No, they are not obliged to sign a contract with a Packaging recovery organization but they are obliged to ensure the separate collection of waste at their site. 

The way they are going to do it is not legally defined (in separate waste containers, bags, at certain places, etc.). However they decide to do it, they need to take into consideration the stipulations of the Waste Management Act and Municipal Ordinances concerning waste management. 

They also need to take into consideration the fact that the separate waste collection systems (color waste containers) that are organized by Packaging recovery organizations are intended for households.

For administrative and office buildings that generate similar to household waste (by origin and content) it is recommended to use the municipal separate waste collection system for the wastes generated at the site.

For commercial sites – they generate more wastes and they should sign a contract with a Packaging recovery organization or with a company that is in the possession of a Permit according to Art. 35 of WMA. 

Detailed information is given by the experts from Ministry of Environment and Waters – available only in Bulgarian: 

For the obligations of commercial sites – download pdf format here or follow the link:  http://www5.moew.government.bg/wp-content/uploads/file/Waste/VAPROSI_OTGOVORI/Zaduljeniya_turgovski_obekti.pdf

For separate waste collection in administrative buildings - download pdf format here or follow the link: http://www5.moew.government.bg/wp-content/uploads/file/Waste/VAPROSI_OTGOVORI/Ukazaniya_RSO_adm_sgradi.pdf

Sample inner rules for the organization of separate collection of waste in administrative buildings - download pdf format here or follow the link: http://www5.moew.government.bg/wp-content/uploads/file/Waste/VAPROSI_OTGOVORI/Pravila_RSO.pdf

Bulecopack Jsc. is an organization that unites companies from all over Bulgaria for a collective fulfillment of the obligations for packaging waste collection and recycling.

The frame of the activities of the packaging recovery organization is legally defined with the Waste Management Act, the Ordinance on Packaging and Packaging Waste and the Ordinance on product fee amount and the order of its determination.

The activities of the organization can be grouped in two main directions:

• Separate collection and recycling of packaging waste and
• Informing the citizens about the way the waste should be separated and the advantages for nature.

The activities of packaging recovery organizations are subject to control by MEW and annual audit.

Each year, on the grounds of controls and the audit report, the Minister of environment and waters issues an order for attainment of the targets.

If the branches of the company do not import and are not separate entities, the management of the company shall report the quantity of packaging imported into the country and placed on the market. Thus, after signing a contract with Bulecopack Jsc., the branches shall not be obliged. 

But if the branches are separate entities that function independently and import packed goods and sell on their behalf, they should sign a separate contract with Bulecopack Jsc.

Once you have signed a contract with Bulecopack Jsc., your only obligation is to report accurately and on time the quantity and type of packaging that are placed on the market and to pay the invoices on time.

The information required, is specified in Art. 5, Para. 1 of the contract:

1. By the 25th (twenty-fifth) day of the month- duly made, signed and stamped monthly report for the quantity of packaging placed on the market during the previous month, according to Appendix 2. The report for December should be submitted by January, 14th.
2. By January, 14th each year - duly made, signed and stamped monthly report for the quantity of packaging placed on the market during the previous year, according to Appendix 3 of the contract. The annual report should contain summarized information about the packaging, placed on the market from January, 1st until December 31st of the previous year.
3. Within 10 working days from the date of the request in writing by the ASSIGNEE- thorough information that is legally defined or necessary for the ASSIGNEE to execute his obligations according to the contract accurately and on time.

If you submit the monthly report by the 14th day, you are entitled to 10% (ten percent) discount of the remuneration (VAT excluded). The deadline for payment of the invoice is 10 working days from the date it has been received.

The membership in a packaging recovery organization contributes to fulfillment of the obligations according to international standards - ISO 9002 and ISO 14001. The contract is prepared in accordance with legal requirement and is approved by the Minister of Environment and Waters.
ISO 9000 is a standard for product quality management. Some of the requirements of ISO 9000 that are connected with packaging and product preservation are improving packaging processes, packaging, marking methods and procedures for safety and control of product quality and the quality of packaging materials. Bulecopack Jsc. Promotes Bulgarian national standards concerning packaging among its members. That is why we believe that the membership of your company in Bulecopack Jsc. shall contribute to obtaining ISO 9000.

