COMMISSION STAFF WORKING DOCUMENT The early warning report for Bulgaria Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for Member States at risk of missing the preparation for re-use/recycling target on municipal waste
Date: 2018-09-24
Institutions: Directorate-General for Environment, European Commission
Subjects: Bulgaria, EU environmental policy, application of EU law, circular economy, environmental law, environmental protection, pollution control, prevention of pollution, waste, waste management

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   EUROPEAN COMMISSION  Brussels, 24.9.2018 SWD(2018) 413 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Bulgaria Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for Member States at risk of missing the preparation for re-use/recycling target on municipal waste {COM(2018) 656 final} - {SWD(2018) 414 final} - {SWD(2018) 415 final} - {SWD(2018) 416 final} - {SWD(2018) 417 final} - {SWD(2018) 418 final} - {SWD(2018) 419 final} - {SWD(2018) 420 final} - {SWD(2018) 421 final} - {SWD(2018) 422 final} - {SWD(2018) 423 final} - {SWD(2018) 424 final} - {SWD(2018) 425 final} - {SWD(2018) 426 final}  
 
 
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1.  Introduction 

This early warning report is part of the Commission's overall implementation report and aims 
to assist Member States at risk of failing to meet the 2020 target of 50 % preparation for re-
use/recycling of municipal waste set out in Article 11(2)(a) of Directive 2008/98/EC. It builds 
on  previous  support  provided  by  the  Commission  to  help Member  States  comply1  with  EU 
law in the area of municipal waste management. This resulted in country-specific roadmaps2 
being drawn up for the relevant Member States.  

The  assessment  underpinning  the  early  warning  report  is  based  on  a  collaborative  and 
transparent process involving the Member States concerned and an in-depth analysis of their 
most  recent  policy  developments.  This  also  involved  extensive  consultation  with  the 
authorities in charge of waste management.  

The possible actions identified during this process are based on the existing best practices and 
aim  to  help  Member  States  in  meeting  the  2020  municipal  waste  preparation  for  re-
use/recycling; they therefore focus on policy measures that can be taken forward in the short 
term. These actions should be seen as complementary to those recommended in the roadmaps 
that  were  drawn  up  as  part  of  the  preceding  compliance  promotion  activities  and  to  the 
recommendations made in the Environmental Implementation Review3. 

2.  Key findings of the early warning report for Bulgaria 

In  2016,  Bulgaria’s  municipal  waste  recycling  rate  (including  composting)  reported  to 
Eurostat was 32 % while the landfilling rate was at 64 %. Based on an analysis of existing 
and firmly planned policies in the area of waste management, Bulgaria is considered at risk of 
missing the 2020 target of 50 % preparation for re-use/recycling of municipal waste. 

The assessment4 that underpins the early warning report concludes that the separate collection 
of  recyclables,  including  bio-waste,  is  not  yet  being  carried  out  effectively,  that  economic 
incentives  for  citizens  to  separate  waste  are  missing  and  that  the  Extended  Producer 
Responsibility  schemes  in  Bulgaria  do  not  fully  cover  the  costs  of  separate  collection.  In 
addition, more investment is needed in projects higher up the waste hierarchy (e.g. recycling) 
that go beyond treatment of residual waste. 

The table below lists possible actions to support Bulgaria's efforts to improve its performance 
in waste management. 

1 http://ec.europa.eu/environment/waste/framework/support_implementation_1st_phase.htm 
2 Roadmap for Bulgaria: http://ec.europa.eu/environment/waste/framework/pdf/BG_Roadmap_FINAL.pdf 
3 http://ec.europa.eu/environment/eir/country-reports/index2_en.htm 
4 Eunomia Research & Consulting et al. (2018), ‘Study to identify Member States at risk of non-compliance with 
the 2020 target of the Waste Framework Directive and to follow-up phase 1 and 2 of the compliance 
promotion exercise. The early warning report: Bulgaria.’ 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Extended Producer Responsibility for packaging 

1)  Audits  of  the  data  reported  by  producers  or  Producer  Responsibility  Organisations 
(PROs) on amounts of packaging waste placed on the market, to ensure that it is in line 
with the data on municipal waste. 

