Greece Law 4819/2021 (Integrated Framework for Waste Management & Circular Economy): Greece’s Law 4819/2021: Integrated Waste and Circular Economy Framework

What’s Required

Law 4819/2021 establishes Greece’s integrated framework for waste management, circular economy measures and plastic product regulation. It transposes EU Directives 2018/851 (Waste Framework) and 2018/852 (Packaging and Packaging Waste).

It introduces:

• A national waste hierarchy and circular-economy approach.

• Expanded separate collection obligations for municipal waste, including bio-waste, textiles and other fractions.

• Stronger extended producer responsibility (EPR) for packaging, electrical and electronic equipment, batteries and other streams, including eco-modulated fees that reward recyclability and recycled content.

• Measures to reduce landfilling and promote preparation for reuse and recycling, including targets to cut municipal waste sent to landfill to around 10% by 2030.

• Provisions on single-use plastics and environmental protection.

• Law effective from July 2021.

• Landfill share of municipal waste to be reduced to about 10% by 2030, five years earlier than the general EU deadline.

• Gradual introduction of landfill bans and separate collection obligations, including a ban on landfilling textiles from 2024 and additional obligations for other streams in the mid-2020s.

Current Status

• Law 4819/2021 is now the main waste and packaging law in Greece, and is central to national circular-economy policy.

• Greece is rolling out new separate-collection schemes and EPR expansions (including for textiles and other products).

• Authorities and EPR organisations are adjusting fee structures to introduce eco-modulation based on recyclability, recycled content and hazardous substances.

Penalties for Non-Compliance

• Administrative fines for improper waste management, failure to implement separate collection, or violation of landfill bans.

• Sanctions for producers that avoid or under-fund EPR obligations, misreport data or place non-compliant packaging or plastic products on the market.

• In serious cases (e.g. illegal dumping or hazardous-waste mismanagement), penalties may include suspension of operations or criminal proceedings under broader environmental law.

Examples of Known Violations

• Public sources focus mainly on structural non-compliance (very high landfill rates, insufficient separate collection) rather than named companies.

• Enforcement is increasing, with inspections targeting non-compliant landfills, inadequate municipal waste practices and underperforming producers within EPR schemes.

Meta Title

Greece Law 4819/2021: Waste, Packaging & Producer Responsibility Rules

Meta Description

Law 4819/2021 is Greece’s main waste and circular-economy law, tightening separate collection, landfill limits and extended producer responsibility for packaging and other products.

Resources (only links)

• https://circulargreece.gr/legislative-framework

• https://trade.gov/market-intelligence/greece-waste-management-opportunities

• https://rokas.com/law-4819-2021-use-of-waste-for-energy-production

• https://eea.europa.eu – Greece municipal waste factsheet

• https://ejournals.epublishing.ekt.gr – “Analyzing the Greek Legal Framework on Waste Management”

3. Greece – Law 4403/2016 – Publication of Non-Financial Information

What’s Required

Law 4403/2016 transposes the EU Non-Financial Reporting Directive (2014/95/EU) into Greek law. It requires certain large companies and groups to disclose non-financial information on environmental, social and employee matters, human rights, anti-corruption and bribery, and diversity. greenfinanceplatform.org+2one.oecd.org+2

In-scope entities must prepare a non-financial statement that forms part of the management report or is published as a separate report referenced by the management report.

The statement must describe:

• Business model and main non-financial risks.

• Policies, outcomes and key performance indicators for environmental and social matters.

• Human-rights due diligence and anti-corruption measures.

• Diversity policy for administrative, management and supervisory bodies. greenfinanceplatform.org+1

Important Deadlines

• Law applies to financial years starting in 2017, following adoption in July 2016. Accountancy Europe+2unitesi.unive.it+2

• Non-financial statement must be published within the same deadline as annual financial statements, typically within a few months after financial year-end. greenfinanceplatform.org+1

Mandatory Requirements

Law 4403/2016 is binding for large public-interest entities (PIEs) that meet defined size thresholds.

Obligated entities must:

• Prepare an annual non-financial statement at individual and, where applicable, consolidated level. Accountancy Europe+1

• Disclose policies, risks and performance indicators on the required ESG topics. greenfinanceplatform.org+1

• Follow the “comply or explain” principle when no policy exists for a required area. Accountancy Europe+1

• Ensure the statutory auditor checks the presence of the statement (at least limited involvement). Accountancy Europe+1

Scope (high level):

• Entities of public interest (listed companies, banks, insurers and other PIEs) that exceed specified thresholds (more than 500 employees and financial size criteria). Accountancy Europe+2one.oecd.org+2

Exceptions

• Small and medium-sized enterprises below the thresholds are not directly required to publish a non-financial statement. Accountancy Europe+1

• Subsidiaries can be exempt at individual level if included in a compliant consolidated non-financial statement prepared by their parent. greenfinanceplatform.org+1

Current Status

• Law 4403/2016 remains in force and is the current legal basis for mandatory ESG reporting in Greece until full transposition of the Corporate Sustainability Reporting Directive (CSRD). eydap.gr+2Lexology+2

• Greek regulators and the Athens Stock Exchange encourage companies, especially listed ones, to move toward CSRD and ESRS-aligned reporting, but Law 4403/2016 still sets the minimum legal requirements. athexgroup.gr+1

Penalties for Non-Compliance

• Failure to publish the non-financial statement, late publication or materially incomplete information can trigger administrative fines, which may reach up to several million euros for serious cases. Accountancy Europe+2Lexology+2

• Additional enforcement tools include orders to correct or re-issue reports and potential liability for directors in cases of serious misstatements. Lexology+1

Examples of Known Violations

• Public sources mention general shortcomings (insufficient detail on ESG risks, weak metrics, lack of human-rights due diligence) rather than named sanction cases. eydap.gr+1

• The law has nonetheless driven a steady increase in formal sustainability and non-financial reporting among large Greek companies, especially listed entities. eydap.gr+1

Summary (≤1000 characters)

Greece’s Law 4403/2016 transposes the EU Non-Financial Reporting Directive and requires large public-interest entities to publish an annual non-financial statement. The report must cover environmental, social and employee matters, human rights, anti-corruption and diversity, and may follow a recognised reporting framework. It applies to large listed companies, banks, insurers and other PIEs above specific thresholds and must be published together with financial statements. While Greece prepares CSRD transposition, Law 4403/2016 continues to define the baseline ESG-disclosure obligations.

Headline

Greece’s Law 4403/2016: Mandatory Non-Financial Reporting for Large Public-Interest Entities

Meta Title

Greece Law 4403/2016: Non-Financial & ESG Reporting Requirements

Meta Description

Law 4403/2016 requires large Greek public-interest entities to publish non-financial statements on environmental, social, human-rights and anti-corruption topics, anticipating future CSRD rules.

Resources (only links)

• https://greenfinanceplatform.org – Greek Law 4403/2016 profile

• https://accountancyeurope.eu – NFRD implementation in EU Member States

• https://efrag.org – NFRD / CSRD technical papers

• https://athexgroup.gr – ESG Reporting Guide for listed companies

• https://oecd.org – analyses of Greek climate and ESG frameworks