Bulgaria EPR

Extended producer responsibility for packaging in Bulgaria

Extended Producer Responsibility (EPR) in Bulgaria (for packaging) places the legal burden on producers, importers, and distributors who place packaged goods on the Bulgarian market to ensure the collection, recycling, recovery and disposal of packaging waste. Under the Bulgarian Waste Management Act (“WMA”) and the Ordinance on Packaging and Packaging Waste (as amended), Bulgaria transposed the EU Packaging and Packaging Waste Directive (94/62/EC, and its amendments) into national law. In December 2022, amendments to the Packaging Ordinance introduced a public register and more explicit registration rules for entities placing packaged goods on the market. In 2025, the new EU Packaging and Packaging Waste Regulation (replacing the Directive) will take effect (from 12 August 2026), which will further harmonize EPR for packaging across EU member states, including Bulgaria.

Who must register for EPR in Bulgaria

In Bulgaria, the following entities are required to register under the EPR packaging scheme (i.e. on the Register of Persons Placing Packaged Goods on the Market) overseen by the Executive Environment Agency (ExEA / ЕxEA / Изпълнителна агенция „Околна среда“) / environmental authority:

• Producers that manufacture packaged goods to be placed on the Bulgarian market (consumer, group, transport packaging).
• Importers of packaged goods (including distance sellers / e-commerce) who bring products into Bulgaria for sale.
• Distributors / retailers who, as part of their commercial activity, place packaged goods on the market (especially when no clear upstream producer or importer is identifiable).
• Entities placing single-use plastic products (SUPP) on the Bulgarian market (as defined under the Bulgarian Ordinance transposing EU Directive 2019/904) must also separately register for SUPP obligations.

If an entity cannot be clearly identified (e.g. in cross-border or online sales), distributors may be held liable for registration and compliance. Because the recent amendments lowered barriers for enforcement and introduced a public register, risk of non-compliance is higher. In short: any entity (producer, importer, retailer) that introduces packaged goods into the Bulgarian market must register for EPR packaging obligations. Ready to make extended producer responsibility effortless for Bulgaria? Request a personalized EPR fee quote now and start turning regulatory obligations into sustainable value for your brand for cross-border sales!

What the package includes

“Package” for EPR in Bulgaria covers various types of packaging in line with EU requirements. Under Bulgarian law:

• Consumer / primary packaging (packaging holding the product to the final user)
• Group or secondary packaging (packaging to group several products)
• Transport packaging (packaging used for transport or logistics)
• All material types: plastic, glass, metal, paper / cardboard, wood, composites, etc.

The package obligations may also extend to single-use plastic products (SUPP) which are subject to additional rules. The SUPP list includes items like plastic beverage bottles (≤ 3 L), food containers, plastic cups, plastic carrier bags of certain thicknesses, wet wipes, balloons, tobacco filters, etc. There is also a product fee / tax mechanism for plastic packaging / SUPP . Entities placing such items may need to contribute a tax if recycling targets are not met. Labeling: packaging must be marked with the material code (alphanumeric code per EU Decision 97/129) to identify the material fraction. The Möbius loop / “chasing arrows” and the Tidyman symbol are no longer mandatory (made voluntary by 2022 amendments), though the material identification code remains compulsory. Hence, the “package” scope is broad and captures virtually all packaging associated with marketed goods in Bulgaria under EPR packaging rules.

Threshold

Unlike some jurisdictions that exclude small operators via volume or weight thresholds, Bulgaria does not explicitly provide a de minimis threshold for packaging tonnage below which EPR registration is waived. In effect, the obligation applies from the first placing of packaged goods. Thus, registration is required regardless of the volume (i.e. threshold = 0) (i.e. all operators). EPR packaging obligations are not limited to large producers only. Clarity

Registration procedure for EPR in Bulgaria

Timeframe

Entities must register within one month before commencing the activity of placing packaged goods on the Bulgarian market. For SUPP, registration was required by 16 February 2023 for those already in operation.

Where / To whom

Registration is to be made to the Executive Environment Agency (ExEA / ExEA / ЕxEA) of Bulgaria (via its executive director or authorized official). The register is a public register of persons placing packaged goods in Bulgaria.

• Information to supply.Entities must provide details including (but not limited to)
  • Name
  • Unified Identification Code (UIC) / registration ID
  • Address, contact person
• Trademarks used in Bulgaria (if applicable)
• Types / materials of packaging placed on the Bulgarian market (consumer / group / transport packaging)
• Manner of fulfilling obligations: individually or via collective (PRO) system
• Method of sale (including distance / online)
• For SUPP, specify which types of single-use plastic products are placed on the market.

