COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - BULGARIA Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: Bulgaria, EU environmental policy, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 262 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       Country Report - BULGARIA               Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Bulgaria  1 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Any comments are welcome to the following email address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs:  

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Bulgaria  2 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. Circular economy and waste management .......................................................................................................... 4 

MEASURES TOWARDS A CIRCULAR ECONOMY ............................................................................................................. 4 
WASTE MANAGEMENT........................................................................................................................................... 6 

2. Biodiversity and natural capital ............................................................................................................................ 9 

NATURE PROTECTION AND RESTORATION ................................................................................................................... 9 
MARINE ECOSYSTEMS .......................................................................................................................................... 15 
ECOSYSTEM ASSESSMENT AND ACCOUNTING ............................................................................................................ 15 

3. Zero Pollution ..................................................................................................................................................... 17 

CLEAN AIR ......................................................................................................................................................... 17 
INDUSTRIAL EMISSIONS ........................................................................................................................................ 18 
MAJOR INDUSTRIAL ACCIDENTS PREVENTION – SEVESO ............................................................................................ 20 
NOISE ............................................................................................................................................................... 22 
WATER QUALITY AND MANAGEMENT ...................................................................................................................... 22 
CHEMICALS ........................................................................................................................................................ 26 

4. Climate Action .................................................................................................................................................... 28 

KEY NATIONAL CLIMATE POLICIES AND STRATEGIES ..................................................................................................... 28 
EFFORT SHARING TARGET ..................................................................................................................................... 28 
KEY SECTORAL DEVELOPMENTS .............................................................................................................................. 29 
USE OF REVENUES FROM THE AUCTIONING OF EU ETS ALLOWANCES ............................................................................ 30 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 31 

5. Financing............................................................................................................................................................. 31 

ENVIRONMENTAL INVESTMENT NEEDS IN THE EUROPEAN UNION ................................................................................. 31 
EU ENVIRONMENTAL FUNDING  2014-2020 ........................................................................................................... 32 
EU ENVIRONMENTAL FUNDING 2021-2027 ............................................................................................................ 34 
NATIONAL ENVIRONMENTAL FINANCING .................................................................................................................. 36 
GREEN BUDGET TOOLS ......................................................................................................................................... 38 
OVERALL FINANCING COMPARED TO THE NEEDS ........................................................................................................ 39 

6. Environmental governance ................................................................................................................................ 41 

INFORMATION, PUBLIC PARTICIPATION AND ACCESS TO JUSTICE .................................................................................... 41 
COMPLIANCE ASSURANCE ..................................................................................................................................... 43 
EFFECTIVENESS OF ENVIRONMENTAL ADMINISTRATIONS ............................................................................................. 45 
COORDINATION AND INTEGRATION ......................................................................................................................... 46 
REFORMS THROUGH THE COMMISSION’S TECHNICAL SUPPORT INSTRUMENT (TSI) .......................................................... 46 
TAIEX EIR PEER TO PEER PROJECTS ....................................................................................................................... 46 

 
 
 
 
 
 
 
 
 
 
Bulgaria  3 

Executive summary 

The main challenges identified in past EIRs with regard to 
implementation  of  EU  environmental  policy  and  law  by 
Bulgaria were: 

 
 

 

the need to improve air quality 
the  need  to  ensure  appropriate  collection  and 
treatment of urban waste water; and 
the  need  to  properly  implement  nature  protection 
legislation. 

implementing  measures 
in 
Despite  some  progress 
addressing  air  pollution,  it  is  still  cause  for  serious 
concern.  Bulgaria  is  one  of  the  Member  States  with  the 
most  pollution-related  deaths,  number  of  years  of  life 
lost  associated  with  air  pollution,  and  urban  population 
exposure to micro-particles. 

There  has  been  no  significant  progress  in  ensuring 
compliance with the  urban wastewater requirements of 
EU  law.  The  overall  compliance  rate  in  Bulgaria  is  30%, 
which is the fourth lowest in the EU.  

Waste management continues to be a challenge, despite 
municipal  waste  generation  remaining  below  the  EU 
average.  There  is  no  progress  on    the  ‘polluter  pays’ 
principle  since  the  2017  and  2019  EIRs.  Bulgaria 
continues  to  postpone  applying  a  fairer  calculation  of 
waste  collection  fees  after  adopting  the  necessary  legal 
basis  years  ago.  Implementation  of  nature  protection 
legislation also remains a challenge. Bulgaria is advancing 
with  the  designation  of  special  areas  of  concervation 
(SAC).  However,  Bulgaria  has  yet  to  establish  the 
site-specific  conservation  objectives  and 
requisite 
measures for all of its Natura 2000 sites.  

Although  in  an  advanced  stage  of  preparedness,  the 
overarching circular economy  policy programme has yet 
to be adopted and applied in Bulgaria. 

is  facing 

in  many  spheres, 

Short-lived parliaments and political instablity in most of 
2021  did  not  help  as  regards  addressing  the  challenges 
Bulgaria 
including  the 
environment.  The  coalition  agreement,  signed  by  the 
parties  that  formed  a  government  in  December  2021  is 
the  first  general  political  document  of  governing  parties 
with explicit and detailed commitments on environment. 
However,  it  is  not  clear  if  this  agreement  is  of  a 
programming  nature  for  the  government  and  whether 
implementation  of  the 
there 
commitments. 

is  a  timeline  for  the 

From  the  European  Structural  and  Investment  Funds 
(ESIFs),  Bulgaria  received  EUR  1  667.5  million  to  cover 
direct environmental investments in 2014-2020. Bulgaria 
has  spent  less  than  one  third  of  it  –  EUR  505  million. 
Most of the funds were spent on water management EUR 
285.7  million;  on  climate  mitigation  and  adaptation,  risk 
management  –  EUR  60.9  million;  on  biodiversity  and 
nature – EUR 55 million; on waste management – EUR 49 
million;  and  on  air  quality  –  EUR  16.2  million  –  all  far 
below  the  planned  allocations.  On  land  rehabilitation 
Bulgaria  spent  EUR  38.1  million,  which  is  slightly  above 
the  originally  allocated  amount.  Total  environmental 
financing  in  2014-2020  is  estimated  to  have  reached 
1.91% of GDP, while the investment needs for 2021-2027 
least  2.98%  of  GDP,  signalling  a  significant 
are  at 
financing gap (over 1.07% of GDP).  

Bulgaria  is  due  to  receive  EUR  6.27  billion  from  its 
recovery  and  resilence  plan  (RRP)  (2021-2026)  and  EUR 
9.77 billion from the cohesion policy (ERDF, CF, ESF+ and 
ETC(ERDF)) (2021-2027). 

Environmental Implementation Review 2022 - Bulgaria 

 
 
 
 
Bulgaria  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Measures towards a circular economy 

 The  new  Circular  Economy  Action  Plan  adopted  in 
March  2020  is  one  of  the  main  building  blocks  of  the 
European  Green  Deal.  The  EU’s  transition  to  a  circular 
economy will reduce pressure on natural resources and 
will  create  sustainable  growth  and  jobs.  It  is  also  a 
prerequisite to achieve the EU’s 2050 climate neutrality 
target  and  to  halt  biodiversity  loss.  The  Action  Plan 
announces  initiatives  along  the  entire  life  cycle  of 
products,  aiming  to  reduce  the  EU's  consumption 
footprint  and  to  double  the  EU's  circular  material  use 
rate  by  2030.  It  targets  how  products  are  designed, 
promotes  circular  economy  processes,  encourages 
sustainable consumption, and aims to ensure that waste 
is prevented and the resources used are kept in the EU 
economy for as long as possible. 

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s  circularity,  as  it  includes  all  materials  that 
are fed back into our economy. Large differences in the 
circularity  rate  exist  among  countries.  To  help  achieve 
the  goal  in  the  EU  circular  economy  action  plan  of 
doubling  the  EU  circular  material  use  rate  by  2030, 
ambitious  measures  targeting  the  whole  product  life 
cycle  are  needed  at  Member  States’ 
level.  Such 
measures  range  from  sustainable  product  design  that 
makes it possible to increase the durability, reparability, 
upgradability  and  recyclability  of  products,  to  other 
measures such as (i) remanufacturing; (ii) increasing the 
circularity  in  production  processes;  (iii)  recycling;  (iv) 
boosting  eco-innovation;  and  (v)  increasing  the  uptake 
of green public procurement. 

Figure 1: Circular material use rate (%), 2010-20201 

The circular (secondary) use of material in Bulgaria was 
4.3% in 2016 and 2.6% in 2020, significantly lower than 
the  EU  average  of  12.8%.  It  demonstrates  a  steady 
decline in secondary material usage in recent years with 
a slight positive change of trend in 20202.  

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown 
in Figure 2, with EUR 0.36 generated per kg of material 
consumed  in  2020,  resource  productivity  in  Bulgaria  is 
well below the EU average of EUR 2.09 per kg. 

Figure 2: Resource productivity 2010-20203 

Circular economy strategies  

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole life cycle of products. This 
is because such strategies are one of the most effective 
ways to progress towards a more circular economy at a 
Member  State  level.  Since  the  launch  of  the  online 
Circular  Economy  Platform  in  20174,  national,  regional 
or  local  authorities  have  used  the  platform  to  share 
their strategies and roadmaps. 

On  2  December  2020,  the  national  development 
programme  ‘Bulgaria  2030’  was  adopted.    It  is  a 
strategic  framework,  which  determines  the  vision  and 

1 Eurostat, Circular Economy Monitoring Framework.  

2 Eurostat, Circular material use rate 
3 Eurostat, Resource productivity 
4  Circular economy stakeholder platform 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
 
                                                                 
Bulgaria  5 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the 
full  potential  of  the  circular  economy  can  only  be 
reached when it is implemented across all value chains. 
Eco-innovation  is  an  important  enabling  factor  for  the 
circular  economy.  New  approaches  to  product  design  
and new business models can help to produce systemic 
circularity 
business 
opportunities. 

innovations, 

creating 

new 

In  2021,  Bulgaria  occupied  the  last  rank  on  the  2021 
indicating  the  country’s 
Eco-Innovation  Scoreboard, 
need  to  urgently  catch  up  with 
  eco-innovation 
activities. In all five components (eco-innovation inputs, 
eco 
innovation  outputs, 
resource  efficiency  outcomes  and  socio-economic 
outfits)  of  the  Eco-Innovation  Index,  Bulgaria  performs 
well below  the EU average. 

innovation  activities,  eco 

Figure 3: Eco-innovation performance 2010-20198 

overall  goals  of  development  policies  in  all  sectors  of 
state governance.  The main objective of its ‘green and 
sustainable Bulgaria’ priority is to increase the resource 
productivity. There is a focus on shifting from landfilling 
to  prevention,  reuse,  recycling  and  recovery  of  waste. 
Rational  and  responsible  use  of  waste  will  be  a 
fundamental 
the 
environment  and  achieving  sustainable  economic 
growth. Bulgaria has not adopted sectoral strategies on 
textiles  or  plastics  and  has  not  updated  its  2011-2020 
strategic  plan  on  construction  and  demolition  waste. 
the  national  development  programme 
However, 
initiatives  targeting  these 
‘Bulgaria  2030’ 
sectors. 

prerequisite 

improving 

includes 

for 

A  strategy  and  action  plan  for  transition  to  circular 
economy  in  Bulgaria  2021-20275  was  drafted  in  June 
2021. The draft is focused on three strategic objectives: 
1) Green and competitive economy; 2) Less waste, more 
resources and 3) Economy to the benefit of consumers. 
The  Action  Plan  consists  of  short-term,  mid-term  and 
long-term  measures.  The  short-term  measures  include 
drafting  and  adoption  of  sectoral  legal  acts  to  cover 
single use plastics, green procurement, etc. This is a first 
step  by  Bulgaria  to  develop  an  overarching  circular 
economy  policy  programme  demonstrating  some 
progress in implementing the priority action received in 
2019 EIR. 

of 

the 

component 

environmental 

new 
The 
government’s  coalition  agreement  has  a  chapter 
dedicated  to  the  circular  economy6.  It  provides  for  a 
review  and  update  of  the  strategy  and  action  plan  for 
transition to circular Economy. However, the document 
does  not  provide  any  specific  commitments  as  regards 
timeline  and  actions  for  implementation  of  the  agreed 
measures. 

The  2021-2028  waste  management  plan    was  adopted 
in  June  20217.  The  plan  should  play  a  key  role  in 
achieving  a  resource-efficient  and  sustainable  waste 
management. It envisages implementation of measures 
in  the  strategy  for  the  transition  to  a  circular  economy 
concerning products containing critical raw materials for 
the  EU  and  for  Bulgaria  to  prevent  as  far  as  possible 
products containing such raw materials from becoming 
increasing  the 
waste. 
qualification  and  skills  for  effective  use  of  resources 
under  the  green  transition  and  the  circular  economy 
and  raising  awareness  of  practices  and  behaviour  in 
sustainable consumption, and the circular economy. 

It  also  sets  the  aims  of 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
consumption,  with  public  authorities’ 
purchasing  power  representing  14%  of  EU  GDP.  Public 
procurement can help drive the demand for sustainable 
products  that  meet  repairability  and  recyclability 
standards.  To  date  reporting  to  monitor  the  uptake  of 
green public procurement (GPP) is voluntary. 

A  national  strategy  for  development  of  the  public 
procurement sector in Bulgaria is in force, as well as an 
Action  Plan  for  the  period  2014-2020.  In  2020,  the 
promotion  of  GPP  and  the  results  of  the  project 
"Methodological support for the development of GPP in 
the  Bulgarian-Swiss  cooperation 
Bulgaria"  under 

5 Draft Strategy and action plan  for  transition to Circular Economy in 
the Republic of Bulgaria 2021-2027 
6 Annex 11 to the coalition agreement 
7 National waste management plan 2021-2028 

8  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation scoreboard and the 
eco-innovation index. 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
                                                                 
programme  also  continued  through  awareness  raising 
(e.g.  distribution  of  a  practical  handbook  on  green 
public  procurement,  update  of  information  regarding 
green  criteria  at  EU  level),  trainings  on  green  public 
procurement by the Public Procurement Agency. 

Ecolabel and the Eco Management and Audit Scheme 
(EMAS) 

The  number  of  EU  Ecolabel  products  and  EMAS-
licensed9 organisations in a given country provides some 
indication of the extent to which the private sector and 
in  that  country  are  actively 
national  stakeholders 
engaged in the transition to a  circular  economy. It also 
shows  how  committed  public  authorities  are  to 
supporting 
instruments  designed  to  promote  the 
circular economy. 

As of September 2021, Bulgaria had 89 products out of 
83 590, and 5 licenцes out of 2 057, registered in the EU 
Ecolabel scheme. This shows a continued very low take-
up of both the products and the licences. Moreover, as 
of  October  2021,  17  organisations,  amounting  to  40 
sites  in  Bulgaria  are  registered  in  EMAS.  Nevertheless, 
since 
  2019,  there  have  been  66  new  product 
registrations  of  the  EU  Ecolabel,  as  well  as  8  new 
organisations  registered  with  EMAS.  EU  Ecolabel 
licensers have remained the same. 

Bulgaria  has  made  some  progress  in  implementing  the 
2019  priority  action  on  developing  a  comprhensive 
circular  economy  strategy  but  has  not  yet  adopted  it. 
Therefore 
is  maintained.  As  Bulgaria’s  circular 
material  use  rate  is  well  below  the  EU  average,  a 
priority action on this is proposed. 

it 

2022 priority action 

  Bulgaria  should  adopt  and  start  implementing  the 
strategic long-term view and an integrated approach 
to mainstreaming government’s policies to speed up 
the uptake of the circular  economy by all economic 
sectors. 

  Bulgaria  should  adopt  measures  to  increase  the  

circular material use rate. 

Waste management 

Turning waste into a resource is supported by:  
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
landfill  diversion 
separate  collection  of  waste,  the 

9  EMAS  is  the  European  Commission’s  eco-management  and  audit 
scheme,  a  programme  to  encourage  organisations  to  behave  in  a 
more environmentally sustainable way. 

Bulgaria  6 

targets, etc.;  
(ii) reducing waste generation and waste generation per 
capita in absolute terms;  
(iii) limiting energy recovery to non-recyclable materials 
and phasing out  landfilling of recyclable or recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste10  for  which  EU  law  sets  mandatory  recycling 
targets. 

resource  efficiency  and 

Preventing  products  and  materials  from  becoming 
waste for as long as possible is the most efficient way to 
improve 
the 
environmental  impact  of  waste.  Waste  prevention  and 
re-use are the most preferred options and are therefore 
at  the  top  the  waste  hierarchy.  The  amount  of 
municipal  waste  generated  is  a  good  indicator  of  the 
effectiveness of waste prevention measures. 

reduce 

to 

There is no clear trend in municipal waste generation in 
Bulgaria.  It  came  to  407  kg/y/inhabitant  compared  to 
the  EU  average  of  496  kg/y/inhabitant  after  a  peak  in 
2017,  when  it  reached  435  kg/y/inhabitant.  That  was 
after  a  slight  downward  trend  since  2014  as  Figure  4 
shows.  In  2018,  the  municipal  waste  generation  in 
Bulgaria was the fifth lowest in the EU. 

Figure 4: Municipal waste by treatment in Bulgaria, 
2010-201811 

10    Municipal  waste  consists  of  (a)  mixed  waste  and  separately 
collected  waste  from  households,  including  paper  and  cardboard, 
glass,  metals,  plastics,  bio-waste,  wood,  textiles,  packaging,  waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators, and bulky waste, including mattresses and furniture; (b) 
mixed  waste  and  separately  collected  waste  from  other  sources, 
where such waste is similar in nature and composition to waste from 
households. (Directive 2008/98/EC, Art. 3 2b).  
11       Eurostat,  Municipal  waste  by  waste  operation,  April  2022  (2019 
and 2020 data not yet available from Bulgaria). 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
 
                                                                 
In  2018 

Figure 4 also shows municipal waste by treatment type 
and  by  kg  per  capita.  There  is  no  clear  trend  in  the 
landfilling 
treatment  of  municipal  waste. 
stabilised at slightly above 60% of the waste generated, 
energy  recovery  doubled  compared  to  2017,  while 
composting  dropped  dramatically  from  nearly  8%  in 
2017 to less than 2% in 2018. Despite having one of the 
lowest levels of generation of municipal waste, Bulgaria 
remains  one  of  the  Member  States  with  the  highest 
landfilling rate (61% in 2018 compared to EU average of 
24%). 

landfills  that  operate 

Moreover,  based  on 
information  available  to  the 
Commission,  it  appears  that  there  are  irregular  and 
substandard 
in  Bulgaria  and 
present  serious  risks  for  human  health  and  the 
environment.  Studies  and  investigations  launched  by 
the  European  Commission  found  that  in  a  number  of 
landfills, waste is not subject to treatment that includes 
streams  and 
selection  of  waste 
an  adequate 
stabilisation  of  organic  waste.  Also,  the  network  of 
installations for treatment of waste before landfilling for 
mixed  municipal  waste  and  biowaste  is  insufficient.  In 
initiated  an 
November  2021  the  Commission  has 
infringement  procedure  against  Bulgaria12  for  failing  to 
comply  with  the  Landfill  Directive13  and  the  Waste 
Framework Directive14. 

of 

in  all 
Despite  having  stopped  accepting  waste 
substandard landfills covered by the Court judgement in 
case C-145/14 Commission v Bulgaria,  Bulgaria has not 
yet completed the works to ensure definite closure and 
Bulgaria’s 
these 
rehabilitation 
implementation record thus still needs improvement to 
ensure,  as  a  matter  of  priority,  definitive  closure  and 
rehabilitation  as  well  as  elimination  of  any 
illegal 
landfills.  Despite  significant  progress  in  the  closure  of 
non-compliant  sites,  their  rehabilitation  still  remains  a 
challenge. 

landfills. 

