COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 311 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review      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 2025 Environmental Implementation Review for prosperity and security     {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
 
 
 
 
 
Greece  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 5 
Transitioning to a circular economy ..................................................................................................................... 5 
Waste management ............................................................................................................................................. 7 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 14 
Global and EU biodiversity frameworks ............................................................................................................. 14 
Nature protection and restoration – Natura 2000 ............................................................................................. 14 
Recovery of species ............................................................................................................................................ 16 
Recovery of ecosystems ..................................................................................................................................... 18 
Prevention and management of invasive alien species ...................................................................................... 23 
Ecosystem assessment and accounting ............................................................................................................. 24 
3. ZERO POLLUTION ..................................................................................................................................................... 26 
Clean air ............................................................................................................................................................. 26 
Industrial emissions ............................................................................................................................................ 27 
Major industrial accidents prevention – Seveso ................................................................................................. 29 
Mercury Regulation ............................................................................................................................................ 31 
Noise .................................................................................................................................................................. 31 
Water quality and management ........................................................................................................................ 32 
Chemicals ........................................................................................................................................................... 35 
4. CLIMATE ACTION ..................................................................................................................................................... 38 
The EU emissions trading system ....................................................................................................................... 39 
Effort sharing ..................................................................................................................................................... 39 
Land use, land-use change and forestry ............................................................................................................. 40 
Adaptation to climate change ............................................................................................................................ 40 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 42 

5. FINANCING ............................................................................................................................................................. 42 
Climate finance landmarks ................................................................................................................................. 42 
Environmental financing and investments ......................................................................................................... 42 
Public financial management ............................................................................................................................. 47 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 50 
Information, public participation and access to justice...................................................................................... 50 
Compliance assurance ........................................................................................................................................ 52 
EU-supported environmental capacity building ................................................................................................. 55 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  3 

Executive summary

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Greece. The purpose of this report is to 
provide information on the implementation performance 
and  highlight  the  most  effective  ways  to  address  the 
implementation gaps  that impact human health and the 
environment and hamper the economic development and 
competitiveness  of  the  country.  The  report  relies  on 
detailed  sectoral  implementation  reports  collected  or 
issued  by  the  Commission  under  specific  environmental 
legislation. 

environmental 

regarding 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target and 
financial  implications.  In  Greece,  such  challenges  have 
been  lingering  since  the  first  EIR  in  2017  and  require 
urgent action. 

Urgent actions for and investments in waste management 
and the circular economy are needed to move away from 
Greece’s reliance on waste disposal in landfills (including 
illegal  ones),  which  remains  significant.  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  difficult  to  close  unless 
new  facilities  are  built,  while  keeping  in  mind  that 
overcapacity of treatment facilities of residual waste will 
not help Greece’s transition towards a circular economy. 
Greece  will  continue  to  pay  fines  until  this  is  achieved. 
Greece  also  has  to  step  up  its  efforts  to  put  in  place  a 
adequate network of facilities that can effectively manage 
all the hazardous waste produced in the country. Greece 
will  continue  to  pay  fines  until  this  is  achieved.  Greece 
missed  the  2020  target  to  recycle  50 %  of  its  municipal 
waste  by  a  great  margin  and  is  on  a  course  to  miss  the 
2025 targets of a 55 % recycling rate for municipal waste 
and  a  65 %  recycling  rate  for  all  packaging  waste.  While 
the national waste management plan has been updated, 
the regional plans, which are necessary for implementing 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

waste  management  policies 
significantly delayed. 

in  practice,  have  been 

On  urban  wastewater  treatment,  some  positive  steps 
have been taken, such as the systematic assessment and 
strategic  reorganisation  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. 

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

On  nature  protection,  Greece’s  Natura  2000  network  is 
now  considered  completed.  Nevertheless,  site-specific 
conservation  objectives  have  not  been  put  in  place  fully 
due  to  insufficient  data,  while  measures  are  lacking 
completely. 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  in Greece  was 
the  set-up  of  a  national  system  for  the  comprehensive 
management, administration and functioning of protected 
areas. The law that established the Natural Environment 
and Climate Change Agency and put in place management 
bodies  for  all  Natura  2000  sites  has  provided  significant 
benefits in this respect. 

The  overall  environmental  investment  needs  to  enable 
Greece to meet its objectives in the main environmental 
areas is EUR 5.3 billion per year, broken down as follows: 
support  to  biodiversity  and  ecosystems,  EUR 2.1 billion 
per year; pollution prevention and control, EUR 1.3 billion 
per year; circular  economy, EUR 1.1 billion per year; and 
water,  EUR 0.9 billion  per  year.  To  meet 
four 
environmental  objectives  beyond  climate  change,  the 
additional investment need over the current levels (i.e. the 
gap)  reaches  an  estimated  EUR 2.3 billion  per  year  in 
Greece, representing around 1.12 % of the national gross 
domestic  product,  being  lower  than  the  EU  average 
(0.77 %). 

its 

On environmental governance, Greece still needs to step 
up  efforts  regarding  the  data  available  on  the  level  of 
participation 
including 
Impact 
authorisations 
Assessment  Directive  (Directive  2011/92/EU)  and  the 

linked  to  the  Environmental 

in  decision-making  processes, 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Greece 

 
 
Greece  4 

Strategic  Environmental  Assessment  Directive  (Directive 
2001/42/EC). 

On  the  positive  side,  Greece  has  invested  significant 
efforts  in  awareness  raising  and  training  (e.g.  under  the 
Financial Instrument for the Environment Plus Regulation, 
the project ‘Promote financial instruments for liability on 

the  environment’  and  a  pilot  Environmental  Liability 
Directive training workshop with the Commission). Greece 
also  has  an  excellent  record  under  the  Bathing  Water 
Directive: 95.8 % of Greek bathing waters are of excellent 
quality. 

Environmental Implementation Review 2025 – Greece 

 
 
 
 
Greece  5 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial systems  by  reducing  input  materials,  keeping 
products  and  materials  in  the  loop  for  longer  and 
reducing  waste  generation,  thus  decoupling  economic 
growth from resource consumption. A circular economy 
has  considerable  potential  to  increase  competitiveness 
and  job  creation  and  will  also  promote  innovation  and 
provide  access  to  new  markets.  With  the  2020  circular 
economy action plan (CEAP) (2) measures either in place 
or legislatively advanced, Member States will now have 
to focus on a swift and effective implementation. 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were  all 
life-cycle 
introduced  following  a  holistic 
approach, with measures addressing the different stages 
of a product’s life cycle, from design through use to end 
of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a measure of one aspect of circularity: the 
share  of  the  total  amount  of  material  used  in  the 
economy  that  is  accounted  for  by  recycled  waste.  A 
higher  CMUR  value  means  that  more  secondary 
materials  were  used  as  a  substitute  for  raw  materials, 
thus  reducing  the  environmental  impacts  of  extracting 
primary material. 

Greece’s  circular  use  of  materials  increased  up  until 
2022,  when  it  peaked  at  6.3 %,  but  then  declined, 
reaching  5.2 %  in  2023,  well  below  the  EU  average  of 
11.8 %. 

(2) 

Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – A new circular 

15,

10,

5,

0,

2013

2015

2017

2019

2021

2023

Greece

EU27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur, last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cu
r. 

10 December 

2024, 

product 

Improving 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic 
resource 
(GDP). 
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 1.71 
generated per kg of material consumed in 2023, Greece’s 
resource productivity is slightly below the EU average of 
EUR 2.22 per kg. However, with the steady increase in its 
resource  productivity  over  the  last  decade,  Greece 
follows an encouraging trend. 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2

1,5

1

0,5

0

2013

2015

2017

2019

2021

2023

Greece

EU27

NB:  The  unit  of  measurement  used  is  EUR/kg  chain-linked  volume 
(2015). Chain-linked volumes focus on changes on quantities and prices 
of commodities in previous years, taking account of inflation, and are 
indexed to the nearest appropriate year, in this case 2015. 

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

economy action plan for a cleaner and more competitive Europe, 
COM(2020) 98 
https://eur-
lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:52020DC0098. 

11 March 

2020, 

final 

of 

2025 Environmental Implementation Review – Greece 

 
 
 
 
Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These  should  be  tailored  to  each  national  and  local 
reality, to harness the proximity economy’s (3) potential, 
while following the principles of a holistic whole-value-
chain approach. 

Since  the 
launch  of  the  online  European  Circular 
Economy  Stakeholder  Platform  in  2017 (4)  national, 
regional and local authorities have used the platform to 
share their strategies, roadmaps and good practices, for 
example  alternative  business  models  and  innovative 
technologies. 

In 2022, Greece adopted its new national action plan for 
circular economy (5) for 2021–2025, following the limited 
results of the 2018 circular economy strategy. 

including  revising 
implementing  a 

Key  initiatives,  many  of  them  focusing  on  waste,  are 
local  waste 
implemented, 
being 
management  plans, 
food  waste 
prevention programme and introducing specific actions 
in  lignite-dependent  regions.  New  infrastructure  for 
waste separation, recycling and recovery  is going to be 
financed,  alongside  economic  incentives  like  extended 
producer responsibility (EPR) schemes for various waste 
streams  and  a  deposit  refund  system  for  beverage 
bottles. 

Additional  measures  include  environmental  fees  for 
single-use plastics, tax incentives for product donations 
and  standardised  recycling  processes.  The  government 
will  also  support  municipalities  through  technical 
platforms and guides on circular practices, including pay-
as-you-throw” (PAYT) schemes. 

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 using green or circular criteria (life-
cycle analysis, PaaS (platform as a service), second hand) 
can help drive the demand for sustainable products that 
meet reparability and recyclability standards. 

Greece  6 

Greece adopted its first green public procurement (GPP) 
action  plan  in  2021,  which  was  revised  in  July  2024 (6). 
The  action  plan  recommends  that  all  public  authorities 
use EU GPP criteria when procuring goods, services and 
public work. It also sets mandatory and non-mandatory 
targets to use EU GPP criteria in 15 categories of products 
and services. Mandatory targets are set for eight product 
categories  (copying  and  graphic  paper,  computers  and 
monitors,  interior  lighting,  air  conditioning  equipment, 
lubricants, road transport vehicles and services, and road 
lighting  and  traffic  signals).  Setting  up  a  monitoring 
system  for  green,  sustainable  and/or  innovative  public 
procurement remains a key priority for 2025. 

The EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number of eco-management and audit scheme (EMAS)-
licensed  organisations  in  each  country  provide  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. The EU 
Ecolabel  is  awarded  to  products  with  best-in-class 
is  a  voluntary 
environmental  performance.  EMAS 
environment  management  scheme  aimed  at  reducing 
the environmental impacts of organisations. 

As of September 2024, Greece had 4 614 products out of 
98 977 and 20 licences out of 2 983 registered in the EU 
Ecolabel scheme, which places its EMAS take-up on the 
low side in the EU (7). Moreover, 38 organisations from 
Greece are currently registered in EMAS, 3 more than in 
2021 (8). 

Greece’s  CMUR  decreased  by  1.1 percentage  points 
between  2022  and  2023.  This  represents  no  progress 
towards  the  2022  priority  action  to  take  measures  to 
increase the CMUR. 

Greece  has  been  implementing  its  circular  economy 
policy  framework’s  initiatives,  has  identified  the  main 
barriers  to  implementation  and  is  addressing  these 
barriers.  Based  on  this,  accelerated  efforts –  not  solely 
focused on waste – are suggested. 

(3) 

(4) 

(5) 

‘Proximity  and 

European  Commission, 
social  economy 
ecosystem’,  European  Commission  website,  https://single-
market-economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
For more information on the Greek CEAP, see the Circular 
Greece website (https://circulargreece.gr/legislative-
framework/#:~:text=The%20National%20Action%20Plan%20for
,at%20the%20same%20time%20competitive). 

Stakeholder 

Economy 

Platform 

(6) 

(7) 

(8) 

website, 

https://gge.mindev.gov.gr/tomeas-dimosion-
simvaseon/ethniko-sxedio-drasis-prasines-dimosies-simvaseis/. 
European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
2025, 
27 January 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 
As of October 2021. European Commission, ‘EMAS Register – 
Published organisations’, EMAS Register website, accessed 
27 January 2024, 
https://webgate.ec.europa.eu/emas2/public/registration/list. 

accessed 

2025 Environmental Implementation Review – Greece 

 
 
2025 priority action 

•  Adopt measures to increase the circular material use 

Figure 3:  Generation  of  waste  (total  and  excluding 
major mineral waste), population and GDP, 2010–2022 

Greece  7 

rate. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  obligation  to 
ensure  separate  collection  of  waste, 
landfill 
diversion targets, etc.; 

(iii)  reducing  waste  generation  per  capita  and 

in 

absolute terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRMs), with a view to reducing 
dependencies  and  building  resilient  value  chains, 
and stimulating demand for recycled content  in all 
products; 

(v)  limiting energy recovery to non-recyclable materials; 

and 

accessed 

income)’, 

15 October 

nama_10_gdp, 

Sources:  Eurostat,  ‘GDP  and  main  components  (output,  expenditure 
and 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cu
stom_9301905/default/table; Eurostat, ‘Generation of waste by waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/defaul
t/table?lang=en; Eurostat, ‘Population change – Demographic balance 
and  crude  rates  at  national  level’,  demo_grind,  accessed  15 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default
/table?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

Greece  does  not  seem  to  have  any  specific  policy  on 
CRMs. 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

Construction and demolition waste 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
option,  disposal 
landfilling  and 
includes 
incineration without energy recovery). 

(which 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

Construction and demolition waste accounts for almost 
40 % of all waste generated in the EU. A recent study (9) 
by  the  Joint  Research  Centre  shows  that  recycling  and 
preparation for reuse are preferred over incineration and 
landfilling from an environmental perspective for most of 
the  different  streams  of  construction  and  demolition 
waste. However, the economics are often unfavourable 
for  recycling  and  preparation  for  reuse  compared  with 
incineration and landfilling. If available technology were 
to  be  applied,  it  is  estimated  that  an  increase  in  the 
recycling and preparation for reuse of construction and 
demolition  waste  would  lead  to  an  additional  33 Mt  of 
greenhouse gas (GHG) emission savings annually (more 
than, for example, the combined annual GHG emissions 
from Estonia, Latvia and Luxembourg). 

The rate of recycling and preparation for reuse of mineral 
construction and demolition waste in Greece in 2022 was 
99.6 %,  compared  with  the  EU  average  of  79.8 %.  This 
equates 
from 
construction and demolition operations (10). In 2020, the 

to  2 228 185 t  of  mineral  waste 

(9) 

European Commission: Joint Research Centre, Cristobal Garcia, 
J.,  Caro,  D.  et  al.,  Techno-economic  and  environmental 
assessment of construction and demolition waste management 
in  the  European  Union,  Publications  Office  of  the  European 
Union, 
2024, 
Luxembourg, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC135
470. 

(10) 

European Commission: Directorate-General for Internal Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works 
–  Updated  edition  2024,  Publications  Office  of  the  European 
2024,  
Luxembourg, 
Union, 

2025 Environmental Implementation Review – Greece 

 
 
 
 
claimed 
construction and demolition operations was 100 %. 

for  mineral  waste 

recycling 

rate 

from 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste (11),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste Early Warning Report (12) identifying the general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Greece 
is at risk of missing both the municipal waste target and 
the packaging waste target. Greece is also at risk of not 
meeting the 2035 target of having a maximum of 10 % of 
municipal waste landfilled. 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing for reuse and recycling targets for municipal 
waste and packaging waste 

Member  States  not  at  risk  of  missing  the  55 % 
preparing  for  reuse  and  recycling  target  for 
municipal  waste  and  the  65 %  recycling  target 
for packaging waste 

Member States at risk of missing the preparing 
for  reuse  and  recycling  target  for  municipal 
waste  but  not  at  risk  of  missing  the  recycling 
target for packaging waste 

Member States at risk of missing both targets 

Greece  8 

Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not  on  track  to  meet  recycling  targets  for  municipal  waste  and 
packaging waste’, briefing No 28/2022, Copenhagen, 2023. Reference 
data © ESRI. 

targets 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
for 
reaching  certain  waste  management 
municipal  and  packaging  waste.  Member  States  that 
want to use this possibility have to notify the Commission 
24 months  in  advance  of  the  deadline  and  submit  an 
laying  down  the  steps  they 
implementation  plan 
envisage  to  reach  the  postponed  targets  within  a  new 
timeframe.  Regarding  the  2025  targets,  11  Member 
States, including Greece, have used this prerogative. 

