Bulgaria maintains its national notification system

Bulgaria has still not adopted the ECHA harmonized notification system, maintaining its national platform in force

To this day, Bulgaria remains the only Member State of the European Union that has not integrated the harmonized system for the notification of hazardous mixtures through the portal of the European Chemicals Agency (ECHA), as required by Annex VIII of Regulation (EC) Nº1272/2008 on classification, labelling and packaging of substances and mixtures (CLP). In practice, this mandates companies, importers, and downstream users placing hazardous chemical mixtures on the Bulgarian market to continue using the Bulgarian national system to submit their notifications.

Why is Bulgaria an exception in the EU harmonised notification system?

While the rest of the countries in the European Economic Area have completed or are close to completing their transition to the harmonized system—and notifications are carried out via the Poison Centre Notification (PCN) portal—Bulgaria remains outside the process and has not provided any estimated date for its integration. In fact, there is still no official confirmation from the Bulgarian authorities indicating their readiness to accept notifications through the ECHA portal, despite the transitional period for the implementation of the harmonized system having ended on 1 January 2025.

This delay is particularly significant because, from that date onwards, all notifications within the EU must be submitted in the harmonized format and accompanied by a Unique Formula Identifier (UFI), as established by the CLP Regulation and its subsequent updates.

The reason behind this postponement may be related to the same factors that have caused other objectives under Bulgaria’s Recovery and Resilience Plan to fall behind schedule. Thus, elements such as outdated pre-existing digital infrastructure in relation to ECHA’s technical requirements, together with the technical and administrative complexity involved in migrating to the PCN portal and the country’s economic context, may help explain the situation.

How are hazardous mixtures currently notified in Bulgaria?

What is clear is that, as of today, the process for notifying hazardous chemical products in Bulgaria is ruled by the Bulgarian Law on Protection Against the Harmful Effects of Chemical Substances and Mixtures. Consequently, importers and downstream users must provide the Bulgarian National Toxicology Centre with information on the product’s chemical composition, intended uses, and toxicological properties, among other data.

What does this situation imply for companies operating in Bulgaria?

For companies placing hazardous mixtures on the Bulgarian market, this situation entails an additional administrative burden, as it requires maintaining notification systems and workflows that are specific to Bulgaria, ensuring that the documentation and information submitted meet national requirements which do not align with the EU harmonized format.