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While key Bulgarian NGO networks such as BlueLink have fostered the use of conventional and innovative information and communications technologies (ICTs) in the work of environmentalists for some time, discussions on electronic waste (ewaste) and ICTs and climate change are just budding in Bulgarian society.

Ewaste management is nominally dealt with by national legislation, applying the European Union WEEE [Waste Electrical and Electronic Equipment, or ewaste] Directive,1 but meets many implementation problems. Moreover, ICT take-up is rarely in focus in climate change and ewaste debates in Bulgaria. ICTs are mainly viewed as a tool for implementing civil society actions for positive change and not as energy-consuming and polluting technology.

However, businesses stress the importance of technology and have actively identified themselves as responsible, climate-conscious and environmentally friendly by minimising their electricity consumption and using low-energy ICTs – which also saves money. As a result, the market for “green” technologies has increased. Additionally, due to repeated warnings from the European Commission on inefficient waste management in Bulgaria, ewaste policy implementation has also become topical for both the government and the businesses licensed to recycle ewaste. Ewaste schemes have been introduced on the market through trade-in offers that help ewaste management companies keep their quotas up, and also boost sales through more affordable prices on new equipment for the mass consumer.

Policy and legislative context

Since 2008, ICTs in Bulgaria have mainly been associated with the increasing social role of new media (blogs, online media, etc.), and public alarm has been provoked by persistent legislative and policy pressure to infringe on privacy in online communications. Given this background, 2009 and 2010 have been marked by a new government that has not changed the inherited negative processes. It has not attempted to prevent the continuing year-long non-transparent monopolisation in the sphere of traditional and electronic media: 2009 was marked by the termination of electronic media models oriented towards public debate (e.g. RE:TV 2 and Radio France International-Bulgaria). 3 While the freedom of both online and traditional media are pointed out as problematic by international 4 and national5 observers – in terms of self-censorship and monopolies – internet activists and bloggers provide an alternative. After almost two years of lobbying for changes to the Law for Electronic Communications, new regulations establishing government access to personal online and mobile communications have continued in the direction of the previous government – despite the alternative the new government had promised before the 2009 elections.

The positive effects of the continuing political mishaps in this sphere are the improved capacity of civil society to organise a strong public response and dialogue with various opposition parties in order to prevent drastic legislative changes (e.g. the public protests and information campaign in December 2009 to January 2010 6 against the proposed amendments to the Law for Electronic Communications). The civil protests have been successful in preventing police being granted direct access to traffic data, but have not been able to prevent adding the category “computer crime” to the one of “serious crime” which gives the right to the court to grant investigators access to traffic data. 7 The December/January protest coalition was chaired by a newly founded political party rooted in re-emerging green activism, “The Greens”, supported by key figures of the Bulgarian blogosphere. This signalled the important link between environmental causes and ICT usage in Bulgaria.

Equally relevant policy developments are the egovernment ICT tools that the government started to apply in line with EU ICT policies. However, egovernance in Bulgaria is mostly aimed at facilitating communication between government and citizens, and the green ICT aspect is overlooked. In early 2010, an integrated egovernment platform 8 was introduced by the Bulgarian Ministry of Transport, Information Technology and Communications (MTITC). Another official effort – in line with EU policies – is the EU-funded Operative Programme for Administrative Capacity, which prioritises egovernance projects and eservices for citizens and businesses. 9

The application of the EU WEEE Directive

The EU directive on ewaste in Bulgaria is widely felt to exist on paper only. 10 The WEEE Directive is intended to both reduce the amount of electrical and electronic equipment being produced and to encourage everyone to reuse, recycle and recover it. The directive stipulates that businesses either do this themselves or delegate the task of recycling any ewaste produced to joint organisations (so called “collective bodies”). In Bulgaria, it is the national administration that oversees the issue, represented by a state enterprise called Environment Protection Action Management Enterprise (PUDOOS),11 which has traditionally been tasked with administrating green policy projects. This enterprise is the ultimate body responsible for the activities to do with the EU WEEE Directive. PUDOOS annually reports at national level on the product taxes received for ewaste and the volumes of ewaste treated, as well as on the collecting and recycling activities which PUDOOS finances.

