Knowledge Base: E-commerce Accounting and VAT Compliance

EPR System in Cyprus

Date22 Oct 2025
Category

If you run an online store, ship products abroad, or plan to expand into new European markets, environmental compliance should be high on your list of priorities. Across the EU, companies are required to take responsibility for the packaging and products they place on the market, ensuring proper collection, recycling, and waste management. In Cyprus, this responsibility is managed through the Extended Producer Responsibility (EPR) system – a framework that makes producers, importers, and online retailers accountable for the waste their products generate.

The EPR Framework in Cyprus

Cyprus operates several national schemes that collectively form its EPR system. The most prominent are Green Dot Cyprus, responsible for packaging waste; WEEE Cyprus, which covers electrical and electronic equipment; and AFIS Cyprus, managing batteries and accumulators. Each is licensed and supervised by the Cyprus Department of Environment. Their role is to ensure that companies contribute financially to waste collection and recycling efforts in proportion to the type and quantity of materials they place on the market.

Joining one of these systems is not optional. Businesses that introduce packaged goods, electronics or batteries to the Cypriot market must register with the relevant organisation, sign a membership agreement, and make regular declarations about the volume and composition of their products. Fees are calculated based on material type and total mass, and most processes are handled online. Green Dot, for instance, requires members to submit annual reports by the end of February for the previous year, while WEEE and AFIS often require quarterly declarations.

The Legal Foundation

Cyprus’s environmental compliance framework is rooted in EU law. The island has transposed the main sectoral directives – including Directive 94/62/EC on packaging, Directive 2012/19/EU on waste electrical and electronic equipment, and Directive 2006/66/EC on batteries – into its national legislation. Key acts include the Packaging Law (L.32(I)/2002) and the Waste Law (L.185(I)/2011), alongside specific regulations governing electronic products and batteries.

This alignment ensures that the Cypriot system mirrors EU standards, meaning that an online seller who already complies with EPR obligations in another member state will find the general principles familiar – though the local registration process and reporting timetables may differ.

Who Is Responsible?

When selling to Cypriot consumers, the responsibility for compliance usually lies with the seller – specifically, the company that first places goods or packaging on the local market. This includes distance sellers based in another EU country who ship directly to Cypriot customers. The only exception applies when a local distributor imports the goods and takes full legal responsibility for them. For e-commerce operators, this often means registering directly with Green Dot or one of the other EPR systems, even if the business itself is not formally established in Cyprus.

Monitoring and Enforcement

Environmental compliance in Cyprus is actively monitored. The Department of Environment carries out inspections to verify registration and reporting accuracy, while the EPR organisations themselves conduct regular audits. Green Dot Cyprus, for example, reviews the declarations of a sample of its members each year to ensure that reported data matches actual packaging volumes.

Non-compliance can lead to administrative penalties and, in more serious cases, formal enforcement action. Even smaller online retailers should take these obligations seriously: a missing registration or an inaccurate report can translate into fines and unnecessary regulatory attention.

Why It Matters

Understanding the Cypriot approach to EPR is essential for any business expanding into the island’s market or using Cyprus as a logistics base for EU distribution. Whether you sell through your own website, operate through Amazon’s fulfilment centres, or ship directly from the mainland, you are still bound by the same principles of producer responsibility.

While the terminology and procedures may differ from other EU countries, the goal remains the same: to ensure that companies play an active role in reducing waste and supporting sustainable material management. For e-commerce sellers, that means more than simply packing and shipping – it means operating with environmental accountability built into every step of the supply chain.

Environmental Compliance in Cyprus – What E-commerce Sellers Should Know

For online retailers operating across Europe, environmental compliance has become a standard part of doing business. Every EU country applies the principle of Extended Producer Responsibility (EPR), which makes companies accountable for the waste generated by the packaging and products they place on the market. While some member states operate through centralised systems, Cyprus manages these obligations differently — through several independent organisations and procedures overseen by the Department of Environment, part of the Ministry of Agriculture, Rural Development and Environment (MARDE).

