Working Document Wms 04.06.2019 - Clean Corr. 05.06.2019

Twinning Project
Support to Waste Management Policy
National Waste Management Strategy

including National Waste Management
Plan for the period 2019-2024
NWMS including NWMP 2019-2024 version from

4.3.2019 (interim version for internal use)
Twinning Project
Project partners:
Ministry of Environmental Protection
1, Omladinskih brigada str., 11070 New Belgrade
Republic of Serbia
Umweltbundesamt
Environment Agency Austria
Spittelauer Lände 5
1090 Vienna
AUSTRIA
and
Naturväradsverket,
Swedish Environmental Protection Agency
Valhallavägen 195
SE-106 48 Stockholm
and
Lietuvos Respublikos aplinkos ministerija,
Ministry of Environmental Protection, Lithuania
A. Jakšto g. 4, LT-01105 Vilnius
Disclaimer:
This publication has been produced with the financial assistance of the European Union. The
contents of this publication are the sole responsibility of the Twinning Partners, Serbian
Ministry of Agriculture and Environmental Protection and Environment Agency Austria, and
can under no circumstances be regarded as reflecting the position of the European Union.
Cover photographs: ©iStockphoto.com/olaf herschbach, © Thomas Reimer – Fotolia.com, © patrkslezak – Fotolia.com
Approvals
Name Date Signature
Prepared by
Approved by MS Project Leader Brigitte Karigl
Approval by BC Project Leader Aleksandar Vesić

Twinning Project
Twinning Project
Project title Support to Waste Management Policy
Project number SR13/IPA/EN/04 16

Project duration August 2017 – August 2019
Project budget 1,500,000 €
Beneficiary country
Republic of Serbia
(BC)
Commissioned/financ European Commission, Instrument for Pre-accession Assistance (IPA)
ed by of the European Union
Ministry of Environmental Protection
Umweltbundesamt - Environment Agency Austria
and
Project partners Naturväradsverket, Environmental Protection Agency, Sweden
and
Lietuvos Respublikos aplinkos ministerija,

Ministry of Environmental Protection, Lithuania
BC project leader Aleksandar Vesić
BC counterpart Luka Starčević
MS project leader Brigitte Karigl
The overall objective is to assist Serbian administration to effectively
Overall project
manage EU integration and pre-accession assistance in order to
objectives
speed up preparations for the EU membership
The project purpose is the development and improvement of waste
management system, by completing the strategic and legislative
Project purpose
framework of required sector specific planning documents in line
with the EU Acquis.
TABLE OF CONTENTS Waste Management Strategy 2019-2024
TABLE OF CONTENTS
WASTE MANAGEMENT STRATEGY
THE NATIONAL WASTE MANAGEMENT STRATEGY.......................10
1 INTRODUCTION.......................................................................11
1.1 Role of the Waste Management Strategy and Waste
Management Plan...............................................................................12
1.2 Territory and population....................................................................12
1.3 Special waste streams and other relevant waste
streams............................................................................................... 13
1.4 Definitions........................................................................................... 13
2 ANALYSIS AND ASSESSMENT OF CURRENT

WASTE MANAGEMENT STATUS...........................................19
2.1 Current institutional framework for waste
management.......................................................................................19
2.2 Current legal framework and strategies for waste
management.......................................................................................24
2.2.1 EU policy and legislation in the area of waste
management........................................................................................ 24
2.2.2 National policy and legislation in the area of waste
management........................................................................................ 35
2.2.3 Other national strategic documents......................................................45
2.2.4 Status of transposition..........................................................................46
2.3 Current waste generation..................................................................48
2.4 Current status of relevant waste streams........................................51
2.4.1 Municipal waste....................................................................................51
2.4.2 Construction and demolition waste including excavated
soils...................................................................................................... 58
2.4.3 Secondary waste (waste from waste treatment)..................................61
2.4.4 Mining wastes......................................................................................63
2.4.5 Sewage sludge.....................................................................................64
2.4.6 Vegetal wastes, animal by-products.....................................................64
2.4.7 Hazardous wastes................................................................................66
2.5 Current status of special waste streams.........................................69
2.5.1 Packaging waste..................................................................................69
2.5.2 End-of-Life vehicles..............................................................................75
2.5.3 Waste mineral oil..................................................................................78
2.5.4 Waste tires........................................................................................... 80
2.5.5 Waste electrical and electronic equipment...........................................82
2.5.6 Waste mercury-containing fluorescent tubes.......................................85
2.5.7 Used batteries and accumulators.........................................................86
2.5.8 PCB waste........................................................................................... 88
2.5.9 Other POPs waste...............................................................................92
2.5.10 Medical waste......................................................................................98

2.5.11 Pharmaceutical waste........................................................................102

2.5.12 Waste generated in Titanium Dioxide production...............................105
2.6 Types and quantities of waste imported / exported......................105
2.7 Summary of the assessment of current waste
management status.........................................................................108
3 NATIONAL WASTE MANAGEMENT GOALS.......................112

3.1 Key principles in waste management............................................112
3.2 Legal framework in harmonization with EU
legislation......................................................................................... 114
3.3 Improvement of institutional set-up...............................................116
3.4 Establishment of a network of waste management
facilities............................................................................................. 116
3.5 Waste management objectives.......................................................117
3.5.1 Short term objectives.........................................................................118
3.5.2 Long term objectives..........................................................................118
3.5.3 Targets for recycling and reduction....................................................119
THE NATIONAL WASTE MANAGEMENT PLAN..............................120
4 EXPECTED TYPES, QUANTITIES, AND ORIGIN

OF WASTE, INCLUDING ESTIMATIONS
RELATED TO GENERATION OF SPECIFIC
WASTE STREAMS.................................................................121
4.1 Expected generation of relevant waste streams...........................121
4.1.1 Municipal waste..................................................................................121
soils.................................................................................................... 124
4.1.3 Secondary waste from waste treatment.............................................125
4.1.4 Mining wastes....................................................................................126
4.1.5 Sewage sludge...................................................................................126
4.1.6 Vegetal wastes, animal by-products...................................................126
4.1.7 Hazardous wastes..............................................................................126
4.2 Expected generation of special waste streams.............................128
4.2.1 Packaging waste................................................................................128
4.2.2 End-of-Life vehicles............................................................................129
4.2.3 Waste mineral oil................................................................................129
4.2.4 Waste tires......................................................................................... 130
4.2.5 Waste electrical and electronic equipment.........................................130
4.2.6 Waste mercury-containing fluorescent tubes.....................................131
4.2.7 Used batteries and accumulators.......................................................131
4.2.8 PCB waste......................................................................................... 133
4.2.9 Other POPs waste.............................................................................133
4.2.10 Asbestos containing waste.................................................................134
4.2.11 Medical waste....................................................................................135

4.3 Expected types and quantities of waste to be

imported / exported..........................................................................135
4.4 Summary of the expected types and quantities of
wastes............................................................................................... 136
5 EXISTING WASTE COLLECTION SYSTEM AND

NETWORK OF LARGE WASTE RECOVERY
AND DISPOSAL FACILITIES INCLUDING ANY
TREATMENT OF WASTE OILS, HAZARDOUS
WASTE AND SPECIAL WASTE STREAMS..........................139
5.1 Existing waste collection systems of relevant waste
streams............................................................................................. 139
5.1.1 Municipal waste..................................................................................139
5.1.2 Construction and demolition waste including soil...............................140
5.1.3 Sewage sludge...................................................................................141
5.2 Existing collection systems for special waste
streams............................................................................................. 142
5.2.1 Packaging waste................................................................................142
5.2.4 Waste tires......................................................................................... 144
5.2.8 PCB waste......................................................................................... 146
5.2.9 Other POPs waste.............................................................................147
5.2.11 Medical and pharmaceutical waste....................................................149
5.3 Existing network of large waste recovery and
disposal facilities.............................................................................150
5.3.1 Waste incineration and co-incineration..............................................150
5.3.2 Landfills.............................................................................................. 150
5.3.3 Physico-chemical treatment and treatment of waste oils...................152
5.3.4 Dismantling/pre-treatment of WEEE and ELV....................................153
5.3.5 Recycling of mineral construction and demolition waste....................154
5.3.6 Further treatment/recycling installations.............................................154
5.4 Summarizing illustration of the existing waste
treatment capacities and of the current status of
waste treatment in Serbia................................................................155
6 ASSESSMENT OF NEEDS FOR NEW

COLLECTION SYSTEM, ADDITIONAL
INFRASTRUCTURE IN WASTE MANAGEMENT
FACILITIES IN COMPLIANCE WITH SELF-
SUFFICIENCY AND PROXIMITY PRINCIPLES,
AND AS NECESSARY, INVESTMENTS INTO

THE CONSTRUCTION OF SUCH

INFRASTRUCTURE...............................................................157
6.1 Assessment for relevant waste streams........................................157
6.1.1 Municipal waste..................................................................................157
soil...................................................................................................... 161
6.1.5 Sewage sludge...................................................................................166
6.2 Assessment for special waste streams.........................................166
6.2.1 Packaging waste................................................................................166
6.2.4 Waste tires......................................................................................... 168
6.2.8 PCB waste......................................................................................... 169
6.2.9 Other POPs waste.............................................................................170
6.2.11 Medical waste and pharmaceutical waste..........................................170
6.3 Assessment of the needs on specific infrastructure
and treatment options.....................................................................171
6.3.1 Source separation and collection system for
households......................................................................................... 172
6.3.2 Public amenity sites (bring-system)....................................................174
6.3.3 Home-composting in rural and semi-urban households.....................176
6.3.4 Composting........................................................................................ 176
6.3.4.1 Small scale composting facilities at municipal level...........................176
6.3.4.2 Large scale biological treatment facilities for source
separated bio-waste...........................................................................178
6.3.5 Transfer stations / storage areas for interim storage..........................178
6.3.6 Mobile treatment facilities for mineral construction and
demolition waste................................................................................179
6.3.7 Secondary separation and mechanical sorting of
recyclables......................................................................................... 180
6.3.8 Mechanical-biological treatment.........................................................180
6.3.8.1 Pre-treatment of mixed municipal solid waste before
landfilling (simple MBTs)....................................................................180
6.3.8.2 Mechanical-biological treatment of residual municipal
solid waste......................................................................................... 181
6.3.9 Waste incineration and co-incineration..............................................182
6.3.10 Capacities for WEEE and batteries and accumulators
treatment............................................................................................ 185
6.3.11 Recycling capacities for metals, plastics, glass, paper
and cardboard....................................................................................186
6.3.12 Recycling of mineral construction and demolition waste....................187

6.3.13 Physico-chemical treatment and treatment of waste oils...................188

6.3.14 Landfills.............................................................................................. 188
6.4 Estimated investment and operational cost of the
proposed waste management options...........................................191
6.4.1 Municipal Solid Waste Management – Investement
costs................................................................................................... 191
6.4.2 Construction and demolition waste management –
Investement costs..............................................................................193
6.4.3 Hazardous waste management – Investement costs.........................193
6.4.4 Transfer stations / Storage areas for interim storage –
Investement costs..............................................................................194
6.4.5 Operational costs...............................................................................194
7 PLAN FOR IMPLEMENTATION OF REDUCTION

OF QUANTITIES OF BIODEGRADABLE WASTE
DISPOSED ON LANDFILLS, MEASURES FOR
THE ACHIEVEMENT OF GOALS FOR
DISPOSAL OF THIS TYPE OF WASTE,
ESPECIALLY, FOR RECYCLING,
COMPOSTING, PRODUCTION OF BIOGAS OR
RE-USE OF MATERIALS/ENERGY RECOVERY..................197
7.1 Stages for implementation..............................................................199
7.2 Monitoring success of the measures taken...................................202
7.3 Legislative instruments to implement the proposed
measures.......................................................................................... 202
8 NECESSARY CAPACITIES OF NEW

ESTABLISHMENTS FOR RECOVERY AND/OR
DISPOSAL OF WASTE..........................................................204
8.1 Conclusion on the needs for new collection
systems and additional installations as well as on
closing down of existing facilities..................................................204
8.1.1 New collection systems and installations proposed...........................204
8.1.2 Proposed schemes for management of waste streams.....................206
8.1.3 Closing down of existing facilities.......................................................210
8.2 Necessary capacities of new establishments
needed for relevant and special waste streams............................212
8.2.1 Municipal solid waste.........................................................................213
8.2.2 Packaging waste................................................................................213
8.2.3 WEEEs (inclunding fluorescent tubes)...............................................214
8.3 Site selection criteria.......................................................................215
8.3.1 General site selection.........................................................................215
8.3.2 Landfill sites.......................................................................................218
9. ORGANISATION OF WASTE MANAGEMENT,

INCLUDING DIVISION OF RESPONSIBILITIES
BETWEEN PUBLIC AND PRIVATE SECTOR IN
THE AREA OF WASTE MANAGEMENT...............................222

9.1 Public sector.....................................................................................222

9.2 Private sector...................................................................................225
9.3 Conclusions on the division of responsibilities............................227
10. SOURCES AND AMOUNTS OF FINANCIAL

FUNDS FOR REALISATION OF ALL WASTE
MANAGEMENT MEASURES.................................................229
Currently available sources and financial funds
dedicated to financing the waste measures..................................229
10.1 229
10.2 Options for the financing of waste management
measures.......................................................................................... 231
10.3 Conclusions on financing of the proposed waste
management options.......................................................................233
11. ASSESSMENT OF USEFUL EFFECTS AND

SUSTAINABILITY OF APPLICATION OF
ECONOMIC AND OTHER INSTRUMENTS IN
WASTE MANAGEMENT, WITH UNDISTURBED
FUNCTIONING OF INTERNAL MARKET..............................234
12. MEASURES AND GUIDELINES FOR

IMPLEMENTATION OF THE NATIONAL PLAN ...................235
12.1 General waste management measures..........................................235
12.1.1 eHarmonizing the legal framework with EU waste
legislation........................................................................................... 235
12.1.2 Establish an integrated systems for municipal waste
management throughout Serbia.........................................................238
12.1.3 Conduct information campaigns related to waste
management for citizens (including municipal waste)........................238
12.1.4 Ensuring environmentally sound waste treatment in
Serbia................................................................................................. 239
12.1.5 Measures for financing the waste management and for
steering waste streams......................................................................240
12.1.6 Improve the monitoring and reporting of the waste
management......................................................................................241
12.2 Hazardous waste management measures.....................................241
12.2.1 Establish an adequate network for collection of
hazardous wastes from households...................................................241
12.2.2 Establish an adequate network of treatment
installations for hazardous waste.......................................................241
12.3 Special waste streams management measures............................242
12.3.1 Establish extended producer responsibility (EPR)
schemes according to the provisions of the Article 8a of
the Directive 852/2018 amending Directive 2008/98/EC
on waste............................................................................................. 242
12.3.2 C&D waste......................................................................................... 242
12.3.3 Packaging waste................................................................................243
12.3.4 End-of-life vehicles (ELV)...................................................................245

12.3.5 Waste Oil........................................................................................... 245

12.3.6 Waste tires......................................................................................... 246
12.3.7 Waste electrical and electronic equipment (WEEE) -
including fluorescent lamps................................................................246
12.3.8 Waste Batteries and Accumulators....................................................247
12.3.9 PCB and POPs waste........................................................................248
12.3.10 Asbestos............................................................................................ 250
12.3.11 Medical waste....................................................................................250
12.3.13 Waste from titan dioxide industry.......................................................254
12.4 General guidelines (policies) for waste
management, planned technologies and waste
management methods, including waste with
specific management difficulties....................................................254
12.5 Guidelines for recovery and disposal of waste,
taking into account national goals for reduction of
packaging waste and reduction of waste generation
of which cannot be avoided, especially reduction of
biodegradable waste disposal on landfills....................................256
12.6 Guidelines for ensuring most favourable technical,
production and other measures for the
achievement of waste management goals.....................................257
12.7 Criteria for technical and economic viability for
hazardous waste management.......................................................257
12.8 Measures for implementation of public awareness
campaigns and provision of information to wider
public or target group of interested consumers...........................258
12.9 Data about disposal sites contaminated historical
waste and measures for rehabilitation thereof..............................259
12.10 Other measures relevant for waste management.........................259
13. MANNER AND DEADLINES FOR

IMPLEMENTATION OF THE NATIONAL PLAN....................260
13.1 Measures.......................................................................................... 260
13.1.1 Regulatory measures / instrument.....................................................260
13.1.2 Operative measures / instruments.....................................................269
13.1.3 Informative measures / instruments...................................................277
13.1.4 Market based measures / instruments...............................................280
13.2 Assignment of responsibilities for implementation
of measures......................................................................................281
TABLES..............................................................................................282
FIGURES............................................................................................285

INTRODUCTION Waste Management Strategy 2019-2014
ABBREVIATIONS
BAT Best Available Technology

BEP Best Environmental Practice
BFRs Brominated Flame Retardants
C&D Construction and Demolition (work)
CDW Construction and demolition waste
DSIP Directive Specific Implementation Plan
EEA European Environmental Protection Agency
EIA Environmental Impact Assessment
ELV End-of-Live Vehicles
EU European Union
GNP Gross National Product
IHWMP Integrated Hazardous Waste Management Plan
LAB Lead-Acid Batteries
LOC Law on Chemicals
LPPW Law on Packaging and Packaging Waste Management
LWM Law on Waste Management
MBT Mechanical-Biological Treatment
MEP Ministry of Environmental Protection of the Republic of Serbia
MOE Ministry of Environment
NIP National Implementation Plan
NSDS National Sustainable Development Strategy
NWMP National Waste Management Plan
PC Physical/Chemical (Treatment)
PCB Polychlorinated Biphenyls
PCT Physical-Chemical Treatment
PPWD Packaging and Packaging Waste Directive
POPs Persistent Organic Pollutants
PUCs Public Utility Companies
SCTM Standing Conference of Towns and Municipalities
SEPA Serbian Environment Protection Agency
SORS Statistical Office of the Republic of Serbia
SWMP Sectoral Waste Management Plan
SWSP Specific Waste Stream Plan

WBA Waste Batteries and Accumulators

WEEEs Waste Electrical and Electronic Equipment
WFD Waste Framework Directive
WMP Waste Management Plan
WMS Waste Management Strategy
WSR Waste Shipment Regulation

THE NATIONAL WASTE MANAGEMENT STRATEGY

1 INTRODUCTION
Sustainable waste management is an essential element of a comprehensive strategy for

protecting the environment and livelihoods of future generations.
The LAW ON WASTE MANAGEMENT (“Official Gazette of the Republic of Serbia”, No. 36/2009,
88/2010 and 14/2016) provides the basic legal framework for the waste management in Serbia.
The basic principles of waste management as defined in Article 6 of the law are:
 the principle of selecting the best option for the environment,
 the principle of self-sufficiency in waste treatment,
 the principle of proximity and regional approach to waste management,
 the principle of applying a waste management hierarchy as a fundamental approach
where waste avoidance shall have the highest priority and final disposal the last,
 the principle of responsibility of the waste generator for the save management of the
wastes generated and
 the “polluter pays” principle.
To implement these principles Article 9 defines planning instruments on governmental level
(Waste Management Strategy, Waste Prevention Programs, Regional and Local Waste
Management Plans) as well as on the level of waste generation (Waste Management Plans for
IPPC establishments and operational plans for waste management facilities).
The National Waste Management Strategy as defined in Articles 10 and 11 of the law is the
master document for the long-term determination and guiding of waste management in the
Republic of Serbia.
The Strategy it shall:
 contain an analysis of the waste management system;
 set out the goals and objectives for the short-term and long-term development of a
sustainable waste management system in Serbia;
 provide a National Waste Management Plan as a planning tool for the implementation
of these goals.
To serve as a planning tool for the development of a sustainable waste management system the
National Waste Management Plan shall contain i.e.:
 an estimation of expected quantities of municipal wastes as well as other relevant waste
streams (e.g. “special waste streams” as defined by Article 47 to 58 of the LWM;
 an overview of the existing collection systems for waste and the existing network of
recovery and disposal facilities;
 an assessment of the needs for new collection systems and additional waste
management infrastructure;
 criteria for site identification and necessary capacities of such additional waste
management facilities;
 an implementation plan for the reduction of quantities of biodegradable waste disposed
on landfills;
 an estimation of waste management costs;
 measures, guidelines deadlines for the implementation of the plan.

