Bulgaria

Cluster Munition Ban Policy

Last updated: 05 September 2023

Summary: State Party Bulgaria ratified the Convention on Cluster Munitions on 6 April 2011 and enacted implementing legislation in 2015. Bulgaria has attended every meeting of the convention and voted in favor of a key United Nations General Assembly (UNGA) resolution promoting the convention in December 2022.

Bulgaria has never used or produced cluster munitions, but it acquired them and once held a stockpile of 6,905 cluster munitions and 190,919 submunitions. Bulgaria completed destruction of the stockpile in June 2023, in advance of its 31 December 2023 deadline. Bulgaria is retaining six cluster munitions and 300 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’s implementing legislation for both the Convention on Cluster Munitions and the Mine Ban Treaty took effect on 8 December 2015.[1] Its Penal Code was amended in June 2016 to provide sanctions for violations of the Convention on Cluster Munitions.[2] A National Authority established in January 2012 coordinates Bulgaria’s implementation of and compliance with the convention.[3]

Bulgaria submitted an initial Article 7 transparency report for the Convention on Cluster Munitions on 27 March 2012. Since then, it has provided annual updated reports, most recently on 28 April 2023.[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 participated in every meeting of the convention, most recently the Tenth Meeting of States Parties in August–September 2022 and the intersessional meetings in May 2022, both held in Geneva, where it provided updates on its stockpile destruction progress.

Bulgaria voted in favor of a key UNGA resolution promoting implementation of the Convention on Cluster Munitions in December 2022.[5] It has voted in favor of the annual UNGA resolution promoting the convention since it was first introduced in 2015.

In August 2022, Bulgaria condemned Russia’s use of cluster munitions in Ukraine, calling the use “a horrific reminder of the devastating impact and the high human costs this highly inhumane weapon is causing in terms of civil casualties.”[6]

In the past, Bulgaria condemned the use of cluster munitions in Syria and voted in favor of UNGA and Human Rights Council resolutions expressing outrage at this cluster munition use.[7]

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

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 formally confirmed in 2012 that there “are no programmes for the conversion or decommissioning of production facilities for cluster munitions in the Republic of Bulgaria.”[11] Previously, in 2008, a Ministry of Foreign Affairs official stated that “Bulgaria does not and has not produced any type of cluster munitions.”[12]

Bulgaria acquired a stockpile of cluster munitions from the Soviet Union.

Stockpiling

Bulgaria possessed a stockpile of 6,905 cluster munitions and 190,919 submunitions when the convention entered into force for the country, as listed in the following table:

 

Cluster munitions stockpiled by Bulgaria (as of October 2011)[13]

Type of munition

Quantity

Type of submunition

Quantity

RBK-250-275 bomb

214

AO-1SCh

32,100

RBK-250-275 bomb

25

AO-2.5SCh

3,750

RBK-250 bomb

60

ZAB-2.5SM

2,880

RBK-250 bomb

488

PTAB-2.5M

20,496

RBK-500 bomb

201

AO-2.5RT

12,060

RBK-500 bomb

86

ZAB-2.5SM

25,542

N/A

0

ZAB-2.5SM

2,939

RBK-500 bomb

36

ShOAB-0.5M

19,656

RBK-500 bomb

3

ShOAB-0.5

1,695

BKF cartridges

1,647

AO-2.5RT

19,764

BKF cartridges

1,431

AO-2.5RTM

17,172

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

9N123K missile

8

9N24

400

Total

6,905

N/A

190,919

Note: N/A=not applicable.

 

The number of stockpiled cluster munitions has changed several times since 2012, when Bulgaria reported stockpiling 6,874 cluster munitions and 149,398 submunitions.[14] This increased in 2013 to 6,909 cluster munitions and 157,664 submunitions, after additional stocks were discovered.[15] An additional 15,497 submunitions were reported in 2014.[16]

 

Stockpile destruction

Under Article 3 of the Convention on Cluster Munitions, Bulgaria was required to destroy all its stockpiled cluster munitions as soon as possible, but not later than 31 December 2023.

In July 2023, Bulgaria’s Ministry of Defence informed the Monitor that the last of Bulgaria’s stockpiled cluster munitions were destroyed on 28 June 2023, six months in advance of the deadline.[17]

Bulgaria’s initial 1 October 2019 deadline to destroy its cluster munition stocks was first extended to 1 October 2020.[18] A second extension further extended the deadline to 1 October 2022.[19] At the Tenth Meeting of States Parties in August–September 2022, Bulgaria was granted a third extension to its stockpile destruction deadline, until 31 December 2023.[20] At the time, Bulgaria assured States Parties of its “dedication and commitment” to meeting the new deadline, stating it was on schedule to do so and committed to providing regular updates on progress.[21]

Bulgaria destroyed 35 cluster munitions in 2018; 35 cluster munitions and 4,170 submunitions in 2019; and 1,991 cluster munitions and 38,234 submunitions in 2020.[22] An explosion at a stockpile destruction facility on 21 December 2020 resulted in the suspension of the destruction process and no cluster munition stocks were destroyed during 2021.

In December 2019, Bulgaria amended legislation to allow it to transport its last cluster munition stocks outside of the country for destruction. By the end of 2022, all remaining cluster munition stocks once held by the Bulgarian Armed Forces had been transferred to Italy for destruction by an Italian company, Esplodenti Sabino Srl, at its facilities in Casalbordino.[23]

The stockpile destruction resumed at the facility in Italy in February 2022 and scaled up rapidly, with 1,303 cluster munitions and 51,285 submunitions destroyed by the end 2022. During the first half of 2023, Bulgaria destroyed 2,285 cluster munitions and 47,529 submunitions.[24]

Bulgaria’s Ministry of Defence expects to receive the signed Certificates of Destruction from the Italian company by the end of July 2023, and then will deliver its Declaration of Completion to the convention’s Implementation Support Unit (ISU).[25] Bulgaria will formally announce the completion of its stockpile destruction at the Eleventh Meeting of States Parties in September 2023.

