Bulgaria

Cluster Munition Ban Policy

Last updated: 27 July 2019

Summary: State Party Bulgaria ratified the convention on 6 April 2011 and enacted implementing legislation in November 2015. It participates in meetings of the convention and voted in favor of a key United Nations (UN) resolution promoting the convention in December 2018.

Bulgaria has reported that it never used or produced cluster munitions. In 2018, Bulgaria started destroying a stockpile of 6,862 cluster munitions and 186,349 submunitions. However, Bulgaria has submitted a request to extend the deadline for completing its stockpile destruction from October 2019 to April 2021, making it the first State Party to request such an extension. Bulgaria has retained eight cluster munitions and 400 submunitions for research and training purposes, but said in September 2018 that it no longer no intends to retain the cluster munitions.

Policy

The Republic of Bulgaria signed the Convention on Cluster Munitions on 3 December 2008, ratified on 6 April 2011, and the convention entered into force for the country on 1 October 2011.

Bulgaria’s parliament adopted implementing legislation for the Convention on Cluster Munitions and the Mine Ban Treaty on 24 November 2015, which took effect on 8 December 2015.[1] It amended Articles 337–339 of the Penal Code in June 2016 to establish sanctions for violations of the convention’s new implementation law.[2] A National Authority established in January 2012 coordinates Bulgaria’s implementation of and compliance with the convention.[3]

Bulgaria submitted its initial Article 7 transparency report for the Convention on Cluster Munitions on 27 March 2012 and has provided annual updated reports since then, most recently on 14 May 2019.[4]

Bulgaria played a notable role in the Oslo Process that created the Convention on Cluster Munitions and hosted a regional conference promoting the convention in Sofia in September 2008.

Bulgaria has attended every Meeting of States Parties of the convention with one exception (2014), as well as the convention’s First Review Conference in 2015 and intersessional meetings held in 2011–2015. It participated in the convention’s Eighth Meeting of States Parties in Geneva in September 2018.

Bulgaria voted in favor of a UN General Assembly (UNGA) resolution promoting implementation of the convention in December 2018.[5] It has voted in favor of the annual UNGA resolution promoting the convention since it was first introduced in 2015.

Bulgaria has condemned the use of cluster munitions in Syria on several occasions since 2013.[6] It has also voted in favor of UNGA resolutions expressing outrage at the use of cluster munitions in Syria, most recently in December 2018.[7]

Bulgaria is a State Party to the Mine Ban Treaty. It is also party to the Convention on Conventional Weapons.

Interpretive issues

In 2009, Bulgaria elaborated its views on several important issues relating to the interpretation and implementation of the convention.[8] Bulgaria interprets Article 1 of the convention to mean that “transit” of cluster munitions across the territory of States Parties is prohibited, as is the stockpiling of foreign-owned cluster munitions. Bulgaria has noted that while a ban on investment in cluster munition production is not explicit in the convention text, it would need to be “considered in light of the general prohibition on the development and production of cluster munitions.”

With respect to “interoperability” and the prohibition on assistance during joint military operations with states not party, Bulgaria has stated that it “will fully observe the regulations of Article 21 of the Convention…Par. 4 of Article 21 stipulates that participation in such military operations ‘shall not authorize a State Party’ to engage in acts prohibited under the terms of the Convention and contains an exhaustive list of such acts.”

Use, production, and transfer

In 2009, a Ministry of Foreign Affairs representative said that “cluster munitions have never been used by the Bulgarian Armed Forces.”[9] Bulgaria was among a handful of states to announce a unilateral moratorium on the use of cluster munitions prior to the creation of the convention.[10]

Bulgaria has reported that there “are no programmes for the conversion or decommissioning of production facilities for cluster munitions in the Republic of Bulgaria.”[11] In 2008, a Ministry of Foreign Affairs official stated that “Bulgaria does not and has not produced any type of cluster munitions.”[12]

Stockpiling and destruction

Bulgaria has reported a stockpile of 6,862 cluster munitions and 186,349 submunitions, as detailed in the following table.

