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MINISTRY OF ENVIRONMENT AND WATER
REPUBLIC OF BULGARIA
IMPLEMENTATION PROGRAM
FOR DIRECTIVE 2002/96/ЕС ON WASTE ELECTRICAL AND
ELECTRONIC EQUIPMENT AND
DIRECTIVE 2002/95/ЕС ON THE RESTRICTION OF THE USE OF
CERTAIN HAZARDOUS SUBSTANCES IN ELECTRICAL AND
ELECTRONIC EQUIPMENT
IN BULGARIA
ANALYSIS OF THE REQUIREMENTS OF THE DIRECTIVES

AND CAPACITY OF BULGARIA TO IMPLEMENT THEM
SOFIA
AUGUST 2004
CONTENTS
I. BACKGROUND 4
I.1. LEGAL FRAMEWORK 4

I.2. TIMEFRAME 4
I.3. OTHER RELEVANT EU DOCUMENTS 4
II. ANALISYS OF THE CURRENT STATUS IN BULGARIA CONCERNING THE

IMPLEMENTATION OF THE DIRECTIVES 6
II.1. LEGAL FRAMEWORK 6

II.1.1.REVIEW OF THE REQUIREMENTS OF DIRECTIVE 2002/96/EC 6
II.1.2.CURRENT LEGAL ACTS IN BULGARIA, CONCERNING DIRECTIVE 2002/96/ЕС 7
II.1.3.LEGAL ACTS CURRENTLY IN FORCE IN BULGARIA, RELEVANT TO DIRECTIVE
2002/95/ЕС 8
II.1.4.FUNCTIONS AND OBLIGATIONS OF THE COMPETENT AUTHORITIES 9
II.1.5.OBLIGATIONS OF PRODUCERS AND IMPORTERS OF EQUIPMENT, COVERED BY
THE DIRECTIVE 2002/96/ЕС 10
II.2. SCIENTIFIC, TECHNOLOGICAL AND TECHNICAL SUPPORT 11
II.2.1.DESCRIPTION OF THE FACILITIES FOR COLLECTION AND RECOVERY OF WASTE
IN BULGARIA 13
II.2.2.METHODS FOR COLLECTION AND TREATMENT OF WEEE IN BULGARIA 16
II.3. DEMOGRAPHIC CHARACTERISTIC OF BULGARIA 16
II.4. ORGANIZATION AND METHODOLOGY OF COLLECTION AND
PROCESSING OF THE NECESSARY DATA 18
II.5. QUANTITIES AND DISTRIBUTION OF EEE IN BULGARIA AND RATES OF
ACCUMULATION OF WEEE 18
III. ANALYSIS OF THE CAPACITY FOR THE IMPLEMENTATION OF THE WEEE

DIRECTIVE AND THE ROHS DIRECTIVE 26
IV. ORGANIZATION FOR IMPLEMENTATION OF DIRECTIVE ON WEEE AND

DIRECTIVE ON ROHS IN BULGARIA 39
IV.1. RELATIONS THAT NEED ARRANGEMENT 39

IV.2. MAJOR PROBLEMS AND PRIORITIES 39
V. FINANCIAL FRAME 42
V.1. ESTIMATION OF COSTS FOR IMPLEMENTATION OF DIRECTIVES IN

BULGARIA 42
V.1.1. COSTS FOR DEVELOPMENT OF WEEE MANAGEMENT SYSTEM IN BULGARIA 42
V.1.2. DETERMINATION OF THE OPTIMAL NUMBER OF COLLECTION FACILITIES 42
V.1.3. COSTS FOR ESTABLISHMENT OF A FACILITY FOR SEPARATE COLLECTION OF
WEEE 43
V.1.4. OPERATIONAL COSTS FOR COLLECTION FACILITY 43
V.1.5. CONSTRUCTION AND OPERATIONAL COSTS FOR TREATMENT AND
RECOVERY FACILITIES 44
V.1.6. SUMMARY 45
V.2. FINANCING 45
V.2.1. WASTE GENERATED BY HOUSEHOLDS AND USERS, SIMILAR TO THEM 46
2
V.2.2. WEEE, GENERATED BY NON-HOUSEHOLD USERS 47
V.2.3. FINANCING OF THE RESTRICTION OF USE OF HAZARDOUS COMPOUNDS IN
EEE 47
VI. REQUESTED TRANSITION PERIODS 48
VII. ACTION PLAN 51
VIII. BIBLIOGRAPHY 61
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I. BACKGROUND
Directive 2002/96/ЕС on waste electrical and electronic equipment is adopted by the
European Parliament and the Council and published in OJ L37 of 13.02.2003. The
Directive shall enter into force on the day of its publication and concerns the collection and
environmentally sound treatment of waste electrical and electronic equipment (WEEE). The
objectives of the Directive on WEEE are to reduce the amount of generated WEEE and to
cover most of the quantity of WEEE generated. Its management must lead to reuse,
recycling and other forms of recovery of such wastes. In addition, another purpose of the
Directive is to improve the general environmental performance of the stakeholders,
participating in the life cycle of EEE (producers, distributors, users and especially the
operators involved in the treatment and disposal of WEEE).
To help the management of this waste stream and to protect human health, European
legislation envisages restriction of the use of the hazardous substances in the production of
EEE (Directive 2002/95/ЕС on restriction of the use of certain hazardous substances in
EEE).
I.1. Legal Framework

Directive 2002/96/EC of 27 January 2003 on waste electrical and electronic equipment
[published in Official Journal L 37 of 13.2.2003].
Directive 2003/108/EC of 8 December 2003, amending Directive 2002/96/ЕС [published in
Official Journal L 345 of 31.12.2003].
Directive 2002/95/EC of 27 January 2003 on the restriction of the use of certain hazardous
substances in EEE [published in Official Journal L 37 of 13.2.2003].
Council decision 2004/486/EC of 26 April 2004 granting the Republic of Cyprus, Malta
and Poland some temporary alleviation concerning Directive 2002/96/EC [published in
Official Journal L 162 of 30.4.2004].
Council decision 2004/312/EC of 30 March 2004 granting Czech Republic, the Republic of
Estonia, Hungary, the Republic of Latvia, the Republic of Lithuania, Slovakia and Slovenia
some temporary alleviations concerning Directive 2002/96/EC [published in Official
Journal L100 of 06.04.2004].
I.2. Timeframe
Directives 2002/96/ЕС and 2002/95/ЕС enter into force on 13.2.2003. Directive
2003/108/ЕС enters into force on 31.12.2003. The deadline for the transposition of the
Directives in the Member States is 13.08.2004. The following derogations from article 5 (5)
and article 7 (2) from Directive 2002/96/ЕС has been accepted:
§ For the Republic of Cyprus, Malta, Poland, Czech Republic, Estonia, Hungary,
Latvia, Lithuania and Slovakia– 24 months
§ For Slovenia – 12 months
I.3. Other relevant EU documents

Directive 96/61/ЕС on integrated pollution prevention and control about the procedures for
defining the best available techniques for treatment, recovery and recycling
4
Directive 75/442/ЕЕС on waste
Recommendation 2001/331/ЕС of the European Parliament and Council of 4 April 2001
about the minimum criteria for organization of environmental inspections in Member States
5
II. ANALYSIS OF THE CURRENT STATUS IN BULGARIA
CONCERNING THE IMPLEMENTATION OF THE
DIRECTIVES
II.1. Legal Framework

II.1.1. Review of the requirements of Directive 2002/96/EC
II1.1.1. Scope of the Directive

The Directive applies to 10 categories of electrical and electronic equipment dependent on
electric currents or electromagnetic fields (battery or power supply), in order to work
properly with voltage rating not exceeding 1000 V АС and 1500 V DC:
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-scale stationary industrial
tools)
7. Toys, leisure and sports equipment
8. Medical devices (with the exception of all implanted and infected products)
9. Monitoring and control instruments
10. Automatic dispensers
II1.1.2. Stakeholders
The Directive concerns the following persons and organizations:
§ Competent authorities: Ministry of Environment and Water and its regional
bodies – Regional Inspectorates of Environment and Water (RIEWs), Ministry
of Economy, Ministry of Health and local authorities
§ Producers of electrical and electronic equipment, included in article 2, except
when they export their production outside the EU.
§ Importers of EEE
§ Distributors of EEE
§ Retailers of EEE
§ Households and users other than private households (business users)
§ Services centers and repair shops of EEE
§ Facilities for separate collection of WEEE
§ Facilities for treatment of separately collected WEEE
§ Facilities for recovery and disposal of WEEE
§ Transport companies, that are engaged in international transport of WEEE for
export
§ Non-government organizations and media
The definition of “Producer” is very important, because the Directive introduces the
“Producer Responsibility” principle and the producers should pay for the treatment,
recycling and some costs of the collection of WEEE. The Directive clearly states, that
“Producer” is a person that manufactures and sells under his own brand, resells other brands
or imports goods in the EU. For the purposes of reporting and trade within the EU, a
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producer may be an exporter. The Directive doesn’t state any obligations for those business
organizations, which export outside the EU.
II.1.2. Current legal acts in Bulgaria, concerning Directive

2002/96/ЕС
The legal acts in Bulgaria currently in force, regulating the social relations concerning
environmental protection and waste management have been adopted in the course of the
integration of Bulgaria in EU, and for that reason the national legislation is largely
harmonized with the European requirements.
The legal acts in Republic of Bulgaria, regulating waste management, related to the
implementation of the Directive 2002/96 /ЕС, are:
General
• Environmental Protection Act – publ. State Gazette 91/2002
• Waste Management Act – publ. State Gazette 86/2003
• Ordinance No 3 on waste classification – publ. State Gazette 44/2004
• Ordinance No 12 on requirements for the sites of facilities for waste treatment –

publ. State Gazette 152/1998
• Ordinance on requirements towards treatment and transport of industrial and

hazardous waste - publ. State Gazette 29/1
• Ordinance on requirements for treatment and transportation of waste oils and waste
oil products, promulgated State Gazette No 59/2000
• Ordinance on when permits for import, export and transit of waste is required and
the procedure of permits’ issuing – publ. State Gazette 66/2000
Special
• Ordinance on placing on the market fluorescent and other mercury containing
lamps and for treatment and transportation of spent fluorescent and other mercury containing
lams – publ. State Gazette 101/2000
• Ordinance on requirements towards production and placing on the market batteries

and accumulators and treatment and transport of waste from batteries and accumulators – publ.
State Gazette 61/2000
WEEE is waste according to the national legislation. It’s included in the definition of “wide
spread waste” according to the Waste Management Act (WMA).
The WEEE, large amount of which is classified as hazardous waste according to Ordinance
No3 on classification of waste, requires treatment under the permit regime - article 37
WMA.
WEEE, which is not hazardous, according to article 12 (2) (1) of WMA may be collected,
transported and temporarily stored without permit, but the persons that carry out these
activities must be registered by the competent authorities.
According to Bulgarian legislation on waste classification, WEEE is in groups 16.02. and
20.01. This classification defines that there are whole appliances, as well as their
components, which are hazardous waste. For the purpose of protection of the environment
7
and human health, the management of WEEE, which contains hazardous substance, should
be performed only by entities holding the necessary permit.
It has to be considered, that the Directive regulates relations concerning equipment, which
wasn’t an object of regulation in the EU as well as in Bulgaria. In this direction it is
necessary that some new legal acts of the national legislation have to be adopted or the
existing ones to be amended, in order to prevent conflicts between national and
international acts and to ensure higher rate harmonization with the requirements of the
Directive.
Below are listed some basic recommendations for the harmonization of the legislation:
With a view of transposing of the Directive it is necessary one or more secondary legal acts
on WEEE to be adopted.
The provisions of the Directives may be transposed also through adoption of Ordinances on
essential requirements towards products, issued according to article 7 of the Act on the
technical requirements on products. This concerns mostly the requirements for placing on
the market and marking of EEE.
The Directive’s principle about the financial responsibility of the producers has to be
implemented through fulfilling of the requirements of WMA. As stipulated in the Directive
on WEEE, producers are responsible for the financing of systems for separate collection,
disposal and recovery. Harmonization of the Bulgarian legislation with the Directive on
WEEE requires the provisions on financial responsibilities of all producers and importers of
EEE to be adopted that as a minimum must ensure free take back of WEEE from end users.
It is necessary:
§ to determine legal penalties for violation of the regulations on WEEE
and
§ to define order and methods for providing the necessary information in accordance
with article 12 of Directive 2002/96 ЕС
The definitions of the Directive on WEEE, which don’t have legal description in the
national legislation, should be transposed.
It is envisaged that a single legal act will be adopted regulating EEE and WEEE, the actions
associated with WEEE, the concerned parties, their obligations, responsibilities and
relations, controlling authorities, penalties and so on. On the other hand through the
amendment of the legal acts, the regulations concerning WEEE have to be unified.
II.1.3. Legal acts currently in force in Bulgaria, relevant to

Directive 2002/95/ЕС
The legal acts in Bulgaria, concerning Directive 2002/95/EC on the restriction of the use of
certain hazardous substances in electrical and electronic equipment are:
§ Act on the technical requirements towards products – publ. State Gazette
86/1999 г.
§ Ordinance on essential requirements and evaluation of compliance of electrical
equipment for use within specified voltage limits – publ. State Gazette 62/2001г.
§ Ordinance on essential requirements and evaluation of electromagnetic
conformability - publ. State Gazette 78/2001г.
8
§ Ordinance on the essential requirements and evaluation of compliance of
household refrigerators, freezers, equipment for storage of frozen food products
and their combinations – publ. State Gazette 84/2002 г.
§ Ordinance on the essential requirements and evaluation of compliance of toys –
publ. State Gazette 62/2001 г.
§ Ordinance on requirements towards production and placing on the market of
batteries and accumulators and treatment and transport of waste from batteries
and accumulators – publ. State Gazette 61/2000
§ Ordinance on marking for compliance with essential technical requirements

towards products – publ. State Gazette 66/2000 г.
§ Ordinance 3 of 2003 on the national scheme for eco-labeling – publ. State
Gazette 49/2003 г.
The main purpose of the Directive and the national legislation is reduction of the risks for
the human health and environment. The most effective way to reduce these risks is by
substituting the hazardous substances with non-hazardous or less hazardous materials.
The legislation currently in force in Bulgaria treating the restriction and reducing of
hazardous substances in equipment and facilities, shares to great extend the purpose of the
Directive. In general, the legal acts in force define the restrictions of the use of substances
in equipment or facilities, covered by the Directive on WEEE. The restrictive provisions in
force are included in secondary legal acts, adopted according to laws regulating different
social relations. These acts introduce requirements towards equipment covered by the
Directive, but as a whole don’t include restrictions of the use of hazardous substances.
For the effective implementation of the Directive and harmonization of the national
legislation a legal act should be adopted, which should ensure common regulation about the
introduction of restrictive measures in the use of hazardous substances in electrical and
electronic equipment, notwithstanding that in the number of legal acts concerning the clean
air, water and soil, have limit values about the maximum allowed concentrations of a
number of hazardous substances, including for the equipment covered by the Directive.
II.1.4. Functions and obligations of the competent authorities
The Minister of environment and water

