Bulgaria's deposit-return scheme: 34% state stake and the notification standstill

Where it stands

Bulgaria has had a packaging register, recovery organisations and an EPR system for years. The deposit and return system is the piece that is not running. On 7 October 2026 the report's first sentence is that it still does not operate, and no deposit is added at a Bulgarian till (press).

The instrument

A draft amendment to Bulgaria's waste law — the report's own subject tags name the Waste Management Act (Закон за управление на отпадъците). It is reported as the "project on deposits", not as an ordinance (press).

The version now on the table

Notified to the European Commission on 29 September 2026 (press).

What is not yet true

No deposit is charged and the system does not operate. Nothing in the report suggests a start date, and the report gives none (press).

The political yardstick it is held to

In October 2025 the environment minister Manol Genov said the system had to reach "every village, every neighbourhood and small shop" (press).

Not the first draft

The same outlet's related coverage shows a deposit-system bill put out for consultation on 2 May and a consultation deadline on 21 May. No year is shown on those links, and we could not reconcile them with the 29 September 2026 notification — see below.

The notification and the three months

This is the part that decides whether anything happens this year. The report's own description of the mechanism: after notification a three-month period runs in which the European Commission and the other member states may submit comments or a detailed opinion, and during that period the bill cannot be adopted (press).

Those features — prior notification to the Commission, a standstill, the possibility of comments or a detailed opinion — are those of the EU's notification procedure for draft technical regulations, run through the TRIS database. The report describes the mechanism without naming the instrument, so that characterisation is ours, not its.

Start

29 September 2026, the notification date (press).

End

Not stated. The report gives no end date. Three months from 29 September 2026 falls at the end of December 2026, but that is our arithmetic, not a date the source contains, and a detailed opinion would move it.

What the period bars

Adoption. The law cannot be adopted while the period runs, so the system cannot start before it ends — and starting a deposit system needs infrastructure that has not been built yet (press for the bar on adoption).

Why we could not check the record ourselves

The Commission's TRIS search page states that TRIS messages become available ten days after the expiry of a notification's initial standstill period. On 7 October 2026, a notification of 29 September 2026 was therefore not expected to be visible, and we could not open the notified text (press for the notification date).

The operator the draft would create

The change the report leads with is not the deposit but who runs the system. Under the notified version:

Legal form

A joint-stock company (press).

State stake

34% (press).

Management

The Minister of Environment and Water must take part in the operator's management — mandatory, in the report's wording, not an option (press).

Supermajority plus government consent

For part of the decisions: 67% approval in the general assembly together with the prior consent of the Council of Ministers (press).

What 34% means next to 67%

Our reading of the two numbers, not a statement in the report: a 34% stake is on its own enough to block any decision that needs 67%, because the remaining 66% cannot reach it. Whatever those decisions turn out to be, they cannot be taken against the state's vote.

What the report does not say

Who the other 66% would be, what the state contributes for its 34%, or what happens to the operator's revenue. None of that is in the report, and we do not fill it in.

The model that was dropped

The model discussed before this draft provided for an independent legal entity that distributes no profit, with industry holding the leading participation (press). That is the structure the sector had been preparing for, and the notified version replaces it with a state-anchored company.

One EU point sits next to that, and it is worth a pause rather than a conclusion. The Commission's FAQ records that a deposit and return system for single-use plastic beverage bottles and metal containers set up after 11 February 2025 must be non-profit, as set out in the minimum criteria in Annex X, point f of the Regulation (FAQ chapter XX, question 4). The report does not discuss how a member state's 34% stake in a joint-stock company sits with that requirement, and we do not answer the question for it — "non-profit" describes what happens to a surplus, not the legal form, but whether a particular design satisfies Annex X is the Commission's call, not ours.

What is still open

The report is explicit that the operational core is not decided. Treat every item below as a blank in the file.

The deposit amount

Not finally settled (press). No figure is reported, and we print none.

The list of packaging in scope

Not finally settled (press). The report describes the mechanism — a refundable deposit added to the price of a drink in scope, returned when the empty packaging is handed in at a designated place or a vending machine — without giving the boundary.

The cost split

Costs are to be divided between producers and importers, traders and the operator, and part may be reflected in prices (press). The report gives no shares, no rate and no ceiling.

The physical system

The report lists what a working scheme needs: vending machines, return points, transport, warehouses, sorting and control. It says separate collection can deliver a cleaner, more uniform material for recycling and that this apparatus is what it takes (press).

