Advertising and Marketing 2024 Comparisons

Primary Laws

The main statutes that govern advertising practices in Greece are:

• Law No 2251/1994 on Consumer Protection (which has transposed EU Directives on consumer protection into Greek law), as recently amended by Law No 5111/2024;
• Law No 146/1914 on Unfair Competition, regulating illegal advertising in B2B relationships; and
• Law No 4779/2021 regulating advertising through audiovisual media (which has transposed the EU Audiovisual Media Services Directive into Greek law).

Other laws may also have an impact on specific advertising practices, such as Law No 2121/1993 on Copyright, Law No 4679/2020 on Trademarks and the laws for the protection of personal data, namely Regulation EU 2016/679 (GDPR), Law No 4624/2019 (implementing certain provisions of the GDPR) and Law No 3471/2006 (which has transposed the E-Privacy Directive into Greek law).

Specific Provisions

The above primary statutes are supplemented by a great number of special provisions that regulate the advertising of specific products and services (tobacco, alcohol, medicines, credit products, gambling services, etc).

Self-Regulation

The main regulatory tool for the self-regulation of advertising is the Hellenic Code of Advertising and Communication Practice (HCACP), the structure and content of which are almost identical to the ICC Consolidated Code of Advertising and Communication Practice. The HCACP covers both non-broadcast and broadcast advertising, including online advertising and social media.

Main Regulatory Authorities

The main regulatory authorities that enforce advertising laws in Greece are as follows.

• The Ministry of Development and Investments through the General Secretariat for Consumers is the state authority that imposes administrative sanctions on those who infringe the consumer protection legislation. If the state authority intervenes, either ex officio or following a complaint, it may address a recommendation or impose a monetary fine ranging from EUR5,000 to EUR1.5 million. Sanctions may be stricter for repeat infringers.
• The Greek National Council for Radio and Television (NCRTV) is an independent administrative authority that monitors compliance with the specific regulations of advertising in audiovisual media, and is empowered to impose sanctions for infringement, such as addressing a recommendation or imposing monetary fines, as follows:
1. the fine for an infringing TV channel ranges from EUR14,673 to EUR1,467,351;
2. the fine for radio stations ranges from EUR2,935 to EUR29,350; and
3. the fine for video-sharing platforms ranges from EUR1,000 to EUR500,000).

Other Authorities

With regard to more specific legislation containing advertising regulations, other authorities may also be charged with enforcement, such as:

• the Hellenic Organisation for Medicines regarding the advertising of medicines/medical devices/nutritional supplements;
• the Ministry of Agricultural Development and Food through the Hellenic Food Authority regarding the advertising of food products;
• the Hellenic Capital Market Commission regarding the marketing communications of investment products;
• the Hellenic Gaming Commission regarding the commercial communication of gambling services; and
• the Municipal and Regional Health Services regarding the advertising of tobacco products.

In principle, advertisers have the overall responsibility for the advertisements they provide and may be held liable if they violate advertising laws and regulations on misleading advertising. Anyone taking part in the planning, creation or execution of a misleading advertisement may also have a degree of responsibility. Under Greek law, the audiovisual media owners can also be held accountable if the infringing advertisements have been broadcast through their media.

Under the Greek Consumer Protection Law, the definition of advertising is very broad: “advertising” means the making of a representation in any form in connection with a trade, business, craft or profession in order to promote the supply of goods or services, including immovable property, rights and obligations.

Pre-clearance of advertisements by the government or sector-specific authorities is not obligatory in Greece, with some exceptions.

• Firstly, the advertising of vaccination campaigns must be submitted to the Hellenic Organisation for Medicines for monitoring before publication or broadcast.
• Television advertisements for plant protection products (pesticides) must also be submitted to the competent Directorate of the Ministry of Agricultural Development and Food prior to their broadcasting.
• Every commercial communication for gambling services must be submitted to the Hellenic Gaming Commission for prior approval.

Intellectual/Industrial Property Rights

If the advertiser wishes to use the intellectual and/or industrial property of a third party (either individual or legal entity) in a marketing communication, this is permissible only if the legitimate right holder of the copyright, trade mark, logo, etc, has given its written consent.

Publicity Rights

Under Greek legal theory and jurisprudence, a publicity right has two aspects:

• a positive one, permitting the person to commercially exploit (namely to license) aspects of its identity; and
• a negative one, entitling the person to forbid any unauthorised commercial use of its name, image, voice, likeness, etc.

The basic rule is that marketing communications should not portray or refer to any persons, whether in a private or a public capacity, unless prior permission has been obtained. Advertisers must be aware that the content of publicity rights is very broad in Greece, and that they are afforded to everyone (not only to famous people). The publicity right is protected under the provisions of Articles 57–59 of the Greek Civil Code, which also serve to protect the personality right.

In Greece, the national system of advertising self-regulation is mainly handled by an independent non-profit association called the Advertising Self-Regulation Council (SEE). The SEE was created in 2003 by the Hellenic Association of Advertising and Communication Agencies (EDEE) and the Hellenic Advertisers Association (SDE), which means that the major advertising agencies and advertisers are part of the self-regulatory system. The SEE is a member of the European Advertising Standards Alliance (EASA).

The SEE may be activated either after an ex officio monitoring or after the submission of a written complaint. Consumers and competitors alike are entitled to file complaints claiming that a marketing communication (printed or broadcast) breaches the HCACP.

If a complaint is upheld, the SEE committee of first instance may address a recommendation for the cessation or modification of the advertisement. This recommendation is immediately binding for the parties and enforceable, although there is a right to an appeal before the committee of second instance. If the infringer fails to comply with the recommendation or unjustifiably delays compliance, the SEE can enforce the adjudication by requesting in writing that all media immediately interrupt the broadcasting or publication of the advertisement in question. If the infringer remains unco-operative, the SEE may issue an “ad-alert”, warning the whole advertising market of the infringer’s activities.

In the case of a commercial communication that constitutes an unfair commercial practice (eg, misleading or aggressive), the Greek Consumer Protection Law permits any consumer and/or any consumer association to:

• request the court to issue a cease-and-desist order;
• request compensation for the material and/or moral damages suffered by reason of the unfair commercial practice;
• demand, where relevant, a price reduction or the termination of the contract that was concluded as a result of the unfair commercial practice; and
• demand that the court judgment is published to the media and/or that a corrective advertisement is published.

Consumers and/or consumer associations may also file a complaint to the SEE challenging an advertisement for violating the self-regulatory code (HCACP). The filing of a complaint to the SEE does not exclude the possibility of also taking legal action before the court.

