processes,  encourages 
sustainable consumption, and aims to ensure that waste 
is prevented and the resources used are kept in the EU 
economy for as long as possible.  

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s  circularity,  as  it  includes  all  the  materials 
that are fed back into our economy. Large differences in 
the  circularity  rate  exist  between  countries.  To  help 
achieve the goal in the EU circular economy action plan 
of  doubling  the  EU  circular  materialuse  rate  by  2030, 
ambitious  measures  targeting  the  whole  product  life 
cycle are needed at Member State level. Such measures 
range  from  sustainable  product  design  that  makes  it 
reparability, 
possible 
upgradability  and  recyclability  of  products,  to  other 
measures,  like:  (i)  remanufacturing;  (ii)  increasing  the 
circularity  in  production  processes;  (iii)  recycling;  (iv) 
boosting  eco-innovation;  and  (v)  increasing  the  uptake 
of green public procurement. 

the  durability, 

increase 

to 

Greece’s  circular  (secondary)  use  of  material    stood  at 
2.4%  in  2016,  and  5.4%  in  2020  compared  to  an  EU 
average  of  12.8%.  Despite  an  increase  in  the  recent 
years, Greece remains far below the EU average for this 
indicatorhttps://www.ianos.gr/i-draki-de-mirazonte-
0520108. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown 
in Figure 2, with EUR 1.77 generated per kg of material 
consumed  in  2020,  resource  productivity  in  Greece  is 
slightly  below  the  EU  average  of  EUR  2.09  per  kg. 
However,  with  the  steady  increase  in  its  resource 
productivity  over  the  last  decade,  Greece  follows  an 
encouraging trend. 

2 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – Greece 

 
 
 
 
 
                                                                 
Figure 2: Resource productivity 2010-20203 

Greece  6 

and  vehicles;  packaging;  plastics;  textiles;  construction 
and  buildings;  food  waste  and  water  use.  Although 
Greece  does  not  have  specific  sectoral  strategies  for 
plastics, constructions and textiles, the action plan  sets 
out initiatives addressing these sectors. 

Greece’s new National Waste Management Plan as well 
as  its  RRP  outline  several  planned  reforms,  namely: 
revising  the  waste  management  law5  to  put  in  place 
incentives  for 
sustainable 
municipalities 
rates; 
enforcing  the  separate  collection  of  waste;  extending 
the  ‘Producer’s  responsibility’  scheme;  upgrading  the 
operation  of  recycling  sorting  facilities;  and  simplifying 
the legislation on “green points”. 

landfilling  and  recycling; 
to  achieve  higher 

recycling 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the 
full  potential  of  the  circular  economy  can  only  be 
reached when it is implemented across all value chains. 
Eco-innovation  is  an  important  enabling  factor  for  the 
circular  economy.  New  approaches  to  product  design 
and  new  business  models  can  help  to  produce 
business 
circularity 
opportunities. 

innovations, 

creating 

new 

Greece  ranked  17th  on  the  2021  Eco-Innovation 
Scoreboard, with a score of 102, making it an ‘average’ 
eco-innovation leader. Greece performed below the EU 
average  on  all  five  components  of  the  2021  Eco-
innovation 
(eco-innovation  activities,  eco-
innovation  outputs,  socio-economic,  eco-innovation 
input and resource efficiency outcomes). 

Index 

Circular economy strategies  

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies  covering  the  whole  life  cycle  of  products,  as 
they are one of the most effective ways for countries to 
progress  towards  a  more  circular  economy.  Since  its 
launch  in  2017,  national,  regional  and  local  authorities 
have  used  the  European  Circular  Economy  Stakeholder 
Platform4 to share their strategies and roadmaps. 

In  April  2018,  the  Government  Council  for  Economic 
Policy  (KYSOIP)  endorsed  the  national  action  plan  on 
circular  economy,  including  short-term  measures  and 
following  sectors  were 
long-term  priorities.  The 
identified  as  priorities:  construction  &  demolition; 
water; reuse preparation; repairs and maintenance; bio-
economy sectors; textiles and chemicals.  In light  of the 
new  EU  circular  economy  action  plan,    in  November 
2021, Greece approved its own action plan in this area, 
with a corresponding roadmap approved by the Council 
of Ministers. 

The national action plan is expected to include a  series 
of actions to be implemented up to 2025. The planned 
actions  will  focus  on:  production,  consumption,  waste 
management 
and 
general 
administrative  issues;  products  and  services  that  are 
resource 
for 
circularity  is  high    e.g.  electronics  and  ICT);  batteries 

intensive  and  where 

the  potential 

governance 

and 

3 Eurostat, Resource productivity. 
4  Circular Economy Stakeholder Platform 

5  Law  4819/2021  has been issued in  July  2021,transposing  Directives 
2018/851  and  2018/852,  where  the  legislative  framework  for  waste 
management and recycling has been updated. 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
 
                                                                 
Figure 3: Eco-innovation performance, 2010-20196 

EU Ecolabel and the Eco Management and Audit 
Scheme (EMAS) 

Greece  7 

The  number  of  EU  ecolabel  products  and  EMAS-
licensed7 organisations in a given country provides some 
indication of the extent to which the private sector and 
national  stakeholders 
in  that  country  are  actively 
engaged in the transition to a  circular  economy. It also 
shows  how  committed  public  authorities  are  to 
supporting 
instruments  designed  to  promote  the 
circular economy. 

As of  September 2021, Greece had  3 559 products out 
of 83 590, and 20 licences out of 2 057 registered in the 
EU  ecolabel  scheme,  ranking  its  EMAS  take-up  on  the 
low side8. Moreover,  35 organisations from  Greece are 
currently registered in EMAS9.   Since 2019, there have 
licence 
been  211  new  product  registrations  but 
registrations have gone down by 12. 

As Greece has adopted a circular economy action plan, 
this  particular  priority  action  from  the  2019  EIR  has 
been fulfilled. Given that  Greece’s  circular  material use 
rate  is  far  below  EU  average,  a  new  priority  action  on 
this is proposed. 

2022 priority action 

  Adopt  measures  to 
material use rate. 

increase  the  circular 

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;  
(iii) limiting energy recovery to non-recyclable materials 
and phasing out  landfilling of recyclable or recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste10,  for  which  EU  law  sets  mandatory  recycling 
targets. 

7  EMAS  is  the  European  Commission’s  eco-management  and  audit 
scheme, which aims to encourage organisations to behave in a more 
environmentally sustainable way. 
8 European Commission, Ecolabel Facts and Figures. 
9 As of May 2018. European Commission, Eco-Management and Audit 
Scheme 
10  Municipal  waste  consists  of  (a)  mixed  waste  and  separately 
collected  waste  from  households,  including  paper  and  cardboard, 
glass,  metals,  plastics,  bio-waste,  wood,  textiles,  packaging,  waste 
electrical  and  electronic  equipment,  waste  batteries  and 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
consumption,  with  public  authorities’ 
purchasing power representing around 14% of EU GDP. 
Public  procurement  can  help  drive  the  demand  for 
sustainable  products 
reparability  and 
recyclability standards.  

that  meet 

Greece adopted its first green public procurement (GPP) 
action  plan  in  2021.  The  action  plan  recommends  that 
to all public authorities use EU GPP criteria for procuring 
goods,  services  and  public  worksIt  also  sets  mandatory 
and non-mandatory targets to use EU GPP criteria in the 
following  categories:  copying  and  graphic  paper; 
computers and monitors; imaging equipment; lubricants 
(regenerated  and  biodegradable);  road  transport,  road 
lighting  and  traffic  signals;  furniture;  textiles;  public 
infrastructure; 
space  maintenance; 
in  the 
electrical  and  electronic  equipment  used 
healthcare  sector;  office  building  design,  construction 
and  management;  and  road  design,  construction  and 
maintenance. Finally, setting up a monitoring system for 
public 
and/or 
green, 
procurement is a key priority for 2022. 

  waste  water 

sustainable 

innovative 

6  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation index. 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
                                                                 
 
resource  efficiency  and 

Preventing  products  and  materials  from  becoming 
waste for as long as possible is the most efficient way to 
improve 
the 
environmental  impact  of  waste.  Waste  prevention  and 
reuse  are  the  preferred  options,  and  are  therefore  at 
the  top  of  the  waste  hierarchy.  The  amount  of 
municipal  waste  generated  is  a  good  indicator  for  the 
effectiveness of waste prevention measures. 

reduce 

to 

After a downward trend, municipal waste generation in 
Greece  started  to  increase  from  2013  onwards  (the 
pattern  reflects  the  post-recession  period).  Waste 
generation  stood  at  524  kg/year/inhabitant  in  2019, 
relatively 
(502  
the 
kg/year/inhabitant),  as  Figure  4  shows.  This  indicates 
that  Greece’s  economic  growth  is  not  yet  decoupled 
from its generation of waste. 

average 

close 

EU 

to 

Figure 4: Municipal waste by treatment in Greece, 
2010-201911 

Greece  8 

two rulings of the  Court  of Justice of the EU, Greece is 
paying fines (EUR 66.5 million so far) for these breaches. 
Greece  has  also  been  condemned  by  the  CJEU  for  its 
inefficient  management  of  hazardous  waste  and  has 
paid EUR 49.6 million in fines so far.  

In  addition,  studies  and  investigations  launched  by  the 
European  Commission  have  revealed  that  Greece  lacks 
sufficient  treatment  facilities  as  well  as  separate 
collection  for  glass  and  biodegradable  waste.  It  also 
appears  that  most  organic  waste  is  landfilled  without 
prior  stabilisation12.  Therefore,  in  November  2021  the 
Commission initiated an infringement procedure against 
Greece for failing to comply with the Landfill Directive13 
and the Waste Framework Directive14 15. 

Greece  has  made  very  slow  progress  over  the  past 
decade  (and,  even  regressed  between  2011  and  2016) 
on  increasing  its  recycling  rate  and  diverting  municipal 
waste  from  landfilling.  In  2019,  the  recycling  rate  for 
municipal  waste  stood  at  21%  (16%  recycled  and  5% 
composted), well below the EU average of 48%. 

Figure 5 shows that Greece needs to step up investment 
in  recycling  to  meet  the  EU  2020  and  2025  recycling 
targets. 

Figure 5: Recycling rate of municipal waste, 2010-201916 

Figure  4  also  shows  municipal  waste  by  treatment,  in 
terms of kilos per capita. Little progress has been made 
since the 2019 EIR. Greece  most of its municipal waste 
in  landfills  (78  %),  with  only  21  %  being  recycled  (EU 
average 48 %). The landfill rate has decreased modestly 
and the recycling rate has slightly increased. 

Moreover,  based  on  the  information  available  to  the 
Commission,  it  appears  that  a  significant  number  of 
irregular  and  substandard  landfills  continue  to  operate 
in  Greece  and  present  serious  risks  for  human  health 
and  the  environment.  First  of  all,  three  illegal  waste 
dumping sites are not  yet  closed and rehabilitated and 
17 such sites are closed but not rehabilitated. Following 

accumulators, and bulky waste, including mattresses and furniture; (b) 
mixed  waste  and  separately  collected  waste  from  other  sources, 
where such waste is similar in nature and composition to waste from 
households. (Directive 2008/98/EC, Art. 3 2b). 
11 Eurostat, Municipal waste by waste operation, april 2022 (2020 data 
not yet available for Greece). 

The  Commission's  Early  Warning  report'17  cited  Greece 
among  the  countries  at  risk  of  missing  the  EU  2020 
target  of recycling 50 % of municipal waste. The report 
listed key priority measures  that Greece should take to 

12 INF/21/5342. 
13 Directive 1999/31/EC. 
14 Directive 2008/98/EC. 
15  October infringements package: key decisions (europa.eu) 
16  Eurostat, Recycling rate of municipal waste, april 2022 (2020 data 
not yet available for Greece). 
17  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)422 accompanying COM(2018)656. 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                                                      
 
 
                                                                 
implementation  gap.  The  Commission 

is 
close  the 
currently  finalising  its  analysis  of  progress  on  the  2018 
‘early  warning’  report  recommendations  and  on 
progress  towards  achieving  the  2025  waste  recycling 
targets, which will be presented in the form of a report 
at  the  end  of  2022  with  recommendations  where 
appropriate. 

Implementation of the 2018 waste legislative package 

Greece has notified its transposition of the 2018 waste 
package18 to the Commission. A conformity assessment 
is now ongoing.  

Greece  9 

recyclable  waste.  Use  the  available  economic 
instruments,  e.g.  pay-as-you-throw  and  mandatory 
recycling  targets  for  municipalities  with  penalties 
for non-compliance (e.g. fines). 
Improve  the  efficiency  of  the  extended  producer 
responsibility  systems,  in  line  with  the  general 
minimum requirements on EPR. 
Ensure  regional  waste  management  plans  in  line 
with  the  revised  Waste  Framework  Diretive  are  in 
place. 

 

 

for 

are 

Waste  management  plans  and  waste  prevention 
programmes 
sound 
instrumental 
implementation  of  EU  waste  legislation.  They  set  out 
key  provisions  and  investments  to  ensure  compliance 
with  existing  and  new  legal  requirements  (e.g.  waste 
prevention, separate collection for a number of specific 
waste  streams,  recycling  and 
landfill  targets).  The 
revised plans and programmes were due by 5 July 2020.  

a 

Greece has adopted and notified to the Commission its 
updated  national  waste  management  plan  (ESDA), 
which  is  under  assessment,  but  has  not  notified  its 
updated regional waste management plans. Greece also 
adopted its new National Waste Prevention Programme 
in June 2021 for the period up to 2030. 

2022 priority actions 

Given  the  limited  progress  since  the  2019  EIR,  and  in 
light of the upcoming Early Warning report for 2022, the 
priority actions are rolled over and a new one is added 
on the adoption of the waste management plans. 

 

  Address  the  issues  of  closure  and  rehabilitation  of 
illegal  landfills  and  of  the  treatment  of  hazardous 
waste as matters of absolute priority. 
Properly  enforce  and  increase  landfill  taxes  to 
phase  out  landfilling  of  recyclable  and  recoverable 
waste.  Channel  those  revenues  towards  measures 
that  improve  waste  management  in  line  with  the 
waste hierarchy. 

 

  Avoid  building  excessive 

infrastructure  for  the 
treatment  of  residual  waste,  e.g.  mechanical 
biological treatment (MBT) facilities or incinerators. 
Improve  and  extend  separate  collection  of  waste, 
including  for  biowaste.  Establish  minimum  service 
standards for separate collection (e.g. frequency of 
in 
collections, 
municipalities  to  ensure  high  capture  rates  of 

containers, 

types 

etc.) 

of 

18  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. 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
 
Greece  10 

2. Biodiversity and natural capital

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and  sets  out  new  targets  and  governance  mechanisms 
to achieve healthy and resilient ecosystems.  
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests;  
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 
The  Birds and  Habitats Directives,  which  are reinforced 
by  the  Nature  Restoration  Law,  are  key  legal  tools  to 
deliver  on  the  strategy’s  targets.  They  are  the 
cornerstone  of  EU  legislation  aimed  at  conserving  the 
EU's wildlife19 

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 202620. 

Nature protection and restoration  

Natura  200021,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  objectives  of  the  Birds  and  Habitats 
Directives.  These  objectives  are:  (i)  to  ensure  the  long-
term  protection,  conservation  and  survival  of  Europe’s 
most  valuable  and  threatened  species;  and  (ii)  to 
maintain  or  restore  the  favourable  conservation  status 
of  these  species  and  habitats.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 

19  These  should  be  reinforced  by  the  Nature  Restoration  Law, 
according to the new EU biodiversity strategy. 
20https://ypen.gov.gr/wp-
content/uploads/legacy/Files/Perivallon/Diaxeirisi%20Fysikoy%20Peri
vallontos/Biopoikilotita/20200323_ethniki_strathgiki_biodiversity.pdf 
21  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated under the Habitats Directive as well as Special Protection 
Areas  (SPAs)  classified  under  the  Birds  Directive;  figures  of  coverage 
do not add up due to the fact that some SCIs and SPAs overlap. Special 
Areas of Conservation (SACs) means a SCI designated by the Member 
States. 

importance (SCIs) as SAC22,  and (iii) the setting of site-
specific  conservation  objectives  and  measures  for  all 
Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Greece  hosts  89  habitat  types23  and  296  species24 
covered  by  the  Habitats  Directive.  The  country  also 
hosts populations of 160 bird species listed in the Birds 
Directive’s Annex I25 . 

Greece has designated 446 Natura 2000 sites, including 
265  SCIs  under  the  Habitats  Directive  and  207  Special 
Protection Areas (SPAs) under the Birds Directive. 

