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Bulgarian model for regulating the trade in plant material for medicinal and other purposes

D. Lange & M. Mladenova

Dr. Dagmar Lange, Jahnstr. 16, 71642 Ludwigsburg, Germany
Magdalena Mladenova, Bulgaria Agribusiness Centre, 3-A, 165 Street, Complex
Izgreva, 1797 Sofia, Bulgaria


The global importance of plants as a source of botanicals is enormous, a trade amounting to more than 300 thousand tonnes, and valued at more than US$ 800 million annually in 1995 and 1996 (Lange & Schippmann, 1997). Plants are the basis of a wide variety of goods ranging from food, phytopharmaceuticals, herbal remedies, perfumes, cosmetics, colouring agents, detergents, liqueurs, varnishes, fireworks, to detergents. The plant species dealt with in this paper are used in all the aforementioned categories, with the exception of food. Since, the term medicinal plant does not include all these different uses, the term botanical drug species is used by preference in this paper.

South-eastern and Eastern European countries are a rich source for botanical drug species within Europe. In a preliminary study by one of the authors (Lange,1996a), it was shown that these countries exported a total of about 11,000 tonnes annually to Germany during the period from 1991 to 1994 . This represented 30% of the average annual import to Germany, and 75% of all botanical drugs imported from the European countries. Within Eastern and South-eastern European countries, Bulgaria is the leading source country for Germany for botanical drugs, followed by Poland, Hungary, and Albania (Lange, 1996a). With regard to the global trade in botanical drugs, Bulgaria is eighth in the list of the leading countries of export, following after China, India, Germany, Singapore, Egypt, Chile, and the USA (Table 1). Thus trade in botanical drugs involving Bulgaria was the subject of an investigation conducted on behalf of the Federal Agency for Nature Conservation in Bonn and carried out in cooperation with the two authors.

Trade Structure in Bulgaria

Prior to the collapse of communism, botanical drugs were traded almost exclusively in Bulgaria by two state-controlled united cooperative enterprises. These were Bilkocoop and Bulgarcoop, which exported through their own foreign trade bureaus. During the last few years, the structure of trade has changed considerably. While the Bulgarian state has lost its monopoly, the two cooperative enterprises continue to operate and still remain the market leader. At the end of 1996, Bilkocoop became a part of Bulgarcoop. In addition, 50-60 smaller, private, mostly family-owned companies have become involved in the collecting, purchasing and export of botanical drugs.

Bilkocoop is also involved in the production of herbal and medicinal teas, at a volume of around 130 million tea-bags in 1995 mainly for the Bulgarian market. This company is also producing herbal bath additives, as well as different kinds of merchandise for the food industry, and supplies for pharmaceutical companies and pharmacies. Bilkocoop purchases the botanical drugs through other cooperatives distributed throughout the country, helps in cultivation of the plants, provides seeds and planting material, and guarantees to buy the agreed harvest.


Table 1: The 12 world leading countries of export of commodity group 1211. The countries are listed according to average export volumes corresponding to the years 1992-1995.
Country of export 
lUSD 1,000]

Sources: (i) UNCTAD COMTRADE database, International Trade Centre, Geneva, Switzerland; ii) Foreign Trade Statistics of Bulgaria 1988-1996, National Statistic Institute, Sofia, Bulgaria (MLADENOVA, 1996).

The new private companies purchase a limited range of botanical drugs, mostly for export. Wild botanical drugs are collected by many people, mainly living in villages, who have a traditional knowledge of them. For many of the retired people in the country, collecting is a source of additional income, generally done sporadically and not according to a prior agreement. Because there is strong competition between the private companies and the cooperative enterprises a Private Herb Exchange has been established with similar tasks to those of Bilkocoop. It is also organising courses for the collectors.

Botanical drugs are sold mainly to larger wholesale drug traders abroad, sometimes backed by drug acencies, whereas direct sales from exporters to retail traders are an exception.

