Sell on Etsy EPR Bulgaria: who is the producer?
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For Etsy sales in Bulgaria, the sourced hierarchy names the manufacturer or brand owner, importer and first distributor as the producer of primary packaging. It adds secondary (manufacturer or brand owner, importer and first distributor). Instica estimates which role fits your sales and prepares the data; you confirm the role, then sign and submit.
Who is the producer for Etsy sales in Bulgaria?
A packaging producer is not one business for every pack. The hierarchy for Bulgaria assigns a role at each packaging level, and 5 levels have roles named in the sourced text. Etsy sales touch 4 of them in Instica’s grouping, so the table below shows every level and marks the ones that apply to this channel.
| Packaging level | Roles named in the hierarchy | For Etsy |
|---|---|---|
| primary | manufacturer or brand owner, importer and first distributor | Applies to Etsy sales |
| secondary | manufacturer or brand owner, importer and first distributor | Applies to Etsy sales |
| tertiary | manufacturer or brand owner, importer and first distributor | Not part of a typical Etsy order |
| shipping | online marketplace seller and manufacturer or brand owner | Applies to Etsy sales |
| service | manufacturer or brand owner, importer and first distributor | Applies to Etsy sales |
| other | — | No role named |
Bulgaria: at the primary packaging level the producer hierarchy names the manufacturer or brand owner, importer and first distributor (2026).
Primary packaging is the pack that directly holds the item and reaches the customer with it: the bag, jar, bottle, can or wrapper. For Etsy sales the hierarchy assigns it to the manufacturer or brand owner, importer and first distributor, in that order of precedence.
Bulgaria: at the secondary packaging level the producer hierarchy names the manufacturer or brand owner, importer and first distributor (2026).
Secondary packaging groups or presents primary packs, such as an outer box, a sleeve or a multipack carton. For Etsy sales the hierarchy assigns it to the manufacturer or brand owner, importer and first distributor, in that order of precedence.
Bulgaria: at the tertiary packaging level the producer hierarchy names the manufacturer or brand owner, importer and first distributor (2026).
Tertiary packaging moves goods in bulk: pallets, stretch wrap, corner boards and outer cartons for warehouse and freight. For Etsy sales the hierarchy assigns it to the manufacturer or brand owner, importer and first distributor, in that order of precedence.
Bulgaria: at the shipping packaging level the producer hierarchy names the online marketplace seller and manufacturer or brand owner (2026).
Shipping packaging is what an order travels in to the customer: the mailer or shipping box, void fill, tape and labels. For Etsy sales the hierarchy assigns it to the online marketplace seller and manufacturer or brand owner, in that order of precedence.
Bulgaria: at the service packaging level the producer hierarchy names the manufacturer or brand owner, importer and first distributor (2026).
Service packaging is supplied at the point of sale to hand goods over, such as carrier bags, takeaway containers and gift wrap. For Etsy sales the hierarchy assigns it to the manufacturer or brand owner, importer and first distributor, in that order of precedence.
The roles above are defined by the law, not by the channel. This is what each one means for a seller whose orders come through Etsy, and the tests below are the questions to answer about your own business. For a seller on Etsy the role is a question of facts: who made the product, whose brand is on it, who packs and ships the order and whether it was brought into the jurisdiction. You answer those questions in the workspace, Instica reads the hierarchy against them, and you confirm the result.
- manufacturer or brand owner
- The manufacturer or brand owner is the maker of the packaged product when it is sold under the maker’s own brand or with no brand shown. Look at the label: if your name or brand is the one on the pack, or no brand is shown and you made it, this role is yours.
- importer
- The importer is the business that brings the packaged goods, or the packaging itself, into the jurisdiction. Look at where the goods came from: stock that crossed the border to reach you makes you the importer for that stock.
- first distributor
- The first distributor is the business that first makes the packaged goods available in the jurisdiction. Look at who first made the goods available locally: if that was you, the role falls to you.
- online marketplace seller
- The online marketplace seller is a business that sells through an online marketplace. Look at whether you list on a platform you do not run: sellers on someone else’s marketplace can carry this role.
The statute or regulator text behind the Bulgaria hierarchy, in its source wording:
Original wording
makes available for the first time on the territory of another Member State, directly to end usersSource: eur-lex.europa.eu: oj
What Etsy changes about the answer
The hub for Bulgaria gives the default answer, primary: manufacturer or brand owner > importer > first distributor. For Etsy sales the outcome is primary: manufacturer or brand owner > importer > first distributor; secondary: manufacturer or brand owner > importer > first distributor; shipping: online marketplace seller > manufacturer or brand owner; service: manufacturer or brand owner > importer > first distributor. The difference is the secondary, shipping and service levels, which an order placed through Etsy brings into scope and a plain in-store sale does not.