By  2021,  27.3%  of  Greece’s  land  area  was  covered  by 
Natura  2000  (EU  coverage  18.5%),  with  SPAs  classified 
under  the  Birds  Directive  covering  21%  (EU  coverage 
12.8%)  and  SCIs  under  the  Habitats  Directive  covering 
16.6%26 (EU coverage 14.2%) of the Greek territory. 

According to the latest assessment of the SCI part of the 
Natura 2000 network, Greece’s Natura 2000 network is 
now considered to be complete. 

Today  the  Natura  2000  network  covers  19.6%  of  the 
total sea area of the country. 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Greece  legally  protects 
35.20% of its terrestrial areas (EU 27 coverage 26%) and 
4.62% of its marine areas (EU 27 coverage 12%). 

Figure 6: Marine & terrestrial protected area coverage, 
202127 

22  Sites  of  Community  Importance  (SCIs)  are  designated  pursuant  to 
the  Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated pursuant to the Birds Directive; figures of coverage do not 
add up due to the fact that some SCIs and SPAs overlap. Special Areas 
of Conservation (SACs) are SCIs designated by the Member States. 
23 EEA, Article 17 dashboard, Annex I total, 2019. 
24  EEA, Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex  II  +  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
25 EEA, Article 12 dashboard, Annex I, 2020. This counting only takes 
into account birds taxa for which information was requested. 
26 According to the Greek Priority Action Framework PAF-EL_FINAL.pdf 
(ypen.gov.gr)  and  the  barometer  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer 

27  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
 
                                                                 
Greece  11 

Moreover,  site-specific  conservation  objectives  and 
conservation  measures  have  not  been  established  due 
to insufficient primary data. 

2020  Greece  has  defined 
Furthermore,  until 
management  plans  for  only  three  SCIs,  whereas  for 
some  areas  presidential  decrees  or  Joint  Ministerial 
Decisions have been issued which define permitted and 
forbidden activities. For these reasons, the Commission 
had  decided  to  bring  the 
infringement  procedure 
opened on this matter before the Court of Justice of the 
EU. 

In  April  2021,  Greece  adopted  national  conservation 
objectives for those habitats and species for which data 
were  available.  But  it  still  has  to  set  out  the  necessary 
site-specific  conservation  objectives  and  measures  for 
the already designated sites. 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

the 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
favourable 
towards  maintaining  or  restoring 
conservation status of species and habitats.According to 
the  report  submitted  by  Greece  on  the  conservation 
status  of  habitats  and  species  covered  by  Article  17  of 
the Habitats Directive for 2013-2018, 48.31% of habitats 
were  in  good  conservation  status  in  2018,  down  from 
61.36%  in  the  previous  reporting  period  (2007-2012). 
On  protected 
in  good 
indicating  a  slight 
in  2018, 
conservation  status 
improvement  compared  to  the  33.33%  reported  for 
2007-2012.  On  birds,  77%  of  breeding  species  showed 
short-term  increasing  or  stable  population  trends  (for 
wintering species this figure was 50%). 

species,  35.02%  were 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202128 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation status increased to 5.62% and the share of 
assessments  for  species  in  bad  conservation  status 
remained stable at 12.46%. The main pressures both for 
species and habitats are development, construction and 
use  of 
industrial  and 
recreational infrastructure and areas  and agriculture. 

commercial, 

residential, 

Designating Special Areas of Conservation (SACs) and 
setting conservation objectives and measures 

The  6-year  deadline  set  by  the  Habitats  Directive  to 
establish  appropriate  conservation  objectives  and 
measures has expired for 239 sites in Greece. 

28  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

Environmental Implementation Review 2022 – Greece 

 
 
 
 
 
 
                                                                 
Figure 8: Assessments on conservation status for 
habitats for 2007-2012 and 2013-201829 

Figure 9: Assessments on conservation status for 
species for 2007-2012 and 2013-2018 reporting 
periods30 

There  seems  to  be  a  general  lack  of  progress  in 
maintaining  or  restoring  the  favourable  conservation 
status  of  species  and  habitats  protected  under  the 
nature directives. 

A  major  challenge  to  protect  and  manage  Natura  2000 
sites  effectively  is  to  set  up  a  national  system  for  the 
comprehensive  management, 
and 
functioning  of  protected  areas  (including  strategy, 
responsibilities, 
structure,  management 

administration 

schemes, 

29  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.  Please  note when  comparing 
the  figures  shown  for  2007-2012  and  2013-2018  these  may  also  be 
affected by changes of methods or due to better data availability. 
30 Idem. 

Greece  12 

financing,  enforcement  and  monitoring).  In  particular, 
Greece  has    to  execute  the  CJEU  ruling  of  December 
2020  in  case  C-849/19  by  adopting  all  the  necessary 
measures  for  establishing  appropriate  conservation 
objectives  and  conservation  measures  for  all  SCIs  that 
are  on  its  territory.  The  currently  ongoing  process  is 
significantly delayed. However, the recent law31, adopted 
in May 2020, aims at remedying the situation by putting 
in  place  management  bodies  for  all  Natura  2000  sites 
and  by  establishing  a  central  organisation  (Natural 
Environment  &  Climate  Change  Agency).  This  new 
governance system is yet to be put in place and become 
fully operational. 

Major  obstacles  to  achieving  the  objectives  of  the 
Nature  Directives  include:  (i)  the  lack  of  awareness 
(among authorities, stakeholders and the public) about 
Natura  2000  and  its  benefits;  (ii)  a  lack  of  incentive  to 
invest  in  promoting  these  benefits;  (iii)  insufficient 
scope for supporting sustainable land management and 
integrating it into other policies; and (iv) difficulties with 
enforcing the law.  

Due  to  these  shortcomings,  many  complaints  and 
infringement cases are pending on issues such as: (i) the 
degradation  of  designated  sites  (e.g.  case  C-517/11  on  
lake  Koroneia  pollution)  ;  (ii)  the  poor  quality  of 
‘appropriate  assessments’  under  Article  6(3)  of  the 
Habitats  Directive  as  well  as  the  lack  of  strategic 
and 
(e.g.  on  windfarm  planning 
assessments 
subsequent  authorisation  of  projects);  and 
(iii) 
insufficient protection of species and habitats  including 
against  illegal  activities  (e.g.  concerning  the  caretta 
caretta species in Kyparissia32).  

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable  agriculture.  The  biodiversity  and  farm  to 
fork strategies have set four important targets for 2030:  
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides;  
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides;  
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  20%  the  reduction  in  the  use  of 
fertilisers);  
- bring back at least 10% of agricultural area under high-

31 ν. 4685/2020 
32 December_infringements_package__key_decisions_ (1).pdf 

Environmental Implementation Review 2022 – Greece 

 
 
 
 
 
                                                                 
                                                                 
diversity  landscape  features    and  increase  areas  under 
organic farming to at least 25%. 

As  shown  in  the  Figure  10  below,  with  an  estimated 
10.15% of its area under organic farming, Greece stands  
above  the  EU  average  of  9.07%  (2020  data,  Eurostat)  , 
showing  a  good  potential  for  growth  towards  the  EU-
level  Green  Deal  target  of  25%  of  agricultural  land  by 
2030. 

Figure 10: Share of total utilised agricultural area33 

According  to  the  Commission’s  recommendations  on 
Greece’s CAP strategic plan34, total ammonia emissions 
in  Greece  have  been  steadily  decreasing  since  2013,  in 
contrast  with  the  rest  of  the  EU.  91%  of  the  ammonia 
emissions  in  2018  came  from  agricultural  sources.  The 
steady  increase  in  permanent  grassland  surfaces  (from 
16%  of  total  agricultural  area  in  2010  to  39%  in  2017)  
contributs  positively  to  the  overall  GHG  emissions 
trend. 

In contrast, soil quality is an issue in Greece. The share 
of  agricultural  area  at  risk  of  soil  erosion  stands  at 
10.2%,  above  the  EU  average  of  6.6%,  and  is  much 
higher  than  in  the  north-west  and  the  south.  Wind 
erosion  is  also  an  issue  in  the  Aegean  islands.  Specific 
Mediterranean  characteristics  mainly  contribute  to 
increased risk of soil erosion, with rainfall patterns and 
drought  leading  to  loss  of  soil  organic  matter  while 
sloping land, especially for pasture, increases the risk of 
soil  erosion.  The  type  of  cultivated  crops  and  other 
management  practices  such  as  reduced  tillage,  cover 
crops and agroforestry can help to protect the soil.  

33 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en (Eurostat, Area under organic farming, February 2022). 
34https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52020SC0372  

Greece  13 

Water  quality  and  quantity  are  one  of  the  biggest 
challenges 
Irrigated  areas 
represented 24% of the total utilized agricultural area in 
Greece in 2016.  

for  Greek  agriculture. 

Pressures  stemming  from  agricultural  practices  affect 
the majority of relevant habitat types, but mostly water 
ecosystems, and are associated with agricultural runoff, 
drainage, change of land use and of natural succession, 
pumping  of  groundwater,  surface  water  and  mixed 
water.  Though in recent  years there is a  slight  upsurge 
in traditional farming, the overall tendency of intensive 
and  large-scale  monocrop  agriculture  puts  significant 
pressure  on  natural  resources,  namely  water  (scarcity 
and pollution) and soil (erosion, low soil organic carbon 
and  pollution).  It  also  has  negative  impacts  on  the 
landscape and leads to habitat fragmentation.  

With 10% of area under organic farming in 2019, Greece 
is  above  the  EU-27  average,  showing  a  good  potential 
for  growth  towards  the  EU  level  Green  Deal  target  of 
25% of agricultural land by 2030. 

Soil ecosystem 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
The  new  EU  soil  strategy,  adopted  on  17  November 
2021,  stresses  the  importance  of  soil  protection,  of 
sustainable soil management and of restoring degraded 
soils to achieve the Green Deal objectives as well as and 
land degradation neutrality by 2030.  
This entails: 
(i) preventing further soil degradation;  
(ii)  making  sustainable  soil  management  the  new 
normal; 
(ii) taking action for ecosystem restoration.  
One factor  in the  degradation of soil ecosystems  is the 
area  of  soil  that  is  sealed  or  artificialised35.  In  Greece 
(Figure 11) the land taken per year in 2012-2018 can be 
seen as a measure of one significant pressure on nature 
and  biodiversity  –  land-use  change.  At  the  same  time, 
land-use change constitutes an environmental pressure 
on people living in urbanised areas.  

Greece  ranks  just  above36  the  EU  average  on    net  land 
take (83,9 m2/km2  vs 83,8 m2/km2). 

land 
In  2018,  Greece  updated 
degradation  according  to  the  latest  PRAIS3  reporting 

its  reporting  on 

35 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non  built-up  areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car  parking  areas  etc.  and  linear  features,  such  as  streets,  roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and  viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 
36 Land take  in Europe — European Environment Agency (europa.eu) 
Fig 6 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
                                                                 
platform37  with  actions 
degradation identified. 

intended  to  achieve  the 

Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201838 

Greece  14 

Out  of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favourable  conservation  status40.  Bad  conservation 
status increased from 27% to 31% in the EU compared 
to 2015. 

Forests  cover  28.53%  of  Greece’s  territory41  and  more 
than  30%  of  the  assessments  of  EU-protected  forest 
habitats  reveal  a  bad  to  poor  status42,  of  which  60% 
shows  an  improving  trend  and  the  remaining  40%  a 
constant trend. 

Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)43 

However, Greece has not yet committed to setting land 
degradation neutrality targets under UNCCD39.  

As  stated  in  the  2019  EIR,  soil  organic  matter  plays  an 
important  role  in  the  carbon  cycle  and  in  climate 
change.  Soils  are  the  second  largest  carbon  sink  in  the 
world after the oceans. 

Forests and timber 

The EU forest strategy for 2030 adopted in July 2021 is 
part  of  the  ‘Fit  for  55’  Package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is  to  ensure  healthy,  diverse  and  resilient  EU  forests 
that  contribute  significantly 
the  strengthened 
biodiversity  and  climate  ambitions.  Forests  are 
important  carbon  sinks  and  conserving  them  is  vital  if 
the EU is to achieve climate neutrality by 2050.  

to 

(EUTR)44 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  the  EUTR,  EU 
Member  States’  competent  authorities  must  conduct 
regular  checks  on  operators  and  traders,  and  apply 
penalties  for  non-compliance.  With  the  amendment  of 
Article 20 of the EUTR, reporting every 2 years has been 
changed  to  annual  reporting,  and  covers  the  calendar 
year as of 2019. 

Between  March  2017  and  February  201945,  Greece 
carried out 488 checks on domestic timber operators. It 
also  carried  out  132  checks  on  operators  importing 
timber. It is estimated that Greece had 1 600 operators 
placing domestic and 1 228 operators placing imported 
internal  market  over  the 
timber  types  onto  the 
reporting period. 

37 All Reports | Prais3 (unccd.int) 
38  European  Environment  Agency,  Land  take  in  Europe,  December 
2021. European Environment Agency, Land take in Europe, December 
2021. European Environment Agency, Land take in Europe, December 
2021. 
39  The LDN Target Setting Programme | UNCCD 

40 EEA, State of Nature in the EU 
41 EEA, Forest information system for Europe. 
42 COM SWD (2021) 652 
43  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
44 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
45 COM/2020/629 final 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
 
                                                                 
Greece  15 

Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for Greece, 2021 

The  new  Deforestation  Regulation 46  will  repeal  and 
replace  the  EUTR,  as  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  legality  of 
timber. 

Invasive alien species (IAS) 

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
use, 
sea 
(alongside 
overexploitation, climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy, many invasive alien species also facilitate the 
outbreak  and  spread  of  infectious  diseases,  posing  a 
threat to humans and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
established  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%. 
The core of Regulation (EU) 1143/2014 on Invasive Alien 
Species (the IAS Regulation47) is the list of invasive alien 
species  of  Union  concern.  The  total  number  of  IAS  of 
Union  concern  is  currently  66,  of  which:  30  are  animal 
species;36 are plant species; 41 are primarily terrestrial 
species;  23  are  primarily  freshwater  species;  1  is  a 
brackish-water species; and 1 is a marine species.  

According  to  a  2021  report48  on  the  review  of  the 
application of the IAS Regulation,  its implementation is 
already  starting  to  deliver  on  its  objectives,  such  as  a 
coherent  framework for addressing IAS at EU level and 
increased  awareness  of  the  problem  of  invasive  alien 
species.  At  the  same  time,  the  above  report  identified 
some challenges and areas for improvement. Given that 
the  deadlines  for  implementing  the  various  obligations 
of  the  IAS  Regulation  applied  gradually  between  July 
2016 and July 2019, it is premature to draw conclusions 
on  several  aspects  of  the  implementation  of  the  IAS 
Regulation. 

to  a  2021  report49  on 

 According 
the  baseline 
distribution,  of  the  66  species  on  the  list,  7  have  been 
observed Greece. (See Figure 13.) 

infringement  case50  has  been 

An 
Greece as the country: 

launched  against 

 

 

 

failed  to  establish  and  implement  a  single 
action  plan  or  set  of  action  plans  fulfilling  the 
requirements  specified  in  Article  13  of  the  IAS 
Regulation  by  13  July  2019  and  to  submit 
it/them to the Commission without delay; 
failed to  set up a surveillance system of  IAS of 
Union  concern,  or  include  it  in  their  existing 
system,  monitoring  or  other  procedures  to 
prevent the spread of IAS into or within the EU 
by 13 January 2018 as required by Article 14(1) 
of the Regulation;  
failed to fulfil its Article 15(1) obligation to put 
in place fully functioning structures to carry out 
the  official  controls  necessary  to  prevent  the 
intentional  introduction  into  the  EU  of  IAS  of 
Union concern51.  

46  A  proposal  for  the  Regulation  on  the  making  available  on  the  EU 
market  and  export  of  products  associated  with  deforestation  and 
forest degradation. 
47  Regulation  (EU)  No  1143/2014  of  the  European  Parliament  and  of 
the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species 
48  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 
49  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 

concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170 

50 Protecting biodiversity (europa.eu)  
51 Α Joint Ministerial Decision was recently published under the title: 
"Measures for the implementation of Regulation (EU) no. 1143/2014 
of the European Parliament and of the Council of 22 October 2014 on 
the  prevention  and  management  of  the  importation  and  spread  of 
invasive  alien  species".  The  JMD  was  published  in  Government 
Gazette  B’5697  /7-12-2021.  Articles  2  and  8  of  the  JMD  resolve  the 
country’s obligations to Article 15(1) of the Regulation. 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
 
 
 
                                                                                                      
 
2022 priority actions 

 

  Define 

site 

clear 

specific 

conservation 
objectives  for  all  Natura  2000  sites  and  put  in 
place necessary conservation measures. 
Complete  and  implement  the  management 
plans  and  legal  tools  for  all  the  sites.  Ensure 
that  all  established  management  bodies 
operate  effectively,  with  clear  responsibilities 
and sufficient financial and human resources.  

