Obligations of companies

All persons who place packaged goods on the Bulgarian market are responsible for the separate collection, recycling and recovery thereof. For the fulfillment of their obligations, the companies may conclude a contract with a licensed packaging waste recovery organization.

• “Person placing on the market” is a natural or legal person who is a manufacturer and / or importer, and / or a person who brings into the territory of the country from the territory of another EU Member State and supplies goods to another person against payment, or free of charge, and / or uses them as part of a commercial, manufacturing or professional activity in order for the products to be distributed or used on the territory of the Republic of Bulgaria.
• “Packaged goods manufacturer” shall mean a natural or legal person who manufactures and markets goods packaged in consumer, group or transport packages, or packs goods with wrapping materials at the point of sale as part of his business or professional activities in order for the products to be distributed on the territory of the country and / or used as part of a commercial, manufacturing or professional activity.

Examples:

More common: Food and drink manufacturers, manufacturers of goods and products for industry, manufacturers of furniture, clothing, footwear, sanitary wares, appliances, spare parts and many more.

More specific:

• Manufacturers of packaging products – they are obliged to declare the packaging of their goods, for example, if the packaging of a carton manufacturer’s goods is a palette and a stretch wrap, he shall describe both these.
• Grocery stores selling goods packaged on-site, warm storefronts, home deliveries, disposable packaged goods, etc.
• Online stores.
• Pastry shops, restaurants, etc. that supply their goods in packages to their customers.
• Catering companies that deliver packaged goods to final customers.

• “Importer of packaged goods” shall mean any natural or legal person who imports packaged goods into the customs territory of the Republic of Bulgaria as part of his commercial or professional activity regardless of the way of sale, including through distance selling in accordance with Art. 48, Para. 1 of the Consumer Protection Act for distance contracts as part of their commercial or professional activity in order to distribute the products on the territory of the country and / or to be used as part of a commercial, manufacturing or professional activity.

More common: Importers of food and beverages, importers of goods and products for industry, manufacturers of furniture, clothing, footwear, sanitary wares, appliances, spare parts and many more.

More specific:

• Importers who do not place packaged goods on the Bulgarian market but should pay a product fee. These are all manufacturers whose goods are 100% exported, but at the same time import the packaged products and raw materials that are used in their production.
• Online stores

Packaging can be:

a) commercial packaging or immediate packaging, i.e. packaging designed as a unit of commodity for sale to the end consumer;

b) bulk or secondary packaging, i.e. packaging designed for a group of a certain number of items at the point of sale, whether sold in this way to the end user or consumer, or only to fill the shelves at the point of sale; it is removed from the product without affecting its quality;

c) transport packaging or tertiary packaging, i.e. packaging designed to facilitate the carrying and transportation of a series of items or group packs to prevent their physical handling or damage during transport; transport packaging does not include containers for road, rail, sea or air transport

There are different methods for determining the exact weight of each package.

• You may request additional information to the declaration of conformity of packaging on the weight of the packaging provided by the manufacturer of the packaging.
• For goods supplied from imports, the invoices themselves may be accompanied by packing lists that describe the type of material of the package and its weight. As well as the gross and net value of the goods.
• In the absence of such information, you could weigh it yourself and enter it into the product file.

Description of the types of packaging materials

Polyethylene Terephthalate

Better known by the abbreviation PET or PETE is pure, rigid, non brittle and lightweight plastic and is fully recyclable. This material was first synthesized in North America, in 1940, by Dupont chemists to be used as synthetic fibers. Much of the PET output is still used to produce fibers known as ‘polyester’, e.g. for making sweaters. In 1950, researchers discovered a way to spread PET into thin film through extrusion. Later PET was also used in the production of packaging products, photo and video tapes. In 1973, the PET bottle manufacturing process was fully developed and was then patented. PET bottles are used as packs for soft drinks, mineral water, beer, juices, cooking oil, salad dressings, shampoos, liquid soaps, detergents, etc. Other applications of this material are food boxes and even tennis balls. PET is pure, rigid, non brittle and lightweight plastic and is fully recyclable.

High density polyethylene, HDPE

Polyethylene was created on March 27, 1933 by the two chemists, Gibson and Fauset, who worked for the Imperial Chemical Industries Research Laboratory while testing different chemicals. In 1936, the first patent for polyethylene was registered by Imperial Chemical Industries. A year later, this material found its first practical application as a film, tape. In 1953, Ziegler and Kaiser of the Kaiser Wilhelm Institute and Holtskamp created HDPE high density polyethylene. Two years later, production of pipes of this material began. Ziegler was awarded the 1963 Nobel Prize for Chemistry.

HDPE is resistant to many different solvents and has a wide variety of applications, e.g. backpacks, ballistic plates, bottle caps, reusable bottles, chemically resistant piping systems, coaxial cable insulators, corrosion protection for steel pipelines, containers, vehicle fuel tanks, detergent bottles, chairs, tables, geo-membrane for hydraulic applications, geothermal piping systems, fireworks, pipes, bags, cartridges, tubes, toys.