As noted in the previous environmental implementation 
country reports, in 2013, Bulgaria introduced a law that 
required waste collection fees to be calculated based on 
the waste generated, instead of on the value of the real 
estate  property.  It  was  due  to  enter  into  force  on  1 
January  2015  but  has  been  postponed  a  number  of 
times,  the  last  target  date  being  1  January  2022. 
However, in February  2021, an amendment  to the Law 
on Local Taxes and Fees by an amendment to the 2020 

12 INFR(2021)5342. 
13 Directive 1999/31/EC. 
14 Directive 2008/98/EC. 

Bulgaria  7 

Law415 

further 

the 
‘Pandemic 
implementation  of  the  polluter-pays  principle  until  1 
January of the second year  following the publication of 
the 2021 census results, i.e. at least until 2024. 

postponed 

After  a  slight  increase  in  the  rate  of  recycling  of 
municipal waste (including composting) in 2017, in 2018 
Bulgaria went back to the 2016 level of 32% due to the 
significant  decrease  in  composting.  This  rate  is  well 
below the EU average of 46 % (EU 2017). Figure 5 shows 
that Bulgaria needs to step up investment in recycling to 
meet the EU 2020 and 2025 recycling targets. 

Figure 5: Recycling rate of municipal waste, 2010-
201816 

The Commission's Early Warning report'17 listed Bulgaria 
as  one  of  the  countries  at  risk  of  missing  the  EU  2020 
target  of recycling 50 % of municipal waste. The report 
listed key priority measures which  Bulgaria should take 
to  close  the  implementation  gap.  The  Commission  is 
currently  finalising  its  analysis  of  the  progress  on  the 
recommendations from the 2018 Early Warning Reports 
and an analysis of progress towards achieving the 2025 
waste  recyling  targets.  This  report  will  be  presented  at 
the  end  of  2022    and  will  assess  the  progress  made  to 
date. 

15 Act amending and supplementing the Act on measures and actions 
during the state of emergency, announced by decision of the National 
Assembly of 13 March 2020, and addressing the consequences, §15. 
16    Eurostat,  Recycling  rate  of  municipal  rate,  april  2022  (2019  and 
2020 data not yet available from Bulgaria). 
17  European  Commission,  Report  on  the  implementation  of  waste 
legislation,  including  the  early  warning  report  for  Member  States  at 
risk  of  missing  the  2020  preparation  for  re-use/recycling  target  on 
municipal waste, SWD(2018)422 accompanying COM(2018)656. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
                                                                 
Implementation of the 2018 waste legislative package 

Bulgaria  has  notified  to  the  Commission  the  national 
legislation  transposing  the  2018  waste  package.18  A 
conformity assessment is ongoing. 

Bulgaria  8 

for 

are 

Waste  management  plans  and  waste  prevention 
programmes 
sound 
instrumental 
implementation  of  EU  waste  legislation.  They  set  out 
key  provisions  and  investments  to  ensure  compliance 
with  existing  and  new  legal  requirements  (e.g.  waste 
preventiion, separate collection for a number of specific 
waste  streams,  recycling  and  landfill  targets).  Revised 
plans and programmes were due on 5 July 2020. 

a 

Bulgaria  has  amended  its  National  waste  management 
plan.  According  to  the  Commission’s  assessment,  it 
seems  that  the  WMP  does  not  comply  with  the 
requirement  to 
litter 
introduced with the 2018 waste package. 

include  measures  to  combat 

In  the  2019  EIR,  four  priority  actions  were  set  for 
Bulgaria.  As  there  is  little  to  no  progress  in  their 
implemention  and 
light  of  the  upcoming  Early 
warning report, they are reiterated, and a priority action 
for the waste management plan is added. Bulgaria also 
received a general priority action in 2019 on signing and 
ratifying outstanding international agreements. 

in 

2022 priority actions 

  Complete  the  process  of  rehabilitation  of  non-

compliant landfills. 

  Prevent illegal dumping of waste, including littering. 
 
Improve  and  extend  separate  collection  of  waste, 
including 
for  biowaste.  Set  minimum  service 
standards  for  separate  collection  (e.g.  frequency  of 
collection, types of containers, etc.) in municipalities 
to ensure high rates of capture of recyclable waste. 
Develop 
support 
programmes  for  municipalities  to  help  support 
efforts  to  organise  separate  collection  and  improve 
recycling performance.  

implementation 

and 

run 

  Enforce and use economic instruments, such as pay-

as-you-throw. 

  Ensure  a  national  waste  management  plan  in  line 
with  the  requirements  of  the  revised  Waste 
Framework Directive is in place. 

  Ratify  relevant  international  conventions  on  ship 

recycling. 

18  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up 
to 2035. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
Bulgaria  9 

2. Biodiversity and natural capital

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and  sets  out  new  targets  and  governance  mechanisms 
to achieve healthy and resilient ecosystems.  

In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s  protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests;  
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 

The  EU’s  Habitats  and  Birds  Directives  are  the  key 
legislative  tools  to  deliver  on  the  targets  of  the  EU 
biodiversity  strategy for 2030, and are the  cornerstone 
of  EU  legislation  aimed  at  conserving  the  EU’s  wildlife, 
natural habitats and ecosystems19. 

A new biodiversity strategy for Bulgaria was prepared; it 
went  through  public  consultation  in  2021.  Its  adoption 
is  pending.  The  strategic  document  sets  the  main 
objectives and targets to be met by Bulgaria in the next 
decade  and  formulates  specific  measures  and  actions. 
All  12 national  objectives  set in the document respond 
to    commitments  taken  at  global  level  or  relate  to  the 
targets set in the EU 2030 biodiversity strategy. 

in  Bulgaria  – 

The  planned  actions  aim  to  tackle  long  standing  issues 
facing  nature  conservation  and 
and  weaknesses 
the  enforcement  of 
biodiveristy 
environmental  regulations,  the  effective  management 
of  protected  areas  based  on  sound  monitoring  and 
clearly  defined  objectives,  and  the  estblishment  of  a 
coherent  and  representative  national  structure  for  the 
management of the country’s rich natural heritage. 

Nature protection and restoration  

Natura  200020,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 

19  These  should  be  strengthened  by  the  Nature  Restoration  Law, 
according to the new EU biodiversity strategy. 
20  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 

achieve  the  objectives 
in  the  Birds  and  Habitats 
Directives.  These  objectives  are  (i)  to  ensure  the  long 
term  protection,  conservation  and  survival  of  Europe's 
most valuable and threatened species and habitats; and 
(ii)  to  maintain  or  restore  the  favourable  conservation 
status  of  these  species  and  habitats.  Key  milestones 
towards  meeting  the  objectives  of  the  Birds  and 
Habitats Directives are: (i) the setting up of a  coherent 
Natura  2000  network;  (ii)  the  designation  of  sites  of 
community  importance  (SCIs)  as  SACs21;  and  (iii)  the 
setting  of  site-specific  conservation  objectives  and 
measures for all Natura 2000 sites.  

Setting up a coherent network of Natura 2000 sites 

Bulgaria  hosts  92  habitat22  types  and  209  species23 
covered  by  the  Habitats  Directive.  The  country  also 
hosts populations of 184 bird species listed in the Birds 
Directive Annex I24 and 126 migratory birds. 

At 2021, 34.9% of the territory of Bulgaria was covered 
by Natura 2000 (EU average 18.5%).  Special Protection 
Areas  (SPAs),  classified  under  the  Birds  directive  cover 
23.1%  (EU  average  12.8%)  of  Bulgaria,  while  SCIs  – 
under  the  Habitats  Directive  cover  30.3%  (EU  average 
14.2%) . 

On  the  basis  of  Natura  2000  and  other  nationally 
designated  protected  areas,  Bulgaria  legally  protects 
41%  of  its  terrestrial  areas  (EU  27  average  26,4%)  and 
8.1% of marine areas (EU 27 average 10,7%)25.  Figure 6 
shows  the  2021  situation  at  the  EU  level  for  terrestrial 
and  marine  protected  area  coverage  in  meeting  the 
2030 biodiversity strategy target. 

designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive; 
figures of coverage do not add up due to the fact that some SCIs and 
SPAs  overlap.  Special  Areas  of  Conservation  (SACs)  means  a  SCI 
designated by the Member States. 
21  Sites  of  Community  Importance  (SCIs)  are  designated  pursuant  to 
the  Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated pursuant to the Birds Directive; figures of coverage should 
not be added up because some SCIs and SPAs overlap. Special Areas of 
Conservation (SACs) are SCIs designated by the Member States. 
22 EEA, Article 17 dashboard, Annex I total, 2019. 
23  EEA,  Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex  II  +  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
24  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 
25  EEA, Protected Areas,  terrestrial  protected area percentage  (2021) 
and marine protected area percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
 
                                                                                                      
 
Figure 6: Marine & terrestrial protected area 
coverage26  

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202127  

Bulgaria  10 

Designating SACs and setting conservation objectives 
and measures 

The  6-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCIs  as  SACs  and  establish  appropriate 
conservation  objectives  and  measures  has  expired  for 
229 sites in Bulgaria. 

With  186  designated  SACs  by  February  2022,  the 
country  is  closer  to  completing  the  designation  of  its 
SCIs  as  SACs,  albeit  significantly  behind  schedule. 
However,  Bulgaria  has  not  yet  established  site  specific 
conservation objectives for any of its Natura 2000 sites. 
Despite  providing  for  some  measures  dispersed  in 
various documents, Bulgaria has not yet established the 
necessary  conservation  measures  as  required  by  the 
Habitats  Directive.  Work  on  setting 
  conservation 
objectives started only at the end of 2021 and work on 
the  conservation  measures  has  yet  to  begin.  The 
European  Commission  has  therefore  referred  the  case 
to the Court of Justice of the EU28. 

The  lack  of  clear,  good  quality  site  specific  objectives 
and  conservation  measures  is  a  major  obstacle  to  
properly  assessing  the  compatibility  of  development 
projects  that  could  affect  the  integrity  of  the  Natura 
2000 sites and the species and habitats they have been 
designated  for.  Bulgaria’s  persistent  failure  to  properly 
assess the impacts of projects  and plans on the Natura 
2000  sites  has  also  led  to  infringement  action  by  the 
Commission29. 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
favourable 
the 
towards  maintaining  or  restoring 
conservation status of species and habitats. 

in  2018 

According  to  the  report  submitted  by  Bulgaria  on  the 
conservation  status  of  habitats  and  species  covered  by  
Article  17  of  the  Habitats  Directive  for  2013-2018,  the 
share of assessments for habitats in good conservation 
status 
is  slightly  higher  than  the  10.87% 
reported  under  the  previous  reporting  period  (2007-
2012).  As 
the  share  of 
assessments  of  good  conservation  status  in  2018  is 
38.06%, a significant decrease compared to the 53.32% 
reported  under  the  previous  reporting  period  (2007-
2012).    As  far  as  birds  are  concerned,  54%  of  the 
increasing  or 
breeding  species  showed  short-term 

to  protected  species, 

26  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
27  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

28 Cae C-85/22 Commision v Bulgaria 
29 INFR(2008)4461 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
 
 
                                                                 
                                                                 
stable  population  trends  (for  wintering  species  the 
figure was nearly 30%). 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation  status  has  increased  to  5.32%  and  the 
share  of  assessments  for  species  in  bad  conservation 
increased  as  well  to  3.15%.  The  main 
status  has 
pressures  are  agricultural,  but  also  come 
from 
unsustainable forestry, the extractive industries as well 
as  from  commercial,  residential  and  instrastructural 
developments and changes in land use. 

Figure 8: Assessments on conservation status for 
habitats for 2007-2012 and 2013-2018 reporting 
periods30 

Figure 9: Assessments on conservation status for 
species for 2007-2012 and 2013-2018 reporting 
periods31 

30  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.    Please  note  when  comparing 
the  figures  shown  for  2007-2012  and  2013-2018  these  may  also  be 
affected by changes of methods or due to better data availability. 
31 Idem. 

Bulgaria  11 

in  Bulgaria.  Full 

In early 2022 the Commission confirmed that Bulgaria’s 
national  prioritised  action  framework  (PAF)  for  the 
period  2021-2027,  developed  pursuant  Art.  8  of  the 
Habitats Directive, is a comprehensive and good quality 
document  which  provides  a  full  overview  of  the 
measures  necessary  to  implement  the  Natura  2000 
network 
implementation  of  these 
measures  will  contribute  to  the  achievement  of  the 
objectives  of  the  EU  Habitats  Directive  to  maintain  or 
restore  the  natural  habitats  and  species  of  European 
importance  at  a  favourable  conservation  status.  An 
appropriate  tool  to  ensure  efficient  implementation  of 
PAF is the submission of a LIFE  strategic nature project 
(SNAP).  These  large  and  long  term  projects  help  with 
the overall coordination of the PAF implementation and 
allow  for  necessary  resource  mobilisation,  stakeholder 
engagement  and  removal  of  administrative  or  other 
barriers to successful network management. Bulgaria is 
still  to  consider  and  submit  an  application  for  a  LIFE 
SNAP project. 

In the 2019 EIR, Bulgaria was set three priority actions in 
the area of nature protection and restoration but there 
is 
implementation; 
little  to  no  progress 
therefore they are reiterated. 

in  their 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture.  
The  biodiversity  and  farm  to  fork  strategies  have  set 
four important targets for 2030:  
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers);  
- bring back at least 10% of agricultural area under high-
diversity  landscape  features  and  increase  areas  under 
organic farming to at least 25%. 

Bulgaria’s estimated 2.3% of area under organic farming 
has  the  third  lowest  value,  and  is  well  below  the  EU 
average  of  9,07%  (2020  data,  Eurostat).  Thus  the 
opportunities provided by this type of farming have yet 
to be explored. 

Figure 10 shows the 2021 situation and the distance at 
the  EU 
level  from  meeting  the  2030  biodiversity 
strategy target for area under organic farming. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202032  

Bulgaria  is  one  of  the  Member  States  with  the  highest 
loss  of  land  with  high  nature  value  (HNV)  due  to 
intensification  of  farming.  Addressing  these  challenges 
will  require  the  promotion  of  sustainable  agricultural 
practices to reduce pressures on farmland biodiversity, 
combined with measures to manage the habitats of wild 
insect pollinators, farmland birds and turtle doves in line 
with the PAF33. 

Soil ecosystem 

The new EU soil strategy, adopted on 17/11/2021, puts 
an  emphasis  on  the  importance  of  soil  protection,  of 
sustainable  soil  management    and  of  restoration  of 
degraded soils for achieving the objectives of the Green 
Deal and achieve Land Degradation Neutrality by 2030. 
This entails:  

(i) preventing further soil degradation,  

(ii)  making  sustainable  soil  management  the  new 
normal,   

(iii) taking action for ecosystem restoration.  

One factor in the degradation of soil eco-systems is the 
area  of  soil  that  is  sealed  or  atificialised  (‘taken’)34. 

32 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/
default/table?lang=en  (Eurostat,  Area  under  organic  farming, 
February 2022). 
33 Commission Staff Working Document SWD2020 (369) – Bulgaria 
34 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non  built-up  areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car  parking  areas  etc.  and  linear  features,  such  as  streets,  roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and  viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 

Bulgaria  12 

Bulgaria  ranks  well  below  the  EU  average  as  regards 
land  take  with  2.3%  of  soil  sealed  or  artificialised  (EU 
average: 4.2% - 2018 data, EU-27)35. 

The net land taken per year in 2012-2018 can be seen as 
a  measure  of  one  significant  pressure  on  nature  and 
biodiversity  -  land  use  change.  At  the  same  time,  land 
use  change  constitutes  an  environmental  pressure  on 
people living in urbanised areas. 

Despite  a  reduction  in  the  last  decade  (land  take  was 
over  1000  km2/year  between  2000-2006),  land  take  in 
EU27  still  amounted  to  539km2/year  between  2012-
201836.  The  concept  of  ‘net  land  take’  combines  land 
take  with  the  return  of  land  to  non-artificial  land 
categories  (re-cultivation).  While  some  land  was  re-
cultivated  in  the  EU-28  in  2000-2018,  11  times  more 
land was taken than returned. 

Bulgaria ranks below the EU average with net land take 
of 53,4 m2/km2 (EU-27 average: 83,8 m2/km2). 

On soil quality, Bulgaria is in the category of EU Member 
States with lower content of organic matter. Its soils are 
characterised  by  a  lack  of  phosphorus  and  would 
benefit  from  fertilising  practices  designed  to  rebalance 
soils.  Rebalancing  would  also  benefit  climate  and  air 
quality37. 

Bulgaria  has  not  committed  to  set  land  degradation 
neutrality  targets  under  United  Nations  Convention  on 
Combating Desertification38. 

35 Eurostat, Land covered by artificial surfaces  
36 Land take in Europe — EEA (europa.eu) fig 6 
37 Commission Staff Working Document SWD2020 (369) – Bulgaria 
38  The LDN Target Setting Programme | UNCCD 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
                                                                 
Figure 11: Land take and re-cultivation in the EU27 
(m2/km2), 2012-201839 

Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)44 

Bulgaria  13 

Forests and timber 

The EU forest strategy for 2030 adopted in July 2021 is 
part  of the ’Fit  for 55’ Package.  The Strategy promotes 
the many services that forests provide. Its’ key objective 
is  to  ensure  healthy,  diverse  and  resilient  EU  forests, 
that  contribute  significantly 
the  strengthened 
biodiversity and climate ambition. Forests are important 
carbon sinks, conserving them is vital for the EU’s vision 
of achieving climate neutrality by 2050.  

to 

Out  of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, fewer than 15% of assessments show 
favourable  conservation  status40.  Bad  conservation 
status increased from 27% to  31% in the EU compared 
to 2015. 

In  Bulgaria,  forests  cover  36%  of  territory41  and  more 
than 75% of the assessments of the conservation status 
of  forest  habitats  protected  under  the  Birds  and 
Habitats  Directives  reveal  a  bad  to  poor  status42.  704 
000 ha  in  Bulgaria  is covered by primary forests,43 99% 
of them in Natura 2000 sites. 

(EUTR)45 
The  European  Union  Timber  Regulation 
prohibits the placing of illegally harvested timber on the 
EU  market.  In  accordance  with  the  EUTR,  EU  Member 
States  competent  authorities  must  conduct  regular 
checks on operators and traders, and apply penalties for 
non-compliance.  With  the  amendment  of  Article  20  of 
the EUTR, reporting  every two years has been changed 
to annual reporting to cover the 2019 calendar year. 

