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Greece: a deposit system adopted, not yet on the pack

Current position

Greece has adopted the legal and technical framework for a national deposit-return system, including future package identification. The operator reports that licensing and nationwide activation remain incomplete. The deposit mark is therefore adopted or pending, not fully in force. Greece does not otherwise require a universal sorting label on ordinary packaging. Harmonised Union labels apply later under the Packaging and Packaging Waste Regulation.

Overall statusAdopted / pending — framework in place; operator licensing incomplete
Primary instrumentsLaw 4736/2020; Joint Ministerial Decision UPEN/DDA/15185/193/2025; Regulation (EU) 2025/40
ApplicationDeposit framework adopted; national activation pending; Union labels later
Last verified21 August 2026

The question this report answers

Greece has moved beyond a policy proposal for beverage-container deposits, and it has not yet reached a fully operational national scheme. Law 4736/2020 and the 2025 Joint Ministerial Decision establish the legal and technical architecture for deposits on specified plastic and metal beverage containers. DRS Hellas was established as the intended national collective system operator and states that participating containers will carry the system logo, a registered barcode and the applicable deposit value. The operator also states that licensing by the Hellenic Recycling Agency and phased activation are still in progress.

That status is the whole of the labelling question. An adopted ministerial framework is legally different from a consumer obligation that applies nationwide to products being placed on the market today. The Atlas therefore records the package mark as adopted or pending, not as fully in force. A claim that a container is already accepted by the national DRS can still create consumer-law risk if the return route is not actually available. Greece does not otherwise require one universal sorting label on all packaging. The PPWR’s harmonised labels follow later Union dates.

RequirementStatusWhat it is
National deposit-system markadoptedThe framework contemplates a DRS logo, registered barcode and deposit value on participating containers once the system is activated.
Deposit collectionpendingThe national operator reports phased activation and pending licensing. A future launch date is not an operative nationwide obligation.
Universal Greek sorting labelnoneNo current national panel applies to every ordinary package.
PPWR harmonised material labeladopted; not yet appliedUnion law. Applicable on the later Article 12 timetable.

What the 2025 decision contemplates

The 2025 decision covers specified single-use plastic and metal beverage containers up to three litres, subject to the definitions and exclusions in the legislation. It establishes deposit values of EUR 0.10 for containers up to 0.5 litres and EUR 0.15 for containers above 0.5 litres and up to three litres. The system is designed around registration and machine-readable product identification so that automated return points can recognise eligible containers. DRS Hellas describes a future configuration containing the DRS logo, the barcode and the deposit amount. Operator-approved technical specifications, once licensing and onboarding are complete, are the files that will matter. A provisional graphic, policy presentation or mock-up is not the authorised mark.

Why licensing is the labelling question

The legal framework anticipates duties for producers and importers placing covered beverages on the Greek market, as well as return and collection obligations for retailers and the collective system. Before those operational duties can function, the operator must be licensed, products must be registered, financial arrangements must be established and return infrastructure must be capable of recognising the approved identifiers. The Greek importer or first domestic market placer is the party who will, when the system starts, need product data, barcodes and mark files. Contractual planning is a present fact. An operative nationwide marking duty is not, as of this verification.

The Ministry of Environment and Energy and the Hellenic Recycling Agency supervise the packaging and collective-system framework. Once operative, failures involving registration, deposit collection, package identification or system participation can attract the measures available under waste and environmental law. Before activation, the enforcement question is different: it is whether a pack is being described as already inside a return system that the consumer cannot yet use.

Producer responsibility, and the Union labels still to come

Packaging producers remain subject to Greek producer-responsibility and waste-management law irrespective of the DRS launch. Scheme registration and financing do not create a general mandatory recycling symbol for all packaging. Voluntary material coding or sorting communication should correspond to Greek collection practice and should not suggest participation in a deposit system that is not yet collecting.

The PPWR generally applies from 12 August 2026, while its harmonised material-composition label begins on the later of 12 August 2028 and 24 months after the relevant implementing act. The future Greek deposit mark and the later Union material label perform different functions and may ultimately appear together according to the rules then in force. They are not, today, two marks on a Greek bottle.

Primary sources and verification

Greece. Joint Ministerial Decision UPEN/DDA/15185/193/2025. Consolidated instrument

Ministry of Environment and Energy. Deposit-return framework documentation. Official PDF

DRS Hellas. National system and company status. Operator information

European Union. Regulation (EU) 2025/40. EUR-Lex

Greek-language legislation and the formal licensing decision control. Last verified: 21 August 2026.

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