Bulgaria Packaging EPR Training | Registration & Fees

Bulgaria Packaging EPR Compliance Training – From A to Z

Learn how to manage Bulgaria’s packaging registration, Extended Producer Responsibility (EPR), recycling scheme participation, material reporting, product fees and collection obligations.

Placing packaged products on the Bulgarian market creates responsibilities that extend beyond manufacturing, importing or selling goods. Companies must determine who is legally responsible for the packaging, establish suitable arrangements for waste collection and recycling, register where required and maintain reliable information on packaging materials and quantities.

Bulgaria operates its packaging EPR framework primarily through the Waste Management Act and the Ordinance on Packaging and Packaging Waste. Businesses placing packaged goods on the market are required to register through the National Waste Information System (NISO) and address their recovery and recycling obligations. These may be managed through a licensed packaging recovery organization or through an approved individual compliance arrangement. A statutory product-fee mechanism also applies in specified circumstances.

The EU Packaging and Packaging Waste Regulation (PPWR), which has applied since 12 August 2026, adds requirements that businesses must consider alongside Bulgaria’s national framework.

ComplyMarket GmbH offers this practical, one-day training at its Munich headquarters for manufacturers, importers, brand owners, online sellers and compliance professionals working with the Bulgarian market.

Participants will examine actual registration procedures, packaging classifications, reporting duties, recovery arrangements, cost structures and upcoming regulatory changes, using practical business examples.

Event Details

 

What Will You Learn?

By attending this training, participants will learn how to:

1.  Identify applicable packaging EPR legislation in Bulgaria and understand the roles of national and regional authorities.

2.  Determine producer responsibility for domestic manufacturers, importers, brand owners, distributors and cross-border sellers.

3.  Understand NISO registration and the information needed for the Bulgarian packaging producer register.

4.  Evaluate recovery organization participation against the formal requirements for individual compliance.

5.  Prepare packaging declarations using accurate material classifications, quantities and supporting records.

6.  Understand EPR-related costs, including commercial recovery contributions and statutory product fees.

7.  Assess collection and recycling duties for household, commercial, transport and reusable packaging.

8.  Identify relevant design and labeling obligations under Bulgarian legislation and the EU PPWR.

9.  Apply the requirements to business scenarios, including imported packaged goods and international supply chains.

One-Day Training Agenda

09:00-09:45 | Packaging EPR framework and packaging classification

The opening session introduces Bulgaria’s packaging waste legislation and explains how businesses identify packaging covered by producer responsibility requirements.

Topics include:

•  Bulgaria’s Waste Management Act and Ordinance on Packaging and Packaging Waste.

•  Responsibilities of the Ministry of Environment and Water (MOEW), Executive Environment Agency (ExEA/IAOS) and regional environmental inspectorates.

•  The distinction between packaging placed on the market and packaging waste generated afterward.

•  Sales or primary packaging, grouped or secondary packaging, and shipping or transport packaging.

•  Materials including plastics, paper, cardboard, glass, metals, composites and wood.

•  Reusable, commercial and service packaging, including how classifications affect compliance records.

09:45-10:30 | Who is responsible?

Participants examine the Bulgarian concept of placing packaged goods on the market and determine which business carries the relevant obligations.

Topics include:

•  Domestic manufacturers selling their own packaged products.

•  Importers bringing packaged goods from EU countries or outside the EU.

•  Private-label brand owners and the importance of contractual responsibility.

•  Online sellers, marketplaces and direct sales to Bulgarian customers.

•  Responsibility for goods packed by contractors or supplied through distribution chains.

•  Applicable exemptions, the absence of a general small-volume exemption in Bulgaria’s existing packaging rules, and representative requirements under the PPWR.

Practical example: A German business supplies packaged household goods to a Bulgarian distributor. Participants identify who first places the goods on the Bulgarian market.

10:30-10:45 | Coffee break

10:45-11:30 | Registration and competent bodies

This session explains the existing Bulgarian registration system and the information businesses need before beginning relevant market activities.

Topics include:

•  The public register under Article 45(1)(13) of the Bulgarian Waste Management Act.

•  Registration through the National Waste Information System (NISO).

•  Submission to the Executive Environment Agency in the statutory period before starting the activity.

•  Company identification, contact details, packaging materials, sales methods and compliance arrangements.

•  Requirements to update registered information when circumstances change.

•  Registration evidence, administrative procedures and the distinction between registration charges and recovery fees.

Participants will examine a practical registration-information checklist.