From  March  2017  to  February  201946,  Bulgaria  carried 
out  587  checks  on  domestic  timber  operators.  It  also 
carried out 37 checks on operators importing timber. It 
is  estimated  that  Bulgaria  had  4  000  operators  placing 
domestic    timber  types  onto  the  internal  market  over 
the reporting period. 

resolution 

Following a request from the Council in 2019 to table a 
forests  and  a  European 
legislative  proposal  on 
the 
recommending 
Parliament 
Commission  create  an  EU  legal  framework  to  halt  and 
reverse  EU-driven  global  deforestation,  a  proposal  for 
the  Regulation  on  the  making  available  on  the  EU 
market  and  export  of  products  associated  with 
deforestation  and  forest  degradation  (Deforestation 
Regulation) was adopted on 17 November 2021 

that 

The  new  Deforestation  Regulation  will  repeal  and 
replace  the  EUTR,  as  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  legality  of 
timber . 

39 European Environment Agency, Land take in Europe.  
40  EEA, State of Nature in the EU 
41 EEA, Forest information system for Europe. 
42 COM SWD (2021) 652 
43 JCR, Mapping and assessment of primary and old-growth forests in 
Europe, p. 13. 

44  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
45 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
46 COM/2020/629 final 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
 
 
                                                                 
to 

the 

According 
Environmental  Crime  Directive 
frequent offence in Bulgaria47. 

Impact  Assessment 

for 
logging 

illegal 

Bulgaria  14 

the 
is  a 

Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for Bulgaria, 2021 

Invasive alien species (IAS) 

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside 
use, 
sea 
overexploitation, climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  IAS  and  decrease  the  number  of  ‘red  list’ 
species they threaten by 50%.  
The core of Regulation (EU) 1143/2014 on invasive alien 
species  (the  IAS  Regulation)  is  the  list  of  IAS  of  Union 
concern. 
The  total  number  of  IAS)  of  Union  concern  is  currently 
66,  of  which:  30  are  animal  species;  36  are  plant 
species;  41  are  primarily  terrestrial  species;  23  are 
primarily  freshwater  species;  1  is  a  brackish-water 
species and 1 is a marine species.  

According  to  a  2021  report48  reviewing  the  application 
of the IAS Regulation, progress is already being made on 
the  objectives,  such  as  a  coherent  framework  for 
addressing  IAS  at  EU  level  and  increased  awareness  of 
the  problem  of  IAS.  At  the  same  time,  the  report 
identified some challenges and areas for improvement. 
Given  that  the  deadlines  for  implementing  the  various 
obligations  of  the  IAS  Regulation  applied  gradually 
between  July  2016  and  July  2019,  it  is  premature  to 
draw conclusions on various aspects of implementation 
of the Regulation. 

A 2021 report49 on the baseline distribution shows that 
from  the  66  species  on  the    Union  list,  15  have  been 
observed in the environment in Bulgaria. The spread  of 
IAS has been shown in Figure 13. 

47 SWD(2021) 465 final/2, p.18 
48  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 

49  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170. 

Along with other 17 Member States, Bulgaria is subject 
to  ongoing  infringement  proceedings  as  it  failed  to 
establish and implement one single action plan or a set 
of  action  plans  fulfilling  the  requirements  specified  in 
Article 13 of of the IAS Regulation by 13 July 2019 and 
to  submit  it/them  to  the  Commission  without  delay;  it 
also  failed  to  establish  a  surveillance  system  for  IAS  of 
Union  concern,  or  include  it  in  their  existing  system, 
monitoring  or  other  procedures  to  prevent  the  spread 
of  IAS  into  or  within  the  EU  by  13  January  2018  to 
comply with Article 14(1) of the Regulation50. 

2022 priority actions 

  Bulgaria  should  complete  the  SAC  designation 
process  as  a  matter  of  priority  and  put  in  place 
clearly  defined  site-specific  conservation  objectives 
and  the  necessary  conservation  measures  for  each 
habitat  and  species  of  community  interest  in  all 
Natura 2000 sites. 

  Bulgaria  should  address  shortcomings 

  Bulgaria  should  establish  efficient  management 
structures  for  the  Natura  2000  network,  with 
sufficient administrative and financial capacity. 
in 
the  nature  directives 

the 
implementation  of 
(in 
particular  the  authorisation  of  plans  and  projects) 
and  integration  of  the  policy  in  the  other  sectoral 
policies. 

  Bulgaria  should  take  the  necessary  steps  to  ensure 

full compliance with the IAS Regulation. 

50 INFR(2021)2007 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
 
 
                                                                 
Marine ecosystems 

The EU Biodiversity Strategy  2030 aims to substantially 
reduce  the  negative  impacts  on  sensitive  species  and 
habitats  in  marine  ecosystems  and  to  achieve  good 
environmental status as well as eliminate or reduce the 
incidental 
endangered, 
threatened  and  sensitive  species  to  a  level  that  allows 
species recovery and conservation51. 

protected, 

catches 

of 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member  States  must  draw  up  marine  strategies  for 
their marine waters, and cooperate with Member States 
sharing  the  same  marine  region  or  sub-region.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over 6-year cycles. 

The  MSFD  describes  the  GES  based  on  eleven 
descriptors. The MSFD requires Member States to draw 
up  a  set  of  GES  characteristics  for  each  descriptor 
(Article 9)) by 15 October 2018, and to provide an initial 
assessment  of  their  marine  waters  (Article  8).  The 
Commission  then  assesses  whether  this  constitutes  an 
appropriate framework to meet the requirements of the 
Directive. 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of  the  MSFD52,  although  regional 
cooperation  has  improved  since  the  adoption  of  the 
MSFD,  more  cooperation 
is  needed  to  attain  full 
regional coherence of the marine strategies, as required 
by the Directive. 

Bulgaria received four priority actions in the 2019 report 
related  to  defining  and  achieving  GES,  ensuring 
cooperation and reporting under MSFD.   

Furthermore, in March 2022, the European Commission 
published  a  communication  with  recommendations  for 
Member  States.  The  Commission  assessment  stresses 
that  Member  States  need  to  step  up  their  efforts  to 
determine  good  environmental  status  and  the  use  of 
the  criteria  and  methodological  standards  according  to 
the Commission GES Decision. The above considerations 
form the basis for the 2022 priority actions. 

Upgrading  and  updating  data  and  information  on  the 
marine  environment,  and  improving  the  definitions, 
targets and indicators for assessment of the definitions 
of  good  environmental  status  were  addressed  by  the 
information  towards  regional 
project 

‘Science  and 

51  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
52 COM(2020)259  

Bulgaria  15 

ENvironmental  action  for  the  Black  Sea  (SCIRENA-Black 
Sea)’,  financed  under  the  European  Economic  Area 
(EEA) 
Financial  Mechanism  2014-2021.  Bulgaria 
completed its reporting in March 2022. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States  to  better  integrate  biodiversity  considerations 
into  public  and  business  decision  making  at  all  levels 
and  to  develop  natural  capital  accounting.  EU  needs  a 
better performing biodiversity observation network and 
more consistent ecosystem condition reporting.  

The  EEA  Financial  Mechanism  2009–2014  through 
programme  BG03  Biodiversity  and  Ecosystem  services 
funded  the  national  scale  mapping  and  assessment  of 
ecosystems  and  ecosystem  services  outside  NATURA 
2000 at EUNIS 3 level. 

in  Bulgaria 

The mapping and assessment was performed in parallel 
for  several  projects,  each  of  which  mapped  and 
assessed  one  or  two  of  the  nine  ecosystem  types  in 
Bulgaria.  The  projects  were:  Freshwater  Ecosystem 
Services  mapping  and  assessment  in  Bulgaria  (FEMA)  – 
also  assessing  marine  ecosystems;  Wetland  Ecosystem 
Services  mapping  and  assessment  in  Bulgaria  (WEMA); 
Assessment  and  mapping  of  grassland  ecosystems 
condition  and  their  services  in  Bulgaria  (IBER-GRASS); 
Mapping  and  assessment  of  sparsely  vegetated  land 
ecosystem  services 
(SPA-Ecoservices); 
Toward better understanding the ecosystem services in 
urban  environments  through  assessment  and  mapping 
services  mapping  and 
(TUNESinURB);  Ecosystem 
assessment  of  heathland  and  shrubs  ecosystems  in 
Bulgaria outside NATURA 2000 (SHE-BG), also assessing 
cropland  ecosystems;  and  Forests  and  woodlands  –
ecosystem  services  mapping  and  assessment  in  the 
Bulgarian  forest  territories  outside  NATURA  2000 
network  (FOR  OUR  FUTURE).  The  projects  further 
performed  additional  activities  for  some  ecosystem 
types,  notably  an  assessment  of  ecological  focused 
areas  (EFAs)  in  two  pilot  locations,  urban  mapping  in 
two pilot cities, and a socio-economic assessment of the 
heathland and shrubs ecosystem services. 

in  parallel  and  after 

the  mapping  and 
Before, 
assessment,  two  horizontal  projects  ensured  the 
coordination  of  the  mapping  projects:  Project  PDP02  - 
methodological support for ecosystem services mapping 
and  biophysical  valuation  (MetEcoSMap)  and  Project 
improving the Bulgarian biodiversity information system 
(IBBIS). 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
Figure 14: ESMERALDA MAES Barometer (January 2016 
- March 2021)53 

  Bulgaria  should  ensure  regional  cooperation  with 
Member States sharing the same marine (sub)region 
to address predominant pressures. 

Bulgaria  16 

  Bulgaria 

should 

the  Commission’s 
implement 
recommendations  regarding  the  preparation  of  the 
marine  strategies,  encompasing:  the  assessment, 
the determination of good environmental status and 
the establishment of environmental targets.   

forest  ecosystems 

Key  policy  priority  areas  for  Bulgaria  are:  water 
regulation  ecosystems, 
(extent, 
carbon  sequestration),  biodiversity,  urban  areas  extent 
and  ecosystems,  cultural  ecosystems  (tourism,  cultural 
these 
heritage)  and  supply  and  use 
ecosystems. 

tables 

for 

account 

forest  extent 

An  updated 
is  under 
development,  as  well  as  an  extent  account  for  all 
ecosystems for the years 2000 up to 2018. A biophysical 
ecosystem  account  is  being  constructed  for  cultural 
ecosystem  services  and  for  flood  regulation,  both  on  a 
local  scale.  Thematic  accounts  are  being  set  up  for 
carbon  in  forest  ecosystems  on  a  regional  scale,  urban 
ecosystems  on  a  local  scale  and  biodiversity  on  a 
national scale. 

issues  and  a 

In  Bulgaria  sometimes  problems  arise  because  of  data 
availability  and  quality 
lack  of  clear 
guidance on working with the available data. The largest 
knowledge  gaps  include  ecosystems  asset  accounts, 
ecosytem accounts and a thematic biodiversity account. 
Another important issue is the lack of engagement of all 
stakeholders, 
and 
collaboration between state institutions and knowledge 
sharing  with 
the  general  public  and  business 
community.  The  last  issue  relates  to  the  establishment 
of uniform translation of the relevant terminology in the 
respective language. 

communication 

insufficient 

2022 priority actions 

  Bulgaria  should  ensure  better  collaboration  among 
all stakeholders to identify  and close the data gaps. 
Policy  support  is  a  necessary  condition  for  further 
development  of  the  core  and  thematic  accounts. 
More training and capacity building at the state and 
research institutions of all scales should enable them 
to  be    more  effective  in  showing  the  business 
community and society in general, the real value of 
the natural environment. 

53 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
Bulgaria  17 

3. Zero Pollution 

Clean air 

its 

EU  clean-air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean-air legislation and defining strategic targets 
and actions for 2030 and beyond.  
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005.  

The EU has developed a comprehensive suite of clean air 
legislation,  which 
sets  health-based  air  quality 
standards54    and  emission  reduction  commitments55  per 
Member State for a number of air pollutants. 

At the same time, air quality in Bulgaria continues to give 
cause  for  serious  concern.  The  latest  available  annual 
estimates  (for  2019)  by  the  European  Environment 
Agency56 point to about 10 600 premature deaths (or 112 
400 years of life lost (YLL)) attributable to fine particulate 
matter  concentrations57,  290  (3  200  YLL)  to  ozone 
concentration58  and  1  120  (11  900  YLL)  to  nitrogen 
dioxide concentration59. 

The  emissions  of  key  air  pollutants  have  decreased 
significantly  in  Bulgaria  over  the  last  years,  while  GDP 
growth continued (see Figure 15). According to the latest 
projections  as  submitted  under  Article  10(2)  of  the 
National  Emission  reduction  Commitments    Directive 
(NECD)60  Bulgaria  plans  to  reach  its  emission  reduction 
commitments  for  all  air  pollutants  covered  by  the 
Directive for 2020 to 2029 and for 2030 onwards. Latest 
inventory data submitted by Bulgaria, prior to the review 

54 European Commission, 2016. Air Quality Standards. 
55 European Commission, Reduction of National Emissions. 
56 European Environment Agency. Air Quality in Europe  – 2021 Report. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106. 
57  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to  particles with a  diameter  of  10  (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
58 Low-level ozone is produced by photochemical action on pollution. 
59  NOx  is  emitted  during  fuel  combustion  e.g.  from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
60 Directive 2016/2284/EU. 

that  Bulgaria 

the  Commission, 

in 
indicate 
by 
compliance  with  the  emission  reduction  commitments 
for  NOx,  non-methane  volatile  organic  compounds 
(NMVOC),  SO2  and  PM2.5,  and  in  non-compliance  with 
the emission reduction commitment for NH3 in 2020.   

is 

Bulgaria  submitted 
programme on 26 September 2019. 

its  national  air  pollution  control 

Figure  15:  Emission  trends  of  main  pollutants/GDP  in 
Bulgaria, 2005-201961 

Figure  16:  PM2.5  and  NOx  emissions  by  sector  in 
Bulgaria (2019)62 

61 European Environment Agency. 
62 European Environment Agency. 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
 
                                                                 
Bulgaria  18 

Bulgaria  is  making  use  of  financial  resourse  by  the 
Cohesion  Fund  and  LIFE  programme  to  address  PM10 
pollution by household heating.64  

In the 2019 EIR, Bulgaria received five priority actions on 
air  quality.  Because  of  the  insufficient  progress  in  their 
implemetation, they are essentially reiterated.  

2022 priority actions 

  Bulgaria must continue, in the context of the national 
air  pollution  control  programme  (NAPCP),  taking 
actions  to  reduce  emissions  from  the  main  sources 
mentioned above. 

  Bulgaria  must  ensure  full  compliance  with    EU  air 
quality  standards  and  maintain  downward  emissions 
trends  of  air  pollutants,  to  reduce  adverse  air 
pollution impacts on health and economy with a view 
to reaching WHO guideline values in the future. 

  Bulgaria  should  accelerate  the  ratification  of  the 
Heavy  Metals  Protocol  and  POPs  Protocol  under  the 
UNECE Air Convention. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  

To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial  Emissions  Directive  (IED)65.  The  Commission 
tabled a proposal  in April  202266. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as  its consistency with climate, energy 
and circular economy policies. 

 The  overview  of  industrial  activities  regulated  by  IED 
below  is  based  on  data  reported  to  the  EU  Registry 
(2018)67. 

64  Bulgarian  Municipalities  Working  Together  to  Improve  Air  Quality 
(LIFE-IP Clean Air) 
65  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
66  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
67  European Environment Agency, European Industrial Emissions Portal. 

Bulgaria  has  not  yet  ratified  the  Heavy  Metals  Protocol 
and  the  Persistent  Organic  Pollutants  (POPs)  Protocol 
under  the  United  Nations  Economic  Commission  for 
Europe (UNECE) Air Convention. 

For 2020, rates above the limit values set by the Ambient 
Air Quality Directive (AAQD)  were registered for sulphur 
dioxide  (SO2)  in  one  air  quality  zone  and  for  particulate 
matter  (PM10)  in  five  zones.  The  target  values  for  ozone 
concentration are not being met in one air quality zone63. 

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are  being  followed  up  by  the  European  Commission 
through  infringement  procedures  (mainly  for  PM10  and 
NO2 exceedances) covering all Member States concerned, 
including  Bulgaria  for  PM10  and  SO2.  For  exceedances  of 
PM10  limit  values,  the  Court  of  Justice  of  the  European 
Union  (CJEU)  delivered  a  judgment  (C-488/15;  COM  vs 
Bulgaria)  confirming  non-compliance  with  Directive 
2008/50/EC.  Bulgaria  did  not  take  the  necessary 
measures  to  execute  the  judgment  in  reasonable  time 
and the Commission referred it to the Court for a second 
time,  proposing  penalties  (C-174/21).  The  Commission 
has  also  referred  Bulgaria  to  the  CJEU  (C-730/19)  for 
persisting  exceedances  of  SO2  limit  values  in  the  south-
east zone, where the four largest thermal power plants in 
Bulgaria are located. The aim of these legal actions is that 
appropriate measures are swiftly put in place to bring all 
air  quality  zones  into  compliance  with  EU  air  quality 
standards. 

63 European Environment Agency, Eionet Central Data Repository. 

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Bulgaria  19 

Figure  18: Emissions to air from IED sectors and rest of 
national total air emissions in Bulgaria, 201869 

industrial 

installations  are 
In  Bulgaria,  around  550 
required  to  have  a  permit  based  on  the  IED.  This  is  an 
increase  of  about  75  installations  since  2015,  mainly  in 
the waste management sector and in intensive rearing of 
poultry or pigs. The distribution of installations is shown 
in Figure 17. 

The  industrial  sectors  in  Bulgaria  with  the  most  IED 
installations  in  2018  are  intensive  rearing  of  poultry  or 
pigs (20%), landfills (18%), production of chemicals (15%), 
followed  by  power  production  (7%)  and  non-ferrous 
metal (7%). 

Figure  17:  Number  of  IED  industrial  installations  per 
sector in Bulgaria, 201868 

The  industrial  sectors 
identified  as  contributing  the 
largest  burden  to  the  environment  for  emissions  to  air 
were:  (i)  the  production  of  non-ferrous  metal  for  zinc 
(Zn),  copper  (Cu),  lead  (Pb),  arsenic  (As),  mercury  (Hg), 
nickel  cadmium  (Cd),  nickel  (Ni)  and  dioxins;  (ii)  the 
power  sector  for  sulphur  oxides  (SOx),  nitrogen  oxides 
(NOx),  Cu,  As,  Hg  and  Ni;  (iii)  the  intensive  rearing  of 
poultry  or  pigs  for  ammonia  (NH3);  (iv)  food  and  drink 
production and coating applications for NMVOCs; and (v) 
chemicals production for SOx and NH3. The breakdown is 
shown in Figure 18. 

