On 3 February 2026, key amendments to the Bulgarian Consumer Protection Act (CPA) entered into force. These changes link Bulgarian law with EU regulations surrounding general product safety and representative actions for the protection of the collective interests of consumers.
Products falling within the scope of the aligned rules
Products may only be placed on the market if they comply with the requirements of EU Regulation 2023/988 on general product safety (GPSR), which went into effect on 13 December 2024. These provisions apply to a multitude of consumer products (except for medicines, food, feed, products of plant or animal origin, antiques) regardless of the sales channel (i.e. products distributed by distance selling and online marketplaces also apply).
The general product safety requirements extend to second-hand products, and to products that have been repaired, refurbished, or recycled and reintroduced into the supply chain as part of commercial activity. An exception applies to products for which consumers cannot reasonably expect compliance with the latest safety standards (e.g. items expressly presented as requiring repair or refurbishment) or marketed as works of art or collectors' items of historical significance.
Enhanced obligations across the supply chain
These amendments provide the GPSR with the specific obligations for producers, importers, distributors, suppliers, service providers and online marketplace providers. Key requirements include:
- conducting internal risk analysis and preparing technical documentation before market placement;
- providing product information, instructions and safety warnings in Bulgarian language;
- maintaining registers of complaints, dangerous products incidents, recalls and corrective measures;
- online market providers must register on the Safety Gate portal and designate a single point of contact enabling direct and rapid communication with consumers on product safety matters, as well as direct electronic communication with market surveillance authorities.
Consumer remedies
When dangerous products are recalled from consumers, whether initiated by an economic operator or ordered by the Consumer Protection Commission (CPC), consumers are entitled to remedies such as repair, replacement, or refund.
Regarding cost allocation, the market surveillance authority will assume the costs when a product is found to be safe after inspection. Where a product is found to be dangerous, the economic operator must bear the costs.
Fines
The revised penalty framework includes increased fines for sole traders and legal entities who place non-compliant products on the market or who fail to comply with an order or mandatory instruction of the CPC.
Changes in relation to price reduction announcements
As per the effective legislation, any price reduction announcement must display the previous price, which is defined as the lowest price applied by the trader during the last 30 days prior to the price reduction. This rule is clarified for products, intended to be placed on the market for less than 30 days. For these, the reduced price must be displayed together with the previous lowest price applied for a term of at least seven days before the price reduction. Goods subject to rapid quality deterioration with short shelf life are exempt from these requirements. The clarifications will take effect in one year: 5 February 2027.
Representative actions for consumer protection
These amendments to the CPA introduce the concept of qualified organisations for bringing representative actions to protect the collective interests of consumers. Qualified organisations include the CPC and organisations included in a list approved by the Minister of Economy and Industry. The amendments state the requirements that qualified organisations must meet, and the actions they can take to protect the collective interests of consumers.
For more information on Bulgaria’s Consumer Protection Act amendment and its impact on businesses, contact your CMS client partner or the CMS experts who contributed to this article: Nevena Radlova and Elina Kostadinova.
Article co-authored by Elina Kostadinova
