© 2023 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org This work is a product of the staff of the World Bank Group. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy, completeness, or currency of the data included in this work and does not assume responsibility for any errors, omissions, or discrepancies in the information, or liability with respect to the use of or failure to use the information, methods, processes, or conclusions set forth. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Nothing herein shall constitute or be construed or considered to be a limitation upon or waiver of the privileges and immunities of the World Bank, all of which are specifically reserved. Rights and Permissions The material in this work is subject to copyright. Because The World Bank encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for noncommercial purposes as long as full attribution to this work is given. Please cite the work as follows: “World Bank. 2023. Diagnostic Analysis for Circular Economy Interventions in Bulgaria. © World Bank.” All queries on rights and licenses, including subsidiary rights, should be addressed to World Bank Publications, The World Bank Group, 1818 H Street NW, Washington, DC 20433, USA; fax: 202-522-2625; e-mail: pubrights@worldbank.org. Cover photo: Media Trading Ltd, Getty Images i Acknowledgments This report is one of three diagnostic analyses for circular economy interventions, which were conducted for Bulgaria, Poland, and Romania. The report was prepared by a World Bank team led by Sameer Akbar (Senior Environmental Specialist), Arno Behrens (Senior Environmental Economist), Eolina Petrova Milova (Senior Environmental Specialist), and Andrea Liverani (Lead Specialist). Research for the Bulgaria report was carried out by Ruslan Zhechkov and Venelina Varbova (GreenEdge Consulting), with contributions from Asel Doranova, Iana Stoyanova, and Nikolay Sidzhimov (Bulgarian Association of Municipal Environmental Experts). Special thanks also go to peer reviewers for their advice and comments that enriched the analysis: The two virtual reviews were chaired by Marc Sadler (Program Leader), and the peer reviewers were Ernesto Sanchez-Triana (Lead Environmental Specialist), Rieko Kubota (Senior Environmental Engineer), and Etienne Raffi Kechichian (Senior Financial Sector Economist). Project management support to the team provided by Grace Aguilar and Linh Van Nguyen is also gratefully acknowledged. The team would like to express its gratitude to Lasse Melgaard (Resident Representative for Bulgaria, Czech Republic, and Slovak Republic), Kseniya Lvovsky and Sanjay Srivastava (the former and current Practice Managers, Environment, Natural Resources and Blue Economy for Europe and Central Asia) for their invaluable guidance and support. The team is also very grateful for the support and information provided by Bulgaria's government, regional and municipal officials, representatives from the private sector, thinktanks and academia, and other stakeholders who contributed their time and insights during the development of this report. ii Contents Acknowledgments............................................................................................................................................... ii Acronyms and Abbreviations ........................................................................................................................... vi Executive Summary ............................................................................................................................................ 7 Methodology and Approach ............................................................................................................................... 7 Progress Toward CE in Bulgaria ....................................................................................................................... 7 The Way Forward: Four Initiatives for a More Circular Bulgaria ........................................................................ 9 1. Introduction: Report Objectives and Methodology.................................................................................... 10 1.1 Literature Review ....................................................................................................................................... 11 1.2 Stakeholder Consultation........................................................................................................................... 11 1.3 Survey........................................................................................................................................................ 12 1.4 Focus Groups ............................................................................................................................................ 12 2. The Circular Economy: Definitions, Strategies and Benefits ................................................................... 13 2.1 Definition .................................................................................................................................................... 13 2.2 Circularity Strategies and Circular Business Models ................................................................................. 13 2.3 Benefits of a Circular Economy ................................................................................................................. 13 2.4 Monitoring Progress Towards a Circular Economy ................................................................................... 14 3. The Circular Economy Policy Framework of the European Union ........................................................... 15 3.1 The European Green Deal......................................................................................................................... 15 3.2 CE Action Plan........................................................................................................................................... 16 3.3 EU Climate Law ......................................................................................................................................... 16 3.4 EU Industrial Strategy ................................................................................................................................ 17 3.5 EU SME Strategy....................................................................................................................................... 17 3.6 EU Just Transition Mechanism .................................................................................................................. 17 3.7 EU Waste Framework Directive................................................................................................................. 18 3.8 EU Plastics Strategy .................................................................................................................................. 18 3.9 The EU Plastics Own Resource or 'Plastics Tax' ...................................................................................... 19 3.10 Initiatives to Address Construction and Demolition Waste ...................................................................... 19 3.11 Initiatives to Address Marine Litter........................................................................................................... 20 4. The Circular Economy Strategic and Legal Framework in Bulgaria ........................................................ 21 4.1 Bulgarian Strategy for Transition to Circular Economy 2022–2027 ........................................................... 21 4.2 Bulgarian Strategy for SMEs (2021-2027) ................................................................................................. 21 4.3 Industrial Parks .......................................................................................................................................... 22 4.4 Bulgarian Innovation Strategy for Smart Specialization 2021–2027 ......................................................... 22 4.5 National Recovery and Resilience Plan for Bulgaria ................................................................................. 22 4.6 Operational Program Innovation and Competitiveness of SMEs (OPIC) 2021– 2027 .............................. 23 4.7 Just Transition Fund .................................................................................................................................. 23 4.8 Green and Circular Jobs ............................................................................................................................ 23 4.9 Marine Strategy of the Republic of Bulgaria and Program of Measures ................................................... 24 4.10 Waste Management and Plastics ............................................................................................................ 24 4.11 Construction and Demolition Waste ........................................................................................................ 25 5. The Status of the Circular Economy in Bulgaria ........................................................................................ 27 5.1 The European Commission’s Circular Economy Monitoring Framework .................................................. 27 5.2 European Semester Country Reports for Bulgaria ................................................................................... 28 5.3 Compliance with EU Waste Targets .......................................................................................................... 29 5.4 Resource Efficiency and Eco-Innovation .................................................................................................. 29 iii 5.5 SME-Related Indicators ............................................................................................................................. 30 5.6 Plastics ..................................................................................................................................................... 31 5.7 Marine Litter ............................................................................................................................................... 32 5.8 Construction and Demolition Waste .......................................................................................................... 33 6. SWOT Analysis for Bulgarian Transition to the Circular Economy ......................................................... 35 6.1 Strategic and Regulatory Framework ........................................................................................................ 35 6.2 Institutions.................................................................................................................................................. 35 6.3 Collaboration Between Institutions and Governance Levels ..................................................................... 36 6.4 Availability of Funding ................................................................................................................................ 36 7. Recommendations for Individual Circular Economy Initiatives and Measures ...................................... 37 7.1 Enterprises Connected for Industrial Symbiosis ........................................................................................ 37 7.2 Plastic-Free Black Sea Coast .................................................................................................................... 38 7.3 Scale up Reuse and Recycling of CDW into New Virtuous Cycles ........................................................... 40 7.4 Establishment of Municipal Reuse and Repair Centers ............................................................................ 41 7.5 Vision: Strategy/Roadmap Development at Urban/Municipal Level ......................................................... 41 7.6 Horizontal CE Platform .............................................................................................................................. 42 Annex A. Stakeholders Consulted................................................................................................................... 43 Annex B. Survey Analysis ................................................................................................................................ 44 Annex C. Notes from Focus Group on Circular Actions at Regional/Local Level with an Emphasis on Industrial Symbiosis (IS) (May 26, 2021) ......................................................................................................... 51 Annex D. Notes from Focus Group on Plastics and Marine Litter in Black Sea Coast Municipalities (May 27, 2021) ............................................................................................................................................................. 54 Annex E. Relevant measures from the Bulgarian SME Strategy .................................................................. 56 Annex F. Proposed Intervention: Enterprises Connected for Industrial Symbiosis .................................. 58 Annex G. Proposed Intervention: Plastic-Free Black Sea Coast and Tourism Initiative............................ 65 Annex H. Proposed Intervention: Scaling up Reuse and Recycling of CDW into New Virtuous Cycles .. 71 Annex I. Proposed Intervention: Establishing Municipal Reuse and Repair Centers ................................ 80 Annex J: Examples of Good Horizontal Practices ......................................................................................... 83 List of Figures Figure 1. SWOT analysis of CE potential in Bulgaria ............................................................................................ 8 Figure 2. Study methodology .............................................................................................................................. 11 Figure 3. Elements of the European Green Deal ................................................................................................ 15 Figure 4. European Eco-innovation Index, 2022 ................................................................................................. 30 Figure 5. Example of a SWOT analysis related to CE potential .......................................................................... 36 Figure 6. Elements of the proposed program of Industrial Symbiosis ................................................................. 38 Figure 7. What is the level of general knowledge and understanding of CE and associated concepts? ............ 44 Figure 8. Which of the following sectors that engage the most primary resources and have significant circular potential are developed in your region, and to what extent? ....................................................................... 46 Figure 9. Is there capacity in your region (within the ecosystem as a whole: public, business, academia) to do the following: ...................................................................................................................................................... 46 Figure 10. What is the capacity within the local administration and within the local ecosystem to implement CE measures and activities in the following sectors .......................................................................................... 46 Figure 11. Perceptions of sufficiency of ESIF funding......................................................................................... 50 iv Figure 12. Components of an initiative on Industrial Symbiosis ‘Enterprises Connected for IS’ ......................... 60 Figure 13. CDW management - Three levels of activity on a territorial scale ..................................................... 72 List of Tables Table 1. Proposed follow-up interventions based on rapid assessment of the CE potential in Bulgaria .............. 9 Table 2. Circularity strategies within the production chain actors in order of priority .......................................... 13 Table 3. Classification of circular jobs ................................................................................................................. 24 Table 4. Examples of recovery targets for materials used in the construction sector (%)................................... 25 Table 5. Indicators within the CE Monitoring Framework: Comparison of Bulgaria and the EU ......................... 27 Table 6. Type of challenges faced by the Bulgarian SMEs with regards to resource efficiency ......................... 31 Table 7. Generation of plastic waste ................................................................................................................... 31 Table 8. Plastic packaging waste: recycling and recovery .................................................................................. 32 Table 9. Composition of marine litter items as recorded on Bulgarian Black Sea beaches ................................ 32 Table 10. Official Data on CDW .......................................................................................................................... 33 Table 11. Stakeholders and their role in an Industrial Symbiosis Initiative ......................................................... 61 List of Boxes Box 1. Finnish National Program on Industrial Symbiosis................................................................................... 63 Box 2. Basque Country IS Initiatives through the “CE Demonstration Projects” Program .................................. 64 Box 3. Strategy for CE transition, Maribor, Slovenia ........................................................................................... 83 Box 4. “be circular be.brussels” Platform, Brussels............................................................................................. 84 v Acronyms and Abbreviations B2B Business-to-Business BSBD Black Sea Basin Directorate CSO Civil Society Organization CDW Construction and Demolition Waste CE Circular Economy CEAP Circular Economy Action Plan EC European Commission Eco-IS Eco-Innovation Scoreboard EMAS Environmental Management and Audit Scheme EPR Extended Producer Responsibility ESIF European Structural and Investment Funds EU European Union GDP Gross Domestic Product GPP Green Public Procurement GHG Greenhouse Gas ICT Information and Communication Technology IFIs International Financial Institutions JRC Joint Research Center JTM Just Transition Mechanism JTF Just Transition Fund HORECA Food service and hotel industries (Hotel, Restaurant, Café) MSFD Marine Strategy Framework Directive MSW Municipal Solid Waste NGO Nongovernmental Organization NUTS classification Nomenclature of Territorial Units for Statistics NWMP National Waste Management Plan OPIC Operational Program Innovation and Competitiveness of SMEs PET Polyethylene terephthalate PREC Programme Régional Bruxellois en Économie Circulaire [Brussels Regional Program for a Circular Economy] RAS Reimbursable Advisory Services RES Renewable Energy Source RIEW Regional Inspection of Environment and Waters RRP Recovery and Resilience Plan SDG Sustainable Development Goal SME Small and Medium-sized Enterprises SPI Sustainable Product Initiative SUP Single-Use Plastic SWOT Strengths, Weaknesses, Opportunities, Threats TEZ Trakia Industrial Zone WFD Waste Framework Directive WMA Waste Management Act vi Executive Summary Over the past decade, material efficiency and resource productivity have surfaced on the global policy agenda. The rise of the circular economy (CE) agenda reflects the objective of moving away from the current systems of production and consumption based on the ‘take-make-use-waste’ linear economic model toward economies centered on minimizing the use of virgin materials without adversely affecting welfare. The focus is on a life-cycle approach to resource management, which starts with reducing raw material demand by looping resources back into consumption and production systems through innovations in material design, production, and reutilization processes. In addition to reducing pollution and other harmful emissions, the CE can be a driver of private sector growth and jobs, and can increase the strategic autonomy of countries by reducing dependence on raw material imports. The objective of this rapid analysis is to identify the CE-related priority areas/sectors in Bulgaria and potential areas of focus for follow-up interventions. The study also aims to highlight concrete barriers that prevent the national and local governments from undertaking these interventions, as well as enabling factors and approaches to overcome them. Methodology and Approach The methodology of the report was based on four key elements: literature review, stakeholder consultations, survey, and focus groups. The study team consulted a variety of stakeholders including national ministries, municipalities, civil society organizations (CSOs), business associations, and thought leaders. The team also invited 200 municipalities to complete an online survey and received more than 30 responses. In addition, the study team conducted two focus groups to capture concrete opportunities for the future and to explore the readiness and maturity for their uptake. One focus group discussed options to support industrial symbiosis on the regional and local level, while the second focus group discussed the issue of plastic waste reduction and marine litter. This report uses the European Union (EU) definition of CE: CE aims to maintain the value of products, materials, and resources for as long as possible by returning them into the product cycle at the end of their use, while minimizing the generation of waste.1 Fewer products discarded means fewer materials extracted and higher benefits for the environment. This process starts at the beginning of a product’s life cycle: smart product design and production processes can help save resources, avoid inefficient waste management, and create new business opportunities. This report focuses on industrial symbiosis (IS) and plastics as two areas where significant progress could be made in Bulgaria. The former is an innovative business model at the crossroads of CE and industry. It addresses the issue of waste management within Bulgarian enterprises and the issue of low resource efficiency, both of which also have tangible climate implications. The latter is associated with a waste stream that significantly harms Bulgarian nature and tourism sector. For example, plastic packaging waste generated per capita in Bulgaria more than doubled between 2010 and 2019.2 Moreover, the plastic production sector has a significant potential for reform. In addition, the report also provides recommendations on Construction and Demolition Waste (CDW), as well as municipal reuse and repair centers. Progress Toward CE in Bulgaria The analysis of selected indicators for Bulgaria reveals an economy that is among the most resource intensive in Europe. While Bulgaria performs above the EU-average in terms of recycling of municipal waste and of plastics packaging, its circular material use rate remains amongst the lowest in the EU with only 4.9 (2021) of material recycled and fed back into the economy.3 This means that over 95 percent of materials used in in the country are eventually wasted. Bulgaria also ranks among the last countries in Europe for eco-innovation, which is crucial for CE. Moreover, a very small proportion of Bulgarian small and medium enterprises (SMEs) have invested in resource-efficiency actions. 1 Codified in the EU Taxonomy Regulation, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852. 2 https://ec.europa.eu/eurostat/web/circular-economy/monitoring-framework. 3 Ibid. 7 Yet, there are numerous initiatives in Bulgaria aimed at accelerating the transition to CE. A national CE Strategy was adopted in October 2022, focusing on three strategic objectives: (i) the transition to a green competitive economy; (ii) waste prevention and the phase-out of landfilling; and (iii) sustainable consumption among both private and public actors. Similarly, the 2021 Bulgarian SME Strategy includes IS and waste prevention measures, with a focus on plastics waste. Bulgarian legislation related to CE focuses on waste reuse and recycling targets. The country introduced an Extended Producer Responsibility (EPR) system for packaging waste, including plastics. While the recycling rate of plastics packaging was at 50.6 percent in 2019 (compared to the EU average of 37.7 percent in 2020),4 there has been a significant increase in plastic waste generated per capita in Bulgaria. As a result, plastic pollution problems persist, and are increasingly visible along the Black Sea coast and riverbeds. Moreover, plastic items contribute tangibly to marine litter. Construction and demolition waste (CDW) is another problem area for the country. The strategic and legal framework favors reuse, recycling, and other recovery of CDW. However, as per stakeholder interviews, data on CDW is unreliable, and a great degree of uncertainty exists about the implementation of CDW management in Bulgaria. This uncertainty points at a clear need to improve monitoring and implement measures for the promotion and development of CE initiatives in demolition, renovation, and construction works. An overall strengths, weaknesses, opportunities, and threats (SWOT) analysis of the Bulgarian transition to CE indicates a favorable EU and Bulgarian strategic framework and availability of funding. Bulgaria has access to significant funding within the EU Structural and Cohesion Funds, as well as through the EU Recovery and Resilience Fund. However, CE measures could generally be much better integrated in Bulgarian legislation. Enforcement of legislation is weak, and institutional capacity stands to be significantly strengthened. Active collaboration among institutions at the national and local levels is essential for using resources more efficiently, driving innovation, and allowing for a broader and more coordinated effort to transition to a more sustainable economic model. FIGURE 1. SWOT ANALYSIS OF CE POTENTIAL IN BULGARIA STRENGTHS WEAKNESSES - Several strategic documents opening up possibilities for CE - Low and declining use of secondary raw materials measures and initiatives - Low resource productivity - National CE Strategy adopted - Low levels of waste collection, sorting and treatment - Several progressive municipalities undertake actions - Limited investment opportunities in eco-innovation and CE - At least one industrial park has a very good understanding of - Data quality issues CE, Industrial Symbiosis, etc. - Insufficient cooperation between institutions, both on national - Ministry of Economy and Industry understands the issue of and local level Industrial Symbiosis - Low awareness and understanding of CE principles - Some success in recycling (e.g., e-waste, plastic packaging) - Instruments in place to support SMEs - EPR system in place. SWOT ANALYSIS Application of CE Measures OPPORTUNITIES THREATS - New EU strategic documents focus on CE - Locked into traditional waste management and landfilling - Significant financial resources available within ESIF, Recovery - Only individual components of different initiatives implemented, and Resilience Fund, Just Transition Fund, etc. rather than a holistic approach - Economic growth potentials through new business models - Weak enforcement of legislation - CE can promote a culture of cooperation - Work culture does not foster institutional collaboration - Few technical, R&I, business, and policy specialists who can support the CE transition Source: Original elaboration for this publication. 4 Ibid. 8 The Way Forward: Four Initiatives for a More Circular Bulgaria Based on the analysis of the country's CE context, key indicators, and, most importantly, feedback from stakeholders, this report proposes four potential follow-up interventions, as presented in Table 1. The activities fit well with the legal and strategic framework (stemming from the EU obligations). During interviews and focus groups, stakeholders expressed their support for all four initiatives and assessed their chances for implementation as realistic. The initiatives are fully aligned with both the EU and national priorities and respond to the challenges and needs that Bulgaria faces in the transition to CE. TABLE 1. PROPOSED FOLLOW-UP INTERVENTIONS BASED ON RAPID ASSESSMENT OF THE CE POTENTIAL IN BULGARIA Enterprises Launch a program on IS allowing Bulgarian enterprises to leapfrog to globally tested circular Connected for business models and work toward a mindset shift looking at waste as a resource. The program Industrial Symbiosis could start with one pilot region (Burgas-Stara Zagora and/or Plovdiv) and potentially expand (IS) nationwide. Plastic-Free Black Sea Contribute to the development of a common vision for a plastic-free Black Sea coast and assist Coast in addressing plastic pollution and marine litter problems in the Bulgarian coastal territories in a holistic and systemic way. Specifically, the intervention would enable local governments, tourism-related businesses, national authorities, and other tourism stakeholders to take a concerted action to shift toward circularity. It could involve support in drafting a National Marine Litter Action Plan (in line with the Regional Black Sea Action Plan endorsed by the Black Sea Commission) and reviewing legal and institutional arrangements, suggesting strengthening the policy and institutional framework for addressing marine litter in the Black Sea. Scaled Up Reuse and Scale up CDW reuse and recycling to enable Bulgaria to reach targets in CDW management Recycling of CDW and recovery, as well as to comply with the hierarchy of waste management in accordance with European and national legislation. This intervention would also address waste-related aspects of building energy efficiency renovation in Bulgaria which will expand in the coming years both because of the high potential for improvement in energy efficiency of Bulgarian residential and public buildings and because of the large amount of EU funding to be directed to the sector through the National Recovery and Resilience Plan. Municipal Reuse and Establish municipal reuse and repair centers. Reuse and preparing for reuse can save one-third Repair Centers of items collected at municipal waste collection points from premature recycling, landfilling, and incineration. At the same time, if repair practices are applied to just 1 percent of municipal waste, this can create 200,000 local jobs in Europe. The establishment of municipal reuse and repair centers would support CE by reducing waste generation while creating local jobs in Bulgaria. The four initiatives could be complemented by the deployment of two horizontal interventions: (i) the development of a pilot local CE strategy and action plan for one of the more advanced municipalities and (ii) the launch of a national CE platform bringing together relevant legal information, CE knowledge, and best practices. The identification of these four initiatives and two horizontal actions does not mean that there are no other initiatives worth embarking upon. However, these initiatives have been prioritized by all consulted stakeholders, including the municipalities, and they fit well with the maturity level in the country and with strategic directions of development. 