In 2017, one power station in Bulgaria (TPP Maritsa iztok 
2  EAD,  burning  lignite)  was  amongst  the  top  30  E-PRTR 
facilities  having  the  highest  absolute  damage  costs  from 
emissions  of  the  main  air  pollutants  and  greenhouse 
gases.  Bulgaria  was  also  the  Member  State  with  the 
second  highest  damage  costs  aggregated  over  all 
pollutant groups normalised against GDP70. 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from 
livestock,  production  of 
chemicals  and  the  production  of  pulp  and  paper  for 
nitrogen,  phosphorous  and  total  organic  carbon,  from 
the production of non-ferrous metal, electricity and heat 
production  as  well  as  extractive  industry  for  heavy 
is 
metals.  The  breakdown,  based  on  E-PRTR  data, 
presented in the Figure 19. 

68  European  Environment  Agency,  EU  Registry,    European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

69  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
70  EEA  (2021).  Costs  of  air  pollution  from  European  industrial  facilities 
2008–2017.  Eionet  Report  -  ETC/ATNI  Report  04/2020,  The  ranking  is 
based  on  the  approach  accounting  for  the  value  of  a  life  year  (VOLY), 
table 41, p.125 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
 
 
                                                                 
Figure  19:  Relative  releases  to  water  from  industry  in 
Bulgaria71, 201872 

Figure  20: Number of inspections in IED installations in 
Bulgaria in 201873 

Bulgaria  20 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted  and  that  the  conditions  of  the  permits  are 
complied  with.  As  part  of  environmental  inspection, 
competent  authorities  undertake  site  visits  to 
IED 
installations  to  take  samples  and  gather  necessary 
information.  According  to  Article  23(4)  of  the  IED,  site 
visits must be carried out between once a year and once 
every  3  years,  depending  on  the  environmental  risks 
posed by the installations. In 2018 Bulgaria made 454 site 
visits,  most  of  which  were  to  the  waste  management 
sector  (28%),  chemicals  production  (17%),  followed  by 
power  production  (13%),  intensive  rearing  of  poultry  or 
pigs (12%) and the production of non-ferrous metal (6%) 
– see Figure 20. 

The  development  of  best  available  techniques  (BAT) 
reference  documents  (BREFs)  and  BAT  Conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED74. Since the last 
EIR report, the Commission adopted BAT conclusions for 
Bulgaria for (i) waste incineration, (ii) for the food, drink 
and  milk  industries  and  (iii)  for  surface  treatment  using 
organic solvents including  the preservation  of  wood and 
wood products with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reduction in pollution.  

Bulgaria has some issues with transposition of the IED.  

In  2019,  Bulgaria  received  priority  actions  to  ensure 
compliance  with  BAT  conclusions  by  reviewing  permits, 
strengthening  control  and  enforcement  and  addressing 
pressure on the power sector. 

2022 priority actions 

  Bulgaria should continue to  address the  emissions to 

air  from the energy sector. 

Major industrial accidents prevention – 
SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;  
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;  
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.  
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 

71  The  heavy  metals  are  presented  both  as  a  weighted  sum  of  eco 
toxicity and human toxicity factors to illustrate both the ecological and 
human impact (based on USEtox). 
72  European  Commissionpean  Environment  Agency,  E-PRTR,  European 
Industrial Emissions Portal (data retrieved on 3 November 2021). 

73 EU Registry (data retrieved on 3 November 2021) 
74 BAT reference documents | Eippcb (europa.eu). 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
                                                                 
 
                                                                 
(the Seveso III Directive)75.  

Figure 22: Situation regarding EEP in Bulgaria, 201879 

Bulgaria  21 

The  overview  of 
industrial  plants  regulated  by  the 
Seveso-III  Directive  (‘Seveso  establishments)’  shown 
below is based on data reported to the eSPIRS database 
(2018)76  and  the  Bulgaria  report  on  the  implementation 
of the Seveso-III Directive for 2015-201877. 

Of  the  202  Seveso  establishments  in  Bulgaria,  121  are 
categorised as  lower-tier establishments (LTE) and 81 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present in them. The 
UTE  are  subject  to  more  stringent  requirements.  The 
is 
change 
presented in Figure 21. 

in  the  number  of  Seveso  establishments 

Figure 21: Number of Seveso establishments in Bulgaria, 
2011, 2014 and 201878 

Many  Seveso  establishments  are  required  to  draw  up 
(EEPs).  These  EEPs  are 
external  emergency  plans 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment  and  the  population  should  a  major 
industrial  accident  occur  at  a  Seveso  establishment. 
According  to  Bulgaria,  an  EEP  is  required  for  76  UTE.  In 
2018, 64 UTE had an EEP and 64 of these EEP had been 
tested over the previous 3 years. The summary is shown 
in Figure 22.  

The  following  types  of  information  are  permanently 
available  for  100%  of  the  Seveso  establishments  in 
Bulgaria:  (i)  information  to  the  public  referred  to  in 
Annex V to the Seveso III Directive – especially about how 
the  public  concerned  is  warned  if  there  is  a  major 
accident; (ii) information on the appropriate behaviour if 
there is a major accident; and (iii) information specifying 
the date of the last site visit.  

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available  to  the  public  over  the  last  years  is  shown  in 
Figure 23. 

Figure 23: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available  to  the  public  in  Bulgaria,  2011,  2014  and 
201880  

75  Directive  2012/18/EU  on  the  control  of  major  accident  hazards 
involving dangerous substances. 
76 European Commission, Seveso Plants Information Retrieval System  
77 As provided for by Article 21(2) of the Seveso-III Directive 
78 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

Bulgaria  was urged to bring its national legislation in line 
with  the  Seveso  III  Directive.  Bulgaria  has  not  yet 
properly defined the scope of application of the Directive 
by  introducing  the  notion  of  ‘other  establishment'  into 
national legislation, which has cascaded into a number of 
non-compliant  provisions.  Some  technical  provisions 

79 Idem. 
80 Idem. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
                                                                 
 
 
 
 
 
                                                                 
have  also  been  incorrectly  enacted  into  national  law 
including  the  definition  of 
‘inspection',  as  well  as 
information that should be made available to the public, 
and  giving  the  public  an  early  opportunity  to  give  its 
opinion. 

2022 priority action 

  Bulgaria  should  strengthen  control  and  enforcement 
to  ensure  compliance  with  Seveso-III  Directive 
provisions, especially on EEP. 

Noise 

The  Environmental  Noise  Directive81  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.    A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people 
transport  noise 
compared to 2017.  

chronically  disturbed  by 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress82. 

limited  set  of  data83, 
In  Bulgaria,  based  on  a 
environmental  noise  is  estimated  to  cause  at  least 
around  500  premature  deaths  and  1150  cases  of 
ischaemic  heart  diseases  annually84.  Moreover,  some 
80 000  people  suffer  from  disturbed  sleep  owing  to 
environmental  noise.  According  to  reported  data,  in 
Bulgaria  the  overall  noise  exposure  increased  by  1% 
between  2012  and  2017;  however,  the  dataset  is  not 
complete and therefore the statistic is not certain. On the 
basis  of  the  latest  full  set  of  information  that  has  been 
analysed,  noise  mapping  of  agglomerations,  roads  and 
railways is complete. 

: (i) the  data 

81 Directive 2002/49/EC 
82 WHO 2018, environmental noise guidelines for the European Region 
83  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
84   These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based on 
reported  by  Member  States 
on noise exposure  covered  by  Directive  2002/49/EC; (ii) ETC/ATNI, 
2021, Noise indicators 
Environmental Noise Directive 
the 
2021: Methodology  for  estimating  missing  data, ETC/ATNI  Report  No 
2021/06, European Topic Centre on Air Pollution, Transport, Noise and 
Industrial 
impact 
calculations, ETC/ACM,  2018,  Implications  of  environmental noise on 
health  and  wellbeing  in  Europe,  Eionet  Report  ETC/ACM  No  2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation.  

Pollution; (iii) the methodology 

health 

under 

for 

Bulgaria  22 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.    Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework  Directive  will  ensure  that  people  in  the  EU 
benefit from high standards for safe drinking and bathing 
water.  It  will  further  ensure  that  the  nutrient  cycle 
(nitrogen  and  phosphorus) 
in  a  more 
sustainable and resource-efficient way. 

is  managed 

Water Framework Directive 

is 

(WFD)85 

The  Water  Framework  Directive 
the 
cornerstone of the EU water policy in the 21st century86. 
The  WFD  and  other  water-related  directives87  set  the 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status. 

for 

the 

third  generation  of 

By  March  2022,  Member  States  have  to  submit  to  the 
Commission 
river  basin 
management  plans  (RBMPs)  required  under  the  WFD. 
Bulgaria  has  not  submitted  it  on  time.  The  Commission 
will  assess  the  reported  status  and  progress  in  the 
RBMPs,  checking  how  the  findings  identified  in  the 
assessment of the second RBMPs88 have been addressed. 
Bulgaria has not yet reported the third RBMPs. 

Report89, 

In  December  2021,  the  Commission  published  the  6th 
assesses 
Implementation 
implementation  of  the  WFD  and  the  Floods  Directive90. 
The 
the 
implementation of the programmes of measures; and (ii) 
the  new  priority  substances.  The  assessment  report  for 
Bulgaria91  showed  that  Bulgaria  has  not  provided 

includes  an  assessment  of: 

report 

which 

(i) 

85 The Water Framework Directive (2000/60/EC) 
86 The EU Water Policy. 
87  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the Industrial Emissions Directive (2010/75/EU) and the new Regulation 
on minimum requirements for water reuse (2020/741). 
88  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
89 Please see the 6th Implementation Report of the WFD and FD. 
90  See the 6th Implementation Report of the WFD and FD. 
91  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Bulgaria, 2022. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
                                                                 
Bulgaria  23 

Figure 25: Percentage of surface water bodies not 
achieving good chemical status95 

Under the IED framework, it should be stressed that over 
the  last  decade  Bulgaria  showed  a  significant  decline 
(63.1%) in industrial releases of heavy metals like Cd, Hg, 
Ni, Pb as well as in the total organic carbon-TOC to water 
percentage (52.2%)96. 

The  total  water  abstracted  annually  from  surface  and 
groundwater  bodies  in  Bulgaria  is  5,458.60 hm3  (EEA, 
2022). The percentage for water abstraction per sector is 
11.48%  for  agriculture,  16.56%  for  public  water  supply, 
64.98%  for  electricity  cooling,  4.39%  for  manufacturing  
2.08%  for  manufacturing  cooling  and  0.51%  for  mining 
and quarrying. The breakdown is illustrated by Figure 26. 
Bulgaria  uses  a  register  to  monitor  water  abstractions. 
The water permit registers are updated regularly and are 
publicly  available.  There  is  a  clear  link  between  the 
permits  registered  and  the  quantities  allowed.  Small 
abstractions  do  not  require  permits  in  Bulgaria,  but  are 
all registered. 

information  on  the  values  and  trends  of 
sufficient 
quantitative  indicators  to  enable  thorough  analysis  of 
progress  on  achieving  the  WFD  objectives.  Further, 
delays of measures were reported for the Black Sea River 
Basin  Districts  (RBD)  and  for  the  Danube  RBD,  but  not 
clearly explained for the other RBDs. 

Based  on  the  reporting  of  the  second  round  of  RBMPs 
published in 202092, in Bulgaria 46.1% of all surface water 
bodies93  have  good  ecological  status  (with  8.8%  having 
unknown  status)  and  only  33.7%  have  good  chemical 
status 
(with  63.7%  having  unknownstatus).  For 
groundwaters,  34.3%  failed  to  achieve  good  chemical 
status; only 4.7% are in poor quantitative status. 

Figure  24  illustrates  the proportion  of  surface  water 
bodies  in  Bulgaria  and  other  European  countries  that 
failed to achieve good ecological status. 

Figure  24:  Proportion  of  surface  water  bodies  (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District94 

Figure  25  presents  the  percentage  of  surface  water 
bodies in Bulgaria and other European countries failing to 
achieve  good  chemical  status.  For  Bulgaria, 
the 
percentage is 2.6 %, including water bodies failing due to 
substances behaving as ubiquitous PBTs (persistent, bio-
accumulative, toxic). Without uPBTs, 2% of surface water 
bodies are failing good chemical status. 

92 See WISE - Freshwater. 
93 Rivers, lakes, transitional, coastal, territorial. 
94 European Environment Agency, 2O21.   

95 European Environment Agency, December 2019. 
96 European Environment Agency, June 2021. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
 
                                                                 
Figure 26: Water abstraction per sector in Bulgaria97 

Floods Directive 

Bulgaria  24 

As  previously  mentioned, 
in  December  2021  the 
Commission  published  the  6th    Implementation  Report. 
The  report  includes  a  review  and  an  update  of  the 
preliminary  flood  risk  assessments  (PFRAs)  drawn  up  by 
all Member States during the second cycle (2016-2021). 

Bulgaria  did  not  report  in  time  to  be  included  in  the 
Commission’s assessment of second-cycle PFRAs. 

Bulgaria  has  not  adopted  or  reported  the  second 
generation  of  flood  risk  management  plans  (FRMPs) 
under  the  Floods  Directive.  The  European  Commission 
will assess progress since the adoption of the first FRMPs 
and publish a new report, as in 2019.  

Drinking Water Directive 

On  the  Drinking  Water  Directive100,  no  new  assessment 
of the quality of drinking water is available since the 2019 
EIR.  The  quality  of  drinking  water  in  Bulgaria  has  not 
been indicated as an area of concern.  

recast  Directive101  entered 

The 
force  on 
12 January 2021,  and  Member  States  have  until 
12 January 2023  to  transpose  it  into  their  national  legal 
system. Bulgaria will have to comply with these reviewed 
quality standards. 

into 

Bathing Water Directive 

On the Bathing Water Directive,  Figure  28  shows that  in 
2020, out of the 96 Bulgarian bathing waters,  58 (60.4%) 
were  of  excellent  quality.102  Detailed  information  on 
Bulgarian  bathing  waters  is  available  from  a  national 
portal103  and  via  an  interactive  map  viewer  of  the 
European Environment Agency. 

The  increasing  demand  for  water  for  multiple  purposes 
and the intensification of severe weather conditions due 
to climate change have put strain on freshwater supplies 
in  Bulgaria.  A  practice  of  issuing  permits  for  abstracted 
water    for  a  period  up  6  years  has  been  imposed  by 
competent  authorities,  allowing  their  revision  and 
alignment with the RBMP within the next planning cycle, 
which is an instance of good practice.   

In  Bulgaria,  the  water  exploitation  index  plus  (WEI+)98  is 
1.78%  (2017),  which  is  less  than  the  20%  generally 
considered an indication of water scarcity.  

The bar in Figure 27 presents the WEI+ index in Bulgaria 
and  other  European  countries.  Bulgaria  is  ranked  16th  
(with  first  ranking  indicating  extreme  water  scarcity)  in  
the EU in the WEI+. 

Figure 27 :  Water  exploitation  index  plus  (WEI+)  inside 
EU, 201799  

97  European  Environment  Agency, Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
98  The  water  exploitation  index  plus  (WEI+)  is a measure  of  total  fresh 
water  used  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how  much  water  is  abstracted  and  how  much  water  is  returned  after 
use to the environment. 
99 EEA, Water exploitation Index Plus, 2022. 

100 OJ L 330, 5.12.1998, pp. 32-54. 
101 OJ L 435, 23.12.2020, pp. 1-62. 
102  European  Environment  Agency,  2021.  State  of  Bathing  Waters  – 
Bulgarian country report. 
103 Ministry of Health, Registries, Bathing Waters  

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Figure  28:  Bathing  water  quality  in  Europe  in  the  2020 
season104 

Figure 29: Bathing water quality 2017-2020105 

Bulgaria  25 

national authorities and farmers have cleaned up waters, 
it has had a positive impact on drinking water supply and 
biodiversity, and on sectors such as fisheries and tourism 
that  depend  on 
them.  Nevertheless,  excessive 
fertilisation remains a problem in many parts of the EU. 

Regrettably, Bulgaria has not provided information to the 
Commission  about  the  contribution  of  agriculture  to 
nitrogen  discharges  in  the  aquatic  environment  for  the 
2016-2019 reporting period. 

Bulgaria has low livestock density, the surplus of nitrogen 
is  average  for  the  EU  and  there  is  a  low  surplus  for 
is  a  well-developed  network  of 
phosphorus.  There 
monitoring stations. The groundwater quality is generally 
good.  However,  there  are  hotspots,  with  a  nitrate 
concentration  >  50  mg/l  and  many  monitoring  points 
have  a  strong  increasing  trend.  A  very  high  number 
polluted groundwater and of surface waters found to be 
eutrophic  are  located  outside  the  Nitrate  Vulnerable 
Zones (NVZ). A revised action programme was published 
in 2020. 

Bulgaria  needs  to  focus  on  the  hotspots  where  nitrates 
pollution  should  be  urgently  diminished  and  review  the 
designation  of  NTZ  to  include  areas  that  drain  into 
is 
eutrophic  waters  where  agricultural  pressure 
significant. 

Urban Waste Water Treatment Directive 

Bulgaria  has,  over  the  years,  encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment  Directive  (UWWTD).  According  to  the  last 
available  data108,  the  overall  compliance  rate  in  Bulgaria 
is 30%, which is the fourth lowest and well below the EU 
average of 76% in 2018.. 

Nitrates Directive 

The latest Commission Report on the implementation of 
the  Nitrates  Directive106,  refers  to    2016-2019107.  The 
report  warns  that  nitrates  are  still  causing  harmful 
pollution  to  water  in  the  EU.  Excessive  nitrates  in  water 
are  harmful  to  both  human  health  and  ecosystems, 
causing  oxygen  depletion  and  eutrophication.  Where 

104 European Environment Agency, Bathing Water Quality in 2020, 2022. 
105 
 European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 
106 Implementation of the Nitrates Directive in the EU. 
107 Last implementation report 2016-2019. 

108  WISE  –  –  Country  profiles  on  urban  waste  water  treatment  - 
Bulgaria. 

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Bulgaria  26 

Figure 30: Proportion of urban waste water that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal) in compliant urban areas of the 
UWWTD (‘compliance rate’), 2018109 

EU  chemicals  legislation.  The  strategy is  part  of  the  EU's 
zero-pollution  ambition  –  a  key  commitment  of  the 
European Green Deal. 

legislation111 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market. 

States’ 

the  Member 

In  December  2020, 

Labelling  and  Packaging 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
the  Regulation  on 
‘(the  REACH  Regulation’)  and 
(‘the  CLP 
Classification, 
the  Commission 
Regulation’). 
assessed 
the 
reports  on 
implementation and enforcement of these Regulations112, 
in  line  with  Article  117(1)  of  the  REACH  Regulation  and 
Article  46(2)  of  the  CLP  Regulation.  According  to  the 
latest  available  data,  national  enforcement  structures 
have  not  changed  much  in  recent  years.  However,  it  is 
apparent  from  this  report  that  there  are  still  many 
disparities  in  the  implementation  of  the  REACH  and  CLP 
Regulations, notably in the area of the law enforcement. 
Recorded  compliance  levels  in  Member  States  seem  to 
show  a  worsening  trend,  which  is  likely  due  to:  (i) 
enforcement  authorities  being  more  effective 
in 
detecting  non-compliant  products/companies,  and  (ii) 
more  non-compliant  products  being  put  on  the  EU 
market.  