1.1 Role of the Waste Management Strategy and Waste Management

Plan
Sustainable waste management is an essential part of sustainable development. Environmental

sound waste management is always a cross-cutting issue and requires an adequate network of
collection systems, treatment-, recycling- and disposal facilities. The Waste Management
Strategy (WMS) defines the goals of an integrated national waste management system and the
objectives necessary. The National Waste Management Plan (NWMP) as part of the Strategy is
a tool to identify and implement the necessary measures to meet these goals and set
benchmarks for the short-term and mid-term implementation of the waste Management
Strategy.
The Waste Management Strategy as defined in Article 10 of the LWM shall:
 provide a full assessment of the current waste management situation in Serbia;
 define the national waste management goals necessary to implement a sustainable
waste management system in Serbia and;
 provide a planning tool – the National Waste Management Plan in accordance with
Article 11 of the LWM – to implement the measures necessary to meet the waste
management goals.
To facilitate the process of approximation with EU legislation in the process of negotiation the
accession to the Union the Strategy shall review the waste management goals in the light of the
requests of community legislation and provide a stepwise short-term and mid-term approach to
fulfil such requirements, e.g. recycling quotas and the National Waste Management Plan shall
comply with Article 11 of the LWM as well as with Article 28 of Directive 2008/98/EC (WFD).
1.2 Special waste streams and other relevant waste streams
Special waste streams as defined by Articles 47 to 58 of the LWM are:

 Packaging waste;
 End-of-Live vehicles;
 Waste mineral oil;
 Waste tires;
 Waste electrical and electronic equipment (WEEEs);
 Waste mercury-containing fluorescent tubes;
 Used batteries and accumulators;
 PCB waste;
 Other POPs waste;
 Asbestos containing waste;
 Medical waste;
 Pharmaceutical waste;
 Waste from titanium dioxide industry;
These special waste streams are partly postconsumer wastes for which the principle of
extended producer responsibility is applicable, partly they are generated mainly during industrial
and professional activities so that the polluter pays principle shall prevail. Some of the waste
streams are generated in both areas and therefor there is a split responsibility.
In this WMS the Sub-Chapters of Chapter 2, 4, 5, 6 and 12 are giving information in relation to
these special waste streams. In addition the relevant waste streams are categorized to:
 Municipal waste;

 Construction and demolition waste;

 Hazardous waste;
 Secondary waste (waste from waste treatment);
 Other waste (such as mining waste, sewage sludge, vegetal waste).
1.3 Definitions
Agricultural waste – waste generated in agricultural activities, forestry, food processing and
wood industry, see also vegetal wastes and animal by-products.
Anaerobic digestion – a series of biological processes in which microorganisms break down
biodegradable material in the absence of oxygen. One of the end products is biogas, which
can be utilized as renewable fuel.
Animal by-products – materials of animal origin, not ready for human consumption (note: in
the European Union animal by-products are subject to a control regime in accordance with
Regulation (EU) 1069/2009).
Best available techniques means the best available techniques that are in accordance with
the law regulating integrated environmental pollution prevention and control.
Biodegradable waste – is biodegradable waste from gardens, parks, food, kitchen waste
from households, restaurants, catering and retail objects as well as organic waste from the
production of food and the biodegradable part of municipal waste (including separate
collected fractions). It does not include forestry or agricultural residues, manure, or other
biodegradable material such as natural textiles and separate collected paper.
Biodegradable waste1 - means any waste that is capable of undergoing anaerobic or
aerobic decomposition, such as food and garden waste, and paper and paperboard.
Bio-waste2 - means biodegradable garden and park waste, food and kitchen waste from
households, offices, restaurants, wholesale, canteens, caterers and retail premises and
comparable waste from food processing plants.
Bio-drying means the controlled evaporation of water through the aerobic microbial and
exothermic decomposition process of mixed waste fractions with a high content of
biodegradable organic matter
Bio-stabilisation means pre-treatment of the organic fraction of mixed municipal solid waste
by means of aerobic rotting under controlled conditions with the aim of reducing volume, the
content of easily biodegradable organic matter, the potential of biodegradability and the gas
potential when disposed on landfills
Collecting centre3 - means the site determined on the basis of a decision made by
municipality, city or city of Belgrade (hereinafter referred to as: local self-government unit)
where citizens bring waste and voluminous waste (furniture, electrical appliances, garden
waste, material suitable for recycling including hazardous waste from households);
Characterization of waste means a testing procedure which shall be applied to determine
physical-chemical, chemical and biological properties and composition of waste, i.e. to
determine if waste contains one or more hazardous characteristics.
1
Landfill Directive consolidated 04.07.2018 and SR LWM
2
WFD consolidated 05.07.2018
3
Law on waste management

Classification of waste means a procedure which shall be applied to classify waste to one
or more waste lists, as prescribed by a specific regulation, according to origins of waste, its
composition and further use.
Co-incineration (combined combustion) – thermal treatment of waste in stationary or
mobile facility whose primary role is to generate energy or produce material products, which
uses waste as primary or supplementary fuel, or in which waste is thermally treated for
disposal thereof.
Commercial waste – waste generated in companies, organisation or other institutions which
wholly or partially deal with trade, services, office business, sport, recreation or
entertainment, except for household and industrial waste.
Composting – transformation of bio- waste performed by micro-organisms in order to form
compost, in presence of oxygen and under controlled conditions.
Construction and demolition waste – waste which is generated during the performance of
construction works at construction sites or preparatory works prior to the construction of
objects, as well as waste generated by demolition or reconstruction of objects. Construction
and demolition waste shall include: soil from earthworks, demolition waste and waste
generated in construction (ceramics, concrete, iron, steel, plastic, etc.), as well as waste
asphalt and concrete.
End-of-life vehicles – motor vehicles or parts thereof which constitute waste, disposal of
which is wanted by the owner, or the owner of such vehicles is unknown.
EU Directives – legal instructions of the EU that relate all the member states and must be
implemented through legislation of member states in prescribed deadlines.
Green waste means garden and park waste such as leaves, branches, grass clippings,
flowers, fall separately collected from private, public or commercial premises.
Hazardous waste – waste that according to its origin, composition or concentration of
hazardous substances can result in danger to the environment and human health, and has at
least one of hazardous properties (explosiveness, flammability, susceptibility to oxidation, it is
organic peroxide, acute toxicity, infectious, susceptibility to corrosion, releases flammable
gases in contact with air, releases toxic substances in contact with air or water, contains toxic
substances with delayed chronicle effects, as well as ecotoxic properties), including
containers which served or are serving as hazardous waste packaging.
Holder means a waste producer, natural person or legal entity in possession of waste
Incineration plant – any stationary or mobile technical unit or equipment dedicated for
thermal treatment of waste with or without recovery of heat generated in combustion process.
Industrial waste – waste generated by any industry or from any site where industry is
located, except for tailings and related mineral raw materials from mines and quarries and
municipal waste generated at that site.
Inert waste – waste that is not susceptible to any physical, chemical or biological changes;
does not dissolve, burn or otherwise react in physical or chemical terms, is not biodegradable
and does not affect adversely other materials when contacting such materials in the way that
may result in environmental pollution or in threat to human health; leachate and contents of
pollutants in waste and ecotoxicity of leachate shall be within allowed limits, and they
particularly shall not affect quality of surface and/or ground waters.
Integrated waste management – includes numerous key elements partners in the decision-

making process; application of various waste management options with local sustainable
management system where each step in waste management process makes a part of the
whole picture.
Landfill – site for surface or underground waste disposal where waste is disposed of,
including: internal disposal sites (landfills used by a manufacturer for disposal of own waste
generated on the spot), permanent sites (more than a year) used as temporary storage of
waste, except for transfer stations and storage of waste before its treatment or re-use (less
than three years), or storage of waste before disposal thereof (less than a year).
Medical waste (also healthcare waste/hospital waste)4 – waste generated in objects where
activities for human or animal healthcare protection is performed and/or in other places where
healthcare services are provided (from diagnostics, experimental works, laboratories,
cleaning, maintenance and disinfection of premises and equipment), and comprises non-
hazardous and hazardous medical waste, namely:
 Non-hazardous medical waste that is not contaminated with hazardous or other
materials, the composition of which is similar to that of municipal waste (recyclable,
biodegradable, etc.);
 Hazardous medical waste requiring specific handling and/or having one or more
hazardous characteristics making it hazardous waste, namely: patho-anatomic waste,
sharps, pharmaceutical waste, including cytotoxic and cytostatic waste, waste
contaminated with blood or body fluids, infective, other dangerous medical waste
(chemical waste, waste with a high metal content and waste pressurised bottles).
Municipal waste – waste generated in households, as well as other waste which due to its
nature and composition is similar to household waste.
Non-hazardous waste – waste that does not exhibit a dangerous characteristic as defined in
accordance with Article 8 of the LWM.
Operator means any legal entity or entrepreneur that, in accordance with regulations,
manages or controls a plant, or is authorised to make economic decisions in the field of
technical functioning of a plant, on whose name the waste management permit is issued.
Packaging waste – any packaging or packaging material that cannot be used for the original
purposes, except for the remains generated in the production process.
Permit – a decision made by competent authority which allows legal or private entity to
collect, transport, import, export and transit, store, treat or dispose of waste, which also
defines conditions for waste handling in the manner that poses the lowest risk to human
health and environment.
Pharmaceutical waste means all drugs, including primary packaging and any accessories
used for their administration, in possession of a legal entity or entrepreneur dealing with
human or animal health care, which became unusable due to the expiry of their life cycle,
defect in terms of the required quality, contaminated packaging, spillage or scattering, which
have been prepared, and then not used, returned by end users, or unusable for other
reasons, and pharmaceutical waste from drug production and wholesale and retail trade of
medicinal products, and manufacture of galenic and/or magistral preparations and other
pharmaceutical waste. Waste produced in drug production shall be categorised as industrial
(organic or inorganic) waste to be handled in accordance with the provisions of this Law.
Pharmaceutical waste shall include:
 Non-hazardous pharmaceutical waste which is not hazardous for the environment or
4
Preparing a Waste Management Plan, A methodological guidance note, 2012, European Commission, DG
Environment.

human health, and is not treated according to the procedure prescribed for the
management of hazardous pharmaceutical waste;
 Hazardous pharmaceutical waste generated from the drugs and disinfectants
containing heavy metals, as well as drugs of known composition and drugs of
unidentifiable composition, which require specific treatment procedures and include
cytotoxic and cytostatic waste, or cytotoxic and cytostatic drugs that have become
unusable, waste produced in the utilisation, transportation, and preparation of drugs
with the cytotoxic and cytostatic effect, including primary packaging that was in
contact with hazardous material, and any accessories used for the preparation or
administration of such products. Cytotoxic and cytostatic drugs are toxic compounds
with a carcinogenic, mutagenic and/or teratogenic effect.
Plant for separation of recyclables – technological line for selection of useful recyclable
components from the municipal waste or from separate collected fractions (e.g. packaging
wastes)
POPs waste – waste that is composed of, contains or is contaminated above the legal
threshold by persistent organic pollutants (as defined by the Stockholm Convention on
persistent organic pollutants)
Prevention means measures taken before a substance, material or product becomes waste,
which reduce the quantity of waste, including the re-use of products or extension of the life
cycle of products, or adverse effects of generated waste on the environment and human
health, or content of harmful substances in materials and products.
Recycling – recovery of waste materials in production process for the original or other
purposes, except for energy purposes.
Regional waste management centres – centres in waste management regions which
contain: regional landfill, plant for separation of recyclables, transfer stations, composting
facility, centres for collection of recyclable waste.
Re-use – means any operation by which products or components that are not waste (no
longer waste) are used again for the same purpose for which they were conceived.
Secondary Waste – waste generated in a waste treatment operation, e.g. sorting residues,
stabilized wastes (e.g. PC-treatment sludge), residues from waste incineration
Separated collection means waste collection where different types of collected waste are
kept separately according to their type and nature, so as to facilitate their special treatment.
Special waste streams – the waste streams listed in Section VII of the LWM, i.e. used
batteries and accumulators, waste oils, waste tires, waste electric and electronic equipment,
waste mercury-containing fluorescent tubes, PCB wastes, POPs wastes, Asbestos and
Asbestos containing wastes, end-of-life vehicles, medical waste, pharmaceutical waste,
waste generated in Titanium Dioxide industry, packaging waste.
Storing of waste – means temporary maintenance of waste at the location of a waste
producer or owner and/or other holder, as well as operator’s activity in a facility equipped and
registered for temporary waste storage
Sustainable waste management – efficient use of material resources, reduction of
hazardousness and quantities of generated waste, and when generated, such waste is
handled with in the manner that shall actively contribute to economic, social and ecological
goals of sustainable development.

Transfer station – point to which waste is delivered and temporary stored for separation or
re-load before transporting it to treatment or recovery or disposal.
Transport of waste – transport of waste outside the facility, including loading, transport (as
well as re-loading) and unloading of waste.
Used battery or accumulator – battery or accumulator that cannot be re-used and has
become waste, intended for treatment, i.e. recycling
Waste – means any substance or object which the holder discards, intends or deems
necessary to discard
Waste collection – the activity of systematic collection of waste, classification, and/or
combining of waste for transport to further treatment or disposal.
Waste disposal – means any treatment operation which is not recovery, recycling or
preparation for re-use even where the operation has as a secondary consequence the
reclamation of substances or energy. (D - list of disposal operations in the REGULATION ON
CATEGORIES, TESTING AND CLASSIFICATION OF WASTE is a non-exhaustive list.)
Waste electric and electronic equipment (WEEE) –means electrical or electronic

equipment which is waste within the meaning of Article 5 (17) of the Law on Waste
management, including all components, sub-assemblies and consumables which are part of
the product at the time of discarding;
Waste from Titanium Dioxide Industry – solid waste, strong acid waste, weak acid waste,
neutralized waste, treatment waste and dust generated during the production of Titanium
Dioxide.
Waste incineration (combustion) – thermal treatment of waste in stationary or mobile plant
with or without use of energy generated in combustion, where primary role is thermal waste
treatment.
Waste management – implementation of prescribed measures for handling with waste as a
part of collection, transport, storing, treatment and disposal of waste, including supervision
over those activities and care for waste management plant upon their closure (LAW ON WASTE
MANAGEMENT, Article 5).
Waste management facility – stationary technical unit for storage, treatment or disposal of
waste, which makes technological unit together with the construction part.
Waste management region – spatial unit which includes several local self-government units
which, in accordance with the agreement entered into between those local self- government
units, jointly manage waste so as to establish a sustainable waste management system.
Waste of animal origins – waste generated in slaughterhouses, meat processing plants and
facilities for animal breeding, as well as carcasses of dead animals.
Waste oils – all mineral or synthetic oils or lubricants, which cannot be used for the original
purpose, such as hydraulic oils, motor, turbine oils or other lubricants, marine oils, oils or
liquids for insulation or heat transmission, as well as oil remains from tanks, oil-water mixture
and emulsions.
Waste owner means a waste producer, an entity participating in waste circulation as a direct
or indirect waste holder, or a legal entity, entrepreneur, or natural person in possession of
waste.
Waste producer – every person (or legal entity) by whose activity waste is generated
(original producer of waste) or anyone who carries out pre-treatment, mixing or other

operations resulting in a change in the nature or composition of this

Waste reduction – priority action whose aim is to achieve maximal reduction of waste.
Waste storing – temporary maintenance of waste at the manufacturer or waste owner’s
location, as well as operator’s activities in a plant equipped and registered for temporary
waste maintenance.
Waste tires – motor vehicle tires (cars, buses, trucks, motorcycles, etc.), agricultural and
construction machines, trailers, aircrafts, towed machines, other machines and devices and
other similar products, upon the end of their life cycle, which are rejected by the owner or
intended for rejection due to damages, wear and tear or other reasons.
Waste treatment – includes physical, thermal, chemical or biological processes, including
waste separation, which change properties of waste, with the aim to reduce volume or
hazardous properties, to facilitate handling with waste or encouraging recycling and it
includes also re-use and recycling of waste.
Wastes from thermal processes – residues generated during incineration, combustion and
thermal metallurgical processes, e.g. slags, ashes, fly-ashes, filter dusts, flue gas cleaning
residues.

ASSESMENT OF CURRENT STATUS Waste Management Strategy 2019-2024
2 ANALYSIS AND ASSESSMENT OF CURRENT WASTE

MANAGEMENT STATUS
2.1 Current institutional framework for waste management
Figure 1:
Institutional framework for waste management
Ministry of Environmental Protection (MEP)
The responsibility for the development and implementation of the National Waste Management
Policy lies at the Ministry of Environmental Protection as stipulated in the LAW ON MINISTRIES
(latest revised by 62/2017). The Ministry is responsible to establish and harmonize legislative
framework in the area of waste management with EU acquis, as well as obligations coming from
international contracts and membership in international organizations. The Ministry is
responsible to prepare the National Waste Management Strategy (including the National Waste
Management Plan) and the Waste Prevention Programme in co-operation with the competent
authority of the autonomous province. According to the Law on Waste Management (latest
revised by14/2016) the Strategy shall be enacted by the Government for a six-year period and,
if necessary, it shall be revised in a three-year interval. The Ministry of Environmental Protection
shall prepare an Implementation Report to be submitted to the Government at least once a year.
The Ministry furthermore coordinates and performs specific waste management activities of
importance for the Republic of Serbia and monitors their status. Concerning permitting of waste
management activities the Ministry is responsible for all activities concerning hazardous waste,
the treatment of inert and non-hazardous waste through incineration and the treatment of waste
in mobile facilities. Furthermore the notification procedure concerning transboundary shipment

of waste including import, export and transit of waste is one of the duties of the Ministry. An
additional important role of the Ministry is to supervise and control application of measures
pertaining to waste management.
The Ministry is organized in following sectors:
 Sector for Financial Management and Control;
 Sector for Environmental Management;
 Sector for Nature Protection and Climate Change;
 Sector for Strategic Planning and Projects;
 Sector for Waste and Waste Water Management;
 Sector for Environmental Monitoring and Precaution;
 Sector for International Cooperation and European Integration.
The Sector for Financial Management and Control within the Ministry of Environmental
Protection is managing the “Green Fund” as one of the economic instruments for environmental
protection. The Green Fund has been formed as a budgetary fund (the Ministry of Finance is
responsible for controlling the allocation of funds). The fund is based on the “Producer
responsibility/Polluter Pays” principle and e.g. collects a fee for introducing specific products into
the market, defined by the decree on products that become special waste streams upon use
thereof (e.g. tires, asbestos containing product, batteries and accumulators, mineral oil and
lubricants, electrical and/or electronic equipment). In addition the fund shall be generated from
earmarked funds based on: charges for using natural resources, other government
budget resources, and international (EU) grants and loans. Further explanations on financial
instruments to establish the waste management system could be found in Chapter 10.
The Sector for Waste and Waste Water Management carries out tasks related to:
 preparation of expert bases for drafting regulations and direct participation in the
drafting of regulations in relevant area of competence;
 coordination of activities in preparation, organization and monitoring of the process of
elaboration and implementation of strategies, programs and plans in the area of
environmental protection and waste management;
 defining, coordinating and developing environmental objectives in the area of waste
management;
 establishing and developing a system for managing municipal, biodegradable and
industrial waste and cooperation with local self-government units in terms of
harmonization of practice and implementation of laws;
 monitoring and participation in the harmonization of national regulations with EU
regulations in the area of waste management within the framework of cross-border
movement of waste, issuing waste management permits and permits for the
management of special waste streams, and waste management planning;
 participation in the development of strategic documents, research and other plans and
programs in the area of sustainable use, conservation of surface and groundwater
quality, protection of waters from pollution and waste water management,
harmonization of these documents with strategic ones in the area of environmental
protection, and defining environmental objectives in terms of surface and groundwater
and protected areas, as well as monitoring the implementation of these strategies, plans
and programs;
 determination of environmental quality standards for surface waters, groundwater and
sediment, parameters of ecological and chemical status of surface waters, as well as
quantitative and chemical status of groundwater and water classification;
 determination of vulnerable and sensitive areas, as well as protected areas in the
watersheds;

 preparing and proposing monitoring of the status of surface and groundwater;

 control of introduction and discharge into surface waters, groundwater and public
wastewater sewerage, establishing measurement of quantities and testing the quality of
waste waters before and after the treatment;
 cooperation with other state authorities and institutions in implementation of
environmental policy in the area of waste management and waste water management;
 participation in work of Negotiating Group for Chapter 27, sectoral working groups and
in preparation of negotiating position.
Serbian Environmental Protection Agency (SEPA)

The Serbian Environmental Protection Agency (SEPA), as administrative body within the
Ministry of Environmental Protection, holding a legal entity status, inter alia is responsible for the
establishment and the operation of the national environmental information system (monitoring of
the state of environment including registers in the area of waste management). Reported data
by the operators and other involved parties specifically on waste streams and secondary
materials are analysed and assessed by the Agency and made available and accessible
electronically to the Ministry as a basis for further national reporting or political decisions. The
Agency furthermore maintains information on the best available techniques and practices and
application thereof in the area of environmental protection. The Agency takes responsibility for
European and International reporting obligations in the waste management sector and
cooperates with the European Environmental Protection Agency (EEA) and the European
Network of Information and Observation (EIONET).
A key area of the Agency is the management of the national information system for
environmental protection (through environmental indicators, the registry of pollutants, etc.) and
the implementation of monitoring systems for the control of air quality, surface water and
groundwater aquifer and precipitation.
Based on requirements stipulated in the Law on Waste Management the following list show
exemplified data to be reported to the Agency:
 As laid down in the LWM, entities who perform collection, storing and treatment of used
batteries and accumulators, waste oils, waste tires, waste of electric and electronic
products, waste mercury-containing fluorescent tubes and PCB waste shall hold a
permit, maintain and keep records on these waste streams and on quantities collected,
stored or treated, and shall submit those data to SEPA (see Articles 47 to 52 of the
Waste Management Act).\;
 Owner of asbestos-containing waste shall maintain records on quantities of waste
stored or disposed of and shall submit such data to SEPA (Article 54 of the Waste
Management Act);
 The entity that treats end-of-life vehicles shall maintain records on all the phases of
treatment, and shall submit such data to SEPA (Article 55 of the Waste Management
Act);
 Pharmacies and healthcare institutions shall maintain and keep records on
pharmaceutical waste and shall submit such data to SEPA (Article 56 of the Waste
Management Act);
 Generator and owner of waste from Titanium Dioxide Industry shall hold appropriate
permit, maintain and keep records on quantities of this type of waste collected, stored,
treated or disposed, and shall submit such data to SEPA (Article 57 of the Waste
Management Act);
 Every waste generator and owner, except for households, shall maintain and keep daily
records on waste and shall submit regular annual report to SEPA;

 Local self-government units shall maintain and keep records on collected municipal
waste, as well as list of unregulated landfills and shall submit such data to SEPA (Article
75 of the Waste Management Act);
 Concerning products that become special waste streams upon use thereof an annual
report as well as daily records on the amount and type of produced and imported
products shall be kept by charge payers and shall be submitted to SEPA. The products
that become special waste streams upon use thereof includes tires, products containing
asbestos, batteries and accumulators, any mineral or synthetic oil and lubricant, end-of-
life vehicles as well as electrical and electronic products (see Decree No. 54/2010).
Other Ministry Levels

For some waste streams the main responsibility lies not at the Ministry of Environmental
Protection but at other Ministries, in some cases also shared responsibilities are taken:
 Agricultural waste - Ministry of Agriculture, Forestry and Water Management;
 Mining waste - Ministry of Mining and Energy;
 Medical waste and pharmaceutical waste – Ministry of Health
The Ministry of Labour, Employment, Veteran and Social Affairs carries out inspections on
occupational safety on the whole territory of Serbia including the Autonomous Province. The
Companies to be inspected include all types of sectors including the waste management sector.
The Ministry of Construction, Transport and Infrastructure carries out inspections on trucks,
trains and ships. Joint inspections between those Ministries and the Ministry on Environmental
Protection are on their agenda and needs to be enhanced.
Autonomous Provinces
The competences of the Autonomous Province of Vojvodina concerning the responsibilities for
environmental protection are laid down in the LAW ON ESTABLISHING COMPETENCIES OF
AUTONOMOUS PROVINCE OF VOJVODINA (no 99/09). The Autonomous Province has its own
revenues to be used to finance its competences. According to the Law on Waste Management
(latest revised by 14/2016) the Autonomous Province shall participate in the development of the
strategy and specific national waste management plans. The Autonomous Province furthermore
coordinates and performs specific waste management activities of importance for the Province.
Concerning permitting of waste management activities the Autonomous Province is responsible
for all waste management activities at its territory. In addition to that the Autonomous Province
is also entrusted to carry out inspection over the activities related to waste management.
The administration of the autonomous province of Vojvodina has twelve secretariats; one
entitled Provincial Secretariat for Provincial Secretariat for Urban Planning and Environmental
Protection with following main responsibilities:
 perform the tasks of the provincial administration in the field of spatial and urban
planning, related to the preparation of acts for the Assembly or the Provincial
Government which shall:
o design, enact and implement documents on the spatial development of the
Province;
o design, enact and implement regional spatial plans and spatial plans for special
purposes; propose measures and activities of the implementation programme of the
spatial plan of the Republic of Serbia in the territory of the Province;
o design, enact and implement regional development plans and spatial plans for
special purposes and monitor their implementation; establish a public company for
spatial and urban planning and design and exercise founder’s rights thereof.