Filing / Format

Currently registration is done via written submission to the Executive Director of ExEA (though transition to electronic filing via the National Waste Information System (NWIS) is expected. Future plans: integration into NWIS for e-submission and updates.

Updates / amendments / deregistration

If declared information changes, the entity must update within one month of the change. Deregistration is possible if the entity ceases placing packaged goods in Bulgaria and meets other conditions.

Consequences of non-registration

Entities failing to register or not declaring accurate data may be subject to penalties under the Waste Management Act and Ordinance provisions.Thus, registration is relatively straightforward in form, but applies broadly and without volumetric thresholds.

Authorized representative

Under the current Bulgarian EPR packaging regime, there is no explicit requirement for a local “authorized representative” akin to many non-EU country regimes. Instead:

• Foreign (non-Bulgaria / non-EU) entities placing packaged goods into Bulgaria must register directly on the Bulgarian public register.

If they are unable or unwilling to register, they may engage a local agent / service provider / compliance consultant to handle registration, reporting and obligations on their behalf (practical/commercial arrangement), but legally the obligation remains with the producer/importer. (Implied from compliance practice) The amendments in 2022/2023 do not explicitly provide for a substitute or proxy registration by third parties; instead, the law focuses on direct registration and transparency. (Source: Lexology) Lexology If new rules under the EU Packaging Regulation (from August 2026) introduce a requirement for authorized representatives, Bulgaria will need to conform. But under current legislation, the concept is not clearly stipulated.

Reporting Deadline

Entities performing EPR for packaging in Bulgaria must comply with reporting obligations under the National Waste Information System (NWIS) and the Bulgarian Ordinance as follows:

• Annual reporting: Entities must submit an annual report covering quantities of packaging placed on the market, by material type, and fulfilling recovery / recycling obligations.
• The deadline for annual report is 31 March of the year following the reporting year.
• Record-keeping (monthly records): Obliged persons must maintain monthly record books (records per month) and submit them to NWIS no later than the 15th day after the end of the preceding month.
• After 31 March, changes to the submitted annual report are generally not permitted.
• Reports and record-keeping must be submitted electronically via NWIS with certified electronic signature (KEP).

Thus, the key reporting date is 31 March annually for the preceding calendar year.

Who Assumes Responsibility?

Under Bulgaria’s EPR packaging regime, the responsibilities are allocated across a few actor types. Below is who is legally responsible, and how obligations can be shared or delegated:

Producer / Importer / Distributor

• They are the primary legally responsible parties for registering, reporting, financing, and fulfilling EPR packaging obligations.
• Even when they delegate tasks (e.g. via a PRO), legal liability typically remains with them.
• In cross-border / e-commerce cases, distributors may assume responsibility if upstream obligations are not clearly met.

Producer Responsibility Organizations (PROs) / Collective Schemes / Recovery Organizations

• Entities may join licensed collective systems / PROs (e.g., ECOPACK Bulgaria) to carry out collection, recycling, reporting, and target performance on behalf of their members.
• PROs must meet aggregation/recycling/recovery targets set by law; if they fail, penalties and product-fee liabilities fall back on PRO and/or its members.
• PROs are typically required to provide a bank guarantee (e.g. BGN 1 million) to cover non-performance risk. (

Environmental Authority / Executive Environment Agency (ExEA)

• ExEA is the competent authority enforcing the EPR packaging regime, maintaining the public register, receiving reports, auditing, and imposing penalties
• It may issue annual orders confirming compliance of each scheme and each producer / importer.
• In case of non-compliance by PROs, ExEA may enforce bank guarantees or require payment of product taxes.

Municipalities, Waste Collectors, Sorting / Recycling Operators

• While not legally “producers,” municipal waste management, collectors, sorters and recyclers implement the collection and material recovery. They may contract or coordinate with PROs.
• They must comply with waste collection regulations and support separate collection systems mandated by Bulgarian law.

Consumers / End Users

• Consumers are indirectly responsible by participating in separate collection (sorting) and discarding packaging waste into designated streams.
• Producers / PROs must conduct awareness campaigns and provide disposal instructions.

In summary: legal responsibility lies primarily with producers/importers/distributors, but many operational duties can be delegated to PROs. The authority oversees enforcement and data transparency.

