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Packaging obligations in Bulgaria (2026)

Verified on: 2026-09-01

Draft
1 documented obligationAuthorised representative: depends on situation4 Providers →
Legal framework (EU & national)
EU framework: 
PPWR (EU) 2025/40, applicable since 12 Aug 2026
National: 
Waste Management Act (Zakon za uprawlenie na otpadazite, ZUO); Packaging Ordinance (Naredba za opakowkite i otpadazite ot opakowki); Product Fee Ordinance (Naredba za opredeljane na reda i razmera za zaplaschtane na produktowa taksa) with payment to the state enterprise PUDOOS

Bulgaria has three compliance routes for parties placing packaged goods on the market: (1) joining a recovery organisation (organisazija po opolzotworjawane) authorised by the Ministry of Environment and Water (MOSW), (2) individual fulfilment with a permit, or (3) payment of the product fee to PUDOOS. Active recovery organisations according to the ministerial orders of May 2026: Ekopak Balgarija, Ekobulpak Balgarija, Bulekopak and Eko Partners Balgarija (no current orders were available for the older organisation Ekokolekt). A particularity: each year the Minister orders (most recently on 5 May 2026 for the year 2024), per organisation, which members are exempt from the product fee and which must pay in arrears – target fulfilment is confirmed retroactively per member. No national packaging producer register exists (the PPWR register under Art. 44 is pending); deposit return legislation is in preparation (drafts of January/April 2026, model contested).

Packaging EPR: recovery organisation or product fee (Bulgaria)

Anyone placing packaged goods on the Bulgarian market must ensure the separate collection and recovery of the packaging waste – as a rule by joining an authorised recovery organisation; anyone who is neither a member nor fulfils individually pays a monthly product fee to PUDOOS. Volumes must be documented and declared on an ongoing basis.

Authorised representativedepends on situation
DeadlinesOrganisation membership before placing goods on the market; product fee (where applicable) monthly by the 15th for the previous month together with the monthly declaration (Annex 13); internal specification (Annex 12) annually by 31 Dec for the following year; annual ministerial orders on product-fee exemption (most recently 5 May 2026, concerning 2024). PPWR obligations have applied since 12 Aug 2026.
CostsLicence fees of the recovery organisations per kg and material by contract (Ekopak Balgarija publishes its price and business policy for members); otherwise the product fee under the Product Fee Ordinance (rates per material in its annexes; amounts not individually verified here). Exported goods are exempt; for reusables in deposit systems the fee is charged only once.

Your to-dos

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Why does this affect me cross-border?
The MOSW FAQ names as obligated parties the 'liza, koito puskat na pazara opakowani stoki' (persons placing packaged goods on the market) – distance selling from abroad is not expressly addressed in it. For classic imports, the Bulgarian importer bears the obligations; foreign direct sellers to Bulgarian end customers come clearly into responsibility only via the PPWR producer definition (since 12 Aug 2026). Whether and how companies without a Bulgarian tax number can join a recovery organisation must be clarified with the respective organisation; Ekopak Balgarija also provides information in English.
Required documents
  • Contract/certificate of the recovery organisation (evidence of the assumption of obligations)
  • Monthly volume records per packaging material
  • Internal specification under Annex 12 and, where applicable, monthly declarations under Annex 13 of the Product Fee Ordinance
Sources & verification status

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Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.