9 1. Introduction: Report Objectives and Methodology Over the past decade, material efficiency and resource productivity have surfaced on the global policy agenda. The rise of the circular economy (CE) agenda reflects the objective of moving away from the current systems of production and consumption based on the ‘take-make-use-waste’ linear economic model toward economies centered on minimizing the use of virgin materials without adversely affecting welfare. The focus is on a life-cycle approach to resource management, which starts with reducing raw material demand by looping resources back into consumption and production systems, through innovations in material design, production, and reutilization processes. In addition to easing the environmental pressures, the CE can be a driver of private sector growth and jobs, and can increase the strategic autonomy of countries by reducing dependence on raw material imports. CE has been on top of the European Union (EU) policy agenda since 2015 and is now a firm component of its growth strategy, the European Green Deal. This study aims to identify CE-related priority areas/sectors and follow-up interventions, including measures, initiatives, and programs. This study was undertaken between April and June 2021, and follows a simple methodology, including a literature review, survey among municipalities, interviews with stakeholders, two focus groups, and discussion with another ongoing World Bank assignment team working on plastic waste. In September 2022 and in August 2023, the study team updated key data and policy documents. The study is not intended to be an in-depth analysis but rather to provide an overview of the status of CE implementation in Bulgaria and some recommendations for policy makers on how to accelerate progress toward a CE in Bulgaria. The report aims to identify solutions which lie at the intersections of: (i) the EU obligations and evolving policy context; (ii) national priorities and the strategic policy context of Bulgaria; and (iii) sufficiently mature needs and demands of key stakeholders in Bulgaria and their capacities, including international financial institutions (IFIs). The analysis also identifies concrete barriers that may prevent the national and local governments from undertaking the priority interventions, as well as the steps to overcome these barriers. These include public administrative and institutional capacity factors, among others. This report focuses on industrial symbiosis (IS) and plastics as two areas where significant progress could be made in Bulgaria. The former is an innovative business model at the crossroads of CE and industry. It addresses both waste management within Bulgarian enterprises and low resource efficiency, both of which also have tangible climate implications. The latter is associated with a waste stream that significantly harms Bulgarian nature and the tourism sector. In fact, over the past decade, there has been a significant increase in plastic waste generated in Bulgaria, and in 2020, the waste generated per capita significantly exceeded the EU average. The plastic production sector also has a significant potential for reform. In addition, the report also provides recommendations on Construction and Demolition Waste (CDW), as well as municipal reuse and repair centers. The report provides an up-to-date picture of the current situation of the circular transition in Bulgaria, which helps to inform potential future interventions. The assessment includes: current and potential actors, indicators, strategic policy framework, ongoing and recent efforts and developments, as well as the capacity of stakeholders to implement the transition. 10 FIGURE 2. STUDY METHODOLOGY Current situation Enabling and Policy and hindering strategic factors framework Future interventions Stakeholder Ongoing demand for CE initiatives actions Stakeholder understanding of CE Source: Original elaboration for this publication. The report follows a “general-to-specific” approach. First, the report provides a legislative and institutional analysis and a cross-sectoral overview, followed by a focused look at specific sectors identified based on stakeholder inputs and literature review. These focus sectors also determine the selection of priority actions. The report starts with an overview of the status quo regarding the CE policy framework in the EU and in Bulgaria, presents key CE-related statistics for Bulgaria, and develops a SWOT analysis that serves as the basis for the proposed areas of intervention. After an introduction to CE in Chapter 2, the current CE policy landscape is laid out for the EU in Chapter 3 and for Bulgaria in Chapter 4. Key CE-related indicators for Bulgaria are presented in Chapter 5. Chapter 6 presents a SWOT analysis for Bulgaria's transition to a more circular economy. Finally, Chapter 7 lists proposed priority actions that may provide the basis for potential future follow-up technical and/or financial assistance. The methodology of the report was based on four key elements: literature review, stakeholder consultation, survey, and focus groups. These are presented in more detail below. 1.1 Literature Review The study relies on an analysis of the existing literature to better understand: • The situation in Bulgaria: institutional setup, CE stakeholder positioning, and measures and initiatives which have already been undertaken; • Good practice from other EU countries, regions, and cities, which might inspire Bulgarian stakeholders to innovate beyond their legal obligations. In preparation of the report, the study team also consulted relevant documents and statistical databases. These include European Commission (EC) progress reports, analytical reports by think tanks and other organizations, and case studies. 1.2 Stakeholder Consultation Transition to a CE is possible only through the mobilization and active engagement of different groups of stakeholders. Therefore, one of the main tasks of this study was to map and consult as many of the (potential) CE stakeholders and CE champions in Bulgaria as possible. Discussions with stakeholders were instrumental in supporting exploratory work, especially in gauging understanding of CE and readiness to take action. While 11 stakeholders were asked to share past actions related to CE, the conversations focused on possible future actions, regulatory interventions, and possible initiatives. Future programs and similar interventions (which could potentially benefit from technical and/ or financial assistance) are differentiated with enabling conditions (for example, regulations) which are the responsibilities of national governments. Stakeholders found the proposed actions relevant and sufficiently mature which is another argument for selecting them. The study team consulted a variety of stakeholders including national ministries, municipalities, civil society organizations (CSOs), business associations, and thought leaders. Consultations were held jointly with the Ministry of Economy and Industry and the Ministry of Tourism. While the project team did not find it possible to consult with the Ministry of Environment and Water during the preparation of the report, consultations were held on the basis of the report's final draft. Consulted stakeholders are listed in Annex A. 1.3 Survey The team invited 200 municipalities to complete an online survey and received more than 30 responses, which represented a response rate of 15–20 percent. The survey was aimed at municipalities and its main purpose was to capture the following elements to inform the analysis: • Level of understanding of the CE concept and its multiple dimensions • Measures and initiatives already implemented or planned • Motivations for implementing CE activities • Obstacles to implementing CE activities • Ideas for concrete future activities on the national, regional and local level as well as their priorities. The survey was divided into two main sections in line with the two main topics of this study, namely IS and plastics and marine litter. A separate analysis of the survey is presented in Annex B. 1.4 Focus Groups The study team conducted two focus groups to capture concrete opportunities for the future and to explore the readiness and maturity for their uptake. Focus group 1. Circular actions at the regional/local level with an emphasis on IS This first discussion focused on circular and sustainable action in municipalities defined as ‘regions in transition’ and included in the World Bank Advisory Services supporting territorial decarbonization in Bulgaria. These include the NUTS3 regions (districts) Varna, Haskovo, Burgas, Lovech, Gabrovo, Targovishte, Sliven, and Yambol. In addition, Plovdiv was included as an industrial center with high potential for industrial symbiosis. The focus group explored circular and sustainable action at the local level with an emphasis on potential action in IS. Through discussion, the study team tested the appetite for such an initiative and the factors that enable and inhibit its implementation. Focus group 1 is summarized in Annex C. Focus group 2. Sustainable tourism: the issue of plastic waste reduction and marine litter The second focus group was on fostering circularity in the tourism sector in Bulgaria and targeted Burgas, Varna, and other smaller municipalities along the Black Sea coast. The tourism sector, especially coastal tourism, was adversely affected by the COVID-19 pandemic. This pandemic provided an opportunity to rethink the potential of the tourism industry and its business models and value chains in a more holistic and systemic way. The discussion centered on the issue of plastics management in coastal cities and the wider context of marine litter. Potential future initiatives were also discussed. Focus group 2 is summarized in Annex D. 12 2. The Circular Economy: Definitions, Strategies and Benefits 2.1 Definition Circular economy (CE) can be defined in numerous ways and there are more than 100 definitions in use. This report uses the definition used by the EC: A Circular Economy aims to maintain the value of products, materials, and resources for as long as possible by returning them into the product cycle at the end of their use, while minimizing the generation of waste. The fewer products we discard, and the fewer materials we extract, the better for our environment. This process starts at the very beginning of a product’s life cycle: smart product design and production processes can help save resources, avoid inefficient waste management, and create new business opportunities.5 2.2 Circularity Strategies and Circular Business Models Several circularity strategies and approaches exist as illustrated in Table 2, ranked by the level of circularity and hence, environmental priority. The underlying logic of this circular hierarchy is that the higher a strategy is on the hierarchy, the more circular it is. While the debate around CE often focuses on recycling, Table 2 also shows that the recycling of waste is rather low on the circular hierarchy, with other strategies more promising in preventing waste and pollution in the first place. While recycling is a necessary component, a circular economy should thus focus on preventing waste rather than recycling it. The below classification is used when exploring potential future interventions. TABLE 2. CIRCULARITY STRATEGIES WITHIN THE PRODUCTION CHAIN ACTORS IN ORDER OF PRIORITY Smarter product use and manufacture R0 Refuse R1 Rethink R2 Reduce Extend the lifespan of products and its parts R3 Reuse R4 Repair R5 Refurbish R6 Remanufacture R7 Repurpose Useful application of materials R8 Recycle R9 Recover Source: Based on Potting J., M. Hekkert, E. Worrell, and A. Hanemaaijer (2017).6 2.3 Benefits of a Circular Economy Reducing material consumption leads to less pollution, waste, and related health impacts, and is key to preserving vital ecosystem services and natural resources, including biodiversity. In the linear system, products eventually end up as waste, most of which is landfilled or incinerated. Globally, inadequate solid waste management contributes, among others, to climate change and (marine) plastic pollution. Locally, solid waste harms public health, putting millions at risk due to soil and water contamination and poor air quality. One of the principal aims of CE is to minimize waste and pollution by returning products, materials, and resources into the product cycle at the end of their use. Reducing waste and pollution and associated negative environmental impacts will thus have substantial benefits for public health, including through designing out toxic chemicals. In addition, it is estimated that the extraction and processing of natural resources is responsible for more than 90 percent of biodiversity loss.7 Decreasing the need for virgin materials can thus contribute to healthy ecosystems and biodiversity preservation. 5 https://ec.europa.eu/eurostat/web/circular-economy. 6 José Potting, Marko Hekkert, Ernst Worrell, and Aldert Hanemaaijer. 2017. Circular Economy: Measuring Innovation in the Product Chain. The Hague: © PBL Netherlands Environmental Assessment Agency https://www.pbl.nl/sites/default/files/downloads/pbl-2016-circular- economy-measuring-innovation-in-product-chains-2544.pdf. 7 https://www.resourcepanel.org/reports/global-resources-outlook. 13 Circular business models can help reduce greenhouse gas (GHG) emissions. The production of goods and services, including food, for the global economy accounts for nearly half of the global GHG emissions. Addressing GHG emissions from industry can be technologically challenging and costly, particularly in sectors such as iron, steel, aluminum, cement, and plastics, which are associated with hard-to-abate emissions related to high- temperature processes, production emissions, and end-of-life emissions. In the food system, food waste is a major source of GHG emissions. An increasing focus on material efficiency and circularity will help align the emissions trajectory of these sectors with the goals of the Paris Agreement. Circularity can help address issues related to import dependencies and security of supply risks of critical raw materials. Ballooning resource consumption also has trade and security implications, raising concerns over resource shocks and supply failures worldwide. In a world of increased competition for access to materials, many advanced and emerging economies face dependency and supply risks. The EU, for example, is 100 percent dependent on the imports of numerous critical raw materials, including lithium and rare earth elements,8 which are essential for renewable energy installations and storage solutions and thus for achieving climate and renewable energy targets. Returning products, materials, and resources back into the product cycle at the end of their use can thus help reduce import dependencies and supply risks. In addition to easing environmental pressures, the circular transition can be a driver of private sector growth and jobs. Although there are still very few ex-post studies to verify growth and job creation potential of CE, technological innovation in resource efficiency can lead to productivity gains. What is certain is that the goal of decoupling natural resource extraction and use from economic output has already led to a range of concrete business applications aimed at closing resource utilization loops, slowing down material use, as evidenced by the growth of repair and remanufacture services, the birth of the sharing economy, or quite simply by an uptick in recycling and reuse rates. For example, already in 2015, an estimated 8 percent of the Dutch workforce was employed in CE jobs, with the biggest concentration in activities that preserve and extend the value of materials already in use, such as reuse and recycling.9 2.4 Monitoring Progress Towards a Circular Economy Monitoring progress towards a circular economy is a challenging task; the European Commission in 2018 brought forward the so-called Monitoring Framework for the Circular Economy consisting of several indicators. Perhaps the simplest indicator to measure circularity is the Circular Material Use Rate, calculated as the contribution of recycled materials to overall material use. However, since circularity goes beyond recycling, the European Commission (EC) included numerous other indicators in its monitoring framework, grouped in five categories: production and consumption, waste management, secondary raw materials, competitiveness and innovation, and global sustainability and resilience. The scores for Bulgaria and the EU on each indicator are presented in Chapter 5 on the current state of the circular economy in Bulgaria. 8 https://op.europa.eu/en/publication-detail/-/publication/57318397-fdd4-11ed-a05c-01aa75ed71a1. 9 https://www.circle-economy.com/resources/circular-jobs-understanding-employment-in-the-circular-economy-in-the-netherlands. 14 3. The Circular Economy Policy Framework of the European Union The concept of CE has been around for many years; however, it only became a widely used term in the EU with the adoption of the EU CE Package in 2015. Before that, the notion of ‘greening the economy’ and ‘greening different economic sectors’ was more common. In recent years, the concept of CE has been integrated in all major EU strategic documents as demonstrated below. 3.1 The European Green Deal The European Green Deal10 is a roadmap launched by the EC in 2019 as a response to the EU obligations to tackle climate change and other environmental issues. The Green Deal commits to making consistent use of all policy levers: regulation and standardization, investment and innovation, national reforms, dialogue with social partners, and international cooperation. The target to achieve a climate-neutral and circular economy will require the mobilization of industry. FIGURE 3. ELEMENTS OF THE EUROPEAN GREEN DEAL Source: EU https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1576150542719&uri=COM%3A2019%3A640%3AFIN. While the Green Deal will remain a strategic document, its messages have been and will be taken up by new legislation and funding programs. The Green Deal is incorporated in the 2021–2027 European Structural and Investment Funds (ESIF), which are a major investment source in Bulgaria. Bulgaria needs to incorporate Green Deal priorities in future measures and initiatives aimed at making value chains more circular. In addition, the Green Deal is an opportunity to strengthen and accelerate the CE transition at both the national and local levels. For example, local authorities will have a series of trainings and also will develop projects related to the Green Deal. 10 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1576150542719&uri=COM%3A2019%3A640%3AFIN. 15 3.2 CE Action Plan The CE Action Plan (CEAP)11 is a key building block of the European Green Deal and the backbone of Europe’s CE policy. It outlines a series of measures and mentions product design, production processes, consumption, food waste, critical raw materials, and biomass and bio-based products. Eco-innovation and investment are highlighted as horizontal measures. The CEAP establishes a concrete program of action, with measures covering the entire cycle: from production and consumption to waste management, the market for secondary raw materials, and a revised legislative proposal on waste. Some of the CEAP's highlights include: • A Focus on key sectors: electronics and information and communication technology (ICT); batteries and vehicles; packaging; plastics; textiles; construction and buildings; and food, water, and nutrients. • The Role of SMEs in stimulating the development of lead markets for climate-neutral and circular products. • A Sustainable Products Initiative (SPI) to support the circular design of products based on a common methodology and principles, thereby putting producers at the heart of the transition. • Prioritizing reduction and reuse of materials before recycling them; The CEAP also includes measures to encourage businesses to offer consumers a choice of reusable, durable, and repairable products. A key aim of this policy framework is to stimulate the development of leading markets for climate neutral and circular products in the EU and beyond. The CEAP includes the Sustainable Product Initiative (SPI) to support the circular design of all products based on a common methodology and principles. According to the Green Deal, the focus will be mainly on resource-intensive sectors such as textiles, construction, electronics, and plastics. The initiative comprises a number of policy instruments and initiatives, including extension of the Eco- design Directive to new products, extension of the sustainability requirements for products, strengthening product sustainability information for consumers and businesses (B2B), and adopting more measures for circularity and value retention. In March 2022, the Commission published a proposal for a revised Directive on Eco-design for Sustainable Products12 which is at the center of the EU Sustainable Product Policy and will allow for setting of new requirements on product durability, energy and resource efficiency, recycled content, carbon and environmental footprint, and so on. Further promoting sustainable consumption, the European Commission is proposing a 'right to repair' for European consumers. In March 2023, the Commission tabled a proposal on common rules promoting repair of goods. By introducing a 'right to repair' for European consumers, the proposal tackles obstacles that discourage consumers to repair products due to inconvenience, lack of transparency or difficult access to repair services. The aim is to ensure that more products are repaired within the 2-year warranty (legal guarantee) period, and that consumers have easier and cheaper options to repair products that are technically repairable (e.g., vacuum cleaners, smartphones, and tablets) when the 2-year legal guarantee has expired or when the good is no longer functional as a result of wear and tear. 3.3 EU Climate Law In June 2021, the EU adopted the first European Climate Law13 codifying the goal set out in the European Green Deal for Europe to become climate neutral by 2050. This means achieving net zero GHG emissions for EU countries as a whole, mainly by cutting emissions, investing in green technologies, and protecting the natural environment. Given the important role CE plays in reducing GHG emissions, the law provides a basis for accelerating action towards the circular transition. The law also sets an intermediate target of reducing net GHG emissions by at least 55 percent by 2030 (compared to 1990 levels) and also includes a process for setting a 11 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1583933814386&uri=COM:2020:98:FIN. 12 https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and- requirements/sustainable-products/ecodesign-sustainable-products_en. 13 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R1119. 16 2040 climate target. A Communication starting the process to establish a 2040 climate target is planned for the first quarter of 2024. 3.4 EU Industrial Strategy In 2020, the EC launched the EU Industrial Strategy14 and the EU SME Strategy15 as part of the Industry Package. These two strategies closely follow the European Green Deal (2019) and the direction set by the CEAP (2020) which drew attention to the important role that industry needs to play in the transition toward a more circular and more just and sustainable society. The 2020 EU Industrial Strategy (including its 2021 revision)16 aims to drive Europe's competitiveness at a time of increasing global competition. The strategy highlights three main drivers that will transform EU industry, support SMEs, and keep Europe sustainable and competitive: • Ecological transition in line with the European Green Deal • Digital transition, which will allow industry and SMEs to be more proactive, provide workers with new skills, and support the decarbonization of economies • International competitiveness, which for Europe means leveraging its advantage as a large single market to set global standards. The strategy also includes a set of actions, including one related to CE. Incorporating circularity across the economy represents a path forward in industrial transformation and will require radical change in the ways products are designed, used, and disposed of. 3.5 EU SME Strategy The 2020 SME Strategy for a Sustainable and Digital Europe supports SMEs in their transition to sustainability and digitalization.17 It is instrumental for the implementation of the European Green Deal and the CEAP by aiming to considerably increase the number of SMEs engaging in sustainable business practices. The strategy notes that almost a quarter of SMEs in Europe already enable the transition by offering green products or services, while a third of SMEs report that they face complex administrative and legal procedures when trying to make their business more resource-efficient. In response to these challenges, the SME strategy focuses on capacity building, reducing regulatory burden and improving market access, and improving access to finance. Competitive sustainability is set to be one of the guiding principles in industrial development in Europe for the future. For companies, competitive sustainability is the assumption that while improving their environmental performance, they keep or enhance their competitiveness. To make the transition to competitive sustainability, industry needs to undergo a fundamental transformation. In addition, SMEs need to “invest in more resource-efficient and circular processes and infrastructure, finding relevant commercial partners, and encouraging peer-to-peer collaboration”. This development opens the door to industrial symbiosis in Europe. 3.6 EU Just Transition Mechanism The Just Transition Mechanism (JTM)18 is an EU tool to ensure a fair transition to a climate-neutral economy. The mechanism provides targeted support to help mobilize around €55 billion over the period 2021– 2027 in the most affected regions, to alleviate the socioeconomic impact of the transition. The JTM beneficiaries will include citizens in affected regions, carbon-intensive companies and sectors, member states and regions. The Just Transition Fund (JTF), one of the three pillars of the JTM, dedicates €1.3 billion in Bulgaria to address the socio-economic fallout of the transition, focusing on the most impacted regions – Pernik, Kyustendil, Stara 14 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1593086905382&uri=CELEX%3A52020DC0102. 15 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0103. 16 https://commission.europa.eu/document/download/9ab0244c-6ca3-4b11-bef9-422c7eb34f39_en?filename=communication-industrial- strategy-update-2020_en.pdf. 17 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0103. 18 https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal/finance-and-green-deal/just-transition- mechanism_en. 17 Zagora, to support them in the transition to a zero-carbon economy. In addition to the JTF, the JTM will include support for private and public investments in the development of these areas.19 3.7 EU Waste Framework Directive The Waste Framework Directive (2008/98/EC)20 (WFD) sets out the EU’s main waste management principles, including definitions of waste, recycling and recovery, as well as concrete and binding targets. The basis of EU waste management is the so-called 'waste hierarchy,' which establishes an order of preference for managing and disposing of waste. According to the waste hierarchy, preventing waste should be the preferred option, followed by re-use and recycling. Recovery and disposal should be the last resort. WFD is crucial to the CE transition not only because it promotes waste prevention, the overall reduction of resource use, and improved resource efficiency, but also because it sets concrete EU-wide waste management targets. These targets include: • By 2020, a minimum of 50 percent (by weight) of waste from households should be prepared for re-use and recycling; • By 2020, a minimum of 70 percent (by weight) of non-hazardous construction and demolition waste shall be prepared for re-use, recycling and other material recovery; • The share of municipal solid waste prepared for re-use and recycling should be increased to 55 percent, 60 percent and 65 percent (by weight) by 2025, 2030 and 2035, respectively. In addition, the WFD defines when waste ceases to be waste and becomes a secondary raw material, and how to differentiate between waste and by-products. This is essential for various CE-related activities, including industrial symbiosis. The WFD has been amended in 2018 and a new proposal for further amendments have been tabled by the EC in July 2023 to further anchor the CE in EU waste management. The 2018 amendments, amongst others, introduced new targets, definitions of different waste streams, and introduced separate collection of bio- waste, hazardous waste produced by households, and textile waste. The 2023 proposals focus on reducing environmental and climate impacts of textiles waste management and food systems, including by improving waste management in these sectors in line with the waste hierarchy. 