August 12, 2025 – As of 1 May 2025, stricter rules apply in Bulgaria for the transport of goods listed as high fiscal risk goods (HFRG). This measure has been introduced to combat tax fraud and affects Dutch companies transporting goods to, through, or from Bulgaria.

What are high fiscal risk goods?

The HFRG list contains goods that the Bulgarian government considers to carry an increased risk of tax fraud. It covers a broad range of products, including agricultural and food products, construction materials, and vehicle parts.

Common categories include meat, dairy, and vegetable oils, but products such as coffee, nuts, fruit, and certain vegetables are also included. Within these groups, both finished products and raw materials used in the food industry are often covered. The complete list of HFRG goods is maintained by the Bulgarian authorities. As the list can be updated, it is important to regularly check whether your goods fall under it.

Mandatory registration before transport

For every shipment involving HFRG goods, it is mandatory to obtain a registration number (UNP or USN) in advance. This unique number is requested by the Bulgarian client from the NRA (Bulgarian tax authority). In most cases, this will be the sender or the recipient. Without a registration number, the transport cannot take place.

Checks during transport

During transport, Bulgarian authorities may stop the vehicle to check whether the correct registration number has been obtained, whether the goods match the declared information, and whether all accompanying documents have been correctly completed. In some cases, a seal or other control device may be applied to the vehicle. This may only be removed by the authorised authorities, usually upon arrival at the unloading location.

If discrepancies are found between the declared and actual goods, the tax authority may require a security deposit to be paid. This can amount to up to 30% of the cargo’s value. The freight may only be unloaded after this has been paid.

What can you do?

To avoid delays, fines, and disputes during transit, good preparation is essential:

1. Check whether your goods fall under the HFRG regulation
–   The full list is here available in Bulgarian.

2. Make clear arrangements with carriers and freight forwarders
–   Who will register the shipment in the Bulgarian e-transport platform?
–   Is the carrier equipped with the required GPS tracking?
–   Who will monitor route progress and reporting obligations?

3. Ensure timely and correct registration of shipments
–   Provide a full description of the goods (including HS codes)
–   Give accurate sender and recipient information
–   Register departure time, planned route, vehicle details, and driver information

Make clear agreements with all parties involved to prevent delays, fines, or standstills at border checks. Unsure about the right preparation? Feel free to contact us!