COMMISSION STAFF WORKING DOCUMENT The early warning report for Bulgaria Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target
Date: 2023-06-08
Institutions: Directorate-General for Environment, European Commission
Subjects: Bulgaria, EU environmental policy, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

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   EUROPEAN COMMISSION  Brussels, 8.6.2023  SWD(2023) 176 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Bulgaria         Accompanying the document Report From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions   identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target     {COM(2023) 304 final} - {SWD(2023) 175 final} - {SWD(2023) 180 final} - {SWD(2023) 181 final} - {SWD(2023) 182 final} - {SWD(2023) 183 final} - {SWD(2023) 184 final} - {SWD(2023) 185 final} - {SWD(2023) 186 final} - {SWD(2023) 187 final} - {SWD(2023) 188 final} - {SWD(2023) 189 final} - {SWD(2023) 195 final} - {SWD(2023) 196 final} - {SWD(2023) 197 final} - {SWD(2023) 198 final} - {SWD(2023) 199 final} - {SWD(2023) 200 final}  
 
 
1.  Introduction 

The early warning report aims to assist Member States at risk of failing to meet: (i) the 2025 target of 55% for 
the preparing for re-use and the recycling of their municipal waste (this target is set out in Article 11(2)(c) of 
Directive 2008/98/EC); and (ii) the 2025 target of 65% for the recycling of their packaging waste (this target 
is set out in Article 6(1)(f) of Directive 1994/62/EC). It also provides an update on how Member States are 
performing against the 2035 target to send no more than 10% of their municipal waste to landfill (this target 
is set out in Article 5(5) Directive 1999/31/EC).  

This report builds on previous support provided by the Commission to help Member States comply with EU 
law on municipal waste management, including, where relevant, the early warning report from 20181. 
The assessment underpinning the early warning report identified 18 Member States at risk of missing the 2025 
preparing for re-use and recycling target for municipal waste, 10 of which are also at risk of missing the 2025 
recycling target for all packaging waste. 

This assessment is based on a collaborative and transparent process involving the Member States concerned, 
the European Environment Agency2, and an in-depth analysis of the most recent policy developments in the 
Member States. This process also involved extensive consultation with the Member State authorities in charge 
of waste management. The possible actions identified during this process are based on existing best practices 
and aim to help Member States meet the 2025 targets, and as such they focus on policy measures which can 
be  taken  in  the  short  term.  These  actions  should  be  seen  as  complementary  to  those  recommended  in  the 
roadmaps  which  were  drawn  up  as  part  of  preceding  compliance-promotion  activities  and  to  those 
recommended in the Environmental Implementation Review3. 

2.  Key findings 

Based on the analysis of collected data and existing policies in the area of waste management, Bulgaria is 
considered to be at risk of missing (i) the 2025 target of 55% for the preparing for re-use and the recycling of 
its municipal waste and (ii) the 2025 target to recycle 65% of its packaging waste.   

The distance between Bulgaria’s current landfilling rate and its 2035 target to landfill no more than 10% of its 
municipal waste is of serious concern too. Commission studies and investigations4 have shown that, in some 
landfills,  waste  is  not  subject  to  treatment  and  stabilisation  of  its  organic  fraction.  Therefore,  in  2021  an 
infringement procedure was launched against Bulgaria5. Illegal dumping of waste is still a matter of concern 
in Bulgaria. 

Municipal waste generation in Bulgaria was 407 kg/person in 2018, which is lower than the EU average of 
496 kg/person.  Packaging  waste  generated  in  2019  was  well  below  the  EU  average  (79.5 kg/person  vs 
177 kg/person). This seemingly low figure may be an indication that significant quantities of packaging placed 
on the market, which is considered as generated packaging waste, are not reported.  

