Product Liability and Safety_2026

GREECE Trends and Developments Contributed by: Dimitris Emvalomenos, Bahas, Gramatidis & Partners LLP

from a cultural standpoint. Also, the absence of a legal framework could raise issues of transparency. • However, following the transposition of the RAD and as of 26 June 2023, TPLF is specifically pro - hibited with respect to representative actions (new Article 10n of Law 2251). • On a related matter regarding the financing rules of QEs, the new regime introduced by Law 5019 as of 26 June 2023 widens the scope of the previous regime to include grants or concessions from the Greek state and limited dues collected from con - sumers wishing to be represented in a specific rep - resentative action seeking redress measures (new Articles 10c, paragraph 4 and 14, paragraphs 4d and 4e of Law 2251). Under the previous regime, the funding/income of consumer associations that could bring collective claims was regulated more restrictively (previous Article 10, paragraphs 6–8 of Law 2251). Increase in consumer rights Overall, there is an enduring trend towards increased and broader consumer rights, as well as sanctions for relevant breaches, including product liability breaches. Law 2251 has been amended several times within this framework, with key revisions as follows. • New provisions have been introduced as far back as 2007 and have covered: (a) expanding the defectiveness concept to include not only the standard safety considera - tion but to also take into account a product’s “expected performance per its specifications”; (b) including compensation for moral harm and mental distress within the ambit of strict prod - uct liability rules, since these were previously covered by general tort legislation; and (c) adding new rules on collective actions also relating to product liability infringements. • In 2012, the right to bring collective actions in Greece (under Law 2251) was extended to other EU member state entities authorised for this per the respective list provided for by Directive 2009/22/EC (repealed by the RAD). • In 2013 and 2015, changes were introduced with respect to the financing of consumer organisations, the sanctions that could be imposed for non-com -

pliance with the provisions of Law 2251 and the categorisation of complaints filed under such Law (previous Articles 10, 13a and 13b of Law 2251). • In 2018, Law 2251 was extensively revised and, with respect to product liability rules, material changes were made to the definition of “consum - er”, which was narrowed; the regulatory authorities and their enforcement duties; the funding of con - sumer associations; and administrative proceed - ings and sanctions imposed (Articles 1a.1, 7 and previous Articles 10, 13a and 13b of Law 2251). • Lastly, in 2022–2025, further changes were enact - ed, including significant modifications affecting product liability, such as: (a) the new legal framework on collective redress in force as from 26 June 2023; and (b) a new set of rules on compliance supervision, enforcement measures and sanctions (new Articles 10a–10r, 13a–13i and 14 of Law 2251). Alternative dispute resolution (ADR) – mediation The EU legislation on ADR of 2013 also changed Greece’s legal landscape. Specifically, Ministerial Decision 70330/30.6.2015 had implemented Direc - tive 2013/11/EU “on alternative dispute resolution for consumer disputes” (the “ADR Directive”) and set supplementary rules for the application of the Online Dispute Resolution Regulation (EU) 524/2013 (the “ODR Regulation”). The above EU ADR rules were revised recently as fol - lows: • the ODR Regulation was repealed by Regulation (EU) 2024/3228, which discontinued the European ODR platform with effect from 20 July 2025; and • the ADR Directive was amended by Directive (EU) 2025/2647 of 16 December 2025, requiring the EU member states to adopt the necessary transposi - tion measures by 20 March 2028 and apply them from 20 September 2028. The key changes introduced for the modernisation of the EU ADR rules are the broader scope of cov - ered disputes, the expansion of the ADR framework, the encouragement of traders’ participation through member states’ initiatives, and the decentralisation to national and sector-specific ADR bodies.

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