COMMISSION STAFF WORKING DOCUMENT The early warning report for Greece Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target
Date: 2023-06-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Greece, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

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   EUROPEAN COMMISSION  Brussels, 8.6.2023  SWD(2023) 182 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Greece            Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions    identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target           {COM(2023) 304 final} - {SWD(2023) 175 final} - {SWD(2023) 176 final} - {SWD(2023) 180 final} - {SWD(2023) 181 final} - {SWD(2023) 183 final} - {SWD(2023) 184 final} - {SWD(2023) 185 final} - {SWD(2023) 186 final} - {SWD(2023) 187 final} - {SWD(2023) 188 final} - {SWD(2023) 189 final} - {SWD(2023) 195 final} - {SWD(2023) 196 final} - {SWD(2023) 197 final} - {SWD(2023) 198 final} - {SWD(2023) 199 final} - {SWD(2023) 200 final}  
 
 
1.  Introduction 

The early warning report aims to assist Member States at risk of failing to meet: (i) the 2025 target of 55% for 
the preparing for re-use and the recycling of their municipal waste (this target is set out in Article 11(2)(c) of 
Directive 2008/98/EC); and (ii) the 2025 target of 65% for the recycling of their packaging waste (this target 
is set out in Article 6(1)(f) of Directive 1994/62/EC). It also provides an update on how Member States are 
performing against the 2035 target to send no more than 10% of their municipal waste to landfill (this target 
is set out in Article 5(5) Directive 1999/31/EC).  

This report builds on previous support provided by the Commission to help Member States comply with EU 
law on municipal waste management, including, where relevant, the early warning report from 20181. 

The assessment underpinning the early warning report identified 18 Member States at risk of missing the 2025 
preparing for re-use and recycling target for municipal waste, 10 of which are also at risk of missing the 2025 
recycling target for all packaging waste. 

This assessment is based on a collaborative and transparent process involving the Member States concerned, 
the European Environment Agency2, and an in-depth analysis of the most recent policy developments in the 
Member States. This process also involved extensive consultation with the Member State authorities in charge 
of waste management. The possible actions identified during this process are based on existing best practices 
and aim to help Member States meet the 2025 targets, and as such they focus on policy measures which can 
be  taken  in  the  short  term.  These  actions  should  be  seen  as  complementary  to  those  recommended  in  the 
roadmaps  which  were  drawn  up  as  part  of  preceding  compliance-promotion  activities  and  to  those 
recommended in the Environmental Implementation Review3. 

2.  Key findings 

Based  on  the  analysis  of  collected  data  and  existing  policies  in  the  area  of  waste  management,  Greece  is 
considered to be at risk of missing (i) the 2025 target of 55% for the preparing for re-use and the recycling of 
its municipal waste and (ii) the 2025 target to recycle 65% of its packaging waste.  The gap between the current 
situation and the 2035 target of landfilling 10% of municipal waste is also of concern. 

Municipal waste generation in Greece (524 kg/cap) was slightly above the EU average (501 kg/cap) in 2019. 
However, packaging waste generated in 2019 was less than half of the EU average (81 kg/cap vs 177 kg/cap). 
This might indicate that significant quantities of packaging placed on the market, which is considered as the 
amount of generated packaging waste, are not reported. 

In 2019, the municipal waste recycling rate reported by Greece was 21% (34 percentage points below the 2025 
target), while the landfill rate was 77.7% (over three times the EU average). The situation is also of concern in 
terms of general trends, as the recycling rate has been growing very slowly: from 15.8% in 2015 to 21% in 
2019), and the landfill rate decreased only marginally, by about 4 percentage points over those 5 years.  

A low rate of composting and digesting is considered one of the main reasons for this performance. The current 
separate  collection  and  treatment  capacity  for  biowaste  is  such  that  only  a  small  share  of  total  biowaste 

1 An early warning report was issued for Greece in 2018 (SWD(2018) 418 final). In total, 10 recommendations were 
drafted  within  the  assessment.  According  to  the  Greek  authorities  five  recommendations  therein  are  considered 
implemented, four partially implemented and one not implemented.  
2 EEA and ETC/CE (2022). Early Warning Assessment Related to the 2025 Targets for Municipal and Packaging Waste 
(https://www.eea.europa.eu/publications/country-profiles-early-warning-assessments) 
3  European  Commission  (2022).  Environmental  Implementation  Review  2022.  COM/2022/438  final.  (https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=comnat%3ACOM_2022_0438_FIN) 

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generated  in  Greece  can  be  collected  and  processed.  The  amount  of  municipal  waste  sent  to  landfill  also 
remains too high. 