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement113  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 
CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement.   

Responsibility  for  checking  compliance  with  REACH  in 
Bulgaria114 lies with: 

  15 regional inspectorates of environment and water  
  28 regional health inspectorates  
  Executive agency ‘General Labour Inspectorate’. 

Bulgaria  has  fully  implemented  both  REACH  and  CLP 
enforcement 
for 
enforcement are based on:  

strategies115. 

priorities 

Their 

  Requirements  set  in  REACH  and  CLP,  and  deadlines 

for their implementation  

  Risks and consequences in cases of breaches  

111 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 
112 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu). 
113  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 
114 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 68 
115 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76 

Despite  the  improvement  in  compliance  throughout  the 
years,  for  which  the  use  of  EU  funding  has  been 
fundamental,  the  incomplete  implementation  of  the 
UWWTD has led to an infringement procedure which is in 
the  final  stage  of  the  pre-litigation  phase  of  the 
infringement proceedings. 

In the 2019 EIR, Bulgaria received four priority actions in 
the  area  of  water  quality  and  management.  Some 
progress has been made in their implementation but the 
efforts  should  continue.  Therefore  the  priority  actions 
are generally maintained. 

2022 priority actions 

  Bulgaria  should  assess  any  new  physical  changes  to 
water  bodies  in  line  with  Article  4(7)  of  the  WFD.  In 
the assessments, alternative options and  appropriate 
mitigation measures must be considered. 

  Bulgaria should  make efforts to improve coordinated 
implementation  between  water,  marine  and  nature 
policies. 

  Bulgaria  should  complete  its  implementation  of  the 
Urban  Waste  Water  Treatment  Directive  for  all 
the  necessary 
agglomerations  by  building  up 
infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment. 
In 
October  2020,  the  Commission published  its  chemicals 
strategy  for  sustainability  - 
'Towards  a  Toxic-Free 
Environment'110  which  led  to  some  systemic  changes  in 

109 European Commission, WISE Freshwater, 2021. 
110 COM(2020) 667 final. 

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Bulgaria  27 

  Available resources 

As  a  rule,  all  infringements  of  REACH  are  classed  as 
serious  or  very  serious  environmental  administrative 
offences.  If  the  infringement  is  sufficiently  serious,  the 
competent  authority  may  decide  to 
impose  further 
penalties  in  addition  to  a  fine.  That  authority  may  also, 
where  necessary,  order  the  provisional  seizure  of  assets 
and documents. 

In  Bulgaria  human  and  financial  resources  allocated  to 
REACH  and  CLP  enforcement  are  limited116.  There  were 
2 577  REACH  controls  in  2019  and  266  CLP  controls. 
Almost all controls carried out were proactive (inspections), 
compared  with 
(i.e. 
investigations  in  response  to  complaints,  accidents  and 
referrals)117. 

reactive/non-routine 

controls 

Figure  31:  Percentage  of  non-compliance  cases  out  of 
the  total  number  of  REACH  and  CLP  controls  during 
2019  per  Member  State  and  compared  to  the  EU 
average118 

2022 priority actions 

  Bulgaria  should  upgrade 

implementation  and 
enforcement administrative capacities towards a zero 
tolerance to non-compliances. 

its 

116 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 74. 
117Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu),  p.  87-
88. 
118 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
 
 
Bulgaria  28 

4. Climate Action 

to 

(NDC) 

law  also 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
limits  the 
2030  compared  to  1990.  The 
contribution  that  carbon  removals  can  make  towards 
emission  reductions  in  2030,  to  ensure  a  sufficient 
mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
the 
Nationally  Determined  Contribution 
UNFCCC in December 2020.  
The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010119  and  sets  binding  GHG  emission 
standards for different vehicle categories120.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from  land-
use,  land-use-change  and  forestry  (LULUCF)  have  been 
included in the EU emission-reduction efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
their  national  adaptation 
required 
policies121,  as  the  EU  Climate  Law  recognises  adaptation 
as a key component of the long-term global response to 
climate change. Member States will be required to adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

report  on 

to 

Key national climate policies and strategies  

Bulgaria  adopted  its  integrated  national  energy  and 
climate  plan 
2021-2030.  Bulgaria’s 
for 
decarbonisation  path  to  long-term  climate  neutrality  is 

(NECP) 

119  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements  for  fuels  used  in  road  transport  in  the  EU  to  protect 
human health and the environment, and to make road travel across the 
EU safer. 
120 Regulation (EU) 2019/631. 
121 Article 29 of Regulation (EU) 2018/1999. 

still unclear. Bulgaria has not yet submmited its national 
long-term strategy under the Governance Regulation.  

Bulgaria allocates 58.9% of its RRP’s spending to climate 
objectives  and  outlines  crucial  reforms  and  investments 
to  further  the  green  transition  (for  more  details  see 
Chapter 5). 

At  the  end  of  2019,  Bulgaria  adopted  its  first  climate 
change  adaptation  strategy  and  action  plan  until  2030. 
Bulgaria  does  not  yet  have  a  review  and  update  of  the 
measures  taken  under  the  strategy  for  vulnerability  and 
risk assessments. 

Between 1990 and 2020, total greenhouse gas emissions 
decreased  by  50%.  Bulgaria’s  greenhouse  gas  (GHG) 
emissions  intensity  (in  terms  of  gross  value  added) 
decreased by over one fifth between 2015 and 2020, but 
is  still  around  four  times  the  EU  average.  Bulgaria 
remains  the  most  energy-  and  greenhouse  gas-intensive 
economy in the European Union and coal is still the main 
source of energy. 

Figure 32: Total greenhouse gas emissions (incl. 
international aviation) in Bulgaria, 1990-2020 

Effort sharing target  

For emissions not covered by the EU’s emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets  under  the  Effort  Sharing  legislation122.  Bulgaria’s 
target  under  the  EU  legislation  is  to  not  increase  its 
emissions 
in  non-ETS  sectors  (buildings,  road  and 
domestic  maritime  transport,  agriculture,  waste  and 
small industries)   by more than 20% by 2020 and by 0% 
by 2030 compared to 2005.  The country’s Effort  Sharing 
emissions in 2019 were slightly above its 2020 target. The 
Bulgarian national energy and climate plan concludes on 

122 Regulation (EU) 2018/842 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
                                                                 
the basis of its projections that it will meet its 2030 non-
ETS target with additional measures.  

Figure 33: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in Bulgaria, 
2020 and 2030 as percentage change from 2005 

Figure 34: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/ deficit of AEAs under the 
Effort Sharing Decision in Bulgaria, 2013-2020 

Bulgaria  29 

increase 

free  parking  or 

in  electric  vehicles 

significantly  higher  than  the  EU  average.  The  uptake  of 
zero-emissions passenger cars in Bulgaria is low, as is the 
density of public charging points. Bulgaria has around 500 
recharging  points  by  2021  (according  to  the  European 
Alternative  Fuels  Observatory  –  EAFO).  In  the  coming 
years,  however,  an 
is 
expected  in  Bulgaria.  In  its  recovery  and  resilience  plan 
Bulgaria committed to installing 10 000 recharging points 
by  2026  to  provide,  among  other  things,  for  the 
necessary energy for travel. This would also contribute to 
significant  progress  towards  achieving  the  necessary 
amount of infrastructure for electromobility. Bulgaria will 
encourage  the  use  of  electric  and  hybrid  vehicles 
incentivised  by  the  application  of  a  tax 
(currently 
reduction, 
for 
municipalities) in public and private transport. According 
to the NECP, every new building should be equipped with 
at  least  one  charging  station.  Bulgaria  also  plans  to 
diversify  the  use  of  renewable  energy  sources  in  the 
transport  sector  by  introducing  biofuels  and  hydrogen. 
GHG  emissions  in  the  sector  can  also  be  reduced  by 
accelerating  the  introduction  of  modern  technologies  in 
railway  transport  (ERTMS)  as  well  as  in  other  modes  of 
transport.  The  upgrade  of  current  intelligent  transport 
in  road  transport.  Regarding 
systems  will  continue 
waterborne  transport,  the 
implementation  of  traffic 
management  systems  –  river  information  system  (RIS) 
and  vessel  traffic  management 
information  system 
(VTMIS) – will continue to be upgraded. The deployment 
of  the  single  European  sky  air  traffic  management 
research (SESAR) programme is ongoing in air transport. 

subsidies  only 

Figure  35:  Greenhouse  gas  emissions  by  sector  in 
Bulgaria123 – historical emissions 1990-2020, projections 
2021-2030124 

Key sectoral developments 

In  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Bulgaria  reduced  by  3.3%  from  2010  to  2019.  Bulgaria 
needs to act swiftly to meet the reduction target of 6% by 
2020.  There  are  several  types  of  action  that  Member 
States  can  take  in  this  regard,  for  example:  (i)  further 
in  road  transport 
expanding  the  use  of  electricity 
(including 
charging 
through 
infrastructure);  (ii)  supporting  the  use  of  biofuels  and 
advanced  biofuels  in  particular;  (iii)  incentivising  the 
development and deployment of renewable fuels of non-
biological  origin;  and  (iv)  reducing  upstream  emissions 
before refining processes. 

deployment 

of 

Road  transport  in  2019  in  Bulgaria  represented  17%  of 
the  country’s  total  greenhouse  gas  emissions.  Road 
transport emissions increased by 35% between 2005 and 
20019.  The  average  age  of  Bulgaria’s  vehicle  fleet  is 

123  The  sectors  in  the  figure  correspond  to  the  following  IPCC  sectors: 
Energy supply: 1A1, 1B and 1C. Energy use in manufacturing industries: 
1A2.  Industrial  processes  and  product  use:  2.  Transport:  1A3.  Other 
energy  use:  1A4,  1A5  and  6.  Agriculture:  3.  Waste:  5.  International 
aviation: 1.D.1.a. 
124 European Environmental Agency, Total GHG trends and projections. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
                                                                 
Bulgaria  30 

Figure 36: Reported and accounted emissions and 
removals from LULUCF in Bulgaria125 

Use of revenues from the auctioning of EU ETS 
allowances 

The  total  revenues  from  the  auctioning  of  emission 
allowances  under  the  EU  ETS  over  the  years  2012-2021 
were  EUR  2.5  billion.  In  Bulgaria,  nearly  98  %  has  been 
spent to climate and energy purposes. Unspent revenues 
are  carried  over  to  later  years,  therefore  in  some  years 
spending is higher than the revenues (as it is the case in 
2016 and 2017).  

2022 priority actions 

  Bulgaria  should  increase  uptake  of  renewables,  both 
in  electricity  production  and  in  the  heating  and 
cooling sector. 

  Bulgaria should enhance renovation of building stock. 
  Bulgaria  should  implement  additional  measures  and 

changes in land management practices. 

  Bulgaria  should  implement  reforms  in  regions  with  a 
regions).

carbon-intensive  energy 

sector 

(coal 

On buildings, Bulgaria plans to take measures to improve 
the energy performance of at least 5% of the total gross 
floor area of all heated and cooled state-owned buildings 
used by the public administration. According to the 2020-
2050  long-term  strategy  for  renovation  of  the  national 
building 
residential  and  non-residential 
buildings, Bulgaria plans to renovate 60% of the building 
stock and approximately 17% of non-residential buildings 
by  2050.  The  expected  energy  saving  is  7329  GWh  per 
year. 

stock  of 

On  agriculture,  emissions  have  increased  significantly 
since 2005. 

On  land  use  LULUCF  sector,  Bulgaria’s  projection  in  the 
NECP  indicates  a  stable  level  of  net  removals  by  2030. 
Reported  quantities  under  the  Kyoto  Protocol  for  the 
LULUCF  sector  in  Bulgaria  show  net  removals  of,  on 
average,  -10.2  Mt  CO2-eq  for  2013  to  2019.  In  this 
regard,  Bulgaria  contributes  with  2.9%  to  the  annual 
average  sink  of  -344.9  Mt  CO2-eq  of  the  EU-27. 
Accounting for the same period shows net credits of, on 
average,  -2.2  Mt  CO2-eq,  which  makes  up  1.9%  of  the 
EU-27 accounted sink of -115.0 Mt CO2-eq.  Reported net 
removals show minor variations with a slightly increasing 
trend overall; the same pattern is  more accentuated  for 
accounted net credits. 

125  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory note 
on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol’.   

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
                                                                 
Bulgaria  31 

Part II: Enabling framework: Implementation tools

5. Financing

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gap between countries. Post-2020, 
environmental  measures  will  also  be  supported  by  the 
EU’s  COVID-19  Recovery  Fund  (via  the  Recovery  and 
Resilience  Facility)  and  the  ‘do  no  significant  harm’ 
principle, which runs across the EU budget. The renewed 
commitments  made  at  COP26 
(Glasgow,  October-
November  2021)  and  the  Biodiversity  Convention  (April-
May 2022)124 will also be reflected in the EU budget.126   

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
is  taken)  for  climate,  energy  and 
additional  action 
transport  were  estimated in 2021 at EUR 390 billion per 
year  (EU-27)127,  with  a  further  EUR  130  billion  a  year  to 
deliver  the  EU's  core  environmental  objectives128.   The 
costs  of  climate  adaptation  can  also  be  significant,  and 
are  estimated  to  reach  a  total  of  EUR  35-62  billion 
(narrower  scope)  or  EUR  158-EUR  518  billion  (wider 
scope)  per  year129.  Those  investment   needs  reflect  the 
implementation  objectives  to  2020  and  to  2030  (except 
for  climate  change  adaptation,  the  costs  of  which  are 
expected to last over a longer time horizon).   

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1130.  Almost  40%  of 

126  The  Convention  on  Biological  Diversity  (cbd.int); Post-2020  Global 
Biodiversity Framework | IUCN. 
127 SWD (2021) 621, accompanying proposal COM(2021) 557 to amend 
the REDII Directive (EU) 2018/2001.  
128 SWD(2020) 98 final/2.  
129  SWD(2018)292, 
Regulation.  
130  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  DG  ENV  ‘Study  supporting  EU  green  investment  needs 
internal  analysis 
analysis’ 
‘Environmental  Investment  needs  and  financing  in  the  EU’s  green 
transition’,  July 2020. 

(ongoing,  2021-2023)  and  DG  ENV 

Impact  assessment  accompanying 

the  LIFE 

the environmental investment gap relate to dealing with 
pollution,  which  accounts  for  nearly  two  thirds  of  the 
total  gap  if  combined  with  water  management.  The 
investment  gap  in  circular  economy  and  waste  amounts 
to  EUR  13-28  billion  a  year,  depending  on  levels  of 
circularity 
implemented.  The  annual  biodiversity 
financing gap is estimated at around EUR 20 billion. 

Table 1: Estimated breakdown of the EU’s 
environmental investment gaps, by environmental 
objective, 2021-2030 per year131 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems132 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in Bulgaria 

Air quality, water, urban wastewater, waste management 
and  circular  economy  stand-out  as  major  environmental 
investment  needs  in  Bulgaria.  Significant  investment 
efforts are still needed in the following fields to support 
the implementation of EU environmental legislation.    

131 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-2023) and DG Environment 
internal analysis ”Environmental Investment needs and financing in the 
EU’s green transition“,  July 2020.  
132   To meet the needs of  the 2030 Biodiversity Strategy (Natura 2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for  nature  (COM/2020/380  final)  while  to  fully  cover  the  strategy 
(including  restoration)  EUR  30-35  billion  may  be  needed,  indicating  a 
gap  of  EUR  10-20  billion  a  year  compared  to  current  baseline 
expenditure. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
                                                                 
 
                                                                 
Pollution prevention & control 

The  EU’s  first  Clean  Air  Outlook133  under  the  clean  air 
programme  estimated  that  to  reach  the  emission 
reduction  requirements134  in  the  NECD  by  2030EUR  908 
million  a  year  would  be  required,  including  EUR  682 
million  a  year  for  capital  investment  (assuming  the 
achievement of the 2030 climate and energy targets).   

The  second  Clean  Air  Outlook135  suggests  that  the 
EU would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  is  implemented  (including  all  air 
pollution  legislation  and  the  2030  climate  and  energy 
targets  set 
in  2018);  and  (ii)  Member  States  also 
implemented  the  measures  announced  in  their  national 
air-pollution  control  programmes136.  The  only  exception 
is  for  ammonia  (NH3)  for  15  Member  States,  including 
Bulgaria137. 

Bulgaria  32 

financial - economic study141 accompanying it, are also a 
relevant source of information in this domain. 

Waste & circular economy 

According to a Commission study142 to meet the recycling 
targets  for  municipal  waste  and  packaging  waste, 
Bulgaria  still  needs  to   invest  an  additional  EUR  113 
million  (around  16  million  per  year)  between  2020-
2027 (beyond the baseline investments).  

reprocessors;  biowaste 

facilities;  and  digitalisation  of 

These  investments  will  need  to  cover:  waste  collection; 
treatment;  waste 
recycling 
sorting 
the  waste 
registry. This  does  not  include  investment  necessary  in 
other  key  waste  streams  (plastics,  textiles,  furniture)  or 
the inevestment needed to increase circularity and waste 
prevention across the economy. 

