COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 302 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025         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 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Bulgaria  1 

Contents 

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

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

1. Circular economy .................................................................................................................................................. 4 

TRANSITIONING TO A CIRCULAR ECONOMY ................................................................................................................. 4 
WASTE MANAGEMENT........................................................................................................................................... 6 

2. Biodiversity and natural capital .......................................................................................................................... 12 

GLOBAL AND EU BIODIVERSITY FRAMEWORKS .......................................................................................................... 12 
NATURE PROTECTION AND RESTORATION – NATURA 2000 ......................................................................................... 12 
RECOVERY OF SPECIES .......................................................................................................................................... 14 
RECOVERY OF ECOSYSTEMS ................................................................................................................................... 15 
PREVENTION AND MANAGEMENT OF INVASIVE ALIEN SPECIES ....................................................................................... 20 
ECOSYSTEM ASSESSMENT AND ACCOUNTING ............................................................................................................ 21 

3. Zero pollution ..................................................................................................................................................... 22 

CLEAN AIR ......................................................................................................................................................... 22 
INDUSTRIAL EMISSIONS ........................................................................................................................................ 24 
MAJOR INDUSTRIAL ACCIDENTS PREVENTION – SEVESO .............................................................................................. 26 
MERCURY REGULATION ....................................................................................................................................... 27 
NOISE ............................................................................................................................................................... 27 
WATER QUALITY AND MANAGEMENT ...................................................................................................................... 28 
CHEMICALS ........................................................................................................................................................ 30 

4. Climate action ..................................................................................................................................................... 34 

THE EU EMISSIONS TRADING SYSTEM ...................................................................................................................... 35 
EFFORT SHARING ................................................................................................................................................ 35 
LAND USE, LAND-USE CHANGE AND FORESTRY........................................................................................................... 36 
ADAPTATION TO CLIMATE CHANGE ......................................................................................................................... 36 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 38 

5. Financing............................................................................................................................................................. 38 

CLIMATE FINANCE LANDMARKS .............................................................................................................................. 38 
ENVIRONMENTAL FINANCING AND INVESTMENTS ...................................................................................................... 39 
PUBLIC FINANCIAL MANAGEMENT .......................................................................................................................... 43 

6. Environmental governance ................................................................................................................................ 46 

INFORMATION, PUBLIC PARTICIPATION AND ACCESS TO JUSTICE .................................................................................... 46 
COMPLIANCE ASSURANCE ..................................................................................................................................... 49 
EU-SUPPORTED ENVIRONMENTAL CAPACITY BUILDING ............................................................................................... 51 

2025 Environmental Implementation Review – Bulgaria 

 
 
Bulgaria  2 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Bulgaria. The purpose of this report is 
to  provide 
implementation 
performance  and  highlight  the  most  effective  ways  to 
address  the  implementation  gaps  that  impact  human 
health  and  the  environment  and  hamper  the  economic 
development  and  competitiveness  of  the  country.  The 
report relies on detailed sectoral implementation reports 
collected  or  issued  by  the  Commission  under  specific 
environmental legislation. 

information  on 

environmental 

regarding 

the 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target, and 
financial  implications.  In  Bulgaria,  such  challenges  have 
been  lingering  since  the  first  EIR  in  2017  and  require 
urgent action. 

Despite some progress made in recent years on municipal 
waste  management,  there  are  some  issues  to  address. 
Municipal  waste  incineration  represents  3%  of  the  total 
generated municipal waste that was incinerated in 2022. 
Bulgaria  still  relies  strongly  on  landfilling  despite  the 
landfilling  rate  decreasing  significantly  over  the  past  10 
years.  A positive development is that Bulgaria closed its 
substandard landfills. 

On water management, Bulgaria did not submit the third 
river basin management plans (RBMPs) and second flood 
risk  management  plans  (FRMPs)  by  March  2022,  as 
required  under  the  Water  Framework  Directive  and  the 
Floods Directive, respectively. The Commission opened an 
infringement procedure for late reporting. Bulgaria finally 
reported its second FRMPs in January 2024, and its third 
RBMPs in January 2025.  Bulgaria has significant scope to 
improve  biodiversity  and  nature  protection  and 
restoration. Several Bulgarian Natura 2000 sites have site-
further  efforts  to 
specific  conservation  objectives; 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

complete the work for all sites are key. Most importantly, 
conservation  measures  have  yet  to  be  adopted  since 
conservation  action  on  the  ground  is  far  from  being 
sufficient. To ensure efficient progress, Bulgaria needs to 
secure  financially  stable  and  operational  management 
structures that are in charge of the Natura 2000 sites at 
the central and regional levels. 

Despite progress in implementing measures addressing air 
pollution, there is still cause for concern in some parts of 
Bulgaria’s  territory.  Persistent  breaches  of  air  quality 
requirements,  which  have  severe  negative  effects  on 
health and the environment, are being followed up by the 
European  Commission  through  infringement  procedures 
covering all Member States concerned, including Bulgaria.  

On climate change, there is some progress in promoting 
zero-emission road transport solutions and in renovating 
building stock. The uptake of renewables is increasing but 
Bulgaria  still  falls  behind  Member  States  of  comparable 
size in terms of total new installed capacity. Bulgaria has 
one out of three regions identified as hotspots of climate 
risks that are most affected by climate change: low-lying 
coastal  regions.  Bulgaria  is  also  vulnerable  to  extreme 
climate events such as heatwaves and heavy rainfall. 

investment  gap 

Bulgaria’s  overall  environmental 
is 
EUR 2.4 billion  per  year,  representing  around  2.87 %  of 
the national GDP, more than the EU average (0.77 %). The 
highest  shares  are  for  biodiversity  and  ecosystems,  and 
water management. It is necessary to ensure an increased 
level  of  financing,  and  further  exploit  opportunities  in 
private financing to close investment gaps.  

improve 

On  the  positive  side,  in  the  field  of  environmental 
governance,  while  Bulgaria  needs  to 
legal 
standing  and  access  to  courts  for  the  public  concerned, 
Bulgaria  has  taken  steps  to  streamline  environmental 
assessments  by 
incorporating  the  Habitats  Directive 
appropriate  assessment,  the  industrial  emissions  permit 
process and the Seveso process for chemical safety into its 
environmental  impact  assessment  procedures.  Bulgaria 
also  has  an  excellent  record  under  the  Bathing  Water 
Directive:  out  of  the  96  Bulgarian  bathing  waters,  91 
(94,8%) were of excellent quality. No bathing waters were 
found of sufficient or poor quality. 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Bulgaria  3 

Part I: Thematic areas 

1. Circular economy 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial systems  by  reducing  input  materials,  keeping 
products  and  materials  in  the  loop  for  longer  and 
reducing  waste  generation,  thus  decoupling  economic 
growth from resource consumption. A circular economy 
has  considerable  potential  to  increase  competitiveness 
and  job  creation  and  will  also  promote  innovation  and 
provide  access  to  new  markets.  With  the  2020  circular 
economy action plan (CEAP) (2) measures either in place 
or legislatively advanced, Member States will now have 
to focus on a swift and effective implementation. 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were  all 
life-cycle 
introduced  following  a  holistic 
approach, with measures addressing the different stages 
of a product’s life cycle, from design through use to end 
of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a measure of one aspect of circularity: the 
share  of  the  total  amount  of  material  used  in  the 
economy  that  is  accounted  for  by  recycled  waste.  A 
higher  CMUR  value  means  that  more  secondary 
materials  were  used  as  a  substitute  for  raw  materials, 
thus  reducing  the  environmental  impacts  of  extracting 
primary material. The CMUR in Bulgaria reached a peak 
of 5.8 % in 2020 and then declined until 2022, before the 
in  2023. 
country  witnessed  an 
However, this is still well below the EU average of 11.8 % 
(Figure 1). 

increase  to  4.9 % 

(2) 

from  the  Commission  to  the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – A new circular 
economy action plan for a cleaner and more competitive Europe, 

15

10

5

0

2013

2015

2017

2019

2021

2023

Bulgaria

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur, last updated 
2024, 
accessed 
13 November 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cu
r. 

10 December 

2024, 

product 

Improving 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic 
resource 
(GDP). 
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 0.38 
generated  per  kg  of  material  consumed 
in  2023, 
Bulgaria’s  resource  productivity  is  well  below  the  EU 
average of EUR 2.23 per kg. 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Bulgaria

EU-27

NB:  The  unit  of  measure  used is EUR/kg  chain-linked volume  (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015. 

final 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

of 

https://eur-

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These  should  be  tailored  to  each  national  and  local 
reality, to harness the proximity economy’s (5) potential, 
while following the principles of a holistic whole-value-
chain approach. 

Since  the 
launch  of  the  online  European  Circular 
Economy  Stakeholder  Platform  in  2017 (6)  national, 
regional, and local authorities have used the platform to 
share their strategies, roadmaps and good practices, for 
example  alternative  business  models  and  innovative 
technologies. 

In October 2022, Bulgaria adopted its strategy and action 
plan for the transition to a  circular  economy for  2022–
2027 (3).  The  strategy  is  built  around  three  key  goals: 
creating a green, competitive economy; reducing waste 
and maximising resource use; and fostering an economy 
that benefits consumers. The accompanying action plan 
outlines  specific  measures  to  achieve  these  objectives. 
Central  to  the strategy  is  improving  resource  efficiency 
by  prioritising  waste  management  practices,  including 
preventing  waste  generation,  promoting  reuse  and 
recycling,  reducing  landfill  use,  and  minimising  the 
harmful  effects  on  both  the  environment  and  human 
health. 

The  strategy  and  the  accompanying  action  plan  were 
adopted under the wider umbrella of Bulgaria’s national 
development programme for 2030, Bulgaria 2030 (4). It is 
a strategic framework, consisting of 13 national priorities 
that  determine  the  vision  and  overall  goals  of 
development policies in all sectors of state governance. 
Priority 4  ‘Circular  and  low  carbon  economy’  has  the 
goals of reducing the resource intensity of the country’s 
economy  and  increasing  the efficiency  of  the  materials 
used.  The  first  action  plan  for  the  implementation  of 
Bulgaria 2030 for 2022–2024 was adopted in 2022; it was 
followed by a second action plan, with specific measures 
for 2024–2026, adopted in March 2024. 

The national development programme shifted the focus 
from  landfilling  to  the  prevention,  reuse,  recycling  and 
recovery of waste. Rational and responsible use of waste 
will  be  a  fundamental  prerequisite  for  improving  the 

Bulgaria  4 

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 (SP) on construction and demolition waste. 
the  national  development  programme 
However, 
Bulgaria 2030 includes initiatives targeting these sectors. 

strategy 

The  2021–2028  waste  management  plan (5)  envisages 
the  implementation  of  the  measures  included  in  the 
circular  economy 
concerning  products 
containing critical raw materials (CRMs). It also sets the 
aims  of  increasing  qualifications  and  skills  regarding 
effective use of resources under the green transition and 
the circular economy and raising awareness of practices 
and  behaviours  in  sustainable  consumption  and  in 
relation to the circular economy. 

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  using  green  or  circular  criteria  (life-cycle 
analysis, PaaS (platform as a service), second hand) can 
help  drive  the  demand  for  sustainable  products  that 
meet reparability and recyclability standards.   

Some 
important 
implemented  to 
procurement in Bulgaria for the first time. 

legislative  measures  have  been 
introduce  mandatory  green  public 

The Public Procurement Law (PPL) has been amended to 
include  minimum  environmental  requirements  in  the 
tender  documentation 
for  all  public  contracting 
authorities under the PPL. According to the amendments 
(new  Article 47(а)  and  Section 2,  p. 9а  of 
the 
supplementary  provisions  to  the  PPL),  when  public 
contracts of a value referred to in the PPL (Article 20(1) 
and (2)) are awarded, the procurement documents must 
contain  environmental  requirements  for  the  products 
that  are  supplied  or  used  for  the  services  provided. 
Contracting  authorities  set  the  requirements  through 
(under 
technical  specifications  or  award  criteria 
Article 70, paragraph 2, item 2 or 3). 

The products, the mandatory minimum requirements for 
environmental  protection  and  the  manner  of  proving 
compliance with these requirements are determined by 
an ordinance issued by the Minister of Environment and 
Water  together  with  the  Minister  of  Finance  and  the 
Minister of Economy and Industry. 

(3)

(4)

https://www.strategy.bg/StrategicDocuments/View.aspx?l

ang=bg-BG&Id=1559. 

(5)

onsists%20of,for%20monitoring%20the%20implementation%2
0of%20the%20strategic%20document. 

https://www.moew.government.bg/bg/otpaduci/strategic

https://www.minfin.bg/en/1394#:~:text=The%20National
%20Development%20Programme%20BULGARIA%202030%20c

heski-dokumenti/. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
for 

requirements 

In  compliance  with  the  legal  requirements,  a  draft 
ordinance  on  the  environmental  requirements  for 
certain products subject to public procurement has been 
created. It determines the product scope, the minimum 
the 
mandatory  environmental 
products procured by public procurers and the means of 
verifying  these  requirements.  Minimum  mandatory 
environmental  requirements  are  defined 
the 
following  product  groups:  copying  and  graphic  paper, 
indoor  cleaning  services,  computers  and  monitors,  and 
food-catering  services  and  vending  machines.  These 
requirements  are  based  on  the  core  green  public 
procurement criteria of the European Commission. Some 
of  them  are  directly  related  to  the  circular  economy, 
including: 

for 

• 

• 

• 

• 

purchasing recycled office paper made entirely from 
recovered paper fibres; 
using  eco-labelled  cleaning  products –  for  cleaning 
services; 
preventing 
food  and  beverage  waste  and 
preventing,  sorting  and  disposing  of  other  waste – 
for catering services; 
using reusable cups – for vending machines for food 
and drinks. 

The EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number of eco-management and audit scheme (EMAS)-
licensed  organisations  in  each  country  provide  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. The EU 
Ecolabel  is  awarded  to  products  with  best-in-class 
environmental  performance.  EMAS 
is  a  voluntary 
environment  management  scheme  aimed  at  reducing 
the environmental impacts of organisations. 

As of September 2024, Bulgaria had 106 products out of 
98 977, and 8 licences out of 2 983 registered in the EU 
Ecolabel scheme. This shows a continued low take-up of 
both  the  products  and  the  licences.  Moreover,  as  of 
October  2024,  20  organisations 
in  Bulgaria  were 
registered in EMAS  (6) 3 more than in 2021. 

The CMUR of Bulgaria increased by 1.9 percentage points 
in  2023.  This  represents  some  progress  towards 
achieving  the  2022  priority  action  to  take  measures  to 
increase the rate. 

In  addition,  Bulgaria  adopted 
strategy 

its  circular  economy 
in  2022,  showing  some  progress  towards 

Bulgaria  5 

achieving  the  2022  priority  action.  Implementation  is 
now needed. 

2025 priority actions 

•  Adopt measures to increase the circular material use 

rate. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 
fully 
implementing  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  obligation  to 
ensure  separate  collection  of  waste, 
landfill 
diversion targets, etc.; 

(i) 

(ii)  reducing  waste  generation  per  capita  and 

in 

absolute terms; 

(iii)  increasing  the  recycling  rates  of  waste  containing 
CRMs,  with  a  view  to  reducing  dependencies  and 
building  resilient  value  chains,  and  stimulating 
demand for recycled content in all products; 

(iv)  limiting energy recovery to non-recyclable materials; 

and 

(v)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

(which 

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
landfilling  and 
includes 
option,  disposal 
incineration without energy recovery). 
All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

As Figure 3 shows, the total amount of waste generated 
in  Bulgaria  has  decreased  over  the  last  12 years.  This 
trend is primarily driven by the largest waste categories – 
namely,  mineral  waste  from  mining  and  quarrying. 
Excluding these categories results in an increasing trend 
of  generated  waste,  mainly  due  to  an  increase  in 
recyclable and mixed ordinary waste. Except for a drop 

(6) 

 European  Commission,  ‘Eco-management  and  audit  scheme 
(EMAS)’,  European  Commission  website,  November  2021, 

http://ec.europa.eu/environment/emas/emas_registrations/st
atistics_graphs_en.htm 

2025 Environmental Implementation Review – Bulgaria 

 
 
in 2020, most likely to be due to the COVID-19 outbreak, 
Bulgaria’s  GDP  tended  to  increase.  While  total  waste 
generation has decoupled from economic growth, total 
waste excluding major mineral waste has increased more 
than the economy has grown. 