On 29 December 2023, Greece notified the Commission 
of  its  intention  to  postpone  the  attainment  of  the 
preparing  for  reuse  and  recycling  target  for  municipal 
waste established by the Waste Framework Directive for 
2025. In addition, Greece notified the Commission of its 
intention  to  postpone  the  attainment  of  the  recycling 
target for plastic and glass packaging waste established 
by  the  Packaging  and  Packaging  Waste  Directive  for 
2025. Attached to these notifications, Greece submitted 
an  implementation  plan  laying  down  the  measures 
necessary  to  attain  the  targets  within  the  postponed 
time frame (i.e. by 2030 instead of 2025). According to 
the implementation plan, the main measures Greece will 
put in place include the closure of the remaining illegal 
landfills,  the  strengthening  of  a  separate  collection 
network  for  recyclable  materials  and  biowaste  and  the 
implementation of a packaging deposit return system. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission is, on one hand, working together with the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (13), the Packaging and 

https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-
01aa75ed71a1/language-en;  European  Commission,  Circular 
Economy  –  Principles  for  buildings  design,  Brussels,  2020, 
https://ec.europa.eu/docsroom/documents/39984. 

(11)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
including  paper  and 
collected  waste 
from  households, 
cardboard,  glass,  metals,  plastics,  biowaste,  wood,  textiles, 
packaging,  waste  electrical  and  electronic  equipment,  waste 
including 
batteries  and  accumulators,  and  bulky  waste, 

mattresses  and  furniture;  and  (ii)  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, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(12) 

(13)   Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  repealing  certain 
Directives, Directive - 2008/98 - EN - Waste framework directive 
- EUR-Lex. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
 
 
Packaging  Waste  Directive  (14)  and  the  Directive  on 
Waste Electrical and Electronic Equipment (WEEE) (15). 

Municipal waste 

Municipal  waste  generation 
in  Greece  stagnated 
between 2010 and 2021 (Figure 5). In 2021, the country 
generated 509 kg per capita of municipal waste, which is 
very close to the estimated EU-27 average of 527 kg per 
capita in the same year. 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source: Eurostat, ‘Municipal waste by waste management operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/def
ault/table. 

22 October 

accessed 

Greece  9 

NB:  Data for  2022  are  not  available.  As of  reference  year  2020,  new 
reporting rules apply to calculating recycled municipal waste pursuant 
to the targets laid down in Article 11(2)(c–e) of Directive 2008/98/EC. 
Greece has applied the new reporting rules since reference year 2020 
(Hellenic Ministry of Environment and Energy, 2024). 
Source: Eurostat, ‘Municipal waste by waste management operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/def
ault/table. 

22 October 

accessed 

The municipal waste recycling rate in Greece remained 
low  over  the  period  covered  (Figure 6).  In  2021,  the 
recycling rate was 17 %, which is significantly below the 
estimated EU-27 average of 49 % in the same year. The 
rate of composting and anaerobic digestion also remains 
very low and stagnating in Greece, reaching 2 % in 2021. 
Municipal  waste  incineration  plays  a  minor  role  in 
Greece,  at  2 %  in  2021,  while  landfilling  is  still  the 
dominant  treatment  method  for  municipal  waste.  The 
landfilling  rate  has  stagnated  at  the  very  high  level  of 
80 % (Figure 5). 

Greece has also reported data to show compliance with 
the preparing for reuse and recycling target of 55 % for 
2025, as set out in the Waste Framework Directive. The 
difference  between  these  (provisional)  data,  following 
the  reporting  obligation  of  the  Waste  Framework 
Directive,  and  the  data  shown  in  Figure 5  (voluntary 
reporting)  was  less  than  1 percentage  point  for  the 
preparing for reuse and recycling rate in 2021 (Eurostat). 

Packaging waste 

Figure 7: Packaging waste generation, 2010–2022 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

(14)   European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste  (OJ  L  365, 
31/12/1994, p. 10–23), Directive - 94/62 - EN - EUR-Lex.  
(15)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 

equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19 - EN - EUR-Lex. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
 
With  regard  to  packaging,  waste  generation  in  Greece 
decreased  between  2010  and  2013  (Figure 7),  after 
which  it  stabilised.  It  then  increased  back  to  the  2010 
level in 2019 and, from 2021 onwards, increased above 
that. In 2022, the country generated 105 kg per capita of 
packaging  waste,  which 
is  significantly  below  the 
estimated European average of 186 kg per capita in the 
same year (16). It should be noted that the estimation of 
generated packaging waste in Greece might  be  missing 
quantities generated due to the de minimis rule, online 
sales and free riders. As a result, the generated quantities 
might in fact be higher than reported, which could also 
affect the recycling rate (17). 

Figure 8:  Packaging  waste  recycling  rates  (%),  2010–
2022 

NB: Data for 2020 are still under validation at Eurostat. As of reference 
year  2020,  the  rules  for  calculating  recycled  packaging  waste  have 
changed,  pursuant  to  Article 6a  of  Directive  94/62/EC.  Greece  has 
applied the new calculation rules since reference year 2020 (Hellenic 
Ministry of Environment and Energy, 2024). 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

The overall packaging waste recycling rate in Greece was 
rather  stable  at  around  60 %  until  2019  (Figure 8). 
However, in 2022 it dropped significantly to 43 %, which 
is  significantly  below  the  (estimated)  EU-27  average  of 
65 %  in  the  same  year.  This  drop  is  due  to  the  lack  of 
verified  data  on  industrial  and  commercial  packaging 
from  two  producer  responsibility  organisations.  These 
volumes  are  therefore  not  included  in  the  recycling 
volumes,  which  has  affected  the  recycling  rates  of  all 
materials (Eurostat, 2024). 

In 2021 and 2022, Greece recycled 54 % and 43 % of its 
total  packaging  waste,  respectively.  The  recycling  rates 
for plastic, aluminium, glass and wooden packaging were 

Greece  10 

clearly below the 2025 targets in both years, while the 
rates were above the 2025 target for steel packaging. The 
overall packaging waste recycling rate is mainly driven by 
paper  and  cardboard  and  plastic  packaging  waste,  as 
these constitute the largest shares of recyclable waste. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of EU waste legislation. They set out key provisions and 
investments to ensure compliance with existing and new 
legal  requirements  (e.g.  on  waste  prevention,  on 
separate  collection  for  certain  waste  streams,  on 
recycling and on landfill targets). 

The  Greek  national  waste  prevention  programme 
is  a  stand-alone  strategic  document  and 
(NWPP) 
addresses  2021–2030  (EEA,  2023b).  The  programme  is 
expected to be partly financed through the EU Structural 
and Investment Funds for the 2021–2027 programming 
period,  in  combination  with  specific  funding  for  waste 
prevention  and  management.  There  is,  however,  no 
indication of a specific budget in the NWPP. Examples of 
objectives  targeting  waste  prevention  outlined  in  the 
programme are: 

• 

• 

• 

• 

• 

promoting circular  consumption, raising awareness 
and providing tools for citizens to transition from a 
linear  to  a  circular  model  of  behaviour  and 
consumption; 
setting  waste  reduction  targets  for  specific  waste 
streams; 
encouraging the perception of waste as a resource 
within the broader context of the circular economy; 
strengthening waste prevention efforts through an 
integrated  and 
systematic  public  awareness 
campaign; 
developing and promoting a new industrial strategy 
to transform circularity in the production process. 

The prioritised waste streams include food waste, paper 
waste,  packaging  waste  (specifying  different  types  of 
plastic),  WEEE,  textile  waste,  bulky  waste,  industrial 
waste  and  waste  generated 
from  excavation, 
construction  and  demolition  activities.  The  NWPP 
establishes  two  quantitative  targets,  in  line  with  those 
established in Law No 4819/2021: to reduce food waste 
per capita by 30 % from 2022 to 2030, at the retail and 
consumer levels, and to reduce the utilisation of single-
use plastic cups for beverages and food by 30 % in 2024 
and  60 %  in  2026,  relative  to  the  levels  in  2022  (EEA, 
2023b).  To  achieve  these  targets,  various  financial 
in  combination  with  the 
incentives  will  be  used 

(16) 

The EU average might have been influenced by not all Member 
States fully applying the reporting rules for packaging waste set 
out in Commission Implementing Decision (EU) 2019/665. 

(17) 

https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

2025 Environmental Implementation Review – Greece 

 
 
 
promotion  of  research  and  development  and  the 
implementation 
campaigns 
(Government of Greece, 2022). 

awareness-raising 

of 

instance,  by 

Measures for waste prevention include several initiatives 
promoting  and  strengthening  collection  networks  for 
textiles and furniture no longer suitable for their original 
use –  for 
investigating  EPR  schemes. 
Additionally, there is a focus on promoting the utilisation 
of  used  electronics 
in  both  private  and  public 
procurement,  along  with  providing  financial  incentives 
for  the  repair  and  reuse  of  electrical  and  electronic 
equipment.  Furthermore,  the  NWPP  encourages  the 
development  of  reuse  practices 
for  construction 
materials  and  limiting  the  use  of  certain  packaging 
materials to promote designing for reuse and recycling, 
among other initiatives (Government of Greece, 2022). 

Based  on  a  pilot  project  in  West  Macedonia,  which 
established  three  creative  reuse  centres  (CRCs)  for 
materials, Law No 4819/2021 committed Greece to the 
establishment  of  more  CRCs  by  the  end  of  2023: 
municipalities  with  more  than  20 000  residents  are 
required  to  establish  CRCs  to  collect  used 
items, 
including  electrical  and  electronic  equipment,  toys, 
furniture, bicycles, books and textiles. In this context, the 
financial instrument for the environment (LIFE) RE-WEEE 
(Development and demonstration of waste electrical and 
electronic  equipment  (WEEE)  prevention  and  reuse 
paradigms) project has emerged, which sorts, cleans and 
repairs  or  prepares  for  reuse  electric  and  electronic 
equipment  (LIFE  RE-WEEE,  2020;  EEA,  2023b).  As  a 
follow-up  activity  to  the  project,  capacity-building 
seminars  started  in  2022  in  several  regions,  and  a  few 
repair  cafes  were  organised  but  have  not  been  widely 
implemented  (Hellenic  Ministry  of  Environment  and 
Energy, 2024). 

The  NWPP  includes  six  main  pillars  of  food  waste 
prevention measures, with several actions for each pillar 
(Government of Greece, 2022). Since 2022, food-waste-
related  data  have  been  reported  in  the  Ministry  of 
Environment and Energy’s Electronic Waste Registry,  in 
accordance  with  the  provisions  of  Article 20  of  Law 
No 4819/2021.  The  first  reporting  concerns  data  for 
2021,  based  on  Commission  Implementing  Decision 
2019/1597. 

To  monitor  the  effectiveness  of  the  NWPP,  Greece  has 
established indicators for each prioritised waste stream. 
The  programme  will  be  evaluated  every  five  years  and 
will  be  revised  when  necessary  and  appropriate  (EEA, 
2023b).  The  evaluation  of  the  previous  programme 
highlights 
significant 
improvements  across  various  areas  and  indicates  that 
the measures implemented for waste prevention so far 
are incomplete and lack a comprehensive assessment of 
their  effectiveness.  Furthermore,  the  evaluation  stated 

pressing 

need 

the 

for 

Greece  11 

that  several  actions  have  recently  been  initiated  and 
therefore  results  have  not  yet  been  recorded  (EEA, 
2023b). 

Policies to encourage separate collection and recycling 

recyclables,  Greece 

For 
implements  door-to-door 
commingled  collection  complemented  by  low-density 
bring  points,  or  collection  corners  at  the  level  of  each 
building block (high-density bring points). However, the 
separate  collection  system  targets  packaging  materials 
only.  Most  of  the  household  packaging  and  non-
packaging  waste  is  collected  co-mingled.  For  example, 
printed  paper  is  collected  with  paper  and  cardboard, 
plastic, metal and glass packaging, and sorted at sorting 
facilities into recyclable materials. Separate collection of 
biowaste  takes  place  in  some  municipalities  (Hellenic 
Ministry  of  Environment  and  Energy,  2024).  Door-to-
door  separate  collection  of  garden  waste  is  in  place 
everywhere  except  in  rural  areas.  Textile  waste  is  only 
collected in cities, using high-density bring points. 

The  separate  collection  of  non-household  packaging 
waste was not mandatory for all non-household sources. 
It  was,  however,  mandatory  for  operators  of  public 
gathering areas and for catering companies able to serve 
over  100  customers.  However,  Law  No 4819/2021 
extends  the  separate  collection  obligation  to  non-
household waste (ETC/CE, 2022). 

Since  separate  collection  in  Greece  currently  delivers 
only  moderate  capture  rates,  there  is  a  need  for 
incentives  to  enhance  separation  at  the  source  and 
separate collection. Greece has already made firm plans 
to improve the situation and several actions were to be 
implemented in 2022 and 2023. Separate collection was 
to  be  extended  regarding  the  four  recyclable  waste 
streams  (paper,  plastic,  glass,  and  metal)  and  non-
packaging  waste  was  to  be  included  in  the  system. 
Schools and government bodies were to collect printed 
paper and the universal separate collection of biowaste, 
including food waste, was to be implemented from the 
end  of  2022  by  municipalities  and  private  companies 
(ETC/CE,  2022).  However,  these  improvements  are  not 
yet fully implemented (Hellenic Ministry of Environment 
and Energy, 2024), and more detailed information on the 
implementation’s status is not available. Under cohesion 
policy  2021-2027,  the  Greek  authorities  have  adopted 
the Recycling and Recovery Facility (RRF) model for waste 
management. Investments in RRFs will be combined with 
comprehensive  and  integrated  local  plans  for  separate 
waste collection in each service area.  

Greece  does  not  yet  apply  pay-as-you-throw  schemes, 
but it has firm plans to do so according to the  national 
waste management plan for 2020–2030 (ETC/CE, 2022). 
Pay-as-you-throw schemes have been made a legislative 
(Article 37,  Law  No 4819/2021).  The 
requirement 

2025 Environmental Implementation Review – Greece 

 
implementation of such schemes is still in its initial stage 
(Hellenic Ministry of Environment and Energy, 2024). 

EPR  schemes  cover  packaging  waste 
from  both 
household and non-household sources for all packaging 
materials. The system applies advanced fee modulation 
to  plastic  packaging  (i.e.  higher  fees  for  difficult-to-
recycle  plastic  types  or  combinations  of  materials) 
(ETC/CE, 2022). In addition, Greek legislation expects to 
introduce  EPR  for  several  product  groups  (textiles, 
agricultural  plastics,  medicines  for  household  use, 
light 
matrices,  furniture,  toys,  athletic  equipment, 
in 
personal  electric  vehicles  and  electric  bicycles), 
addition to those provided for in the Single-use Plastics 
Directive (Hellenic Ministry of Environment and Energy, 
2024). 

Greece  has  packaging  taxes  for  plastic  carrier  bags, 
single-use  plastic  beverage  cups  and  food  containers, 
and  packaging  products  containing  polyvinyl  chloride 
(PVC).  Greece  has  no  deposit  return  systems  in  use, 
except for systems for glass drink bottles run by private 
initiatives.  A  nationwide  deposit  return  system  for 
aluminium, glass and plastic beverage packaging was to 
be  implemented  at  the  beginning  of  2023  by  beverage 
packaging producers (ETC/CE, 2022). A legal amendment 
to  introduce  a  nationwide  deposit  return  system  for 
plastic  and  metal  beverage  containers  is  in  process. 
According 
the 
implementation of the system has been postponed until 
December  2025.  The  required  ministerial  decision  is 
expected  to  be  issued  by  the  end  of  2024  (Hellenic 
Ministry of Environment and Energy, 2024). 

provisions, 

proposed 

the 

to 

Policies to discourage landfilling or incineration 

Greece applies a landfill tax, with a rate of EUR 20/t as of 
2022. This fee is very low and lies considerably below the 
landfill taxes applied in other Member States. However, 
the  landfill  fee  increases  annually  by  EUR 5/t,  until 
reaching  EUR 55  from  2027  onwards.  According  to 
Article 38  of  Law  No 4819/2021,  the  revenues  will  be 
used  to  finance  waste  prevention,  separate  collection 
and  recycling  measures  of  municipalities  and  waste 
management bodies, and research and technologies for 
recycling  and  waste.  There  is  no  landfill  ban  at  the 
moment  but,  since  the  beginning  of  2024,  it  has  been 
prohibited  to 
landfill  textiles,  electrical  electronic 
equipment,  products  used  for  daily  hygiene,  footwear 
and  books  unsuitable  for  sale  or  use  unless  it  can  be 
proved that all other waste hierarchy options have been 
applied to the extent possible (ETC/CE, 2022; EEA, 2023a; 
Hellenic Ministry of Environment and Energy, 2024). 

Greece  12 

There are no incineration taxes in Greece, as there are no 
incineration  facilities  in  the  country.  Greece  currently 
does not export waste for incineration. 

Until recently, the combination of a low landfill fee and 
cheap  illegal  landfills  had  not  created  any  incentive  to 
enhance recycling (ETC/CE, 2022). 

In  2003, 

to  date) (18). 

