PROCEDURE

The Hellenic Competition Commission (HCC) has initiated the procedure of regulatory intervention in the petroleum sector as set out in article 11 of Law 3959/2011  in order to examine the petroleum industry and assess the prevailing market conditions in terms of effective competition in the three production and distribution stages (refining, wholesale, retail) of petroleum products (95 octane unleaded petrol, diesel and heating oil) in the Greek market. The Regulatory Intervention procedure focuses on the examination of specific market conditions that may raise issues in the operation of the competitive process, which cannot be resolved by the application of articles 1, 2 and 5 to 10 of Law 3959/2011.  The HCC publishes its views in two stages of the procedure and opens them to public consultation.

In August 2024 the HCC published its preliminary views (First Interim Report). This Report provided an analysis of (a) the structure and competitive conditions at each stage of the industry's supply chain (refining, marketing and retailing), (b) the institutional framework of the petroleum product market in Greece, (c) price developments, trade flows and profitability indicators of refineries and wholesalers; (d) the pricing of the products under consideration and the factors affecting price levels over the period of reference; and (e) the phenomenon of asymmetric pass-through of fuel price increases (‘rockets and feathers’).

The First Interim Report was published for public consultation in August 2024 and is available (in Greek) here. The public consultation was completed in November of the same year. In response to requests for clarification, the HCC further published in October 2024 a supplementary Technical Annex with the econometric model used, which is available (in Greek) here.

This Second Interim Report is published pursuant to Article 11(3) of Law 3959/2011, according to which after the conclusion of the first public consultation and in case the HCC still finds an absence of conditions of effective competition in the specific sector of the economy, it may propose the adoption of specific measures which are  necessary, appropriate and in compliance with the principle of proportionality, to create conditions of effective competition. The HCC shall make its views on the proposed measures publicly available and initiate a public consultation. Following the completion of the above consultation and after taking into account any conclusions drawn therefrom, the HCC issues its decision.

The Second Interim Report is available ( in Greek) here.

Please visit our website for further information in English https://www.epant.gr/en/information/regulatory-interventions/regulatory-intervention-in-the-petroleum-industry.html

Any interested person can participate in the public consultation, regardless of any claim of legitimate interest. The views of a legal entity participating in the consultation can be submitted by its legal representative. All comments and opinions of those interested in participating in the consultation and sharing any information they have that could be useful for shaping the Competition Commission's decision are welcome.

The public consultation will be completed on 26.09.2025.

Those interested, are invited to submit their comments in writing and by name electronically (in an editable format) to This email address is being protected from spambots. You need JavaScript enabled to view it., by that date.

SUMMARY OF PROPOSED MEASURES 

A. Reinforcing imports with the establishment of a Central Stockholding Entity

In order to facilitate the maintenance of emergency stocks for imports, in particular by non-vertically integrated wholesalers, the HCC proposes the establishment of a special independent Central Stockholding Entity (CSE).

The CSE will be under the supervision of the Regulatory Authority for Energy, Waste and Water (RAAEY). The CSE will hold the emergency stocks on behalf of the obligors for a fixed fee, which will be paid by all obligors in proportion to their total consumption in the previous year.  In this way, those active in the relevant market will be able to maintain the mandatory emergency stocks required by law without being discouraged from importing (whether on a full or a limited range). 

This measure is deemed necessary, appropriate and effective to achieve the objective pursued, namely to increase the intensity of competition at the refining stage by strengthening imports, in particular by non-vertically integrated trading companies.  The establishment of the CSE will allow trading companies (in particular non-vertically integrated companies) to import without directly linking such imports to the additional costs of maintaining the mandatory emergency stocks and/or associated storage facilities. Furthermore, the establishment of an independent CSE will not allow the occurrence and ‘maintenance’ of the bargaining advantage of domestic refiners as certified emergency stockholders, which may lead to distortion of competitive conditions in this relevant market through possible refusal to sell, abusive practices (including any abusive stock costing practices, such as excessive or discriminatory pricing, and consequent price manipulation) and preferential treatment of the operators. Reinforcing imports, is expected to increase competition at the refining stage.