 provide expert assistance and secure the funds for financing, i.e. co-financing of local
self-governments for the design of spatial and urban planning documentation, projects
by expert and non-governmental organizations, in the field of spatial planning, urban
planning; conduct expert control and provide public inspection into regional spatial plans
and spatial plans for specific purposes for the areas in the territory of the Province;
 control the exploitation and protection of natural resources and assets on the territory of
the Province; provide continuous control and monitoring of the state of the environment;
give conditions for securing the measures and terms for the environment protection,
upon the request of the competent body, in charge of preparing and enacting of spatial
and urban plans, and on the grounds of the conditions and opinions of the competent
expert organizations - take part in the process of preparing and enacting of spatial,
urban and other plans (spatial plan and the grounds for the exploitation of agriculture
soil, forest soil plan, water management plan and hunting management plan, as well as
programmes for the improvement of fishing at the fishing areas and other plans).
Local Self-Government Units (LSG units)

At local level the Local Self-Government Units (LSG units) are responsible to adopt local Waste
Management Plans. Their establishment is regulated by the Law on Local self-government
(latest amended by 83/2014). The LSG units establish, regulate, ensure, organize and
implement the management of municipal waste including the procedure on collection of this
waste stream at its territory. In addition, LSG units issue permits for activities concerning inert
and non-hazardous waste, keep records and submit data to the Ministry. Permits for activities
concerning inert and non-hazardous waste at the territories of more than local self-government
unit are issued by the Ministry, i.e. competent authority of Autonomous Province for the territory
of autonomous province. A joint waste management can be established via an assembly of two
or more local self-government units. Assemblies with at least 250.000 inhabitants living within
their territories shall develop a regional waste management plan, which shall define common
goals in waste management, in compliance with the Serbian Waste Management Strategy.
Waste Testing Organizations

Professional Waste Testing Organizations shall perform testing of waste for classification
purposes with respect to transboundary movement of waste, treatment and disposal as well as
end-of-waste, in accordance with the range they are certified for, and shall issue a report on
waste testing. By 2018 eight institutions were listed as Professional Waste Testing
Organizations. The laboratories performing waste testing apply for certification at the
Environment Ministry every four years; prerequisite for the certification is that the Laboratories
are accredited by the National Accreditation Body. The Accreditation Audit is repeated every
year.
Statistical Office of the Republic of Serbia (SORS)

The Statistical Office is inter alia responsible for the reporting to Eurostat in accordance with the
Waste Statistic Regulation and for coordination of official statistic data in Serbia. Users of the
Office’s data and services encompass citizens, legal entities, state administration bodies and
local self–government bodies, journalists, scientists, researchers, analytics, students and
international organizations. The Unit for Environment Statistics within the Department for
Business Statistics of the Republic Statistical Office establishes statistical data of importance for
presentation of environmental status in the area of waste, hazardous chemicals and water-
related statistics.

Standing conference of towns and municipalities (SCTM)

The “Standing Conference of Towns and Municipalities (SCTM)” is the association of Serbian
towns and municipalities. The association is supporting the towns and municipalities via building
up competences and staff resources to be in line with overall Serbian legislation requirements
and plays an important role in terms of organizing the information exchange to foster the
communication between their Members and other institutions.
Others
Further participants with specified roles in waste management according to the LAW ON WASTE
MANAGEMENT are: Product producers or importers, waste producers, owner and holder of the
waste, waste carrier, broker/dealer and operators of waste management facilities. Those
players comprise both public and private sector.
Beside the institutions with specified roles in waste management the participation of the public
sector (including consumer’s organizations and single waste producers) plays an important role
for success in implementing the waste management policy. Changing consumer behaviour is a
crucial factor to foster initiatives in the waste management sector such as waste prevention or
source-separation of waste in households as part of a Strategy.
2.2 Current legal framework and strategies for waste management
2.2.1 EU policy and legislation in the area of waste management
Cross-horizontal strategies and policies

At European Level following priority objectives for waste policy are set in line with the 7 th
Environment Action Programme (Decision No 1386/2013/EU): To reduce the amount of waste
generated; to maximise recycling and re-use; to limit incineration to non-recyclable materials; to
phase out landfilling to non-recyclable and non-recoverable waste; to ensure full implementation
of the waste policy targets in all Member States. The 7th Environment Action Programme will be
the guideline for European environment policy until 2020 and has special focus on turning waste
into a resource. It identifies the key objectives to protect, conserve and enhance the Union’s
natural capital, to turn the Union into a resource-efficient, green, and competitive low-carbon
economy as well as to safeguard the Union's citizens from environment-related pressures and
risks to health and wellbeing.
The European Union´s Circular Economy Package (COM/2015/0614) sets ambitious
measures, which includes revised legislative proposals on waste to stimulate Europe's transition
towards a circular economy. The actions proposed in the EU Action Plan for the Circular
Economy shall contribute to "closing the loop" of product lifecycles through greater recycling
and re-use, and bring benefits for both the environment and the economy.
With its Strategy for Plastics in the Circular Economy (COM/2018/028 final) the Commission
intends inter alia to transform the way plastics and plastics products are designed, produced,
used and recycled. According to the Strategy by 2030, all plastics packaging should be
recyclable. The Strategy also highlights the need for specific measures, possibly a legislative
instrument, to reduce the impact of single-use plastics, particularly in our seas and oceans.
The construction of large waste treatment installations is regularly subject to an assessment
process in accordance with Directive 2011/92/EU on Environmental Impact Assessment as
amended by Directive 2014/52/EU.

Waste management plans are subject to an assessment process in accordance with Directive
2001/42/EC on the assessment of the effects of certain plans and programmes on the
environment (SEA Directive).
Framework legislation
The Waste Framework Directive (WFD, Directive 2008/98/EC as amended by (EU)

2018/851)
The Directive lays down measures to protect the environment and human health by preventing
or reducing the adverse impacts of the generation and management of waste and by reducing
overall impacts of resource use and improving the efficiency of such use. It sets the basic
concepts related to waste management and establishes a legal framework for the treatment of
waste within the EU. The Waste Framework Directive defines in Article 4 the “waste
hierarchy” considering the following steps as a priority order 1) prevention, 2) preparing for re-
use, 3) recycling, 4) other recovery, e.g. energy recovery and 5) disposal. These comprise the
key elements for establishing national waste prevention and management legislation and
policies.
With the requirement for Member States to establish a Waste Prevention Programme (see
Article 29) comprising the evaluation of measures and the definition of indicators for waste
prevention the Waste Framework Directive takes up the meaning of the highest priority step.
Re-use and recycling is issued by defining specific targets for the waste materials such as
paper, metal, plastic and glass from households as well as construction and demolition waste
(excluding naturally occurring material) (see Article 11) to be achieved in 2020. Member States
are obliged to take the necessary measures to fulfil the targets in order to move towards a
European recycling society with a high level of resource efficiency. Where recovery in is not
undertaken, waste should be undergoes safe disposal operations according to Article 12 of
the Waste Framework Directive. All steps of the hierarchy on the management of waste needs
to be carried without endangering human health, without harming the environment and, in
particular: (a) without risk to water, air, soil, plants or animals; (b) without causing a nuisance
through noise or odours; and (c) without adversely affecting the countryside or places of special
interest (see Article 13).
In addition the Waste Framework Directive stipulates provisions for waste management
covering aspects such as responsibility for waste management, the principles of self-sufficiency
and proximity and more specifically for the management of hazardous waste (e.g. control and
labelling of hazardous waste). Specific requirements for the management of waste oils and bio-
waste are laid down in Article 21 and 22 comprising e.g. separate collection and treatment
under high level of environmental protection.
Any establishment or undertaking intending to carry out waste treatment need to obtain a
permit from the competent authority according to Article 23 of the Waste Framework
Directive. The permits shall specify in detail e.g. types and quantities of waste that may be
treated and safety and precautionary measures. Parties, not subject to permit requirements
(professional collectors and transporters or dealers and brokers) need to be registered in a
register to be kept by the competent authority. Establishments or undertakings which carry out
waste treatment operations, establishments or undertakings which collect or transport waste on
a professional basis, brokers and dealers, and establishments or undertakings which produce
hazardous waste shall be subject to appropriate periodic inspections by the competent
authorities (see Article 34).
In Article 5 the key requirements for “by-products” are defined enabling that a substance or
object, resulting from a production process, the primary aim of which is not the production of

that item, may be regarded as not being waste. Furthermore, Article 6 defines following key
requirements for “end-of-waste” enabling that certain specified waste shall cease to be waste:
 further use of the substance or object is certain;
 the substance or object can be used directly without any further processing other than
normal industrial practice;
 the substance or object is produced as an integral part of a production process; and
 further use is lawful, i.e. the substance or object fulfils all relevant product,
environmental and health protection requirements for the specific use and will not lead
to overall adverse environmental or human health impacts.
Both instruments intend to enhance the use of certain re-usable/recyclable materials by
reducing the bureaucratic burden that is connected with the waste status, provided this doesn’t
jeopardise the goals of the Waste Framework Directive. At European Level several “end-of-
waste” regulations were already enacted (iron and aluminium scrap, copper scrap, glass culets).
Concerning classification of waste in Article 7 of the Waste Framework Directive the reference
is taken to Decision 2000/532/EC (amended by Decision 2014/955/EU) establishing a “list of
waste”. When assessing the hazardous properties of waste, the criteria laid down in Annex III to
the Waste Framework Directive (amended by Regulation (EU) No 1357/2014 and Regulation
(EU) No 2017/997) apply.
In Article 8 of the WFD the extended producer responsibility is defined whereby Member
States may take legislative or non-legislative measures to ensure that any natural or legal
person who professionally develops, manufactures, processes, treats, sells or imports products
(producer of the product) takes responsibility on the management of waste thereof. This may
cover measures such as encouraging the design of products or making available information on
recyclability of products considering the technical feasibility and economic viability as well as the
overall environmental, human health and social impacts. Article 8a (introduced by (EU)
2018/851) defines the minimum criteria of EPR schemes to be established.
In accordance with the polluter-pays principle, the costs of waste management shall be borne
by the original waste producer or by the current or previous waste holders (see Article 14).
In Article 28 of the Waste Framework Directive (2008/98/EC), the minimum requirements for
national waste management plans are laid down. The plans shall cover the entire
geographical territory of the Member State concerned and shall set out an analysis of the
current waste management situation therefore. They shall define measures to be taken to
improve environmentally sound preparing for re-use, recycling, recovery and disposal of waste
and an evaluation of how the plan will support the implementation of the objectives should be
established.
Minimum requirements to enhance recycling already applicable according to WFD:
 Increase of the preparing for re-use and the recycling of waste materials such as at
least paper, metal, plastic and glass from households and possibly from other origins as
far as these waste streams are similar to waste from households, to a minimum of
overall 50 % by weight by 2020;
 Increase the preparing for re-use, recycling and other material recovery, including
backfilling operations using waste to substitute other materials, of non-hazardous
construction and demolition waste excluding naturally occurring material defined in
category 17 05 04 in the list of waste shall be increased to a minimum of 70 % by
weight, by 2020;

Directive (EU) 2018/851 amending Directive 2008/98/EC on waste was published in the Official
Journal of the European Union on June 14 th 2018 as a part of the European Circular Economy
Package. The main elements of the amendments of the Directive include:
 Increase of the preparing for re-use and recycling target for municipal waste: 55% by
2025, 60 % by 2030 and 65% by 2035;
 Strict recycling calculation rules based on input into recycling and as of 1 January 2027
Member States may only count municipal bio-waste entering aerobic or anaerobic
treatment as recycled if it has been separately collected or separated at source
 by 31 December 2023 bio-waste shall either be separated and recycled at source or
collected separately + shall not be mixed with other types of waste; this is includes also
the obligation to encourage home composting and composting and digestion of bio-
waste resulting in compost or digestate that meet relevant high-quality standards;
 Separate collection system for textiles it will have been established by 1 January 2025;
 Concrete measures to promote re-use and prevention (including prevention of food
waste);
 Improvement of definitions, harmonisation of calculation methods for recycling rates and
streamlining of reporting obligations;
 Introduction of minimum operating conditions for Extended Producer Responsibility;
 Economic incentives for producers to put greener products on the market and support
recovery and recycling schemes.
The Waste Shipment Regulation (Regulation (EC) No 1013/2006)

Regulation lays down procedures for the transboundary shipments of waste and implements the
provisions of the Basel Convention on the Control of Transboundary Movements of Hazardous
Wastes and their Disposal as well as the Decision of the OECD Council on the control of
transboundary movements of waste destined for recovery operations (OECD Decision). The
Regulation which is directly applicable in the Member States was amended in 2014 by
Regulation (EU) No 660/2014.
The Waste Shipment Regulation (WSR) includes a ban on the export of hazardous wastes to
non-OECD countries ("Basel Ban") as well as a ban on the export of waste for disposal. It also
stipulates a procedure of prior written notification and consent before cross borders shipments
of all hazardous waste and some other types of waste, including certain non-hazardous wastes
that are destined to non-OECD countries.
The amendment of the Waste Shipment Regulation through Regulation (EU) No 660/2014 aims
at better addressing of the problem of illegal waste shipments by strengthening Member States'
inspection systems. Member States were required to establish inspection plans by 1 January
2017 based on a risk assessment that would aim, inter alia, to identify the minimum number of
inspections required. Moreover, the amendment the Waste Shipment regulation aims to provide
enhanced powers to the authorities involved in inspections, enabling them to decide on the
basis of evidence whether a carried substance or object is waste and whether a shipment can
be considered an illegal shipment of waste.
European Agreement Concerning the International Carriage of Dangerous Goods

(ADR):
The European Agreement concerning the International Carriage of Dangerous Goods by Road
(ADR) is under the auspices of the United Nations Economic Commission for Europe. The
Agreement was amended by the Protocol amending article 14(3) and entered into force on 19
April 1985.

Equivalent agreements have been realized concerning the International Maritime Dangerous
Goods Code (of the International Maritime Organization), the Technical Instructions for the Safe
Transport of Dangerous Goods by Air (of the International Civil Aviation Organization) and the
Regulations concerning the International Carriage of Dangerous Goods by Rail (of the
Intergovernmental Organisation for International Carriage by Rail).
If hazardous wastes are dangerous goods in the sense of ADR has to be decided in every
single case, depending of the quantity and concentration of toxic or corrosive substances in the
transport unit and physical properties of the waste (e.g. flashpoint of inflammable liquids). Most
of other hazardous properties (e.g. mutagenic) which may arise in hazardous waste streams are
not covered by the ADR agreement.
Examples of cases where the ADR regulations may apply are:
 Asbestos based insulation material (EWL code 17 06 01*) – UN 2590 or UN 2212,
class 9;
 PCB containing Construction & Demolition waste (EWL code 17 09 02*) – UN 3152,
class 9;
 Wastes containing mercury – UN 2809, class 8, UN 2825, class 6.1.
 Residues of paint and lacquer – UN 1263, class 3; UN 3066, class 8.
For these materials a proper packaging and labelling in accordance with the ADR agreement is
mandatory. Packaging and labelling has to be done at the place of generation.
Regulation on waste treatment
The Landfill Directive (1999/31/EC as amended by (EU) 2018/850)

The objective of the Landfill Directive is to prevent or reduce the adverse effects of the landfill of
waste on the environment. It defines the different categories of waste (municipal, hazardous,
non-hazardous waste and inert waste) to be landfilled and distinguishes three different classes
of landfills: Landfills for inert waste; Landfills for non-hazardous waste; Landfills for hazardous
waste.
A standard waste acceptance procedure is laid down so as to avoid any risks 5, namely:
 Waste must be treated before being landfilled;
 Hazardous waste must be assigned to a hazardous waste landfill;
 Landfills for non-hazardous waste are foreseen for (pre-treated) municipal waste and for
industrial and commercial non-hazardous waste;
 Landfill sites for inert waste must be used only for inert waste.
The waste acceptance procedure and criteria are defined in Article 11 and Annex II to the
Landfills Directive and in Council Decision 2003/33/EC establishing criteria and procedures for
the acceptance of waste at landfills.
The Landfill Directive sets up a system of permit conditions for landfill sites. Applications for
permits must contain the following information:
 the identity of the applicant respectively of the operator and it’s financial security;
 a description of the types and total quantity of waste to be landfilled;
 the capacity of the disposal site and a description of the site;
 the proposed methods for operation, monitoring and control plans, for pollution
prevention and abatement measures;
5
Council Decision of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills
pursuant to Article 16 of and Annex II to Directive 1999/31/EC, OJ L 11, 16.1.2003.

 the plan for closure and aftercare procedures;

 an impact assessment study, where required under Directive 85/337/EEC 6.
According to the Landfill Directive the following wastes may not be accepted in a landfill:
 liquid waste;
 flammable waste;
 explosive or oxidizing waste;
 hospital and other clinical waste which is infectious;
 used tires, with certain exceptions;
 Any other waste which does not meet the acceptance criteria laid down in Annex II.
The reduction of biodegradable waste going to landfills
Directive (EU) 2018/850 amending Directive 1999/31/EC on the landfill of waste was published
in the Official Journal of the European Union on June 14 th 2018 as a part of the European
Circular Economy Package. The main elements of the amendments of the Directive include:
 Member States shall take measures in order that waste that has been separately
collected for preparing for re-use and recycling are not accepted in a landfill;
 Member States shall endeavour to ensure that as of 2030, all waste suitable for
recycling or other recovery, in particular in municipal waste, shall not be accepted in a
landfill. The only exception concerns waste for which landfilling delivers the best
environmental outcome.
 Member States shall ensure that by 2035 the amount of municipal waste landfilled is
reduced to 10% or less of the total amount of municipal waste generated.
The Industrial Emissions Directive (2010/75/EU)

The Directive is the result of the recast of the IPPC Directive 7 (96/61/EC) and entered into force
in January 2011. Six other directives related to industrial emissions are taken up in the recast of
the IED. These are:
 Three directives on waste from TiO2 industry;
 The Directive on the limitation of emissions of volatile organic compounds due to the
use of organic solvents in certain activities and installations (1999/13/EC);
 The Directive on large combustion plants (2001/80/EC);
 The Waste Incineration Directive (2000/76/EC).
The IED is based on four main principles:
 The integrated approach, i.e. the permits must take into account the whole
environmental performance of the plant,
 The permit conditions including emission limit values must be based on the BATs, laid
down in BAT notes for each type of installation,
 Allowing the licensing national authorities certain flexibility, when determining permit
conditions, taking into account the technical characteristics of the installation, its
geographical location and the local environmental conditions.
 The participation of the public in the decision making process, giving access to permit
procedure in order to give comments, and access to a public register, which is intended
to provide environmental information on major industrial activities.
6
Council Directive 85/337/EEC of 27 June 1985 on the assessment of the effects of certain public and private projects
on the environment (Environmental Impact Assessment Directive)
7
Directive 96/61/EC concerning integrated pollution prevention and control (IPPC Directive)

Like the former IPPC Directive, the aim of the IED is to achieve a high level of environmental
protection through the integrated permitting of certain highly polluting new or existing industrial
and agricultural installations, the so-called "IED (former IPPC) installations". It covers a wide
range of activities, i.e. from metals production, the processing of minerals, chemical
manufacture, poultry and pig farming, to waste incineration and fuel combustion in large
combustion plants. This permit can only be issued if the relevant environmental conditions are
met, so that the companies themselves bear responsibility for preventing and reducing any
pollution they may cause.
The IED improves and clarifies the concept of the BATs (Best Available Technology Concept). It
also introduces minimum provisions on environmental inspections of installations, the review of
permit granting conditions, and reporting of compliance with regulations. Reference Documents
on Best Available Techniques (BAT) have been published for several industrial sectors and are
reviewed after a specific time period. The related Implementation Decisions cover the BAT
conclusions with requirements for limitations of emissions. The BREF Reference Document on
Waste Treatment and Waste Incineration are under revision in 2018 (for status, see also
Website of the EIPPC Bureau8).
Waste incineration and co-incineration plants:

With the adoption of the Directive 2010/75/EU on industrial emissions a recast of the Waste
Incineration Directive (2000/76/EC) took place. The requirements to waste incineration and co-
incineration are now given in Chapter IV (Articles 42 -55) of the Industrial Emissions Directive
(2010/75/EU). The technical requirements for installations using incineration or co-incineration
are found in Annex VI.
The delivery and reception of waste, especially of hazardous waste, is regulated in detail. Prior
to accepting hazardous waste, the operator has to have available information about the waste
and to carry out a comprehensive reception procedure. High standard measurement techniques
are required to monitor emissions to ensure compliance with the emission limit values.
Operators of waste incineration and co-incineration plants of a capacity of 2 tonnes or more per
hour have to realize an annual report about the functioning and monitoring of the plant which
has to be provided to the competent authority and to be made available to the public. In
addition, the competent authority has to elaborate a list of incineration or co-incineration plants
with a nominal capacity of less than 2 tonnes per hour and has to make this list available to the
public.
Landfills falling under the scope of the IED

Some landfills covered by Directive 1999/31/EC on Landfill of Waste also fall within the scope of
the IED Directive (2010/75/EU). As a consequence, the requirements laid down in Annex I to
the Landfills Directive replace the emission limit values, equivalent parameters and technical
measures based on best available techniques (BAT) required by the Industrial Emissions
Directive.
The Industrial Emissions Directive also requires competent authorities to periodically recon-
sider and, where necessary, up-date the permit conditions. This obligation is independent from
pollution levels, substantial changes in BA, safety requirements or new legislative provisions. No
corresponding provision exists in the Landfills Directive. Any landfill also covered by the IED
must be made subject to such periodic reconsideration. Landfills covered by the IED must be
made subject to public participation and information as outlined above.
8
http://eippcb.jrc.ec.europa.eu/

Waste stream specific regulations

On the special waste streams covered by this Strategy a numerous number of European
Directives have been established in terms of harmonizing national measures concerning the
management of these wastes and enabling a high level of environmental protection and
ensuring the functioning of the internal market.
The Directives on the specific waste streams set inter alia targets to be met by the Member
States to guarantee sufficient re-use, recycling and recovery of wastes. Certain targets were
amended throughout the Circular Economy Package and finally approved by the European
Parliament in 2018.
Table 1 gives an overview on main targets defined by European Directives.