Article 17 (3) of the national Act on the Utilisation of WEEE12 stipulates that a producer must pay a product tax to PUDOOS for its ewaste. In doing so it is exempt from any further responsibility. According to the Bulgarian Association of Electrotechnics and Electronics (BASEL), the tax does not go to the state budget but to an account held by the Ministry of the Environment and Water (MOSV). However, BASEL complains that MOSV does not explain how the product tax is calculated, and suspects that the ministry spends the ewaste product tax on tasks not related to ewaste.

The EU WEEE Directive offers only two possible ways for ewaste management: either the producer company collects its ewaste, or a collective body is created by different companies in order to ensure that the necessary ewaste management activities are carried out. However, in Bulgaria, the companies certified by MOSV for ewaste management are not actually formed as collective bodies on behalf of producers. Another basic issue is that no clear actions have been set for ewaste management.

According to the directive, producers have the obligation to accept equipment when a customer wants to send it back. They need to organise this via contracts with distributors. Producers are also obliged by the directive to finance the collection and recycling of their products. Neither of these actions are now required for Bulgarian businesses.

The extent to which product taxes collected are not being spent on ewaste recycling initiatives is suggested by the fact that in the whole of Bulgaria, there is only one ewaste recycling facility: Nadin, built in 2009 and not fully operational yet. Regarding the treatment of hazardous components in ewaste, Bulgaria mostly exports the components to other EU countries. 13 So we can conclude that no real actions with regard to ewaste are taking place in Bulgaria and regulations only nominally implement the EU WEEE Directive.

However, over the last year licensed recycling companies have significantly grown in number, which gives hope that competition will develop and real services will be offered in the field of ewaste management.

ICTs for environmental causes

Over the past year, government institutions have supported pilot initiatives that use ICTs in environmental protection, in line with environmental policy.14 However, state support is usually inefficient. It supports civil society projects in its speeches but lacks the budget for concrete action. That is why institutions only agree with but do not react to civil society efforts, such as introducing ICT applications for the environment.

An example of a very successful initiative is Spasi gorata (“Save the Forest” in Bulgarian), 15 which has been initiated by BlueLink and supported by leading environmental NGOs in Bulgaria and the Executive Forestry Agency of the Bulgarian government. 16 Spasi gorata is an online platform for posting citizens’ alerts about suspected illegal logging activities. 17 Illegal logging is high on the public agenda and is an issue raised in the debate over the new Law of Forests. The online posting of illegal logging alerts has encouraged civil society’s monitoring of forestry management, and has had a significant awareness and prevention effect in some key forest areas, such as Samokov and Velingrad. However, Spasi gorata is not regularly utilised by the Executive Forestry Agency for control and penalties on illegal logging.

The Spasi gorata initiative combines traditional and innovative interactive tools requiring online actions that eventually facilitate sustainable participation in the real, “offline” world. It has proven to be relevant to Bulgarian civil society more generally, and similar initiatives have been started elsewhere in the environmental sector.

The environmental NGO coalition “For Nature” maintains a highly interactive website 18 and is testing an online ICT platform for volunteer task management. The organisation Veloevolution, which is concerned with promoting sustainable urban transport, uses a variety of ICT instruments on its website, 19 which allow online working groups on specific tasks to be formed. Another action-oriented online platform that allows for online submission of alerts on the misuse of public funds has been created in partnership with BlueLink by the Coalition for Sustainable Use of EU Funds. 20 Over the last year, a network of sustainable education and permaculture initiatives has been formed.21 Most of its members are located in remote rural and mountainous areas, so their coordination and joint work is mainly done online (shared online calendar, mailing list, etc.). BlueLink is currently working on an online activist platform which aims to address the needs of citizens for online communication and will provide more innovative ICT tools for environmental activism. The platform will be open and available to be used as a communication hub and online activity space for different civic causes, and was anticipated to be available at www.grajdani.eu by the end of July 2010. Similar online initiatives with interactive features have been started by organisations working on education for sustainability, aimed at youth and children. 22

Apart from civil society, business interest has also been seen in the field of green ICTs, such as the use of geographic information systems (GIS) data in the management of natural resources. A very recent business project was developed in partnership with the administrations of two Nature Parks23 for the implementation of the EU INSPIRE Directive 24 in Bulgaria. In order to minimise the threat of the monopolisation of environment spheres (e.g. managing all administrative plans in the forestry sector is currently done by the state company Agrolesproject),25 more public-private partnerships in online GIS data registers are needed.