What the Economic and Social Council wants

The ESC insists that the return of packaging be accessible in small settlements too, and that the financial model limit administrative costs and inflationary pressure (press). Both are positions, not text in the draft.

The EU's own pending piece

How separate collection under Art. 50(1) is calculated and reported is to be fixed by an implementing act due by 12 February 2027 (FAQ chapter XIX, question 2). Until it exists, even the 90% figure is measured by a method not yet written.

The EU floor: 90% by 2029

Whatever Bulgaria's draft does, the member state duty is already in the Regulation. The Bulgarian report carries it in one sentence — the European regulation requires member states to achieve separate collection of at least 90% of single-use plastic bottles and metal beverage containers by 2029 (press). The Commission's FAQ is the official version, and it is slightly more demanding than the sentence suggests.

Two targets, not one — by 1 January 2029

"The 90% separate collection targets for single-use plastic beverage bottles and metal beverage containers are two separate collection targets that apply by 1 January 2029." An exemption from having to be part of a deposit-return system would therefore have to be obtained separately for each format (FAQ chapter XX, question 1).

The exemption route — Art. 50(5)

A member state that collected more than 80% of all single-use plastic beverage bottles or metal beverage containers in scope by 2026 may be exempt from setting up a DRS — and must still show the Commission, with concrete measures, how it will reach 90% by 2029 without one (FAQ chapter XX, question 1).

What is out of the DRS but still counted — Art. 50(4)

Single-use plastic beverage bottles and metal containers for milk and milk products, wine and similar products, and spirits are exempt from having to be part of a DRS, but they are included in the calculation of the 90% target, and a member state may include them in its system if it wants (FAQ chapter XX, question 5).

A member state may go further

National DRS rules may go beyond the Article 50 and Annex X minimum, observing the Treaty; glass beverage bottles and beverage cartons are named as formats a member state is encouraged to cover (FAQ chapter XX, question 2). The Bulgarian scope list is therefore a national decision as much as an EU one.

Where the deposit sits

The duty is the member state's. What a seller meets is the deposit charged at the point of sale and the national label on the container — not the collection target itself. The same divide is set out date by date on the PPWR dates desk.

What to prepare now

None of this needs the Bulgarian law to exist yet, and none of it is wasted if the design changes again. If you sell drinks to Bulgarian consumers, EPR already makes you the producer there — see the Bulgaria desk for that side.

1. Write down what is in scope, and keep watching the Bulgarian list

The EU floor is single-use plastic beverage bottles and single-use metal beverage containers. Glass and beverage cartons are optional additions a member state may make (FAQ chapter XX, question 2), and milk, wine and spirits are outside the DRS requirement but counted in the target (question 5). Bulgaria's own list is not fixed (press), so build the list from your own range and mark the uncertain items.

2. Count containers, not only kilograms

A deposit follows the unit returned, not the weight reported. Keep a per-container record by material and volume from your first Bulgarian shipment, alongside the kilogram figures your monthly EPR declaration already needs. Reconstructing units from invoices a year later is the expensive version of this.

3. Plan for a Bulgarian deposit label

DRS labelling is not harmonised in the PPWR: packaging must comply with the DRS label of the member state where it is made available, and a member state may require the harmonised colour label under Art. 12(1), fourth subparagraph (FAQ chapter VIII, question 3). There is nothing to print yet — the label does not exist — but it is a second artwork change sitting behind the 2028 sorting label.

4. Ask who registers and who files

A DRS set up under Art. 50 whose organisational, technical and financial arrangements are comparable to a producer responsibility organisation can register and report on behalf of the producers participating in it for the register under Art. 44(1) (FAQ chapter XX, question 6). Ask the Bulgarian recovery organisation you are joining whether it intends to be that operator, or whether you will hold two relationships.

5. Keep the deposit out of your price

The report says costs will be split between producers and importers, traders and the operator, and that part may be reflected in prices (press). It gives no rate. Plan for a variable per-container line in the scheme contract and keep the deposit separate from your net price in invoicing and bookkeeping, so a future rate change does not rewrite your margin.

6. Watch the clock, not the headlines

The standstill bars adoption; the 1 January 2029 EU target is what makes the file urgent for the state. Neither is a launch date, and the report gives none. The signal to act is the adopted law and the published scope list — not the next round of coverage.

What we could not establish

The notified draft itself

Not available to us. The 34%, the 67%, the ministerial participation, the Council of Ministers consent and the 29 September 2026 notification date all rest on one report, which attributes them to BNR. We could not find the text, and TRIS does not publish a message until ten days after the initial standstill expires.