 

and 

policies 

promote 

into 
better 

integrate  biodiversity  concerns 

  Better 
other 
communication between actors.  
Increase the capacity of competent authorities 
(central, regional, site management bodies) to: 
(i)  apply  conservation  measures  that  increase 
awareness about Natura 2000 and its benefits; 
(ii)  raise  awareness  about  the  economic 
benefits  of  healthy  ecosystems  and  offer 
incentives  to  invest  in  them;  and  (iii)  improve 
enforcement  to  tackle  illegal  activities  that 
harm  wildlife,  both  within  and  outside  Natura 
2000 areas.  
Fill in the gaps in the monitoring system of the 
conservation  status  of  protected  habitats  and 
species.  
Improve 
appropriate 
quality 
assessments  at  plan  and  project  level  and 
is 
ensure  that  their  environmental 
adequately monitored. 
Step  up  action  on 
the 
recommendations  set  out  in  the  Greek  CAP 
Strategic Plan.   
Step  up  implementation  action  on  the  EU 
Invasive Alien Species Regulation. 

implementing 

impact 

the 

of 

 

 

 

 

Marine ecosystems 

The  EU  biodiversity  strategy  for  2030  calls  on  Member 

A co-financed project entitled "Compilation of a list of invasive species 
and organization of a methodology for the assessment of their risk" is 
being implemented since February 2021. It includes proposals for the 
management  and  continuous  monitoring  of  the  most  dangerous  (to 
biodiversity)  invasive  species.  The  project  has  been  included  in  the 
Operational  Program  "Transport  Infrastructure,  Environment  and 
Sustainable  Development  2014-2020".  It  is  serving  as  a  first  step  for 
fulfilling  the  requirements  of  the  EU  regulation  concerning  the 
adoption  of  Action  Plans  (Article  13  of  the  Regulation),  and  will  also 
propose the specifications of the surveillance system of Article 14(1). 
Due  to  the  significant  interaction  of  Invasive  Alien  Species  with 
Fisheries, the General Directorate of Fisheries of the Ministry of Rural 
Development  and  Food  already 
implements  actions  within  the 
Operational  Program  "Fisheries  and  Maritime  2014-2020"  which  are 
implemented  in  parallel  and  in  collaboration  with  the  actions  of  the 
Ministry  of  Environment  and  Energy  and  are  aimed  at  tackling  the 
effects of the most harmful alien species to Fisheries. 

Greece  16 

States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision  making  at  all  levels 
and to develop natural capital accounting. The EU needs 
a  better  performing  biodiversity  observation  network 
and  more  consistent  reporting  on  the  condition  of 
ecosystems  52. 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  of  their  marine  waters.  To  that  end, 
Member  States  must  draw  up  marine  strategies  for 
their marine waters, and cooperate with Member States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

(Article  9),  and  to  provide  an 

The  MSFD  also  requires  Member  States  by  15  October 
2018  to  draw  up  a  set  of  GES  characteristics  for  each 
descriptor 
initial 
assessment  of  their  marine  waters  (Article  8).  The 
Commission  then  assesses  whether  this  constitutes  an 
appropriate framework to meet the requirements of the 
Directive.  

The MSFD also requires that Member States assess the 
current  environmental  status  of  their  marine  waters 
against  the  defined  GES  characteristics.  A  good  or  very 
good  score  indicates  that  a  Member  State  has  good 
in 
capabilities  to  assess  their  marine  environment 
in  the 
accordance  with  the  requirements  set  out 
Commission’s GES decision. 

Greece  has  not  reported  data  on  the  state  of  the 
environment,  definitions  of  GES  or  environmental 
targets. 

Currently, Greece has signed but not yet ratified: 

 

 

 

to 

the  Barcelona 

the  offshore  protocol 
Convention; 
the  protocol  on  Specially  Protected  Areas  and 
biological diversity in the Mediterranean; 
the  protocol  on 
management; 

integrated  coastal  zone 

Moreover,  Greece  has  neither  signed  nor  ratified  the 
International Convention for the Regulation of Whaling. 

the  MSFD53,  while 

As  highlighted  in  the  Commission’s  report  on  the 
regional 
implementation  of 
cooperation  has  improved  since  the  adoption  of  the 
MSFD,  more  cooperation 
is  needed  to  attain  full 
regional coherence of the marine strategies, as required 
by the Directive. 

52  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
53 COM(2020)259 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                                                      
                                                                 
In the EIR 2019, the Commission suggested that Greece 
should  ensure  timely  reporting  of  the  different 
elements  under  the  Marine  Strategy  Framework 
Directive  so  that  Greece  can  be  part  of  future 
Commission  assessments.  However,  Greece  has  shown 
no progress in this respect. 

Furthermore, in March 2022, the European Commission 
published  a  Communication  with recommendations for 
Member States. The Commission assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine  the  good  environmental  status  and  the  use 
of  the  criteria  and  methodological  standards  according 
to 
the  Commission  GES  Decision.  The  above 
considerations  form  the  basis  for  the  2022  priority 
actions. 

2022 prority actions   

 

  Report  data  on  the  state  of  the  environment, 
determinations  of  GES  and  environmental 
targets. 
Ensure  regional  cooperation  with  Member 
States sharing the same marine (sub) region to 
address predominant pressures.   
Sign and ratify the International Convention for 
the  Regulation  of  Whaling  (1946).  Ratify  the 
offshore protocol to the Barcelona Convention; 
the  protocol  concerning  Specially  Protected 
the 
and  biological  diversity 
Areas 
Mediterranean;  the  protocol  on 
integrated 
coastal zone management. 

in 

 

Greece  17 

types  outside  Natura 

ecosystem  condition  and  services.  The  project’s  key 
deliverables, produced in 2020, were a map of Greece’s 
ecosystem  services’  priority  areas  and  a  map  of 
ecosystem 
SACs. 
Presentations  were  given  in  several  regions  level  to 
raise  awareness  about  ecosystem  services  and  their 
relevance  for  policy  support  and  decision  making. 
Greece  has  provided  updated 
information  and 
significant  progress  has  been  recorded  since  January 
2016  (Figure  14).  This  assessment  is  based  on  27 
implementation questions and updated every 6 months. 

2000 

Figure 14: ESMERALDA MAES Barometer. January - 
March 202156 

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

Figure 15: Ecosystem accounting Barometer, 
September 202157 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision  making  at  all  levels 
and to develop natural capital accounting. The EU needs 
a  better  performing  biodiversity  observation  network 
and  more  consistent  reporting  on  the  condition  of 
ecosystems.  

Ecosystem  assessment  developments  in  Greece  mainly 
occur  under  the  LIFE-IP  4Natura  project  (2017-2025)54. 
A key deliverable is the Technical-methodological guide 
on  the  determination  and  assessment  of  ecosystem 
types 
in  Greece  and  their  national,  regional  and 
localecosystem services. The first glossary55 in Greek for 
MAES related studies was produced in 2018. MAES field 
surveys  were  also  carried  out 
for  the  national 
assessment using an agreed field protocol for assessing 

54 Natura 2000 – Edo Zoume 
55  Glossary  of  ecosystem  services  mapping  and  assessment 
terminology (pensoft.net) 

56 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 
57  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting (SEEA-EEA) as the methodological basis for the ecosystem 
accounting. The SEEA EA is an integrated an comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
 
 
 
                                                                 
Ecosystem  accounting  in  Greece  is  currently  in  its 
infancy.  However,  the  policy  relevance  is  clear.  Up  to 
now,  no  accounts  have  been  finalised 
in  Greece. 
However,  a  national  ecosystem  extent  account,  an 
ecosystem  monetary  asset  account  and  a  thematic 
biodiversity  account,  all  for  woodland  and  forest,  are 
being  developed  and  are  expected  to  be  published 
soon.  On  accounts 
services,  a 
for 
methodological 
physical  as  well  as  for  monetary  accounting  of  water-
related ecosystem services (i.e. water regulation).  

is  being  designed 

for  ecosystem 

framework 

in  Greece 

for  setting  up  natural  capital 
The  data  needed 
accounting 
is  scarce  and  unavailable. 
Methodologies  have  been  developed  to  gather  missing 
information  and  to  start  to  develop  accounts  on 
ecosystems, ecosystem services and biodiversity.  

The main obstacles for the SEEA EEA implementation in 
Greece  are  the  lack  of  capacity  and  expertise  of  the 
involved  stakeholders  and  state  agencies,  along  with 
data  gaps.  Knowledge  sharing  among  MAIA  partners 
should  address 
these  shortcomings  and  provide 
guidance via each country’s pilot accounts. 

Greece  18 

2022 priority actions 

 

 

continue 

supporting 

supporting 

the  mapping 

Continue 
and 
assessment  of  ecosystems  and  their  services, 
and  ecosystem  accounting  development, 
through  appropriate  indicators  for  integrating 
ecosystem  extent,  condition  and  services 
(including some monetary values) into national 
the 
accounts; 
development  of  national  business 
and 
biodiversity platforms, including natural capital 
accounting  systems  to  monitor  and  value  the 
impact of business on biodiversity. 
Implement 
Commission’s 
recommendations regarding the preparation of 
the 
the  marine  strategies,  encompasing: 
assessment, 
the  determination  of  good 
environmental status and the establishment of 
environmental targets.   

the 

Environmental Implementation Review 2022 – Greece 

 
 
 
 
 
Greece  19 

3. Zero pollution 

Clean air 

its 

EU  clean  air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean air legislation and defining strategic targets 
and actions for 2030 and beyond.  
The 2030 zero pollution action plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the EU ecosystems threatened by air pollution by 25%. 

The  EU  has  developed  a  comprehensive  body  of  air 
quality  legislation42,  which  sets  health-based  air  quality 
standards58  and  emission  reduction  commitments59  by 
Member State for a number of air pollutants. 

However, air quality in Greece continues to  be a serious 
concern. The latest available annual estimates (for 2019) 
by the European Environment Agency60 point to about 10 
400 premature deaths (or 107 300 years of life lost (YLL)) 
attributable  to  fine  particulate  matter  concentrations61, 
650  (6  900  YLL)  to  ozone  concentrations62  and  2  310 
(23.900 YLL) to nitrogen dioxide concentrations63 64. 

The  emissions  of  several  air  pollutants  have  decreased 
significantly  in  Greece  over  the  last  years,  while  GDP 
growth  continued  (see  graph).  According  to  the  latest 
projections  as  submitted  under  Article  10(2)  of  the 
National  Emission  reduction  Commitments  Directive 
(NECD)65 Greece expects to fulfill the emission reduction 
commitments  for  all  air  pollutants  covered  by  the 
directive  for  2020-  2029  and  for  2030  onwards.  Latest 
inventory  data  submitted  by  Greece,  prior  to  review  by 

58 European Commission, 2016. Air Quality Standards. 
59 European Commission, Reduction of National Emissions. 
60 European Environment Agency, Air Quality in Europe –2021 Rapport. 
in  this  report  as  regards  the  underpinning 
Please  see  details 
methodology, p.106 
61  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 human sources, including combustion. 
62 Low-level ozone is produced by photochemical action on pollution. 
63  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). 
64 Note that these  figures refer  to the impacts of individual pollutants, 
and to avoid double-counting cannot be added up to derive a sum.   
65 Directive 2016/2284/EU 

the  Commission,  indicate  that  Greece  is  in  compliance 
for  all 
with  the  emission  reduction  commitments 
pollutants in 2020. 

Greece  submitted 
programme on 29 January 2021. 

its  national  air  pollution  control 

Figure 16: Emission trends of main pollutants/ GDP in 
Greece, 2005-201966 

Figure 17: PM2.5 and NOx emissions by sector in 
Greece, 201967 

66 European Environment Agency 
67 European Environment Agency 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
 
 
                                                                 
Greece  20 

in  the  form  of  government  commitments  and  the 
adoption  of  Greece’s  Just  Transition  plan.  Greece  also 
received  a  general  priority  action  in  2019  to  sign  and 
ratify outstanding international agreements. 

2022 priority actions 

  Take,  in  the  context  of  the  National  Air  Pollution 
towards 
Control  Programme 
reducing emissions from the main sources mentioned 
above. 

(NAPCP),  actions 

  Ensure  full  compliance  with  the  EU  air  quality 
standards  and  maintain  downward  emissions  trends 
of  air  pollutants,  to  reduce  adverse  air  pollution 
impacts  on  health  and  economy  with  a  view  to 
reaching WHO guideline values in the future. 
  Greece is strongly encouraged to accelerate the 
ratification  of 
the  amended  Gothenburg 
Protocol,  Heavy  Metals  Protocol  and  POPs 
Protocol under the UNECE Air Convention. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive69 (IED).  
 As  announced 
in  the  European  Green  Deal,  the 
Commission  carried  out  an  impact  assessment  for  the 
revision  of  the  IED  in  2021  with  a  view  to  tabling  a 
proposal  in  early  202270.  The  revision  seeks  to  improve 
the  directive’s  contribution  to  the  zero  pollution 
objective, as well as its consistency with climate, energy 
and circular economy policies. 
The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  data  reported  to  the  EU  Registry 
(2018)71. 

In  Greece,  around  340 
installations  are 
required  to  have  a  permit  based  on  the  IED.  The 
distribution of installations is shown in the figure below. 

industrial 

69  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). 
70  The  revision  of  the  IED  is  performed  in  parallel  to  the  revision  of 
Regulation  (EC)  No  166/2006  on  the  European  Pollutant  Release  and 
Transfer Register (E-PRTR). 
71 European Environment Agency, European Industrial Emissions Portal. 

For 2020, exceedances above the EU air quality standards 
were  registered  for  nitrogen  dioxide  (NO2)  in  one  air 
quality  zone  and  for  particulate  matter  (PM10)  in  two 
zones.  Furthermore,  in  several  air  quality  zones  the 
target  values  on  ozone  concentration  are  not  being 
met68. 

Greece  has  not  yet  ratified  the  amended  Gothenburg 
Protocol,  the  Heavy  Metals  Protocol  and  the  POPs 
Protocol under the UNECE Air Convention. 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission  through  infringement  procedures  (mainly 
over  PM10  and  NO2  exceedances)  for  all  Member  States 
concerned,  including  Greece.  The  European  Commission 
has referred Greece to the Court of Justice of the  EU for 
poor  air  quality  due  to  the  persisting  exceedances  of 
PM10  limit  values  in  the  agglomeration  of  Thessaloniki 
and  NO2  limit  values  in  the  agglomeration  of  Athens 
(cases  C-70/21  and  C-633/21  respectively).  The  aim  of 
these  legal  actions  is  that  Greece  adopts  and  puts  in 
place appropriate measures in all air quality zones so that 
they comply with the EU limit values. 

In the 2019 EIR, Greece received five priority actions. The 
first  -  to  take  specific  action  under  the  national  air 
pollution  control  programme  (NAPCP)  –  has  only  seen 
limited  progress,  so  it  is  repeated  in  this  EIR.  On  the 
second priority action to upgrade and improve air quality 
monitoring  and  ensure  timely  reporting,  Greece  made 
some  progress  with  the  NAPCP  being  adopted.  On  the 
third  and 
-  toreduce  nitrogen  oxides  and 
particulate matter, including through planning, fiscal and 
energy choices, some progress was made, but WHO and 
EU  standards  still  need  to  be  complied  with.  There  was 
some progress on the fifth and final one -to build on the 
‘Coal Regions in Transition’ initiative to reduce the use of 
coal for domestic heating to limit air pollutant emissions, 

fourth 

68 European Environment Agency, Eionet Central Data Repository 

 Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
 
                                                                 
industrial  sectors 

in  Greece  with  most 

IED 
The 
installations in 2018 were the waste management sector, 
including landfills (29%), followed by intensive rearing of 
poultry and pigs (16%),  the energy sector (12%) and the 
food and drink sector (10%). 

Greece  21 

Figure 19: Emissions to air from IED sectors and rest of 
national total air emissions in Greece, 201873 

Figure 18: Number of IED industrial installations per 
sector in Greece, 201872 

In  2017,  one  power  station  in  Greece  (located  in  Agios 
Dimitrios)  was  among  the  top  30  E-PRTR  facilities  with 
the highest absolute damage costs from emissions of the 
main air pollutants and greenhouse gases74. 

The  environmental  burdens  caused  by 
industrial 
emissions  to  water  is  mainly  from  the  energy  sector  for 
total  nitrogen  and  heavy  metals,  and  from  refineries  for 
total organic carbon (TOC). The breakdown, based on E-
PRTR data, is presented in the figure below. 

73  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
74  EEA  (2021).  Costs  of  air  pollution  from  European  industrial  facilities 
2008–2017. Eionet Report - ETC/ATNI 2020/4. The ranking is based on 
the  approach  accounting  for  the  value  of  a  life  year  (VOLY),  table  41, 
p.124 & table 44, p.138. 