E-waste management

Until the current government was formed in August 2009, MOSV had monopolised the sphere of ewaste by licensing two business organisations for carrying out all ewaste collection and recycling: Ekobultech and Eltechresource. Though licensed by MOSV as collective bodies for ensuring the necessary ewaste management activities, these two companies had purely contractual relations with the companies producing ewaste and were not created by them. Producers paid their ewaste product taxes to Ekobultech and Eltechresource instead of to PUDOOS, as it was cheaper. In return, their documents (accounting for the quantities of ewaste managed, as obligated under the law) were managed for them by the companies. However, this mechanism was efficient on paper only, and resulted in no real ewaste management practices.

MOSV has significantly raised the number of licensed companies over the last year – there are currently sixteen, the four most recent certificates having been issued since December 2009. The competition seems to be aimed at improving ewaste management services, an observation supported by MOSV’s recent cancellation of the licence for one of the new ewaste companies, certified for battery recycling.26

The importance of ewaste seems to be more evident for the general public too, and the media has started discussions on the topic. However, it seems that household appliances are currently the most visible part of the ewaste problem, 27 as well as light bulbs and batteries, as suggested by recent developments: a new site for light bulb storage near the town of Targovishte and a battery collection campaign at Sofia University.

In terms of spending the ewaste tax, the total revenue from ewaste taxes that entered the state budget in 2009 is BGN 1,096,011 (approximately USD 702,000), and no ewaste project has been funded in the past year. 28

With regard to activities by the licensed companies, computer ewaste is being addressed only marginally by some of the ewaste collection schemes (home collections by certified companies after citizens phone them; trade-ins for used equipment at advantageous prices at the stores of partner businesses). 29 Dealing with PC waste in storage has been announced as an upcoming part of the activities at the Nadin plant that was officially inaugurated in June 2010. 30

Greenwashing and green marketing of businesses in questionable “green” ICT approaches

Since the environmental civil society sector is the most influential one in Bulgaria, supporting green causes adds to the legitimacy of Bulgarian businesses and is an effective model for advertising, aimed at the growing target group of environmentally conscious consumers. This approach has been used by many a controversial business in Bulgaria. For example, the main investor 31 in a ski resort project that led to the deforestation of Pirin National Park has established an “environmental” foundation 32 over the last year to legitimise its new ski investment plan for the Vitosha Nature Park, which again envisages illegal deforestation and construction in a protected area.

With regard to the area of green ICTs, public opinion on technical innovation that leads to environmental protection is positive, as can be seen by the growing number of blogs and civil society initiatives focusing on the topic. 33 In this milieu of green ICTs being a “politically correct” topic, a method for marketing one’s label by using the generally accepted “sustainability” discourse can be seen – for instance, by promoting office practices that save electricity, including the use of energy-saving ICT hardware. A similar trend has even appeared in the guise of civil society: promoting green actions (e.g. planting trees) has been accompanied by marketing of specific clothes and food brands, as in the case of the very popular initiative Gorichka (“Shrubbery” in Bulgarian). 34 As “green” products are proving a successful model for marketing, ICT vendors stress the fact that their newest products are greener 35 and that is why customers should buy them, even if their old equipment satisfies their needs. This is a business practice that eventually leads to a commodity-driven lifestyle that directly contradicts the logic of green ICTs: saving nature’s resources. In general, using more energy-efficient hardware is a positive development in business practice, insofar as it inevitably leads to the lowering of the human impact on the environment. However, it is doubtful whether introducing green ICT hardware would be so popular if it did not lead to economic savings as well.

Action steps

In order for Bulgarian civil society to adequately respond to the recent developments regarding ICTs and environmental sustainability, the following directions should be taken:

  • Innovative online action tools for green causes need to be formally recognised by state institutions, and NGO online alerts need to be treated as administrative documents, submitted by citizens.
  • State online registers need to be made available, and GIS data needs to be used in environmental protection.
  • E-waste management needs more efficient state monitoring, and efficient and innovative plants for treating electronic waste need to be built. To this end, PUDOOS should also be monitored and required to provide evidence that ewaste product taxes are actually being used for ewaste recycling.
  • “Green technology”, introduced by businesses, should be discussed in view of its real impact on the environment and not only marketed as being vaguely “environmentally friendly”. More practical information about the necessity of sustainable technology is needed, and there should be an emphasis on the usability and affordability of green ICTs with everyday consumers in mind.


