Author: Svilena Velcheva
Published On: 23/01/2020

At the end of last year the usual news of illegal imports of counterfeit and excise goods, which flooded the media during holiday time, were displaced by waste imports.

Italian rubbish

815 tonnes of illegal rubbish were stopped by police near Milan in December. The cargo represented the end products of treated plastic, not as it was written in the documents – recycled plastic. Since June 2015, the Chairman of the Public Environmental Center for Sustainable Development (PECSD) Ilian Iliev has been monitoring the import of waste through the Port of Varna.

Since we are following the process, the topic has escalated twice in the public space – before the May 2019 Euro elections and before last October’s local elections, Iliev says. Various media have taken up the issue, but real measures by the state have not been reached, as the Chairman of PECSD believes. According to him, there was a feeling in the society that the business was to blame for the burning, and Kovachki was insulted as a specific culprit.

Since 2016, PECSD has regularly published on Facebook its photos and videos of waste bales waiting at the Varna port or traveling by BDZ wagons. Over the years, various citizens have helped us with monitoring, but they have remained anonymous, Ilian Iliev says. One of the first pictures we received was from an activist – a worker at Varna West, the ecologist recalls. The result was a meeting of port workers in which theey have been threatened that if caught taking pictures with the aim to give them to environmentalists they would have been fired immediately.

BDZ employees have also been watching the process for years, but their comment is only: “the smell poisons us”.

Since the beginning of 2018, imports have accelerated. Most analysts attribute it to the ban imposed by China on the import of plastic waste and more than 20 other recycling materials.

In February 2019 Ilian Iliev reports on the topic of the Conference on Democracy, which environmentalists organize annually in Varna. One of the guest associate professors and a civic activist from Peru makes a shocking speech. According to him, Bulgaria is known in the South American country not as a place for recreation and tourism, but as a destination for waste.

From the EU or from Africa?

With a frequency of about 25-40 days bales are unloaded at the Port of Varna, the Chairman of PECSD stated. The bales are labeled ‘rifiuti non pericolosi’ (non-hazardous waste – Italian). There is also a date of production, a producer company and a code for the waste itself. The waste comes mainly from Italy and the United Kingdom, but as large multinationals are involved, it is difficult to identify the source of the garbage. For example, one of the importers, Deco S.p.A., is part of a well-known company in Italy and abroad for the construction of tanks and systems for the wine, food and chemical industries. However, the company is also the founder of the Italian-Tunisian Ecoti, which operates landfills throughout Tunisia (North Africa).

In 2018, environmentalists monitor more than twenty ships importing waste through Varna ports. In addition to the port of Odessos, the PECSD Chairman also registered imports through Varna West. The waste that arrives at Odessos is transported from BDZ to the cement plant in Beli Izvor, Ilian Iliev says. The garbage from Varna West is transported by truck to Devnya Cement. The head of the Varna Association has also managed to locate one of the sources of export of waste for our country: Hartlepool Port – North East UK.

What do we import?

The garbage, intended for burning, is imported in Bulgaria with code 19 12 10. These are the so-called RDF – modified fuels derived from waste. Legislation requirements for this type of waste are non-hazardous, combustible and shredded to a certain extent so that they do not cause technical problems in the installations. Due to the heterogeneous waste, the so-called RDF fuel has variable parameters – calorific value, emission factor, biomass fraction, etc. Using RDF as a fuel for TPPs instead of coal leads to a significant reduction in the cost of purchasing allowances for greenhouse gas emissions. This type of incentive is enshrined in the EU Waste Framework Directive, where waste incineration was reclassified into the category “energy recovery” 10 years ago. The Association of Irish Environmental Physicians (IDEA) petitioned the European Parliament in 2009 against the request for reclassification of the incineration, focusing on the harmful effects of this process on public health. The document fails to change the will of the politicians.

There is another category, the so-called green list of EU waste. Such, for example, are plastic and rubber with code 19 12 04. Shipment of green waste is not subject to prior written notification and consent from the country of destination. They shall be accompanied solely by a document referred to in Annex 7 to Regulation (EC) No 1013/2006 and a written recovery contract between the carrier and the consignee. This type of waste (according to documents) was discovered in mid-August last year at the site of the Maritza 3 TPP at the behest of citizens. Upon inspection of the site, it was found that there were other materials between the plastic materials, ie. the waste didn’t match the code with which it was imported.
According to the Ministry of Environment and Water, only 3% of the waste in Bulgaria is incinerated in TPPs, and Maritsa is not among them. The remaining 97% go to cement kilns. What is happening then on the sites of the cement plants in Bulgaria?

Does anybody know?