Cluster munitions stockpiled by Bulgaria (as of 31 December 2018)[13]

Type of munitions

Quantity

Type of submunitions

Quantity

RBK-250-275 bombs

214

AO-1SCh and AO-2.5SCh

32,100

RBK-250 bombs

60

ZAB-2.5SM

2,880

RBK-250 bombs

478

PTAB-2.5M

20,076

RBK-500 bombs

201

AO-2.5RT

12,060

RBK-500 bombs

86

ZAB-2.5SM

25,542

 

0

ZAB-2.5SM

2,939

RBK-500 bombs

36

ShOAB-0.5M

19,656

RBK-500 bombs

3

ShOAB-0.5

1,695

BKF cartridges

2,166

AO-2.5RT

25,992

BKF cartridges

912

AO-2.5RTM

10,994

BKF cartridges

740

PTM-3

8,880

BKF cartridges

1,965

PTAB-2.5

23,580

BKF cartridges

0

PTAB-2.5

2

PBS-100 bomb

1

AO-25-33

3

Total

6,862

 

186,349

 

The exact number of Bulgaria’s stockpile of cluster munitions has changed several times since 2012, when it first reported a stockpile of 6,874 cluster munitions and 149,398 submunitions.[14] That number increased in 2013 to 6,909 cluster munitions and 157,664 submunitions after additional stocks were discovered.[15] Bulgaria reported another 15,497 submunitions in 2014.[16] Bulgaria changed its classifications of certain types of cluster munitions and amended the number stockpiled in June 2018 following an inventory check by the Ministry of Defense and reported that it would retain eight 9N123K cluster munitions and 400 submunitions that were previously scheduled for stockpile destruction.[17]

The cluster munition stocks have been decommissioned and separated from the munitions that are retained for operational use and “the entire Bulgarian stock of cluster munitions is marked for destruction.”[18]

Bulgaria has also reported on cluster munition stocks transferred from Cyprus and Slovenia to Bulgaria for destruction (see section on foreign stocks below).

Stockpile destruction

Under Article 3 of the Convention on Cluster Munitions, Bulgaria is required to destroy all its stockpiled cluster munitions as soon as possible, but not later than 1 October 2019.

Bulgaria submitted a request to States Parties in April 2019 to extend this stockpile destruction deadline by another 18 months, until 1 April 2021. It intends to complete destruction of the stockpile in 2020 and undertake verification of the completion in the first quarter of 2021.[19]

Bulgaria is the first State Party to request an extension to its stockpile destruction deadline, which the convention’s States Parties will decide on during the Ninth Meeting of States Parties in September 2019.

Bulgaria initially hoped to begin stockpile destruction in 2011.[20] It has engaged in an extensive process to prepare the destruction plan and budget.[21] The 2015 implementing legislation required the government establish a commission to solicit and process tenders from companies to destroy the cluster munitions.[22] Bulgaria reported in 2017 that it was exploring “new options” for destroying the stockpiled cluster munitions after the suspension six months earlier of a program by the Bulgarian armed forces, managed by the NATO Support and Procurement Agency.[23]

During 2018, 35 cluster munitions stockpiled by of Bulgaria were destroyed at a facility in Italy: 25 RBK 250-275 AO-1SCh cluster bombs and 10 RBK 250 PTAB-2.5M cluster bombs.

Stockpile and destruction of foreign stocks

State Party Slovenia transferred 41,825 PAT-794 submunitions to Bulgaria in 2011 for the purposes of stockpile destruction.[24] Slovenia reported in June 2018 that the cluster munitions in Bulgaria had been “effectively and irreversibly destroyed” according to written reports from the contractor EXPAL Bulgaria and on-site inspections.[25] Bulgaria’s June 2018 Article 7 transparency report confirmed, “The Slovenian submunitions, declared in previous periods, have been destroyed.”[26]

Signatory Cyprus transferred 3,760 4.2-inch OF projectiles used for the GRM-20 mortar system and 2,559 M20G submunitions to Bulgaria in 2014 for the purposes of destruction.[27] According to Bulgaria’s 2019 transparency report a total of 2,416 of the 4.2-inch OF projectiles were destroyed by private company EXPAL Bulgaria in 2018.[28] The report indicated that the remaining 1,344 4.2-inch OF projectiles would be destroyed by 1 October 2019.