Volumes and Values

Every year more than 10,000 tonnes (estimated at 13,000-14,000 tonnes in 1995 and 1996) of botanical drugs are collected, purchased and processed in Bulgaria ( Mladenova, 1996). Around 60-70% of the material is exported, while the other 30-40% remain in the country for the production of phytopharmaceuticals, herbal teas and spices.

From 1987 to 1995, the export of botanical drugs amounted to an average of 6,600 tonnes annually (Table 2). The annual export fluctuates considerably in this period: between 1987 and 1989 it was around 5,000 tonnes, dropping to about 3,300 tonnes in 1990, probably because of the political changes in that time. In 1991 a sharp increase to more than 10,000 tonnes can be observed, however according to Mladenova (pers. comm.) it is likely, that this high volume is not correct. This is also indicated by the very high difference between the Bulgarian and the German Foreign Trade Statistics in 1991, amounting to 4,900 tonnes, which is much higher than in the following years (see below). Reasons can be again the changes in politics, and the change-over to the Harmonized System (HS, see below) in 1992. In 1993 5,100 tonnes have been exported. From 1994 onwards the export increased by far until 10,600 tonnes in 1995.

Germany is by far the most important purchaser for botanical drugs from Bulgaria. According to Bulgarian Foreign Trade Statistics, Germany imported on average more than 4,500 tonnes annually from 1987 to 1995 (table 2), that is on average 67% of the total Bulgarian export, with a distinct peak in 1991, when the import exceeded 8,500 tonnes. The German Foreign Trade Statistics reveals much lower import volumes from Bulgaria into Germany in the period 1991-1995 (Lange, 1996b), which are about 3,600 tonnes in 1991 (difference: 4,900 tonnes), 3,500 tonnes in 1992 (difference: 850 tonnes), 2,600 tonnes in 1993 (difference: 550 tonnes), 4,900 tonnes in 1994 (difference: 1,200 tonnes), and 6,472 tonnes in 1995 (difference: 500 tonnes).

In the list of the most important trading partners with Bulgaria in botanical drugs, Germany is followed by France, Spain, and Italy with imports of only 350-400 tonnes on average: that is less than 1/10th of Germany’s imports. The only extra-European country with a noteworthy import of Bulgarian botanical drugs is the USA, which imports around 200 tonnes on average per annuum.

Little information is available on the export volumes of individual botanical drugs. The exports of botanical drugs are summarized mainly in one tariff code. From 1992 onwards, this has been Commodity Code No. 1211.90.00 , equivalent to the Harmonized System (HS), commonly accepted between GATT (General Agreement on Tariffs and Trade) members, which Bulgaria entered in 1996. As Bulgaria revealed individual trade figures for selected drugs until 1991, these are available for rose hips, linden flowers and leaves, peppermint, and chamomile (Mladenova, 1996). A further source for individual export volumes is the German Foreign Trade Statistics. Thus, in the German Utilisation Tariff some botanical drugs of high commercial value have been monitored separately since 1993 under the heading 1211.90. These include pyrethrum, mint, linden flowers and leaves, verbena, wild marjoram, and sage (Lange, 1996a). Wild thyme or serpolet, obtained from Thymus serpyllum s.l. is also monitored separately under the heading of spices (commodity group 0910.40.11). Additional information could be collected on the import/export of botanical drugs through a survey of traders.

