BEYOĞLU PROFESSIONALPPWR-EPR COMPLIANCE SERVICES

Bulgaria Packaging EPR · Operating workspace · 2026

Selling packaged goods in Bulgaria? Start with the operating route.

Bulgaria already operates an EEA/NISO packaged-goods register and a recovery-organisation framework. For a foreign seller, the practical sequence is producer → EPR AR → registration → recovery route → reporting and evidence.

PPWR + Bulgarian EPREEA / NISOEPR Authorised Representative4 recovery organisationsPUDOOS2026 cost workspace
Primary sources verified · 4 September 2026

The Bulgaria route

What actually happens when you start selling packaged goods in Bulgaria?

Before comparing organisations or tariffs, reduce the process to five operating stages.

Your job is to provide the commercial and packaging facts.

We determine the Producer, EPR AR route, EEA/NISO registration, recovery-organisation or PUDOOS route, regulatory funding, reporting calendar and evidence file. You do not need to assemble those institutions yourself.

01You

Tell us how the goods enter Bulgaria

Legal entity, establishment country, Bulgarian customer or importer, end-user route, packaging materials and annual quantities.

Input: transaction + packaging facts
02We analyse

We identify the Bulgarian Producer and EPR AR route

We apply the first-market transaction and establishment rules to determine the Producer, representation result and registration owner.

Output: Producer + representation position
03We set up

We activate the Bulgarian compliance structure

EEA/NISO registration is completed. For the covered EU cross-border route, the Bulgaria-established EPR AR mandate is activated. The recovery-organisation or statutory route is then established.

Output: active Bulgarian compliance setup
04You fund

Regulatory money stays separate

Recovery-organisation contributions or the PUDOOS product fee remain seller liabilities. Beyoğlu service revenue remains a separate commercial layer.

Output: regulatory prefunding
05We operate

Report → invoice → pay → retain evidence

Packaging quantities follow the selected reporting profile, invoices and regulatory payments are coordinated, EEA/NISO records stay current and evidence remains in the Bulgaria file.

Output: recurring compliance evidence
One Bulgarian difference

Collective fulfilment and PUDOOS are alternative compliance routes.

A valid recovery-organisation contribution and the statutory PUDOOS product fee are not added together as one universal Bulgaria EPR charge.

Practical result

Register first. Then operate the selected compliance route.

The commercial decision is not simply which operator has the lowest €/kg rate. Producer status, EPR AR, registration and the lawful fulfilment route come first.

01 · Bulgaria Compliance Route Wizard

Answer two operational questions. The page returns the producer, EPR AR, registration and next-action route without using probability language.

Where is the business established?
Who first supplies the Bulgarian market?
Your operating route

EU seller → Bulgarian end user

The covered EU-established producer appoints a Bulgaria-established EPR AR by written mandate under PPWR Article 45(3), then completes the Bulgarian registration and recovery route.

ProducerREQUIRED
EPR ARREQUIRED
Registration

Appoint a Bulgaria-established EPR AR by written mandate under Article 45(3), then complete the Bulgarian packaged-goods registration.

Next action

Execute the EPR AR mandate, register, select the recovery route and start reporting.

02 · EPR Authorised Representative

EPR AR is a Chapter VIII responsibility role. Manufacturer AR, customs broker, VAT representative, recovery organisation and regulator are different roles.

EU → BG

Article 45(3) · REQUIRED

The covered EU-established producer appoints a Bulgaria-established EPR AR by written mandate under PPWR Article 45(3), then completes the Bulgarian registration and recovery route.

THIRD COUNTRY → BG

Current Bulgarian packaging rule · NO PACKAGING-SPECIFIC EPR AR MANDATE

The direct seller is the PPWR producer. PPWR leaves a third-country EPR-AR mandate to national law; the current verified Bulgarian packaging rules require registration and do not add a packaging-specific mandatory EPR AR.

KEEP SEPARATE

Manufacturer AR ≠ EPR AR

EPR AR is a Chapter VIII responsibility role. Manufacturer AR, customs broker, VAT representative, recovery organisation and regulator are different roles.

03 · Registration workflow

The current Bulgarian packaged-goods register is live. Registration is filed electronically with EEA through NISO; Article 74 also sets the pre-start registration window and one-month change/deregistration rules.

01Determine Producer

Fix the entity that first places the packaged goods on the Bulgarian market.

02Article 74 window

Submit registration information electronically during the one-month period before the activity starts.

03EEA register

Register of persons placing packaged goods on the Bulgarian market · Waste Management Act Article 45(1)(13).

04NISO · НИСО

Electronic application and waste-information infrastructure.

05Recovery route

Declare the collective recovery organisation or lawful individual fulfilment route in the registration data.

06Maintain record

Declare changed registration data within one month; request deregistration within one month after cessation.