- monitors and controls the implementation of the WMA;
- takes part in adoption of legal acts on the implementation of WMA;
- issues and withdraws permits for carrying out of collection, transportation,
temporary storage, recovery and/or disposal of waste;
- applies penalties for violations of WMA and regulations on its implementation;
- undertakes compulsory administrative measures;
Directors of Regional Inspectorates of Environment and Water

- Issue and withdraw permits for collection, transportation, temporary storage,
recovery and/or disposal of waste;
- Control:
1. the activities concerning generation, collection, including separate collection,
storage, transportation, recovery and/or disposal of waste;
2. the facilities and installations for storage, recovery and/or disposal of waste;
9
- Undertakes compulsory administrative measures.
Mayor of Municipality
- Develops and implements Programs on management of waste, generated on the
territory of the municipality;
- Controls the implementation of the municipal regulations issued under article 19
WMA, and the implementation of other legal acts concerning waste management;
- Organizes systems for separate collection of waste fluorescent and other lamps
containing mercury and determines the places for collection of spent batteries;
- Prevents throwing out of waste on not authorized places;
Director of Hygienic-Epidemiological Inspection

- Exercises sanitary control on the activities of treatment of hazardous waste;
Chairman of the State Metrological and Technical Supervision Agency

- In accordance with article 99 of WMA, control functions over the products, which
generate wide-spread waste after their use are imposed. According to this, while
transposing the Directive 2002/96/ЕС and the Directive 2002/95/ЕС functions for
the State Metrological and Technical Supervision Agency may arise.
II.1.5. Obligations of producers and importers of equipment,

covered by the Directive 2002/96/ЕС
According to the legal definition in Directive 2002/96 ЕС “Producer” is every entity, that
irrespectively of the selling technique used (including by means of distance
communication) produces and sells electrical and electronic equipment under its own brand
or resells under its own brand equipment produced by other suppliers.
“Producer” is also every entity, that imports or exports electrical and electronic
equipment in EU.
Producers are responsible for the creation of individual and/or collective systems for the
collection, treatment and recovery of WEEE.
The systems have to be made and to function so as to ensure:
1. Free take back of WEEE from households and users, similar to the households
2. Treatment of WEEE using the best available technologies for treatment, recovery
and recycling.
3. The recovery of the separately collected WEEE with a priority of reuse of whole
appliances and the rate of recovery of WEEE should not be less then the targets set in
article 7 of the Directive.
Producers:
§ Should be responsible for the financing of the implementation of the Directive;
§ Ensure that the products they put on the market are marked with the proper labels
and symbols, according to the requirements of the directive;
§ Prepare and keep data for the quantity of EEE, which they have put on the market or
have exported in the EU states and also the quantity and the types which they have
treated, recycled and/or disposed of on their own or through a third party;
10
§ Design products in a manner benefiting reuse, recycling and recovery of EEE and
their components;
§ Provide reuse, recovery and treatment information for each type of EEE put on the
market;
§ Have to provide information to the WEEE treatment and recycling facilities about
the different components and materials used as well as the content of dangerous
substances and preparations in EEE;
Distributors/ retailers
The distributors and retailers that sell products to the end users even if they are not included
in the definition of “Producer” should take back the wastes generated from the EEE sold by
them, which in any case is free for the households.
According to the directive the distributors and retailers may depart from the requirement for
taking back of WEEE only in case the Member states can guarantee the returning of WEEE
through third parties or collective systems if it is not made more difficult for the final holder
and remain free of charge for him.
II.2. Scientific, technological and technical support

In accordance with article 2 of the Directive 96/61/ЕС concerning the integrated pollution
prevention "best available techniques" shall mean the most effective and advanced stage
in the carrying out of activities and the methods for their realization, ensuring practical
suitability of the respective techniques for prevention of the pollution (mainly by setting
emission limit values or requirements for the design) and, where that is not practicable, to
reduce emissions and the impact on the environment.
• "Techniques" shall include both the technology used and the way in which the
installation is designed, built, maintained, operated and decommissioned;
• "Available” shall mean techniques developed on a scale which allows their
introduction in the respective industrial sector, under economically and technically
viable conditions, taking into consideration the costs and advantages, whether or not the
techniques are used or produced inside the respective state, as long as they are
reasonably accessible to the operator;
• "Best" shall mean most effective in achieving a high level of protection of the
environment.
The life cycle of EEE and the material balance of WEEE are shown on the scheme below.
The scheme shows the stakeholders that are important for the life cycle of EEE as well as
the range of activities, which have to implement the requirements of article 7 (2) of the
Directive. On this basis an analysis of the currently available facilities for collection and
recovery of waste in Bulgaria has been made.
11
Scheme of the life cycle of EEE and the material balance of WEEE treatment
Companies – consumers of recycled

Producers of EEE by the
materials
definition in the Directive
≥80%**
Retailers and distributors
Recycled components and parts of EEE

of EEE
Recycling of non ferrous metals
Extracting of precious metals

Recycling of ferrous metals
Consumers of EEE
Recycling of plastics
Recycling of rubber
business/households
Recycling of glass
Service centers for

Reused whole appliances* EEE
Facilities for treatment of separately collected

WEEE Collection
facilities for the
separate collection
Съоръжения за of WEEE
изгаряне с
оползотворява
не на енергия
≤20%** Disposal
* The second hand EEE has to be
facilities
accompanied by a certificate for
compliance with the standards
** article 7 (2) by categories EEE
12
II.2.1. Description of the facilities for collection and recovery of
waste in Bulgaria
In Bulgaria there are no treatment facilities for WEEE with enough capacity. There are
facilities for recycling of some of the materials used in WEEE. The larger companies for
recycling of ferrous metals are “Stomana Industry“ Pernik and Kremikovtsi; for non-ferrous
metals – “KCM” – Plovdiv, “Monbat” – Montana, OCK Kardjali; for plastics - “Himik”
Asenovgrad, “Phoenix Plastic” - Turgoviste; for glass – “Stind”, Drujba” etc.; for rubber –
“Gumi Eco” in v.Gaber. There are no companies for recycling of textile waste.
In Bulgaria, there is capacity for the recycling of the materials1 as follows:
§ plastics /polyethylene, polypropylene, polyvinyl chloride, polyethylene
terephthalate/ – 12 000 tones/annually,
§ glass – 60 000 tones/annually (used capacity in 2001 г. - 12 000 tones),
§ ferrous metals – 750 000 tones/annually
The existing broad network of service centers has great experience in the repairing of some
components of EEE and repairing of whole EEE. This is confirmed by the research made in
2002 in a pilot region (Burgas, Pomorie and Karnobat) aiming to assess the quantity of
РСВ-containing appliances and materials and the capacity for their environmentally sound
management in Bulgaria2.
The facilities for incineration with energy recovery, which were constructed during the last
few years, mainly incinerate hospital waste. As facilities for incineration with energy
recovery may be used the cement plants, which now are developing plans for incineration
of waste composite materials, plastics, textile etc.
Concerning the existing companies for collection and trade with wastes from ferrous and
non-ferrous metals there is detailed information, as this activity is under a license regime
and there is a register in the Ministry of Economy.
According to this register by 16.08.2004 in Bulgaria there are 520 licensed companies
trading with ferrous and non-ferrous materials. The number of companies is different in the
different regions of the country but some of them execute their activities in more than one
place. Summarized data about the number of the registered economic organizations
performing such activities in the different regions are presented in the table below.
Table 1. Allocation of the licensed economic organizations involved in the

collection and trade of ferrous and non ferrous metals by regions in Bulgaria
No Region Number of companies
1 Blagoevgrad 11
2 Bourgas 16
3 Varna 27
4 Veliko Turnovo 31
1
The data is from the Implementation program for Directive 94/62/EC in Bulgaria
2
Origin, Quantity and Destination of PCB-containing Residues in Bulgaria, ARGUS GmbH and local
partners BalBok Engineering Co. and IC-ISI Innovation Center, the survey in the model region was conducted
in 2002
13
No Region Number of companies
5 Vidin 5
6 Vratza 20
7 Gabrovo 6
8 Dobrich 3
9 Kurjali 6
10 Kustendil 2
11 Lovetch 8
12 Montana 10
13 Pazardjik 17
14 Pernik 25
15 Pleven 10
16 Plovdiv 29
17 Razgrad 8
18 Ruse 22
19 Silistra 8
20 Sliven 8
21 Smolan 3
22 Sofia 27
23 Sofia (capital) 140
24 Stara Zagora 25
25 Targovishte 7
26 Haskovo 14
27 Shumen 16
28 Yambol 17
Some of these companies may serve as a basis for establishment of collecting sites for
separate collection and dismantling of WEEE after provision of additional equipment and
personnel training.
By 1 August 2004 in Bulgaria there is a system for separate collection and recovery (95%)
of waste from fluorescent lamps with one collection facility of 2500 m2 and two mobile
collecting facilities – 3.5 tones and 20 tones. This system covers the big enterprises that
possess spent fluorescent lamps. The separately collected waste is directed for recycling in
a plant in Germany. The system functions for a year and it is working with 10% of its
capacity.
Concerning the treatment of hazardous substances and components of EEE in Bulgaria
there are the following possibilities:
- PCBs in capacitors – the practice in the EU shows that the recycling of this type of
waste can not be undertaken and so it is incinerated in installation for hazardous
waste and disposed in mines. In Bulgaria there is an alternative for the disposal in
mines – permanent storage in licensed equipment (reinforced concrete container B-
B cube).
- Components containing mercury like switches and backlighting lamps – in Bulgaria
exists the practice that these components are collected separately by holders
different from households and consequently they are directed to recovery facilities
abroad meeting the requirements of the WEEE Directive and Regulation 259/93.
14
- Batteries – in Bulgaria the management of this type of waste is regulated by a
special ordinance which transposes the requirements of the Directive 91/157/EEC.
- Printed circuit boards in mobile phones generally and other appliances, with surface
more than 10 cm2 – currently in Bulgaria there are no licensed facilities for the
treatment of this kind of waste but there are opportunities for the construction of
such plants.
- Toners cartridges, liquid and pasty, as well as color toners – a project for the
construction of a facility for the recycling of this kind of waste is currently in
progress. A broadly used technique in Bulgaria is the refilling of the toner cartridges
by licensed companies.
- Plastics with brominated flame retardants – currently there are no licensed facilities
for the treatment of this kind of waste but there are opportunities for the
reorganization of existing plants for incineration with energy recovery to treat this
type of waste. Another way is to direct the waste to facilities abroad.
- Asbestos waste and components containing asbestos – in Bulgaria there are
technologies for the conditioning of this type of waste through its immobilization in
a cement matrix, which is used in the construction industry. According to Decision
2003/33/EC, after the immobilization the asbestos waste can be taken to landfills for
non-hazardous waste.
- CRT – there are no facilities for the treatment of these wastes in Bulgaria. It is
considered that this type of waste should be directed to facilities abroad.
- CFC, HCFC, HFC, HC – in Bulgaria there aren’t any plants for the extraction and
recycling of this kind of waste.
- Gas discharge lamps – in Bulgaria the management of this type WEEE is
determined by a special legal act and they are collected by the final holders, other
than households, and afterwards they are directed to plants for recycling abroad,
meeting the requirements of the WEEE Directive and Regulation 259/93. The
current system covers only the business users of this EEE.
- LCD - there are no facilities for the treatment of these wastes in Bulgaria. It is
envisaged that this type of waste should be directed to facilities abroad.
- External electrical cables – it is envisaged that they will be disposed in the facilities
for incineration with energy recover. The preliminary surveys PCBs in external
electrical cables in EEE in Bulgaria were not found.
- Components containing refractory ceramic fibers – in Bulgaria there aren’t any
facilities for the treatment and recovery of this kind of waste. The amount of EEE
containing such components in Bulgaria is very small and the construction of such
facilities is not economically efficient.
- Components containing radioactive substances – in Bulgaria there is very well
organized regulation system for radioactive waste management and thus there are
licensed facilities for its disposal. The extraction of the radioactive components
from the rest of equipment is strictly monitored. In every facility for metal recycling
each batch is checked for presence of radioactivity at the point of entrance.
- Electrolyte capacitors containing substances of special interest - there are no
facilities for the treatment and recovery of these wastes in Bulgaria. It is considered
that this type of waste should be directed to facilities abroad.
15
At the moment a lot of regional landfills for municipal waste are being constructed some of
which will be with cells for hazardous waste. The existing facilities for landfilling of
hazardous waste which are constructed and operated by the enterprises are used mainly for
landfilling of the wastes generated by their activities.
II.2.2. Methods for collection and treatment of WEEE in Bulgaria