According to the above sources, the most commonly exported commodity is mint, obtainted from peppermint Mentha x piperita, with the export to Germany increasing from 840 tonnes in 1993 to 2,350 tonnes in 1995. Other important products are linden flowers and leaves, obtained from small-leaved lime Tilia cordata, large-leaved lime T. platyphyllos, and silver lime T. argentea to be exported to Germany on an annual average of 280 tonnes since 1993, rose hips, collected from dog-rose Rosa canina, which have been exported from Bulgaria between 1987 and 1991 on an average of about 220 tonnes annually (Mladenova, 1996). Wild thyme or serpolet is exported from Bulgaria to Germany on average 18 tonnes annually from 1992-1995. Other botanical drugs exported in noteworthy volumes annually, but without exact trade figures, are common nettle (Urtica dioica), common balm (Melissa officinalis), valerian (Valeriana officinalis), lavender-blossom (Lavandula angustifolia subsp. angustifolia), St. John’s Wort (Hypericum perforatum), savory (Satureja hortensis), chamomile (Matricaria recutita), black elder-blossom (Sambucus nigra), yarrow (Achillea millefolium), betony (Stachys officinalis), common dandelion (Taraxacum offininalis), and the fruits of hawthorn (Crataegus spp.), bilberry (Vaccinium myrtillus), common juniper (Juniperus communis), horse-chestnut (Aesculus hippocastanum), and dwarf elder (Sambucus ebulus).

The value of the exported botanical drugs amounted to USD 9.4 million in 1992, and increased from USD 7 million in 1993 to USD 15.4 million in 1995. This correspondend to an average export price of USD 1.40 per kilogram.

Compared to exports, the imported volume of botanical drugs into Bulgaria is very low. From 1992-1995 Bulgaria imported on average 400 tonnes annually. Altogether, imports came from 13 different countries during this period. However, in 1992 (520 tonnes) and 1993 (300 tonnes) these came mainly from Turkey, and in 1994 (240 tonnes) and 1995 (350 tonnes) from Macedonia. The value of the imported merchandise fluctuates between USD 0,7 and 1 million.

There is no information available on the individual botanical drugs that are imported. But according to Mladenova (1996), in the last 2-3 years rose hips have been imported, mainly from Russia, Albania, and Macedonia. These imports have been destined mainly for re-exports. In addition, some botanical drugs, which are not native to or cultivated in Bulgaria, or are not available in sufficient quantities are imported. These include the flower calyces of red sorrel, for example, which are a component of herbal teas, and the herb of periwinkle (Catharanthus roseus) produced in phytopharmaceuticals. Other botanical drugs, such as the bark of alder buckthorn (Frangula alnus) and the leaves of bearberry (Arctostaphylos uva-ursi) have been imported for the Bulgarian market, since the collection of and trade in these have been subject to restrictions. This is also true for the flowers of sandy immortelles (Helichrysum arenarium).

Botanical Drug Supply

Botanical drug species are one of the natural resources of Bulgaria (Hardalova, 1997), and collecting them has a long tradition. Around 750 plant species, that is 21% of the 3,567 vascular plants of Bulgaria, are used in folk medicine, in the food and pharmaceutical industry, and for export. Of these 200 to 300 species are the most commonly used (Hardalova, 1997). More than two thirds are known to be exported to Germany (Lange, 1996b). Most of the species are collected in the wild, and an estimated 20-25% are produced from cultivation (Hardalova, 1997). Important cultivated plant species are peppermint (Mentha x piperita), rose hips (Rosa canina), valerian (Valeriana officinalis), chamomile (Matricaria recutita), marsh-mallow (Althaea officinalis), and milk thistle (Silybum marianum).

Table 2: Exports volumes from Bulgaria for commodity group 1211. The countries are
listed according to average export volumes corresponding to the years 1987 -1995, arranged according to average volume.
of export 
1987  1988  1989  1990  1991  1992  1993  1994  1995
Germany  3,185 3,949 2,569 2,233 8,586 4,334 3,134 6.135 6,975
Spain  235  206  958  299  147  440  317  493  472
Frauce  321  416  830  382  307  301  357  271  364
Italy  317  223  154  189  219  423  425  754  620
USA  161  181  122  59  129  163  271  304  532
Switzerland  140  84  32  44  138  220  248  229  271
Austria 67  116  179  126  ill  229  91  145  69
Greece  10 20 10 - 91 52 30 284 399
Sweden  190  133  190  20  276  36  - - -
Poland - - - - - 4 10 209 483
Hungary - - - - - - 47 50 209 
Netherlands  88 37  - - 38  27  52
Belgium  - 87 - - - 43 21 44
Turkey  - - - - - 53 19 10 35 
Argentina - - - - - 48 45à-à-     
Macedonia  - - - - - - 36 24
Ireland  - - - - - - 21 - 43 
Czech Repub. - - - - 27 15 4 -
England - - - - - - - 31 11 
Finland - - - - - - - 30- 12 
Yugoslavia - - 38 - - 2 - -
Croatia  - - - - - - - - 20 
Russia - - - - - - - - 19 
Jordan - - - - - - - - 15 
Romania - - - - - - - -
Georgia - - - - - - - -
Slovenia - - - - - - - -
Total  4,710  5,454  5,110 3,358  10,042  6,440  5,139  9,052  10.601

