TO
THE PRIME MINISTER OF THE REPUBLIC OF BULGARIA
THE MINISTER OF ENVIRONMENT AND WATER
THE MINISTER OF ENERGY
THE MINISTER OF ECONOMY AND INDUSTRY
THE MINISTER OF INNOVATION AND GROWTH
THE MINISTER OF FINANCE THE MASS MEDIA
OPEN LETTER
REGARDING: Transparency in Extended Producer Responsibility (EPR) systems and the introduction of a deposit return system for beverage containers
The undersigned representatives of leading employers and industry organizations, representing producers, importers, retailers, and recycling enterprises in Bulgaria, insist on the urgent initiation of an inter-institutional dialogue regarding the accumulated systemic problems in the waste management sector.
The occasion for this request is the discussion forum "Transparency in Extended Producer Responsibility (EPR)", held on March 10, 2026, at the Bulgarian Industrial Association (BIA), which clearly outlined a number of serious challenges facing businesses. These challenges stem from the lack of transparency, predictability, and effective dialogue in shaping the state policy for sustainable environmental management and EPR across various industries.
The EPR system manages significant financial resources generated through license fees paid to recovery organizations by producers and importers of all types of goods (the obligated entities). It is no longer a surprise to anyone that the current operational model of the EPR system and the activities of the recovery organizations do not ensure sufficient transparency and efficiency. Even though these organizations operate with financial resources collected from end consumers and designated for achieving a public environmental goal, and by law have no right to distribute profit, access to information regarding the fulfillment of targets, as well as to their financial reports and statements, remains limited.
There is also a lack of clarity regarding how the collected license fees are formed and spent, and how they genuinely support the recycling industry and the achievement of the environmental targets set in the legislation. This compromises the fundamental principle of EPR – that obligated entities should exercise control and provide incentives for economic efficiency. The practice of non-transparent and selective issuance of permits to recovery organizations for specific economic operators in the respective market sector creates preconditions for corrupt practices and encourages non-market behavior.
The existing vicious practices in the EPR system lead to an unjustified increase in the license fees paid by the obligated entities, which reflects on the final value of their production, respectively – increases the prices paid by consumers. At the same time, this is not met with good management of widespread waste.
There are increasing examples of unjustified, significant, and pervasive increases in all license fees, including for motor vehicles, electrical and electronic equipment, batteries and accumulators, and solar panels – notably, from all recovery organizations. This raises reasonable suspicions of anti-competitive agreements and coordinated non-market practices. Similarly, without any public consultation and amidst suspicions of corrupt pressure, attempts were made to introduce a state-owned deposit return system for beverage containers – a reform of national significance, scale, and impact, affecting hundreds of manufacturing enterprises, tens of thousands of retail outlets, and all consumers in the country.
All this leads to a significant and inevitable increase in consumer prices and additional inflationary pressure. Therefore, we urgently call upon the caretaker government, including the Ministry of Environment and Water, the Ministry of Economy and Industry, the Ministry of Energy, the Ministry of Finance, and the Ministry of Innovation and Growth, to take immediate anti-crisis actions:
We are convinced that an open and constructive dialogue between institutions and businesses is crucial for the effective implementation of circular economy principles, for creating a transparent and competitive business environment, and for preventing unfair and coordinated practices that increase the prices of various goods to the detriment of consumers and generate inflationary pressure. We believe that circular economy goals are achieved not only through regulatory requirements but through predictability of rules, strategic planning, transparent financing, innovation, and cost-effectiveness. In this context, we are confident that with the decisive role of the institutions, coordinated and workable solutions can be achieved both for environmental protection and for defending the interests of citizens and economic operators in the country.
SIGNATORIES:
Bulgarian Industrial Association (BIA)
Active Consumers
Association for Production, Storage and Trading of Electricity (APSTE)
Association of Car Importers (ACI)
Association of Soft Drink Manufacturers in Bulgaria (BSDMA)
Association of Manufacturers of Domestic Appliances in Bulgaria (APPLiA Bulgaria)
Association of Producers, Importers, Traders and Vulcanizers of Tires
Recycling Industry Association (RIA)
Branch Association Polymers (BAP)
Bulgarian Association Circular Textile (BACT)
Bulgarian Association of Electrical Engineering and Electronics (BASEL)
Bulgarian Association of the Metallurgical Industry (BAMI)
Bulgarian Photovoltaic Association (BPVA)
Association for Modern Trade (AMT)
Union of International Haulers (UIH)
Union of Brewers in Bulgaria (UBB)
