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Timber Risk Assessment
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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. 
Corruption Perceptions Index

Score: 42 / 100 in 2021

Rank:  78 out of 180 countries in 2021

Armed conflict

There are currently no armed conflicts in Bulgaria according to the Council on Foreign Relations' Global Conflict Tracker.

Certification

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 sources

Timber source Description of source type

Managed forests

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.

  • If 5 or fewer trees are to be logged, , a permit is given by the Mayor of the Municipality. A reason has to be given.
  • If more than 5 trees are to be logged, a permit is given by the head of the Municipal Agricultural Department. A significant reason has to be given.

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

Legal rights to harvest
  • Risk that ownership rights are violated due to unclear tenure and management and corruption
  • Risk of logging or forest road construction by a former owner, without the consent of the new owner
  • Risk that logging by a co-owner without the consent of the other owners
  • Risk of logging in forest plots of other owners without their consent
  • Risk that tender processes for the assigning of timber harvesting and/or for wood purchase in public forests (state-owned and municipal) are compromised by illegal activities and corruption
  • Risk that prior agreement between the participants leads to non-market prices being fixed
  • Risk that documents are manipulated
  • Risk that data on forest volumes and tree species in the inventory and logging site certification documents does not match
  • Risk that planned forest activities are not in compliance with the silvicultural or ecological characteristics of the forests
  • Risk that harvesting permits are issued and logging takes place without having a Forest Management Plan
  • Risk of illegal logging without a harvesting permit
  • Risk that logging is not in compliance with harvesting permits
  • Risk that logging occurs outside the boundaries of permitted sites
  • Risk that firewood collection takes place without a permit
Taxes and fees
Taxes and fees
  • Risk that royalties/harvesting fees are reduced though illegal logging and/or illegal transport, or incorrect classification of timber
  • Risk that VAT payment is reduced though incorrect classification of volume, quality and species of timber during sale
  • Risk that wood from private forests (mainly firewood) is sold without invoices or receipts, leading to evasion of VAT
  • Risk that individual logging companies do not declare the full amount of their income and activities, or submit false tax declarations in order to reduce their taxes

Timber harvesting activities

Timber harvesting activities
  • Risk of logging of unselected trees and subsequent false marking of the illegally logged trees
  • Risk that harvesting techniques are not properly implemented (e.g. damaging regenerating trees, remaining trees, or roads during the extraction and transport of logged timber, etc.)
  • Risk that protocols, data of logged timber and transportation tickets are manipulated
  • Risk of illegal logging in protected areas
  • Risk of logging during the breeding season and near the breeding sites of threatened and rare species
  • Risk that deadwood and habitat trees are logged for spurious ‘sanitary’ reasons
  • Risk that old-growth forests are logged
  • Risk that environmental requirements are violated
  • Risk that water courses, water-catchment areas and habitat trees are damaged or destroyed
  • Risk that soil is polluted by machine oil
  • Risk that forest roads are destroyed or eroded
  • Risk that regulations concerning personal protective equipment for forest workers are violated
  • Risk of violations of the labour law, including lack of contracts, training, insurance, and unjustified dismissals

Third parties' rights

Third parties rights
  • Risk that local peoples’ rights are not respected
Trade and transport
Trade and transport
  • Risk that harvested material is incorrectly classifed to reduce/avoid taxes and fees
  • Risk that wood is transported without valid transport documents
  • Risk that valid transport tickets are used more than once
  • Risk that transport tickets are used to accompany timber with another origin than indicated in the documents
  • Risk that transfer pricing takes place
  • Risk that export regulations are violated
  • Risk that timber is smuggled across national borders because of a lack of control of trucks
  • Risk that required due diligence systems as required under the European Timber Regulation are not implemented

 

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.

Mitigation recommendations

There are five recommended actions to mitigate the risks associated with the timber sources from Bulgaria.

1. Fully map your supply chain

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.

Profile Publication Date
2017-11-01