Finally, in cases of illegal commercial practices, consumers may address a complaint to the Hellenic Consumers’ Ombudsman, which is an independent authority of extrajudicial dispute resolution in the area of consumer disputes.

Consumers’ Collective Action

Consumer associations that have been registered in the consumer associations’ registry for more than a year are entitled to file a class action for the protection of collective interests of consumers. With regard to class actions, the remedies include:

• a provisional or definitive measure to cease or prohibit an illegal market practice; and
• a request that the consumers concerned are provided with compensation, repair, replacement, price reduction, contract termination or reimbursement of the price paid.

The most important legal trends in the past 12 months have been:

• the entry into force of Law No 5111/2024 regarding marketing communications of price reductions and the publication of a new “Code of Conduct for Communications of Price Reductions” – see 7.4 Free and Reduced-Price Offers; and
• the addition of Annex IX to the HCACP regarding influencer marketing (based on EASA’s Best Practice Recommendation on Influencer Marketing) – see 5.1 Special Rules/Regulations on Influencer Campaigns.

Advertisers should keep in mind that LGBTQ+ representation is not very common in Greek advertisements, even though it seems to be increasing. In very recent years there have been some gay couples and LGBTQ+ people appearing in a few advertising campaigns. Many people and organisations have applauded these campaigns for their progressive social stance and for accurately representing LGBTQ+ people. At the same time, some people also expressed extremely negative opinions because they stand against LGBTQ+ representation in media and advertising.

Religion is another “sensitive” issue for a significant part of the Greek audience, since the Greek Orthodox Church has a strong presence; therefore, religious advertising is not common.

No changes in the political climate or administration have impacted the regulation of advertising and/or the enforcement of advertising regulations.

Misleading Commercial Practices in General

The Greek Consumer Protection Law prohibits misleading commercial practices (through either action or omission). This prohibition covers misleading advertising practices and claims.

Misleading Acts

According to the general clause provided in Article 9c of the Consumer Protection Law, a commercial practice (eg, an advertisement) should be considered as misleading if it contains inaccurate information or is in any way, including by its overall presentation, likely to deceive the consumers in relation to one or more of the elements mentioned below and is likely to cause them to make a transactional decision that they would not otherwise have made:

• the existence or nature of the product;
• the main characteristics of the product, such as its availability, benefits, risks, execution, composition, accessories, after sale customer assistance and complaint handling, method and date of manufacture or provision, delivery, fitness for purpose, usage, quantity, specification, geographical or commercial origin, the results to be expected from its use, or the results and material features of tests or checks carried out on the product;
• the extent of the trader’s commitments, the motives for the commercial practice and the nature of the sales process, and any statement or symbol in relation to direct or indirect sponsorship or approval of the trader or the product;
• the price or the manner in which the price is calculated, or the existence of a specific price advantage;
• the need for a service, part, replacement or repair;
• the nature, attributes and rights of the trader or their agent, such as their identity and assets, qualifications, status, approval, affiliation or connection and ownership of industrial, commercial or intellectual property rights, or awards and distinctions; and
• the consumer’s rights.

Misleading Omissions

An advertisement shall also be regarded as misleading if, taking account of all its features and circumstances and the limitations of the communication medium, it omits material information that the average consumer needs, according to the context, to make an informed transactional decision and thereby causes or is likely to cause the consumer to take a transactional decision that they would not otherwise have taken.

Blacklist of Misleading Practices

The above general clauses on misleading acts and omissions are supplemented by a blacklist of 23 commercial practices that are considered misleading under all circumstances, including particular advertising practices and claims (eg, falsely claiming that a product will only be available for a very limited time in order to make the consumer decide immediately, or falsely claiming that a product can cure diseases, defects or malformations).

Aggressive Commercial Practices

Similar to the rules on misleading commercial practices, the Greek Consumer Protection Law also includes a general clause prohibiting aggressive commercial practices, supplemented by a blacklist of eight commercial practices that are considered aggressive (eg, creating the false impression that the consumer has already won, will win or upon doing a particular act will win a prize or gain other equivalent benefit when in fact the possibility to claim the prize or such equivalent benefit is subject to the consumer paying money or incurs a cost).

All objective (verifiable) advertising claims, either express or implied, must be substantiated and are subject to regulation. However, there is an exception for claims or statements that obviously exaggerate (puffery).

Greek law does not define the criteria under which puffery is distinguished from those advertising claims that require substantiation, but some guidance on this issue can be found in the Best Practice Recommendation on claims substantiation (the Recommendation) issued by the SEE. According to the Recommendation, advertising claims which can be verified and which the average consumer is likely to regard as objective require substantiation. On the contrary, puffery is a claim that the average consumer cannot treat seriously. An example of this difference is provided in the Recommendation: the claim that a glass cleaning liquid is “the most economic in its category” is verifiable and requires substantiation, while the claim that “it makes glass invisible” is obvious puffery.

The type of proof required to support objective (verifiable) advertising claims depends on the type of advertising claim and the characteristics of the advertised product. The Recommendation issued by the SEE (see 2.2 Regulation of Advertising Claims) indicatively stipulates the following means of proof:

• statistical surveys;
• market shares;
• sales data;
• certificates/accreditations from the competent public authorities; and
• scientific studies and testimonials.

According to the same Recommendation, the advertiser has the burden to prove the truth/accuracy of the advertising claim; therefore, before publishing or broadcasting an advertisement, the advertiser must have evidence available in order to substantiate the objective (verifiable) advertising claims. According to Article 6 of the HCACP, such substantiation should be available without delay and upon request of the SEE Committee, which will examine any complaint challenging the advertisement.

No special standards apply to the use of product demonstrations in advertising. In the framework of the general rule of truthful advertising, any such demonstration must present the actual qualities of the advertised product without exaggerating its performance. In light of this, it is advisable that the demonstration is performed with samples of the product already available to consumers (or prototypes that perform no differently than the actual product); no mock-ups, modifications or alterations should be employed.

With regard to demonstrations of cosmetics’ performance, specific guidance is provided by the Guiding Principles on Responsible Advertising and Marketing Communication of Cosmetics issued by Cosmetics Europe.

Under Greek law, the use of endorsements and testimonials in advertising is permitted in principle, with the exception of over-the-counter medicines. There are also certain restrictions in relation to endorsements of food supplements.

Marketing communications should not contain or refer to any testimonial or endorsement unless it is genuine, verifiable and authorised by the person making the endorsement. Any claim that a trader or product has been approved, endorsed or authorised by a public authority or private body, when it actually has not, is forbidden as this is considered a misleading advertising practice (Article 9f of the Consumer Protection Law). Testimonials or endorsements that have become obsolete or misleading through the passage of time should not be used.

