Bulgaria EPR

Does this apply to e-commerce & online sales

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. To estimate the likely cost before registration or reporting, use Lappa’s EPR fee calculator. 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:

1. Register in the Public Register of obligated persons maintained by ExEA
2. 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.

EPR and PPWR for Bulgaria

Bulgaria's packaging EPR runs through the Waste Management Act and the Ordinance on Packaging and Packaging Waste, with the Executive Environment Agency keeping the public register. There's no de minimis threshold — obligations start from the first kilogram — and most companies fulfil them through a licensed Recovery Organisation like Bulecopack or Ecopack rather than reporting individually.

PPWR doesn't replace any of that. From 12 August 2026, it sits alongside the national system as a separate EU-wide layer: technical documentation, an EU declaration of conformity, and an authorised representative requirement under Article 45. That last point matters more in Bulgaria than in some Western EU markets, because Bulgarian packaging law has never had a formal authorised representative regime of its own — foreign sellers typically just work through a local compliance provider informally. PPWR introduces a binding, EU-wide version of that requirement regardless of what Bulgarian practice has looked like until now.

The bigger structural gap is the deposit-return system. Bulgaria doesn't currently operate one — a 2022 EUR-Lex summary and Bulgaria's own Ministry of Environment and Water confirm deposit schemes here have stayed at the discussion stage for years. PPWR changes that from a policy option into a binding deadline: every member state needs a functioning deposit-return system for single-use plastic and metal beverage containers by 2029, hitting 90% separate collection. Bulgaria's Economic and Social Council has already flagged this as urgent, given the country's circular economy rate sits at roughly 5%, well under the EU average of 12%. For a market with no deposit infrastructure today, that's less a compliance tweak and more a build-from-scratch project on a fixed clock.

PPWR Labels for Bulgaria

Bulgarian packaging labelling is already closer to EU-standard than in some neighbouring markets. The mandatory combined mark pairs the Möbius loop recycling symbol with a material identification code under EU Decision 97/129/EC, and members of a Recovery Organisation typically add that organisation's own trademark alongside it. It's a material-coding system, not a consumer sorting instruction — it tells you what the packaging is made of, not where to put it.

PPWR adds a genuinely new layer on top. From 12 August 2028, most packaging placed on the EU market needs a harmonised sorting pictogram, giving consumers the same visual sorting cues whether they're in Sofia or Stockholm. Because Bulgaria's existing combined mark is a material-identification label rather than a sorting label, there's less direct overlap here than in countries like France, where a national sorting label already competes with the same territory PPWR's pictogram is about to occupy.

That said, the transition period isn't friction-free. Businesses selling into Bulgaria will likely run the combined mark and the harmonised pictogram side by side from 2028 onward, since one identifies material composition and the other guides sorting — different legal bases, same package, more artwork to manage. See the PPWR labelling requirements for the harmonised EU rules, implementation dates and packaging-label changes.

The clearest case study for how contentious national labelling can get under PPWR is France, where the Commission referred the mandatory Triman/Info-Tri requirement to the CJEU in July 2025 over free-movement-of-goods concerns. Bulgaria isn't part of that dispute, but the ruling will shape how much latitude any member state's existing label — including Bulgaria's combined mark — gets to keep once the harmonised pictogram exists.

PPWR Product Rules for Bulgaria

The PFAS restriction has applied since 12 August 2026: food-contact packaging placed on the Bulgarian market can't carry PFAS above 25 ppb for any individual measured substance, 250 ppb summed, or 50 ppm total including polymeric PFAS. This isn't a slow-moving obligation — a food-contact coating or liner that exceeds the limit doesn't clear customs, and Bulgarian market surveillance treats a breach with the same seriousness as a CE-marking failure.

Recyclability requirements land on 1 January 2030, when packaging needs to sit in Design for Recycling Performance Grade A, B, or C, with Grade C losing EU market access from 2035. Recycled content thresholds for plastic contact-sensitive packaging apply from the same date, rising again by 2040. This is a heavier lift for suppliers into Bulgaria than into some Western EU markets — Bulgaria's recovery organisations don't yet run the kind of eco-modulation or Design-for-Recycling advisory programmes that exist in, say, Belgium, so businesses may need to source recyclability data and technical evidence more independently.

Packaging minimisation follows on the same 2030 timeline, capping empty space in grouped, transport, and e-commerce packaging at 50% and banning oversized-packaging tricks. Reuse and refill targets for beverage, grouped, and transport packaging phase in from 2030 as well, layering on top of the separate 2029 deposit-return deadline already discussed above.

For suppliers and design teams, the practical challenge in Bulgaria is less about any single rule and more about starting point: Bulgarian recovery organisations already collect material-type and weight declarations, but the recyclability and recycled-content evidence PPWR's technical file requires is largely new documentation that needs building well ahead of the 2030 deadlines, not assembled once enforcement starts. The PPWR packaging data sheet explains which product, material and compliance information businesses should start collecting.

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:

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

Registration must be completed before placing goods on the Bulgarian market. If you need help completing the process, Lappa can manage Bulgaria EPR registration and the required compliance documentation for you.

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. Separately, manufacturers affected by PPWR should check whether the EU authorised representative requirements apply to their packaging.

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. For companies managing recurring declarations, EPR reporting software can centralise packaging quantities, deadlines and reporting data.

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

Exact reporting dates may be specified by the collective scheme agreement. Businesses operating in several markets can manage registration and reporting obligations through one EPR compliance workflow.

EPR Eco-Fees & Product Fees

If using a Recovery Organisation:

• You can calculate an indicative EPR fee before registration 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

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.