Figure 3:  Generation  of  waste  (total  and  excluding 
major mineral waste), population and GDP, 2010–2022 

accessed 

income)’, 

15 October 

nama_10_gdp, 

Sources:  Eurostat,  ‘GDP  and  main  components  (output,  expenditure 
2024, 
and 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cu
stom_9301905/default/table; Eurostat, ‘Generation of waste by waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/defaul
t/table?lang=en; Eurostat, ‘Population change – Demographic balance 
and  crude  rates  at  national  level’,  demo_grind,  accessed  15 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default
/table?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

The  CRM  Act  aims  to  ensure  the  EU’s  access  to  CRMs, 
needed in increasing amounts for the green and digital 
transitions and for its defence and space ambitions. An 
important  lever  to  increase  both  the  security  and  the 
sustainability  of  the  CRM  supply  is  to  increase  the 
contribution  of  secondary  raw  materials  and  to 
moderate  overall  demand  for  CRMs.  Circularity 
is 
therefore a  key priority in this context.  Bulgaria  has an 
important  mining  and  metallurgy  industry  and  the 
extraction  and  recycling  of  CRMs  is  dealt  with  in  the 
national  waste  management  plan 
for  2021–2028 
(NWMP),  the  circular  economy  transition  strategy  for 
2022–2027 and the related strategy action plan (Decision 
No 832 of the Council of Ministers of 26 October 2022). 
One  of  the  objectives  of  the  strategy  is  for  Bulgaria  to 
contribute  to  the  supply  of  CRMs,  which  should  be 
supported by a national CRM strategy and CRM act. 

Bulgaria  6 

Council  of  Ministers’  Decision  No 508  of  18 July  2024 
adopted the national scientific programme ‘Critical and 
for  green  transition  and 
strategic  raw  materials 
sustainable  development’,  supporting  research 
to 
explore,  extract  in  an  environmentally  sound  manner 
and  process  CRMs  and  strategic  raw  materials  from 
various  sources, 
from 
processing  primary  raw  materials  and  from  secondary 
resources (from recycling). 

including  waste  originating 

Construction and demolition waste 

Construction and demolition waste accounts for almost 
40 % of all waste generated in the EU. A recent study (7) 
by  the  Joint  Research  Centre  shows  that  recycling  and 
preparation for reuse are preferred over incineration and 
landfilling from an environmental perspective for most of 
the  different  streams  of  construction  and  demolition 
waste. However, the economics are often unfavourable 
for  recycling  and  preparation  for  reuse  compared  with 
incineration and landfilling. If available technology were 
to  be  applied,  it  is  estimated  that  an  increase  in  the 
recycling and preparation for reuse of construction and 
demolition  waste  would  lead  to  an  additional  33 Mt  of 
greenhouse gas (GHG) emission savings annually (more 
than, for example, the combined annual GHG emissions 
from Estonia, Latvia and Luxembourg). 

The rate of recycling and preparation for reuse of mineral 
construction  and  demolition  waste  in  Bulgaria  in  2022 
was  87.8 %,  compared  with  the  EU  average  of  79.8 %. 
The  absolute  figures  (in  t  per  year)  of  treated  and 
recycled mineral construction and demolition waste vary 
significantly  over  the  years  (e.g.  the  recycled  amount 
varies from around 126 000 t in 2018 to over 900 000 t in 
2020,  while  dropping  to  around  286 000 t  in  2022). 
Measures  to  further  increase  the  rate  of  recycling  and 
preparation  for  reuse  of  construction  and  demolition 
waste  include  separating  collection  at  the  source –  for 
instance,  through  digitalised  pre-demolition  audits (8) 
(‘resource 
producer 
responsibility  and  other  economic  instruments;  and 
upstream  measures  such  as  increasing  the  recycled 
content 
in  construction  products  and  the  circular 
design (9) of construction works. 

assessments’); 

extended 

(7) 

(8) 

European Commission: Joint Research Centre, Cristobal Garcia, 
J.,  Caro,  D.  et  al.,  Techno-economic  and  environmental 
assessment of construction and demolition waste management 
in  the  European  Union,  Publications  Office  of  the  European 
Union, 
2024, 
Luxembourg, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC135
470. 
European Commission: Directorate-General for Internal Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 

(9) 

Luxembourg, 

pre-demolition  and  pre-renovation  audits  of  construction 
works –  Updated  edition  2024,  Publications  Office  of  the 
European 
2024, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-
01aa75ed71a1/language-en. 
European  Commission,  Circular  Economy –  Principles 
buildings 
https://ec.europa.eu/docsroom/documents/39984. 

for 
2020, 

Brussels, 

design, 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Boosting implementation – the 2023 Waste Early 
Warning Report 

packaging waste’, briefing No 28/2022, Copenhagen, 2023. Reference 
data © ESRI. 

Bulgaria  7 

targets 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching  certain  waste  management 
for 
municipal  and  packaging  waste.  Member  States  that 
want to use this possibility have to notify the Commission 
24 months  in  advance  of  the  deadline  and  submit  an 
implementation  plan 
laying  down  the  steps  they 
envisage  to  reach  the  postponed  targets  within  a  new 
timeframe.  Regarding  the  2025  targets,  11  Member 
States, not including Bulgaria, have used this prerogative. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission is, on one hand, working together with the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of  the  Waste  Framework  Directive,  the  Packaging  and 
Packaging  Waste  Directive  and  the  Directive  on  Waste 
Electrical and Electronic Equipment (12). 

Municipal waste 

Municipal  waste  generation 
in  Bulgaria  decreased 
between 2010 and 2022 (Figure 5). In 2022, the country 
generated 488 kg of municipal waste per capita, which is 
slightly below the estimated EU-27 average of 513 kg per 
capita. Bulgaria still relies strongly on landfilling despite 
the  landfilling  rate  having  decreased  significantly  over 
the  past  10 years,  reaching  54 %  in  2022.  Municipal 
waste incineration plays a minor role in Bulgaria, as only 
3 % of the generated municipal waste was incinerated in 
2022. 

This section focuses on the management of municipal and 
packaging  waste (10),  for  which  EU  law  sets  mandatory 
In  June  2023,  the  Commission 
recycling  targets. 
the  Waste  Early  Warning  Report (11) 
published 
identifying the general trends in waste management and 
the Member States at risk of missing 2025 waste targets 
(see  Figure 4).  Bulgaria  is  at  risk  of  missing  both  the 
municipal waste target and the packaging waste target. 
Bulgaria is also at risk of not meeting the 2035 target of 
having a maximum of 10 % of municipal waste landfilled. 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing for reuse and recycling targets for municipal 
waste and packaging waste 

Member  States  not  at  risk  of  missing  the  55 % 
preparing  for  reuse  and  recycling  target  for 
municipal waste and the 65 % recycling target for 
packaging waste 

Member  States  at  risk  of  missing  the  preparing 
for reuse and recycling target for municipal waste 
but not at risk of missing the recycling target for 
packaging waste 

Member States at risk of missing both targets 

Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not  on  track  to  meet  recycling  targets  for  municipal  waste  and 

(10)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected  waste 
including  paper  and 
from  households, 
cardboard,  glass,  metals,  plastics,  biowaste,  wood,  textiles, 
packaging,  waste  electrical  and  electronic  equipment,  waste 
batteries  and  accumulators,  and  bulky  waste, 
including 
mattresses  and  furniture;  and  (ii)  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, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32012L0019. 

(11) 

(12) 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
 
 
Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–202213 

Bulgaria  8 

NB:  The  total  of  municipal  waste  reported  as  landfilled,  incinerated, 
materially  recycled  and  composted/digested  is  much  lower  than  the 
reported ‘total treatment’ values for 2021 and 2022. As of reference 
year 2020, new reporting rules apply to calculating recycled municipal 
waste  pursuant  to  the  targets  laid  down  in  Article 11(2)(c–e)  of 
Directive 2008/98/EC. However, it is unclear based on the information 
available whether these new reporting rules have been implemented 
in Bulgaria yet. 

Source: Eurostat, ‘Municipal waste by waste management operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/def
ault/table. 

22 October 

accessed 

Packaging waste 

Bulgaria’s  packaging  waste  generation  has  increased 
since  2010  (Figure 7).  In  2022,  the  country  generated 
79 kg  per  capita,  which 
is  significantly  below  the 
estimated EU average of 186 kg per  capita in the same 
year and the lowest among all Member States. 

It  is  essential  to  view  these  data  with  caution,  as  they 
might be underestimated (14). Steps have been taken to 
improve  data  quality,  addressing  issues  such  as  the 
under-reporting  of  packaging  put  on  the  market  and 
freeriding (15). 

Bulgaria  has shown  low  and stagnating  waste  recycling 
rates over recent years (Figure 6). In 2022, the municipal 
waste recycling rate stood at 25 %, which is significantly 
below the estimated EU-27 average of 49 %. 
Bulgaria has reported data to show compliance with the 
preparing for reuse and recycling target of 55 % by 2025, 
as  laid  down  in  the  Waste  Framework  Directive.  The 
difference  between  these  (provisional)  data,  following 
the  reporting  obligation  of  the  Waste  Framework 
Directive,  and  the  data  shown  in  Figure 4  (voluntary 
reporting)  is  below  1 percentage  point  for  the  rate  in 
both 2021 and 2022. 

(14) 

Commission staff working document – The early warning report 
for  Bulgaria,  SWD(2023) 176  final  of  8 June  2023,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A176%3AFIN;  Eunomia, 
Study to identify Member States at risk of non-compliance with 
the 2020 target of the Waste Framework Directive and to follow-
up Phase 1 and 2 of the compliance promotion exercise – Early 
warning report: Bulgaria, Bristol, 2018; European Environment 

Agency  (EEA),  Early  warning  assessment  related  to  the  2025 
for  municipal  and  packaging  waste –  Bulgaria, 
targets 
Copenhagen, 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/bulgaria/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal and packaging waste – Bulgaria, Copenhagen, 2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/bulgaria/view. 

(15) 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
Figure 7: Packaging waste generation, 2010–2022 (16) 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

Figure 8:  Packaging  waste  recycling  rates  (%),  2010–
2022 

Bulgaria  9 

https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

Note: no data available for 2020; the recycling rates for both steel and 
aluminium packaging in 2021 and 2022 are 0 %. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of EU waste legislation. They set out key provisions and 
investments to ensure compliance with existing and new 
legal  requirements  (e.g.  on  waste  prevention,  on 
separate  collection  for  certain  waste  streams,  on 
recycling and on landfill targets). 

clearly 

indicated 

Bulgaria’s  national  waste  prevention  programme 
is 
into  the  NWMP (17).  Waste  prevention 
integrated 
separate 
measures  are 
subprogramme  with  the  strategic  goal  of  reducing  the 
harmful impact of waste by preventing its generation and 
promoting  its  reuse.  The  priority  waste  streams  for 
prevention, also covered by the NWMP, are food waste, 
household  waste,  industrial  waste,  construction  waste 
and hazardous waste. 

in  a 

Policies to encourage separate collection and recycling 

improving 

Since  the  publication  of  the  early  warning  report (18), 
Bulgaria  has  not  made  progress  on 
its 
preparing  for  reuse  and  recycling  rate  of  municipal 
waste. However, the landfill rate of municipal waste has 
significantly decreased although data  for 2021 seem to 
show inconsistencies. Bulgaria’s rates of composting and 
anaerobic  digestion  remain  significantly  low  and  were 
previously 
for  weak 
performance (19). There are discrepancies in the data on 
packaging waste and the actual progress is not clear. 

identified  as  a  key 

factor 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 

Policies to discourage landfilling or incineration 

A landfill tax was introduced in Bulgaria in 2011. The tax 
was  planned  to  be  increased  to  BGN 95/t  in  2022 

(16) 

(17) 

(18) 

EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal and packaging waste – Bulgaria, Copenhagen, 2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/bulgaria/view. 
EEA, Waste Prevention Country Profile – Bulgaria, Copenhagen, 
2023, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
of 
sheets/bulgaria_waste_prevention_2023; 
Environment  and  Water,  Draft  National  Waste  Management 
Plan 
2021, 
https://www.moew.government.bg/bg/proekt-na-nacionalen-
plan-za-upravlenie-na-otpaducite-2021-2028/. 
Commission staff working document – The early warning report 
for  Bulgaria,  SWD(2023) 176  final  of  8 June  2023,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A176%3AFIN. 

2021–2028, 

Ministry 

Sofia, 

(19) 

document – 

staff  working 

Commission staff working document – The early warning report 
for  Bulgaria,  SWD(2023) 176  final  of  8 June  2023,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A176%3AFIN; 
Commission 
Environmental 
Implementation  Review  2022:  Country  Report –  Bulgaria, 
SWD(2022) 255 
final  of  8 September  2022,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0262&qid=170195259
5514.  Commission  staff  working  document –  Environmental 
Implementation  Review  2022:  Country  Report –  Bulgaria, 
SWD(2022) 255 
final  of  8 September  2022,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0262&qid=170195259
5514. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
(EUR 50/t) (20).  The  landfill  tax  is  close  to  the  average 
landfill  tax  of  Member  States  using  such  taxes.  Landfill 
tax  revenues  are  designated  for  municipal  use  to 
enhance  separate  waste  collection,  develop  waste 
treatment infrastructure and enhance waste prevention. 
If  a  municipality  achieves  specified  goals  under  the 
Waste  Management  Act,  the  landfill  tax  is  reduced  by 
50 %.  This  deduction  serves  as  an  economic  incentive, 
landfilling, 
encouraging  municipalities  to  decrease 
increase  recycling  and  recovery,  and  accumulate  funds 
for  waste  treatment 
infrastructure  construction.  In 
Bulgaria, there is no tax on municipal waste incineration 
and no plans to introduce such a tax (21). 

As noted in the previous Environmental Implementation 
Review (EIR) country report, 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 this has been postponed a number of 
times,  with  the  last  target  date  being  1 January  2022. 
However, in February  2021, an amendment  to the Law 
on Local Taxes and Fees through an amendment to the 
2020  Pandemic  Law (22) 
the 
implementation  of  the  polluter-pays  principle  until 
1 January of the second year following the publication of 
the  2021  census  results  (i.e.  until  January  2025).  In 
September  2024,  Bulgaria  postponed  applying  the 
polluter-pays principle once again, this time until January 
2026.  That  is  17 years  after  the  Waste  Framework 
Directive (23)  entered  into  force  and  19 years  after  the 
accession of Bulgaria to the EU, when the polluter-pays 

further  postponed 

Bulgaria  10 

principle became binding. An infringement procedure to 
address the issue is ongoing (24). 

In the 2022 EIR, Bulgaria had several priority actions in 
the field of waste management. Bulgaria has made some 
progress on improving the separate collection of waste, 
including  biowaste,  and  some  progress  on  using 
economic  instruments,  and  has  a  waste  management 
plan in place in line with the requirements of the revised 
Waste  Framework  Directive.  Bulgaria  has  made  no 
progress on the ratification of the Hong Kong Convention 
on Ship Recycling. 

2025 priority actions 

•  Ratify international conventions on ship recycling. 
• 

Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps of the waste hierarchy. In particular, improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps of the waste hierarchy. In particular, improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Improve municipal waste preparation for reuse and 
recycling. 
Invest in waste prevention measures to reduce the 
total amount of waste generated. 
Ensure the achievement of the 2025 waste targets, 
following  the  recommendations  made  by  the 
Commission  in  the  Early  Warning  Reports  where 
applicable. 