2)  Consider  the  following  alternative  options  when  reviewing  the  Packaging  and 

Packaging Waste Ordinance: 

a.  re-specify the minimum collection service that PROs are required to provide so 
that there is a focus on door-to-door collection where this is appropriate; or 
b.  limit  the  number  of  PROs  dealing  with  each  municipality  to  only  one 
organisation and entitle the municipalities, which are effectively responsible for 
compliance with the recycling targets, to procure collection services (funded by 
the PRO) of a minimum standard required to comply.  

3)  Enforcement of the obligation for the producers to comply with the specific packaging 

recycling targets by imposing appropriate sanctions. 

Separate collection of bio-waste 

4)  Review of the existing plans on collection and treatment of bio-waste in terms of their 
assumptions  regarding  the  approach  to  collection,  the  capture  of  material,  and  the 
choice  of  bio-waste  treatment,  to  ensure  that  they  are  both  reasonable  and  internally 
consistent. 

5)  Development  of  national  waste  collection  guidance  for  municipalities  in  the  form  of 
minimum  service  standards  (to  complement  action  2).  These  standards  could  for 
example specify the type and volume of containers, the frequency of collection and the 
type of vehicle used, taking into account the type of housing stock, how rural the area 
is, typical climate, etc. 

6)  Roll-out  of  collection  services  to  those  types  of  premises  /  municipalities  where  the 

yield is likely to be highest. 

7)  Establishment  of  a  quality  assurance  mechanism  to  assure  the  quality  of  compost  or 

digestate derived from waste. 

8)  In  the  longer  term,  modification  of  the  wording  of  the  targets  for  bio-waste  separate 
collection  and  recovery  in  the  Waste  Management  Act  so  that  they  do  not  refer  to  a 
fixed  amount  of  bio-waste  from  2014.  This  approach  tends  to  hinder  bio-waste 
prevention,  especially  if  decreases  in  waste  generation  can  also  be  linked  to  other 
factors, such as decline in population. 

Separate collection – civic amenity sites 

9)  Setting  minimum  criteria  on  density  of  civic  amenity  sites  (i.e.  container  parks, 
household  waste  recycling  centres)  to  ensure  sites  are  located  within  reasonable 
distance to citizens, increasing convenience and the likelihood of them being used. 

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10) Establishing key design principles of civic amenity sites, including: 

a.  integration of re-use centres; 
b.  layout of facilities; and 
c.  rationale for high levels of staffing. 

11) Those  sites  could  first  be  established  in  those  municipalities  where  the  collection 
service  is  most  advanced  (i.e.  for  example,  where  door-to-door  separate  collection  is 
becoming  well  established)  to  maximise  the  likely  effectiveness  of  these  sites.  This 
would  also  allow  ‘best  practices’  to  be  identified  and  used  as  a  model  for  other 
municipalities. 

Economic incentives 

12) Implementation  of  relevant  changes  to  the  Local  Taxes  and  Fees  Act  so  that  Pay-As-

You-Throw schemes can be implemented. 

13) Roll out of pay-as-you-throw schemes first by municipalities where separate collection 

services of a minimum standard have been implemented (see action 6). 

14) Effective sanctions for PROs (as per action 3) and for municipalities which fail to meet 
the targets, under an amendment to Section II of the Waste Management Act to provide 
a strong incentive to meet targets.  

Communications and awareness raising 

15) Development of a set of national communications materials addressed to the public for 
use at local level, with clear and consistent messages, and with particular focus on bio-
waste.  These  materials  should  be  used  as  part  of  awareness-raising  campaigns,  in 
leaflets and at civic amenity sites. 

Technical support to municipalities 

16) Development  of  a  system  at  national  level  that  provides  technical  support  for 

municipalities, specifically in the following areas: 

a.  choosing collection services;  
b.  service procurement; 
c.  service management; 
d.  communication campaigns; 

coupled with active sharing of good ideas and practices that can improve efficiency in 
terms of cost reduction and improvement in performance. 

Efficient spending 

17) Review  the  funding  needed  to  achieve  the  50  %  target,  away  from  spending  on 
towards  separate  collection,  sorting  and  recycling 

treatment  of  mixed  waste 
infrastructure. 

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