Water management 

Biodiversity & ecosystems 

According to an OECD study on financing a water secure 
future  (2022)138,  access  to  sanitation  services  remains 
low,  with  only  66%  of  the  population  connected  to  a 
wastewater  collection  system  and  only  50%  to  a 
wastewater  treatment  plant.  Investment  is  needed  in 
water  and  sanitation  infrastructure,  as  most  of  it  was 
in  the  1960s  and  1970s  and  needs  to  be 
built 
rehabilitated,  extended  and  repaired.  EU  funding  has 
provided  a  significant  share  of  past  public  funding  over 
the past decade. It is estimated that Bulgaria will need to 
invest  an  additional  cumulative  EUR  2.3  billion  by  2030 
for  drinking  water  and  sanitation  (beyond  the  baseline 
investments)  –  corresponding  to  around  230  million 
additional  investment  need  (capital  expenditure)  per 
annum,  with  around  93%  of  that  relating  to  wastewater 
139. Moreover, the recent 6th Water Framework Directive 
and  Floods  Directive  Implementation  Report140  and  the 

133 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018. 
134  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
135 COM(2021) 3 Final and Report Annex.   
136  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis  (IIASA),  Support  to  the  development  of  the  Second  Clean  Air 
Outlook, 2020 and Annex. 
137  Nevertheless, the NECD also foresees deliveries by 2020 and 2025. 
Communication Second Clean Air Outlook; Annex.   
138 OECD, Financing a Water Secure Future, 2022. 
139  OECD,  Bulgaria  -  Country  fact  sheet-  Financing  Water  Supply, 
Sanitation and Flood Protection.  
140 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

The  recently  submitted  priority  action  framework  (PAF) 
for  Bulgaria  shows  that  existing  nature  protection  costs 
(including  Natura  2000)  in  2021-2027  are  estimated  at 
EUR 716.1  million.  This  represents  an  annual  cost  of 
about  EUR  102.3  million,  of  which  EUR  24.5  million  are 
on- off costs143.  

the 
This  excludes  additional  costs 
biodiversity  strategy  up  to  2030,  including  on  increased 
protection and restoration. 

implement 

to 

EU environmental funding  2014-2020 

The MFF for 2014-2020 allocated almost EUR 960 billion 
(in  commitments,  2011  prices)144  for  the  EU  to  spend 
over  this  period.  The  commitment  in  this  2014-2020 
MMF  to  the  green  transition  included  a  20%  climate 
spending  target.  It  also  included  funding  opportunities 
for  the  environment,  in  particular  under  the  European 
Structural  and  Investment  (ESI)  Funds145.  The  2014-2020 

141  European  Commission,  Directorate-General 
for  Environment, 
Economic data related to the implementation of the WFD 
and  the  FD  and  the  financing  of  measures,  Final  report. 
Publications Office, 2021. 
142  European  Commision,  Study  on  investment  needs  in  the  waste 
sector and on the financing of municipal waste management in Member 
States, 2019. 
143  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021.  
144 Council Regulation (EU, Euratom) No 1311/2013. 
145  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 

 Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
                                                                 
 
MFF  budget  was  subsequently  topped  up  with  over 
EUR 50 billion  (in  current  prices)  from  the  REACT-EU 
programme  for  cohesion-policy  action  against  COVID-
19146.  

environmental 

Bulgaria  received  EUR  11 047.7  million  from  the  ESI 
Funds  in  2014-2020  to  invest  in  job  creation  and  a 
sustainable  and  healthy  European  economy  and 
environment.  Of  this  EUR  11 047.7  million,  the  planned 
direct 
to 
EUR 1 667.5  million  with  a  further  EUR  697.4  million 
identified  as  indirect  environmental  investment  value, 
totalling  EUR  2  635  million.  Figure  38  gives  an  overview 
of (planned) individual ESI Funds earmarked for Bulgaria 
(EU  amounts,  without  national  amounts)  for  2014-2020 
and the environmental investments included.   

investment 

amounted 

Figure 37: ESI Funds allocated to Bulgaria, including 
environmental investments, 2014-2020147 

Bulgaria  has  spent  less  than  one  third  (EUR  505  million) 
of  the  allocated  EUR  1  667.5  million.  Most  of  the  funds 
were  spent  on  water  management  –  EUR  285.7  million. 
Bulgaria  spent  EUR  49  million  on  waste  management; 

(YEI),  the  European  Agricultural  Fund  for  Rural  Development  (EAFRD) 
and the European Maritime and Fisheries Fund (EMFF).   
146 Regulation (EU) 2020/2221. 
147 European Commission, DG Environment - Data analysis based on ESI 
Funds  Open  Data  Portal  (cohesiondata.ec.europa.eu),  Integration  of 
in  Cohesion  Policy  Funds  (COWI,  2017), 
environmental  concerns 
(EU)  2021/1060  and 
Regulation 
Implementing  Regulation 
Environmental 
investments  here  are  captured  via  the  combined  use  of  intervention 
fields  and  coefficients  under  the  Regulation  (EU)  No  1303/2013  and 
Regulation  (EU)  2021/1060    allowing  for  a  more  precise  identification 
and  valuation  of  relevant  environmental  investments.  N.B.  Indirect 
environmental investments are valued using the Annex I environmental 
coefficients of the Regulation (EU) 2021/1060 (as opposed to full value).    

(EU)  No  1303/2013,Regulation 

(EU)  No  215/2014. 

Bulgaria  33 

EUR  16.2  million  on  air  quality,  EUR  55  million  on 
biodiversity and nature, and EUR 60.9 million on climate 
mitigation and adaptation and risk management. All were 
far below the planned allocations. On land rehabilitation 
Bulgaria spent EUR 38.1 million, which was slightly above 
the originally allocated sum. 

Table 2: Direct and indirect environmental investments 
under the ESI Funds in Bulgaria, 2014-2020148 

Instrument 

Under cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
waste 
air quality 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
energy efficiency 
sustainable transport 
business development, R&I 

Under EAFRD/rural development 
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Indirect environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

2 158.4 
1 538 
801.0 
197.2 
250.8 
125.0 
37.8 
126.2 
620.4 
136.1 
461.0 
23.3 

184.9 
108.3 
45.6 
62.7 
76.6 
31.9 
44.7 

21.6 
21.2 
21.2 

0.4 
0.4 

2 365.0 
1 667.5 
697.4 

Funding  for  the  environment  from  the  ESI  Funds  has 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States,  such  as  the  LIFE 

investments 

148  European  Commission,  DG  Environment  -  Data analysis.  The  values 
of  environmental 
the  specific 
in 
environmental  areas  may  differ 
from  the  tracking  values  at 
cohesiondata.ec.europa.eu, e.g. for clean air or biodiversity due to two 
factors:  the  set  of  environmental  coefficients  used  and  the  range  of 
funds assessed. DG Environment’s analysis here  covered the full range 
of ESI Funds. See also previous footnote. 

identified  here 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                                                        
 
  
 
 
                                                                 
programme,  Horizon  2020  or  loans  from  the  European 
Investment Bank (EIB), that add up to an estimated total 
of EUR 2.7 billion for Bulgaria in 2014-2020.  

is  entirely  dedicated 

The  LIFE  programme149 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best  practice  actions  for  green 
solutions to be deployed. In 2014-2020, Bulgaria received 
EU  support  for  20  LIFE  projects  with  EUR  44.0  million 
from  the  LIFE  programme  for  nature  and  environment 
(out  of  1 028  LIFE  projects  across  the  EU27  with  a  total 
EU contribution of EUR 1.74 billion)150. 

It 

In  2014-2020,  Horizon  2020  allocated  about  EUR  5.8 
million  to  Bulgaria  for the  environment, in particular  for 
natural resources and ecosystems and raw materials; the 
sum  represented  3.6%  of  Bulgaria’s  total  allocation151. 
From the European Fund for Strategic Investments (EFSI), 
Bulgaria received a total of EUR 358 million financing. Of 
this,  EUR  65  million  was  for  environmental  projects152.  
Environment-related  EIB  loans  to  Bulgaria  amounted  to 
EUR  237 million (supporting  both water and  waste), out 
of overall EIB lending to Bulgaria  of EUR 1 820 million in 
the period153, 154.  The country ranks 21st for size of total 
EIB lending in 2014-2020. 

In  2020,  the  EIB  provided  EUR  24.2  billion  in  funding 
across  Europe  to  fight  climate  change,  37%  of  its  total 
financing.  It  also  provided  EUR 1.8 billion  (3%  of  its 
financing) for broader environmental lending155,  

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU spending programme will mobilise 
EUR  2.018  trillion  (in  current  prices)  to  support  the 
long-term 
from  COVID-19  and  the  EU’s 
recovery 

149 European Commission, LIFE Programme.  
150 LIFE Country overview Bulgaria 2020 (europa.eu). 
151 Source: https://sc5.easme-web.eu/, accessed: 15-12-2021.  
152  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm.  
153 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm.  
154 EIB Activity Report 2021. 
155  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just Transition Mechanism. The EIB Group stands as a key implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 

several  programs 

finance 

that 

Bulgaria  34 

including 

environmental 

protection156. 
priorities, 
Following the EU Green Deal’s157 pledge to ‘do no harm’ 
and  the  Interinstitutional  Agreement  on  the  2021-2027 
MFF158, 30% of the EU budget in 2021-2027 will support 
climate efforts, while biodiversity will receive 7.5% of the 
EU  budget  as  of  2024  and  10%  as  of  2026  that  requires 
increased  programming  of 
for 
biodiversity,  specifically  under  the  2021-2027  Cohesion 
policy and the 2023-2027 CAP to reach those targets.  

resources 

financial 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)159. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard)160.  Reinforced  by  the  renewed  sustainable-
finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change162 can help to close the insurance-protection gap, 
which  currently  leaves  many  risks  from  climate-related 
events uninsured163. The EIB will align 50% of its lending 
for  climate  and  environment  projects  by  2025164,  with  a 
EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027.  

(2020)161,  sustainable 

climate  and 

investment 

to 

Table 3: Key EU funds allocated to Bulgaria (current 
prices), 2021-2027 

Instrument 

Cohesion policy 
ERDF 
CF 
ESF+ 
ETC (ERDF) 

Allocations (million EUR) 
9 768.4165 
5 741.5   
1 266.2166 
2 625.2 
135.5167 

long-term  EU  budget  & 

https://ec.europa.eu/info/business-economy-euro/banking-and-

156  European  Commission,  2021-2027 
NextGenerationEU. 
157 COM/2019/640 final. 
158 Interinstitutional Agreement, OJ L 433I. 
159 
finance/sustainable-finance/eu-taxonomy-sustainable-activities_en.   
160 EU Green Bond Standard - 2021/0191 (COD). 
161 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
162 COM(2021) 82 final. 
163  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA  (the  Association  for  European  Insurance  and  Occupational 
Pension Authorities) dashboard on insurance protection gap for natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
164 EIB Climate Bank Roadmap 2021-2025, November 2020. 
165  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
166  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
167  Interreg  initial  allocations  per  MS  including  ETC  transnational  and 
ETC cross-border cooperation.  

 Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
  
                                                                 
Bulgaria  35 

Just Transition Fund 
 EAFRD/rural development  
under CAP strategic plans 2023-
2027169 
European  Maritime,  Fisheries 
and Aquaculture Fund (EMFAF) 

1 295.1168 

1 410.8 170 

EUR 84.9 171 

RRF  
2021 – 2026172  

Total: EUR 6 267  173  
(grants) 

In  Bulgaria,  the  programming  for  most  EU  funds 
(cohesion  policy 
funds,  EAFRD  and  the  European 
Maritime, Fisheries and Aquaculture Fund) is ongoing.   

In the course of the programming exercise for 2021-2027 
in Bulgaria, estimations based on draft programmes show 
that 
the  European  Regional  Development  Fund’s 
contribution to the EU climate target should reach 30.2% 
or  EUR  1  733  million.  The  contribution  of  the  Cohesion 
Fund should reach EUR 616 million or 51.5% of the total 
allocation from this Fund for the Member State. 

However,  the  negotiations  have  been  concluded  under 
the  RRF.  Its  main  outcomes,  especially  as  regards  its 
environmental dimension, are summarised below.   

The  plan  will  support  the  green  transition,  in  particular 
the  climate  change  dimension  but  also  dedicated 
environmental  measures  addressing  biodiversity,  water 
supply  and  sewerage,  sustainable  agriculture  as  well  as 
circular  economy  (at  company  level)  and  air  quality 
(through clean transport measures and energy efficiency 
of buildings), totalling to far above the minimum of 37% 
of  a  climate  target  to  reach  58.9%  (approximately  EUR 
3.7 billion). 

‘Connected  Bulgaria’;  and 

is  structured  around  twelve  components 
The  RRP 
in  four  policy  pillars:  ‘Innovative  Bulgaria’; 
grouped 
‘Green  Bulgaria’; 
‘Fair 
Bulgaria’.  Eight  out  of  the  twelve  components  include 
expenditure that contributes to climate objectives, most 
notably  the  low-carbon  economy,  sustainable  transport 
and  smart  industry.  Most  of  the  components  contribute 
to climate objectives, including environmental ones.  

The  plan  includes  a  set  of  interrelated  and  reinforcing 
investments  enhanced  by  a  water  sector  reform,  all  of 
which  are  aimed  at  modernising  water  resource 
management and making it more sustainable. The water 
sector  reform  is  expected  to  optimise  the  regulatory 

168  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
169 European Commission, CAP strategic plans.  
170 Regulation (EU) 2021/2115, Annex XI.  
171 Regulation (EU) 2021/1139, Annex V.  
172  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
173 Council Implementing Decision  

framework  for  water  supply  and  sewerage  services.  It 
consists of the adoption of a new law, the Water Supply 
and Sewerage Act, which aims  to provide the conditions 
for  consolidation  in  the  provision  of  water  supply  and 
sewerage services and introducing uniform conditions for 
service  quality  and  efficiency  criteria  to  be  met  by  the 
water  supply  and  sewerage  operators.  The  new 
legislation 
is  expected  to  refine  the  tariff  setting 
mechanisms,  ensuring  cost-based  pricing  for  the  use  of 
the  systems  and  the  consumed  services  while  also 
ensuring  financial  sustainability  of  the  operators.  The 
water  management  investments  included  in  the  plan 
reconstruction  and 
consist  of 
modernisation  of  water  supply  and  sewerage  systems, 
and drinking and wastewater treatment plants, as well as 
the  digitalisation  of  water  management  and  improving 
the control of water use. 

construction, 

the 

The  main  risks  to  biodiversity  in  Bulgaria  are  the  loss  of 
habitats and the degradation of ecosystems as a result of 
urban  and  infrastructure  development,  unsustainable 
agriculture  and  the  exploitation  of  species  of  economic 
importance.  The  RRP  includes  a  dedicated  component 
aiming  at  protecting  and  restoring  ecosystems  and 
natural  habitats  and  species  of  European  and  national 
in  this 
importance.  The  reforms  and 
component  are  expected  to  contribute  to  building 
effective  Natura  2000  management  structures 
in 
Bulgaria, and to restoring climate-related ecosystems and 
protecting biodiversity. 

investments 

The  plan  also 
includes  measures  to  enhance  the 
sustainable  management  and  competitiveness  of  the 
Bulgarian  agricultural  sector  as  part  of  the  green 
transition.  The  plan 
includes  a  national  action 
programme, which is expected to set out a framework for 
the management and protection of the environment and 
natural resources in the field of agriculture.  The plan also 
includes dedicated investments that consist of setting up 
a  Fund  for  promoting  the  technological  and  ecological 
transition of the Bulgarian agricultural sector. 

The  plan  includes  reforms  and  investments  to  support 
deployment of renewable electricity generation (by 2026, 
3.5 GW of wind or solar collocated with (30%) storage; 10 
MW  of  geothermal  electricity  generation  capacity  and 
500  MW  large-scale  electricity  storage  with  6,000  MWh 
discharge  over  12h  should  be  commissioned  and 
connected  to  the  grid)  and  a  dedicated  measure  to 
support  the  development  of  pilot  projects  enabling  the 
introduction of green hydrogen and biogas for industrial 
applications,  as  well  as  for  their  future  use  in  transport 
and for the production of electricity and heat.  

It includes significant investment in energy renovation of 
finance  energy 
investments  will 
buildings.  The 
renovations  of  residential  and  public/private  buildings, 
street  lightning  and  renewables  for  households  not 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
connected  to  natural  gas  and/or  heat  transmission 
networks.  The measures are expected to deliver at least 
30% reduction of energy needs and lead primary energy 
savings of 1.1 TWh/year.  

road  decarbonisation 

The  RRP  addresses 
through 
measures such as the promotion of electric car mobility, 
with  10  000  charging  stations  –  including  fast-charging 
stations – to be built across Bulgaria. Its aims include new 
zero-emission and low-emission vehicles to reach a total 
of  30 000  by  mid-2026;  new  electric  rolling  stock  for 
suburban 
the 
construction of a 3km new section of Sofia metro; and a 
sustainable urban mobility pilot scheme with purchase of 
zero-emission  public  transport  vehicles  and  charging 
station infrastructure. 

interregional 

transport; 

and 

rail 

Figure 38: Climate expenditure in RRP, 2021-2026174 

Bulgaria  36 

Connecting  Europe  Facility  (EUR  33.7  billion)176 or  the 
funds  to  be  mobilised  via  the  InvestEU177.  They  will  also 
support  the  green  transition,  including  research  and 
innovation  activities 
for  environmental  protection 
(Horizon  Europe)178,   clean  transport  and  energy  (the 
Connecting 
sustainable 
infrastructure (InvestEU)180.   

Facility)179  

Europe 

or 

National environmental financing 

Total  national  environmental  protection  expenditure 
(including all relevant current and capital expenditure )181 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  the  common  GDP  being  quite  stable  over  time.  
While  absolute  expenditure  is  concentrated  in  a  few 
countries,  as  a  share  of  GDP,    most  countries  spend 
between 1-2%, with Bulgaria spending 1.3%. 

Of  the  above  total,    the  EU-27's  capital  expenditure 
(Capex)  on  environmental  protection  (i.e.  investment)  
amounted  to    EUR  56.3  billion  in  2018,  lowering  to  EUR 
54.5  billion  in  2020,  representing  around  0.4%  of  GDP. 
Most  Member  States  invested  0.2-0.5%  of  their  GDP  in 
environmental protection, with Bulgaria belonging to the 
higher  end  (0.5%).  During  2014-2020,  this  totalled  to 
around  EUR  376  billion  of  environmental  investment  in 
the  EU-27,  and  to  a  little  under  EUR  3.6  billion  for 
Bulgaria.  

Under  NextGenerationEU,  the  Commission  will  issue  up 
to  EUR  250  billion  of  EU  green  bonds  (one  third  of  all 
bonds  issued  under  NextGenerationEU)  until  2026  that 
will  comply  with  the  general  spirit  of  the  ‘do  no 
significant harm’ principle. However, this EUR 250 billion 
in  green  bonds  will  not  be  subject  to  the  currently 
developed  delegated  acts  related  to  the  EU  Taxonomy 
and  will  not  fully  align  with  the  proposed  EU  standards 
for green bonds.  

In  addition  to  EU  funds  earmarked  specifically  for 
Bulgaria in the 2021-2027 period, there are also funding 
programmes that can be accessed at EU level and which 
are  open  to  all   member  states  on  competitive  basis. 
These  include,  among  others,  the  LIFE  programme  (EUR 
5.4  billion),  Horizon  Europe   (EUR  95.5  billion)175,  the 

174 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
175 European Commission, Multiannual Financial Framework 2021-2027 
(in commitments) - Current prices. 

176 Regulation (EU) 2021/1153. 
177  The InvestEU Fund  is foreseen  to  mobilise over EUR 372 billion of 
investment  through  an  EU  budget  guarantee  of  EUR  26.2  billion  to 
back the 
investment  of  financial  partners  such  as  the  European 
Investment Bank (EIB) Group and others. 
178 European Commission, Horizon Europe. 
179 European Commission, Connecting Europe Facility. 
180 European Union, InvestEU.   
181    At  economy  level,  including  final  consumption,  intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
                                                                 
                                                                 
Figure 39: Environmental protection investments in the 
EU-27 (EUR million and % of GDP), 2018182 

Figure 40: EU-27 Member States' environmental 
protection investments (Capex) by institutional sectors 
(Total economy = 100%), 2018183

Bulgaria  37 

institutional 

sector,  over  60%  of  Bulgaria’s 
By 
environmental 
(capital 
investments 
protection 
expenditure) came from the general government, a third 
from  the  business  sector  and  almost  6%  from  specialist 
producers  (of  environmental  protection  services,  e.g. 
waste  and  water  companies).  At  EU  level,  37%  comes 
from  governments,  33%  from  specialist  producers  and 
30% from industry (business). 