• 

• 

• 

• 

(20) 

(21) 

Copenhagen, 

EEA,  Technical  note  accompanying  the  EEA  briefing  ‘Economic 
instruments  to 
instruments  and  separate  collection –  Key 
increase 
2023, 
recycling’, 
https://www.eea.europa.eu/publications/economic-
instruments-and-separate-collection/technical-note-
accompanying-the-eea/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal and packaging waste – Bulgaria, Copenhagen, 2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/bulgaria/view. 

(22) 

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,  ￼HYPERLINK 
"https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=
155972"https://dv.parliament.bg/DVWeb/showMaterialDV.jsp
?idMat=155972 

(23)  Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19 November  2008  on  waste  and  repealing  certain 
directives (OJ L 312, 22.11.2008, p. 3). 
INFR(2023)2064. 

(24) 

2025 Environmental Implementation Review – Bulgaria 

 
 
2. Biodiversity and natural capital 

Global and EU biodiversity frameworks

Bulgaria  11 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. The EU biodiversity strategy for 2030 (BDS) aims to 
put EU biodiversity on a path to recovery by 2030. It sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (25)  and  a  dashboard  of  indicators (26) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (27) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20 % of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
implementation 
national 
restoration plans. The BDS is the main instrument used 
by the EU to deliver on its obligation under the GBF.   

implementation 

framework 

enable 

based 

on 

to 

financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

An  updated  national  biodiversity  strategy  for  Bulgaria 
was presented for public consultations (28) in 2022. It sets 
national objectives and targets to be met by Bulgaria in 
the  next  decade  to  contribute  to  the  EU  and  global 
biodiversity  commitments  and 
formulates  specific 
measures and actions. 

in  Bulgaria – 

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

representative  national 

structure 

No  revised  draft  has  been  published  since  the 
consultations, and no date has been announced for the 
adoption of the updated strategy. 

The EU aims to allocate at least 7.5 % of annual spending 
under the EU budget to biodiversity objectives in 2024, 
rising  to  10 % 
in  2026  and  2027.  For  details  on 
biodiversity financing and investments  for Bulgaria, see 
‘Biodiversity and ecosystems’ in Chapter 5. 

2025 priority actions 

• 

Submit  to  the  CBD  an  updated  NBSAP  or  national 
targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

The  Commission  has  submitted  to  the  Convention  on 
Biological Diversity its report on GBF-aligned EU targets 
that  stem  from  the  BDS  and  from  other  policy 
instruments under the European Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
line  with  the  global 
2030  biodiversity  targets. 
obligations,  NBSAPs  should  also  include  a  biodiversity 

In 

Nature protection and restoration – Natura 
2000 

Natura  2000 (29),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 

(25) 

(26) 

(27) 

Actions 

Tracker 

Strategy 

Strategy 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
law 
on 
Commission 

see  also 
the 

Dashboard 

page 

web 

(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 
https://dialog.bmuv.de/bmu/de/process/58604. 

(28) 
(29)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 

2025 Environmental Implementation Review – Bulgaria 

 
 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (30); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
Natura  2000  sites 
is  a  cornerstone  of  the  EU’s 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000  shall  enable the natural habitat types and 
the  species’  habitats  concerned  to  be  maintained  or, 
where 
favourable 
a 
restored 
conservation status in their natural range. 

appropriate, 

to 

Bulgaria  hosts  92  habitat  types (31)  and  209  species (32) 
covered by the Habitats Directive. The country also hosts 
populations of 184 bird taxa listed in the Birds Directive 
Annex I (33) and 126 migratory bird taxa. 

As shown in Figure 9, in 2023, 34.9 % of the territory of 
Bulgaria was covered by Natura 2000 sites (EU coverage: 
18.6 %),  with  special  protection  areas  (SPAs)  classified 
under the Birds Directive covering 23.1 % (EU coverage: 
12.8 %)  of  Bulgaria,  while  SACs  under  the  Habitats 
Directive  covered  30.3 %  of  the  country  (EU  coverage: 
14.3 %). 

Considering  both  areas  covered  by  Natura  2000  and 
other  nationally  designated  protected  areas,  Bulgaria 
legally  protects  41 %  of  its  terrestrial  areas  (EU-27 
coverage:  26.1 %)  and  8 %  of  marine  areas  (EU-27 
coverage: 12.3 %) (34). 

(30) 

(31) 

(32) 

SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
19 December 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-

19 December 

dashboard, 

Bulgaria  12 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating special areas of conservation and setting 
site-specific conservation objectives and measures 

To  ensure  that  SCIs  contribute  to  the  objectives  of  the 
Habitats Directive, Member States must designate them 
as  SACs,  setting  site-specific  conservation  objectives 
based on the ecological needs of the species and habitats 
present  on  the  sites.  Such  site-specific  conservation 
objectives  should  define  attributes  and  targets  that 
describe the habitats’ or species’ condition as favourable 
or  unfavourable,  addressing key  pressures  and threats. 
Under  Article 6  of  the  Habitats  Directive  requires 
Member States must establish and implement measures 
to achieve these objectives. 

The  six-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. Bulgaria’s failure to designate SACs 
and to establish site-specific conservation objectives and 
measures  was  subject  to  an  infringement  procedure, 
which  reached  the  Court  of  Justice  of  the  European 

nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  birds  taxa  for  which 
information was requested. 
Eurostat dataset env_bio4, 12 March 2025 

(33) 

(34) 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
judgment  of  the  Court  of  Justice (35) 
Union.  The 
confirmed  Bulgaria’s  failure  to  designate  all  the  SACs, 
dismissing the claims concerning a systemic breach of the 
establishment of conservation objectives and measures 
on formal grounds (without judging the substance of the 
claims). 

Bulgaria  completed  the  designation  of  SACs  in  2024. 
However,  Bulgaria  has  not  yet  established  site-specific 
conservation objectives for a large number of its Natura 
2000 sites. Most importantly, despite providing for some 
measures dispersed in various documents, Bulgaria has 
not yet established the necessary conservation measures 
required by the Habitats Directive in all SACs. Work on 
setting conservation objectives started only at the end of 
2021  and  work  on  the  conservation  measures  is  yet  to 
begin.  These  delays  continue  to  negatively  affect  the 
effective  management  of  nature  in  Natura  2000  sites, 
and the country needs to step up efforts in this regard. 
Appropriate  capacities  in  terms  of  both  financing  and 
expertise to ensure efficient management of the sites are 
also lacking. 

information  on  authorisations  that 

Bulgaria’s  failure  to  properly  assess  the  impacts  of 
projects and plans on the Natura 2000 sites has led to an 
infringement action by the Commission (36). The country 
has  made  good  progress  in  this  field  by  introducing 
changes in national legislation and updating the database 
with 
facilitate 
cumulative  impact  assessment.  Training  and  guidance 
provided  to  regional  authorities  have  also  positively 
affected the authorisation process of plans and projects 
with  possible  effects  on  Natura  2000  sites.  Central 
authorities’ continuous efforts to control the quality of 
the  impact  assessments  undertaken  by  the  16  regional 
entities should nevertheless be reinforced. 

2025 priority actions 

• 

• 

of 

the 

establishment 

Finalise 
site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
implementation  of 
the  Nature  Restoration 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Bulgaria  13 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (37). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

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  deeming  habitats  as  in  good 
conservation status in 2018 was 12.23 %. For protected 
species,  the  share  of  assessments  marked  as  good 
conservation status in 2018 was 38.06 %. As far as birds 
are  concerned,  54 %  of  the  breeding  species  showed 
short-term  increases  or  stable  population  trends  (for 
wintering species, the figure was nearly 30 %). 

in  bad 
At  the  same  time,  the  share  of  habitats 
conservation  status 
is  5.32 %  and  the  share  of 
assessments  for  species  marked  as  bad  conservation 
status is 3.15 %. The main pressures on both habitats and 
species  are  agricultural,  but  also 
from 
unsustainable  forestry,  the  extractive  industries  and 
infrastructural 
residential  and 
from 
developments and changes in land use. 

commercial, 

come 

(35) 

(36) 
(37) 

Judgment  of  20 June  2024,  Commission  v  Bulgaria,  C-85/22, 
EU:C:2024:535. 
INFR(2008)4461. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 

European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Bulgaria 

 
 
Figure 10:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods38 

Bulgaria  14 

the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

In  2022  the  Commission  started  an  infringement  case 
concerning Bulgaria's failure to implement the measures 
required  by  the  Habitats  Directive  to  avoid  bycatch  of 
protected species by fishing vessels.39 

2025 priority action 

•  Reinforce  action 

for  habitats  and  species 

in 
unfavourable  conservation  status,  for  example 
through 
increased 
restoration  measures, 
connectivity,  better  policy  coordination  and 
integration, and increased funding. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will  result in a  20 % reduction in the use of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The “Vision for agriculture and food” (40), adopted by the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective. 

The  CAP  and  national  CAP  SPs  that  establish  the 
framework for the transition to a sustainable agriculture 
are  key  instruments  to  facilitate  and  strengthen  the 
efforts of European farmers to protect biodiversity and 
the  environment  at  large.  The  Commission  approved 
Member  States’  CAP  SPs  in  2022.  CAP  is  the  largest 
implementation  of  EU 
source  of  funding  for  the 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-

December 

accessed 

2019, 

(39)  

INFR(2022)2052. 

(40) 

https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en   

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
environment  policy  and  SPs  should  lead  to  better 
protection of soil, water, air quality and biodiversity. 

While certain CAP result indicators focus on the national 
measures  favouring  sustainable  agriculture  practices 
that  regenerate  the  ecosystems,  the  impact  of  these 
measures  is  difficult  to  be  assessed.  The  uptake  of  the 
eco-schemes is voluntary for farmers.  

The utilised agricultural area in Bulgaria decreased from 
5 122 980 ha in 2012 to 5 022 060 ha in 2022 (41). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  only –  semi-natural 
vegetation  present  in  or  adjacent  to  agricultural  land. 
They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
feature 
landscape 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  Bulgaria  is  6.2 %, 
slightly above the EU average. At the EU level, landscape 
features cover 5.6 % of agricultural land. 

In  2024,  the  CAP  basic  regulations  were  amended (42) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  areas  or  landscape  features  in  their 
farm.  The  amended  regulations  set  out,  however,  an 
obligation  for  Member  States  to  establish  and  provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 
fallow,  and  for  the  establishment  of  new  landscape 
features, on arable land. 

The recently adopted Nature Restoration Regulation (43) 
focuses on the restoration of agricultural ecosystems and 
requires Member States to put in place measures which 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (44). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

(41) 
(42) 

(43) 

Eurostat dataset, 5 December 2024. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 

Bulgaria  15 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
2.20 % of Bulgaria’s land area is used for organic farming. 
This is the third worst result in the EU and far below the 
EU  average  of  10.50 % (45).  Bulgaria 
is  currently 
contributing very insufficiently to achieving the target of 
25 % of the EU’s agricultural land being used for organic 
farming by 2030. 

Figure 12:  Share  of  total  utilised  agricultural  area 
occupied  by  organic  farming  per  Member  State  (%), 
202246 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

2025 priority action 

• 

• 

and 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
to 
environmental needs of Bulgaria. 
Implement  and  scale-up  the  uptake  of  organic 
farming practices. 

practices 

address 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 

(44) 

(45) 

in  cropland  mineral  soils’  and 

The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
is  currently  under  review;  European  Commission, 
which 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
mitigation. 

Grasslands 

Bulgaria  16 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

the 

aims 

introduce 

The  proposed  directive  on  soil  monitoring  and 
resilience (￼47 
first 
to 
comprehensive legislation on the protection of all soils in 
the EU. Should the directive be adopted, Member States 
will  have  to  transpose  it  into  national  legislation  and 
in  place  the 
implement 
governance systems and a sound monitoring framework 
building on existing national soil monitoring frameworks. 
The  objective  of  the  proposed  directive  is  to  provide 
better  and  more  comparable  soil  health  data  with  the 
view of attaining healthy soils by 2050. 

it,  starting  with  putting 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Bulgaria (48). 

soil  organic 

loss  of 

carbon, 

31 % of Bulgaria’s land cover is experiencing loss of soil 
organic carbon in mineral soils (49), representing 84 % of 
cropland and grassland area. Unsustainable soil erosion 
by  water,  wind,  tillage  and  harvest  affects  26 %  of  the 
national territory, particularly along the northern border 
of the country. 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

Bulgaria hosts 18 grassland types listed in Annex I of the 
Habitats  Directive.  These  include  some  of  the  most 
biodiversity-rich grasslands in Europe, some of which are 
present  only  in  Bulgaria.  In  the  past,  these  grasslands 
have  been  linked  to  traditional  land  stewardship  and 
management,  but  changes  over  the  past  few  decades 
have endangered them, due to ploughing up, overgrazing 
and abandonment, which leads to under-grazing. Only a 
small percentage of the protected grassland habitats in 
Bulgaria  are 
in  favourable  conservation  status.  To 
prevent  their  continuing  loss,  it  is  imperative  that  the 
grasslands are appropriately managed. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I of the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

The  majority  of  Bulgarian  grassland  habitats  protected 
the  Habitats  Directive  have  unfavourable 
under 
for 
status,  major  pressures/threats 
conservation 
wetlands/peatlands in four types of bogs, fens and mires 
habitats, listed in Annex I of the Habitats Directive, are 

(47) 

(48) 

final 

Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 

2023, 

5 July 

of 

5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

2023, 

ASSESSMENT 

(49)  De  Rosa,  D.,  Ballabio,  C.,  Lugato,  E.  et  al.,  ‘Soil  organic  carbon 
stocks in European croplands and grasslands: How much have we 
lost in the past decade?’, Global Change Biology, Vol. 30, No 1, 
2023, e16992, https://doi.org/10.1111/gcb.16992. 

2025 Environmental Implementation Review – Bulgaria 

 
 
protected in Bulgaria and none of these is in favourable 
conservation  status.  The  modification  of  hydrological 
conditions,  mixed-source  pollution,  drainage  and  land 
reclamation are the main threats to these habitats. 

Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

Bulgaria  17 

Forest ecosystems 

Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
forests  that  contribute 
diverse  and  resilient  EU 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I of the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
Directives, 
is  a 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several  guidelines  on  forestry  management  were 
published  in  2023.  They  covered  biodiversity-friendly 
afforestation, reforestation and tree planting; closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring  and  strictly  protecting  primary  and  old-
growth  forests.  Further  guidance  on  payment  schemes 
for ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (50) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (51).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

(50)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
forests, 
2023, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

COM(2023)728, 

November 

22 

Source: Commission staff working document – New EU forest strategy 
for  2030,  SWD(2021) 652 
final  of  16 July  2021,  p. 24,  eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

. 

Among forest disturbances contributing to loss of forest 
integrity  and 
loss,  wildfires 
related  biodiversity 
constitute a particular  reason for concern. In 2022, the 
EU  saw  a  record  number  (2 700)  of  wildfires  affecting 
more  than  30 ha,  which  led  to  the  destruction  of 
785 605 ha  of  forest,  the  second  highest  annual  figure 
recorded.  Recent  years  have  also  witnessed  the 
occurrence of widespread uncontrollable fires (so-called 
megafires), which are associated with loss of life and an 
enormous cost in terms of damage to the environment, 
businesses and society (over EUR 2 billion annually) and 
carbon dioxide (CO2) emissions. Megafires are practically 
beyond suppression capacity and can be prevented only 
by  an  integrated  risk  management  approach.  Wildfires 
prevention is also essential to preserve resources for the 
bioeconomy. 
According  to  the  Executive  Forest  Agency  database  in 
2023, the number of forest fires in Bulgaria was 448 and 
the burnt area is estimated to be 6 388 ha, with 689.6 ha 
of  them  burned  by  crown  fires.  The  average  size  per 
forest  fire  in  2023  increased  to  14.25  ha  and  the  main 
cause  (for  59%  of  fires)  was  carelessness.  The  direct 
losses  by  forest  fires  in  2023  are  estimated  at  170  000 
Euro,  although  the  average  losses  for  the  last  10  years 
total about 1 000 000 Euro (52).  