 

Destruction of foreign stockpiles

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

State Party Slovenia transferred 41,825 PAT-794 submunitions to Bulgaria in 2011.[26] In June 2018, Slovenia reported that the cluster munitions were “effectively and irreversibly destroyed” by contractor EXPAL Bulgaria.[27] Bulgaria’s 2018 Article 7 transparency report confirmed that “The Slovenian submunitions, declared in previous periods, have been destroyed.”[28]

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.[29] 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.[30]

 

Retention

Bulgaria reported retaining a total of six 9N123K cluster munitions and 300 9N24 submunitions for research and training purposes, as of the end of 2022, as permitted under Article 3 of the Convention on Cluster Munitions.[31] The Bulgarian Armed Forces consumed one cluster munition and 50 submunitions during training in June 2021.

Bulgaria had initially said that it had “no intention to retain cluster munitions or explosive submunitions for training purposes.”[32]



[1] Letter from Maria Pavlova, Ministry of Foreign Affairs, to Mary Wareham, Advocacy Director, 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] An interministerial 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. Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 28 April 2023. See, Convention on Cluster Munitions Article 7 Database.

[5]Implementation of the Convention on Cluster Munitions,” UNGA Resolution 77/79, 7 December 2022.

[6] Statement of Bulgaria, Convention on Cluster Munitions Tenth Meeting of States Parties, Geneva, 30 August 2022.

[7] Statement of Bulgaria, UNGA First Committee on Disarmament and International Security, New York, 23 October 2014; and “Situation of human rights in the Syrian Arab Republic,” UNGA Resolution 75/193, 16 December 2020. Bulgaria voted in favor of similar UNGA resolutions on Syria in 2013–2019. See also, “Situation of human rights in the Syrian Arab Republic,” Human Rights Council Resolution 43/28, 22 June 2020.

[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. Petio 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.

[11] Bulgaria Convention on Cluster Munitions Article 7 Report, Form E, 27 March 2012.

[12] Email from Lachezara Stoeva, Chief Expert, Arms Control and International Security Department, North Atlantic Treaty Organization (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 munition (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.

[13] Bulgaria Convention on Cluster Munitions Third Article 3 deadline Extension Request, April 2022; Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 29 April 2022; and 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 munitions 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] Bulgaria 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 United Nations (UN) in Geneva, 22 May 2013; and Bulgaria Convention on Cluster Munitions Article 7 Report, Form J, 27 March 2012.

[16] In its April 2014 Article 7 report, Bulgaria reported possessing 150 AO-1SCh submunitions (which were previously unreported); 42 fewer PTAB-2.5M submunitions; 5,337 additional ZAB-2.5SM submunitions; 5,676 additional AO-2.5RT submunitions; and 4,376 additional PTAB-2.5 submunitions.

[17] Email to Mary Wareham, HRW, from Stoyan N. Karastoyanov, Chief Expert, European Union (EU) and International Organizations Department, Defence Policy and Planning Directorate, Ministry of Defence, 7 July 2023.

[18] Bulgaria Convention on Cluster Munitions Article 3 deadline Extension Request, January 2019. The deadline extension was granted at the Ninth Meeting of States Parties in September 2019. See also, Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 30 April 2019.

[19] Bulgaria Convention on Cluster Munitions Second Article 3 deadline Extension Request, March 2020. The extension was agreed by silent procedure in February 2021.

[21] Statement of Bulgaria, Convention on Cluster Munitions Tenth Meeting of States Parties, Geneva, 1 September 2022.

[22] Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 25 April 2020; and Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 5 May 2021.

[23]  Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 28 April 2023.

[24] In the second half of 2023, Bulgaria destroyed: 46 RBK 250-275 AO-1SCh bombs and 6,900 submunitions; 120 RBK 500 AO-2.5RT bombs and 7,200 submunitions; 15 RBK 500 SHOAB-O.5M bombs and 8,190 submunitions; 672 BKF AO-2.5RT bombs and 8,064 submunitions; 1,431 BKF AO-2.5RTM bombs and 17,172 submunitions; and one RBS 100 AO-25-33 bomb and three submunitions. Email to Mary Wareham, HRW, from Stoyan N. Karastoyanov, Chief Expert, EU and International Organizations Department, Defence Policy and Planning Directorate, Ministry of Defence, 10 July 2023.

[25] Email to Mary Wareham, HRW, from Stoyan N. Karastoyanov, Chief Expert, EU and International Organizations Department, Defence Policy and Planning Directorate, Ministry of Defence, 7 July 2023.

[26] Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 18 May 2016. In 2017, Bulgaria reported that, “As it was previously declared, due to wrong interpretation of the CCM [Convention on Cluster Munitions] 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.” See, Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 29 June 2017.

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

[28] Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 27 June 2018.

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

[30] Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 30 April 2019; and Bulgaria Convention on Cluster Munitions Article 7 Report, Form B, 25 April 2020.

[31] Bulgaria Convention on Cluster Munitions Article 7 Report, Form C, 28 April 2023. In 2018, Bulgaria reported that it would retain eight cluster munitions and 400 submunitions for research and training purposes that were previously scheduled for destruction. It later reduced the amount to be retained. Bulgaria Convention on Cluster Munitions Article 7 Report, Forms B and C, 27 June 2018.

[32] Statement of Bulgaria, Convention on Cluster Munitions Eighth Meeting of States Parties, Geneva, 3 September 2018. At the First Review Conference in 2015, Bulgaria also stated 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.