(EUR 72 million 

In 2001, the Commission launched an infringement case 
and asked Greece to close and rehabilitate all the illegal 
landfills that continue to operate in the country. In 2014, 
the  Court  of  Justice  of  the  European  Union  (CJEU) 
imposed financial sanctions on Greece, as it had still not 
complied. Greece continues to pay fines on a semestrial 
basis 
the 
Commission  launched  an  infringement  case  and  asked 
Greece to ensure that all its hazardous waste is properly 
treated. In 2016, the CJEU imposed financial sanctions on 
Greece, as it had still not complied. Greece continues to 
pay  fines  on  a  semestrial  basis  (EUR 72 million  to 
date) (19). 
launched  an 
infringement  case  and  asked  Greece  to  ensure  that  all 
waste  is  subject  to  adequate  treatment  before  being 
landfilled  and  to  establish  an  integrated  and  adequate 
network  of  waste  disposal 
installations  for  mixed 
municipal  waste.  The  continuous  non-compliance  with 
the  rulings  of  the  CJEU  is  an  indication  of  systemic 
weaknesses 
in  the  Member  State’s  administrative 
system. 

In  2021,  the  Commission 

Greece has made no progress in addressing the issues of 
the closure and rehabilitation of illegal landfills and of the 
treatment  of  hazardous  waste  as  matters  of  absolute 
priority. It has also made no progress in avoiding building 
excessive  infrastructure  for  the  treatment  of  residual 
waste.  Greece  made  some  progress  in  improving  and 
extending  the  separate  collection  of  waste,  including 
biowaste.  The  country  also  made  some  progress  in 
increasing  and  enforcing  landfill  taxes  and  channelling 
those  revenues  towards  measures  that  improve  waste 
management  in  line  with  the  waste  hierarchy.  Finally, 
Greece made some progress in improving the efficiency 
of  the  EPR  systems,  in  line  with  the  general  minimum 
requirements on EPR, and in ensuring that regional waste 
management  plans  are  in  place  and  in  line  with  the 
revised Waste Framework Directive. 

2025 priority actions 

• 

• 
• 

Implement,  harmonise,  and  gradually 
increase 
landfill  taxes  to  phase  out  landfilling  of  recyclable 
and recoverable waste.    
Complete closure of non-compliant landfills. 
Improve  separate  collection  at  source  e.g.  through 
economic  instruments,  investing  in  infrastructure 

(18) 

INFR(2001)2273. 

(19) 

INFR(2003)2187. 

2025 Environmental Implementation Review – Greece 

 
 
Greece  13 

for  separate  collection,  sorting  and  recycling,  and 
increasing public awareness. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps of the waste hierarchy. In particular, improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Increase the recycling rates of packaging waste. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 

• 

• 
• 

• 

• 

• 

Improve the system for managing the quality of data 
on packaging waste in order to build coherent and 
verifiable data sets. 
Invest in waste prevention measures to reduce the 
total amount of waste generated. 
Ensure the achievement of the 2025 waste targets, 
following  the  recommendations  made  by  the 
Commission  in  the  Early  Warning  Reports  where 
applicable. 

2025 Environmental Implementation Review – Greece 

 
 
 
2. Biodiversity and natural capital

Global and EU biodiversity frameworks

Greece  14 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. The EU biodiversity strategy for 2030 (BDS) aims to 
put EU biodiversity on a path to recovery by 2030. It sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (20)  and  a  dashboard  of  indicators (21) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (22) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20 % of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
implementation 
national 
restoration plans. 

implementation 

framework 

enable 

based 

on 

to 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity 
(CBD)  its  report  on  GBF-aligned  EU  targets  that  stem 
from the BDS and from other policy instruments under 
the European Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 

(20) 

(21) 

(22) 

Actions 

Tracker 

Strategy 

Strategy 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
law 
on 
Commission 

see  also 
the 

Dashboard 

page 

web 

In 

2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

Greece  has  not  yet  submitted  to  the  CBD  an  updated 
NBSAP or aligned national targets. 

The EU aims to allocate at least 7.5 % of annual spending 
under the EU budget to biodiversity objectives in 2024, 
in  2026  and  2027.  For  details  on 
rising  to  10 % 
biodiversity  financing  and  investments  for  Greece,  see 
‘Biodiversity and ecosystems’ in Chapter 5. 

2025 priority action 

• 

Submit  to  the  CBD  an  updated  NBSAP  or  national 
targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (23),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (24); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

(23)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 

(24) 

2025 Environmental Implementation Review – Greece 

 
 
Setting up a complete and coherent network of Natura 
2000 sites 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Greece  15 

The  setting  up  of  a  complete  and  coherent  network  of 
is  a  cornerstone  of  the  EU’s 
Natura  2000  sites 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000 will enable the natural habitat types and the 
species’ habitats concerned to be maintained or, where 
appropriate,  restored  to  a  favourable  conservation 
status in their natural range. 

Greece  hosts  89  habitat  types (25)  and  296  species (26) 
covered by the Habitats Directive. The country also hosts 
populations  of  160  bird  species  listed  in  the  Birds 
Directive Annex I (27). 

Greece has designated 446 Natura 2000 sites, including 
265  SCIs  under  the  Habitats  Directive  and  207  special 
protection areas (SPAs) under the Birds Directive. 

As  shown  in  Figure 9,  in  2023,  27.3 %  of  Greece’s  land 
area  was  covered  by  Natura  2000  sites  (EU  coverage: 
18.6 %),  with  SPAs  classified  under  the  Birds  Directive 
covering 21 % (EU coverage: 12.8 %) and SCIs under the 
Habitats  Directive  covering  16.6 % (28)  (EU  coverage: 
14.3 %). 

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

Today, the Natura 2000 network covers 18 % of Greece’s 
territorial waters. 

Considering  both  areas  covered  by  Natura  2000  and 
other  nationally  designated  protected  areas,  Greece 
reports  that  it  legally  protects  34.6 %  of  its  terrestrial 
areas  (EU-27  coverage:  26.1 %)  and  19.8 %  of 
its 
territorial marine waters (EU-27 coverage: 12.3 %) (29). 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating special areas of conservation and setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  Such  site-specific 
conservation  should  define  attributes  and  targets  that 
describe the habitats or species’ condition as favourable 
or unfavourable, addressing key pressures and threats . 
Under Article 6 of the Habitats Directive Member States 
must establish and implement measures to achieve these 
objectives.   The  six-year  deadline  set  by  the  Habitats 
Directive 
conservation 
objectives  and  measures  has  expired  for  239  sites  in 
Greece. 

to  establish 

appropriate 

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

In  2020,  the  CJEU  condemned  Greece  for  not  having 
established  the  necessary  conservation  objectives  and 
measures  for  all  Natura  2000  sites  designated  as 

(25) 

(26) 

(27) 

European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
19 December 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 

19 December 

dashboard, 

(28) 

(29) 

https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  bird  taxa  for  which 
information was requested. 
According 
to 
(https://ypen.gov.gr/wp-content/uploads/2021/04/PAF-
EL_FINAL.pdf) 
Natura 
the 
and 
(https://www.eea.europa.eu/data-and-
maps/dashboards/natura-2000-barometer). 
Eurostat dataset env_bio4, 2022 data, accessed 12 March 2025 

the  Greek  priority 

framework 

Barometer 

action 

2000 

2025 Environmental Implementation Review – Greece 

 
 
 
this 

indicates 

SACs (30). Greece has adopted site-specific conservation 
objectives.  However,  for  the  majority  of  species  and 
habitats, the objectives are compromised by the lack of 
data; 
that  an  annual,  permanent 
monitoring system for the conservation status of species 
and habitats is needed. Greece also still has to set out the 
necessary  conservation  measures 
for  the  already 
designated  sites.  The  Ministry  of  Environment  and 
Energy has commissioned the preparation of 23 special 
environmental  studies and corresponding  management 
plans  for  the  446  areas  in  the  country’s  Natura  2000 
network,  divided  into  11  area  groups.  The  national 
restoration plans will indicate the zones and permitted 
land  uses  within  their  boundaries,  in  relation  to  the 
protected species and habitats in each area group and in 
harmony with the anthropogenic activities of the wider 
area.  The  plans  are  institutionalised  by  presidential 
decrees. Today, only 3 out of the 23 regional restoration 
plans have been approved in Greece. 

Some  progress  has  been  made  by  Greece  on  the  2022 
priority actions, but there is a need to continue working 
on those to speed up and finalise the work. 

2025 priority actions 

•  Complete  Complete 

the  Natura  2000 

site 

• 

• 

of 

the 

establishment 

designation process. 
Finalise 
site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
implementation  of 
the  Nature  Restoration 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Greece  16 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (31). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

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 
(Figure 10).  Of  protected  species  (Figure 11),  35.02 % 
were in good conservation status. Regarding birds, 77 % 
of  breeding  species  showed  short-term  increases  or 
stable  population  trends  (for  wintering  species,  this 
figure was 50 %). 

‘4  Natura’ 

In  the  context  of  the  LIFE 
integrated 
project (32),  12  action  plans  have  been  developed  for 
habitats  and  species  of  community  interest  whose 
conservation  status  is  considered  unsatisfactory  and 
requires  rapid  improvement.  Eight  action  plans  have 
been  adopted  so  far,  while  the  legal  adoption  of  the 
remaining four is expected soon. 

(30) 

(31) 

Judgment of 17 December 2020, Commission v Greece (Habitats 
dans  la  région  biogéographique  méditerranéenne),  C-849/19, 
EU:C:2020:1047. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 

(32) 

Union, 

European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
https://edozoume.gr/. 

Luxembourg, 

2020, 

2025 Environmental Implementation Review – Greece 

 
 
Greece  17 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

The main pressures and threats for habitats in Greece are 
related  to  agriculture, 
infrastructure  development, 
development  and operation of transport systems, alien 
and problematic species and natural processes (33). All of 
these – together with human-induced changes in water 
regimes, unknown pressures and pressures from outside 
the Member State – are also the main pressures affecting 
species. 

The  Greek  Red  List  of  Threatened  Species  of  Plants, 
Animals, and Fungi is almost complete, with over 11 000 
species  having  been  assessed  and  classified  into  threat 
categories.  The  Greek  Red  List  is  a  valuable  tool  for 
biodiversity  conservation,  guiding  targeted  actions  and 
policies to protect Greek  natural heritage and promote 
sustainable  management  practices.  All  species  were 
for 
assessed  based  on 
Conservation  of  Nature  criteria,  while  Greek  endemic 
species  will  be  gradually  added  to  the  International 
Union  for  Conservation  of  Nature  global  Red  List.  The 
Greek Red List is now accessible to all through its official 
website  that  provides  public  access  to  scientific 
knowledge about the country’s flora and fauna (34). 

International  Union 

the 

Figure 10:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

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. 

for 

the 

A  major  challenge  in  protecting  and  managing  Natura 
2000  sites  effectively  has  been  setting  up  a  national 
system 
comprehensive  management, 
administration  and  functioning  of  protected  areas 
(including  strategy,  structure,  management  schemes, 
responsibilities, financing, enforcement and monitoring), 
as shown by the fact that Greece still has to execute the 
above  CJEU  ruling  of  17 December  2020  in  Case  C-
849/19. In May 2020, a central organisation, the Natural 
Environment and Climate Change Agency (NECCA), was 
established (35). NECCA aims to remedy the situation. All 
Natura 2000 sites now belong to one of the 24 protected 
area  management  units,  integrated  into  NECCA,  and 
comprising  the  protected  area  management  system  at 
the regional level. 

(i)  the 

Most  of the complaints received point  to the following 
shortcomings: 
(among 
authorities, stakeholders and the public) of Natura 2000 
and  its  benefits  and  the  lack  of  incentive  to  invest  in 
promoting these benefits; (ii) the insufficient integration 

lack  of  awareness 

(33) 

https://www.eea.europa.eu/en/analysis/maps-and-
charts/main-pressures-and-threats-article-17-national-
summary-dashboards-archived. 

(34)  www.redlist.necca.gov.gr. 
(35) 

ν. 4685/2020. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
of  nature  protection  considerations  into  other  policies; 
(iii) the lack of management of the sites; (iv) difficulties 
with  enforcing  the  law;  and  (v)  the  lack  of  proper 
implementation  of  Article 6(3)  and  6(4)  of  the  Habitats 
Directive. 

The  shortcomings  are  reflected  in  the  two  ongoing 
infringement cases related to (i) the lack of an adequate 
appropriate  assessment  under  the  Habitats  Directive 
concerning wind farm planning at national level (which 
has 
impacts  on  the  subsequent  authorisation  of 
projects);  and  (ii)  the  insufficient  protection  of  species 
and habitats, including  against illegal activities (see the 
Court ruling of November 2016 (36) to ensure adequate 
protection of the Kyparissia area and the Caretta caretta 
turtle species). 

Little  progress  has  been  made  by  Greece  on  the  2022 
priority actions, and there is a need to continue working 
on those to speed up and finalise the work. 

2025 priority actions 

• 

Enhance  efforts  to  collect  reliable  data  on  the 
conservation status of habitats and species as well as 
their occurrence at site level. In view of this, consider 
the creation of a body in charge of monitoring and 
reporting, to ensure that data are not provided only 
ad hoc on a contract basis. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
is  no 
fertilisers)  while  ensuring 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

high-diversity landscape features; and 

Greece  18 

— 

increase the area under organic farming to at least 
25 %.  

The “Vision for agriculture and food” (37 ), adopted by the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective. 

The  CAP  and  national  CAP  strategic  plans  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity.  

in 

While certain CAP result indicators focus on the national 
measures  favouring  sustainable  agriculture  practices 
impact  of  these 
that  regenerate  ecosystems,  the 
measures  is  difficult  to  assess.  The  uptake  of  the  eco-
schemes is voluntary for farmers. 

The  utilised  agricultural  area  in  Greece  increased  from 
5 134 710 ha in 2012 to 5 406 720 ha in 2014, and then 
decreased to 5 371 560 ha in 2022 (38). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  Greece  is  7 %,  above 
the EU average. At the EU level, landscape features cover 
5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (39) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 

(36) 

(37) 

(38) 

Judgment  of  10 November  2016,  Commission  v  Greece,  C-
504/14, EU:C:2016:847. 

https://agriculture.ec.europa.eu/overview-vision-agriculture-

food/vision-agriculture-and-food_en  
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 

5 December 

(39) 

Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 

2025 Environmental Implementation Review – Greece 

 
 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  area  or  landscape  features  in  their 
farms.  The  amended  regulation  set  out,  however,  an 
obligation  for  Member  States  to  establish  and  provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 
fallow,  and  for  the  establishment  of  new  landscape 
features on arable land. 

The recently adopted Nature Restoration Regulation (40) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (41). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
17.22 % of Greece’s land area is used for organic farming. 
This is one of the highest levels in the EU and well above 
the EU average of 10.50 % (42). Greece is contributing an 
above average amount to achieving the target of 25 % of 
the EU’s agricultural land being used for organic farming 
by 2030. 

Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
2022 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
2024, 
5 December 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

Greece  19 

2025 priority actions 

• 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of Greece. 

practices 

address 

and 

to 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
security  and  climate 
resilience,  adaptation  and 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (43) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 

soil  organic 

loss  of 

carbon, 

(40) 

(41) 

(42) 

Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
‘share  of 
organic  carbon 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
is  currently  under  review;  European  Commission, 
which 

in  cropland  mineral  soils’  and 

(43) 

Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 
Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 

2023, 

5 July 

final 

of 

2025 Environmental Implementation Review – Greece 

 
 
 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Greece (44). 

13 % of Greece is affected by loss of soil organic carbon 
in  mineral  soils (45),  representing  83 %  of  cropland  and 
grassland areas. 11 % of the national territory has a high 
or  very  high  susceptibility  to  topsoil  compaction,  and 
10 % of the land experiences unsustainable soil erosion 
by water, wind, tillage and harvest, representing 60 % of 
total cropland area. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

Greece  hosts  10  grassland  habitat  types (46)  listed  in 
Annex I to the Habitats Directive. According to data for 
the latest reporting period (2013–2018), reported under 
Article 17,  the  conservation  status  of  four  grassland 
habitats  is  favourable,  another  four  are  deemed  of 
unfavourable – inadequate status and for two grassland 
habitats the status is unknown (47). The main pressures 
and  threats  for  these  habitat  types  are  related  to 
agriculture,  infrastructure  development,  development 

(44) 

Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
2023, 
5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

(46) 

(45)  De  Rosa,  D.,  Ballabio,  C.,  Lugato,  E.  et  al.,  ‘Soil  organic  carbon 
stocks in European croplands and grasslands: How much have we 
lost in the past decade?’, Global Change Biology, Vol. 30, No 1, 
2024, e16992, https://doi.org/10.1111/gcb.16992. 
These are rupicolous calcareous or basophilic grasslands of the 
Alysso-Sedion  albi;  alpine  and subalpine  calcareous  grasslands; 
pseudo-steppe  with  grasses  and  annuals  of  the  Thero-
Brachypodietea;  species-rich  Nardus  grasslands,  on  siliceous 
substrates  in  mountain  areas  (and  submountain  areas  in 
continental  Europe);  Pannonic  sand  steppes;  eastern  sub-
(Scorzoneratalia  villosae); 
Mediterranean  dry  grasslands 
serpentinophilous 
acidophilous 
grasslands; Mediterranean tall humid grasslands of the Molinio-
Holoschoenion;  Hydrophilous  tall  herb  fringe  communities  of 
plains  and  of  the  montane  to  alpine  levels;  and  lowland  hay 
meadows (Alopecurus pratensis, Sanguisorba officinalis). 

grasslands;  Oro-Moesian 

Greece  20 

and  operation  of  transport  systems  and  natural 
processes 
following 
abandonment) (48). 

succession 

natural 

(i.e. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

Regarding  wetlands,  Greece  hosts  10  freshwater  and 
coastal  habitat 
the  Habitats 
types  covered  by 
Directive (49).  According  to  the  latest  reporting  under 
Article 17,  all  except  two  of  them  have  unfavourable 
conservation status (50). The main pressures and threats 
identified  for  freshwater  and  coastal  habitat  types  are 
infrastructure development, agriculture, pollution, alien 
and problematic species and human-induced changes to 
water regimes (51). 