As for ISO 14001 – Signing a contract with a packaging recovery organization itself for attaining the targets for separate collection and recovery is fulfillment of your legally defined obligation in environmental legislation, which is, in fact, one of the requirements of the System for environment management according to international standard ISO 14001.

Bulecopack Jsc. is certified according to: EN ISO 9001:2015; EN ISO 14001:2015 and BS OHSAS 18001:2007 with scope as follows:

Certificate EN ISO 9001:2015 for developed and implemented quality control system with the following scope: Management of the activities for separate collection, recycling and recovery of mass-spread wastes – download

Certificate EN ISO 14001:2015 for developed and implemented system for management of the environment with the following scope: Management of the activities for separate collection, recycling and recovery of mass-spread wastes – download

Certificate DIN ISO 45001:2018 for developed and implemented system for management of health and safety with the following scope: Management of the activities for separate collection, recycling and recovery of mass-spread wastes – download

One of the requirements of the standards is the certification of your suppliers according to them, too. By signing a contract with Bulecopack Jsc. You meet these requirements.

On signing a contract with Bulecopack you will receive a Certificate according to a sample, approved by the Minister of Environment ad Waters. You should present this certificate instead of a document for paid product fee, which is required at the customs.

If this is the first time that you sign a contract with a packaging recovery organization, that is not necessary.

If you have been a member of a packaging recovery organization and you transfer to another, then you need to inform the Minister of Environment and Waters within 20 days.

This requirement is according to Art. 51, Para. 2 of the Ordinance on packaging and packaging waste.

“Art. 51(1) Each year by 01 March each packaging recovery organization presents to the Minister of Environment and Waters a list of the members of the organization which have not paid the remuneration negotiated and/or which have not reported the quantity of packaging placed by them on the market during the previous year.

(2) The members of the packaging recovery organization, shall inform the Minister of Environment and Waters within 20 days from their transfer to another packaging recovery organization, and together with this notice they shall present a copy of the document certifying the termination of the contract.”

The membership in Bulecopack Jsc., respectively signing a contract concerns your obligations for attainment of the targets according to Art. 9, Para 1 of the Ordinance on packaging and packaging waste. By signing a contract with Bulecopack Jsc. You assign Bulecopack Jsc. to collect your packaging waste. Bulecopack Jsc. organizes systems for separate collection of packaging waste- by setting up systems for separate collection of packaging waste in municipalities and with sub-contractors that collect packaging waste at special sites. That is why, the obligations of your company defined in the WMA, concerning packaging, and the Ordinance on packaging and packaging waste are fulfilled and it is not necessary to organize by yourselves separate waste collection. 

In case your company accomplishes activities for separate collection and treatment of waste, you need to possess permit/ registration document according to the stipulations of Art. 35 from the WMA. For specific requirements for the sites, on which activities with waste are accomplished, see Art. 37 and Art. 38, Para. 1-3 of the WMA and Ordinance № 7 from 24 August 2004 for the requirements for sites where equipment for the treatment of waste is placed, as well as the respective ordinances for mass-spread wastes.

We have nothing in common with your purchases on the territory of the country. For the attainment of the targets for separate collection and recovery of the packaging waste- the persons that you have bought the goods from should report their packaging to Bulecopack or to the respective packaging recovery organization they participate in. 

You report to Bulecopack only the packaging that you import/ from intra-Community delivery and/or produce/pack and place on the market. If you buy a packed good from a trader from the country and you sell the good without changing the packaging, you do not need to declare it to Bulecopack, the trader must have already reported the packaging. The product fee is calculated only once for the respective packaging.

If you buy goods in bulk and after that sell by retail in different packaging, then you should report the new packaging to Bulecopack because you are the person that places the product in the new packaging on the market.

In the group “other packaging materials” are included textiles, ceramics, porcelain, nacre and others.

Wooden packaging- palettes, grates, coil, crate, case, wooden pads, cork pads, cork closures, etc. are reported in a different group.

