Pricing and modulation
How the remuneration to Eco Oil Resource is set
Rates by class
Base rate: 0.25 EUR/kg excl. VAT
The public range of the modulated rates is from 0.20 to 0.286 EUR/kg excl. VAT
| Class | Rate excl. VAT | Which products |
|---|---|---|
| A | 0.20 EUR/kg | the highest demonstrated durability and suitability for regeneration |
| B | 0.22 EUR/kg | increased durability and suitability for regeneration |
| C | 0.25 EUR/kg | the standard class and the base rate |
| D | 0.286 EUR/kg | special products with higher costs or impeded regeneration |
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 exact class is set under this methodology and the product documents submitted
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 Used 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 used 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
| 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 this methodology, 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 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;
- necessary management costs — separation, additional analysis, specialized transport, more expensive treatment.
Rules of application
- Where the evidence for class A or B is insufficient, the standard class C applies, unless the known characteristics objectively call for class D
- Biodegradability alone does not automatically give class A or B if the oil impedes the available R9 process
- 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 organization does not publish a scoring system or numeric thresholds that it and its technical specialist have not approved
Every product outside the obvious cases goes through an individual technical assessment
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 price annex to 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 — at least 90 days' written notice and effect for the future only; for an increase, the organization announces the change at least six 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 on 90 days' written notice, with the previous rates applying until it expires.
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
Version and effect of the methodology
| Version | Published | In force for remuneration for | Status |
|---|---|---|---|
| 1.0 | 5 September 2026 | 1 January 2027 – 31 December 2031 | adopted |
The base rate holds for the whole period under normal conditions
A deviation is possible only through the emergency mechanism described in advance, on demonstrated shortfall, and only temporarily
The organization’s permit runs to 31 December 2026
The rates for 2027 – 2031 apply where the term of the permit is extended under Chapter Five, Section III of the Waste Management Act
When a new version is adopted, the previous one stays published in this table marked “superseded”, so it remains traceable which methodology was in force and when
For running agreements, every rate change follows the contractual notice procedure and takes effect for the future only
An increase in a rate is announced at least six months before it takes effect
Art. 18 of the General Terms and Conditions requires 90 days; the six months are a longer period the organization commits to, not a different rule
A decrease may take effect immediately — it favours the member and needs no preparation period
The notice states the new numeric rate, the product groups or codes it applies to, and the date it takes effect
Where a member disagrees with an increase, it may terminate the agreement under Art. 18(8) of the General Terms and Conditions, and the previous rates apply until the notice period expires