How the EPR System Works in Cyprus

Cyprus does not use a single, centralised registration platform for environmental reporting. Instead, companies meet their EPR obligations by joining one or more licensed recovery organisations. The main systems cover the three key waste streams: Green Dot Cyprus handles packaging, WEEE Cyprus manages electrical and electronic equipment, and AFIS Cyprus is responsible for batteries and accumulators.

Although it is technically possible to establish an individual compliance scheme, this approach is rarely chosen in e-commerce. Most businesses opt for membership in existing organisations, which provide a structured framework for declarations, fee payments, and ongoing communication with the authorities.

Legal Foundations

The Cypriot system is firmly based on EU law. It transposes the major sectoral directives that shape waste management across the Union: Directive 94/62/EC on packaging and packaging waste, including the later Single-Use Plastics Directive; Directive 2012/19/EU on waste electrical and electronic equipment (WEEE); and Directive 2006/66/EC on batteries and accumulators.

These are implemented through national acts such as the Packaging Law (L.32(I)/2002, as amended), the Waste Law (L.185(I)/2011), and accompanying regulations for electronics and batteries. The Waste Law also incorporates Directive 2008/98/EC, the EU’s framework on waste, along with subsequent updates, including Directive 2018/851 on circular economy targets. Together, these laws ensure that Cypriot obligations mirror EU-wide environmental policy.

When Registration Becomes Mandatory

The obligation to register under an EPR scheme in Cyprus arises when a business is the first to place a product on the local market. For most e-commerce sellers operating on a cross-border basis, this means that if you sell directly to Cypriot consumers from another EU country, you are the one responsible for compliance. The only exception occurs when a local distributor imports your products and takes full responsibility for their introduction to the market.

Once registered, companies must sign a membership agreement, pay contributions based on the volume and type of materials they place on the market, and submit reports according to the deadlines set by each organisation. Green Dot typically requires an annual declaration by the end of February, while WEEE and AFIS operate on quarterly reporting cycles or, in some cases, allow an annual summary.

Key Differences and Similarities

The most important difference between Cyprus and more centralised systems elsewhere in the EU is structural. Cyprus divides responsibilities among several organisations rather than managing them through one unified database. Despite this decentralisation, the core principles remain the same. If you introduce products, packaging, or electronic goods to the market, you have a legal obligation to register, report, and contribute to the cost of waste management. The mechanism may vary, but the underlying duty is identical across the Union.

Oversight and Control

The Department of Environment acts as the main supervisory body, ensuring that producers and importers comply with their obligations. It carries out inspections, issues guidance, and, when necessary, imposes administrative penalties for breaches. In addition, the recovery organisations themselves perform regular audits. Green Dot Cyprus, for instance, conducts annual reviews of selected members’ reports—typically around twenty companies each year—to verify the accuracy of data submitted.

For small online sellers, this oversight may seem distant, but it has very real implications. Missing registrations, incomplete reports, or inaccurate declarations can lead to enforcement actions or complications when working with logistics partners and marketplaces that increasingly demand proof of environmental compliance.

Additional Considerations for E-commerce

Businesses offering chemical products, cosmetics, or detergents should also be aware that their goods may fall under separate regulations such as REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and CLP (Classification, Labelling and Packaging). These are not part of the waste management framework but impose their own registration and labelling duties.

Neglecting these aspects can create issues not only with Cypriot authorities but also with business partners or sales platforms that now require sellers to demonstrate full regulatory compliance. As environmental standards continue to tighten across the EU, understanding and managing your obligations in each market has become a fundamental part of running a sustainable and legitimate e-commerce business.

Business Registration and Environmental Permits in Cyprus

When a Waste Management Permit Is Required

In Cyprus, a Waste Management Permit is required only for companies that are directly involved in waste-related operations. This includes the collection, transport, storage, treatment, recovery, or disposal of waste materials. Simply storing fully functional products that have not yet become waste does not trigger this requirement. In such cases, the relevant obligations are managed through the island’s Extended Producer Responsibility (EPR) systems—Green Dot Cyprus, WEEE Cyprus, and AFIS Cyprus—rather than through waste permits.

A permit becomes necessary when a facility handles returned goods that are no longer usable and are classified as waste, or when it processes, sorts, or repackages packaging waste for recycling. In those cases, the company is considered to be conducting waste management activities and must obtain formal authorisation before proceeding.