The end of the standstill

Not stated. The arithmetic pointing at the end of December 2026 is ours, not the source's.

Two related items we could not date

The same outlet links a consultation opening on 2 May and a consultation deadline on 21 May for a deposit-system bill, with no year shown. We have not used them, and we cannot say whether they describe an earlier version of this draft or a different bill.

The deposit, the scope and the money

All open in the report, and none of them invented here: deposit amount, full list of packaging, and the shares of the cost split.

Whether the corporate design fits the EU minimum criteria

The Annex X non-profit criterion (FAQ chapter XX, question 4) applied to a joint-stock company with a 34% state stake is a question for the Commission, and the report does not raise it.

Sources

One press report carries the whole Bulgarian side; the EU side comes from the Regulation as explained by the Commission's own FAQ. Where a sentence rests only on the press it is marked press, and nothing in this note should be quoted at an authority as Bulgarian law — the law does not exist yet.

1. Ruse news — Проектът за депозитите предвижда 34% държавно участие Bulgarian media, 7 October 2026, Martin Blagov, citing Българско национално радио (BNR). Read in full. The sole source, marked press, for: the deposit-return system still not operating; the notified version providing for the operator to be a joint-stock company with 34% state participation, notified on 29 September; the environment minister having to take part in its management; 67% general-assembly approval and prior Council of Ministers consent for part of the decisions; the earlier model of an independent legal entity without profit distribution and with leading participation by industry; the refundable deposit added to the price of an in-scope drink and returned on handing in the empty packaging at a designated place or vending machine; the deposit amount and full list of packaging not being finally settled; the need for vending machines, points, transport, warehouses, sorting and control; the cost split between producers and importers, traders and the operator with part possibly reflected in prices; the Economic and Social Council's insistence on accessibility in small settlements and on a financial model that limits administrative costs and inflationary pressure; environment minister Manol Genov's October 2025 statement that the system must reach "every village, every neighbourhood and small shop"; the 90% separate collection requirement for 2029; and the three-month period after notification during which the bill cannot be adopted. Its subject tags name the Waste Management Act. It gives no start date, no deposit amount and no end date for the three-month period
2. European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official: DG ENV Unit B01, and the PDF is mirrored here; a description of the document is on the note about it. Read for this page: chapter XX, question 1 (the 90% targets for single-use plastic beverage bottles and metal beverage containers are two separate targets applying by 1 January 2029, and the exemption route in Article 50(5) requires more than 80% collection in 2026); question 2 (member states may go beyond the Article 50 and Annex X minimum, with glass bottles and beverage cartons named); question 4 (a DRS set up after 11 February 2025 must be non-profit, Annex X, point f); question 5 (milk, wine and spirits exempt from DRS participation but counted in the target); question 6 (a DRS with PRO-comparable arrangements may register and report on behalf of participating producers under Article 44(1)). Also chapter XIX, question 2 (the implementing act on calculating and reporting separate collection under Article 50(1), due by 12 February 2027) and chapter VIII, question 3 (DRS labelling is not harmonised; packaging must carry the DRS label of the member state where it is made available). It states in its own disclaimer that it reflects the views only of its authors and is not binding law
3. Regulation (EU) 2025/40 (PPWR) — EUR-Lex The governing text, read here through the Commission's FAQ for the figures above, and read directly for the PPWR dates desk, where Art. 50(1) and (2) are recorded as the separate-collection and deposit-and-return duty with the 1 January 2029 date. Source for Art. 50(4) on milk, wine and spirits, Art. 50(5) on the exemption, Art. 50(9) on stricter national rules, Annex X, point f, on the non-profit requirement and Art. 12(1) on the harmonised label
4. European Commission — TRIS, notification database search Official. The register for notifications of draft technical regulations. Source for the publication rule quoted above — that TRIS messages are available ten days after the expiry of the notification's initial standstill period — which is why the 29 September 2026 notification could not be checked there on 7 October 2026. No notification for this Bulgarian bill was visible to us

Help us keep this page honest

What this file needs is not more commentary on the same report. It is the notified draft, or the TRIS record once the standstill has run — either would turn the 34%, the 67% and the 29 September date from press into primary text. Failing that: the Bulgarian deposit amount and scope list as soon as anyone publishes them, and anything in writing from the Ministry of Environment and Water on whether a producer established abroad joins through the operator.