Table 1: Targets defined in EU legislation for recovery of specific waste streams

Legislation Main content of the legislation
Directive 94/62/EC on packaging and  Member States are to introduce systems for the
packaging waste (amended latest by return and/or collection//treatment of used
Directive (EU) 2018/852) packaging to attain the following targets:
- No later than 31 December 2025 (2030) a
minimum of 65% (70%) by weight of all
packaging waste will be prepared for reuse and
recycled;
- No later than 31 December 2025 (2030) the
following minimum targets by weight for
preparing for reuse and recycling will be met
regarding the following specific materials
contained in packaging waste: (i) 50% (55%)of
plastic; (ii) 25% (30%) of wood; (iii) 70% (80%) of
ferrous metal; (iv) 50% (60%) of aluminium; (v)
70 (75%) of glass; (vi) 75% (85%) of paper and
cardboard.
Directive 2000/53/EC on end-of life  Member States were to introduce systems for the
vehicles (ELV) (amended latest by return and/or collection/treatment of end-of life
Directive 2017/2096/EC and by Directive vehicles (ELV) to attain the following targets:
(EU) 2018/849) - No later than 1 January 2015, for all end-of life
vehicles, the reuse and recovery shall be
increased to a minimum of 95 % by an average
weight per vehicle and year. Within the same
time limit, the re-use and recycling shall be
increased to a minimum of 85 % by an average
weight per vehicle and year.


Directive 2012/19/EC on waste electrical  Member States were to introduce systems for the
and electronic equipment (WEEE) return and/or collection//treatment of waste
(recast, amended latest by Directive (EU) electrical and electronic equipment (WEEE) to attain
2018/849) the following targets:
- From 2016 onwards, taking account individual
national economies: Collection target of 45% of
the average weight of products placed on the
market in a given country in the 3 preceding
years;
- From 2019, the collection target increases to 65%
of the average weight of products placed on the
market in a given country in the 3 preceding
years.
- From 15 August 2018 the recovery targets apply
as follows:
 for temperature exchange equipment and
large equipment (any external dimension
more than 50 cm): 85 % shall be recovered,
and 80 % shall be prepared for re-use and
recycled;
 for screens, monitors, and equipment
containing screens having a surface greater
than 100 cm²: 80 % shall be recovered, and
70 % shall be prepared for re-use and
recycled;
 for small equipment and small IT and
telecommunication equipment: 75 % shall be
recovered, and 55% shall be prepared for re-
use and recycled;
 for lamps: 80 % shall be recycled.
Directive 2006/66/EC on batteries and  Member States were to introduce systems for the
accumulators and waste batteries and return and/or collection/treatment of batteries and
accumulators (amended latest by accumulators and waste batteries and accumulators
Directive 2013/56/EU and by Directive to attain the following targets:
(EU) 2018/849) - Minimum collection rates of 45 % by 26
September 2016 (including batteries and
accumulators incorporated into appliances).
- Recycling processes shall achieve the following
minimum recycling efficiencies:
 recycling of 65 % by average weight of lead-
acid batteries and accumulators, including
recycling of the lead content to the highest
degree that is technically feasible while
avoiding excessive costs;
 recycling of 75 % by average weight of nickel-
cadmium batteries and accumulators,
including recycling of the cadmium content to
the highest degree that is technically feasible
while avoiding excessive costs; and
 recycling of 50 % by average weight of other
waste batteries and accumulators.

For specific waste streams minimum technical requirements for treatment are defined in several
European Directives (e.g. Annex I of Directive 2000/53/EC (ELV Directive); Annex VII and VIII of
Directive 2012/19/EU (WEEE Directive); Annex III of Directive 2006/66/EC (Batteries Directive)).
Those, in combination with the Best Available Techniques defined in the related sectoral
Reference Documents (EIPPCB) gave the framework for environmentally sound management
and treatment of specific waste streams.
For several waste streams covered by European legislation financing schemes are proposed to
achieve high collection and recycling rates by applying the “producer responsibility” principle.
Thereby, all producers as defined by the Directives should be registered in order to participate
in financing the net costs of collecting, treating and recycling of collected wastes (see also
Article 8 of the WFD and specific obligations defined in the waste stream related regulation).
Specific requirements for the management of waste oils and bio-waste are laid down in Article
21 and 22 of the WFD comprising e.g. separate collection and treatment considering a high
level of environmental protection. Construction and demolition waste is also tackled in the
WFD by defining a recycling target on that waste stream (see Article 11 of the WFD). In
addition, the WFD sets recycling targets for municipal waste and non-hazardous C&D
wastes except excavated soil (Article 11 of the WFD)
The Directive on Urban Waste Water Treatment (91/271/EEC) sets out EU-wide rules for
collection, treatment and wastewater discharge and defines inter alia minimum requirements for
the management of sewage sludge. The law also covers wastewater generated by industries
such as the agro-food industries (like food-processing and brewing). The Directive inter alia
requires EU countries to collect and treat wastewater in urban settlements with a population of
at least 2.000 and apply secondary treatment on the collected wastewaters and to apply more
advanced treatment in urban settlements with populations over 10.000 located in designated
sensitive areas.
There are more stringent provisions for agglomerations discharging into sensitive areas such as
fresh waters or estuaries.
Complementary, the sewage sludge Directive (86/278/EEC) seeks to encourage the use of
sewage sludge in agriculture and to regulate its use in such a way as to prevent harmful effects
on soil, vegetation, animals and man.
Wastes which result from prospecting, extraction, treatment and storage of mineral re-sources
and the working of quarries and are covered by the Mining Waste Directive (2006/21/EC) are
excluded from the scope of the Waste Framework Directive (2008/98/EC). For those wastes
from extractive industries the Mining Waste Directive (2006/21/EC) introduces measures for
safe management, treatment and storage of mineral resources and the working of quarries. It
lays down the rules for the granting of permits to operators of extractive industry waste facilities.
The operators must provide a financial guarantee to ensure that the Directive’s obligations are
covered prior to operations beginning. They must also ensure that funding is available for site
restoration when a facility closes down.
Additional regulation addressing hazardous substances in waste streams

In the following, main EU regulation tackling hazardous substances are listed and related
obligations defined therein are shortly described:
Table 2: Selected EU regulation on hazardous substances


Directive 87/217/EC on the prevention  Member States must take inter alia the measures
and reduction of environmental necessary to:
pollution by asbestos - ensure that asbestos emissions into the air,
asbestos discharges into the aquatic environment,
and solid asbestos waste are, as far as reasonably
practicable, reduced at source and prevented;
- to ensure that in the course of the transport and
deposition of waste containing asbestos fibres or
dust, no such fibres or dust are released into the
air and no liquids which may contain asbestos
fibres are spilled;
- to ensure that where waste containing asbestos
fibres or dust is landfilled at sites licensed for the
purpose, such waste is so treated, packaged or
covered, with account being taken of local
conditions, that the release of asbestos particles
into the environment is prevented.
Regulation (EC) No 850/2004 on  Based on Global Treaty of the Stockholm Convention

persistent organic pollutants (the POPs on Persistent Organic Pollutants (adopted in 2001) and
Regulation) UNEP Aarhus Protocol (1998) the Regulation:
- creates a framework to protect human health and
the environment by prohibiting, phasing out as
soon as possible or restricting the production,
placing on the market and use of POPs;
- lays down rules for dealing with stockpiles and
waste containing POPs;
- requires EU countries to set up inventories for
unintentionally produced POPs, draw up national
implementation plans, monitor POPs in close
cooperation with the European Commission and
engage in information exchanges with both other
EU countries and non-EU countries.


Directive 96/59/EC on disposal of  The Directive establishes minimum requirements on
polychlorinated biphenyls and the disposal of polychlorinated biphenyls and
polychlorinated terphenyls (PCBs/PCTs) polychlorinated terphenyls (PCBs/PCTs) and the
decontamination or disposal of equipment containing
them. Member States inter alia are requires to take
measures ensuring that:
- used PCBs and PCTs and equipment containing
them are disposed of as soon as possible;
- inventories are compiled of equipment containing
more than 5 litres of PCBs and PCTs, and
summaries of these are sent to the European
Commission within 3 years of the legislation’s
adoption;
- companies disposing of PCBs and PCTs are
licensed and keep registers of the quantity, origin
and nature of the used PCBs and PCTs they
receive;
- safety precautions are in place to prevent any risk
of fire to PCBs and PCTs or equipment containing
them;
- transformers containing more than 0.05 % by
weight of PCBs or PCTs are decontaminated
according to the conditions specified in the
legislation.
Regulation (EU) 2017/852 on mercury  The Regulation establishes rules for the use and
storage of and trade in mercury, mercury compounds
and mixtures of mercury, and the manufacture and use
of and trade in mercury-added products, and the
management of mercury waste, such as:
- The export of mercury outside the EU shall be
prohibited and the export of specific mercury
compounds and mixtures of mercury shall be
prohibited as from the dates set out in the
regulation;
- The import of mercury and of specific mixtures of
mercury for purposes other than disposal as waste
shall be prohibited. Such import for disposal as
waste shall only be allowed where the exporting
country has no access to available conversion
capacity within its own territory.
- The use of mercury and mercury compounds in
specific manufacturing processes shall be
prohibited or shall only be allowed subject to the
conditions set out in the regulation;
- Mercury and mercury compounds, whether in
pure form or in mixtures, resulting from the chlor-
alkali industry, the cleaning of natural gas, non-
ferrous mining and smelting operations or
extraction from cinnabar ore within the Union
shall be considered to be waste within the
meaning of the WFD and be disposed of without
endangering human health or harming the


environment, in accordance with that Directive.
Directive 2011/65/EU restricting the use  The Directive strengthens existing rules on the use of
of certain hazardous substances in hazardous substances in electrical and electronic
electrical and electronic equipment equipment to protect human health and the
(recast) environment, by also promoting the appropriate
electrical and electronic equipment (EEE) end of life
with a view to maximising their recovery. Specifically,
the Directive:
- define restrictions in the use of hazardous
chemicals, such as lead, mercury and cadmium, to
specific EEE;
- list technical substance-specific applications that
are exempted from the restrictions. Several
exemptions have been added since the
publication of the directive and many have
expired and no longer apply; the exemption lists
are continuously updated in line with technical
progress;
- places an obligation on manufacturers to ensure
any EEE that they place on the market has been
designed and produced in line with the
requirements set out in the legislation;
- defines that importers must check that equipment
has been approved as meeting the required
standards, while distributors must also ensure the
rules are adhered to.
2.2.2 National policy and legislation in the area of waste management
The adoption of the Law on Waste Management, and the Law on packaging and packaging
waste in 2009, set up conditions for the establishment and development of an integrated waste
management system in the Republic of Serbia, in accordance with the standards of the relevant
EU legislation in this area. In addition, waste management is directly or indirectly regulated by
other regulations that provide the legal framework for environmental protection and sustainable
development in the Republic of Serbia.
Law on Waste Management (“Official Gazette of the Republic of Serbia“, No. 36/09, 88/10,
14/16) sets forth types of waste and its classification, waste management planning,
stakeholders, obligations and liability with regard to waste management, specific waste
streams management, requirements and procedures for the issuance of permits,
transboundary waste movement, reporting, waste management financing, supervision and
other relevant aspects of waste management. Waste management consists of a set of
activities of joint interest which comprise implementation of prescribed action plans to be
carried out within waste collection, transport, storing, treatment and disposal, including
supervision of the aforesaid activities and responsibility for waste management facilities upon
closure thereof. On the basis of this Law, a set of by-laws were adopted which define in details
the waste management framework, including management of specific waste streams. In
addition, these by-laws further harmonize national legislation with the EU regulations in this
area. On the basis of this law, the following by-laws have been adopted or prepared:

 Regulation on the lists of wastes for transboundary movement, on the content and
appearance of documents accompanying the transboundary movement of waste with
the filling instructions (“Official Gazette of the Republic of Serbia“, No. 60/09);
 Regulation on the determination of types of hazardous waste that can be imported as a
secondary raw material (“Official Gazette of the Republic of Serbia“, No. 60/09);
 Rulebook on the content of documentation submitted with an application for the
issuance of permit for the import, export and transit of waste (“Official Gazette of the
Republic of Serbia“, No. 60/2009, 101/2010, 48/2017, 80/2017, 98/2017, 38/2018);
 Rulebook on the form of application for permit for treatment, storing, recovery and
disposal of waste (Official Gazette of RS, no. 38/2018). ;
 Rulebook on the form of document on the movement of waste with the filling
instructions (“Official Gazette of the Republic of Serbia“, No. 114/13);
 Rulebook on the format of the Document on movement of hazardous waste, prior
notification template, manner of its submission and instructions for filling in (“Official
Gazette of the Republic of Serbia“, No. 17/2017);
 Rulebook on the content and design of the permit for storage, treatment and disposal of
waste (“Official Gazette of the Republic of Serbia“, No. 96/09);
 Rulebook on the manner and procedure of waste tires management (“Official Gazette of
the Republic of Serbia“, No. 104/09, 81/10);
 Regulation on products that after use become special waste streams (, form of daily
records on the type and quantity of manufactured and imported products and the annual
report, the methods and timeframe for submission of annual reports, taxpayers, criteria
for the calculation, the amount and method of calculation and payment of fee) (“Official
Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14);
 Regulation on manner and procedure for management of waste mercury-containing
fluorescent tubes (“Official Gazette of the Republic of Serbia”, No 97/2010).
 Regulation on categories, testing and classification of waste (“Official Gazette of the
Republic of Serbia“, No. 56/10);
 Rulebook on the methodology for data collecting on the composition and quantities of
communal waste at the local government unit territory (“Official Gazette of the Republic
of Serbia“, No. 61/10);
 Rulebook on conditions, the methods and procedure of waste oil management (“Official
 Rulebook on the content of the certificate of exemption from the obligation of obtaining
a permit to store of inert and non-hazardous waste (“Official Gazette of the Republic of
Serbia“, No. 73/10);
 Rulebook on Medical Waste Management (“Official Gazette of the Republic of Serbia“,
No. 78/10);
 Proposal for a “Rulebook on the Manner and Procedures for Pharmaceutical Waste
Management“, Ministry of Environmental Protection and Ministry of Health;
 Proposal for a “Rulebook on Medical Waste Management“, Ministry of Environmental
Protection and Ministry of Health;
 Regulation on abrogation of the Decree on waste oils (“Official Gazette of the Republic
 Rulebook on disposal of waste containing asbestos (“Official Gazette of the Republic of
Serbia“, No. 75/10)
 Rulebook on the procedure for management of waste batteries and accumulators
(“Official Gazette of the Republic of Serbia“, No. 86/10);
 Rulebook on the manner of storage, packaging and labelling of hazardous waste

 Regulation on disposal of waste in landfills (“Official Gazette of the Republic of Serbia“,

No. 92/10)
 Regulation on abrogation of the Decree on criteria for location and planning of the
landfill (“Official Gazette of the Republic of Serbia“, No. 92/10);
 Rulebook on the contents, manner and appearance of the register of issued permits for
waste management (“Official Gazette of the Republic of Serbia“, No. 95/10);
 Rulebook on the forms of daily records and annual reports on waste with instructions to
complete it (“Official Gazette of the Republic of Serbia“, No. 95/10, 88/15);
 Rulebook on the procedure for the management of waste fluorescent tubes containing
mercury (“Official Gazette of the Republic of Serbia“, No. 97/10);
 Rulebook on conditions and manner of collection, transport, storage and treatment of
waste that is used as a secondary raw material or for energy production (“Official
 Rulebook on the procedure for end of life vehicle management (“Official Gazette of the
 Rulebook on the List of electrical and electronic products, measures of prohibition and
restrictions on the use of electrical and electronic equipment containing hazardous
substances, manner and procedure for management of waste of electrical and
electronic product (“Official Gazette of the Republic of Serbia“, No. 99/10);
 Regulation on the List of non-hazardous waste for which no permit is issued, with the
documentation accompanying transboundary movement (“Official Gazette of the
 Regulation on waste types for which thermal treatment, the conditions and criteria for
determining of the location, technical and technological requirements for the design,
construction, equipping and operation of plants for thermal treatment of waste,
treatment of residue after combustion are performed (“Official Gazette of the Republic
of Serbia“, No. 102/10, 50/12);
 Rulebook on treatment of devices and waste containing PCB (“Official Gazette of the
 Rulebook on the list of POPs substances, the manner and procedure for the
management of POPs waste and limit values for concentrations of POPs substances
related to the disposal of wastes containing or contaminated with POPs substances
(“Official Gazette of the Republic of Serbia“, No. 65/11, 17/2017);
 Rulebook on the manner and procedure for the management of titanium dioxide waste,
measures of supervision and environmental monitoring of the site (“Official Gazette of
the Republic of Serbia“, No. 1/12)
 Rulebook on adjusted amounts for the management of specific waste streams (“Official
Law on Packaging and Packaging Waste Management (“Official Gazette of the Republic
of Serbia“, No. 36/09) sets forth environmental requirements which packaging must meet in
order to be marketed; packaging and packaging waste management, reporting on
packaging and packaging waste, economic instruments, as well as other relevant issues
with regard to packaging and packaging waste management. The Law also regulates
imported packaging, produced, i.e. marketed packaging, as well as packaging waste
generated in the course of business activities on the territory of the Republic of Serbia,
regardless of its origin or purpose, and used packaging material.
The Serbian legal framework is adequately addressing the following aspects promoted by the
Directive:

 shared responsibility among all commercial entities in compliance with the “polluter
pays” principle throughout whole life-cycle of a product;
 prevention, i.e. reduction of generation of packaging and packaging waste, as
well as harmful effects thereof for the environment;
 reuse of packaging, recycling and other forms of reuse and reduced final
disposal of packaging waste;
 voluntary agreements on packaging waste management.
Based on this Law, and in order to create a more precise framework for implementation, by-laws
were adopted. On the basis of this law the following by-laws have been adopted:
 Rulebook on the types of durable packaging (“Official Gazette of the Republic of
 Rulebook on the criteria for determining whether something is package, with examples
for the application of criteria and the list of Serbian standards regarding basic conditions
which a package must fulfil to be placed on the market (“Official Gazette of the Republic
 Rulebook on the annual quantity of packaging waste according to types which must be
provided space for the takeover, collection, classification and temporary storage
 Rulebook on the manner of numbering, the abbreviations and symbols on which the
system of identification and marking of packaging materials is based (“Official Gazette
of the Republic of Serbia“, No. 70/09);
 Rulebook on the type and annual quantity of packaging used for the packaged product
placed on the market, for which the producer, importer, packer/filler and the supplier is
not obliged to ensure packaging waste management (“Official Gazette of the Republic
 Rulebook on the limit value of the total level of concentration of lead, cadmium, mercury
and hexavalent chrome in the package or its components, exemptions from application
and the deadline for limit value application (“Official Gazette of the Republic of Serbia“,
No. 70/09);
 Rulebook on the contents and methods for keeping the register of licenses issued for
packaging waste management (“Official Gazette of the Republic of Serbia“, No. 76/09);
 Regulation on establishing the Plan for reduction of packaging waste from 2015-2019
 Regulation on criteria for calculation of fee for packaging or packaged product and
exemption from payment of fees, payers, amount of fees and the method of calculation
and payment of fees (“Official Gazette of the Republic of Serbia“, No. 08/10, 22/16);
 Rulebook on form of the report on packaging management and packaging waste
(“Official Gazette of the Republic of Serbia“, No.21/10, 10/13);
 Rulebook on chemicals for which the producers or importers is obligated to establish a
deposit for an individual packaging contained chemicals (“Official Gazette of the
 Regulation on technical and other requirements for plastic bags with additives for
oxidational degradation and biodegradation, on appraisal of harmonisation and
conditions that must be met by appointed body (“Official Gazette of the Republic of
Serbia“, No.3/12).
Law on Environmental Protection (“Official Gazette of the Republic of Serbia“, No. 135/04,
36/09, 72/09 (state law), 43/11 (CC), 14/16) sets forth the integrated system of environmental
protection comprising action plans, conditions and instruments for sustainable management
and conservation of natural balance, integrity, diversity and quality of natural values and

conditions for survival of living beings, prevention, control, reduction and rehabilitation of all
forms of pollution, promotion and utilization of products, processes, technologies and
practices which have less harmful effect on environment, application of special codes of
conduct in waste management from its generation point to its disposal, i.e. prevention or
reduction of its generation, waste reuse and recycling, separation of secondary raw
materials and utilization of waste as fuel, waste import, export and transit, establishment of
Environmental Protection Agency, staff training designed to upgrade knowledge and raise
awareness, information access and participation of the public in decision making process. In
addition, the Law stipulates rule in the management from the waste generation to final disposal,
including prevention, reuse and recycling, transboundary shipment of waste. On the basis of
this law the following by-laws have been adopted:
 By-law on the requirements to be fulfilled by competent organizations for waste testing
 Regulation on the type of pollution, the criteria for calculation of charges for
environmental pollution and payers, the amount of charges and manner of charge
calculation and payment (“Official Gazette of the Republic of Serbia“, No. 113/05,
6/07,8/10,102/10, 15/12, 91/12) stipulating the liability to pay the charge for
environmental pollution according to the type, amount or characteristics of emission
from specific sources, i.e. type, amount or characteristics of emission of generated or
disposed waste, as well as according to the quantity of materials harmful to
environment in raw materials, semi-products or products;
 Regulation on the measures and conditions for return, exemption or reduction of a
charge for environmental pollution (“Official Gazette of the Republic of Serbia“, No.
113/05);
 Rulebook determining consolidated amounts of charge for environmental pollution
(“Official Gazette of the Republic of Serbia“, No. 43/2017) regulating annual amounts of
charges for, inter alia, disposed non-hazardous industrial waste and generated
hazardous waste;
 Rulebook on the methodology for the elaboration of the integral cadastre of polluters
 Rulebook on more detailed conditions and procedure for obtaining the right to utilise
ecological label, the elements, layout and manner of utilisation of ecological label for
products, processes and services (“Official Gazette of the Republic of Serbia“, No.
3/09);
 Rulebook on methodology for the design of national and local registry of sources of
pollution, as well as the methodology for the types, terms and data collection (“Official
Gazette of the Republic of Serbia“, No. 91/10)
 Rulebook on adjusted amounts for the environmental pollution tax (“Official Gazette of
the Republic of Serbia“, No. 43/17) which prescribes annual fee, also for disposed non-
hazardous industrial waste as well as generated hazardous waste;
Law on Strategic Environmental Assessment (“Official Gazette of the Republic of Serbia“,

