The Club would like to draw Members’ attention to recent increases in fines for ship-source pollution under Greek Environmental Law. These increases, which are substantial, have been introduced via Presidential Decrees 113/2019 and 108/2019 to bring Greek environmental legislation in line with EU Directives 2005/35 and 2009/123. 

Details of the previous fines and of the new fines, which took effect on 1 January, 2020, are summarised in the table below. These fines apply to pollution incidents involving oil as well as other substances:

    Maximum fine prior to 31 December 2019 Maximum fine after 31 December 2019
A An everyday pollution not deemed to cause a serious detrimental impact on the marine environment. EUR 60,000 EUR 100,000
B A serious pollution. EUR 1,200,000 EUR 2,000,000
C Where the pollution has been caused deliberately to benefit the interests of a company or other legal entity, independently of A or B. EUR 500,000 EUR 800,000
D In the event of a continuing pollution, a fine for each day that over runs  the deadline set by the authorities for rehabilitation. EUR 8,000/day EUR 15,000/day

Note: While there is no definition of what constitutes a serious pollution incident for the purposes of A or B, it is anticipated that such an incident would include a pollution extending over a large area, one which has a detrimental effect on the marine environment and which potentially impacts the tourist industry.

We take this opportunity to remind Members of the 2020 tariffs for pollution fines in Turkey.

Members may additionally find the attached joint publication between the UK Club and the Nautical Institute, Risk Awareness – Pollution Claims – An aid to identification and loss reduction of interest.

If Members have any questions relating to this update, your usual contact at the Club will be pleased to assist you.


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