Among bogs, fens and mires, four habitat types listed in 
Annex I  to  the  Habitats  Directive  are  protected  in 

(47) 

(48) 

(49) 

(50) 

(51) 

https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=GR&region=. 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/main-pressures-and-threats-article-17-national-
summary-dashboards-archived. 
These  are  oligotrophic  to  mesotrophic  standing  waters  with 
vegetation  of  the  Littorelletea  uniflorae  and/or  of  the  Isoeto-
Nanojuncetea,  hard  oligo-mesotrophic  waters  with  benthic 
lakes  with 
vegetation  of  Chara  spp.,  natural  eutrophic 
Magnopotamion- 
vegetation, 
Mediterranean temporary ponds, coastal lagoons, large shallow 
inlets and bays, Salicornia and other annuals colonising mud and 
sand,  Mediterranean  salt  meadows  (Juncetalia  maritimi), 
Mediterranean  and 
scrubs 
(Sarcocornetea fruticosi) and halo-nitrophilous scrubs (Pegano-
Salsoletea). 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Coastal+habitats&country=GR&region=. 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/main-pressures-and-threats-article-17-national-
summary-dashboards-archived. 

thermo-Atlantic  halophilous 

Hydrocharition-type 

or 

2025 Environmental Implementation Review – Greece 

 
 
these,  only  one  has 

Greece (52).  Of 
favourable 
conservation  status  (transition  mires  and  quaking 
bogs) (53).  Agriculture,  development  and  operation  of 
transport systems, and human-induced changes in water 
regimes are some of the main pressures for and threats 
to these habitats (54). 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
is  a 
Directives, 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several Commission guidelines on forestry management 
were  published  in  2023.  They  covered  biodiversity-
friendly  afforestation,  reforestation  and  tree  planting; 
closer-to-nature  forest  management;  and  defining, 
mapping, monitoring and strictly protecting primary and 
old-growth  forests.  Further  guidance  on  payment 
schemes 
for  ecosystems  services  has  also  been 
published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring  law  that  aims  to  create  a  comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (55).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

Greece  21 

Forests covered 30.3 % of Greece’s territory in 2020 (56) 
and more than 30 % of the assessments of EU-protected 
forest habitats in Greece reveal a bad or poor status (57), 
of  which  60 %  show  an  improving  trend  and  the 
remaining 40 % a constant trend. 

Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

Source: Commission staff working document – New EU forest strategy 
final  of  16 July  2021,  p. 24,  eur-
for  2030,  SWD(2021) 652 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652  

Among forest disturbances contributing to loss of forest 
integrity  and 
loss,  wildfires 
related  biodiversity 
constitute a particular  reason for concern. In 2022, the 
EU  saw  a  record  number  (2 700)  of  wildfires  affecting 
more  than  30 ha,  which  led  to  the  destruction  of 
785 605 ha  of  forest,  the  second  highest  annual  figure 
recorded.  Recent  years  have  also  witnessed  the 
occurrence of widespread uncontrollable fires (so-called 
megafires), which are associated with loss of life and an 
enormous cost in terms of damage to the environment, 
businesses and society (over EUR 2 billion annually) and 
carbon dioxide (CO2) emissions. Megafires are practically 
beyond suppression capacity and can be prevented only 
by  an  integrated  risk  management  approach.  Wildfires 
prevention is also essential to preserve resources for the 
bioeconomy. 

(52) 

(53) 

(54) 

(55) 

These  are  transition  mires  and  quaking  bogs,  calcareous  fens 
with Cladium mariscus and species of the Caricion davallianae, 
petrifying  springs  with  tufa  formation  (Cratoneurion)  and 
alkaline fens. 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs%2C+mires+%26+fens&country=GR&region=. 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/main-pressures-and-threats-article-17-national-
summary-dashboards-archived. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

(56) 

(57) 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 

Accompanying 

base: 

the 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  was  the  country  most  affected  by  wildfires  in 
2023,  with  136 499 ha  burnt,  the  highest  amount 
recorded  since  2007.  Greece  experienced  the  largest 
single wildfire recorded in the EU since 2000 near the city 
of Alexandroupolis, in the East Macedonia, Thrace (58). 

The  EU  Timber  Regulation  (EUTR) (59)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (60)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(61).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR.  

force 

into 

Greece has not  implemented the obligations set  out  in 
Article 14(1)  and  (2)  of  the  EUDR  to  ‘designate  one  or 
more competent authorities responsible for fulfilling the 
obligations arising from [this] Regulation’ and inform the 
Commission thereof at the latest by 30 December 2023. 
This date remains unchanged, and no additional time is 
expected  to  be  granted,  as  it  is  a  key  element  of 
preparation for the smooth application of the EUDR. 

2025 priority action 

•  Designate  the  competent  authority  responsible  for 
fulfilling the obligations arising from the EUDR and 
inform the Commission of the names, addresses and 
contact details of said competent authority.on51 

Marine ecosystems 

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

(58) 

(59) 

(60) 

San-Miguel-Ayanz, J., Durrant, T., Boca, R.  et al., Forest fires in 
Europe, Middle East and North Africa 2023, Publications Office 
of the European Union, Luxembourg, 2023. 
Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(61)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 

Greece  22 

developed and implemented over six-year cycles. 

Since  the  2022  Environmental  Implementation  Review 
(EIR)  report,  no  additional  data  regarding  Member 
States’  set  of  GES  characteristics  for  each  descriptor  in 
the MSFD have become available. Nevertheless, Member 
States have to report updates by  15 October 2024, and 
these will be assessed by the Commission. In the context 
of this next round of reporting, in accordance with the 
MSFD  and  the  Commission  GES  decision (62),  Member 
States  must 
include  as  part  of  their  set  of  GES 
characteristics any threshold values for the descriptors in 
the MSFD that may have been established in cooperation 
with other Member States at the EU or regional level (63). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (64). At 
that time, their updates on the elements, features and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
levels  of 
work 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. 

However,  Greece  reported  its  programme  of  measures 
with too much delay to be included in the Commission’s 
general assessment  of the  programmes of  measures of 
the Member States. 

2025 priority action 

•  Report its updates on the state of its marine waters, 
its  targets and  its  determinations  of  GES (65)  which 
are expected to include any threshold values for the 
descriptors  in  the  MSFD  that  may  have  been 

(62) 

(63) 

(64) 

(65) 

Commission  Decision  (EU) 2017/848  of  17 May  2017  laying 
down  criteria  and  methodological  standards  on  good 
environmental  status  of  marine  waters  and  specifications  and 
standardised  methods  for  monitoring  and  assessment,  and 
repealing  Decision 2010/477/EU  (OJ  L 125,  18.5.2017,  p. 43), 
http://data.europa.eu/eli/dec/2017/848/oj. 
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
Strategy  Framework  Directive  (Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), http://data.europa.eu/eli/C/2024/2078/oj. 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 
In accordance with Article 17 of Directive 2008/56/EC. 

2025 Environmental Implementation Review – Greece 

 
 
established  in  cooperation  with  other  Member 
States at the EU or regional level. 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (66). 

The third update of the Union list (67) entered into force 
on 2 August 2022. The fourth update is in preparation. 

Meanwhile,  the  action  plan  has  been  issued  for  the 
introduction routes of spatial alien species in Greece (68), 
which  concerns  the  treatment  of  the  introduction  of 
alien  species  of  interest  at  the  most  common  entry 
points.  It  does  not  concern  the  management  of  items 
that  have  already  entered  into  the  country.  For  this 
purpose, management plans will be drawn up per species 
or  group  of  species.  A  related  joint  ministerial  decision 
was issued in 2021 on 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  introduction  and 
spread  of  IAS.  Several  studies  have  been  conducted,  in 
particular on marine species. 

The IAS Regulation (69) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

(66) 

(67) 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 

(68)  Governmental Gazette 4144/B΄/23-6-2023. 
(69) 

Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 

Greece  23 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (70).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (71),  and  at 
USD 423 billion annually at the global level (72). 

The total number of IAS of Union concern in the country 
is 25. This includes 7 species recorded in the previous EIR 
(2021)  and  18  additions.  Of  these  additions,  13  were 
already  on  the  Union  concern  list  in  2021,  and  5  were 
added later under Commission Implementing Regulation 
(EU) 2022/1203 (73). 

Figure 14:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Greece, 2024 

management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

(70)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(72) 

(Intergovernmental 

(71)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 
Recently, the basis for an action plan on the management of the 
IAS that is most widely dangerous in many aspects, Lagocephalus 
sceleratus, was established in a comprehensive study. 

on 
Science-Policy 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

Ecosystem 

and 

(73) 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece fulfilled the priority action for 2022 to step up the 
implementation of the IAS Regulation. 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

Similarly, target 14 of the GBF (74) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (75). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (76)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

increasing  number  of  platforms,  networks  and 
An 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (77). These platforms and communities are key 

Greece  24 

tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

There is still no Greek business and biodiversity network 
member of the EU Business & Biodiversity Platform. 

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 woodlands and forests, are 
being developed and are expected to be published soon. 
Regarding  accounts 
services,  a 
methodological framework is being designed for physical 
as  well  as  for  monetary  accounting  of  water-related 
ecosystem services (i.e. water regulation). 

for  ecosystem 

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

The  main  obstacles  for  implementing  the  ecosystem 
accounting  framework  of  the  system  of  environmental 
economic accounting in Greece are the lack of capacity 
and  expertise  of  the  stakeholders  and  state  agencies 
involved, and data gaps. Knowledge sharing among  the 
‘Mapping  and  assessment  for  integrated  ecosystem 
accounting’  project  partners  should  address  these 
shortcomings  and  provide  guidance  through  each 
country’s pilot accounts. 

(74)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
framework 
biodiversity 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 

Assessment – 

Summary 

(75) 

for 

(76) 

(77) 

final 

Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy.  

11 July 

2022, 

of 

2025 Environmental Implementation Review – Greece 

 
 
 
 
Greece  25 

3. Zero pollution 

methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide (SO2), ammonia (NH3) and PM2.5. According to the 
latest  projections  submitted  under  Article 10(2)  of  the 
NECD, Greece is projected to meet its emission reduction 
commitments  for  2030  onwards  for  NOx,  NMVOC,  SO2, 
NH3 and PM2.5. 

Greece  submitted  its  first  national  air  pollution  control 
programme  (NAPCP)  to  the  Commission  on  26 January 
2021. 

Figure 15:  Emission  trends  of  main  pollutants /  GDP  in 
Greece (%), 2005–2022 

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
https://www.eea.europa.eu/en/topics/in-depth/air-
25 June 
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

Clean air 

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
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 suite of air quality 
policies (78).  These  set  health-based  EU  air  quality 
standards (79)  and  stipulate  Member  States’  national 
emission  reduction  commitments (80)  for  several  air 
pollutants. 

The  air  quality  in  Greece  continues  to  give  cause  for 
concern in some parts of the territory. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (81) for Greece attribute 10 700 deaths each year (or 
93 800 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (82),  2 200  deaths  each  year  (or  19 500 YLL)  to 
nitrogen dioxide (NO2) (83) and 2 300 deaths each year (or 
19 900 YLL) to ozone (84). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Greece since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (85)  in  2024, 
Greece has  met  its emission reduction commitments for 
2020–2029 for air pollutants  nitrogen oxides (NOx), non-

(78) 

(79) 

(80) 

(81) 

(82) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(83)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(84) 

(85)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Greece 

 
 
 
Figure 16: PM2.5 and NOx emissions  by  sector in Greece 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
15,45%

14,77%

NOₓ

2,57%

51,35%

46,46%

3,56%

13,64%

8,54%

3,67%

6,02%

26,15%

7,83%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (86) were registered 
for NO2 in two air quality zones (87), for PM10 in three air 
quality zones (88) and for PM2.5 in one air quality zone (89) 
in  Greece.  Furthermore,  the  target  values  for  ozone 
concentrations  have  not  been  met  in  several  air  quality 
zones, as well as the target value for benzo(a)pyrene (BaP) 
concentration in one air quality zone (90). 

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 covering all 
Member  States  concerned,  including  Greece.  The  CJEU 
delivered  two  judgments  in  2023  confirming  the  non-
compliance  of  Greece  with  Directive  2008/50/EC,  on 
exceedances of PM10 limit values in Thessaloniki (C-70/21) 

(86)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

Greece  26 

and  on  exceedances  of  NO2  limit  values  in  Athens  (C-
633/21). The aim is for appropriate measures to be put in 
place to bring all air quality zones into compliance with the 
directive. 

Greece has not yet ratified the Heavy Metals Protocol and 
the  Persistent  Organic  Pollutants  Protocol  to  the  Air 
Convention of the United Nations Economic Commission 
for Europe. 

In the 2022 EIR, Greece received three priority actions. The 
first priority action was to further reduce emissions in the 
context  of  the  NAPCP.  Greece  has  made  substantial 
progress on this, as the latest reported data show that the 
2020–2029  emission  reduction  commitments  have  been 
met  and  that  the  emission  reduction  commitments  for 
2030  onwards  are  projected  to  be  reached.  The  second 
priority action was to ensure full compliance with EU air 
quality  standards  and  maintain  downward  emission 
trends. Based on the latest data, Greece has made some 
progress in this regard. However, exceedances above limit 
values  and  target  values  remain  for  NO2,  PM10,  PM2.5, 
ozone and BaP, which require further action. Since 2019, 
downward  emission  trends  have  been  reported  for  all 
main pollutants, except for PM2.5, which requires further 
action. The third priority action received by Greece was to 
ratify  the  amended  Gothenburg  Protocol,  the  Heavy 
Metals  Protocol  and  the  Persistent  Organic  Pollutants 
Protocol.  Substantial  progress  has  been  made,  as  the 
Gothenburg  Protocol  has  been  ratified,  but  the  Heavy 
Metals  Protocol  and  the  Persistent  Organic  Pollutants 
Protocol remain unratified by Greece. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

•  Accelerate  the  ratification  of  relevant  international 

conventions and protocols. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve  energy  and  resource  efficiency,  including 

Agglomeration Athens and agglomeration Thessaloniki. 

(87) 
(88)  North  Greece,  agglomeration  Athens  and  agglomeration 

Thessaloniki. 

(89)  North Greece. 
(90) 

EEA, Eionet Central Data Repository (). 

2025 Environmental Implementation Review – Greece 

 
 
 
water; 

(iv) contribute to decarbonisation. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (91). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (92). 

In Greece, around 390 industrial installations are required 
to have a  permit based on the IED, with the majority of 
them  being  in  the  waste  management  sector,  including 
landfills  (29 %),  followed  by  the  intensive  rearing  of 
poultry and pigs (16 %), the energy sector (10 %) and the 
food and drink sector (10 %). 

Figure 17  shows  the  damage  to  health  and 
the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions ‘intensity’. Greece has 
relatively  high  damage  (the  11th  highest  damage  in  the 
EU) and it is above the EU average of EUR 27.5/EUR 1 000 
GVA  in  emissions  intensity  (5th  highest  intensity  in  the 
EU). The main industrial contributor to emissions to air (93) 
is the energy sector (including refineries and gasification). 

Figure 17:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

Greece  27 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

NB:  Cd,  cadmium;  Hg, mercury;  Ni,  nickel;  Pb,  lead;  TOC,  total  organic 
carbon; total N, total nitrogen; total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Greece  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as  the 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity  (expressed  in  GVA).  Greece  has  the  11th  lowest 
emissions of heavy metals to water and is in 16th position 
for  emissions  intensity  (with  the  EU  average  intensity 
being 0.864 kg/EUR 1 billion GVA). As shown in Figure 20, 
the main industrial contributors to emissions to water in 
Greece  are  the  energy  sector  (including  refineries)  in 
general and livestock rearing for emissions of nitrogen and 
phosphorus. 

(91)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 
emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 

(92) 

(93) 

European 

Emissions 

EEA, 
Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 
European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
Figure 19:  Industrial  releases  and  intensity  of  heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 20:  Relative  releases  to  water  from  industry  in 
Greece (%), 2022 

100%

75%

50%

25%

0%

Heavy
Metals
Ecotoxicity

Heavy
Metals
Human
Toxicity

Total
nitrogen

Total
organic
carbon
(TOC)

Total
phosphorus

Refineries
Electricity and heat production

Livestock
Chemicals

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
(NGOs),  alongside 
non-governmental  organisations 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
revised  directive, 
that  worst 
the  provisions 
infringements can be sanctioned by fines of at least 3% of 

set 

Greece  28 

the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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 reductions in pollution. 

