Timber Risk Score: 5 / 100 in 2017. The Timber Legality Risk Assessment contains an evaluation of the risk of illegality in Bulgaria for five categories and 21 sub-categories of law. We found:
- Specified risk for 18 sub-categories.
- Low risk for 1 sub-category.
- No legal requirements for 2 sub-categories.
This page provides an overview of the legality risks related to timber produced in Bulgaria.
34% (3.82 million ha) of Bulgaria is covered by forests of which:
- About 9% is primary forest
- About 71% is naturally regenerated forest
- About 20% is planted forest
Roundwood production totalled 6.3 million m3 in 2015. The forestry sector (including wood processing and pulp and paper) contributed USD 482.1 million to the country’s economy in 2011, or nearly 1% of its GDP.
Several legality risks are present in Bulgarian timber supply chains. The risks relate to legal rights to harvest, taxes and fees, timber harvesting activities, third parties’ rights and trade and transport. Companies sourcing timber from Bulgaria should take care to ensure the risks identified are not present in their supply chains, or have been sufficiently mitigated.
This risk assessment was prepared between 2014-2018 according to the FSC-STD-40-005. The approved FSC Risk Assessment can be downloaded in the FSC Document Centre. ONLY Risk Assessments that have been formally reviewed and approved by FSC can be used by an FSC candidate or certified companies in risk assessments and will meet the FSC standards without further verification.
Score: 44 / 100 in 2020
Rank: 69 out of 180 countries in 2020
There are currently no armed conflicts in Bulgaria according to the Council on Foreign Relations' Global Conflict Tracker.
FSC Certified Forest Area:1,454,068 hectares (4 December 2019).
Use this section to:
- Find out the different sources of legal timber.
- Determine which Source Type your timber comes from.
|Timber source||Description of source type|
Timber from intensely managed forests. Harvesting permits as well as a Forest Management Plan or a plan-extract is required. Managed forests can be state or privately owned.
Special use forests
Timber from protected areas or Natura 2000 sites, which are managed to protect biodiversity. Harvesting permits may be issued only if the forest activities are included in a Forest Management Plan for a 10-year period or in a plan-extract. Special use forests can be state, publicly or privately owned.
|Protection forests||Timber from forests which are managed to protect soil, water, and infrastructure. Harvesting permits may be issued only if the forest activities are included in a Forest Management Plan for a 10-year period or in a plan-extract. Protection forest can be state, publicly or privately owned|
|Farmland forests||Timber from farmland forests. Harvesting permits as well as a Forest Management Plan or a plan-extract is required. Farmland can be publicly or privately owned.|
|Single trees on farmland||
Timber from single trees grown on farmland. Logging on farmland is allowed with a permit.
Farmland can be publicly or privately owned.
|Reserves and national parks||Timber from strictly protected areas. This is a limited source of timber, as there is no industrial production. The aim of logging is solely to maintain protected forests. Reserves and national parks are state owned.|
Risk assessment summary
Legal rights to harvest
|Taxes and fees
Timber harvesting activities
Third parties' rights
|Trade and transport
Mitigate the risks in your supply chain
Learn which actions we recommended to mitigate the risks associated with the timber sources from Bulgaria
Source Certified Materials
NEPCon believes that third party certification (for example FSC and PEFC certification) can provide strong assurances of the legality of the products they cover. Companies seeking to mitigate the risks of sourcing illegal timber should seek to purchase third party certified materials wherever possible.
While the European Timber Regulation does not include an automatic “green lane” for certified products, it does recognise the value of certification as a tool for risk assessment and mitigation. The European Commission says that companies “may rate credibly certified products as having negligible risk of being illegal, i.e. suitable for placing on the market with no further risk mitigation measures, provided that the rest of the information gathered and the replies to the risk assessment questions do not contradict such a conclusion.”
For more information on using certified materials in your due diligence, including how to assess whether a certification system meets EUTR requirements, see the page on Certification and Due Diligence.
There are five recommended actions to mitigate the risks associated with the timber sources from Bulgaria.
1. Fully map your supply chain
- Our supply chain mapping tool can help you do this.
2. Obtain and verify documents
- Forest level documents
- The management contract or other agreements with the owner
- For non-state forests, it is necessary that contracts for usage of wood (incl. logging) are legalised by a notary
- Court decisions, court cases, prosecutors’ investigations, or any other evidence to show potential infringements
- Maps to show harvesting areas
- Forest management plans
- Annual operating or harvesting plans
- Harvesting permits
- Environmental Impact Assessments
- Records confirming complaints for infringed rights of stakeholders in the forest management units have been/are being followed up on
- Tax related documents
- Receipts for payments of harvesting-related royalties and fees, VAT and income taxes.
- Sales documents whichinclude applicable sales taxes
- Volumes, species and qualities given in sales and transport documents match fees paid
- Health and safety related documents
- Lists of all workers, including information about their qualifications, insurance, personal protection equipment
- Employment related documents
- List of (permanent and temporary) workers as well as their contracts with the organisation
- Records showing payment of salaries
- Trade and transport documents
- Trade permits
- Documents related to transportation, trade or export, clearly linked to the specific material in question
- Invoices showing that prices of timber sold correspond with general sales prices in the country
- Due Diligence System procedures as required by the EU Timber Regulation
- Due Diligence System records of identified risks and how they are mitigated, as required by the EU Timber Regulation
3. Consult stakeholders
- Authorities confirm that the legal status of operations or rights for conducting the established activities are not subject to court orders or other legally established decisions to cease operations
- Financial authoritiesconfirm that all required royalties and taxes have been paid
- Staff and contractors confirm that legally required protection equipment is provided and required to be used
- Public authorities in charge of monitoring occupational health and safety confirm that applicable legal requirements are met and that there are no major violations
- Staff confirm that there is no illegality in terms of social security, insurance, contract or other statutorily-required working terms and conditions
- Stakeholders confirm that customary rights are observed during harvesting activities
4. Carry out on-site verification
- Confirm that harvesting takes place within property boundaries and limits defined in harvesting permits
- Confirm that the harvesting plan is adhered to in the field
- Confirm that information regarding area, species, volumes and other information given in the harvesting permit is correct and within the limits prescribed by legislation
- Confirm harvesting does not take place in areas where legally prohibited
- Confirm tree species or selected trees which are prohibited to be felled are marked in the field.
- Confirm that environmental restrictions are followed in the field, such as requirements related to soil damage, buffer zones, retention trees, seasonal restrictions etc.
- Confirm that mitigation measures recorded in the company’s due diligence system are conducted and are effective
- Confirm that legally established procedures for surveying, managing and protecting endangered or threatened species are followed
5. Conduct targeted timber testing
Conduct timber testing on samples of purchased material to verify the species or origin of timber, where appropriate.