The Hellenic Competition Commission (“HCC”), taking into account the economic importance of the waste management and recycling sectors in Greece and their contribution to sustainable development objectives, as well as the need to ensure their proper functioning and efficient operation, has launched on 16.7.2021 a Sector Inquiry in the Waste Management and Recycling Sectors in specific categories of waste pursuant to Article 40 of Law 3959/2011.
Waste management and alternative management is a pressing issue in modern, European societies, and beyond, in two respects: on the one hand, for reasons of environmental protection and in the broader context of addressing climate change and the introduction of the production model in the circular economy and sustainable development; on the other hand, for economic reasons, through the treatment of waste as tradable goods with economic value. A major part of the European Union’s expenditure on waste management is allocated to solid waste.
An integrated solid and liquid waste management system does not only include the management, recycling or regeneration of the generated waste, through its collection at source, the recycling of various materials for the purpose of energy recovery or reuse of materials and, finally, its final treatment, but also the limitation of its generation.
In the context of the obligations of Union origin for proper waste management, Law 2939/2001 on “Packaging and alternative management of packaging and other products - Establishment of the National Organisation for Alternative Management of Packaging and Other Products (N.O.A.M.P.O.P.) and other provisions", as in force, constitutes the core of the legislative framework on recycling in Greece. Its purpose is, inter alia, "… g. the optimisation of the operation of the Alternative Management Systems (ALS) by establishing conditions aimed at transparency, better control and rationalisation of the costs of the services concerned, as well as promoting economically and environmentally sustainable investments, in order to bring about contributory benefits for citizens from recycling".
In short, alternative waste management for different categories that fall, according to the above, within the scope of the relevant legislation (Law 2939/2001), concerns the packaging placed on the market and the packaged waste deriving from industries, trading, offices, shops, services, households or any other source, regardless of the materials from which they are made, as well as waste from vehicles, motor vehicle tyres, catalytic converters, waste oils, batteries and accumulators, electric and electronic equipment, furniture, printed materials, clothing, sleeping mats, biowaste, excavation waste, construction and demolition waste, small quantities of hazardous household waste, etc. Therefore, the categories of waste provided for by Law 2939/2001 are numerous, while the above list is not exhaustive.
The Hellenic Recycling Agency (HRA/EOAN) is responsible for monitoring the alternative management of seven (7) categories of waste from those mentioned above (which are often referred to by EOAN as waste "streams"), for which further, more specific individual rules have been adopted, in most cases through ministerial decisions or presidential decrees, and in which alternative management systems (AMS) are already in place. In general, alternative management consists of the collection, transport, transshipment and storage operations, preparation for reuse, recycling and any other type of waste recovery. These waste categories are: Packaging waste, Waste lubricating oils, Used motor vehicle tyres, Waste batteries and accumulators, End-of-life vehicles (ELVs), Waste electrical and electronic equipment (WEEE), Excavation, construction and demolition waste.
- Packaging waste
- Waste lubricating oils,
- Used motor vehicle tyres,
- Waste batteries and accumulators,
- End-of-life vehicles (ELVs),
- Waste electrical and electronic equipment (WEEE),
- Excavation, construction and demolition waste.
In addition to the management of the above streams, there are other categories of waste which are managed by other operators and can subsequently be made available for recycling. The provision of facilities for delivery, receipt and management of waste to port users is one of these categories that is of particular interest to the Greek economy.
Protecting the marine environment from discharge of ship-generated waste and cargo residues is also a major area of European action for maritime transport. The main categories of ship waste are the following: a) cargo residues from tank washings, b) sewage and non-sewage, c) engine-room mixed waste, d) anti-fouling paints, e) fuel residues, f) waste / garbage, g) exhaust gas and h) ballast water.
Furthermore, the above waste can be divided into two major categories: liquid waste and solid waste, while there are provisions for the reduction of waste gases in ports.
In order to reduce the environmental risks to which ports are exposed, environmental management frameworks have been set up to reduce the adverse effects.
Regarding port waste management, there is a high concentration in the industry which seems to be favored by the implementation of the legislative and regulatory framework.
The purpose of the HCC’s sector inquiry is to clarify any potential competition issues in certain markets of this industry, such as:
- the forces (bargaining power) that develop in each ecosystem of alternative management of a specific stream where the Collective Alternative Management System (CMS) / Individual Alternative Management System can function as a bilateral or multilateral platform;
- the structural links between players vertically and horizontally in waste management and recycling and the extent to which they can influence competition variables;
- the application of the regulatory framework to each of the investigated markets and any inconsistencies with competition law - regulatory barriers, and how removing them will increase the effectiveness of the markets;
- barriers to entry other than regulatory;
- whether the market structure contributes to the possibility of developing coordinated or non-coordinated effects;
- the extent to which specific practices can be justified due to effectiveness and public interest objectives, such as sustainable development, and how this can be justified on the basis of different instruments of competition law;
- how the existing market structure ultimately contributes to the development, innovation and efficiency of each individual waste management and / or alternative waste management market.
As part of the first phase of this sector inquiry, we are initiating a public consultation, inviting any interested party to submit their comments and positions regarding the conditions of competition in the wider industry. Those interested can participate in the public consultation in person, through a teleconference to be held by the HCC within October 2021, and / or by submitting their views in writing.
It is noted that the above is subject to the possibility of the HCC to limit and / or expand the scope of the sector inquiry, depending on the findings of the ongoing inquiry, as the case may be.
