The spring and summer of 2025 were marked by intensified dialogue between the government and affected industry business organizations regarding the draft Supply Chain Act for Agricultural Products and Food, published for public consultation. Although its intentions are, in principle, good – to address rising prices and support farmers – the draft has many shortcomings and was met with widespread disapproval.
How many versions of the draft law were there?
- 1st version: published for public consultation on June 13, 2025 (until July 14).
- 2nd version (revised): new consultation opened on July 29, 2025 (until August 12).
What do the controversial provisions include (key highlights from both versions)?
- Markup caps: up to 20% for retailers and processors, 10% for wholesalers, and 10% for certain imported unprocessed products.
- Mandatory minimum markup: at least 10% for producers of agricultural products and food.
- Quotas for Bulgarian goods: up to 50% Bulgarian production (and up to 80% for dairy products).
- Discount restrictions: discounts capped at 10% and promotions limited to 25% of contracted quantities annually.
- Contracts and “first buyers”: minimum contract duration (e.g., 6 months) and requirements for first buyers in the chain.
- Publicity and registration: mandatory online publication of price lists for traders with a turnover above BGN 20 million.
What were the reactions?
On July 22, 2025, the Bulgarian Industrial Association and 15-member industry organizations organized a discussion forum on “The Country’s Food Security Under Threat.” Business organizations strongly opposed the draft law during the discussion and through subsequent statements and meetings with relevant institutions.
According to the business sector, the measures are overregulatory, risky for prices and competition, and incompatible with EU law—introducing different conditions for participants in the supply chain could be considered “state aid,” which violates European legislation. Business organizations warned of a potential procedure by the European Commission and demanded the withdrawal of the draft.
Independent experts, analysts, and media also expressed concerns about possible price increases, shortages, and market distortions caused by the introduction of administrative caps and quotas.
What are the expectations?
The second public consultation closed on August 12, and for now, the draft remains in final coordination.
It is currently possible that the European Commission may return the draft law due to incompatibility with EU legislation in three key areas:
- Strict markup caps and quotas – potentially restricting free trade and competition.
- Minimum contract duration, “first buyer” – creating administrative burdens for businesses.
- Mandatory publication of price lists – may infringe on traders’ rights and distort competition.
These measures potentially conflict with the free market principles, non-discriminatory access, and competition enshrined in European law.
In addition, the Corporate Sustainability Due Diligence Directive (CSDDD) has already been adopted at the EU level (Directive 2024/1760), and Bulgaria must transpose it by 2026. If the national law contradicts the CSDDD or introduces more restrictive measures, the European Commission could also intervene.
If the Commission finds that a national law violates EU law, it may launch an infringement procedure – yet another against Bulgaria, following numerous already initiated cases in areas such as waste, public procurement, energy, and more.
