The Greek National Climate Law (Law 4936/2022) is Greece’s key institutional framework towards achieving climate neutrality by 2050. Within this framework, Article 19 of the said Law introduces specific obligations for businesses and facilities with activities that hold Category A environmental licensing and are not covered by the European Union Emissions Trading System, known as the EU ETS.

For these businesses, compliance with the Greek National Climate Law is not limited to a mere formal submission of documents. On the contrary, it requires consistent accuracy in calculating their carbon footprint, documenting greenhouse gas emissions, preparing Compliance Reports, as well as designing impactful actions that drive emission reduction.

What Article 19 of the Greek National Climate Law mandates

Article 19 applies to specific categories of projects and activities that fall under Category A environmental permitting pursuant to Law 4014/2011 and are not included in the EU ETS. These businesses are required to monitor, calculate, and report the direct and indirect greenhouse gas emissions associated with their operations.

A central objective of the Greek National Climate Law is to reduce emissions by at least 30% by 2030, compared to the 2019 baseline year or, for newer activities, compared to their first full year of operation. This reduction is assessed on the basis of the appropriate product or project unit, depending on the type of activity.

Which businesses are affected by the Greek National Climate Law

Businesses that should immediately assess whether they fall under Article 19 are those holding an Environmental Terms Approval Decision, known in Greece as an AEPΟ, for Category A activities and that are not covered by the EU ETS. Indicatively, the main sectors affected include:

• Food and beverage industrial units
• Dairy industries and cheese production facilities
• Wineries and bottling facilities
• Plastics and packaging manufacturing units
• Waste management and recycling units
• Logistics centers and storage facilities
• Quarries and extractive activities
• Chemical product industries
• Large-scale hospitality units and tourism complexes

For each business, a standalone technical review is required, covering its environmental permit, its activity, and its potential inclusion under the provisions of the Greek National Climate Law. Several of those businesses opt for a custom consultation on sustainability, tailored to their own legal requirements.

Which professionals need to take action

Compliance with the Greek National Climate Law concerns multiple levels of management and operations. It is not solely the responsibility of the environmental department, as it is directly linked to production, operations, compliance, ESG, and business development strategy. Some of the key decision makers who need to take action include the following roles:

• Environmental Managers
• HSE Managers
• ESG and Sustainability Managers
• Compliance Managers
• Technical Directors
• Plant Managers
• CEOs and General Managers of small and medium-sized industrial companies

The timely involvement of the aforementioned professionals is critical, as compliance requires extensive data collection, accurate verification of relevant information, and strategic planning of emission reduction actions.

Key compliance deadlines

The Greek National Climate Law sets specific deadlines for businesses required to abide by its regulations. For existing projects and activities, the initial Compliance Report had to be submitted by January 1, 2026, together with the required emissions documentation.

Thereafter, from 2026 onwards and for each subsequent year, obligated entities must submit an annual report of verified emissions for the previous year, by the deadline of October 31st. Meeting the deadlines is essential, as delays or incomplete compliance may lead to administrative sanctions and financial penalties.

Why carbon footprint calculation is essential

Carbon footprint calculation and reporting is the foundation of every compliance action under the Greek National Climate Law. Through this process, businesses will gain a clearer view of the emissions generated by their operations, including those related to fuel consumption, electricity usage, raw materials, transport, and other relevant segments.

Accurate emission mapping enables each business to identify the most significant areas of environmental impact, prioritizing relevant reduction activities, and documenting its legal compliance in the most reliable and verifiable way.

From legal compliance to competitive advantage

The National Climate Law –and Article 19 in particular– creates a new framework of responsibility for businesses with a significant environmental footprint. Compliance with its requirements should not be viewed solely as a legal obligation. Instead, it can become a valuable tool for improving a company’s operations, competitiveness, and visibility.

Businesses that organize their data early on and adopt emission reduction plans can achieve better energy efficiency, reduce operating costs, strengthen their profile in relation to Environmental, Social, and Governance criteria, and respond more effectively to the requirements of customers, financial institutions, and partners.

How Ecostart S.A. can support your business

Ecostart S.A. supports businesses that fall, or may fall, under Article 19 of the National Climate Law, offering integrated technical and environmental compliance services for companies operating both in Greece and abroad. Our services include:

• Assessment of applicability under Article 19 of Law 4936/2022
• Carbon footprint calculation
• Preparation of Compliance Reports
• Preparation of verified emissions reports
• Design of Emission Reduction Plans
• Support in accordance with ISO 14064-1 and GHG Protocol
• ESG and Sustainability Reporting
• Collaboration with accredited verification bodies and support throughout the verification process
• Support throughout the submission of the report to the competent authority (the Electronic Waste Registry – E.W.R. or N.E.C.C.A.)

With specialized technical expertise and extensive experience in environmental and sustainability issues, Ecostart S.A. can help your business respond to the requirements of the National Climate Law in a timely and effective manner, turning legal compliance into an organized and meaningful process of environmental improvement.