EPR System in Greece
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Many founders now think beyond their home market from day one, aiming to sell across the European Union. Greece is an increasingly attractive destination—particularly for fashion, beauty, and home-decor brands. If your company plans to enter Greece, it’s worth knowing that the country operates its own system for waste traceability and reporting: the Hellenic Electronic Waste Register (HMA).
At first glance, these systems across Europe can look similar: they exist to keep tabs on who places packaging and products on the market, what happens to the resulting waste, and who is responsible for it. In practice, however, the legal framework, registration steps, and reporting scope can differ from country to country—and those differences often catch fast-growing teams by surprise when expanding abroad.
This article clears up the essentials. Step by step, we’ll walk you through the key elements of Greece’s HMA—covering the legal basis, how to register, what you need to report, and the practical benefits of getting it right. With this overview, you’ll know which documents to prepare and which procedures to follow so your business can operate legally—and confidently—on the Greek market.
What Is the HMA System in Greece
Before exploring the practical aspects, it’s useful to understand what the Greek equivalent of a waste register actually is. In Greece, the system is known as ΗΜΑ – Ηλεκτρονικό Μητρώο Αποβλήτων (the Hellenic Waste Registry, or HMA). It is a centralized, online platform operated by the Ministry of Environment and Energy, which collects and manages data from all entities involved in the generation, transport, or treatment of waste.
HMA has been in operation since 2016 and is based on two key legal acts. The first, Law 4042/2012, established the general framework for waste management in Greece. The second, Ministerial Decision JMD 43942/4026/2016, provided the detailed rules for implementation and gave the system its practical form. Together, these regulations have unified the national approach to waste reporting and digitized it, allowing both businesses and authorities to handle waste data electronically.
Every company whose activities generate waste—whether through production, collection, transport, or processing—is required to register in HMA and submit reports via the online platform. The Ministry not only oversees the system but also manages its day-to-day operation. The move to a digital structure has made it easier and faster for businesses to submit information, while giving public authorities a complete, real-time picture of waste flows across the country.
Electrical and Electronic Equipment (WEEE) and Batteries Under EPR in Greece
In Greece, producer obligations extend well beyond packaging waste. Electrical and electronic equipment (WEEE) as well as batteries and accumulators are also subject to collection and recycling schemes under the principle of Extended Producer Responsibility (EPR). Companies that place electronic devices on the Greek market are required to cooperate with a collective compliance organization, such as Appliances Recycling S.A., which manages the take-back and recycling process for WEEE.
In the case of portable batteries, producers are responsible for financing waste collection systems that operate through officially designated collecting points. Since 2021, batteries that are built into electronic devices have been classified as separate waste streams. This means that manufacturers of such devices have additional responsibilities for managing those batteries once they reach the end of their life cycle.
Objectives of the HMA System
The main purpose of the HMA is to record all entities that are required to report their waste-related activities. Through the system, companies can register their production or transport facilities, assign waste codes in accordance with the European Waste Catalogue (EWC), and submit annual electronic reports.
By centralizing this data, the Greek authorities are able to monitor waste management in real time, design more effective environmental policies, and react quickly when irregularities occur. The system also supports greater transparency and consistency across the waste sector, ensuring that all actors are accounted for and compliant with national regulations.
An Important Distinction for Foreign Companies
It is important to note that HMA does not cover all producer obligations in Greece. Alongside it operates the ΕΜΠΑ – Εθνικό Μητρώο Παραγωγών (the National Producers Registry, or EMPA), which is managed by the Greek Recycling Organization (EOAN). EMPA serves as the official register for companies that place packaging or other regulated products on the Greek market, including those based outside of Greece. This obligation arises from the principles of Extended Producer Responsibility, which assign producers financial and organizational responsibility for the waste their products generate.
In practical terms, the distinction between the two systems is clear. Companies that actually generate, collect, transport, or process waste within Greece must register in HMA. Companies that place packaged products or goods on the Greek market must instead register in EMPA.
Understanding the difference between these two registers is crucial for any business expanding into Greece. It allows companies to focus on the right compliance requirements from the start and to avoid unnecessary delays, misunderstandings, or penalties—particularly in sectors such as e-commerce, retail, and consumer goods.
Who Must Register in the HMA
Registration in the ΗΜΑ – Ηλεκτρονικό Μητρώο Αποβλήτων (Hellenic Waste Registry) does not apply to every business operating in Greece, but only to those that directly influence the generation or movement of waste. Entry in the system is mandatory for both private entities and public institutions whose operations result in waste that must be tracked.
