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GREECE

 

Legal Basis

 

With regard to defence exemption provision of Regulation (EC) No 1907/2006 (REACH Regulation), the Greek Government has issued an official Legal Act (Joint-Ministerial Decision 30458/40), which was published in the Greek Government’s Official Journal on January 26th 2010 (registered with the code 56Β΄). This Legal Act is available at the Greek Government’s Official Journal website (www.et.gr, available only in Greek). The Joint-Ministerial Decision signed by the Greek MoD and the Ministry of Finance (MoF), due to the fact that the National Authority for granting REACH exemptions is the Directorate General of the General Chemical State Laboratory (GCSL) of the Independent Authority of Public Revenue (IAPR) that falls under the jurisdiction of the MoF.

 

Due to 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 Defence exemption procedure among the EU/EDA Member States. This CoC was subsequently accepted, endorsed and transformed within each MS’ national legislation. For that specific reason, a new Multi-Ministerial Decision – number Φ.900/1963/47526/Σ.1719/December 30th 2016 – signed by the Greek Ministers of Finance, Development and Investments and National Defence) was published [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. Furthermore, in the scope of simplifying the procedures for granting exemptions a modification of the previous decision (Φ.900/1963/47526/Σ.1719/30-12-2016) was published on the Official Journal of the Hellenic Government on Aug 26th 2021 [Decision Φ.900/34/88143/Σ.15034 (Issue No Β΄3943)].

 

Description of National Procedure

 

The core Multi-Ministerial Decision of 2016 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 Infrastructure of the Hellenic MoD.

 

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 2010 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 2016 and 2021 Decision.

 

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

 

National Bodies Involved

 

As described, Hellenic MoD’s Department of Infrastructure is primarily responsible for conducting the required coordination of all the involved parties within the EL MoD. It is also responsible for conducting the coordination with the REACH National Regulatory Authority (DG of General Chemical State Laboratory of the Independent Authority of Public Revenue – GCSL/IAPR).

 

Where to File an Application

 

This process is described in Article 2 of the 2016 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 Decision. The minimum requirements for acknowledging another member state’s exemptions 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

 

A number of exemptions (for the use of 49 substances) have been already granted to the Greek Defence Industry, since 2010. These exemptions have been reviewed and will be valid for the next 4 years, at minimum. Furthermore, exemptions for more substances used by the Hellenic Armed Forces are expected to be granted within 2021 and will be valid also for the next 4 years.

 

Contact Info

 

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

 

Deputy REACH POC in the Hellenic MoD : Lt (HAF) Konstantina PAPADIMITRIOU (EL Air Force)
E-mail : kpapadimitriou@mod.mil.gr
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 : environment.gcsl@aade.gr

 

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

 Official website of the Greek MoD : www.mod.mil.gr and www.greenarmedforces.gr

Official website of the GCSL : www.aade.gr/gcsl

 

 

 

Last Update: 23 November 2021

 

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