What is Bulgaria EPR Batteries

Bulgaria's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States without requiring national transposition. The Regulation has applied in stages since 18 February 2024, with EPR and waste management obligations fully in force from 18 August 2025.

At national level, the Regulation is supplemented by Bulgaria's Waste Management Act (Закон за управление на отпадъците) and subordinate ordinances governing the product fee system, registration of producers, and the operation of collective organisations. The competent authority for battery producer registration and oversight is the Ministry of Environment and Water (Министерство на околната среда и водите — МОСВ), which maintains the national Register of Persons Placing Batteries and Accumulators on the Market (Регистър на лицата, които пускат на пазара батерии и акумулатори).

The EU Battery Regulation replaced the previous Batteries Directive 2006/66/EC in full from 18 August 2025. It covers all battery types regardless of chemistry or form, whether sold separately or incorporated into products or vehicles.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Bulgarian consumers via an online store — with no physical establishment in Bulgaria — is treated as a producer and must comply with Bulgarian battery EPR obligations.

Under Bulgarian EPR law, foreign companies distributing products to end users in Bulgaria bear responsibility for the collection and treatment of waste from those products. This applies specifically to distance selling into Bulgaria, including cross-border online sales. Non-compliant foreign companies are subject to the same enforcement mechanisms as domestic producers, including fines and the product tax system.

Online marketplace operators are required under the EU Battery Regulation to verify that sellers on their platforms are EPR-registered in each country where they sell batteries.

Who is the "Producer" under Bulgaria EPR?

Under Regulation (EU) 2023/1542 and the Bulgarian Waste Management Act, a producer is any person who places batteries or accumulators on the Bulgarian market for the first time. This includes:

1. Manufacturers established in Bulgaria who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Bulgaria from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Bulgaria (лица, които въвеждат батерии и акумулатори от друга държава – членка на ЕО).
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Bulgaria who sell batteries or battery-containing products directly to Bulgarian consumers.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Bulgaria

All producers placing batteries on the Bulgarian market must register in the national Register of Persons Placing Batteries and Accumulators on the Market, maintained by the Ministry of Environment and Water (МОСВ). Registration is a prerequisite for placing batteries on the market.

Producers may fulfil their EPR obligations in one of two ways:

Option 1 — Join a collective organisation (PRO): By contracting with an approved collective organisation such as Ecobattery AD (Екобатери АД), producers are exempt from paying the product tax. The PRO issues a certificate confirming membership, which serves as proof of compliance with EPR obligations when presented to enforcement authorities. Members pay a contribution to the PRO based on the weight of batteries placed on the market.

Option 2 — Pay the product tax directly: Producers who do not join a PRO must pay a product tax (продуктова такса) to the PUDOOS (Executive Environment Agency fund — ПУДООС, part of МОСВ). The product tax rate significantly exceeds PRO contribution levels and functions as a financial incentive to join a collective system.

Bulgaria EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Bulgarian market must register and comply, regardless of size or volume.

The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside scope entirely.

For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Detailed EPR Guidance for each Jurisdiction

We support 36 jurisdictions

Get a Fee Quote I give your consent to the processing of personal data

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Bulgaria:

Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. The most commonly encountered category for e-commerce sellers.

Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles.

Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles.

Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027.

Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations.

Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

The main approved collective organisation for batteries in Bulgaria is Ecobattery AD (Екобатери АД), established in 2009. Ecobattery manages collection, recycling, and reporting obligations on behalf of its members — importers, producers, and companies introducing batteries from other EU Member States.

Upon signing a contract with Ecobattery and completing the required declaration, members receive a certificate confirming their membership in the organisation. This certificate exempts them from paying the product tax at import and serves as proof of compliance when presented to customs or enforcement authorities.

The Bulgarian system requires independent annual audits of PRO organisations. On the basis of audit results, the Minister of Environment and Water issues annual orders confirming compliance by each PRO and its members. PROs must provide a bank guarantee of BGN 1 million (Bulgarian Lev) against non-compliance — if targets are missed, the guarantee is called and the full product tax is applied.

A list of approved collective organisations for batteries is published on the МОСВ website alongside the producer register.

EPR Registration in Bulgaria

The registration process for battery producers in Bulgaria is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Bulgarian Waste Management Act — i.e. whether you are placing batteries on the Bulgarian market for the first time.
2. If established outside Bulgaria, appoint an authorized representative established in Bulgaria before registering.
3. Register in the national producer register maintained by МОСВ (Ministry of Environment and Water).
4. Contract with an approved PRO — in practice, Ecobattery AD — and complete the required declaration (справка-декларация) of batteries placed on the market.
5. Receive the membership certificate from Ecobattery confirming exemption from the product tax.
6. Submit annual declarations of batteries placed on the Bulgarian market to Ecobattery for reporting to МОСВ.
7. Alternatively, if not joining a PRO, pay the product tax to ПУДООС (МОСВ) directly.

Authorized Representative

Under Regulation (EU) 2023/1542 (Article 57), producers established outside the Member State where they sell batteries must appoint an authorized representative — a legal or natural person established in Bulgaria — to fulfill EPR obligations on their behalf. This requirement applies to all foreign producers selling into Bulgaria.

The authorized representative handles registration with МОСВ, contracts with the PRO, annual reporting, and contact with Bulgarian enforcement authorities. The representative must be appointed in writing.

Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of April 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered in Bulgaria must declare and report the following data annually, either directly to МОСВ or through their PRO:

• Total weight (kilograms) of batteries placed on the Bulgarian market during the reporting year, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
• Battery chemistry type where relevant to compliance and product tax calculations
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, as required by the Waste Management Act and reported by the PRO on behalf of members
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in Bulgaria for many years under the former Batteries Directive. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 February 2024: EU Battery Regulation begins applying. CE marking and substance restrictions in force.
• 18 August 2025: EPR registration, waste management, and labelling obligations fully in force under the new Regulation.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
• 18 August 2027: Due diligence obligations in force (delayed from 2025 under Omnibus IV).

Annual declaration and reporting deadlines are set by МОСВ and administered through the PRO system. Producers should confirm submission schedules with their PRO or directly with МОСВ at the time of registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol. The symbol must cover at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm.

Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb.

Capacity marking Portable and rechargeable batteries must display capacity information.

QR code From 18 August 2026, all batteries must carry a QR code linking to product information. For LMT, industrial (>2 kWh), and EV batteries, the QR code links to the Digital Battery Passport from 18 February 2027.

CE marking Mandatory for all batteries from 18 August 2024.

Language requirements Consumer-facing information on batteries sold in Bulgaria must be provided in Bulgarian. Labels and instructions that are only in other languages may be treated as non-compliant under Bulgarian consumer protection law.

Environmental claims All environmental and sustainability claims must comply with Bulgarian consumer protection law and the Unfair Commercial Practices Directive. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Bulgaria.

EPR Eco Fees & Eco-Modulation

Bulgaria operates a dual-track financial system for battery EPR:

PRO contribution (preferred route): Producers joining Ecobattery or another approved PRO pay a contribution per kilogram of batteries placed on the market. The contribution rate is set by the PRO and is substantially lower than the product tax. Exact rates are agreed upon contracting with Ecobattery.

Product tax (sanction/default route): Producers not affiliated with a PRO must pay a product tax (продуктова такса) per kilogram of batteries to ПУДООС. The product tax is designed to be significantly higher than PRO contribution rates, functioning as a financial penalty for non-participation. If a PRO fails to meet its recycling targets, the full product tax applies to both the PRO and its members for the non-compliant quantities.

Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all Member States. Bulgaria's specific eco-modulation framework under the new Regulation has not been published as of April 2026.

Risks, Penalties & Common Mistakes

1. Operating without registration in the МОСВ producer register. Placing batteries on the Bulgarian market without registration is a compliance breach subject to enforcement by МОСВ and the Executive Environment Agency (ИзпАОС).
2. Failing to join a PRO or pay the product tax. Companies that neither join Ecobattery nor pay the product tax have no valid compliance arrangement. Fines of BGN 10,000 to BGN 50,000 (approximately €5,000 to €25,000) apply to infringements under Bulgarian EPR law.
3. Failing to appoint an authorized representative. Non-EU and non-Bulgarian producers must appoint a Bulgarian-established representative before registering. Without one, registration cannot be completed.
4. Assuming one EU registration covers Bulgaria. Battery EPR registration is national. Registration in another EU member state does not fulfil Bulgarian obligations.
5. Importing without a PRO certificate. Members of Ecobattery must present their membership certificate to customs authorities upon import to be exempted from the product tax at the border. Operating without this documentation results in the product tax being collected at import.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Labels must include Bulgarian-language consumer information.
7. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance of this deadline.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries — including batteries incorporated into devices — and whether they are being sold to Bulgarian consumers.
2. If established outside Bulgaria, identify and appoint an authorized representative established in Bulgaria.
3. Register in the national producer register with МОСВ (Ministry of Environment and Water).
4. Contract with Ecobattery AD (ecobatterybg.com) and complete the required declaration to receive your membership certificate and exemption from the product tax.
5. Ensure the membership certificate is available at import to avoid product tax being charged at Bulgarian customs.
6. Submit annual declarations of battery volumes placed on the Bulgarian market through your PRO.
7. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Bulgarian-language consumer instructions as required.
8. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

Register online

Start your EPR Reporting within 24 hours

Start Registration I give your consent to the processing of personal data

FAQ

Is battery EPR mandatory in Bulgaria?

• Yes. Battery EPR has been mandatory in Bulgaria under the former Batteries Directive and continues under the new EU Battery Regulation (2023/1542), fully in force from 18 August 2025. All producers placing batteries on the Bulgarian market must register with МОСВ and either join an approved PRO or pay the product tax directly.

Do foreign brands selling online into Bulgaria need to register?

• Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Bulgarian consumers are captured as producers under the EU Battery Regulation and Bulgarian Waste Management Act. Non-Bulgarian companies must appoint an authorized representative established in Bulgaria before registering.

What is the product tax and when does it apply?

• The product tax (продуктова такса) is a per-kilogram fee payable to ПУДООС (part of МОСВ) by producers who do not join an approved PRO. It is set at a rate significantly higher than PRO contributions to incentivise collective system participation. It is also applied at the point of import if the importer cannot present a valid PRO membership certificate.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Bulgarian market must register and comply regardless of size.

What languages must battery labels be in for the Bulgarian market?

• Consumer-facing information on batteries sold in Bulgaria must be provided in Bulgarian. Labels and instructions available only in other languages may be treated as non-compliant under Bulgarian consumer protection and product safety law.