Inquiry into the Waste Management and Recycling Sectors in specific categories of waste
Latest Updates
- 03 August 2021 - Launch of public consultation: publication of an invitation to any interested party to submit written observations and comments, as well as to express interest in participating in the teleconference with officials of the HCC, see the relevant Press Release
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Questions & Answers
- General Questions: Scope and Aims of the Sector Inquiry
The Hellenic Recycling Agency (HRA/EOAN) is responsible for monitoring the alternative management of seven (7) categories of waste from those mentioned above (which are often referred to by EOAN as waste "streams"), for which further, more specific individual rules have been adopted, in most cases through ministerial decisions or presidential decrees, and in which alternative management systems (AMS) are already in place. In general, alternative management consists of the collection, transport, transshipment and storage operations, preparation for reuse, recycling and any other type of waste recovery. These waste categories are: a) Packaging waste, b) Waste lubricating oils, c) Used motor vehicle tyres, d) Waste batteries and accumulators, e) End-of-life vehicles (ELVs), f) Waste electrical and electronic equipment (WEEE), g) Excavation, construction and demolition waste.
From the financial technology services providers' perspective, the spread of the specific services creates new business opportunities, which contribute to the boost of their competitiveness through the promotion of innovation, as well as economic growth and new jobs creation. It is worth mentioning the growing activity in the sector not only of credit institutions (which have set their digital transformation as a top priority), but also of other companies (especially e-commerce and business services' providers, as well as IT companies), start-ups and organizations.
The waste generated by the users of the Greek ports can be divided into two major categories: liquid waste and solid waste, while there are provisions for the reduction of waste gases in ports.
In order to reduce the environmental risks to which ports are exposed, environmental management frameworks have been set up to reduce the adverse effects. The management and administration of ports belongs in principle to the port authority, which is responsible for each port, however there are other bodies involved at the second level. Greece has a number of ports, which are characterised by diversity in terms of their use, their distribution on the Greek territory, their size and importance, and they are either public or private. In particular, Greece has 16 ports of international interest, 16 ports of national importance, 25 ports of major importance and many others of local importance. The existing ports / port facilities, both public and private of all sizes and uses, amount to about 890. The responsibility for these ports lies with more than 100 public management bodies (12 Port Organisations operating as public limited companies, 1 of mixed ownership, 23 harbor funds supervised by the Ministry of Shipping and Island Policy and 68 Municipal Harbor Funds).
Furthermore, in Greece there is a specific way of project undertaking and concession of port facilities, i.e. through licensing tenders. Today, in the 13 largest Greek ports, following licensing tenders: a) solid waste and cargo residues are managed by two companies and b) liquid waste, is also managed by two companies, one of which is common in both categories.
Regarding recycling for specific categories of waste, the HCC’s sector inquiry will focus on the relationships between waste generators, collectors, alternative management systems and treatment plants / recyclers / regenerators. In the waste management markets concerning the Greek ports, the HCC’s sector inquiry will focus on the relationship between ports (as contracting entities) and concessionaires, as well as on the award procedure for the designation of concessionaires and the legal framework governing such award procedures.
The HCC, taking into account the importance of the waste management and recycling sectors in Greece, as well as the need to ensure its effective and efficient operation due to the nature of its subject-matter, especially in the context of the Authority’s initiatives in the context of sustainable development, takes the initiative to launch a sector inquiry into the waste management and recycling sectors, having recourse to the relevant possibility conferred by law to determine whether and to what extent competition is effective and to identify any practices that could harm consumer welfare and hinder innovation and competitiveness in Greece in this sector.
The HCC's Sector Inquiry will focus on the following:
- definition, delimitation and mapping of the relevant markets,
- assessment of any power existing in these relevant markets, as well as of the definition of the ecosystem created by the interdependence relations, structural relations and shareholding relations between the different market players,
- description of the parameters shaping the competition framework at horizontal and vertical level,
- assessment of the bargaining power in the relevant waste management and recycling sectors,
- assessment the appropriateness of competition law tools to address identified issues compared to sectoral legislation.
- PHASE A’: Public Consultation
You can assist the HCC’s work from the earliest stages of the sector inquiry into the waste management and recycling sectors. We kindly invite you to contribute to the public consultation by participating in the relevant teleconference that will be held by the HCC in November 2021 and/or by submitting your views and comments, in the form of written submissions to This email address is being protected from spambots. You need JavaScript enabled to view it..
- Participation in the teleconference
In November 2021, the Competition Commission will organise a conference on the waste management and recycling sectors, aimed to be the first forum with a view to hearing the positions of each stakeholder. Due to the unforeseen circumstances created by the coronavirus (Covid-19) pandemic, the relevant conference will be held online, in the form of a teleconference. Please express your interest in participating in the teleconference by sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it., by September 20, 2021. Please indicate in your message the name of the institution or company you are representing. The date of the teleconference will be announced at a later time. An invitation with details for the exact date and time of the teleconference, as well as for the way of the communication, will be sent to the participants in due course.
- Written Submissions
In addition to participation in the HCC’s teleconference, you are invited to submit your comments and observations in the form of written submissions by September 27, 2021. The HCC will process the collected submissions and will publish an anonymous summary table of issues raised through the above website, also giving you the opportunity to express your views at the specially designed conference or teleconference
If you wish your submission or any part of it to be treated as confidential, please make a relevant statement when submitting it.
Participation in the consultation is open to anyone who can provide useful information and comments on part or all of the issues that are the subject of this sector inquiry. We will greatly appreciate the participation of (amongst others):
- Undertakings that are active at all levels of operation and supervision in the waste management and recycling sectors
- Professional associations/federations of the sectors concerned
- Academics and researchers
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Sector Inquiry’s Timeframe
- July 2021 - Formal launch of the sector inquiry in the waste management and recycling sectors
- 8 November 2021 - First public consultation: publication of an invitation to any interested party to submit written observations and comments, as well as to express interest in participating in the teleconference with officials of the HCC
- February 2022 – Publication of the Interim Report
- April 202 2 – Second public consultation
- December 2022 – Publication of the Final Report