Finally, according to the Recommendation of the SEE, testimonials themselves are not considered substantiation, and impartial evidence is required.

Specific industries are obliged by law to include warning messages and other disclosures in their marketing communications (eg, advertisements of over-the-counter medicines, food supplements, gambling services and credit and investment products).

Disclosures voluntarily used by advertisers (disclaimers, footnotes, etc) are permitted to the extent that they do not mislead the average consumer. They are used to clarify the advertising claim and must not contradict or alter the general impression created by the main body of the advertisement.

Another important rule is that the disclosures and any other superimposed text in advertising should be legible. To this end, the SEE has issued a Best Practice Guide relating to the size and timing of the superimposed text in audiovisual marketing communications.

The basic principle relating to the issues of inclusion and diversity in advertising is that marketing communications should respect human dignity and should not incite or condone any form of discrimination, including that based upon ethnic or national origin, religion, gender, age, disability or sexual orientation (Article 2a of the HCACP).

In relation to audiovisual marketing communications, Law No 4779/2021 (incorporating Directive EU 2010/13 as amended by Directive EU 2018/1808) prohibits any incitement to violence or hatred based on people’s race, skin colour, ethnic or national origin, genetic features, religion, disability, sexual orientation, gender identity or gender characteristics (Article 8 of Law No 4779/2021). In addition, video-sharing platforms that fall under the Greek jurisdiction should take appropriate measures against content and audiovisual marketing communications that contain such incitement to violence or hatred (Article 32 of Law No 4779/2021).

Advertisers should be aware that female stereotyping in advertising is not appreciated by Greek society; advertisements may be monitored by a regulatory authority or the SEE for offending the dignity of women.

There are currently no Greek laws dealing specifically with environmental claims in advertising, with the exception of a special law that forbids the use of the term “ecologic” or “eco” in the packaging and advertising of products unless such products have been granted the EU Ecolabel (according to EC Regulation No 66/2010).

In the field of advertising self-regulation, Chapter D of the HCACP is dedicated to environmental claims in advertising, and introduces the following basic principles.

• Marketing communications should not contain any statement or visual treatment that is likely to mislead consumers in any way about the environmental aspects or advantages of products, or about actions being taken by the marketer in favour of the environment. Examples include overstatement of environmental attributes, such as highlighting a marginal improvement as a major gain, or the use of statistics in a misleading way (“we have doubled the recycled content of our product” when there was only a small percentage to begin with).
• Vague or non-specific claims of environmental benefit, which may convey a range of meanings to consumers, should be made only if they are valid, without qualification, in all reasonably foreseeable circumstances. If this is not the case, general environmental claims should be either qualified or avoided. In particular, claims such as “environmentally friendly”, “ecologically safe”, “green”, “sustainable” or “carbon-friendly”, or any other claim implying that a product or an activity has no impact – or only a positive impact – on the environment, should not be used without qualification, unless a very high standard of proof is available. As long as there are no definitive, generally accepted methods for measuring sustainability or confirming its accomplishment, no claim to have achieved it should be made.
• Marketing communications should use technical demonstrations or scientific findings about environmental impact only when they are backed by reliable scientific evidence.

Consumer Protection Legislation

Depending on the circumstances, “dark patterns” or “deceptive design patterns” may constitute infringements of consumer protection legislation (in particular, Greek Law 2251/1994), which expressly prohibits unfair commercial practices, including misleading and aggressive practices (see 2.1 Deceptive or Misleading Claims). For example, a design that – by “hiding” certain information – leads consumers to believe that a service can be provided with a single payment, but, in fact, more payments are later needed in order to continue using the service, may constitute a misleading practice. Another example is a design that falsely states that a product will only be available for a very limited period of time, so that consumers are “pushed” to make a quick decision instead of an informed choice, which would constitute a misleading practice expressly prohibited in Article 9f of Law 2251/1994.

Data Protection Legislation

Dark patterns may also violate data protection rules, particularly the GDPR, which is directly enforceable in Greece. More specifically, depending on the case, dark patterns may violate privacy rules, such as fulfilling the conditions for legitimately obtaining a user’s informed consent for data processing, as well as the privacy-by-design and privacy-by-default principles. In this context, the European Data Protection Board (EDPB) has also adopted Guidelines 03/2022 (dated 14 February 2023) on deceptive design patterns in social media platform interfaces.

Digital Services Act

For cases not covered by legislation on consumer protection or data protection, Article 25(1) of the Digital Services Act (DSA – EU Regulation 2022/2065) expressly sets a “ban” on dark patterns, by prohibiting online platforms from designing, organising or operating their online interfaces in a way that deceives, manipulates or otherwise materially distorts or impairs users' ability to make free and informed choices.

Recital 67 of the DSA mentions that online “dark patterns” may include, indicatively:

• giving more prominence to certain choices when users are asked to make a decision;
• repeatedly requesting users to make a choice even though the choice has already been made by the users; and
• making the process for cancelling a service significantly more difficult than subscribing to it, etc.

As per Article 25(3) of the DSA, the European Commission may issue guidelines on specific practices that constitute dark patterns, in which case these guidelines are expected to be followed in Greece as well.

Greek laws and the HCACP set out some basic principles regarding advertising to children, such as:

• products that it is illegal for children or teens to purchase or that are unsuitable for them should not be advertised in media targeted to them (eg, tobacco, alcohol or gambling services);
• marketing communications should not contain any statement or visual treatment that could have the effect of harming children or teens mentally, morally or physically; and
• children and teens should not be portrayed in unsafe situations or engaging in actions harmful to themselves or others, nor be encouraged to engage in potentially hazardous activities or inappropriate behaviour.

Advertising self-regulation also deals with the issue of food and beverage advertisements to children. The “Greek Pledge” is a voluntary initiative by of the Federation of Hellenic Food Industries to improve the way such products are advertised to children under 13 years of age, aiming to tackle childhood obesity and non-communicable diseases. It was developed in the context of the “EU Pledge”, and has identical commitments.

To be specific, Greek Pledge members have committed:

• not to advertise food and beverages to children under 13 years, except for products that fulfil the common nutrition criteria of the EU Pledge; and
• not to engage in food and beverage advertising in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.

Audiovisual Marketing Communications Addressed to Children

Specific rules apply in relation to audiovisual marketing communications addressed to children. According to Article 14 of Law No 4779/2021, these communications should not:

• directly induce minors to buy or hire a product or service by exploiting their inexperience or credulity;
• encourage them to persuade their parents or others to purchase the goods or services being advertised;
• exploit the special trust minors place in parents, teachers or other persons; and
• unreasonably portray minors in dangerous situations.

