Pricing and modulation
How the remuneration to Eco Oil Resource is set
Current rates
Today every product is paid for at the base contractual rate of EUR 0.275/kg, excl. VAT
| Term | Under the participation agreement |
|---|---|
| Base contractual rate (reference class C) | EUR 0.275/kg excl. VAT, for every product |
| Member’s notice period for termination | 3 (three) months, and in special cases 12 months — as in the agreement template |
Rates are in euro per kilogram of oil placed on the market and are stated excluding VAT
VAT is charged on top under the Bulgarian Value Added Tax Act and is shown separately on the invoice
The scale is uniform and does not depend on the notice period or on the term of the agreement (Art. 5(2) of the participation agreement)
No individual rate, trade discount or volume discount is agreed or applied (Art. 5(3))
From when it applies, and to whom. The rate above is the base contractual rate under Art. 5 of the participation agreement, template v2 of 30.09.2026, and it applies to new agreements and to agreements re-signed with a reference to the General Terms and Conditions EOR-OM-GTC-2026-6 (in force from 30 September 2026)
For an individual member it applies from the date agreed in that member’s agreement, and no earlier than the date the General Terms took effect (Art. 65(3))
An existing member keeps their own rate. For a member who has not signed a new agreement, the existing agreement, its rate and the version of the General Terms applicable to it are preserved
Publishing this version for information does not replace the agreement
Moving over is voluntary — by signing a new agreement or an explicit written arrangement with a stated start date, and obligations arising before that date are not recalculated (Art. 65(5))
The contractual scale under Art. 5 — not in force today
By signing the agreement, the parties consent to a uniform scale with four tariff classes (Art. 5(1) and (4) of the participation agreement)
The class rates do not apply today: they take effect only under the conditions below, and the Programme 2027 – 2031, which has to contain the same scale, is a draft and has not been approved
The class rates are agreed in Art. 5(1) of the participation agreement and are not published on this site: today every product is paid for at the base contractual rate of EUR 0.275/kg excluding VAT
Publication of the scale under Art. 33(5), item 2 of the General Terms and Conditions is only one of the conditions in Art. 5(4) of the participation agreement and will be made once the Programme is approved — until then the class rates do not apply and no rate other than the base one is owed
When the class rates apply (Art. 5(4) of the participation agreement)
- class D — from the first day of the month in which the following conditions are cumulatively met: an approved and applicable Programme containing the same scale; publication of the scale under Art. 33(5), item 2 of the General Terms and Conditions; a consultation held under Art. 33a(2) of the General Terms and Conditions and written notice to the member, but not earlier than 1 January 2027 (the date comes from Art. 5(4) of the participation agreement; the conditions from Art. 16a(3) of the General Terms and Conditions, which itself sets no date);
- classes A and B, which are lower than the base contractual rate — from the beginning of the programme period for which the Programme has been approved (Art. 5(4) of the participation agreement); a consultation that has not been held does not defer a reduction (Art. 33a(5) of the General Terms and Conditions), and under the General Terms and Conditions a reduction takes effect from the date stated in the notice, and no later than the first day of the month following it (Art. 18(3));
- until then, all of the member’s products are paid for at the base contractual rate, without subsequent additional payments or refunds on account of the tariff class — the class rates have no retroactive effect;
- where the approved Programme contains a scale different from the contractual one, the class rates are brought into line with it only under the procedure in Art. 23 of the agreement, and lower rates apply under Art. 23(2).
Product modulation and tariff classes
The legislation requires the remuneration to be modulated by product criteria
For that purpose there are four tariff classes — A, B, C and D
The class is determined for the product, not for the customer
It is not a volume, a discount, a negotiated price or a special condition for an individual member
| Class | What it covers | How it is determined |
|---|---|---|
| A | the highest demonstrated durability and suitability for regeneration, with no hazardous substances above the statutory thresholds | only on the evidence under Art. 16a |
| B | increased durability and suitability for regeneration and recycling | on the same evidence, against the class B thresholds |
| C | the standard class — it carries the current base rate above | applies by default, including where there is no evidence |
| D | special products with objectively higher management costs or impeded regeneration | automatically, by type of product — it is not applied for |
Class D by type covers electrical insulating oils, metalworking oils and cutting/cooling fluids (including water-miscible ones), mould release oils and anticorrosion oils, as well as products containing hazardous substances above the statutory thresholds, halogenated formulations or substances on the SVHC list
Published information about another product class does not automatically confer a right to that rate for a product that does not meet its criteria
The rates for classes A, B and D are part of the contractual scale, which is not in force and is not published
The criteria and thresholds for the classes are contained in the Programme, which is a draft — see the programme section below
Why the rates are not the same
Modulation is not a commercial choice of the organization — it is a legal requirement
The Bulgarian requirement
Art. 14(11) of the Waste Management Act provides that the ordinances under Art. 13(1) also determine the cases in which the remuneration is differentiated for individual products or groups of similar products, taking into account their durability, reparability, reusability and recyclability, as well as the presence of hazardous substances
Art. 12(1), point 3(c) of the Ordinance on Waste Oils and Waste Petroleum Products requires the remuneration to be modulated for individual products or groups of similar products, taking into account
- the durability of the products;
- their suitability for regeneration;
- their suitability for recycling.
