Producers' questions

1. What is EEE ?

Electrical and electronic equipment" or "EEE" means 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 falling under the categories set out in Annex II (JMD 23615/651/E.103)  and designed for use with a voltage rating not exceeding 1000 Volt for alternating current and 1500 Volt for direct current.


Εlectrical and Electronic Equipment is classified, according to European and Greek legislation, in the following distinct product categories:


1. Temperature exchange equipment (TEE) - EEE with internal circuits where substances other than water (e.g. gas, oil, refrigerant or a secondary fluid) are used for the purpose of cooling and/or heating and/or dehumidifying.


2. Screens and monitors >100cm2 - EEE intended to provide images and information on an electronic display. For example, equipment such as Laptops, Notebooks, are considered under category 2, but not equipment like washing machines, printers, even if they have a screen surface > 100 cm2, because their intended usage focus is not displaying information on a screen.


3. Lamps


4. Large equipment (any external dimension > 50 cm) - EEE that is not allocated to categories 1, 2 or 3. Any external dimension > 50 cm.


5. Small equipment (no external dimention >50cm) - EEE that is not allocated to categories 1, 2, 3, 4 or 6. No external dimension > 50 cm.


6. Small IT and telecommunication equipment (no external dimention >50cm) - EEE that is not allocated to categories 1, 2, 3, 4 or 5. Information equipment is equipment that can be used for collecting, transmitting, processing, storing and showing information. Telecommunication equipment is equipment designed to transmit signals (voice, video and data) electronically over a certain distance.


You can find here a detailed diagram of WEEE definition criteria.


2. What is the Alternative Management of WEEE?

Alternative Management of WEEE is the collection, receipt, transportation, temporary storage, reuse and recovery (recycling and energy recovery) of WEEE and/ or their components and subassemblies (including consumables), that after reuse or processing respectively return to the market.


3. Where arises the requirement for Alternative Management of WEEE?

Law 2939/2001 (Solid Waste Management & Producers responsibility).
Ministerial Decision 23615/651/E.103 that transposes the European directive 19/2012/EC to the Greek legislation.


4. How is the collection rate set out?

The european and the greek legislations lay down the following quantitative targets for collection and recovery of WEEE :

Until 31 December 2015 a collection target of at least 4 kilograms on average per inhabitant per year of WEEE from private households or the same amount of weight of WEEE as was collected in that Member State on average in the three preceding years, whichever is greater, shall apply.
However, from 2016 onwards the minimum collection rate shall be 45 %, calculated on the basis of the total weight of WEEE collected in a given year in the Member State concerned and expressed as a percentage of the average weight of EEE placed on the market in the three preceding years (2013-2014-2015) in that Member State. This means that from 2016 onwards a single minimum collection rate applies to the total amount of WEEE, both from private households and from users other than private households.


5.Who has the obligation to be registered?

Producers of Electrical and Electronic Equipment in accordance with EU Directives and the Greek legal framework required to arrange individual systems or engage in collective alternative management systems for WEEE relating to their activity (Article 17 of Law 2939/2001 and in accordance with specific terms under MD 23615/631/Ε.103). 

According to the law EEE Producer means any natural or legal person who, irrespective of the selling technique used, including distance communication:

  • is established in the country  and manufactures EEE under his own name or trademark, or has EEE designed or manufactured and markets it under his name or trademark within the territory of Greece;
  • is established in the country  and resells within the its territory, under his own 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
  • is established in the country and places on its market , on a professional basis, EEE from a third country or from another Member State; or
  • sells EEE by means of distance communication directly to private households or to users other than private households in the country, and is established in another Member State or in a third country.

If any natural or legal person commit an infringe, HRA is obliged to impose the article 6, 20 & 21 by law 3854/10, law 2939/01 and 23615/651/E.103 so as to impose criminal, civil and administrative penalties.


6. Producer Registration Number (PRN) /WEEE Number meaning

The Producer Registration Number of Electric and Electronic Equipment (EEE ) is an information system in which participate  all companies / producers that are  contracted with approved Systems for the Alternative Management of Waste Electrical and Electronic Equipment ( WEEE) .
 Ιn accordance with the current legislative framework distributors are obliged to distribute EEE only in the case that the producers of these products are registered in the producer’s register of HRA. Presupposition of the latter is, that they (the producers) are affiliated with an approved collective scheme for WEEE in Greece.
The criteria for the PRN to be granted are:

  • Affiliation with Appliances Recycling S.A. 
  • An application submission to the local WEEE Registry    


The producers are obliged to display their PRN on seals, invoices, delivery documents, etc. as a proof of compliance with the law.