It is forbidden to advertise toys on TV from 07.00 to 22.00 hours, and war toys may not be advertised at any time.

The basic rules related to sponsor identification and branded content are as follows:

• marketing communications should be clearly distinguishable as such, whatever their form and whatever the medium used; and
• the identity of the advertiser should be transparent – where appropriate, marketing communications should include contact information to enable the consumer to get in touch with the advertiser without difficulty.

In the field of digital marketing communications, advertisers should take appropriate steps to ensure that the commercial nature of the content of a social network site or profile under the control or influence of an advertiser is clearly indicated and that the rules and standards of acceptable commercial behaviour in these networks are respected.

Hidden marketing communications are specifically prohibited in audiovisual media, according to the provisions of Article 14(1)(a) of Law No 4779/2021.

Claims Regarding Geographic Origin

Advertising that includes misleading information regarding the geographic origin of a product is specifically prohibited by the Law on Consumer Protection (Article 9d of Law 2251/1994) and by the legislation on Unfair Competition (Articles 3–4 of Law 146/1914).

“Free/Without Charge”

The claim that something is offered for free/without charge (or similar expressions) is permissible only if the consumer does not have to pay anything other than the unavoidable cost of responding to the commercial practice and of collecting or paying for delivery of the item (Article 9f of the Consumer Protection Law). Advertising a product as being offered for free if another one is purchased (“buy one, get one free”) is accepted only if the consumer will pay nothing for the one item and no more than the regular price for the other.

Comparative advertising is permissible under Greek law (Article 9 paragraph 2 of Law No 2251/1994 on Consumer Protection), provided that the following conditions are met:

• it is not misleading;
• it objectively compares one or more material, relevant, verifiable and representative features of those goods and services, which may include price;
• it compares goods or services meeting the same needs or intended for the same purpose; and
• for products with designation of origin, it relates in each case to products with the same designation.

If the name/trade mark of a competitor is used in the course of comparative advertising, additional restrictions apply (see 3.2 Competitor Copyrights and Trade Marks).

Identifying a competitor by its name or by its trade mark/packaging in the course of comparative advertising is permitted in Greece, provided that any such advertisement does not:

• discredit or denigrate the trade marks, trade names, other distinguishing marks, goods, services, activities or circumstances of a competitor;
• take unfair advantage of the reputation of a trade mark, trade name or other distinguishing marks of a competitor or of the designation of origin of competing products;
• create confusion between the advertiser and a competitor or between the advertiser’s trade marks, trade names, other distinguishing marks, goods or services and those of a competitor; or
• present goods or services as imitations or replicas of goods or services bearing a protected trade mark or trade name.

If the comparative claims made by a competitor are illegal (ie, they infringe the rules mentioned in 3.1 Specific Rules or Restrictions and 3.2 Competitor Copyrights and Trade Marks), the advertiser who is directly affected by the claims may initiate court action to challenge them. In such cases, the advertiser may request that the court:

• issues a cease-and-desist order;
• orders that the court judgment is published to the media and/or that a corrective advertisement is published; and
• awards material damages (including loss of profit) and/or moral damages.

Alternatively to court proceedings, the advertiser may follow the route of advertising self-regulation. In such case, a complaint may be filed with the SEE, requesting the comparative claims to be checked for compliance with the HCACP.

Greek legislation does not include any legal provisions prohibiting or dealing specifically with ambush marketing, with the exception of the special legislation relating to the Olympic Games (Law No 2598/1998 as amended), which protects the Olympic symbol (Olympic Rings) and the term “Olympic” from any unauthorised use.

An official sponsor that is affected by ambush marketing may raise a claim against the offender, relying primarily on the provisions of Law No 146/1914 on Unfair Competition and perhaps those of trade mark law (if there is also a trade mark infringement).

In cases of ambush marketing activity that involves misleading advertising practices (eg, a false claim that a product has been approved or authorised by a public or private body), Law No 2251/1994 on Consumer Protection may also be invoked.

At a self-regulatory level, the HCACP prohibits the ambushing of sponsored properties (Chapter B, Sponsorships, Article B4).

All Advertisements and Advertisers Should Be Clearly Identifiable

A basic principle in Greek advertising law, which is especially applicable in the field of online and social media advertising, is that all advertisements should be clearly identifiable as such. The identity of the advertised entity should also be clear in all marketing communications.

This is specifically stipulated with regard to online commercial communications in Article 5 of Presidential Decree 131/2003, which transposed Article 6 of Directive 2000/31/EC (e-Commerce Directive) into Greek law.

In the field of self-regulation, Articles 7 and 8 of the HCACP (see 1.1 Primary Laws and Regulation and 1.7 Self-Regulatory Authorities) also set the basic rules that all advertising communications should be clearly identifiable as such, whatever their form and whatever the medium used, and that the identity of the promoter should be visible to the consumers.

Digital Services Act

The DSA shall be directly enforceable in Greece and also sets out rules in relation to advertising on online platforms, according to which:

• online platforms shall clearly and unambiguously label all advertisements as such, and shall let the users know who the advertised entity is and who paid for the advertisement;
• online platforms shall let users/promoters declare whether the content they provide is or contains commercial communications, and when a user submits such a declaration, the platform shall ensure that other users can clearly and unambiguously identify that such content is or contains commercial communications;
• online platforms shall inform the users about the parameters based on which they are presented with a specific advertisement and, where applicable, about how the users may change these parameters; and
• targeted advertising based on profiling that uses special categories of personal data (racial or ethnic origin, political opinions, religion, sexual orientation, etc) is banned, as is targeted advertising based on profiling of minors.

Other Laws

Advertising in online or social media in Greece is also governed by all laws applicable to advertising in general (see 1.1 Primary Laws and Regulation) – ie, mainly the Greek Consumer Protection Law, which prohibits unfair commercial practices, as well as the laws on data protection, intellectual and industrial property, unfair competition, prohibition of defamation, etc.

Generally, all rules mentioned in 1. Legal Framework and Regulatory Bodies, 2. Advertising Claims and 3. Comparative Advertising and Ambush Marketing are applicable to advertising in social/digital media as well.

In addition, the advertising of specific products in online and social media may fall under certain restrictions and prohibitions, as described under 10.1 Regulated Products.

Self-Regulation

Self-regulatory rules (see 1.7 Self-Regulatory Authorities) are also directly applicable to advertising in online and social media. Advertisers should always comply with the general principles of legal, decent, honest, truthful, non-defamatory and socially responsible advertising.