The households and similar holders of small quantities of WEEE in most of the cases keep
their old appliances after they have bought equivalent new one, and they use them in places
where such appliances are used rarely or where there is free space to store them. This
tendency is observed even for the non-working appliances also. When the households and
the similar holders of WEEE at the end dispose of these wastes, they put them into the
municipal waste stream. The large appliances are collected as they contain large quantity of
metals. These appliances are dismantled (manually) by companies involved in the trade of
ferrous and non-ferrous metals and afterwards they are delivered for smelting. Mainly, such
WEEE are taken during the campaigns organized by the local authorities – in spring and
autumn.
The holders of WEEE which is classified as hazardous are obliged to store them until they
are given to licensed companies. For the appliances which can be reused, the holders seek
different ways for reselling or donating directly or through charity organizations.
In Bulgaria there is a functioning system for the collection and transportation, temporary
storage and export for recycling of waste fluorescent and other mercury containing lamps.
The system is established on the basis of the Ordinance on the requirements for putting into
market of luminescent and other containing mercury lamps, and on the treatment and
transportation of spent luminescent and other containing mercury lamps, which has entered
into force in 2000. The financing of the delivery of the fluorescent lamps is responsibility of
the consumers other then households. The ordinance does not contain provisions obliging
the producers to finance the system for the collection of lamps as it is in the Directive. Until
now the system covers only the business users, over 50 companies in Bulgaria. In 2004 21
tons of lamps have been exported to Germany. These lamps have been recycled with
recycling rate reaching over 90%.
II.3. Demographic Characteristic of Bulgaria

By 1 March 2001 the population of Bulgaria is 7 932 984 inhabitants and from 1985 on
there is a tendency of decreasing of the population at 65 904 (1986-1992) and 69 292 in the
following years until 20013. It can be assumed that this tendency will continue in the next
few years in the course of implementation of the Directive 2002/96/EC and by 2007 the
population will be approximately with 500 000 people less – meaning 7 400 000.
Below is summary of the demographic characteristic:
3
Census 2001, volume I, book 3, NSI, Sofia 2002
16
Table 1. Allocation of the settlements by the number of
population
No Size - Settlements Settlements Population Population
inhabitants 2002
2001 2001 2002
1 Total 5336 5333 7891095 7845841
2 under 199 2288 2319 160690 164775
3 200- 499 1232 1226 406626 406379
4 500- 999 870 853 616262 604805
5 1000-1999 536 529 738154 728468
6 2000-4999 264 262 771855 768695
7 5000-9999 65 65 471052 477160
8 10000-24999 42 41 647682 647393
9 25000-99999 31 31 1605952 1664672
10 100000-499999 7 6 1373313 1269752
11 over 500000 1 1 1099507 1113742
(Urban residence)
Total 240 242 5473018 5461255
1 Under 999 2 2 974 915
2 1000-1999 12 14 18641 22355
3 2000-4999 85 87 287727 297218
4 5000-9999 60 60 439222 445207
5 10000-24999 42 41 647682 647393
6 25000-99999 31 31 1605952 1664672
7 100000-499999 7 6 1373313 1269752
8 over 500000 1 1 1099507 1113742
Rural residence
Total 5096 5091 2418077 2384586
1 under 199 2288 2319 160690 164775
2 200-499 1231 1225 406383 406152
3 500-999 869 852 615531 604117
4 1000-1999 524 515 719513 706113
5 2000-4999 179 175 484128 471476
6 5000-9999 5 5 31832 31953
17
As it seems the tendency of decreasing of the population continues and it is stronger in the
small settlements and especially the villages. The data above shows that about 1/3 of the
population lives in the villages which will impede the organization of systems of separate
collection of WEEE. The overall area of Bulgaria is 111 000 sq.m. The population density
is 72 people per sq.m. Significant part of the area of Bulgaria is agricultural. From the
overall 111001902 decares 63764817 or 57% are agricultural lands.
II.4. Organization and methodology of collection and processing

of the necessary data
For the elaboration of the present implementation program it is necessary to analyze the
current state of EEE and WEEE in Bulgaria as well as to analyze the tendencies for the
change in the status.
For the purposes of the development of this program a database was created. It keeps all the
available data about: EEE, WEEE, the administrative structure of Bulgaria, producers,
importers of WEEE and other parties concerned.
The database contains all the necessary data for characterization of the elements in each
administrative structure:
- population
- urban population
- households
- surface
- average distances in the administrative units, which are calculated as the radius
of an equivalent circle. As a ground for this choice may be used the assumption
that center of each administrative unit has not less than half of the WEEE
generated in this unit.
- number of EEE in the private households for each type of EEE, for which there
is relevant data
The database contains all categories of WEEE. They are characterized by parts and
materials of EEE and by ecological characteristic taken from relevant publications.
II.5. Quantities and distribution of EEE in Bulgaria and rates of

accumulation of WEEE
The assessments and analysis of the quantities of EEE and WEEE in Bulgaria are based on
the data from NSI, published each year.
Basis for calculations are the results from the censuses, conducted in 1985 and 2001, which
contain data about the type and quantities of EEE from the households. It is evident from
the surveys for the relative percentage of each appliance in the overall weight of the EEE in
households, that 90% of the weight is formed by some “major” for the household
appliances. These “major” appliances are cookers, refrigerators, washing machines,
freezers, microwaves and TVs. The average weight of these appliances is 25 kg according
to the surveys in the network of shops.
EEE in households in Bulgaria in 2001, in kg
Data are form NSI, Census 2001
Major appliances
18
Number Average weight in kg Total weight in kg
Cookers, category 1 2286518 20 45730360
Microwaves, category 1 238334 15 3575010
Washing machines, category 1 1223799 55 67308945
TV, category 4 2284450 35 79955750
Freezers, category 1 741938 50 37096900
Refrigerators, category 1 2451931 25 61298275
Sum 9226970 32 294965240
Other appliances
PC, category 3 120851 20 2417020
Telephones, category 3 2112468 0.5 1056234
Others from categories 3 and 4 2717269 8 21279686
Sum 4950588 5 24752940
Total 14177558 23 319718180
The Census covers only the main types of appliances in the households. These appliances
are from categories 1, 3 and 4, according the Annex IA of the Directive on WEEE. The
group “Others” used above covers all other appliances and equals the result of subtraction
of overall quantity of WEEE in the households measured in the census and the quantity of
the “major” households appliances. The partial distribution of appliances is shown below.
19
Partial distribution of appliances in the households, by type and weight4
Others
PC 8%
1%
Cookers
14%
T elephones
0%
M icrowaves
1%
Refridgerat ors
19%
W ashing
m achines
21%
Freezers
11%
TV
25%
Table 3 contains data on the availability of “major” appliances in households. Data are from
the Censuses 1985 and 2001.
Table 2. Quantities of major EEE in

households5
№ Household 1985 2001
appliance Households Number, Weight, Households Number, Weight,
with the in thousands in tones with the in thousands in tones
appliance appliance
1. Cooker 71% 2150 43000 78.2% 2287 45730
2. Washing 14.0% 422 23240 42% 1224 67310
machine
3. Refrigerator 81.5% 2470 61760 84% 2452 61300
4. Freezer 0.0% 0 0 25.4% 742 37100
5. Microwave oven 0.0% 0 0 8.0% 238 3570
Average percentage of 33.3% 5042 128000 47.5% 6943 215010
contentedness
Total appliances cat.1
6. TV (cat. 4) 23.5% 713 25000 78.4% 2284 79960
Average percentage of 31.7% 5755 153000 52.6% 9227 294970
contentedness with
main appliances
Total appliances
Total appliances per 3030303 1.9 50.5 2922715 3.12 100.9
appliances appliances
household households
per
kg per households per
kg per
household household. household household
Total major appliances 2.9 0.65. 17.2 kg 2.7 1.16 37.2 kg
per inhabitant persons persons
4
NSI., "Census 2001"
5
Source: the database, containing processed results of the NSI’s conducted censuses 1985 and 2001.
20
per per
household household
Data in Tables 4 and 5 show the rate of contentedness of households with domestic
(category 1) and with consumer (category 3 and 4) equipment. The data are officially
published in the issues of NSI. The contentedness of the population with appliances within
the consumer equipment group by 2001 (color TV, video recorder, video camera, cable TV
set, satellite dish, audio system, telephone, mobile phone, home PC) according to the data
from the census in 2001 is shown in Table 4.
Table 3. Distribution of households and population according to number of units
within the consumer equipment group available in the households in 2001
No Number of units Inhabitants in the households Households
number % number %
1 Without any appliance 744518 9.5 336120 11.5
2 With 1 unit 1076636 13.8 491357 16.9
3 With 2 units 1840319 23.5 747378 25.7
4 With 3 units 1918215 24.5 651561 22.4
5 With 4 units 1198846 15.3 369974 12.7
6 With 5 units 614174 7.8 186295 6.4
7 With 6 units 294803 3.8 88836 3.0
8 With 7 units 109768 1.4 32778 1.1
9 With 8 units 25921 0.3 7678 0.3
10 With 9 units 4031 0.1 1216 0.0
As it is evident, 28.4% of the households have less that 2 units and only 10.8% have more
than 4 of all 9 consumer products.
The contentedness of the population with household appliances /big domestic appliances/
by 2001 (cooker, microwave, washing machine, dishwasher, refrigerator and freezer)
according to the above mentioned NSI survey also shows that 23.5% of the households
have less than 2 appliances and 19.8% of the households have more than 3 of the 6
appliances.
Table 4. Distribution of households and population according to number of large
domestic appliances available in the households in 2001
No Number of units Inhabitants in the households Households
number % number %
1 Without any appliance 639920 8.2 255703 8.8
2 With 1 1009049 12.9 428368 14.7
3 With 2 2035681 26.0 860030 29.5
3.1 Including with cooker and 1757501 22.5 757262 26.0
refrigerator
4 With 3 2286299 29.2 792444 27.2
4.1 Including with cooker, 1721567 22.0 583368 20.0
washing machine and
refrigerator
5 With 4 1389097 17.7 435836 15.0
6 With 5 410020 5.2 123415 4.2
7 With all 6 units 57165 0.7 17397 0.6
21
With a view of comparing the rate of contentedness of the households in Bulgaria and
Germany below it is presented table with the rates of of contentedness of the households in
Germany.
Table 5. Availability of large household appliances in households in
6 7
Germany and Bulgaria by years
Year Germany Bulgaria
Appliance 1980 1985 1990 1995 2000 2001 1985 2001
Washing machines 88 90 92 94 95 95 14 42.0

Dishwasher 21 27 35 40 53 56 0.0 1.6
Cooker 77 78 79 80 83 84 71 78.2
Refrigerator 95 95 95 96 96 99 81.5 84
Freezer 49 54 58 67 62 59 0.0 25.4
Microwave oven 1 4 33 52 63 65 0.0 8.0
Average % of 55 58 65 72 75 76 28 40
availability
Average number of 3.3 3.5 3.9 4.3 4.5 4.6 1.7 2.4
appliances in
households
Households, million 25 26.4 28.2 36.9 38.1 38.5 3.03 2.92
This table shows the large difference in the status of the households in Germany and
Bulgaria.
To estimate when the availability of appliances in households in Bulgaria will become
comparable with the status of the households in Germany, Table 7 contains a prognosis,
based on the data about the sales of household appliances by retailers. For the calculations
the decrease of the population and an increase of the sells at a rate of 4% annually
commensurable with the expected economic growth are taken into account.
Table 6. Retail Sales of Household Appliances, based on the data from
8
NSI and prognosis till 2010
Year Retail Sold Sold Availability Available Household Average

sales of appliances in appliances in of appliances appliances in appliances number
domestic tones, units, in the households in the household
appliances conditionally conditionally households with households, appliances
in calculated calculated with accumulation kg per per
thousands assuming accumulation in tones inhabitant household
BGL average at the end of
weight of 25 the period, in
kg and thousand
average units
price of 250
BGL
2000 187 364 18 736 749 6 943 215 010 27 2,4
2001 201 195 20 120 805 7 748 235 130 30 2,7

2002 251 486 25 149 1 006 8 754 260 278 33 3,0
6
Overview of the German Market of Household Appliances 2003/2004, GfK Marketing Services – ZVEI, Dec. 2003
7
processed data from Table 3
8
NSI Statistical Yearbook 2000, 2001, 2002 and 2003, р. 367-370
22
Year Retail Sold Sold Availability Available Household Average
sales of appliances in appliances in of appliances appliances in appliances number
domestic tones, units, in the households in the household
appliances conditionally conditionally households with households, appliances
in calculated calculated with accumulation kg per per
thousands assuming accumulation in tones inhabitant household
BGL average at the end of
weight of 25 the period, in
kg and thousand
average units
price of 250
BGL
2003 261 545 26 155 1 046 9 800 286 433 37 3,4
2004 272 007 27 201 1 088 10 888 313 633 41 3,8
2005 282 888 28 289 1 132 12 019 341 922 45 4,3
2006 294 203 29 420 1 177 13 196 371 342 49 4,7

2007 305 971 30 597 1 224 14 420 401 940 54 5,2
2008 318 210 31 821 1 273 15 693 433 761 59 5,7
2009 330 938 33 094 1 324 17 017 466 854 64 6,3
2010 344 176 34 418 1 377 18 393 501 272 69 6,9
The prognostic results show that the low level of EEE consumption by households will be
kept. Only in 2006 households in Bulgaria will have average 4.7 units, e.g. the level of
availability of those domestic appliances per household in EU in 2000.
The factors influencing the implementation of requirements of Article 5 (5) of the Directive
in Bulgaria are the quantities of appliances in the households, the term of usage and the
potential for WEEE generation.
Regarding the appliances’ term of usage by 2006, the relevant data from the Census in 1985
should be taken into consideration.
According to these data in 1985 households had 5755000 household appliances (cookers,
washing machines, TVs and refrigerators) – overall 153000 tones /Table 3/. Since 1985 the
population has decreased from 8900 thousand inhabitants to 7900 thousand inhabitants.
Taking into account that this is a result of migration processes, the household appliances are
kept, even not used. To this quantity of EEE which is 91% from all EEE /the figure above/
we must add the rest of EEE which is 9% or 15000 tones. The whole amount of EEE in
households in 2001 is 168000 tones.
An assumption is made that, for the households possessing 4 or more household appliances
within the consumer equipment group, the purchasing of new TV set will lead to discarding
the old one. This means that if these 686 777 households (Table 4) buy one additional TV
set it will lead to discarding of approximately 24 050 tones end-of-life TVs (average 35 kg
per TV).
By analogy, only for households with 4 and more domestic appliances the purchase of new
appliance will lead to discarding the old one. This means that if these 567648 households
(Table 5) buy one additional appliance with an average weight of 25 kg, approximately
14500 tones of WEEE will be generated (taking into account the term of usage of
household appliances of 20 for the EU states and reached level of contentedness of
23
households in Bulgaria by that year). Therefore, in 2006 it can be expected that 38 550
tones waste from end of life domestic appliances and end-of-life TV sets. 4200 tones should
be added to this amount- the waste quantity of the rest appliances (except TVs and large
household appliances), which represents 10 % of the total EEE quantity. The total WEEE
quantity, which is expected to be generated in 2005 is 42 833 tones.
As it is necessary to determine the capacity in Bulgaria needed to achieve the targets of Art.
5 of the Directive on WEEE, a prognosis for the potential for generation of WEEE in the
years after 2007 must be prepared – the WEEE potential. The prognosis is presented in
Table 8.
Table 7. Prognosis for quantities generated and separately
collected WEEE from households
Year Population of Prognosis for Prognosis for Prognosis Prognosis Prognosis