In the 2019 and 2022 EIRs, Greece received priority actions 
to  review  permits  and  to  strengthen  control  and 
enforcement  in  line  with  the  BAT  conclusions  and  to 
address pollution in power sector installations. There is no 
data  available  to  assess  progress  towards  these  priority 
actions. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i)  control  major-accident  hazards  involving  dangerous 

(ii) 

substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (94). 

(94)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 

repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (95)  and  the  report  by 
Greece on the implementation of the Seveso III Directive 
for 2019–2022 (96). 

In 2024, of the 220 Seveso establishments in Greece, 139 
were categorised as lower-tier establishments and  81 as 
upper-tier establishments (UTEs), based on the quantity of 
hazardous  substances  likely  to  be  present.  UTEs  are 
subject  to  more  stringent  requirements.  The  number  of 
Seveso  establishments  for  various  years  is  presented  in 
Figure 21. 

Figure 21: Number of Seveso  establishments  in Greece, 
2018, 2022 and 2024 

250

200

150

100

50

0

134

76

2018

139

139

81

2022

UTE

LTE

81

2024

NB: LTE, lower-tier establishment. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are essential to allow 
proper  preparation  and  effective  implementation  of  the 
necessary  actions  to  protect  the  environment  and  the 
population should a major industrial accident occur. 

According  to  the  Greek  authorities,  in  2022  an  EEP  was 
required for all 81 UTEs. In addition, 47 of them had an EEP 
and 26 EEPs had been tested over the last three years. The 
summary is shown in Figure 22. 

Greece  29 

Figure 22: Situation regarding EEPs in Greece, 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Greece  did  not  report  on  the  number  of  Seveso 
establishments  for  which  information  for  the  public 
referred  to  in  Annex V  to  the  Seveso III  Directive  is 
permanently available, but indicated that this information 
can be provided at the prefectoral level. This is important, 
as  awareness  by  the  public  of  this  information  may 
ameliorate  the  consequences  of  a  major 
industrial 
accident. 

Figure 23: Share of UTEs for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

100%

80%

60%

40%

20%

0%

AT BG CZ DK EL FI HR IE LT LV NL PT SE SK

NB: No data available for Greece. 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-

2022, 

(95) 

; data extracted in September 2024. 

(96) 

As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
Greece  30 

releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

In 2019, 43 % of dental treatments were still using dental 
amalgam,  which  represented  a  challenge  for  Greece  to 
phase out its use by 1 January 2025. However, measures 
should  have  been  put  in  place  to  ensure  a  socially  and 
economically  sound  phase-out,  including  an  adequate 
reimbursement  of  the  alternatives  to  dental  amalgam 
through the health insurance scheme and the training of 
dental  practitioners.  The  Commission 
is  monitoring 
whether the phase-out  has taken place under the terms 
and conditions of the regulation. Greece will also need to 
ensure  that  the  manufacture  and  export  of  mercury-
containing lamps are prohibited by the deadlines set out 
in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (97) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health-related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (98). 

In  Greece,  environmental  noise  is  estimated  to  cause  at 
ischaemic  heart  disease 
least  around  170  cases  of 

en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in Figure 23. No data  were available for Greece as it has 
not reported information on that issue. This provision on 
knowledge  is  an  important  provision  of  the  Seveso III 
Directive, as awareness by the public of this information 
may  ameliorate  the  consequences  of  a  major  industrial 
accident. 

In 2022, Greece was given a priority action to strengthen 
control  and  enforcement  to  ensure  compliance  with 
Seveso III  Directive  provisions,  especially  on  information 
to the public and on EEPs. 

Data reported on the implementation of the directive for 
2019–2022  do  not  show  substantial  progress  in  the 
numbers  of  EEPs  established  and  tested  for  UTEs  in 
Greece. 

2025 priority actions 
• 

Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs, in particular  as regards reviewing, testing and 
updating  EEPs,  at  intervals  of  no  longer  than  three 
years. 
Ensure  access  to  transparent  and  clear  information 
towards citizens on risks and behaviour in the event 
of accidents. 
Ensure full and correct transposition of the Seveso III 
Directive. 
Improve 
Seveso III Directive. 

implementation  of 

reporting  on 

the 

• 

• 

• 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 

(97)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 

noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(98)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 

2025 Environmental Implementation Review – Greece 

 
 
annually (99)  and  some  42 500  people  to  suffer  from 
disturbed sleep(100). 

Based  on  the  latest  set  of  information  analysed,  Greece 
has not  completed its noise mapping of agglomerations, 
roads, railways and airports. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

Since  Greece  failed  to  report  to  the  Commission  all 
relevant 
information  on  the  strategic  noise  maps, 
including  the  noise  exposure  of  the  population,  the 
European  Commission  decided  to  open  an  infringement 
procedure  against  Greece,  in  addition  to  an  ongoing 
infringement  procedure  related  to  the  failure  to  adopt 
noise action plans. 

Greece  received  two  priority  actions  in  the  2022  EIR 
regarding the need to complete noise mapping and noise 
action  plans.  There  has  been  no  progress  on  the  first 
priority action on noise mapping, as detailed above. Given 
that reporting under the most recent reporting cycle for 
noise action plans was due in early 2025, these have not 
been  assessed.  Therefore, 
is 
maintained for the 2025 EIR. 

this  priority  action 

Therefore, both priority actions are repeated for the 2025 
EIR. 

2025 priority actions 

•  Complete noise mapping. 
•  Complete  and  implement  action  plans  on  noise 

management. 

(99) 

These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
2018, 
No 2018/10, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise. 

Bilthoven, 

(100)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2. 

(101)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32000L0060. 

(102)  https://environment.ec.europa.eu/topics/water_en. 

Greece  31 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens and the 
environment 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 

Directive 
form 

The Water Framework Directive (101) is the cornerstone of 
EU  water  policy  in  the  21st  century (102).  The  Water 
other  water-related 
Framework 
and 
directives (103) 
the  basis  of  sustainable  and 
integrated  water  management  in  the  EU.  They  aim  to 
achieve  a  high  level  of  protection  of  water  resources, 
prevention  of  further  deterioration  and  restoration  to 
good status. These objectives are very important for the 
EU’s  competitiveness,  strategic  autonomy  and  security, 
yet  have  become  even  more  challenging  in  the  face  of 
climate change affecting our precious water resources. 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 

(103)  These 

the 

Floods 

include 

the  Groundwater  Directive 

(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
the 
(https://eur-
new 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

Nitrates 
(https://eur-lex.europa.eu/legal-
MSFD 

Drinking  Water 

Treatment 

Directive 

and 

IED 

the 

the 

the 

the 

2025 Environmental Implementation Review – Greece 

 
 
  
Greece  32 

countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025 (104). 

Greece  is  facing  water  scarcity,  as  evidenced  by  the 
Seasonal Water Exploitation Index +105. In 2022, this index 
reaches  33.6  %  which  is  much  above  the  20%  generally 
considered as a sign of scarcity in the third quarter of the 
year. Above 40%, it would be a sign of severe scarcity. This 
seasonal  index  at  national  level  does  not  reflect  the 
situation  at  river  basin  level106  where  more  acute  water 
stress can be recorded. 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and  risk  maps  (FHRMs)  and  the  preliminary  flood  risk 
assessments  drawn  up  during  the  second  cycle  (2016–
2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

Greece did not submit the third RBMPs and second FRMPs 
by March 2022, as required under the Water Framework 
Directive  and  the  Floods  Directive.  The  Commission 
opened  an  infringement  procedure  for  late  reporting. 
Greece was referred to  the  CJEU in March 2024. Greece 
finally reported all its third RBMPs by June 2024. However, 
the second FRMPs are being compiled and are expected to 
be reported shortly (107). As a result of this late and, in the 
case  of  the  FRMPs,  still  lacking  reporting  as  of  mid 
December  2024,  the  Commission  has  not  been  in  a 
position to assess the plans and include such assessment 

in  its  report  to  the  European  Parliament  and  to  the 
Council (108). 

As a consequence, the EIR report cannot be updated for 
Greece  and  reference  is  made  to  the  2022  EIR  for  an 
overview of the main issues (109). 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (110), (ii) a methodology for measuring microplastics 
in drinking water (111) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (112). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019. 

The  quality  of  drinking  water  (supplied  by  large  water 
suppliers)  in  Greece  does  not  give  rise  to  concern (113). 
From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 
per- and polyfluoroalkyl substance monitoring data in the 
future. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 

(104)     ENV - Bibliothèque 
(105)   https://www.eea.europa.eu/en/analysis/indicators/use-of-

freshwater-resources-in-europe-1.  

(106)   https://www.eea.europa.eu/en/analysis/maps-and-

charts/percentage-of-seasons-with-water-stress.  

(107)  The second flood hazard and risk maps have been completed since 
November  2023  and  significant  progress  has  been  made  in  the 
compilation  of  FRMPs.  Their 
imminent 
(https://floods.ypeka.gr/consultation/2round-consultation/). 
[A link to this report will be added once it is published.] 

(108) 
(109)  https://environment.ec.europa.eu/law-and-

submission 

is 

governance/environmental-implementation-review_en#country-
reports. 

(110)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(111)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 

(113) 

(112)  OJ L, 

2024/369, 

measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
23.4.2024, 
2024/370, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary,  the  compliance  for  all  parameter  groups in Greece 
was at least 98.50 % in 2017, 98.24 % in 2018 and 98.34 % in 2019. 

2025 Environmental Implementation Review – Greece 

 
 
Greece  33 

groundwater /  surface  waters  that  is  affecting  these 
waters’ good status and as one of the main factors in not 
meeting the WFD objectives. 

is 

to  provide  proper  guidance  on 

Since  2021,  the  updated  Code  of  Good  Agricultural 
Practice  for  the  Protection  of  Waters  from  Nitrate 
Pollution  of  Agricultural  Origin  has  been  in  force.  Its 
purpose 
the 
implementation of good agricultural practices to all those 
involved in agricultural and livestock activities to protect 
the  environment,  with  the  aim  being  to  prevent 
groundwater and surface waters being polluted by nitrate 
ions. 

In  2022,  Greece  received  a  priority  action  on  tackling 
nutrient  pollution,  especially  nitrates  from  agriculture, 
through  the  implementation  of  the  Nitrates  Directive. 
Since  the  report  on  the  implementation  of  the  Nitrates 
Directive  covering  2020–2023  will  become  available  in 
2025, the 2022 EIR priority action cannot be assessed and 
is repeated. 

2025 priority action 

•  Tackle  nutrients  pollution,  especially  nitrates  from 
implementation  of  the 

agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Overall, in Greece, the compliance rate was 98 % in 2020. 
However,  31  agglomerations,  generating  235 480 
population  equivalent  of  urban  waste  water,  did  not 
comply with the requirements of the directive. 

promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 24  shows  that  in  2023,  out  of  the  1 731  Greek 
bathing waters, 1 659 (95.8 %) were of excellent quality, 
17 (1 %) bathing waters were of good quality and 4 (0.2 %) 
bathing  waters  were  of  sufficient  quality.  No  bathing 
waters  were  found  to  be  of  poor  quality.  However,  51 
(2.9 %)  bathing  waters  were  not  classified.  Detailed 
information on Greek bathing waters is available from the 
national portal (114) and through an interactive map viewer 
of the EEA (115). 

Figure 24:  Bathing  water  quality  per  Member  State, 
Albania and Switzerland (%), 2023. 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (116)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the Nitrates Directive (117), dating back to 2021, warns that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a problem in many parts of the EU. 

The  analysis  of  Greece’s  RBMPs  has  identified  nutrients 
important  pressure  on 
from  agriculture  as  an 

(114)  http://www.bathingwaterprofiles.gr/en. 
(115)  EEA, 

‘State  of  bathing  water’,  EEA  website,  2024, 

https://www.eea.europa.eu/en/topics/in-depth/bathing-
water/state-of-bathing-water. 

(116)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(117)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

2025 Environmental Implementation Review – Greece 

 
 
 
Figure 25:  Proportion  of  urban  waste  water  that  fully 
complies with the UWWTD (%), 2020 

Source:  12th  technical  assessment  of  UWWTD 
Publications Office of the EU 

implementation  - 

Three infringement proceedings, each at a very advanced 
stage,  are  open  against  Greece  for  non-compliance  with 
the  requirements  of  the  directive.  For  two  of  these 
in  eastern 
infringement  procedures  (agglomerations 
Attica  and  Thriasio  Pedio),  judgments  of  the  CJEU  have 
been delivered and Greece will continue to pay fines (to 
date, EUR 69 million for the first case and EUR 17 million 
for  the  second  one)  until  it  complies  with  these  CJEU 
judgments (118). Additionally, Greece was referred to the 
CJEU in July 2024 as part of the third ongoing infringement 
procedure,  concerning  153  agglomerations (119).  In  all 
these  cases,  Greece  must  ensure  that  the  urban  waste 
water  of  the  concerned  agglomerations  is  collected  and 
treated appropriately. It is essential that Greece takes the 
necessary measures to fully comply with the requirements 
of the directive. The continuous non-compliance with the 
rulings of the CJEU is an indication of systemic weaknesses 
in the Member State’s administrative system. 

This  is  all  the  more  important  as  the  directive  has  been 
revised  in  order  to,  among  other  things,  strengthen 
existing  treatment  standards and  establish  an  additional 
treatment of micropollutants in urban waste water. Other 

Greece  34 

new  requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  EPR  system  to 
ensure sustainable financing of micropollutant treatment 
by  the  most  polluting  industries  and  ensuring  access  to 
sanitation,  especially  for  vulnerable  and  marginalised 
groups.  Greece  has  until  31 July  2027  to  transpose  the 
new directive into its national legal system. 

The 2019 and 2022 EIRs for Greece included three priority 
actions on water management. Considering that progress 
has been limited, the following action is recommended. 

2025 priority action 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  urban  wastewater 
treatment  directive,  taking  into  account  the  new 
requirements of the recast directive. 

to  ensure 

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 (120), 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (121)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 

(118) 

Judgment  of  22 February  2018,  Commission  v  Greece, C-328/16, 
EU:C:2018:98;  Judgment  of  15 October  2015,  Commission  v 
Greece, C-167/14, EU:C:2015:684. 
(119) 
INFR(2020)2021. 
(120)  Communication 

the  Commission 

to 

from 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(121)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
No 1907/2006 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 

p. 1), 

2025 Environmental Implementation Review – Greece 

 
 
 
of 

and 

enforcement 

assessed  the  Member  States’  reports  (122)  on  the 
implementation 
these 
regulations (123).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies 
and (ii) more non-compliant products are being placed on 
the EU market. 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (124) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (125). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (126).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (127).  The 
Commission  is  working  on  the  delegated  acts  to  include 

(122)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
2020, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(123) 

the 

European 

Luxembourg, 

(124)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(125)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC, siloxanes (D4, D5, D6) and, finally, microplastics. 
(126)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(127)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

Greece  35 

these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Responsibility  for  checking  compliance  with  the  REACH 
following 
Regulation 
authorities (128): 

in  Greece 

lies  with 

the 

• 

Independent  Authority 
(Directorate-General), 

for 

Public 

Revenue 

•  General  Chemical  State  Laboratory  (Directorate  of 

Energy, Industrial and Chemical Products), 
all the regional chemical services. 

• 

Greece has fully implemented enforcement strategies for 
both the REACH and CLP Regulation (129). 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  country-specific  data  on  enforcement 
since 2022. 

In 2022, 70 staff members were allocated to REACH and 
CLP Regulation enforcement in Greece (130). Almost 2 000 
REACH checks were carried out in the previous reporting 
period (2019). 

In  2020,  Greece  participated 
in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (131).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

(128)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 68, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(129)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(130)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 74, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(131)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
and 
p. 20, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Greece 

 
 
Figure 26: Compliance of imported products – results of 
the REF-8 project (%) 

Figure 27:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

Greece  36 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliances.  Therefore,  the  non-compliance  rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

Greece’s  participation 
enforcement project was around the EU average. 

the  REF-8 

in 

coordinated 

In  2022,  Greece  received  a  priority  action  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance. In the absence of reporting 
since 2022, no progress has been shown and this priority 
action  remains  valid  in  2025,  partly  because  of  the 
experience with the REF-8 project. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement towards a policy of 
zero tolerance for non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
European  Chemicals  Agency, 
the 
in 
coordinated enforcement projects, called REFs. 
Increase  customs  controls  and  controls  of  products 
sold online with regard to compliance with chemicals 
legislations.  

including 

• 

• 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  37 

4. Climate action 

strengthening  and  expanding  the  EU  emissions 
trading  system  (ETS),  with  the  creation  of  a  new, 
second,  ETS  for  transport  and  buildings  together 
with a dedicated Social Climate Fund to help citizens 
during the transition; (ii) increasing targets under the 
effort  sharing  regulation;  and 
(iii)  a  revised 
regulation  for  Land  Use,  Land  Use  Change  and 
Forestry (133).  The  package  has  been  fully  adopted, 
and the Member States have been implementing the 
legislation. 