1An early warning report was issued for Bulgaria in 2018 (SWD(2018) 413 final). In total, 18 recommendations were 
drafted within the assessment. According to the Bulgarian authorities eleven recommendations therein were considered 
implemented, three partially implemented and four not implemented.  
2 EEA and ETC/CE (2022). Early Warning Assessment Related to the 2025 Targets for Municipal and Packaging Waste 
(https://www.eea.europa.eu/publications/country-profiles-early-warning-assessments) 
3  European  Commission  (2022).  Environmental  Implementation  Review  2022.  COM/2022/438  final.  (https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=comnat%3ACOM_2022_0438_FIN) 
4  European  Commission  (2022).  Environmental  Implementation  Review  2022.  COM/2022/438  final.  (https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=comnat%3ACOM_2022_0438_FIN). 
5  An infringement procedure was launched against Bulgaria  for failing to comply  with the Landfill Directive and the 
Waste Framework Directive (INFR(2021)2167). 

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In 2018, Bulgaria’s municipal waste recycling rate was 31.5%, which is over 20 percentage points below the 
2025 target, while the landfilling rate was 61%, almost three times the EU average. General trends in waste 
management  are  also  of  concern:  the  recycling  rate  improved  marginally  in  the  last  5  years  (by  about  8.4 
percentage points from 2014), while the landfilling rate decreased only by about 8 percentage points in that 
period. 

Bulgaria’s excessively low rates of composting and anaerobic digestion are considered a key reason for this 
weak performance. Concerning biowaste, Bulgaria does not have enough capacity for the separate collection 
and the adequate treatment of about 0.8 million tonnes of this waste stream. Similarly, for compost produced 
from separately collected biowaste, the country still has no legally binding national quality standards or quality 
management system. The amount of municipal waste sent to landfill also remains too high. 

In 2019, the overall recycling rate for packaging reached 61%, which is very close to the 2025 target (65%). 
No data were reported for the year 2020. However, there are issues with the quality of data on packaging (for 
example, there is a notable discrepancy between the low recycling rate for municipal waste and the rather high 
recycling rates for packaging waste, which is likely due to underreporting of packaging placed on the market). 
The data sets on municipal waste and packaging waste appear to be inconsistent, given that a large share of 
packaging waste is generated by households and so is part of municipal waste. Therefore, these data should be 
considered with caution. 

Although considerable funding has been allocated to waste infrastructure, major improvements are still needed 
to bring the country’s performance in waste management in line with the EU’s waste hierarchy. Some of the 
main challenges facing waste management in the country are listed below. 

-  The  infrastructure  for  treating  biowaste  is  insufficient,  and  there  is  no  clear  plan  to  implement  its 
separate collection. There are also no national standards for compost/digestate quality and no quality 
management system. 

-  There  is  a  low  density  of  bring  points  for  packaging  waste,  and  there  are  very  limited  economic 

incentives for its separate collection.  

-  There are data quality issues, mainly on packaging. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Bulgaria’s  efforts  to  improve  its  performance  in  waste 
management, three main recommendations are listed below. 

1.  Support preparing for re-use of municipal waste and re-use systems for packaging. 
2.  Further  increase  separate  collection  of  waste  and  develop  waste  recycling  infrastructure,  such  as 

increasing the capacity to treat biowaste and supporting home composting. 

3.  Swiftly implement a national deposit-refund scheme for beverage packaging and a pay-as-you-throw 

system for businesses and households.  

4.  Improve the data quality management system on packaging waste to present consistent and verifiable 

data sets. 

The  table  below  lists  the  main  actions  to  support  Bulgaria’s  efforts  to  improve  its  performance  in  waste 
management. 

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4.  Good practices 

The following measures implemented by Bulgaria are considered good practices that that help to improve its 
recycling performance and could be replicated and that could help other Member States achieve the above-
mentioned targets. 