Bulgaria WEEE WEEE for % for for
generation, generation WEEE, separately separately
tones kg per covered by collected collected
inhabitant systems for WEEE WEEE
collection [tones] [kg/inh.]
01.1.2006 7 586 524 42 833 5,65 5 2141,65 0,28
01.1.2007 7 517 232 44 546 5,93 20 8909,26 1,19
01.1.2008 7 447 940 46 328 6,22 40 18531,27 2,49
01.1.2009 7 378 648 48 181 6,53 62 29872,41 4,05
01.1.2010 7 309 356 50 109 6,86 65 32570,56 4,46
The prognosis is based on the assumption that there will be 4% annual growth,
corresponding with the assumed growth of the sales of EEE.
The results presented in Table 8 are prepared to facilitate planning of the activities for
implementation of Art. 5 of the Directive. Establishment of a Registry containing data form
producers, importers of EEE, companies collecting WEEE after the establishment of
systems for separate collection and from the regular campaigns will allow the collection of
reliable information.
Table 8 shows, that only after 2008, the requirement for separate collection of 4 kg per
inhabitant will be reached. In that respect the requirements of art. 5 (5) of the Directive on
WEEE will be relevant for Bulgaria after 2008, if a rate of 62 % of WEEE covered by
systems for separate collection is achieved.
The percentage of WEEE covered by systems for separate collection is based on the data
from the Ministry of Environment of Germany. In Germany, in the year 2000, 400000 tones
(19%) of the generated WEEE were covered by the existing system for separate collection
and treatment. It is expected that in Bulgaria during the second year similar percentage of
WEEE covered by systems for separate collection will be achieved.
Except from private households, WEEE will be generated from other sources also. It is hard
to define the exact quantity of EEE respectively WEEE. For the purpose of the prognosis it
is assumed that the WEEE arising from private householders is about 45–50% from all
24
WEEE. This is based on estimates that in Germany this percentage is 46%. This percentage
is corroborated from the data of the National statistics for retail sales of EEE after 2000,
from which it can be assumed that 35-42% from the EEE are sold to private households.
25
III. ANALYSIS OF THE CAPACITY FOR THE
IMPLEMENTATION OF THE WEEE DIRECTIVE AND THE
ROHS DIRECTIVE
Requirements regarding the product design
Obligation: Encouraging the design and production of EEE in a manner facilitating the
dismantling and recovery, in particular the reuse and recycling of WEEE, their components
and materials.
Parties affected by this obligation:
§ Producers of EEE
§ Ministry of Environment and Water
§ Ministry of Economy
§ Ministry of Education and Science
§ Bulgarian Standardization Institute
§ Education facilities
§ Non-governmental organizations and the media
Possible ways to fulfill this requirement:
§ Through standardizing documents
§ Including of disciplines, connected with “green design” in the education of
specialists in the different educational stages
§ Through popularization of the eco-labeling
§ Through consultations of the producers and importers with the service centers
and with the operators of facilities for recycling and other forms of recovery of
WEEE
Necessary capacity to fulfill this requirement:
Producers, as a directly affected party from this provision should comply their
standardization documents about EEE with the EU regulations and the international
standards on EEE. The same applies for the importers. It should be considered that the
resources invested at the stage of development of EEE can guarantee the receiving of eco
labeling and on the other hand – they will optimize the costs for the dismantling, recycling
and disposal, which are covered by them on the basis of the “producer responsibility”
introduced in the WEEE Directive.
Currently in Bulgaria Ordinance № 3 from 15 May 2003 on the National scheme about the
eco labeling was adopted . Department “Prevention activities” at MOEW coordinates the
activities of the National scheme on eco-labeling and the performance of the procedures for
receiving these labels9. Orders of the Minister of environment and water are about to
introduce specific requirements for the receiving of eco labeling for some of the product
groups covered by the WEEE and ROHS Directives.
9
Organizational structure of MOEW, art. 25 (13), publ. in State Gazette 104/1999., ammended SG
100/2000,.28/2001, 32/2001г.,.91/2001,.64/2002,3/2003,.93/2003,.107/2003,.31/2004.
26
There is an increasing coordination between the work of the Ministry of Environment and
Water and the Ministry of Education and Science. The inclusion of disciplines, connected
with “green design” and the popularization of the eco markings are a natural part of this
cooperation.
The popularization of the importance of the eco labeling among the population may be
performed also with the help of non government organizations and the media.
Requirements for the separate collection

Obligation: Presence of available and accessible for the population collection facilities for
WEEE (taking into account in particular the population density) by 13 August 2005.
§ Local Authorities
§ Producers and importers of EEE
§ Analysis of the allocation of EEE in the households, including taking into
account in particular the population density
§ Determining the minimum number of facilities for separate collection
§ Determining the requirements of the facilities for separate collection
§ Ensuring the financing and construction of such facilities
Necessary capacity to fulfill this obligation:
Currently in Bulgaria there aren’t any publicly available facilities for the collection of waste
covered in the WEEE Directive. The households and similar to them holders of small
amounts of WEEE, as a rule, keep their old appliances (where there is enough free space to
store them). When the households and the similar holders of WEEE at the end dispose of
these wastes, they put them into the municipal waste stream.
There are collection facilities for scrap metals where almost all large domestic appliances
containing metal parts are accepted. However these facilities do not comply with the
requirements set in Annex ІІІ (1) of the Directive.
As part of the development of this Implementation program, an analysis of the allocation of
the appliances in the households was made, taking into account in particular the population
density. Schemes for the organization of these facilities by administrative (regions) and
controlling (RIEW) structures are proposed.
Obligation: Organizing systems, allowing final holders (households and similar users of
EEE) and distributors to return WEEE free of charge.
§ Producers of EEE
§ Importers of EEE
§ Retailers of EEE
27
§ Take back of old appliances when selling a new one
§ Establishment of collective and individual take back systems
The functioning of the systems could not be possible without the participation of the
distributors of EEE, who have to ensure the take back of WEEE from private households
free of charge if the customer buys new appliance which is from the same type and
performs the same functions as the returned one. Bulgaria has relatively small experience in
the set up of collective systems. At the moment experience regarding waste packaging is
being gained.
The local authorities (mayors) shall adopt local Regulations and may take part in the
organization of the functioning of the systems.
Now in Bulgaria the necessary capacity is not present. The parties related to this obligation
need some time to be informed about their role in order to be able to estimate the necessary
administrative and financial capacity. In addition, currently there are no clear criteria for
defining the conditions for refusing of taking back because of WEEE pollution.
The establishment of the systems for separate collection is related with overcoming of the
difficulties with the low population density and the higher percentage of the rural territories.
Obligation: By 31 December 2006 at the latest a rate of separate collection of at least 4

kilograms on average per inhabitant per year of WEEE from private households must be
achieved.
§ Retailers of EEE
§ Collection facilities
§ Households and similar to them generators
§ Non-government organizations and the media
§ Existing collection facilities
§ Stimulating the population to return the appliances that are not in use
§ Take back not following the principle for equality (i.e. a refrigerator for a cooker
etc.)
The analysis of the EEE in households from the census in 1985 and 2001 shows the fact
that in Bulgaria the households are not saturated with EEE. For example the large
household appliances per inhabitant in Germany are 3 times more than Bulgaria. There is
lower consumption of EEE in Bulgaria.
28
On the other hand in the country there is not enough capacity for collection of this amount
of WEEE both regarding the lack of collection facilities and readiness of the business
organizations to perform the taking of the WEEE back. There are no individual or collective
systems. The currently functioning system for collection of waste fluorescent lamps now
covers only the generators other than households, while this obligation concerns the waste
arising from households and similar users.
Requirements about the treatment of WEEE

Obligation: Setting up of individual or collective systems for the treatment of WEEE,
possessing the necessary permits to perform such activities issued by competent authorities
(MOEW or RIEW)
§ Competent Authorities: Ministry of Environment and Water, Ministry of
Economy and Local Authorities
§ Producers of EEE, listed in article 2, except when they export their production.
§ Importers of EEE
§ Retailers of EEE
§ Households and business users
§ Service centers and repair shops for EEE
§ Centers for dismantling, recycling and other forms of recovery
§ Setting up of individual systems
§ Setting up of collective systems
§ Setting up of centers for dismantling, recycling and other forms of recovery in
Bulgaria
§ Directing of the separately collected WEEE to existing centers for recycling and
other forms of recovery complying with the requirements of the Directive and
outside Bulgaria
Currently in Bulgaria there are no organizations of producers and importers of EEE for
fulfillment of their obligations for separate collection, dismantling and submission for
recycling and recovery of WEEE. By the adoption of the Waste Management Act
(September 2003) legal requirements were introduced for collective and individual
fulfillment of the obligations of the persons that put on the market products that generate
wide spread waste. The producers and importers of EEE are interested in participating in
such schemes because they will not be obliged to pay product charges and are able to
optimize the costs for management of WEEE.
Obligation: Treatment of materials and components from waste electrical and electronic
equipment with regard to the requirements of Annex ІІI, including the equipment
containing materials and components set in Annex ІІ of the WEEE Directive.
29
§ Competent Authorities: Ministry of Environment and Water, Ministry of
Economy and Local Authorities
§ Centers for collection and temporary storage
§ Research and development organizations
§ Encouraging research and development activities including thought financing
such research
§ Implementation of new technologies
§ Exporting abroad the separately collected WEEE to centers for recycling and
other forms of recovery complying with the Directive
Currently in Bulgaria there are no facilities with enough capacity for dismantling,
separation of the wastes into material flows and separation of hazardous and non-suitable
for recycling substances and materials. “Stomana Industry” – Pernik operates installation
for shredding of metal waste but as a whole the manual dismantling of bulky WEEE
predominates.
The question about the ensuring the financing of the construction of such facilities and the
implementation of treatment technologies complying with annexes ІІ and ІІІ of the WEEE
Directive is at hand.
Recovery
Obligation: Stimulating the re-use of the separately collected WEEE
§ Households and business users of WEEE
§ Sorting the WEEE to working and non-working in the separate collection
centers
§ Re-sale of the working appliances and components
§ Informing the population about the opportunity to by “second hand” appliances
and components
The fulfillment of this obligation does not demand significant additional resources if the
separate collection facilities are set up and functioning.
Obligation: Fulfillment by 31 December 2006 at the latest of the requirements about the
rates of recovery of the separately collected appliances according to their categories (except
category 8):
30
§ For WEEE falling under categories 1 and 10 of Annex IA:
o The rate of recovery shall be increased to a minimum of 80 % by an average
weight per appliance, and
o Component, material and substance reuse and recycling shall be increased to
a minimum of 75 % by an average weight per appliance;
§ For WEEE falling under categories 3 and 4 of Annex IA:
§ For WEEE falling under categories 2, 5, 6, 7 and 9 of Annex IA:
§ For gas discharge lamps, the rate of component material and substance reuse and
recycling shall reach a minimum of 80% by weight of the lamps.
§ Competent authorities: Ministry of Environment and Water
§ Research and development organizations
§ Encouraging research and development activities including through financing
such research
§ Implementation of new technologies
§ Exporting abroad the separately collected WEEE to centers for recycling and
other forms of recovery complying with the Directive
The fulfillment of this obligation demands significant financial resources. Currently in
Bulgaria there is no capacity for its entire fulfillment.
There are no existing facilities specialized in WEEE treatment or meeting requirements of
Annexes II and III of the Directive.
The capacity for recycling of materials in Bulgaria is as follows:
§ metal – practically unlimited
§ plastics /polyethylene, polypropylene, polyvinyl chloride, polyethylene
terephthalate/ - 12 000 tones per year
§ glass – 60 000 tones per year (used capacity in 2001 г. – 12 000 tones)
31
To evaluate the capacity for meeting the requirement of article 7 (2) of the Directive,
several scenarios were made. In the scenarios WEEE are separated in three groups and the
results are conforming to the three targets, set in the Directive:
§ Group 1 - categories 1 and 10
§ Group 2 - categories 3 and 4
§ Group 3 - categories 2, 5, 6, 7 and 9
The data for the possibilities for recovery and recycling of the different components and
materials from the three groups are presented in Annex I. It’s shown there that several
material flows are formed, which can potentially meet the requirements (as percentage
content) regarding recycling and recovery. The analysis of the capacities in Bulgaria for
recovery in conformity with the Directive these flows revealed the following:
1. As it was mentioned above Bulgaria has not enough capacity for separation of the
collected WEEE by materials and components and separation of the fluids and the
hazardous components form the waste. , e.g. there are no conditions for forming
material flows which afterwards to be sent to the existing recycling facilities or facilities
for incineration with energy recovery and/or facilities for disposal.
2. There is capacity in Bulgaria for recycling of ferrous and non-ferrous metals.
3. There is capacity in Bulgaria for glass recycling. However the waste flows of glass
destined for recovery as a result of the implementation of Directive 94/62/EC on
packaging and packaging waste and Directive 2000/53/EC on end-of-life vehicles
should be taken into account.
4. In Bulgaria there is capacity for plastics such as PE, PP, PET and HDPE, but there is no
capacity for other types of plastics used in EEE. There is a need to develop and
introduce technologies for recycling such plastic waste. Like the glass waste flow, the
quantities of plastic waste from other waste flows should be taken into consideration.
5. In Bulgaria there is no capacity for treatment of WEEE, containing hazardous
components or substances. There are no functioning technologies or facilities in
operation to treat hazardous waste resulting from WEEE treatment. A facility for
treatment of waste toner cartridges is planned to be constructed.
6. There are no facilities for incineration with energy recovery. The existing cement plants
are suitable for this purpose but up to now only one of them poses permit for
incineration of waste. It is expected that in near future the other plants will be
reconstructed with a purpose of incineration of waste with energy recovery. The waste
accepted in these facilities should be pre-treated - sorting, balling etc.
From the data presented in Annex 1 it is obvious that for the achievement of the targets for
recovery, reuse and recycling of WEEE of Group 1 the country should ensure recycling of
significant quantities plastics and glass. For these materials targets for recovery and
recycling should be attained in accordance with the requirements of Directive 94/62/EC and
the capacity of the existing installations will be used almost to its full extent. According to
the Program for Implementation of Directive 94/62/EC for the period 2006-2009 the
following quantity of packaging waste should be recycled:
Table 8. Recycling of glass and plastic packaging