The  industrial  sectors  known  to  be  the  most  harmful  to 
the environment in Greece in terms of air emissions are: 
(i)  the  energy  sector  for  arsenic  (As),  cadmium  (Cd), 
chromium  (Cr),  copper  (Cu),  mercury  (Hg),  sulfur  oxides 
(SOx),  nitrogen  oxides  (NOx),  nickel  (Ni),  lead  (Pb),  zinc 
(Zn),  and  particulate  matter  (PM2.5);  (ii)  the  production 
and processing of metals (in particular iron and steel) for 
Cu and dioxins; (iii) intensive rearing of poultry or pigs for 
ammonia (NH3); and (iv) surface treatment and the foοd, 
drink  and  milk  sectors  for  non-methane  volatile  organic 
compounds  (NMVOCs).  See  the  breakdown  in  the  graph 
below. 

72  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
 
 
 
                                                                 
Figure 20: Relative releases to water from industry in 
Greece, 201875  

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers  the 
public  and  NGOs  to  ensure  that  permits  are  complied 
with.  As  part  of  environmental  inspection,  competent 
authorities  undertake  site  visits  at  IED  installations  to 
take  samples  and  to  gather  necessary 
information. 
According  to  Article  23(4)  of  the  IED,  site  visits  must  be 
carried out between once a year and once every 3 years, 
depending  on  the  environmental  risks  posed  by  the 
installations. In 2018,  Greece  made 47  site  visits,  mostly 
to  the  waste  management  sector,  including  landfills 
(26%),  followed  by  installations  for  the  energy  sector 
(19%),  the  mineral  sector  (17%)  and  the  food  and  drink 
sector (11%). 

Figure 21: Number of inspections in IED installations in 
Greece in 201876 

75  European  Environment  Agency,  E-PRTR,  European 
Industrial 
Emissions  Portal.  The  heavy  metals  are  presented  both  as  a  weighted 
sum  of  eco  toxicity  and  human  toxicity  factors  to  illustrate  both  the 
ecological  and  human  impact  (based  on  USEtox)  (data  retrieved  on  3 
November 2021). 
76  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

Greece  22 

(BAT) 
The  development  of  best-available-technique 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED77. Since the last 
EIR report, the Commission adopted BAT conclusions for 
Belgium for: (i) waste incineration; (ii) the food, drink and 
milk  industries;  and  (iii)  surface  treatment  using  organic 
solvents  including  the  preservation  of  wood  and  wood-
products with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reduction of pollution.  

In  2019,  Greece  received  priority  actions  to  review 
permits  and  to  strengthen  control  and  enforcement,  in 
line with BAT conclusions. Greece reported on the action 
taken  in  this  respect  via  the  EU  Registry,  and  the 
Commission 
is  following  up  by  checking  that  the 
information  provided  by  Greece  on  the  permits  granted 
for  each  installation  is  in  line  with  the  IED.  Another 
priority  action  for  Greece  was  to  address  pollution  in 
power  sector 
in  the  Agios 
installations,  especially 
Dimitrios,  Kardia  and  Amindeo  lignite  power  plants.  In 
addition,  an 
is  ongoing  on 
authorisations granted to large combustion plants. 

infringement 

case 

2022 priority action 

 

Continue  addressing  pollution  in  energy  sector, 
especially  in  the  Agios  Dimitrios  coal  power 
plant. 

Prevention of major industrial accidents – 
SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to  
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;  
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;  
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.  
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 
(the Seveso-III Directive)78. 

The below overview of industrial plants regulated by  the 
Seveso-III  Directive,  (‘Seveso  establishments’),  is  based 

77 European Commission BAT reference documents. 
78  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 

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Greece  23 

on  data  reported  to  the  eSPIRS  database  (2018)79  and 
Greece’s  report  on  the  implementation  of  the  Seveso-III 
Directive for the period 2015-201880. 

Of  the  210  Seveso  establishments  in  Greece,  134  are 
categorised as  lower-tier establishments (LTE) and 76 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present. The UTE are 
subject  to  more  stringent  requirements.  The  number  of 
Seveso  establishments  for  various  years  is  presented  in 
Figure 22.  

Figure 22: Number of Seveso establishments in Greece, 
2011, 2014 and 201881  

The  information  to  the  public  referred  to  in  Annex  V  of 
the  Seveso-III  Directive  –  especially  on  how  they  will  be 
warned in the case of a major accident ; the appropriate 
behaviour in the event of a major accident ; and the date 
of the last  site  visit  – are permanently available for 70% 
of  the  Seveso  establishments 
is 
important,  as  arming  the  public  with  information  may 
reduce the consequences of a major industrial accident. 

in  Greece.  This 

Figure 24: Share of UTE for which information on safety 
measures and desired behaviours was made available to 
the public in Greece, 2011, 2014 and 201883 

to 

According 
the  Greek  authorities,  an  external 
emergency plan (EEP) is required for 76 UTE. In 2018, 62 
UTE  had  an  EEP.  (See  Figure  23.)  Establishing  EEPs  is 
essential 
implementthe 
necessary  actions  to  protect  the  public  and  the 
environment in the case of a major industrial accident. 

to  properly  prepare  and 

Figure 23: Situation regarding EEP in Greece, 201882 

79 European Commission, Seveso Plants Information Retrieval System. 
80 As provided for by Article 21(2) of the Seveso-III Directive 
81 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 
82 idem. 

2022 priority action 

 

Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on information to the public and EEP. 

Noise 

The  Environmental  Noise  Directive  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise 
although  it  does  not  set  noise  limits  as  such.  Its  main 
instruments  in  this  respect  are  strategic  noise  mapping 
and planning. A key target under the 2030 zero pollution 
action  plan  is  to  reduce  by  30%  the  share  of  people 
chronically  disturbed  by  transport  noise  compared  to 
2017. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress84 . 

In Greece, based on limited data, environmental noise is 
estimated  to  cause  at  least  100  premature  deaths  and 
300  cases  of  ischaemic  heart  disease  per  year85.  In 

83 idem 
84 WHO 2018, Environmental Noise Guidelines for the European Region 
85  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based  on  :  (i)  the  data  reported  by  Member  States  on  noise 

 Environmental Implementation Review 2022 – Greece 

 
 
 
 
 
                                                                 
 
 
 
                                                                 
 
Greece  24 

addition,  some  45  000  people  suffer  from  disturbed 
sleep. According to the latest full set of information that 
has  been  analysed,  noise  mapping  of  roads  and 
agglomerations  remains  incomplete.  Moreover,  Greece 
still  lacks  action  plans  for  10  agglomerations  and  most 
roads.  These  plans,  which  will  undergo  a  public 
consultation, should include measures to reduce noise. 

The two priority actions set out in the 2019 EIR are rolled 
over,  as  Greece’s  progress  has  been  limited,  as  detailed 
above.  

2022 priority actions 

 
 

Complete noise mapping. 
Complete action plans for noise management in 
agglomerations and major roads. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

Water Framework Directive 

By March 2022, Member States  have to report the third 
generation  of  river  basin  management  plans  (RBMPs) 
under the WFD. The Commission will assess the reported 
status and progress, checking how the findings identified 
in  the  assessment  of  the  second  RBMPs89  have  been 
addressed. Greece has not yet reported the third RBMPs. 

The  Commission’s  6th  implementation  report  on  the 
WFD90,  published 
in  December  2021,  assessed  the 
progress  of  the  implementation  of  the  ‘programmes  of 
measures’  and  the  monitoring  of  the  new  priority 
substances,  among  other  developments.  The  progress 
report  for  Greece91  stated  that  most  of  the  measures 
were  planned  to  begin  in  the  second  half  of  the  second 
cycle, and found that the level of actual implementation 
in the field is unknown. 

According to the 2nd RBMPs reporting and data published 
in  202092,  63.8%  of  all  surface  water  bodies  in  Greece93 
are in a good ecological status (with 8.0% in an unknown 
status)  and  88.6%  are  in  a  good  chemical  status  (with 
9.8%  in  an  unknown  status).  For  ground  waters,  84.6% 
achieve  good  chemical  status  and  15.7%  are  in  poor  a 
quantitative status. 

The  below  figure  shows  the proportion  of  surface  water 
bodies  in  the  EU  that  failed  to  achieve  good  ecological 
status.  

Figure 25: Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District94 

is 

(WFD)86 

The  Water  Framework  Directive 
the 
cornerstone of the EU water policy for the 21st century87. 
The  WFD  and  other  water-related  legislation88  set  the 
framework 
integrated  water 
sustainable  and 
management,  which  aims  to  ensure  a  high  level  of 
protection  of  water  resources,  prevention  of  further 
deterioration and restoration to good status. 

for 

exposure  covered  by  Directive  2002/49/EC;  (ii)  ETC/ATNI,  2021,  Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for  estimating  missing  data,  ETC/ATNI  Report  No  2021/06,  European 
Topic Centre on Air Pollution, Transport, Noise and Industrial Pollution; 
(iii)  the  methodology  for  health  impact  calculations,  ETC/ACM,  2018, 
Implications of environmental noise on health and wellbeing in Europe, 
Eionet  Report  ETC/ACM  No  2018/10,  European  Topic  Centre  on  Air 
Pollution and Climate Change Mitigation. 
86 The Water Framework Directive (2000/60/EC). 
87 The EU Water Policy. 
88  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the Industrial Emissions Directive (2010/75/EU) and the new Regulation 
on minimum requirements for water reuse (2020/741). 

89  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
90 See the 6th Implementation Report of the WFD and FD. 
91  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Greece, 2022. 
92 WISE Freshwater (europa.eu) 
93 River, lake, transitional, coastal, territorial 
94 European Environment Agency, 2021. 

 Environmental Implementation Review 2022 – Greece 

 
                                                                                                        
 
                                                                 
Greece  25 

The  below  figure  shows  the  proportion of surface  water 
bodies in the EU that  failed  to  achieve  a good chemical 
status.   For  Greece,  the  percentage  is  1.6%,  if  one 
includes water bodies failing due to substances behaving 
as  ubiquitous  PBTs  (persistent,  bio-accumulative  and 
toxic  chemicals).  Without  PBTs,  1%  of  surface  water 
bodies failed to achieve good chemical  status  (with 10% 
of unknown chemical status). 

Figure 26: Percentage of water bodies not achieving 
good chemical status95 

The  increasing  demand  for  water  for  multiple purposes 
and the intensification of severe weather conditions due 
to  climate  change  have  put  significant  strain  on 
freshwater supplies in Greece.  The registration of water 
it  also  gathers 
  apositive  step,  as 
abstraction 
information  on 
in 
inactive  abstractions,  abstractions 
private  networks  and  abstractions  for  the  needs  of 
forestry  services  in  forested  areas  and  areas  designated 
for reforestation. 

is 

Figure 27: Water abstraction per sector in Greece97 

Under  the  IED  framework,  it  should  be  stressed  that 
Greece showed a significant increase (236%) over the last 
decade in industrial releases of heavy metals like Cd, Hg, 
Ni, Pb and a decrease  (55.4%) in Total Organic Carbon – 
TOC to water96. 

The  total  water  abstracted  annually  (corresponding  to 
2019  baseline)  in Greece  from  surface  and  groundwater 
sources is 10,027. 80 hm3 (EEA, 2022). Water abstraction 
per  sector  is  as  follows:  80.47%  for  agriculture;  16.76% 
for public water supply; 0.97% for electricity cooling; and 
1.80%  for  manufacturing  (see  the  following  figure). 
Greece uses  a  register to  control  water  abstractions. 
Water  use  and  water  utilisation  projects  are  subject  to 
authorisation, while all relevant permits are registered in 
the  National  Register  of  Abstractions  (NRA).  These 
if  an 
authorisations  are  reviewed,  as  appropriate, 
amendment is requested (change of name, use, quantity, 
etc.)  and  and  in  accordance  with  the  Programme  of 
Measures  of  the  RBMPs.  Review  intervals  can  therefore 
exceed  6  years.  As  many  permit  applications  are  still 
pending,  the  NRA  cannot  provide  accurate  data  on  the 
number  of  water  abstractions  and  on  the  amount  of 
water abstracted.  

95 European Environment Agency, December 2019.  
96 European Environment Agency, June 2021. 

According to the WEI+98, Greece’s level of water scarcity 
stands  at  39.37%,  just  below  the  40%  threshold  for 
‘severe’  water  scarcity99.  Figure  28  below  shows  how 
Greece compares  to  the  EU  average.  Greece  has  the 2nd 
highest level of water scarcity in the EU. 

Figure 28 : Water exploitation index plus (WEI+) inside 
EU, 2017100 

97  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
98 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how  much  water  is  abstracted  and  how  much  water  is  returned  after 
use to the environment. 
99  By  May  2022,  EEA  will  develop  seasonal  WEI+  at  river  basin  and 
NUTS2  level,  which  provide  a  more  complete  picture  of  water  stress 
and water scarcity for each Member State. 
100 European Environment Agency, Water exploitation Index Plus, 2022. 

 Environmental Implementation Review 2022 – Greece 

 
 
 
 
                                                                 
 
 
 
 
                                                                 
Floods Directive 

As  mentioned,  the  Commission  published  the  6th 
implementation  report  on  the  FD  in  December  2021, 
which  included  a  review  and  update  of  the  preliminary 
flood  risk  assessments  during  the  second  cycle  (2016-
2021). 

The  assessment  report101  identified  the  additional  work 
on the change in rainfall intensity due to climate change 
as a good practice. Moreover, methodologies have been 
worked  out  for  the  revision  of  the  APSFRs  and  for 
defining past floods with significant adverse impacts  and 
potential adverse consequences of future floods.  Explicit 
consideration  of  the  effects  of  long-term  developments 
(e.g. land use change), beyond climate change, should be 
added to these methodologies.   

Greece  has  not  adopted  and  reported  the  second 
generation  of  flood  risk  management  plans  (FRMPs) 
under  the  Floods  Directive.  The  European  Commission 
will  assess  the  progress  made  since  the  first  plans  were 
adopted  and  will  publish  a  new  report,  as  was  done  in 
2019. 

 Drinking Water Directive 

On  the  Drinking  Water  Directive102,  no  new  assessment 
of the quality of drinking water is available since the 2019 
EIR. The quality of drinking water in Greece has not been 
highlighted as an area of concern. 

The  recast  Directive  103entered  into  force  on  12  January 
2021, and Member States have until 12 January 2023 to 
transpose  it  into  their  national  legal  system.  Greece  will 
have to comply with these reviewed quality standards. 

Bathing Water Directive 

On the  Bathing Water Directive, Figure  29  shows that  in 
2020  97.1%  of    Greece’s  1  634  bathing  waters  were  of 
excellent  quality104.  Detailed 
information  on  Greeκ 
bathing  waters  is  available  on  the  national  portal105  and 
on  an  interactive  map  developed  by  the  European 
Environment Agency106. 

101  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification  of  Areas  of  Potential  Significant  Flood  Risk  under  the 
Floods Directive : Member State : Greece, 2022 
102 OJ L 330, 5.12.1998, p. 32–54. 
103 OJ L 435, 23.12.2020, p. 1–62. 
104  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu). 
105 ΕΓΥ - Greek Bathing Water Profiles Registry 
106  EEA,  State  of  bathing  waters  in  2020  —  European  Environment 
Agency (europa.eu) 

Greece  26 

Figure 29: Bathing water quality in Europe in the 2020 
season107 

Figure 30: Greece, bathing water quality 2017-2020108 

Nitrates Directive 

The  Commission’s  latest  implementation  report  on  the 
Nitrates  Directive109,  covering  2016-2019110,  warns  that 
nitrates  are  still  causing  harmful  pollution  to  EU  water. 
Excessive  nitrates  in  water  are  harmful  to  both  human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication.  Where  national  authorities  and  farmers 
have cleaned up  waters, it has had a  positive impact on 
drinking  water  supply  and  biodiversity,  as  well  as  on 
sectors  such  as  fisheries  and  tourism  that  depend  on 

107 European Environment Agency, Bathing Water Quality in 2020, 2022. 
108  European  Environment  Agency,  European  Bathing  Water  Quality 
in 2017, 2018, 2019, 2020.  
109  Implementation of the Nitrates Directive in the EU. 
110 Last Implementation Report 2016-2019 

 Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
 
 
                                                                 
them.  Nevertheless,  excessive  fertilisation  remains  a 
problem in many parts of the EU.  

