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Legal Basis

For addressing the issue of REACH military exemptions, Greece has issued an official Legal Act (Bi-ministerial Decision 30458/30), which was published in the Greek Government’s Official Paper on January 26th 2010 (registered with the code 56B). This Legal Act is available from the Greek Government’s Official Paper website at, (right now only available in Greek). The Bi-ministerial Decision is between the Greek MoD and the Ministry of Economics (hereinafter abbreviated as MoE), due to the fact that the National Authority which has the right to grant REACH exemptions is the General Chemical State Laboratory (hereinafter abbreviated as GCSL) that falls under the jurisdiction of the MoE.

Sensing the growing importance of the issue, at pan-European level, the Hellenic Ministry of Defence has fully endorsed the EDA initiative of establishing a Code of Conduct (CoC) and thus harmonizing the granting Defence exemption procedure among the EU / EDA Member States. That was the key driver for joining the EDA Task Force Group, the tech expert’s sub-team which was formulated under the REACH EDA Working Group and addressed, as its prime task, the issue of conducting the CoC and making sure that this CoC was subsequently accepted, endorsed and transformed within each MS’ national legislation. For that specific reason a new Multi-Ministerial Decision – number F.900/1963/47526/ December 30th 2016 – signed by the Greek Ministers of Finance & Development, Fiscal Affairs and National Defence) was issued [Issue No 4573 of the Beta(B) Paper of the Official Journal of the Hellenic Government]. This Decision substitutes the existing Bi-ministerial Decision and makes the proper adjustments, in order to ensure the aligned performance of the Hellenic Armed Forces with the new provisions of the CoC, hence establishing the relevant technical and administrative requirements.

Description of National Procedure

The new Multi-Ministerial Decision has 8 Articles and an Annex.

Article No1, describes the general framework of the requirements in order to grant a defence exemption. In a nutshell, issuing a defence exemption is the “last resort” after examining and exploiting any other possibilities (mainly, substitution and authorisation).

Article No2 highlights the basic steps of the whole process (application, technical review of the dossier and final approval). In general terms, there are 2 cases: Either the applicant is the Ministry itself or the applicant is a legal entity (usually a Defence Industry). In both cases the final approval is granted by the REACH Competent Authority (GCSL), after the internal (within the Hellenic MoD) staffing procedure has taken place, a procedure which is supervised by the Department of Environment and Infrastructure in the first case (HMoD application) and the General Directorate of Defence Investments and Armaments in the second case (Defence Industry or another applicant).

Article 3 sets the framework for the periodic re-evaluation of the defence exemptions, already granted.

Description of National Safeguard Measures

The safeguard measures already described in the previous Ministerial Decision (existence of a Health & Management System in the Hellenic Armed Forces and the requirement of the provider for handing over to the MoD authorities, the relevant SDSs of the incoming chemical substances, mixtures and products within the MoD supply chain) continue to be valid, also in the new Decision.

Furthermore, the Annex of the new Decision is the exact endorsement of the Technical Dossier of the CoC requirements, concerning the tonnage, the classification for the levels of hazard, for the chemicals associated.

National Bodies Involved

As described in the previous templates, Hellenic MoD’s Environmental Protection Department is primarily responsible for conducting the required coordination of all the involved parties within the MoD. It is also responsible for conducting the coordination with the REACH National Regulatory Authority (GCSL), in the case of the HMoD acting as applicant. In all other cases, the coordination process between the applicant, the HMoD and the GCSL is performed by the relevant Agency of General Directorate of Defence Investments and Armaments.

Where to File an Application

This process is described in Article 2 of the new Decision (already analyzed in previous paragraphs).

Conditions/Procedures for Acknowledgment/Recognition of Foreign Defence Exemptions

Mutual acknowledgement procedure and respective requirements are described in Article 4 of the new Decision. The minimum requirements for such an act are the technical and administrative provisions described in the Annex of the Decision and are the exact content of the Technical Dossier of the CoC.

Number of Exemptions Granted

In Article 6 of the new Decision, it is clearly stated that the 63 different Defence exemptions, already granted through the previous Decision remain valid. Furthermore, these cases are subject to periodic review, according to Article 3 of the new Decision.

Contact Info

REACH POC in the Hellenic MoD : Lt. Col. Marios BONATSOS (EL Army)
E-mail :
General Directorate of Economic Planning and Support,
Directorate of Military and Technological Support,
Department of Infrastructure and Environmental Protection

Deputy REACH POC in the Hellenic MoD : Capt. Polyxeni (Jenny) TSAKALOU (EL Air Force)
E-mail :
General Directorate of Economic Planning and Support,
Directorate of Military and Technological Support,
Department of Infrastructure and Environmental Protection

REACH POC in the GCSL : e-mail address

Link to national web site(s) (if any)

Official website of the Greek MoD : or
Official website of the GCSL :


Last Update: 13 June 2019

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