In 2019 the overall packaging recycling rate reached 60.1%, which is quite close to the 2025 target (65%). 
However, there are data quality issues with regard to packaging. For instance, there is a notable discrepancy 
between the low recycling rate for municipal waste and the  quite high recycling rates for packaging waste, 
which are likely due to underreporting of packaging placed on the market. The datasets on municipal waste 
and  packaging  waste  appear  inconsistent,  given  that  a  large  share  of  packaging  waste  is  generated  by 
households and is thus part of municipal waste.  

Significant improvements are needed to bring Greek waste management into line with the EU waste hierarchy. 
Some of the main challenges facing waste management in Greece include: 

-  High reliance on landfilling, in the context of low landfill tax and high illegal dumping rates.  
- 

Insufficient biowaste treatment capacity. Even with plans to increase capacity, less than 30% of total 
biowaste generation would be covered.  

-  Data quality issues, particularly concerning the reported amount of packaging waste generation. 
-  Poor separate collection services for non-household municipal waste and biowaste. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Greece’s  efforts  to  improve  its  performance  in  waste 
management, three main recommendations are listed below: 

1.  Support preparing for re-use of municipal waste and re-use systems for packaging 

2.  Extend at national level separate collection at the source (especially for biowaste) and improve citizen 
awareness as regards waste segregation and prevention. Implement economic instruments such as pay-
as-you-throw  and  increase  landfill  tax  to  incentivise  separate  collection  at  source  and  minimise 
landfilled waste.  

3.  Further develop waste treatment infrastructure associated with the higher steps of the waste hierarchy 
(in  particular,  increasing  treatment  capacity  for  biowaste  and  supporting  home-composting)  and 
establish a quality management system for compost/digestate from biowaste.  

4.  Improve  the  data  management  system  in  order  to  present  coherent  and  verifiable  data  sets  (e.g. 

packaging waste). 

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

4.  Good practices 

The following measures implemented by Greece are considered good practices that could be replicated and 
could help Member States in attaining the above-mentioned targets: 

- 

‘Circular  Economy  Implementation  in  Greece’  LIFE  project4  –  This  country-wide  project  aims  to 
reduce the amount of municipal waste sent to landfill and to promote waste prevention and re-use. The 
project  includes  demonstration  activities  such  as  the  installation  of  re-use  centers  in  three  urban 
municipalities, the promotion and monitoring of food waste prevention, building stakeholder capacity, 

4 https://webgate.ec.europa.eu/life/publicWebsite/index.cfm?fuseaction=search.dspPage&n_proj_id=7404  

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and information and awareness-raising events aimed at changing the behaviour of citizens and local 
communities. 

-  Waste recycling and prevention program in a small island5 – This recycling and prevention program 
called ‘Just Go Zero’ was launched in December 2021 on Tilos island. Although it involved a small 
community (about 800 inhabitants), it triggered a major cultural change in the field of waste prevention 
and in terms of citizen participation. After less than one year, more than 85% of municipal waste was 
recycled or composted. Furthermore, the project has helped raise the awareness of the local population 
on the importance of sound waste management.  

-  Establishing  ambitious  national  targets  – Greece  has  included  in  national  legislation  a  mandatory 
target of 10% landfilled waste by 20306. This ambitious target anticipates the relevant EU target and 
sets a very clear commitment towards all relevant actors. 

5 https://www.justgozero.com/tilos-the-first-zero-waste-island/  
6 Ministerial Decision 39 (Gazette 185 A/2020) - Approval of the National Waste Management Plan, Official Gazette 
185/A/29-09-2020. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Address data quality issues, especially in relation to generated packaging waste and related recycled 
quantities. Ensure swift and effective integration between the National Register of Producers and 
the General Commercial Register. 