The  key  strategic  document  at  country  level  is  the 
National  Energy  and  Climate  Plan  (NECP) (134). 
Greece  submitted  its  updated  plan  in  December 
2024 after the deadline set by the Regulation on the 
Governance  of  the  Energy  Union  and  Climate 
Action135.  The  European  Commission  assessed  the 
plan  and  the  extent  to  which  Greece  has  followed 
the  recommendations  for  the  draft  version.  The 
findings from the assessment are: 

• 

the  Effort  Sharing 
Emissions  under 
Regulation  will  decrease  by  43%  in  2030 
compared  to  2005;  Greece  will  meet  its 
target of 23%. 

•  Greece is in line with its LULUCF target and 
target for the share of renewable energy.  
There  are  still  gaps  in  energy  efficiency 
targets that must be closed. 

• 

To  minimise  the  impacts  of  climate  policies  on 
vulnerable  people  and  sectors,  Greece  is  using  the 
Just  Transition  Fund,  Modernisation  Fund  and  will 
use  Social  Climate  Fund  from  2026.  (for  more 
information, see Chapter 5 on Finance). 

its  determination 

The  impacts  of  climate  change  have  continued  to 
increase  in  recent  years,  inflicting  damage  and 
suffering in the EU and around the world. Globally, 
2023 was the hottest year on record, while Europe 
has  been  warming  twice  as  quickly  as  the  global 
average, and is now the fastest-warming continent. 
The  frequency  and  severity  of  extreme  climate 
events are also increasing. Against this backdrop, the 
EU  has  demonstrated 
to 
implement the European Green Deal and to become 
climate  neutral  and  resilient  by  2050,  ensuring 
sustainable  competitiveness  and  supporting  EU 
industry  in  the  net-zero  transition.  The  European 
Climate  Law  is  the  EU’s  response  to  the  need  for 
action.  It  sets  the  objective  of  achieving  climate 
neutrality  by  2050  and  a  midterm  target  of  a 
reduction in GHG emissions of at least 55 % by 2030, 
and  outlines  the  adaptation  efforts  necessary  to 
adjust  to  climate  change’s  present  and  future 
impacts. Almost all the ‘Fit for 55’ proposals set out 
in the European Green Deal have been agreed in law, 
and the European Commission recommended a new 
intermediate  climate  target  of  a  90 %  reduction  in 
emissions  by  2040.  In  2024,  the  Member  States 
submitted  updated  national  energy  and  climate 
plans  for  2021–2030,  reflecting  the 
increased 
ambition of the revised EU legislation. In 2024, the 
European Commission also released, jointly with the 
risk 
EEA, 
assessment. 

first-ever  European 

climate 

the 

Over the last three decades, since 1990, the EU has 
achieved steady decreases in its emissions, reaching 
a  running  total  in  2022  of  – 32.5 % (132).  However, 
the EU and its Member States need to step up their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 
55 %  reduction  in  net  GHG  emissions  by  2030  and 
climate neutrality by 2050. Between 1990 and 2022, 
net  GHG  emissions  of  Greece  decreased  by  28%, 
making  it  one  of  the  countries  with  below-average 
decrease. 

The ‘Fit for 55’ legislative package reflects the need 
to  speed  up  the  green  transition.  It  includes  (i) 

(132)  EU net domestic emissions, including the land use, land-use 
change  and  forestry  (LULUCF)  sector  and  excluding 
international aviation. 

(133)  A full overview of the Fit for 55 package is available at 

https://commission.europa.eu/strategy-and-
policy/priorities-2019-2024/european-green-

deal/delivering-european-green-deal/fit-55-delivering-
proposals_en. 

(134)  More information about NECP is on the dedicated website 

https://energy.ec.europa.eu/topics/energy-
strategy/national-energy-and-climate-plans-necps_en. 

(135)    Article 14 of regulation 2018/1999 on the Governance of 

the Energy Union and Climate Action 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
Figure 28:  Total  GHG  emissions 
international aviation) (%), 1990–2022 

(excluding 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG 
emissions cost-effectively across all Member States. 
It  is  the  world’s  biggest  carbon  market,  covering 
around  40%  of  the  EU’s  total  GHG  emissions  from 
electricity  and  heat  generation,  the  manufacturing 
industry,  aviation  within  Europe (136)  and,  from 
2024, maritime transport also. 

The system sets a limit or cap on the total amount of 
GHGs that can be emitted at the EU level. Within this 
limit,  companies  buy  emissions  allowances  (one 
allowance  gives  the  right  to  emit  1 t  of  CO2  eq 
(carbon dioxide equivalent)), in auctions or through 
trading allowances with others. The cap is reduced 
annually  to  ensure  that  overall  emissions  in  the 
sectors covered decrease over time. 

The emissions under the ETS decreased by 64% from 
2005 to 2023. 

It is mainly due to the latest development. In Greece, 
GHG emissions covered by the EU emissions trading 
system (ETS) have been on a strong downward trend 
since  2019  and  have  reduced  by  57 %  since  2013, 
mostly  thanks  to  the  power  generation  sector. 
Emissions  decreased  between  2013  and  2022. 
However,  in  the  industry  sectors,  GHG  emissions 
have  only  decreased  by  14 %  since  2019,  after 
having  risen  by  12 %  between  2013  and  2019.  In 
2023,  Greece’s  ETS  installations  emitted  37 %  less 
GHG  than  in  2019  altogether.  In  2023,  45 %  of 
from  power 
Greece’s  ETS  emissions  came 
generation. Of the total emissions from all industry 

Greece  38 

sectors, cement and lime production accounted for 
36 %, refineries for 42 %, other industries for 19 %, 
and chemicals and the metals industry for up to 2 % 
each. 

From 2027, a new emissions trading system, called 
ETS  2,  for  buildings,  road  transport  and  additional 
sectors (mainly industry not covered by the current 
ETS)  will  become  fully  operational (137).  Member 
States should have notified full transposition of the 
provisions of the revised EU ETS directive related to 
the  new  ETS  2  into  national  law  by  30 June  2024. 
Greece did not communicate full transposition into 
national  law  by  this  deadline.  The  Commission 
therefore  opened  an 
infringement  procedure 
against Greece on 25 July 2024, by sending a letter 
of  formal  notice  for  failing  to  fully  transpose  the 
provisions into national law. 

Greece  has  since  notified  transposition  of  the 
relevant  provisions  of  the  ETS  2  Directive  to  the 
reporting 
Commission.  The  monitoring  and 
requirements and the obligation to hold a permit to 
carry  out  activities  under  ETS  2  will  commence  on 
1 January 2025. 

infringement 
The  Commission  also  opened 
procedures  against  Greece  on  25 January  2024,  by 
sending a  letter of  formal notice for failing to fully 
transpose 
ETS 
Directive (138)  into  national  law.  Greece  has  since 
notified  full  transpositions  of  the  abovementioned 
directives to the Commission. 

revisions 

previous 

the 

of 

Effort sharing 

The Effort Sharing Regulation (ESR) (139) covers GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture, 
small  industry  and  waste.  Emissions  from  these 
sectors  account  for  around  60 %  of  the  EU’s 
domestic emissions. The regulation sets the EU-wide 
target  to  reduce  emissions  from  the  effort  sharing 
sectors  by  40 %  by  2030  compared  to  2005  levels. 
This  overall  target  for  the  EU  translates  to  binding 
national  emission  reduction  targets 
for  each 
Member State. The target of Greece is – 22.7 %. 

In addition to the 2030 targets, Member States have 
annual  GHG  emissions 
limits  (annual  emission 
allocations), reducing every year until 2030. 

(136)  Flights between the EU Member States including 

(138)  Directive  -  2023/959  -  EN  -  EUR-Lex  and  Directive  - 

departing flights to Norway, Iceland, Switzerland and the 
United Kingdom. 

(137)  Directive (EU) 2023/959 (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.
ENG). 

2023/958 - EN - EUR-Lex. 

(139)  Regulation (EU) 2018/842 (https://eur-
lex.europa.eu/eli/reg/2018/842). 

2025 Environmental Implementation Review – Greece 

 
 
 
There  is  some  flexibility  to  take  account  of  annual 
fluctuations in emissions, by trading emissions and 
transfers from the ETS and LULUCF. 

Based on historical emissions and the most updated 
projections,  Greece  is  on  track  to  achieve  its  2030 
ESR target. Projected emissions are 23.3 percentage 
points above its 2030 target. 

The  largest  contributor  is  the  domestic  transport 
sector, which accounted for 38 % of all effort sharing 
emissions in 2022. Sustainable transport has yet to 
take off in Greece.  Road transport  is the dominant 
mode in  Greece.  Trains provide only  3 % of  freight 
transport and 0.6 % of passenger transport, which is 
way below EU average of 16 % and 6 %, respectively. 
Only 0.1 % of car fleet were battery electric vehicles 
in  2023  (EU  average  is  1.2 %).  On  the  other  hand, 
Greece has about 3 200 publicly accessible charging 
points,  or  1  for  every  6  e-vehicles  (above  the  EU 
average of 1:10). 

The  buildings  sector  is  a  significant  concern  for 
Greece  as  well.  As  per  its  most  recent  long  term 
intends  to  reduce 
renovation  strategy,  Greece 
building  energy  consumption  by  8 % 
in  2030 
compared  to  2015.  However,  between  2015  and 
2022,  final  energy  consumption  in  the  residential 
sector declined only by 1 %. Emissions of the sector 
have not changed in the same period. 

Figure 29:  Effort-sharing  emissions  by  sector  (%), 
2022 

Greece  39 

Land use, land-use change and forestry 

The  Land  Use,  Land-Used  Change  and  Forestry 
(LULUCF) sector plays a significant role in achieving 
the EU’s climate neutrality goal. In the EU, this sector 
absorbs  more  GHGs  than 
it  emits,  removing 
significant volumes of carbon from the atmosphere. 
Thus, it is the only sector with negative emissions. 

Greece’s  LULUCF  sector  has  had  approximately 
constant net removals since 2015. 

Greece’s target in 2030 is to enhance land removals 
by additional – 1.2 Mt of CO2 equivalent compared 
to the yearly average of the period 2016–2018. The 
latest available projections show a gap to the 2030 
target  of  −1.2  Mt  of  CO2  equivalent.  Therefore, 
Greece is on track to meet this target. 

Adaptation to climate change 

Halting  all  GHG  emissions  would  still  not  prevent 
climate 
that  are  already  occurring. 
Therefore, adaptation to climate change is also a key 
component of climate policy. 

impacts 

Greece  is  in  two  out  of  three  regions  identified  as 
hotspots  of  climate  risks  most  affected  by  climate 
change –  Southern  Europe  and  low-lying  coastal 
regions (140). 

Greece is both vulnerable to the impacts of extreme 
weather  events  such  as  floods,  coastal  floods, 
droughts  and  heatwaves  and  at  risk  due  to  a 
persistently  high  climate  protection  gap.  Wildfires 
are  the  highest  risk,  with  a  high  economic  impact 
historically.  There  are  also 
to  water 
management, but work has begun to assess FRMPs. 
Putting  in  place  the  right  institutional  settings  is 
crucial  to  climate  adaptation.  Greece  has  made 
progress 
in  understanding  and  monitoring  the 
effects  of  climate  change  but  faces  challenges  in 
implementing adaptation strategies, notably due to 
insufficient human and financial resources. 

risks 

Greece adopted its national adaptation law in 2022 
and has a national adaptation strategy and regional 
adaptation plans. There are no sectoral adaptation 
plans.  The  creation  of  a  climate  crisis  and  civil 
protection ministry is welcome, but it has not been 
assigned 
to  effectively 
implement these policies. 

resources 

sufficient 

The  European  Commission  identified  three  priority 
actions in the 2022 edition of the EIR. 

(140)  European  Climate  Risk  Assessment 

(EUCRA).  2024. 
Available  at  European  Climate  Risk  Assessment 
(europa.eu). 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  40 

Greece has significantly accelerated the installation 
of  renewable  energy  capacity  and  overall  share  of 
renewables 
is  close  to  EU  average.  However, 
important challenges remain including grid capacity. 

is  still 

There 
little  progress  as  regards  the 
decarbonisation  of  the  transport  sector  and  the 
renovation of buildings stock. Greece needs to speed 
up both. 

2025 priority actions 

• 

Implement  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the 
Effort  Sharing  Regulation  (ESR)  and  LULUCF 
regulation.  More  detailed  priority  actions  are 
set out in the assessment of the final National 
Energy and Climate Plan (NECP)(141).  

(141)   National energy and climate plans 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
 
Greece  41 

Part II: Enabling framework – implementation tools 

5. Financing

The  EU  budget  supports  climate  investment  in  Greece 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022,  Greece’s  revenues  from  auctioning  reached 
EUR 2851 million  in  total,  with  all  of  it  spent  on  climate 
and energy. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 5.3 billion per year in 
Greece. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 3 billion per year; thus, there is a 
gap of EUR 2.3 billion per year. 

Of  the  environmental  investment  gap,  EUR 1.4 billion 
concerns  biodiversity  and  ecosystems,  EUR 300–
400 million each of pollution prevention and control and 
circular economy, and a further EUR 212 million the water 
objective. 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
ERDF), 
(RRF) 
EUR 275.7 billion and CAP EUR 145.9 billion (142). 

recovery  and 

resilience 

facility 

the 

In  Greece,  the  EU  cohesion  policy  (considering  EU 
contribution amounts) provides EUR 6.2 billion for climate 
action  in  2021–2027  (with  around  half  of  this  via  the 
ERDF), with a further EUR 185 million from the European 
Maritime, Fisheries and Aquaculture Fund (EMFAF) (143). 

The  RRF  contributes  to  climate  finance  in  Greece  with 
EUR 13.7 billion  up  to  2026,  representing  38.1 %  of  the 
recovery and resilience plan (RRP) (144). 

(EIB)  provided 
Investment  Bank 
The  European 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 2.5 billion was assigned to 
Greece in the reference period (145). 

National financing, including EU emissions trading 
system revenues 

to  EUR 507 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 1 015 million  in  2021  and  1 330 million  in  2022,  in 
Greece,  totalling  approximately  EUR 2 851 million  in  the 
three-year  period. 
In  Greece,  these  revenues  are 
earmarked  and  fully  spent  on  domestic  climate  change 
and energy projects (146). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level. 

the  environment 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (147). 

therefore, 

and, 

Environmental financing and investments 

This section describes Greece’s investment needs, current 
four 
financing  and  gaps  as 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 

relate 

they 

the 

to 

(142)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(143)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(144)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

(145)  A  list  of  financed  projects  is  provided  by  the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(146)  European  Commission:  Directorate-General 

for 
Climate Action, Progress Report 2023 – Climate action, 
the  European  Union, 
Publications  Office  of 
Luxembourg, 
2023, 
https://climate.ec.europa.eu/news-your-
voice/news/climate-action-progress-report-2023-
2023-10-24_en. 

(147)  NB:  Indirect  investments  (from  climate  and  other 
policies) in support of the environment are accounted 
for via the tracking. 

2025 Environmental Implementation Review– Greece 

 
 
Greece  42 

waste,  water  protection  and  management,  and 
biodiversity and ecosystems (148). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient  to  enable  Greece  to  meet  its  objectives  in  the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 5.3 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 2.1 billion per year, can be attributed to the need to 
support  biodiversity  and  ecosystems,  with  a  further 
EUR 1.3 billion  needed  for  pollution  prevention  and 
control,  EUR 1.1 billion 
for  circular  economy  and 
EUR 0.9 billion for water (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR   3 billion  in  Greece  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 8.5 billion for  Greece in total, during 2021–2027 (or 
EUR 1.2 billion per year). 

Table 1: Key environmental allocations from EU funds to 
Greece (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

EMFAF 

Other MFF sources 

RRF (d) (2021–2026) 

Allocations 

4 703.8 (a) 
2 705.5 
1 833 
165.4 
2 972.2 (b) 
2 039.6 
932.6 

148.2 

663.8 (c) 

 6 890 

(a) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 

(148)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

its  publication  date.  Source  and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

information: 

(b) 

(c) 

(d) 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

Space  Fund,  Horizon  Europe,  LIFE  and  the  Connecting  Europe 
Facility. 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Greece,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the LIFE programme (EUR 5.4 billion) (149), Horizon Europe 
(EUR 95.5 billion (150)),  the  Connecting  Europe  Facility 

(149)  https://cinea.ec.europa.eu/programmes/life_en. 
(150)  European  Commission,  Horizon  Europe  ,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  43 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 2.3 billion 
per  year  in  Greece,  representing  around    1.12 %  of  the 
national GDP, being higher than the EU average (0.77 %). 

Figure 30: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

(EUR 33.7 billion) (151)and  funds  that  can  be  mobilised 
through the InvestEU programme (152). 

Greece’s RRP supports climate objectives through funding 
of  EUR 13.7 billion  (38.1 %  of  total),  with  an  additional 
EUR 1.36 billion (3.8 % of total) for the environment. 