waste
Year 2006 2007 2008 2009
32
Quantity plastic waste
[tones] 5904 8346 13285 16148
Quantity glass waste
[tones] 18618 22673 28178 33616
Table 9 shows that during the period after 2008 the capacity of the installations for
recycling of plastic waste will be filled up and in 2007 the country should recycle double
quantity glass waste comparing to the quantity recycled in 2001. Moreover for achievement
of the targets set in Art. 7 (2) (a), waste for which there is no wide spread practice such as
rubber, concrete, textile, organic materials should be recovered.
The lack of enough capacity for incineration with energy recovery and recycling of plastics
and glass hinders even at greater extent the attainment of the targets set in Art. 7 (2) (b).
The equipment in Group 2 contains less percentage of metals which requires the percentage
of recovery of the other components mainly plastics and glass to be increased. Furthermore
this WEEE is composed of components containing hazardous substances (CRT, printed
circuit boards, monitors of liquid crystals etc.) for which there are no facilities for recovery
WEEE of Group 3 contains large quantities plastic and glass. Moreover considerable part of
the plastic contains brominated flame retardants, which additionally hinders the recycling
and finding of markets for the recycled materials.
There are no facilities for recovery of waste gas discharge lamps and measures are taken for
export for recovery abroad. At present the lamps exported abroad are delivered to facility
that guarantees above 90% recycling rate Currently there is no mechanism for financing of
the collection and recovery of waste gas discharge lamps from the households.
Due to the problems for recycling and recovery of WEEE described above, the targets of
Art. 7 (2) of Directive 2002/96/EC should be attained gradually. Bellow it is presented
prognosis for the quantities and the percentage of recovery, recycling and reuse of WEEE.
Table 9. Prognosis for the quantities and the percentage of

recovery, recycling and reuse of WEEE
2006 2007 2008 2009
Quantity Quantity Quantity Quantity Quantity Quantity Quantity Quantity

Composition processed processed processed processed processed processed processed processed
of WEEE WEEE WEEE WEEE WEEE WEEE WEEE WEEE WEEE
[t] [% [t] [% weight] [t] [% weight] [t] [% weight]

weight]
Total for the 2141,7 8909,3 18531,3 29872,4
three
Groups
Group 1 1579,2 73,74% 6569,4 73,74% 13664,6 73,74% 22027,9 73,74%
Recovery, 947,5 60,00% 4467,2 68,00% 10248,5 75,00% 17616,6 79,97%

reuse,
recycling
Recycling, 947,5 60,00% 4270,1 65,00% 9565,2 70,00% 16800,4 76,27%

reuse
Disposal 631,7 40,00% 2102,2 32,00% 3416,2 25,00% 4412,2 20,03%
33
Group 2 536,2 25,04% 2230,7 25,04% 4639,8 25,04% 7479,3 25,04%
Recovery, 107,2 20,00% 736,1 33,00% 2319,9 50,00% 5606,2 74,96%

reuse,
recycling
Recycling, 107,2 20,00% 669,2 30,00% 2087,9 45,00% 4972,0 66,48%

reuse
Disposal 429,0 80,00% 1494,6 67,00% 2319,9 50,00% 1873,1 25,04%
Group 3 26,1 1,22% 109,1 1,22% 226,8 1,22% 365,9 1,22%
Recovery, 9,1 35,00% 49,1 45,00% 136,1 60,00% 257,7 70,43%

reuse,
recycling
Recycling, 9,1 35,00% 46,9 43,00% 104,3 46,00% 186,9 51,07%

reuse
Disposal 17,0 65,00% 60,0 55,00% 90,7 40,00% 108,2 29,57%
The necessary infrastructure for treatment and recovery of WEEE can be established after
the adoption of legal act for WEEE, the designation of the responsibilities of the
stakeholders concerned and the provision of the needed funds by each responsible party.
The accounts and the quantities listed in Table 10 and Annex 1 are only for the WEEE
collected from private households. The WEEE collected form the sources other than private
households should be added to this quantity. As a minimum this quantities should be
increased with 25 – 50 % which should be taken into account when planning the
infrastructure for achievement of the targets for recycling and recovery of WEEE.
In order to gain experience till the construction of new facilities the export of WEEE may
be a good solution for reaching the objectives listed in article 7 of the Directive. The export
of waste for recycling abroad will cost averagely 350 EUR per tone depending of the type
of WEEE and its condition. This cost should be taken into consideration in the decision
making process about the development and implementation of new technologies for
treatment of WEEE. This scenario should be examined in detail because it will reduce the
initial financing and thus on one hand it will allow the setting up of separate collection
facilities and on the other hand there is already experience of the export of fluorescent
lamps.
Information for users

Obligation: Producers should label appropriately electrical and electronic equipment put on
the market after 13.08.2005 with the symbol shown in annex IV; provide information to the
users about the possibilities and conditions for take back and the potential effects on the
environment and human health as a result of the presence of hazardous substances in EEE.
§ State Agency for Metrology and Technical Surveillance
§ Commission of Trade and Consumer Protection
§ Producers of EEE
34
§ Retailers of EEE
§ Households and business users of EEE
§ Marking of the equipment by the producers and importers
§ Providing user information at the moment of sale and through Local Authorities,
non government organizations and the media
The fulfillment of this obligation does not require significant additional resources from the
producers, distributors and control authorities. In Bulgaria there is enough capacity to meet
this requirement. At the moment there are requirements for labeling. The label certifies that
the appliances are in conformity with requirements set in the ordinances based on article 7
of the Act on the technical requirements towards products.
This requirement is very important for meeting the objectives of the Directive because it
will contribute to the voluntary participation of the users in the separate collecting facilities
for WEEE. Such participation will lead to the reduction of the costs for collection of
WEEE.
Information for treatment facilities

Obligation: The producers of EEE should be clearly identifiable by a mark on the
appliance; producers should provide reuse and treatment information for each type of new
EEE put on the market, its materials and components, as well as the location of hazardous
substances and preparations to the reuse centers, treatment and recycling facilities.
§ Producers of EEE
§ Providing information in the form of the manuals, online or on disc
§ Through the creation of or referring to standards
The fulfillment of this obligation does not require significant additional resources from the
producers and importers. According to article 7 of the Act on the technical requirements
towards products, producers and importers should make technical dossier of the equipment
which should be checked by the control authorities by request. Great part of the content of
this dossier complies with the requirements of the Directive. However other requirements
for provision of information by the producers for the components and materials in EEE
should be regulated by the secondary legislation.
Requirements for the collection and providing of information and reporting

Obligation: A register of producers and importers should be drawn up and it should contain
information including estimates on an annual bases on the quantities and categories of EEE
35
put on the market collected through all routes and systems, reused, recycled and recovered
in the country as well as the waste exported by weight or if this is possible by numbers.
§ Commission for trade and consumer protection
§ Regional Inspectorate of Environment and Water
§ Bulgarian EEA
§ National Statistical Institute
§ Bulgarian Custom Agency
§ Commission of Trade and Consumer Protection
§ Producers of EEE
§ Importers of EEE
§ Facilities for separate collection of WEEE
§ Facilities for recycling and other forms of recovery of WEEE
§ Creating of a register of the producers, importers and the facilities for separate
collection, recycling and other forms of recovery
§ Gathering information about the appliances put on the market
§ Gathering information about the life cycle of WEEE by facilities, weight and
numbers
§ Ensuring public access to the register
This obligation is very important for the financing of the activities connected with WEEE
and the control of the attainment of the targets for separate collection, recovery and
recycling. The improvement of the coordination between the affected institutions is
essential. The creation of such register will require resources and time.
The fulfillment of this obligation will require additional resources for the administrative
cost from all affected parties.
Requirements for the restriction of the use of hazardous substances in EEE

Obligation: The use of lead, mercury, cadmium, hexavalent chromium, PBB and PBDE in
the new EEE put on the market after 01.07.2006 is forbidden. There are some exceptions
according to the Annex of the ROHS Directive.
§ State Agency on Metrology and Technical Surveillance
§ Commission for trade and consumers protection
36
§ Regional Inspectorate of Environment and Water
§ Ministry of Health
§ Regional Hygienic- Epidemiological Inspectorates
§ Bulgarian Institute of Standardization
§ Producers of raw and refined materials
§ Processing companies
§ Suppliers of components of EEE;
§ Companies for assembling of EEE;
§ Producers of EEE;
§ Service centers of EEE;
§ Facilities for treatment, recycling and other forms of recovery of WEEE
§ Research and development centers
§ Informing the companies about the requirements of the Directive
§ Coordination of the national standards with the acts of the EU
§ Development of substitute substances
§ Popularization of the voluntary certification by ISO 14000 before the
enforcement of the Directive
All different participants in the production chain of EEE - producers of materials, suppliers
of components, assembling companies and producers10 – will be affected by the ROHS
Directive. The distribution of the expenses for the implementation of the Directive will
depend on the market structure on the certain sector of EEE. As part of these costs fall on
the consumers this means that they will bear some of the expenses which will probably be
different in the different sectors and products. It is assumed that EEE is only small part of
implementation of these substances. In a short period the suppliers of components probably
will have to bear the greatest part of the cost. But in long term this additional costs probably
will be taken by the assemblers and/or producers. The amount of this cost will depend on
the market structure.
In Bulgaria there isn’t any data for the presence of producers of BFR. As the use of lead,
cadmium and hexavalent chromium in EEE is estimated to be less than 10% of their use,
the restriction of the use of these substances in new EEE is expected to have relatively
small impact on the producers of raw and refined materials.
While the restricted substances enter the production stream of components the products
which use the components afterwards may have to be adapted or redesigned to ensure that
they will function with the new components. It is also possible that some companies will be
vertically integrated and so the research and development, production of components and
10
The supply of components and the assembly of the appliances may be performed by local producers or
abroad. This process is different by companies.
37
final assembly of the products will be made in the same place, in that case these companies
will be directly affected at all levels. If there is no need for changes of the design of the
products as a result of changes of the components then the producers at the end of the
production chain will be affected indirectly.
At this stage it is very hard to define the exact expenses as the restricted substances will be
used in some specific products more than in others and thus some sectors will be more
affected then others. In addition not all companies in the different business sectors will be
affecter equally, because some of them will not produce or will produce relatively small
amount EEE while some will not deal with or will deal with relatively small amount of
WEEE.
38
IV. ORGANIZATION FOR IMPLEMENTATION OF
DIRECTIVE ON WEEE AND DIRECTIVE ON ROHS IN
BULGARIA
IV.1. Relations that need arrangement
To achieve a working mechanism on WEEE management, the relations between the

following stakeholders need arrangement:
• Between the administrative structure and organizational structure of the executive units
for WEEE treatment and recovery.
• Between WEEE holders and transporters and collection facilities
• Manufacturers and importers of EEE and administrative structure.
There are no working relations between the above mentioned structures; some of these
structures are not even established yet.
The administrative structure in Bulgaria is established and the necessary regulations for
permitting, control and enforcement are in force. As WEEE requires a very complex
network of relations between parties, it is of key importance to define those who are
responsible for this waste. The responsibilities are spread among manufacturers, importers
and WEEE holders, different from households.
The responsibility of manufacturers and importers covers on one hand the content of
hazardous substances in the EEE, and costs for separate collection and treatment of
separately collected EEE on the other as well as the attainment of the targets for recovery
and recycling.
Holders of WEEE, different from households are responsible mainly for the
decommissioning and temporary storage of EEE till WEEE is transferred to the transporter.
They also are responsible for the costs for collection, treatment and recovery of “historical”
WEEE.
Responsibilities of retailers are limited to the taking of the WEEE back from households
and holders, similar to them and for delivering this separately collected WEEE to the
separate collection or treatment facilities.
Companies, collecting WEEE are obliged not to prevent further re-use or recovery of the
appliances or their components.
Responsibilities of the companies carrying out treatment, recovery and recycling of WEEE
are for use of technologies, meeting recovery and recycling target, set in art. 7(2) and to
fulfill the requirements of Annexes II and III of the Directive.
Competent authorities issue permits and control the activities of the collective systems for
collection and recovery of WEE. They issue permits for collection, transportation,
temporary storage, recovery and disposal of WEEE and respectively control the
implementation of the conditions set in the permits.
IV.2. Major problems and priorities