Volumes are given in tonnes.
Source: Foreign Trade Statistics of Bulgaria 1988
1996, National Statistic Institute, Sofia, Bulgaria (MLADENOVA, 1996).

As a result of the high percentage of wild-collected plant material that is used and the huge volumes collected every year, there is a high risk of damaging, or even destroying the natural resources of Bulgaria’s botanical drug species. According to Hardalova (1997) 20% of wild botanical drug species are weeds or occur in rural habitats, and are not threatened by collection. However, for the remaining species a permanent means of control, or even restictive measures, are necessary.


The trade in, to and from Bulgaria in botanical drugs is governed by legislation at national and international levels. Those species protected internationally are covered in the Convention on International Trade with Endangered Species of Wild Flora and Fauna (CITES). Those protected nationally are listed (i) in the Bulgarian Ordinance on the Conservation of Species, and/or (ii) are subject to legal restrictions and ordinances concerning control of utilization and trade of the botanical drug species. In addition, botanical drug species can be protected through habitat protection.

While no species used as a source for a botanical drug is listed in CITES Appendix I, eight species are listed in CITES Appendix II: snowdrop (Galanthus nivalis), pyramidal orchid (Anacamptis pyramidalis), butterfly orchid (Orchis papilionacea), globose orchid (O. globosa), military orchid (O. militaris), Provence orchid (O. provincialis), Cyclamen coum, and ivy-leaved sowbread (C. hederifolium).

The Bulgarian Species Conservation Legislation came into force on 21.7.1989 (Ordinance No. 718, dated 20.6.1989). This ordinance updated the first list of protected plant species published in 1961, and covers 330 plant species. Criteria for inclusion in this listing are varied, including over-exploitation, limited natural distribution, habitat destruction and difficulties with dissemination (Hardalova, 1997). For all the 330 plant species, cutting, collecting, picking, uprooting, trading, exporting them, either as fresh or as dried material is stricty forbidden. Additionally, it is prohibited to harvest their seeds, bulbs, or other reproductive organs. Amongst the 330 plant species, thirty-seven species are used for medicinal or related purposes. Examples for protected species with a narrow distribution in Bulgaria are: Round-leaved sundew (Drosera rotundifolia), liquorice (Glycyrrhiza glabra), Rhapontic rhubarb (Rheum rhaponticum), common rue (Ruta graveolens), sideritis (mountain tea) (Sideritis scardica), and yew (Taxus baccata). A species which is protected because of over-exploitation is yellow gentian (Gentiana lutea), for example, and species who are are affected by habitat destruction are sweet-flag (Acorus calamus), bogbean (Menyanthes trifoliata), and different Orchis-species (Hardalova, 1997).

According to Hardalova (1997) a total of 820 ha of conservation sites exist in Bulgaria for the protection of botanical drug species around 50 protected areas. They have been established to protect the habitat of summer snowflake (Leucojum aestivum), peony (Paeonia peregrina), liquorice (Glycyrrhiza glabra), snowdrop (Galanthus nivalis), elecampane (Inula helenium), and cowslip (Primula veris), inter alia. The collection of these species is forbidden. In addition to this in-situ conservation, about 150 botanical drug species are preserved in collections of living plants and seeds of the Academy of Sciences.

