Law 4791/2021 and EOKAN: where Greek anti-doping law touches research materials

Which substances does the Greek anti-doping law cover, whom does it bind, and what does it define as trafficking?

Law 4791/2021 (Government Gazette A 51/03.04.2021) is the Greek statute that incorporates the revised Anti-Doping Code of the World Anti-Doping Agency (WADA), in force from 1.1.2021. It defines which conduct is an anti-doping rule violation and how WADA's Prohibited List applies in Greece ^[1]. It concerns sport and the people who take part in it. It is not a medicines law and not a law on research materials.

Why should someone who handles laboratory material read it? Because the Prohibited List contains categories of substances, among them peptide hormones and growth factors, and because the law defines «trafficking» more widely than trade. The law binds specific persons, not every citizen, and that distinction is the main point of the text.

Three different regimes, not one

A substance can fall at the same time under three independent legal logics. The first is medicines law, which governs marketing authorisation and supply. The second is the status of research-use-only material, which concerns how laboratory reagents are supplied and the claims that accompany them. The third is anti-doping law, which concerns sport.

The three do not replace one another. A substance's presence on the Prohibited List does not make it a medicine or a research material; the fact that a material is supplied for laboratory use does not exempt it from the list for athletes. The reason to keep them apart is that each has a different addressee and a different authority.

What Law 4791/2021 did

The law's title states its purpose: necessary provisions to harmonise Greek legislation with the revised World Anti-Doping Code in force from 1 January 2021. The text, published by EOKAN, follows the structure of the Code: definitions and scope, violations, proof, the prohibited list, testing, sample analysis, results management, sanctions, appeals, and the roles and responsibilities of athletes and support personnel ^[1][4].

EOKAN, the National Organisation Against Doping, is the law's national anti-doping organisation, on the basis of Article 128ΣΤ of Law 2725/1999 and Presidential Decree 87/2020. Decisions are appealed either to the Court of Arbitration for Sport (CAS) in the cases provided, or to the Supreme Sports Disputes Resolution Council ^[1].

The Prohibited List and category S2

Article 4.1 of the law provides that the Prohibited List, as published and revised by WADA, is an integral part of the law. Unless the list itself provides otherwise, each new edition takes effect three months after WADA publishes it, with no further action by the national organisation. Athletes and third parties are themselves responsible for knowing the current edition ^[1].

The list is organised in categories. In its recent form it includes S0 (non-approved substances), S1 (anabolic agents), S2 (peptide hormones, growth factors, related substances and mimetics), S3 (beta-2 agonists), S4 (hormone and metabolic modulators), S5 (diuretics and masking agents), S6 (stimulants), S7 (narcotics), S8 (cannabinoids) and S9 (glucocorticoids), as well as prohibited methods ^[3]. The edition in force, with explanatory notes and a monitoring programme, is also published in Greek by EOKAN; on 10 October 2026 its page lists the 2026 edition ^[2].

For a reader interested in peptides, the relevant category is S2. This article does not list substances: WADA's list names them or describes them generally, and the current edition should be read from the source itself ^[2][3]. The sporting rationale for banning certain peptides is explained separately, in a text on sports policy.

Whom the law binds

The law defines an «athlete» as any person who competes in sport at international level or at national level as defined by the national organisation, while for certain purposes, such as education and the provisions on administration and complicity, an athlete is anyone competing in a sport under the jurisdiction of a signatory to the Code. The national organisation has discretion to apply the rules to lower-level athletes as well ^[1].

«Athlete support personnel» means a coach, trainer, manager, agent, team staff, official, medical or paramedical personnel, parent or any other person working with, treating or assisting an athlete in preparing for or taking part in competition ^[1]. The definition is functional: it turns on the relationship to the athlete, not on a title or profession.

What the law defines as trafficking

In the definitions of Article 1, trafficking is the sale, giving, transport, sending, delivery and distribution to any third party, or possession for any of those purposes, of a prohibited substance or method, physically or by electronic or other means, by an athlete, athlete support personnel or another person subject to the jurisdiction of the national anti-doping organisation. The definition expressly excludes actions of bona fide medical personnel connected with genuine and legal therapeutic purposes ^[1].

Two things deserve attention. First, the definition is not limited to selling: delivery and sending without payment also fall within it. Second, the Article 2.7 violation is defined as committed by an «athlete or other person», and the definition of trafficking is tied to persons «subject to the jurisdiction» of the national organisation ^[1]. The exact reach of «other person» must be read in the text of the law rather than assumed.

What it means for sellers and suppliers of laboratory material

The law is not addressed to suppliers of laboratory materials as such. Their relationship to it is indirect and arises at two points. The first is that the definition of trafficking covers an «other person» under the jurisdiction of the national organisation, and if a supplier deals with sporting bodies, the question goes beyond ordinary trade. The second is that, for dealings with persons under sporting jurisdiction, documenting the recipient and the stated purpose gains additional weight.

In practice, prudent record-keeping covers three things: who the recipient is (institution, laboratory, private individual), what purpose they stated, and what connection the recipient has to sport, if it appears from the document or the correspondence. The purpose declaration collected from the receiving laboratory is covered in a separate article on the declaration and the research purpose.

How to follow changes

The edition of the List usually changes yearly and, as Article 4.1 provides, takes effect three months after publication unless stated otherwise ^[1]. EOKAN's page lists the editions for the years 2021 to 2026 ^[2]; the one in force at any moment must be verified there and on WADA's page ^[3]. This text was read on 10 October 2026 and does not replace checking the current edition.

1. Check the current edition of the List at EOKAN and WADA.
2. Record the date of the check and the edition in your file.
3. If you deal with a sporting body, record the recipient and the stated purpose.
4. For criminal questions, consult a lawyer; this article does not cover them.