Head of Healthcare and Life Sciences at Schoenherr Elena Todorova and AECO Law Partner Emre Atayilmaz analyze how officials are testing different playbooks to blunt food-price pressures in their jurisdictions.
Strong Policy Toolkits
“Bulgaria introduced the ‘Euro Law’ which freezes prices on basic foodstuffs during the dual currency display period, between August 8, 2025, and August 8, 2026,” Todorova begins. The law prohibits traders from raising prices without an objective economic justification. “The National Revenue Agency and Commission for Consumer Protection received broad enforcement powers to monitor pricing practices; large retailers, with over BGN 10 million turnover, must publish prices online in machine-readable format.” However, inflation remains “highly concentrated on goods produced in Bulgaria,” while imports do not rise in price, Todorova outlines.
As for Turkiye, Atayilmaz reports that “the Ministry of Trade has intensified nationwide retail inspections and initiated a mobile app, called ‘Unfair Price Increase Complaints’ app, for consumer feedback, in addition to other reporting channels.” As he puts it, with the inflation rate jumping to 33.3% year-on-year in September of 2025, the consumer price index rising to 36.1% year-on-year, and food and drink prices growing to 4.6% month-on-month, the app was “introduced as an effective tool among others to fight the rise in food prices.”
Authorities have long used targeted trade measures, which “have in fact been in place for many years, particularly on staple products such as dairy products and vegetable oil,” Atayilmaz adds. “We have seen some restrictions lifted in recent years, but price increases have led to their reimposition in many instances, such as those on meat exports.”
Caps, Subsidies, and Scrutiny
While Bulgaria implemented price caps, Todorova elaborates that “traders cannot increase prices unless justified by objective economic factors, including: raw material costs, electricity and natural gas prices, fuel costs, minimum wage increases, tax burden changes, and force majeure. No direct subsidies were mentioned [in the euro law]; the approach focuses on regulatory price controls and enhanced monitoring with extensive reporting requirements for retailers.”
“Traditionally, Turkiye has been using various measures, such as tax cuts and support schemes,” Atayilmaz chimes in. “On the tax side, VAT on basic food was cut from 8% to 1% by presidential decree in 2022, a measure designed to cushion retail prices on an expansive basket of staples. As a consumer support, subsidized bread has long been provided by local government-owned entities, and this remains an important subsidy.” Additionally, Atayilmaz reports that the Turkish Government has planned to increase agricultural support payments, “including base per-decare payments and add-ons tied to crop plans and practices, to temper cost pressures that feed into food prices. In parallel, the Turkish Government’s five-year agricultural priorities largely emphasize food security, reduced dependence on imported inputs, and technology-enabled production planning, while the policy pillars are intended to stabilize staple supplies and farm-to-fork costs.”
Further, Atayilmaz explains that Turkiye has been using regulatory transparency and enforcement tools. “The Ministry of Trade recently amended the Price Tag Regulation requiring restaurants and similar establishments to electronically transmit price-list data to the ministry, giving consumers digital access to menu prices and enabling tighter supervisory analytics.” Moreover, the Unfair Price Assessment Board, “comprising senior officials and consumer/business representatives,” may inspect cases of “excessive/unjust price increases and stockpiling, with administrative monetary fines available where infringements are found.”
On-the-Ground Effects
“Before implementation, the mere discussion of price freezing prompted food producers and traders to pre-emptively increase prices as a ‘defensive reaction’,” Todorova says. “Retailers face extensive compliance burdens, including detailed reporting on pricing methods and costs, with commercial confidentiality protections waived. The Deputy Governor of the Bulgarian National Bank acknowledged that Bulgaria ‘will end up with higher inflation than in the euro area, but still within manageable limits.’”
In Turkiye, for consumers, “enforcement and complaint tools have led to visible administrative actions,” Atayilmaz says. “Nevertheless, the environment remains challenging for retailers. Also, administrative scrutiny yields an unpredictable environment regarding shelf price movements and their regulatory outcomes.” On the other hand, for producers, “subsidies and trade restrictions eased some of the risks; however, operational risks have been heightened in recent years, including animal health events, climate stress, and logistics shocks due to geopolitical events. Turkiye is diversifying its gas supply via new LNG deals, and these may have a positive effect on lowering costs in the long term, and their effects on food prices indirectly.”
Legal Frictions and Risks
“The policy announcement itself triggered pre-emptive price increases before implementation,” Todorova says for Bulgaria. “Government actions contradicted anti-inflation goals: Budget execution failures, including missing EU Recovery Plan conditions and VAT collections at half the projected increase, created revenue shortfalls undermining policy credibility. The extensive monitoring powers requiring commercially sensitive information may create legal disputes.” Additionally, according to her, the “scheduled minimum wage increase from BGN 1,077 to BGN 1,200 provides an immediate exemption, potentially undermining the freeze from the outset. We do expect even further wage increases, because the local employment market is dictated by the increased demand for qualified employees.”
“In a high inflation/high-interest rate environment, large players with superior financing ride out shocks better than SMEs,” Atayilmaz adds. “That asymmetry is already pushing consolidation through acquisitions, exclusivities, or tighter vertical integration, to stabilize supply and margins. Such developments triggered concerns on merger control and competition law.”
Atayilmaz also reports that the “growing geopolitical crisis in the Middle East exacerbated the food prices and logistics costs unexpectedly. Notably, due to conflicts, maritime insurance premiums have risen, materially impeding logistics budgeting and forward planning.” Furthermore, Atayilmaz indicates that “contractual relationships are being reshaped by heightened price volatility, prompting rewrites across the food chain, particularly in raw-material and packaging procurement. Some parties are adopting commodity-indexed pricing with precise adjustment mechanisms. More common practices include foreign exchange indexation, banded escalation and de-escalation clauses, and stricter definitions of force majeure events.”
Takeaways for Policymakers
Amid differing philosophies, practical lessons are emphasized more than macro-planning.
As per Todorova, “Bulgaria’s experience offers critical lessons: implementing price controls to prevent anticipatory price hikes shows that price controls alone cannot address the local structural inflation drivers; avoiding implementing freezes when predictable cost increases are scheduled, as this creates immediate exemptions undermining effectiveness; requiring detailed public price reporting from competitors opens the door to certain competition-related issues.”
Based on experience in Turkiye, Atayilmaz stresses that “using consumer complaint systems with visible outcomes strengthens deterrence and increases public awareness; limited and targeted import/export restrictions can be a tool for addressing price fluctuations, without using blunt price freezes; curbing speculative behavior via digital gatekeeping methods may be considered.”
This article was originally published in Issue 12.9 of the CEE Legal Matters Magazine. If you would like to receive a hard copy of the magazine, you can subscribe here.