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

(52)

https://publications.jrc.ec.europa.eu/repository/handle/JR

C139704   

(51) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
The  EU  Timber  Regulation  (EUTR) (53)  prohibits  the 
placing on the EU market of illegally harvested timber.  

into 

(EUDR) (54)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(55).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  Regulation  on 
deforestation-free  products  repeals  the  EU  Timber 
Regulation. 

force 

In  Bulgaria,  forests  cover  35.9 %  of  the  country’s 
territory (56) and more than 75 % of the assessments of 
the  conservation  status  of  forest  habitats  protected 
under the Birds and Habitats Directives reveal a bad or 
poor  status (57).  In  total,  704 000 ha  in  Bulgaria  are 
covered  by  primary  forests (58),  99 %  of  them  are  in 
Natura 2000 sites. 

On 29 June 2023, the Regulation on  Deforestation-free 
Products  (EUDR) (59)  entered  into  force.  The  regulation 
seeks to guarantee that products in the EU that are made 
using  any  of seven  listed  commodities  have  no  links  to 
deforestation.  The  EUDR  repeals  the  EUTR.  The 
Commission has proposed giving  the  parties  concerned 
additional time to prepare. If approved this would make 
the  law  applicable  on  30 December  2025  for  large  and 
medium-sized  companies  and  30 June  2026  for  micro- 
and small enterprises. 

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 

(53) 

(54) 

Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
forest 
and  products  associated  with  deforestation  and 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(57) 

(56) 

(55)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
EEA  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 

Accompanying 

base: 

the 

Bulgaria  18 

status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine waters and cooperate with other Member States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
in  the  MSFD  have  become  available. 
Nevertheless, Member States have to report updates by 
15 October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  decision (60),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (61). 

Bulgaria  is  the  only  Member  State  that  has  not  yet 
reported its programme of measures, which is required 
under Article 13 of the MSFD and must be updated every 
six  years.  The  Commission  has  therefore  launched  an 
infringement  procedure  against  Bulgaria  for  the  non-
reporting of its updated programme of measures (62). 

Bulgaria adopted its updated programme of measures on 
31 December 2024. Because it did not report it in time, 
however,  the  programme  could  not  be  included  in  the 
Commission’s 
States’ 
programmes of measures. 

of  Member 

assessment 

(58) 

(59) 

(60) 

(61) 

(62) 

European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 
Commission  Decision  (EU) 2017/848  of  17 May  2017  laying 
down  criteria  and  methodological  standards  on  good 
environmental  status  of  marine  waters  and  specifications  and 
standardised  methods  for  monitoring  and  assessment,  and 
repealing  Decision 2010/477/EU  (OJ  L 125,  18.5.2017,  p. 43), 
http://data.europa.eu/eli/dec/2017/848/oj. 
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
Strategy  Framework  Directive  2008/56/EC  and  Commission 
Decision  (EU)  2017/848  (OJ  C,  C/2024/2078,  11.3.2024), 
http://data.europa.eu/eli/C/2024/2078/oj. 
INFR(2022)2172. 

2025 Environmental Implementation Review – Bulgaria 

 
 
2025 priority actions 

•  Report  Bulgaria’s  programme  of  measures,  as 

required under Article 13 of the MSFD. 

its 

•  Report  updates  on  the  assessment  of  the  state  of 
Bulgaria’s  marine  waters, 
its 
determinations  of  GES (63),  which  are  expected  to 
include  any  threshold  values  for  the  descriptors  in 
the  MSFD  that  may  have  been  established  in 
cooperation with other Member States at the EU or 
regional level. 

target  and 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (64). 

The  (￼) entered into force on 2 August 2022. The fourth 
update is in preparation. 

The IAS Regulation (65) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already  widespread  on  their  territory.  This  aligns  with 
target 6 of the GBF to reduce the introduction of IAS by 
at least 50 % by 2030 and minimise their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 

(63) 
(64) 

(65) 

In accordance with Article 17 of Directive 2008/56/EC. 
Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
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 (OJ L 317, 4.11.2014, p. 35). 

Bulgaria  19 

and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (66).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (67),  and  at 
USD 423 billion annually at the global level (68). 
The total number of IAS of Union concern is currently 66, 
of which 30 are animal species and 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. 
A  2021  report (69)  on  the  baseline  distribution  shows 
that, of the 66 species on the Union list, 15 had at that 
time been observed in the environment in Bulgaria. The 
spread of IAS is shown in Figure 14. 

Figure 14:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Bulgaria, 2024 

The total number of IAS of Union concern in the country 
is 20. This includes 15 species recorded in the previous 
EIR (2021) and 5 additions. Of these 11 additions, 1 was 
already  on  the  Union  concern  list  in  2021,  and  4  were 
added later under Commission Implementing Regulation 
(EU) 2022/1203. 

(66)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(68) 

and 

Ecosystem 

(Intergovernmental 

Science-Policy 
on 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

(67)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Summary 
Biodiversity 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 
European  Commission:  Joint  Research  Centre,  Cardoso,  A. C., 
Tsiamis,  K.  et  al.,  EU  Regulation  1143/2014:  Assessment  of 
invasive  alien  species  of  Union  concern  distribution –  Member 
States  reports  versus  JRC  baselines,  Publications  Office  of  the 
European Union, Luxembourg, 2021. 

(69) 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Bulgaria failed to establish and implement a single action 
plan or a  set  of action plans fulfilling the requirements 
specified  in  Article 13  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 such surveillance in its 
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 IAS 
Regulation. Therefore, Bulgaria was referred to the Court 
of Justice of the European  Union. The judgment  in this 
case  confirmed  Bulgaria’s  failure  to  fulfil  the  above 
obligations (70).  In  its  ruling  of  14 November  2024,  the 
Court of Justice found that Bulgaria had failed to comply 
with its obligations. Bulgaria should now take measures 
to implement the ruling. 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

Similarly, target 14 of the GBF (71) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (72). 

(70) 

Judgment of 14 November 2024, Commission v Bulgaria (Espèces 
exotiques envahissantes), C-165/23, EU:C:2024:958. 

(71)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
biodiversity 
framework 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
policymakers, 
Ecosystem 

Assessment – 

Summary 

(72) 

for 

Bulgaria  20 

The    (EU)  No 691/2011  on  European  environmental 
economic  accounts (￼73  introduces  new  requirements 
for  Member  States  to  report  on  the  condition  of 
ecosystems 
including  urban  ecosystems,  croplands, 
grasslands,  forest  and  woodlands,  coastal  beaches, 
dunes  and  wetlands.  Data  reported  by  the  Member 
States  will  feed  into  the  second  European  ecosystem 
assessment, due in 2027, and can also be used to support 
policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

In  Bulgaria,  sometimes  problems  arise  because  of  data 
availability, quality issues and a lack of clear guidance on 
working with the available data. The  largest knowledge 
gaps  concern  ecosystem  asset  accounts,  ecosystem 
accounts  and  a  thematic  biodiversity  account.  Other 
important  issues  are  the  lack  of  engagement  of  all 
and 
stakeholders, 
collaboration between state institutions, and insufficient 
knowledge sharing with the general public and business 
community. The last issue relates to the establishment of 
a  uniform  translation  of  the  related  terminology  in  the 
appropriate language. 

communication 

insufficient 

There are no Bulgarian business or biodiversity network 
members of the EU Business & Biodiversity Platform. 

In  the  2022  EIR,  Bulgaria  received  priority  actions  on 
ensuring better collaboration among all stakeholders to 
identify  and  close  data  gaps,  ensuring 
regional 
cooperation  with  Member  States  sharing  the  same 
marine  (sub)region  to  address  predominant  pressures, 
and  implementing  the  Commission’s  recommendations 
regarding  the  preparation  of  the  marine  strategies, 
encompassing assessment, the determination of GES and 
the establishment of environmental targets. 

2025 priority action 

• 

Support  the  development  of  the  national  business 
and biodiversity network.

(73) 

Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 
Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 

11 July 

2022, 

final 

of 

2025 Environmental Implementation Review – Bulgaria 

 
 
Bulgaria  21 

3. Zero pollution 

Clean air

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (74).  These  set  health-based  EU  air  quality 
standards (75)  and  stipulate  Member  States’  national 
emission  reduction  commitments (76)  for  several  air 
pollutants. 

Air quality in Bulgaria continues to give cause for concern 
in some parts of its territory. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (77) for Bulgaria attribute 9 000 deaths each year (or 
86 000 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (78),  1 500  deaths  each  year  (or  14 100 YLL)  to 
nitrogen dioxide  (NO2) (79) and 930 deaths each year  (or 
9 000 YLL) to ozone (80). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Bulgaria since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (81)  in  2024, 
Bulgaria has met its emission reduction commitments for 
2020–2029 for air pollutants  nitrogen oxides (NOx), non-

methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide (SO2) and PM2.5. It has not met them for ammonia 
(NH3).  According  to  the  projections  submitted  under 
Article 10(2) of the NECD in 2023, Bulgaria is projected to 
meet  its  emission  reduction  commitments  for  2030 
onwards for NOx, SO2, NH3 and PM2.5, but not for NMVOC. 

Bulgaria  submitted  its  first  national  air  pollution  control 
programme (NAPCP) to the Commission on 26 September 
2019. An update was due four years afterwards. Bulgaria 
also needs to update its policies and measures to reduce 
air emissions. 

Figure 15:  Emission  trends  of  main  pollutants /  GDP  in 
Bulgaria (%), 2005–2022 

300%

250%

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 2024, https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

(74) 

(75) 

(76) 

(77) 

(78) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(79)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(80) 

(81)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Bulgaria  22 

opened  for  Member  States  not  meeting  the  emission 
reduction  commitments  for  2020–2029,  including  for 
Bulgaria for NH3 (86). 

Bulgaria has not yet ratified  the 1998 Protocol on Heavy 
Metals,  as  amended  on  13 December  2012,  and  the 
Persistent  Organic  Pollutants  Protocol  under  the  United 
Nations  Economic  Commission 
for  Europe’s  Air 
Convention.  The  two  bills  for  the  ratification  of  the 
amendments to the protocols were submitted to the 50th 
National Assembly. Due to the premature end of the 50th 
National Assembly’s activities, the proposed amendments 
to  the  protocols  were  not  adopted.  Another  convention 
Bulgaria participated in was the Hong Kong Convention on 
Ship Recycling. 

In  the  2022  EIR,  Bulgaria  received  three  priority  actions. 
The first priority action was to further reduce emissions in 
the context of the NAPCP. Bulgaria has not made progress 
on this, as the latest reported data show continued non-
compliance  with  the  2020–2029  emission  reduction 
commitment  for  NH3  and  also  project  non-compliance 
with the emission reduction commitments for NMVOC for 
2030 onwards. The second priority action was to ensure 
full compliance with EU air quality standards and maintain 
downward  emission  trends.  Based  on  the  latest  data, 
Bulgaria has made some progress in this regard. However, 
exceedances of limit values and target values remain for 
NO2,  PM10  and  ozone.  Since  2019,  downward  emission 
trends have been reported only for NH3 and PM2.5, and for 
NH3  although  these  are  still  above  2005  levels.  This 
situation requires further action. The third priority action 
received  by  Bulgaria  was  to  ratify  the  Heavy  Metals 
Protocol  and  the  Persistent  Organic  Pollutants  Protocol. 
Bulgaria has made some progress in this regard, but still 
has not ratified those protocols. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

•  Accelerate  the  ratification  of  relevant  international 

conventions and protocols. 

Figure 16: PM2.5 and NOx emissions by sector in Bulgaria 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
1,2%

5,7%

NOₓ

0,016%

42,113%

78,9%

3,069%

6,2%

7,4%

0,7%

10,228%

27,031%

17,542%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
https://www.eea.europa.eu/en/topics/in-depth/air-
25 June 
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (82) were registered 
for NO2 in one air quality zone (83) and for PM10 in one air 
quality  zone (84)  in  Bulgaria.  Furthermore,  for  one  air 
quality  zone,  the  target  values  for  ozone  concentrations 
have not been met (85). 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures covering all 
Member States concerned, including Bulgaria. The Court 
of  Justice  of  the  European  Union  has  delivered  two 
judgments  confirming  Bulgaria’s  non-compliance  with 
Directive 2008/50/EC: in 2017 over exceedances of PM10 
limit values (C-488/15) and in 2022 over exceedances of 
SO2  limit  values  (C-730/19).  The  aim  is  that  appropriate 
measures are put in place to bring all air quality zones into 
compliance.  Infringement  procedures  have  also  been 

(82)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(83) 
(84) 
(85) 

(86) 

Plovdiv. 
Plovdiv. 
EEA, 
‘Eionet 
(https://cdr.eionet.europa.eu/). 
INFR(2022)2086 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_23
_142). 

Central 

Data 

Repository 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Industrial emissions 

Figure 17:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

The  main objectives of EU policy on industrial emissions 
are to: 

Bulgaria  23 

protect air, water and soil and to prevent harmful 

(i) 
effects on human health and the environment; 
prevent and manage waste; 
(ii) 
improve  energy  and 
(iii) 
including water; 
(iv) 

contribute to decarbonisation. 

resource  efficiency, 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (87). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (88). 

In  Bulgaria,  there  were  612  installations  covered  by  the 
IED in 2022, a quarter of them (25 %) being installations 
from  the  waste  management  sector  (including  landfills). 
The  other  main  sectors  are  the  sector  involved  in  the 
intensive  rearing  of  poultry  or  pigs  (21 %),  the  chemical 
sector (15 %) and the metals sector (13 %). 

Figure 17 shows the damage  to health and environment 
due to the main industrial air pollutants. As this depends 
on, among other factors, the size of the industrial sector in 
each  Member  State,  the  figure  also  shows  the  ratio 
between the damage and the industrial activity (expressed 
in gross value added (GVA)), which gives an indication of 
the  emissions  ‘intensity’.  Bulgaria  has  the  ninth  highest 
damage  in  the  EU;  however,  in  the  case  of  emissions 
intensity, it comes first, with its intensity being ten times 
the  EU  average  of  EUR 27.5/EUR 1 000  GVA.  The  main 
industrial  contributors  to  emissions  to  air  (89)  are  the 
energy  sector  for  SO2,  NOX  and  heavy  metals,  and  the 
mineral industry for heavy metals. 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

NB:  Cd,  cadmium;  Hg, mercury;  Ni,  nickel;  Pb,  lead;  TOC,  total  organic 
carbon; total N, total nitrogen; total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Bulgaria  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account  the  human  toxicity  of  each  metal,  as  well  as 
emissions  intensity,  based  on  the  ratio  with  industrial 
activity (expressed in GVA). Bulgaria has the 15th highest 
emissions of heavy metals to water and is in 2nd position 

(87)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial emissions (integrated 
pollution prevention and control) (OJ L 334, 17.12.2010, p. 17), as 
amended by Directive (EU) 2024/1785 of the European Parliament 
2024,  https://eur-
and  of 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 

the  Council  of 

24 April 

(88) 

(89) 

European 

Emissions 

EEA, 
Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 
European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
Bulgaria  24 

using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
that  worst 
the  provisions 
revised  directive, 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

set 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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 reductions in pollution. 

In 2022, Bulgaria received a priority action to address the 
emissions to air from the energy sector. Data are not yet 
available  to  assess  progress  towards  this  priority  action. 
However,  the  energy  sector  remains  among  the  main 
sources of industrial emissions in Bulgaria. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water,  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

intensity  (above  the  EU  average  of 
for  emissions 
0.864 kg/EUR 1 billion  GVA).  As  shown  in  Figure  20,  the 
main  industrial  contributors  to  emissions  to  water  in 
Bulgaria are the livestock sector for total phosphorus and 
total nitrogen, the electricity and heat production sector 
for heavy metals and the pulp, paper and wood sector for 
total organic carbon. 

