Food and beverage industry representatives warn of significant administrative burdens on business and heightened risks to sensitive commercial data.

Nationally representative trade associations from the food and beverage sector have expressed serious concerns regarding the draft Ordinance establishing the terms, conditions, and procedures for operating the central electronic supply chain traceability register, as well as the scope of data to be submitted. The draft was published for public consultation on August 19, 2026.

In an official position paper addressed to the Deputy Prime Minister and Minister of Economy, Investments, and Industry, the Minister of Agriculture and Food, the Commission for Consumer Protection, and the Commission for Protection of Competition (CPC), the industry bodies highlighted disproportionate administrative burdens and uncontrolled access to sensitive commercial data as critical flaws in the proposal.

According to industry representatives, the draft mandates extensive reporting for every batch and sale of designated food items—including detailed data on products, volumes, pricing, suppliers, buyers, logistics, and accompanying documentation. This would generate substantial operational costs and administrative strain, hitting small and medium-sized enterprises (SMEs) and agricultural producers particularly hard.

The position paper notes that covering just the 23 product categories currently specified would directly impact over 10,000 operators, the vast majority being SMEs and small farms. Industry leaders warn that enforcing these requirements as written could force businesses to cease operations, drive up food production costs, and undermine primary agriculture and broader food security.

A major point of contention is the requirement to submit all accompanying product documentation electronically. Industry stakeholders emphasize that supply chain traceability across the agri-food sector is already rigorously governed by existing EU and national law under the established "one-step-forward, one-step-back" framework, which already obliges operators to retain all necessary documentation.

The associations also question the actual effectiveness of the proposed model. Aggregating massive volumes of transaction data across all shipments will fail to achieve the register's intent, given that a significant share of products undergoes further processing or moves through operators outside the ordinance’s regulatory scope.

Unclear and overly aggressive submission timelines represent another key issue—specifically, 72-hour reporting windows and the requirement to log data prior to goods leaving a production facility. The industry warns that these vague requirements could prove virtually impossible to comply with in practice.

Trade Secrets at Risk

Strong objections were raised regarding the broad range of public institutions and officials granted access to highly sensitive business data stored in the register, including pricing, volumes, vendor networks, and logistics channels. The signatories warn this compromises trade secrets, undermines fair competition, and threatens commercial confidentiality.

To address this, the organizations propose restricting data access strictly on a need-to-know basis, enforcing the CPC's established standards for handling sensitive data, and instituting severe penalties for trade secret breaches. They also urge regulators to scrap the proposed 20-year data retention mandate, calling it ungrounded and excessive.

As a practical alternative, the industry suggests that when competition authorities require supply chain data, they leverage existing state databases—such as streamlined access to National Revenue Agency records. Furthermore, they urge that the register be deployed targetedly for specific cases where reasonable suspicion of cartel activity exists and data cannot be obtained through standard means, rather than imposing a blanket mandatory regime on all operators and shipments.

In conclusion, industry leaders urge a fundamental restructuring of the proposal and a complete review of the register's underlying concept to prevent disproportionate regulatory burdens from inflicting economic damage, inflating consumer prices, disrupting supply chains, and limiting consumer choice.

The position paper was jointly signed by 14 nationally representative industry associations:

The full text of the position paper, including the annex detailing the estimated number of affected operators by product category, is available to read HERE.

• Association of Meat Processors in Bulgaria

• Association of Soft Drinks Manufacturers in Bulgaria

• Association of Fish Products Producers "BG FISH"

• National Union of Bakers and Confectioners

• Bulgarian Vegetable Oil Producers Association

• Food & Drink Bulgaria Association

• Union of Brewers in Bulgaria

• Union of Fruit and Vegetable Processors

• Union of Sugar and Sugar Products Manufacturers

• Spirits Bulgaria (Association of Producers, Importers, and Distributors of Spirits)

• Union of Poultry Breeders in Bulgaria

• Association of Industrial Pig Breeding in Bulgaria

• Association of Pig Breeders in Bulgaria

• Union of Bulgarian Millers