B. Mapping and supervision of storage facilities

A reliable inventory for monitoring and supervision of storage facilities for petroleum products is necessary. The HCC proposes the creation of such an inventory for storage facilities, including records on any absence thereof or of any unused facilities in a single inventory, kept by a competent institutional body.  The proposed inventory would enhance, inter alia, the possibility for imports.  It should be noted that this inventory should not be limited to the register kept by the Ministry of Environment and Energy, which includes data of storage facilities of Refineries, Facilities of Oil Product Trading Companies and Large Final Consumers, which have been certified in accordance with the provisions of Ministerial Decision D1/B/21196/2013 “Regulation on Emergency Stocks”.

C. Removal of exclusivity clauses in storage contracts

The exclusivity clauses included in the existing fuel (co-)storage and/or service agreements are not deemed appropriate or necessary to achieve the objective pursued, namely, to ensure regular supplies to the whole country, nor for serving the purpose of more rational management of the available storage facilities. On the contrary, such a rational management of storage facilities is a prerequisite for enhancing the importing potential, facilitating the maintenance of emergency stocks and strengthening the conditions of effective competition on the supply market, which is in fact hampered by storage exclusivity clauses.

It is therefore suggested that exclusivity clauses should not be included in future fuel storage/services agreements in facilities owned by third parties. This measure is deemed necessary, appropriate and effective to reach the objective pursued, namely, to increase the intensity of competition at the refining stage by strengthening imports. Exclusivity in the use of storage facilities ultimately results in the exclusive supply of the facility’s owner by the contracting refiners for a fee, thereby preventing imports, and the investigation has shown that the purpose of the agreements is served even without such clauses. This measure is proportionate because it is limited to the removal of exclusivity clauses henceforth, without otherwise interfering with the trading/contractual relations between refiners and their customers or otherwise restricting their economic activity. Any alternative measures, such as mandatory access to refinersand/or traders storage facilities of would be more burdensome.

D. Reduction of price transparency in refining

In order to reduce the risk of tacit collusion in refining, it is proposed to reduce price transparency. According to the Ministerial Decision under ref. no. 3006, Government Gazette B’/554/2007, the selling price of petroleum products intended for the domestic market shall be notified to trading companies by electronic means no later than 10:00 a.m. on the day of delivery. This notification should be made by individual communication with the trading companies without any public announcement of the prices concerned, which are currently posted daily on the website of the General Secretariat for Trade and Consumer Protection.  The above measure is deemed necessary and appropriate to reduce the degree of transparency in the market, which facilitates tacit collusion, and is not onerous for refiners.

E. Increase of price transparency in retail

The First Interim Report refers to an a past proposal by the HCC to place special electronic display boards along motorways to inform passing drivers of the retail price of liquid fuels (unleaded and diesel) available at the next three service stations (from the location of each electronic display board) as well as of the respective distances in kilometres. The relevant requirement to install the above electronic display boards has not been met to date.

The installation of electronic display boards along motorways can be complemented by other measures to increase the level of information of final consumers on fuel prices or quality and at the same time be more in line with the digital evolution of recent years and its impact on consumers' daily lives.

The HCC  proposes that the competent Ministry should adopt a similar effective measure through the creation of a digital application to inform consumers about prices in real time and in a user-friendly manner. The HCC's proposal concerns the development of a user-friendly application that would include the prices found at service stations by product, in real-time listing by service station and by geographical area and would show the user (based on his current location) the nearest service stations and their respective pricing. This measure would be sufficient to increase market transparency to the benefits of consumers. Such an application could be seen as a further development of the existing Price Observatory to enhance the good standing and credibility of a governmental body.

Service‐station operators should inform the Price Observatory of their prices in real time and the relevant data should be automatically entered into the app to allow price comparison and the selection of the cheapest petrol station per region. Consumers will therefore be able to opt for the cheapest fuel at any time, which in turn will increase the incentives for petrol stations to compete vigorously on price and at the same time competitive pressures will be extended to marketing companies.