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Who Is Considered an Obligated Producer?
According to the legislation, an obligated producer is any entity that manufactures and/or imports and subsequently places on the Greek market products that fall under Electrical and Electronic Equipment (EEE), and is legally required to participate in an Producer Responsibility Organization (PRO), as well as to register in the National Producer Registry (NPR) of the Hellenic Recycling Agency (HRA).
More specifically, according to Joint Ministerial Decision 23615/651/E.103/2014, an “obligated producer” or simply “producer” is defined as:
“Any natural or legal person, regardless of the sales technique used—including distance selling, as defined in Article 2(1) of Ministerial Decision Z1-496/2000 (‘Distance Selling – Comparative Advertising – Adaptation of Law 2251/1994… to Directive 97/7/EC… etc.’ Government Gazette B’ 1545)—which:
- Is established in the country and manufactures EEE under its own name or trademark or commissions the design or manufacture of EEE, which it places on the market under its own name or trademark within Greek territory;
- Is established in the country and resells within Greek territory, under its own name or trademark, equipment produced by other suppliers—unless the producer's brand is indicated on the equipment, in which case the reseller is not considered a producer as per point i);
- Is established in the country and places EEE on the market professionally, imported from a third country or another EU member state; or
- Sells EEE in the country via distance selling directly to private households or to users other than private households, and is established in another EU member state or a third country.
Any entity that exclusively provides financing under or through a financing agreement is not considered a “producer,” unless it also acts as a producer under points i) to iv).”
Main Obligations of Photovoltaic Panel Producers:
The main obligations of photovoltaic panel producers are:
- Participation in a Producer Responsibility Organization (PRO) for photovoltaic panels.
- Registration in the National Producer Registry (NPR) and acquisition of a Producer Registry Number.
- Inclusion of the Producer Registry Number on tax documents and separate indication of the recycling fee on sales invoices (except invoices issued to the final consumer).
You can find instructions for registering as an Obligated Producer in the National Producer Registry (NPR) by using the link below.
FAQ
Who Is Considered an Obligated Producer?
According to the legislation, an obligated producer is any natural or legal person that manufactures, imports, or places Electrical and Electronic Equipment (EEE) on the Greek market.
Who Is Required to Participate in a Producer Responsibility Organization (PRO)?
Manufacturers, importers, resellers using their own brand name, and businesses placing products on the Greek market may be required to participate in an approved Producer Responsibility Organization (PRO).
Is Registration in the National Producer Registry (NPR) Mandatory?
Yes. Obligated producers must register in the National Producer Registry (NPR) and obtain a Producer Registry Number.
What Are the Main Obligations of a Photovoltaic Panel Producer?
The main obligations include participation in a Producer Responsibility Organization (PRO), registration in the National Producer Registry (NPR), and inclusion of the Producer Registry Number on the relevant documents.
Must the Producer Registry Number Be Included on Official Documents?
Yes. The Producer Registry Number must appear on tax documents in accordance with the applicable legal requirements.
What Happens If I Do Not Comply with My Obligations?
Failure to comply with the applicable legislation may result in administrative penalties and other consequences provided for under the current regulatory framework.
How Can PV REVIVE Help Me?
PV REVIVE supports obligated producers in fulfilling their legal obligations through participation in an approved Producer Responsibility Organization (PRO) for photovoltaic panels.