Bulgaria creates new register for persons placing packaged goods on the domestic market

At the end of 2022, the Bulgarian Council of Ministers adopted amendments to the Packaging and Packaging Waste Ordinance (PPW Ordinance), establishing the terms and procedure for registration on the Register of Persons Placing Packaged Goods on the Market. The following outlines the main features of this Register:

• Who is obliged to register?

Producers, importers, and distributors who place packaged goods on the market are required to register. According to the Bulgarian Waste Management Act, "Placing on the market" basically refers to the first introduction of the packaged product within Bulgaria. In cases where the entity responsible for placing packaged goods cannot be determined, distributors (including those who sell directly to end consumers) must fulfil the same obligations including registering on the Register.

• What must be declared for registration?

The Executive Environmental Agency (EEA) has published two official forms for registration. The obliged entities must submit only one form or both, depending on their activity. The forms are as follows:

1. The form for registering, amending, or deregistering from the Register for entities placing packaged goods on the market. In this form, the obligated entity must declare all material types used for packaging placed on the market (e.g. packaging of a consumer unit, group packaging or transport packaging).
2. The form for registering, amending, or deregistering from the Register for entities placing single-use plastics products (SUPP) on the market in accordance with Part E of Appendix No 1 to Article 2 of the Ordinance on Reducing the Impact of Certain Plastic Products on the Environment. The SUPPs triggering this registration requirement include: food containers used for storing food intended for immediate consumption; plastic beverage bottles with a capacity of up to three litres (with certain exemptions); plastic packets and wrappers made of flexible material containing food for immediate consumption; plastic beverage cups including lids and caps; plastic carrier bags with a wall thickness below 50 microns; wet wipes; balloons (with certain exemptions); and tobacco products with filters. All SUPP producers must submit this form to fulfil their registration obligation, and state the type of SUPP they are placing on the market.

• Is there a deadline for registration?

Entities should apply for registration by 16 February 2023. They are also obliged to report changes in the declared information on an ongoing basis, within one month as of the respective change.

• How should the forms be filed?

Per the current procedure, forms should be submitted in writing to the attention of the Executive Director of the EEA. It should also soon be possible for forms to be submitted through the National Waste Information System (NWIS).

For further assistance with the registration process or to meet other obligations under Bulgarian law, contact your CMS client partner or local CMS experts Nevena Radlova and Margarita Ivanova.