Greece  has  a  low  livestock  density  and  the  surplus  of 
nitrogen  is  in  line  with  the  EU  average,  while  there  is 
almost no surplus of phosphorus. It has a well-developed 
network  of  monitoring  stations.  The 
latest  report 
includes  data  for  year  2018-2019  only,  missing  2016-
2017.  There  are  a  number  of  hotspots,  with  a  nitrate 
concentration  above  50  mg/l.  A  high  number  of  surface 
waters  are  eutrophic.  Groundwater  quality  has  been 
improved between the reporting periods 2012-2015 and 
2016-2019,  since  the  recorded  levels  of  nitrates  fell  by 
14.2%  for  average  concentrations  above  the  limit  of  50 
mg/l  NO3  and  by  7.5%  above  40  mg/l  NO3  (EEA,  CDR, 
Nitrates  Report  2020).    A  high  number  of  groundwater 
monitoring stations with nitrate concentrations above 50 
mg/l  and  of  surface  waters  found  to  be  eutrophic  are 
located  outside  of  nitrate  vulnerable  zones  (NVZ).  A 
revised action programme was published in 2019. 

Urban Waste Water Treatment Directive  

Greece  has,  over  the  years,  encountered  serious  and 
structural difficulties in meeting its obligations under the 
Urban Waste Water Treatment Directive (UWWTD).  

Overall,  96%  of  urban  waste  water  in  Greece  is  treated 
according to the requirements of the UWWTD111. This  is 
above the EU average of 76% in 2018. On the amount of 
urban  wastewater  that  needs  to  be  collected  according 
to  the  UWWTD,  Greece  has  met  its  targets.  However, 
further  efforts  are  needed 
to  provide  biological 
treatment to an additional 3.8% and biological treatment 
with  nitrogen  and/or  phosphorus  removal  to  0.6%. 
treated  urban  wastewater for 
Greece reuses 2%  of 
irrigation in agriculture and for other uses. 

Figure 31: Proportion of urban waste water that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal) in compliant urban areas of the 
UWWTD (‘compliance rate’)112 

111 Greece (europa.eu) 
112 European Commission, WISE Freshwater, 2021. 

Greece  27 

Despite the  steady improvement in compliance  over the 
years,  for  which  EU  funding  has  been  fundamental,  the 
incomplete  implementation  of  the  UWWTD  has  already 
led  to  several  Court  of  Justice  rulings  against  Greece. 
Greece  has  had  to  pay  heavy  fines  in  two  urban  waste 
water  cases  (collection  and  treatment  of  wastewater  in 
five  agglomerations  in  Eastern  Attica113  and  in  four 
agglomerations in Western Attica114). To date, it has paid 
approximately EUR 67 million for these two cases. It has 
also  been  condemned  by  the  Court  in  another  case,  for 
lack of adequate collection and treatment of wastewater 
in various small agglomerations115. 

The  2019  EIR  for  Greece  included  three  priority  actions 
on  water  management.  Considering  that  progress  has 
been limited, the following actions are suggested. 

2022 priority actions 

  New  physical  modifications  of  water  bodies  should 
be  assessed  in  line  with  Article  4(7)  of  the  WFD.  In 
these assessments alternative options and adequate 
mitigation measures should be considered. 
To adopt the 2nd FRMPs and 3rd RBMPs. 
Efforts  should  be  done  to  improve  the  coordinated 
implementation  between  water,  marine  and  nature 
policies. 

 
 

  Verify  the  designation  of  NVZ,  considering  that  not 
all  the  ground  waters  with  nitrate  concentrations 
above  50  mg/l  and  surface  waters  found  to  be 
eutrophic  are  included  in  the  NVZ’s.  Extend  the 
monitoring  data  to  include  the  four  years  of  the 
reporting period and report the trends. 
Complete 
implementation  of  the  Urban  Waste 
Water Treatment Directive for all agglomerations, by 
building up the necessary infrastructure. 

 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment. 
In 
October  2020,  the  Commission  published  its  chemicals 
strategy  for  sustainability  - 
‘Towards  a  Toxic-Free 
Environment’116  which  led  to  some  systemic  changes  in 
EU chemicals legislation. It is part of the EU zero pollution 
ambition,  which  is  a  key  commitment  of  the  European 
Green Deal. 

legislation1117 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 

113 C-167/14 
114 C-328/16 
115 C-320/15 
116 COM(2020) 667 final 
117 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 

 Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
                                                                 
ensures  stability  and  predictability 
operating within the internal market.  

for  businesses 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of  Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’).. 
In  December  2020,  the  Commission  assessed  the 
Member  States  reports  on  the  implementation  and 
enforcement  of  these  Regulations118,  in  line  with  Article 
117(1)  of  the  REACH  Regulation  and  Article  46(2)  of  the 
CLP  Regulation.  According  to  the  latest  available  data, 
national enforcement structures have not changed much 
in recent years. However, it is apparent from this report 
that  there  are  still  many  disparities  in  the  REACH-CLP 
implementation  and  notably  in  the  area  of  the  law 
enforcement. The recorded compliance levels in Member 
States seem to be quite stable over time, but with a slight 
worsening  trend,  which  is  likely  due  to:  (i)  enforcement 
authorities  being  more  effective 
in  detecting  non-
compliant  products/companies;  and  (ii)  more  non-
compliant  products  being  put  on  the  EU  market.  In 
August  2021,  the  Commission  published  a  quantitative  
assessment  of  the  enforcement119  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 
CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement.   

Responsibility  for  checking  compliance  with  REACH  in 
Greece lies with the following authorities120:  

 

Independent  Authority 
Directorate-General  

for  Public  Revenue, 

  General  Chemical  State  Laboratory  -  GCSL 
(Directorate  of  Energy,  Industrial  and  Chemical 
Products); and all the regional chemical services. 

Greece  has  fully  implemented  both  the  REACH  and  the 
CLP enforcement strategies121, notably:  

  An annual inspections plan; 
 

Prioritisation of enforcement based on results of 
previous controls, annual REF and pilot projects, 
new  obligations  or  an  extension  of 
the 
obligations  that  already  apply  to  new  products, 
complaints and national target groups; 
Yearly reporting on enforcement activities. 

 

Greece  28 

impose  further 
competent  authority  may  decide  to 
penalties  in  addition  to  a  fine.  That  authority  may 
also, where  necessary, order  the  provisional  seizure  of 
assets and documents.  

In Greece, 70 staff members are allocated to REACH and 
CLP enforcement122.  Almost  2 000 REACH controls were 
carried  out  in  the  reporting  period  (2019).  Most  were 
proactive (inspections) rather than reactive/non-routine (i.e. 
investigations  in  response  to  complaints,  accidents  and 
referrals)123. 

Figure 32: Percentage of non-compliance cases out of 
the total number of REACH and CLP controls during 
2019 per Member State and compared to the EU 
average124 

2022 priority action 

  Upgrade 

the 

implementation  and  enforcement 
administrative capacities towards a ‘zero tolerance’ to 
non-compliances.  

As  a  rule,  all  infringements  of  REACH  are  classed  as 
‘serious’  or  ‘very  serious’  environmental  administrative 
offences.  If  the  infringement  is  sufficiently  serious,  the 

Final 

European 

118 
Commission, 
reporting_2020.pdf (europa.eu) 
119  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 
120  Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.68. 
121 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.76. 

report_REACH-CLP  MS 

Final 

European 

Commission, 

122 
reporting_2020.pdf (europa.eu), p. 74. 
123  Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu),  p.  87-
88 
124 European Commission, Final  report  on the operation of REACH and 
CLP, pp.87-88, 2022. 

report_REACH-CLP  MS 

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Greece  29 

4. Climate action 

Key national climate policies and 
strategies  

Greece  has  an  integrated  national  energy  and 
climate plan (NECP) for 2021-2030, which  builds on 
other  energy  and  climate  plans  and  is  consistent 
with  the  long-term  strategy  for  2050.  The  overall 
goal  of  the  government’s  strategy  is  the  transition 
towards climate neutrality by 2050 in a sustainable, 
fair, and cost-efficient manner.  

Under 
its  Recovery  and  Resilience  Plan  (RRP), 
Greece  allocates  37.5  %  of  the  budget  to  climate 
reforms  and 
objectives  and  outlines  crucial 
investments  to  further  the  transition  to  a  more 
sustainable, 
climate-resilient 
economy.  It  covers  a  number  of  areas,  including 
clean  energy,  building  and  renovating,  sustainable 
mobility,  resilient  infrastructure  and  sustainable 
agriculture. 

low-carbon 

and 

Greece  adopted  its  national  adaptation  strategy  in 
2016 The 13 Regional adaptation action plans have 
been  drafted  and  are  expected  to  be  adopted  by 
the  regional  councils 
in  2022.  The  EU-funded 
integrated  project  LIFE-IP  AdaptInGR  (2019-2026) 
supports  the  implementation  of  the  strategy  and 
action  plans  through  activities  to  enhance  climate 
capacity, 
data, 
sectoral 
facilitate 
mainstreaming, 
improve  monitoring  and  raise 
awareness (www.adaptivegreece.gr).  

build 

Between 1990 and 2020,  GHG emissions decreased 
by 28% in Greece. 

Figure 33: Total GHG emissions (incl. international 
aviation) in Greece, 1990-2020 

In line with the Paris Agreement and as part of the 
European  Green  Deal,  the  European  Climate  Law 
sets the EU target of reaching climate neutrality by 
2050 and reducing greenhouse gas (GHG) emissions 
by  55%  by  2030  compared  to  1990.  The  law  also 
limits  the  contribution  that  carbon  removals  can 
make  towards  emission  reductions  in  2030,  to 
ensure a sufficient mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution  (NDC)  to  the 
UNFCCC in December 2020.  
The EU is working across all sectors and policies to 
cut  GHG  emissions  and  make  the  transition  to  a 
climate neutral and sustainable economy, as well as 
addressing 
the  unavoidable  consequences  of 
climate change.  
incentivises  emissions 
EU  climate 
industry, 
from  power  generation, 
reductions 
transport,  the  maritime  sector  and  fluorinated 
gases (F-gases) used in products.  

legislation 

for 

different 

standards 

For road transport, EU legislation requires the GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010125  and  sets  binding  GHG 
emission 
vehicle 
categories126. 
Under  the  F-gas  Regulation,  the  EU’s  F-gas 
emissions  will  be  cut  by  two-thirds  by  2030 
compared  with  2014  levels.  From  2021  emissions 
and  removals  of  GHG  from  LULUCF  have  been 
included in the EU emission reduction efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States 
are required to report on their national adaptation 
policies127 as the European Climate Law  recognises 
adaptation  as  a  key  component  of  the  long-term 
global response to climate change. Member States 
will  be  required    to  adopt  national  strategies  and 
the  EU  will  regularly  assess  progress  as  part  of  its 
overall governance on climate action.  The updated 
EU adaptation strategy, published in February 2021, 
sets out  how the EU can adapt  to the unavoidable 
impacts  of  climate  change  and  become  climate 
resilient by 2050. 

125  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict 
quality requirements for fuels used in road transport in the EU to 
protect  human  health  and  the  environment,  and  to  make  road 
travel across the EU safer.  
126 Regulation (EU) 2019/631 
127 Article 29 of Regulation (EU) 2018/1999 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
 
 
 
 
Effort sharing target  

Key sectoral developments 

Greece  30 

the  Effort 

targets  under 

For  emissions  not  covered  by  the  EU’s  emissions 
trading scheme (ETS), Member States have binding 
Sharing 
national 
legislation128.  The  country  is  estimated  to  largely 
overachieve  its  current  2030  target.  Under  EU 
legislation,  Greece  has  a  target  to  reduce  GHG 
emissions  in  the  non-ETS  sectors  (buildings,  road 
and  domestic  maritime  transport,  agriculture, 
waste and small industries) by 4% by 2020 and 16% 
2030,  compared  to  2005.  The  country’s  non-ETS 
emissions  in  2019  were  much  lower  than  its  2020 
target.  In  its  NECP,  Greece  intends  to  exceed  its 
current non-ETS target for 2030 of -16%. 

Figure 34: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in 
Greece, 2020 and 2030 as percentage change from 
2005 

In road transport, the GHG intensity of vehicle fuels 
in  Greece  decreased  by  3.5%  between    2010  and 
2019. The country needs to act swiftly to meet the 
current EU-wide reduction target by 6%. There are 
several types of action that Member States can take 
in  this  regard,  for  example:  (i)  further  expanding 
in  road  transport;  (ii) 
the  use  of  electricity 
in  particular 
supporting  the  use  of  biofuels, 
advanced 
the 
(iii) 
biofuels; 
development and deployment of renewable fuels of 
non-biological  origin;  and  (iv)  reducing  upstream 
emissions before refining processes. 

incentivising 

Road transport accounted for 17% of Greece’s total 
GHG  emissions  in  2019.  Emissions  have  decreased 
by 20% compared to 2005.  

Figure 36: GHG emissions by sector in Greece129 – 
historical emissions 1990-2020, projections 2021-
2030 130 

Figure 35: Emissions, annual emission allocations 
(AEAs) and accumulated surplus/ deficit of AEAs 
under the Effort Sharing Decision in Greece, 2013-
2020  

128 Regulation (EU) 2018/842 

To reduce emissions from buildings, Greece has set 
a  target  to  renovate  3%  of  the  total  floor  area  of 
public  buildings  per  year  and  to  upgrade  40  000 
homes  per  year  by  2030  (equal  to  12-15%  of  total 
housing stock by 2030). According to Greece’s long 
term  renovation  strategy,  final  energy  demand  in 
buildings will be reduced by 8% compared to 2015 
levels through targeted policy measures.  

In  the  land  use,  land  use  change  and  forestry 
(LULUCF) sector, Greece projects a further decrease 
of  net  removals  by  2030.   Reported  quantities 

129  The  sectors  in  the  figure  correspond  to  the  following  IPCC 
sectors:  Energy  supply:  1A1,  1B  and  1C.  Energy  use 
in 
manufacturing industries: 1A2. Industrial processes and product 
use:  2.  Transport:  1A3.  Other  energy  use:  1A4,  1A5  and  6. 
Agriculture: 3. Waste: 5. International aviation: 1.D.1.a. 
130 European Environmental Agency, Total GHG trends and 
projections. 

Environmental Implementation Review 2022 – Greece 

 
 
 
 
                                                                 
 
                                                                 
Greece  31 

hydrogen  production).  The  Reliance  on  heavy-
polluting  lignite-fired  power  plants  and  natural 
gas remains an issue in Greece.  

  Enhance sustainable transport 
  Energy  efficiency  remains  a  key  issue,  with  a 
modest 
level  of  ambition  for  final  energy 
consumption  and  a  low  level  of  ambition  for 
primary energy consumption. 

under  the  Kyoto  Protocol  for  the  LULUCF  sector  in 
Greece  show  net  removals  of,  on  average,  -2.0  Mt 
CO2-eq  for  2013-2019. 
In  this  regard,  Greece 
contributes with 0.6% to the annual average sink of 
-344.9 Mt  CO2-eq of the EU-27. Accounting for the 
same period depicts net credits of, on average, -0.4 
Mt CO2-eq, which corresponds to 0.4% of the EU-27 
accounted  sink  of  -115.0  Mt  CO2-eq.  Reported  net 
removals  are  nearly  unchanged  over  the  7-year 
period,  but  accounted  net  credits  show  a  more 
accentuated pattern with an increase in 2018. 

Figure 37: Reported and accounted emissions and 
removals from LULUCF in Greece131 

Use of revenues from the auctioning of EU 
ETS allowances. 

The total revenues from the auctioning of emission 
allowances under the EU ETS in 2012-2021 came to 
nearly  EUR  3.4  billion.    In  Greece,  revenues  are 
earmarked  and  fully  spent  on  domestic  climate 
change and energy projects.  

2022 priority actions 

 

Increase  renewable  energy.  There  is  room  for 
Greece  to  further  exploit  its  renewable  energy 
potential,  resulting  in  a  lower  carbon  intensity, 
green 
resource 

diversification 

(including 

131  The  differences  between  reported  and  accounted  emissions 
from  LULUCF  under  the  Kyoto  Protocol  are  described  in  the 
‘explanatory  note  on  LULUCF  –  accounted  and  reported 
quantities under the Kyoto Protocol’.   

Environmental Implementation Review 2022 – Greece 

 
 
 
 
                                                                 
Greece  32 

Part II: Enabling framework: Implementation tools 

5. Financing

Environmental investment needs in the EU 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to    close  the  financing  gaps.  Post-2020,  environmental 
measures  will  also  be  supported  by  the  EU’s  Covid-19 
recovery  fund  (via  the  RRF)  and  the  “do  no  significant 
harm” (DNSH) principle which runs across the EU budget. 
Tthe  renewed  commitments  made  at  the  COP  26 
(Glasgow,  Oct.-Nov. 
  the  Biodiversity 
  2021)  and 
(COP15,  April-May  2022)  will  also  be 
Convention 
reflected in the EU budget132. 