2)  Ensure  the  closure  and  rehabilitation  of  remaining  substandard  landfills  and  take  action  against 
illegal  landfills  and  fly  tipping.  Increase  enforcement  capacity  in  order  to  inspect,  control  and 
discourage uncontrolled dumping. 

3)  Set mandatory indicators and targets for separate waste collection to be achieved by the bodies in 
charge of the collection of municipal waste (e.g. municipalities) in order to monitor, enforce and 
achieve higher capture rates. This could be complemented with a system of financial rewards and 
penalties  dependant  on  the  performance  of  the  bodies  against  the  targets.  Information  on  the 
performance of those bodies could also be made available to the general public to raise awareness 
(e.g. on a website).  

Prevention 

4)  Take measures to increase re-use and to prevent the generation of non-recyclable municipal waste 

5)  Ensure proper monitoring of the implementation of waste prevention measures.  In the light of the 
specific characteristics of the territory of Greece, further support the expansion of successful small-
scale  waste-prevention  pilot  projects  to  more  densely  populated  regions.  Foster  coordination 
between central government level and local level in reaching EU waste-prevention objectives. 

Separate Collection 

6)  Develop, enforce and monitor minimum national service standards for separate waste collection 
(including  for  biowaste).  This  could  include  specifying,  for  example,  the  type  and  volume  of 
containers, minimum and maximum frequency of collection and type of vehicle used, taking into 
account the type of housing stock, climate and seasonality, etc. Ensure that the necessary separate 
collection infrastructure is put in place. 

Waste treatment  

7)  Support preparing for reuse of municipal waste and develop waste-treatment infrastructure in a way 
that focuses on the higher steps of the waste hierarchy. Firm plans and concrete actions are needed, 
such as supplementing centralised biowaste treatment with decentralised composting solutions such 
as home composting and community composting. 

8)  Support preparing for reuse of municipal waste and develop waste-treatment infrastructure in a way 
that focuses on the higher steps of the waste hierarchy. Firm plans and concrete actions are needed, 
such as supplementing centralised biowaste treatment with decentralised composting solutions such 
as home composting and community composting. 

9)  Develop waste-treatment infrastructure associated with the higher steps of the waste hierarchy. Firm 
plans  and  concrete  actions  are  needed,  such  as  supporting  home-composting  and  stepping  up 
treatment capacity for biowaste in order to fully cover the biowaste generated. 

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10) The  capacity  for  sorting  and  recycling  of  separately  collected  packaging  waste  needs  to  be 
increased.  This  could  be  achieved  by  increasing  the  number  of  new  recycling  material  sorting 
centres established across the country and by improving the capacity of existing ones. 

Communication and awareness raising 

11) Maintain and reinforce awareness-raising activities specifically tailored to different target groups 
(e.g. households and commercial waste generators, schoolteachers and students, tourists) to enhance 
participation  in  separate  collection.  A  set  of  national  communication  materials  with  clear  and 
consistent  messages,  and  with  particular  focus  on  biowaste,  home  composting  and  sound 
management  of  waste  (e.g.  sorting)  should  be  developed.  Consider  preparing  communication 
materials (e.g. leaflets) in English as well as in Greek to help tourists contribute to waste separation. 

Extended producer responsibility and economic instruments 

12) Implement economic instruments (e.g. landfill tax of a sufficient magnitude) to incentivise waste 
management associated with the higher steps of the waste hierarchy, to make re-use, preparation for 
re-use and recycling economically attractive and reduce the dependency on waste landfilling. The 
economic incentive should be designed and made strong enough to develop a steering effect. Ensure 
that the  newly  adopted  higher landfill tax  regulations  are  applied  to  all  municipalities.  Consider 
anticipating the landfill tax increase currently planned by 2027.  

13)  Implement a pay-as-you-throw system for both businesses and households to attain higher capture 
rates  for  recyclable  fractions  and  reduce  residual  waste.  Local  authorities  could  be  supported 
through  guidance  on  the  design  of the  incentive  mechanisms  and  through  the  introduction  of  or 
learnings from pilot projects.  

14) Stepping up efforts to establish re-use systems for packaging will bring environmental benefits and 

help Member States in complying with the EU packaging recycling targets. 

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