04 · Recovery organisations

Choose the recovery organisation only after the producer and registration route is fixed. Operator tariffs are commercial EPR-system tariffs, not national statutory fees.

Recovery organisation

ECOPACK Bulgaria

2026 base EUR/kg tariffs. The published 10% reporting and additional 20% payment discounts apply above 10 tonnes/year when the stated deadlines are met. Minimum annual fee: €80 excl. VAT.

Official source
Recovery organisation

Bulecopack

2026 base EUR/kg tariffs. The published 10% reporting discount uses the 14th deadline; the additional 15% payment discount follows the stated contract condition.

Official source
Recovery organisation

Eco Partners Bulgaria

Published 2026 EUR/kg tariff. The online system supports monthly, quarterly or six-monthly packaging reporting profiles.

Official source
Recovery organisation

ECOBULPACK Bulgaria

Published 2026 EUR/kg tariff. Previous-month report: 25th. Issued invoice: 5th of the following month.

Official source

05 · Money architecture

Keep operator contributions, PUDOOS, deposit money and Beyoğlu revenue in separate accounting lanes.

OPERATOR

Recovery-organisation contribution

Contracted operator EUR/kg tariff. VAT, minimum and published discount rules stay inside the operator lane.

STATUTORY

PUDOOS product fee

Statutory route for obligated persons outside the collective/individual exemption. It is not an operator surcharge.

DEPOSIT

National beverage DRS

Not operational in Bulgaria today. MOEW states that current national law lacks an operating mechanism; national work targets introduction from 2027.

SERVICE

Beyoğlu service revenue

Commercial service revenue remains separate from operator, authority, PUDOOS and deposit money.

06 · Multi-material 2026 cost workspace

Enter the packaging portfolio by material. The workspace totals all four published 2026 operator base tariffs and shows the PUDOOS statutory route separately.

Build the packaging portfolio

Enter kg for every material you place on the Bulgarian market. Zero is allowed; totals update instantly.

Packaging materialkgECOPACKBulecopackEco PartnersECOBULPACKPUDOOS
Plastic0.1250.1160.0870.0891.19
Plastic beverage bottles ≤3 L0.1510.1470.1070.1101.19
Paper / cardboard0.1180.1090.0820.0840.34
Steel / other metals0.0660.0610.0450.0470.07
Aluminium0.1520.1460.1070.1100.31
Glass0.1440.1350.1010.1060.10
Composite materials0.1740.1600.1200.1240.88
Wood0.0690.0640.0450.0480.20
Other0.2050.1940.1430.1450.41
Total packaging0.0 kg
ECOPACK · 2026 base contribution0.00EUR · excluding VAT
Bulecopack · 2026 base contribution0.00EUR · excluding VAT
Eco Partners · 2026 base contribution0.00EUR · excluding VAT
ECOBULPACK · 2026 base contribution0.00EUR · excluding VAT
PUDOOS statutory route0.00Alternative compliance lanes — never add PUDOOS to a valid operator contribution.

ECOPACK: Base comparison uses the published 2026 tariff. Discounts apply only under the published volume, reporting and payment conditions; minimum annual fee €80 excl. VAT.

Bulecopack: Base comparison uses the published 2026 tariff. Reporting and payment discounts remain separate because the published filing/payment conditions control them.

Eco Partners: The 2026 contribution is kilograms × published EUR/kg rate for each material; the total is the sum of all material contributions.

ECOBULPACK: The 2026 tariff is EUR/kg excl. VAT. Previous-month report: 25th; invoice payment: 5th of the following month.

PUDOOS: PUDOOS is the statutory product-fee route for obligated persons outside the collective/individual exemption. It is not added to a valid recovery-organisation contribution.

07 · Deadline explorer

Choose the exact operating route. The explorer returns the published deadline, rule and primary source for that route.

EEA / NISO packaged-goods registration

Deadline: Electronic application during the one-month period before market-placement activity starts

Operating rule: Article 74 requires electronic registration data before the activity starts. Changes are declared within one month; cessation is followed by a deregistration request within one month.

Open source · State Gazette of the Republic of Bulgaria

08 · Who does what?

The seller owns the facts and funding; the EPR AR performs its mandate; EEA/NISO runs the current national registration infrastructure; the recovery organisation runs contracted recovery compliance.

Seller / Producer

Owns the supply-chain facts, packaging ledger, declarations and regulatory funding.

EPR AR

Performs the written Chapter VIII mandate for the EU cross-border route that requires the Bulgaria-established representative.

EEA / NISO

Maintains the current packaged-goods registration and electronic waste-information infrastructure.

Recovery organisation

Runs contracted packaging recovery/recycling compliance and invoices its own tariff.

PUDOOS

Receives the statutory product fee on the state-fee route.

Beyoğlu

Coordinates the operating workflow; commercial service revenue stays separate from regulatory money.

09 · Evidence Pack Builder

Choose your scenario and generate the evidence pack that must stay in the Bulgaria country file.