Breakdown  of  investment  by  environmental  topic  is 
partially  available,  but  only  at  the  level  of  institutional 
sectors  (rather  than  at  economy  level),  due  to  different 
reporting  patterns  across  the  sectors.184  At  Bulgaria’s 
level,  70%  of  environmental 
general  government 
protection 
investments  went  to  wastewater  and  a 
quarter  to  waste  management.  For  Bulgaria’s  specialist 
producers  of  environmental  protection  services,  an 
overwhelming  share  (over  90%)  of  relevant  investments 
were  received  by  waste  management.  As  regards  the 
business  sector,  55%  of  environmental  protection 
investments  went  on  protection  of  air,  19%  on 
wastewater and 10% on waste management. 

In 2020, the total issuance of green bond185 by European 
countries  (including  some  non-EU  countries)  was  USD 
156  billion  (EUR  137  billion),  up  from  USD  117  billion 
(EUR  105  billion)  in  2019186.  For  EU-27  Member  States, 

183 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
184  Data  reporting  differs  for  the  three  institutional  sectors,  leading  to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data across all environmental areas (CEPA 1-9), although this is less the 
case for general government and industry, which often report (the non-
obligatory)  data  in  merged  categories  only  (because  it  is  difficult  to 
disaggregate these data) or not at all.  
185  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  Most  green  bonds  issued  are 
green ‘use of proceeds’ or asset-linked bonds. The very first green bond 
was  issued  in  2007  with  an  AAA-rated  issuance  from  multilateral 
institutions, the European Investment Bank (EIB) and the World Bank. 
186Climate 
Bonds 
https://www.climatebonds.net/standard/taxonomy.  USD 
converted via Eurostat’s annual average EUR/USD exchange rates. 

Taxonomy: 
is 

value 

182 Eurostat, Environmental Protection Expenditure Account, 2021. 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
                                                                 
 
 
                                                                 
Bulgaria  38 

Figure 42: Environmental taxes in the EU-27, 2020191 

issuance 

in  2020  was  EUR 124  billion. 
green  bond 
Bulgaria did not issue green bonds in 2020. In 2014-2020, 
83%  of  the  green  bonds  issued  by  European  countries 
served objectives in energy, buildings or transport, while 
8%  supported  objectives  in  water  and  waste,  with  a 
further 6% supporting sustainable land use – with links to 
ecosystem conservation and restoration187. 

Figure 41: Annual EU green bond issuance in 2020 (EUR 
billion)188 

simultaneously 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society  and  promote  a  just 
transition.  Tax  reforms  can  contribute  to  sending  the 
right  price  signals  and  incentives  to  economic  players. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations192. The Green Deal promotes the ‘polluter 
pays  principle’  (PPP)193,  which  stipulates  that  polluters 
should bear the cost of measures to prevent, control and 
remedy  pollution;  it  is  not  fully  ensured  in  Bulgaria.  The 
polluter-pays  principle    is  facilitated  by  the  European 
Commission’s Technical Support Instrument  (TSI) project 
taxes194.  Bulgaria  applies  economic 
on  greening 
instruments  such  as  water  consumption  charges,  but 
does not make use of pay-as-you-throw schemes195. 

into  account 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 

191 Eurostat, Environmental taxes accounts (env_eta). 
192 COM (2019/640 final), p. 17.  
193  Enshrined  in  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the 
European  Union:  ‘Union policy  on  the  environment  (…)  shall  be  based 
on  the  precautionary  principle  and  on  the  principles  that  preventive 
action should be taken, that environmental damage should as a priority 
be rectified at source and that the polluter should pay’.  
194  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice,  green budgeting TSI participation. 
195  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021.  

Green budget tools 

Green taxation and environmental tax reform 

Representing  3.03%  of  its  GDP,  Bulgaria’s  revenue  from 
environmentally relevant taxes in 2020 is well above the 
EU  average  of  2.24%  although  in  absolute  figures  it 
remains among the lowest  (with EUR 1859.1 million), as 
shown  in  the  Figure  43.  The  largest  portion  of  the 
environmental taxes were the energy taxes  with a share 
of  88.3%  in  2020  (2.68%  of  the  GDP,  well  above  the  EU 
average  of 1.74%), while transport  tax represents  10.2% 
(0.31%  of 
the  GDP,  EU  average  0.42%)  and 
pollution/resources  tax  accounts  for  1.4%  (0.04%  of  the 
GDP, EU average 0.08%)189. 

Bulgaria allocates more than the EU average on fossil-fuel 
subsidies  —  and  higher 
renewable-energy 
subsidies190. 

than 

187  Interactive  Data  Platform  at  www.climatebonds.net.  Climate  Bonds 
Taxonomy is similar to the EU Taxonomy. 
188 Climate Bonds Initiative, 2022. 
189  Eurostat, Environmental Taxes. 
190  European  Court  of  Auditors,  Energy  taxation,  carbon  pricing  and 
energy subsidies, 2022.  

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
 
 
 
                                                                 
reforms196.  Fossil  fuel  subsidies  are  costly  for  public 
budgets  and  make  it  difficult  to  achieve  the  Green  Deal 
objectives.  In  many  cases  the  subsidies  also  counteract 
incentives  for  green  investments,  not  contributing  to 
levelling  the  playing  field.  Annual  fossil  fuel  subsidies 
have  been  around  EUR  55  billion  in  the  EU  since  2015. 
They rose by 4% between 2015 and 2019, although some 
countries  (such  as  Latvia,  Lithuania  Sweden,  Greece  or 
Ireland) managed to decrease them in this period. In the 
EU,  subsidies  for  petroleum  products  in  sectors  such  as 
transport  and agriculture continued to increase in 2015-
2019. However, subsidies  for coal and lignite decreased, 
largely  due  to  the  diminishing  role  of  solid  fuels  in 
electricity  generation.  As  a  share  of  GDP,  fossil  fuel 
subsidies ranged from 1.2% in Hungary to less than 0.1% 
in Malta in 2019 (with an EU average of 0.4%). Fossil fuel 
subsidies amounted to EUR 0.6 billion in Bulgaria in 2019, 
reaching  almost  1%  of  GDP  –  more  than  double  the  EU 
average. 

In 2020, the EU-27’s total fossil fuel subsidies decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  actions,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020197. 

Figure 43: Trends in natural gas and electricity subsidies 
in Bulgaria198 

% GDP 

2015 

2016 

2017 

2018 

2019 

2020 

Electri
city 

2,81 

1,26 

3,18 

3,20 

3,33 

2,99 

Natur

0,79 

0,78 

0,81 

0,97 

0,13 

0,32 

196  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform potential for the EU 28, 2016.  
197  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex.  
198 OECD, Fossil fuel subsidy tracker.  

Bulgaria  39 

al gas 

Current green budgeting practices  

Green  budgeting  encompasses  various  climate  and 
environmental  tagging  and  tracking  practices  in  budgets 
and  some  EU  Member  states  already  use  green 
budgeting  elements.199  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues  to 
increase 
environmental 
impliacatitons  of  budgetary  policies,  improving  policy 
coherence  and  supporting  green  policies  (including 
climate end environmental objectives)200. 

transparency 

the 

on 

EU climate proofing and sustainability proofing guidance 
have  also  been  developed,  as  tools  to  assess  project 
eligibility  and  compliance  with  environmental  legislation 
and  criteria.201  The  EU  Commission  established  a  green 
budgeting  reference 
launched  a 
technical  support  project  (TSI)  on  green  budgeting  in 
2021  to  assist  Member  States  in  developing  or  further 
developing  national  green  budgeting  frameworks  to 
improve  policy  coherence  and  support  the  green 
EU 
transition. 
Commission’s green budgeting project started in 2021. 

framework202  and 

participation 

Bulgaria’s 

the 

in 

Overall financing compared to the needs 

The EU’s overall environmental financing for investments 
is  estimated  to  have  been  0.6-0.7%  of  GDP  in  the  2014-
2020  period,  taking  into  account  major  EU  funds  and 
national  financing.  This  ranged  from    0.3%  (Ireland)  to  
1.91%  (Bulgaria), 
individual 
linked  to  the 
environmental challenges in Member States. In the 2021-
2027  period,  the  EU’s  environmental  investment  needs 
are  estimated  to  range  between  0.9-1.5%  of  the 
projected  GDP  (2021-2027),  suggesting  a  potential 
environmental financing gap  of 0.6-0.8% of the EU  GDP, 
compared to previous financing levels.203 

level  of 

199 European Commission, Green budgeting practices in the EU: A First 
Review, 2021.  
200  European  Commission,  European  Commission  green  budgeting 
reference  framework.  European  Commission,  Green  budgeting  in  the 
EU Key insights from the 2021 Commission survey.  
201 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
202 European Commission, Green budgeting reference framework, based 
on  the  review  of  the  OECD  Paris  Collaborative  on  Green  Budgeting 
initiative, 2017. 
203 Source: DG Environment data analysis. EU financing sources covered: 
ESI  Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon  2020,  LIFE,  EFSI 
(EU amount), EIB loans. National financing: total national environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset.  Cut-off  date  for  data:  end  2021.  N.B.  The  total  financing  may 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
                                                                 
 
 
                                                                 
 
Figure 44: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% 
of GDP)204 

needs across the environmental objectives by closing 
investment 
the 

gaps.    

Bulgaria  40 

In 

EU 

the 

funds. 

overall 

financing 

2021-2027, 

environmental 

Bulgaria’s 
for 
investments  came  to  an  estimated    1.91%  of  GDP  in 
2014-2020, with a dominance of national financing (62%) 
over 
country’s 
environmental investment needs are also high, estimated 
to  reach    2.98%  of  Bulgaria’s  GDP  (with  partial  data, 
available  at  country  level),  suggesting  an  environmental 
financing gap of at least 1.07% of GDP, likely to be higher 
when  also  accounting  for  needs  estimated  at  EU  level 
(e.g. water protection, circularity, biodiversity etc.) -to be 
addressed  through  mobilising  further  financing  sources 
to back environmental implementation priorities. 

In  the  2019  EIR,  Bulgaria  had  no  priority  actions  for 
environmental  financing.  However,  there  is  room  for 
improvement in the next years. 

2022 priority actions 

  Bulgaria  should  devise  an  environmental  financing 
for  closing 
to  maximise  opportunities 
strategy 
environmental 
bringing 
implementation 
together all relevant administrative levels, potentially 
increasing the share of EU funds as well as of private 
financing sources (that are currently around 30%). 
  Bulgaria should ensure an increased level of financing 
for  the  environment  to  cover  the  high  investment 

gaps, 

be  higher,  in particular  through further  indirect  investments,  requiring 
further analysis in the future. 

204 Eurostat, ESI Funds Open Data, 2021. 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
                                                                                                        
 
Bulgaria  41 

6. Environmental governance

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  

(i) access to information;  

(ii) public participation in decision making; 

(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively205.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment206. It includes the right to bring 
legal challenges (‘legal standing’)207.  

Environmental information 

This section focuses on Bulgaria’s implementation of the 
INSPIRE  Directive.  The 
INSPIRE  Directive  aims  at 
establishing  a  European  spatial  data  infrastructure  for 
sharing   environmental  spatial 
information  between 
public  authorities  across  Europe,  assisting   in  policy-
making across boundaries and facilitating public access to 
this  information.  Geographic  information  is  needed  for 
good  governance  at  all  levels  and  should  be  readily  and 
transparently available.  

As  part  of  a  general  compliance  promotion  exercise  on 
the  accessibility  of  priority  data  sets  for  reporting,    a 
letter of formal notice was send to Bulgaria. Bulgaria has 
responded to the formal notice with a steadily improving 
implementation.  

Nevertheless,  Bulgaria’s  implementation  of  the  INSPIRE 
Directive  could  be  better.  Its  performance  has  been 
reviewed  based  on  the  country's  2021  country  fiche208. 
Data  identification  and  documentation  have  made  good 
progress,  and  implementation  levels  have  improved. 
However, more efforts are needed209. 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020210 

2020 

Legend 

201
6 

Effective  coordination  and  data 
sharing 

Ensure 
coordination  

effective 

■  ■ 

Data  sharing  without 
obstacle  

■  ■ 

INSPIRE performance indicators 

Conformity 

i. 
metadata 

of 

■  ■ 

Conformity 

ii. 
spatial data sets211 

of 

■  ■ 

iii.  Accessibility  of 
spatial 
sets 
through  view  and 
download services 

data 

■  ■ 

iv.  Conformity  of 
network services 

■  ■ 

■ 
Implementation  of 
is  well 
this  provision 
advanced 
(nearly) 
or 
completed.  Outstanding 
issues  are  minor  and  can 
be 
easily. 
Percentage: >89% 

addressed 

■ 
Implementation  of 
this  provision  has  started 
and  made 
some  or 
substantial  progress  but 
is  still  not  close  to  be 
Percentage: 
complete. 
31–89% 

■    Implementation  of 
is  falling 
this  provision 
behind. 
significantly 
efforts 
Serious 
are 
close 
necessary 
to 
implementation 
gap. 
Percentage: <31% 

Public Participation 

Publication  of  the  initiation  of  Environmental  Impact 
Environmental 
Assessment 

Strategic 

(EIA) 

and 

205  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive  (Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation.  
206 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
207  This  EIR  focuses  on  the  means  implemented  by  Member  States  to 
guarantee  rights  of  access  to  justice,  legal  standing  and  to  overcome 
other major barriers to bringing cases on nature and air pollution. 

208 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/BG. 
209European Commission, List of high value spatial data sets. 
210 INSPIRE knowledge base, 2021. 
211 The deadlines for implementation of the spatial data interoperability 
were  in  2016  still  in  the  future:  23/11/2017  for  Annex  I  data  and 
21/10/2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
majority  of  the  countries  provide  as-is-data  sets  in  addition  to  the 
INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
  
  
                                                                 
Assessment  (SEA)212  procedures  and  the  possibility  for 
the  public  to  submit  views  regarding  plans  or  projects 
which  require  an  EIA  or  SEA  are  mandatory  in  Bulgaria. 
The Ministry of Environment and Water and the Regional 
Inspectorates  for  Environment  and  Water  (for  SEA/EIA 
falling  within  their  region)  have  well-developed  and 
updated  information  on  SEA/EIA  procedures  on  their 
websites. The  information published covers notifications 
for investment proposals (planned projects), information 
to  assess  the  need  of  an  EIA  or  SEA,  information  for 
forthcoming public consultations on EIA reports (and the 
EIA  report  itself)  or  EA  consultations,  EIA  decisions  (or 
refusals),  SEA  opinions  (or  refusals),  transboundary 
EIA/EA  procedures  and  public  registers  on  EIA/SEA. 
However, the national law does not require the public to 
be  informed  about  the  nature  of  possible  decisions  or, 
where there is one, the draft decision. 

Citizens  and  NGOs  may  express 
their  opinions, 
suggestions,  and  comments  in  written  form,  also  via  e-
mail  (during  the  consultations)  or  in  person  at  public 
hearings of EIA/SEA Reports. However, while the national 
law  requires  the  main  reasons  and  considerations  on 
which  the  decision  is  based  to  make  available  to  the 
public  and  other  relevant  authorities  by  the  competent 
authority,  this  does  not  cover  information  about  the 
public participation process. In addition, the national law 
has  no  sanctions  covering  essential  violations  of  the  EIA 
procedures. 

Statistics  on  the  level  of  public  participation  in  decision 
making  processes  including  authorisations  is  available  in 
the  national  reports  on  the  state  and  protection  of  the 
environment in the Republic of Bulgaria (available at the 
web-page of the Executive Environmental Agency)213 and 
the MoEW reports214. 

Access to justice 

Bulgarian 
interested 
legislation  grants  standing  to 
persons  (environmental  NGOs  –  ENGOs  –  and  physical 
persons)  to  bring  to  court  both  measures  of    general 
nature, such as protected areas management  plans, and 
certain 
the  executive 
authorities. 

regulatory  acts 

issued  by 

The  normative  acts  (by-laws)  issued  by  the  executive 
authorities  can  be  challenged  (Article  185-196  of  the 
APC).  They  may  be  challenged  in  full  or  in  relation  to 
individual  provisions.  Citizens,  organisations  and  bodies 
whose rights, freedoms or legal interests are affected, or 

212 Bulgarian law uses notion ‘environmental assessment’ as equivalent 
to ‘strategic environmental assessment’. 
213 http://eea.government.bg/bg/dokladi 
214 

https://www.moew.government.bg/bg/otchet-za-izpulnenieto-na-

byudjeta-po-politiki-i-programi-za-2020-g-na-mosv 

Bulgaria  42 

may be affected, by a by-law normative act, or for whom 
such  act  gives  rise  to  obligations,  have  the  right  to 
challenge the act. 

After the provision of the Spatial Development Act (SDA), 
which  fully  banned  challenging  general  spatial  plans  as 
being  unconstitutional  (Article  215  (6)  SDA),  a  limited 
possibility  for  legal  review  was  introduced  (Article  127 
(12)  and  (13)  SDA).  General  spatial  plans  can  now  be 
challenged by the owners of  estates directly affected by 
the  plan.  Plots  that  can  be  considered  directly  affected 
are  further  limited  to  plots  where  the  plan  envisages 
either  the  construction  of  public  infrastructure  or  the 
restriction of owner’s rights for public interests related to 
protection  of  the  environment  and  of  human  health, 
protection  of  agricultural  areas,  forest  areas,  protected 
areas  and  special  areas  of  conservation.  There  is  still  no 
access  to  justice  in  cases  where  plans  envisage,  for 
example,  urbanising  protected  areas  or  otherwise 
affecting  such  sites.  Similarly,  the  detailed  plans  cannot 
be  challenged  by  the  general  public  or  ENGOs,  but  only 
limited  property  rights  and 
by  owners,  holders  of 
concessionaires  of  the  plot  or  of  the  neighbouring  real 
estates  regulated  or  directly  affected  by  the  detailed 
spatial  plan  (Article  131  SDA).  At  the  moment,  the 
prevailing  case-law  on  the  matter  is  that  only  ENGOs 
registered  with  public  interest  have  a  right  of  appeal  in 
environmental cases. To grant standing to the interested 
public  within  the  scope  of  environmental 
impact 
assessments,  the  court  carries  out  an  admissibility  test 
regarding  the  legal  personality  and  legal  interest  of  the 
complainant,  as  well  as  the  suitability  of  the  challenged 
act as a subject of appeal. There is a persistent practice of 
restrictive interpretation by the national courts, whereby 
standing  was  not  granted  to  the  public  concerned  –   
including  NGOs  –  to  challenge  a  municipal  programme 
for  improving  the  quality  of  the  ambient  air  under  the 
Clean  Ambient  Air  Act215.  This  practice  goes  against  the 
settled  case-law  of  the  Court  of  Justice  of  the  EU  and  is 
subject to infringement proceedings by the Commission. 

If  an  act  is  adopted  in  the  form  of  a  law  (normative 
instrument), the only possibility for direct judicial review 
of  the  act  is  before  the  Constitutional  Court,  and  only 
specific  subjects  (one  fifth  of  the  Members  of  the 
Parliament,  the  President,  the  Council  of  Ministers,  the 
Supreme Court of Cassation, the Supreme Administrative 
Court and the Prosecutor General) are entitled to initiate 
this review (Article 150(1) of the Constitution). 