Implementation of the Directives on WEEE and RoHS has 4 aspects:
39
§ legal
§ economic
§ technical
§ informational
The legal aspect of the problem is the absence of secondary legislative act to impose the
responsibilities for WEEE management and to establish the necessary financial mechanism.
The economic aspect of the problem is related to the shortage of financial resources and
working mechanisms for their collection. First come the costs for control of the
implementation of the requirements of the Directive. Second – capital costs for establishing
collection treatment and recovery and recycling facilities. On the third place are the
organizational costs for producers and importers and for retailers for taking the WEEE back
and document turnover. Not to be missed are the costs for technological renovations for
production of new EEE to meet the requirements of RoHS and WEEE Directives.
The technical aspect of the problem is related to the selection of strategy for technical
assurance of WEEE management. The treatment technologies must meet the requirements
of art 7 (2) of the Directive on WEEE. Technical issue is also the capacity of retailer to take
back WEEE from households and from users other than private households (after 13th of
August 2005). The number of shops for EEE and their distribution according to space are
presented in Tables below. Data are from the NSI Statistical Yearbook 2003.
Table 10. Retail shops for white and brown goods

Year 2000 2001 2002
Unit
Number of retail shops
foe white and brown 1822 1888 2024
goods.
Table 11. Distribution of shops in 2002 г. according to

space in sq. m
Space Under 120 Between Between Above 1000 sq.m.
sq.m. 120 and 399 400 and 999
Unit sq.m. sq.m.
Number of 1911 99 8 6
retail shops
It can be expected based on the above data, that only 5% of the retail shops will actually
have the capacity to take back appliances. That means that the role of the State and local
authorities is of key importance for implementation of the Directive on WEEE.
The informational aspect is related to the way of generating, delivering, colleting and
processing of information, which will assure both implementation of the Directive and
compliance monitoring, enforcement and reporting.
The key-stone implementation activities are as follows (listed according to their priorities):
1) Development of legislative act transposing WEEE and RoHS Directives
40
– Defining type of schemes to guarantee collection, treatment and recovery of WEEE.
2) Establishment of registry and implementation of system for collection of information
about
– Producers of EEE in Bulgaria
– Importers of EEE
– Wholesalers of EEE
– Retailers of EEE
– Information about the weight and/or number of electrical and electronic equipment,
placed on the market, by type and by producer and importers
– Facilities for separate collection of WEEE
– Facilities for treatment and recovery of WEEE together with data about the
technologies applied
– Individual and collective schemes
– Use of hazardous compounds in production of EEE
3) Enhancement of the qualification of control authorities
4) Raising awareness, knowledge and interest among the stakeholders, especially:
– Producers of EEE in Bulgaria
– Importers of EEE
– Wholesalers and retailers of EEE
– Business users
5) Construction of facilities and establishment of schemes for separate collection
6) Construction of facilities for dismantling, separation, recycling and other forms of
recovery and/or directing collected WEEE to existing facilities for treatment abroad
7) Informing public about the danger for the environment and human health from
uncontrolled disposal of WEEE and about separate collection options.
41
V. FINANCIAL FRAME
V.1. Estimation of costs for implementation of Directives in

Bulgaria
V.1.1. Costs for development of WEEE management system in
Bulgaria
The initial costs include:
- costs for development of legislative act –approximately 15000 BGN (to be assigned
to external organization by MOEW)
- costs for development of a Registry of Producers and importers of EEE of facilities
for separate collection treatment and recovery of WEEE – between 100000 BGL
and 200000 BGL
- annual maintenance costs of the Registry - between 100000 BGL and 200000 BGL
- administrative costs – according to the estimates from producers of EEE in EU,
compliance with the Directive will increase administrative costs with 2000 working
hours annually per organization. For Bulgaria this means one employee plus
working place, or 8000 BGL. For the control authorities more than one working
place is needed depending on the territory covered.
V.1.2. Determination of the optimal number of collection facilities

Estimates for the WEEE generation rate shows, that in Bulgaria, starting in 2006 more than
42000 tones of WEEE will be generated annually. This quantity will grow up together with
the rise of the contentedness of households.
As it was described above, the practice in Germany shows that in the year 2000 20% of the
WEEE generated were covered by the system for separate collection and this percentage is
for all sources not only for households. In this respect the total capacity for separate
collection in Bulgaria in the end of 2006 should be no more than 10 000 tones. This can be
guaranteed by 15 collection points as it is shown below.
The analysis of the distribution of the appliances in the households and the population
revealed that the organization of the collecting points by RIEWs is the most appropriate
one. Thus the control and monitoring of the implementation of the Directive will be
facilitated. The proposed structure will assure that each collection point will serve on the
average 225 thousands households or 610 thousands inhabitants. The proposed organization
is presented in Table 13.
Table 12. Proposed initial distribution of WEEE separate
collection facilities in Bulgaria
№ Placement of the RIEW Number of Population Population Density of Number of
facility (town) households in towns, the collection
in the % population facilities
covered in the
region region,
persons
per sq.m
RIEW
1 Blagoevgrad 113402 341173 56.70 54 1
Blagoevgrad
42
№ Placement of the RIEW Number of Population Population Density of Number of
facility (town) households in towns, the collection
in the % population facilities
covered in the
region region,
persons
per sq.m
2 Burgas RIEW Burgas 156005 423547 70.60 50 1
3 Varna RIEW Varna 248130 677230 75.30 80 1
RIEW Veliko
4 Veliko Tarnovo 172134 437297 69.60 66 1
Tarnovo
RIEW Montana
5 Montana 211012 555368 57.30 53 1
and Vratza
6 Pleven RIEW Pleven 179157 481936 62.60 57 1
RIEW Plovdiv
7 Plovdiv 360017 1022495 65.30 97 2
and Pazardjik
8 Russe RIEW Russe 199614 560574 57.00 69 1
RIEW Smoljan
9 Haskovo 197758 570193 57.80 47 1
and Haskovo
Pernik (for
10 RIEW Sofia 224352 585606 65.00 43 1
Sofia-district)
11 Sofia - town RIEW Sofia 459765 1170842 95.40 846 2
RIEW Stara
12 Stara Zagora 277443 760573 66.20 63 1
Zagora
13 Shumen RIEW Shumen 123098 342067 57.80 59 1
TOTAL 2921887 7928901 15
AVERAGE 224761 609915 68.60 72
This organization allows the average distance for WEEE collection to be as low as 50-60
km. which leads to decrease in the operational costs. Thus, each collection point will collect
and transfer further 600 tones WEEE annually in the first years of implementation of the
Directive in Bulgaria.
The validity of this choice is proved by the practice of one of the leading German
companies in the field of waste management and waste recycling. It operates 400 collection
points and 14 recycling facilities in Germany, with capacity of 246900 tones per year. Their
average capacity per collection point is 620 tones per year, and the average distance
covered is 50 km.
V.1.3. Costs for establishment of a facility for separate collection of

WEEE
The collection facilities need space, depending on the maximum quantity of WEEE
processed annually and how long WEEE must be stored there before being transferred to a
recycling facility. A space of 2500 m2 per collection point is enough for acceptance of the
initial quantity of WEEE. Construction of a facility meeting requirements set in Annex III
of the Directive is assessed 70 EUR per sq.m or about 1705000 EUR per facility. The
additional equipment should include transport means and containers for WEEE as well as
loading equipment. The necessary equipment is assessed to additional 75000 EUR.
Thus, the estimated costs for construction of a facility for separate collection of WEEE are
250000 EUR.
V.1.4. Operational costs for collection facility

The personnel of each collection facility shall consist of 15 employees. These personnel
will be responsible for the logistics of the trucks, informational campaigns for WEEE
43
holders, WEEE collection and transportation, book keeping, reporting and accounting. The
responsibilities of the above mentioned personnel will also include sorting of WEEE in the
facility as suitable or non-suitable for direct re-use. Those suitable for re-use can be sold
directly from the facility or given for charity.
Annual operational costs of a facility consist of:
- Average costs per employee are 8000 BGL per year (social and medical insurance
included) or total 120000 BGL per 15 employees
- Consumables – electricity and water supply, heating during the winter, telephone,
etc. – 1000 BGL per month or 12000 BGL per year
- Transport of WEEE – 400 shipments * 1.5 tones each * 100 km per ply * 1 BGL/km
average for own and hired transport means = 40000 BGL
- Administrative transport – 3000 km per month * 0.40 BGL/km prime costs = 1200
BGL per month or 14400 BGL per year
- Printing materials and other costs for informational campaigns – 10000 BGL per
year
The overall costs per year per collection facility are 196400 BGL or about 100000 EUR. If
the facility operates full scale, the costs per tone will be 150 EUR.
V.1.5. Construction and operational costs for treatment and

recovery facilities
Capital costs for construction and equipment of WEEE treatment facility depend on the
technology to be implemented, type of waste to be treated and annual capacity. Regarding
the costs for construction and supply of equipment the calculations for separate collection
facility should be taken into consideration.
For the purposes of cost assessment, a comparison with prices for waste treatment in
facilities abroad can be used. Depending on the type of WEEE, prices for recovery in
facilities in EU are between 150 EUR per tone for white goods to 300 EUR per tone for
TVs and monitors. Hazardous components contained in the waste increase these prices.
A transport charge and the costs for logistics and notification procedures in accordance with
Regulation (EEC) 259/93 have to be added to these costs. On the average, one shipment can
be of 6 tones of used white goods or 15 tones of smaller appliances depending on the
volume of the appliances and packaging. Transport and administrative costs account
additionally for 200 EUR per tone.
Thus, costs for export of WEEE for recovery will be between 350 and 500 EUR per tone.
Every treatment facility that can provide lower prices for attainment of the targets of Article
7 of the WEEE Directive will be economically viable.
According to the prognosis if 7900 tones will be collected in the end of 2006 in all 15
collection facilities and they are exported for recycling abroad, the costs will be 635 EUR
per 1 tone WEEE separately collected and recovered in accordance with the Directive.
For some types of WEEE (such as fluorescent lamps, TVs, monitors and PCs), if the
existing recycling facilities that fulfill the requirements the Directive, are very expensive it
will be economically preferable to export them for recovery abroad. Moreover the
consumers of recycled materials are not in Bulgaria but abroad.
44
For other types of waste (such as cookers and washing machines), it is possible to organize
very quickly treatment facilities (at the collection points or at existing collection and
recovery installations) that will ensure meeting of the recovery targets. In this way, the
actual average price for collection and recovery of WEEE could be reduced below 450 EUR
per tone.
V.1.6. Summary
Summarized information about the necessary funds for implementation of WEEE Directive
in Bulgaria is presented in the table below.
Type of expenses Comments
1. Development of 100’000 EUR This is an estimate of the initial costs for
legislative act and activities, that are essential for
Registry implementation of the Directive and which
shall be realized by 2006.
2. Registry annual 75’000 EUR This is an average estimate and includes
maintenance personnel, consumables, transportation,
technical support and other operational
costs.
3. Construction of 3’750’000 EUR 15 facilities for separate collection are
WEEE separate 250000 EUR per facility planned to be established in the first years
collection facilities of implementation
4. Operational costs 1’500’000 EUR There are 15 facilities for separate
for the WEEE 100’000 EUR per collection of WEEE.
separate collection facility It is assumed, that facility will process
facilities 150 EUR per tone about 650 tones WEEE per year
WEEE
5. Treatment of At the moment it is Export of WEEE for recycling will cost
separately collected impossible to about 635 EUR for 2006.
WEEE provide sound Recovery of WEEE in Bulgaria meeting
estimation for requirements of art. 7 (2) of the Directive is
neither capital nor possible only for some waste, not for all.
operational costs
V.2. Financing
In Bulgaria, financial obligations of stakeholders are stipulated in the Waste Management
Act. According to it, recovery and disposal costs are covered by:
1. waste holders;
2. entities, that place on the market products, forming at the end of their usage wide-spread
waste, pay product charges. The rate and way of payment of this charges is stipulated by
a legal act adopted by the Council of Ministers of Bulgaria. Product charges can be
waived if these legal entities prove to the Minister of Environment and Water that they
fulfill their obligations for separate collection and recovery according to the WMA and
its ordinances.
Forms for waiving product charges are individual implementation of obligations for
separate collection and recovery or collective schemes (recovery organizations) for WEEE
management. The latter approach has the following advantages:
- optimization of waste management costs;
- promotion of new, highly effective and economically viable technologies
for recovery and recycling of WEEE;
45
- control over the finances, put in the system by the producers;
- reaching the maximum high rate of re-use of components of WEEE (for
example if the producers use the recycled components in their maintenance centers).
Analyzing the possible options for financing, one must consider the difference that the
Directive set between “historical” and “new” WEEE, and between WEEE from households
and from other sources (business users).
V.2.1. Waste generated by households and users, similar to them
V2.1.1. Financing of costs for management of waste resulted from

EEE placed on the market after 13.08.2005 (“new”)
Directive on WEEE requires producers and importers of “new” EEEE to provide a
guarantee that they will finance costs for separate collection, treatment, recovery and
environmentally sound disposal of waste resulted from this equipment. The WMA gives the
following options:
Participation in appropriate scheme

Product charges, paid by entities that place on the market product, which form wide-spread
waste, are collected by the Enterprise for management of environment protection activities
(EMEPA), organized at the Ministry of Environment. These charges are used for financing
the costs for separate collection, treatment and disposal of WEEE. The payment of the
product charge for the electrical and electronic equipment put on the market is a kind of
participation of the producers and importers in the collective scheme managed by the
EMEPA. The purpose of this scheme is to cover those entities that don’t want to participate
in the recovery organizations or to fulfill their obligations individually. As the charges are
paid per unit put on the market and they are collected by state enterprise, no additional
guarantee is considered necessary.
Other option, stated in the WMA is participation in collective schemes, so called Recovery
organizations. The members of these organizations pay a member fee at amount
proportional to the products placed on the market. The accumulated finances are used for
separate collection, recovery and disposal of the waste.
WMA stipulates mechanisms that guarantee fulfillment of the targets by the Recovery
organizations, so provision of additional guarantees is not considered necessary. However,
these mechanisms have to be further elaborated in the regulations on WEEE management.
Individual scheme
There is an option for the producers to fulfill their obligations individually. According to
the requirements of the Directive there is a need an obligation for provisions of financial
guarantees (insurance or blocked bank account) to be introduced in the legislation. In both
cases it has to be stipulated that if the obligations for collection and recovery are not
fulfilled, the insurance sum or the funds in the account will be transferred in the bank
account of EMEPA.
V2.1.2. Financing of costs for WEEE management from equipment,

placed on the market before 13.08.2005 (“historic” waste)
Directive on WEEE requires producers in the market to cover the costs for collection and
treatment of “historic” waste, based on their market share for that type of equipment. This
necessitates the market share of its members for the respective type of equipment to be
taken into consideration (not only the EEE quantity put on the market) when determining
46
the WEEE quantities that given Recovery organization or individual producer should
collect. Similarly, when the amount of product charges is determined for a given type of
equipment, not only the costs for collection of the WEEE generated during the current year
but the costs for collection and recovery of the “old” WEEE of the respective type as well
as the market share of the persons that put on the market the same type of equipment and at
the same time are members of Recovery organizations or fulfill their obligations
individually must be taken into account.
V.2.2. WEEE, generated by non-household users
V2.2.1. Financing of costs for management of waste resulted from