11:30-12:15 | EPR participation, producer schemes and packaging types

Bulgaria permits collective compliance through authorized recovery organizations and formally approved individual arrangements. This session compares the operational implications.

Topics include:

•  Licensed packaging recovery organizations and their role in recycling and recovery obligations.

•  Examples of Bulgarian operators, including ECOPACK Bulgaria, Bulecopack and Ecobulpack Bulgaria.

•  Participation contracts, reporting commitments and payment responsibilities.

•  Requirements for organizations and businesses fulfilling obligations individually.

•  How household collection differs operationally from commercial and transport packaging management.

•  The importance of confirming valid permits, contractual coverage and evidence of actual performance.

Participants will assess which compliance approach is appropriate for different business models.

12:15-13:00 | Lunch break

13:00-14:00 | Packaging quantity reporting

Accurate packaging information supports registration, recovery-organization reporting, product-fee calculations and regulatory inspections.

Topics include:

•  Preparing a packaging bill of materials for each product or packaging configuration.

•  Recording packaging quantities by material and weight.

•  Connecting product sales, imports and inventory movements to packaging declarations.

•  Monthly declarations under the applicable Bulgarian product-fee framework.

•  Recovery-organization reporting schedules, annual reconciliation and contractual deadlines.

•  Record retention, corrections, supporting documents and internal data controls.

The session also explains the monthly declaration prepared by the 15th of the following month under Article 16 of the Product Fee Ordinance, including its five-year retention requirement. Practical exercise: Participants classify packaging for an imported product and calculate the material weights needed for reporting.

14:00-14:45 | Collection, deposits and take-back

Collection responsibilities depend on the packaging stream, the compliance arrangement and the waste-management activities involved.

Topics include:

•  Bulgaria’s separate collection arrangements for household packaging waste.

•  Recovery organizations and their agreements with municipalities.

•  Collection routes for commercial, industrial and transport packaging waste.

•  Return and reuse arrangements for pallets, crates and other reusable packaging.

•  Existing business-operated deposit or reusable packaging systems.

•  Bulgaria’s proposed national deposit-return system for beverage packaging and the distinction between draft legislation and binding requirements.

Participants will review how collection arrangements influence practical compliance planning.

14:45-15:00 | Coffee break

15:00-15:45 | EPR licensing fees and recycling cost model

This session separates government product fees from commercial recovery-organization contributions and other operational costs.

Topics include:

•  Statutory product-fee obligations and the circumstances in which they apply.

•  The distinction between producer registration and recycling scheme participation.

•  Material-based and weight-based recovery contributions.

•  Published 2026 recovery-organization tariffs and their contractual conditions.

•  Potential charges for collection, logistics, recycling and specialized waste services.

•  Cost forecasting, data quality, invoice reconciliation and annual budgeting.

For illustration, ECOPACK Bulgaria publishes 2026 base contributions of €0.125/kg for plastics other than specified beverage bottles and €0.118/kg for paper and cardboard, excluding VAT. These are operator-specific commercial rates, not universal Bulgarian statutory fees. Practical exercise: Compare packaging-related costs for two material configurations using illustrative quantities.

15:45-16:30 | Packaging design, labeling, recycling and regulatory changes

Packaging EPR is only one part of packaging compliance. This session separates waste-management obligations from product and packaging design requirements.

Topics include:

•  Bulgaria’s existing packaging design and material requirements.

•  Packaging minimization, reuse and recyclability considerations.

•  Identification markings and relevant packaging labeling provisions.

•  Restrictions affecting certain substances, including PPWR rules for PFAS in food-contact packaging.

•  The PPWR provisions applying since 12 August 2026 and later implementation stages.

•  Future harmonized labeling, recycled-content, recyclability and reuse requirements, including changes scheduled from 2028 and 2030 where applicable.

Participants will identify which requirements apply now and which require preparation for future implementation.

16:30-17:00 | Practical case study and Q&A

The final session brings together the day’s learning through a cross-border business example.

Case study: A European manufacturer supplying packaged products to Bulgaria

Participants will:

•  Identify the business responsible for placing packaged goods on the Bulgarian market.

•  Classify consumer, grouped and transport packaging.

•  Determine the applicable registration process.

•  Evaluate collective and individual compliance options.

•  Prepare a basic material-weight reporting schedule.

•  Identify likely cost categories, collection arrangements and documentation risks.

The training concludes with questions and discussion of practical implementation challenges.

