Bulgaria Enforces New Food Law

On 9 June 2020 Bulgaria enforced the new Bulgarian Food Law (Food Law). The law aligns Bulgarian legislation with European Union food requirements and introduces several public registers related to the manufacturing and distribution of food. The Food Law creates new food packaging, labeling and advertising restrictions and bans.

Verisk 3E Review

The newly enforced Food Law (D.V. 52/2020) aligns with the following European legislation:

• Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs
• Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin
• Regulation (EC) No 1935/2004 of the European Parliament and of the Council of 27 October 2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC, etc.

The law regulates:

• General requirements for foods that are placed on the market and requirements for business operators in the food sector
• Procedures for registration or approval of food production and food trade establishments
• Conditions and procedures for placing special-purpose foods and food additives on the market for the first time
• Conditions for, and the order for carrying out, activities on food banking and food donations

The primary at home production, preparation and storage of food, wine and any type of spirits for personal consumption are explicitly excluded from the scope of the Food Law.

The Bulgarian Food Safety Agency maintains on its website a national public register of business operators, sites for production, processing and/or distribution of food and food supplements and foods intended for use to support intense physical activity.

The Ministry of Health maintains on its website public registers of:

• Business operators and the sites for the production of bottled natural mineral, spring and table waters
• Foods placed on the market under Art. 76 of the act
• Persons performing the activity "food processing with ionizing radiation"

For the first time, the requirements for distance food trade are regulated. Registration of vehicles for the transport of food of animal origin and of food of non-animal origin, such as flour, bread, bakery and confectionery products is introduced. The registration will be certified with a sticker placed on the vehicle.

Business operators who produce, process and trade food will be required to offer food labeled in accordance with the new European requirements. Two major advertising bans prohibit:

• Additional labeling of a labeled product with information other than the original or in a way that obscures even part of the original labeling
• The advertising of genetically modified foods and on foods for which there are statutory restrictions on use by children, through advertisements or commercial messages aimed at children, in which children participate or that present children consuming these foods.

The new Bulgarian Food Law completely replaces the previous 1999 Food Act.

Verisk 3E Analysis

All stakeholders involved with the manufacture, import and distribution of food should comply with the requirements set by the Bulgarian Food Law which are enforced as of 6 June 2020.