Trade in botanical drugs in Bulgaria is subject to different laws and regulations established in 1991 under the Law for the Protection of the Environment (Mladenova, 1996). In addition to taxes and duties, import/export turnover taxes, excise taxes, any customs duties, possible countervailing duties, regulations concerning required documents for imports/exports, or registration and transaction charges, there are some interesting legal requirements, which are described below:
(A) Where botanical drug species occur in the forests, they come under the jurisdiction of the Forestry Committee, and their use is subject to forestry laws, which the Forestry Administration is responsible for applying (Hardalova, 1997). In the forests, wild-collecting is seen as a business and thus fees have to be paid for using the so-called forestry by-products. The rates are species-specific and are paid in leva per kilogram (Decree No. 202 dated 26.9.1994, published in Official Gazette No. 82, 1994), but charges will only apply when forestry resources are exploited commercially. For example, the charge for 1 kg of the roots of cowslip (Primula veris) is 4 leva, and for leaves of ribwort plantain (Plantago lanceolata) 2.50 leva must be paid. For further examples see table 3.

Table 3: Examples for botanical drugs collected in the forests in Bulgaria and the charges to be paid for their commercial use. - Source: MLADENOVA (1996).
Common name  Scientific name Plant part used Charge [leva/kg] 
Hazel Coryllus avellana bark  3,00 
Hazel Coryllus avellana leaves 1,50 
Bilberry Vaccinium myrtillus leaves 2,50 
Bilberry Vaccinium myrtillus fruits 6,00 
Wild strawberry Fragaria vesca leaves 2,50 
Wild thyme, serpolet Thymus serpyllum herb 1,50 
St. John's Wort Hypericum perforatum herb 1,50 
Hawthorn Cratuegus monogyna fruits 3,00 
Black elder Sambucus nigra flowers  1,50 
Orange mullein Verbascum phlomoides leaves 1,50 
Cowslip Primula veris flowers 2,00 
Cowslip Primula veris roots  4,00 
Dog-rose Rosa canina fruits  3,00 
Large-leaved lime Tilia platyphyllos flowers 2,00 
Mistletoe Viscum album leaves  1,50 
Ribwort plantain Plantago lanceolata leaves 2,50 
Common dandelion Taraxacum officinalis herb  l,50 
Common dandelion Taraxacam officinalis roots 4,00 

Explanation: Herb, i.e. the aerial part of the plant. - 1 DM = 1,000 leva (1.7.1997), 1USD = 1,800 lava.

(B) Several fees are collected by the Ministry of Environment for the National Fund for Protection of the Environment. Those are related to the granting of import/export certificates (lastest Decree No. 132 dated 31.3.1997, published in Official Gazette No. 28, 3.3.1997). Because of the high rate of inflation, the system of setting charges changed in 1997 from a fixed amount (for 1996) to fees determined as percentage of the minimal monthly wage in Bulgaria (April 1997: 29,920 leva, May 1997: 41,290 leva). The following are charges for the export of each wild-collected species: (i) to export a plant species not covered by any regulations 5% (1996: 50 levas), for those which are subject to species conservation regulations 10% (1996: 200 levas); (ii) the rate for the export of a wild plant species that has been cultivated is 2%; (iii) the fee for operating a purchasing centre for botanical drug species, inter alia, amounts to 30% (1996: 500 leva); (iv) to export a Bulgarian species included in CITES, the charge is 45% (1996: 1,000 levas), and to export, import or re-export a foreign species included in CITES the charge is 75% (1996: 1,500 levas); (v) For the allocation of quotas for using threatened biological resources 10% (1996: 200 levas) for each species is charged (see paragraph C).