Who Should Attend?

This training is intended for organizations manufacturing, importing, distributing or selling packaged goods into Bulgaria, including:

•  Manufacturers and producers of packaged consumer or industrial products.

•  Importers sourcing goods from EU and non-EU markets.

•  Brand owners and private-label businesses.

•  Retailers, distributors and e-commerce sellers.

•  Packaging development, procurement and supply chain teams.

•  Environmental, sustainability, legal and regulatory compliance professionals.

•  Consultants supporting packaging registration and waste-management compliance.

The course is particularly relevant to companies entering the Bulgarian market, reviewing supplier responsibilities or improving packaging reporting across multiple European countries.

Why Attend ComplyMarket’s Packaging EPR Training?

Focus on Bulgaria’s actual requirements

The course examines Bulgarian registration procedures, competent authorities, recovery organizations and product-fee rules rather than applying a generic European EPR model.

Improve operational decision-making

Practical examples show how packaging classifications, producer responsibility and contractual arrangements affect compliance activities.

Understand packaging-related costs

Participants learn how to distinguish statutory obligations from commercial recycling contributions and identify the data required for reliable budgeting.

Prepare for regulatory changes

The training addresses current Bulgarian requirements alongside relevant PPWR implementation stages and proposed national changes.

The objective is to help participants identify the correct processes, ask better questions and establish a more structured approach to packaging compliance.

Frequently Asked Questions

1. Who must register for packaging EPR in Bulgaria?

Businesses placing packaged goods on the Bulgarian market generally fall within the registration framework. Depending on the transaction, this can include manufacturers, importers, brand owners and online sellers. The responsible entity must be identified from the actual supply arrangement.

2. Which packaging categories are covered?

Bulgaria’s packaging framework covers packaging placed on its market, including consumer, grouped, transport, commercial and relevant reusable packaging. Materials include plastic, paper, cardboard, glass, metal, wood and composites. Obligations depend on the packaging and the business activity.

3. Where do companies register?

The Executive Environment Agency maintains the relevant public register under the Waste Management Act. Registration information is submitted through NISO. The national ordinance establishes a pre-activity submission window and requires changes to registered information to be notified within one month.

4. Is joining a recovery organization mandatory?

Collective compliance through a licensed recovery organization is a common approach, but it is not the only legally recognized route. Businesses may also fulfill obligations individually under the applicable authorization and program requirements. The statutory product-fee mechanism applies in specified circumstances.

5. Is Bulgarian packaging EPR registration free?

The registration process must be distinguished from participation and product-fee costs. No universal administrative registration charge was established from the official sources reviewed for this training. Commercial recovery organizations charge according to their contracts, while statutory product fees follow separate legislation.

6. How are packaging EPR fees calculated?

Recovery organizations commonly calculate contributions using packaging material and weight. Rates and minimum contributions vary by operator and agreement. Bulgaria also has statutory product-fee schedules that are separate from commercial recovery contributions.

7. What packaging quantities must companies report?

Businesses need records of packaging materials and quantities associated with goods placed on the Bulgarian market. Product-fee declarations and recovery-organization reports have different procedures. For the applicable monthly product-fee declaration, the Bulgarian ordinance specifies preparation by the 15th of the following month.

8. Do foreign businesses need a local representative?

The answer depends on the sales model and applicable rules. Article 45(3) of the PPWR currently requires an EPR authorized representative for specified cross-border direct-to-end-user activities. A proposal to suspend or modify this requirement is under negotiation, but has not yet become binding law.

9. Does Bulgaria have a mandatory national beverage deposit-return system?

As of October 2026, Bulgaria has proposed legislation for a national deposit-return system for specified beverage packaging, but the national system has not yet entered operation. Existing business-operated reusable packaging and deposit arrangements are distinct.

10. How does the EU PPWR affect Bulgarian packaging compliance?

The PPWR applies in Bulgaria from 12 August 2026, with several requirements introduced in stages. Businesses must assess current measures, including relevant substance restrictions, while preparing for future labeling, recyclability, recycled-content and reuse provisions. Bulgarian registration and waste-management requirements remain relevant.

Register Your Interest

Planning to enter the Bulgarian market, improve packaging reporting or review your current EPR arrangements?

Join ComplyMarket’s Bulgaria Packaging EPR Compliance Training to develop a clearer understanding of the registration process, recycling responsibilities, reporting requirements and associated costs.

To express your interest or request information about the upcoming training, contact:

info@complymarket.com