According to JM 23615/651 / Ε.103 / 2014, Electrical and Electronic Equipment is defined as:

“Equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields, designed for use with a voltage rating not exceeding 1000 V for alternating current (AC) or up to 1500 V direct current. The concept of EEE includes all its components, assembled parts and consumables, which are part of the product when it is placed on the market.”

The categories of EEE according to JM 23615/651 / Ε.103 / 2014 are the following:

1. Temperature exchange equipment
2. Screens, monitors, and equipment containing screens having a surface greater than 100cm²
3. Lamps
4. Large equipment (any external dimension more than 50cm), including (not exclusively) the following:

Household appliances, IT and telecommunications equipment, consumer equipment, luminaires, equipment reproducing sound or images, musical equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments, automatic dispensers, equipment for the generation of electric currents, photovoltaic panels. This category does not include equipment in categories 1 to 3.

5. Small equipment (no external dimension more than 50cm) including (not exclusively) the following:

Household appliances, consumer equipment, luminaires, equipment reproducing sound or images, musical equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments, automatic dispensers, equipment for the generation of electric currents, small equipment with integrated photovoltaic panels. This category does not include equipment in categories 1 to 3 and 6.

6. Small IT and telecommunication equipment (no external dimension more than 50cm).

Alternative management of WEEE according to JM 23615/651 / E.103 / 2014 are all the activities concerning the collection, sorting, transportation, transshipment, temporary storage, preparation for reuse and processing, recycling or recovery of energy, for the purpose of utilization of WEEE and return to market current.

The basic legal framework that defines the obligation to register in a collective scheme of alternative waste management of EEE Waste, but also in the National Producers’ Register is the following:

• Law 4819/2021: Integrated framework for waste management – Transposition of Directives 2018/851 and 2018/852 of the European Parliament and of the Council of 30 May 2018 amending Directive 2008/98/EC on waste and Directive 94/62/EC on packaging and packaging waste, framework for the organization of the Hellenic Recycling Organization, provisions for plastic products, urgent provisions for the protection of the natural environment, spatial-urban planning and energy regulations.
• Law 4496/2017: Amendment of Law 2939/2001 for the alternative management of packaging and other products, adaptation to Directive 2015/720 / EU, regulation of issues of the Hellenic Recycling Agency and other provisions.
• Ministerial Decision 181504/2016: As in force, on the establishment, funding etc. of the National Producer Register laid down the obligation, conditions and requirements for the establishment and implementation of the National Producer Register, as well as the relevant sanctions in case of erroneous implementation
• JMD 23615/651 / Ε.103 / 2014: Definition of rules, terms and conditions for the alternative management of waste electrical and electronic equipment (WEEE), in accordance with the provisions of Directive 2012/19 / EC “On waste electrical and electronic equipment (WEEE) “, of the European Parliament and of the Council of 4 July 2012 and other provisions.

Obligated Producer according to the law is the one who manufactures and / or imports products of Electrical and Electronic Equipment and place them on the Greek market and has a legal obligation to participate in a collective scheme of alternative waste management as well as to be registered in the National Producers’ Register.

More specifically, according to JM 23615/651/Ε.103/2014, “obligated producer” or “producer” is considered:

“Any natural or legal entity, irrespective of the selling technique used, including distance communication as defined in Article 2 (par. 1) of no. G1−496 / 2000 of joint ministerial decision “Distance sales – Comparative advertising − Adaptation of law 2251/1994… to the provisions of directive 97/7 / EC… etc.” (BD 1545), which:

1. is established in Greece and manufactures EEE under its name or trademark, or has EEE designed or manufactured and markets it under its trade name or trademark within the territory of Greece;
2. is established in Greece and resells within the territory of Greece, under its own trade name or trademark, equipment produced by other suppliers, a reseller not being regarded as the “producer” if the brand of the “producer” appears on the equipment, as specified under point (1) above;
3. is established in Greece and places on the market EEE originating from a third country or another Member State; or
4. sells EEE by means of distance communication directly to private households or to other users in Greece, and which is established in another Member State or in a third country.

In this case, the obligated Producers are the Greek companies.

However, according to HRA (Hellenic Recycling Agency) and the European directive, a company that places its products to Greek market through Greek client(s) can affiliate with an authorised Scheme in Greece as Producer, instead of the Greek client(s) and declare these products to the Scheme.

This can happen to make it easier for its client(s) in Greece and in order the recycling fee of these products safely be paid as European directive demands.

There are already many foreign companies based in EE or in third country which are affiliated with the Scheme.

Yes, according to Greek law that has been already mentioned, a company that is not located in Greece, in order to affiliate with an authorised Greek collective Scheme has to cooperate with an authorised representative in Greece.

• The National Producers’ Register is an organised Register scheme of the Hellenic Recycling Agency (HRA) which obligatorily includes the Obligated

• Producers who must have a corresponding Producer Registration Number for the legal exercise of their activity in Greece and for the monitoring of the recycling obligations by the competent authorities.

• The registration of producers in the registry is a necessary condition for the legal exercise of their activity and for their participation in public tenders.

• The Producer Registration Number is a unique number and is granted to each company registered in the National Producers’ Register and must be stated in all its tax documents.

The term “placing on the market” means according to JM 23615/651 / Ε.103 / 2014, “the first time a product is circulated on the market on a professional basis”. Accordingly, “market circulation” is defined as “any supply of a product for distribution, consumption or market use in the course of a commercial activity, either for a fee or free of charge”.

• Fulfil of the obligations imposed by Law 4819/2021 and the JMC. 23615/651 / Ε.103 on the Alternative Management of WEEE related to their activity.
• Obtaining the Producer Registration Number by the Hellenic Recycling Agency, a basic condition for participation in public tenders in Greece.
• Improvement of your corporate image and increase competitive advantage

The total cost of Alternative Management of WEEE includes the following sub-costs:

• Collection, Transportation, Sorting and Temporary Storage costs of WEEE
• Transportation costs of WEEE to licensed recyclers
• Treatment costs of WEEE
• Cost of public awareness and information
• Administrative costs

The monetary contribution is charged by the Producer, is passed on to all stages of placing on the market and is returned to the Scheme through periodic declarations. According to JM 112145/2004, the amount of the financial contribution is indicated separately in the sales invoices at all stages of the sale of the products, except for the invoices addressed to the final buyers – users.

In invoices and / or retail receipts addressed to the final consumer, the financial contribution is included in the price of the product and is invoiced uniformly.

According to article 6 par. 2.1.2 of JM 23615/651 / Ε.103, distributors of Electrical and Electronic Equipment are obliged:

To distribute EEE products the producers of which are registered in the National Producers’ Register provided for in Article 17 and integrated in collective schemes of alternative management of WEEE.