3.8 EU Plastics Strategy The 2018 European Strategy for Plastics in a Circular Economy (EU Plastics Strategy)21 plays an important role in the transition to a CE, and has the objective to protect the environment and reduce marine litter, GHG emissions, and the EU’s dependence on imported fossil fuels. The strategy aims to protect the environment and citizens from plastic pollution and demonstrate the business case for transforming the way that products are designed, produced, used, and recycled. Under the strategy, all plastic packaging on the EU market will need to be recyclable by 2030, the consumption of single-use plastics (SUPs) will be reduced and the intentional use of microplastics will be restricted. The strategy highlights the main commitments for action at the EU level but also emphasizes the important role of businesses, together with national and regional authorities, and citizens. SMEs are the main actors in driving forward the implementation of the EU Plastics Strategy and in adapting the design of products; working on product substitution strategies; and, when prevention and substitution have been exhausted, ensuring proper recycling of plastics. Most of the actions included in the EU Plastics Strategy are directly or indirectly related to marine litter, including its international dimension. One of the actions resulting from the EU Plastics Strategy was the adoption of the Single-Use Plastics (SUP) Directive,22 which entered into force in 2019. The SUP Directive aims to: (i) prevent and reduce the impact of certain plastic products on the environment, in particular the aquatic environment, and on human health; and (ii) promote CE and to harmonize product regulation across the EU internal market. The directive applies to certain SUP products, products made from oxo-degradable plastic, and fishing gear containing plastic. The SUP Directive introduces increased collection goals for plastic packaging, extended producer responsibility schemes, 19 https://ec.europa.eu/commission/presscorner/detail/en/SPEECH_22_3582. 20 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20180705. 21 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1516265440535&uri=COM:2018:28:FIN. 22 https://eur-lex.europa.eu/eli/dir/2019/904/oj. 18 marking requirements, and awareness-raising measures. The first requirements under this directive entered into force in July 2021 and since then, a number of SUP products has been banned from being placed on the EU market. The reduction of packaging waste is a major goal of the European Green Deal, the CEAP and the EU Plastics Strategy. Waste reduction is becoming an even higher priority given the rising evidence of the negative impact of plastic waste—a major component of packaging waste—on the environment. The Packaging and Packaging Waste Directive (94/62/EC)23 emphasizes prevention, including reduction of the use of packaging bags, and an introduction of a reuse system for packaging (i.e., a deposit system). In November 2022, the EC proposed a revision of the Packaging and Packaging Waste Directive aimed at reducing wasteful packaging and boosting reuse and recycling. The proposal is a key building block of the CEAP and includes a headline target to: (i) reduce packaging waste by 15 percent by 2040 compared to 2018 (per member state per capita); (ii) make all packaging on the EU market recyclable in an economically viable way by 2030; and (iii) increase the use of recycled plastics in packaging through mandatory targets. The EU Plastics Strategy provides the justification for ambitious policies and initiatives (and the channeling of associated funds) in Bulgaria. This transformation opens significant new markets for producers of biodegradable, bio-based plastics. At the same time, a number of SMEs producing SUPs risk bankruptcy if they do not adapt. 3.9 The EU Plastics Own Resource or 'Plastics Tax' In accordance with the EU Plastics Strategy, the EU budget can contribute to reducing pollution from plastic packaging waste. The European Council introduced a 'tax' of €0.8 per kg for non-recycled plastic packaging waste, which has been applied from January 2021 as part of the post-COVID-19 economic recovery package for the period 2021–2027. The 'plastics tax' represents a national contribution from each EU member state to the own resources of the EU (the EU budget), based on the quantity of plastic packaging waste that is not recycled in each member state. This measure incentivizes countries to reduce the consumption of SUPs, foster recycling, and boost CE. At the same time, member states will be free to take the most suitable measures to achieve those goals, in line with the principle of subsidiarity. 3.10 Initiatives to Address Construction and Demolition Waste Waste generated by construction and demolition activities accounted for 37.5 percent of total waste generation in the EU in 202024 and is thus the largest waste stream in the EU. The definition of construction and demolition waste (CDW) covers a wide variety of materials including concrete, bricks, wood, glass, metals, and plastic. As mandated in the EU WFD, by 2020, “the preparing for re-use, recycling and other material recovery, including backfilling operations using waste to substitute other materials, of non-hazardous construction and demolition waste […] shall be increased to a minimum of 70 percent by weight”. However, with the exception of a few member states, only about 50 percent of CDW is being recycled.25 Numerous voluntary initiatives address CDW at the EU level. One of their main goals is to increase confidence in the CDW management process and trust in the quality of CDW recycled materials. Key initiatives include voluntary guidelines such as the EU Construction and Demolition Waste Protocol and Guidelines,26 which aim to improve: waste identification, source separation and collection; improve waste logistics; and improve waste processing, quality management and appropriate policy and framework conditions. Similarly, the Guidelines for the Waste Audits before Demolition and Renovation Works of Buildings27 provide guidance on best practices for the assessment of CDW before the demolition or renovation of buildings. In addition, 'Level(s)'28 provides a 23 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31994L0062. 24 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Waste_statistics#Total_waste_generation. 25 https://single-market-economy.ec.europa.eu/news/eu-construction-and-demolition-waste-protocol-2018-09-18_en. 26 Ibid. 27 https://ec.europa.eu/docsroom/documents/31521/. 28 https://environment.ec.europa.eu/topics/circular-economy/levels_en. 19 common voluntary reporting framework to assess the environmental performance of buildings along their lifecycle. 3.11 Initiatives to Address Marine Litter In the EU, about 85 percent of marine litter is plastic waste.29 SUPs represent about half of all marine litter and fishing-related items represent another 27 percent of the total.30 A significant proportion of the fishing gear placed on the market is not collected for treatment. SUPs and fishing gear containing plastic are therefore a particularly serious problem in the context of marine litter; pose a severe risk to marine ecosystems, biodiversity, and human health; and have a negative impact on activities such as tourism, fisheries, and shipping. Microplastics (items smaller than 5 mm) released in the aquatic and marine environment are of particular concern due to their harmful effects on marine animals and on human health caused by the consumption of seafood. In the second CEAP, the EC committed to address the unintentional release of microplastics by developing labeling, standardization, certification, and regulatory measures. Where reduction of the emissions at source is not possible, measures will be envisaged for later stages of the life cycle. There is a growing body of EU legislation on marine waste. The EU Marine Strategy Framework Directive31 (MSFD) is the first EU legal instrument to directly address marine litter; it requires EU member states to ensure that, by 2020, “properties and quantities of marine litter do not cause harm to the coastal and marine environment.” As noted above, pollution of the seas from plastics and microplastics is one of the three major areas of the EU Plastics Strategy adopted in 2018. Furthermore, the SUP Directive introduces a set of ambitious measures that also address plastic pollution of the marine environment. Among these are EPR programs covering the cost to clean up litter, and applied to products such as tobacco filters and fishing gear. The amended WFD acknowledges that since marine litter, in particular plastic, stems to a large extent from land-based activities, specific measures should be included in waste prevention programs and waste management plans. The Port Reception Facilities Directive32 aims to protect the marine environment by effectively addressing marine litter both from shipping and fishing waste, by providing for financial incentives for delivery of waste to ports, better monitoring and enforcement of the mandatory delivery obligation, and better management of this waste in EU ports in adequate port reception facilities. 29 https://www.eea.europa.eu/publications/european-marine-litter-assessment. 30 https://eur-lex.europa.eu/eli/dir/2019/904/oj. 31 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32008L0056. 32 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019L0883. 20 4. The Circular Economy Strategic and Legal Framework in Bulgaria Overall, the strategic and legal framework in Bulgaria is aligned with EU narratives and requirements of the EC. A national CE strategy has been adopted in October 2022. Numerous other policies and policy initiatives support the transition to a green and circular economy, both at the macro and micro levels. 4.1 Bulgarian Strategy for Transition to Circular Economy 2022–2027 In October 2022, the Bulgarian government adopted the Strategy for Transition to a Circular Economy for the period 2022-2027, together with an Action Plan for implementation of the Strategy.33 Both the Ministry of Environment and Water and the Ministry of Economy and Industry were involved in drafting the strategy. The strategy defines three key objectives related to the transition to a more circular economy. The first one is focused on the transition to a green and competitive economy, with particular focus on the achievement of higher resource productivity, the introduction of new circular business models, better connectivity of the economy through market platforms, and the contribution of the Bulgarian mining and recycling industries to the supply of critical raw materials in the EU. The second objective is focused on waste prevention, a more sustainable use of resources, and minimizing landfilled waste. The third objective is to promote more sustainable consumption and behavioral patterns, as well as to increase support for a just and green economy. Priority sectors include plastics, construction and demolition waste, food waste, and biomass and bio-based materials. The Action Plan stipulates some 100 concrete activities for the implementation of the above-mentioned key objectives. Proposed actions include additional studies, awareness raising, the creation of business platforms, the integration of the Bulgarian SMEs into EU organizations, and so on. Measures are to be funded from the state budget (mainly Ministry of Environment and Water and Ministry of Economy and Industry), municipal budgets, Horizon Europe, product fees, and other sources. With regard to industrial symbiosis the strategy calls for a number of measures. These include promoting CE and industrial synergies especially in industrial parks, development of the industrial symbiosis platform, construction of installations for biomass from agricultural sector, and supporting biomass-oriented industrial symbiosis. Also, the strategy envisages the development of a platform showcasing the results of implemented technologies for resource efficiency, environmental products, results of industrial synergies, and so on. Recognized as an enabler of CE, green public procurement is also promoted. The strategy addresses plastic waste and food waste. The issue of plastics and plastic waste is included in the strategy both in terms of prevention and recycling. Priority is placed on SUPs, improving separate collection in households, reducing unwanted impurities in manufactured and sold plastic products, and reducing packaging that hinders subsequent recycling. With respect to food waste, priority is on the introduction of mandatory separate collection of bio-waste from households, together with the completion of municipal systems for the treatment of bio-waste. 4.2 Bulgarian Strategy for SMEs (2021-2027) Adopted in April 2021, the National Strategy for SMEs (2021–2027)34 is in line with the principles of the European Green Deal and, in particular, with the Green Deal principle that the transition to a climate-neutral and circular economy requires full mobilization of industry, including SMEs. The strategy includes a dedicated measure (Measure 6.3) to support SMEs in value chains of strategic importance for Bulgaria and the EU in shifting towards a more circular mode of operation. In particular, support for more intensive action is envisaged in priority sectors such as electronics and ICT; batteries and vehicles; packaging; plastics; textiles; construction and buildings; and food, water, and nutrients. The strategy also includes an action focused on the launch of a program for a reduction of plastics in the economy (including plastic packaging) in line with the European Strategy for Plastics in a CE as well as support for SMEs producing SUPs to adapt to production of bio-based products (to ensure compliance with the EU SUP Directive).35 33 https://www.strategy.bg/StrategicDocuments/View.aspx?lang=bg-BG&Id=1559. 34 https://www.mi.government.bg/strategy-policy/natsionalna-strategiya-za-malki-i-sredni-predpriyatiya-msp-v-balgariya-2021-2027-g/. 35 A bylaw for transposition of the EU SUP Directive entered into force on November 2, 2021. 21 Measure 6.3 of the strategy calls for building the capacity of SMEs for the CE transition. In addition to the series of capacity-building programs for SMEs, the strategy envisages support for improving the effectiveness and efficiency of EPR systems and extending them to sectors generating large quantities of waste (for example, construction); support for Bulgarian SMEs and start-ups to adopt concrete circular business models and increase the share of recycled waste on a sectoral basis; and for the launch of several lighthouse projects in individual sectors. Measure 6.3 additionally calls for support to SMEs to increase the share of secondary raw materials in production processes, as well as to launch a pilot project on industrial symbiosis. The relevant measures of the strategy are summarized in Annex E. 4.3 Industrial Parks Industrial parks (IP) are one of the main stakeholders in developing industrial symbiosis across the EU. Therefore, the legal framework for the functioning of IP is an important factor for the CE transition. Among other things, the Law on Industrial Parks,36 published in October 2022, aims to create “a favorable institutional framework for environmentally friendly productions” (Art. 2). The law classifies industrial parks into three groups: type A — no specialization of industrial activities; type B — specialized in one type of industry and accompanying activities; and type C — focused on specialized, high-tech activities (Art. 17). The law neither incentivizes nor forbids any activities related to industrial symbiosis. The Carbon Neutral Industrial Parks initiative37 holds significant potential to support the introduction of industrial symbiosis in Bulgaria. The initiative is implemented by Trakia Industrial Zone (TEZ) in a consortium with Plovdiv, Burgas, Gabrovo, and Haskovo. The initiative aims, among other things, to “reduce carbon emissions of participating industrial parks.” The intention is to draft low-carbon transition roadmaps and implement several individual projects to lower the carbon emissions of individual companies in the parks and of the parks as a whole. The initiative is an excellent entry point for and one of the components of the overall initiative introducing industrial symbiosis in Bulgaria. 4.4 Bulgarian Innovation Strategy for Smart Specialization 2021–2027 The Bulgarian Innovation Strategy for Smart Specialization (ISSS) 2021–202738 aims to accelerate the green and digital transformation of industrial ecosystems. The ISSS is a policy instrument used in the EU to support regional prioritization in innovative sectors. The current ISSS for Bulgaria 2021-2027, adopted in December 2022, defines five thematic areas in which Bulgaria has a competitive advantage and capacity for smart specialization. One of the five thematic areas is “clean technologies, circular and low-carbon economy.” This priority area promotes increasing resource and energy productivity while following the principles of the CE and stimulating the deployment of low-carbon, resource-efficient, and waste-free technologies. Specifically, the priority area promotes resource-efficient technologies, the reduction of hazardous substances, the use of alternative raw materials, product lifetime extension, waste-free technologies, and methods for incorporating waste and materials from production in other industries and services. The focus on the latter will also facilitate the development of industrial symbiosis in Bulgaria. 4.5 National Recovery and Resilience Plan for Bulgaria The National Recovery and Resilience Plan (NRRP) aims to foster a strong recovery from the COVID19- pandemic, and covers 56 investments and 47 reforms, with a total value of €6.9 billions; 59 percent of the plan will support climate objectives.39 The plan received a green light from the EC in April 2022 and from the EU Council in May 2022, opening the door to its implementation and financing. The NRRP is structured along four pillars: Innovative Bulgaria (25.3 percent of the RRF amount); Green Bulgaria (41.8 percent); Connected Bulgaria (18.2 percent); and Fair Bulgaria (14.6 percent). The measures proposed in the plan cover a variety of areas, such as intelligent industry, sustainable agriculture, healthcare, and digital connectivity. CE aspects are mostly embedded in the 'Green Bulgaria' and 'Innovative Bulgaria' pillars. 36 Law 4982/2022, Government Gazette 195/A/15-10-2022. 37 See https://tez.bg. 38 https://strategy.bg/StrategicDocuments/View.aspx?lang=bg-BG&Id=1569. 39 https://nextgeneration.bg/14. 22 The ‘Green Bulgaria’ pillar focuses on three main components: low-carbon economy, biodiversity, and sustainable agriculture. The main objective of the low-carbon economy component is to reduce the carbon footprint and energy intensity of the economy and facilitate a green transition by supporting the increase of energy efficiency in the building sector, as well as by promoting the production of energy from renewables. The NRRP also includes awareness-raising activities in the agricultural sector for the uptake of CE, as well as an updated strategic framework for the agricultural sector. The Bulgarian authorities should explore avenues and opportunities for scaling up CE interventions in the conceptualization and subsequent implementation of these reforms. For example, the establishment of a National Decarbonization Fund (with the support of the European Commission’s Directorate-General for Structural Reform Support) could explore further opportunities for addressing CDW from residential energy efficiency interventions. Opportunities might also exist with regard to the development of a mechanism for financing energy efficiency and renewable energy source (RES) projects, where more emphasis could be placed on measures related to waste stream management or to product eco-design. The ‘Innovative Bulgaria’ pillar includes three main components: education and skills, research and innovation, and intelligent industry. Under the latter component support for businesses is foreseen for the modernization and transition to green, circular, and digital-oriented business practices. As part of the public support program for the development of industrial zones, the NRRP includes a fund called ‘green transition and circular economy’ which is structured in two strands. The first strand aims to support the transition to climate neutrality and envisages a grant scheme of BGN 200 million targeting SMEs. The support will be focused on use of RES for own consumption in combination with local energy storage facilities as well as an additional guarantee financial instrument for energy efficiency and renewable energy. The second strand of the fund focuses on access to finance for SMEs and large enterprises to support the transition to CE by introducing circular business models, environmental standardization, technologies related to waste recycling and reuse, repair, and use of bio-based products. The grant financing for these objectives is BGN 180 million. 4.6 Operational Program Innovation and Competitiveness of SMEs (OPIC) 2021– 2027 The OPIC 2021–2027,40 funded by the European Regional Development Fund (ERDF), makes strong reference to CE, with one of the program’s thematic priorities dedicated specifically to this topic. The OPIC states that it will respond to identified investment needs for innovative and clean technology, adaptation of industrial facilities, more sustainable and circular use of resources, and development of industrial symbiosis. More concretely, the OPIC incudes measures targeting resource efficiency with focus on product design, as well as waste management (€48 million); innovative products, process, and circular business models (€30 million for design and €126.92 million for implementation); industrial symbiosis (€10 million); investments to improve resource efficiency (€11.91 million); support for enterprises in industrial parks for clean technologies, circular and low-carbon economy (€69.1 million). 4.7 Just Transition Fund Bulgaria receives more than €1.3 billion from the EU Just Transition Fund (JTF) targeted at EU regions with high carbon intensity due to coal production. In Bulgaria, support from the JTF will be channeled to three core coal regions: Stara Zagora, Kjustendil, and Pernik. The government has also prepared, with the World Bank support, Territorial Decarbonization plans for additional regions (Haskovo, Sliven, Yambol, Varna, Burgas, Lovech, Gabrovo, and Targovishte), that would be financed by other European structural and investment funds, including the Regions in Growth Program. 4.8 Green and Circular Jobs In 2020, an analytical report on green jobs was developed as part of drafting the Program Human Resources by the Ministry of Labor and Social Policy. According to the report, Bulgaria’s CE transition requires close consideration and analysis when discussing green employment. However, during the CE transition, specific ‘circular’ jobs may be created, with the potential to accelerate the transition (Table 3). Governments should pay special attention to these catalytic jobs. 40 https://opic.bg/public/opik/nov-programen-period-2021-2027-g. 23 TABLE 3. CLASSIFICATION OF CIRCULAR JOBS Circular jobs Direct circular jobs Indirect circular jobs Core jobs Enabling jobs Prioritize regenerative resources Rethink business models Provide services for primary Sustain and preserve what is Design for the future circular activities, that is, courier, already there Team up to create joint value models teacher, and so on. Use waste as a resource Optimize resource use through digital technology Source: Circular Jobs Initiative. 4.9 Marine Strategy of the Republic of Bulgaria and Program of Measures The aim of the EU Marine Strategy Framework Directive (MSFD)41 is to protect the marine environment across Europe. It requires EU member states to assess the quality of the marine environment, determine ‘good environmental status,’ set appropriate environmental targets, develop adequate monitoring programs, and implement measures to achieve the directive’s key goal of securing the ‘good environmental status’ of all EU marine waters by 2020. The Bulgarian National Marine Strategy42 includes four measures related to marine litter: management of waste generated by shipping, raising the private sector’s awareness of marine litter, inclusion of the term ‘marine litter’ in Bulgarian legislation, and beach clean-ups. Targeted measures for beach litter such as limiting the proliferation of SUPs or reducing microplastics appear to be underdeveloped.43 However, an addendum to the strategy (Addendum III.2: List of New Measures) includes a measure to raise awareness about marine litter in particular, targeting beach concession operators, tourists, fishermen, children, and the general public. This measure is in line with the need to address plastic pollution that arises in coastal municipalities as a result of tourism. The Black Sea Marine Litter Regional Action Plan44 was adopted in 2018 with the overall objective to consolidate, harmonize, and implement necessary environmental policies, strategies, and measures for sustainable, integrated management of marine litter issues in the Black Sea region. As a next step and based on the regional plan, Bulgaria, along with the Black Sea littoral states, is mandated to prepare a national plan to address marine litter and introduce a common monitoring system, along with dedicated measures and institutional responsibilities for strengthening enforcement. 4.10 Waste Management and Plastics The Bulgarian Waste Management Act (WMA),45 in force since July 2012, introduces the requirements of the EU WFD, including the polluter-pays and EPR principles and the waste hierarchy. The key legal provisions stemming from the WMA are quantitative goals which the municipalities need to meet regarding the preparation, reuse, and recycling of waste materials, including, at the very least, paper and cardboard, metal, plastic, and glass from households, and similar waste from other sources. Municipalities must organize systems for the separate collection of household waste paper and cardboard, metal, plastic, and glass, and ensure appropriate conditions for separate collection of waste from packaging in all settlements with a population of more than 5,000 inhabitants and for resorts. The system for collection of separate waste packaging was the first such system introduced in the country. With the 41 https://www.bsbd.org/bg/m_env_and_action.html. 42 Ibid. 43 Based on a statement made during the focus group on tourism and CE held as part of this assignment. 44 www.blacksea-commission.org/Downloads/BS_Marine_Litter_RAP_adopted.pdf. 45 https://www.moew.government.bg/static/media/ups/tiny/%D0%A3%D0%9E%D0%9E%D0%9F/%D0%97%D0%B0%D0%BA%D0%BE%D 0%BD%D0%BE%D0%B4%D0%B0%D1%82%D0%B5%D0%BB%D1%81%D1%82%D0%B2%D0%BE/WASTE%20MANAGEMENT%20A CT_13.pdf. 24 adoption of the packaging and waste packaging ordinance and its subsequent changes, the system of managing this waste stream has been embedded in the national legislation and is continuously being enlarged. There is no door-to-door collection for the four recycling streams mentioned above or for biodegradable waste. The users of commercial sites, manufacturing facilities, business and administrative buildings in settlements of more than 5,000 inhabitants and in resorts are required, as of the beginning of 2013, to collect paper and cardboard, glass, plastic, and metal wastes separately in compliance with the ordinances of the municipalities under the WMA. Under national law, annual targets for recycling and recovery of six groups of widespread waste have been set; since 2000, such targets have been in place for packaging waste. According to Bulgarian legislation, there are six widespread waste streams: packaging waste, end-of-life vehicles, waste electrical and electronic equipment, waste oils and petroleum products, waste batteries (including rechargeable types), and waste tires. Targets for the recovery and recycling of the six waste streams have been implemented throughout the country according to a program based on EPR. The current National Waste Management Plan (NWMP) 2021–2027,46 adopted in June 2021, provides the strategic framework for achieving sustainable waste management in the coming years. The Plan creates the conditions for waste reduction and transition to a CE and sets a target of a 55 percent recycling rate for municipal solid waste (MSW) by 2025. The NWMP requires, by 2025, 65 percent of packaging waste to be recycled with a target of 50 percent for plastic. The targets increase to 70 percent of packaging waste and 55 percent of plastic packaging to be recycled by 2030. The Plan highlights the need to improve and expand separate collection systems for packaging waste, given the increase in quantitative targets for recycling and recovery, as well as specific targets for separate collection of SUP bottles up to 3 liters. The Plan also sets a target for an expanded program of required fees for plastic bags.47 The EU SUP Directive is transposed into Bulgarian legislation by the ordinance on reduction of the impact of certain plastic products on the environment. In force since November 2021, the measures are aimed at reducing the impact of certain plastic products on the environment and promoting the CE transition through innovative and sustainable business models, products, and materials. Producers, and in some cases distributors, of certain SUP products listed in the ordinance have to apply EPR measures. These include implementation of awareness-raising measures, payment of a product fee for certain products, and so on. 4.11 Construction and Demolition Waste The Ordinance on Construction and Demolition Waste Management and Use of Recycled Building Materials48 was adopted in 2017. This ordinance details recovery target rates by material, with targets gradually increasing during the period 2014–2020 (Table 4). TABLE 4. EXAMPLES OF RECOVERY TARGETS FOR MATERIALS USED IN THE CONSTRUCTION SECTOR (%) 2017 2018 2019 2020 and after Wood waste 70 73 77 80 Glass waste 53 62 71 80 Plastics 63 69 74 80 Metal waste 90 90 90 90 Source: The Ordinance. The Ordinance also transposes the waste hierarchy required by the EU WFD in relation to CDW generated. Prevention is the favored strategy to reduce CDW, achieved through the reuse of products derived from demolition or/and the extension of the lifespan of products.49 Recycling of CDW is next in line in the hierarchy 46 https://www.moew.government.bg/static/media/ups/tiny/%D0%A3%D0%9E%D0%9E%D0%9F/%D0%9D%D0%9F%D0%A3%D0%9E- 2021-2028/NPUO_2021-2028.pdf. 47 https://www.moew.government.bg/static/media/ups/tiny/filebase/Waste/Legislation/Naredbi/waste/NNVOPPVOS.pdf. 48 https://eea.government.bg/bg/legislation/waste/NAREDBAZAUPRAVLENIENASTROITELNITEOTPADATsII_0.pdf. 49 Reuse is defined by regulation as any operation by which products or components that are not waste are used again for the same purpose for which they were conceived. 