Expensive packaging

Bulgarians pay more than other Europeans for waste management while receiving unsatisfactory results, including in terms of recycling. With the new European plastics tax, they will pay even more. The article proposes seven measures for strategic improvement of waste management in Bulgaria.

Analysis by Iva Dimitrova*

Starting 2021, Bulgarian citizens will be paying three times for the part of their plastic waste that is packaging. Firstly, as consumers they pay a ‘product fee’, the value of which producers and importers calculate in the retail prices of packaged goods, in order to finance packaging recovery organizations (PROs) responsible for the collection and recycling of their packaging. Secondly, they pay as local taxpayers through a municipal waste fee. And now, with the introduction of the European tax on non-recycled plastic packaging, they will pay for a third time for waste plastic packaging.

The current inefficient separate waste collection system in Bulgaria is at the root of this, combined with the lack of reliable and detailed information about the waste quantities and different waste streams. This allows for a large part of this plastic waste to ‘leak’ into the environment or end up in the mixed municipal solid waste. Local taxpayers cover the costs of cleaning, transporting and treating waste, the recovery of which they have already paid for, whereas communities living near landfills and waste burning facilities bear the invisible but grave health risks.

High waste management costs

Bulgaria has spent an average of 0.62% of GDP per year on waste management for the period 2015-2019. This is one of the highest rates allocated to waste management among EU countries and is almost twice as high as the Baltic States’ and Romanian rates. The data shows that Bulgaria has higher waste management costs compared to other countries in the region.

Note: Waste management includes collection, treatment and disposal. Source: Eurostat, COFOG data

Waste management costs are an important expenditure part of the state and municipal budgets. In order to cover these costs, municipalities collect municipal waste fees from citizens and companies. The waste charge for citizens and companies is based on the tax evaluation of the property or the book value of the assets, which means that larger sites or those with expensive equipment pay more, regardless of how much waste they generate.

For example, in some municipalities with a population of over 50 000 people company with 600 staff, contributes 50-70% of the total revenues from the local waste charge. The current option of determining the municipal waste tax lacks an incentive to reduce waste, and the value of the tax does not correspond to the individual contribution. 

However, the revenues from taxes are not sufficient and the Operational Programme “Environment” (OPE) and the state-run Enterprise for Management of Environmental Protection Activities (EMEPA) provide additional funds for the construction of regional waste management systems, reclamation of old landfills and other similar investments.

Waste management costs are a considerable part of the state and municipal budgets. For 2019, waste management expenditures in Bulgaria amount to 1.6% of total government expenditures and 7.2% of local government expenditures. The data shows that compared to other countries in the region  Bulgaria spends the highest share of its budget for waste management and more than twice the share of the state budget than the EU average.

Source: Eurostat, COFOG data

Nevertheless, a large part of the material value of the waste is lost. 

Despite the significant investments for the improvement of the waste management system – just the Waste priority axis of the Operational Program “Environment” 2014-2020 has paid out BGN 266 million (as of 12 Oct 2021), the share of recycled waste in Bulgaria remains low. 

Source: Eurostat, Recycling rate of municipal waste

According to Eurostat, Bulgarians generate 18.7 kg of plastic packaging per capita annually(2018). Out of this amount, only 59% reach the recycling stage and the rest either leaks into the environment or ends up in the mixed waste and is typically disposed or incinerated. 

This is valid especially for, but not limited to, the settlements that are not serviced by packaging recovery organizations. According to data from waste composition analyses conducted by environmental association Za Zemiata in several Bulgarian municipalities, mixed municipal solid waste before sorting and treatment contains nearly 14% plastic packaging waste. 

In addition to Eurostat data, a report by the international NGO Reloop Platform shows that 113 plastic bottles per year are lost per capita in Bulgaria, meaning that they ‘leak’ into the environment or into mixed waste, without being recycled or reused.

Single-use PET beverage containers wasted per capita, by country

Source: What We Waste report, Reloop

What does the “new plastic tax” stand for?

The website of the European Commission says:

 “The plastics own resource, in place since 1 January 2021, consists of a national contribution based on the amount of non-recycled plastic packaging waste. This own resource is closely linked to the EU policy priorities. This is expected to encourage Member States to reduce packaging waste and stimulate Europe’s transition towards a circular economy by implementing the European Plastics Strategy. At the same time, it leaves Member States the possibility to define the most suitable policies to reduce plastic packaging waste pollution in line with the principle of subsidiarity.”

The Member States owe a flat rate of EUR 0.80 per kilogram of non-recycled plastic packaging waste. Given the estimated 53.6 thousand tons of non-recycled plastic packaging waste, the annual plastics tax for Bulgaria should be around EUR 43 million. Due to the lower than the EU average gross national income per capita, a significant tax reduction is provided. However, according to the calculations of the Center for European Policy, the expected annual liability of Bulgaria in regards to this tax will be EUR 20,912,800.

Seven proposals

To avoid triple payment for inefficient waste management in Bulgaria, several changes need to be made in three key directions: more accurate waste reporting, more fair financing of waste management and strategic decisions regarding packaging waste. 

  1. A reform of municipal waste management, striving for ‘door-to-door’ separate waste collection. 
  2. The municipal waste charge should be determined based on the generated amount of (unseparated) waste.
  3. It is necessary to summarize and analyze data on the municipal costs for cleaning and managing packaging waste at local level. The waste composition should be examined according to an updated methodology that takes into account the share of packaging and the results should be published on an annual basis, together with municipal expenditures for waste management. 
  4. Part of the product fees collected by PROs should be distributed to local authorities, in proportion wtih the municipal expenditures for packaging waste management  – a measure of especially high priority for settlements that are not serviced by packaging recovery organizations.
  5. An independent audit of the licensed packaging waste recovery organizations is needed to determine the actual quantity of packaging that is placed on the market, collected separately and recycled – as there is a significant discrepancy between the amount of total plastic packaging placed on the market at national level as reported by the National Statistics Institute and the amount of plastic packaging waste declared by recovery organizations [i].
  6. Manufacturers should bear the cost of the new European plastics tax charged for each kilogram of non-recycled plastic packaging waste, in order to encourage them to offer reusable and recyclable packaging and to invest in expanding and increasing the efficiency of the recycling system.
  7. Introduction of a deposit refund system for beverage packaging of all material types (plastic, metal, glass). Such a system will save a lot of public costs related to cleaning and treatment, it will increase recycling, improve the cleanliness of public places and help reduce the burden of national obligations under the new plastic tax.

*Coordinator “Economic justice“ at Environmental Association “Za Zemiata“.
The publication “Expensive packaging” has been edited by PhD Dimitar Sabev


[I] Report of 22.06.2021 of the National Audit Office audits the implementation of “Plastic waste management.” This does not cancel the responsibility of the Ministry of Environment and Water to appoint its own audit (especially considering that the National Audit Office gives the MoEW a deadline of 31.06.2022 to implement the recommendations).