No. 135/04, 88/10) sets forth the relations between environmental protection policy and
other departmental policies, which are currently being developed, as well as the development
of new plans and programmes in the field of spatial and urban planning or land use,
agriculture, forestry, fisheries, hunting, energy, industry, transport, waste management, water
management, telecommunications, tourism, natural habitat and wild flora and fauna
conservation, establishing a framework for adoption of future development projects.
Furthermore, it regulates conditions, method and procedures of conducting the strategic
assessment of environmental impact of certain plans and programmes within their
preparation and adoption phases, as well as the content of reports to be made on strategic

assessment, its verification and public involvement, i.e. participation in the report evaluation
proceedings.
Law on Environmental Impact Assessment (“Official Gazette of the Republic of Serbia“,

No. 135/04 and 36/09) sets forth the procedure with regard to the assessment of
potentially significant environmental impacts of certain projects carried out by public or
private enterprises, the content of study on environmental impact assessment, the liability of
applicants for permits or approvals for development or reconstruction of buildings, the
change of technologies, the capacity expansion, the discontinuation of operations and
cancellation of projects which may have an important environmental impact or other
interventions taking place in nature and natural environment, as well as participation of the
public in project development or approval. The impact assessments is carried out in the
case of projects in the field of industry, mining, energy, traffic, tourism, agriculture, forestry,
water management, waste management and public utility services, as well as in the case
of projects planned in protected areas or protected surroundings of immovable cultural good.
On the basis of this law, the following by-laws have been adopted:
 Regulation on the establishment of the List of projects for which the impact assessment
is mandatory and the List of projects for which the environmental impact assessment
may be required (“Official Gazette of the Republic of Serbia“, No.114/08);
 Rulebook on the content of the application for the impact assessment need, and the
content of the application for the establishment of the scope and content of the study on
environmental impact assessment (“Official Gazette of the Republic of Serbia“, No.
69/05);
 Rulebook on the content of the study on environmental impact assessment (“Official
 Rulebook on the activities of the technical commission for evaluation of the
environmental impact assessment study (“Official Gazette of the Republic of Serbia”,
No. 69/05);
 Rulebook on the procedure of public insight, presentation and public discussion on the
environmental impact assessment study (“Official Gazette of the Republic of Serbia”,
No. 69/05);
 Rulebook on the content, layout and method of maintaining the public register on
conducted procedures and rendered decisions on environmental impact
assessment (“Official Gazette of the Republic of Serbia”, No. 69/05);
Law on Integrated Pollution Prevention and Control (“Official Gazette of the Republic of
Serbia“, No. 135/04, 25/15) sets forth conditions and procedure for issuance of integrated
operating permit for plants and activities which may have negative impact on human
health, environment or tangible assets, type of activities and plants, supervision and other
relevant aspects of environmental pollution prevention or control. Based on this Law, few by-
laws were adopted in order to define obligations of the operator and time schedule of application
for IPPC permit. On the basis of this law, the following by-laws have been adopted:
 Regulation on types of activities and plants for which the integrated permit is issued
(“Official Gazette of the Republic of Serbia”, No. 84/05);
 Regulation on the criteria for determining the best available techniques, application of
quality standards, as well as limit values of emission in the integrated permit (“Official
Gazette of the Republic of Serbia”, No. 84/05);
 Regulation on the content of the program of measures for adjustment of existing facility
operations or activities to the prescribed conditions (“Official Gazette of the Republic of
Serbia”, No. 84/05);
 Rulebook on the content, layout and method of maintaining the register of issued

integrated permits (“Official Gazette of the Republic of Serbia”, No. 69/05);

 Rulebook on the content, layout and method of filling in the application for integrated
permit (“Official Gazette of the Republic of Serbia”, No. 30/06, 32/2016);
 Rulebook on the content and layout of the integrated permit (“Official Gazette of the
Republic of Serbia”, No. 30/06);
 Regulation on the establishment of the Program of dynamics of application for
integrated permits (“Official Gazette of the Republic of Serbia”, No. 108/08);
Law on Mining and Geological Investigation (“Official Gazette of the Republic of Serbia“, No.
101/2015) define, beside other issues, mining waste management, i.e. waste from extractive
industry. The Law stipulates obligation for preparation of Mining waste management plan and
issuing of permit for disposal and management of mining waste. By-law based on Law on
Mining and Geological Investigation:
 Regulation on conditions and procedure of issuing permits for waste management, as
well as the criteria, characterization, classification and reporting on mining waste
(“Official Gazette of the Republic of Serbia“, No. 53/2017).
Law on planning and construction (“Official Gazette of the Republic of Serbia“, No. 72/09,
81/09-corr., 64/10 –decision CC, 24/11, 121/12, 42/13- decision CC and 50/13-decision CC,
98/2013 – decision CC, 132/14, 145/14) prescribes procedure for construction of infrastructure
for waste management. Also it determines the conditions and method of spatial planning,
arrangement and utilisation of construction land and development and utilisation of buildings.
Law on Utility Services (“Official Gazette of the Republic of Serbia”, No. 88/11, 104/16)
determines utility services and regulates general conditions and manner of their provision,
enable organisation and provision of utility services for two or more municipalities and/or
towns, under the conditions stipulated by the law and agreement among the municipal
assemblies.
Law on Chemicals (“Official Gazette of the Republic of Serbia”, No. 36/09, 88/10, 92/11,
93/12, 25/15) regulates integrated management of chemicals, classification, packaging and
labelling of chemicals, the integrated chemical register and register of chemicals placed on the
market, restrictions and prohibitions for production, placement on the market and use of
chemicals, import and export of certain hazardous chemicals, permits for trading operations
and permits for utilisation of particularly hazardous chemicals, placement of the detergents
on the market, systematic monitoring of chemicals, availability of data, surveillance and
other issues of importance for chemical management.
Law on Biocidal Products (“Official Gazette of the Republic of Serbia“, No. 36/09, 88/10,
92/11, 25/15) sets forth the lists of active substances, the procedures for adoption of acts
determining the placement of biocidal products on the market, the restrictions and
prohibitions of exploitation and placement the biocidal products on the market, the research
and development of biocidal products, the classification, packaging, labelling, advertising and
safety data sheet of a biocidal product, the register of biocidal products, the safe utilisation of
biocidal products, monitoring and other areas of concern for safe utilisation and placement of
biocidal products on the market.
Law on Air Protection (“Official Gazette of the Republic of Serbia”, No.36/09, 10/13)
regulates air quality management, and stipulates the measures, the manner of
organization and control of implementation of protection and promotion of the quality of air
as a natural value of common interest under special protection. The provisions of this Law

shall not apply to pollutions caused by radioactive materials, industrial accidents and
natural disasters. On the basis of this law, the following by-laws have been adopted:
 Up to finishing the operation emission limit value from the Rulebook on emission limit
values, method and schedule of measurement and recording of data (“Official Gazette
of the Republic of Serbia“, No. 30/97, 35/97 – corr.);
 Regulation on the conditions for monitoring and requirements for air quality (“Official
Gazette of the Republic of Serbia“, No. 11/10, 75/10, 63/13);
Law on Plant Health (“Official Gazette of the Republic of Serbia”, No. 41/09), by whose
entry into force the Law on Plant Protection ceased to be valid (”Official Gazette of the
FRY”, No. 24/98, 26/98 – correction, “Official Gazette RS” No.101/05 – other law and 41/09-
other law) regulates the method of manipulation of plant harmful organisms, seized
consignments of pesticides and fertilisers, including their destruction. The following by-laws
shall apply:
 Rulebook on the method of plant destruction designated to be destroyed (“Official
Gazette of the FRY”, No. 67/01);
 Rulebook on the types of packaging for pesticides and fertilisers and destruction of
pesticides and fertilisers (“Official Gazette of the FRY”, No.35/99 and 63/01)
Law on Veterinary Medicine (“Official Gazette of the Republic of Serbia”, No. 91/05,
30/10, 93/12) regulates the protection and promotion of animal health and welfare,
determines animal infectious diseases and measures for the prevention of occurrence,
detection, prevention of spreading, control and elimination of animal infectious diseases and
diseases that can be passed from animals to humans, the veterinary-sanitary control and
requirements for breeding and trading in animals, the production and trading in products
of animal origin, foods of animal origin, food for animals, the requirements for veterinary
practice, as well as the method of safe disposal of animal corpses and animal waste. The by-
laws passed on the basis of this Law are:
 Rulebook on the method of classification and treatment of animal by-products,
veterinary-sanitary conditions for construction of facilities for the collection, treatment
and destruction of animal by-products, method of official control and self-control, as well
as conditions for animal cemeteries and grave pits (“Official Gazette of the Republic of
Serbia“, No. 31/11, 97/13, 15/15, 61/17);
Law on Medicines and Medical Devices (“Official Gazette of the Republic of Serbia“, No.
30/10, 107/12,105/17 (state law),113/17 (state law)) stipulates the conditions for the
production, trade in and testing of medicines and medical products used in human and
veterinary medicine, the monitoring in these areas, the establishment of the Agency for
Medicines and Medical Products of Serbia, permitting conditions and procedure for placing
the medicines and medical products and other issues of importance on the market.
Law on Sanitary Surveillance (“Official Gazette of the Republic of Serbia“, No. 125/04)
regulates the method of and procedure for conducting sanitary surveillance, defines areas and
establishments subject to sanitary surveillance and the sanitary requirements to be met by
establishments.
Law on Health Care (“Official Gazette of the Republic of Serbia“, No. 107/05, 72/09 (state
law), 88/10, 99/10, 57/11, 119/12, 45/13 (state law), 93/14, 96/15, 106/15, 105/17 (state law),
113/17 (state law)) regulates the healthcare system, the organization of health service, the
social care for the population health, general interest in health care, the rights and

obligations of patients, health care for foreign citizens, the establishment of the Agency for
Accreditation of Health Institutions in Serbia, the surveillance and other issues of importance
to organisation and implementation of health care. The scope of social concern for the health
of the population includes, inter alia, the responsibility to adopt state program in the area of
health care concerning the polluted environment which has resulted from the presence of
harmful and hazardous substances in the air, water and soil, disposal of waste materials,
hazardous chemicals etc. The responsibility of health institutions and private practice to
organise, i.e. to provide measures for disposal and/or destruction of medical waste in
conformity with the law has been established as well.
Law on Standardisation (“Official Gazette of the Republic of Serbia“, No. 36/09, 46/15)
stipulates the principles and objectives of standardisation, establishment, organisation and
operation of standardisation organisation, the adoption, issuance and application of Serbian
standards and related documents in the field of standardisation. Serbian standards (SRPS
EN) concerning specific requirements for placing the packaging on the market apply in Serbia,
and these are the following:
 Identification of critical regions for the reduction of used raw materials (SRPS EN
13428)
 Methodology for determining the concentration of heavy metals, depending on
packaging material or its component (SRPS EN 13695-1);
 Identification of the presence of hazardous materials in the package or the
components thereof, and the possibility of their presence in the emission, ashes and
leachate water from landfills. (SRPS EN 13428 and 13695-2);
 Requirements for minimisation if hazardous materials have been identified in the
packaging or its component that can be released into the environment (SRPS EN
13695-2, subsection 7);
 Presentation of harmonisation with the minimisation requirement (SRPS EN 13695-2,
subsection 8, SRPS EN 13428, appendix C);
 Identification of the most appropriate system of recoverable use for certain type of
packaging (SRPS EN 13429);
 Assessment of packaging harmonisation with the requirements for reusable packaging
(SRPS EN 13429);
 Criteria for packaging suitable for recycling (SRPS EN 13430);
 Methodology for the assessment of harmonisation of packaging with the
requirements of certain criteria (SRPS EN 13430);
 Methodology for the assessment and evaluation of suitability of packaging for
biodegradation and composting (SRPS EN 13432);
 Methodology for the assessment of harmonisation of the packaging reusable in the
form of energy (SRPS EN 13431) and procedure for the application of that
methodology (SRPS EN 13427);
 Packaging – Labelling and material identification system (SRPS CR 14311).
Law on Waters (“Official Gazette of the Republic of Serbia“, No. 30/10, 93/12, 101/16)
regulates water management conditions and water management consent for specific industrial
facilities discharging wastewaters; regulates the obligation of construction of wastewater
treatment plant and facilities for disposal and discharge of wastewater, including industrial
and municipal landfills. By-laws adopted before the adoption of this Law, which are based on
the previous Law on Water, will be applied until by-laws based on this Law are adopted, except
the provisions which are in collision with this Law:
 Rulebook on hazardous substances in water (“Official Gazette of the Republic of

 Rulebook on method and minimal number of testing of wastewater quality (“Official

Gazette of the Republic of Serbia“, No. 47/83, 13/84);
By-laws based on Law on Waters are:
 Regulation on Limit Values of Priority and Priority Hazardous Substances Polluting
Surface Waters and Deadlines for their Achievement (“Official Gazette of the Republic
 Regulation on Emission Limit Values of Pollutants in Waters and Deadlines for their
Achievement (“Official Gazette of the Republic of Serbia“, No. 67/11, 48/12,1/16);
 Regulation on Limit Values of Pollutants in Surface and Ground Waters and Sediments,
and Deadlines for their Achievement (“Official Gazette of the Republic of Serbia“, No.
50/12);
 Rulebook on methods and conditions for wastewater quantity measurement and quality
testing, and the content of the measurement report (“Official Gazette of the Republic of
Serbia”, No. 33/2016).
Law on Agricultural Land (“Official Gazette of the Republic of Serbia“, No. 62/06 and
65/08 (state law), 41/09, 112/15, 80/17) regulates the protection of land, as well as the
conditions for land utilisation for mineral raw materials exploitation and disposal of tailing,
ashes and slag and other waste and hazardous substances on agricultural land and
stipulates the obligation of recultivation of agricultural land utilised for disposal of tailing,
ashes and slag or other waste material.
Law on Energy (“Official Gazette of the Republic of Serbia“, No. 57/11, 80/11 (corr.), 93/12,
124/12, 145/14 (state law).
Law on public private partnership and concession (“Official Gazette of the Republic of
Serbia“, No. 88/11, 15-16, 104-16).
Law on Ministries (“Official Gazette of the Republic of Serbia“, No. 44/14, 14/15, 54/15, 96/15
state law, 62/17).
Law on abolishing of the Environmental Protection Fund (“Official Gazette of the Republic
of Serbia“, No. 93/12).
Law Determining Competencies of the Autonomous Province of Vojvodina (“Official

Gazette of the Republic of Serbia“, No. 99/09, 67/12 CC) determines the competencies of the
autonomous province, particularly in the areas where the system is regulated by the
Republic, such as the following: culture, education, health care, sanitary inspection, protection
and improvement of the environment, urban planning, construction, economy and
privatisation, mining and power industry, agriculture, forestry etc.
Local Self-Government Law (“Official Gazette of the Republic of Serbia“, No. 129/07, 83/14
(state law), 101/16 (state law) stipulates the rights and responsibilities of a local self-
government unit stipulated by the Constitution, law, other regulation and statute (main and
entrusted affairs), the possibility of cooperation and association of the local self-
government units aiming at fulfilment of mutual objectives, plans and development
programmes, as well as other needs of common interest.
Law on Funding of Local Self-government (“Official Gazette of the Republic of Serbia“,

No. 62/06, 47/11, 93/12, 83/16,104/16 (state law)) regulates the manner of funding of local
self-government units from the source revenue and conceded public revenues of the

Republic.
Capital City Law (“Official Gazette of the Republic of Serbia“, No. 129/07, 83/14 (state law),
101/16 (state law) regulates the position, competences and authorities of the City of
Belgrade, the capital city of the Republic of Serbia.
Law on Public Enterprises (“Official Gazette of the Republic of Serbia“, No. 15/16)
regulates the establishment and business operation of the enterprises that perform activities
of general concern, the form and share of the state capital in a public enterprise, and
defines an activity of general concern as activities that are stipulated by law as such and that
are, inter alia, in the field of utilization, management, protection and promotion of assets of
general concern, as well as utility services.
Law on Commercial Entities (“Official Gazette of the Republic of Serbia“, No. 36/11, 99/11,
83/14 (state law), 5/15).
Criminal Code (“Official Gazette of the Republic of Serbia“, No.85/05, 88/05 (corr.), 107/05
(corr.), 72/09, 111/09, 121/12, 104/13, 108/14, 94/16) sanctions: the transfer of goods across
the customs border avoiding the measures of customs surveillance; the sale, distribution or
concealment of uncleared goods; illicit production or processing of goods without the
approval of a competent authority; illicit trade, production, sale or marketing of harmful
food products, food or drinks or other harmful products; pollution of drinking water or food
products; the breach of regulations concerning the protection, preservation and promotion of
the environment by air, water and soil pollution; failure to undertake designated
environmental protection measures; illegal construction, in case that authorized or
competent person approves the construction, operation or exploitation of facility or the
application of the technology polluting the environment, thus acting against the regulations on
the environmental protection.
2.2.3 Other national strategic documents
The implementation of a sustainable waste management system is an essential part of a

sustainable development strategy. Thus the lack of an adequate waste management system
was identified as one main risk factor for the sustainable development of Serbia in the National
Sustainable Development Strategy9 pursuant to Article 17, paragraph 1 and Article 45,
paragraph 1 of the Law on the Government. The implementation of an adequate waste
management system is listed as priority measure in the sustainable development strategy.
However in line with the holistic approach of the sustainable development strategy such a waste
management system shall take into account not only the technical requirements for save and
environmentally sound waste management but also the combined socio-economic effects.
The national spatial plan of the Republic of Serbia 2010 – 2020 10 (adopted by the Serbian
parliament on November 23rd 2010) as general spatial planning instrument defines areas for 27
centres for collection of municipal wastes, areas for 5 centres for intermediate storage of
hazardous wastes and an area for centralized hazardous waste management.
9
http://www.srbija.gov.rs/extfile/sr/88898/nacionalna_strategija_odrzivog_razvoja0081_cyr.zip
10
http://195.222.96.93//media/zakoni/Spatial%20Plan%20of%20the%20Republic%20of%20Serbia_2010-
2020_abridged%20(1).pdf

The harmonization of the legal framework for waste management in Serbia with the legal
framework of the European Union is part of the accession process and part of the National
Program for the Adoption of the EU Acquis.11
2.2.4 Status of transposition
Directive 2008/98/EC
The 2016 amendment of the LWM implemented relevant provisions of Directive 2008/98/EC,
e.g. on by-products and the End-of-waste status. However relevant provisions including the
changes of Annex 3 and the 2018 amendment of the WFD still need to be transposed.
Management of waste oils is currently regulated by the Waste Framework Directive
(2008/98/EC), which repealed the Directive on waste oils (79/439/EEC). Nevertheless, it might
be worth keeping in mind the main contents of the Waste Oil Directive (79/439)/EEC), because
until now waste oil is regulated in Serbia by the Waste Management Act and GOVERNMENTAL
ORDER ON CONDITIONS, METHODS AND MANAGEMENT PROCEDURES OF WASTE OILS, which both
transposed the repealed Directive 75/439/EEC on waste oils into the national legislation.
The definition of hazardous wastes and hazardous properties is based on Article 8 of the LWM
in conjunction with the REGULATION ON CATEGORIES, TESTING AND CLASSIFICATION OF WASTE
(“Official Gazette of RS”, No. 56/10). Article 8 of the LWM still refers to obsolete Q- and Y-
categories and constituent lists and doesn’t reflect the HP-properties as defined in Annex III of
the WFD (Commission Regulation (EU) 1357/2014 and Council Regulation (EU) 2017/997).
Recycling targets in accordance with Article 11 of the WFD (amended by Directive (EU)
2018/851) have not been implemented yet.
Commission Decision 2000/532/EC

Commission Decision 2000/532/EC (as amended) is transposed by the LWM in combination
with the REGULATION ON CATEGORIES, TESTING AND CLASSIFICATION OF WASTE (Official Gazette of
RS, No. 56/10). However the amendment by Commission Decision 2014/995/EC (adding a new
waste code and changing the limits for hazard characteristics) has not been implemented yet.
Directive 1999/31/EC and Council Decision 2003/33/EC

The Directive and the Council Decision were transposed by the LWM in combination with the
REGULATION OF LANDFILL OF WASTE (“Official Gazette of the Republic of Serbia”, No. 92/10) and
REGULATION ON CATEGORIES, TESTING AND CLASSIFICATION OF WASTE (“Official Gazette of RS”,
No. 56/10). However the REGULATION ON CATEGORIES doesn’t cover fully the two step approach
(basic characterization and on site verification) of Council Decision 2003/33/EC. Furthermore,
despite that the provisions of Directive 1999/31/EC are already reflected in the Serbian law, the
major part of existing sites don’t comply with the legal requirements.
The amendment of the landfill directive by Council Directive 2011/97/EU has not been
implemented. Since the amendment refers to the storage of metallic mercury and there is no
obligation to transpose this amendment provided the exemption for metallic mercury is not used.
Also the amendment by Directive of Council and Parliament 2018/850 have not been
implemented yet.
Directive 94/62/EC as amended by Directive (EU) 2015/720 and Directive (EU) 2018/852
11
The third revised version of the National Programme for the Adoption of the Acquis Communautaire covering the
period 2019-2011 has been adopted on March 1st 2018