The same provision also sets a ceiling — the amount of the remuneration does not exceed the costs necessary to provide the waste oil management services in a cost-efficient way
The necessary costs cap the rate from above; they are not a criterion that raises it
The European Union requirement
Art. 8a(4)(b) of Directive 2008/98/EC provides that, under collective compliance, financial contributions are modulated, where possible, for individual products or groups of similar products, taking into account in particular their durability, reparability, reusability and recyclability, as well as the presence of hazardous substances, thereby taking a life-cycle approach
Art. 8a(4)(c) requires the contributions not to exceed the costs necessary for cost-efficient management, and the costs to be established transparently between the parties
What follows from this
A single identical rate for every oil
- ignores the differing suitability for regeneration under operation R9;
- ignores the need for separation, extra analysis or more expensive treatment;
- creates no incentive for more durable and more readily regenerable products;
- confuses equal treatment of members with identical pricing of different products.
Equal treatment means the same objective rules for every member, not the same price for products with different environmental characteristics and different management costs
The rate does not depend on the origin, size, reputation or bargaining power of the company
It differs only by published product criteria and demonstrated cost
Remuneration to the organization and product fee to EMEPA (ПУДООС)
These are two different payments and must not be conflated
| Criterion | Remuneration to Eco Oil Resource | Product fee to EMEPA |
|---|---|---|
| Legal nature | a contractual price | a statutory public-law charge |
| Who receives it | the recovery organization | the Bulgarian Enterprise for Management of Environmental Protection Activities |
| Who owes it | the member of the organization | a company meeting its obligation individually |
| How the amount is set | under the tariff methodology in the Programme (Art. 16(3) and Art. 16a of the General Terms and Conditions), within the necessary costs | by a legal act |
| Can it be modulated | yes, and it must be | not by the organization |
Members of a recovery organization meet their obligations through it
The rates on this page are a contractual remuneration, not a product fee
General criteria for the classes
The class is set by the characteristics of the product, not by the characteristics of the member company
- durability of the product — service life and stability of the oil in use;
- suitability for repair and for re-use, in so far as they apply to the product concerned;
- suitability for regeneration — how well the oil fits the available R9 process at the contracted regeneration operator;
- suitability for recycling and material recovery;
- presence of hazardous substances requiring separate collection, storage, transport or separate treatment.
The necessary management costs are not a product criterion in their own right
They set the ceiling on the remuneration, while its overall level is determined under Art. 17 of the General Terms and Conditions (Art. 16(3))
Rules of application
- Where there is no valid evidence for class A or B, the standard class C applies, unless the type of product objectively falls within class D
- Biodegradability alone does not justify class A or B where the product impedes regeneration
- A self-declaration or a marketing “eco” claim is not sufficient evidence
- Classification is by product or by group of similar products, not by member
- The draft Programme provides that class A or B is not assigned at all to ester and vegetable base oils or formulations whose ester component exceeds 10 per cent, to products containing more than 2 per cent water in the composition in which they are placed on the market, to water-miscible products and concentrates for preparing emulsions, or to the product groups that fall within class D by type
The thresholds are public and numeric
The draft Programme 2027 – 2031 (Art. 53 of the Waste Management Act) sets thirteen indicators, each with its test method, and exact thresholds for class A and for class B — base oil type and group under API 1509, base oil content, sulphated ash, sulphur, total chlorine, PCBs, zinc, sum of metals, silicon, water, polymeric viscosity index improvers, oxidation stability, and the presence of halogenated formulations or substances on the SVHC list
The General Terms and Conditions contain no thresholds (Art. 16a(1)), and until the Programme is approved its thresholds do not change the tariff class of a product (Art. 16a(2))
The class is assessed for the product in the composition in which it is placed on the market, including all additives, and by how the used product behaves in the technology actually applied by the organization’s operators — not by the properties of the fresh product alone
What evidence is accepted
To determine the class, the organization may use
- a safety data sheet (SDS);
- a technical data sheet (TDS);
- a declaration of composition and additives, within the permissible scope of commercial confidentiality;
- recognized product or environmental certificates, where applicable;
- evidence of regenerated content, where demonstrated;
- a technical assessment of suitability for the available R9 process;
- where necessary, a written opinion from a technologist or from the contracted regeneration operator.