Instica groups the packaging levels an order placed through Etsy produces as primary, secondary, shipping and service. That grouping is our reading of how the channel ships goods, not wording from the law, and it is what makes the outcome here different from the default.
Etsy shops are typically small makers who buy in shipping supplies and send each order themselves. The order items download carries the SKU and the ship-to location of every sale, which is what links an order to the packaging it used.
For Etsy sales in Bulgaria, the producer outcome is primary: manufacturer or brand owner then importer then first distributor.
For Etsy sales in Bulgaria, the producer outcome is secondary: manufacturer or brand owner then importer then first distributor.
For Etsy sales in Bulgaria, the producer outcome is shipping: online marketplace seller then manufacturer or brand owner.
For Etsy sales in Bulgaria, the producer outcome is service: manufacturer or brand owner then importer then first distributor.
The hierarchy for Bulgaria names online marketplace seller as well, so an order placed through Etsy can bring the marketplace itself into the chain.
Bulgaria lists these sales routes as in scope: import, production and acquisition for the Bulgarian market.
Bulgaria treats these sales routes as in scope: import, production and acquisition for the Bulgarian market. Orders placed through Etsy reach the customer remotely, so the remote-sale wording is the one to read.
Does a small-seller threshold apply in Bulgaria?
One threshold is published for Bulgaria. A threshold can exempt a small producer, trigger registration or move a producer to a lighter regime, so check these before anything else as a seller on Etsy.
| Measure | Amount | Effect | Basis |
|---|---|---|---|
| tonnage | 10 tonnes per year | reduced duties | reported quantity |
Bulgaria threshold on tonnage: 10 tonnes per year; effect: reduced duties.
Marketplace sales count toward your totals even when the marketplace handles fulfilment, because the thresholds measure what you put on the market, not who drove the van.
Registration and the organisation in Bulgaria
Once you know you are the producer, the next questions are where to register and with whom. The facts below are the sourced answers for Bulgaria; Instica prepares the data, and you register and report yourself.
Bulgaria organises producer responsibility through more than one producer responsibility organisation: ECOPACK Bulgaria AD and ECOBULPACK; membership is not required.
Bulgaria uses more than one producer responsibility organisation. Instica estimates your fees; the organisation invoices you.
Bulgaria allows a producer’s obligation to be transferred to another party.
A transfer lets another party take on your obligation; the source says contract with a recovery organisation. If you sell through Etsy, ask whether the other party is willing before you rely on it.
Exemptions listed for Bulgaria
No verified exemption is published for Bulgaria yet.
Dates that matter in Bulgaria
4 dates are published for Bulgaria. Dates come from the regulator or the organisation, and each one shows what it covers.
| Kind | Date | Covers | Note |
|---|---|---|---|
| report | 15th of the following month for the 10 percent reporting discount | — | Timely payment by the 25th of the next month earns a further 20 percent. Commercial term of Ecopack. |
| other | August 12, 2026 | — | Regulation (EU) 2025/40 (PPWR) applies from this date; national EPR rules continue alongside it. |
| registration | August 12, 2026 | — | PPWR Art 45(3): a producer selling directly to end users in another Member State (Art 3(1)(15)(c),(d)) must appoint an authorised representative for EPR in each Member State where it first makes packaging available, other than its own. Registration also required (Art 44(2),(4)). Instica never acts as authorised representative. |
| report | 1 June each year, for the preceding full calendar year | — | PPWR Art 44(7) annual submission of Annex IX Part B information to the register authority; national implementation of the register is pending. |
Bulgaria: report date 15th of the following month for the 10 percent reporting discount.
Bulgaria: other date August 12, 2026.
Bulgaria: registration date August 12, 2026.
Bulgaria: report date 1 June each year, for the preceding full calendar year.
Marketplace order reports are available on demand, so the quickest way to be ready for a reporting date is to export the last period’s orders and check the destination split early.
Penalties in Bulgaria
6 penalties are published for Bulgaria.
Bulgaria penalty for Legal entity or sole trader not paying the product fee under Art 59 where required (Art 149(2)): BGN 30,000 to BGN 500,000 per offence.
Bulgaria penalty for Individual complier or recovery organisation: false information or records, obstructing access or audit, or breaching collection/treatment/system duties (Art 148(1) items 1, 3, 4, 6; sanction in Art 148(2)): BGN 50,000 to BGN 150,000 per offence.
Bulgaria penalty for Individual complier or recovery organisation: other Art 148(1) breaches, including not providing information or records: BGN 10,000 to BGN 20,000 per offence.
