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Bulgaria: one mandatory code, two graphics that are no longer obligatory
Bulgaria requires a material identification number and/or abbreviation, drawn from Annex 2 of the packaging ordinance, on every package placed on the market by a person under Article 14(1) of the Waste Management Act. The recycling graphic in Annex 3 and the separate-collection mark in Annex 4 have been voluntary since 16 December 2022. Older guidance that still speaks of three obligatory signs is out of date. There is no operating national deposit-return logo. Harmonised Union labels apply later.
The question this report answers
Article 5(1) of the Ordinance on Packaging and Packaging Waste — Council of Ministers Decree No. 271 of 30 October 2012, State Gazette No. 85 of 6 November 2012 — still lists three marks. Persons in Waste Management Act Article 14(1) are to mark every package they place on the market with an identification number and/or abbreviation according to Annex 2; a recycling-and-material mark according to Annex 3; and a separate-collection mark according to Annex 4. Read alone, that list looks like Italy’s all-packaging coding duty multiplied by three. It is not current law in that form.
Transitional § 7, as replaced by Council of Ministers Decree No. 419 of 14 December 2022 (State Gazette No. 100 of 16 December 2022), provides that Article 5(1) points 2 and 3 apply voluntarily. Point 1 remains mandatory. If Annex 3 or 4 is used, it must be the official graphic. Article 5(4) still prohibits other signs for identifying the corresponding packaging materials. That prohibition is a rule about competing material alphabets. It is not a ban on the Green Dot, which is an EPR trademark rather than a material identifier.
There is no millimetre table, no small-pack exemption, and no operating national deposit-return logo. Article 39’s inscription “За многократна употреба” applies only where a pack is actually in a deposit or other reuse system. A draft Waste Management Act amendment for a national deposit-return system was described by the ministry in April 2026. It is not in force. Supreme Administrative Court repeals published in State Gazette No. 63 of 2025 struck other provisions of the ordinance. They did not repeal Article 5. A 2021 transitional that delayed points 1 and 2 until 1 January 2022 is spent.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Annex 2 number and/or abbreviation | mandatory | Every package placed on the Bulgarian market by an Article 14(1) person. The table is the Bulgarian transposition of Decision 97/129/EC, in capital letters, with a C/ convention for composites. |
| Annex 3 recycling-and-material mark | voluntary since 16 Dec 2022 | A Möbius loop with the Annex 2 digit between the arrows and the abbreviation below. If used, this graphic — not a house variant or a foreign loop. |
| Annex 4 separate-collection mark | voluntary since 16 Dec 2022 | The ordinance’s person-with-bin graphic, not the WEEE crossed-out wheeled bin. Consumer-side fines still attach to throwing waste that bears this mark into mixed bins where a separate-collection system exists (ЗУО Art. 133(1)(4)). |
| Other material-identification signs | prohibited | Article 5(4). This is not a Green Dot ban. |
| “За многократна употреба” | if in a reuse or deposit system | Article 39. There is no national DRS logo to add today. |
| National DRS on-pack logo | not in force | Ministry materials of April 2026 describe a draft amendment, not an operating system. |
| PPWR harmonised label | adopted; not yet applied | Article 12(1) applies from 12 August 2028 or 24 months after the implementing act, whichever is later. Decision 97/129/EC is repealed from 12 August 2028. |
The code that remains obligatory
Annex 2 is headed as the abbreviation and code identifying the material of a given packaging. Footnotes require capital letters and, for composites, C/ plus component abbreviations separated by slashes — for example C/PAP/PE/ALU. The table is the Bulgarian transposition of Commission Decision 97/129/EC: plastics 1–7 (and 7–19 other plastics), paper and board 20–39, metals 40–49, wood 50–59, textiles 60–69, glass 70–79, composites 80–99. The code identifies composition. It does not prove recyclability, collection access or recycled content.