Figure 19:  Industrial  releases  and  intensity  of  heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 20:  Relative  releases  to  water  from  industry  in 
Bulgaria (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

Chemicals
Extractive industry
Food and drink
Livestock
Pulp, paper and wood

Electricity and heat production
Ferrous metal
Landfill
Non-ferrous metal

Source: EEA, ‘Industrial reporting under the Industrial Emissions 
Directive 2010/75/EU and European Pollutant Release and Transfer 
Register Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular 
data)’, EEA Geospatial Data Catalogue, 13 September 2024, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
non-governmental  organisations 
(NGOs),  alongside 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i) 

(ii) 

control major-accident hazards involving dangerous 
substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (90). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (91)  and  the  report  by 
Bulgaria on the implementation of the Seveso III Directive 
for 2019–2022 (92). 

In 2024, of the 200 Seveso establishments in Bulgaria, 116 
were categorised as lower-tier establishments and 84 as 
upper-tier establishments (UTEs), based on the quantity of 
hazardous  substances  likely  to  be  present.  UTEs  are 
subject to more stringent requirements. The change in the 
number  of  Seveso  establishments 
in 
Figure 21. 

is  presented 

Figure 21: Number of Seveso establishments in Bulgaria, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-

2022, 

Bulgaria  25 

en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are 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. 

According to Bulgaria, in 2022, an EEP was required for 84 
UTEs, out of 84 in total at the time. In 2022, 84 UTEs had 
an  EEP  and  77  of  these  EEPs  had  been  tested  over  the 
previous three years. The summary is shown in Figure 22. 

Figure 22: Situation regarding EEPs in Bulgaria, 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

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

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are shown in 

(90)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(91) 

(92) 

https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024. 
As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Bulgaria  26 

releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

In  2019,  21 %  of  the  dental  treatments  were  still  using 
dental  amalgam,  which  represented  a  challenge  for 
Bulgaria to phase out its use by 1 January 2025. However, 
measures  should  have  been  put  in  place  to  ensure  a 
socially  and  economically  sound  phase-out,  including  an 
adequate  reimbursement  of  the  alternatives  to  dental 
amalgam  through  the  health  insurance  scheme  and  the 
training  of  dental  practitioners.  The  Commission 
is 
monitoring whether the phase-out has taken place under 
the  terms  and  conditions  of the  regulation.  Bulgaria  will 
also need to ensure that the manufacture and export  of 
mercury-containing lamps are prohibited by the deadlines 
set out in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (93) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

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 stress (94). 

In Bulgaria, environmental noise is estimated to cause at 
ischaemic  heart  disease 
least  around  520  cases  of 

Figure 23.  This  provision  on  knowledge  is  an  important 
provision of the Seveso III Directive, as awareness by the 
public  of 
the 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

Figure 23: Share of UTEs for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

N.B. No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

In 2022, Bulgaria received a priority action to strengthen 
control and enforcement  to  ensure compliance with  the 
Seveso III  Directive  rules,  especially  those  on  EEPs.  Data 
reported on the implementation of the directive for 2019–
2022  show  significant  progress  in  the  numbers  of  EEPs 
established and tested for UTEs in Bulgaria. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 

(93)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 

noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(94)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Bulgaria  27 

annually (95)  and  some  45  600  people  to  suffer  from 
disturbed sleep (96). 

Water Framework Directive 

Based on the latest set of information analysed, Bulgaria 
has not completed its noise mapping of agglomerations. 

Since Bulgaria has failed to report to the Commission all 
relevant 
information  on  the  strategic  noise  maps, 
including  the  noise  exposure  of  the  population,  the 
European  Commission  decided  to  open  an  infringement 
procedure against Bulgaria. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18  January  2025:  these  have 
not been assessed as yet. 

Bulgaria received no priority action in the 2022 EIR. 

2025 priority actions 

•  Complete noise mapping. 
•  Complete  and  implement  action  plans  on  noise 

management.  

Water quality and management 

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

Directive 

The Water Framework Directive (97) is the cornerstone of 
EU  water  policy  in  the  21st  century (98).  The  Water 
other  water-related 
and 
Framework 
directives (99) form the basis of sustainable and integrated 
water management in the EU. They aim to achieve a high 
level  of  protection  of  water  resources,  prevention  of 
further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The  Water  Framework  Directive  (WFD)  establishes  a 
procedural  framework  for  reaching  good  surface  water 
ecological  and  chemical  status  and  good  groundwater 
quantitative and chemical status. This implies monitoring 
and  classification  of  all  waterbodies,  assessment  of 
pressures and impacts and identification of the most cost-
effective  measures  to  achieve  the  objectives  of  the 
directive. The directive dates from 2000 and set an initial 
deadline  of  2015  for  achieving  its  objectives,  with  the 
option to extend the deadline to the end of 2027. Every six 
years,  Member  States  must  report  their  river  basin 
management  plans  (RBMPs)  to  the  Commission.  They 
should cover river basin districts in their countries, some 
of  which  may  be  shared  with  other  countries.  The 
Commission has assessed the third cycle of RBMPs, which 
were to be submitted by March 2022. The analysis of the 
last  RBMPs  of  Bulgaria  has  identified  nutrients  from 
agriculture  as  an  important  pressure  for  groundwater / 
surface waters that is affecting these waters’ good status 
and  as  one  of  the  main  factors  in  not  meeting  the  WFD 
objectives. 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  report  their  flood  risk 

(99) 

(95) 

These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
2018, 
No 2018/10, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise  

Bilthoven, 

(96)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 
https://environment.ec.europa.eu/topics/water_en. 

(97) 

(98) 

the 

Floods 

include 

the  Groundwater  Directive 

(https://eur-
These 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
the 
(https://eur-
new 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

Nitrates 
(https://eur-lex.europa.eu/legal-
MSFD 

Drinking  Water 

Treatment 

Directive 

and 

the 

IED 

the 

the 

the 

2025 Environmental Implementation Review – Bulgaria 

 
 
  
management  plans  (FRMPs),  based  on  the  flood  hazard 
and risk maps and the preliminary flood risk assessments 
drawn up during the second cycle (2016–2021). 

the 

Bulgaria  did  not  submit  the  third  RBMPs  and  second 
FRMPs  by  March  2022,  as  required  under  the  Water 
Floods  Directive 
Framework  Directive 
and 
respectively.  The  Commission  opened 
infringement 
proceedings for late reporting. Bulgaria finally reported its 
second  FRMPs  in  January  2024  and  its  third  RBMPs  in 
January 2025. As a result of this late/incomplete reporting, 
the Commission has not been in a position to assess the 
plans  and  include  such  assessment  in  its  report  to  the 
European Parliament and to the Council  (100). 

As a consequence, the EIR report cannot be updated for 
Bulgaria  and  reference  is  made  to  the  2022  EIR  for  the 
latest state of play (101). 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (102), (ii) a methodology for measuring microplastics 
in drinking water (103) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (104). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019. 

The  quality  of  drinking  water  (supplied  by  large  water 
suppliers)  in  Bulgaria  does  not  give  rise  to  concern (105). 
From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 

(100)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(101)  https://environment.ec.europa.eu/law-and-

governance/environmental-implementation-review_en#country-
reports. 

(102)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(103)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 

(104)  OJ L, 

Bulgaria  28 

per- and polyfluoroalkyl substances monitoring data in the 
future. 

2025 priority action 
• 

Take  action  to  ensure  full  compliance  with  the 
Drinking Water Directive. 

Bathing Water Directive 
The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 24  shows  that  in  2023,  out  of  the  96  Bulgarian 
bathing waters, 91 (94.8 %) were of excellent quality and 
5 bathing waters (5.2 %) were of good quality. No bathing 
waters  were  found  to  be  of  sufficient  or  poor  quality. 
Detailed  information  on  Bulgarian  bathing  waters  is 
available from a national portal (106) and via an interactive 
map viewer of the EEA. 

Figure 24: Bathing water quality  per Member State and 
Albania and Switzerland (%), 2023 season 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

2024/369, 

OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary, the compliance for all parameter groups in Bulgaria 
was at least 99.35 % in 2017, 99.26 % in 2018 and 99.44 % in 2019. 
(106)  Ministry of Health, ‘Registries – Bathing waters’, Ministry of Health 
https://www.mh.government.bg/bg/administrativni-

(105) 

website, 
uslugi/registri/vodi-za-kupane. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Nitrates Directive 

The  Nitrates  Directive  (107) aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive (108),  dating  to  2022,  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. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 
The  report  on  the 
implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025. 

2025 priority action 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 
agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Overall, in Bulgaria, the compliance rate was 31 % in 2020. 
In  total,  210  agglomerations,  generating  4 560 660 
population equivalent (p.e.) of urban waste water, did not 
comply with the requirements of the directive. 

Bulgaria  29 

Figure 25:  Proportion  of  urban  waste  water  that  fully 
comply with the UWWTD (%), 2020 

Source:  Directorate-General 
for  Environment,  Fribourg-Blanc,  B., 
Dhuygelaere, N., Berland, J. and Imbert, F., 12th technical assessment of 
UWWTD  implementation  –  Final  version,  Publications  Office  of  the 
European  Union,  2024  12th  technical  assessment  of  UWWTD 
implementation - Publications Office of the EU 

In  November  2024,  the  Commission  decided  to  refer 
Bulgaria to the Court of Justice of the European Union￼ 
for non-compliance with the obligations of the UWWTD in 
31  agglomerations  with  more  than  10 000 109.  It 
is 
essential  that  Bulgaria  takes  the  necessary  measures  to 
comply with the requirements of the directive. 

This  is  all  the  more  important  as  the  directive  has  been 
revised  in  order  to,  among  other  things,  strengthen 
existing  treatment  standards and  establish  an  additional 
treatment of micropollutants in urban waste water. Other 
new  requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  extended 
producer  responsibility  system  to  ensure  sustainable 
financing  of  micropollutant  treatment  by  the  most 
polluting  industries  and  ensuring  access  to  sanitation, 
especially 
for  vulnerable  and  marginalised  groups. 
Bulgaria  has  until  31 July  2027  to  transpose  the  new 
directive into its national legal system. 

2025 priority actions 

• 

the  necessary  measures 

full 
Take 
implementation  of  the  current  urban  wastewater 
treatment  directive,  taking  into  account  the  new 
requirements of the recast directive. 

to  ensure 

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 

(107)  https://environment.ec.europa.eu/topics/water/nitrates_en. 
(108)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

(109) 

INFR(2017)2082. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
sustainability  towards  a  toxic-free  environment (110), 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (111)  provides  a  baseline 
protection for human health and the environment. It also 
for  businesses 
ensures  stability  and  predictability 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (112)  on  the 
these 
implementation 
regulations (113).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
law  enforcement.  Recorded 
notably  in  the  area  of 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

of 

(110)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
final  of  14 October  2020,  https://eur-
COM(2020) 667 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(111)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(112)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 

p. 1), 

Bulgaria  30 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (114) of the two  main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (115). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (116).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (117).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Responsibility  for  checking  compliance  with  the  REACH 
Regulation in Bulgaria (118) lies with: 

• 
• 
• 

15 regional inspectorates of environment and water; 
28 regional health inspectorates; 
the executive agency General Labour Inspectorate. 

Union, 

Luxembourg, 

European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

2020, 

(113) 

the 

European 

(114)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
2021, 
Union, 
of 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(115)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

(116)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and  mixtures  (Text  with  EEA  relevance),  OJ  L,  2024/2865, 
20.11.2024, p.1 (Regulation - EU - 2024/2865 - EN - EUR-Lex). 
(117)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

(118)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 68, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Bulgaria 

 
 
Bulgaria  31 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliances.  Therefore,  the  non-compliance  rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 
proportion of non-compliance cases found in the project 
are of concern. 

Figure 27:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

Bulgaria has fully implemented enforcement strategies for 
both the REACH and CLP Regulation (119). 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  national-specific  data  on  enforcement 
since 2022. 

In  Bulgaria,  human  and  financial  resources  allocated  to 
REACH and CLP Regulation enforcement are limited (120). 
There  were  2 577  REACH  checks  in  2019  and  266  CLP 
checks.  Almost  all  of  those  carried  out  were  proactive 
(inspections),  rather  than  reactive/non-routine  checks  (i.e. 
investigations  in  response  to  complaints,  accidents  and 
referrals) (121). 

In  2020,  Bulgaria  participated  in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (122).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

Figure 26: Compliance of imported products – results of 
the REF-8 project (%) 

Bulgaria  participated  to  a  small  extent  in  the  REF-8 
coordinated enforcement project. Online sales have been 
proven  to  correspond  consistently  to  higher  non-
compliance  rates  in  checks  performed  across  the  EU,  in 
particular when related to imported products. 

In  2022,  Bulgaria  received  a  priority  action  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance. In the absence of reporting 
since 2022, no progress has been shown and this priority 
action  remains  valid  in  2025,  partly  because  of  the 
experience with the REF-8 project. 

(119)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(120)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 74, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(121)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
pp. 87–88, 
Luxembourg, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Union, 

2020, 

(122)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
and 
p. 20, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
2025 priority actions 

•  Upgrade 

the 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 

capacities 

• 

Bulgaria  32 

including 

the 
European  Chemicals  Agency, 
coordinated  enforcement  projects,  called  REF 
projects. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislation. 

in 

• 

2025 Environmental Implementation Review – Bulgaria 

 
 
Bulgaria  33 

4. Climate action 

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average,  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030, 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals set  out  in  the  European  Green 
Deal  have  been  agreed 
law,  and  the  European 
in 
Commission  recommended  a  new  intermediate  climate 
target of a 90 % reduction in emissions by 2040. In 2024, 
the  Member  States  submitted  updated  national  energy 
and climate plans for 2021–2030, reflecting the increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 

its  Member  States  need 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running  total  in  2022  of  – 32.5 % (123).  However,  the  EU 
and 
their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  net  GHG 
emissions of Bulgaria decreased by 40%, making it one of 
the countries with an above-average decrease. 

to  step  up 

Forestry (124). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The key strategic document at country level is the National 
Energy  and  Climate  Plan  (NECP) (125).  Bulgaria  submitted 
its final plan in January 2025 after the deadline set by the 
regulation.  The  European  Commission  assessed  the  final 
plan  and  the  extent  to  which  Bulgaria  has  followed  the 
recommendations for the draft version. The findings from 
the assessment are: 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  11%  in  2030  compared  to  2005,  and 
Bulgaria  will  overachieve  its  target  by  1  percentage 
point. 
The  latest  projections  show  a  gap  to  the  LULUCF 
target, meaning that current levels of removals have 
been insufficient.  

•  Bulgaria  is  in  line  with  its  target  for  the  share  of 

• 

renewable energy. 
There  is  still  gaps  in  target  for  the  final  energy 
consumption  that  must  be  closed.  Projections  for 
primary  energy  consumption  are  in  line  with  the 
target. 

To minimise the impacts of climate policies on vulnerable 
people  and  sectors,  Bulgaria  is  using  the  Just  Transition 
Fund,  Modernisation  Fund  and  will  use  Social  Climate 
Fund  from  2026  (for  more  information,  see  Chapter  5 
Finance). 

Figure 28: Total GHG  emissions (excluding international 
aviation) (%), 1990–2022 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with a dedicated Social Climate Fund to 
help  citizens  during  the  transition;  (ii)  increasing  targets 
under  the  effort  sharing  regulation;  and  (iii)  a  revised 
for  Land  Use,  Land  Use  Change  and 
regulation 

(123)  EU  net  domestic  emissions,  including  the  land  use,  land-use 
change and forestry (LULUCF) sector and excluding international 
aviation. 