25 of waste management, followed by other recovery. To achieve the target rates of reuse, recycling, and other recovery of CDW, regulation now requires measures be taken for selective removal of materials in demolition works, and for sorting systems for CDW at least for wood, mineral fractions (concrete, bricks, tiles and ceramics, stones), metal, glass, plastic and plaster. To achieve the national target of 70 percent recovery of materials by 2020 and beyond, the Ordinance requires Construction Site Waste Management Plans be developed for all new projects for construction, reconstruction, overhaul, and deconstruction of existing buildings, with a relatively large total built-up area. An additional target of the ordinance is the use of recycled construction materials or treated CDW for recovery in backfills, depending on the type of construction and the scope of the permit for construction. At the level of the WFD, member states are required to take measures to promote preparing for reuse activities, by encouraging the establishment of preparing for reuse and repair networks, by facilitating their access to construction and demolition waste, and by promoting the use of economic instruments, procurement criteria, quantitative objectives or other measures.50 50 According to the EU WFD, preparation of reuse activities includes checking, cleaning, or repairing so that products or their components can be reused without additional pre-processing. 26 5. The Status of the Circular Economy in Bulgaria 5.1 The European Commission’s Circular Economy Monitoring Framework The CE Monitoring Framework assesses progress toward CE at both the EU and national levels through a set of indicators that capture the main elements of CE. Indicators are presented in five categories: production and consumption, waste management, secondary raw materials, competitiveness and innovation, and global sustainability and resilience. Table 5 shows the most recent data for the CE indicators in the EU and Bulgaria and compares them with EU targets. TABLE 5. INDICATORS WITHIN THE CE MONITORING FRAMEWORK: COMPARISON OF BULGARIA AND THE EU EU Bulgaria EU targets INDICATOR Production and consumption Material Consumption Material footprint (tonnes per capita) 14 (2020) 21 (2020) Resource productivity (index 2000 = 100) 135.5 (2021) 127.4 (2021) Green public procurement n/a n/a Waste Generation Total waste generation per capita (kg) 4,813 (2021) 16,785 (2020) Generation of waste excluding major mineral wastes per GDP unit (kg per 65 (2020) 418 (2020) thousand €, chain linked volumes (2010)) Generation of municipal waste per capita (kg) 530 (2021) 408 (2020) Food waste per capita (kg) 131 (2020) 86 (2020) Generation of packaging waste per capita (kg) 177.9 (2020) 79.5 (2019) Generation of plastic packaging waste per capita (kg) 34.6 (2020) 23.4 (2019) Waste management Overall recycling rates Recycling rate of municipal waste (percent) 49.6 (2021) 35.2 (2019) 50 (2020) 65 (2035) Recycling rate of all waste excluding major mineral waste (percent) 58.0 (2020) 23.0 (2018) Recycling rates for specific waste streams Recycling rate of overall packaging (percent) 64.0 (2020) 61.2 (2019) 65 (2025) 70 (2030) Recycling rate of plastic packaging (percent) 37.6 (2020) 50.6 (2019) 50 (2025) 55 (2030) Recycling rate of WEEE separately collected (percent) 83.4 (2020) 83.6 (2020) Secondary raw materials Contribution of recycled materials to raw materials demand Circular material use rate (percent) 11.7 (2021) 4.9 (2021) End-of-life recycling input rates (EOL-RIR), aluminum (percent) 32.0 (2022) n/a Trade in recycling materials Imports from non-EU countries (thousand tonnes) 41,388.1 118.6 (2021) (2021) Exports to non-EU countries (thousand tonnes) 37,616.2 1,257 (2021) (2021) Intra EU trade (thousand tonnes) 91,655.6 542.3 (2021) (2021) Competitiveness and innovation Private investment, jobs and gross value added related to circular economy sectors Private Investments (percentage of GDP at current prices) 0.8 (2021) 0.6 (2021) Persons employed (percentage of total employment) 2.1 (2021) 1.5 (2021) Gross value added (percentage of GDP at current prices) 2.1 (2021) 1.5 (20121) Innovation Patents related to waste management and recycling (number) 295.3 (2019) 0.0 (2019) Global sustainability and resilience 27 Global sustainability from circular economy Consumption footprint (index 2010 = 100) 104 (2021) 115 (2021) GHG emissions from production activities (kg per capita) 6,412 (2021) 7,521.9 (2021) Resilience from circular economy Material import dependency (percent) 22.9 (2021) 15.5 (2021) EU self-sufficiency for raw materials, aluminum (percentage) 11.0 (2022) n/a Source: Eurostat. While many CE related indicators for Bulgaria are in the range of the EU average, the Bulgarian economy is much more waste-intensive than the EU average, both per capita and per unit of GDP. Total waste generation per capita in Bulgaria is almost 3.5 times the level of the EU average, while waste generation per unit of GDP is almost 6.5 times higher. At the same time, recycling rates are significantly below the EU average. This results in a circular material use rate some 60 percent below the EU level. On a positive note, food waste and packaging waste generation per capita are below the EU average, while the reported recycling rates of plastic packaging and WEEE are above the EU average. 5.2 European Semester Country Reports for Bulgaria The European Commission’s European Semester Country Reports for Bulgaria highlight challenges as well as achievements in CE transition. The EC publishes European Semester Country Reports on the overall economic and social developments in each member state. The 2023 country report for Bulgaria51 notes that Bulgaria’s circular economy transition was insufficient and needed accelerating to meet the EU’s CE goals. The report highlighted the low and declining usage of secondary raw materials in Bulgaria, low resource productivity and the fact that Bulgaria remained one of the Member States with the highest landfilling rates and the lowest recycling performance. In particular, the 2023 European Semester Country Report Bulgaria highlights that Bulgaria will need to make efforts to increase resource and energy efficiency, by moving toward a more sustainable and CE model. Further, the 2023 report notes that at 4.9 percent (2021), Bulgaria’s circular material use rate is far below the EU average of 11.7 percent (2020). Bulgaria also failed to meet the 2020 recycling target for municipal solid waste and is at risk of not meeting the 2025 recycling targets for municipal and packaging waste. At the same time, landfilling remains substantially above EU average, representing 61.7 percent of waste generated in Bulgaria, compared to 23 percent in the EU (2020). There are numerous challenges for CE development in Bulgaria. These include boosting domestic and foreign investment opportunities in eco-innovation and CE, promoting efficient use of resources through increasing energy efficiency, further developing renewable energy sources, and improving sustainability practices within the transport sector.52 The financing gap in the CE is a concern, particularly in waste management. The EC estimates that investment was €65 million short annually between 2014 and 2020. Increases will be particularly required in CE areas like eco-design, repair, reuse and remanufacture, as well as in the uptake of new business models. Investments will also need to be increased in separate waste collection and treatment infrastructure to divert waste from landfilling and incineration. Finally, positive steps have been also highlighted in the reports. The 2021-2027 strategy and action plan for transition to a CE in Bulgaria, adopted in October 2022, is mentioned in the 2023 report as a positive step, as is the ordinance on reducing the impact of certain plastic products on the environment, adopted in 2021 and amended in 2022. The 2022 report refers to Bulgaria’s RRP that includes measures to address a series of its structural challenges, including the provision of significant support to businesses, especially SMEs, through grants and financial instruments aimed at promoting CE, and the use of renewables for own consumption. The 2020 edition mentions that ongoing municipal demonstration projects, projects for composting and separate 51 https://economy-finance.ec.europa.eu/document/download/9f9f4e76-83da-451e-9dd0- 4298913d693a_en?filename=BG_SWD_2023_602_en.pdf. 52 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020SC0501&from=EN. 28 collection of bio-waste, and the good practice of circular use of material in some industrial sites should be further pursued and developed. 5.3 Compliance with EU Waste Targets In June 2023, the European Commission published an Early Warning Report for Bulgaria53 for being at risk of missing several EU waste targets. The EC considers Bulgaria at risk of missing: (i) the 2025 target of 55 percent for the preparing for re-use and the recycling of its municipal waste; and (ii) the 2025 target to recycle 65 percent of its packaging waste. Similarly, the report voices concerns over the gap between Bulgaria’s current landfilling rate and its 2035 target to landfill no more than 10% of its municipal waste. To put things into perspective, only nine EU member states are on track to meet the 2025 targets, while 18 member states, including Bulgaria, are considered at risk of missing one or both of the targets. Landfilling practices in Bulgaria have already resulted in the launch of an infringement procedure in 2021. The EC notes that in some landfills, waste is still not subject to treatment and stabilization of its organic fraction. This resulted in the launch of an infringement procedure. In addition, the EC is concerned with illegal dumping of waste. Key challenges facing waste management include infrastructure for treating biowaste, packaging waste collection and data quality. The Early Warning Report identifies the insufficient infrastructure for treating biowaste as a major challenge, and highlights the lack of a clear plan to implement its separate collection. There are also no national standards for compost/digestate quality and no quality management system. Another challenge is the low density of collection points for packaging waste coupled with the lack of economic incentives for its separate collection. Finally, the EC highlights data quality issues, in particular regarding packaging waste. In response to the challenges, the EC has identified four recommendations for Bulgaria to improve its waste management performance: 1. Support the preparation for re-use of municipal waste and re-use systems for packaging. 2. Increase the separate collection of waste and develop waste recycling infrastructure, such as increasing the capacity to treat biowaste and supporting home composting. 3. Implement a national deposit-refund scheme for beverage packaging and a pay-as-you-throw system for businesses and households. 4. Improve the data quality management system on packaging waste to present consistent and verifiable data sets. 5.4 Resource Efficiency and Eco-Innovation Bulgaria is last in the EU in terms of overall eco-innovation performance. According to the 2022 Eco- Innovation Scoreboard (Eco-IS)54 presented in Figure 4, Bulgaria continues to be ranked last of the EU member states. Countries are categorized into three groups, depending on their eco-innovation performance. Bulgaria remains among the countries that are in the 'Eco-Innovation Catching Up' group, even though the country’s Strategic Vision through 2020 called for the country to graduate to the 'Average Eco-Innovation Performers' group by 2020 (the most advanced countries are in the “Eco-Innovation Leaders” group). There is only a small number of circular business model good practices in the country. Waste management within SMEs has a large margin for improvement and new circular business models (for example, industrial symbiosis, sharing economy) and actions high on the waste hierarchy are scarce. Material, water, and energy productivity, as well as the GHG emissions intensity are among the lowest in the EU. Specific resource efficiency outcomes included in the EU Eco-IS include material, water, and energy productivity, as well as the GHG emissions intensity. Bulgaria ranks last in the EU in material and energy productivity, and second to last in water productivity and GHG emissions intensity. 53 https://environment.ec.europa.eu/document/download/7deaa9a5-3285-4376-9e6d-03633cb4714c_en. 54 https://green-business.ec.europa.eu/eco-innovation_en. 29 Bulgaria has the potential to move from its current position as ‘catching up with Eco-Innovation’ to become an ‘average Eco-Innovation performer.’ This can be achieved if the country manages to fill structural gaps in the eco-innovation system support to SMEs. With regard to strategic and policy landscape, Bulgaria needs to move beyond the simple inclusion of concepts like eco-innovation and CE in strategic documents and take much more radical measures to improve environmental performance and trigger eco-innovation beyond the renovation of the productive stock of companies. FIGURE 4. EUROPEAN ECO-INNOVATION INDEX, 2022 Source: EU Eco-Innovation Observatory. Note: Countries are classified in three groups, depending on their score in the Eco-Innovation Index. The 'Eco-Innovation Leaders' group is marked in green, the 'Average Eco-Innovation Performers' group is marked in orange, and the 'Eco-Innovation Catching-up' group is marked in red. The EU’s score is marked in blue. The alignment of Bulgaria with the strengthened EU CE agenda will be associated with investments in projects higher on the waste hierarchy (for example, reuse and repair) beyond recycling as well as into innovative circular business models such as industrial symbiosis, remanufacturing, and product-as- service. The weak performance of different sectors of the economy with regard to energy and material efficiency is an additional argument in favor of large-scale support and uptake of eco-innovation and circular solutions at the enterprise and sectoral levels. For Bulgaria to improve its energy and material efficiency, enterprises need to start perceiving investing in eco-innovation as a priority and as an opportunity to improve their financial performance and position in the market. As regulatory constraints (in line with the EU Green Deal) and market and resource pressures change, companies will come to rely more on eco-innovation. 5.5 SME-Related Indicators Europe’s transition to a resource-efficient, low-carbon economy presents new business opportunities for both potential entrepreneurs and existing enterprises. Support of green entrepreneurship is a priority for the EC. In Bulgaria, both the proportion of SMEs that have undertaken resource efficiency actions and the proportion of SMEs planning to undertake resource efficiency actions in the next two years are much 30 below the EU average. A significant share of Bulgarian SMEs faces difficulties when trying to undertake resource efficiency actions which are presented in Table 6. TABLE 6. TYPE OF CHALLENGES FACED BY THE BULGARIAN SMES WITH REGARDS TO RESOURCE EFFICIENCY Share of SMEs that Challenge identified the challenge (%) Complexity of administrative or legal procedure 32 Technical requirements of the legislation not being up to date 20 Cost of environmental actions 14 Lack of demand for resource efficient products or services 14 Lack of specific environmental expertise 12 Difficulty to adapt environmental legislation to their enterprise 11 Lack of supply of required materials, parts, products, or services 11 Difficulty in choosing the right resource efficiency action for their enterprise 9 Source: Based on the SMEs Strategy Technical Report available at https://www.mi.government.bg/files/useruploads/files/sme/FINAL_DG_Reform_SME%20Strategy_Technical%20Report_2020-04-27.pdf. As a result, investments by SMEs in resource efficiency actions remain low. In the two years preceding the EC’s Environmental Implementation Review 2019, only 11 percent of Bulgarian SMEs had invested 6–10 percent of their annual turnover and 6 percent had invested 11–30 percent of their annual turnover in resource efficiency actions. Bulgarian SMEs tend to rely mainly on their own financial resources (65 percent) and their own technical expertise (65 percent) in their efforts to be more resource efficient. Only 13 percent of Bulgarian SMEs say they rely on external support in these efforts. Only 15 percent of Bulgarian SMEs are currently offering green products or services.55 5.6 Plastics In the last decade, there has been a significant increase in plastic waste generated in Bulgaria. In 2020, the waste generated per capita has significantly exceeded the EU average (Table 7). TABLE 7. GENERATION OF PLASTIC WASTE Plastic waste, non-hazardous (kg per capita) 2014 2016 2018 2020 EU average 34 35 39 43 Bulgaria 27 30 37 53 Source: Eurostat.56 The country’s more than 6 million residents are covered by separate collection systems for waste packaging, paper and metal, plastic and glass. In 2019, the country reported a recycling rate of plastic packaging waste (50.6 percent) significantly above the EU average (41.1 percent). However, as noted by several interviewees, Bulgaria’s actual recycling rate is lower. The discrepancy is a result of issues in data collection methodology and interpretation. In fact, the recycling rate of plastic packaging waste per capita is below the EU average (Table 8) and signals that there is a need for further efforts to address plastic packaging waste. In practice, the issue in part relates to containers for separate collection often not being available or not being used properly when available, which leads to deterioration of the quality of the collected packaging waste and 55 https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf. 56 https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/table?lang=en. 31 undermines its subsequent treatment. The amount of plastic packaging waste recovery per capita more than doubled in the period 2013–2019, but still the figure remains significantly below the EU average (Table 8). TABLE 8. PLASTIC PACKAGING WASTE: RECYCLING AND RECOVERY Plastic packaging waste, (kg per 2013 2014 2015 2016 2017 2018 2019 capita) Recycling (EU average) 11.03 11.99 12.06 13.63 13.88 13.98 14.03 Recycling (Bulgaria) 5.49 9.05 8.43 7.99 10.99 11.06 11.82 Recovery (EU average) 20.19 21.34 22.29 23.71 24.50 25.24 26.68 Recovery (Bulgaria) 5.50 9.06 8.43 7.99 11.08 11.09 11.82 Source: Eurostat. No monitoring mechanism exists to track separate collection of packaging waste by owners of commercial sites, small retailers, and shops. However, this is an area with potential for increase of the amount of separately collected high-quality packaging waste. 5.7 Marine Litter Descriptor 10 (Marine Litter) of the Marine Strategy of Bulgaria highlights that there is a shortage of data, knowledge and specialized studies on marine litter and notes that marine litter is included in the scope of the Strategic Action Plan for rehabilitation and conservation of the Black Sea (BS SAP) (2014–2020).57 Descriptor 10 also describes criteria and indicators for the marine environment, but does not define any environmental objectives. No reference to marine litter is made in the current NWMP 2021–2027. A quantitative assessment of the composition of marine litter along the Bulgarian Black Sea coastline identified several categories of litter and gauged their contribution to coastal pollution by both number and weight of items. The highest contribution (by number) comes from cigarette butts and filters, followed by plastic caps/lids of beverages and plastic cups and cup lids (Table 9). By weight, drink bottles >5 liters accounted for the greatest share of littler (30.7 percent), followed by shopping bags (15.5 percent) and drink bottles ≤0.5 liters (13.2 percent). Most marine litter is made of plastic. Higher concentrations of marine litter were found during the summer, associated with tourism and activities such as fishing and wild camping.58 Almost 85 percent of marine litter on Black Sea beaches is composed of plastic (Table 9).59 The remainder comprises other type of materials including metal, rubber, paper, glass, and processed wood. TABLE 9. COMPOSITION OF MARINE LITTER ITEMS AS RECORDED ON BULGARIAN BLACK SEA BEACHES Share % (by number of Marine litter items marine litter type) Cigarette butts and filters 29.7 Plastic caps/lids drinks 9.4 Plastic caps and cup lids 7.9 Plastic/polystyrene pieces/sweet wrappers 5.4 Small plastic bags 3.9 Drink bottles ≤ 0.5 liters 2.9 Source: Less Plastics Bulgaria. Simeonova et al. 2017 Microplastics concentrations in the Bulgarian Black Sea coast are comparatively low but further studies are needed. Studies of the Bulgarian Black Sea coast have shown that the concentration of microplastics (items smaller than 5mm) was on average lower than those found in other parts of the Black Sea, the Baltic Sea, and the Mediterranean Sea, although the observed ranges were similar. While, for example, the Burgas Municipality 57 https://www.bsbd.org/UserFiles/File/Sea/%D0%9C%D0%BE%D1%80%D1%81%D0%BA%D0%B0_%D1%81%D1%82%D1%80%D0%B 0%D1%82%D0%B5%D0%B3%D0%B8%D1%8F_%D0%A0_%D0%91%D1%8A%D0%BB%D0%B3%D0%B0%D1%80%D0%B8%D1%8F. pdf. 58 Simeonova, A. and R. Chuturkova. 2019. "Marine litter accumulation along the Bulgarian Black Sea coast: Categories and predominance." Waste Management, 84, pp.182-193. 59 Ibid. 32 is adapting their laboratory to better study microplastics, further studies are needed to elaborate the extent and spatial distribution of this type of pollution in the Black Sea basin. Bulgaria took steps in transposing the EU Marine Strategy Framework Directive by adopting the National Marine Strategy which includes four measures relevant to marine litter. However, important gaps in the legislative and strategic framework remain such as the absence of a definition of the term 'marine litter,' as well as a clear methodology for marine litter hotspots. The National Waste Management Plan 2021-2028 does not include reference to marine litter. Similarly, the issue of microplastics is not specifically addressed in the current national policy framework. Another hindering factor is the lack of monitoring of inner rivers. This is not an obligation, but the majority of plastic pollution is associated with the rivers flowing into the Black Sea. Numerous gaps constitute hindering factors for effective institutional coordination especially at the local level as the Black Sea municipalities are not in position to address the problem of marine litter alone. As noted during stakeholder consultations there is insufficient coordination and information exchange between the Black Sea Basin Directorate and the Black Sea municipalities regarding marine litter. The inclusion of a definition of 'marine litter' in the legal framework and relevant by-laws will be a clear message for the local authorities as they will be legally obliged to address marine litter in their waste management programs at the local level and take more ambitious actions. 5.8 Construction and Demolition Waste No reliable data are available on the amounts of CDW produced per municipality in Bulgaria. Data on the national production of CDW, published by the National Statistical Institute,60 show an unrealistic decrease in CDW over the last five years, with total generated CDW streams dropping by over 97 percent between 2015 and 2019. This indicates that the data available are unreliable, and demonstrates the need for more transparency, further studies, and analysis of the flows relevant to CDW in Bulgaria. Moreover, the data on CDW that Bulgaria submits to Eurostat are not reliable.61 CDW management policies are misunderstood in the country, influenced by national economic, social, and technological factors.62 TABLE 10. OFFICIAL DATA ON CDW CDW 2015 2016 2017 2018 2019 Total generated (tonnes) 1,661,067 2,088,923 559,309 192,964 59,744 Recycling and recovery (tonnes) 436,345 1,507,418 148,673 142,622 44,003 Recycling and recovery (percent) 26 72 27 74 74 Disposal (tonnes) 549,958 85,254 257,494 23,222 11,555 Disposal (percent 33 4 46 12 19 Exported (T) 2,390 314 534 — 1,333 Exported (%) 0.14 0.02 0.10% — 2.23 Source: National Statistical Institute, Bulgaria. 60 https://nsi.bg/. 61 Stoyanov, V. A., V. Petkova, and V. Andonova. 2020. "Analysis of the construction site waste management plans in Bulgaria, adopted in the period 2015-2017." In IOP Conference Series: Materials Science and Engineering, vol. 951, no. 1, p. 012027. IOP Publishing. 62 Saez, P. V., and M. Osmani. 2019. “A Diagnosis of Construction and Demolition Waste Generation and Recovery Practice in the European Union.” Journal of Cleaner Production 241: 118400; Malinauskaite J., H. Jouhara, and N. Spencer. 2017. “Waste Prevention and Technologies in the Context of the EU Waste Framework Directive: Lost in Translation?” European Energy and Environmental Law Review 26: 66. 33 In addition, no information is available on the implementation of the main indicators for achieving CDW targets.63 This is accompanied by a lack of vision and strategies after 2020, lack of detailed and summarized statistics on CDW, and lack of monitoring mechanisms and reports to national authorities. Overall, there is a great degree of uncertainty about the application of CDW management in Bulgaria and a demonstrated need for measures to promote and develop CE initiatives in demolition, renovation, and construction. 63 Stoyanov, et al. 2020. 34 6. SWOT Analysis for Bulgarian Transition to the Circular Economy This Strengths, Weaknesses, Opportunities, Threats (SWOT) analysis focuses on the general transition of Bulgaria to CE and is based on interviews, focus groups, and past experience of the study team. It thus includes an inevitable degree of subjectivity. Key strengths identified in the SWOT analysis are related to taking steps to set up the strategic policy framework for CE development, as well as implementation of individual projects for composting and separate collection of bio-waste, as well as good practice of circular use of material in some industrial sites. As noted in the 2020 European Semester Country Report, these practices need to “be pursued and developed.” On the other hand, significant weaknesses exist with regard to the low circular use of materials, waste management challenges, as well as insufficient knowledge and understanding of CE among businesses and public authorities at the local level. Some of the key strengths, weaknesses, opportunities, and threats are presented below with a particular focus on the strategic and regulatory framework, institutions, assignment of responsibilities, and funding. 6.1 Strategic and Regulatory Framework In principle, as Bulgaria is a member of the EU, all EU laws need to be in place, including those which would support the transition to CE. However, implementation of the legislation remains an issue. Strategies are often perceived solely as a necessary condition for accessing EU funds, rather than essential guiding documents for long-term planning. Moreover, strategies are often developed without broad consultation with stakeholders, and thus do not have stakeholder buy-in. While Bulgarian legislation currently tends to focus on waste management, circularity is often determined upstream. In Bulgaria, waste management is a key element of CE, given the multiple problems related to waste in the country. In fact, CE is often confused or considered synonymous with the concept of waste management. CE is not possible without circular waste management systems, but CE policies need to go beyond. The focus on waste management may distract from a wider government vision of a circular transition, including related legislation and fiscal policy, which would also support the development of circular products and businesses. The existence of strategies, laws and regulations does not necessarily always entail change on the ground. This is due to a gap between de jure and de facto implementation of policies, which may exist due to issues related to monitoring, reporting and enforcement. In fact, stakeholders noted that enforcement of legislation is weak in Bulgaria and needs to be strengthened through, among others, a review of institutional responsibilities and capacities. 6.2 Institutions CE solutions can succeed if they are driven and implemented by strong and experienced public institutions; however, this is not always the case in Bulgaria, where the culture of collaboration between institutions often leaves significant margin for improvement. The capacity of municipalities with regard to implementation of CE is far from optimal. The interviews carried out as part of this study demonstrated that very few municipalities are active in developing CE initiatives. Cooperation between local authorities, universities, business intermediaries, and nongovernmental organizations (NGOs) can also be significantly improved. Industrial parks (or zones) are important stakeholders, especially with regard to CE. Some industrial parks interviewed demonstrate a high degree of understanding of CE and have concrete ideas about how industrial symbiosis could play a role in developing a CE model. A number of NGOs have an increasing understanding of CE and who may be important allies in future initiatives. These NGOs include, among others, Za Zemiata, Bluelink, Institute for CE, and the Public Center for Environment and Sustainable Development. 