(AGENPARL) – Thu 09 October 2025 PRESS RELEASE No 131/25
Luxembourg, 9 October 2025
Judgment of the Court in Case C-368/24 | Commission v Greece (Enforcement of the judgment on the
Zakynthos landfill)
Failure of a Member State to fulfil its obligations: Greece is ordered to pay
financial penalties for failing to comply with a 2014 judgment of the Court
of Justice
Greece is ordered to pay the European Commission a periodic penalty payment of €12 500 for each day of
In the 2014 Commission v Greece judgment, 1 the Court held that Greece had failed to fulfil its obligations under two
directives on waste. 2 3 Greece had not put an end to the use of a landfill in the Zakynthos National Maritime Park,
the habitat of the ‘Caretta caretta’ sea turtle, even though the landfill was overfull and its malfunction represented a
danger to health and the environment.
With regard to the present case, an exchange of correspondence took place between the European Commission and
Greece from 2014 to 2023 concerning the measures adopted by the latter to rehabilitate the Zakynthos landfill and
comply with the 2014 judgment. Taking the view that Greece had not yet taken the necessary measures to do so, the
Commission sent a letter of formal notice in 2017 and, in 2024, brought a new action for failure to fulfil obligations
before the Court, which gave rise to today’s judgment.
In today’s judgment, the Court finds that Greece has failed to fulfil its obligation to adopt all the measures
necessary to comply with the 2014 Commission v Greece judgment.
The Court notes that, by the reference date set in the letter of formal notice, namely 28 June 2017, Greece had
neither drawn up a development plan for the continued operation of the Zakynthos landfill in accordance with the
requirements of Directive 1999/31 nor decommissioned that landfill. In addition, the Zakynthos landfill continued to
receive waste until the end of 2017.
Consequently, the Court orders that Member State to pay the Commission a periodic penalty payment of €12 500
for each day of delay from the date of delivery of today’s judgment until the date of compliance with the 2014
infringement. That infringement poses a significant risk to the environment and human health. In addition, the
Court took into account the large number of judgments finding that the Member State concerned had failed to fulfil
its waste management obligations, the number of cases in which it found that the Member State had failed to
comply with its judgments in that area, the fact that the infringement continued long after the 2014 judgment was
delivered and the Member State’s ability to pay.
NOTE: An action for failure to fulfil obligations directed against a Member State which has failed to comply with its
Communications Directorate
Press and Information Unit
curia.europa.eu
obligations under EU law may be brought by the Commission or by another Member State. If the Court of Justice
finds that there has been a failure to fulfil obligations, the Member State concerned must comply with the Court’s
judgment without delay.
Where the Commission considers that the Member State has not complied with the judgment, it may bring a further
action seeking financial penalties. However, if measures transposing a directive have not been notified to the
Commission, the Court of Justice can, on a proposal from the Commission, impose penalties at the stage of the
initial judgment.
Unofficial document for media use, not binding on the Court of Justice.
The full text and, as the case may be, an abstract of the judgment is published on the CURIA website on the day of
delivery.
Stay Connected!
Judgment of 17 July 2014, Commission v Greece, C-600/12 (see also Press Release No 104/14).
Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives.
Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.
Communications Directorate