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition  cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
additional  action 
is  taken)  for  climate,  energy  and 
transport  were  estimated  in  2021  at  EUR  390  billion  a 
year  (EU27)  with  a  further  EUR  130  billion  a  year  to 
deliver the EU’s core environmental objectives  133. Those 
investment  needs reflect the implementation objectives 
to 2020 and to 2030  (except  for climate adaptation, the 
costs  of  which    are  expected  to    last  over  a  longer  time 
horizon).   

A  preliminary  update  of  the  EU’s  core  environmental 
investment gap is provided in Table 1  134. Almost 40% of 
the  environmental  investment  needs  relate  to  dealing 
with  pollution,  which  accounts  for  nearly  two-thirds  of 
the  total  gap  if  combined  with  water  management.  The 
investment  gap 
is 
estimated  to  be  between  EUR  13-28  billion    a  year, 
depending  on  levels  of  circularity  implemented.  The 
annual  biodiversity  financing  gap  is  estimated  at  around 
EUR 20 billion.    

in  circular  economy  and  waste 

132  The  Convention  on  Biological  Diversity  (cbd.int); Post-2020  Global 
Biodiversity Framework | IUCN 
133  SWD(2021)621,  accompanying  proposal  COM(2021)557  to  amend 
the REDII Directive (EU) 2018/2001. 
134  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  Source:  DG  ENV  ”Study  supporting  EU  green  investment 
needs  analysis”  (ongoing,  2021-2023)  and  DG  ENV  internal  analysis 
”Environmental  investment  needs  and  financing  in  the  EU’s  green 
transition” July 2020. 

Table 1: Estimated breakdown of the EU27’s 
environmental investment gaps, by environmental 
objective, 2021-2030 (per year)135 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems 136 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

 % 

 39% 

24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in Greece  

Completing  and 
improving  waste  and  wastewater 
management infrastructure is considered the top priority  
for environmental investment in Greece.  This is followed 
by investments to compy with the Nature Directives and 
to  monitor  and  mitigate  air  pollution.  Furthermore,  the 
following  environmental  investment  needs  have  been 
identified by sector:  

Pollution prevention & control 

The  EU’s  first  Clean  Air  Outlook137  under  the  clean  air 
programme estimated that the total air pollution control 
costs  for  Greece  to  reach  the  NECD  emission  reduction 
requirements  138  by  2030  amount  to  EUR  1  338  million 

135 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-2023) and DG Environment 
internal analysis ”Environmental Investment needs and financing in the 
EU’s green transition“,  July 2020.  
136  To  meet  the  needs  of  the  2030  biodiversity  strategy  (Natura  2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for nature (COM/2020/380 final). To fully cover the strategy (including 
restoration) EUR 30-35 billion may be needed, indicating a gap of EUR 
10-20 billion a year compared to current baseline expenditure. 
137 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018.  
138  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Source:  Progress  towards  the  achievement  of  the 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
 
                                                                 
 
per  year,  including,  EUR  926  million  a  year  for  capital 
investment (assuming the achievement the 2030 climate 
and energy targets).   

The  second  EU’s  Clean  Air  Outlook139 suggests  that  the 
EU would largely achieve the reductions that correspond 
to the obligations under the NEC Directive for 2030 if: i) 
all  relevant 
legislation  adopted  up  to  2018  was 
implemented  (including  all  air  pollution  targets  and  the 
2030  climate  and  energy  targets  set  in  2018);    ii)  and 
Member  States  also 
the  measures 
announced 
in  their  national  air  pollution  control 
programmesThe  only  exception  is  for  ammonia  for  15 
Member States , excluding Greece.   

implemented 

Greece  33 

Waste & circular economy 

According  to  a  Commission  study145,  to  meet  the 
recycling  targets  for  municipal  waste  and  packaging 
waste,  Greece  needs  to   invest  an  additional  EUR  385 
million (around EUR 55 million per year) in 2021-2027 on 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste 
registry 
digitalisation. Biowaste  treatment  facility  replacement 
costs (EUR 9.4 million in 2021-2027 or EUR 1.3 million per 
year) are included in this amount, though it excludes the 
investment  necessary  for  other  key  waste  streams 
(plastics, textile, furniture) and to increase circularity and 
waste prevention across the economy.  

and  waste 

facilities 

sorting 

Water management 

Biodiversity & ecosystems 

According  to  the  OECD  study  ‘Financing  a  Water  Secure 
Future’  (2022)140,  Greece  relies  mainly  on  conventional 
resources for its water supply (e.g. groundwater). A small 
fraction  (2%)  of  its  total  drinking  water  supply  comes 
from desalination. Projections shows that  Greece  could 
face among the highest potential health risks due to non-
safe  drinking  water  in  the  EU  by  2050.  Also,  leakage 
within the distribution system is substantial.  

The  recently  submitted  prioritised  action  framework 
(PAF)  for  Greece  shows  that  nature  protection  costs 
(including  Natura  2000)  in  2021-2027  amount  to  EUR  1 
039.5  million.  This  represents  an  annual  cost  of  about 
EUR 148.5 million, of which EUR 24.7 million are one-off 
costs  146. This excludes additional costs to implement the 
biodiversity  strategy  for  2030,  including  on  increased 
protection and restoration. 

Freshwater  shortage  and  sea  level  rise  are  the  greatest  
climate change-related risks faced by the country. Major 
drought  episodes  are  projected  to  become  more 
frequent  and  severe,  with  particularly  intense  summer 
droughts.  Greece  faces    challenges  in  financing  future 
investment needs for water supply and sanitation as well 
as  flood  protection,  particularly  for  areas  where  EU 
funding  is  not  available141.  Up  to  2030,  the  cumulative 
additional investment needed for Greece is estimated at 
EUR  1.7  billion  (around  170  million  per  year)  over 
baselines, of which around 90% relates to wastewater 142. 
Moreover,  the  recent  (6th)  Water  Framework  Directive- 
and  Floods  Directive  Implementation  Report143  and  the 
financial - economic study144 accompanying it, are also a 
relevant source of information in this domain. 

EU’s  air  quality  and  emissions  objectives,  IIASA  2018.  (page  29). 
Requirements are based on Directive (EU) 2016/2284.  
139  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis  (IIASA),  Support  to  the  development  of  the  Second  Clean  Air 
Outlook, 2020 and Annex.   
140 OECD, Financing a Water Secure Future, 2022. 
141 OECD, Financing a Water Secure Future, 2022.  
142  OECD,  Greece-  Country  fact  sheet-  Financing  Water  Supply, 
Sanitation and Flood Protection. 
143 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

144  European  Commission,  Directorate-General 
for  Environment, 
Economic  data  related  to  the  implementation  of  the  WFD  and  the  FD 
and the financing of measures, Final report. Publications Office, 2021. 

The  main  conservation  priorities  are  to:  (i)  improve 
knowledge at national and local level on the conservation 
status  of  species  and  habitat  types;  (ii)  improve  the 
conservation  status  of  species;  (iii)  address  interactions 
and  conflicts  between  wildlife  and  human  activities;  (iv) 
mitigate  the  effects    of  climate  change  on  protected 
species,  habitats  and  areeas; 
  green 
infrastructure;  (vi)  conserve  genetic  resources;  (vii) 
address  the  effects  of  invasive  alien  species  with  an 
emphasis  on  the  marine  environment  and  habitat 
species;  and 
large 
infrastructure  (e.g.  wind  farms,  hydrocarbon  extraction 
research,  etc.)  on  Natura  2000  sites  and  on  community 
species / habitat types of interest. 

the  effects  of 

(viii)  mitigate 

(v)  create 

EU environmental funding  2014-2020 

The  multiannual  financial  framework  (MFF)  for    2014-
2020  allocated  almost  EUR  960  billion  (in  commitments, 
2011 prices)147 for the EU to spend over this period. The 
commitment  in  this  2014-2020  MFF  included  a  20% 
climate spending target and funding opportunities for the 
wider  environment,  in  particular,  under  the  European 

145  European  Commission,  Study  on  investment  needs  in  the  waste 
sector and on the financing of municipal waste management in Member 
States, 2019.  
146  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
instruments  report  to  the 
improving  synergies  with  EU  funding 
European Commission, 2021.  
147 Council Regulation (EU, Euratom) No 1311/2013. 

Environmental Implementation Review 2022 – Greece 

 
                                                                                                        
                                                                 
Structural  and  Investment  (ESI)  Funds148.  The  2014-2020 
MFF budget  was subsequently topped up with over EUR 
50  billion  (in  current  prices)  from  the  REACT-EU 
programme    for  cohesion  policy  action  against  COVID-
19149. 

Greece received EUR  23.1 billion from the ESI Funds over 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR 3.3 billion with a further EUR 896.4 million identified 
as  indirect  environmental  investment  value,  totalling  to 
EUR 4.2 billion. Figure 39 shows an overview of (planned) 
individual ESI Funds earmarked for Greece (EU amounts, 
without national amounts). 

Figure 38: ESI Funds allocated to Greece, including 
environmental investments, 2014-2020150 

148  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI),  the  European  Agricultural  Fund  for  Rural  Development  (EAFRD) 
and the European Maritime and Fisheries Fund (EMFF).   
149 Regulation (EU) 2020/2221. 
150  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
for  data:  December  2021. 
(EU)  No  215/2014. Cut-off  date 
Environmental investments here are  captured via the combined use of 
intervention  fields  and  coefficients  under  the Regulation  (EU)  No 
1303/2013 and Regulation (EU) 2021/1060  allowing for a more precise 
identification  and  valuation  of  relevant environmental investments. 
N.B.  Indirect  environmental  investments  are  valued  using  the  Annex  I 
environmental  coefficients  of  the Regulation 
(EU)  2021/1060 (as 
opposed to full value). 

2017), Regulation 

(COWI, 

Funds 

Policy 

Greece  34 

Table 2: Direct and indirect environmental investments 
under the ESI Funds in Greece, 2014-2020151 

Instrument 

Under Cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
waste 
air quality 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy152 
sustainable transport 
sustainable tourism 
business development, R&I 

Under EAFRD/rural development 
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Indirect environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

3 306.7 
2 426.8 
1 159.7 
763.5 
39.9 
85.7 
17.6 
360.3 
879.9 
43.1 
220.6 
33.0 
517.0 
47.3 
19.0 

744.5 
729.8 
505.8 
224.1 
14.7 
10.7 
4.0 

133.1 
131.3 
131.3 

1.8 
1.8 

4 184.4 
3 288.0 
896.4 

Funding for the environment from the ESI Funds has also 
been    supplemented  by  other  EU  funding  programmes 
and financing available to all Member States, such as, the 
LIFE  programme,    Horizon  2020  and  financing  from  the 
European  Investment  Bank  (EIB)153,  that  add  up  to  an 

investments 

in 
tracking 

identified  here 
the 
from 

151  European  Commission,  DG  Environment  -  Data analysis. The  values 
the  specific 
of  environmental 
environmental  areas  may  differ 
values 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis here  covered the full range 
of ESI Funds. See also previous footnote. 
152  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
REGULATION (EU) 2021/1060, Annex I. 
153  The  EIB  Group  works  with  the  European  Commission 
implementing  several  programmes 

in 
finance  environmental 

that 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
  
 
 
                                                                 
 
estimated  total  environmental  financing  of  EUR  4.7 
billion for Greece in 2014-2020.  

The  LIFE  programme154  is  dedicated  to  environmental 
and climate objectives, financing  the demonstration and 
roll-out  of  green  solutions.  In  2014-2020  ,  Greece 
received EU support  for  26 LIFE projects (for nature and 
environment) for an amount of EUR 53.6 million  (out of 
1 028 EU27 LIFE projects with the total EU contribution of 
EUR 1.74 billion)155. 

In  2014-2020,  Horizon  2020  allocated  about  EUR  74.3 
million  toGreece  (notably,  for  circular  economy,  climate 
action,  earth  observation,  water,  and  natural  resources 
and  ecosystems  projects)    about  4.4%  of  Greece’s  total 
allocation156.  From  the  European  Fund  for  Strategic 
Investments (EFSI), none of Greece’s total allocation (EUR 
1.8  billion)  157  was  spent  on  environmental  projects. 
Greece  received  EUR  343.2  million  from  EIB  for  direct 
environmental  investments,  specifically,  for  water  and 
sewerage and waste, out of the total EIB loans for Greece 
(EUR 12.7 billion)  158. The country ranks  7th in the EU in 
terms of total EIB lending. 

In  2020,  the  EIB  provided  EUR  24.2  billion  in  funding 
across  Europe  to  fight  climate  change  at  EU 
level 
(corresponding to 37% of its total financing)  and EUR 1.8 
billion  for  the  environment  (representing  3%  of  its 
financing)159 . 

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU (NGEU) spending programme will 
mobilise EUR 2 018 trillion (in  current  prices) to support 
the  recovery  from  COVID-19    and  the  EU's  long-term 
protection.160 
priorities, 
Following the EU Green Deal’s161 pledge to ‘do no harm’ 
pledge and the Interinstitutional Agreement on the 2021-

environmental 

including 

Greece  35 

2027  MFF162,  30%  of  the  EU  budget  in  2021-2027  will 
support  climate  efforts,  while  biodiversity  will  receive 
7.5%  as  of  2024  and  10%  as  of  2026  of  the  MFF,    that 
requires  increased  programming  of  financial  resources 
the  2021-2027 
for  biodiversity,  specifically  under 
Cohesion  policy  and  the  2023-2027  CAP  to  reach  those 
targets. 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)163. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard164).  Reinforced  by  the  renewed  sustainable 
finance  strategy  (2020)165,  sustainable  finance 
  will 
increase 
the 
climate  and 
flows 
environment. The new strategy on adaptation to climate 
change166  can  help  close  the  insurance  protection  gap, 
which  currently  leaves  many  risks  from  climate-related 
events uninsured167. The EIB will align 50% of its lending 
for climate and environmental objectives by 2025168 with 
an  EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027. 

investment 

to 

Table 3 gives an overview of the EU funds earmarkedfor 
Greece for 2021-2027 . These funds are supplemented by 
other  EU  funding  programmes  available  to  all  Member 
States. 

Table 3: Key EU funds allocated to Greece (current 
prices), 2021-2027  

Instrument 

Country funding allocation  

Cohesion policy 

Total: 20 448.2169 

(Million EUR) 

ERDF 

CF 

ESF+ 

11 451.7 

3 023.4170 

5 844.8 

implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just  Transition  Mechanism.  The  EIB  Group  is  a  key  implementing 
partner for InvestEU, managing 75% of the overall budgetary capacity of 
the mandate. 
154 European Commission, LIFE Programme. 
155 Source: CINEA 
156 Source: EASME, https://sc5.easme-web.eu/. 
157  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
158 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
159 EIB 2021 Activity Report.  
160  European  Commission,  2021-2027 
NextGenerationEU. 
161 COM/2019/640 final. 

long-term  EU  budget  & 

162 Interinstitutional Agreement, OJ L 433I. 
163 

https://ec.europa.eu/info/business-economy-euro/banking-and-

finance/sustainable-finance/eu-taxonomy-sustainable-activities_en   
164 EU Green Bond Standard - 2021/0191 (COD). 
165 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy.  
166 COM(2021) 82 final. 
167  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA  (the  Association  for  European  Insurance  and  Occupational 
Pension Authorities) dashboard on insurance protection gap for natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
168 EIB Climate Bank Roadmap 2021-2025, November 2020 
169  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
170  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 

Environmental Implementation Review 2022 – Greece 

 
                                                                                                        
                                                                 
ETC (ERDF) 

128.3171 

management  reform  to  promote  sustainable  landfilling 
and recycling and improve governance178. 

Figure 39: Climate  expenditure in RRPs, 2021-2026179  

Greece  36 

Just Transition Fund 

830.2172 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027173 

European  Maritime, 
and 
Fisheries 
Fund 
Aquaculture 
(EMFAF) 

Recovery 
and 
Resilience Facility (RRF)  

2021 – 2026176  

2 784.8174 

375.0175 

17 769.9 (grants)  

12 727.5 (loans)177  

In Greece, the programming for most EU funds (cohesion 
policy  funds,  EAFRD  and  EMFAF)  is  ongoing.  However, 
negotiations have been concluded under the RRF. 