35 6.3 Collaboration Between Institutions and Governance Levels Responsibilities for CE are divided across several ministries, with each ministry responsible for a specific aspect of CE; this leads to institutional fragmentation and calls for the need for better coordination. As specified in the institutional analysis of proposed interventions, a major factor for the success of all proposed interventions is an active collaboration between institutions, especially as follows: 1. At the national level: between the Ministry of Economy and Industry, the Ministry for Innovation and Growth, the Ministry of Environment and Water, and the Ministry of Tourism (in the case of the plastics and marine litter initiatives); 2. At the local level: between local authorities, the Regional Inspection of Environment and Waters (RIEW), the Black Sea Basin Directorate (BSBD), the EPR organizations (in charge of packaging waste), and NGOs; 3. Between the national and local levels: in certain cases, local authorities still need the green light from the central level especially where funding is concerned. Policy that entirely depends on the national level can create roadblocks to local level action; cooperative action is needed to remove this roadblock. 6.4 Availability of Funding Bulgaria finds itself in a favorable position with significant financial resources originating from the ESIF and the Recovery and Resilience Plan. Stakeholders (including national, municipal, business, and so on) are, or will be, eligible for a large number of programs. Through 10 national programs, Bulgaria benefits from ESIF funding of €11.1 billion under the 2014-2020 programs, which together with national co-financing increases to €13.1 billion. Of this amount, some €9.8 billion, or 75 percent, had been spent already as of the end of 2022.64 However, Bulgaria should improve its capacity to prioritize, structure, and tender projects. The country should also switch from infrastructure-based to systemic projects. For example, hundreds of millions of euros planned for energy renovation of buildings within the Recovery and Resilience Plan should be accompanied by systemic circular measures and approaches in the building and construction sector. FIGURE 5. EXAMPLE OF A SWOT ANALYSIS RELATED TO CE POTENTIAL STRENGTHS WEAKNESSES - Several strategic documents opening up possibilities for CE - Low and declining use of secondary raw materials measures and initiatives - Low resource productivity - National CE Strategy adopted - Low levels of waste collection, sorting and treatment - Several progressive municipalities undertake actions - Limited investment opportunities in eco-innovation and CE - At least one industrial park has a very good understanding of - Data quality issues CE, Industrial Symbiosis, etc. - Insufficient cooperation between institutions, both on national - Ministry of Economy and Industry understands the issue of and local level Industrial Symbiosis - Low awareness and understanding of CE principles - Some success in recycling (e.g., e-waste, plastic packaging) - Instruments in place to support SMEs - EPR system in place SWOT ANALYSIS Application of CE Measures OPPORTUNITIES THREATS - New EU strategic documents focus on CE - Locked into traditional waste management and landfilling - Significant financial resources available within ESIF, Recovery - Only individual components of different initiatives implemented, and Resilience Fund, Just Transition Fund, etc. rather than a holistic approach - Economic growth potentials through new business models - Weak enforcement of legislation - CE can promote a culture of cooperation - Work culture does not foster institutional collaboration - Few technical, R&I, business and policy specialists that can support CE transition Source: Original elaboration for this publication. 64 https://cohesiondata.ec.europa.eu/countries/BG. 36 7. Recommendations for Individual Circular Economy Initiatives and Measures The main purpose of this diagnostic analysis is to identify areas of intervention with high potential to accelerate the CE transition in Bulgaria. As specified in the methodology, the recommended initiatives and measures have been selected based on several criteria: • Relevance o To the country’s need to improve resource efficiency in industry o To solve the issue of pollution of the Black Sea and Black Sea beaches with plastics o To the huge volumes of CDW • Coherence with the EU and Bulgarian strategic directions and legal context and targets to which the country has committed • Acceptance by consulted stakeholders, national authorities, and municipalities • Availability of good examples across the EU • Link with digitalization: all initiatives have a strong digital component. Based on this approach, the analysis suggests follow-up operations in four areas: • Enterprises Connected for Industrial Symbiosis • Plastic-free Black Sea Coast • Scale-Up, Reuse, and Recycling of CDW into New Virtuous Cycles • Establishing Municipal Reuse and Repair Centers The four initiatives could be complemented by the deployment of two horizontal interventions: • Development of a pilot local CE strategy and action plan for one of the more advanced municipalities • Launch of a national CE platform bringing together relevant legal information, CE knowledge, and best practices The identification of these four initiatives and two horizontal actions does not mean that there are no other initiatives worth embarking upon. However, these initiatives have been prioritized by all consulted stakeholders including the municipalities and fit well with the maturity level in the country and with strategic directions of development. 7.1 Enterprises Connected for Industrial Symbiosis The launch and implementation of a program on industrial symbiosis (IS) may start with one pilot region (Burgas-Stara Zagora) and/or Plovdiv. The program would be an opportunity for Bulgarian enterprises to leapfrog to the globally tested circular business model and work toward a mindset shift toward viewing waste as a resource. The initiative would be coherent with EU efforts to promote IS as a whole through the European IS network, CircLean, and other initiatives. The program would be composed of several components, as illustrated in Figure 6. 37 FIGURE 6. ELEMENTS OF THE PROPOSED PROGRAM OF INDUSTRIAL SYMBIOSIS Source: Original elaboration for this publication. The program would ideally be implemented in a holistic manner. If individual components of the initiative are funded separately, then it must be fully clear that they are a part of a bigger program and could only work in combination with the other components, for example, individual components such as the software should not be implemented in isolation but together, as part of a holistic approach. The intervention would fit with the strategic framework of the country, the recently adopted CE Strategy and the SME Strategy adopted in April 2021. It would be positively received by the EC, given the EC’s strong insistence on actions higher on the waste hierarchy. An initiative on industrial symbiosis would address both the issue of waste management within Bulgarian enterprises and the issue of low resource efficiency. Both of these have tangible climate implications. The initiative would also improve the knowledge of both the local authorities and industry stakeholders on materials flows. This activity would trigger a higher degree of cooperation between industry stakeholders and the benefits would go beyond the exchange of material flows. The most significant impact of the initiative would be the change in perception of waste from material to be landfilled or recycled to waste as a secondary raw material. During the focus group on industrial symbiosis and CE and within the survey it has also been confirmed that a potential action would be in line with local priorities. While the usefulness of the initiative is undisputed, there are still some obstacles that need to be addressed. These include insufficient political support and limited coordination between local and national levels. Legal issues like end-of-waste status can also potentially come in the way but these can be addressed by the government as has been the case in other EU countries. The initiative is presented in detail in Annex F. 7.2 Plastic-Free Black Sea Coast This intervention aims to contribute to the development of a common vision for a plastic-free Black Sea coast and assist in addressing in a holistic and systemic way problems related to plastics pollution and marine litter along the Bulgarian coastal territories. Specifically, the intervention seeks to enable local governments, tourism-related businesses, national authorities and other tourism stakeholders to take concerted action to shift toward circularity. The intervention will contribute to the integration of sustainability principles in coastal tourism, which was adversely affected by the COVID-19 pandemic. The proposed intervention was developed as a response to the gaps and needs identified through the interviews, focus group meeting, and analysis of relevant documents. Specifically, the gaps that will be addressed through the intervention include the following: 38 • Regulatory gaps related to addressing marine litter (for example, ‘marine litter’ as a term is not included in the legislation; there is no monitoring of inner rivers for plastics that turns into marine litter as this is not a legal obligation, but the majority of plastics pollution is associated with the rivers flowing into the Black Sea) • Insufficient coordination and cooperation among public institutions and governments at the national and local levels to address plastic waste pollution at its source and ensure proper marine litter monitoring • Suboptimal functioning of the EPR system (for example, insufficient/lack of infrastructure for separate waste collection, especially in lesser populated areas including some resorts) • Unsustainable practices of the hotel/restaurant/café (HORECA) sector leading to plastic pollution and littering and in general lack of integration of circularity principles in the tourism sector in Bulgaria. • Low level of awareness of plastic pollution and the need to take action on the part of tourism businesses, beach concession operators, and the general public. The intervention is structured around four components with several actions per component. Component 1: Support for addressing marine litter in the national strategic framework • Review and analysis of the national regulatory framework with a focus on marine litter and plastic waste; contributions to the development of a national action plan for marine litter. • Review of institutional responsibilities related to implementation and enforcement of the provisions on plastic pollution prevention and clean-up in the coastal areas. Component 2: Support improvement of the existing EPR system • Analysis of the EPR regulatory framework and recommendation for its improvement with a focus on stricter responsibilities of recovery companies. Analysis of the role and responsibilities of municipal authorities. Component 3: Support Black Sea municipalities to improve local policies toward stronger emphasis on waste prevention including plastic waste prevention and reuse. • Pilot waste prevention and reuse municipal program addressing plastic waste and marine litter • Recommendations on how to put in place a deposit return system in Bulgaria and its main features, management, and so on. Component 4: Support for greening the HORECA sector and reducing the plastic waste it generates. • An assessment of HORECA sector-induced plastic pollution; recommendations for phasing-out unnecessary plastic packaging and items, and taking action to move from single-use to reuse models or reusable alternatives • A program for raising awareness and knowledge of how to integrate sustainability in the activities of the HORECA sector • ‘Plastic-free’ label for the HORECA sector in Bulgaria. The initiative will be in line with a number of national and subnational development priorities addressing the problems of unsustainable waste management practices in the tourism sector and increased littering and plastic pollution especially with SUPs. These objectives are included in a number of national documents such as the National Strategy for Sustainable Tourism Development (2014–2030) Marine Strategy, Black Sea Marine Litter Regional Action Plan Waste Management Law of Bulgaria and Bylaws, and so on. During the focus group on tourism and within the survey, it has also been confirmed that the potential action would be in line with the priorities of the Black Sea municipalities. The initiative is presented in detail in Annex G. 39 7.3 Scale up Reuse and Recycling of CDW into New Virtuous Cycles The ultimate strategic objective of the proposed intervention is to enable Bulgaria to reach its CDW management and recovery targets and to comply with the hierarchy of waste management in accordance with European and national legislation.65 In addition, the proposed intervention would address the waste- related aspects of Bulgaria's energy renovation sector, which are expected to expand in the coming years because of the high potential for energy efficiency improvement in Bulgarian residential and public buildings but also because of the high amount of EU funding to be directed to the sector in the coming years through the National Recovery and Resilience Plan. To reach the strategic objective, three outcomes must be achieved: (i) visibility and understanding of recurrent CDW flows must be provided by characterizing, quantifying and locating them at the municipality level; (ii) effective methods for CDW management must be implemented at both the construction site and municipality levels for their effective reuse, recycling, and other recovery; and (iii) tracking and tracing methods for CDW must be introduced and generalized to establish reliable statistical data on CDW management and recovery rates in Bulgaria. CE, applied to CDW, has impacts on different levels of activity: CDW flows at the municipal level, connecting construction and demolition sites (sources of waste and outlets for secondary products) to local industrial and economic actors (reuse and repair networks, recycling industries). To achieve the strategic objectives of the intervention, this study aims to elaborate the CDW management targets taking into account different levels of activity. It offers a holistic approach for systemic actions, mobilizes players at the local, regional, and national levels, and engages stakeholders in both construction and industry. The proposed approach is in line with the energy efficiency upgrade of existing buildings. In view of the numerous energy efficiency renovation works planned for public buildings and housing, the study team proposes this process to be coupled with CE measures in CDW management. These renovation projects offer the possibility to launch pilot projects for study and innovation, enabling a link between the different levels and stakeholders, and allowing for targeting several recurrent CDW flows generated by the renovation activities. This proposed intervention includes three actions, corresponding to the three levels of development of CE in CWD management. The aim is to integrate innovative strategies and operating methods into current practices, and to provide actors with a better understanding of and expertise in the issues at stake: Component 1: Study the CDW flows at the municipal level • Provide visibility for CDW and secondary resource flows at the territorial level. Component 2: Implement innovative project and construction site activities • Design strategies for efficient extraction of secondary resources from demolition operations • Design strategies for integration of reused elements and recycled materials in construction and renovation projects. Component 3: Promote and support local reuse networks and industrial and economic players • Study the existing reuse and recycling activities and the opportunities for business development to handle new flows • Promote new reuse activities, by encouraging the establishment of reuse and repair networks. Potential counterparts • Potential primary institution: Ministry of Regional Development and Public Works, local authorities 65 The set target for preparing for reuse, recycling, and other material recovery of non-hazardous CDW is a minimum of 70 percent by weight. Prevention is to be achieved through the reuse, then recycling, followed by other recovery, with disposal as the last resort. The European legislation referred to here is the Directive 2008/98/EC on waste (WFD) from 2008, amended by Directive 2018/851 in 2018; Bulgarian legislation referred to here is the Ordinance on Construction and Demolition Waste Management and Use of Recycled Building Materials, introduced in Bulgaria in 2012. 40 • Other stakeholders that should be taken into consideration: construction/renovation project owners (public and private), demolition, and construction contractors, local industrial stakeholders, and reuse networks. • This proposed initiative was discussed during the focus group on industrial symbiosis and participants acknowledged its importance and timeliness. This initiative is presented in detail in Annex H. 7.4 Establishment of Municipal Reuse and Repair Centers The repair business model traditionally has been present in Bulgaria because of the relatively low cost of labor. However, the combination of rising living standards and consumerism has reduced the importance of the repair culture as it is becoming increasingly easy and cheap to purchase a new item. At the same time, reuse and repair are two circular strategies which are increasingly promoted at the EU level. Extending the life of products is paramount for the reduction of the use of virgin raw materials and the reduction of GHG emissions. Moreover, currently the EC is preparing for the launch of an ambitious Sustainable Product Initiative where the repairability of products would be integrated as a legal requirement. This study explored possible deployment of different reuse and repair initiatives. Reuse is also associated with other concepts like repurposing and upcycling related to the previous initiative. Reuse and preparation for reuse can save one-third of items collected at municipal waste collection points from premature recycling, landfilling, and incineration. At the same time, repair practices applied for just 1 percent of municipal waste can create local jobs for vulnerable segments of the population in Bulgaria. Reuse and repair are not only an opportunity for waste prevention and job creation, but they also help ensure that benefits and resources are kept at the local level and that wellbeing and the quality of life of citizens can improve, both in the regions and beyond. Establishing a network of centers for implementing circular practices will bring together the skills and expertise of artists, scientists, designers, and craftspeople in a common purpose of sustainability. The intervention is in line with the EU CE objectives, as well as the priorities defined in a number of Bulgarian strategic documents. These include the National Waste Management Plan 2021–2027, the recently adopted CE Strategy, and so on. In particular, the latter envisages support for the establishment of reuse and repair centers in cities. Establishment of municipal repair and reuse centers as well as their social aspects was also discussed and supported during the meeting of the focus group on industrial symbiosis and CE. This initiative is presented in detail in Annex I. In addition to the four measures, which have been outlined above and are described in more detail in the annexes, a number of additional horizontal initiatives/measures could further enable the transition to CE. These are briefly described below. 7.5 Vision: Strategy/Roadmap Development at Urban/Municipal Level In the context of recent developments in the countries of the EU and beyond, and in addition to the national CE strategy, Bulgaria could explore the preparation and adoption of local CE strategies or Local Green Deals with strong CE aspects. Work on the preparation of CE strategies encourages local governments to enter into intensive consultation with different city-level stakeholders such as companies, civil society, and the knowledge community. The process of drafting the strategy allows local authorities to map local/regional assets, map relevant actors, and outline concrete measures and initiatives adapted to the need of the city or the region. It also allows local authorities to draw the attention of the public to important issues and local potential. The purpose would be to map measures and initiatives which increase the circularity of the city and go beyond its legal obligations in waste management and other related sectors. Making cities more circular has an additional positive impact on waste (that is, CDW and food waste) generation and waste prevention (that is, through industrial symbiosis). The interviews, meetings, and focus groups conducted as part of this study have demonstrated that the Burgas Municipality has the highest maturity and readiness for the development of a CE 41 strategy/roadmap. The level of understanding of the leadership and the experts and the level of cooperation between different CE stakeholders would make the development of a CE strategy or roadmap possible. Stakeholders to be consulted during CE roadmap/strategy development include local governments, the Ministry of Environment and Water, the Ministry of Economy and Industry, CSOs, local businesses/industries, and entrepreneurs/communities of start-ups. Aspects to be explored during meetings with stakeholders include previous similar efforts (if any), relevance of a potential city-level CE strategy for urban needs and priorities, coherence of a city-level strategy on CE with other strategic documents, identifying main institution and/or departments within the institution to be responsible for drafting the strategy, listing the main stakeholders to be engaged in and consulted with during its drafting. A good practice example of a CE strategy on the city level is presented in Annex J. 7.6 Horizontal CE Platform A horizontal CE platform would serve as an information and awareness-raising tool. The platform could be national, regional, or local. It could combine technical tools, useful reports, newsletters, and other information. Currently, no such platform exists in Bulgaria. For such a platform to succeed, it is crucial that it becomes the single platform for CE in Bulgaria and is recognized as such by different CE players. The platform should be actively facilitated by a professional moderator and should serve several complementary purposes. • Communicate the strategic/policy framework • Serve as a knowledge hub on CE • Include sections targeted at national and local authorities, citizens, and industries • Provide a tailored sectoral approach for industries and SMEs. A good practice example of a CE platform is presented in Annex J. 42 Annex A. Stakeholders Consulted Institution/Organization Ministry of Economy and Industry Ministry of Tourism Burgas Municipality Sofia Municipality, Waste Directorate Bulgarian Development Bank Water and Sewage Holding Ecopartners, Varna Branch Association Public Environmental Center for Sustainable Development, Varna Regional Economic Development Agency, Stara Zagora Denkstatt Osnova Trakia Economic Zone (TEZ) Za Zemiata Institute for CE World Wide Fund for Nature (WWF) 43 Annex B. Survey Analysis An online survey was sent to more than 200 Bulgarian municipal authorities by e-mail. Answers were received from 34 municipalities. Of the municipalities which responded, seven are district centers: Sofia, Varna, Haskovo, Dobrich, Targovishte, Sliven, and Yambol; seven are located in the Black Sea coast area: Varna, Sozopol, Nesebar, Primorsko, Balchik, Shabla, and Dolni Chiflik; and 27 are small and medium-size municipalities. The survey was organized in nine sections: Sections Section A Understanding of the CE concept Section B Implementation of past, current activities/initiatives related to the CE. Already planned future activities Section C Local potential and capacity for taking up future concrete CE actions/initiatives/measures Section D Vision, priorities, and partnerships Section E Ideas for future concrete CE actions/initiatives/measures Section F Enabling conditions and hindering factors for a circular transition Section G Sustainable tourism in coastal territories Section H Development of industrial symbiosis Section I Funding for future concrete CE actions/initiatives/measures The results are presented below. Section A: Understanding of the CE concept (within the local administration and among local CE stakeholders) FIGURE 7. WHAT IS THE LEVEL OF GENERAL KNOWLEDGE AND UNDERSTANDING OF CE AND ASSOCIATED CONCEPTS? 30 25 20 15 10 5 0 Within the administration Among local CE stakeholders none low average very good excellent In general, most of the responses confirm that the administration and the local business system have an average level of understanding of the CE concept. 44 Section B: Implementation of activities/initiatives related to the CE (even if they are not necessarily referred to as ‘CE’) Planned activities Some municipal programs or similar activities that support CE models are being (or have been) implemented, but also some of the examples (that had been provided as options) had never been implemented. Almost all such activities are under consideration. Most of the programs or activities that have been implemented are related to waste management and waste prevention - recycling, composting, reuse, and repair centers. The lack of organizational and financial capacity are the main reasons why actions are postponed or still not implemented. The intentions for future projects are predominantly in waste prevention (especially plastics), in the sectors of construction and textiles, followed by packaging, furniture, and agriculture. Unfortunately, few activities are planned in industry or the information technology (IT) sector. Examples of implemented activities for different types of waste generated in the municipalities, predominantly green waste: • In the municipality of Levski and Bratsigovo, green and biodegradable waste generated by households is composted in people’s backyards using household composters provided by the municipality • Belogradchik Municipality also does some composting and has separate collection for packaging waste. Textile is collected separately • Sozopol and Burgas are involved in a project for energy production through anaerobic digestion of household waste. Tundja Municipality introduced a biogas installation which processes agriculture waste. Quite a large share (34 percent) of municipalities surveyed have never implemented initiatives related to sustainable and circular sectors. But there are also many good examples of activities implemented on the territory of the municipality spontaneously and without the municipality’s participation. These include initiatives of NGOs and businesses, mostly concerning waste. One example of industrial symbiosis was provided (utilization of sawdust generated as industrial waste). Motivation factors cited by local authorities for ‘going circular’ and implementing CE measures and initiatives include, in first place, “reduced landfilling and waste prevention” and “reducing environmental pressures.” This is understandable since waste problems are considered among major concerns for the municipalities. Next on the list of motivating factors, municipalities cite image of the municipality and business, access to funding, alignment with the EU Green Deal, and creation of business and job opportunities locally. Section C: Local potential and capacity for taking up future concrete CE actions/initiatives/measures A thorough assessment of the regional/local potential for a transition to CE has not been completed in any of the surveyed municipalities. Only specific industries/economic sectors have been assessed. The opinion of most respondents is that the agricultural sector and construction sector have the potential for circular actions. Wood processing, automotive services, recycling processes are also considered as potential growth areas for CE. 45 FIGURE 8. WHICH OF THE FOLLOWING SECTORS THAT ENGAGE THE MOST PRIMARY RESOURCES AND HAVE SIGNIFICANT CIRCULAR POTENTIAL ARE DEVELOPED IN YOUR REGION, AND TO WHAT EXTENT? Packaging FIGURE 9. IS THERE CAPACITY IN YOUR REGION (WITHIN THE ECOSYSTEM AS A WHOLE: PUBLIC, BUSINESS, ACADEMIA) TO DO THE FOLLOWING: FIGURE 10. WHAT IS THE CAPACITY WITHIN THE LOCAL ADMINISTRATION AND WITHIN THE LOCAL ECOSYSTEM TO IMPLEMENT CE MEASURES AND ACTIVITIES IN THE FOLLOWING SECTORS Section D: Vision, priorities, and partnerships Only 9.1 percent of respondents said that their municipality has a territorial vision for the transition to the CE, with sectoral and other priorities. But only 10 percent state that their municipality does not have such a strategic view at all. Most respondents have elaborated vision and priorities for some sectors, but not complete plans or strategies. Just 3 percent say the issue has not been discussed at all at the strategic level. Almost all municipalities are planning to do so in the near future. Prioritization of regional/local actions in the transition to CE has not been undertaken in most of the municipalities. Waste, tires and auto parts, transportation, wood processing, and public procurement process are mentioned as priorities for the CE transition and implementation of planning in this direction. 