7. How is the operation and the implementation of the System of Alternative Management of WEEE monitored?

Every three (3) years the HRA  proceeds to all necessary actions concerning the renewal of the approval of the System of Alternative Management of WEEE in order to find out whether the alternative management methods and aims are applicable.
In case of positive result, HRA grants the respective Certificate of Alternative Management of WEEE to the Scheme.

8. What is Appliances Recycling S.A.?

Appliances Recycling S.A. has been approved in June 2004 by the Minister of Environment Planning and Public Works (Ministerial Decision Number 105134/10.06.2004 - OFFICIAL JOURNAL OF THE HELLENIC REPUBLIC 905B/17.06.2004) to operate as Collective System for the Management of the Waste of Electrical and Electronic Equipment in Greece.

9. How Appliances Recycling S.A. will implement the project of the Alternative Management?

  • Appliances Recycling S.A. functions on a non-investment and non-profit basis, and has an organizational and controlling role.
  • Appliances Recycling S.A. has as primary aim to achieve national targets as they are defined by the European Union and the Greek Government. It also aims at controlling effectively the cost of the Alternative Management of WEEE.


10. How can EEE Producers adhere to Appliances Recycling S.A.?


  • Signing a contract with Appliances Recycling SA and submitting monthly periodic declaration with quantities of EEE (by product category) marketed in Greece
  • Paying the financial contribution to Appliances Recycling S.A.

11. What are the benefits for EEE Producers from their participation in Appliances Recycling S.A.?

Exemption from the fulfilment of obligations imposed by the Law 2939/2001 and  Ministerial Decision 23615/651 / E.103 on the Alternative Management of WEEE related to their activity.
The right to use the Symbol for the marking of Electrical and Electronic Equipment.

12. How is the confidentiality of EEE Producers' submitted data ensured ?

Appliances Recycling S.A. has developed an online application (Information System of Security & Confidentiality) which ensures the confidentiality of any data required for calculating the recycling fees regarding the EEE they put on the Greek market.

13. What does the cost of Alternative Management of WEEE include?

Total cost of the Alternative Management of WEEE includes individual costs:

  • Cost of collection, transportation and temporary storage of WEEE
  • Transportation cost to Treatment Centres
  • Processing cost of WEEE
  • Public awareness - information
  • Administrative cost of the System


14. Since when has the Alternative Management of WEEE in Greece been applicable?

Since 2004 when the Government Gazette of Presidential Decree 117/2004 was signed and published, harmonizing greek legislation with the european Directive 2002/96.

15. How is the recycling fee calculated for each type of product?

The financial contribution is calculated on:

  • Viability of Alternative Management System
  • Management costs that should be covered
  • Non - impact on competition between similar products
  • The basis of the monthly put on the market of each product category
  • Collection cost
  • De-pollution and treatment cost
  • Cost of removal of hazardous materials
  • Selling price of materials resulting from the treatment
  • Quantities of individual products to be handled and processed


16. Is the financial contribution incorporated to the product price?


The recycling fee is paid by EEE Producers of each product to Appliances Recycling S.A.
According to the Ministerial Decision (MD 112145, 24/12/2004), recycling fees (determined by the Alternative Management Systems) are shown separately on all invoices at all stages of the product's sale, except invoices to end- users.
As for the invoices and / or receipts of retail sales, the recycling fee is incorporated in the product price.

17. What are the obligations of EEE distributors?

Ιn accordance with the Ministerial Decision 23615/651/E.103 (article 6, paragraph 2.1.2), distributors are obliged to:

  • take back from end-users in one to one basis and free of charge, withdrawn equipment that is of equivalent type and has fulfilled the same functions as the supplied equipment
  • offer end-users, in retail stores with  EEE sale areas at least 400 m2 or very close to them, free of charge disposal of very small WEEE ( none of the external dimensions exceeding 25 cm) with no obligation to purchase relevant EEE. Then to deliver the WEEE to legitimate collectors – conveyors who cooperate with approved alternative management WEEE Systems
  • be affiliated with the approved WEEE collective System in Greece
  • distribute EEE only if the producers of these products are registered in the producer’s register of HRA


18. Does the Alternative Management of WEEE cover entire Greece?

  • Appliances Recycling SA is authorized to cover the entire Greek territory
  • Until now the System has achieved a coverage of over 90% of the national territory


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