The deposit system is a structural reform of national importance with a direct impact on the domestic market, businesses, municipalities, and all consumers. The resolution takes into account the new European regulatory framework introduced by Regulation (EU) 2025/40, which places deposit systems at the center of packaging waste management policy. Member States are required to achieve at least 90% separate collection of single-use beverage packaging by 2029, as well as to meet binding requirements for minimum recycled plastic content in new bottles. This means that Bulgaria must have a fully operational deposit system by 2029. In this regard, the ESC explicitly notes that the country has still not actually started the process of implementation and highlights the significant volume of work required to develop the regulatory framework for establishing a national deposit system in Bulgaria.
Among the main recommendations in the resolution are that the system should guarantee universal coverage and equal access for consumers, including in small settlements; the deposit value must be clearly separated from the product’s unit price, and its full reimbursement should not lead to additional costs for households; a transparent and effective governance mechanism based on the principle of extended producer responsibility should be ensured; cost efficiency and predictability for industry and fair compensation for retailers for the expenses actually incurred should be guaranteed; and an effective control mechanism should be established to protect consumer interests.
The ESC calls for a transparent, coordinated, and predictable legislative framework, prepared in accordance with good law-making practices, including an impact assessment and broad public consultation, so that Bulgaria can meet its European commitments on time and establish a sustainable and economically balanced deposit system. The Council recommends that the legislative proposal currently being developed within the working group at the Ministry of Environment and Water, with the participation of the obligated industry, municipalities, and the non-governmental sector, be finalized as soon as possible.
The ESC also warns of serious systemic problems in its opinion titled “Forests as a Strategic Resource in the Context of Sustainable Management and Economic Development,” which was also adopted at the plenary session.
The most serious deficiency is the lack of an updated National Forest Strategy after 2020 and the absence of a national forest inventory carried out using EU-harmonized methods, leading to a lack of reliable data, inconsistent policies, and risks for fulfilling European commitments. A worrying trend of deteriorating phytosanitary conditions in forest stands is also noted, especially in coniferous plantations outside their natural range and coppice forests (which account for over 50% of forest territories). The lack of sufficiently active forestry management and the accumulation of biomass directly increase the vulnerability of forests to fires and pest outbreaks. The sector is lagging behind in modernization, suffers from labor shortages, and faces a demographic collapse in mountainous regions. The Council insists on the urgent adoption of a new long-term strategy and reform of the sector’s governance model.