Duties of Each Group

Here is a breakdown of duties under EPR packaging in Bulgaria for each stakeholder group:

Group	Main Duties / Obligations
Producer / Importer / Distributor	Register on the public packaging register with ExEA. Declare packaging volumes by material, type, sale method, etc. Finance the cost of collection, recycling, recovery, disposal of packaging waste (or pay product fees/taxes if targets are not met). Submit annual reports via NWIS by 31 March. Maintain monthly records and submit to NWIS by the 15th of each month. Ensure labeling of packaging (material code). Conduct or support awareness / public information campaigns, provide disposal instructions. If dealing with SUPP, additional obligations relating to collection systems or fees.
PRO / Collective Scheme / Recovery Organization	Operate or manage collection, sorting, recycling, recovery (or contracting with operators). Aggregate member packaging volumes and meet recovery / recycling targets. Report to ExEA on aggregated performance. Provide data transparency, issue certificates to members. If failing to meet targets, manage fallback payment obligations or activate bank guarantee. Coordinate with municipalities, collectors, recyclers to optimize waste management. Possibly modulate fees depending on environmental performance of packaging (eco-modulation). Maintain administrative compliance, audits, and guarantee instruments.
Executive Environment Agency (ExEA) / Environmental Authority	Maintain the public register of entities placing packaged goods. Receive registrations, reports, audits, updates. Audit and validate compliance of producers / PROs. Impose penalties, enforce bank guarantees, require product tax payments for non-performance. Issue annual compliance orders / acknowledgments. Provide guidance, oversee implementation of separate collection infrastructure, enforce labeling and waste collection rules.
Municipalities / Collectors / Recyclers	Provide infrastructure for separate collection of packaging waste (e.g. bins, bring points). Perform collection, sorting, transport, and handover to recycling / recovery plants under contracts / coordination with PROs. Maintain reporting on volumes collected. Ensure compliance with local waste management regulations in cooperation with PROs / authorities.
Consumers / Public	Separate packaging waste according to required streams (e.g., plastics, paper, glass). Use collection bins or drop-off points. Follow disposal instructions provided on packaging or via awareness campaigns.

  Each group has a role to play; the system depends on coordination and performance across stakeholders.Stay ahead of global EPR requirements with our all-in-one compliance platform. Book a free demo today to see how easily you can register and report,whether it’s packaging, electronics, batteries, textiles, or any other regulated stream, anywhere in the world.Who Is ResponsibleHere are additional considerations, practical nuances, and upcoming changes to watch for in the EPR packaging regime in Bulgaria:

• EU Packaging Regulation (2025/2026 impact) The new EU Packaging and Packaging Waste Regulation (entered into force 11 February 2025, applicable from 12 August 2026) will replace the current Directive regime and may impose more harmonized obligations (reporting, fee modulation, transparency, reuse targets, traceability) across member states including Bulgaria.
• Free-riders / Underreporting Bulgaria has historically faced challenges with “free-riders” and underreporting of packaging volumes. Recent amendments broaden registration requirements (including to distance sellers) to curb this.
• Product fee / tax fallback mechanism If recycling or recovery targets are not met, producers or PROs are liable to pay a product fee / product tax (BGN per kg) for packaging placed on the market.
• A plastic packaging / SUPP specific tax of 2.33 BGN/kg is proposed from 2025 (and 0.25 BGN/kg for certain single-use plastics) for those failing obligations.
• Bank guarantees by PROs PROs are required to provide a bank guarantee (commonly BGN 1 million) to back non-compliance risk.
• Labeling & marking changes Since the 2022 amendments, the Möbius loop (“chasing arrows”) and Tidyman icons became voluntary; the material identification code (alphanumeric) remains mandatory.
• The labeling obligation must be adhered to for packaging introduced to the market from 1 January 2022 onward.
• Separate collection obligations for SUPP
• Producers of SUPP have more stringent obligations to organize separate collection systems or comply with higher fee contributions.
• Electronic reporting and the National Waste Information System (NWIS)
• Bulgaria uses NWIS for record keeping and reporting. Monthly data must be entered within 15 days, and annual report by 31 March.
• No Pay-As-You-Throw (PAYT) system currently Bulgaria does not yet have a nation-wide “pay as you throw” waste charging system, which could encourage better household sorting.
• Recycling targets and performance risk Under new calculation rules, Bulgaria may lag behind the 2025 recycling targets, especially for plastics, due to losses in recycling plants and underreporting.
• The European Environment Agency has flagged that Bulgaria is at risk of missing packaging recycling targets
• Coordination with municipalities
• Success of EPR depends on cooperation with municipalities (local collection infrastructure), as PROs must often rely on local collection networks.
• Penalties & enforcement
• Violations (e.g. failure to register, misreporting, lack of take-back obligations) can incur fines, enforcement actions, and demands for retroactive payments.

Practical compliance advice

• Use a certified local PRO (e.g. Lovat to outsource compliance burdens.
• Ensure your labeling and packaging declarations are precise and aligned with approved material codes.
• Maintain clear internal systems to track packaging volumes by material, region, and sales channel.
• Monitor regulatory developments around the EU Packaging Regulation to prepare for new requirements.
• Engage with local authorities and waste operators early to ensure collection pathways exist for your packaging types.