(124)  A  full  overview  of  the  Fit  for  55  package  is  available  at 
https://commission.europa.eu/strategy-and-policy/priorities-

2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

(125)  More  information  about  NECP  is  on  the  dedicated  website 
https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Bulgaria  34 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around  40% of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (126) 
and, from 2024, maritime transport also. 

The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the right to emit 1 t of CO2 eq (carbon dioxide equivalent)), 
in auctions or through trading allowances with others. The 
cap is reduced annually to ensure that overall emissions in 
the sectors covered decrease over time. 

The emissions under the ETS decreased by 42% from 2005 
to 2023. 

About  72 %  of  the  GHG  emissions  from  Bulgaria’s  ETS 
installations  came  from  power  generation,  significantly 
more than the EU average of 57 %. Of the total emissions 
from  all  industry  sectors,  31 %  came  from  the  chemical 
industry, 31 % each from refineries and from cement and 
lime production, 21 % from other industries, and 8 % from 
the  metals  industry.  Since  2019,  the  power  sector’s 
emissions  have  declined  by  35 %.  The  industry  sectors’ 
emissions have declined by slightly less, 33 %. Since 2013, 
GHG emissions have declined by 48 % in power generation 
and by 10 % in the industry sectors. GHG emissions in both 
the  power  sector  and  the  industry  sectors  showed  both 
increases and decreases in that decade. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors, 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (127).  Member  States  should 
have  notified  full  transposition  the  provisions  of  the 
revised  EU  ETS  directive  related  to  the  new  ETS2  into 
national 
law  by  30  June  2024.  Bulgaria  did  not 
communicate  full  transposition  into  national  law  by  this 
therefore  opened  an 
deadline.  The  Commission 
infringement procedure against Bulgaria on 25 July 2024, 
for  failing  to  fully  transpose  the  provisions  into  national 
law. 

Bulgaria  had  two  months  to  respond  and  address  the 
shortcomings raised by the Commission. In the absence of 
a  satisfactory  response,  the  Commission  may  decide  to 
issue a reasoned opinion. 

The  Commission  also  opened  infringement  procedures 
against  Bulgaria  on  25  January  2024  for  failing  to  fully 

transpose  previous  revisions  of  ETS  directive (128)  into 
national law. Bulgaria had two months to respond and 
address the shortcomings raised by the Commission. 
In  the  absence  of  a  satisfactory  response,  the 
Commission may decide to issue a reasoned opinion. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation (ESR) (129)  covers  GHG 
emissions 
(excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. Bulgaria‘s target is –10%. 

In  addition  to  the  2030  targets,  Member  States  have 
annual GHG emissions limits (annual emission allocations), 
reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations 
in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  Bulgaria  is  on  track  to  achieve  its  2030  ESR 
target. 

Projections show a total decrease of emissions by 11.1 %. 
That means that reduction is 1.1 percentage points above 
the 2030 target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 41 % of all effort sharing emissions in 
2022 and its emissions increased by 27 % from 2005 level. 
In  Bulgaria,  much  remains  to  be  done  in  the  sector, 
especially for passenger transport. Only 0.1 % of car fleet 
were  battery  electric  vehicles  in  2023  (EU  average  is 
1.2 %).  On  the  other  hand,  Bulgaria  has  about  1  400 
publicly accessible charging points, or one for every three 
e-vehicles (above the EU average of 1:10). Share of public 
transportation is below the EU average, especially share of 
railways  (2 %)  is  considerably  lower  than  the  average 
(6 %). At 24 % of inland freight transport, Bulgaria has one 
of  the  highest  shares  of  freight  transport  by  inland 
waterway in the EU, also Bulgaria’s share of rail is above 
the  EU  average.  74 %  of  railways  are  electrified,  a 
relatively high share compared to EU average of 56 %. 

The buildings sector is a significant concern for Bulgaria as 
well.  Between  2005  and  2022,  emissions  from  buildings 
fell  by  17.6 %,  well  below  the  EU  average  of  27.6 %. 

(126)  Flights between the EU Member States including departing flights 
to Norway, Iceland, Switzerland and the United Kingdom. 

(127)  Directive 

(EU) 

2023/959 

(https://eur-lex.europa.eu/legal-

(128)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

- EUR-Lex 
(129)  Regulation 

(EU) 

2018/842 

(https://eur-

content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG) 

lex.europa.eu/eli/reg/2018/842). 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
Bulgaria missed the energy savings required by 2020 and 
needs to step up its efforts in the sector to achieve its 2030 
energy consumption target for buildings. 

for management of the Natura 2000 network. Bulgaria has 
also  put  forward  the  commitment  to  restore  150 ha  of 
habitats through nature-based solutions. 

Bulgaria  35 

Emissions from agriculture increased by 20 % compared to 
2005. The country has one of the lowest shares of organic 
farming  in  the  EU,  at  2.3 %  of  total  utilised  agricultural 
area in 2020 against the EU average of 9.1 % and the EU 
target of 25 % by 2030. The share of organic farming has 
fallen  since  2016  when  it  was  3.2 %.  Bulgaria’s  livestock 
density index barely changed between 2010 and 2020 and 
is  well  below  the  EU  average.  Looking  at  the  trends  to 
2030,  with  current  measures  in  place  as  well  as  with 
additional  measures,  Bulgaria  will  increase  agriculture 
emissions by 38 % from 2005. 

Figure 29: Effort-sharing emissions by sector (%), 2022 

Land use, land-use change and forestry 

The LULUCF sector plays a significant role in achieving the 
EU’s climate neutrality goal. In the EU, this sector absorbs 
more GHGs than it emits, removing significant volumes of 
carbon  from  the  atmosphere.  Thus,  it  is  the  only  sector 
with negative emissions. 

and 

Forests play the main role in Bulgaria in removing carbon 
through land use. The main contributing areas are forest 
by 
management 
afforestation/reforestation. Total net removals have gone 
from –16.3 Mt of CO2 equivalent in 2005 to –9.5 in 2022, 
representing  a  long-term  deterioration  of  the  situation, 
albeit net removals have remained somewhat stable since 
2016. 

removals 

Bulgaria‘s target for 2030 is to enhance land removals by 
an additional –1.2 Mt of CO2 equivalent compared to the 
yearly  average  of  the  period  2016–2018.  The  latest 
projections show a gap to the 2030 target of 1.4 Mt of CO2 
equivalent, meaning that current levels of removals have 
been  insufficient.  Therefore,  Bulgaria  needs  to  apply 
additional measures to reach its 2030 target. 

Adaptation to climate change 

Halting all GHG emissions would still not prevent climate 
impacts that are already occurring. Therefore, adaptation 
to  climate  change  is  also  a  key  component  of  climate 
policy. 

Bulgaria  has  one  out  of  three  regions  identified  as 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (130). 

Bulgaria  is vulnerable to extreme climate events such as 
heatwaves and heavy rainfall. From 1980–2019, only 5 % 
of losses caused by climate-related events were insured. 
Insurance  coverage  is  below  50 %  for  all  climate-related 
risks. Bulgaria’s vulnerability to floods is at medium levels, 
due  to  more  intense  and  frequent  extreme  weather 
events. Bulgaria lacks coordination among authorities and 
has not yet aligned its monitoring and modelling to current 
measures  and  challenges.  It  has  limited  administrative 
capacity  for  action  on  adaptation,  it  has  made  little 
progress on international networks. 

Bulgaria adopted its national adaptation strategy and plan 
in 2019 and has its national adaptation strategy. There are 
regional  adaptation  plans  and  Bulgaria  lacks subnational 
planning  and  reporting  to  align  planning  tools  and  help 
coordinate  mechanisms  to  ensure  that  subnational 
policies are regularly reviewed and updated. 

European  Commission  identified  four  priority  actions  in 
the 2022 edition (131) of the review. 

Bulgaria  is  making  progress  towards  deployment  of 
renewables.  Total  renewable  energy  capacity  in  2023 
stood  at  6  215  MW  (23 %  increase  compared  to  2022). 
Bulgaria also committed to increase renewables to 34.1 % 
by 2030 in their draft updated NECP. This trend had not 
impacted  the  2022  total  share  of  renewables  where  the 
share  of  renewables  decreased  by  4 percentage  points 
compared to 2020 level, but indications show higher RES 
production in 2023 compared to 2022. 

The law on Biodiversity was amended at the end of 2022. 
It entered into force in 2023 to establish a new approach 

(130)  European  Climate  Risk  Assessment  (EUCRA).  2024.  Available  at 

(131)  2022 edition  

European Climate Risk Assessment (europa.eu) 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
 
Bulgaria  36 

Investment  to  boost  renewable  energy  are  being 
launched.  A  national  scheme  to  support  investments  in 
renewable  energy  and  storage  with  at  least  300  MW  of 
storage  and  1  140  MW  of  renewable  energy  production 
has been put forward. BG also put forward the revision of 
its Renewable Energy Act which assists in the acceleration 
of renewables. Still administrative burden prevails in the 
areas permitting for installing renewable energy sources. 

Progress on enhancing the renovation of building stock is 
limited. Bulgaria needs to accelerate building renovation 
in  order  to  incentivise  energy  efficiency  and  address 
energy poverty. The Recovery and resilience plan contains 
measures, but its implementation is delayed. 

On  the  implementation  of  additional  measures  and 
changes in land management practices, Bulgaria does not 
have  a  clear  pathway  how  they  will  achieve  its  LULUCF 
target  and  what  specific  policies  and  measures  will 
contribute to this. They have prepared a national strategy 

on the development  of the  forest  sector that is pending 
ministerial approval. 

Since  2022,  Bulgaria  has  adopted  three  Bulgaria’s 
Territorial  Just  Transition  Plans  (TJTPs)  for  the  regions 
Stara Zagora, Kyustendil and Pernik that face the biggest 
socio-economic  challenges 
in  phasing  out  coal  and 
reducing CO2 emissions. Progress on the implementation 
of these plans is limited. 

2025 priority actions 

• 

Implement all polices and measures that are needed 
to  achieve  targets  laid  down  in  the  Effort  Sharing 
Regulation  (ESR)  and  the  Land  Use  and  Land-Use 
Change  and  Forestry  (LULUCF)  Regulation.  More 
detailed priority actions are set out in the assessment 
of the final National Energy and Climate Plan (NECP) 
(132). 

(132)  National energy and climate plans 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
 
 
Bulgaria  37 

Part II: Enabling framework – implementation tools

5. Financing

The  EU  budget  supports  climate  investment  in  Bulgaria 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022, Bulgaria’s revenues from auctioning reached 
EUR 2.4 billion in total, with 100 % of it spent on climate 
and energy. 

action in 2021–2027 (with 45 % of this via the ERDF), with 
a  further  EUR 41 million  from  the  European  Maritime, 
Fisheries and Aquaculture Fund (134). 

The  RRF  contributes  to  climate  finance  in  Bulgaria  with 
EUR 3.24 billion  up  to  2026,  representing  57 %  of  the 
recovery and resilience plan (RRP) (135). 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 4.1 billion per year in 
Bulgaria. 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 424 million was assigned 
to Bulgaria in the reference period (136). 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 1.6 billion per year; thus, there is a 
gap of EUR 2.4 billion per year. 

National financing, including EU emissions trading 
system revenues 

The  environmental  investment  gap  is  predominantly 
linked to biodiversity and ecosystems (EUR 1.4 billion per 
year), with around EUR 0.4 billion in water and in pollution 
prevention and control (each). 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
recovery and resilience facility (RRF) EUR 275.7 billion and 
CAP EUR 145.9 billion (133). 

In  Bulgaria,  the  EU  cohesion  policy  (considering  the  EU 
contribution  amount)  provides  EUR 4 billion  for  climate 

to  EUR 449 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets,  amounted 
in  2020, 
EUR 833 million in 2021 and EUR 1 094 million in 2022 in 
Bulgaria, totalling EUR 2.4 billion in the three-year period, 
representing 100 % of the revenues from auctioning, as all 
auction  revenues  are  earmarked  for  climate  and  energy 
purposes in  Bulgaria. Unspent  revenues are carried  over 
to later years; therefore, in some years spending is higher 
than revenues (137). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level (138). 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (139). 

therefore, 

and, 

(133)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
the 
pp. 94–96, 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024 

(134)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(135)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

(136)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(137)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(138)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(139)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

Environmental Implementation Review 2022 – Bulgaria 

 
 
 
 
 
 
Bulgaria  38 

Other MFF sources 

RRF (d) (2021–2026) 

405.9 (c) 

1 546.2 

(a) 

(b) 

(c) 

(d) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
information: 
its  publication  date.  Source  and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf ). Source: European Commission.    

Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 

instrument  for  the 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Bulgaria,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
(EUR 5.4 billion) (￼141,  Horizon  Europe 
programme 
(EUR 95.5 billion) (￼), 
Europe 

Connecting 

the 

Environmental financing and investments 

This  section  describes  Bulgaria’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (140). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable Bulgaria’s to meet its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 4.1 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 1.8 billion per year, can be attributed to biodiversity 
and  ecosystems,  followed  by  pollution  prevention  and 
control  (EUR 0.9 billion  per  year)  and  circular  economy 
and water (around EUR 0.7 billion per year for each of the 
two, in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 1.6 billion  in  Bulgaria  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 2.1 billion for Bulgaria in total, during 2021–2027 (or 
EUR 744 million per year). 

Table 1: Key environmental allocations from EU funds to 
Bulgaria (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

European  Maritime,  Fisheries  and 
Aquaculture Fund 

Allocations 

3 340 (a) 
2 103.3 
840.1 
396.6 
1 433.1 (b) 
1 054.8 
378.3 

27.3 

(140)  Research,  development  and  innovation  is  accounted  for  under 
each  environmental  objective.  The  financing  needs,  baselines, 
gaps  estimates  are  based  on  the  Directorate-General  for 
internal  analysis  (of  2024).  Throughout  this 
Environment’s 

chapter,  specific  references are  provided  to  the  most  important 
data sources used. 

(141)  European  Commission,  Horizon  Europe,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Bulgaria  39 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 2.4 billion 
per  year  in  Bulgaria,  representing  around  2.87 %  of  the 
national GDP, being higher than the EU average (0.77 %). 

Figure 30: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of Bulgaria’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Faci142 (EUR 33.7 billion) (￼) and funds that can be 143the 
InvestEU programme (￼). 

Bulgaria’s  RRP  supports  climate  objectives  through 
funding  of  EUR 3.24 billion  (56.9 %  of  the  total),  with  an 
additional  EUR 0.16 billion  (2.9 %  of  total)  for  the 
environment. 

The EIB provided around EUR 153 million in environment-
related  financial  contributions  to  Bulgaria  from  2021  to 
mid  2024,  linked  to  the  area  of  sustainable  energy, 
industrial  projects,  which  provides 
transport  and 
significant 
reducing  air  pollution, 
environmental noise and other pollution. 

co-benefits 

to 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Bulgaria, the 
total national environmental protection expenditure was 
EUR 1.2 billion 
in  2021, 
representing 2 % of GDP in both years. 

in  2020  and  EUR 1.4 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Bulgaria,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 337 million in 2020, rising to EUR 360 million in 2021, 
representing around 0.5 % of GDP. 

investment 

protection 

from 

Splitting  by  institutional  sector,  38.5 %  of  Bulgaria’s 
national  environmental  protection  investment  (capital 
expenditure) comes from the general government budget, 
specialist  private-sector 
with  6.1 %  coming 
producers (of environmental protection services, such as 
waste and water companies) and 55.4 % from the general 
business  sector,  whose  environmental  activities  are 
usually ancillary to its main activities. At the EU level, 38 % 
of  environmental  protection  investment  comes  from 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (144). 

from 

Bulgaria’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 1.6 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  56.6 %,  with  around 
43 % national financing (both public and private). The total 
public financing (EU funds plus national public) represents 
around 73 % of the total. 