Bulgaria penalty for Individual complier not taking back packaging waste (Art 148(4)): BGN 20,000 to BGN 40,000 per offence.
Bulgaria penalty for Placing on the market packaging that does not meet the ordinance under Art 13(1) (Art 147(2) item 3): BGN 10,000 to BGN 50,000 per offence.
Bulgaria penalty for Member of a collective system refusing an audit (Art 149(3)): BGN 10,000 to BGN 30,000 per offence.
Penalties are quoted from the source. Instica does not predict whether one will be applied to you.
What Etsy data Instica reads
Instica reads one export from Etsy and maps each column to the fields an estimate needs: the order, the SKU, the quantity and where the order was sent. The destination is what splits your units by jurisdiction.
Etsy: the Etsy order items CSV layout is not yet published. Reason: Etsy's help page explains how to download the Order Items CSV but does not list its column headers, so the headers below are unconfirmed. Use the Order Items download, which carries SKU. Map your own columns if your file differs.
The layout of the Etsy export has not been confirmed against the publisher’s own documentation yet. Instica shows it as not yet published rather than guessing, and you can map your own columns.
Map your own Etsy columns in the workspace; the required fields stay the same.
What to do next as a seller on Etsy
- Confirm your role for Etsy sales in Bulgaria against the table above.
- Check the thresholds and exemptions with your total sales across every channel.
- Find out where producers register in Bulgaria.
- Export your Etsy orders and let Instica match the destinations and estimate the weights.
- Review the estimate, correct any figure you know better, then sign and submit the report yourself.
Instica measures, estimates and prepares the Etsy data. It does not decide your role, sign for you or submit anything.
Questions sellers ask
Am I the producer if I sell on Etsy in Bulgaria?
It depends on the facts of each product. The sourced hierarchy for Bulgaria names the manufacturer or brand owner, importer and first distributor for primary packaging. If you made the product, own its brand or imported it, you are probably in that list; if you only resell another brand’s goods, someone else may be the producer. Instica estimates the likely role from your answers and you confirm it.
Does Etsy register or report for me?
The hierarchy names online marketplace seller for Bulgaria, so the marketplace can carry a role in some cases. Do not assume it covers your own products: read the source and keep your own records.
What is different about Etsy compared with selling in a shop?
An order placed through Etsy is shipped to the customer, so shipping packaging enters the picture. For Bulgaria the outcome is primary: manufacturer or brand owner > importer > first distributor; secondary: manufacturer or brand owner > importer > first distributor; shipping: online marketplace seller > manufacturer or brand owner; service: manufacturer or brand owner > importer > first distributor. The hub for Bulgaria describes the default for primary packaging only.
Is there a size threshold for Etsy sellers in Bulgaria?
Bulgaria threshold on tonnage: 10 tonnes per year; effect: reduced duties. The threshold counts all your sales, not only Etsy.
When is the next date I should know about?
Bulgaria: report date 15th of the following month for the 10 percent reporting discount.
What happens if I do not register?
Bulgaria penalty for Legal entity or sole trader not paying the product fee under Art 59 where required (Art 149(2)): BGN 30,000 to BGN 500,000 per offence.
Do I need an organisation to handle this for me?
The sourced text for Bulgaria names no single organisation. Instica prepares the data and you choose how to register.
How these figures are made
Sources
- eur-lex.europa.eu: oj retrieved
Original wording: makes available for the first time on the territory of another Member State, directly to end users
- ecopack.bg: why choose ecopack retrieved
Original wording: obliged all producers and importers of packaged goods in the Bulgarian market to collect, recycle, and recover a set percentage
Original wording: ECOPACK Bulgaria does not distribute profit and manages the separate collection, recycling and recovery of packaging waste on behalf of its member companies.
Original wording: members transfer to ECOPACK their obligation to collect, recover, and recycle all packaging they release onto the Bulgarian market
Original wording: ECOPACK services are intended for all entities that import, acquire, or produce packaged goods for the Bulgarian market.
- ecopack.bg: pricing and business policy retrieved
Original wording: Indicated fee discounts apply only for reported quantities more than 10 tons per annum.
Original wording: After 10% discount for timely reporting till 15th of next month
- eur-lex.europa.eu: eng retrieved
Original wording: It shall apply from 12 August 2026.
Original wording: shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where
Original wording: by 1 June for each full preceding calendar year
- moew.government.bg: ZAKON za upravlenie na otpadacite retrieved
Original wording: продуктовата такса по чл. 59, в случаите, когато такава се изисква, се наказва с имуществена санкция в размер от 30 000 до 500 000 лв.
The free plan is enough to start. We estimate and prepare; you sign and submit.