46 Municipal administrations are working on a regular or spontaneous basis with most of the regional/local stakeholders involved in the transition to CE. There is more active collaboration with utility companies and CSOs. Collaboration is not as regular with businesses and business intermediaries (business associations, clusters, accelerators/incubators, and so on) and even less so with academia and other organizations and structures. Respondents shared some highly feasible ideas for future concrete CE actions/initiatives/measures that might be implemented in the next five years, as follows: • Developing a circular vision for the regional/local level by involving various stakeholders • Deploying waste prevention programs among citizens and businesses for different waste streams (for example, food, plastics) • Introducing programs/initiatives/measures for reuse (for example, textile, municipal reuse centers) and programs for the tourism sector. Somewhat likely feasible ideas for future concrete CE actions/initiatives/measures, that might be implemented in in the next five years included the following: • Integrating CE into local regulations • Introducing programs/initiatives/measures for repair (for example, electronics, household appliances, municipal reuse centers) • Introducing different sharing services (transportation, municipal centers for shared products, and so on) • Supporting social enterprises for CE • Restricting or controlling the use of disposable items (including SUPs) • Improving the recycling infrastructure for different waste streams • Developing a functioning market for secondary raw materials • Introducing resource efficiency programs for businesses • Introducing a regional industrial symbiosis program • Working with individual sectors of the economy for greening the sectors and making them more circular • Electric, electronic, and ICT • Cars, auto parts, and batteries - new regulatory framework for batteries, that will ensure higher recycling, durability and will foster circular potential of batteries • Packaging and production of packaging material • Textile, textile goods, and apparel • Waste treatment installations • Banning the destruction of unsold durable goods • Integrating CE into city planning • Introducing municipal innovation clusters. Section F: Enabling conditions and hindering factors for a circular transition The responses make it clear that both the administration and local ecosystem (businesses, utilities, business intermediaries, NGOs, and so on) do not have significant capacity related to CE or understanding of CE business models. The local authorities do not have enough capacity to work with (and guide) different sectors and local ecosystems to make them more circular either. The capacity of local authorities to formulate a vision and prioritize actions and formulate policies is also considered to be limited. The information which municipalities are providing to people and businesses with regard to the opportunities from CE is insufficient, or in some cases, nonexistent. Businesses and individuals lack information on how they can get support for the application of these principles in their daily lives and business ventures. Most of the municipalities state that some information is provided. About one-third of them (Sofia, Varna, Levski, Bracigovo, Miziya, Dobrich, Kustendil, Nesebar, and Shabla) believe that the information is sufficient for people and businesses with regard to: • Sustainable production for businesses • Waste management for citizens 47 • Waste management for businesses • Plastic waste prevention for citizens • Plastic waste prevention for businesses. Very few (Nesebar, Kustendil, and Sozopol) state that they are providing sufficient information on these additional topics: • Circular business models • CE for different economic sectors • Possibilities for enterprises to exchange waste flows (industrial symbiosis), financial opportunities related to the CE • Existing legal requirements • Sustainable use of goods for citizens • Waste management for businesses • Circular business models. Most of the municipalities plan to support the introduction of new information products and services that will facilitate sharing of information as follows: • Waste management information for citizens, 77 percent • Waste management information for businesses, 77 percent • Information on plastic waste prevention for citizens, 69 percent • Sustainable consumption information for citizens (for example, on sustainable products), 62 percent • Reuse, 60 percent • Information on plastic waste prevention for businesses, 57 percent • Repair, 51 percent • Sustainable production information for businesses, 49 percent • Collaborative consumption/sharing, 43 percent • Information on circular business models, 40 percent • Information on financial opportunities related to the CE, 34 percent • Information on possibilities for enterprises to exchange waste flows (industrial symbiosis), 34 percent • Information for existing legal requirements, 34 percent • Information on CE for different economic sectors, 23 percent • Information for sustainable usage of goods for citizens, 3 percent • Information for waste management for businesses, 3 percent • Information for circular business models, 3 percent. When asked about the creation of an appropriate environment for the development of innovation — an important factor for the prosperity of society and the economic development — respondents noted the importance of industrial zones (44 percent) and business centers (31 percent), and innovation infrastructure and support (22 percent). Other options were proposed by fewer than 5 percent of respondents. Only three municipalities have already conducted Green Public Procurement or have included ‘green’ requirements in regular public procurement procedures. Changes in the regulations at local and national levels are considered as needed to remove administrative and legal barriers to implement CE principles and economy of sharing of goods and services, foster circular businesses, especially in waste management and taxation. The need for more resources for this to be implemented is also mentioned. The municipalities of Rakitovo and Levski noted that changes in local waste management legislation are needed. Shabla is proposing new tax legislation and additional reforms in the educational system, as well as information campaigns, business support programs, and trainings. 48 Section G: Sustainable tourism in coastal territories This section was announced as open for municipalities from the Black Sea area. Thirteen municipalities provided answers The municipalities in coastal areas have already implemented some initiatives/measures/activities related to plastics. These are mainly for separate collection of waste, in the municipalities of Varna, Sozopol, Dolni Chiflik, and Primorsko, and regular cleaning of the beaches in Shabla. Marine litter is not generally considered a direct obligation of municipalities. Additional initiatives that have been implemented or planned are related to waste management in resorts, increasing awareness of local people and tourists, issues related to water savings and water management, and hotel operations. Also implemented or planned are programs for sustainable tourism, integrated tourist packages, and connections between the tourism and agricultural sectors. Development of actions for reduction of plastics in general and marine litter are being considered at both the regional and local levels, with 40 percent of municipalities considering these types of actions as a part of a national effort. Only 10 percent are not considering some actions in the near future. The Municipality of Sozopol is considering the implementation of measures for development of sustainable tourism: • Projects for development and popularization of alternative forms of tourism by using the potential of the internal territory of the municipality • A project for creation and promotion of an integrated tourist product, distinguishing the Municipality of Sozopol from the other Black Sea municipalities • Projects to improve the connection of local agriculture with the tourism sector. The municipality is also considering initiatives for interaction between the Black Sea municipalities, the concessionaires, and the tenants of the sea beaches, including campsites and recreation areas. Section H: Development of industrial symbiosis There is some limited, but insufficient understanding of the concept of industrial symbiosis within the local administrations (67 percent) and local industries (53 percent). Some surveyed municipalities reported unsuccessful attempts to develop (elements of) industrial symbiosis locally. Two successful examples were also mentioned in wood processing and waste treatment. In the Municipality of Rakitovo, timber and wood processing is well developed. The remaining 'waste' from wood processing is used from small companies to produce eco-pellets. These eco-pellets have found a very good market in recent years, with much of the production exported to Italy as a fuel for pizzerias. The Municipality of Tundja is an agricultural region and uses much of its green waste and manure in small bioreactors in the production of biogas. The gas is used in a cogeneration process for the production of electricity. Some 38 percent of respondents are considering implementing measures to support the development of industrial symbiosis locally in the near future. Fifty-two percent say they will implement such measures only if it is a part of a national effort. Two main obstacles to industrial symbiosis were identified by the respondents: • Lack of (or very little) understanding of the concept on the municipal level and lack of government CE policy • Insufficient knowledge among SMEs of the concept of industrial symbiosis. Lack of a multi-stakeholder platform and lack of matching events between interested parties were also cited as less important obstacles. These are then followed by regulatory barriers; insufficient quantity, quality, and type of the generated waste; and lack of sufficient clarity on the status of industrial zones (which could allow for industrial symbiosis to start at the stage of planning of the industrial zone). 49 Section I: Funding for future concrete CE actions/initiatives/measures The financial resources from landfill taxes (deductions for landfilling under Art. 60 and 64 of the WMA) are planned to be used for improvement of the waste management system — equipment, planning and construction of infrastructure, and information campaigns. Most respondents believe that funding under the ESIF will not be sufficient to support all of the measures and initiatives discussed above (Figure 11). FIGURE 11. PERCEPTIONS OF SUFFICIENCY OF ESIF FUNDING Fully sufficient Sufficient to a large degree Sufficient only to a small degree Additional funding sources for implementing measures and initiatives discussed above are considered: • Own municipal budget, 47 percent • Funding from other sources, 24 percent • Not considering other sources, 29 percent 50 Annex C. Notes from Focus Group on Circular Actions at Regional/Local Level with an Emphasis on Industrial Symbiosis (IS) (May 26, 2021) Objective of the Discussion The discussion with municipalities in regions in transition aimed to identify the potential of CE in Bulgaria. The results of the discussion would contribute to the formulation of future actions for the development of industrial symbiosis in Bulgaria. Participants (18 total) • Burgas Municipality (6 participants) • Gabrovo Municipality (3 participants) • Haskovo Municipality (1 participant) • Plovdiv Municipality (2 participants) • Varna Municipality (3 participants) • GreenEdge Consulting (2 participants) • BAMEE (1 participant) Discussion Notes: Main Takeaways on Industrial Symbiosis (IS) Understanding At the expert level, there is some understanding of the concept of IS, especially in big cities. Still, there is a significant margin for improvement. The raw material/waste flows are monitored by the Regional Inspection of Environment and Waters (RIEW), not the municipalities. Municipalities are not responsible and have no information on raw material/waste flows. Timing In Stara Zagora, it is the right moment for the development of IS (for example, IS on the territories of the Maritsa East mine). Experience with elements of IS Some waste capacity has been created in the municipalities; it can be built upon. There are good examples of IS in some places: in Velingrad, a system for using sawdust in other industries has been made. Enabling factors The regional plans for just transition are now being drafted (three regions have been approved; the remaining eight regions are under consideration). This would help to implement the concept. Obstacles • State administration is not hindering IS much, but is not helping either. • At the local level alone, it is difficult to expect to have an initiative if there is no funding. • At the national level, implementation of the vision is insufficient; the plans are only on paper. The plans look good, but have not been executed. • Coordination is lacking between local and national governments. • In practice, the integrated approach is not working. • Business is reluctant to make long-term investments. • Businesses do note share information, are distrustful, and do not understand the concept well. • Regulatory barriers at the national level: participants say that businesses can describe the barriers, but note that SMEs resent inspections and penalties, and view the process as taking away business. 51 • Need to clearly define waste and resource. Ambiguities need to be cleared up. In countries where there is, this has been cleared up. Delivery • Establishing a coordinating mechanism is the most important step; such a mechanism will also help increase understanding of IS. • Need to move away from municipal grants on IP because businesses are connected; thinking should be at the regional level. • Need coordination between municipalities, but also between institutions. • Coordination at the national level is a must; it is important to create understanding. • Coordination mechanism is needed between municipalities, business, and RIEW on flows. • Municipalities are willing to support but they do not perceive themselves as the ones to manage these processes. • Industrial symbiosis is to be developed regionally and nationally. • Local authorities will participate as generators as long as they have a good foundation and a good understanding of the business. • Joint effort is needed at national and local levels. • Main parts of the project: • Secure software solutions are needed to allow businesses to score waste and connect with initiatives in Europe to connect businesses. • Platform can be open or subscription-based. • Finnish example: start with a paid platform, then develop a free one with high security. • Local expertise is needed to facilitate processes. • There is a need for studies on the raw material/waste flows of companies in a certain territory. • If the programming is not structured so that integrated investment can take place, the situation of the previous programming period will continue. Industrial parks • The important role of industrial zones in facilitating IS. This is also possible in Bulgaria. • Zagorje Industrial Zone as an opportunity to support the regional economy as well. • Industrial parks - in the OPIC and in the recovery plan, funding should be maximized. • Green energy, waste streams - need to be foreseen at the planning level. • In Burgas: Phase 1 of the IP completed, land sold off, and currently working on phase 2; identification of Ravnez airport. This is a large area with potential for IS, no economic interest declared at present. Areas to be developed for green, clean businesses. • Industrial symbiosis: Gabrovo has several industrial zones; lacks good infrastructure. • Will focus on expanding Gabrovo-Sevlievo zone, create a focused industrial zone in the next territorial development plan. Structuring a future IS initiative • Carrying out a material flow survey • Funding to promote the idea among businesses • Meeting different businesses to collaborate • Piloting a project in a region in transition at planning area level based on the potential it has • Focusing efforts and investors • Could be a pilot project and become an example for the 18 transition regions in Central and Eastern Europe • World Bank is funding Territorial Equitable Transition Plans and could take the next step • Take an integrated approach - this will lead to sustainability • For a region in transition, not removing all regulations, but seeing what can work given the situation. 52 Other Issues Related to CE Establish municipal repair and reuse centers, social aspect • Burgas has established a center for repairing old furniture — municipalities did not focus on such initiatives earlier because they could only fund certain measures • The problem is not only funding but also the sustainability of such an investment. At the same time, there are also centers that are self-sustaining • The attitudes of the population are that second-hand clothes/furniture are not socially acceptable; there is a need to raise awareness among citizens • There is enthusiasm among colleagues in Burgas Municipality to work on these issues • Gabrovo welcomes the establishment of repair and reuse centers including for electrical appliances • With regard to a more circular building/construction sector, not only is there potential but there are benefits. However, awareness is low. Companies pay more for landfill than to pass on recovery. 53 Annex D. Notes from Focus Group on Plastics and Marine Litter in Black Sea Coast Municipalities (May 27, 2021) Objective of the discussion The discussion with municipalities on regions in transition aimed to identify the potential of CE in Bulgaria. The results of the discussion would contribute to the formulation of future actions for addressing plastic waste pollution and marine litter in Bulgarian Black Sea municipalities in the context of sustainable tourism development. Participants (15 total) Institution/Organization • Black Sea Basin Directorate (1 participant) • Beloslav Municipality (1 participant) • Burgas Municipality (4 participants) • Dolni Chiflik Municipality (1 participant) • Varna Municipality (3 participants) • Pomorie-FLAG (1 participant) • World Bank, Bulgaria (1 participant) • GreenEdge Consulting (2 participants) • BAMEE (1 participant) Challenges related to marine litter and plastic waste There are eight main categories of marine litter. Plastic (polyethylene terephthalate [PET]) is the main pollutant contributing to 80 percent of all marine litter. The volumes are substantial: in 2017, about 70,000 items were detected at 10 beaches. There has been a slow decrease to 40,000 items as a result of the implemented measures and the monitoring activities but still this remains a figure of concern. The EC has adopted a maximum threshold of 20 items for a 100-m section of the beach. This is an ambitious target for Bulgaria in the short term. With the exception of the Burgas Municipality, it seems that there is insufficient coordination and information exchange between the Black Sea Basin Directorate and the Black Sea municipalities regarding addressing marine litter. There is no monitoring of inner rivers as this is not an obligation, but the majority of plastic pollution is associated with the rivers flowing into the Black Sea. Some efforts have been taken to address this land-sea link as per the EC recommendation for monitoring, especially around the mouths of the rivers. Marine litter as a term is not included in the legislation. This hinders national and local authorities in adopting prevention measures and taking more ambitious steps. There is insufficient awareness of the business sector and citizens in general about marine litter and plastic waste. Initiatives have been targeting kindergartens, students, among others, and such efforts need to continue through trainings, seminars, beach cleaning, and so on. At the same time there is a positive attitude among the general public toward behavioral change with regard to plastics. However, the level of awareness among different social groups varies substantially. There is a problem with availability of products substituting plastics. For instance, there is no supply of glass bottles in the big chains. The business has to be included as well in the efforts to address plastic waste and marine litter. The information stream with regard to monitoring of beaches has to be improved. It was acknowledged that tourism is a major source of plastic pollution and measures toward more sustainable operations of HORECA should be taken. There is a problem with small municipalities: capacity of the administration is insufficient. The responsibilities in addressing marine litter are limited. 54 Enabling factors related to marine litter The following measures targeting marine litter are envisaged in the National Marine Strategy: inclusion of marine litter as a term in the legislation, management of shipping waste, and raising marine litter awareness. There is a positive trend in addressing waste from shipping. The responsible institutions, the Ministry of Transport and Communications and the Port Authority are implementing projects aimed at waste reduction. The Black Sea Regional Action Plan was adopted at the level of the Black Sea Commission and since 2016, it has served as a framework document. One of the action plan requirements is to develop national action plans for marine litter, with a monitoring framework, identify sources of pollution. and improve measures and their effectiveness. A national plan for Bulgaria is under development. A consultation process with municipalities has been initiated demonstrating that many measures and projects are implemented at the local level. The River Basin Management Plans include measures at the local level, as a big share of marine litter comes from the rivers and dumpsites. Measures are only related to monitoring. Main Takeaways Experience with addressing plastic pollution and marine litter There is no municipal document specifically on marine litter but the topic is integrated horizontally in all municipal documents (Burgas). Examples of implemented projects by the Burgas Municipality: • Stimulating restaurants to stop using plastics (developed a logo) • Awareness-raising campaigns focused on students; some measures were targeting fishermen. Every year a Black Sea Day is organized, and the municipality signed a declaration on organizing a European Sea Day • The focus is to prevent SUPs in municipal buildings by: using green public procurement (GPP), revising contracts for events to avoid use of plastics; planning a training for the administration, delivering dispensers to prevent plastic waste • Burgas is adapting their laboratory which will be able to study microplastics • Blue label initiative: preparation of business for the ban on SUPs, soon there will be a round table for hoteliers and restaurants. Structuring a future initiative targeting plastic pollution and marine litter in the context of sustainable tourism development There is a need to develop a long-term media strategy including different target groups: municipalities, fishermen, students, divers. Tourism as a sector should be a focus. A campaign targeting tourists with the aim to raise their awareness about plastic pollution and marine litter should be launched. There is a need for cooperation with the hospitality sector (hotels, resorts, and so on). Logos for environment-friendly hotels could be considered. The number of trash bins needs to be increased in resorts for which EPR organizations are responsible. Increase in waste taxes could be considered and the deposit system could be brought into spotlight for discussion. While discussing bans, the question on the availability of substitutes of plastic products should be considered. Legislation needs better enforcement. Consultation on Waste Management Plans and more concrete measures are needed to address this. The National Plan needs to consolidate the municipal waste management plans and complement them with a marine litter focus. A main recommendation of this report is that efforts on waste management need to be combined. Municipalities are important but the responsible national authorities have a major role to play. The World Bank is already working to promote this government involvement. 55 Annex E. Relevant measures from the Bulgarian SME Strategy Measure 6.1 Support the Improvement of Energy Efficiency and Resource Efficiency of SMEs • Support to improve energy intensity in SMEs. Strengthening the network of energy auditors • Support to improve resource/material efficiency and the overall transition toward a circular model in SMEs. Improve water efficiency as a resource in SMEs and promote water reuse. Establish a network of resource auditors • Support to increase the use of different types of renewable energy by SMEs in line with European best practice (solar, wind, hydro, biomass, and cogeneration systems, and so on) Measure 6.2 Promote Environmental Certification among SMEs • Support SMEs to complete the registration process under the EU’s Environmental Management and Audit Scheme (EMAS), as well as certification to ISO 14001 (environmental management), ISO 5001 (energy management) and ISO 9001 (quality management) standards. • Select and support flagship projects for registration under the EMAS in priority sectors for the Bulgarian economy. • Promote the sectoral good practices for environmental management developed by the Joint Research Center (JRC) as the EC’s baseline documents for the implementation of environmental practices in a given sector. • Promote a culture of environmental responsibility among SMEs by building capacity and rewarding businesses with a proven record of environmental responsibility. Measure 6.3 Support SMEs in Specific Sectors (and Value Chains) of Strategic Importance for Bulgaria and the European Union • Support SMEs to better integrate into European value chains in the context of the CE. Implement targeted actions to increase the circularity of individual SMEs or value chains by introducing circular business models such as the following: • Substitution of primary raw materials with secondary raw materials • Transition to product systems and related services • A functional economy (selling the use rather than the product) • Implementation of industrial symbiosis • Substitution of products or packaging by bio-based ones • Introduction of intelligent/circular design for better reuse • Reusability and reparability, material efficiency, increased product life cycle • Manufacturing initiatives • Support SMEs to reduce and substitute the use of plastics in production processes (including plastic packaging) in line with the European Strategy on Plastics in a CE. Support the adaptation of SMEs producing SUPs to the production of bio-based products (to ensure compliance with Directive (EU) 2019/904 on reducing the environmental impact of certain plastic products). • Support SMEs in the bioeconomy sector (including the blue bioeconomy) to access markets and develop bio-based products. • Modernize the regulatory framework for advanced biotechnologies and genetic resources. Measure 6.4 Improve Capacities of SMEs with Regards to the Transition to the CE as an Opportunity for Growth, Investment, and Export • Launch a series of capacity-building programs for SMEs in the country to • Promote CE concepts • Develop new circular business models at regional and local levels; and opportunities for SMEs in the process of transition to a CE • Increase the circularity of certain value chains (with the support of industry organizations, sector associations, and business intermediaries). • Support the effectiveness and efficiency of EPR schemes and their inclusion of waste-intensive sectors (for example, construction) 56 • Support SMEs and start-ups to do the following: - Introduce specific circular business models such as reuse, repair and refurbishment, reverse logistics, remanufacturing, industrial symbiosis, and so on. Support SMEs in the transition from selling products to providing services. Increase the share of separately collected and recycled waste on a sectoral basis, with a specific focus on sectors producing significant amounts of waste (for example, construction and demolition, building renovation). Launch several pilot projects in different sectors; - Improve the sustainability of primary raw materials used and increase the share of secondary raw materials in production processes. Support SMEs to use water efficiently as a resource in production processes, including promoting water reuse and introducing closed loops in enterprises to save water; - Launch a pilot project on industrial symbiosis as one of the circular business models. Measure 6.5 Promotion of Green Products with the EU Ecolabel, the Environmental Technology Verification System and Circular Design This can be done by supporting SMEs to do the following: • Certify products under the EU Ecolabel scheme • Transition to eco-design and circular design • Replace non-renewable products with alternative or bio-based products. 