(142)  Connecting  Europe  Facility  (Transport)  Regulation  (Regulation 

(EU) 2021/1153). 

(143)  The  InvestEU  Fund  is  set  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  EIB  group 
and others. 

(144)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Table 2: Summary of environmental investment gaps in 
Bulgaria per year, 2021–2027 

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap per year  

Million EUR  
(2022 
prices) 

%  
of 
total 

%  
of GDP 

406 

16.8 

0.48 

147 

6.1 

0.17 

439 

18.1 

0.52 

1 432 

59.1 

1.69 

Total 

2 425 

100.0 

2.87 

Source:   Directorate-General for Environment analysis. Rounding used.  

Pollution prevention and control 

Investment needs 

to 

reduce 

In pollution prevention and control, Bulgaria’s investment 
needs  are  estimated  to  reach  EUR 0.9 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this, almost EUR 0.8 billion, relates to air pollution control, 
to comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs 
reach 
EUR 128 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (145).  Industrial  site  remediation 
requires an estimated EUR 16 million per year. Protection 
from  radiation  (nuclear  site  decommissioning,  nuclear 
year. 
waste) 
Microplastics pollution and the chemicals strategy require 
around EUR 10 million per year (each) (146). 

around  EUR 105 million  per 

environmental 

noise 

costs 

(145)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
report 
implementation 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(146)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(147)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 

Bulgaria  40 

control 

investment 
and 

Current investments 
levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 503 million per year in Bulgaria in 2021–2027. Most 
of  the  financing  concerns  clean  air  (EUR 431 million  per 
year).  Protection  from  environmental  noise  receives 
around  EUR 140 million  per  year,  with  a 
further 
EUR 44 million for site remediation (147). 

reach 

In Bulgaria, the EU MFF provides an estimated  35.7 % of 
the clean air  financing  (mostly via  cohesion policy), with 
further  37.1 % from the RRF, adding up to  72.8 %  of the 
total. EIB financing contributes 4.1 % and national sources 
reach 23.1 % (148). 

The gap 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Bulgaria 
needs  to  provide  an  additional  EUR 406 million  per  year 
(0.48 % of GDP), mostly related to clean air. The adequate 
investments 
implementation  of  the  NECP  with  the 
included  for  sustainable  energy  and  transport  would 
largely  deliver  this,  while 
in  many  Member  States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

According to the latest (2023) NAPCP review report (149), 
Bulgaria  did  not  comply  with  ammonia  reduction 
requirements in 2020 and 2021, while it is not  at risk  of 
non-compliance  with  ammonia  concerning  the  NECD’s 
2030  emission  reduction  commitments,  based  on  the 
policies and measures in its NAPCP that take into account 
climate, energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Bulgaria’s  investment  needs  in  circular  economy  and 
waste reach EUR 677 million per year (including baseline 

tracking: 

information  on  clean  air 

Annex  VI.  Further 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(148)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(149)  European Commission, ‘National air pollution control programmes 
website, 
European 

information  on  clean  air 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

Commission 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
Bulgaria  41 

investments).  Most  of  this,  around  EUR 529 million  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 149 million  necessary 
for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (150). 

Current investments 

Circular economy investments across the economy reach 
around EUR 404 million per year in Bulgaria in 2021-2027, 
with  a  further  EUR 128 million  provided  for  waste 
management that does not constitute circular economy. 

investment needs both for the water industry and for the 
protection and the management of water. The largest part 
of  the  total  annual  need,  EUR 356 million,  relates  to  the 
management  of  waste  water  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 118 million  is  necessary  for  drinking-water-related 
investments  and  around  EUR 230 million 
the 
protection and management of water (152). 

for 

Current investments 

Water investments in Bulgaria are estimated to be around 
EUR 267 million per year (in 2022 prices) in 2021–2027. Of 
this, EUR 117 million supports wastewater  management, 
EUR 87 million drinking water and around EUR 63 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Around  12.6 %  of  the  combined  financing  for  circularity 
and waste comes from the EU MFF, with a further 2.6 % 
from the RRF, adding up to 15.1 % of the total. The share 
of  national  sources  is  the  largest,  reaching  85 %  of  the 
total financing (151). 

Around half of the total financing (49.8 %) is provided by 
the  EU  MFF  (mostly  through  cohesion  policy),  with  a 
further  1.8 %  from  the  RRF,  reaching  51.6 %  combined. 
The smaller half of the water  financing is provided from 
national sources in Bulgaria (153). 

The gap 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Bulgaria  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 126 million 
additional 
EUR 21 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
EUR 147 million per year, representing 0.17 % of Bulgaria 
GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 33 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 93 million constitutes further investment need to 
unlock Bulgaria’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 0.7 billion (in 2022 prices) in Bulgaria. This comprises 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Bulgaria’s water investment gap reaches EUR 439 million 
per year (0.52 % of GDP), with EUR 239 million per year for 
wastewater  measures.  Drinking  water  measures  require 
an  additional  EUR 31 million  per  year  and  the  other 
aspects  of  the  Water  Framework  Directive  around 
EUR 167 million  per  year  over  the  existing  levels  of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 1.8 billion per year (in 2022 prices) in 
Bulgaria 
includes  the  following 
financing needs: 

in  2021–2027.  This 

(150)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

(151)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(152)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
28 May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(153)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 

2025 Environmental Implementation Review – Bulgaria 

 
 
•  Bulgaria’s 

action 

prioritised 

framework (154), 
concerning  the  Natura  2000  areas:  EUR 102 million 
per year, mostly running costs; 
additional BDS costs (155): EUR 1.2 billion per year on 
top of the framework; 
sustainable 
EUR 0.5 billion per year. 

management 

costs (156): 

soil 

• 

• 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 332 million per year (in 2022 prices) in 2021–2027. 
62 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

22.4 % of the total financing is estimated to come from EU 
cohesion  policy,  58 %  from  CAP  and  9.5 %  from  Horizon 
Europe. The EU MFF altogether accounts for 95 % of the 
financing  and  the  RRF  for  0.6 %,  adding  up  to  a  total  of 
96 %  from  the  EU  budget.  The  rest,  4 %,  comes  from 
national sources.157 

At  0.3 %,  Bulgaria  has  a  very  low  share  of  RRF  funding 
for  biodiversity 
dedicated  to  supporting  measures 
compared  with  other  Member 
States.  Bulgaria 
programmed 18.9 % of its CAP budget for 2021–2027 for 
biodiversity,  which  is  around  the  EU  average.  Lastly, 
10.4 %  of  Bulgaria’s  cohesion  policy  EU  contribution  is 
estimated  to  contribute  to  biodiversity  (disregarding 
ESF+), which is above the EU average (see Figure 31). 

Figure 31: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

(154)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

Commission 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

European 

(155)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(156)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
COM(2023) 416 
2023, 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 
in 

(157)  Based  on  biodiversity 

EU  budget 

tracking 

5 July 

final 

the 

of 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-

Bulgaria  42 

NB: ESF+, European Social Fund Plus. 

The gap 
To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Bulgaria’s 
investment gap is estimated to be EUR 1.4 billion per year, 
corresponding to 1.7 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States  already  use  green  budgeting  tools  for  identifying 
and  tracking  green  expenditures  and/or  revenues (158). 
Green budgeting practices provide increased transparency 
on the environmental implications of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (159). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021  to  2024 (160).  Bulgaria  participated,  developing  and 
testing green budgeting practices at national level. 

6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(158)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

2023, 

(159)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(160)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Bulgaria  43 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (161),  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According  to  a  2024  study (163),  Bulgaria  does  not  apply 
environmental  taxes  to  discourage  environmentally 
harmful activities and behaviours. 

Green taxation and tax reform 

Green bonds and sustainable bonds 

formed  the 

Total environmental taxes amounted to EUR 4.1 billion in 
Bulgaria  in  2022,  representing  4.8 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 4.5 % 
of GDP, which is significantly higher than the EU average 
of  1.6 %.  Transport  taxes,  at  0.25 %  of  GDP,  were  lower 
than  the  EU  average  (0.4 %),  as  were  taxes  on  pollution 
and  resources,  at  0.03 %  (EU  average:  0.08 %).  In  2022, 
environmental  taxes  in  Bulgaria  accounted  for  15.3 %  of 
total revenues from taxes and social security contributions 
(well above the EU average of 5.0 %) (162). 

Figure 32: Environmental taxes per Member State, 2022 

In  2023,  the  total  value  of  the  green  bonds  issued  by 
Member States  was USD 245 billion (EUR 227 billion),  up 
from USD 234 billion (EUR 198 billion) in 2021 (164). 

During 2021–2023, Bulgaria did not issue green bonds. 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  those  issued  by  supranational  entities)  was 
issued  by  financial  corporates,  29.1 %  by  sovereign 
governments  and  23.1 %  by  non-financial  corporates. 
8.3 % of the issuances was linked to government-backed 
entities, 6.4 % to developments banks and 1.4 % to local 
governments. 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-

(161)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), 
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

(162)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(163)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 

https://op.europa.eu/en/publication-detail/-
Annex 2, 
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(164)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
Figure 33: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

Bulgaria  44 

In  Bulgaria,  the  energy  subsidies  have  decreased  since 
2017.  As  part  of  this,  however,  FFS  slightly  increased, 
reaching EUR 0.8 billion in 2020. In 2021, FFS dropped to 
EUR 0.4 billion, but showed signs of recovery in 2023 (to 
EUR 1 billion). 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to  less  than  0.1 %  in  Denmark  and  Sweden.  Bulgaria’s 
value reached 0.6 %, below the EU average (0.8 %) (168). 

Figure 34:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
action  programme  objectives  and 
the  enabling 
conditions (165). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (166). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (167). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

(165)  Article 3(h) and 3(v) of the eighth environment action programme. 
(166)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

Union, 

NB: RES, renewable energy source. 

Source : analysis of Directorate-General Energy 

The overall environmental investment gap is around 2.9 % 
of GDP (well above the EU average), with almost 60 % of 
the identified investment needs unmet (i.e. constituting a 
gap). 

2025 priority action 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(167)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

(168)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

Union, 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
 
 
 
 
 
Bulgaria  45 

6. Environmental governance

Information, public participation and access to 
justice 

Table 3:  Bulgaria  dashboard  on  implementation  of  the 
Inspire Directive, 2016–2023 

2016 

2023 

Legend 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (169).  Public 
is 
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 environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (170).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (171). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
infrastructure  for  spatial  information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
information  between  public 
environmental  spatial 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

Effective coordination and data sharing 

Ensure 
coordination  

effective 

Data 
without obstacle  

sharing 

■ 

■ 

INSPIRE performance indicators 

i.  Conformity  of 
metadata 

ii.  Conformity  of 
spatial data sets172 

iii.  Accessibility  of 
spatial  data  sets 
through  view  and 
download services 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

iv.  Conformity  of 
network services 

■ 

■ 

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

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

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

Source:  European  Commission,  ‘Bulgaria’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/bulgaria_en 

2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(171)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

172 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. 

(169)  The 

Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
Inspire 
content/EN/TXT/?uri=CELEX:32003L0004) 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(170)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
  
 
Inspire 
Bulgaria’s  performance 
Directive  has  been  reviewed  based  on  its  2023  country 
fiche (173) (see Table 3) and shows some progress. 

implementing  the 

in 

infringement  procedure 
Bulgaria  was  subject  to  an 
regarding  the  Inspire  Directive.  In  2022,  Bulgaria  also 
received a priority action on the need to improve access 
to spatial data and services. It  has made some progress, 
but  implementation  levels  are  still  limited.  More  efforts 
are  needed  regarding  the  Inspire  Directive  to  make  the 
data more widely accessible. Public participation 

Public  involvement  at both the planning and the project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (174) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (175). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and  continues to support the 
Member  States  in  this  regard  (176).  Bulgaria  has  already 
taken 
to  accelerate  permit-issuing 
procedures  taking  advantage  of  the  broad  flexibilities 

steps  aiming 

(173)  European  Commission, 

‘Bulgaria’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/bulgaria_en. 
(174)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(175)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 
 Commission Staff Working Document  (SWD/2022/0149 final), 18 
May 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

2022, 

(176) 

  Bulgaria  46 

legal  framework,  such  as  the 
offered  by  the  EU 
establishment  of  one-stop  shops  and  accelerated  short 
deadlines  for 
issuing  permits  for  renewable  energy 
projects. 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  the  maximum  duration  of 
75.7 months (177).  In  Bulgaria,  the  average 
is 
13 months, excluding the development consent stage. The 
duration  of  each  step  in  an  EIA  process  (screening, 
scoping,  EIA  report,  public  consultation,  reasoned 
conclusion,  development  consent)  varies  considerably 
between Member States and projects. Effective use of EU 
procedures can positively influence the timely approval of 
activities  underpinning  the  decarbonisation  of  the 
economy on the way to net zero by 2050. 

length 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (178). 

EIA  and  SEA (179)  procedures  and  the  possibility  for  the 
public  to  submit  views  regarding  plans  or  projects  that 
require  such  procedures  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)  provide  well-developed  and 
updated  information  on  SEA/EIA  procedures  on  their 
websites. The  information published covers notifications 
for investment proposals (planned projects), information 
on assessing the need for an EIA or SEA, information for 
forthcoming public consultations on EIA reports (and the 
itself)  or  environmental  assessment 
EIA 
consultations, EIA decisions (or refusals), SEA opinions (or 
refusals), transboundary EIA / environmental assessment 
procedures  and  public  registers  on  EIA/SEA.  Since  the 
2022  EIR,  Bulgaria  has  improved  public  participation  by 
amending  its  Environmental  Protection  Act  to  introduce 
the requirement for the competent authorities to inform 
the public of the nature of the possible decisions, and to 
announce  the  draft  EIA  decisions  no  later  than  three 

reports 

Impact  Assessment 

(177)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(178)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

(179)  Bulgarian  law  uses  the  notion  of  ‘environmental  assessment’  as 

equivalent to that of SEA. 

2025 Environmental Implementation Review – Bulgaria 

 
 
  Bulgaria  47 

working  days  prior  to  the  meeting  of  the  relevant 
authority for their adoption. 

act, or for whom such an act gives rise to obligations, have 
the right to challenge the act. 

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

Statistics  on  the  level  of  public  participation  in  decision-
making processes including authorisations are available in 
the  national  reports  on  the  state  and  protection  of  the 
environment  in  the  Bulgaria  (available  on  the  Executive 
Environmental  Agency  website) (180)  and  the  Ministry  of 
Environment and Water reports (181). 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As mentioned in the 2022 EIR, Bulgarian legislation grants 
standing to interested persons (environmental NGOs and 
physical  persons)  to  bring  to  court  both  measures  of  a 
general  nature,  such  as  protected  area  management 
plans, and certain regulatory acts issued by the executive 
authorities. 

The  normative  acts  (by-laws)  issued  by  the  executive 
authorities can be challenged (articles 185–196). Citizens, 
organisations and bodies whose rights, freedoms or legal 
interests are affected, or may be affected, by a normative 

(180)  http://eea.government.bg/bg/dokladi. 
(181)  https://www.moew.government.bg/bg/otchet-za-izpulnenieto-
na-byudjeta-po-politiki-i-programi-za-2020-g-na-mosv/. 

(182)  Confirmed  by  Supreme  Administrative  Court  Order  No 552  of 
24 January 
(https://info-
2022 
adc.justice.bg/courts/portal/edis.nsf/e_act.xsp?id=1765866&cod
e=vas&guid=2130851112). 