Retention

Bulgaria reported in 2018 that it would retain eight 9N123K cluster munitions containing 400 9N24 submunitions for training purposes.[29] Its May 2019 transparency report lists the eight cluster munitions and 400 submunitions as retained for “training purposes of the Bulgarian Armed Forces.”[30]

However, in September 2018, Bulgaria told States Parties that the “entire stock of cluster munitions is marked for destruction” as it “has no intention to retain cluster munitions or explosive submunitions for training purposes, permitted under Article 3 of the Convention.”[31] Previously, in 2014 and 2015, Bulgaria stated that it did not intend to retain any cluster munitions for training or research purposes.[32]



[1] Letter Ref. 258 from Maria Pavlova, Ministry of Foreign Affairs, to Mary Wareham, Arms Division, Human Rights Watch (HRW), 18 May 2016.

[2] The sanctions, which apply to activities involving cluster munitions and landmines, are generally greater than those for other weapons, including explosives, firearms, and ammunition. The amendments impose prison sentences of: one to 15 years for developing, producing, storing, or transferring these weapons; two to 15 years for failing to take relevant safety measures or transferring the weapons to persons under the age of 18; and three to 12 years for acquiring, possessing, or transferring the weapons without a permit. Law on the Criminal Code, Decree No. 182, Law No. 47/2016, adopted 8 June 2016.

[3] The inter-ministerial working group is chaired by the Ministry of Foreign Affairs and includes representatives of the Ministry of Defense, Ministry of Interior, and Ministry of Economy, Energy, and Tourism.

[4] The annual updated reports cover the previous calendar year, while the initial Article 7 report provided on 27 March 2012 covered an unspecified period. Convention on Cluster Munitions Article 7 Report, Form B, 30 April 2019.

[5]Implementation of the Convention on Cluster Munitions,” UNGA Resolution 73/54, 5 December 2018.

[6] Statement of Bulgaria, UNGA First Committee on Disarmament and International Security, New York, 23 October 2014.

[7]Situation of human rights in the Syrian Arab Republic,” UNGA Resolution 73/182, 17 December 2018.Bulgaria voted in favor of similar resolutions in 2013–2017.

[8] Letter from Dr. Petio Petev, Ministry of Foreign Affairs, 25 February 2009. According to the letter, “The prohibitions stipulated in Article 1 of the Convention create an obligation for the States Parties not to allow the transit, transfer or stockpiling on their territories of cluster munitions…regardless of whether these munitions are foreign or nationally owned.”

[9] Letter from Dr. Petev, Ministry of Foreign Affairs, 25 February 2009.

[10] For details on Bulgaria’s cluster munition policy and practice through early 2009, see HRW and Landmine Action, Banning Cluster Munitions: Government Policy and Practice (Ottawa: Mines Action Canada, May 2009), pp. 46–48.

[12] Email from Lachezara Stoeva, Chief Expert, Arms Control and International Security Department, NATO and International Security Directorate, Ministry of Foreign Affairs, 17 May 2008. According to Jane’s Information Group, the Vazov Engineering Plant was associated with the production of 122mm Gradrockets, which included a variant that contains 15 dual-purpose improved conventional munitions (DPICM) submunitions. See, Terry J. Gander and Charles Q. Cutshaw, eds., Jane’s Ammunition Handbook 2001–2002 (Surrey, UK: Jane’s Information Group Limited, 2001), p. 625.

[13] Convention on Cluster Munitions Article 7 Report, Form B, 14 May 2019; Convention on Cluster Munitions Article 7 Report, Form B, 27 June 2018; letter from Vassil Petkov, Ministry of Foreign Affairs, to Mary Wareham, HRW, 13 May 2014. The BFK cartridges containing PTM-3 antivehicle mines, the RBK bombs containing ZAB series incendiary submunitions, and the PBS-100 munition do not appear to be covered by the Convention on Cluster Munitions as the first contains antivehicle mines, the second contains incendiary submunitions, and the third contains three submunitions that each weigh more than 20 kilograms. The “PBS-100” is a previously unknown type of cluster munition that contains three submunitions each weighing 27 kilograms.

[14] Convention on Cluster Munitions Article 7 Report, Form B, 27 March 2012.

[15] The additional stockpiled cluster munitions were identified in March 2013 by a private company, EMCO Ltd. and scheduled for destruction: 25 RBK-250-275 cluster bombs containing AO-1SCh submunitions and 10 RBK-250 cluster bombs containing PTAB-2.5M submunitions. Email from Dragomir Zakov, Permanent Mission of Bulgaria to the UN in Geneva, 22 May 2013; and Convention on Cluster Munitions Article 7 Report, Form J, 27 March 2012.