EEE placed on the market after 13.08.2005 (“new” waste)
Financing of costs for management of WEEE from non-household sources, placed on the
market after 13.08.2005 is not different from those generated by households. It is under the
producer’s responsibility.
V2.2.2. Financing of costs for WEEE management from equipment,

placed on the market before 13.08.2005 (“historic” waste)
Directive allows in the case of historic waste, the user to be totally or partially responsible
for costs for collection and treatment of WEEE. The existing practice in Bulgaria proved
that such an approach is sound and it is considered applicable for this type of WEEE.
V.2.3. Financing of the restriction of use of hazardous

compounds in EEE
Implementation costs for the RoHS Directive include costs for reconstruction of
technological lines, costs for step-by-step elimination of use of restricted substances,
possible additional costs arising from scientific research and testing of alternative
substances. In addition, there are costs for information and monitoring. All of these costs
should be covered by the producers of EEE. The State must provide incentives for scientific
research and implementation of new technologies.
47
VI. REQUESTED TRANSITION PERIODS
The expected date for accession of Republic of Bulgaria to EU is 1st of January 2007.
Bulgaria requests the following transition periods:
§ 2-year transition period for implementation of article 5 (5) of Directive

2002/95/EC regarding separate collection of 4 kg per inhabitant per year
from households
§ 2-year transition period for implementation of article 7 (2) of Directive

2002/96/ЕС regarding re-use/recycling and recovery targets
1. The request regarding transition period for implementation of article 5 (5) is based on
the following:
§ Low level of consummation of EEE by households. In 2001 the percentage of

contentedness of households with basic domestic appliances is 40%, which shows
that that purchases of new EEE leads to generation of WEEE but on a lower rate
(Table 6)
§ According to the prognosis on the generated quantities from households, showed

in Table 8, the expected quantities WEEE in 2006 are 5.65 kg per inhabitant.
Assuming 65% rate of separate collection of WEEE from households, the
requirement for minimum 4 kg. per inhabitant per year will be reached in the end
of 2008.
§ Due to absence of specific legislative act and financial mechanisms for collection
of the necessary funds, the organization of systems for separate collection of
WEEE can not be realized before 31.12.2006.
§ Density of population in Bulgaria is low.
§ The percentage of agricultural areas is high.

2. The request regarding the transition period for implementation of recycling and recovery
targets, set in art. 7 (2) of the Directive is based on the absence of WEEE treatment
infrastructure.
§ There are no facilities for WEEE treatment – shredders, facilities for dismantling,
separation into material flows, separation of fluids and hazardous substances
§ There are no facilities for waste incineration with energy recovery, except cement
production plants, that should be reconstructed
§ The available capacity for material recycling is only for some of the material
streams – metal and depolluted and sorted glass.
§ The market for recycled materials is quite limited in Bulgaria
48
§ Significant investments are necessary to establish facilities meeting requirements
set in art. 7 (2) and for development of waste collection systems and dismantling
centers.
49
VII. ACTION PLAN
The proposed Action plan covers the period 2005 – 2007 and includes the main measures and activities that have to be fulfilled in order to meet the objectives of
the implementation program of Directive 2002/96/EC and Directive 2002/95/EC. The structure of the Action plan is compiled with the targets and priorities listed
in the Program.
The target of implementation of this plan is to achieve optimum balance between the different legislation, institutional, economic and technical
measures and the implementation of an integrated approach for the management of WEEE. The plan defines the responsibilities of the different
institutions and organizations involved in the management of WEEE connected with the realization of the stated measures and activities, the
expected expenses and the sources of their financing.
No Measure/activity ExpectedDeadline Responsible

Proposed source
(implementation institutions and
expenditures of financing
period)
(thousands organizations
BGL)
OBJECTIVE PROTECTION AND IMPROVEMENT OF THE ENVIRONMENT THROUGH PREVENTION AND CONTROL OF THE
1 ARISINGS OF WEEE AND HSEEE
1.1 Updating the code register so as to comply to the 31.03.2005 NSI Institution budget
activities connected with waste management and
particularly WEEE. 30.06.2005
Registration of all parties by the new codes is demanded.
1.2. Discussion on the possibility of starting a project for the 31.12.2004 MOEW
research of the current state of the life cycle of WEEE in
and out of the households in a model region
Starting a project for the research of the current state of 31.12.2004 MOEW 70 EMEPA
the life cycle of WEEE in and out of the households in
model region
51
No Measure/activity Deadline Responsible Expected Proposed source
(implementation institutions and expenditures of financing
period) organizations (thousands
BGL)
1.3. Application of different prices for the treatment of WEEE permanent Operators of - -
according to the hazardous substances they contain treatment facilities
1.4. Coordinating the measures and activities on WEEE with 31.06.2005 MOEW - -
those on PCBs and PCTs according to the National
program for waste management 2003-2007
OBJECTIVE HEALTH PROTECTION
2
2.1 Introduction and control of restrictions of the use of Permanent after State Agency for - -
hazardous substances in EEE which become wide spread the enforcement Metrology and
waste of a legal act Technical
Surveillance
Commission for trade
and consumer
protection
2.2. Introduction of “cleaner technologies” in the industry 31.12.2007 BIA, Branch 100 Industry, External
associations financing
2.2.1 Development of new technologies 31.12.2007 BIA, Branch 90 industry, External

2.2.2 Training on using the developed technologies 31.12.2007 BIA, Branch 10 industry, External
52
BGL)
2.3. Defining the conditions when the distributors of EEE may 31.06.2005 Labor inspection
- -
waive take back of the WEEE in order to guarantee the MOEW
safety and health of their personnel with regulations about
WEEE
OBJECTIVE RATIONAL USE OF THE NATURAL RESOURCES TROUGH INCREASING OF THE RECYCLED AND RECOVERED
3 WEEE
3.1. Introduction of legal restrictions and prohibitions for the 31.12.2005 MOEW - -
discharge of WEEE in the stream of mixed municipal
waste
3.2. Discussing the possibilities for applying of financial 01.01..2005 MLSP, MEER, - -
measures for restriction of the import of second hand EEE MOEW, MF, ME
until Bulgaria joins the EU in order to meet the targets of
Directive 2002/96/EC for the recovery of the EEE
currently available in Bulgaria
3.3. Introduction of systems for separate collection of WEEE Permanent Producers and Up to 500 for Producers and
for its recovery importers the set up of a importers
Municipalities collection site
Up to 200 for
annual
operational
expenses per
site
3.4. Requirements about the separate collection and According the Municipalities, - -
transportation of WEEE should be included in the waste regulation Companies
management programs and municipal contracts on requirements
collecting and transportation of WEEE
53
BGL)
3.5. Exploring the possibilities for recovery of different types 30.09.2005 Industry МРРБ, 25 EMEPA
WEEE MOEW,
3.6. Introducing of quantitative targets for the recovery of 31.12.2005 MOEW - -
WEEE, according to the Directive 2002/96/ЕС
3.7. The facilities for recovery of waste should be adapted into 31.12.2007 Operators of facilities Depending on Operators of
compliance with the environmental legislation and installations the facilities and
companies’ installations
programs for
WM
3.8. Supporting the construction of additional facilities for permanent Industry Depending of Private
recovery of waste and reconstruction of the currently EMEPA the investments,
existing installations (plastic waste, waste from ferrous companies’ EMEPA
and non ferrous metals, glass waste, textile waste, rubber programs
waste and other arising in the processing of WEEE) 4 000
annually for
low interest
credits
3.9. Construction of installations for the recovery of WEEE 31.12.2007 MOEW Private
Recovery investments
organizations External financing
EMEPA
3.10. Exploring of possibilities for introducing tax concessions 31.12.2007 MF, MOEW - -
and additional incentives for the recycling companies
54
BGL)
OBJECTIVE IMPROVEMENT OF THE ORGANIZATION OF SEPARATION, TEMPORARY STORAGE, COLLECTION AND

4 TRANSPORTATION OF WEEE
4.1. To meet the target: “active performance of the consumers 30.06.2005 MOEW 20 EMEPA
for the success of the take back and collection of WEEE”
the criteria for the design and organizing of facilities for
the take back of WEEE from the householders should be
defined
4.2. An inventory of the licensed sites for collection and 01.01.2006 MOEW, ME 20 EMEPA
processing of ferrous and non ferrous metals should be
made and the possibilities for their reorganization in
collection facilities for WEEE should be estimated
4.3. Construction of facilities for pre-treatment of WEEE 01.01.2006 Producers and Producers and
including installations for separation by recyclable importers importers
materials, separation of fluids and hazardous substances
etc.
OBJECTIVE ENVIRONMENTALLY SOUND DISPOSAL OF WEEE
5
5.1. Organizing the sorting of WEEE from municipal waste in 31.12.2006 Landfill operators,
the municipal waste landfills and their return into the Municipalities
WEEE treatment facilities or disposal in the hazardous
waste cells
55
BGL)
5.2. Improving the control on the Implementation of the permanent RIEW, EEA - -
requirements for depositing of waste including monitoring
and penalties for the landfill operators who violate the
construction and operation requirements
5.3. Improving the control over the unauthorized disposal and permanent Municipalities, RIEW Municipal
incineration or other form of uncontrolled disposal of budgets incomes
WEEE from penalties
5.4. Identification of all companies whose activities require 31.12.2006 RIEW, EEA - -
permit for activities with WEEE
5.5. Issuing permits for activities with WEEE and controlling permanent RIEW, MOEW Industry, through
their implementation. the taxes for
Adding these permits to the Registry on WEEE licensing
OBJECTIVE LEGAL REGULATION OF THE WASTE MANAGEMENT AND ACCELERATION OF THE IMPLEMENTATION OF
6 THE LEGISLATION AND POLICY IN THIS FIELD
6.1. Transposing Directive 2002/96/EC and Directive 31.03.2005 MOEW 15 EMEPA
2002/95/EC and the EU decisions in the field of WEEE
management in the national legislation
6.2. Amendment of the municipal ordinances for the 31.12.2006 Municipalities - Municipal
collection storage and transportation of WEEE according budgets
to the targets of the national legislation
6.3. Updating the municipal programs regarding WEEE 30.09.2004 Municipalities - Municipal
management budgets
56
BGL)
6.4. Developing of a methodology for defining and prognosis 31.12.2005 Municipalities, 20 EMEPA,
the quantity and morphological content of WEEE MOEW Municipal
budgets
6.5. Revising the regional development plans in order to set up 31.12.2005 Regional - -
regional treatment facilities for WEEE and administration
implementation of other initiatives connected with WEEE
management
OBJECTIVE ENSURING OF PROPER AND RELIABLE DATA OF WEEE

7
7.1. Public procurement for the establishment of an 30.06.2005 MOEW 5 EMEPA
information system for MOEW for the collection of the
necessary information for monitoring and control of
meeting the targets of the Directive 2002/96/EC
7.2. Development, introduction and maintenance of the 31.12.2006 EEA 100-200 (for EMEPA
information system and a public access registry including MOEW construction)
all institutions involved the WEEE legislation and 100-200 (for
training for using this system. annual
maintenance)
7.3. Introduction of procedures for collection and processing permanent EEA, RIEW, NSI - -
the information and reporting to the international and
European institutions in order to fulfill international
obligations connected with WEEE management (Basle
Convention Secretariat, European Commission, European
Environmental Agency, Eurostat)
57
BGL)
7.4. Labeling of EE appliances in order to provide user 31.12.2006 Producers of EEE
information about the requirements that EEE should not
be illegally disposed
7.5 Gathering information from the producers about the Permanent Producers of EEE
components, materials and substances in EEE they
produce in order to facilitate the treatment and recovery of
WEEE and providing it to the treatment facilities
7.6 Getting information about the weight, amount of EEE put Permanent Operators of facilities
on the market in Bulgaria and collecting, reuse, recovery for the treatment of
and export of WEEE through which the meeting of WEEE, NSI, CA
objectives of the Directives are controlled
OBJECTIVE STRENGHTENING OF THE ADMINISTRATIVE CAPACITY OF THE INSTITUTIONS RESPONSIBLE FOR THE
8 WASTE MANAGMENT
8.1. Training of the experts in the RIEW to control, issued 31.07.2005 MOEW 10 (without STATE
permits and implementation of legislation of WEEE the costs for BUDGET,
management, including appointment of additional appointment External
personal of additional financing
personal)
8.2. Controlling the compliance with the permits for the Permanent after RIEW State budget
treatment of WEEE including periodical checks of the licensing (MOEW)
WEEE treatment facilities
8.3. Improving the municipal administrative capacity for Permanent Municipalities Municipal
control of the collection of WEEE from households budgets
including increasing personnel
58
BGL)
8.4. Training the experts in the municipalities involved in the Permanent Municipalities 40 (annually) EMEPA, External
implementation of legislation of WEEE management MOEW financing
8.5. Regular national meeting and discussion of mayors, 31.12.2006 MOEW, 10 EMEPA
producers and importers of EEE and representatives of the MUNICIPALITIEWS
competent institutions on WEEE management
OBJECTIVE INCREASING THE INVESTMENTS IN THE SECTOR AND THE IMPLEMENTATION OF THE PRINCIPLES
9 “PRODUCER RESPONCIBILITY” AND “POLLUTER PAYS” IN THE SYSTEM FOR INTEGRATED WASTE
MANAGEMENT
9.1 Preliminary discussion of the proposed regulations with 01.03.2005 MOEW
the participation of all interested parties
9.2 Organizing a discussion table including representatives of 31.03.2005 MOEW