By referring to the Access to Public Information Act, PECSD  asked to five institutions in an attempt to obtain data on the amount of imported, transported and used combustion waste, their sources as well as the enterprises operating RDF waste for the period 2014-2019: to the Ministry of Environment and Water (MOEW), to the Executive Environmental Agency (EEA), to the Regional Inspectorates of Environment and Water in Varna and Bourgas as well as to the Port of Varna.

The Ministry of Environment and Water referred us to the Basel Convention and the parliamentary scrutiny of the National Assembly in order to be informed about the quantities of RDF waste that have entered our country since 2014, as well as their sources.

The Regional Inspectorate of Environment and Waters in Varna has informed of the quantities it has checked for the period. The EEA refuses to provide information because 2019 has not been reported. EEA experts did not understand our questions about the sources of waste and the amount to which treatment activities were carried out for the period 2014-2019.

About RIEW-Burgas, it is unknown why they referred the questions to the Varna Inspectorate.

And the Port of Varna is still silent.

In response to environmental expert Neno Dimov from the parliamentary rostrum in September this year it is clear that in 2017, about 72,000 tonnes of energy recovery litter for cement plants were imported to Bulgaria. In 2018, the amount is 85,000 tonnes. Nearly 11,000 tonnes of them have been checked by RIEW-Varna on suspicion signals. We have no data on how much was imported through the Bourgas and Varna ports separately. Assuming that it is equal, it means that one quarter of the imported garbage in Bulgaria is officially of dubious documents, origin and quality.

In 2017 RIEW-Varna did not perform any signal checks. In 2018, there were three inspections throughout the year, with all the waste tested being destined for final recovery at Devnya Cement. Of all 13 inspections by signal from 2014 to 2018, six of them have been incinerated at Devnya Cement, six at Beli Izvor Plant and one at Zlatna Panega Cement.

Who burns garbage?

Since 2005, the EEA has issued 8 complex permits under the Environmental Protection Act for carrying out activities for the utilization of RDF waste. During the parliamentary scrutiny of September 13, Neno Dimov refers as first one Devnya Cement AD, owned by the Italian company Italchimenti. This is followed by Holcim AD – the cement plant in Beli Izvor, Vratsa (50 tons of used printer supplies from Italy at an unlicensed landfill were discovered in Vratsa). A considerable part of the garbage imported through the Port of Varna, without considering the amount for Devnya Cement, goes to the plant in Beli Izvor, says the Chairman of the PECSD Ilian Iliev. The Plovdiv-based Zlatna Panega Cement, Bobov Dol TPP, Vulcan Cement – Dimitrovgrad (owned by Italchimenti) and Toplofikatsiya-Sliven are also licensed for waste incineration.

Greenburn EOOD Sofia owns two installations for combustion of hazardous waste and generation of heat in our country. One is at the Biovet antibiotic plant in Razgrad and it has a capacity of over 10 tons of hazardous waste per day and 3 tons per hour of non-hazardous waste. The other installation is in the Cave – at the Biovet Veterinary Medicine Plant. It has a capacity of 2-3 tons per hour of hazardous waste. Biovet is owned by Kiril Domuschiev. Through its managed companies, Domuschiev also keeps the Shipping Company Bulgarian Navy and BMF Port Bourgas – a company-port operator and concessionaire of Terminal Burgas East 2 and Terminal Burgas West – where the ships loaded with garbage dock.

In addition to Devnya Cement, EcoSef Ltd. has a permit for the use of waste as fuel in the Varna region. In 2018, the company received a permit for a thermal treatment facility for hazardous (8 t / day) and non-hazardous waste (40 t / day) in an urban area opposite the Devnya quarter. At the end of last year, the company submitted a proposal to RIEW to increase its capacity to 9.8 tonnes / day hazardous and 66 tonnes / day non-hazardous waste, including new types of combustion wastes containing petroleum, asbestos, hazardous substances , sludge, oil filters, brake and antifreeze fluids. The company has a pledge of a trading company against a loan of BGN 2.66 million from the bank of Tsvetelina Borislavova. In 2017, Ecoseif’s revenues were BGN 16,000 and in the next year, when it receives the waste incineration permit, they jumped to over BGN 1 million. The company is part of Sofia’s Perfect Property Portfolio Ltd., whose sole owner , according to the Trade Register, is 22-year-old Simona Prodanova.

The permit of another company on the territory of RIEW-Varna includes waste treatment with code 19 12 10 – Metarex Ltd. in Sofia. The company is affiliated with Wind Energy Ltd. – Dobrich, according to the Commercial Register.

