EPR in Bulgaria: NISO, Ecopack or the Product Fee

Every business placing packaging on the Bulgarian market either joins a licensed recovery organisation and pays a per-material fee, or opts for individual compliance and pays a product fee direct to the state. Both routes run through the same national registry, and the second one usually costs more.

If you sell packaged goods to consumers in Bulgaria, the practical question is not whether you owe an Extended Producer Responsibility fee - you almost certainly do - but which of those two routes you take to pay it. That fork, and the registry behind it, is what a cross-border seller needs to understand before shipping into the country.

The fork: recovery organisation or the state product fee

Bulgarian packaging law, the Waste Management Act (ZUO) that entered into force in July 2012, hands producers a binary choice. The first route is collective: you sign a membership contract with an approved recovery organisation - a producer responsibility organisation such as Ecopack - and transfer your operational recycling obligations to it. You declare the exact mass and material composition of the packaging you place on the market, and the organisation invoices you a fee that varies by material, so paper and cardboard are priced differently from plastics or metals.

The second route is individual compliance. Here you meet the recycling duty yourself and pay a product fee straight to the state. This is the fallback the law keeps in place for producers who do not affiliate with a collective scheme, and it is generally the more expensive of the two - the reason the overwhelming majority of sellers choose the recovery-organisation route.

For a distance seller shipping variable volumes into Bulgaria, the collective route also removes the burden of proving individual recovery, which is why it is the default recommendation for e-commerce. Working out which EPR duties apply to your business is the step that precedes either choice.

NISO and the ExEA: one system for most streams

Both Bulgarian compliance routes report through a single piece of infrastructure. The National Waste Information System (NISO) is the central digital registry, live since 1 January 2021, and it is operated by the Executive Environment Agency (ExEA), Bulgaria's competent authority for waste. Filing into NISO is typically done with a qualified electronic signature. You can reach the system through the Bulgarian National Waste Information System portal.

NISO is not packaging-only. It holds the producer registers for most of Bulgaria's Extended Producer Responsibility streams, and if your catalogue spans product types you may need to register in several of them.

Electronics fall under the WEEE Directive 2012/19/EU on electrical equipment, in force since July 2012; any item with a plug, a battery or a power cord pulls you into this stream. Single-use plastic items - food containers, cups, lightweight carrier bags - are regulated under the Single-Use Plastics Directive (EU) 2019/904, which has applied in Bulgaria since July 2021. End-of-life vehicle duties have run since 2000, and Bulgaria operates long-standing national schemes for tyres (in place since 2012) and for waste oils. Producer duties for fishing gear containing plastics, also under the SUP Directive, are still being brought in.

Batteries deserve a specific note. Bulgaria has regulated batteries through a national ordinance since 2013, and battery producers register this stream in NISO separately from packaging or WEEE. The EU Batteries Regulation (EU) 2023/1542 has applied across the Union since 18 August 2025. Whether Bulgaria's national battery ordinance has been fully aligned to that regulation is not confirmed on an official source, so producers should treat the existing national regime as the operative one and watch for an updated ordinance.

Bulgaria runs no national EPR scheme for furniture, graphic paper, toys, DIY and garden equipment, sports goods, construction materials or recreational boats; if you sell those, you owe fees only on their packaging.

The ExEA representative cross-border sellers underestimate

The obligated party is whoever first places a product on the Bulgarian market. You do not have to manufacture anything to qualify: importing packaged goods, selling under a private label, or running an online store that ships directly to Bulgarian households from a warehouse abroad all make you a producer under Bulgarian law. Marketplaces including Amazon and eBay increasingly ask third-party sellers for a valid registration number, and a missing one can mean delisted listings, so the registry entry is what protects a seller account as much as it satisfies the regulator.

Bulgaria sets no de minimis threshold for packaging. There is no minimum sales volume below which the duty falls away; the first unit of packaged goods placed on the market triggers it. A seller based outside Bulgaria cannot simply self-certify on NISO. The route in runs through a Bulgarian tax identification number and, for a business without a local entity, an authorised representative established in Bulgaria who completes the registration and files declarations with the ExEA. That representation requirement is the single most common thing cross-border sellers underestimate, and it applies whichever compliance route you pick.

Bulgaria's early footwear-and-textiles register

One Bulgarian feature stands apart from the NISO structure. Bulgaria created a footwear-and-textiles registration duty in 2021, moving ahead of the rest of the EU, and it lives in a separate ExEA register rather than inside NISO. For now it is a registration duty only: the implementing ordinance that would set collection targets and fees has not yet been adopted, so there is no financial scheme to pay into yet.

The textiles duty changes when the revised Waste Framework Directive 2025/1892 brings mandatory textile and footwear EPR into force, with a scheme required by 17 April 2028. Apparel sellers should register in the ExEA producer registers and reference lists now and budget for fees arriving with the full scheme.

Three cost layers, and ExEA fines under the Waste Management Act

Costs split three ways. There are the registration and service costs of getting into NISO and, for foreign sellers, of retaining an authorised representative to hold your credentials and file on your behalf. There are the ongoing environmental fees themselves, set by material weight if you go the recovery-organisation route, or paid as the higher state product fee if you go it alone. And streams beyond packaging - WEEE and batteries in particular - carry their own registrations and, often, their own membership contracts with specialised recovery organisations, so a seller of packaged electronics pays into more than one scheme.

The cost of ignoring the rules is real but has two faces. The ExEA administers the registry and levies administrative fines under the Waste Management Act for non-compliance. Alongside state enforcement, the marketplaces act as day-to-day gatekeepers: without valid NISO registration numbers for your applicable streams, a platform can suspend selling privileges and remove listings, which for most e-commerce sellers is the more immediate commercial risk.

Scaling across the region - whether you are also weighing EPR obligations in Romania or EPR requirements in Greece - rewards getting the Bulgarian representation and registrations in place early. The underlying mechanics are the same Extended Producer Responsibility principle applied through a national registry.

The planned deposit-return system

Bulgaria is developing a national deposit-return system for single-use beverage containers such as plastic bottles and metal cans, introduced to meet the EU's separate-collection targets. It is in the planning phase, and no national launch date is fixed, though the PPWR requires every Member State to operate a deposit-return system for single-use plastic and metal beverage containers up to three litres by 1 January 2029, so the scheme has a firm outer deadline even without a Bulgarian launch date.

The point to hold onto is that a deposit-return system is not Extended Producer Responsibility: once it is live, regulated beverage containers carry a point-of-sale deposit and specific labelling, and they drop out of the household-packaging declarations you file to your recovery organisation. Sellers of beverages should track the launch date separately from their NISO obligations.

Milestones for packaging and EPR in Bulgaria

The Bulgarian picture is a mix of long-standing national law and incoming EU rules.

Mapping your packaging materials, tracking weights across borders, and filing accurately with the ExEA can strain a small team. Rather than manage it in spreadsheets, put your EPR reporting on autopilot to keep filings accurate and marketplace listings live.

Sources:

• Bulgarian National Waste Information System portal
• ExEA producer registers and reference lists
• Directive 2012/19/EU on waste electrical and electronic equipment
• Regulation (EU) 2023/1542 concerning batteries and waste batteries
• Directive (EU) 2019/904 on the reduction of the impact of certain plastic products
• Revised Waste Framework Directive 2025/1892 entering into force