all interested parties about the decisions on the
implementation of the Directives
9.3. Setting up financing scheme which should allow private 31.03.2005 MOEW, МИ, MF -
households to return WEEE free of charge and trying to
stimulate them to take their WEEE to the collection sites
OBJECTIVE PUBLIC AWARENESS
10
10.1. Organizing the training of the experts on the environment permanent BIA, Branch Private financing,
protection and managers in the business organizations in associations, MOEW EMEPA
order to clarify the requirements of the WEEE
management legislation
59
BGL)
10.2. Publishing information on the problems of WEEE permanent MOEW, EEA 25 (annually) EMEPA,
management External
financing
10.3. Organizing an information campaign for the population, 31.12.2006 MOEW 10 for each EMEPA,
local authorities and business companies including the Producers and campaign Producers and
treatment centers operators about the proper treatment of importers importers, traders,
WEEE Municipalities External
financing
60
VIII. BIBLIOGRAPHY
1. A report on the accounting implications for producers and business users of Electrical
and Electronic Equipment of articles 8 and 9 (including potential amendment) of the
EU Directive on Waste Electrical and Electronic Equipment, KPMG, 14 November
2003
2. Assessment of Responses to the Second Consultation Document: WEEE and RoHS
Directives, www.erm.com, April 2004
3. Bulgaria Country Commercial Guide FY2001, Computer Hardware Market,
http://www.factbook.ro/countryreports/Bu_ComputerHware_mkt.htm, 04.08.2004
4. Discussion paper of 28 March 2003 by the UK Government, Scottish Executive,
Welsh Assembly Government, Northern Ireland Administration on the
Implementation of Directives of the European Council and Parliament 2002/96/EC of
27 January 2003 Waste Electrical and Electronic Equipment (WEEE) & 2002/95/EC
of 27 January 2003 Restriction of the Use of Certain Hazardous Substances in
Electrical and Electronic Equipment (ROHS), Department of Trade and Industry, UK,
28 March 2003
5. Electrolux Sustainability Report 2003,
http://ir.electrolux.com/html/sustainabilityreport2003/index_8.phtml?header=print,
09.08.2004
6. Final Report Origin Quantity and Destination of PCB-containing Residues in
Bulgaria, Submitted by ARGUS – Statistik und informationssysteme in Umwelt und
Gesundheit GmbH, Berlin, BalBok Engineering Co, Sofia, IC-ISI Innovation Centre –
Iron & Steel Research Institute, Kremikovci, Berlin, October 2002
7. Guideline Disposal of White and Brown Goods Decree, Ministry of Housing, Spatial
Planning and the Environment Wastes Department, The Hague, 16 July 1998
8. Proceedings from: OECD Workshop on Extended & Shared Product Responsibility:
Economic Efficiency and Environment Effectiveness, Washington D.C., USA,
December 1-3, 1998
9. Report, WEEE & Hazardous Waste, prepared by AEA Technology, March 2004
10. Solutions for Implementation of the WEEE Directive into a national WEEE
regulation, RWE Umwelt Elektrorecycling GmbH, 16.08.2004
11. Technical report 65, Waste management facilities, Electronic catalogue, prepared by
Thomas Weibenbach, European Topic Centre On Waste, European Environment
Agency, Copenhagen, 2001
12. WEEE frequently asked questions about the household appliance industry’s appraisal
of Directive 2002/96/EC on WEEE, prepared by CECED, 22 January 2004
13. International Trade of Bulgaria 2003, NSI, Sofia, 2004
14. Local Authorities in Bulgaria 2003, NSI, Sofia, 2003
15. Environment 2002, NSI, Sofia 2004
16. Census 2001, Vol 1, Book 3, NSI, Sofia, 2002
61
20. Economic and Administrative Regions in Bulgaria 1997-2001, NSI, Sofia 2003
21. Statistical Year Book 2003, Data on 2002, NSI, Sofia 2003
22. Unified Classificatory of the administrative and territorial entities in Bulgaria, NSI,
Sofia 2001
23. NSI, Letter 336/05.08.2004 г.
24. Registry of MI, http://www.mi.government.bg/ind/lic/oochmc.html#restor,
16.08.2004
62
Annex 1
Quantity Quantity Quantity

Composition of WEEE processed processed processed
WEEE WEEE WEEE
[kg.] [t.] [ %]
Group 1 22027912,1 22027,91 73,74%
Concrete 1778651,13 1778,651 8,07%
Recycling and reuse 533595,338 533,5953 2,42%
Disposal 1245055,79 1245,056 5,65%
Other 1364927,98 1364,928 6,20%
Disposal 1364927,98 1364,928 6,20%
Rubber 200675,284 200,6753 0,91%
Recovery 50168,8211 50,16882 0,23%
Disposal 140472,699 140,4727 0,64%
Other combustible 337750,843 337,7508 1,53%
Recovery 67550,1685 67,55017 0,31%
Disposal 270200,674 270,2007 1,23%
Plastics with TBBPA 57279,0995 57,2791 0,26%
Recovery 28639,5498 28,63955 0,13%
Disposla 28639,5498 28,63955 0,13%
Organic materials 66246,2197 66,24622 0,30%
Recoery 19873,8659 19,87387 0,09%
Disposal 46372,3538 46,37235 0,21%
Iron 2153005,55 2153,006 9,77%
63
Copper 828079,11 828,0791 3,76%
Plastics 1288541,75 1288,542 5,85%
Recoery 257708,351 257,7084 1,17%
Disposal 257708,351 257,7084 1,17%
Plastics with phtalates 1475414,49 1475,414 6,70%
Recovery 295082,898 295,0829 1,34%
Disposal 295082,898 295,0829 1,34%
Steel 10977807,6 10977,81 49,84%
Glass 456418,233 456,4182 2,07%
Disposal 91283,6466 91,28365 0,41%
Textile 194354,658 194,3547 0,88%
Recovery 97177,329 97,17733 0,44%
Disposal 97177,329 97,17733 0,44%
Transformers 68514,2533 68,51425 0,31%
Disposal 13702,8507 13,70285 0,06%
Non-ferrous metals 209508,75 209,5088 0,95%
Containing hazardous
substances 0 0 0,00%
Magnetron 11369,4901 11,36949 0,05%
Disposal 11369,4901 11,36949 0,05%
64
Ozone depleting
substances 198843,673 198,8437 0,90%
Disposal 198843,673 198,8437 0,90%
Other hazardous 360523,918 360,5239 1,64%
Disposal 360523,918 360,5239 1,64%
Recovery 17616584,6 17616,58 79,97%
Disposal 4421361,2 4421,361 20,07%
Group 2 7479267,62 7479,268 25,04%
Electrolytic condensers 4487,56057 4,487561 0,06%
Disposal 4487,56057 4,487561 0,06%
Cable and other electrical 153324,986 153,325 2,05%
Recycling 122659,989 122,66 1,64%
Disposal 30664,9972 30,665 0,41%
Recovery 127783,287 127,7833 1,71%
Disposal 22549,9919 22,54999 0,30%
Antimony Trioxide 11966,8282 11,96683 0,16%
Recycling 11966,8282 11,96683 0,16%
Cadmium metal 2277,60238 2,277602 0,03%
Recycling 2277,60238 2,277602 0,03%
Metal 660419,331 660,4193 8,83%
Recycling 660419,331 660,4193 8,83%
Lead oxide 468950,08 468,9501 6,27%
Recycling 468950,08 468,9501 6,27%
Plastics 920697,844 920,6978 12,31%
65
Energy recovery 506383,814 506,3838 6,77%
Recycling 276209,353 276,2094 3,69%
Disposal 138104,677 138,1047 1,85%
Printed circuit boards 482412,762 482,4128 6,45%
Disposal 289447,657 289,4477 3,87%
Glass 4623683,24 4623,683 61,82%
Recycling 3236578,27 3236,578 43,27%
Disposal 1387104,97 1387,105 18,55%
Chromium VI 747,926762 0,747927 0,01%
Disposal 747,926762 0,747927 0,01%
Recovery 5606193,66 5606,194 74,96%
Recycling 4972026,56 4972,027 66,48%
Disposal 1873107,78 1873,108 25,04%
Group 3 365898,735 365,8987 1,22%
Others 29509,2136 29,50921 8,06%
Recovery 11803,6854 11,80369 3,23%
Recycling 2950,92136 2,950921 0,81%
Disposal 14754,6068 14,75461 4,03%
Recovery 851,922021 0,851922 0,23%
Disposal 1277,88303 1,277883 0,35%
Aluminum 32654,0558 32,65406 8,92%
Recycling 32654,0558 32,65406 8,92%
Iron 47181,4982 47,1815 12,89%
66
Recycling 47181,4982 47,1815 12,89%
Tin 2322,61779 2,322618 0,63%
Recycling 2322,61779 2,322618 0,63%
Copper 16262,757 16,26276 4,44%
Recycling 16262,757 16,26276 4,44%
Lead 14511,9287 14,51193 3,97%
Recycling 14511,9287 14,51193 3,97%
Plastics with phtalates 75159,2911 75,15929 20,54%
Energy recovery 37579,6456 37,57965 10,27%
Recycling 15031,8582 15,03186 4,11%
Disposal 22547,7873 22,54779 6,16%
Nickel 1959,1547 1,959155 0,54%
Recycling 1959,1547 1,959155 0,54%
Printed circuit boards 12577,1526 12,57715 3,44%
Recycling 3773,14579 3,773146 1,03%
Disposal 8804,00684 8,804007 2,41%
Glass 57325,2211 57,32522 15,67%
Recycling 34395,1327 34,39513 9,40%
Disposal 22930,0884 22,93009 6,27%
Zinc 5079,61829 5,079618 1,39%
Recycling 5079,61829 5,079618 1,39%
Precious and rare metals 438,815193 0,438815 0,12%
Recycling 438,815193 0,438815 0,12%
Other hazardous 68683,4427 68,68344 18,77%
Recovery 20605,0328 20,60503 5,63%
Recycling 10302,5164 10,30252 2,82%
67
Disposal 37775,8935 37,77589 10,32%
Plastics with brominated

flame retardants 99,7307257 0,099731 0,03%
Disposal 99,7307257 0,099731 0,03%
Recovery 257704,306 257,7043 70,43%
Recycling 186864,02 186,864 51,07%
Disposal 108189,997 108,19 29,57%
68

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MINISTRY OF ENVIRONMENT AND WATER

ANALYSIS OF THE REQUIREMENTS OF THE DIRECTIVES

I.1. LEGAL FRAMEWORK 4

II. ANALISYS OF THE CURRENT STATUS IN BULGARIA CONCERNING THE

II.1. LEGAL FRAMEWORK 6

III. ANALYSIS OF THE CAPACITY FOR THE IMPLEMENTATION OF THE WEEE

IV. ORGANIZATION FOR IMPLEMENTATION OF DIRECTIVE ON WEEE AND

IV.1. RELATIONS THAT NEED ARRANGEMENT 39

V.1. ESTIMATION OF COSTS FOR IMPLEMENTATION OF DIRECTIVES IN

VI. REQUESTED TRANSITION PERIODS 48

VII. ACTION PLAN 51

I.1. Legal Framework

I.3. Other relevant EU documents

II.1. Legal Framework

II1.1.1. Scope of the Directive

II.1.2. Current legal acts in Bulgaria, concerning Directive

• Waste Management Act – publ. State Gazette 86/2003

• Ordinance No 3 on waste classification – publ. State Gazette 44/2004

• Ordinance No 12 on requirements for the sites of facilities for waste treatment –

• Ordinance on requirements towards treatment and transport of industrial and

• Ordinance on requirements towards production and placing on the market batteries

II.1.3. Legal acts currently in force in Bulgaria, relevant to

§ Ordinance on marking for compliance with essential technical requirements

II.1.4. Functions and obligations of the competent authorities

The Minister of environment and water

Directors of Regional Inspectorates of Environment and Water

Director of Hygienic-Epidemiological Inspection

Chairman of the State Metrological and Technical Supervision Agency

II.1.5. Obligations of producers and importers of equipment,

II.2. Scientific, technological and technical support

Companies – consumers of recycled

Retailers and distributors

Recycled components and parts of EEE

Extracting of precious metals

Service centers for

Facilities for treatment of separately collected

Table 1. Allocation of the licensed economic organizations involved in the

II.2.2. Methods for collection and treatment of WEEE in Bulgaria

II.3. Demographic Characteristic of Bulgaria

II.4. Organization and methodology of collection and processing

II.5. Quantities and distribution of EEE in Bulgaria and rates of

Total 14177558 23 319718180

Table 2. Quantities of major EEE in

Washing machines 88 90 92 94 95 95 14 42.0

Year Retail Sold Sold Availability Available Household Average

2000 187 364 18 736 749 6 943 215 010 27 2,4

2001 201 195 20 120 805 7 748 235 130 30 2,7

2004 272 007 27 201 1 088 10 888 313 633 41 3,8

2005 282 888 28 289 1 132 12 019 341 922 45 4,3

2006 294 203 29 420 1 177 13 196 371 342 49 4,7

2008 318 210 31 821 1 273 15 693 433 761 59 5,7

2009 330 938 33 094 1 324 17 017 466 854 64 6,3

2010 344 176 34 418 1 377 18 393 501 272 69 6,9

Year Population of Prognosis for Prognosis for Prognosis Prognosis Prognosis

01.1.2006 7 586 524 42 833 5,65 5 2141,65 0,28

01.1.2007 7 517 232 44 546 5,93 20 8909,26 1,19

01.1.2008 7 447 940 46 328 6,22 40 18531,27 2,49

01.1.2009 7 378 648 48 181 6,53 62 29872,41 4,05

01.1.2010 7 309 356 50 109 6,86 65 32570,56 4,46

Requirements for the separate collection

Obligation: By 31 December 2006 at the latest a rate of separate collection of at least 4

Requirements about the treatment of WEEE

Table 8. Recycling of glass and plastic packaging