The MARDE Online Portal

Applications for a Waste Management Permit are submitted through the Department of Environment’s online portal, operated under the Ministry of Agriculture, Rural Development and Environment (MARDE). This platform is not a reporting database but rather an administrative tool for filing permit applications and supporting documents. The EPR obligations for packaging, electronics, and batteries are handled separately through the licensed compliance organisations.

Through the MARDE portal, businesses can apply for environmental permits, register as waste operators, upload the required documentation—such as a business description, waste management plan, and contact details—and track the status of their application as it moves through the administrative process. Most procedures are available in English, although some forms remain accessible only in Greek. In practice, many foreign companies work with local consultants or authorised representatives to ensure their submissions are correct and complete.

Why It Matters

Operating a waste management activity without the necessary permit can lead to serious administrative penalties and, in severe cases, a suspension of operations. The Cypriot authorities take these obligations seriously and conduct regular inspections. However, if your business only places products or packaging on the market, and waste arises later at the consumer’s end, you fall under the EPR framework rather than the waste permit system.

Understanding this distinction—between waste management permits and producer responsibility schemes—is crucial for planning compliance effectively and avoiding unnecessary costs.

The Extended Producer Responsibility (EPR) System in Cyprus

What EPR Means for Businesses

Extended Producer Responsibility (EPR) is a legal framework that holds companies accountable for the entire lifecycle of the products they place on the market, including their end-of-life management. Under Cypriot law, the term “producer” covers not only manufacturers but also importers and distance sellers who ship directly to Cypriot consumers. This means that in a typical B2C e-commerce model, the seller—rather than the buyer or the logistics provider—is treated as the first entity placing goods on the Cypriot market and is therefore responsible for compliance.

Cyprus applies the EPR principle across three main areas of activity: packaging, electrical and electronic equipment, and batteries. Each area is managed by a separate, licensed organisation that maintains its own registry, collects declarations, and supervises members under the oversight of the Department of Environment.

Packaging and Green Dot Cyprus

For packaging, the designated compliance organisation is Green Dot Cyprus, the island’s official recovery system. Any company that sends packaged products to customers in Cyprus—whether through local sales, dropshipping, or third-party fulfilment—must register with Green Dot or establish its own authorised recovery system. In practice, virtually all e-commerce companies join the existing organisation rather than setting up individual schemes.

Registration is mandatory for any business introducing primary packaging (such as boxes for cosmetics or food products) and secondary packaging (such as shipping cartons or wrapping materials) to the Cypriot market. Failure to register is treated as a breach of environmental law and can result in administrative penalties.

Once registered, companies must file annual packaging declarations reporting the total weight of materials placed on the market, broken down by category—typically paper and cardboard, plastic, metal, and glass. The declaration for the previous calendar year must be submitted by 29 February, though Green Dot may request quarterly updates or corrections for businesses with large or variable volumes.

Recycling fees are calculated based on the total mass and material type. Rates are reviewed annually and published on the organisation’s website. As a general rule, the greater the volume of packaging introduced, the higher the contribution required.

Electrical and Electronic Equipment – WEEE Cyprus

Scope and Registration

The Cypriot WEEE system covers a wide range of electrical and electronic products — from small household appliances and consumer electronics to lighting equipment, photovoltaic panels, IT devices, and even medical or industrial equipment placed on the Cypriot market. Registration takes place through recovery organisations such as WEEE Electrocyclosis Cyprus, rather than directly with the authorities.

Once registered, companies are required to submit quarterly declarations specifying the quantities and categories of equipment introduced to the market. These declarations form the basis for calculating recycling contributions and verifying compliance with EU and national waste regulations.

Information and Labelling Requirements

Under the EU’s WEEE Directive, all electrical and electronic equipment placed on the market must display the crossed-out wheeled bin symbol. This marking informs users that the product should not be disposed of with regular household waste and must instead be collected through proper recycling channels. The accompanying user manual or packaging must also include clear information on how to handle and dispose of the device responsibly once it reaches the end of its life cycle.