The HCACP contains a special set of rules (HCACP Chapter C) on Direct Marketing and Digital Marketing Communications, which is applicable to social media advertising. The SEE has also published a Digital Marketing Best Practice Guide based on EASA’s Digital Marketing Communications Best Practice Recommendation.

It is worth noting that in all of the SEE’s decisions regarding any disputed marketing communication, it is always mentioned that its rulings are valid and applicable to all media where each disputed advertising content is present, including in all digital media and social media channels of the promoter.

User Generated Content (UGC) such as comments, posts, photos, videos, podcasts, etc, created by independent internet users that has not been commissioned, distributed or later approved or adopted by the advertiser would not, in principle, be considered to be a marketing communication of the advertiser. The Digital Marketing Best Practice Guide issued by the SEE also stipulates that independent UGC is normally (unless certain conditions are met) beyond the scope of advertising self-regulation.

Under Article 6 of the DSA (and also under the similar regime of Article 13 of Presidential Decree 131/2003, which transposed Article 14 of the E-Commerce Directive), a service provider, such as an advertiser who hosts websites or social media channels, would, in principle, not be held liable for content posted by others (UGC), provided that the service provider:

• does not have actual knowledge of illegal activity or illegal content and, as regards claims for damages, is not aware of facts or circumstances from which the illegal activity or illegal content is apparent; or
• upon obtaining such knowledge or awareness, acts expeditiously to remove or to disable access to the illegal content.

If the above conditions are not met (eg, if the promoter does not act to remove illegal third-party content on its own channel upon becoming aware of it), then the advertiser could be held liable.

UGC could be considered as a digital marketing communication of the promoter under specific conditions, in which case the advertiser would be liable for its content. As per the Digital Marketing Best Practice Guide issued by the SEE, if the advertiser has commissioned, adopted, approved, recognised, accepted, distributed or actively promoted the UGC (examples of adopting/approving/accepting UGC are “liking”, “retweeting”, “sharing” or re-using it in other media), the advertiser could be held liable for it.

Also, in cases where a promoter agrees with users to create UGC in exchange for any kind of compensation (monetary or otherwise), this would have to clearly be labelled as marketing communication. In such cases, the advertiser would have liability for such UGC.

Both Greek law and self-regulatory guidance provide that all marketing communications in any form or medium should be clearly identifiable as such. The disclosure can be made by various means, as long as it is easily and clearly understandable to consumers that the content is an advertisement. In social media, keywords or “hashtags” are often used in marketing posts, in order to label them as advertisements of a specific promoter.

For example, in Annex IX of the HCACP on Influencer Marketing it is recommended that influencers use the hashtag #διαφήμιση (the Greek equivalent of the term #advertisement). The English-language tags #ad and #advertisement may also be acceptable if they provide sufficient clarity to consumers, depending on the advertisement. The special disclosure labels available in many social media platforms, such as “paid collaboration”, “paid partnership”, etc, should also be used in order to ensure that the consumers are aware of the advertising nature of the post.

The labels/identifiers should not be “hidden” (eg, among other unrelated tags or at the end of the post) but should be obvious and visible at first glance for consumers, at the beginning of the advertising content.

All major social media platforms are available in Greece (Facebook, X/Twitter, YouTube, Instagram, TikTok, Snapchat, etc).

In relation to the use of social media by children, minors under 15 years of age need the consent of their parents/legal guardians in order to participate in “information society services” such as social media platforms, as per Article 21 of Law 4624/2019 implementing Article 8 of the GDPR.

Regarding the rules applicable for advertising in social media platforms, see 4.1 Special Rules Applicable to Social Media.

Native advertising falls under the basic principle that all marketing communications should be clearly identifiable as such, and it should also comply with all other general laws and regulations (see also 4.1 Special Rules Applicable to Social Media).

Under Article 9f point k of the Greek Consumer Protection Law, it is a misleading and forbidden commercial practice, considered as “disguised advertising”, to use editorial content in the media for the promotion of a product where the trader has paid for such promotion, without clarifying in the content itself, or by images or sounds clearly identifiable by consumers, that this is a paid promotion.

Under the HCACP (see 1.1 Primary Laws and Regulation and 1.7 Self-Regulatory Authorities), marketing communications must not be misleading as to their promotional purpose and should not be “disguised”, for example as market research, consumer survey, UGC, private social media posts, private blogs or independent reviews, etc.

The HCACP also stipulates that an advertisement appearing in any medium containing news or editorial material (“native advertising”) must be presented in such a way that it is immediately recognisable as an advertisement and, where necessary, should be clearly labelled as such.

As per the Self-Regulatory Digital Marketing Best Practice Guide issued by the SEE, the distinction in social media between marketing communications and editorial content should be clear. The easy identification of an advertising communication can be shown in various ways – eg, from the design, the content, the position within the website or through an identifier, depending on the specific characteristics of each advertising communication, as long as it is obvious to the consumers that it is an advertisement.

Influencer campaigns fall under the same rules as other online and social media marketing communications. All rules outlined in 4. Social/Digital Media are applicable to influencer campaigns as well (see 4.1 Special Rules Applicable to Social Media, 4.2 Liability for Third-Party Consent, 4.3 Disclosure Requirements and 4.5 Special Rules for Native Advertising).

Most importantly, as provided by both the law and self-regulatory rules, all marketing communications, including sponsored influencer campaigns, must be clearly identifiable as being advertisements, should state what the advertised entity is and should abide by the general principles of legal, decent, honest, truthful, non-defamatory and socially responsible advertising.

In addition, Chapter C.1 of the HCACP (on Direct Marketing and Digital Marketing Communications) specifically stipulates that where a marketer has paid for a product review or endorsement, the commercial nature of the communication should be transparent. In such cases, it should not be stated or implied that the product review or endorsement came from an individual consumer or from another independent entity.

In addition, Annex IX on Influencer Marketing, which has been added to the HCACP based on the content of EASA’s Best Practice Recommendation on Influencer Marketing, has set even more specific self-regulatory rules and recommendations for influencer campaigns. The Annex clarifies that marketing communications via social media are governed by all rules applicable to advertising in general – ie, the general principles of legal, decent, honest, truthful and socially responsible advertising. It is also noted that transparency is of the utmost importance in this kind of marketing communications, with the main rule being that they should be clearly identifiable as such, regardless of the form they take and the medium that is used. The Annex further aims to assist the advertising market (advertisers, advertising agencies, influencers, etc) in complying with these rules by listing the cases when specific online content should be classified as influencer marketing. Finally, the Annex includes specific recommendations regarding the appropriate ways to disclose that such content is advertising (eg, by using particular indications and hashtags).