(C) Since 1991, wild-harvesting of, and trade in, threatened botanical drug species are subject to restrictions and prohibitions, issued by the Ministry of the Environment. Several ordinances regulate the gathering, trade and export of selected wild botanical drug species, with the aim of protecting them and their natural habitats, to re-establish wild populations, and to encourage cultivation of some species (Ordinance No. RD-48, dated 15.2.1995, published in Official Gazette No. 21, 28.2.1995, added by Ordinance No. RD-50, dated 17.2.1995, published in Official Gazette No. 22, 7.3.1995, revised with Ordinance No. RD-76, dated 28.2.1996, published in Continent, dated 8.3.1996, and Ordinance No. RD-97, dated 28.3.1997). These ordinances establish restrictions and prohibitions on collecting, trading and exporting botanical drug species:

(i) At least 14 plant species are totally prohibited from being collected from the wild, traded and processed for commercial purposes (table 4). Thus, the species, marsh-mallow (Althaea officinalis), madder (Rubia tinctorium), valerian (Valeriana officinalis), inter alia, must be cultivated for commercial use.

(ii) The collecting of 23 other plant species from the wild, their processing, and trade are subject to restrictions. A quota-system was established for these species. The volumes of each species (according to plant parts used) which can be collected from their natural habitats in the different Bulgarian districts, and which are allowed to be exported have been published in the Official Gazette every spring since 1992, drawn up by specialists of the Ministry of Environment, and the Institute of Botany. The list of plant species affected by this order has been modified slightly, but the volumes which are allowed to be gathered vary considerably from year to year according to the species and the region. Table 4 lists the species concerned, table 5 shows examples for quotas for botanical drugs allowed to be collected by region in 1997.

(iii) The export of six additional botanical drugs collected from the wild is strictly prohibited. These include the herb (aerial parts) of summer snowflake (Leucojum aestivum), the bark of alder buckthorn (Frangula alnus), and the roots of cowslip (Primula veris)(table 4).

The following is an illustration of the quota-system:

In 1995, and 1996, quotas for 18 botanical drugs obtained from 15 of the 23 plant species mentioned in table 4, column 2, have been set up, whereas in 1997, quotas for 19 botanical drugs obtained from 15 plant species have been published. Collecting of the remaining botanical drugs, viz. plant species from the wild, as well as trading or processing them for commercial purposes has been prohibited.

Example 1: In 1995 and 1996 it was totally prohibited to collect the roots of deadly nightshade (Atropa bella-donna) from the wild, however 2,550 kg are allowed in 1997 (table 5).

Example 2: The herb of asarabacca (Asarum europaeum) was not permitted to be obtained from the wild in 1995, but in 1996 (500 kg) and 1997 (50 kg, see table 5).

This ordinance includes an annual periodic ban on the exploitation of regional populations. It was forbidden to collect any wild plant species involved in the districts Pazardgik, Silistra, and Smolian in 1995, the districts Dobrich, Kardjali, and Jambol in 1996, and the districts Lovech, and again Dobrich, Kardjali, Silistra, and Smolian in 1997.

From year to year the total and the regional quotas for each species have changed.

Example 1: In 1996 and 1997 collection of 500 kg Herba Adonidis (aerial part of yellow pheasant’s eye Adonis vernalis) in Razgrad district was allowed (table 5), where it was forbidden in 1995.

Example 2: Wild-collecting of a total of 3,700 kg of Folia Belladonnae, obtained from the leaves of deadly nightshade (Atropa bella-donna), was allowed in 1995, and the whole volume was allowed to be exported, whereas in 1996 and 1997 6,050 kg respectively 4,320 kg were allowed to be wild-harvested. Only half of the volume, however, was destined for export (table 5).

Example 3: In 1995 it was forbidden to collect the leaves of bearberry (Arctostaphylos uva-ursi) from natural habitats. In 1996 it was allowed to collect 800 kg in Pazardgik district only, and in 1997 the quota is 2,500 kg shared to Blagoevgrad district 1,000 kg, and to Pazardjk 1,500 kg.

Example 4: In 1995 the quota for the flowers of cowslip (Primula veris) was 6,300 kg. In 1996 it increased up to 12,000 kg, and dropped in 1997 to 8,670 kg (table 5).