57 Annex F. Proposed Intervention: Enterprises Connected for Industrial Symbiosis Development Objective The implementation of a program on industrial symbiosis (IS) is proposed starting with one pilot region (Burgas- Stara Zagora) and/or Plovdiv. As explained earlier in the report, the program would provide an opportunity for the Bulgarian enterprises to leapfrog to the tested circular business model and work toward a mindset shift looking at waste as a resource. Such a program would fit with the strategic framework of the country, the recently adopted CE strategy and the SME strategy. It would be positively considered by the EC given its strong insistence on actions higher on the waste hierarchy. It will also support the Bulgarian transition to a more resource-efficient economy. Activity Type Advisory/Analytical Expected Results and Outcomes Component Outcome Result Strategic Developed local/regional strategies Increased buy-in from local stakeholders and/or Local Green Deal(s) and better prioritization Policy Removed policy obstacles Companies will not face policy obstacles with end-of-waste Development of a regional pilot Regional project implemented Approach tested at a regional level Mapping of materials’ flows Main material flows identified Companies are more aware of circulating materials Development/purchase of a system Available software support for Precise knowledge of materials which material flow identification could be exchanged Awareness raising and matching Much better-informed industrial Companies understand the benefits of IS events ecosystem and the ways to approach it Support to companies on local level Consulting support available Technical barriers overcome Problem Statement Context and background Environmental problem - industrial waste is not managed properly and is often landfilled in the best case scenario and recycled or dumped at non-sanitary landfills in the worst-case scenario Low resource productivity of Bulgarian industry - companies use more resources than their EU counterparts to reach a similar goal Companies will need to take ownership for achieving low-carbon targets - EU and Bulgarian strategic documents reiterate the need for companies in general and SMEs in particular in assuming their role for addressing climate change and low-carbon targets Gaps to be addressed by the activity (based on analysis) The activity will improve the waste management of companies and will contribute to a more fundamental cultural shift whereby the companies perceive waste and by-products as a resource. Potential impacts/benefits of activity Industrial symbiosis leads to a number of benefits such as waste prevention through reuse of waste and by- products; capturing value of underutilized resources; enhancing collaborative efforts and projects between companies in one region. Industrial symbiosis • Enhances environmental sustainability • Achieves economic benefits • Provides higher awareness for companies about regional material flows and the circular potential 58 • Leads to a mindset shift toward perceiving waste as a resource. Strategic Relevance Industrial symbiosis initiatives are multiplying in the EU because of their increasing relevance to a multitude of EU strategies and in line with the increasing know-how on how industrial symbiosis is to be implemented. Link with national and subnational development objectives (for example, national action plans, strategic documents) Work on the initiative will encourage to build on already existing synergies or get familiar with the concept of industrial symbiosis. The initiative is coherent with the Bulgarian SME Strategy (action on industrial symbiosis included) and with the Bulgarian CE Strategy (action on industrial symbiosis included in the draft version). During the focus group on industrial symbiosis and within the survey, it has also been confirmed that a potential action would be in line with local priorities. Link with EU policies There is a close relationship between IS actions with the EU CEAP, the EU Industrial Strategy, and the EU SME Strategy. The initiative is also in line with waste prevention and recycling targets within the WFD and other sister directives. Currently, an industrial symbiosis network—CircLean—is being established in the EU. Link to green recovery Industrial symbiosis brings multiple benefits associated with better waste management and is thus relevant to any period. However, the COVID-19 crisis has revealed a number of unsustainable production and consumption practices. In this particular case, it is the short life of materials and by-products and the missed opportunities associated with symbiotic practices within the industry. The period of industrial recovery is an excellent opportunity to increase the sustainability of production in different ways including better resource efficiency and industrial symbiosis. Link to climate change The introduction of a national IS program/initiative would lead to a mindset shift among local companies, whereby waste would be perceived as a resource rather than as something to get landfilled/dumped. Industrial symbiosis is associated with increased life of materials within the productive system and with avoided waste landfilled leading to GHG emission reduction proportional to the volume of waste exchanged. There is also a link to initiatives of carbon-free industrial zones. Activity Description What do you propose concretely? The study team proposes the implementation of a program on IS starting with one pilot region (Burgas-Stara Zagora and/or Plovdiv). The program would provide an opportunity for Bulgarian enterprises to leapfrog to the tested circular business model and work toward a mindset shift looking at waste as a resource. Such a program would fit the strategic framework of the country, the CE strategy and the SME strategy. It would be positively considered by the EC given its strong insistence on actions higher on the waste hierarchy. 59 FIGURE 12. COMPONENTS OF AN INITIATIVE ON INDUSTRIAL SYMBIOSIS ‘ENTERPRISES CONNECTED FOR IS’ Territorial/sectors scope Option 1: Structured as a local/regional program in Burgas-Stara Zagora and/or Plovdiv to grow into a national program Option 2: Structured as a national program which starts with one pilot project at the local/regional level and is then expanded into a national program Deliverables Component Deliverable Strategic Industrial symbiosis is a part of different strategic frameworks Policy End-of-waste is removed as an obstacle Development of a regional pilot Structured and implemented pilot project Mapping of material flows A detailed map of material flows available for use and integration Development/purchase of a system Software system for by-product registration (proprietary or open-source) with high-level of protection Awareness raising and matching events Events at local level, materials, and so on. Support to companies on local level Technical support through tailor-made facilitation Timeframe Two years Potential Counterparts/Clients Potential primary client If Option 1 is selected, then the potential client could be the local authority. If Option 2 is selected, then the Ministry of the Economy and Industry and the Ministry of Environment and Water should be the primary clients. Has there been explicit interest expressed from any of the stakeholders? Yes, there was a specific and strong interest expressed by the Burgas Municipality, the Stara Zagora Regional Development Agency and the Trakia Industrial Zone. Any other stakeholders that should be taken into consideration? Yes, the effort is holistic, and all the stakeholders listed below will need to be involved in different components of the initiative. 60 TABLE 11. STAKEHOLDERS AND THEIR ROLE IN AN INDUSTRIAL SYMBIOSIS INITIATIVE Component Ministry of Ministry of Business Local Environment Economy Industrial intermediar NGOs authorities and Water and zones ies and RIEW Industry Strategic ++ ++ X Consultation level Policy End-of- X ++ Consultation level waste Other As needed relevant Mapping of material flows X X X ++ Development of a software system for by-product + X X + + + registration Awareness raising and matching X + + +++ X ++ events Support to companies on local X + X ++ +++ level Piloting ++ X Legend: X lead + degree of relevance and involvement involved 61 Risks and success factors Key risks to the success of the intervention and proposed mitigation measures: Risk Deliverable Lack of strategic vision on the part of the national Work with the two main ministries to align vision government Approaching the initiative as scattered components rather Brand the initiative as a program with separate interlinked than as a systemic initiative components Insufficient collaboration between Ministry of Environment Active upfront collaboration and buy-in from both ministries. and Water and Ministry of Economy and Industry (at national Active buy-in from local stakeholders. level and at local level as a mirror) leading to lack of common local efforts Insufficient knowledge among SMEs of the concept of Raising the awareness of companies of the benefits of industrial symbiosis industrial symbiosis should be integrated as a part of the program Lack of information on material flows and by-products Conduct a project for mapping of material flows available locally Launching of a material flow registration platform is a precondition for the implementation of industrial symbiosis Conduct a project for the development of a platform or - Concerns on behalf of companies with regard to revealing even better - pay a tested proprietary platform information Companies do not know each other and the material flows There is a need for the organization of multiple matching of other companies events between interested parties Companies who ‘meet’ each other and have materials to Within the program, provide the necessary technical support exchange do not implement the transaction needed to take the symbiosis to a successful end Low landfill fees are another obstacle - for political reasons, these fees are kept low and companies do not feel any pressure to look for alternative approaches to landfill Success factors The first and most important condition for the success of the intervention is approaching it as one holistic and systemic intervention and not as individual, unrelated components. The second important factor is the close collaboration between the Ministry of Economy and Industry, the Ministry of Environment and Water, RIEW, local authorities, and business intermediaries. Including industrial zones in the pilot would be key. In addition, there is a need to collaboratively address the risks identified above. 62 BOX 1. FINNISH NATIONAL PROGRAM ON INDUSTRIAL SYMBIOSIS What Practical tool for promoting CE, bioeconomy, and regional development. Provides a systematic way to help companies and other organizations to create partnerships and new business opportunities through more efficient use of raw materials, technology, services. and energy. Aims to produce competitive higher-value products and services. Targets Creating new technology and service business/improving profitability of existing business. Resource wisdom and closing cycles (following waste hierarchy): Virgin material savings; GHG reduction; Landfill diversion; Increase on recycled and reused materials; Hazardous waste reduction; Water savings. Targets Creating new technology and service business/ improving profitability of existing business. Resource wisdom and closing cycles (following waste hierarchy): Virgin material savings; GHG reduction. Institutional setup National Coordinator (Motiva): National coordination, communication, and reporting; Finnish Industrial Symbiosis System development and quality management; Data management (resource database); Support of regional organizers, linking different regions; Development of knowledge transfer network. Regional organizers (practitioners): Activation and engagement of companies; Exchange of information and networking; Synergy identification and facilitation; Co-development and expert cooperation. Stages Stage I: NISP-pilot project (Sitra and Motiva) - testing of working methods and international benchmarking Stage II: Starting and regularizing of FISS: engaging regions and starting of activities; further development of working methods; instructions, training and tools for facilitators; taking SYNERGie® resource database into operation; web-portal; support of facilitators; co-ordination and networking; communication and activation; and reporting and follow-up. Stage III: FISS continues and extends: 10–15 regions engage; >600 companies; further development toward better implementation of CE and regional targets. Stage IV: FISS is an established national operating model: National program; all regions involved; >1000 companies; measurable targets (financial and environmental); new business models. Source: Presentation of Motiva at Industrial Symbiosis workshop in Helsinki (22/05/2019) and http://www.industrialsymbiosis.fi/. 63 BOX 2. BASQUE COUNTRY IS INITIATIVES THROUGH THE “CE DEMONSTRATION PROJECTS” PROGRAM Main objectives of the program Develop new innovative alternatives to landfill Bridge the ‘Valley of Death’ for innovative new Circular Solutions (from technology readiness level (TRL) 5 to 9) Reduce environmental impact taking an integral perspective (Life cycle thinking) Contribute to creating new circular business with relevant impact on turnover and employment Increase collaboration inside and between the different value chains in a regional context, with the aim to increase competitiveness through availability of secondary materials and second life products Improve public-private collaboration by practical experience. Stakeholders Industries of the most relevant value chains (automotive, electric-electronic, construction, metal, plastic, textile and paper), including manufacturers, equipment suppliers and recyclers Environmental Department of the Basque Government, including its public agency Ihobe The Basque Science, Technology and Innovation Network. Impact evaluation Only 25 percent of the projects showing high transferability potential to Basque industry, are geared toward demonstrating specific solutions from one company, with high replication potential. Collaboration of different value chain companies in the projects—a necessary aspect of CE projects—is low in 39 percent of cases and medium in the remaining 61 percent. The relevance of the public sector’s role in the projects is high. Public-private collaboration aimed at creating a market or driving supply is considered a key aspect in 56 percent of projects beyond the limited funding they receive, according to the results of satisfaction surveys for completed projects. Source: European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, Artola, I., Doranova, A., Domenech, T. et al. 2018. Cooperation fostering industrial symbiosis – Market potential, good practice and policy actions – Final report https://data.europa.eu/doi/10.2873/346873. 64 Annex G. Proposed Intervention: Plastic-Free Black Sea Coast and Tourism Initiative Development Objective The objective is to bring together the ecosystem under a common vision for development of plastic-free Black Sea coast and assist in addressing the identified problems related to plastic pollution and marine litter in the Bulgarian coastal territories in a holistic and systemic way. Specifically, the intervention aims to enable local governments, tourism-related businesses, national authorities, and other tourism stakeholders to take concerted action to shift toward circularity. The intervention will aim to contribute to the integration of sustainability principles in coastal tourism which was adversely affected by the COVID-19 crisis. Expected Results and Outcomes Activity Outcome Result Component 1: Support for addressing Analysis of the national regulatory Improved national strategic framework marine litter in the national strategic framework with focus on marine regarding plastic waste and marine litter framework litter and plastic waste Inputs to the development of a national action plan for marine litter Review of institutional responsibilities related to implementation and enforcement of the provisions on plastic pollution prevention and clean-up in the coastal areas Component 2: Support for the Revised EPR system Revised EPR approach stimulating improvement of the existing EPR system waste prevention and more sustainable solutions (for example, move to multiple use + deposit systems) Component 3: Support Black Sea Pilot waste prevention and reuse Improved national and municipal policy municipalities to improve local policies municipal programs frameworks for the regulation of plastic toward stronger emphasis on waste Analysis for putting in place a waste and protection of the environment prevention including plastic waste deposit return system from marine litter prevention and reuse Component 4: Support for greening the An assessment of HORECA sector- Increased awareness of the tourism HORECA sector and reducing the induced plastic pollution sector actors to integrate circularity plastic waste it generates Recommendations for phasing-out principles unnecessary plastic packaging A program for raising awareness and knowledge of how to integrate sustainability in the activities of the HORECA sector ‘Plastic free’ label for the HORECA sector in Bulgaria 65 Activity Summary Problem Statement Context and background А large proportion of marine plastic litter has been found to come from tourism and other tourism-related value chains in coastal areas. Recreational activities, building and construction as well as fishing and food supply in coastal tourism destinations appear as the most probable sources. The two main types of plastic waste connected with tourism are packaging and SUP items. In Europe, 40 percent of plastic is used to produce packaging; the tourism industry generally, including in Bulgaria, is a high consumer of single-use items. As noted earlier in the report, plastic caps/lids drinks, plastic cups and cup lids, plastic/polystyrene pieces/sweet wrappers, small plastic bags and drink bottles ≤ 0.5 liters are among the most abundant type of marine litter in Bulgaria. As part of the monitoring of marine litter in 2017, 70,000 items from 10 beaches were detected. There is a slow decrease to 40,000 items but the figure is still far from the threshold of 20 items on a 100-m section of the beach adopted by the EC. At the same time, uncontrolled littering and plastics pollution are increasingly leading to the negative perception of consumers toward the Black Sea as a tourism destination. These can in turn trigger a decrease in tourism arrivals, and consequent revenue and job losses and contribute to the development of a cheap mass tourism model. The impact of the tourism sector on plastic pollution poses the need for industry stakeholders to act upon the issue of plastic pollution in a collective and coordinated manner across the value chain. It is worth mentioning that tourism is among the sectors which have been included in global initiatives to address plastic waste and pollution such as the New Plastics Economy Global Commitment,66 led by the Ellen MacArthur Foundation in collaboration with United Nations Environment Program. Tackling plastic pollution is at the core of the Global Tourism Plastics Initiative.67 Gaps to be addressed by the activity (based on analysis) This intervention will address several gaps in the issue of plastics and marine litter along the Bulgarian coastline, as follows: • Regulatory gaps related to addressing the marine litter (for example, ‘marine litter’ as a term is not included in the legislation; inland rivers are not monitored for marine litter as this is not a legal obligation, but the majority of plastic pollution is associated with the rivers flowing into the Black Sea) • Insufficient coordination and cooperation among public institutions and governments at national and local levels to address plastic waste pollution at its source and ensure proper marine litter monitoring • Suboptimal functioning of EPR (for example, insufficient/lack of infrastructure for separate waste collection especially in lesser populated areas including some resorts) • Unsustainable practices of the HORECA sector which lead to plastic pollution and littering and in general lack of integration of circularity principles in the tourism sector in Bulgaria • Low level of awareness of tourism businesses, beach concession operators and citizens of plastic pollution and the need to take action. Potential impacts/benefits of activity The initiative responds to acute problems and needs and can serve as a first attempt to unite national and local authorities, businesses, and other organizations behind a common vision to address plastic pollution and marine litter along the Bulgarian Black Sea coast in a coherent, integrated, and participatory manner. 66 https://www.unep.org/resources/report/new-plastics-economy-global-commitment-2020-progress-report. 67 https://www.unwto.org/sustainable-development/global-tourism-plastics-initiative. 66 Strategic Relevance The initiative is in line with a number of European, national, and subnational development objectives, included in the following documents: Link with national and subnational development objectives • National Strategy for Sustainable Tourism Development (2014–2030) mentions the problems of inefficient use of resources (for example, water, energy), as well as the unsustainable waste management practices in the tourism sector • Marine Strategy of the Republic of Bulgaria and Program of Measures addresses marine litter (Descriptor 10 in the strategy) • Waste Management Law of Bulgaria and Bylaws • Environmental Law of Bulgaria • Black Sea Marine Litter Regional Action Plan. Link with EU policies • European Green Deal • European Strategy for Plastics in a CE • The SUP Directive aims to prevent and reduce the impact of certain plastic products on the environment, in particular the aquatic environment, and on human health, to promote CE. • WFD 2008/98/EC. Link to green recovery Bulgaria’s National Recovery and Resilience Plan consists of a total of €6.27 billion in grants, 59 percent of which support climate objectives. The plan includes multiple measures in favor of a more circular and carbon-neutral economy, including €801 million for supporting businesses for the modernization and transition to green, circular and digital-oriented business practices, and support for industrial parks’ infrastructure development Green recovery of the Bulgarian tourism sector especially after the COVID-19 crisis is mentioned in the analysis preceding the Development of a Future Long-term Tourism strategy until 2040. Link to climate change Currently, there are discussions about the development of a long-term tourism strategy till 2040, and as part of the analysis preceding the development of the strategy, it is stated that tourism sector in Bulgaria should be adapted to climate change.68 Integrating the principles of the Green Deal and CE in the tourism sector is also mentioned in the analysis. Activity Description What do you propose concretely? The initiative will target both national authorities and Black Sea municipalities and will include the following components: • Component 1: Support for addressing marine litter in the national strategic framework • Component 2: Support for the improvement of the existing EPR system • Component 3: Support Black Sea municipalities to improve local policies toward stronger emphasis on waste prevention including plastic waste prevention and reuse • Component 4: Support for greening the HORECA sector and reducing the plastic waste it generates. 68 https://www.tourism.government.bg/bg/kategorii/strategicheski-dokumenti/dulgosrochno-razvitie-na-turizma-analiz-i-predlozheniya-koito- da. 67 Component 1: Support national authorities in addressing marine litter in the national strategic framework As per the requirements of The Black Sea Regional Action Plan, Bulgaria intends to develop a national action plan for marine litter. The Plan will include a monitoring framework, identification of sources of pollution, and steps for improving the scope of the measures and their effectiveness. The purpose of this activity is to support the country in this process, and, in particular, to bring the local perspective into the national strategic documents. Second, the activity will aim to support the Bulgarian authorities to incorporate the land-sea link in the legislation as per the EC recommendation for monitoring especially of the river mouths, which is currently missing. Finally, the component will include a review of institutional responsibilities related to implementation and enforcement of the provisions on plastic pollution prevention and clean-up in the coastal areas. Component 2: Support for the improvement of the existing EPR system Support the improvement of the EPR regulatory framework with a focus on stricter responsibilities of recovery companies. As it is now, the dynamics between local authorities and the recovery companies is not sufficient. Currently, small settlements are not included in the system; this serves as an obstacle for separate waste collection in these municipalities. Monitoring mechanisms for EPR systems could be strengthened as well. Roles and responsibilities of producers for managing the post-use packaging collection and recycling of packaging waste will be revisited and rediscussed in the light of longer-term zero-waste/plastic-free Black Sea coast target. Analysis of the role and responsibilities of municipal authorities is also a part of this component. Transition from disposable to reusable/from linear to circular systems in packaging of beverages and food will be discussed as part of EPR. Component 3: Support Black Sea municipalities to improve local policies toward stronger emphasis on waste prevention including plastic waste prevention and reuse Support a pilot municipality (or municipalities) in developing municipal waste prevention and reuse programs, focused on setting ambitious targets (for example, “Zero plastic in coast of city/region X by year YYYY”), encouraging local businesses to offer reusable, durable, and recyclable products; encouraging local shops to use sustainable packaging, sell in bulk, and offer refill packaging, and so on. The program can include ambitious rules that align with the SUP Directive. For example, rules on waste prevention for public events along the Black Sea coast could be introduced and tested first at the festivals. Examples include placing a ban on the use of certain SUP items, enacting closed-loop reuse systems (for example, reusable cups and containers with a deposit at event venues) and ensuring effective waste collection and separation systems are in place. Support the elaboration and deployment of deposit return schemes for PET which could be piloted in some of the coastal municipalities. The deposit system will be essential for achieving the targets set in the SUP Directive (77 percent separate collection for plastic bottles by 2025 - increasing to 90 percent by 2029). Component 4: Greening the HORECA sector and reducing the plastic waste it generates by Carrying out an assessment of HORECA sector-induced plastic pollution and providing recommendations for phasing-out unnecessary plastic packaging and items and taking action to move from single-use to reuse models or reusable alternatives. Developing a program for raising awareness and knowledge of how to integrate sustainability in the activities of HORECA sector. Developing, in cooperation with national and local authorities, sectoral organizations, and experts, ‘plastic free’ label for the HORECA sector in Bulgaria. This needs to be done carefully so that the substitutes used are not necessarily bioplastics. The correct approach is the return of multiple-use containers, and so on in compliance with the sanitary requirements. Territorial/sectors scope Black Sea municipalities, tourism sector 68 Deliverables Component 1: Support for addressing marine litter in the national strategic framework Review and analysis of the national regulatory and institutional framework with focus on marine litter and plastic waste; contributions to the development of a national action plan for marine litter. Component 2: Support improvement of the existing EPR system Analysis of the EPR regulatory framework and recommendation for its improvement with focus on stricter responsibilities of recovery companies. Component 3: Support Black Sea municipalities to improve local policies toward stronger emphasis on waste prevention including plastic waste prevention and reuse Pilot waste prevention and reuse municipal program addressing plastic waste and marine litter. Recommendations on how to put in place a deposit return system in Bulgaria and its main features, management, and so on. Component 4: Support for greening the HORECA sector and reducing the plastic waste it generates An assessment of HORECA sector-induced plastic pollution; recommendations for phasing-out unnecessary plastic packaging and items; and taking action to move from single-use to reuse models or reusable alternatives. A program for raising awareness and knowledge of how to integrate sustainability in the activities of HORECA sector. ‘Plastic-free’ label/logo for the HORECA sector in Bulgaria. Timeframe Three years. Potential Counterparts/Clients Responsible institution Activity Ministry of Environment and Water Component 1: Support for addressing marine litter in the Black Sea Basin Directorate national strategic framework Ministry of Environment and Water Component 2: Support for the improvement of the existing EPR system Black Sea municipalities Component 3: Support Black Sea municipalities to improve local policies toward stronger emphasis on waste prevention including plastic waste prevention and reuse Ministry of Tourism (department dealing with sustainable Component 4: Support for greening the HORECA sector and tourism and coastal tourism) reducing the plastic waste it generates Ministry of Environment and Water Has there been explicit interest expressed from any of the stakeholders? The proposed actions are based on the identified problems, as well as insights and ideas shared by the stakeholders consulted during the assignment via the focus group meeting and individual interviews with relevant stakeholders. Any other stakeholders that should be taken into consideration? Tourism chambers, waste recovery companies, the Association of Black Sea municipalities. 69 Risks and success factors Key risks to the success of the intervention Insufficient cooperation between relevant institutions is the biggest risk by far which is also linked to the lack of culture/willingness to solve a problem in a holistic manner in cooperation with different actors. Lack of interest in the initiative on the part of the Black Sea municipalities and national authorities. Different capacities in Black Sea municipalities may limit the implementation of the initiative to bigger municipalities which have more experience and stronger capacity in place. Low awareness of the HORECA sector about plastic pollution and marine litter stemming from tourism and unwillingness to take action. Success factors Political will to modify the national legal policy frameworks for better regulation of plastic and protection of the environment from marine litter in line with the EU directives. Capacity at local and national levels to adequately address the challenges associated with marine litter and plastic waste. Effective cooperation between national and local authorities, local stakeholders, and tourism professionals. Support of tourism sector actors for adopting more environmentally friendly practices specifically focused on reducing plastic waste. Availability of adequate financing to implement the measures. 