[16] In its April 2014 Article 7 transparency report Bulgaria reported possessing: 150 AO-1SCh submunitions (previously no information available); 42 fewer PTAB-2.5M submunitions; 5,337 additional ZAB-2.5SM; 5,676 additional AO-2.5RT; and 4,376 additional PTAB-2.5 submunitions.

[18] Statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 8 April 2014. In April 2012, it made a similar statement to the Monitor that “All cluster munitions have been decommissioned, separated from munitions retained for operational use and marked for the purpose of destruction.” Letter Ref. 55-76g-47 from Plamen Bonchev, Ministry of Foreign Affairs, to Mary Wareham, HRW, 23 April 2012. Bulgaria reiterated this in a letter to the Monitor in 2016. See, Letter Ref. 258 from Maria Pavlova, Ministry of Foreign Affairs, to Mary Wareham, HRW, 18 May 2016.

[20] In April 2011, Bulgaria stated that stockpile destruction was scheduled to begin in 2011, with the aim of completing the destruction of the majority of its stockpile by 2013. It said that the eight cluster submunitions held by the land forces would be destroyed in 2016, when their shelf-life expires. Letter Ref. 04-06-98 from Plamen Bonchev, Ministry of Foreign Affairs, Sofia, 11 April 2011. A year later an official informed the Monitor that the stockpile destruction did not prove possible due to “austerity in the State budget in 2011.” Letter Ref. 55-76g-47 from Plamen Bonchev, Ministry of Foreign Affairs, to Mary Wareham, HRW, 23 April 2012.

[21] In April 2012, Bulgaria said that it was developing aplan for the destruction of stocks including a timeline and budget. In April 2013, Bulgaria announced that it was in “the final stages” of preparing the stockpile destruction plan. In May 2013, a Bulgarian official informed the Monitor that the draft stockpile destruction plan “has been elaborated” and the plans “financial parameters…await further clarification.” In April 2014, Bulgaria stated that the national plan was “close to being finalized” and said that physical destruction would begin after adoption of the plan. In May 2014, Bulgaria informed the Monitor that the plan is “undergoing an interagency review” and promised more information after its adoption. See, Letter Ref. 55-76g-47 from Plamen Bonchev, Ministry of Foreign Affairs, to Mary Wareham, HRW, 23 April 2012; statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 17 April 2013. Notes by the CMC; email from Dragomir Zakov, Permanent Mission of Bulgaria to the UN in Geneva, 22 May 2013; statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 8 April 2014; and letter from Vassil Petkov, Ministry of Foreign Affairs, to Mary Wareham, HRW, 13 May 2014.

[22] Letter Ref. 258 from Maria Pavlova, Ministry of Foreign Affairs, to Mary Wareham, HRW, 18 May 2016.

[23] It reported that this was because the contractor EXPAL Bulgaria, “could not meet the criteria for authorization under the Bulgarian legislation.” Convention on Cluster Munitions Article 7 Report, Form B, 29 June 2017.

[24] Convention on Cluster Munitions Article 7 Report, Form B, 18 May 2016. In 2017, Bulgaria reported, “As it was previously declared, due to wrong interpretation of the CCM provisions by the private company ‘EXPAL BULGARIA’ JSC some 41,825 submunitions, owned by the Armed Forces of the Republic of Slovenia, are stockpiled in the company’s warehouses. In January 2017, a Slovenian delegation inspected the warehouses of ‘EXPAL BULGARIA’ JSC and the remaining submunitions. ‘EXPAL BULGARIA’ JSC has undertaken the necessary procedure to obtain a permission to destroy these cluster submunitions.” Convention on Cluster Munitions Article 7 Report, Form B, 29 June 2017.

[25] Convention on Cluster Munitions Article 7 Report, Form B, 6 June 2018. See also, email from Jelka Travnik, Deputy Permanent Representative, Permanent Mission of the Republic of Slovenia to the UN in Geneva, to Mary Wareham, HRW, 11 June 2018.

[27] Ibid. Bulgaria included the stockpiled cluster munitions received from Cyprus in its own national stockpile in this report.

[31] Statement of Bulgaria, Convention on Cluster Munitions Eighth Meeting of States Parties, Geneva, 3 September 2018.