The EIB provided around  EUR 1.2 billion in  environment-
related financial contributions to Greece from 2021 to mid 
2024, most of which, EUR 983.2 million (81 %) was in the 
area  of  sustainable  energy,  transport  and  industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In  Greece, the 
total national environmental protection expenditure was 
EUR 2.4 billion 
in  2021, 
representing 1.5 % and 1.4 % of GDP, respectively. 

in  2020  and  EUR 2.5 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Greece,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 376 million in 2020, falling to EUR 358 million in 2021, 
representing around 0.2 % of GDP. 

investment 

protection 

from 

protection 

investment 

Splitting by institutional sector, 93 % of Greece’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
specialist  private-sector 
with  3.3 %  coming 
producers (of environmental protection services, such as 
waste and water companies) and 3.7 % from the general 
business  sector,  whose  environmental  activities  are 
usually ancillary to its main activities. At the EU level, 38 % 
of  environmental  protection  investment  comes  from 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (153). 

from 

Greece’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 3 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  74 %,  with  around 
26 % national financing. The total public financing (EU plus 
national public) represents 98 % of the total. 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of Greece’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
Greece per year, 2021–2027 

Environmental 
objective 

Investment gap per year 

Million EUR 
(2022 prices) 

% of 
total 

% of 
GDP 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

349 

 15.0 

0.17 

379 

16.3 

0.18 

212 

9.1 

 0.10 

1 391 

59.7 

0.67 

(151)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % 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. 

(152)  The  InvestEU  Fund  is  set  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  EIB  group 
and others. 

(153)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Greece 

 
 
 
Total 

 2 331 

100.0 

 1.12 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Greece’s investment 
needs  are  estimated  to  reach  EUR 1.3 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1.2 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs 
reach 
EUR 316 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (154).  Industrial  site  remediation 
requires  an  estimated  EUR 38 million  per 
year. 
Microplastics pollution and the chemicals strategy require 
around EUR 20–30 million per year (each) (155). 

environmental 

reduce 

noise 

to 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 962 million  per  year  in  Greece  in  the  2021–2027 
period.  Most  of  the  financing  concerns  clean  air 
(EUR 918 million 
from 
environmental noise receives around EUR 147 million per 
year, with a further EUR 13 million for site remediation. 

Protection 

year). 

per 

In Greece, the EU MFF provides an estimated 22 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further  62.5 % from the RRF, adding up to  84.5 % of the 
total.  EIB  financing  contributes  13.7 %  and  national 
sources reach 2 % (156). 

The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Greece 
needs  to  provide  an  additional  EUR 349 million  per  year 
(0.17 % of GDP), mostly related to clean air and noise. The 

(154)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(155)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(156)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 

Greece  44 

the  NECP  with 

implementation  of 

the 
adequate 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

According to the latest (2023) NAPCP review report (157), 
Greece  complied  with  ammonia  reduction  requirements 
in 2020 and 2021, and it is not at risk of non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction  commitments,  based  on  the  policies  and 
measures)  in  its  NAPCP  that  take  into  account  climate, 
energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Greece’s investment needs in circular economy and waste 
reach  EUR 1.1 billion  per  year 
(including  baseline 
investments).  Around  half  of this,  around  EUR 0.5 billion 
per  year,  relates  to  circular  economy  measures  in  the 
mobility,  food  and  built  environment  systems,  with  a 
further  EUR 0.5 billion  necessary  for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (158). 

Current investments 

Circular economy investments across the economy reach 
around EUR 214 million per year in Greece in 2021-2027, 
with  a  further  EUR 456 million  provided  for  waste 
management that does not constitute circular economy. 

Around 20 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 19 % from 
the RRF, adding up to 39 % of the total. EIB loans identified 
in  support  of  circularity  and  waste  represent  2 %  of  the 

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(157)  European Commission, ‘National air pollution control programmes 
website, 
European 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

Commission 

(158)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

2025 Environmental Implementation Review – Greece 

 
 
total.  The  share  of  national  sources 
overwhelming, reaching 59 % of the total financing (159). 

is  absolutely 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Greece  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 310 million 
additional 
EUR 69 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
EUR 379 million per year, representing 0.18 % of Greece’s 
GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 81 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 229 million constitutes further investment need 
to unlock Greece’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 1 871 million  (in  2022  prices) 
in  Greece.  This 
comprises investment needs both for the water industry 
and for the protection and the management of water.  A 
large  part  of  the  total  annual  need,  EUR 442 million, 
relates  to  drinking  water,  with  a  further  EUR 284 million 
necessary 
investments  and 
around  EUR 127 million 
the  protection  and 
management of water (160). 

for  wastewater-related 

for 

Current investments 

EUR 370 million 

Water investments in Greece are estimated to be around 
EUR 659 million per year (in 2022 prices) in 2021–2027. Of 
drinking  water, 
this, 
EUR 163 million  wastewater  management  and  around 
118 million  the  other  aspects  of  the  Water  Framework 
Directive (water management and protection). 

supports 

(159)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(160)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
28 May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD  (Organisation  for 
Economic  Co-operation  and  Development),  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(161)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 

Greece  45 

Of the total financing,  30.9 % is provided by the EU MFF 
(mostly  through  cohesion  policy),  with  a  further  12.1 % 
from  the  RRF,  reaching  43 %  combined.  EIB  financing  is 
around2.6 %  of  the  total,  while  the  bulk  of  financing 
comes from national sources (54.5 %) (161). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Greece’s  water  investment  gap  reaches  EUR 212 million 
per  year  (0.11 %  of  GDP),  with  over  half  related  to 
wastewater  management  (EUR 122 million  per  year). 
require  an  additional 
Drinking  water  measures 
EUR 72 million  per  year  and  the  other  aspects  of  the 
Water  Framework  Directive  around  EUR 10 million  per 
year over the existing levels of financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 2.1 billion per year (in 2022 prices) in 
Greece in 2021–2027. This includes the following financing 
needs: 

(i)  Greece’s PAF (162) concerning the Natura 2000 areas: 
EUR 149 million per year, mostly running costs; 
(ii)  additional BDS costs (163): EUR 1.4 billion per year on 

top of the PAF; 

(iii)  sustainable 

soil 

management 

costs (164): 

EUR 543 million per year. 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 704 million per year (in 2022 prices) in 2021–2027. 
59.5 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

15.1 % of the total financing is estimated to come from EU 
cohesion  policy,  56 %  from  CAP,  2 %  from  EMFAF,  6.4 % 
from Horizon Europe and around 2.5 % from LIFE. The EU 

(162)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

Commission 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

European 

(163)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(164)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
COM(2023) 416 
2023, 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 

5 July 

final 

of 

2025 Environmental Implementation Review – Greece 

 
 
Greece  46 

increased transparency on the environmental implications 
of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (167). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021 to 2024 (168). Greece participated and  introduced a 
national green budgeting methodology. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (169),  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 11.6 billion in 
Greece in 2022, representing 5.6 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 4.8 % of GDP, which 
is higher than the EU average of 1.6 %. Transport taxes, at 
0.76 % of GDP, were above the EU average (0.4 %), while 
taxes on pollution and resources, at 0.04 %, were  below 
average  (EU  average:  0.08 %).  In  2022,  environmental 
taxes  in  Greece  accounted  for  13.6 %  of  total  revenues 
from taxes and social security contributions (above the EU 
average of 5.0 %) (170). 

MFF altogether accounts for 83 % of the financing and the 
RRF for 16.3 %, adding up to a total of 99.5 % from the EU 
budget. The rest, 0.5 %, comes from national sources (165). 

Greece  has  envisaged  7.0 %  of  the  cohesion  policy  EU 
contribution amount (disregarding ESF+) and 2.5 % of the 
RRF funds to be investments into biodiversity, which are 
relatively  high  shares  compared  with  the  EU  average. 
While Greece also dedicates an estimated share of 17 % of 
its CAP budget to supporting biodiversity over 2021–2027, 
this is slightly below the EU average (see Figure 31). 

Figure 31: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Greece’s 
investment gap is estimated to be around EUR 1.4 billion 
per year, corresponding to 0.67 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States,  including  Greece,  already  use  green  budgeting 
tools  for  identifying  and  tracking  green  expenditures 
and/or revenues (166). Green budgeting practices provide 

(165)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(167)  European  Commission, 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(166)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(168)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(169)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
https://op.europa.eu/en/publication-detail/-
p. 1), 
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

(170)  Eurostat, ‘Environmental taxes accounts’, env_eta. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
Figure 32: Environmental taxes per Member State, 2022 

Greece  47 

applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  supranational 
issued  by 
financial  corporates,  29.1 %  by  sovereign  governments 
and  23.1 %  by  non-financial  corporates.  8.3 %  of  the 
issuances was linked to government-backed entities, 6.4 % 
to developments banks and 1.4 % to local governments. 

issuances)  was 

Figure 33: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According  to  a  2024  study (171),  Greece  applies  landfill 
taxes to quantities of untreated municipal waste, as well 
as  residues  from  municipal  waste  treatment,  being 
landfilled;  product  charges  (levies  on  plastics);  and  user 
charges (charges for visits to national parks, hunting and 
fishing taxes). 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Green bonds and sustainable bonds 

Environmentally harmful subsidies 

In 2023, the total value of green bonds issued by Member 
States  was  USD 245 billion  (EUR 227 billion),  up  from 
USD 234 billion (EUR 198 billion) in 2021 (172). 

During 2021–2023 combined, Greece issued green bonds 
worth USD 1.4 billion (EUR 1.2 billion). Of this, there was 
no issuance in 2023. 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
the  enabling 
action  programme  objectives  and 
conditions (173). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

(171)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(172)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(173)  Article 3(h) and 3(v) of the eighth environment action programme. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
 
As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 103 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (174). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (175). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In  Greece,  the  energy  subsidies  followed  a  decreasing 
trend  between  2015  and  2021,  including  FFS,  which 
decreased from EUR 3.4 billion (in 2015) to EUR 1.9 billion 
(in  2021).  However,  2022  saw  a  jump  in  overall  energy 
subsidies  (mainly  for  electricity),  with  FFS  increasing  to 
EUR 3.1 billion, but returning to 2021 levels in 2023. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. Greece’s value 
reached 1.5 %, above the EU average (0.8 %) (176). 

Figure 34:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

Greece  48 

NB: RES, renewable energy source. 
Source: analysis of Directorate-General Energy 

The 2022 EIR included the following recommendations. 

• 

• 

including  by 

Prepare  an  environmental  financing  strategy  to 
maximise  opportunities  to  close  environmental 
implementation  gaps, 
increasing 
environmental  taxation  and/or  private  financing  for 
the environment. 
Tackle  the  main  environmental  challenges  affecting 
the  country,  through  adequate  funding,  including 
through the mobilisation of investments and the use 
of EU funds. 

An environmental investment gap of 1.1 % of the GDP is 
observed  in  Greece,  mainly  related  to  biodiversity  and 
ecosystems. This necessitates further efforts in this area. 

2025 priority action 

light  of 

following 
the  observed  gap, 
In 
recommendation  is  made  for  Greece,  repeating  the 
second action from the 2022 EIR. 

the 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(174)      European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

Union, 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

(176)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

Union, 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

(175)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
 
 
Greece  49 

6. Environmental governance 

Information, public participation and access to 
justice 

Table 3:  Greece  dashboard  on  implementation  of  the 
Inspire Directive, 2016–2023 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (177).  Public 
is 
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 environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (178).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (179). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
information  between  public 
environmental  spatial 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

(177)  The 

Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004) 
Inspire 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(178)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 

2016 

2023 

Legend 

■ 

Effective coordination and data sharing  ■ Implementation of 
Ensure  effective 
this  provision  is  well 
coordination 
advanced  or  (nearly) 
completed. 
issues 
Outstanding 
are minor and can be 
addressed 
easily. 
Percentage > 89 % 

Data 
sharing 
without obstacle  ■ 

Inspire performance indicators 

■ 

■ 

(i)  Conformity  of 
metadata 

■ 

(ii)  Conformity  of 
spatial datasets (a)  ■ 

(iii) Accessibility of 
spatial 
datasets 
through  view  and 
download services 

(iv)  Conformity  of 
network services 

■ 

■ 

■ 

■ 

■ 

■ 

■ Implementation of 
this  provision  has 
started  and  made 
some  or  substantial 
progress,  but  is  still 
not  close  to  being 
completed. 
Percentage = 31–89 % 

■ Implementation of 
this provision is falling 
significantly  behind. 
Serious  efforts  are 
necessary to close the 
implementation  gap. 
Percentage < 31 % 

(a) 

In  2016,  the  deadlines  for  implementation  of  spatial  data 
interoperability  were  still  in  the  future:  23 November  2017  for 
Annex I data and 21 October 2020 for Annex II and III data. It must 
also  be  considered  that  this  indicator  will  in  many  cases  never 
reach 100 % conformity, as the majority of countries provide as-is 
datasets in addition to the Inspire-harmonised datasets. 

Source:  European  Commission,  ‘Greece’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/greece_en. 

Inspire 
Greece’s  performance 
Directive is substantial and has been reviewed based on its 
2023 country fiche (180) (see Table 3). 

implementing  the 

in 

In 2022, Greece received a priority action on the need to 
make  spatial  data  more  widely  accessible  and  prioritise 

(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 
2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(179)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(180)  European  Commission, 

‘Greece’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/greece_en. 

2025 Environmental Implementation Review – Greece 

 
 
 
environmental  datasets (181).  Greece  has  made  good 
progress  on  the  accessibility  of  spatial  data,  but  more 
efforts are needed. The 2022 priority action is repeated. 

Public participation 

Public involvement  at both the planning and the project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, i.e. the 
Environmental Impact Assessment (EIA) Directive (182) and 
the 
(SEA) 
Directive (183). 

Environmental 

Assessment 

Strategic 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member States in this regard (184). Greece has not taken 
steps  aiming  to  accelerate  permit-issuing  procedures 
taking advantage of the broad flexibilities offered by the 
EU legal framework. 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  a  maximum  duration  of 

(181)  The  European  Commission provides  a  list  of  high-value  spatial 
datasets 
(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

(182)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
https://eur-lex.europa.eu/legal-
p. 1), 
28.1.2012, 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(183)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
https://eur-lex.europa.eu/legal-
p. 30), 
content/EN/ALL/?uri=CELEX:32001L0042. 

(184)  Commission Staff Working Document  (SWD/2022/0149 final), 18 
https://eur-lex.europa.eu/legal-

2022, 

May 

( 

Greece  50 

(screening, 

scoping,  EIA 

75.7 months (185).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The  available  data  for  Greece  show  that  the  average 
duration of the EIA process appears to be faster than the 
EU average, but  definitive conclusions cannot  be drawn, 
as the information on the duration of the screening phase 
is  missing.  Effective  use  of  EU  procedures  can  positively 
influence  the  timely  approval  of  activities  underpinning 
the  decarbonisation  of  the  economy  on  the  way  to  net 
zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (186). 

Register 

Environmental 

The  Ministry  of  Environment  and  Energy  maintains  the 
Digital 
(Ηλεκτρονικό 
Περιβαλλοντικό Μητρώο) (187), which enables citizens and 
environmental  organisations  to  monitor  the  progress  of 
any  environmental  authorisation,  including  those  under 
the  EIA  Directive,  and  its  results.  User  registration  is 
required.  Public  consultation  is,  in  principle,  carried  out 
exclusively through this online system. It is not clear if an 
assessment has been made of how effective the website 
is  in  facilitating  public  participation.  In  any  event,  the 
legislation (Article 3, paragraph 1.1(b), of Joint Ministerial 
Decision 1649/45/2014) provides an additional action for 
the competent environmental authority, which consists of 
informing the appropriate regional council of the start of 
the  public  consultation.  The  related  announcement  is 
posted in the register and is also provided electronically by 
the same regional council. 

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

content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

Impact  Assessment 

(185)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(186)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

(187)  https://eprm.ypen.gr/. 

2025 Environmental Implementation Review – Greece 

 
 
some  of  the  documents  may  also  accompany  the 
announcement of the SEA. 

in  decision-making  processes, 

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

SEA  Directive 

and 

the 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As  mentioned  in  the  2022  EIR,  anyone,  any  group  of 
people acting together or any environmental NGO has the 
right  to  appeal  before  the  courts  to  protect  the 
environment  by  proving  a  specific,  legitimate  interest 
regarding their case (188). 

2025 priority actions 

• 

for 

spatial  datasets 

•  Make  spatial  data  more  widely  accessible  and 
prioritise  environmental  datasets  in  implementing 
the  Inspire  Directive,  especially  those  identified  as 
high-value 
implementing 
environmental legislation 
Ensure  that  relevant  information  on  EIA  and  SEA 
(including  on  public  participation 
procedures 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, through 
at least a central portal or easily accessible points of 
access, at the appropriate administrative level. 
•  Ratify  the  amendment  to  the  United  Nations 
Economic  Commission  for  Europe  Convention  on 
in 
Access 
in 
Decision-making 

Information,  Public  Participation 
Justice 

and  Access 

to 

to 

Greece  51 

Environmental Matters. 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (189) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools. 