70 Annex H. Proposed Intervention: Scaling up Reuse and Recycling of CDW into New Virtuous Cycles Development Objective The ultimate strategic objective of the proposed intervention is to enable Bulgaria to reach the targets in terms of CDW management and recovery as well as to comply with the hierarchy of waste management in accordance with European and national legislation.69 Expected Results and Outcomes Provide visibility and understanding of recurrent CDW flows by characterizing, quantifying, and locating them on a municipality scale. Implement effective methods for CDW management on a construction site scale and municipality scale for their effective reuse, recycling, and other recovery. Introduce and generalize tracking and tracing methods of CDW to establish reliable statistical data on CDW management and recovery achievements in Bulgaria. Activity Summary Context and background The construction sector is responsible for over one third of the EU’s total waste generation, with CDW being the largest waste stream in the EU. This waste stream contains materials and products with the potential to be used over several life cycles, and partially replace new products and materials. Bulgaria, as an EU member state, is required to reach the targets related to CDW management, but the current situation shows a great degree of uncertainty about the application of CDW management in Bulgaria. Despite regulatory pressure, there is no information available on the implementation of the main indicators set for achieving the targets.70 This can be established by the lack of vision and strategies after 2020, lack of detailed and summarized statistics on CDW, lack of monitoring mechanisms and reports to national authorities, and so on. Moreover, the data on CDW that Bulgaria submits to Eurostat are not reliable,71 as the misunderstanding of CDW management policies is influenced by national economic, social, and technological factors.72 Gaps to be addressed by the activity • Lack of strategic vision on CDW management to achieve the targets • Lack of application of the waste hierarchy • Lack of waste identification on a territorial scale • Lack of data on the implementation of Construction Site Waste Management Plans • Lack of determination of the resources on the construction site • Lack of effective coordination, planning, and organization of the activities on the construction/demolition site • Lack of operational methods and procedures for the activities on site • Lack of proper procedures for monitoring and communication on the construction/demolition site • Lack of appropriate training necessary for all operators. 69 The set target for preparing for reuse, recycling, and other material recovery of non-hazardous construction and demolition waste is a minimum of 70 percent by weight. Prevention is to be achieved through the reuse, then recycling, followed by other recovery, with disposal as last resort. The European legislation referred to here is the Directive 2008/98/EC on waste (WFD) from 2008, amended by Directive 2018/851 in 2018; Bulgarian legislation referred to here is the Ordinance on Construction and Demolition Waste Management and Use of Recycled Building Materials, introduced in Bulgaria in 2012. 70 Stoyanov et al. 2020 71 Ibid. 72 Saez and. Osmani 2019 71 Potential impacts/benefits of activity CE, applied to construction and demolition works, has an impact on three levels of activity: CDW flows at the municipal level, connecting construction and demolition sites (sources of waste and outlets for secondary products), to local industrial and economic actors (reuse and repair networks, recycling industries). In addition to prevention and better CDW management, reuse and recycling activities allow the creation of jobs and the development of economic opportunities. FIGURE 13. CDW MANAGEMENT - THREE LEVELS OF ACTIVITY ON A TERRITORIAL SCALE Source: Original elaboration for this publication. To achieve the legal targets, a strategic vision on CDW management, involving these three dimensions in a common synergy needs to be elaborated. This proposal considers the three levels of activity and offers a holistic approach for systemic actions. It mobilizes players at local, regional, and national levels and stakeholders of both construction and industry. 72 Strategic Relevance Link with national and subnational development objectives The proposed approach is in line with another dynamic of scale, the energy efficiency upgrading of existing buildings. These renovation works in Bulgaria have already been under way for a few years now, as a result of dedicated funding. The National Recovery and Resilience Plan of the Republic of Bulgaria stipulates that “efforts to increase energy efficiency are necessary … given the extremely adverse energy performance of the building stock in the country with prevailing energy consumption classes E, F and G. Efforts to renovate the building stock will be essential to support economic recovery by creating jobs in the construction sector, energy savings, healthier living conditions and reducing energy poverty." 73 The energy efficiency renovation involves replacing windows, enhancing insulation, upgrading obsolete technical equipment with low-energy alternatives, and so on. There is no specific data available on construction and demolition waste (CDW) generated through energy efficiency upgrading works in Bulgaria — neither on quantities and types of waste, nor on its management and recovery rate. The findings show that in general most CDW goes to landfills, despite legal obligations to follow the priority order in waste management, and high reuse and recycle potential for some elements. 74 Only metals are processed by the recycling industry. In view of the numerous energy efficiency renovation works planned for public buildings and housing, the study team proposes coupling this process with CE measures in CDW management. These renovation projects offer a possibility to launch pilot projects — a field of study and innovation, enabling the link between the different levels and stakeholders, and allowing for targeting several recurrent CDW flows generated by the renovation works. Link with EU policies The WFD75 requires member states to take the necessary measures designed to achieve the following target by 2020: “the preparing for reuse, recycling and other material recovery of non-hazardous construction and demolition waste shall be increased to a minimum of 70 percent by weight.” The directive defines a priority order in waste management, required by the WFD, in relation to the generated CDW. Prevention is the favored strategy to reduce CDW, achieved through the reuse76 of products derived from demolition and/or the extension of the lifespan of products. Recycling of CDW is next in line in the hierarchy of waste management, followed by other recovery. To achieve the target rates of recycling and other recovery of CDW, regulation requires taking measures to establish selective removal of materials in demolition works, and of sorting systems for CDW, at least for wood, mineral fractions (concrete, bricks, tiles and ceramics, stones), metal, glass, plastic and plaster. The directive also requires the member states to take measures to promote preparation for reuse77 activities, by encouraging the establishment of networks for preparation for reuse and repair, by facilitating their access to CDW, and by promoting the use of economic instruments, procurement criteria, quantitative objectives or other measures. The initiative is in line with the EU 2020 Construction Strategy that aims to improve resource efficiency, environmental performance, and business opportunities in the construction sector. 73 Natsonalen plan z vzstanovyvane I ustoichivost https://www.nextgeneration.bg/14. 74 Dolchinkov, N. T. 2019. “State of Recycling of Waste in Bulgaria.” International Scientific Journal Science. Business. Society Year IV (4): 131–134 https://stumejournals.com/journals/sbs/2019/4/131.full.pdf. 75 Directive 2008/98/EC on waste (WFD) from 2008, amended by Directive 2018/851 in 2018. 76 Reuse is defined by regulation as any operation by which products or components that are not waste are used again for the same purpose for which they were conceived. 77 According to the WFD, the preparing for reuse activities consists of checking, cleaning, or repairing recovery operations, by which products or components of products can be reused without any other pre-processing. 73 Link to green recovery The initiative is especially relevant to green recovery as a huge share of the Recovery and Resilience Fund will be directed to energy efficiency renovation of buildings. One of the main criticisms of the previous drafts of the Recovery and Resilience Plan was the lack of CE measures. Currently, the interim government is making attempts to improve the previous version by adding more circular solutions. This initiative is an opportunity to make this activity more circular. Link to climate change Construction requires vast amounts of resources, and accounts for about 50 percent of all extracted materials. Emissions from material extraction, manufacturing of construction products, construction and renovation of buildings are estimated at 5–12 percent of total national GHG emissions.78 Greater material efficiency, effective CDW management and recovery could save up to 80 percent of those emissions.79 Activity Description The proposed intervention is structured in three actions, corresponding to the three levels of CE development in CWD management. The aim is to integrate innovative strategies and operating methods into current practices, and to provide actors with a better understanding and expertise on the issues at stake. Component 1: Study the CDW Component 2: Set up pilot projects flows on municipal level - provide Component 3: Promote and visibility of CDW and secondary for the Implementation of innovative construction site support local reuse networks, resources flows available at a industrial and economic players activities territorial level Design strategies for efficient Study the existing reuse and extraction of secondary recycling activities and the resources from demolition opportunities for business development to handle new operations flows Design strategies for Promote new reuse integration of reused elements and recycled activities, by encouraging the establishment of reuse and materials in construction and repair networks renovation projects Component 1: Study the CDW flows at a municipal level to provide visibility of CDW and secondary resource flows available at a territorial level One of the challenges for CE-based CDW management is to make visible the secondary resources available in a given territory, so that the local reuse network and recycling stakeholders can take charge of it. Studying secondary resource/CDW flows allows for identification of recurrent types of secondary resources and CDW, and to design replicable strategies in relation to these elements. 78 https://www.boverket.se/sv/byggande/hallbart-byggande-och-forvaltning/miljoindikatorer---aktuell-status/vaxthusgaser/. 79 IRP, Hertwich, E., Lifset, R., Pauliuk, S., Heeren, N. 2020. Resource Efficiency and Climate Change: Material Efficiency Strategies for a Low-Carbon Future. Nairobi, Kenya: United Nations Environment Programme https://www.unep.org/resources/report/resource-efficiency- and-climate-change-material-efficiency-strategies-low-carbon. 74 The proposed intervention will start with a large-scale study of the renovation projects currently planned on the territory of the municipality, including location and typology of intended renovation sites, and estimate of types and quantities of elements to be replaced. Component 2: Set up pilot projects for the Implementation of innovative construction site activities The proposed intervention calls for setting up one more pilot project for upgrading the energy efficiency of existing buildings, involving dismantling and demolition works for renovation. Municipalities and projects interested in getting involved and investing in the innovation process will be invited. The purpose of these pilot projects is experimentation and setting up of management and operating methods. They will also enable training of the stakeholders and operators involved in the projects and construction site activities. These pilot projects will act as the source and the outlet for reused and recycled products and materials. They will allow for establishment of replicable methods and procedures to be tested, then scaled up, and gradually disseminated in current practices. The following actions will be tested and implemented: • Design strategies for efficient extraction of secondary resources from demolition operations • Implement auditing before demolition activities, for identification and study of potential secondary resources on the construction site • Elaborate different management approaches and operational methods and procedures to CDW, based on the knowledge of material flows • Expand Construction Site Waste Management Plans, including description of specific management decisions • Develop operational methods and procedures for selective demolition and dismantling works, source separation and waste logistics • Design effective coordination, planning and organization of the activities • Develop transparency, tracking, and tracing. • Design strategies for implementation of reused and recycled products and materials into construction/renovation projects: • Develop design processes that incorporate reused elements • Develop designers’ expertise on recycled construction materials • Develop operational methods and procedures for preparing for reuse of products and materials on the construction/renovation site. Component 3: Promote and support local reuse networks, industrial and economic players In a CE process, the CDW flows out of the construction/demolition sites and gets picked up by reuse and recycle stakeholders. This report proposes measures to promote preparing for reuse and recycling activities by the established actors, and to encourage the development of new activities and businesses related to reuse and recycling. The aim is to encourage the establishment of preparing for reuse and repair networks, by facilitating their access to CDW, and by promoting the use of economic instruments, procurement criteria, quantitative objectives, or other measures. The following actions will be carried out: • Study the existing reuse and recycling activities at a municipal and larger scale, and their potential growth for handling new flows • Within the framework of the pilot projects - identification of established players to set up experimental operations of preparing for reuse or recycling • Study of stakeholders and operators’ capacity and requirements for handling certain CDW flows • Building a connection between established players and construction/demolition sites (partnerships and collaborations); • Provision of funding, training, and other support for stakeholders and operators involved. 75 • Promote new reuse activities, and the establishment of reuse and repair networks: create a favorable ground to encourage the development of new activities and businesses related to reuse and recycling - provision of funding, incubation, training and other support. Territorial/sectors scope The intervention is directed at three levels of activity: • CDW flows at a municipality level • Industrial and economic actors (reuse and repair networks, recycling industries) à at a municipality level • CDW management à at construction and demolition sites. Deliverables Deliverables related to the analysis at municipal level: Report on mapping and data on CDW flows - characterization of flows, quantification and geolocation by typology • Report on mapping and data on planned renovation sites • Report on mapping and data on potential stakeholders Tools for the application of these analyses on other territories. Deliverables related to each pilot project: • Report on resource analysis on renovation site - quantification and characterization of materials and products to be dismantled, based on their potential for reuse, recycling, or other recovery • Report on recommendations for operating methods and procedures for the selective removal of materials in demolition works, and of sorting systems for CDW at least for wood, mineral fractions (concrete, bricks, tiles, and ceramics, stones), metal, glass, plastic and plaster • End of operation report with tracking and tracing of CDW flows, results of operations in relation to the targets, analysis of actions, and recommendations for improvement. • End-of-intervention deliverables: • Final report of evaluation of actions implemented in relation to the targets - both at municipal and renovation site scales • Generic tools to be applied at both scales for the generalization of practices • Good practice guide for raising awareness and training of stakeholders and operators involved. Timeframe The whole process is planned to be completed over a three-year period. • A first stage of six months consists of studies on a municipality scale: CDW flows, expected renovation sites, and stakeholder ecosystem for the identification of pilot projects and intervention participants, and first drafts of the strategy to be implemented. • The second stage, lasting two years - the operational phase of experimentation and implementation of management and operating methods, between renovation sites and local reuse networks, industrial and economic players. • The final stage, lasting six months, to draw conclusions, assess the results of experiments, and develop generic and replicable strategies. 76 Potential Counterparts/Clients Potential primary client: Ministry of Regional Development and Public Works, Local authority. Interest was expressed at the focus group on industrial symbiosis but there was no time to explore this interest further. Other stakeholders to be taken into consideration: Construction/renovation project owners (public and private), demolition and construction contractors, local industrial stakeholders and reuse networks. Risks and Success Factors Key risks to the success of the intervention Lack of interest in the intervention on the part of the stakeholders Lack of understanding of the challenges and the need to improve practices and behavior. Success factors Adequate financing Stakeholders willing to participate and collaborate, for an effective cooperation between local authority, local stakeholders, and construction and demolition professionals Awareness and adequate training for stakeholders and operators involved for the long-term implementation of the new methods. Budget Estimate The intervention budget will depend on the number of municipalities wishing to take part in the intervention, on the number of pilot projects per municipality, and on the stakeholders willing to get involved. Analysis at the municipal level for each municipality: €16,000 For each pilot project: €18,000 For final reports and generic tools: €14,000. 77 Examples of CDW elements integrated into reuse and recycling dynamics Recurrent waste flows generated by energy efficiency renovations Renovation Taken in Materials Operations New outlet site activities charge by Preparing for reuse: New use for Selective Cast-iron radiators Cast iron Reuse network cleaning and the same removal reconditioning purpose Wood Preparing for reuse: New design and products with Glass Reuse network manufacturing of new Metal new products functions Wooden frame Selective windows dismantling Recycling New Glass Recycling industry products Recycling New Metal Recycling industry products Preparing for reuse: New use for Wood Reuse network cleaning and the same reconditioning purpose Selective Wooden doors removal Preparing for reuse: New design and products with Metal Reuse network manufacturing of new new products functions 78 Examples of economic activities based on reused materials Cleaning and reconditioning of cast-iron radiators, Radiastyl, France Series of furniture in reused wooden doors, by Collectif Restore, France Furniture and outdoor furnishings in wooden window frames, Atelier R-ARE, France 79 Annex I. Proposed Intervention: Establishing Municipal Reuse and Repair Centers Waste prevention is the most efficient way to improve resource efficiency and reduce the environmental impact of waste. The WFD underlines the importance of appropriate measures to prevent waste generation and encourages the increase of the lifespan of products and the promotion of reuse including through the establishment and support of reuse and repair networks, such as those run by social economy enterprises. The development of reuse and preparation for reuse centers also leads to the creation of local green jobs and enables training people who are distanced from the labor market such as long-term unemployed, low-skilled workers, persons with disabilities, former prisoners, and people who have struggled with addiction. Preparing for reuse of just 1 percent of municipal waste generated in Europe could help support 200,000 local green and inclusive jobs. Despite the efforts at the European and national levels thus far, the amount of waste generated is not going down. Annual waste generation from all economic activities in the EU amounts to 2.5 billion tons, or 5 tons per capita per year, and each citizen produces on average nearly half a ton of municipal waste. The decoupling of waste generation from economic growth will require considerable effort across the whole value chain and in every home. Development Objectives • Strategic vision on municipal waste management to achieve the recycling targets • Effective coordination, planning, and organization of the activities on reuse and preparing for reuse, and recycling • Appropriate training for all employees and managerial staff • Increase educational function spreading awareness around for environmental issues • Social integration and jobs creation • Reuse and repair centers turned out to be a highly relevant aspect of waste prevention as they support cities in both improving bulky waste management and in enhancing their transition toward a CE and they can present an opportunity to exploit new secondary resources, and at the same time reduce the negative environmental impact of lot of lot of material wastes • Reuse and recycling operations offer opportunities for job creation and for new dynamics of industrial symbiosis and CE development • Implementation of such projects will raise awareness of the citizens for the value of the resources and their responsibility for the environment, society, economy. Activity type Advisory and Investment Financing. Excepted Results and Outcomes At least 15 municipalities to be trained and funded for establishing Reuse and Repair Centers as social enterprises, to include five larger municipalities, five average-sized municipalities, and five smaller municipalities. They will be the pilot projects that will demonstrate appropriate measures, tactics, and strategies for implementation of circular business models and sustainable practices. 80 Activity summary CE, applied to bulky wastes, waste from electronic and electric equipment, other type of wastes that hold valuable materials, has an impact on three levels of activity: municipal and small industrial waste flows at a territorial level, connecting to local industrial and economic actors (reuse and repair networks, recycling industries), and social actions of all citizens in the municipalities, that will establish similar centers or projects. To achieve the legal targets, it is necessary to elaborate a strategic vision on municipal waste management, involving these three dimensions in a common synergy. Our proposal offers a holistic approach for systemic actions. It mobilizes players at local, regional, and national levels and stakeholders of both local authorities and industry. Problem Statement Context and background Despite the introduced EPR schemes in Bulgaria, a lot of electric and electronic waste is going to landfills. Textile, furniture, construction wastes also might be used in some production or recycling processes, instead of being disposed. Large quantities of paper, glass, and plastics can easily be recycled. On the other hand, the leakage from hazardous materials, loss of valuable resources, lack of space in landfills are problems that are forcing authorities to act in the direction for reducing landfilling, increasing resource efficiency, and implementing circular economic models. This also will provide a lot of job opportunities for low-skilled and disadvantaged people. The municipalities do not have experience in developing such social enterprises. They usually need financing for infrastructure renovation and development, training of personnel, and help in establishing symbiosis between businesses at regional and national levels. They also will need consultancy support for implementing taxation with reverse value-added tax (VAT), for networking and supporting measures. Potential impacts/benefits of activity—high recycling rates, less waste, jobs created, awareness raising on environmental issues. Strategic Relevance • Legal pressure: WFD of 2008, amended by Directive 2018/851 in 2018 • Application of the waste hierarchy and strategic goals for CE implementation • CE measures are part of the green recovery and climate change objectives Activity Description What do you propose concretely? Establishing pilot projects in several municipalities—ranging from smaller municipalities to average ones to larger ones, throughout Bulgaria. The municipalities should be provided with expert consultancy teams who will develop concrete proposals for each municipality, provide financial support for investment in infrastructure, and assure appropriate training for all stakeholders involved in the project. Timeframe Such a project could be implemented for 3–5 years. Potential counterparts/clients Municipalities, SMEs, NGOs. Risks and Success Factors If the business plans for a concrete center are not well justified, it may lead to unsustainable projects and the municipality should subsidize the activities in the future. It is also important that local businesses are involved in the project and have a crucial role in its success. 81 Budget Estimate The project budget will depend on the number of pilots and availability of appropriate infrastructure. For one center, the approximate budget might be between €150,000–400,000. Example The Rediscovery Center is the national center for the CE in Ireland—A creative movement connecting people, ideas, and resources to support greener low-carbon living. The national center for the CE brings together the skills and expertise of artists, scientists, designers, and craftspeople united in a common purpose of sustainability. Located in a bespoke demonstration eco-facility, it supports four reuse social enterprises; Rediscover Furniture, Rediscover Fashion, Rediscover Paint, and Rediscover Cycling. These businesses use unwanted materials for new product development and design demonstrating effective resource efficiency, reuse, and low carbon living. The Rediscovery Center is also home to a unique Eco Store located on the first floor. The Eco Store sells sustainably made products from over 20 independent Irish suppliers and from its own reuse social enterprises. 82 Annex J: Examples of Good Horizontal Practices Below are two good practice examples of a CE strategy at the city level and a CE platform (Boxes 3 and 4). These are examples for the two horizontal measures proposed in Chapter 7 of the report. BOX 3. STRATEGY FOR CE TRANSITION, MARIBOR, SLOVENIA Purpose Stimulate cross-sectoral cooperation in handling, processing, reuse and development of resources, which deals with CE in Maribor in seven selected sectors (that is, pillars or circles). Manage waste without a new landfill and without an incinerator through maximizing reuse. Reduce the use of natural resources; increase the use of renewable sources, energy, and water; promote quality use of land; develop a cooperative economy. Institutional setup Implemented through the WCycle project and the WCycle Institute. Sectors and institutions involved Waste, Construction, Energy, Mobility, Water, Spatial Planning, Collaborative economy. Principles Based on the operation of enterprises that are predominantly publicly owned. Close cooperation between public companies, citizens, industry and local self-government which can lead to a successful interconnected system that optimizes resources and results. Companies share information and work together to achieve the highest possible rate of reuse of waste, excess heat, and wastewater as new sources, while respecting the quality of land use, the development of sustainable urban mobility and a cooperative economy. Based on wide stakeholder approach: working group, participatory local workshops. Links with the Sustainable Development Goals (SDGs). Benefits Emergence of new business opportunities for the municipality, the people and the economy. Creation of high-quality, predominantly green jobs, new added value, and a new economic boost. Additional activities Circular planning and development of resource management policies City agenda for CE Establishment of a resource management center in the city of Maribor Requirements for the use of secondary resources Circular procurement Sustainable use of land Sustainable food production Circular knowledge management Funding for the CE Source: https://ec.europa.eu/futurium/en/system/files/ged/2018.10.23_maribors_strategy_on_circular_economy.pdf. 83 BOX 4. “BE CIRCULAR BE.BRUSSELS” PLATFORM, BRUSSELS About “be circular be.brussels” is a platform developed by the Brussels Municipality within the Regional Program for CE 2016– 2020 (Programme régional bruxellois en économie circulaire, PREC). The website is an information and awareness-raising platform which is a part of PREC communication tools. It is targeted both at businesses and citizens. About the Regional Program for CE The PREC has three general objectives: • Transform environmental challenges into economic opportunities. • Relocate the economy to Brussels to produce locally, when possible, reduce travel, optimize land use, and create added value for the people of Brussels. • Contribute to job creation. PREC contains 111 measures split in four strategic types of measures: horizontal, sectoral, territorial, and governance. PREC is governed by three ministries and four regional administrative entities. The latter include: the Impulse — the Brussels Enterprise Agency; Brussels Environment - the Brussels Administration for the Environment and Energy; Agence Bruxelles-Propreté — the Brussels Agency for cleaning, collection, and treatment of household waste; Innoviris — Brussels Administration for the promotion and support of innovation. Functionalities The platform includes several modules: Circular Business Models in everyday life such as eco-design, GPP, extension of product life, upcycling, sharing economy, and so on. These are divided by sectors (construction, resource and waste, logistics, and trade) and include funding opportunities. The tools also include training opportunities, calls for projects, legal framework, innovation, green job opportunities, and social economy opportunities. The platform also publishes recent reports on CE. Source: https://www.circulareconomy.brussels/homepage/. 84