Bulgaria has adopted amendments related to the Waste Management Act, particularly to the Ordinance on Packaging and Packaging Waste [Наредбата за опаковките и отпадъците от опаковки] (the "Ordinance").
The amendments were published in the State Gazette, issued on 8 January 2021 and in force since 12 January 2021. These are some of the more noteworthy amendments:
Increase of the recycling targets for packaging waste and
introduction of a phased schedule for their implementation until
2030, reaching the recycling of 70 % of the total weight of
packaging waste. While the amendment mainly affects recovery
organisations, it could indirectly affect the contractual terms
with such organisations. The achievement of targets will be
measured, calculated and reported in accordance with the
requirements and rules of the new Annex 8a to the Ordinance.
Repeal of Art. 17, para. 4 of the Ordinance. This was a provision
introducing releases from liability for certain persons whose
activity generates packaging waste. The amendment shows that the
actual implementation of the recycling targets is important for all
actors in the waste chain.
Two new paragraphs of Art. 19 introduced regarding commercial
sites: (i) in the case of separate collection of packaging waste,
retail sites should have sufficiently large containers for separate
waste collection in accordance with the number of visitors; (ii) it
is prohibited to mix separately collected packaging waste with
other materials or waste in a way that hinders their subsequent
recycling or recovery.
- Annex 3 to the Ordinance introduces amendments that may lead to an obligation to label packaging.
The change will be effective from 1 January 2022 and reintroduces the requirement to depict the "chasing arrows" pictogram on the packaging/label of prepacked goods.
Prepacked goods placed on the market before 1 January 2022 that do not bear the "chasing arrows" pictogram can be sold until out of stock.
Originally Published by Schoenherr, March 2021
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