The Directive was transposed into the Serbian national legislation by Law on Packaging and
Packaging Waste (Official Gazette of the RS, No. 36/09) and other related legal act. The law is
broadly in line with the Directive and establishes “the environmental requirements that should be
met by packaging so as to be placed on the market, packaging and packaging waste
management, reporting on packaging and packaging waste, economic instruments, as well as
other issues important for packaging and packaging waste management”.
However, the analysis of the provision of Article 1(2) of the LPPW shows that the Serbian law is
narrower in scope in comparison with the Directive by excluding the packaging waste released
at industrial, office, shop, service, household or any other level, regardless of the material use.
The Serbian text refers only the “packaging waste generated in commercial activities in the
Republic of Serbia, regardless its origin, use and used packaging material.” Also, some other
aspects (e.g. several definitions, packaging waste prevention national programme and
packaging waste management plan, plastic bags) need to be addressed in the following period
in order to fully transpose the Directive. The changes of the Directive 94/62/EC introduced by
Directive (EU) 2018/852 require further adaptation of the LPPW and its by-laws (namely with
regard to recycling targets and stricter extended producer responsibility).
To conclude the Directive is partially transposed.
Directive 96/59/EC on PCB/PCT

The Directive is transposed by the LWM in connection with the RULEBOOK ON TREATMENT OF
DEVICES AND WASTE CONTAINING PCB (“Official Gazette of the Republic of Serbia“, No. 37/11).
However the sunset clause for the use of PCB-containing electrical equipment in accordance
with Article 3 of the directive (disposal or decontamination of PCB-containing equipment) was
not transposed, nor is there a fixed date of expire for the use of PCB-containing equipment.
Directive 2000/53/EC on ELV

The Directive 2000/53/EC is transposed by the LWM in combination with the RULEBOOK ON THE
MANNER OF ELV MANAGEMENT (Official Gazette RS, No. 98/10). Specific parts of the Directive
are transposed only on the level of a by-law (Rulebook).
Regulation (EC) 850/2004 on POPs

The EU POPs regulation has not been fully transposed yet. The management of POPs wastes
is regulated by the RULEBOOK ON THE LIST OF POPS, MANNER AND PROCEDURE FOR POPS
WASTE MANAGEMENT AND LIMIT VALUE OF POPS CONCENTRATION RELATED TO DISPOSAL OF
WASTE CONTAINING POPS OR CONTAMINATED WITH POPS (“Official Gazette of the Republic of
Serbia”, No.65/11). However recent changes of the EU regulation need to be transposed. It
should be noted that the ongoing recast of the EU POP regulation will require further
amendment of the Serbian implementation (e.g. limit values for unintentional trace
contaminants).
Directive 2012/19/EU on WEEEs

The level of transposition of the WEEE Directive is rather low with just under half of its
provisions being fully transposed by the Serbian legislation. The main reason for the gaps or
partial transposition is that the national legislation has not yet been revised to take account of
the new provisions introduced by the new WEEE Directive 2012/19/EU.
The old Directive 2002/96/EC was transposed partially within the national legislation by
Rulebook on the List of Electric and Electronic Products, Measures of Prohibition and
Restriction of Use of Electric and Electronic Equipment Containing Hazardous Substances,

Methods and Procedures of Managing Waste from Electric and Electronic Products (hereafter
called: MO on WEEE).
From 248 separate Directive obligations, Serbia has fully transposed 115; partially transposed
30; and 103 provisions not yet transposed
Directive 2006/66/EC on waste batteries and accumulators

The WBA Directive has been amended a number of times, and a number of other pieces of EU
legislation are relevant. In Serbia the Directive was transposed by the RULEBOOK ON MANNERS
AND PROCEDURES OF USED BATTERIES AND ACCUMULATORS MANAGEMENT (“Official Gazette of
RS, no 86/2010”) (hereafter Rulebook on WBA).
From 135 separate Directive obligations, Serbia has fully transposed 83; partially transposed
13; and 39 provisions not yet transposed.
Directive 87/217/EC on the prevention and reduction of environmental pollution by

asbestos
Directive 1987/217/EEC has been largely but not fully transposed through the Law of Waste
Management (OG No. 36/09 as amended) and related secondary legislation, chemicals
legislation, legislation related to save and legislation on information system and reporting. Full
transposition is planned to be achieved, by amendments to the existing legislation (e.g.
Rulebook on disposal of waste containing asbestos “Official Gazette of the Republic of Serbia“,
No. 75/10). The competent authorities in place are: the MEP, SEPA, Ministry of Labour,
Employment, Veteran and Social Affairs, Ministry of Health, Ministry of Construction, Transport
and Infrastructure and the Environmental Inspection. Serbia plans to achieve full implementation
by 2020.
2.3 Current waste generation
In this document data on waste generation are mainly based on the following sources:
 Data from the waste generation data base of SEPA. These data are produced from the
mandatory yearly reports in accordance with the “Rulebook on the form of daily records
and annual report on waste (Official Gazette of the Republic of Serbia, No. 95/2010 and
88/2015)”
 Data on waste generation reported by the Statistical Office of the Republic of Serbia.
These data are based on a statistical survey that has been carried out according to the
standards and rules of the Regulation (EC) 2150/2002 on reporting on Waste Statistics.
Due to the different way of data collection (and incomplete reporting by stakeholders as well as
incomplete data delivery to surveys) some differences may appear. Furthermore the statistical
survey partly reflects materials that are not covered by the LWM (e.g. mining wastes).
Additional sources used are:
 Reviewed data from DSIPs
 Reviewed data from draft SWMPs
For DSIPs and SWMPs primary data were adapted by using additional information (e.g.
turnover of specific material streams, comparison with other countries) and cross checking of
different data sources.
According to SEPA, the total generation of waste in Serbia in 2016 was 9.2 million tonnes, out
of which 74.000 tonnes were classified as hazardous waste. Table 3 shows the quantities of

waste generated in Serbia in 2016 broken down by the 2-digit chapter codes of the List-of-
Waste. The data covers quantities reported by companies which submit to the Environmental
Protection Agency annual reports12 on the types and quantities of waste generated.
Wastes of the category 10 “Thermal processes waste” represent approximately 70% of the total
waste generation in 2016 in Serbia. The largest waste generators are thermal energy facilities,
which produce fly coal ashes during their operations. Other wastes originating from thermal
processes are slags, sludge and filter cakes.
12
Every waste generator, except for households, shall maintain and keep daily records on waste and shall submit
regular annual report to SEPA, including the types and quantities of wastes generated. The reporting takes place
under the RULEBOOK ON METHODOLOGY FOR DEVELOPMENT OF NATIONAL AND LOCAL REGISTER OF POLLUTION SOURCES,
AS WELL AS THE METHODOLOGY FOR THE TYPES, METHODS AND CUT-OFF DATE FOR DATA COLLECTION “(Official Gazette of
the Republic of Serbia”, No.RS, no. 91/10 and 10/13) and under the RULEBOOK ON THE DAILY RECORD ON WASTE AND
ANNUAL WASTE REPORT FORMS AND INSTRUCTIONS FOR THEIR COMPLETION ((“(Official Gazette of the Republic of Serbia”,
No.RS, no. 95/2010).

Table 3: Quantities of waste generated in Serbia in 2016 broken down by the 2-digit chapter
codes of the List-of-Waste (Source: Waste management in the Republic of Serbia for the period
2011-2016; SEPA 2017).
Code Chapter Quantity (t)

Wastes resulting from exploration, mining, quarrying, physical and
01 /
chemical treatment of minerals
Wastes from agriculture, horticulture, aquaculture, forestry, hunting
02 32.861
and fishing, food preparation and processing
Wastes from wood processing and the production of panels and
03 32.455
furniture, pulp, paper and cardboard
04 Wastes from the leather, fur and textile industries 6.657
Wastes from petroleum refining, natural gas purification and
05 3.642
pyrolytic treatment of coal
06 Wastes from inorganic chemical processes 893
07 Wastes from organic chemical processes 7.704
Wastes from the manufacture, formulation, supply and use (MFSU)
08 of coatings (paints, varnishes and vitreous enamels), adhesives, 3.554
sealants and printing inks
09 Wastes from the photographic industry 305
10 Wastes from thermal processes 6.546.377
Wastes from chemical surface treatment and coating of metals and
11 2.215
other materials; non-ferrous hydro- metallurgy
Wastes from shaping and physical and mechanical surface
12 56.848
treatment of metals and plastics
13 Oil wastes and wastes of liquid fuels (except edible oils, 05 and 12) 10.182
Waste organic solvents, refrigerants and propellants (except 07
14 27
and 08)
Waste packaging; absorbents, wiping cloths, filter materials and
15 105.325
protective clothing not otherwise specified
16 Wastes not otherwise specified in the list 38.628
Construction and demolition wastes (including excavated soil from
17 107.897
contaminated sites)
Wastes from human or animal health care and/or related research
18 (except kitchen and restaurant wastes not arising from immediate 2824
health care)
Wastes from waste management facilities, off-site waste water
19 treatment plants and the preparation of water intended for human 274.930
consumption and water for industrial use
Municipal wastes (household waste and similar commercial,
20 industrial and institutional wastes) including separately collected 1.963.776
fractions
TOTAL 9.197.100

The statistics of SORS provide quite different picture of the waste generation on Serbia.
According to SORS, approximately 47.1 million tonnes of waste were generated in Serbia in
2016. Approximately 63.5% of the generated quantity was non-hazardous and 36.5%
hazardous waste. The main reason for the differences of the figures of SORS and SEPA is, that
the statistics of SORS include approximately 38.6 million tonnes of wastes from mining and
quarrying, which are not covered by the statistic of SEPA, since these wastes are not covered
by the Waste Framework Directive (2008/98/EC) but by the Mining Waste Directive
(2006/21/EC). However an analysis of specific material streams show a good match of data
based on the same definition (e.g. in case of waste from energy production 5.6 million tonnes).
Figure 2: Share of generated waste in the Republic of Serbia by sectors in 2016 (Source:
SORS, Statistical Release ZS60)
2.4 Current status of relevant waste streams
2.4.1 Municipal waste
According to the LWM municipal waste means “household waste, as well as other waste which
is similar to household waste due to its nature or composition”. To a large extent, municipal
waste consists of the waste generated by households but may also include similar waste
generated by small businesses and public institutions and collected by or on behalf of
municipalities or directly by private operators. Municipal wastes including separately collected
fractions (except packaging wastes, which are listed in chapter 15 01) are classified in chapter
20 of the Waste List.
 20 01 – separately collected fractions (except 15 01);
 20 02 – garden and park wastes (including cemetery waste);
 20 03 – other municipal wastes.
The vast majority of municipal waste is mixed municipal waste. Mixed municipal waste is
classified as 20 03 01 waste group in the Waste Catalogue.

In accordance with the RULEBOOK ON METHODOLOGY FOR COLLECTION OF DATA ON COMPOSITION

AND QUANTITIES OF WASTE ON THE TERRITORY OF LOCAL SELF-GOVERNMENT UNIT (“Official Gazette
of the Republic of Serbia”, No. 61/2010) local self-governments have an obligation to analyse
quantities and composition of utility waste on its territory four times a year. The amount of waste
generated in group 20 of the waste list is shown in Table 4 below.
Table 4: Quantity of waste from category 20th of the Waste list in tonnes/year (Source: Waste
management in the Republic of Serbia for the period 2011-2016; SEPA 2017)
Years
Group
2010 2011 2012 2013 2014 2015 2016
20 2.682.404 2.733.825 2.658.549 2.454.520 2.186.297 1.936.309 1.963.776
Total 10.094.362 7.337.333 10.601.454 9.881.313 7.451.105 9.354.680 9.197.100
As indicated in Table 4, in Serbia, municipal waste makes about 21 % of total quantity of waste.
According to latest data from Serbian environment protection agency, in 2016, the total quantity
of waste was about 9 million tonnes. Although the data is not provided by all companies which
should report data, according to official statistics it is estimated that average daily quantity of
utility waste in 2016 was 0,73 kg per inhabitant, and average annual quantity was – 270 kg.,
while the EU average in 2016 was 483 kg. There are also differences between old EU member
states and the variations reflect differences in consumption patterns and economic wealth, but
how municipal waste is collected and managed should also be kept in mind. To properly ensure
the reduction of municipal waste disposal in landfills and in planning for investment, it needs to
be defined in municipal waste management to what degree and which waste from commerce,
trade and administration is collected and managed together with waste from households.
Table 5 presents basic indicators that show the quantities of produced utility waste (mainly
consists of mixed municipal waste), which are used for monitoring of the implementation of the
strategic objective, that is – avoiding and reducing waste generation. The indicators are
prepared based on annual data on waste quantities reported by Public utility companies (PUC)
in local self-governments in accordance with the RULEBOOK ON FORM OF DAILY WASTE RECORDS
AND ANNUAL WASTE REPORT (“Official Gazette of the Republic of Serbia”, no 95/10).
Table 5: Quantities of utility waste (Source: Waste management in the Republic of Serbia for
the period 2011-2016; SEPA 2017)
2010 2011 2012 2013 2014 201513 2016
Total quantity of generated
2,65 2,71 2,62 2,41 2,13 1,84 1,89
waste (million tonnes)
Quantity of waste collected
and deposited by municipality 1,89 2,09 1,83 1,92 1,67 1,36 1,49
PUCs (million tonnes)
Average scope of waste
72 77 ~ 70 80 ~80 82 ~82
collection (%)
Average daily quantity of
utility waste per inhabitant 0,99 1,01 0,99 0,92 0,81 0,71 0,73
(kg)
Average annual quantity per
0,36 0,37 0,36 0,34 0,30 0,26 0,27
inhabitant (t)
13
Note: The data for 2014/2016 differ from the data used in chapter 4 based on the study on waste generation and
composition for the period 2014 to 2030 (Municipal Solid Waste Information Republic of Serbia 2014 Bojan Batinić.
Since this study also includes also data on waste composition chapter 4 to 8 rely on these data primarily.

According to information from the Serbian Environmental Protection Agency, very small number
of PUC performed measurements and submitted the reliable information about municipal waste
characteristics. In most municipalities, a lack of weighbridges represents one of the major
problems for collecting good quality data about waste generation. In most cases, this kind of
practice results in data on the quantities of generated and landfilled municipal solid waste which
is based on estimations. Reasons therefor are mainly lack of understanding the importance of
this type of analysis, difficult economic conditions in companies, lack of equipment and lack of
professional (skilled) people who could adequately carry out the analysis in terms of taking
representative samples and separation of waste fractions according the catalogue.
Based on available information and research on the composition of mixed municipal waste,
which was made in 2008, it can be concluded that about 60% of the municipal waste
represents a biodegradable fraction consisting of garden and food waste and other
biodegradable material like paper and cardboard. Relevant recyclable fractions are plastics
(about 15%), paper and cardboard (about 15%), glass (5.26%) and metals (2%).
Figure 3: Average morphological composition of mixed municipal waste in Serbia
Source: Batinic 2014, Report on Municipal Solid Waste Information, reference year 2008
Reducing of biodegradable waste disposed in landfills is one of the key priorities. According to
the definition set in the Landfill Directive, as well as in Serbian LAW ON WASTE MANAGEMENT
(“Official Gazette of the Republic of Serbia”, No 88/2010), biodegradable municipal waste is:
“any waste that is capable of undergoing anaerobic or aerobic decomposition, such as food and
garden waste, and paper and cardboard”. It is important to distinguish with term “bio-waste”
provided by the Waste Framework Directive which includes garden and park waste, food and
kitchen waste from households, restaurants, caterers and retail premises as well as comparable
waste from food processing plants but no other potential biodegradable wastes like paper and
cardboard or textiles.
Another source of biodegradable waste is the “green waste” generated by activities of
maintaining public areas like garden, parks, cemeteries as well as from private gardens etc.
Amount of biodegradable waste that comes from the parks and public areas should also as
biodegradable municipal waste. Due to lack of data about this source of biodegradable waste,

results from weighbridges where this type of waste is separately measured (Novi Sad-4.4%,
Pančevo-2,8%, Subotica-1,4%), assumed average value of 3% (of the total amount of
municipal waste) for “green waste” from parks and accompanying greenery for all Serbian
municipalities can be considered.
Out of the biodegradable municipal waste, an important fraction is represented by paper and
cardboard. Most of this stream consists of packaging waste but also of newspapers, magazines
and other publications. This specific waste stream has a great potential for recycling.
It is worth noting, that not the whole quantity of textile wastes should be considered as
biodegradable waste, as only natural textiles are biodegradable.
Wood waste is mainly generated by commercial and industrial activities (packaging) but also, in
a smaller rate, by the activity of households (packaging of some appliances, rehabilitation and
repair works).
Determining the data on waste quantities and morphological composition is the basis for
successful planning of waste management. The process of waste management planning must
be based on reliable data which should be based on generated amount of waste, sources and
types, as well as current situation in waste management (collection, transport, recycling,
treatment and disposal). In the future, the estimation of waste quantities and composition will
become necessary in order to measure progress and to reflect on the results achieved.
Local self-government units are responsible for organizing of the municipal waste management
systems, thus ensuring their functionality. Local self-government units are also responsible for
the management of waste whose owner cannot be determined or does not exist, and for the
administration of the provision of municipal waste management services.
Waste management issues are not equally and evenly present in all municipality units, and the
activities regarding the introduction of an integrated system are not conducted with the same
intensity, but they primarily depend on the capacities of a municipality. Such an incoherent
system cannot function adequately and the change of such condition in the direction of applying
the modern sanitary and safe ways for handling with waste cannot be expected without
significant assets. The only economically feasible solution would be the establishment of
regional waste management centres where the waste collected from several municipalities
(including separately collected waste fractions) will be treated at the plants for separation of
recyclable waste, and the rest of it will be disposed of at the regional landfills, as was defined in
the 2003 National Waste Management Strategy. These regions will implement the principles of
integrated waste management system for a longer period.
Table 6: Waste management regions (Source: Investment Planning Tool (Solid Waste
Management in Serbia) and Implementation plan for council directive 1999/31/EC On the landfill
of waste)
REGION OWNERSHIP14 MUNICIPALITIES
Sremska Mitrovica Public Bogatić, Šabac, Sremska Mitrovica.
Pančevo Public Opovo, Pančevo.
Inđija Inđija, Irig, Pećinci, Ruma, Šid, Sremski

Public
Karlovci, Stara Pazova.
14
Public: Ownership in the form of a Public Utility Company or Publicly owned limited liability company.
Majority Private: Where the main assets or services are provided either by private companies or joint ventures with
majority private ownership.
IMCA: Inter-municipal agreement exists but regional company not in place yet.

REGION OWNERSHIP MUNICIPALITIES

Arilje, Bajina Bašta, Čačak, Čajetina,
Užice Public Ivanjica, Kosjerić, Ljubovija, Lučani,
Požega, Užice.
Pirot Babušnica, Bela Palanka, Dimitrovgrad,
Public
Pirot.
Kikinda Majority Ada, Bečej, Kikinda, Nova Crnja, Novi
private Bečej.
Lapovo Majority Batočina, Despotovac, Lapovo, Rača,
private Svilajnac.
Jagodina Majority Ćuprija, Jagodina, Paraćin, Smederevska
private Palanka, Velika Plana.
Bojnik, Crna Trava, Lebane, Leskovac,
Leskovac Majority
Medveđa, Prokuplje, Vladičin Han,
private
Vlasotince, Žitorađa.
Subotica Bačka Topola, Čoka, Kanjiža, Mali Iđoš,
Public
Novi Kneževac, Senta, Subotica.
Barajevo, Koceljeva, Lajkovac, Lazarevac,
Valjevo Public Ljig, Mionica, Obrenovac, Osečina, Ub,
Valjevo, Vladimirci.
Zrenjanin IMCA Kovačica, Sečanj, Titel, Žitište, Zrenjanin.
Nova Varoš IMCA Nova Varoš, Priboj, Prijepolje, Sjenica.
Vranje Bosilegrad, Bujanovac, Preševo,

IMCA
Surdulica, Trgovište, Vranje.
Čukarica, Grocka, Mladenovac, Novi
Beograd Beograd, Palilula, Rakovica, Savski venac,
Public
Sopot, Stari Grad, Surčin, Voždovac,
Vračar, Zemun, Zvezdara.
Bačka Palanka, Bački Petrovac, Beočin,
Novi Sad IMCA Novi Sad, Srbobran, Temerin, Vrbas,
Žabalj.
Niš Aleksinac, Doljevac, Gadžin Han,
IMCA
Merošina, Niš, Ražanj, Sokobanja, Svrljig.
Sombor IMCA Apatin, Bač, Kula, Odžaci, Sombor.
Vršac IMCA Alibunar, Bela Crkva, Plandište, Vršac.
Zaječar Boljevac, Bor, Kladovo, Knjaževac,

IMCA
Majdanpek, Negotin, Zaječar.
Smederevo Golubac, Kovin, Smederevo, Veliko
IMCA
Gradište.
Kragujevac Aranđelovac, Gornji Milanovac, Knić,
IMCA
Kragujevac, Topola
Kraljevo Kraljevo, Novi Pazar, Raška, Tutin,
IMCA
Vrnjačka Banja.
Kruševac Aleksandrovac, Brus, Ćićevac, Kruševac,
IMCA
Rekovac, Trstenik, Varvarin.
Petrovac Kučevo, Malo Crniće, Petrovac,
IMCA
Požarevac, Žabari, Žagubica.
Loznica IMCA Krupanj, Loznica, Mali Zvornik.

