Bulgaria

Cluster Munition Ban Policy

Last updated: 17 November 2020

Ten-Year Review: State Party Bulgaria ratified the convention on 6 April 2011 and enacted implementing legislation in November 2015. Bulgaria has attended every meeting of the convention and voted in favor of a key annual United Nations (UN) resolution promoting the convention in December 2019.

Bulgaria reports that it has never used or produced cluster munitions. Bulgaria has reported stockpiling 6,862 cluster munitions and 186,349 submunitions. It began the process of destroying the stockpile in 2019, destroying a total of 35 cluster munitions and 4,170 submunitions. Bulgaria is the first State Party to have received an extension to its stockpile destruction deadline, and Bulgaria requested in 2020 to extend it further, to 1 October 2022. Bulgaria has reported that it will retain seven cluster munitions and 350 submunitions for research and training purposes.

Policy

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

Bulgaria has adopted specific legislation to guide its implementation of both the Convention on Cluster Munitions and the Mine Ban Treaty, which took effect on 8 December 2015.[1] Bulgaria’s Penal Code was amended in June 2016 to establish sanctions for violations of the convention.[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 in April 2020.[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, as well as the convention’s First Review Conference in Dubrovnik, Croatia in 2015 and intersessional meetings held in 2011–2015. At the convention’s Ninth Meeting of States Parties in Geneva in September 2019, Bulgaria became the first State Party to be granted an extension to its stockpile destruction deadline.

Bulgaria voted in favor of a UN General Assembly (UNGA) resolution promoting implementation of the convention in December 2019.[5] It has voted in favor of the annual UNGA resolution promoting the convention since it was first introduced in 2015.

Bulgaria has firmly condemned new use of cluster munitions in Syria.[6] It has voted in favor of UNGA resolutions expressing outrage at the use of cluster munitions in Syria, most recently in December 2019.[7] Bulgaria has also voted in favor of similar Human Rights Council resolutions condemning use of cluster munitions in Syria, most recently in June 2020.[8]

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.[9] 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.”[10] 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.[11]

Bulgaria has reported that there “are no programmes for the conversion or decommissioning of production facilities for cluster munitions in the Republic of Bulgaria.”[12] In 2008, a Ministry of Foreign Affairs official stated that “Bulgaria does not and has not produced any type of cluster munitions.”[13]

Stockpiling and destruction

Bulgaria has reported a stockpile of 6,862 cluster munitions and 186,349 submunitions that it inherited from the break-up of the Soviet Union, as detailed in the following table:

Cluster munitions stockpiled by Bulgaria (as of 31 December 2018)[14]

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

N/A

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

Note:N/A=not applicable.

The exact number of Bulgaria’s stockpiled cluster munitions has changed several times since 2012, when it first reported a stockpile of 6,874 cluster munitions and 149,398 submunitions.[15] That number increased in 2013 to 6,909 cluster munitions and 157,664 submunitions after additional stocks were discovered.[16] Bulgaria reported another 15,497 submunitions in 2014.[17] The number of stockpiled cluster munitions was amended again in June 2018 following an inventory check by the Ministry of Defense, which reported that it would retain eight 9N123K cluster munitions and 400 submunitions previously scheduled for stockpile destruction.[18] The cluster munitions have been decommissioned and separated from the operational stockpile.[19]

Bulgaria has also reported on cluster munition stocks transferred by 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 was originally required to destroy all its stockpiled cluster munitions as soon as possible, but not later than 1 October 2019. States Parties extended Bulgaria’s stockpile destruction deadline by another 18 months in September 2019, until 1 April 2021.[20] Bulgaria submitted another extension request in April 2020, to further extend that deadline until 1 October 2022.[21]

During 2019, 35 cluster munitions and 4,170 submunitions once stockpiled by Bulgaria were destroyed at a facility in Italy: 25 RBK 250-275 AO-1SCh cluster bombs and 3,750 submunitions were destroyed on 8 April, while 10 RBK 250 PTAB-2.5M cluster bombs and 420 submunitions were destroyed on 15 April.[22] This marked the start of Bulgaria’s destruction of cluster munition stocks after a long planning process that began in 2011.[23] The Monitor previously recorded that the first cluster munition destruction had occurred in 2018, based on Bulgaria’s 2019 transparency report.[24]

