REGARDING THE DRAFT LAW AMENDING THE WASTE MANAGEMENT ACT

The Bulgarian Industrial Association welcomes the effort to align national legislation with EU requirements and improve the management of widespread waste, including electrical and electronic equipment (EEE). However, we believe the draft law should be further developed to ensure effectiveness, transparency, and integration of circular economy principles.

We call for:

- Fair enforcement of Extended Producer Responsibility (EPR): All obligated producers must be registered and participate in recovery organizations (PROs), with proper data verification and oversight included in official reports.

- Eco-modulated fees: Sustainable and repairable products should benefit from lower fees; inefficient products should bear higher costs.

- Digital traceability: Introduce electronic tracking systems and digital tools (e.g., QR codes) to improve accountability and limit the grey market.

- Reuse over recycling: The law should explicitly prioritize reuse and repair, supported by reuse centers and good EU practices.

- Support for social enterprises: Facilitate their access to funding and infrastructure to enhance dismantling, repair, and reuse activities.

- Public awareness campaigns: Legally require national and local authorities to inform citizens about proper waste disposal.

We oppose replacing the current permit regime for PROs with a simple registration model. PROs manage significant resources and must remain subject to prior approval, clear rules, and strong oversight—following best practices from countries like Germany and France.

We urge the inclusion of mechanisms that give producers:

- Contractual control and audit rights;

- Representation in PRO management;

- Access to public reporting and independent verification;

- The right to switch organizations;

- Real-time tracking through digital platforms.

In conclusion, we recommend strengthening the draft law to ensure real progress toward a circular economy and improved waste governance. We urge the Parliament to include these proposals in the final text and ensure stakeholder involvement in implementation and monitoring.

We propose adding a legal clause affirming the rights of producers to oversee and participate in the governance of the PROs they fund.