There is a link to the website of the MoEW with general 
information  about  the  Aarhus  Convention  and  some 

215 Confirmed by a Court Order of the Supreme Administrative Court No 
552 of 24 January 2022.  

 Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
                                                                 
guidance  related  to  its  provisions216.  Other  forms  of 
dissemination  are  provided  mostly  by  NGOs  on  their 
websites217 or on the special project websites. 

(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement222.  

Bulgaria  43 

In the 2019 EIR, Bulgaria received two priority actions in 
this  area.  Despite  some  progress  in  the  implementation 
of  the  INSPIRE  Directive,  more  efforts  are  needed.  Little 
progress  has  been  made  in  access  to  justice  as  regards 
general spatial plans. No progress has been made in the 
area  of  access  to  justice  on  air  pollution.  Although 
amendments to the Air Quality Act have been drafted in 
this sense, they have not yet been adopted. 

2022 priority actions 

  Bulgaria  should  make  spatial  data  more  widely 
accessible  and  prioritise  environmental  datasets  in 
implementation  of  the  INSPIRE  Directive,  especially 
those  identified  as  high-value  spatial  datasets  for 
implementing environmental legislation 

  Bulgaria should improve access to courts by the public 
concerned  when 
challenging 
administrative  or  regulatory  decisions  and  omissions 
also  in  the  planning  context,  in  particular  under 
water, nature and air quality. 

comes 

to 

it 

  Bulgaria  should  better  inform  the  public  about  their 
access  to  justice  rights,  notably  in  relation  to  air 
pollution  and  nature  in  particular  by  referring  to  on 
judicial and administrative portals to the Commission 
eJustice 
in 
environmental matters218. 

fact  sheets  on  access 

justice 

to 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste219.  It 
includes  support  measures  provided  by  the  authorities 
such as: 
(i) compliance promotion220;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring221;  

216https://www.moew.government.bg/bg/dostup-do-
informaciya/orhuska-konvenciya/. 
217 https://www.zazemiata.org/за-земята-достъп-до-правосъдие  
218https://e-
justice.europa.eu/content_access_to_justice_in_environmental_matter
s-300-en.do 
219  The  concept  is  explained  in  detail  in  the  Communication  on  ‘EU 
actions  to  improve  environmental  compliance  and  governance’  COM 
(2018) 10  and  the  related  Commission  Staff  Working  Document,  SWD 
(2018)10. 
220 This EIR focuses on the help given to farmers to comply with nature 
legislation and nitrates legislation. 
221 This EIR focuses on inspections of major industrial installations. 

Compliance promotion and monitoring 

The  main  measures  addressed  to  duty  holders  (incl 
farmers)  to  support 
implementation  of  the  Nature 
Directives  and  Nitrates  Directive  are  provision  of 
information on the web-sites of the relevant authorities, 
information  campaign  and  advices  provided  by  the  27 
regional  offices  of  the  National  Agricultural  Advisory 
Service at the Ministry of Agriculture, Food and Forestry 
which  works  as  farmer  helpdesk  by  providing  advisory 
services, current  information and technical assistance to 
implementation  of  efficient  and 
farmers 
for 
in  the  Republic  of  Bulgaria, 
competitive  agriculture 
including provision of consultations and trainings. 

the 

The 
its 
information  on  the  Nature  Directive  and 
implementation  is  detailed  and  well  elaborated223,  as 
information  on  good  agricultural  and 
well  as  the 
environmental  conditions,  related  national  standards, 
CAP,  Rural  Development  Programmes  and  its  specific 
measures. 

As regards the Nitrates Directive the national authorities 
have  a  number  of  measures,  programmes  and 
consultations for  farmers  (carried out  by the Ministry of 
Agriculture,  Food  and  Forestry  and  its  bodies  -  National 
Agricultural Advisory Service and State Fund Agriculture). 

it  can  be  noted  that  the 

Still 
information  on  the 
obligations  of  the  duty  holders  under  the  Nature  and 
Nitrates  Directives  is  spread  across  different  websites 
and  Bulgaria  lacks  one  centralised  point  of  information, 
which  would  facilitate  access  to  this  information  for 
farmers and duty holders. 

The information on inspections (plans and reports) or on 
follow-up cases of non-compliance based on information 
from  the  public/citizens  is  publicly  available  on  the 
websites  of  the  national  competent  authorities  and 
regularly  updated.  The  territorial  structures  of  the 
Ministry  of 
(Regional 
Inspectorates  for  Environment  and  Waters,  National 
Parks and River Basin Directorates) publish their plans for 
monitoring  and  control  activities  online,  together  with 
the  lists  of  entities  subject  to  monitoring  under  various 

and  Water 

Environment 

222  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
223  https://www.moew.government.bg/bg/priroda/natura-2000/natura-
2000-v-bulgariya/naj-chesto-zadavani-vuprosi/  https://natura2000.bg/   
http://natura2000.moew.government.bg/Home/Documents 
https://www.naas.government.bg/data/Natura%202000.pdf 
https://www.mzh.government.bg/bg/sektori/rastenievadstvo/dobri-
zemedelski-i-ekologichni-usloviya/ 
https://www.dfz.bg/en/ 

 Environmental Implementation Review 2022 – Bulgaria 

 
 
                                                                 
                                                                 
relevant  laws,  including  industrial  emissions  legislation. 
The  Regional  Inspectorates  for  Environment  and  Water 
(RIEW)  publish  monthly  activity  reports  covering  the 
number  of 
inspections  carried  out,  the  number  of 
recommendations provided, and the number of penalties 
imposed, including fines. The inspection reports are also 
made publicly available on their web-sites. Public access 
to  environmental 
is  provided  through 
regional reports on the state of the  environment,  which 
are  prepared  by  each  RIEW  annually  and  contains 
detailed 
incl.  analysis  on  environmental 
media  and  the  control  activities  carried  out  within  the 
current year. 

information 

information 

Complaint handling and citizen science 

Bulgaria  has  a  functioning  environmental  complaint 
system  in  place.  Members  of  the  public  can  report  on 
environmental issues  via telephone (the ‘Green hotline’) 
or  by  e-mail  to  the  Ministry  of  Environment  and  Water, 
RIEW,  Basin  Directorates  or  National  Park  Directorates. 
The  telephone  numbers  are  published  on  the  Ministry’s 
website224  and  on  the  websites  of  its  regional  bodies.  
Complaints  can  also  be  submitted 
in  paper.  After 
verification  of  the  complaint,  the  competent  authorities 
send information about the follow-up of the complain to 
the complainant.  

The  regional  inspectorates  of  environment  and  water 
keep anonymous monthly public records on submissions 
of  complaints  and  the  measures  taken  to  address  them 
by the competent authorities. Information on the action 
taken  is  published  on  the  websites  of  the  MoEW225  and 
its territorial offices. 

information 

is  available  on 

Online 
the  national 
competent authorities’ websites about complaints on the 
management  by  the  administration  on  environmental 
including  public  authority's  handling  of  the 
cases, 
complaints,  response  time,  follow-up  steps,  actions 
preserving anonymity, and statistics on the outcomes226. 

No  evidence  was  found  for  public-awareness  raising 
initiatives  to  make  citizens  aware  of  the  possibility  to 
alert or inform the authorities about facts likely to cause 
environmental  damage,  or  breaches  of  environmental 
law.  Although  the  legislation  on  biodiversity  and  on 

224  https://www.moew.government.bg/bg/zelen-telefon-za-podavane-
na-signali/ 
225  https://www.moew.government.bg/bg/zelen-telefon-za-podavane-
na-signali/predprieti-dejstviya-po-postupili-signali-v-mosv/ 
226https://portal.moew.government.bg/bg/Home/Service?admUnitServi
ceId=3 
; 
https://www.mzh.government.bg/media/filer_public/2019/04/12/rd09
; 
-373-vp.pdf 
https://www.mh.government.bg/bg/politiki/antikoruptsiya/podavane-
na-signal/ 

Bulgaria  44 

environmental  damage  provides  opportunity  for  NGOs 
and  other  organizations  to  be  involved  in  activities 
related  to  nature  protection  and 
identification  of 
environmental  damage,  no  specific  national  policy  on 
encouraging  the  use  of  citizens’  science  in  respect  of 
enforcement  or  promotion  of 
compliance  with 
environmental law was identified. 

Enforcement 

is  no  centralised  database  or  statistics  on 
  No 
the  prosecution  of 

There 
environmental  crimes  and 
information 
environmental crimes. 

is  available  on 

their  outcomes. 

The  cooperation  between  the  different  competent 
authorities  for  the  protection  of  the  environment  and 
investigation  of  environmental  crimes  is  required  by 
information 
several  national 
is 
available 
dealing  with 
environmental  damages  or  crimes  work  together  in 
practice. 

limited 
professionals 

laws.  Still, 

how 

on 

In 2020, a special coordination center was created at the 
MoEW  which  has  as  one  of  its  tasks  to  coordinate 
information  between  environmental 
exchanges  of 
enforcement  authorities.  However,  besides  a  written 
instruction  for  administrative  cooperation  in  cases  of 
transboundary  shipments  of  waste,  no  other  written, 
standardized  procedures  or  internal  rules,  circulars  or 
memoranda  of  understanding  have  been  identified  on 
cooperation 
competent 
the 
authorities,  dealing  with  environmental  crimes  or 
damages227. 

between 

different 

Environmental Liability Directive (ELD) 

In  Bulgaria,  the  Law  on  liability  for  preventing  and 
remedying  ecological  damage  requires  the  Minister  of 
Environment  and  Water  to  set  up  and  maintain  an 
information  system  for  cases  of  imminent  threats  of 
environmental  damage  or  cases  of  environmental 
damage  caused.  The  information  must  include  the  type 
of  (imminent)  ecological  damage, 
initiated  pre-trial 
proceedings  or  court  cases  in  connection  with  such 
(imminent)  ecological  damage  and  results  thereof,  and 
the  application  of  financial  insurance.  However,  this 
information  system 
is  not  yet  available.  Currently, 
information  on  environmental  damage  is  made  public 
through  national  reports  on  the  state  and  protection  of 
the environment in the Republic of Bulgaria (available at 

227  The  national  authorities  states  that  there  is  no  need  for  written 
strategy  as  far  as  exchange  of  information  and  coordination  among 
is  done  at 
authorities  and  administrations 
operational level on the basis of the functions and responsibilities of the 
unit set out in the Rules of the structure and the activity of MoEW. 

is  concerned.  This 

 Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
 
                                                                 
the  web  page  of  the  Executive  Environmental  Agency) 
and the MoEW reports. 

Little  progress  has  been  achieved  as  regards  the  four 
priority  actions  received  in  2019.  Therefore  they  are 
essentially reiterated. 

2022 priority actions 

  Bulgaria  should  make  available  a  structured  and 
centralized  online  information  point  for  farmers  and 
other  duty-holders  on  how  to  comply  with  their 
obligations on Nitrates and Nature Directives. 

  Bulgaria  should  encourage  public  participation  in 
enforcement,  by  awareness-raising  activities  on  the 
options  for  reporting  environmental  problems;  more 
generally,  establish  active  plans  for  making  use  of 
citizen science. 

  Bulgaria  should  make 

information  and  statistics 
available on the prosecution of environmental crimes, 
and through information on formal arrangements for 
cooperation among responsible public bodies. 

Effectiveness of environmental 
administrations 

Those  involved  in  implementing  environment  legislation 
at EU, national, regional and local levels need to have the 
knowledge,  tools  and  capacity  to  ensure  that  the 
legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

The  structure  of  the  public  administration  in  Bulgaria 
reflects  its  three  administrative  tiers  (central,  regional 
and local). 

for  devising 

The  Ministry  of  Environment  and  Water  remains  the 
central and main authority in the environmental sector in 
Bulgaria.  It  is  responsible  for  drafting  and  implementing 
national  environmental  policy; 
the 
environmental  regulation  system;  and  for  coordinating 
and supervising the protection, conservation and rational 
utilisation  of  natural  resources,  waste  management 
policy  and  water  management  policy. 
is  also 
for  coordination  and  management  of 
responsible 
financial  resources  on  environmental  matters,  including 
the  operational  programme  for  the  environment.  The 
Executive  Environment  Agency 
is  an  administration 
linked  to  the  Environment  Minister  managing  the 
national environment monitoring system. 

It 

Bulgaria  45 

orders  on  application  of  coercive  administrative 
measures  and  penalty  decrees.  They  also  provide  the 
‘green hotline’ for environmental information and alerts. 
The four basin directorates are regional authorities of the 
Ministry with responsibility for water basin management. 
They cover the  four  RBDs in  Bulgaria: the Danube  River, 
the Black Sea, the East Aegean and the West Aegean. The 
three  national  park  directorates  (NPD)  —  Rila,  Pirin  and 
Central Balkan — are administrative structures under the 
Minister  of  environment  and  water,  ensuring  the 
implementation of the state policy for management and 
protection  of  the  national  parks.  Their  tasks  include 
the  updated 
the  development  of 
assignment  of 
management plans and their implementation. 

Municipalities  are  the  basic  administrative-territorial 
units  of  self-governance.  The  powers  of  municipalities 
legal  powers  regarding  waste 
vary  from  full-scale 
to  drafting  policies  and  providing 
management, 
information  on  and 
for  administrative 
procedures such as SEA and EIA, for which the RIEWs are 
responsible. They may also participate in procedures  for 
designating  protected  areas  and  drafting  management 
plans for protected areas228. 

support 

Bulgaria  is  characterised  by  a  high  turnover  rate  of  civil 
servants  for unclear reasons, indicating  some underlying 
deficits229.  This  is  a  striking  exception  compared  to  the 
low  to  medium  turnover  in  the  civil  service  of  most 
the 
Member 
administration. 

to  weakening  of 

leading 

States 

Bulgaria’s  governance  effectiveness 
indicator  has 
significantly  dropped  from  0.26  in  2019  to  -0.07  in 
2020230. 

Improving  the  quality  of  services  and  introducing    e-
government  has  been  a  key  priority 
in  public 
administration  reform  for  many  years  without  visible 
results. 

As  noted  in  the  2019  EIR,  unstable  policies  and  lack  of 
trust  in  key  public  institutions  such  as  the  judiciary 
continue to be significant deterrents to investment in the 
Bulgarian  economy  and  lead  citizens  and  environmental 
NGOs  to  opt  to  address  their  concerns  about  possible 
breaches  of  environmental  legislation  to  the  European 
Commission, even in areas not covered by EU law. 

strategic 

The 
importance  of  an  efficient  public 
administration  and  of  a  well-functioning  digital 
government,  including  e-health  and  e-procurement  was  
emphasised by the COVID-19 crisis. Although having been 

The 15 Regional Inspectorates of Environment and Water 
(RIEWs)  are  territorial  units  of  the  Ministry.  They  have 
regulatory,  information  and  inspection  tasks;  their  main 
activity  is  to  enforce  environment  law.  They  have  the 
issue  prescriptions, 
power  to  impose  sanctions  and 

228  UNECE,  Environmental  performance  review  (EPR)  Bulgaria,2017, 
p. 28. 
229 A Comparative Overview of Public Administration Characteristics and 
Performance in EU28 
230 World Bank, 2020 Worldwide Governance Indicators. 

 Environmental Implementation Review 2022 – Bulgaria 

 
                                                                 
Bulgaria  46 

ios  done 
accelerating  decision-making,  provided 
without  coimpromising the quality of the environmental 
assessment procedure232. 

it 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 

The Commission supports environmental implementation 
and  the  green  transition  through  the  EU  financing 
programmes.  It  also  gives  support  by  granting  technical 
assistance through the TSI. 

In  2021,  Bulgaria  participated  in  a  green  budgeting  TSI 
training in 2021 and made a request for a TSI project  for 
the  establishment  of  a  national  decarbonisation  fund. 
The  Commission  encourages  Bulgaria 
to  continue 
applying in the coming years.  

TAIEX EIR Peer to Peer Projects 

The  TAIEX-EIR  peer-to-peer  tool233  was  launched  by  the 
Commission  to  facilitate  peer-to-peer  learning  between 
environmental  authorities.  Bulgaria  is  not  very  active  in 
using  the  TAIEX-EIR  peer-to-peer  tool.  During  the 
reporting period, it participated in only two multicountry 
events  related  to  air  quality,  involving  all  or  most 
Member States. 

supported by the EU, their implementation is progressing 
too slowly. This negatively impacted the effectiveness of 
the public sector during the lockdown period. Bulgaria is 
lagging  behind  in  the  provision  of  e-services.  Looking 
forward, an effective public administration will be key for 
ensuring the timely and effective implementation of the 
recovery  measures.  Cooperation  and  coordination  at  all 
levels  of  government  remain  particularly  important.  A 
stronger  regulatory  predictability  and  stability,  effective 
control  over  policy  implementation,  and  a  reduction  of 
the  administrative  burden,  would  improve  the  business 
environment  and  promote 
investment,  positively 
affecting the speed of the recovery231. 

Non-conformity is not a significant factor in infringement 
proceedings  against  Bulgaria,  as  Bulgaria  generally 
transposes  environmental  directives  on 
time  and 
correctly.  Poor  application  and  enforcement  of 
environmental legislation, however, continue to be major 
cause of infringement proceedings. 

Structural issues in areas such as air quality, appropriate 
assessment  under 
the  Habitats  Directive,  waste 
management  and  urban  waste  water  treatment,  while 
having been partially addressed, remain unresolved. The 
application  of  the  Directives  on  environmental  impact 
assessment (EIA) and strategic environmental assessment 
(SEA)  are  also,  to  some  extent,  raised  as  complaints 
mainly in relation to Nature protection. 

Coordination and integration  

Structural  problems 
in  areas  such  as  air  quality, 
appropriate  assessment  under  the  Habitats  Directive, 
waste  management  and  urban  waste  water  treatment, 
while  having  been  partially  addressed,  remain  unsolved. 
The  application  of  the  Directives  on  environmental 
impact  assessment  (EIA)  and  strategic  environmental 
assessment (SEA) are also, to some extent, raised as part 
of complaints mainly in relation to Nature protection. 

the 

As  mentioned  in  the  2019  EIR  Report,  Bulgaria  has 
environmental 
streamlining 
introduced 
assessments  under  EIA  and  Habitats  Directives  already 
prior  the  revision  of  the  EIA  Directive.  Coordinated 
procedures  have  been  established  for  EIA,  Water 
Framework Directive and Industrial Emission Directive. It 
was highlighted as a good practice. 

of 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments 
reduce 
in  environmental 
duplication  and  avoid  overlaps 
assessments  applicable  to  projects.  Although  helping  to 
and 
reduce 

administrative 

unnecessary 

in  order 

burden 

to 

231  Recommendation  for  a  Council  Recommendation,  Bulgaria  2020 
(para 24). 

232 The Commission issued a guidance document in 2016 regarding the 
setting  up  of  coordinated  and/or 
that  are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive,  Water  Framework  Directive,  and  the  Industrial  Emissions 
Directive, OJ C 273, 27.7.2016, p. 1.  
233  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu). 

joint  procedures 

 Environmental Implementation Review 2022 – Bulgaria