Positions and statements

Consumer credit: clear rules and proportionate requirements

The Association for the Protection of Bulgarian Manufacturers and Traders supports clear consumer credit rules that combine effective consumer protection with a predictable business environment. Regarding the Consumer Credit Bill No. 52-602-01-41 of 11 September 2026, we emphasise understandable information, responsible lending and proportionate requirements for small and medium-sized enterprises.

For instalment sales, including “buy now, pay later” arrangements, consumers should be able to identify the total amount payable, credit costs, repayment terms and consequences of late payment easily before entering into a contract. Information should be visible and comparable, including when shopping online. Additional services and charges should be clearly distinguished from the price of the goods and the principal financing terms.

We recommend clearly distinguishing the obligations of lenders, intermediaries and traders according to their actual roles. Where a business sells goods and has limited involvement in financing, requirements should reflect this. Duplicate checks and documentation should be avoided without weakening consumer protection.

Assessing repayment capacity should help prevent over-indebtedness. Data collection should be limited to what is necessary for that purpose, and consumers should receive understandable information about material conditions and decisions affecting them. The convenience of digital services should not lead to hasty or uninformed commitments.

Businesses need practical guidance, model information formats and a realistic transition period to adapt contracts, software and internal procedures. We support consistent supervision focused on material risks, together with accessible arrangements for handling complaints and resolving disputes.

The guiding criterion should be the actual outcome: informed consumers, responsible financing and fair competition. Administrative work should deliver a real benefit to customer protection.

Fair relations between producers, suppliers and traders

The Association for the Protection of Bulgarian Manufacturers and Traders supports fair and predictable supply-chain relationships. Implementation of the amendments to Bulgaria’s Protection of Competition Act adopted in 2026, including protection against unfair practices in agricultural and food supply chains, should be guided by equal treatment and fulfilment of commitments.

Producers, suppliers and traders have different functions and costs but share an interest in sustainable supplies and consumer trust. Protection of the weaker party should reflect the economic context, without assumptions that a category of businesses is always responsible for misconduct or always the affected party.

We recommend clearly agreeing the material commercial terms: price and pricing method, payment deadlines, delivery and acceptance, additional services, promotions and returns. Changes should be traceable and predictable. In agricultural and food supply chains, unilateral retroactive changes, opaque fees and discounts, unjustified transfers of costs and risk, and late payments deserve particular attention.

Supervision should distinguish unfair conduct from justified negotiation based on quantity, quality, logistics and assumed risk. This matters both for small producers’ market access and for traders’ ability to organise their operations efficiently. Rules should not discourage voluntary partnerships and improvements throughout the supply chain.

Small and medium-sized enterprises need concise practical guidance and proportionate documentation. Traceability requirements should use existing data and avoid repeated submissions. Complaints should be examined with protection for confidential commercial information, an opportunity for the parties concerned to be heard and clear reasons for decisions. Voluntary dispute resolution can complement supervision without replacing it.

The aim is a workable balance between participants. Predictable contracts and timely payment support investment, quality and the resilience of supplies on which consumers also depend.

Predictable price supervision and clear rules for business

The Association for the Protection of Bulgarian Manufacturers and Traders supports consumer protection through transparent prices and consistent supervision. Implementation of the amendments to Bulgaria’s Consumer Protection Act adopted in 2026 concerning economically unjustified price increases requires clear criteria, equal treatment and proportionate requirements for businesses.

Consumers should be able to understand and compare prices and receive accurate information about sales conditions. Misleading presentation of prices and discounts undermines trust and disadvantages businesses that act fairly. Supervision should focus on specific, identifiable infringements and rely on verifiable facts.

We recommend publicly available guidance on the scope of inspections, required documents and how the economic justification for price changes is assessed. Analysis should consider actual production, energy, transport and labour costs, seasonality, changes in supply conditions and the characteristics of the activity concerned. A price change alone should not substitute for establishing an infringement.

Information requirements should be proportionate. Small businesses should not have to maintain complex reporting systems solely for an inspection where existing accounting and commercial documents can establish the same facts. Reasonable deadlines for supplying information and protection of confidential information are needed.

We support coordination between supervisory authorities to limit repeated requests for the same documents and contradictory guidance. Businesses should understand the grounds for findings and have an opportunity to submit explanations and evidence. The consequences of infringements should reflect their seriousness and the applicable rules, rather than formal differences in business organisation.

Predictable supervision supports consumer trust and fair competition. It should deter unfair conduct while preserving businesses’ ability to respond to genuine changes in costs and market conditions. Clear rules facilitate voluntary compliance.

Areas of work

The Association’s Statutes provide for research and analysis, preparation of statements, exchange of experience and cooperation in support of manufacturing and trade. Focus areas include innovation, vocational skills, digital technologies, the circular economy and regional development.

Previous activities

AI awareness among small retailers

14–25 October 2024. Informal conversations with small retailers about potential uses of artificial intelligence in inventory management and pricing, and their training needs.

Discussions on risks in e-commerce

20–21 June 2024. Two informal meetings with online retailers addressing the risks of AI-assisted fraud and the need for appropriate vocational training.

Review of the legal framework for protecting manufacturers

14 October–30 November 2024. Preparation of an analysis on unfair competition and intellectual property protection, incorporating feedback from business and legal professionals.

Vocational skills needs assessment

1–30 April 2023. An internal assessment through VET Center “Primis” of how workforce skills align with employers’ expectations in manufacturing, trade and logistics.

Resilience of small and medium-sized enterprises

16 June 2022. Informal peer exchange among SME owners on crisis management, digital adaptation and business continuity following the economic disruption caused by COVID-19.