Source hierarchy: law/authority for legal facts; operator for tariff and procedure.

Keep these records
  1. 01Producer-status / direct-to-end-user transaction record
  2. 02Written Bulgaria EPR AR mandate
  3. 03EEA/NISO registration record
  4. 04Recovery-organisation membership or individual fulfilment evidence
  5. 05Packaging material-and-weight ledger
  6. 06Declarations and reporting confirmations
  7. 07Invoices, payment proof and reconciliation
  8. 08Marketplace EPR evidence supplied
  9. 09Versioned primary-source snapshot

11 · Primary sources

Binding EU law and Bulgarian authority/register sources support legal facts. Operator sources support operator tariffs, reporting profiles and payment conditions.

Citation hierarchyBinding law / authority / register → legal factsRecovery organisation → tariff / reporting / payment procedureBeyoğlu → commercial service information only
01
EU_LAW · European UnionRegulation (EU) 2025/40 on packaging and packaging waste2026-09-04
02
NATIONAL_LAW · State Gazette of the Republic of BulgariaWaste Management Act Article 14a — national authorised-representative rule for EU-established persons2026-09-04
03
NATIONAL_LAW · State Gazette of the Republic of BulgariaPackaging and Packaging Waste Ordinance — Articles 74–76 registration procedure2026-09-04
04
REGISTER · Executive Environment Agency (ИАОС)Public register of persons placing packaged goods on the Bulgarian market2026-09-04
05
REGISTER · Executive Environment Agency (ИАОС)National Waste Information System (НИСО) and registration FAQ2026-09-04
06
AUTHORITY · Ministry of Environment and Water (МОСВ)Packaging recovery organisations — current market-share and permit information2026-09-04
07
GUIDANCE · Ministry of Environment and Water (МОСВ)Packaging product-fee questions and answers2026-09-04
08
AUTHORITY · Ministry of Environment and Water (МОСВ)2026 ministerial orders on recovery-organisation members and product-fee status2026-09-04
09
AUTHORITY · Ministry of Environment and Water (МОСВ)Current Bulgarian law has no operational national beverage deposit-system mechanism; national work targets 20272026-09-04
10
TARIFF · ECOPACK BulgariaPricing and Business Policy — 2026 base licence fees and discount conditions2026-09-04
11
TARIFF · Bulecopack Jsc.Tariff and terms of contract — 2026 rates and discount conditions2026-09-04
12
TARIFF · Eco Partners BulgariaPackaging recovery contribution tariff for 20262026-09-04
13
SYSTEM · Eco Partners BulgariaOnline reporting system — monthly, quarterly and six-monthly reporting profiles2026-09-04
14
TARIFF · ECOBULPACK Bulgaria2026 packaging tariff and monthly reporting/payment dates2026-09-04

FAQ

Who must register in Bulgaria's current packaged-goods register?

EEA states that all persons placing packaged goods on the Bulgarian market register in the public register under Waste Management Act Article 45(1)(13).

When is the Bulgarian registration filed?

Article 74 requires the electronic registration information during the one-month period before the activity of placing packaged goods on the market starts.

Does an EU-established seller shipping directly to Bulgarian end users need an EPR AR?

Yes. For the covered Article 3(1)(15)(c)/(d) route, PPWR Article 45(3) requires a Bulgaria-established EPR authorised representative appointed by written mandate.

Does PPWR itself impose the same EPR AR rule on a third-country producer?

No. Article 45(3) leaves that requirement to Member State law. The current verified Bulgarian packaging rules require packaged-goods registration and do not add a packaging-specific mandatory EPR AR.

Is NISO the PPWR Article 44 producer register?

No. NISO is the current Bulgarian waste-information infrastructure used for the existing packaged-goods register. Article 44 creates a separate PPWR national-register architecture.

Do I pay PUDOOS on top of a recovery-organisation invoice?

No. PUDOOS is the statutory state-fee route for obligated persons outside the collective/individual exemption. It is not an additive operator surcharge.

Are ECOPACK, Bulecopack, Eco Partners and ECOBULPACK statutory tariffs?

No. They are operator tariffs. The state product-fee amounts form a separate legal layer.

Is a national beverage DRS operating in Bulgaria today?

No. MOEW states that current Bulgarian law does not yet contain the operating mechanism. National work targets introduction from 2027.

What does Article 44 require for annual register reporting?

Article 44(7) and (8) set 1 June for information covering each full preceding calendar year under the PPWR register layer.

What should a professional user cite from this page?

Use binding EU or Bulgarian law and the competent authority/register source for legal facts. Use the relevant recovery-organisation source for its tariff, reporting profile and payment procedure. Beyoğlu commercial information is not a regulatory source.

Operate Bulgaria from one country file: decide the producer → set the EPR AR route → register → choose recovery → calculate → schedule → retain evidence.