[32] In April and May 2014, Bulgaria said it did not intend to retain cluster munitions or explosive submunitions for training purposes. Statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 8 April 2014; and letter from Vassil Petkov, Ministry of Foreign Affairs, to Mary Wareham, HRW, 13 May 2014. At the 2015 Review Conference, Bulgaria confirmed that it “has no intention to retain cluster munitions or explosive submunitions for training purposes, permitted under article 3 of the Convention.” See, statement of Bulgaria, Convention on Cluster Munitions First Review Conference, Dubrovnik, 7 September 2015.


Mine Ban Policy

Last updated: 13 November 2019

Policy

The Republic of Bulgaria signed the Mine Ban Treaty on 3 December 1997 and ratified it on 4 September 1998, becoming a State Party on 1 March 1999. On 24 November 2015, Bulgaria adopted implementation legislation, which entered into force on 8 December 2015.[1] The legislation defines key terms and “regulates the conditions and procedures for transfer, transportation and destruction of APLMs and the control over these activities.” In June 2016, Bulgaria also amended its Penal Code to establish sanctions for violating the provisions of the implementation law.[2]

Bulgaria consistently submits annual Article 7 transparency reports. Bulgaria also regularly attends meetings of the treaty, including the Seventeenth Meeting of States Parties in Geneva in November 2018 and the Third Review Conference in Maputo in June 2014. However, Bulgaria did not attend the intersessional meetings in May 2019.

Bulgaria served as co-rapporteur and then co-chair of the Standing Committee on Stockpile Destruction from 2008–2010. Additionally, Bulgaria served on the Committee on General Status and Operation of the Convention in 2012–2013.

Bulgaria is party to the Convention on Conventional Weapons and its Amended Protocol II on landmines and Protocol V on explosive remnants of war.

Production, transfer, use, and stockpiling

Bulgaria ceased antipersonnel mine export in 1996 and production in 1998. Previously, Bulgarian mines were reported to have been used in Cambodia and other countries. In April 2002, Bulgaria reported that production facilities were permanently decommissioned.[3]

Bulgaria finished destruction of its stockpile of 885,872 antipersonnel mines in December 2000, well ahead of its treaty-mandated destruction deadline of 1 March 2003. Bulgaria initially retained 10,446 mines for training purposes, but this was reduced to 3,672 by 31 March 2010. In 2019, Bulgaria reported 3,318 mines as retained for training and research.[4] In its 2010 Mine Ban Treaty Article 7 report, Bulgaria also reported possessing 171,050 antipersonnel mines transferred to Bulgaria by Greece for the purpose of destruction.[5] On 1 October 2014, an explosion at the Midzhur munitions destruction plant owned by VIDEX in Gorni Lom, Bulgaria killed 15 workers and halted Greece’s stockpile destruction program.[6] The Bulgarian President, Rosen Plevneliev, attributed the Midzhur plant blast to “arrogant non-observance” of rules of procedure.[7] In November 2018, Bulgaria announced that the remaining antipersonnel mines were transferred back to Greece.[8]

Bulgaria initially reported 72 minefields on its territory, which had been laid during the Cold War. Clearance of all antipersonnel mines in mined areas was completed by 31 October 1999, well in advance of its 1 March 2009 clearance deadline.



[1] Law on the Implementation of the Convention on Cluster Munitions and the Convention on the Prohibition of the Use, Stockpiling, Production and Transfer of Anti-Personnel Mines and on their Destruction (Mine Ban Treaty). Mine Ban Treaty Article 7 Report, Form A, 2019.

[2] Articles 337–339 of the Penal Code.

[3] Karen Bartosik, “Landmine Monitor,” Spot On (English-language Bulgarian periodical), Issue 22, October 2002, p. 20.

[5] Mine Ban Treaty Article 7 Report (for the period 31 March 2009 to 31 March 2010), Form D.

[6] Bulgaria stated that 6,986 mines were being destroyed at the Midzhur plant in Gorni Lom at the time of the explosion. A total of 130 of the mines had been recovered but were not going to be transferred due to their damaged condition. The remaining 6,856 mines were either destroyed during the initial plant explosion or are still scattered throughout the processing facility, and these mines will be destroyed upon discovery according to Bulgaria’s statement. Statement of Bulgaria, Mine Ban Treaty Intersessional Meetings, Geneva, June 2015.

[7] Stoyan Nenov and Tsvetelia Tsolova, “Blasts kill 15 people at Bulgaria explosives plant,” Reuters, 2 October 2015.

[8] Statement of Bulgaria, Mine Ban Treaty Seventeenth Meeting of States Parties, Geneva, 29 November 2019.