- 

-  Regional waste management associations in municipalities – Almost all 265 municipalities in Bulgaria 
have  established  regional  waste  management  associations.  Cooperation  on  waste  management  is 
explicitly  provided  for  in  national  legislation,  leading  to  economies  of  scale  and  a  more  efficient 
collection and treatment of municipal waste. 
Integrated  economic  instruments  (fees  and  economic  incentives)  –  A  high  landfill  tax  applies  in 
Bulgaria,  with  a  related  deduction  if  certain  targets  are  met.  Article 64  of  the  Bulgarian  Waste 
Management Act offers a strong incentive to municipalities: the ones which meet set recycling targets 
on municipal waste can get back up to 100% of the landfill tax contributions which they have paid. 
This is expected to reduce the amount of landfilled waste and increase the  amount of recycled and 
recovered waste, provided that the capacity for separate collection and recycling increases. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Address data quality issues, especially those related to waste generated from packaging placed on 
the market and the amount that has been recycled. Fully apply the criteria provided in the document 
Guidance for the compilation and reporting of data on packaging and packaging waste according 
to  Decision  2005/270/EC.  Carry  out  regular  audits  on  extended  producer  responsibility 
organisations. 

2)  Set mandatory objectives or indicators for separate waste collection should be set by the bodies in 
charge of the collection of municipal waste (e.g. municipalities) in order to monitor, enforce and 
achieve higher capture rates. This could be complemented with a system of financial rewards and 
penalties for those entities depending on whether they achieve the targets or not. Information on the 
performance of municipalities could also be made available to the general public to raise awareness 
(e.g. on a website). 

Prevention 

3)  Foster coordination between the central government and local authorities to achieve EU objectives 
on waste prevention. Properly monitor implementation of waste prevention measures, increase the 
reuse of packaging and the prevention of non-recyclable municipal waste. 

Separate collection 

4)  Introduce  clear  plans  for  the  separate  collection  of  biowaste  and  ensure  citizens’  participation 
through highly convenient collection services. Municipal bins for the separate collection of biowaste 
should be introduced alongside existing glass, paper, co-mingled (plastic and metal), and residual 
waste-stream bins. Minimum density standards for biowaste bring points should also be considered. 

5)  Swiftly  implement  a  national  deposit-refund  scheme  for  beverage  packaging  (to  collect  plastic, 
aluminium and glass beverage packaging). This could include promoting multi-use packaging over 
single-use packaging. 

6)  Specify the minimum collection service for producer responsibility organisations, further increase 
the  coverage  of  the  extended  producer  responsibility  system  and  increase  the  minimum  density 
standard for packaging waste bins matching at least the residual waste collection ones. 

Waste treatment  

7)  Support preparing for reuse of municipal waste and further develop waste treatment infrastructure 
associated with the higher steps of the waste hierarchy. Firm plans and concrete action are needed, 
such as supporting home composting and increasing the capacity to treat all generated biowaste. 
This  should  be  accompanied  with  strict  national  compost/digestate  quality  standards  to  produce 
high-quality compost and digestate. 

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Communication and awareness-raising 

8)  Carry  out  awareness-raising  activities  specifically  tailored  to  different  target  groups  (e.g. 
households, commercial waste generators, schoolteachers and students) to increase participation in 
separate collection.  A  set of  national communication  materials  should  be  developed that:  (i)  are 
addressed to the general public for use at local level; (ii) have clear and consistent messages; and 
(iii) have a particular focus on biowaste, separate collection and sound management of waste. These 
materials should be used in awareness-raising activities on social media and the internet and at civic 
amenity sites. 

Extended producer responsibility and economic instruments 

9)  Bulgaria  should  speed  up  implementing  the  Pay-as-you-throw  system  for  both  businesses  and 
households to attain higher capture rates for recyclable fractions and reduce residual waste. Local 
authorities could be supported through guidance on how to design the incentive mechanisms. 

10) Introduce changes to the Packaging and Packaging Waste Ordinance to make it more effective. 

These changes should include specifying the minimum collection service for producer 
responsibility organisations, further increasing coverage of the extended producer responsibility 
system and increasing the minimum density standard for packaging waste bins. 

11) Stepping up efforts to establish reuse systems for packaging will bring environmental benefits and 

help Member States in complying with the EU packaging recycling targets. 

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