REGION OWNERSHIP MUNICIPALITIES

Undefined15 Blace, Kuršumlija.
Waste management regions are formed through the voluntary cooperation of local self-
government units. In the previous waste management strategy and the DSIP on landfill it was
foreseen to be a maximum of 27 regions was foreseen (based on application of an Investment
Planning Tool). Waste management is considered as an “activity of general interest” and can be
conducted by either public enterprises under the Law on Public enterprises or private
companies through the delegation of activities implemented in accordance with the Law on
public private partnership and Concessions.
Four regional companies are public utility companies, the other four are publicly owned limited
liability companies, and the last four are operated under Private Public Partnership
arrangements (as mentioned above). Twelve more have inter-municipal agreements but have
not formed a company. The remaining regions are still developing their approach.
Waste collection service is not available to a large part of the population. Collection is organized
primarily in urban areas, whereas rural areas are significantly less covered. Thus the service
ranges from only 25% to 100% in some municipalities. It has been estimated that collection rate
of organized municipal waste collection amounts to ~82% in the Republic of Serbia as indicated
in Table 7.
Currently there are only 10 sanitary landfills complying with EC sanitary landfill standards and
three regional sanitary landfills are under construction (2016). According to latest data from
SEPA, in 2016 474.018 tonnes of waste was landfilled into compliant sanitary landfills. The
three largest cities in Serbia (Belgrade, Novi Sad and Niš) do not have a sanitary landfill.
Furthermore there are 123 controlled not-compliant municipal landfill sites in Serbia and about
3.450 dumpsites. Due to the poor service coverage in rural areas it is likely that large amounts
of waste fall into non-compliant landfills or dumpsites. Thus about 20% of generated utility waste
in Serbia is disposed in wild landfills, outside control of the public utility companies. The
statistics on the amount of municipal waste generated may change depending on future waste
control measures and a more coherent measurement of waste by weighing them after they are
delivered to waste management facilities (Landfill, MBT, etc.).
Table 7: Quantity of waste disposed on sanitary landfills in tonnes per year (Source: Waste
management in the Republic of Serbia for the period 2011-2016; SEPA 2018)
Landfill 2011 2012 2013 2014 2015 2016
RSL “Duboko” Užice 3.566 34.135 65.955 72.757 72.051 77.930
RSL “Vrbak” Lapovo 14.924 25.660 27.873 24.344 35.580 49.749
RSL Kikinda 20.497 25.212 23.298 41.018 54.008 50.903
RSL “Gigoš” Jagodina 50.011 58.975 69.704 57.667 62.760 74.113
RSL “Zeljkovac -D2” Leskovac / / 58.938 62.332 64.269 63.380
RSL “Muntina padina“ Pirot / / 40.537 41.976 36.956 31.685
RSL “Jarak” Sremska Mitrovica / / / 17.808 44.545 48.126
RSL Pančevo / / 56.666 63.533 54.098 64.305
SL “Meteris” Vranje / / 2.723,9 2.593,9 178,8 199,3
SL “Vujan” Gornji Milanovac / / 11.479 12.731 14.879 13.628
TOTAL 88.998 143.982 357.174 396.760 439.325 474.018
15
Prokuplje region ceased to exist. Two municipalities, former members of the region joined Leskovac region, and two
remaining Kuršumlija and Blace, have not yet decided which region to join.

Mixed municipal wastes in Serbia are not treated and the untreated waste is disposed of in
landfills. A big part of generated utility waste is disposed of in wild landfills, outside control of the
public utility companies. In most cases, wild landfills are located in villages and are primarily the
result, of the lack of funds for expansion of waste collection system and poor organization of
waste management on local level.
There is no systematically organized separate collection, sorting and recycling of municipal
waste in the Republic of Serbia. Although the primary waste selection in Serbia has been set
forth under the law which envisages which separation of paper, glass and metal in specially
labelled containers, recycling is not functioning in practice even low amounts of recyclables are
collected (see Table below).
Table 8. Calculation of recycling rate of municipal waste, taking into account separately
collected packaging waste from households and WEEE, % of waste generation 16
2010 2011 2012 2013 2014 2015 2016

Mixed MSW + separately
collected packaging waste 2,653,318 2,737,860 2,656,242 2,462,392 2,180,609 1,905,334 1,930,297
and treated WEEE [t/year]
Municipal PPW collected
separately [t/year] 3,318 19,983 24,260 30,595 29,344 35,673 35,673(a)
Separate
WEEE-streams [t/year] (b) 7,877 11,982 21,797 21,265 29,661 40,297
Recycling [t/year] 3,318 23,921 30,251 66,337 54,497 64,667 60,689
Recyclables
collected by PUC [t/year] 24,843 14,521 14,164 4,868
Municipal PPW recycled
[t/year] (c) 3,318 19,983 24,260 30,595 29,344 35,673 35,673(a)
Estimated recycling
of WEEE, based on 50%
of separate WEEE
streams [t/year] (d 3,939 5,991 10,899 10,633 14,831 20,149
Calculated recycling rate,
including separate PPW 0% 1% 1% 3% 2% 3% 3%
and WEEE streams
estimated value, same as 2015 value, (b), WEEE is estimated to be from household sources, (c)
(a)
according to the SEPA figures, practically all the separately collected packaging waste is
recycled, (d).50% recycling is the lowest recycling target required by the WEEE-Directive.
Hazardous waste from households is not collected separately from the mixed municipal waste
stream.
Serbia does not have the necessary infrastructure to reduce the disposal of
biodegradable waste. Currently, composting sites exist only in Subotica and partially in Sremska
Mitrovica regions. The biodegradable waste generated by households in full falls into a mixed
municipal waste stream and is not further treated before disposal. Given the fact that in Serbia
most of these waste flows are not collected separately, the absence of separate collection will
not allow to achieve environmentally, economically as well as financially beneficial treatment of
this waste in the context of targets of biodegradable waste disposal and recycling.
Assessment of the current situation – main issues
16
Source: Draft Directive Specific Implementation Plan for Directive 2008/98/EC of the European Parliament and of the
Council of 19 November 2008 on Waste (2018 May)

Main challenges in municipal waste management in Serbia remain related to ensuring good
coverage and capacities for providing basic services, such as collection, transport and sanitary
waste disposal. The main issues in municipal waste management are:
 Most of the municipal waste goes to landfills untreated, as well as a significant
proportion of municipal waste is still being disposed of in non-sanitary landfills because
it is the cheapest way to handle waste (not addressing the future cost for later sanitation
of polluted areas);
 These low disposal costs jeopardise the goal of waste prevention and recycling since
separate collection, sorting, re-use and recycling of secondary raw material and
biodegradable waste therefore is not economical attractive;
 Not all municipalities have guaranteed the conditions for the use of public waste
management services by waste holders located in their territory. Currently the coverage
of waste collection in Serbia is about 82%;
 Separate collection of recyclables and bio-waste is not yet implemented adequately.
Recycling targets for Municipal waste are not yet achieved. Currently the recycling rate
for Municipal waste based on reported waste data is about 3%.
 Hazardous waste from households is not collected separately from the mixed municipal
waste stream;
 Cooperation between municipalities and producer and importer organizations is not
ensured, a large part of secondary raw materials is collected by the informal sector;
 There is no common and clear mechanism for assessing the achievement of targets for
municipal waste treatment;
 There are no centres of competence that would help the municipality to implement the
strategic objectives on a regional basis;
 There is no accurate and reliable record-keeping on generation and management of
municipal waste, which may lead to the adoption of unjustified strategic decisions on the
selection of waste management methods.
2.4.2 Construction and demolition waste including excavated soils
Definition, generation and legal framework

In accordance with Article 6 of the EU Directive 2008/98/EC mineral C&D waste is one of the
priority waste streams to introduce an end-of-waste regulation although there was no proposal
for such a regulation on Union level up to now. In accordance with Article 11 of the WFD there is
a recycling goal for non-hazardous C&D waste (except excavated soil) of 70% by 2020.
According to Article 4 of the LWM uncontaminated soil and other naturally occurring material
excavated in the course of construction activities are excluded from the waste definition if it is
certain that the material will be used for the purposes of construction in its natural state on the
site from which it was excavated. By that a big share of excavated materials from C&D activities
are non-waste if used on the site of generation. Statistics show that about 75% of excavated
material is not treated as waste but reused directly.
In accordance with Article 38 of the LWM C&D waste is one of the priority waste streams for re-
cycling and recovery. At the moment only small amounts of C&D waste are recycled (metals
and to some small extent asphalt). The major part of C&D waste is landfilled or more often
dumped together with household wastes on unsecured dump-sites.
C&D waste as listed in chapter 17 of the waste list results from construction, demolition and
maintenance of buildings and infrastructure (roads, sewer system, etc.). Since the construction

sector is a relevant indicator for the economic development the generation of C&D waste
reflects widely the economic trends.
The waste stream (as described in chapter 17 of the waste list) is composed mainly of non-
hazardous wastes, especially excavated soil, (mixed) mineral material (bricks, concrete, glass,
etc.), organic material (plastic, wood, etc.), metals (iron and steel, copper, lead, etc.) and mixed
(household like) wastes.
Hazardous C&D waste from construction and maintenance consist mainly of uncured paints and
sealants, specific chemicals and to some extent contaminated soil.
Hazardous C&D waste from demolition is mostly waste contaminated with hazardous
substances, namely asbestos (asbestos cement, asbestos insulating material), tar (sealants,
tar containing asphalt, tar impregnated wood), PCBs (sealants and paints, contamination
caused by electrical equipment) and mercury (specific contamination by electrical equipment –
mercury switches and fluorescent tubes – and contaminated waste water pipes from dental
practice).
Blending of hazardous waste with non-hazardous C&D waste is prohibited under Articles 35 and
44 of the LWM as hazardous waste has to be collected and transported separately. As stated by
several stakeholders, hazardous substances like WEEE and lamps are not separated before
deconstruction and are directed to landfills together with non-hazardous C&D waste. In this term
Article 30 of the LWM is of main importance since landfill operators shall refuse the reception of
waste when it is mixed with other waste. Source separation of varietal fractions at the
construction sites is generally important in order to enable material recovery of these fractions.
Contaminated excavation material can be classified not only in Chapter 17 (17 05 03*, 17 05
05*) but also in Chapter 19 13 (if the focus is on the clean-up of a contaminated site).
The estimated composition of construction and demolition waste is as follows (MAEP 2015):
 soil from excavation, 75%;
 waste from construction and demolition (ceramics, concrete, iron, steel, plastic waste),
15-25%;
 waste asphalt and concrete, 5-10%
Recycling of C&D waste depends on good source separation. Every mixed collection increases
the degree of contamination and reduces the possibilities of recycling. The following
classification (based on the recycling potential) can be applied for this purpose:
 Mineral C&D wastes: building rubble (17 01 07), bricks (17 01 02), concrete (17 01 01),
mortar (17 01 01), plaster (17 09 04), gypsum based construction material (17 08 02),
glass (17 02 029), excavated soil (17 05 04), etc.;
 Mineral C&D waste with organic binders: bitumen bound road surface 17 03 02), etc.;
 Organic C&D wastes: wood (17 02 01), plastics (17 02 03) including window frames,
organic insulating material (17 06 04), etc.;
 Metal C&D wastes: pipes (17 04 03), ferrous metals (17 04 05), cables (17 04 11),
gutters (17 04 07), metal roofing (17 04 07, 17 04 01), reinforcing rods and clamps (17
04 05), etc.
Current waste generation shows strong fluctuations reflecting the economic situation and
infrastructure development activities.
Table 8: Waste generation in construction sector (data from SORS, 2017)

Waste categories 2012 2013 2014 2015 2016

Total, tonnes 363.706 328.235 263.302 259.713 547.474
Hazardous waste, all 4.737 373 321 4.935 386
01.1 Spent solvents 0 0 0 4 1
01.2 Acid, alkaline or saline wastes 0 1 0 - o
01.3 Used oils 185 132 109 128 180
01.4, 02, 03.1 Chemical wastes 24 8 25 7 74
07.7 Waste containing PCB 0 - 8 - 23
08 (excluding 08.1 and
Discarded equipment 53 29 23 33 27
08.41)
08.1 Discarded vehicles - 173 3 32 0
08.41 Batteries and accumulators wastes 41 30 58 32 52
10.2 Mixed and undifferentiated materials 2 - 5 4
12.1 Mineral waste from construction and demolition 4 431 - 64 4524 1
12.2, 12.3, 12.5 Other mineral wastes - 1 25 6 6
Non-hazardous waste, all 358.969 327.862 262.981 254. 779 547. 088
01.4, 02, 03.1 Acid, alkaline or saline wastes 43 8 172 - 160
06.1 Metallic wastes, ferrous 21.886 11.333 25.801 3.758 6.180
06.2 Metallic wastes, non-ferrous 201 71 117 945 580
06.3 Metallic wastes, mixed ferrous and non-ferrous 441 456 985 243 1.892
07.1 Glass wastes 68 43 149 19 13
07.2 Paper and cardboard wastes 1.133 231 179 230 3.990
07.3 Rubber wastes 406 260 264 372 581
07.4 Plastic wastes 105 28 152 49 232
07.5 Wood wastes 441 137 120 89 264
08 (excluding 08.1 and
Discarded equipment 16 6 1 9 11
08.41)
08.1 Discarded vehicles - - 2 0 65
08.41 Batteries and accumulators wastes 4 3 3 9 22
09.1 Animal and mixed food waste 5 13 773 22 16
09.2 Vegetal wastes 35 20 - 0 1
10.1 Household and similar wastes 19.241 2.540 1.415 2.525 4.166
10.2 Mixed and undifferentiated materials 312 247 10 105 15
11 Common sludge 23 - - - -
12.1 Mineral waste from construction and demolition 82.557 66.297 43 977 83.879 238.982
12.2, 12.3, 12.5 Other mineral wastes - 1.054 1.050 47 769
12.4 Combustion wastes 18 15 510 - 129
12.6 Soils 229.120 245 100 175.835 154.241 288.499
12.7 Dredging spoils 2.910 - 11.467 8.310 521
Mineral waste from waste treatment and stabilised
12.8, 13 5 - - - -
wastes
It should be noted, that for wastes from the construction sector there is a great discrepancy
between statistically collected data and the amount of waste reported by companies to SEPA
with a waste code from group 17 of the waste list. While the amount of waste from construction

sector accounted according to the statistics of SORS for 547.474 tonnes in 2016, the total
amount of wastes reported to SEPA under group 17 accounted only for 107.967 tonnes.
However about 47% (51.037 tonnes) were reported in group 17 04 (metal wastes) while metal
waste from the construction sector were estimated by the SORS with only 8.652 tonnes (about
3.6% of metal waste). It can be assumed that the major part of metal scrap was reported to
SEPA under group 17 04 because in this group different types of scrap (ferrous scrap, copper
scrap, aluminium scrap, etc.) can be identified, while in other chapters of the waste list metals
are not specified.
At the moment no specific collection of C&D waste and no recycling scheme for C&D waste are
in place. Although there is a general legal obligation for the waste generator to collect
generated waste separately and sort it in compliance with regard to future treatment, in quantity,
i.e. Percentage in accordance with the national goals (Article 26 of the LWM) this provision is
not effective with regard to C&D waste due the lack of implementing by-law. Thus mainly wastes
with high economic value, such as metals, are recycled, while other potential recyclables are
landfilled or more often dumped at unsecured local dump-sites.
Exports of C&D waste regard only metal wastes and to a small amount contaminated soil (for
specific treatment, not available in Serbia). However since the notified export data for specific
types of metals (e.g. 17 04 05 iron and steel) widely exceed the amount generated as C&D
waste it can be assumed that these code numbers were chosen by the notifier mainly because
the waste code reflects the type of metal specifically and not because the scrap was generated
during construction or demolition work. Notified exports of scrap in Chapter 17 were about
50.000 tonnes while scrap generated in the construction sector was reported by the SORS with
8.652 tonnes only.
Imports of C&D wastes cover also mainly metal waste for recycling.
Main obstacles for recycling of C&D wastes are:
 Missing economic incentive since mineral C&D waste can be dumped at relatively low
costs;
 No legal obligation for the waste generator to recycle (although the LWM defines C&D
waste as a priority waste stream for recycling);
 Missing quality standards for recovered C&D waste (especially with regard to
environmental performance) and therefore liability problems;
 Legal uncertainty of the legal status of recovered C&D waste (no end-of waste
regulation in place yet).
2.4.3 Secondary waste (waste from waste treatment)
Secondary wastes are defined as wastes generated during waste treatment operations, either
recovery operations (in this case secondary wastes are typically the separated recoverable and
not recoverable parts of the waste input or e.g. residues (ashes) generated during energetic
use) or disposal operations (e.g. stabilization, PC-treatment, etc.). A more detailed description
of processes generating secondary wastes can be found in chapter 2.6 Treatment options.
In the waste list secondary wastes can be identified under specific codes in:
 Chapter 19 Wastes from waste management facilities and off-site waste water
treatment plants; most prominent are:
o Chapter 19 01 wastes from incineration and pyrolysis (note that residues from co-
incineration are also partly covered in Chapter 10 01);

o Chapter 19 02 wastes from C/P-treatment;

o Chapter 19 03 wastes from stabilization;
o Chapter 19 05 wastes from aerobic waste treatment (MB-Treatment, composting);
o Chapter 19 06 wastes from anaerobic biological treatment (biogas production);
o Chapter 19 08 wastes from waste water treatment plants (note that industrial
specific on-site treatment is listed under the relevant industrial chapter, e.g. 07);
o Chapter 19 10 wastes from shredding;
o Chapter 19 11 wastes from waste oil regeneration;
o Chapter 19 12 wastes from mechanical treatment (e.g. sorting);
o Chapter 19 13 wastes generated in clean-up procedures of contaminated sites.
 Chapter 16 01 End-of-Life vehicles (wastes from dismantling);
 Chapter 16 02 WEEEs (wastes from dismantling);
 Chapter 13 05 Oil/water separator contents.
It has to be mentioned that especially in chapter 16 a full separation of primary and secondary
wastes is not feasible on basis of the waste code only since the same wastes (e.g. 16 01 07* oil
filters) can be generated during the dismantling of an End-of-Life vehicle (R12 – generation of
secondary waste) as well as during normal maintenance operations of a car. Thus the data
collected on basis of the waste codes only give an upper limit of secondary wastes. At the same
time dismantling of End-of-Life vehicles and of WEEEs is also performed in the informal sector
and thus residues from this operations may be registered only in chapter 20 (municipal wastes).
The amount of waste generation from waste treatment activities depends on the level of the
waste treatment infrastructure, e.g. waste incineration and preparatory treatment leads to
secondary waste generation.
Secondary wastes may be either a secondary raw material (e.g. sorted scrap, plastics, etc.)
which can be re-introduced into the economic circle, or they constitute a sink for unusable
fractions or dangerous substances and pollutants. To promote the use of recovered material
end of waste regulation, technical standards and economic incentives should be used.
While in general waste reduction is a benchmark for a sustainable waste management, in case
of secondary wastes an increased generation can be seen as a positive result (provided the
amount of wastes being disposed of without pre-treatment is reduced). In accordance with the
data on waste generation collected by SEPA about 264.063 t (lower limit) and 273.366 t (upper
limit) were generated as secondary wastes in 2016. 190.383 t were the result of stabilisation,
PC-treatment and/or blending/mixing as pre-treatment for further disposal (landfilling or co-
incineration) or recovery (R5).
At the moment the greater share of secondary wastes is landfilled in Serbia. When new waste
treatment capacities will be installed, more secondary hazardous wastes (e.g. from PC-
treatment), requiring safe disposal will be generated. These secondary wastes need to be taken
into account in the planning of an integrated waste management system, in order to guarantee,
that enough final treatment capacities will be available also for these streams. The main
capacities are required in secure landfill and in incineration of hazardous wastes.
Complying with recycling targets will create a large stream of secondary wastes which shall be
re-introduced into the economic circle. To promote this use of recovered material end of waste
regulation, technical standards and economic incentives should be used.
2.4.4 Mining wastes

Mining has always been an important part of the Serbian economy. The industry produces
primarily copper, iron, significant production of gold, lead, coal, salt and selenium.
Mining waste is the waste generated during the geological exploration, exploitation, preparation
and storage of mineral resources (except for water) and the working of quarries. Mining waste is
excluded from the scope of the Waste framework directive. The same approach has also been
transposed into the LAW ON WASTE MANAGEMENT (“Official Gazette of the Republic of Serbia“,
No. 36/09, 88/10).
Directive 2006/21/EC on mining waste management imposes reduction of impact of treatment
and disposal of extractive waste on environment and human health, but not under the waste
legislation. This particular extractive waste must be managed in specialized facilities in
compliance with specific rules. The Directive was transposed by the LAW ON MINING AND
GEOLOGICAL EXPLORATION (“RS Official Gazette”, No. 101/2015). In 2017 Serbia has established
the REGULATION ON THE CONDITIONS AND PROCEDURES FOR ISSUING PERMITS FOR WASTE
MANAGEMENT, AS WELL AS THE CRITERIA, CHARACTERISATION, CLASSIFICATION AND REPORTING ON
MINING WASTE (“Official Gazette of the Republic of Serbia“, No. 53/17). Based on the LAW ON
MINING WASTE the preparation of a cadastre of Mining Waste is underway, aiming to develop
and improve the mining waste management system in Serbia . 17
It must be noted that the provisions of this Directive (2006/21/EC) as well as the LAW ON MINING
does not apply to those waste streams which, albeit generated during mineral extraction or
treatment operations, are not directly linked to the extraction or treatment process, e.g. food
waste, waste oil (from maintenance), end-of-life vehicles, spent batteries and accumulators. The
management of such waste is subject to the provisions of Directive 2008/98/EC or of Council
Directive 1999/31/EC of 26 April 1999 on the landfill of waste or any other relevant Community
and national legislation, as is the case with waste generated at a prospecting, extraction or
treatment site and transported to a location that is not a waste facility according to this Directive.
Thus these wastes are regulated by the LWM and its by-laws.
Specific waste from exploitation of mineral raw materials is classified as waste group 01 of the
Waste list. The quality ranges from inert residues (e.g. 01 04 08) to potentially leachable waste
(e.g. 01 03 04*) to highly toxic chemicals and extraction residues (e.g. 01 04 07*). In
accordance with the data from SORS a share of 40% to 45% is characterized as hazardous.
The generated amounts of wastes from mining and quarrying, and data about quantities of
hazardous and non-hazardous waste from mining can be provided by Statistical Office of the
Republic of Serbia. During 2016 mining and quarrying sector generated 38.671.285 tonnes of
waste. In relation to the previous year (2015), the observed decrease in amounts is 6.5%. The
main concern remains that 44.3% (in 2016) of it was hazardous, most of it being disposed in
landfill.
The vast majority of these wastes are regulated under the LAW ON MINING AND GEOLOGICAL
EXPLORATION and not under the LWM. The share of the mining sector in waste generation
(including wastes regulated under the LAW ON MINING AND GEOLOGICAL EXPLORATION) was 82%
in 2016 (Source: SORS Statistical Release ZS60).
2.4.5 Sewage sludge
About 55% of the overall Serbian population has access to public sanitation. About 75% of the
population live in settlements larger than 2,000 inhabitants, in which the average connection
17
Project web-site: http://katastarrudarskogotpada.rs/

rate to sewers is 72% and 27% connected to septic tanks. In settlements with less than 2,000
inhabitants (about 90% of all settlements in Serbia), the connection rate to sewers is less than
5% on average.
Operational WWTP’s provide services for approx. 600.000 residents, which equals to 385.000
P.E. Less than 10% of the population is covered by some secondary level of wastewater
treatment.18
The total sludge production from existing WWTP’s is estimated in a nominal range of 11.000
-15.000 t/DS/yr. wet sludge (reported 4.000 t/DS/year) 19 and this does not represent significant
load. WWTPs in Serbia are perpetrated mainly by local (municipal) public utility companies.
Therefore, these companies are responsible for sludge management as well. Sludge treatment
mainly means simple drying and disposal on landfill, very often unsanitary. There is a lack of
data of sludge quantities and quality. However, the development of sewage collection systems
in cities and other urbanized areas and increasing the effluent treatment efficiency, results in an
increase in sewage sludge generation. Sludge disposal in landfills or storing in specially
designated areas could be potentially acceptable for a short period, but it is necessary to keep
in mind that minimal treatment (drainage) will be necessary. However, sludge disposal in
landfills will have an impact on the achievement of the goals stipulated in the landfill directive.
When planning for long-term investments in sludge management infrastructure, it needs to be
borne in mind that EU priority is given to the use of material contained in sludge. State policy
must be focused on two interrelated directions - maximum exploitation of potential of energy
accumulated from the sludge and its materials and expanding options of its use.
To reduce the amount of sludge treated at the final stage, optimizing sludge transport logistics
tasks as well as investment and operating costs, it would be beneficial to install thickening and
dewatering equipment in all agglomerations. Talking about small agglomerations, there should
be an assessment implemented whether it is technically and economically preferable to install
sludge thickening or to transport to larger facilities for dewatering.
For further treatment of sludge, it will be very important to determine which methods for the
sludge treatment fit best to regional/ local conditions to ensure that the quality of the product
meets the requirements of the intended use at the lowest cost. The final use of the product
should be the main criteria for selecting the technology for sludge treatment. Under the climatic
conditions of Serbia solar sewage sludge drying can be a sustainable method to increase the
energy recovery from sludge. Stricter requirements should be set for the discharge of hazardous
substances into sewage networks and better pollution control in order to ensure proper sludge
management. Based on the quality of the sludge preferred recovery options are:
 Composting (R3);
 Co-incineration (R1);
 Co-incineration in cement production (R1/R5);
Proper disposal and use of sewage sludge must be ensured by the owners of this sludge.
Sludge from facilities of municipal wastewater treatment is classified as 19 08 05 waste group in
the Waste Catalogue.
2.4.6 Vegetal wastes, animal by-products
18
Water Management Institute “Jaroslav Černi” - Draft Water Management Strategy within the Territory of the Republic
of Serbia (2015).
19
Directive Specific Implementation Plan for the Council Directive of 21 May 1991 concerning
Urban Wastewater Treatment (91/271/EEC).