18 other companies in the area have a registration document for waste collection and transportation with code 19 12 10: “Terminal Operator” EOOD; Ecohim – Devnya OOD; Pattrans OOD; Tanatos Ltd.; Yanika Kline Trans EOOD; Tusius Ltd.; Ecohimsnab EOOD; Deni Logistics EOOD; Land Armi Group EOOD; Multi Trans Varna OOD; M-Trans EOOD; Eco Scrap Varna Ltd.; Transfreight OOD; Elemar Group Ltd.; KTY EOOD; Adian AMG EOOD; Meteor Trans – 02 Ltd. and Elemar Group Ltd..

The garbage business in Bulgaria is in an upward trend and is attracting more and more participants.

Only numbers

The Waste Management Act introduces a restriction on the import to Bulgaria of waste destined for incineration up to quantities not exceeding half of the annual capacity of the installations. Without considering the large kilns of the cement factories, only 23 tons of hazardous imported waste can be incinerated in Razgrad and the Cave alone, subject to legal restrictions.

There is a strange discrepancy between the data on imported wastes, reported by former environmentalist Neno Dimov and the same, but with source, Finance Minister Vladislav Goranov. In response to a question to BSP MPs, Goranov states: the total amount of domestic industrial and technological waste generated for import into the country for the period 2014-2019 is 736 319 t. These are only customs-registered waste as imports from countries outside the European Union. On average, this amounts to about 123,000 tonnes a year. The figure is nearly 45,000 tonnes / year more than the figures presented by Neno Dimov to parliament.


Combustion, also called RDF energy recovery, would not be such a problem in Bulgaria if control were at a sufficiently high level and corruption was sufficiently low. In Bulgaria, the responsibility for what happens to imported garbage is blurred between several institutions. RIEWs are obliged to periodically control all installations licensed for waste activities. The EEA should make control and emergency measurements of the same installations. In addition, transboundary shipments of waste are also controlled by: customs authorities, border police, road police, as well as the road administration, the railway administration and the maritime administration.

However, the basic control is left in the hands of the operators of the incineration plants themselves. According to the permits issued, they must carry out their own continuous and periodic measurements of dust, sulfur dioxide, nitrogen dioxide, carbon monoxide, ammonia and organic substances designated as total carbon.
Operators are also required to carry out their own periodic measurements for hydrogen chloride and hydrogen fluoride, benzene, dioxins and furans and heavy metals.

The first signals for the incineration of imported garbage in Bulgaria date back to 2009, when a change to the European Waste Regulation was undertaken. Ecoglass then warned that Austrian garbage was being burned at the Beli Izvor Cement Plant and that air pollution samples were only taken when the plant was down.

What are we breathing?

The incineration of waste releases carcinogenic dioxins and furans, which are transported by air, accumulated in soil and water and become a danger to human health. Due to the heterogeneous composition of RDF waste, other toxic gases are thrown away during combustion. For example, phosgene, hydrogen cyanide, carbon monoxide and other compounds with strong toxic effects are released from plastics. In the case of waste plastic containing nitrogen, halogens, sulfur and other hazardous substances in the stream, the process can lead to air and soil pollution from the gases and ash generated.

We take as an example what is pollution from a cement plant with one of the most modern wastewater treatment plants in the country – Devnya Cement. From the 2018 annual report of the company to the EEA, it is clear that the carbon dioxide emission threshold is exceeded twice, carbon dioxide – 8 times, nitrogen oxides – 14 times, sulfur oxides – 5.5 times, of mercury – 4.6 times, of zinc – 2.5 times.

Nobody also talks about nanoparticles coming out of the chimney, because the laboratories in our country do not have the equipment to control them, the chairman of PECSD is indignant. By inhaling them, they enter directly through the cell membrane and damage the cell. The ultrafine dust particles are initially emitted as a result of combustion and are the most numerous.

In 2017, Bulgaria was sanctioned by the European Court of Justice for regularly exceeding the limit values ​​for fine particulate matter in the air. Last year, a lawsuit was filed against our country for failing to comply with sulfur dioxide standards.

The burning will continue

The incineration of imported waste in Bulgaria will continue with full steam while we closely monitor the statements of political figures by the governing. According to the eco-ministry and ex-minister Dimov, “in Bulgaria, the incineration of waste still has a small share compared to the average levels in the European Union, especially when compared to other countries. Only four Member States have a lower incineration rate – Cyprus, Malta, Greece and Croatia. In Latvia, it is in proportion to our percentage. ” The question is which data Dimov has compared – his, Goranov’s or coming from a third source.
The most recent European Union legislation by 2035 sets ambitious targets for 65% recycling of municipal waste and limiting their landfill to 10%. This means for the Bulgarian government that “at least 25% of the total amount of municipal waste should be incinerated. Otherwise, the goal of a 10% deposit is unthinkable. “.

Contrary to government policy, the Public Environmental Center for Sustainable Development is preparing a petition to ban the import of incineration waste with code 19 12 10.

Translator: Valentina Vagge