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Bulgaria EPR

Provinces

Packaging

Provinces

Packaging

About

Packaging

About

Packaging

Bulgaria operates a mandatory Extended Producer Responsibility (EPR) system for packaging under:

the Waste Management Act (WMA / ZUO)
the Ordinance on Packaging and Packaging Waste

The system applies to entities that place packaged goods on the Bulgarian market. Obligated producers must:

Register in the public register maintained by the Executive Environment Agency (ExEA)
Ensure collection and recycling of packaging waste
Achieve national recycling and recovery targets
Maintain records and submit reports
Pay eco-fees (via a collective scheme) or product fees (if not participating in a scheme)

The system is fully mandatory.

Does this apply to e-commerce & online sales

Yes. Bulgarian legislation applies regardless of the sales channel. If you place packaged goods on the Bulgarian market, including via distance selling (cross-border e-commerce), you may qualify as the obligated producer. The key factor is who first makes the packaged goods available on the Bulgarian market, not where the seller is located. Foreign online sellers shipping directly to Bulgarian customers may therefore fall within scope.

Who is the “Producer” in Bulgaria

Under Bulgarian law, the obligated person is typically the entity that first places packaged goods on the Bulgarian market, including:

Manufacturers of packaged goods in Bulgaria
Importers of packaged goods into Bulgaria
Companies introducing packaged goods from another EU Member State
Brand owners placing goods under their own name
Distance sellers supplying directly into Bulgaria

Responsibility lies with the entity that first makes the packaged goods available for distribution, consumption, or use in Bulgaria.

Who Must Register for Packaging EPR in Bulgaria

All entities placing packaged goods on the Bulgarian market must:

Register in the Public Register of obligated persons maintained by ExEA
Choose a compliance method (collective or individual)

Registration must be completed before placing packaging on the market (in practice, at least one month prior to starting activities). Failure to register before market placement is a violation of Bulgarian law.

Bulgaria EPR Packaging — Registration Threshold

Bulgaria does not provide a general de minimis exemption threshold. There is no broad exemption based on low weight or turnover. If you place any amount of packaging on the Bulgarian market, EPR obligations generally apply from the first kilogram.

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Packaging Covered

Covered The system applies to:

Primary packaging
Secondary packaging
Transport packaging
Household packaging
Commercial / industrial packaging

Materials typically include:

Plastic
Paper & cardboard
Glass
Metals
Wood
Composite materials

All packaging types placed on the market are generally in scope. Exclusions There is no general exemption for small businesses or low volumes. Certain specific items may fall outside scope if they do not qualify as packaging under EU definitions.

Producer Responsibility Organizations (Recovery Organizations)

In Bulgaria, PROs are called Recovery Organisations for Packaging Waste. They must:

Be licensed under national law
Meet financial and operational requirements
Achieve national recycling targets
Submit annual compliance reports

Most companies join a licensed collective system rather than opting for individual compliance.

EPR Registration in Bulgaria — Step-by-Step

The compliance process typically involves:

Determining producer status
Registering in the Public Register (ExEA)
Signing a contract with a licensed Recovery Organisation
Tracking packaging quantities
Submitting annual declarations
Paying eco-fees

Registration must be completed before placing goods on the Bulgarian market.

Authorized Representative

Bulgarian packaging legislation focuses on the entity that places goods on the market. While the law does not establish a separate mandatory authorized representative regime specifically for packaging, foreign companies typically require:

Local administrative support
Access to Bulgarian reporting systems
A qualified electronic signature (KEP)

In practice, many foreign sellers appoint a local compliance provider to manage their obligations.

What Data Must Be Reported

Producers must report:

Total packaging placed on the Bulgarian market (kg / tonnes)
Breakdown by material type
Household vs. commercial packaging
Reusable packaging (if applicable)

Companies must maintain supporting documentation for declared quantities. Reporting is generally submitted electronically via national systems.

First Reporting Period

Obligations apply from the moment packaging is first placed on the Bulgarian market. The first reporting period typically covers the calendar year in which activities begin. Annual reporting covers the previous calendar year.

EPR Reporting Deadlines

Obligation	Typical Deadline
Registration	Before placing packaging on market
Annual packaging declaration	Q1 of following year (often by 31 March)
Scheme reporting to MOEW	Annually

Exact reporting dates may be specified by the collective scheme agreement.

EPR Eco-Fees & Product Fees

If using a Recovery Organisation:

Eco-fees are calculated based on:
- Material type
- Weight placed on the market
- Scheme tariff structure

Bulgaria does not currently operate a highly developed eco-modulation system comparable to some Western EU Member States, but fee structures may reflect material recyclability and cost factors. If not participating in a collective scheme, a state product fee may apply.

Labels & Marketing Claims in Bulgaria

Mandatory label for EPR products in Bulgaria

If your product is placed on the Bulgarian market, it must comply with the Waste Management Act and the Ordinance on Packaging and Packaging Waste.

Companies placing packaged goods on the market must:

Register with the Bulgarian environmental authority (ExEA)
Finance the collection and recycling of packaging waste through an EPR system
Label packaging with the appropriate material identification code

These requirements apply to producers, importers, and online sellers placing packaged products on the Bulgarian market.

Failure to comply may result in penalties.

An example of what a label looks like on packaging for Bulgaria

Packaging placed on the Bulgarian market typically includes:

Möbius loop recycling symbol
Material identification code according to EU Decision 97/129/EC
Optional sorting or disposal instructions

Combined recycling mark — Mandatory in Bulgaria

Bulgarian legislation requires packaging to be clearly marked with a material identification code to support proper sorting and recycling.

The Combined mark typically includes:

The recycling symbol
The alphanumeric material code
Optional additional marks for separate collection

Members of Bulgarian recovery organizations (such as Bulecopack or Ecopack) may also display the organization’s trademark on packaging.

📎 Download the Combined Mark from Lappa

PNG – best for digital use - Figurative logo
PNG – best for digital use.- Bulecopack combined in Bulgarian
PNG – best for digital use.- Bulecopack combined in Bulgarian

Recycling & Recovery Targets

Bulgaria must meet EU Packaging Directive recycling targets. Current EU targets applicable include:

65% recycling of all packaging waste
Material-specific targets for plastic, paper, glass, metal, wood

Recovery organizations must demonstrate compliance annually .

Risks, Penalties & Common Mistakes

Potential consequences of non-compliance include:

Administrative fines
Financial penalties
Product fee liabilities
Orders to suspend activities

Common mistakes (especially for e-commerce sellers):

Assuming EU compliance in another country covers Bulgaria
Failing to register before first sale
Underestimating packaging weights
Not joining a licensed Recovery Organisation
Missing annual reporting deadlines
Failing to maintain documentation

What E-commerce Sellers Should Do Now

Confirm who qualifies as the legal producer
Register before placing goods on the Bulgarian market
Join a licensed Recovery Organisation
Implement a packaging weight tracking system
Prepare for annual reporting in Q1
Monitor EU PPWR implementation developments

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FAQ

Is Bulgaria’s system mandatory

Yes. Packaging EPR is mandatory under national law.

Is joining a Recovery Organisation required?

Not legally mandatory, but practically essential unless choosing individual compliance.

Do foreign online sellers need to comply

Yes, if they place packaged goods directly on the Bulgarian market.

Is there a de minimis threshold

No general exemption threshold applies. Obligations typically apply from the first kilogram placed on the market.

February 24, 2026 99

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