Under certain legal conditions, influencers may be considered as “media service providers” and must therefore comply with the obligations of Law 4779/2021 (which has transposed the EU Audiovisual Media Services Directive into Greek law).

As a general principle under Article 23 of the HCACP and also as specifically provided in Chapter C.20 of the HCACP, overall responsibility for all digital marketing communications, whatever their kind and regardless of the medium used – and therefore including influencer content – rests with the marketer. This is further confirmed in Annex IX of the HCACP on Influencer Marketing (which is based on the content of EASA’s Best Practice Recommendation on Influencer Marketing).

Apart from the advertiser, influencers themselves also have to abide by the rules on marketing communications, as specifically mentioned in the HCACP.

See also 4.2 Liability for Third-Party Content regarding advertiser liability for UGC.

Article 9e paragraph 6 of the Consumer Protection Law, which was added following the implementation of the Omnibus Directive, provides that when a trader provides access to consumer reviews of products, it is of material importance to provide information about whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product. Failure to provide such information may be considered as a misleading omission, and thus a prohibited, unfair commercial practice.

According to Article 9f of the Consumer Protection Law, as amended after the transposition on the Omnibus Directive, the following specifically constitute misleading commercial practices, which are prohibited:

• if marketers state that product reviews have been submitted by consumers who really purchased or used that product, when no reasonable and proportionate steps had been taken by the marketers to ensure that such reviews indeed originate from such consumers; and
• if marketers submit or commission another person to submit “fake” consumer reviews or endorsements, or if they misrepresent consumer reviews or endorsements, for the purposes of product promotion.

See 5.3 Consumer Reviews and 4.2 Liability for Third-Party Consent regarding advertiser liability for UGC content.

General Rules

All direct marketing communications via email must be clearly identifiable as such, must clearly state the identity of the sender and of the advertised entity, and must always provide the receiver with a clear and easy way to object to receiving further such emails.

All direct marketing communications should always comply with data protection rules (most importantly, the GDPR), and can only be sent in the following cases.

“Opt-in” system

As provided in Article 11(1) of Law 3471/2006, which transposed Directive 2002/58/EC (the E-Privacy Directive) into Greek law, direct marketing communications via email require, in principle, the express prior consent of the consumers to receive such communications (opt-in system). All communications should provide an easy way to “unsubscribe” from further emails.

“Soft opt-in” system

As an exception to the above strict “opt-in” rule, Article 11(3) of Law 3471/2006 stipulates that, in cases where email addresses have been legally obtained in the context of a purchase of products or the provision of services to customers, the customers’ emails may be used for direct marketing of similar products or services, under certain conditions.

Most importantly, in order for this “soft opt-in” rule to apply, the customers need to be clearly informed (as per the GDPR) when their email is first collected about the trader’s intention to use it for marketing purposes, and the customers also need to be clearly provided with a free and easy way to object (“opt out”) to receiving such marketing emails. The opt-out possibility needs to be provided both at the moment when the email address is first collected and also within every marketing communication that will be sent.

Liability for Unsolicited Marketing Communications

Promoters that infringe the above rules may bear administrative, civil and penal liability in Greece.

Administrative liability

The Hellenic Data Protection Authority may impose administrative penalties (such as monetary fines) if it finds that GDPR or E-Privacy Directive rules have been infringed.

Civil liability

The recipients of unsolicited marketing communication have the right to claim compensation for any material damages as well as moral damages. According to the law, moral damages of at least EUR10,000 shall be adjudicated in cases of unsolicited marketing communications.

Penal liability

When personal data is used, collected, stored, exploited or otherwise illegally processed contrary to the above-mentioned rules, the infringer may also face penal liability under Greek law.

Under the Greek legal framework (specifically Article 11 of Law 3471/2006, which transposed into Greek law the E-Privacy Directive), a distinction has to be made between calls without human intervention (automatic calling systems) and phone calls conducted with human intervention (ie, when an employee is making the call).

Calls Without Human Intervention (Automated): “Opt-In” System

It is necessary to have the prior express consent (opt-in) of the called persons to receive such automated communications.

Calls With Human Intervention: “Opt-Out” System

There is a right to opt out from receiving direct marketing phone calls, and promoters should always make sure that the receivers of the calls have not “opted out”. The “opt-out” right of telephone subscribers can be exercised in one of two ways, as follows.

• With a declaration from a telephone subscriber to their phone provider that they wish to opt out from advertising/marketing calls in general, from any promoter. Each Greek telecommunications provider holds an “opt-out registry” with these phone numbers, and advertisers should receive up-to-date copies of these registries at least every month, so that they do not call the numbers that have opted out.
• If an initial contact has been made with potential customers, they may declare directly to the calling promoter that they do not wish to receive further promotional phone calls from this promoter (even if their number is not included in the general “opt-out registries”).

General Rules for Marketing Phone Calls

All GDPR rules apply. The caller should always inform the consumers at the beginning of the call about the identity of the promoter and should also let them know that they have the right to object to further communications.

Chapter C.21 of the HCACP also contains a set of detailed self-regulatory guidelines for the lawful conduct of marketing phone calls.

Liability for Unsolicited Marketing Communications

The same liability rules apply as mentioned under 6.1 Email Marketing.

All rules mentioned under 6.1 Email Marketing also apply to text messaging, which is treated the same as email marketing.

All GDPR rules, which are directly applicable in Greece, and consumer protection rules banning misleading and aggressive practices should be respected in the context of targeted advertising.

Under the DSA, targeted advertising on online platforms shall be identifiable as such, and users should be informed about the parameters based on which they are presented with a specific advertisement and, where applicable, about how they may change these parameters. In addition, the DSA bans targeted advertising on online platforms based on profiling that uses special categories of personal data (racial or ethnic origin, political opinions, religion, sexual orientation, etc).

Regarding targeted advertising of minors, see 6.5 Marketing to Children.

Chapter C.22 of the HCACP also contains a set of detailed self-regulatory guidelines for the lawful conduct of interest-based advertising (IBA). As a basic rule, marketers participating in IBA should comply with the principles of transparency of data processing, and ensure that consumers are clearly informed and able to choose whether to share their data for IBA purposes or not.

Regarding the use of cookies, see also 6.6 Other Rules.

Prohibition of Profiling/Targeted Advertising to Minors

The processing of personal data of minors by media service providers and video-sharing platforms for commercial purposes (such as for direct marketing, profiling and behaviourally targeted advertising) is prohibited under Greek Law 4779/2021, which transposed the Audiovisual Media Services Directive.