The Ministry of Environment, the Forestry Committee, and the local Authorities are responsible for administering the control. The quota-system described is based on scientific research done by specialists of the Ministry of Environment in cooperation with the Institute of Botany of the Bulgarian Academy of Science, and the National Centre of Phytotherapy and Popular Medicine. Regional Environmental Inspectorates approved by regional Forestry Administrations are responsible for allocation of the quantities of the wild-harvested botanical drugs in each country. Purchaser of these plants must make their applications by the end of the previous year. The botanical drugs affected by these ordinances must to be accompanied by documents of origin up to the end user. Those obtained from cultivation, are not subject to prohibitions and restrictions. However, this must be substantiated by documents from the Municpality, State Forestries, and regional Environmental Inspectorates.

For controlling the legal requirements of the ordinances mentioned, the purchasers of the botanical drugs involved are obliged (i) to register with the regional Environmental Inspectorates, (ii) to ensure complete access to the controlling authorities, and (iii) to keep the necessary documentation for all transactions concerning these botanical drugs.

Table 4: Botanical drug species affected by the prohibitions and restrictions on collecting, trading and exporting.
Total prohibition of collecting, trade, and processing from the wild for commercial purposes  Restrictions on collecting, trade, , and processing from the wild, for commercial purposes (quota system)  Prohibition of export 
Flowering plants    
Althaea officinalis Adonis vernalis Atropa bella-donna (roots) 
Artemisia santonicam  Alchemilla vulgaris s.1. Berberis vulgaris (bark) 
Cnicus benedictus Allium ursinum  Leucojum arstivum (herb) 
Convallaria majalis Angelica pancicii1 Paeonia peregrina (tuber) 
Glaucium flavum Arctostaphylos uva-ursi Primula veris (roots) 
Helichrysum arenariarn Artemisia alba Frangula alaus (bark) 
Inula helenium  Asarum europaeum  Stachys officinalis (roots) 
Orchis spp. Atropa bella-donna  
Origanum vulgare subsp. hirtum2 Berberis vulgaris  
Rubia tinctorium Carlina acanthifolia  
Salvia tomentosa3 Gallum odoratum  
Valeriana officinalis Hyssopus officinalis  
  Leucojum aestivum  
  Paeonia peregrina  
  Primula veris  
  Frangula alaus  
  Ruscus aculentus  
  Sedum acre  
  Stachys officinalis  
  Vinca minor  
Conifers Juniperus oxycedrus  
Aspleniarn trichomanes
Asplenium scolopendrium    
Lichens Cetraria islandica  
Algae Cystoseira barbata  

The nomenclature of the vascular plants is according to Flora Europaea (Tutin, T.G. & al., 1968-1993).1 =A. sylvestris; 2 = o heracleoticum; 3 =S. officinalis;
  Source: Ordinance No. RD-48 of 1995, Ordinance No. RD-50 of 1995, Ordinance No. RD-76 of 1996, and Ordinance No. RD-97 of 1997.

When comparing the quota-tables of 1995-1997, it could be stated that the overall volume of botanical drugs, affected by the ordinances mentioned, fluctuates only between 73.5 tonnes in 1995, 77 tonnes in 1996, and around 62.4 tonnes in 1997. However the share of the botanical drugs directed to the internal Bulgarian market only, increased from 5% in 1995 to 28% in 1997.

Table 5: Examples for quotas for botanical drugs allowed to be collected by region in
1997. Source: Ordinance No. RD-97, dated 28.3.1997.
District  Asarum europa-
Primula veris
 Atropa  bella- 
taphylos uva-ursi 
Adonis vernalis