Greece’s RRP sets out measures for a strong recovery and 
preparing  Greece  for  the  future.  The  reforms  and 
investments outlined in the plan will help Greece become 
more  sustainable,  resilient  and  better  prepared  for  the 
challenges  and  opportunities  of  the  green  and  digital 
transitions. To this end, the RRP sets out 106 investment 
measures  and  68  reforms,  which  will  be  supported 
by EUR  17.77  billion  in  grants  and  EUR  12.73  billion  in 
loans. 37.5% of  the  plan  will  support climate  objectives. 
through 
the  green 
The  RRP  supports 
investments  of EUR  1.3  billion  in the  energy-efficient 
renovation of  more  than  100,000  residences,  including 
low-income  households.  On  green  and  sustainable 
transport,  the  RRP  envisages  more  than  8  000  electric 
charging  points  and  220  green  urban  transport  buses  in 
Athens  and  Thessaloniki,  a  major 
in 
railways and  a  thorough reform  of  the  transport  sector. 
in 
Investments  of  more 
reforestation, biodiversity, flood mitigation and irrigation 
network  upgrades  aim 
to  support  environmental 
protection  and  are  complemented  by  a  waste 

than  EUR  600  million 

investment 

transition 

171  Interreg  initial  allocations  per  MS  including  ETC  transnational  and 
ETC cross-border cooperation.  
172  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
173 European Commission, CAP strategic plans. 
174 Regulation (EU) 2021/2115, Annex XI.  
175 Regulation (EU) 2021/1139, Annex V. 
176  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented by 31 December 2026.   
177 Council Implementing Decision, FIN 514. 

Under  NGEU,  the  Commission  will  issue  up  to  EUR  250 
billion  in  EU  green  bonds  (one  third  of  all  bonds  issued 
under NGEU) until 2026 that will comply with the general 
spirit  of  the  “do  no  significant  harm”  (DNSH)  principle. 
However, this EUR 250 billion in green bonds will not be 
subject to the currently developed delegated acts related 
to  the  EU  Taxonomy  and  will  not  fully  align  with  the 
proposed EU green bond standard. 

In  addition  to  the  EU  funds  earmarked  for  Greece  for 
2021-2027  ,  various  other  EU  funding  programmes  are 
open  to  all    Member  States,  for  example:    the  LIFE 
programme  180  (EUR  5.4  billion);  Horizon  Europe  (EUR 
95.5  billion)181;  the  Connecting  Europe  Facility182  (EUR 
33.7  billion)183;  and  the  InvestEU184.  These  instruments 
will also support the green transition, including research 
and  innovation  activities  for  environmental  protection 
(Horizon  Europe)185,    clean  transport  and  energy  (the 

178 European Commission, Greece recovery and resilience plan.  
179 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
180 European Commission, LIFE Programme. 
181  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
182  The  CEF  (Transport)  includes also  EUR  11.3  billion transferred from 
the  Cohesion  Fund.  30  %  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
Cohesion Fund. The remaining 70% will respect the national envelopes 
until  31  December  2023.  Any  unspent  amount,  by  that  date,  under 
national envelopes will support all Cohesion Fund’s Member States. 
183 Regulation (EU) 2021/1153. 
184  The  InvestEU  Fund  is  expected  to  mobilise  over  EUR  372  billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to back 
the  investment  of  financial  partners  such  as  the  European  Investment 
Bank (EIB) Group and others. 
185 European Commission, Horizon Europe. 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
 
 
                                                                 
Connecting 
infrastructure (InvestEU)187. 

Europe 

Facility)186 

and 

sustainable 

National environmental protection 
expenditure 

Total national expenditure on  environmental protection 
(including all relevant current and capital expenditure )188 
in  the  EU27  was  EUR  272.6 billion  in  2020,  representing 
2%  of  the  Union’s  GDP.  This  percentage  has  remained 
quite  stable  over  time.    Although  the  largest    absolute 
amounts  of    expenditure  are  concentrated  in  a  few 
countries,  most  countries  spend  1-2%  of  their  GDP  on 
environmental protection, including Greece (1.2%). 

Of  this  spending,  capital  expenditure 
(Capex)  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR  56.3  billion  in  2018,  falling  to  EUR  54.5  billion  in 
2020, representing around 0.4% of the EU27 GDP. Greece 
invested  0.2%  of  GDP  on  environmental  protection,  in 
line  with  most  other  Member  States  (0.2-0.5%  of  their 
GDP).  In 2014-2020, this amounted to around EUR 3.48 
billion  in  environmental  investment  in  (EU27  total:  EUR 
376 billion).  

Figure 40: Direct and indirect environmental protection 
investments in EU27 (EUR million and % of GDP), 
2018189 

level, 

including  final  consumption, 

186 European Commission, Connecting Europe Facility. 
187 European Union, InvestEU. 
188  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 
189 Eurostat, Environmental Protection Expenditure Account, 2021.  

Greece  37 

protection 

investments 

institutional  sector,  around  87.8%  of  Greece’s 
By 
environmental 
(capital 
expenditure)  came  from  the  general  government,  8.5% 
from  specialist  producers  (of  environmental  protection 
services, e.g. waste and water companies) and only 3.7% 
from 
(businesses)  whose  environmental 
activities  are  usually  ancillary  to  their  core  activities.  At 
EU level, in 2018, 37.2% came from governments, 32.5% 
industry 
from  specialist  producers  and  30.3%  from 
(business). 

industry 

Figure 41: Environmental protection investments 
(Capex) in EU27 by institutional sector (Total economy = 
100%), 2018190 

government 

A  breakdown  of  investment  by  environmental  topic  is 
only available at institutional  sector level (rather than at  
economy level), due to different reporting patterns ￼. At 
general 
in  Greece,  71%  of 
level 
environmental  protection  investments  were  for  waste 
management  and  29%  for  wastewater.  The  country’s 
focused  on  waste 
specialist  producers  mainly 
management 
(84%),  with  a  further  8%  spent  on 
wastewater  and  8%  on  water  and  soil  protection.  The 
business  sector’s    environmental  investments    were  for: 
(20%),  air 
(35%),  waste  management 
wastewater 
protection (10%), while a significant share (35%) was not 
specifically classified. 

The  total  annual  European  green  bond  issuance  191 
amounted to USD 156 billion (EUR 137 billion192) in 2020, 

190  Eurostat,  Environmental  Protection  Expenditure  Accounts 
(env_epe).  
191  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green “use of proceeds” or asset-linked bonds. The very first 

Environmental Implementation Review 2022 – Greece 

 
 
 
                                                                 
 
 
                                                                 
 
Greece  38 

Figure 43: Environmental taxes in the EU27, 2020195 

up from USD 117 billion (EUR 105 billion) in 2019 (these 
figures  include    some  non-EU  European  countries).  For 
EU27  ,  the  2020  green  bond  issuance  came  to  EUR  124 
billion.  In  2014-2020,  83%  of  the  green  bonds  issued  by 
European  countries  went  towards  energy,  buildings  or 
transport  objectives  ,  8%  supported  water  and  waste, 
and  6%  supported  land  use  –  with  links  to  ecosystem 
conservation  &  restoration,  as  the  Climate  Bonds 
Taxonomy  is  broadly  similar  to  the  EU  Taxonomy193.  
Greece contributed to the EU27’s total 2020 green bond 
issuance with a value of EUR 582.6 million. 

Figure 42: Annual EU green bond issuance in 2020 (EUR 
billion)194 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience, foster a fairer society and a just transition. Tax 
reforms can contribute to this, by sending the right price 
signals  and  incentives  to  economic  actors.  The  Green 
Deal creates the context for broad-based tax reforms, the 
removal of fossil fuel subsidies , and for a shift in the tax 
burden  from  labour  to  pollution,  while  simultaneously 
taking  account    of  social  considerations  196.  The  Green 
Deal  promotes  the  ‘polluter  pays  principle’    197,  which 
stipulates that polluters should bear the cost of measures 
to  prevent,  control  and  remedy  pollution.  The  polluter-
pays  principle 
the  European 
Commission’s Technical Support Instrument  (TSI) project 
198 on greening taxes. 

facilitated  by 

is 

instruments 

According to a Commission’s study on Green taxation and 
other  economic 
(2021)  Greece  could 
introduce a landfill tax, a ‘pay-as-you-throw' scheme and 
a water consumption charge to further address particular 
areas  of  environmental  concern199.  After  several  delays, 
Greece reintroduced a landfill tax  but it has not yet been 
applied200.  Greece  also  recently  introduced  a  "resource 
cost" for water, setting different prices for different types 
of water use and water sources. 

195 Eurostat, Environmental taxes accounts (env_eta). 
196 COM (2019/640 final), p.17. 
197  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union:  “Union  policy  on  the  environment  (…)  shall  be  based  on  the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay”. 
198  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice,  green budgeting TSI participation. 
199  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021.  
200 European Commission, Ensuring that polluters pay Greece.  

Green budget tools 

Green taxation and tax reform 

Greece’s revenue from environmental taxes amounted to 
EUR 6 226  million in 2020, accounting for 3.77% of  GDP 
(above the EU average of 2.24%), as shown in Figure 44.  
Of  this  amount,  energy  taxation  accounted  for  the 
highest share, 77.5%, compared with 22.4% for transport 
and less then 0.1% for pollution/resources tax. 

green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
192 At Eurostat’s annual average EUR/USD exchange rates. 
193 
Bonds 
information 
https://www.climatebonds.net/standard/taxonomy  
194 Climate Bonds Initiative, 2022. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 

Climate 

on 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                                                        
 
 
 
                                                                 
Environmentally-harmful subsidies 

Figure 44: Trends in natural gas, petroleum products, 
electricity and coal subsidies in Greece203 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms. 

Greece  39 

in 

often 

investment 

deincentivise 

Fossil-fuel  subsidies  are  costly  for  public  budgets  and 
undermine  Green  Deal  objectives  (on  climate  neutrality, 
air  quality,  zero  pollution  and  health  impacts  etc.).  They 
also 
green 
technologies,  and  do  not  contribute  to  levelling  the 
playing  field.  Fossil  fuel  subsidies  have  varied  by  around 
EUR  55  billion  in  the  EU  since  2015.  They  rose  by  4%  in 
2015-2019,  although  some  countries 
(e.g.  Latvia, 
Lithuania  Sweden,  Greece  and  Ireland)  managed  to 
decrease  subsidies  for  fossil  fuels.  At  EU  level,  subsidies 
on petroleum products, in sectors such as transport  and 
agriculture,  continued to increase in 2015-2019, whereas 
subsidies on coal and lignite decreased, largely owing to 
the  diminishing  role  of  solid 
in  electricity 
generation. As a share of GDP, fossil fuel subsidies ranged 
from 1.2% in Hungary to less than 0.1% in Malta in 2019 
(EU  average:  0.4%).  In  Greece,  total  fossil  fuel  subsidies 
amounted to EUR 1.6 billion in 2019, representing 0.85 % 
of GDP. 

fuels 

In 2020, the EU27’s total  fossil fuel subsidies decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  actions,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020201. Greece allocates 
more than the EU average to fossil-fuel subsidies, which 
are higher than its renewable-energy subsidies202. 

201  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex.  
202  European  Court  of  Auditors,  Energy  taxation,  carbon  pricing  and 
energy subsidies, 2022.  

% GDP 

2013 

2014 

2015  2016 

2017  2018  2019 

2020 

Electricity 

0,30 

0,30 

0,31 

0,23 

0,31 

0,30 

0,29 

0,32 

Natural 
gas 

Petroleum 
products 

0,40 

0,13 

0,09 

0,12 

0,09 

0,09 

0,09 

0,10 

0,76 

0,70 

0,63 

0,55 

0,60 

0,54 

0,52 

0,56 

Coal 

0,23 

0,23 

0,23 

0,22 

0,18 

0,18 

0,17 

0,16 

Current green budgeting practices 

‘Green  budgeting’  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  states  already  use  certain  green 
budgeting  practices204.  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues  to 
increase transparency on the environmental implications 
of  budgetary  policies.  This  is  aimed  at  improving  policy 
coherence  and  supporting  green  policies  (including 
climate end environmental objectives) 205. 

The  Commission  developed  EU  climate-proofing  and 
sustainability  proofing  guidance 
to  assess  project 
eligibility  and  compliance  with  environmental  legislation 
and  criteria206.  The  Commission  have  also  drawn  up  a 

203 OECD, Fossil Fuel Subsidy Tracker. 
204 European Commission, Green Budgeting Practices in the EU: A First 
Review,  2021,  Green  Budgeting  in  the  EU  Key  insights  from  the  2021 
Commission survey  and OECD,  Public  Governance  Directorate,  Climate 
Change  and  Long-term  Fiscal  Sustainability,  Working  Paper,  February 
2021. Climate Change and Long-term Fiscal Sustainability (oecd.org) 
205 OECD Paris Collaborative on Green Budgeting initiative, 2017. 
206 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 

Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
 
 
 
                                                                 
Greece  40 

green budgeting reference framework  207 and launched a 
TSI project on green budgeting in 2021 to help Member 
States develop  national green budgeting frameworks to 
improve  policy  coherence  and  support  the  green 
transition. Greece participates in the Commission’s green 
budgeting project, launched in 2021. 

Overall financing compared to the needs 

The EU’s overall financing for environmental investments 
is estimated to have been  0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from    0.3%  (Ireland)  to    1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
different  Member  States.  In  2021-2027  ,  it  is  estimated 
that the EU’s environmental investment needs will range 
between  0.9-1.5%  of  the  projected  2021-2027  GDP, 
suggesting  a  potential  environmental  financing  gap  of 
0.6-0.8%  of  GDP  at  EU  level,  compared  to  previous 
financing levels208.  

Figure 45: Total environmental financing baseline (‘14-
20) and estimated needs (‘20-30) in the EU27 (% of 
GDP)209  

In 

sources. 

2021-2027, 

Greece’s  environmental  financing  for  investments  came 
to  0.72%  of  GDP  in  2014-2020,  relying  on  both  EU-  and 
national 
country’s 
environmental investment needs are estimated to reach 
over  1.12%  of  GDP  (with  partial  information,  existing  at 
country level), suggesting an environmental financing gap 
of  at  least  0.4%  of  GDP,  likely  to  be  higher  when  also 
accounting  for  needs  identified  at  EU  level  (e.g.  water 
protection, circularity, biodiversity strategy etc.).    

the 

The priority action set out in the 2019 EIR, to provide the 
adequate  funding  to  tackle  the  main  environmental 
challenges  (e.g.  via  the  mobilisation  of  investments  and 
the  use  of  EU  funds)  is  rolled  over,  as  Greece  made 
limited progress in this respect.  

2022 priority actions 

 

 

Prepare  an  environmental  financing  strategy  to 
maximise  opportunities  to  close  environmental 
implementation  gaps,  including  by  increasing 
environmental taxation and/or private financing 
for the environment  (which latter source is less 
used, under 20%).   
Tackle 
the  main  environmental  challenges 
through  adequate 
affecting 
funding,  including  through  the  mobilisation  of 
investments and the use of EU funds. 

country, 

the 

207  European  Commission,  Green  Budgeting  Reference  Framework, 
based  on  the  review  of  the  OECD  Paris  Collaborative  on  Green 
Budgeting initiative, 2017. 
208 Source: DG Environment data analysis. EU financing sources covered: 
ESI  Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon  2020,  LIFE,  EFSI 
(EU amount), EIB loans. National financing: total national environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset.  Cut-off  date  for  data:  end  2021.  N.B.  The  total  financing  may 
be  higher,  in particular  through further  indirect  investments,  requiring 
further analysis in the future.   
209 Eurostat, ESI Funds Open Data, 2021. 

Environmental Implementation Review 2022 – Greece 

 
  
 
 
                                                                 
 
 
 
 
Greece  41 

6. Environmental governance 

Information, public participation and access to 
justice 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020214 

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; 
(iii) access to justice in environmental matters.  
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared  
efficiently  and  effectively210.  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 environment211. It includes the right to bring 
legal challenges ("legal standing")212. 

Environmental information 

for 

sharing   environmental 

This  section  focuses  on  Greece’s  implementation  of  the 
INSPIRE Directive, which sets up a European spatial data 
infrastructure 
spatial 
information  between  public  authorities  across  Europe, 
in  policy-making  across  boundaries  and 
assisting  
facilitating  public  access  to  this  information.  Geographic 
information  is  needed  for  good  governance  at  all  levels 
and should be readily and transparently available. 

Greece’s  implementation  of  the  INSPIRE  Directive  could 
be  better.  Its  performance  has  been  reviewed  based  on 
its  2021  country  factsheet213.  Data  identification  and 
documentation has progressed well, and implementation 
levels have improved. However, more efforts are needed 
to: 

  make the data more widely accessible; and 
 
improve the conditions for data reuse. 

the 

(Directive 2003/4/EC) and 

210  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive 
INSPIRE 
Directive, (Directive 2007/2/EC)   create  a  legal  basis  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation. 
211  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. 
212 This EIR focuses on the means used by Member States to guarantee 
rights of access to justice, legal standing and to overcome other major 
barriers to bringing cases on nature and air pollution. 
213 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/EL. 