The DSA also specifically prohibits targeted advertising on online platforms based on profiling of minors.

Marketing Communications to Children

Under Article 21 of Law 4624/2019 (implementing Article 8 of the GDPR), only minors who are above the age of 15 years can consent (if all other GDPR conditions are met) to participate in “information society services”, such as receiving marketing communications. Younger children need the consent of their parents/legal guardians.

Recital 38 of the GDPR states that “children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data. Such specific protection should, in particular, apply to the use of personal data of children for the purposes of marketing or creating personality or user profiles and the collection of personal data with regard to children when using services offered directly to a child.” Also, as per Recital 58 and Article 12(1) of the GDPR, where processing is addressed to a child, all information provided by the data controller should be in clear and plain language that the child can easily understand.

Regarding advertising to children, see also 2.10 Children.

Generally, any personal data processing, for marketing purposes or otherwise, shall always comply with the GDPR, which is directly enforceable in Greece, and with Law 3471/2006 transposing the E-Privacy Directive into Greek law.

Cookies

Under the applicable legal framework, the use of “cookies” (except for absolutely necessary cookies) is allowed only when users have been specifically informed and have actively granted their valid prior consent to them (“opt-in” system). Privacy-by-default and privacy-by-design principles also apply. The default option in all websites should be to not use cookies, unless users actively choose to accept them. Also, cookie banners and pop-ups should not make it more difficult to reject cookies than to accept them.

General Conditions for Promotional Sweepstakes and Contests

Promotional sweepstakes and contests should be clearly identifiable as such. In principle, they are permissible in Greece if no wager/stake is involved (otherwise they may be considered to constitute illegal lotteries or gambling). The entrants and the winners shall not assume any financial risk or cost in order to claim/receive the prize. The promotions shall also not fall under the prohibitions of aggressive or misleading commercial practices (see 2.1 Deceptive or Misleading Claims and 2.12 Other Regulated Claims).

The HCACP also contains a special set of provisions on sales promotion (Chapter A), setting out the basic rules for the presentation of promotional activities to consumers, including sweepstakes and contests.

Terms and Conditions

For any promotional sweepstakes and contests, the Terms and Conditions (T&Cs) and the Privacy Policy should be presented clearly and be easily accessible to consumers. The entrants should actively accept the T&Cs (eg, via an opt-in check-box with a direct link to the full text of the rules), prior to participating.

The T&Cs should be very clear regarding all necessary details of the promotion, including the nature, the rules, the mechanism, the duration, the conditions of participation, the conditions of winning, etc. The number, value and nature of the prize(s) to be awarded should be clearly stated in the T&Cs and in the promotional materials. The prizes/gifts themselves need to be lawful in Greece.

The T&Cs, the Privacy Policy and all materials associated with the promotion must be provided in the Greek language.

Purchase-Linked Promotions

In addition to the above, if a promotion is linked to purchasing a main product, there should be no mark-up in the price of the product, and the value of the prize should not be so high as to excessively entice the consumers to buy the product (otherwise it may be deemed as an unlawful commercial practice).

Sponsors of purchase-linked promotions tend to also provide an alternative no-purchase route for participation, given that, under certain conditions, purchase-linked promotions could be considered as unfair.

The Consumer Protection Law and the self-regulatory framework do not make a clear distinction between contests of skill and games of chance/prize draws, to the extent that they are conducted with promotional/marketing purposes and do not fall within the field of gambling law (ie, provided that they do not constitute illegal gambling, betting or illegal lotteries, which are all heavily regulated in the Gambling Law).

The principles described in 7.1 Sweepstakes and Contests are applicable to both promotional contests of skill and promotional games of chance/prize draws.

There is no requirement for administrative/official registration or approval for promotional sweepstakes and contests, provided of course that they do not fall within the definition of gambling, which is heavily regulated and requires special licences.

A market practice followed by some sponsors when running promotional sweepstakes and contests in Greece is to voluntarily file the T&Cs with a Notary Public.

In general, all communications on offers should be complete, clear, truthful and in the Greek language, and must not create misleading impressions to the consumers regarding the specific terms of the offers.

Special Offers and Reduced Prices

Article 9(3) of Consumer Protection Law 2121/1994 stipulates that any comparative advertising referring to a “special offer” is permitted only if it clearly indicates the date on which the offer ends or, where appropriate, that the special offer is subject to the availability of the products and services. If the special offer has not yet begun, the advertisement must clearly indicate the start date of the period during which the special price or other specific conditions shall apply.

Furthermore, regarding “reduced-price offers” specifically, according to the rule set out in Article 9j of Law 2251/1994 (which has been added by Law 5111/2024), each communication regarding a price reduction shall indicate the previous price applied by the supplier for a specified period of time prior to the application of the price reduction. The previous price shall be considered the lowest price applied during the 30 days prior to the price reduction. Where the price is progressively reduced during the 60 days prior to the price reduction, the previous price shall mean the price in force prior to the first of the successive price reductions.

In addition, a new “Code of Conduct for Communications of Price Reductions” has recently been ratified by Ministerial Decision No 66877/2024 (Gov. Gaz. B’ 5002/2024), and contains extensive guidelines for the lawful communication of reduced-price offers to consumers (especially in relation to sales, offers, promotional activities and other related marketing practices). The guidelines, which also include multiple examples of best and worst practices, are based mainly on the principles of fair advertising and the prohibition of unfair (misleading and aggressive) commercial practices (see 2.1 Deceptive or Misleading Claims).

The HCACP also contains a special set of provisions on sales and promotions (Chapter A). A Best Practice Guide on Discounts & Offers has also been issued by the SEE, containing basic guidelines for the fair communication of offers to consumers.

Free

See 2.12 Other Regulated Claims regarding claims that a product is “free” or “without charge”.

Any automatic renewal/continuous service offers under which a marketer can continue to bill for products and services on a recurring basis (until the consumer cancels) are first of all regulated by the basic principles that marketing communications shall be honest, clear and truthful, and shall not fall under prohibited misleading or aggressive commercial practices.

Consumers should be provided the specific terms of such offers in writing, which shall be clear and easy to understand, prior to agreeing to them.

The process for cancelling a service shall not be significantly more difficult than subscribing to it (see also 2.9 Dark Patterns).

In cases of “free trials” or “special offers” that are later converted to paid subscriptions or where the cost is increased at the end of the offer period, Article 10 of the HCACP specifically stipulates that the T&Cs of such transactions should be disclosed clearly, distinctly and unambiguously before the consumer accepts the offer.