1 The WEEE Directive is European Community Directive 2002/96/EC on Waste Electrical and Electronic Equipment which, together with the Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC, became European Law in February 2003, setting collection, recycling and recovery targets for all types of electrical goods. More at ec.europa.eu/environment/waste/weee/index_en.htm

2 A Bulgarian private online TV focusing on public debate issues. www.retv.bg

3 An analysis by Human Rights Bulgaria is available at humanrightsbulgaria.wordpress.com/%D0%B8%D0%B7%D1%80%D0%B0%D0%B7%D1%8F%D0%B2%D0%B0%D0%BD%D0%B5

4 www.freedomhouse.org/template.cfm?page=251&year=2009; http://en.rsf.org/report-bulgaria,96.html

5 www.svobodata.com/page.php?pid=3094&rid=31; http://ivo.bg/2010/05/30; www.mediapool.bg/show/?storyid=161869

6 www.bluelink.net/en/index.shtml?x=42251; svobodata.org; www.bluelink.net/en/index.shtml?x=42264

7 These amendments were finally voted on in parliament on 17 February 2010.

8 www.bluelink.net/en/index.shtml?x=42490

9 www.opac.government.bg/index.php?option=com_content&view=article&id=534…

10 www.infoweek.bg/display.php?show_category=10&show_subcategory=10&open_a…

11 www.moew.government.bg/funds/nat_env_fund.html

12 www.moew.government.bg/recent_doc/legislation/waste/bg/Naredba_pazarEE…

13 See Todorova, D. (2009) Assessment of E-Waste in Bulgaria After EU WEEE Directive 2002/96, Master’s thesis at the University Of Chemical Technology and Metallurgy, Sofia, p. 5.

14 BlueLink’s project www.spasigorata.net in partnership with the Executive Forestry Agency, as well as two Nature Park Directorates supporting a business project for GIS data application in the implementation of the EU INSPIRE Directive in Bulgaria. www.ursit.com/all/nasdi/initiative.html

15 www.spasigorata.net

16 www.spasigorata.net/partners

17 An idea similar to Spasi gorata was later launched by Google in 2009, but is not yet in use. See earth2tech.com/2009/12/10/copenhagen-google-launches-forest-monitoring-tool/

18 www.forthenature.org

19 velobg.org

20 www.fesbg.org/node/add/signal

21 aliveplaces.org

22 www.futurefriendly.bg and www.gudevica.org/moodle/mod/wiki/view.php?id=391

23 www.ursit.com/all/nasdi/initiative.html

24 The INSPIRE Directive, in force since 15 May 2007, aims to create EU spatial data infrastructure. This will enable the sharing of environmental spatial information among public sector organisations and better facilitate public access to spatial information across Europe. More information at inspire.jrc.ec.europa.eu

25 www.agrolesproject.com

26 www.bluelink.net/index.shtml?x=42654

27 paper.standartnews.com/bg/article.php?d=2009-11-24&article=303091; eltechresource.com; www.ecobultex.com/?page=news&id=20

28 www2.moew.government.bg/recent_doc/funds/predpriatie/godishen_otchet_pudoos_2009.doc

29 www.bluelink.net/index.shtml?x=41800; paper.standartnews.com/bg/article.php?d=2009-11-24&article=303091; news.ibox.bg/news/id_1239947346

30 nadin.bg/?page=dei&id=3&lang=2; www.seenews.com/news/latestnews/bulgarianmetalcompanynadinopens20_5mlne…

31 www.fibank.bg

32 topbloglog.com/blogs/prirodata.com

33 E.g. greentech-bg.net; greenjotter.org; www.passive.bg; www.bpva.org

34 www.gorichka.bg

35 E.g. Philips, with the words “sustainability” and “green” repeatedly displayed on their homepage in all languages (www.philips.com/global/index.page) and Siemens boasting of their “environmental portfolio” (www.siemens.com/about/en/worldwide/bulgaria_1154594.htm) and “[s]ustainability as a central pillar of our corporate strategy” (www.siemens.com/entry/cc/en).