Companies That Generate Waste
All businesses that produce waste other than household waste are required to register in the HMA. This obligation is not limited to large industrial plants—it also applies to smaller operations such as warehouses, workshops, and distribution centres.
For instance, if a company opens a logistics hub in Greece and generates packaging or production waste as part of its activities, it must register in the HMA and regularly report its waste management data.
Transport and Processing Companies
The obligation also extends to companies involved in the transport and processing of waste. Each transport operation and each waste treatment activity must be recorded in the system. This allows the authorities to trace the full life cycle of waste and ensure that none of it ends up outside legal disposal channels.
Landfills and Waste Management Facilities
Landfills and waste treatment installations must also be registered. These entities are responsible for the final stage of the waste management process, and therefore their activities are subject to close monitoring. Through the HMA, authorities can verify the types and quantities of waste received and ensure that all operations are carried out according to environmental regulations.
Municipalities and Public Waste Operators
Greek municipalities and other public entities responsible for collecting municipal waste are also required to register. By including both public and private operators, the HMA provides a unified, nationwide overview of waste management, making it possible to oversee the entire system from local collection to final treatment.
A Practical Example
Imagine a European e-commerce company that ships products to customers in Greece. Online sales alone do not create an obligation to register in the HMA. However, if the company opens a local logistics or distribution centre where packaging waste or other by-products are generated, it becomes a waste producer under Greek law. In that case, it must obtain an HMA registration number and submit annual reports through the online system.
Similarly, if a business works with a Greek waste carrier, that carrier must also be registered in the HMA. For the contracting company, it is important to check that any waste management partner is properly registered and compliant with Greek environmental regulations.
The Key Distinction Between HMA and EMPA
In Greece, two separate registers operate in parallel, serving different purposes. The HMA (Hellenic Waste Registry) covers entities that physically generate, transport, or process waste within Greece. The EMPA (National Producers Registry), managed by the Greek Recycling Organization (EOAN), applies to companies that place products or packaging on the Greek market. The latter register is part of the country’s Extended Producer Responsibility (EPR) framework.
In practice, this means that a business selling goods remotely to Greek customers—without any local physical operations—must register in EMPA, not in HMA. However, if the same business operates a warehouse, distribution centre, or production site in Greece where waste is generated, registration in HMA becomes mandatory.
How to Register in the HMA
Registration in the ΗΜΑ – Ηλεκτρονικό Μητρώο Αποβλήτων (Hellenic Waste Registry) is carried out entirely online through the official platform operated by the Greek Ministry of Environment and Energy. Although the process is formal, it has been designed to be straightforward and does not require any in-person visits to government offices.
Creating an Account
The first step is to create an account on the HMA platform, available at https://wrm.ypeka.gr. This is where a company sets up its profile and begins the registration procedure. Access to the system requires authentication using tax information and basic company identification details.
Information Required for Registration
The registration form requires a full set of company details, including the VAT number (for foreign companies, this is the EU VAT number), registered address, contact information, and NACE codes, which describe the company’s business activities. It is also necessary to specify the type of waste-related activities carried out and to assign the appropriate EWC (European Waste Catalogue) codes, classifying the waste types the company generates or handles.
Depending on the nature of the business, additional environmental permits may need to be uploaded in scanned form. These might include waste transport permits, collection authorisations, or decisions allowing the operation of a waste treatment or recycling facility.
Verification and Registry Number
Once the application is submitted, the Ministry reviews all information and attached documents for accuracy and completeness. If the application meets all formal requirements, the company receives a unique HMA registration number.
This number has practical significance—it must appear on official documents related to waste management, such as transport records, environmental reports, and invoices associated with waste handling. The number serves as a traceable identifier linking each waste-related operation to a specific company, ensuring transparency and accountability throughout the process.
Reporting Electrical Equipment and Batteries in Greece
After registration, producers and importers are required to submit reports detailing the quantities and weights of electrical and electronic equipment and batteries placed on the Greek market. The reporting methodology must comply with WEEE (Waste Electrical and Electronic Equipment) requirements and the local battery collection framework.
For portable batteries, it is particularly important that data on quantities placed on the market and those collected for recycling are accurately documented, as producers are financially responsible for the collection and recycling processes.