Fees and Financial Contributions

Fees within the WEEE system depend on both the category and the mass of the equipment placed on the market. The relevant recovery organisations publish their rates annually, allowing businesses to calculate costs according to product type and total weight. These fees fund the collection, treatment, and recycling of electronic waste across Cyprus and are a mandatory element of market participation for all sellers.

Batteries and Accumulators – AFIS Cyprus

Registration and Reporting

The AFIS Cyprus system manages producer responsibility for portable, industrial, and automotive batteries. Registration in the system is compulsory for any company placing batteries or battery-powered products on the Cypriot market. Declarations are submitted quarterly — typically by 10 April, 10 July, 10 October, and 10 January — or, for smaller operators, through a single annual report due by 31 January. All processes are managed through AFIS’s dedicated online portal.

Why Compliance Matters

Participation in EPR systems such as Green Dot, WEEE, and AFIS is not optional. These frameworks are legally binding and subject to oversight by the Department of Environment, which can conduct audits and impose administrative penalties for non-compliance. The recovery organisations themselves also carry out regular checks; for instance, both Green Dot and WEEE Cyprus periodically review member declarations to ensure accuracy.

Beyond legal obligations, compliance demonstrates corporate integrity. Environmental responsibility has become a marker of trust in the modern marketplace — customers, logistics partners, and online platforms increasingly expect sellers to provide evidence of their sustainability practices. Regular reporting and timely payments not only help avoid penalties but also strengthen a company’s reputation as a transparent and responsible market participant.

Reporting and Environmental Fees

EPR Declarations and MARDE Reporting

Although Cyprus does not operate a centralised digital reporting system, the obligation to report environmental data remains in full effect. For most e-commerce companies, this responsibility is fulfilled through their membership in EPR organisations rather than through direct communication with the Department of Environment. Each recovery organisation collects data from its members, verifies it, and reports the aggregated figures to the authorities.

Direct reporting to MARDE (the Ministry of Agriculture, Rural Development and Environment) is only required for companies that hold a Waste Management Permit or operate an individual recovery system outside the collective EPR framework.

Scope and Deadlines

The content of the declarations depends on the type of products introduced to the market. In Green Dot Cyprus, companies report the total mass of packaging by material type — such as cardboard, plastic, metal, or glass — and by packaging form, distinguishing between consumer, group, and transport packaging. The annual declaration must be submitted by 29 February for the previous year, although high-volume producers may be required to provide additional quarterly updates.

In the WEEE system, companies report the mass and number of electronic devices introduced, covering categories such as household appliances, IT equipment, lighting, or photovoltaic panels. Declarations are generally filed quarterly, though smaller firms may be allowed to report annually. The AFIS system requires the declared weight and quantity of batteries and accumulators to be submitted quarterly or, alternatively, once a year by the end of January.

Environmental Fees and Payment Structure

Participation in EPR systems involves several types of costs. These include an initial registration fee, an annual or quarterly membership contribution, and variable charges based on the weight or category of products placed on the market. In both Green Dot and AFIS, fees are typically calculated in euros per kilogram of material, while WEEE fees depend on the product type and mass category.

Each organisation publishes an annual pricing schedule and provides guidance to help businesses prepare their declarations accurately — a valuable resource for smaller companies without dedicated environmental compliance teams. Keeping financial and reporting records organised ensures smooth audits and predictable operational costs throughout the year.

The Importance of Accurate and Timely Reporting

Environmental reporting is a recurring obligation that must evolve with your business. As order volumes grow, packaging materials change, or new product categories are introduced, declarations must be updated accordingly. Late submissions or inaccurate data can lead to penalties from both the recovery organisations and the Department of Environment.

Maintaining detailed internal records of packaging, equipment, and batteries throughout the year allows companies to prepare precise reports and demonstrate compliance during audits. This approach not only helps avoid fines but also strengthens corporate credibility, signalling that the business operates responsibly and transparently within the European regulatory framework.