The quantity of packaging, subject of the contract, is defined on the base of packed goods placed by your company on the market. What you need is information about the type and weight of your packaging (you can obtain this information from the producer of packaging or to ask for packing list if the goods are imported). The quantity of packaging is calculated on the base of produced/imported goods- for each product the weight of the packaging is multiplied by the number of goods sold. After which you sum similar packaging materials of different goods and thus you calculate the total weight of each packaging material. Here is an example:

You sell tomato puree and mayonnaise in the following packaged cuts:

 - puree - jar 200 ml – components of packaging: glass jar- 40 g; metal or composite cap- 8 g; label- 2 g; cardboard box + separating grid for 12 pcs. Jars- 360 g (30g per jar). In May you have sold 2000 pcs. tomato puree, 200 ml, packed as follows: 

- glass: 2000 pcs. х 0.40 g= 800 kg

- metal: 2000 pcs. х 0.08 g = 160 kg

- paper: 2000 pcs. х 0.02 g = 40 kg

- cardboard: 2000 pcs.х 0.30 g = 600 kg

- mayonnaise - jar 250 ml - components of packaging: glass jar - 50 g, metal or composite cap - 8 g label - 2 g cardboard box + separating grid for 12 pcs. Jars - weight 420 g (35g per jar). In May you have sold 1000 pcs. mayonnaise 250 ml., packed as follows: - стъкло: 1000 бр. х 0.50 гр.= 500 кг.

- metal: 1000 pcs. х 0.08 g = 80 kg

- paper: 1000 pcs. х 0.02 g = 20 kg

- cardboard: 1000 pcs.х 0.35 g = 350 kg

That means that the total quantity placed on the market is: glass: 1300 kg; metals: 240 kg; paper: 60 kg; cardboard - 950 kg (the paper and cardboard are reported in different cells since they have different codes according to the Ordinance on packaging, but the price is the same.)

Yes. You owe product fee. Product fees are meant to finance the environmental management of waste on the territory of the European Union, though they are different in the different countries. If as a result of your activity mass-spread wastes are generated on the territory of Bulgaria, you are responsible for their separate collection and recovery, which you may assign to Bulecopack Jsc. or to pay product fee to the Enterprise for management of the activities for environmental preservation (EMAEP).

The prices of Bulecopack are considerably lower than those of (EMAEP).

The quantity of the goods is described in the invoice for purchase. The type and quantity of packaging could also be included in that invoice. If not, you need to ask for a packing list. 

No, that is not necessary. The monthly report – declaration is filled in by the persons that place on the market packed goods by the 15th day of the month for the previous month. It is kept for a period of 5 years and is presented upon request from the competent bodies (RIEW).

“Art. 16. (1) For payment of product fee according to art. 2, Para. 1 the persons that place on the market packed goods, prepare a monthly report – declaration according to Appendix № 15.

(2) The monthly report – declaration according to Para. 1 is prepared by the 15th day of the current month and contains information about the packed goods placed on the market during the previous month.

(3) The product fee for the respective month is calculated on the base of the quantity of packaging materials, corresponding to the placed on the market packed goods or used to pack goods at the place of selling and the amount of the product fee according to Appendix 3.

(4) The monthly report – declaration according to Para. 1 shall be kept by the persons that place on the market packed goods for a period of 5 years from the date of its preparation and shall be presented to the competent bodies upon request.

(5) If no packaging/packaging materials have been placed on the market during the previous month, a zero monthly report – declaration shall be prepared.”

For the attainment of the targets for separate collection and recovery of these products and payment of product fee is responsible the person supplying the materials, since he is the person that places the goods on the market with his own trademark.

The deposit system is a way to use one packaging several times. Each system is specific and depends on the distribution, the type and the packaging of the product. If a company decides to implement a deposit system, it should ensure the returning of its packaging. In this case, the products are marked with the writing “For re-use”. They are reported to Bulecopack only the first time they are placed on the market.

You should take into consideration Art. 4, Para. 1 (3) from The Ordinance on packaging and packaging waste, which says that, in order to be suitable for re-use, packaging should:

"3. To be suitable for re-use, all the conditions should be met:

а) the physical properties and characteristics of packaging, when used by purpose, to allow a definite number of uses or circulation of packaging; 

b) to be possible to process the used packaging in a way that the requirements of human health and safety are observed; 

c) when packaging is no longer suitable for re-use and become waste, their recovery to be possible.”

Those examinations are made by accredited laboratories. The laboratory issues a protocol for the examination, on the base of which the persons that place on the market packed goods issue a correspondence declaration. The correspondence declaration is issued after a sample- Appendix 5 to Art. 6, Para. 2 of the Ordinance on packaging and packaging waste.

Could you give us information about plastic shopping bags?

Frequently asked questions about plastic shopping bags you can find here.