Part of plant used  herb  flowers  roots  leaves Roots  leaves Herb
Blagoevgrad  800  15  300  1000 -
Varna - - - - - - 700
V. Tirnova - 500 - 300 - - 50 
Vidin - - - 700 - -
Vratza - 800 - 200 - -
Gabrovo 50  500  100  500  50  - 50
Kustendil - 400 - - - -
Montana - 700 - 500 - - 100 
Pazardjik - - - - 1000 1500
Pernik - 500 - - - - 600 
Pleven - 300 - 300 - -
Plovdiv - - - - - -
Razgrad - 500 - - - - 500 
Ruse - 500 - - - - 200
Sliven - 800 200 500 - -
Sofia - 20 - 20 - - -
St. Zagora - 800 200 1,000 1,500 - -
Targoviste - 250 - - - - 500 
Schumen - 800 - - - - 500 
Jambol - 500 200 - - -
Total [kg)  50  8,670  715  4,320  2,550  2,500 3,200
Internal mar
ket only [kg] 
50  1,000  715  2,000 2,550 2,500  500


Demand for certain botanical drugs is expected to increase (Mladenova, 1996). This is not only true for cultivated species, like peppermint (Mentha x piperita), common balm (Melissa officinalis), or chamomile (Matricaria recutita), but also for some wild species used as raw material for herbal and medicinal teas, as well as for the production in Bulgaria of phytopharmaceuticals and of cosmetics, such as creams and shampoos.

The laws and regulations concerning wild-collection of some of the highly-sought-after botanical drug species, will enforce an increase in their cultivation. Further, according to Mladenova (1996), the share of the cultivated plant material to be exported will increase in the future.

The Bulgarian model for controlling and protecting botanical drug species includes not only species and habitat conservation measurements, but also legislation on the collection and trade of some selected species. In this respect, it is unique. However legislation and regulation alone are insufficient to achieve the sustainable use of the species concerned. Additional administrative, technological and educational measures to the purchasers, growers or collectors will need to be established (Hardalova , 1997). An unintended, however, negative consequence of the legislation concerning control of utilization and trade of the botanical drug species could be that botanical drug traders and producers of herbal teas, phytopharmaceuticals or cosmetics will get around Bulgaria’s law by purchasing raw materials abroad. As stated above, this has been observed for some species during recent years. As a result, these species could become scarce in other countries. Consequently, it will be necessary to ensure that imports of those particular botanical drugs are also subject to control, or even to restrictions, in cooperation with the source countries. Thus, there is a need to develop guidelines for the sustainable exploitation of wild plant resources, including requirements for the qualifications of those involved in the trade.

Further scientific research is warranted on cultivation, development of population status due to habitat change and exploitation, type of harvesting, and the demands of the plant species in the market. All of these measures should be taken into account with regard to the expected increased demand for botanical drug species within the coming years.


Both authors would like to express their gratitude to staff members of the Scientific Authorities of CITES, Bonn, namely Natalie Hofbauer, Uwe Schippmann and Hajo Schmitz-Kretschmer, and of the Agribusiness Centre of the Institute of Trade, especially to Milena Nalbantova doing the translation from Bulgarian to English, and Desisslava Georgieva for the data processing. Also, we would like to thank Rayna Hardalova from the Ministry of Environment who supported the project with her knowledge and provided the official documents.

Hardalova, R. (1997): The use of medicinal plants in Bulgaria and their protection. - Proceedings of Planta Europa, 2-8 September 1995, Hyères, France 184-187.

Lange, D. (1996a): Untersuchungen zum Heilpflanzenhandel in Deutschland. Ein Beitrag zum internationalen Artenschutz. - 130 pp.; Bundesamt fur Naturschutz, Bonn.

Lange, D. (1996b): Der Handel mit drogenliefernden Pflanzenarten zwischen Deutschland und Bulgarien. - In: D. Lange, Analyse der Gefährdung von Heilpflanzen durch den internationalen Handel: 50-110. - unpublished report for the Federal Agency for Nature Conservation in Bonn, Germany, 1996.

Lange, D. & Schippmann, U. (1997). Trade Survey of Medicinal Plants in Germany A Contribution to International Plant Species Conservation. Bonn-Bad Godesberg (Bundesamt für Naturschutz) 128pp. Annexes (pp.I-XVI).

Mladenova, M. (1996): The trade in medicinal plants between Germany and Bulgaria. - Bulgarian Agri-business Centre; Sofia (unpublished report).

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