Placement is on the component with the greatest weight, or on the label (Article 5(3)). That is one location, not a full set on every detachable part. Durability includes after opening (Article 5(2)). No millimetre minimum is stated; “clear and legible” is the size law. No small-pack, business-to-business or QR substitute appears in Article 5. Decision 97/129 is voluntary at Union level. Bulgaria made the numbering mandatory. That national mandate can last until 12 August 2028, when PPWR Article 70(2) repeals the Decision. It did not expire on 12 August 2026, which was the Regulation’s general application date rather than its labelling trigger.
The two graphics that became voluntary
If Annex 3 is used, the Annex 2 digit sits between the three arrows and the abbreviation sits under the sign. A bare Möbius loop, a How2Recycle panel or an SPI triangle is not Annex 3. If Annex 4 is used, the official drawing is the one the ordinance contemplates — not Triman, and not the WEEE crossed-out bin. Recovery organisations publish vectors sourced from the annexes. Using the graphics is a choice. Using a rival material-identification alphabet is still prohibited.
The usual error in English-language accounts of Bulgarian packaging law is to treat all three Article 5(1) marks as still mandatory. They have not been, for points 2 and 3, since 16 December 2022. Pre-2022 recovery-organisation flyers that still demand three obligatory signs are historical documents. They are not the current ordinance.
Who must mark, and what a missing DRS logo means
Article 5 addresses “лицата по чл. 14, ал. 1 ЗУО”: persons placing on the market products after whose use mass-distributed waste is generated. In practice that is the person who first makes the packed product available in Bulgaria — manufacturer, importer, intra-EU introducer. Article 14(2) allows individual or collective extended producer responsibility. Marking remains on the Article 14(1) person. Membership of a recovery organisation does not substitute the Annex 2 code.
A producer-side sanction for placing packaging not marked in accordance with the Article 13(1) ordinance appears in the Waste Management Act; notified consolidations have cited BGN 10,000–50,000. The current article number should be confirmed in the latest State Gazette consolidation before a penalty figure is quoted. Consumer-side Article 133(1)(4) fines natural persons who throw marked separate-collection waste into mixed bins where a separate-collection system exists. That consumer fine attaches to waste that bears the Annex 4 mark. It is not a reason to treat Annex 4 as still obligatory on every pack.
The Ministry of Environment and Water described, on 30 April 2026, a deposit system as an instrument for a circular-economy transition and referred to draft legislative work. That is a proposal. Bulgaria does not, as of this verification, have an operating national deposit-return logo to place beside the Annex 2 code. “За многократна употреба” remains a reuse-system inscription, not a substitute for a deposit pictogram that has not been brought into force.
What the Union regulation does, and does not yet do
Regulation (EU) 2025/40 is generally applicable from 12 August 2026. Its harmonised material-composition label under Article 12(1) applies from 12 August 2028 or 24 months after the relevant implementing act, whichever is later. From 12 February 2027, Article 12(9) confines identification of EPR participation to a digital carrier. Commission Notice C/2026/3084 is Commission interpretation of the labelling transition. It is not a Bulgarian amendment of Article 5, and it is not a licence to drop the Annex 2 code on the Regulation’s general application date.
Primary sources and verification
Bulgaria. Ordinance on Packaging and Packaging Waste, consolidated. lex.bg
Bulgaria. Ordinance PDF (EEA 2026 file). EEA PDF
Bulgaria. Council of Ministers Decree No. 419 / State Gazette No. 100 of 16 December 2022 (§ 7, voluntary). State Gazette
Bulgaria. Waste Management Act. lex.bg
Ministry of Environment and Water. Deposit system status (30 April 2026). MOEW
European Union. Regulation (EU) 2025/40; Decision 97/129/EC. PPWR · 97/129
European Commission. Notice C/2026/3084. EUR-Lex
Bulgarian-language consolidations control. The usual English error is to treat all three Article 5(1) marks as mandatory. Last verified: 21 August 2026.