The Environmental Inspectorate has created an electronic 
Registry of Projects and Activities of categories A1 and A2 
(in  accordance  with  the  EIA  Directive  and  its  related 
annexes, which have been transposed into national law). 
Based  on  this  registry  and  considering,  among  other 
things, the environmental risk analysis from the operation 
of the activities contained in it, the five-year national plan 
of  environmental  inspections  for  2024–2029  was  drawn 
up. 

regional 

authorities,  prepared 

The  inspectorate,  in  cooperation  with  the  competent 
decentralised 
the 
inspections, 
programme  of 
including  the  planned  frequency  of  on-site  visits  to  the 
relevant  facilities,  after  a  systematic  assessment  of  the 
environmental risks, in accordance with the provisions of 
Article 20, paragraph 10, of Law No 4014/2011 (190). 

regular  environmental 

In  addition,  with  the  recent  change  in  legislation  on 
environmental 
Law 
No 4014/2011), a  ministerial decision on the compliance 
action model has been issued, in which environmental risk 

inspections 

(Article 20 

of 

(188) 

In Article 24, paragraph 1, of the Greek constitution, protection of 
the environment is defined as an individual right of every citizen 
and as an obligation of the state. 

(189)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission staff working document (). 

(190)  The law is on environmental permits for projects and activities and 
other  provisions  within  the  competence  of  the  Ministry  of 
Environment and Energy. 

2025 Environmental Implementation Review – Greece 

 
 
analysis  is  considered  appropriate  for  the  categorisation 
of non-conformities. 

In addition to imposing fines, the inspectorate can set out 
a  corrective  action  plan  for  the  compliance  of  the 
inspected activities with current environmental legislation 
and the approved environmental conditions. 

inspectorate, 

The 
in  collaboration  with  the  Waste 
Management  Directorate,  is  in  the  process  of  creating  a 
plan  for  cross-border  inspections,  as  per  Article 62  of 
Regulation (EU) 2024/1157. 

It appears that the environmental compliance assurance 
system  in  Greece  would  benefit  from  a  more  active 
participation in the work of the European Union Network 
for 
of 
Environmental Law. Providing a more detailed assessment 
of compliance assurance activities will be  an aim for the 
next EIR. 

Implementation 

Enforcement 

and 

the 

In  November  2023,  a  regional  conference  dedicated  to 
strengthening  the  fight  against  crime  affecting  the 
environment  was  held,  which  representatives  from 
Albania,  Bosnia  and  Herzegovina,  Bulgaria,  Croatia, 
France, Greece, Kosovo, Montenegro, North Macedonia, 
Serbia, Slovakia, Slovenia, Poland and Romania attended 
(191). 

the 

The 2022 EIR recommended that Greece (i) improve the 
availability  of  practical  information  for  farmers  and  land 
managers on how to contribute to better implementation 
of  the  Nature  and  Nitrates  Directives;  (ii)  improve  the 
information  provided  to  citizens  on  opportunities  to  file 
complaints about environmental issues or infringements, 
and publish data on the follow-up of such complaints; (iii) 
improve 
taken  against 
reporting  of  action 
environmental  crime;  (iv)  establish  a  database  for  ELD 
cases, and other instances of environmental damage, and 
publish information on such cases, including on sanctions 
and  other  financial  measures.  Sygapez,  the  national 
competent  authority 
implementation  of 
environmental liability, has developed a platform through 
the  LIFE  ‘Promote  financial  instruments  for  liability  on 
environment’ 
(Profile)  programme.  ELD  cases  are 
registered  on  the  platform  by  Sygapez  and  regional 
competent  authorities  for  environmental 
liability.  A 
training event on the use of platform was held.  Some of 
the data registered will be available to the public. 

the 

for 

Concerning  compliance  promotion,  monitoring,  and 
criminal and administrative enforcement, the other 2022 
priority  actions  are  not  assessed  here  due  to  a  lack  of 
systematic  information.  Similarly,  the  Commission  is  not 
aware of whether information is easily available online at 

Greece  52 

the national level for farmers regarding compliance with 
the Nitrates and Nature Directives, and hence the related 
2022 priority action is not assessed. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203) (192) and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
in  place  and  more  systematic 
measures  are  put 
information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
in  particular  through  training,  coordination, 
crime, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 

including  by 

(192)    Directive  2024/1203/EU  on  the  protection  of  the  environment 
https://eur-

criminal 

law 

through 
lex.europa.eu/eli/dir/2024/1203/oj/eng 

2025 Environmental Implementation Review – Greece 

 
 
 
 
Law (193),  EnviCrimeNet (194),  the  European  Network  of 
Prosecutors for the Environment (195) and the EU Forum of 
Judges  for  the  Environment (196).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Justice  Cooperation 
Union  Agency 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)  (197)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (198), which will be finalised in 2025, and which 
was  supported  by  an  external  study (199),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some  of  which  may  have  been  handled under  the  other 
liability instruments. 

(193)  https://www.impel.eu/en. 
(194) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(195)  https://www.environmentalprosecutors.eu. 
(196)  https://www.eufje.org/index.php?lang=en. 
(197 )   Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage, https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626. 

Greece  53 

The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
encourage 
financial  security 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 

the  development  of 

From 1 May 2013 to 31 December 2021, Greece reported 
165 occurrences of environmental damage under the ELD, 
which  was  a  considerable  increase  from  the  previous 
reporting  period,  when  there  were  11  confirmed 
occurrences  of  imminent  threat  and  40  environmental 
damage  occurrences  under  the  ELD.  One  reason  for  the 
relatively  high  number  of  ELD  occurrences  in  Greece  is 
that Greece does not have specific national legislation for 
preventing and remediating environmental damage other 
than national legislation implementing the ELD. There are 
thus no overlaps or gaps between national ELD legislation 
and  other  national  environmental  legislation.  Moreover, 
Greece  is  among  the  Member  States  that  have  most 
heavily invested in developing training and methodologies 
assisting ELD implementation (200). 

security 

for  ELD 

The  environmental  insurance  market  in  Greece  is  in  a 
relatively early stage of development except for insurance 
that provides cover for businesses involved in hazardous 
and non-hazardous waste management, which are subject 
to  mandatory  financial  security  in the  form  of  insurance 
policies  or,  occasionally,  bank  guarantees.  Greece  has 
proposed, but has not yet brought into force, mandatory 
financial 
In  general, 
environmental  insurance  policies  for  on-site  and  off-site 
ELD  liabilities  are  available  from  a  limited  number  of 
insurance companies; however, demand for them is very 
low.  Nevertheless,  demand  for  financial  security  has 
introduction  of  Law 
increased  since  2020  with  the 
No 4685/2020,  which 
financial 
imposed  mandatory 
security  on 
non-hazardous  waste  management. 
Environmental extensions to general liability policies are 
not  generally  available  and  demand  for  them  is  low  as 
well. 

liabilities. 

In  relation  to  the  ELD,  the  2022  EIR  recommended  that 
Greece  establish  a  database  for  ELD  cases,  and  other 

(198)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025.  

(199)  European Commission: Directorate-General for Environment and 
in  support  of  the  evaluation  of  the 
Fogleman,  V.,  Study 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

(200)  An  example  is  the  EU-funded  programme  LIFE  Profile  (LIFE19 

GIE/GR/001127) (https://life-profile.gr/en/). 

2025 Environmental Implementation Review – Greece 

 
 
instances  of  environmental  damage,  and  publish 
information  on  such  cases,  including  on  sanctions  and 
other 
latest 
financial  measures.  According  to  the 
information,  a  platform  on  ELD  cases  has  been 
established. It will soon be available to the public. There is 
no further information available on the progress regarding 
the 2022 priority actions in relation to the ELD. Therefore, 
efforts  to  implement  them  should  continue  along  with 
efforts to implement the 2025 priority action. 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interactions  with  the 
other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 
expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (201) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
the  European 
for 
Commission  are  the  TSI (202)  and  the  TAIEX-EIR  PEER  2 
PEER tool (203). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The  TSI  had  annual  calls  in  2021,  2022,  2023,2024  and 
2025.  The  following  environment-related  projects  have 
been selected for Greece: 

(201)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(202)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

tool 

(203)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 
‘ESG’ here means ‘environmental, social and governance’. 

(204) 

Greece  54 

• 

Post-fire  biodiversity  and  biotic  natural  capital 
recovery: Framework development in the case of Evia, 
Ministry  of  Environment  and  Energy,  Natural 
Environment & Climate Change Agency (2021); 
•  Greening taxes – Applying the polluter pays principle 

in practice, Ministry of Finance (2022); 

• 

• 

framework 

•  Bridging the climate financing gap with public policy 
instruments,  Ministry  of  Finance,  Ministry  of 
Development  and  Investments  and  the  Ministry  of 
Environment and Energy (2022)  
ESG (204)  risk  management 
for  the 
financial sector, Capital Market Commission  (2023); 
Enhancing  the  centre  of  government’s  capacities  to 
steer  complex  priorities  and  manage  crisis  and 
megatrends  through  peer  to  peer  review  and 
learning, General Secretariat of Coordination (2024); 
Technical  support  for  the  development  of  a  Social 
Climate  Plan  and  the  implementation  of  the  EU 
Emission  Trading  Systems  as  well  as  the  Carbon 
Border  Adjustment  Mechanism  in  Greece  (CLIMA+), 
Ministry of Environment and Energy (2024); 
Strengthening Greece’s resilience, preparedness, and 
crisis  response  capacity,  Ministry  for  Climate  Crisis 
and Civil Protection (2024); 
Strengthening the green budgeting reform in Greece, 
Ministry of National Economy and Finance (2024). 

• 

• 

• 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-cultural  workshops  are  those  requested  by  the 
European  Commission  to  present  new  and  upcoming 
environmental 
in  all  Member 
legislation  and  policy 
States (205). 

Workshops involving Greece are as follows: 

• 

Future  challenges  for  air  protection  (24 November 

(205)  Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality: 
further 
implementation  of  the  NEC  Directive  to 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 
and implementation of the revised directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noise  limit 

2025 Environmental Implementation Review – Greece 

 
 
 
Greece  55 

2022) with the Czech EU presidency; 

•  Best  practices  in  applying  Article 6(3)  of  Habitats 
Directive:  Practical  solutions  to  carry  out  Natura 
impact  assessments  effectively 
(25–27 October 
2023); 

•  Green budgeting at regional level (9 April 2024); 
•  New aspects in the cross-border cooperation against 
environmental  crime  (Hungary,  19–20 November 
2024); 

•  Online  platforms:  EU  Batteries,  Packaging  and 
Packaging Waste Regulation (28–29 October 2024). 

Greece  hosted  one  expert  mission  on  the  proper 

implementation of the Nature Directives and the BDS (24–
27 September 2024), and benefited from one study visit to 
Ireland  (27–29 March  2023)  on  the  implementation  of 
Article 6(3) and 6(4) of the Nature Directives (92/43/EC). 

2025 priority action 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

values and EU reduction targets (5 June 2024); Best practice use 
of  environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 

in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19–20 September 
2022); and  Renewable energy projects: permit granting processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Greece 

 
 
 
 
 
Greece  56 

Annex 

2025 priority actions 

Circular economy and waste management 
Transitioning to a circular economy 

•  Adopt measures to increase the circular material use rate. 

• 

Implement, harmonise, and gradually increase landfill taxes to phase out landfilling of recyclable 
and recoverable waste.    

Waste management 

•  Complete closure of non-compliant landfills. 
• 

• 

• 
• 
• 
• 

Improve separate collection at source e.g. through economic instruments, investing in 
infrastructure for separate collection, sorting and recycling, and increasing public awareness. 
Increase reuse of products and scale up waste recycling infrastructure associated with the higher 
steps of the waste hierarchy. In particular, improve collection and increase treatment capacity for 
bio-waste. 
Improve municipal waste preparation for reuse and recycling. 
Increase the recycling rates of packaging waste. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 
Improve the system for managing the quality of data on packaging waste in order to build coherent 
and verifiable data sets. 
Invest in waste prevention measures to reduce the total amount of waste generated. 

• 
•  Ensure the achievement of the 2025 waste targets, following the recommendations made by the 

Commission in the Early Warning Reports where applicable. 

Biodiversity and natural capital 
Global and EU biodiversity frameworks 
•  Submit to the CBD an updated NBSAP or national targets following the adoption of the Kunming-

Montreal Global Biodiversity Framework. 

Nature protection and restoration – Natura 2000 

•  Complete the Natura 2000 site designation process. 
•  Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 
sites (including by adopting their management plans) and ensure their effective implementation. 

•  Ensure the effective implementation of Natura 2000 management plans and sufficient 

administrative capacity and financing both for Natura 2000 and the implementation of the Nature 
Restoration Regulation. Ensure implementation of Prioritised Actions Framework 2021-2027 (PAFs). 

Recovery of species  

•  Enhance efforts to collect reliable data on the conservation status of habitats and species as well as 

their occurrence at site level. In view of this, consider the creation of a body in charge of 
monitoring and reporting, to ensure that data are not provided only ad hoc on a contract basis. 

Recovery of ecosystems 

• 

Implement eco-schemes and agri-environmental measures and practices to address the 
environmental needs of Greece. 

•  Designate the competent authority responsible for fulfilling the obligations arising from the EUDR 
and inform the Commission of the names, addresses, and contact details of said competent 
authority. 

2025 Environmental Implementation Review – Greece 

 
Greece  57 

•  Report its updates on the assessment of the state of its marine waters, its targets, and its 

determinations of GES which are expected to include any threshold values for the descriptors in the 
MSFD that may have been established in cooperation with other Member States at the EU or 
regional level. 

Prevention and management of invasive alien species  
•  Step up implementation of the IAS Regulation, including with regard to enforcement and capacity 

of inspection authorities. 

Zero pollution 
Clean air 

•  As part of the NAPCP, take action towards reducing emissions of air pollutants. 
•  Ensure full compliance with the current AAQD standards, also in light of future stricter 

requirements under the revised AAQD. 

•  Accelerate the ratification of relevant international conventions and protocols. 

Industrial emissions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce industrial releases to water, and their intensity. 
•  Engage with industry and environmental NGOs to ensure proper contribution to and 

implementation of BAT conclusions; and ensure timely update of permits following publication of 
BAT conclusions. 

•  Ensure effective public participation and access to justice in relation with the IED. 

Major industrial accidents prevention – Seveso 
•  Strengthen compliance with requirements on safety measures to prevent major accidents and 

ensure appropriate preparedness and response for UTEs, in particular as regards review, testing 
and update of EEPs; at intervals of no longer than 3 years. 

•  Ensure access to transparent and clear information towards citizens on risks and behaviour in case 

of accidents. 

•  Ensure full and correct transposition of the Seveso III Directive. 
• 
Improve reporting on implementation of Seveso III Directive. 

•  Complete noise mapping. 
•  Complete and implement action plans on noise management. 

Noise 

Water quality and management 
•  Tackle nutrients pollution, especially nitrates from agriculture through the implementation of the 

Nitrates Directive. 

•  Take the necessary measures to ensure full implementation of the current urban wastewater 

treatment directive, taking into account the new requirements of the recast directive. 

Chemicals 

•  Upgrade the administrative capacities in implementation and enforcement towards a policy of zero 

• 

• 

• 

tolerance for non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of 
the European Chemicals Agency, including in the coordinated enforcement projects, called REFs. 
Increase customs controls and controls of products sold online with regard to compliance with 
chemicals legislations. 

Climate action 
Implement all polices and measures that are needed to achieve targets laid down in the Effort 
Sharing Regulation (ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. 
More detailed priority actions are set out in the assessment of the final National Energy and 
Climate Plan (NECP).  

2025 Environmental Implementation Review – Greece 

 
Greece  58 

Financing 

•  Use more national funding (including by increasing taxes in favour of the environment and reducing 
environmentally harmful subsidies), EU funding and private funding to help close the investment 
gap. 

Environmental governance 
Information, public participation and access to justice 
•  Make spatial data more widely accessible and prioritise environmental datasets in implementing 
the Inspire Directive, especially those identified as high-value spatial datasets for implementing 
environmental legislation. 

•  Ensure that relevant information on EIA and SEA procedures (including on public participation 

opportunities and on publication of final decisions) is electronically accessible in a timely manner, 
through at least a central portal or easily accessible points of access, at the appropriate 
administrative level. 

•  Ratify the amendment to the UNECE Convention on Access to Information, Public Participation in 

Decision-Making and Access to Justice in Environmental Matters. 

Compliance assurance 

•  Encourage the use of training programmes provided by the Commission (or developed at the 
national level) covering the ELD and its interactions with the other national liability related 
instruments, to ensure more efficient ELD implementation, improve the expertise of the competent 
authorities and raise awareness among all stakeholder groups. 

• 

EU-supported environmental capacity building 
Improve overall national environmental governance, in particular administrative capacity to 
support the green transition and coordination at the regional and local levels. 

2025 Environmental Implementation Review – Greece