Under Bulgaria’s 2015 implementation law, the government established a commission to solicit and process tenders from companies to destroy cluster munitions.[25] In July 2019, Bulgaria signed a contract with Italian company Esplodenti Sabino Srl. to destroy cluster munition stocks held by the Bulgarian Armed Forces.[26] Bulgaria adopted a legislative amendment in December 2019 approving the transportation of cluster munitions outside its territory for the purpose of stockpile destruction. According to Bulgaria’s second Article 3 extension request, the “transportation and destruction activities” are set for April 2020, while Bulgaria intends to complete the destruction of its stockpile by April 2022 and then complete the verification process by 1 October 2022.[27]

Destruction of foreign stockpiles

Two states have transferred their cluster munitions to Bulgaria for the purposes of stockpile destruction.

State Party Slovenia transferred 41,825 PAT-794 submunitions to Bulgaria in 2011.[28] In June 2018, Slovenia reported that the cluster munitions were “effectively and irreversibly destroyed” by the contractor EXPAL Bulgaria.[29] Bulgaria’s Article 7 transparency report confirmed that “The Slovenian submunitions, declared in previous periods, have been destroyed.”[30]

Signatory Cyprus transferred 3,760 4.2-inch OF projectiles used for the GRM-20 mortar system containing 2,559 M20G submunitions to Bulgaria in 2014.[31] A total of 2,416 of the projectiles were destroyed by private company EXPAL Bulgaria at a facility in Bulgaria in 2018, while the remaining 1,344 4.2-inch OF projectiles were destroyed in August 2019.[32]

Retention

As of 31 December 2019, Bulgaria retained seven 9N123K cluster munitions and 350 9N24 submunitions for research and training purposes.[33] Bulgaria consumed one cluster munition and 50 submunitions during 2019.

Previously, in September 2018, Bulgaria had told States Parties that its “entire stock of cluster munitions” was “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.”[34]



[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. See Articles 337–339 of the 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 Bulgaria’s 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,” UN General Assembly (UNGA) Resolution 74/62, 12 December 2019.

[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 74/169, 18 December 2019. Bulgaria voted in favor of similar resolutions in 2013–2018.

[8]Situation of human rights in the Syrian Arab Republic,” Human Rights Council Resolution 43/28, 22 June 2020.

[9] 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.”

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

[11] 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.

[13] 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 Grad rockets, 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: Jane’s Information Group, 2001), p. 625.

[14] 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.

[16] 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.

[17] 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.

[19] Statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 8 April 2014. In April 2012, Bulgaria 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] Bulgaria is the first State Party to request an extension to its stockpile destruction deadline, which was granted by States Parties during the Ninth Meeting of States Parties in September 2019. Convention on Cluster Munitions Article 7 Report, Form B, 30 April 2019.

[23] In April 2011, Bulgaria stated that stockpile destruction would begin in 2011 and said the goal was to complete destruction of a majority of the stocks by 2013. However, in 2012, Bulgaria said that it was developing a plan to destroy the cluster munition stocks, including timeline and budget. In 2013, Bulgaria said the stockpile destruction plan was in “the final stages” of preparation. In 2014, Bulgaria said the plan was “close to being finalized.” See, Letter Ref. 04-06-98 from Plamen Bonchev, Ministry of Foreign Affairs, 11 April 2011; 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; and statement of Bulgaria, Convention on Cluster Munitions Intersessional Meetings, Geneva, 8 April 2014.

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

[27] Ibid.

[28] 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.

[29] 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.

[31] Ibid. Bulgaria included the stockpiled cluster munitions received from Cyprus in its own national stockpile in its 2018 Article 7 report.

[33] Convention on Cluster Munitions Article 7 Report, Form C, 25 April 2020. Bulgaria also stated in 2014 and 2015 that it did not intend to retain any cluster munitions for training or research purposes. 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 First 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, Croatia, 7 September 2015.

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


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.