Since 2021, batteries built into electronic devices have been classified as separate waste streams. This means they must be reported and managed independently, and producers of such devices carry additional reporting and financing obligations under Greek regulations.
Obligations After Registration
Obtaining an HMA registration number marks the beginning of ongoing compliance obligations. Registered entities must submit annual waste reports by 31 March of the following year, covering all relevant waste quantities and movements. Companies are also required to keep their information in the system up to date—for instance, when there is a change in company address, activity type, or environmental permits.
The HMA number must be used consistently in all relevant documentation, and failure to include it in operational paperwork may be considered a breach of regulations.
Non-compliance—whether by failing to register when required, providing outdated data, or missing reporting deadlines—can result in administrative penalties. In more serious cases, financial fines may also apply. For that reason, ensuring full compliance with the Greek waste registry from the outset is both a legal and strategic necessity for any business operating in the country.
Reporting Obligations in the HMA
Obtaining a registration number in the ΗΜΑ – Ηλεκτρονικό Μητρώο Αποβλήτων (Hellenic Waste Registry) is only the first step. The system is not merely a database; it serves as a continuous monitoring and reporting platform for waste-related activities. Every registered entity is required to provide regular updates and ensure that all information remains accurate and complete.
Annual Waste Reports
The most important obligation for registered companies is the submission of annual waste reports. These reports must include detailed data on the types and quantities of waste generated, collected, transported, or processed during the previous calendar year.
Reports must be submitted by 31 March of the following year. Missing the deadline or failing to submit a report at all may lead to administrative sanctions, and in some cases, financial penalties.
Reporting goes beyond simple numerical data entry. Each waste type must be assigned a corresponding EWC (European Waste Catalogue) code. This ensures that data across the country remain standardised and comparable across sectors, regions, and industries.
Reporting Food Waste
Food waste is treated as a distinct reporting category within the HMA. The obligation to report it applies only to companies that actually generate this type of waste—most commonly those in hospitality, catering, food logistics, and distribution.
These reports must be filed separately, allowing authorities to analyse the scale of food waste across the country and to design targeted measures to reduce it.
Functionalities of the HMA System
HMA is more than a reporting tool—it has been designed as a practical management system to support companies in handling their environmental documentation.
Registered businesses can generate waste statistics based on EWC codes, helping them track costs, measure performance, and plan sustainability initiatives. The system also allows users to download registration certificates and proof of entry, which are often required by business partners, clients, or local authorities.
Another useful feature is the built-in record of submitted reports and declarations. This archive helps companies prepare for audits or inspections and maintain consistent documentation over time.
What It Means for European Businesses
For companies operating in Greece, the reporting obligations under the HMA mean that internal procedures must be in place to collect, categorise, and manage waste data.
For example, if a logistics or distribution centre in Greece generates packaging waste, each waste type must be assigned to the correct EWC code and included in the company’s annual waste report. Inaccurate or missing data can result not only in fines but also in reputational risks, as many Greek business partners and local authorities require up-to-date HMA certification before entering into or continuing cooperation.
HMA in Numbers (as of 2024)
Although the Hellenic Waste Registry has been active only since 2016, it has already become a central pillar of Greece’s waste management framework. Data released by the Ministry of Environment and Energy show that the number of registered entities grows every year, and the system has become an integral part of both public administration and business practice.
As of June 2024, more than 40,000 active facilities were registered in the HMA, covering a wide range of industries—from large industrial sites to smaller logistics and distribution centres. The system had already processed over 185,000 annual waste reports, showing that HMA reporting has become a standard compliance practice for companies operating in Greece.
Around 330 municipalities are also registered, which means the system now includes not only industrial waste but also a significant portion of municipal waste streams. This integration provides the government with a comprehensive overview of national waste flows and supports the development of coherent environmental policies.
Support for Businesses
The scale of the HMA system requires strong administrative and technical support. To facilitate this, the platform includes a dedicated helpdesk and a team of specialists who assist businesses with day-to-day reporting and compliance issues.
Companies can seek help with technical problems related to the online platform, guidance on interpreting regulations, or advice on how to prepare reports correctly. This makes HMA not only a compliance mechanism but also a practical support tool for businesses.
For international companies expanding into Greece, this accessibility is especially valuable. Having direct access to assistance within the system reduces the risk of reporting errors and helps ensure smooth, ongoing compliance with Greek environmental obligations.