Polyvinyl chloride PVC

Polyvinyl chloride was created in 1872 by the chemist Bauman, but was never patented by him. Later, in 1913, in Germany, Frederic Klathe created a new method for synthesizing PVC in the process of polymerization of vinyl chloride by sunlight.

PVC is widely used in all sectors of industry. It is used to produce pipes, windows, joinery, food and medicine packaging, foil, boxes, etc.

Low density polyethylene LDPE

It was first produced in 1933, in England, by Imperial Chemical Industries Ltd. in the process of polymerization of polyethylene at high pressure and high temperature. In 1937, it was patented by ICI and its first application was during the Second World War as an insulator for radar cables.

Nowadays, it is widely used in the production of plastic bags, stretch foils, boxes, bottles, tubes and other packaging products.

Polypropylene PP

Polypropylene is a thermoplastic polymer that was created in 1951 by the scientists Hogan and Banks for Phillips. It is used in many different areas: for making packaging, tubes, crates, bottles, boxes, pots, furniture, appliances, toys etc.

Polystyrene PS

Pure rigid polystyrene is a colorless flexible plastic with low deformability, which can be molded into fine details. Polystyrene can be transparent or colored in different colors. It is used for the production of packaging products, plates, yogurt pans, baby constructors, plastic cutlery and many other items, for which relatively rigid plastic with the ability to color in different colors is required. The most widely used polystyrene is expanded polystyrene (EPS), also known as Styrofoam, Facade Styrofoam and others, which is a mixture of about 5% polystyrene and 95% air. An improved non-hygroscopic version of polystyrene is extruded polystyrene (XPS) under the trade names Fibran, Styrodur, Styroflex, Monodur, Glazform, Styrofom, Tictas, Polpan etc.

Composite materials

The juice and milk boxes are made of liquid packaging board, cardboard laminate and LDPE (as waterproof inner and outer layers) and often have an aluminum foil layer (which makes it aseptic packaging).

Persons under Art.14, Para. 1 OPPW shall mark each of package placed on the market by them with:

Subject to the Ordinance on packaging and packaging waste, there are two obligatory signs, which shall be put on each packaging: The first sign contains information about the type of material from which the packaging was created / Annex 3 / and the second indicates that the packaging should be deposited separately in colored containers.

Annex No. 3 to Art. 5, Para. 1, item. 2

Annex No. 4 to Art. 5, Para. 1, item. 3

Each packaging is required to be marked with the sign specified n Annex 3 of the Ordinance on packaging and packaging waste.

Any number entered in the recycling triangle is in compliance with the type of material specified in Annex 2 of the Packaging Ordinance. You can download the full list of materials from the following link (only in Bulgarian).

If you are marketing packaged products for the first time and have to declare the packaging to a utilising organisation, you will have to prepare your first report. All packaging that you have sold on the Bulgarian market during the reported period has to be described therein. You will need the following starting information:

• Specify the origin of the goods: produced and/or imported.
• If you are the manufacturer of the goods, all packaging used will be appropriately documented specifying the material, which should have been provided by the producer of the packaging.
• If the goods are imported from another country, their manufacturer had the obligation to provide you with information about packaging type and weight. The invoices should be accompanied by packing lists containing detailed information.
• Define packaging type and weight
• Depending on the type of packaging material, there are several main groups described in ‘What are the main and specific materials used to manufacture the packaging?’
• Calculate the quantities of packaging sold in Bulgaria during the reporting period.
• It will be necessary to collect data about the number of goods sold in order to determine their primary, secondary, and tertiary packaging as well as the material from which the packaging was produced. After the unit weight is determined it would be very easy to calculate the total weight of the packaging per type of material, depending on the quantities sold in the Bulgarian market. Our consultants are available to help you, if you need assistance.
• Entering information in the reporting form of Eco Partners Bulgaria
• Eco Partners has a web-based platform for filing reports. Enter the total quantities of packaging per type of material in a special form used for reporting on a regular basis.

The annual estimate of  the quantity of packaging sold by members of the organisation for whom recycling targets will be set is to be prepared by January 30 of the current year. The estimate must include the packaging components of all packaged goods to be offered for sale in the same year.

In order to prepare the estimate the annual report for the previous year may be used. It is also possible to draw up a new estimate. In this case, there are various ways to prepare the estimate, depending on available information and the possibility to use expert assistance, for instance the preparation of in-company specifications based on information about the quantity of the goods to be released in the market and the primary, secondary, and tertiary packaging of each product.

A realistic estimate of the quantity of packaging waste a company plans to release in the Bulgarian market would help the achievement of the quantitative targets for waste recycling and recovery.

If you have any questions or need further clarification, please contact our experts for a free consultation at the following contacts.