2016 

2020 

Legend 

Implementation 

■ 
is  well 
advanced or (nearly) complete. 
Outstanding  issues  are  minor 
and  can  be  addressed  easily. 
Percentage: >89% 

some 

■  Implementation  has  started 
and 
substantial 
or 
progress has been made, but it 
is  still  not  close  to  being 
complete. Percentage: 31-89% 

is 

Implementation 

■ 
falling 
significantly  behind.  Serious 
efforts are needed to close the 
implementation gap. 
Percentage: <31% 

Effective  coordination  and  data 
sharing 

Ensure 
effective 
coordination  

sharing 

Data 
without 
obstacle  

INSPIRE 
indicators 

■  ■ 

■  ■ 

performance 

i.  Conformity 
of metadata   ■  ■ 

ii.  Conformity 
of spatial data 
sets215 

iii. 
Accessibility 
of spatial data 
through 
sets 
view 
and 
download 
services 

iv.  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

Public participation 

Register 

Environmental 

The  Ministry  of  Environment  and  Energy  maintains  a 
(Ηλεκτρονικό 
Digital 
Περιβαλλοντικό  Μητρώο)216,  which  enables  citizens  and 
environmental  organisations  to  monitor  the  progress  of 
any environmental authorization, including under the EIA 
Directive,  and  its  results.  User  registration  is  required. 
Public consultation is, in principle, carried out exclusively 

214 INSPIRE knowledge base 
215 The deadlines for implementation of the spatial data interoperability 
were  in  2016  still  in  the  future:  23/11/2017  for  Annex  I  data  and 
21/10/2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
majority  of  the  countries  provide  as-is-data  sets  in  addition  to  the 
INSPIRE harmonised data sets. 
216  Digital  Environmental  Register 
Μητρώο). Information available at: https://eprm.ypen.gr/. 

(Ηλεκτρονικό  Περιβαλλοντικό 

Environmental Implementation Review 2022 – Greece 

 
                                                                 
  
  
  
  
                                                                 
It 

is  not  clear 

if  an 
through  this  online  system. 
assessment has been made of how effective the website 
is  in  facilitating  public  participation.  In  any  event,  the 
legislation  (article  3  par.  1.1.  b  of  JMD  1649/45/2014) 
for  the  competent 
provides  an  additional  action 
environmental authority, which consists in informing the 
relevant  Regional  Council  about  the  start  of  the  public 
consultation.  The  relevant  announcement  is  posted  on 
the ΗΠΜ and is also addressed electronically by the same 
Regional Council. 

and 

Energy 

includes 

For  the  SEA  Directive,  the  website  of  the  Ministry  of 
consultation 
Environment 
(διαβούλευση)  section,  where  SEAs 
for  plans  or 
programmes  are  announced,  with  an  accompanying 
invitation  forinterested  public  to  submit  their  views. 
Information  on  where  the  public  can  access  to  the 
relevant  documents  is  also  provided;  in  some  cases, 
some  of  the  documents  may  also  accompany  the 
announcement of the SEA. 

There  is  still  lack  of  data  available  on  the  level  of 
participation 
including 
authorisations  linked  to  the  EIA  Directive  2011/92/EU 
and the SEA Directive 2001/42/EC. 

in  decision-making  processes 

Access to justice  

(after 

the  Constitution 

Article  24  of 
the  2001 
Constitutional revision) underlines that “the protection of 
the  natural  and  cultural  environment  is  an  obligation  of 
the State and everyone's right”. That means that anyone, 
or  any  group  of  people  acting  together,  or  an  NGO,  has 
the right to appeal before the courts in order to protect 
the  environment  by  proving  a  particular 
legitimate 
interest  regarding  their  case.  The  Greek  Constitution, 
after  its  revision  in  2001,  gives  NGOs  the  right  to  legal 
standing  in  environmental  cases.  Concerning  NGOs,  in 
most  cases  the  Greek  courts  have  considered  that  the 
protection  of  the  environment  must  be  generally 
described  in  the  statutory  objective  of  the  legal  entities 
without  being their  sole or predominant  purpose.  There 
is  also  a  system  of  regular  supervision  of  regulatory 
legally  binding  acts,  but  it  is  largely  inaccessible  to 
members  of  the  public  and  NGOs,  who  can  only  flag 
cases to bodies or officials that are entitled to initiate an 
extraordinary supervision procedure. 

There is some information available on access to justice, 
usually  only  in  Greek,  maintained  by  the  government. 
However, this information needs to be searched for. The 
official  site  of  the  Ministry  of  Environment  provides 
relevant  information  and  includes  hyperlinks  to  other 
relevant  sites217.  It  provides  mostly  general  information 

217http://www.ypeka.gr/el-gr/Περιβάλλον/Περιβαλλοντική-
Πληροφορία 

Greece  42 

on  the  implementation  of  the  Aarhus  Convention  in 
Greece.  Additional  information,  including  case-law,  can 
be found on the Council of State’s website218. 

A priority action was addressed to Greece in the 2019 EIR 
to  better  inform  the  public  about  their  access  to  justice 
rights.  However,  there  has  been  limited  progress  in  this 
regard. 

2022 priority actions 

  Make  spatial  data  more  widely  accessible  and 
the 
prioritise  environmental  datasets 
INSPIRE  Directive, 
the 
implementation  of 
especially  those  identified  as  high-value  spatial 
datasets 
implementing  environmental 
legislation.  

for 

in 

 

 

  Assess 

the  effectiveness  of 

the  Digital 
in  facilitating  public 
Environmental  Register 
participation, 
accompanying 
and  whether 
measures  to  publicise  EIA  processes  would  be 
helpful in raising awareness. 
Collate  and  publish  data  on public  participation 
into environmental decision-making. 
the  public 
Improve  access 
to  challenging 
concerned  when 
administrative  or  regulatory  decisions  and 
omissions  also 
in 
in  the  planning  context, 
particular under water, nature and air quality. 
  Better  inform  the  public  about  their  access  to 
justice  rights,  in  particular  by  referring  to  on 
judicial  and  administrative  portals 
the 
Commission  eJustice  fact  sheets  on  access  to 
justice in environmental matters. 

to  courts  by 

it  comes 

to 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
that 
undertaken  by  public  authorities 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste219.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i)compliance promotion220;  
(ii) the inspections and other checks that they carry out, 
i.e. compliance monitoring221;  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 

218http://www.adjustice.gr/webcenter/portal/ste/pageste/stepage?_ad
f.ctrl-state=lsv69fkwq_4&_afrLoop=7255543756255087#  
219  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. 
220 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
221 This EIR focuses on inspections of major industrial installations.  

 Environmental Implementation Review 2022 – Greece 

 
                                                                 
                                                                 
enforcement222.  
Citizen  science  and  complaints  enable  authorities  to 
liability223 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

information  provided  by 

Online 
the  Ministry  of 
Environment  and  Energy  and  the  Ministry  of  Rural 
Development and Food, is largely limited to a description 
of  the  legal  measures  in  place  to  implement  the  Nature 
Directive  and  the  Nitrates  Directive  and  information  on 
common 
the 
agricultural  policy  payments.  Practical  information  for 
farmers and land managers on  how to help comply with 
legal  requirements  fulfil  water  and  nature  objectives, 
seems to be lacking. 

cross-compliance 

requirements 

for 

Greece  43 

complaints  is  provided,  or  feedback  to  complainants. 
Moreover,  the  website  of  the  Ministry  of  Environment 
and Energy does not provide a link to the Ombudsman’s 
website. Additionally, statistics indicating the number of 
incoming complaints and cases/infringements in total are 
missing228. 

In late 2020, a complaint Management System (CMS) for 
environmental  complaints  was  developped  and  formally 
adopted  by  the  MoEE.  However,  it  has  not  been  fully 
implemented yet. 

There  are  a  number  of  active  citizen  science  projects, 
particularly  in  the  field  of  biodiversity,  organised  by  the 
Hellenic Biodiversity Observatory229. 

Enforcement 

The  Ministry  of  Environment  and  Energy  publishes 
annual  reports  on  inspections  .  The  latest  report  was 
published  in  2019224,  covering  activities  in  2018.  In 
addition  to  summary  data  on  the  types  of  inspection, 
activities  carried  out  during  the 
inspections,  and 
infringements  identified,  the  reports  also  provide  a 
schedule  of  inspections  to  be  carried  out  the  following 
year.  However,  details  and  documentation  on  individual 
inspections  are  not  made  available.    The  Secretariat  of 
inspectorate of MoEE  was disbanded in 2019225 and as of 
2020 has been replaced by the General Directorate of the 
body  of  inspectors  and  auditors  of  the  Ministry  of 
Environment and Energy, subject directly to the Minister, 
with 
all 
environmental inspecting authorities in Greece.  

competencies 

coordinating 

some 

for 

Complaint handling and citizen science 

of 

breaches 

environmental 

The  Greek  Ombudsman226  (Συνήγορος  του  Πολίτη) 
enables  members of  the public to submit complaints on 
quality of life issues, including the environment. This can 
include 
legislation, 
degradation  of  the  natural  environment,  and  general 
deterioration  of  the  quality  of  life.  The  Ombudsman’s 
website227  provides  an  archive  of  published  texts,  which 
includes conclusions of its investigations, annual reports, 
special  reports  on  specific  issues  considered  to  be  of 
wider interest, mediation summaries and press releases. 
No  specific  information  on  the  follow-up  of  individual 

222  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
223  The  Environmental  Liability  Directive  (2004/35)  provides  the 
framework. 
224  Available  at:  https://ypen.gov.gr/ypourgeio/soma-epitheoriton-kai-
elegkton/ 
225 
https://www.kodiko.gr/nomothesia/document/539871/p.d.-84-2019. 
226 See https://www.synigoros.gr/?i=quality-of-life.el 
227 See https://www.synigoros.gr/?i=quality-of-life.el.qualitykeimena 

Presidential 

84/2019, 

available 

Decree 

at: 

of 

the 

type 

distinguishing 

Data on the prosecution of environmental crimes and on 
the  follow-up  to  inspections  and  compliance  is  not 
available.  More  specifically,  statistics  on  waste  crime 
cases are collected only by administrative authorities and 
they  include  both  administrative  and  criminal  cases,  but 
without 
violation 
(administrative or criminal case). Regarding the judiciary, 
there  are  no  statistics  either  on  the  number  of 
environmental  criminal  cases  or  on  the  results  of  the 
criminal proceedings in these cases. Additionally, there is 
a  lack  of  statistics  on  the  number  of  cases  prosecutors 
  and  where  statistics  are 
commenced  and  closed, 
available, these are not broken down to show the type of 
the environmental crime cases at the prosecutors’ offices 
or in courts. As to the offences, these are not  published 
as statistics, but the administrative fine is posted on the 
website of DIAVGEIA (ΔΙΑΥΓΕΙΑ)230. 

In  2021, 

In  addition  to  legislation  setting  out  the  respective 
competences of public bodies on environmental matters, 
and  their  duties  to  provide  assistance  or  information 
when  requested,  steps  have  recently  been  taken  to 
formalise  cooperation. 
the  Ministry  of 
Environment  and  Energy  and  the  Chief  of  the  Hellenic 
Police  signed  a  Memorandum  of  Cooperation  for  the 
’Prevention  of  Environmental  Crime  with  Smart 
Inspections’  project  under 
LIFE  PROWhIBIT 
programme. A  similar  Memorandum of Cooperation has 
been signed between the Ministry and the Director of the 
Independent  Authority  for  Public  Revenue  (AADE),  in 

the 

228  Evaluation  report  on  the  eighth  round  of  mutual  evaluations  "The 
implementation  and  operation  of  European  policies  on 
practical 
preventing and combating environmental crime" - Report on Greece. 

https://www.biodiversitygr.org/blog/category/citizen-

229 
See 
science.html 
230  Evaluation  report  on  the  eighth  round  of  mutual  evaluations  "The 
implementation  and  operation  of  European  policies  on 
practical 
preventing and combating environmental crime" - Report on Greece. 

 Environmental Implementation Review 2022 – Greece 

 
                                                                 
                                                                 
order  to  combat  the  illegal  cross-border  transfer  of 
waste. 

Administrative capacity and quality 

Greece  44 

Environmental Liability Directive (ELD) 

to 

No 
information  on  environmental  damages,  or 
mechanisms  to  encourage  reporting  on  environmental 
damages could be identified online, and there appears to 
be  no  registry  or  central  database  on  environmental 
incidents  or  ELD  cases  available 
the  public. 
Nevertheless, a registry of envrironemental incidents and 
ELD  cases  is  maintained  by  the  Minsitry  of  Environment 
and Energy; data of the registry are made available upon 
request.  The Minisitry of Environment  and Energy is the 
leading  beneficiary  of  a  LIFE  PROFILE  project  in  the 
framework  of  which  a  database  for  ELD  cases  is  to  be 
developped.  On  financial  security,  while  the  national 
legislation231 provides for a joint decision by the Finance 
and  Environment  ministries  setting  out  the  method  for 
determining  amounts  of  financial  security,  the  relevant 
decision  is  still  awaited.  However,  several  insurance 
companies provide cover for ELD liability. Under the LIFE 
PROFILE  project  referred  above,  a  methodology  for 
environmental  risk  assesment  will  be  developped  to 
support the implementation of finacial security for ELD. 

2022 priority actions 

 

 

 

 

Improve the availability of practical information 
for  farmers  and  land  managers  on  how  to 
contribute  to  better 
implementation  of  the 
Nature and the Nitrates Directives. 
Improve information to citizens on opportunities 
to file complaints about environmental issues or 
infringements and publish data on the follow-up 
to such complaints. 
Improve  the  reporting  of  action  taken  against 
environmental crime. 
Establish  a  database  for  ELD  cases,  and  other 
instances  of  environmental  damage,  as  well  as 
publishing  information  on  such  cases  including 
on sanctions and other financial measures. 

Effectiveness of environmental 
administrations  

in 

involved 

implementing 

Those 
environmental 
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 brings about the intended benefits. 

The  Ministry  of  Environment  &  Energy  (MoEE) 
is 
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  out  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. Under its RRP, Greece is undertaking two 
promising  reforms,  aiming  to  establish  regulators  in  the 
fields of waste and water management. 

The number of open infringement cases is high compared 
to  other  Member  States  and  at  an  advanced  stage  (i.e. 
infringement proceedings under Article 260 of the Treaty 
on  the  Functioning  of  the  European  Union).  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  the  fields  of  waste  and  urban 
wastewater  treatment. Penalty payments remain due as 
long as the judgments of the Court are not fully executed 
by the Member State. 

Electronic  services  are  available  for  public  consultations 
and for filing complaints. For example:: (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 
in  public 
informed  about  and  participate 
consultations;  (iii)  the  digital  environmental  registry 
platform;  (iv)  the  website  on  approved  environmental 
permits  (AEPO);  (v)  an  electronic  database  used  by  the 
Climate  Change  Directorate  of 
the  Ministry  of 
Environment  and  Energy  named  “F-GASES  &  ODS 
DATABASE” for the monitoring of fluorinated greenhouse 
gases  under  Regulation  (EU)  517/2014  and  substances 
that  deplete  the  ozone  layer  under  Regulation  (EC) 

231 Presidential Decree 148/2009. 

 Environmental Implementation Review 2022 – Greece 

 
 
                                                                 
Greece  45 

the 

in  environmental  assessments 

The  Commission  encourages 
streamlining  of 
environmental  assessments  to  reduce  duplication  and 
for 
avoid  overlaps 
projects.  Moreover,  streamlining  helps 
reduce 
  accelerates 
unnecessary  administrative  burden  and 
is 
decision-making, 
done  without 
the  environmental 
compromising 
assessment  procedure.  Greece  has  started  streamlining 
environmental  assessments  under  the  EIA  Directive,  the 
Habitats Directive and the Industrial Emissions Directive.  

provided 
it 
the  quality  of 

to 

1005/2009; and (vi) the Region of Attica’s online platform 
for submitting complaints. 

Coordination and integration 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised Environmental Impact Assessment (EIA) Directive 
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. 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 
The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing  programs,  but  also  by  granting  technical 
assistance  such  as  the  Technical  Support  Instrument 
(TSI). 

The  Commission’s  TSI  supported  several  environment-
related  projects  in  Greece,  including  a  project  on  land 
uses  under  the  TSI  2020  and  two  projects  under  the  TSI 
2022:  “Greening  taxes  –  applying  the  polluter  pays 
principle in practice” and “Bridging the climate financing 
gap with public policy instruments”. 

TAIEX EIR Peer to Peer Projects 

The  TAIEX EIR Peer-to-Peer tool232 has been launched in 
2017  by  the  Commission  to  facilitating  peer-to-peer 
learning  between  environmental  authorities.  During  the 
reporting  period, Greece benefited from two workshops 
on waste management for Greek cities (2019) and water 
management in protected areas: Nature Based Solutions 
(2021), and a study visit on successful bio-waste recycling 
two 
(2019).  Greece  also  participated 
facilities 
in 
multicountry  workshops 
reducing 
technology  and  measures  (2021)  and  on  zero  pollution 
(2021). 

ammonia 

on 

232  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu). 

 Environmental Implementation Review 2022 – Greece