Practical Guidance for Businesses

Assessing Your Business Model and Identifying Obligations

If you operate an online store in Cyprus or ship products there that reach consumers in packaging, as electrical devices, or with batteries, you are part of the local waste management system. The first and most important step is to assess your business model realistically. If your products are shipped in cardboard boxes, padded envelopes, or plastic film; if they include powered devices or batteries; or if you use a warehouse or fulfilment centre located in Cyprus, it is very likely that you have obligations under the island’s Extended Producer Responsibility (EPR) framework.

It’s essential to distinguish between the two main compliance paths from the outset. Companies participating in EPR schemes such as Green Dot Cyprus, WEEE Cyprus, or AFIS Cyprus report directly to those organisations and pay their recycling fees within those systems. The data is then compiled and forwarded collectively to the Department of Environment. Direct reporting to the Ministry of Agriculture, Rural Development and Environment (MARDE) is only necessary for businesses that hold a Waste Management Permit or operate their own recovery systems.

Working with EPR Organisations

For companies introducing packaged goods to the market, the key partner is Green Dot Cyprus. For electronic equipment, it’s WEEE Cyprus, and for batteries and accumulators, AFIS Cyprus. These organisations take over the practical aspects of waste collection, recovery, and recycling — but the business must register, provide the required data, and pay the relevant fees.

In practice, Green Dot members file annual reports by the end of February for the previous calendar year, detailing the mass and type of packaging materials used. WEEE Cyprus members usually report quarterly, although smaller companies may opt for annual declarations. AFIS Cyprus also works on a quarterly schedule, with reporting deadlines typically falling in April, July, October, and January.

Fees in Green Dot and AFIS are calculated per kilogram of material introduced to the market — covering paper, plastic, metal, and glass — while in WEEE, charges depend on the category and weight of electrical equipment, such as large appliances, IT devices, or small household electronics. Understanding these schedules early allows businesses to plan their data collection and payments efficiently throughout the year.

How to Avoid Mistakes and Stay Compliant

The most common issues in environmental reporting stem from a lack of preparation. To avoid compliance problems, maintain accurate records of packaging, devices, and batteries throughout the year instead of estimating data at the last minute. It’s also a mistake to assume that small-scale activity exempts a business from its responsibilities — even a modest online store can be subject to EPR obligations if it places products or packaging on the market.

Because procedures in Cyprus may differ from those in other EU countries, it’s unwise to rely solely on domestic interpretations of environmental law. When in doubt, it’s best to consult a local environmental advisor or legal expert familiar with Cypriot regulations. This small investment helps prevent costly penalties and reinforces your credibility with partners and customers alike.

In Summary

For e-commerce businesses operating in Cyprus, environmental compliance can initially seem complex — particularly compared to more centralised systems in other EU countries. But once broken down, the key obligations are straightforward, logical, and fully manageable, even for small companies. Every business that introduces products generating waste onto the Cypriot market, regardless of scale, must ensure that it is registered, reporting, and contributing financially to the recovery and recycling of the materials it uses.

The fundamental requirements include registering with the relevant recovery system, submitting annual or quarterly declarations on packaging and products, and paying environmental fees based on material type and quantity. Companies directly handling waste — through transport, storage, or processing — must also hold the appropriate environmental permit.

The Cypriot Approach Compared to Other EU Systems

Unlike some EU countries that rely on a single national registry, Cyprus operates through multiple independent organisations. Each entity — Green Dot, WEEE, and AFIS — is responsible for a specific waste stream, and businesses must manage communication with each of them separately. While this requires coordination, the procedures are often more flexible and less bureaucratic than in more centralised systems, making compliance accessible even for smaller operators.

Compliance as a Competitive Advantage

Complying with Cypriot and EU environmental legislation is not just about avoiding fines — it’s a mark of professionalism and credibility. Today’s consumers, business partners, and marketplaces expect sellers to demonstrate responsibility and transparency. Treating compliance as an integral part of your business strategy builds trust, reduces operational risk, and strengthens your long-term position in the market.

For many businesses, managing environmental obligations across borders can feel overwhelming — but you don’t have to do it alone. Our team can help you handle your EPR compliance in Cyprus, from registration and reporting to communication with Green Dot, WEEE, or AFIS. Reach out to us, and we’ll make sure your business stays compliant, confident, and ready to grow sustainably across Europe.

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