The  Spatial  Development  Act  (SDA)  introduces  a  limited 
possibility for legal review (Article 127 (12) and (13) of the 
SDA),  granting  standing  to  owners  of  estates  directly 
affected by  a plan. These estates are defined as  plots in 
which the plan envisages either the construction of public 
infrastructure or the restriction of  the owner’s rights for 
public 
interests  related  to  the  protection  of  the 
environment  and  of  human  health,  or  the  protection  of 
agricultural areas, forest areas, protected areas and SACs. 
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 
environmental  NGOs,  but  only  by  owners,  holders  of 
limited property rights and concessionaires of the plot or 
of  the  neighbouring  real  estate  regulated  or  directly 
affected  by  the  detailed  spatial  plan  (Article 131  of  the 
SDA).  At  the  moment,  the  prevailing  case-law  on  the 
matter  is  that  only  environmental  NGOs  registered  with 
public  interest  have  a  right  to  appeal  in  environmental 
cases. 

To grant standing to the interested public within the scope 
of EIAs, 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 
has not been 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 Act (182). This practice goes against the settled 
case-law of the Court of Justice of the European Union (183) 
and 
infringement  proceedings  by  the 
Commission (184). 

is  subject  to 

If  an  act  is  adopted  in  the  form  of  a  law  (normative 
instrument),  the  only  possibility  for  the  direct  judicial 
review of the act  is before the Constitutional Court, and 
only  specific  subjects  (one  fifth  of  the  members  of 
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). 

In the 2022 EIR, Bulgaria received two priority actions in 
this  area:  (i)  to  improve  access  to  courts  by  the  public 
concerned when it comes to challenging administrative or 

(183)  Commission notice on access to justice in environmental matters 

(2017/C 275/01) (OJ C 275, 18.8.2017, p. 1). 

(184)  Commission notice on access to justice in environmental matters 
(2017/C  275/01)  (OJ  C 275,  18.8.2017,  p. 1).  See  infringement 
proceeding INFR(2020)2106. 

2025 Environmental Implementation Review – Bulgaria 

 
 
regulatory decisions and omission; and (ii) to better inform 
the  public  about  their  right  to  access  to  justice.  Some 
progress  has  been  made  in  terms  of  access  to  justice  as 
regards general spatial plans. No progress has been made 
in the area of access to justice on air pollution. No progress 
has been made in better informing the public of their right 
to access to justice. 

2025 priority actions 

spatial  datasets 

•  Make  spatial  data  more  widely  accessible  and 
prioritise  environmental  datasets  in  implementing 
the  Inspire  Directive,  especially  those  identified  as 
implementing 
high-value 
environmental legislation. 
Improve  access  to  courts  in  national  environmental 
cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive 
costs in some Member States. 

for 

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (185) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 
Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools. 

In  November  2023,  a  regional  conference  dedicated  to 
strengthening  the  fight  against  crime  affecting  the 
environment  was  held,  which  representatives  from 
Albania,  Bosnia  and  Herzegovina,  Bulgaria,  Croatia, 

(185)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission 
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

  Bulgaria  48 

France, Greece, Kosovo, Montenegro, North Macedonia, 
Serbia,  Slovakia,  Slovenia,  Poland  and  Romania 
attended(186). 

It appears that the environmental compliance assurance 
system  in  Bulgaria  would  benefit  from  providing  more 
inspections  and 
human  and  financial  resources  to 
enforcement  authorities  and 
from  more  active 
participation  in  the  work  of  the  EU  Network  for  the 
Implementation and Enforcement of Environmental Law. 
Completion of a more detailed assessment of compliance 
assurance activities will be an aim for a future EIR. 

The 2022 EIR recommended that Bulgaria should (i) make 
a  structured  and  centralised  online  information  point 
available for farmers and other duty-holders covering how 
to  comply  with  their  obligations  under  the  Nitrates  and 
Nature  Directives;  (ii)  encourage  public  participation  in 
enforcement through  awareness-raising activities on the 
options for reporting environmental problems, and more 
generally  establish active plans for making use of citizen 
science; and (iii) make information and statistics available 
on the prosecution of environmental crimes and  provide 
information  on  formal  arrangements  for  cooperation 
among responsible public bodies. Concerning compliance 
promotion,  monitoring,  and  criminal  and  administrative 
enforcement,  the  2022  priority  actions  are  not  assessed 
here due to lack of systematic information. Similarly, the 
Commission is not aware of whether information is easily 
available online at the national level for farmers regarding 
compliance with the  Nitrates and Nature  Directives, and 
hence the related 2022 priority action is not assessed. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203)(187) and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
measures  are  put 
in  place  and  more  systematic 
information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 

(186) 

(187) 

https://www.selec.org/strengthening-the-fight-against-crimes-

that-affect-the-environment-in-southeast-europe/ 
 Directive  2024/1203/EU  on  the  protection  of  the  environment 
through 
(https://eur-
law 
lex.europa.eu/eli/dir/2024/1203/oj/eng), 

criminal 

2025 Environmental Implementation Review – Bulgaria 

 
 
legislation  on  chemicals,  mercury, 
breaches  of  EU 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

including  by 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
crime, 
in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
invited  to 
specialised  skills  required  and  they  are 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (188),  EnviCrimeNet (189),  the  European  Network  of 
Prosecutors for the Environment (190) and the EU Forum of 
Judges  for  the  Environment (191).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)  (192)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 

(188)  https://www.impel.eu/en. 
(189) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(190)  https://www.environmentalprosecutors.eu. 
(191)  https://www.eufje.org/index.php?lang=en. 
(192)  Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage (https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626).  

  Bulgaria  49 

quality of  groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

indicators 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (193), which will be finalised in 2025, and which 
was  supported  by  an  external  study (194),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 
One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some  of  which  may  have  been  handled under  the  other 
liability instruments. 
The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
financial  security 
encourage 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 
From  1 May  2013  to  31 March  2022,  Bulgaria  reported 
one occurrence of an imminent  threat of  environmental 
damage 
(water  damage)  and  two  occurrences  of 
environmental damage under the ELD (one land/soil and 
water  damage  case  and  one  water  and  biodiversity 
damage case). Bulgaria also reported one non-ELD case of 
biodiversity  damage.  In  the  previous  reporting  period, 

the  development  of 

(193)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(194)  European Commission: Directorate-General for Environment and 
in  support  of  the  evaluation  of  the 
Fogleman,  V.,  Study 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
there  were  four  confirmed  occurrences  of  imminent 
threat. 

reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

  Bulgaria  50 

Insurance  for  liabilities  is  covered  by  the  Bulgarian  Civil 
insurance  policies  have  been 
Code.  To  date,  138 
submitted  to  the  Ministry  of  Environment  and  Water. 
Bulgaria has not introduced a mandatory financial security 
system  for  ex  ante  ELD  liabilities  but  has  introduced  a 
scheme  in  which  operators  can  submit  evidence  of 
insurance to the Ministry of Environment and Water, the 
competent authority for the ELD. If this has been done, the 
operator  avoids  the  need  to  provide  ex  post  financial 
ELD-related  occurrences.  Concerning 
security 
compliance  promotion,  monitoring,  and  criminal  and 
administrative enforcement, as well as the ELD, the 2022 
priority  actions  are  not  assessed  here  due  to  a  lack  of 
systematic information. 

in 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interactions  with  the 
other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 
expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (195) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (196)  and  the  TAIEX-EIR  PEER  2 
PEER tool (197). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 
The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation  of 

(195)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(196)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(197)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 

tool 

The Commission’s TSI had annual calls in 2021, 2022, 2023 
,2024  and  2025.  The  following  environment-related 
projects have been selected for Bulgaria: 

•  Creation 

and 

implementation  of 

regulatory 
mechanisms  for  the  natural  gas  market  in  Bulgaria 
from  the  Energy  and  Water  Regulatory  Commission 
(2023); 
Strategy  for  the  development  of  entrepreneurship, 
innovation  and  digitisation  in  Stara  Zagora  and  a 
the 
its 
roadmap 
municipality of Stara Zagora (2023); 
ESG (198)  risk  management 
for  the 
financial  sector  from  the  Financial  Supervision 
Commission (2023); 

implementation 

framework 

from 

for 

• 

• 

•  Development of legal framework for fully fledged and 
comprehensive regional green hydrogen market from 
the Ministry of Energy (2024); 

•  Building a  resilient  innovation  ecosystem in Bulgaria 

• 

• 

from the Ministry of Innovation and Growth (2024); 
Improving  the  competence  and  skills  of  FMFIB  in 
sustainable finance and implementation of green and 
digital financial instruments from the  Fund Manager 
of Financial Instruments in Bulgaria (2024); 
Enhancing  the  centre  of  government’s  capacities  to 
steer  complex  priorities  and  manage  crisis  and 
review  and 
through  peer-to-peer 
megatrends 
learning  from  the  administration  of  the  Council  of 
Ministers (2024). 

•  Action  plans  for  sustainable  forest  management  in 
Bulgaria from the Executive Forest Agency (2025). 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country).  Flagship 
events are those requested by the Commission to present 
new and upcoming environmental legislation and policy in 
all Member States (199). 

governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 
(198) 
‘ESG’ here means ‘environmental, social and governance’. 
(199)  Flagship  multi-country  workshops  in  the  reporting  period  are:  
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
  Bulgaria  51 

Workshops involving Bulgaria are as follows:  

• 

Future challenges in the air protection in Europe with 
the Czech EU presidency (24 November 2022); 

•  Decentralised  bio-waste  recycling 

in  Austria  (9–

10 October 2023); 

•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024). 
Freight  transport  by  rail  (in  relation  to  waste 
transport) (17 - 18 March 2025). 

• 

Bulgaria also hosted an expert mission on dune protection 
(28–29 February 2024). 

2025 priority action 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

with climate change and decarbonation  (12 December 2024); Air 
further 
implementation  of  the  NEC  Directive  to 
quality: 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25  September  2024);  Industrial  emissions  transposition 
and implementation of the revised Directive (12 September 2024); 
Noise progress towards meeting Member States’ noise limit value 
and  EU  reduction  targets  (5  June  2024);  Best  practice  use  of 
environmental  footprint  methods  on  the  EU  market  (30  May 
2024);  Sustainable  finance  (9  November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 

environmental  funding  and  support  (13  June  2023);  Advisory 
service  for    businesses  to  go  circular  (24  April  2023);  Digital 
product  passport  implementation  (6  December  2022);  Public 
involvement  in  planning  and  approval  of  renewable  energy 
projects  (17  November  2022);  Environmental  compliance  and 
governance  (14  November  2022); Biowaste  management  (19-20 
September 2022); Renewable energy projects: permitting granting 
processes (13 June 2022). N.B. the first flagship workshop on Zero 
Pollution for Air, Water and Soil, took place 9 February 2022. 

2025 Environmental Implementation Review – Bulgaria 

 
 
 
 
  Bulgaria  52 

Annex 
2025 priority actions     
Circular economy and waste management   
Transitioning to a circular economy   

• 

• 
• 

• 

• 
• 
• 

• 

• 

• 

• 

• 

• 

• 
• 

• 

 Adopt measures to increase the circular material use.   

Waste management   

Ratify international conventions on ship recycling.  
Increase reuse of products and scale up waste recycling infrastructure associated with the higher steps of the 
waste hierarchy. In particular, improve collection and increase treatment capacity for bio-waste.  
Increase reuse of products and scale up waste recycling infrastructure associated with the higher steps of the 
waste hierarchy. In particular, improve collection and increase treatment capacity for bio-waste.  
Improve municipal waste preparation for reuse and recycling.  
Invest in waste prevention measures to reduce the total amount of waste generated.  
Ensure the achievement of the 2025 waste targets, following the recommendations made by the Commission in 
the Early Warning Reports where applicable. 

Biodiversity and natural capital   
Global and EU biodiversity frameworks    

Submit to the CBD an updated NBSAP or national targets following the adoption of the Kunming-Montreal Global 
Biodiversity Framework.  

Nature protection and restoration – Natura 2000   

Finalise  the  establishment  of  site-specific  conservation  objectives  and  measures  for  all  Natura  2000  sites 
(including by adopting their management plans) and ensure their effective implementation.  
Ensure the effective implementation of Natura 2000 management plans and sufficient administrative capacity and 
financing  both  for  Natura  2000  and  the  implementation  of  the  Nature  Restoration  Regulation.  Ensure 
implementation of Prioritised Actions Framework 2021-2027 (PAFs). 

Recovery of species    

Reinforce action for habitats and species in unfavourable conservation status, for example through restoration 
measures, increased connectivity, better policy coordination and integration, and increased funding.  
Recovery of ecosystems   

Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of 
Bulgaria.  
Implement and scale-up the uptake of organic farming practices. 
Marine ecosystems   

Report Bulgaria’s programme of measures, as required under Article 13 of the MSFD.  
Report updates on the assessment of the state of Bulgaria’s marine waters, its target and its determinations of 
GES, which are expected to include any threshold values for the descriptors in the MSFD that may have been 
established in cooperation with other Member States at the EU or regional level. 

Prevention and management of invasive alien species    

Step up implementation of the IAS Regulation, including with regard to enforcement and capacity of  inspection 
authorities. 

Ecosystem assessment and accounting    

• 

Support the development of the national business and biodiversity network. 

Zero pollution   
Clean air   

• 
• 

• 

• 

As part of the NAPCP, take action to reduce emissions of air pollutants.  
Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under the 
revised AAQD.  
Accelerate the ratification of relevant international conventions and protocols. 

Reduce industrial air pollution damage and intensity.  

Industrial emissions   

2025 Environmental Implementation Review – Bulgaria 

 
  
  Bulgaria  53 

• 
• 

• 

• 
• 

Reduce industrial releases to water, and their intensity.  
Engage  with  industry  and  environmental  NGOs  to  ensure  proper  contribution  to  and  implementation  of  BAT 
conclusions and ensure timely updates to permits following the publication of BAT conclusions.  
Ensure effective public participation and access to justice in relation to the IED.  

Complete noise mapping.  
Complete and implement action plans on noise management. 

Water quality and management   

Noise   

Drinking Water Directive    

• 

Take action to ensure full compliance with the Drinking Water Directive.  

Nitrates Directive    

• 

Tackle  nutrient  pollution,  especially  nitrates  from  agriculture,  through  the  implementation  of  the  Nitrates 
Directive.  

Urban Wastewater Treatment Directive    

• 

• 

• 

• 

• 

• 

Take the necessary measures to ensure full implementation of the current urban wastewater treatment directive, 
taking into account the new requirements of the recast directive. 

Chemicals   

Upgrade the administrative capacities in implementation and enforcement to move towards a policy of zero 
tolerance of non-compliance.  
Increase  involvement  in  the  activities  of  the  Forum  for  Exchange  of  Information  on  Enforcement  of  the 
European Chemicals Agency, including in the coordinated enforcement projects, called REF projects.  
Increase  customs  checks  and  checks  of  products  sold  online  with  regard  to  compliance  with  chemicals 
legislation. 

Climate action   

Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing Regulation 
(ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed priority actions 
are set out in the assessment of the final National Energy and Climate Plan (NECP). 

Financing   

Use  more  national  funding  (for  instance  by  increasing  taxes  in  favour  of  the  environment  and  reducing 
environmentally harmful subsidies), EU funding and private funding to help close the investment gap.   
Environmental governance   

Information, public participation and access to justice    

• 

• 

Make  spatial  data  more  widely  accessible  and  prioritise  environmental  datasets  in  implementing  the  Inspire 
Directive, especially those identified as high-value spatial datasets for implementing environmental legislation.  
Improve  access  to  courts  in  national  environmental  cases  by  the  public  concerned  and  eliminate  practical 
barriers, such as length of proceedings and excessive costs in some Member States.  

Environmental liability directive    

• 

Encourage  the  use  of  training  programmes  provided  by  the  Commission  (or  developed  at  the  national  level) 
covering the ELD and its interactions with the other national liability-related instruments, to ensure more efficient 
ELD  implementation,  improve  the  expertise  of  the  competent  authorities  and  raise  awareness  among  all 
stakeholder groups.  

EU-supported environmental capacity building   

• 

Improve  overall  national environmental  governance,  in  particular  administrative  capacity  to  support  the green 
transition and coordination at the regional and local levels. 

2025 Environmental Implementation Review – Bulgaria