Benefits of the HMA System
The HMA – Hellenic Waste Registry was created not only to impose new obligations on businesses but also to streamline and modernise Greece’s entire waste-management framework. Its main goal has always been to make processes more transparent, more efficient, and easier to navigate. As a result, the system delivers tangible benefits for both public administration and the private sector.
Benefits for Public Administration
One of the key strengths of HMA is the ability to ensure far greater control over waste flows. Every operation—from transport to final treatment—is linked to a company’s unique registration number, providing full traceability and greatly reducing the risk of irregularities.
The system also enables data-driven environmental policymaking. The Ministry of Environment and Energy receives up-to-date information on waste generation and management across the country, allowing it to respond quickly to emerging issues and design more effective regulations.
Equally valuable is the statistical insight HMA provides. Reliable data are shared with ELSTAT, the Hellenic Statistical Authority, and then incorporated into national and EU-level environmental reports. This means that policy decisions can be based on verified figures rather than estimates, improving both accuracy and accountability in environmental governance.
Benefits for Businesses
For companies, HMA represents a major step towards digitalisation. Instead of maintaining stacks of paper documentation, businesses can store and submit all required information electronically. This not only saves time but also reduces administrative errors.
Reporting has also become simpler and more efficient. The platform can generate summaries and statistics based on each company’s data, turning HMA into a practical management tool rather than a mere compliance requirement.
Another advantage is the immediate online verification process. Companies can download registration certificates and reporting confirmations at any time—documents that are frequently required in tenders, supplier vetting processes, and cooperation with local authorities.
HMA registration also enhances a company’s reputation. Being listed as an active, compliant entity demonstrates transparency and environmental responsibility, strengthening business credibility in the eyes of partners and clients.
A European Perspective
For international companies operating in Greece, the HMA offers a welcome shift from traditional bureaucracy to a modern, digital approach. The system is fully accessible online, which means that reporting, certification, and documentation management can all be handled remotely, without the need for physical presence in the country.
This is particularly advantageous for e-commerce and logistics businesses that rely on speed, accuracy, and seamless cooperation with local partners. Certificates and confirmations can be downloaded on demand, simplifying negotiations and reinforcing the company’s reliability in the market.
In practice, the HMA has become far more than a compliance platform. It is an integrated digital tool that supports everyday waste-management operations, helps companies stay compliant with Greek and EU regulations, and contributes to a broader culture of transparency and environmental accountability.
Risks and Penalties for Non-Compliance with EPR Obligations for Electrical Equipment and Batteries
Failure to register electrical and electronic equipment or batteries, or to submit the required reports, can lead to administrative penalties under the Greek Extended Producer Responsibility (EPR) system. Sanctions may include financial fines, orders to correct or resubmit declarations, and, in severe cases, restrictions on the right to sell products covered by the system.
With the European Union placing increasing emphasis on circular economy principles and the effective recycling of batteries and electronic devices, Greek authorities have become more proactive in enforcing compliance. Companies operating in these categories can therefore expect closer scrutiny and stricter controls in the coming years.
Conclusion
The HMA – Hellenic Waste Registry plays a central role in Greece’s waste management framework. Its purpose extends well beyond maintaining a database; it provides continuous oversight of waste flows across the entire country. In practice, any business that generates, transports, or processes waste in Greece must be registered in the system and submit regular reports.
For European companies expanding into Greece, it is crucial to understand that environmental registrations obtained in other EU countries do not automatically apply there. Depending on the nature of the activity, companies may fall under one of two separate systems:
- HMA (Hellenic Waste Registry) – for businesses that physically generate, transport, or manage waste within Greece.
- EMPA (National Producers Registry) – for companies placing products or packaging on the Greek market under the rules of Extended Producer Responsibility (EPR).
Understanding the distinction between these two systems is essential. Confusing them—or failing to register in the appropriate one—can result in formal errors, administrative complications, and potentially financial penalties.
Awareness of how HMA and EMPA operate is therefore a key part of preparing for market entry in Greece. Proper registration is not only a legal obligation but also an important step toward building trust with partners, clients, and public institutions. Certificates and confirmations from HMA or EMPA are often required in tenders, business negotiations, and contracts with local authorities.
For any company considering expansion into Greece, it is worth identifying early on which register applies to its activities and what specific obligations arise from that. When in doubt, consulting waste-management or compliance experts can save significant time and prevent costly mistakes. Professional support ensures that your operations in Greece are not only fully compliant but also run smoothly, transparently, and without unnecessary risk.