The documents are supplied by the member
The organization keeps the evidence and the reasoned decision on the class in its audit trail
How a class is set and how it changes
- The member declares a product or a group of similar products and submits the documents listed above
- The organization carries out a technical assessment of suitability for the available R9 process and of the necessary management costs
- The organization takes a reasoned decision on the class and notifies the member in writing, stating the class, the rate, the products or codes and the date of application
- The class is entered in the table in Art. 6(1) of the agreement, and any change in Portal 2.0 with reasons and a date (Art. 6(6) of the agreement)
- The class is reviewed on new product data, on a change in composition or additives, on a change in the available regeneration process, or on a change in costs
- The organization carries out an annual review of the actual product mix and of the average rate
- A rate change under a running agreement follows the General Terms and Conditions (Bulgarian text) — on 3 (three) months’ written notice (Art. 23(1) of the agreement), with effect for the future only; for an increase, the organization announces the change on this page at least 3 months in advance
A change does not apply to quantities for which the remuneration arose before the date it took effect
The right to reasons and to a second review
Every member is entitled
- to receive the written reasons for the class assigned;
- to request a second review by submitting new or additional evidence;
- to receive a written answer to that request;
- on disagreement with a rate increase, to terminate the agreement within 30 calendar days of receiving the notice, on 3 (three) months’ written notice, with the previous rates applying until termination (Art. 23(3) of the agreement).
A review is requested at info@ecooilresource.com
A different rate agreed with another member does not in itself create a right to the same rate where the difference is justified by permissible objective factors
Programme 2027 – 2031
DRAFT — not in force
The programme does not change the current contractual rate
Every product is paid for at the base contractual rate of EUR 0.275/kg excl. VAT under Art. 5 of the participation agreement, until the conditions of Art. 5(4) are met
The waste oil management programme for 2027 – 2031 is the document required by Art. 53 of the Waste Management Act
It contains the tariff methodology — the criteria and thresholds for the four classes, the scale and the financial plan of the scheme
At present it is a draft: version v4.6 has been audited but has not been approved by the Minister of Environment and Water and is not in force
The programme itself describes its tariff values as “draft until lawfully introduced”
For that reason the rates for classes A, B and D in the contractual scale do not apply today (Art. 5(4) of the participation agreement)
The arrival of a proposed date does not by itself make the scale applicable
It becomes applicable only after adoption by the proper procedure, including the public consultation under Art. 33a of the General Terms and Conditions (Bulgarian text)
Once the programme is approved, this page will state the date from which the class rates apply
Version of the methodology and how a rate may change
| Part | Where it sits | Status |
|---|---|---|
| Legal principles and the referral | Art. 16a of the General Terms and Conditions EOR-OM-GTC-2026-6 | in force from 30 September 2026 |
| Criteria, technical thresholds, evidence and test methods | The organization’s Programme under Art. 53 of the Waste Management Act | draft — not approved |
From edition EOR-OM-GTC-2026-6 the Methodology is not contained in the General Terms and Conditions (Bulgarian text) — those set out the legal principles only
The criteria, technical thresholds, admissible evidence and test methods sit in the organization’s Programme under Art. 53 of the Waste Management Act, and Art. 16a only refers to it rather than reproducing it (Art. 16a(1))
A version of the Programme that has not been approved and has not taken effect does not change the agreement, the base contractual rate, the tariff class of a product or the applicable product rate (Art. 16a(2))
The organization’s permit runs to 31 December 2026
Rates that are to apply from 2027 onwards presuppose that the term of the permit is extended under Chapter Five, Section III of the Waste Management Act
When and how a rate may change
A rate increase is notified on 3 (three) months’ written notice (Art. 23(1) of the agreement)
For an increase, the organization announces the forthcoming change on this page at least 3 months before the date it takes effect; if it fails to do so, the effective date is deferred until 3 months from the announcement have passed (Art. 18(1))
The notice states the new numeric rate, the codes or product groups it applies to, and the date from which it takes effect
The change operates for the future only and does not apply to quantities for which the remuneration arose before that date
A reduction takes effect from the date stated in the notice, without a notice period — it is in the member’s favour
The ceiling on an increase
A unilateral increase is made no more than once every 12 months and may not exceed the greater of the two (Art. 18(9)):
- the annual rate of inflation under the consumer price index of the National Statistical Institute (December on December) for the preceding year, increased by 3 percentage points;
- the documented increase in the necessary costs per unit of quantity, confirmed by a registered auditor.
The notice contains the calculation itself and states which of the two bases has been applied
The limit falls away only where a statutory act changes the percentage of a recovery, recycling or separate-collection target applicable to the organization, or introduces a new such target
Even then the increase does not exceed the documented increase in costs confirmed by an auditor, and does not take effect before the date from which the new target applies
If you disagree with an increase
You have 30 calendar days from receiving the notice in which to terminate the agreement on 3 (three) months’ written notice, counted from receipt of the notice (Art. 18(8) of the General Terms and Art. 23(3) of the agreement)
Until termination, including for the reporting period in which it takes effect, the previous rate applies and no difference is payable
The period is final
Once it has passed, termination follows the general rule
The organization and the member may at any time agree a rate by mutual written consent, with immediate or another agreed effect (Art. 19)
Before the scale changes — public consultation
Before adopting or amending the scale of rates, the Methodology or the cost model, the organization publishes the draft together with the cost model and allows no less than 30 calendar days for written views (Art. 33a(2))
Together with the final decision it publishes the views received in summary form and a reasoned response to each of them, including the reasons for not accepting a view
A change adopted without the consultation having been held is unenforceable against the member until it is held
This does not apply to a reduction of a rate — that takes effect regardless