The ICC has also published guidelines on “Principles on Automatic Subscription Renewals” (March 2023), which are expected to be followed by the SEE as well.

Under Article 2(7d) of the Greek Consumer Protection Law, general commercial terms that result in the extension or renewal of a contract for an excessively long period of time unless the consumer terminates it within a certain timeframe are abusive, and therefore illegal.

Currently, there is no specific framework regarding content, such as advertisements, created by artificial intelligence (AI). AI-generated material still remains a grey legal area, especially regarding the issue of the existence or not of “copyrights” on such content.

All rules and regulations applicable to any marketing communications shall apply to AI-generated advertisements as well.

Special attention shall be paid to ensure that content created by AI does not result in misleading or otherwise unlawful advertisements, so that it does not infringe existing IP or other rights of third parties.

There are currently no specific regulations for advertising claims related to AI (eg, that a product is developed through AI or that it offers possibilities related to AI). All general rules regarding advertising claims shall be followed, especially regarding the substantiation of such claims (see 2.3 Substantiation of Advertising Claims).

Chatbots are not yet specifically regulated, but all general rules regarding lawful marketing communications and personal data protection shall apply to the use of chatbots as well.

Appropriate measures need to be taken by advertisers in order to ensure GDPR compliance and to avoid misleading or otherwise unfair commercial practices towards consumers because of the use of chatbots.

Crypto-assets

The Markets in Crypto-Assets Regulation (“MiCA” – EU Regulation 2023/1114) shall set the new basic regulatory framework on the issuance and marketing of crypto-assets and related services across the EU. MiCA shall apply and be directly enforceable across the EU from 30 December 2024.

The Regulation, inter alia, contains rules on marketing communications related to crypto-assets, with the basic principles being that marketing communications should be clearly identifiable as such, should be fair, clear and not misleading, and should be consistent with the crypto-asset white paper. Depending on the type of crypto-assets, specific disclosures may also have to be included in the marketing communications.

NFTs

MiCA exempts unique and non-fungible crypto-assets (ie, NFTs that often represent digital art and collectibles) from its regulatory framework. Therefore, there are currently no specific rules in Greece or in the EU regarding NFTs. The general advertising rules shall be deemed to apply also to the marketing of NFTs.

Currently, there is no special regulation regarding the Metaverse; the rules described in previous sections shall be deemed to be appropriately applicable for advertising within the Metaverse as well. The HCACP also specifically mentions that its provisions are “technology neutral” – ie, they are applicable regardless of the means and the technology used.

Alcohol

The advertising of alcoholic beverages must not:

• be aimed specifically at minors nor depict persons below the age of 25 consuming alcohol;
• encourage immoderate consumption of alcoholic beverages nor show negatively the abstinence from their consumption or their moderate consumption;
• link the consumption of alcohol to enhanced mental or physical performance nor to driving;
• create the impression that alcohol consumption contributes towards social or sexual success; or
• imply that alcoholic beverages have therapeutic properties.

Alcohol advertisements should only be placed in media for which at least 70% of the audience are reasonably expected to be 18 years or older. All alcohol advertisements should include the tag line “enjoy responsibly”.

Alcohol advertisements on TV and radio should be broadcast after 7pm.

Tobacco/Vaping

All forms of tobacco advertising (including e-cigarette advertising) are prohibited, except for advertisements inside tobacco stores.

Cannabis Products

Under Greek law, products (not specifically foods) deriving from the cultivation of Cannabis Sativa L that contain THC (tetrahydrocannabinol) at a concentration of less than 0.2% are not considered to be illegal narcotic drugs. However, this does not mean that foods and food supplements containing THC under that level are legal, per se. The legality of the circulation/advertising of such products in the Greek market is doubtful, since there are still a lot of grey legal areas in this field.

Medicines

It is illegal to advertise medicines that are available on medical prescription only. The advertising of over-the-counter medicines is permitted in principle, but certain restrictions apply – eg, said advertisements must disseminate particular minimum information and include the following warning message: “The Ministry of Health and the National Organisation for Medicines advise you to read the instructions carefully and consult your doctor or pharmacist.” These restrictions have been added to the new Annex X of the HCACP.

Foodstuff/Food supplements

Regulation (EC) 1924/2006 “on nutrition and health claims made on foods” is applicable in Greece and introduces specific restrictions on the advertising, presentation and labelling of food (eg, that the advertisements concerned should not induce excessive consumption of food, that nutrition and health claims shall be based on and substantiated by generally accepted scientific evidence, etc). Certain restrictions are also imposed on advertisements of nutritional supplements and food products intended for use in energy-restricted diets for weight reduction.

Gambling

Under Law No 4002/2011, the advertising of gambling services in Greece is permitted only to entities licensed by the Hellenic Gaming Commission (HGC). Said Law and the Guidelines of the HGC set out the general principle of responsible advertising, along with a number of specific restrictions safeguarding a high level of consumer protection (these advertisements should include a warning message on gambling harm, etc).

Plant Protection Products

Regulation (EC) 1107/2009 concerning the placing of plant protection products on the market applies in Greece, and imposes certain rules and restrictions on the advertising of authorised plant protection products. For example, all such advertisements should include the following warning notice: “Use plant protection products safely. Always read the label and product information before use.”

Cosmetics

Claims on cosmetic products must comply with Regulation (EU) No 655/2013 and with Annex VII of the HCACP, which incorporates the Guiding Principles on Responsible Advertising and Marketing Communication of Cosmetics.

Cars

Advertisements related to passenger cars should disclose information on CO2 emissions and fuel consumption.

Firearms and weapons

It is illegal to advertise firearms and weapons in audiovisual media.

Product placement in audiovisual media is permitted under Greek law (Article 16 of Law No 4779/2021 incorporating Directive EU 2010/13 as amended by Directive EU 2018/1808), provided that the following rules are respected:

• product placement is not permitted in news and current affairs programmes, consumer affairs programmes, religious programmes and children’s programmes;
• product placement programmes must not directly encourage the purchase or rental of goods or services by making special promotional references to those goods or services;
• the products in question must not be given undue prominence;
• the editorial autonomy of the media service provider must be respected; and
• viewers must be clearly informed of the existence of product placement by an appropriate identification at the start and at the end of the programme, and when a programme resumes after an advertising break.

Product placement of the following is prohibited:

• cigarettes and other tobacco products, including electronic cigarettes and refill containers;
• medicines that are available only on medical prescription; and
• any other product or service that it is illegal to advertise.

The advertising of certain professional services, such as those of lawyers, doctors, etc, is strictly regulated by Professional Codes of Conduct, which impose several restrictions on the respective marketing communications.