The agriculture sector contributes for 10% of the GDP of Serbia. In accordance with Article 4, 5
and 8 of the LWM residues of biological material produced in this sector, such as straw, are
excluded from the scope of the LWM. Therefor the following materials are not subject to the
waste regulation:
 Straw and other natural non-hazardous agricultural or wooden materials used in
agriculture, forestry or for the energy generation from such biomass by applying
processes or methods that do not have the adverse effect to the environment and do
not endanger human health are not covered
 By-products of animal origin, including obtained products to which shall apply regulation
from the field of veterinary, except those which are intended for incineration, use in
biogas facilities or facilities for composting, or disposal to sanitary landfill under special
conditions, in accordance with special regulation;
The materials of animal origin (including faecal material from farms) are defined as animal by-
products in accordance with the Rulebook on the method of classification and treatment of
animal by-products (“Official Gazette of the Republic of Serbia“, No. 31/11, 97/13, 15/15, 61/17)
and specifically controlled under the LAW ON VETERINARY MEDICINE (“Official Gazette of the
Republic of Serbia”, No. 91/05, 30/10, 93/12).
Animal by-products including obtained products to which the regulation from the field of
veterinary shall apply are only subject to the waste legislation if they are intended for
incineration, use in biogas facilities or facilities for composting, or disposal to sanitary landfill
under special conditions, in accordance with special regulation. In case that animal by-products
are incinerated the regulation on types of waste subject to thermal treatment, conditions and
criteria for determining the site, technical and technological conditions for designing,
construction, equipping and operation of waste thermal treatment plant, and handling with
residues from thermal processes (“Official Gazette of the Republic of Serbia”, No.102/10 and
50/12) applies.
In 2016 livestock in Serbia amounted to around 0.89 million cattle, 3 million pigs, 1.7 million
sheep and 0.2 million goats (Source: Statistical Yearbook of Serbia 2017; SORS). Based on
that data the amount of manure produced can be estimated in the range of 1 million tonnes DM
per year.
The production of grain and crops accounted for about 2.9 million tonnes of wheat and 1 million
tonnes maize (excluding maize for silage) accounting for about 3.7 million tonnes of straw. 20
The vast majority of these material streams – vegetal wastes and animal by-products – are in
accordance with Article 4 of the LWM not considered as waste. Thus the amount registered as
manure and vegetal waste in the survey of SORS accounts only for 77.794 t of manure and
12.558 t vegetal waste.
Meat production is an essential part of the Serbian agriculture sector. The total meat production
increased between 2012 and 2016 from 450.000 tons to 500.000 tonnes 21 . Thus animal by-
products from slaughterhouses can be estimated on basis of literature data 22 to be between
174.000 tonnes in 2012 and 194.000 tonnes in 2016.
20
Estimation is based on Annex 5 of the German DüngeVO from 27.02.2007 (BGBl. I S. 221) and a guidance
document on sustainable use of straw as fertilizer,
http://www.effizientduengen.de/download/Sondernewsletter_Jun09_web.pdf
21
Source: http://publikacije.stat.gov.rs/G2018/PdfE/G201817011.pdf
22
Jedrejek, Dariusz & Levic, J & Wallace, John & Oleszek, Wieslaw. (2016). Animal by-products for feed:
Characteristics, European regulatory framework, and potential impacts on human and animal health and the
environment. Journal of Animal and Feed Sciences. 25. 189-202. 10.22358/jafs/65548/2016

However both material streams, animal by-products and vegetal waste from farming, if not
directly processed and used on farm may constitute a valuable feedstock for compost
production, anaerobic digestion producing biogas as well a fuel for sustainable energy
production by incineration of biomass (forest and wood processing waste). Furthermore
compost and digestate are used as sustainable soil improver and organic fertiliser. On the other
hand they may compete with bio-waste other organic wastes for treatment capacities.
2.4.7 Hazardous wastes
The data on the generation of hazardous waste covers quantities reported by companies which
submit to the Environmental Protection Agency annual reports 23 on the types and quantities of
waste generated in the course of their activities. The data does not include quantities of these
types of waste generated by households and disposed of on wild dumpsites or delivered directly
to operators for treatment.
According to the statistics of SEPA, the total generation of industrial and commercial waste in
Serbia in 2016 was 9.2 million tonnes, of which only 74.300 tonnes were classified as
hazardous waste. Thus, the share of hazardous waste in the total waste generation was less
than 0.8% in 2016.
Table 9 presents the quantities of the most important hazardous waste types generated in
Serbia in 2016. The 12 waste types presented here made up about 78% of the hazardous waste
generated in 2016 according the statistics of SEPA.
Table 9: Hazardous industrial and commercial waste in Serbia in 2016. The most important
waste types in terms of quantity (SEPA 2017).
Waste Quantity
code Waste (tonnes)
10 02 13* Sludge and filter cakes from gas treatment containing dangerous substances 27.600
05 01 03* Tank bottom sludge 3.600
15 01 10* Packaging containing residues of or contaminated by dangerous substances 3.000
Discarded equipment containing hazardous components other than those
16 02 13* 2.900
mentioned in 16 02 09 to 16 02 12
Wastes whose collection and disposal is subject to special requirements in order to
18 01 03* 2.500
prevent infection
16 02 15* Hazardous components removed from discarded equipment 2.400
12 01 09* Machining emulsions and solutions free of halogens 2.300
10 02 07* Solid wastes from gas treatment containing dangerous substances 2.100
Other wastes (including mixtures of materials) from mechanical treatment of waste
19 12 11* 2.000
containing dangerous substances
13 07 03* Other fuels (including mixtures) 1.800
16 07 08* Wastes containing oil 1.800
Discarded electrical and electronic equipment other than those mentioned in 20 01
20 01 35* 1.400
21 and 20 01 23 containing hazardous components
13 08 99* Wastes not otherwise specified 1.300
13 05 06* Oil from oil/water separators 1.200
Absorbents, filter materials (including oil filters not otherwise specified), wiping
15 02 02* 1.200
cloths, protective clothing contaminated by dangerous substances
13 02 05* Mineral-based non-chlorinated engine, gear and lubricating oils 1.100
Other waste types 16.100
23
Every waste generator, except for households, shall maintain and keep daily records on waste and shall submit
regular annual report to SEPA, including the types and quantities of wastes generated.

Waste Quantity
code Waste (tonnes)
TOTAL 74.300
According to the statistics of SEPA, in 2016 in total about 34.400 tonnes of hazardous waste
were disposed of at landfills (operations D1 and D5). The most important hazardous waste type
landfilled was 10 02 13* “Sludge and filter cakes from gas treatment containing dangerous
substances – waste from iron and steel industry” (27.600 t). (SEPA 2017)
In 2016, about 6.800 t of hazardous wastes were used for energy recovery (operation R1)
according to the data reported to SEPA. The most important hazardous waste types used for
energy recovery were 16 07 08* “Wastes containing oil” (2.300 t), 19 12 11* “Other wastes from
mechanical treatment” (2.000 t) and 13 07 03 “mineral-based non-chlorinated insulating and
heat transmission oils” (900 t).
Moreover, about 59.200 t of hazardous waste were treated in operations aiming at recycling/
material recovery (operations R2-R11) and 10.900 t were taken over to storage / exchange of
waste (R12/R13) in Serbia in 2016. Hazardous waste types treated in operations aiming at
recycling/material recovery included 20 01 35 “discarded electrical and electronic equipment…”
(17.600 t), 16 02 13 “discarded equipment…” (14.100 t) and 16 06 01 “lead batteries” (9.400 t).
It is worth noting, that the quantities of hazardous wastes reported as treated in operations
aiming at recycling/ material recovery may include double counting because no clear distinction
between pre-treatment and final treatment can be made based on the reported R-codes.
Table 10 shows the quantities of hazardous wastes treated in Serbia by recovery / disposal
operation in 2016 as reported to SEPA.
Table 10: The quantities of hazardous wastes treated in Serbia in 2016 by recovery/disposal
operation (Source: SEPA 2017)
Code Type of disposal / recovery operation Quantity

(tonnes)
D1 Deposit into or onto land 400
D5 Specially engineered landfill 30.000
R1 Use principally as a fuel or other means to generate energy 6.800
R2 Solvent reclamation/regeneration 300
R3 Recycling/reclamation of organic substances which are not used as solvents 2.700
R4 Recycling/reclamation of metals and metal compounds 41.700
R5 Recycling/reclamation of other inorganic materials 2.200
R7 Recovery of components used for pollution abatement 6.500
R9 Oil re-refining or other reuses of oil 2.900
R10 Land treatment resulting in benefit to agriculture or ecological improvement 1.200
R11 Use of wastes obtained from any of the operations numbered R1 to R10 1.700
R12 Exchange of wastes for submission to any of the operations numbered R1 to R11 10.100
R13 Storage of wastes pending any of the operations numbered R1 to R12 800
TOTAL 107.300
Generally speaking, import of hazardous waste to Serbia is prohibited. However, certain types
of hazardous waste, which are needed as secondary raw materials in the processing industry in
Serbia, may exceptionally be imported. Such imports require a permit by the MOE. The
Government decides on the types of the hazardous waste which may be imported as secondary
raw materials (REGULATION ON DESIGNATING THE TYPES OF HAZARDOUS WASTE THAT MAY BE
IMPORTED AS SECONDARY RAW MATERIALS (“Official Gazette of the Republic of Serbia”, No.

60/2009)). During 2016, 163 t of lead-acid batteries were imported from Montenegro to Serbia
(SEPA 2017).
During 2016 in total 16.700 t of hazardous waste were exported from Serbia. The most
important waste types exported were 19 12 11* “other wastes from mechanical treatment…”
(6,606 t), 16 06 01* “lead batteries” (5,200 t), 16 02 15* “hazardous components removed from
discarded equipment” (1,943 t) and 16 02 09* “PCB-containing equipment” (117 t). The most
important countries of destination were Bulgaria (29% of the total quantity of hazardous wastes
exported), Slovenia (27%), Romania (18%), Germany (9.4%) and Austria (8.3%). (SEPA 2017).
Table 11 presents a summarizing illustration of the generation and treatment of hazardous
wastes in Serbia in 2016 broken down according to the 2-digit groups of the European List of
Waste. The table is based on the data reported to the Serbian Environmental Protection Agency
(SEPA, 2017).
The following issues should be taken into account, when the illustration is interpreted:
 There is no exact information available on the generation of hazardous wastes from
households and similar establishments. Theoretically, these waste quantities should
however be included in the reported treated quantities of hazardous wastes;
 The quantities of hazardous wastes reported as recovered may include double counting
because no clear distinction between pre-treatment and final treatment can be made
based on the reported R-codes;
 Temporary storage can sometimes be the reason, if the total generated quantity of a
waste category is higher/lower than the total treated quantity of the category.
Table 11: Generation and treatment of hazardous wastes in Serbia broken down according to
the 2- digit groups of the European List of Waste (SEPA 2017).
Genera D1/D5 R2-R11 R12/R13 Export
Group Chapter R1 [t]
tion [t] [t] [t] [t] [t]
WASTES FROM PETROLEUM REFINING, NATURAL GAS
5 3.600 2.500 1.200
PURIFICATION AND PYROLYTIC TREATMENT OF COAL
6 WASTES FROM INORGANIC CHEMICAL PROCESSES 800 1.900 0 40
7 WASTES FROM ORGANIC CHEMICAL PROCESSES 700 300 100 100 100
WASTES FROM THE MANUFACTURE, FORMULATION,
SUPPLY AND USE (MFSU) OF COATINGS (PAINTS,
8 1.800 1.300 400 300
VARNISHES AND VITREOUS ENAMELS), ADHESIVES,
SEALANTS AND PRINTING INKS
9 WASTES FROM THE PHOTOGRAPHIC INDUSTRY 100 100 0
10 WASTES FROM THERMAL PROCESSES 29.800 27.600 100 100 100
WASTES FROM CHEMICAL SURFACE TREATMENT AND
11 COATING OF METALS AND OTHER MATERIALS; NON- 1.100 900 0 700
FERROUS HYDRO METALLURGY
WASTES FROM SHAPING AND PHYSICAL AND
12 MECHANICAL SURFACE TREATMENT OF METALS AND 3.200 1.000 500 2.400
PLASTICS
OIL WASTES AND WASTES OF LIQUID FUELS (except
13 10.200 1.500 3.700 2.900 100
edible oils, and those in chapters 05, 12 and 19)
WASTE PACKAGING; ABSORBENTS, WIPING CLOTHS,
15 FILTER MATERIALS AND PROTECTIVE CLOTHING NOT 4.200 700 1.200 300 200
OTHERWISE SPECIFIED
16 WASTES NOT OTHERWISE SPECIFIED IN THE LIST 10.200 2.300 25.300 1.500 7.800
CONSTRUCTION AND DEMOLITION WASTES (INCLUDING
17 800 1.000 1.900 0
EXCAVATED SOIL FROM CONTAMINATED SITES)
WASTES FROM HUMAN OR ANIMAL HEALTH CARE
AND/OR RELATED RESEARCH (except kitchen and
18 2.600 1.800 700
restaurant wastes not arising from immediate health
care)

Genera D1/D5 R2-R11 R12/R13 Export

Group Chapter R1 [t]
tion [t] [t] [t] [t] [t]
WASTES FROM WASTE MANAGEMENT FACILITIES, OFF-
SITE WASTE WATER TREATMENT PLANTS AND
19 3.100 2.000 800 200 300 7.000
PREPARATION OF WATER INTENDED FOR HUMAN
CONSUMPTION AND WATER FOR INDUSTRIAL USE
MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR
COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL
20 2.100 17.700 1.000
WASTES) INCLUDING SEPARATELY COLLECTED
FRACTIONS
TOTAL 74.300 6.800 30.400 59.200 10.900 16.700
The major challenges related to the management of hazardous wastes in Serbia currently
include:
 The treatment capacity for the treatment of the wide range of hazardous industrial
wastes on the territory of the Republic of Serbia is not sufficient. There is only a limited
capacity for physical-chemical treatment (PCA) of hazardous waste and only limited
capacities for landfilling of hazardous waste. In recent years hazardous waste
solidification and bioremediation processes have been applied as pre-treatment
technique in single cases;
 There is insufficient capacity for the storage of hazardous waste. In such
circumstances, hazardous waste generators store hazardous waste temporarily in their
own locations in temporary storages; due to the lack of alternatives, waste has been
stored for 20 or more years in some of them. In the majority of cases, temporary
storages of hazardous waste do not meet prescribed conditions;
 No regular collection system for hazardous wastes from households has been
established in Serbia until now.
2.5 Current status of special waste streams
2.5.1 Packaging waste
The Packaging and Packaging Waste Directive (94/62/EC) (hereafter PPWD) was partially
transposed by the Law on Packaging and Packaging Waste (Official Gazette of the RS, No.
36/09) and related legal acts.
In line with requirements of article 7 of the PPWD, has been established by the Law on
packaging and packaging waste the system for return/collection of packaging waste. Therefore,
producers, importers, packers/fillers and suppliers, other than shops, shall provide for the
packaging placed on the market, the following24:
 That utility company takes the municipal packaging waste regularly;
 That non-municipal packaging waste is regularly taken over and collected from end
users;
 Reuse, recycling or disposal in compliance with Law on packaging and packaging
waste.
Manufacturer, importer, packer / filler and supplier can manage waste packaging in three ways:
24
Art. 23 of the Law on packaging and packaging waste

1. transfer its obligations to the operator of a packaging waste management system in

accordance with Article 24 of the Law on packaging and packaging waste and submit
an annual report to the Environmental Protection Agency;
2. provide own management of packaging waste in accordance with Articles 25 and 26 of
the same law and submit an annual report to the Environmental Protection Agency;
3. submit the annual report to the Environmental Protection Agency and to pay the fee
prescribed by the Ministry of Environment on the basis of the submitted Report, in
accordance with the Decree on the criteria for calculation of the fee for packaging or
packed product and exemption from payment of compensation, payers, as well as on
the method of calculation and payment of compensation.
Manufacturers, importers, packers/fillers and suppliers may assign their obligation of handling
the waste to a third party, i.e. Producers Responsibility Organisation/ Operator (or collective
scheme, as called in Serbia) of the packaging waste management system which has been
legally assigned to carry out the activity of management of packaging waste. In this way
producers and importers which are placing packaging on the Serbian market are financially
responsible for the packaging waste and also, obliged to achieve the recycling and recovery
targets for packaging waste.
The collective scheme shall, on behalf of the manufacturer, importer, packer/filler and supplier,
ensure the following:25
 Provide that utility company takes the municipal packaging waste over regularly;
 Regularly takes over and collects non-municipal packaging waste from end users; and
 Ensure reuse, recycling or disposal in compliance with Law on packaging and
packaging waste.
The operator is obliged to inform the public and end users about the purpose, objectives,
method and place of collection containers, as well as the possibilities of recovery and recycling
of packaging waste.
Municipalities, according to Article 13 of the LWM, shall develop a local waste management
plan defining the collection system by taking into consideration the local conditions. It is the local
governments that should make available the waste collection system to the citizens and enforce
the set rules. Nevertheless, the separate collection has been initiated only in some cities and in
several villages at the level of pilot projects.
To conclude, significant progress has been made towards Directive transposition and
implementation and at the end of 2018 seven collective schemes (PRO’s organization) were
licensed (Article 31 of the LPPW) by the Ministry of Environment. So, in this way the system for
return/collection of used packaging waste (Article 7 of the PPWD) is in place and produces
effects.
In terms of reporting the Packaging Law prescribes the obligation to produce and submit an
annual report for the manufacturer, importer, packer/filler and supplier, the producer of waste
that independently manages its packaging waste, and collective scheme regardless of the
quantities placed on the market. The content of reports is given in THE RULES ON THE FORMS OF
THE REPORT ON THE MANAGEMENT OF PACKAGING AND PACKAGING WASTE (“Official Gazette of the
Republic of Serbia”, No. 21/10, 10/2013).
End users, who import or buy the packaging or packaging raw material for their own needs have
to present to the Ministry the report, by 31st March of the current year, including the information
about the type and quantity of packaging they imported by themselves, for the needs of their
own business activity during previous year.
25
Art. 24 from Law on packaging and packaging waste

Based on these reports the Agency is establishing and managing the data base about the
quantities and types of packaging and packaging waste. Each year, the Environmental
Protection Agency shall prepare and publish a report on the quantity of produced (imported)
packaging and the quantity of packaging waste and the management of packaging waste.
The baseline scenario for packaging and packaging waste management in Serbia starts with the
quantities placed on the market (POM) by producers under contracts with the collective
schemes Table 12 and by producers which are not within any PROs organization and have
chosen to pay a fee to the Environmental Fund for not achieving the recycling/recovery targets
(Table 13), during 2010-2016, namely approx. 349 thou tonnes of packaging.
Table 12: Packaging quantities placed on the market by producers/importers/fillers organised in
a collective/individual scheme in tonnes (Source: SEPA annual reports)
Type 2010 2011 2012 2013 2014 2015 2016
Glass 65.224,12 85.534,4 77.774,4 61.496,8 55.236,8 57.115,5 58.155,2
Plastic 83.118,28 80.373,3 87.742,9 84.568,6 86.878,9 90.811 89.492,6
Paper
and 101.957,
91.352,04 103.738 102.152,5 105.532,3 108.751,1 109.159,6
cardboar 1
d
Metal 8.333,17 11.218,0 11.992,3 12.608,7 12.546,3 13.661,9 13.626,7
Wood 44.220,72 52.905,9 56.539,1 55.057,7 62.982,4 68.449,2 73.475,6
Other 1.766,60 2.268,3 2.622,6 1.443 1.231,9 907,1 752,1
334.257,
TOTAL 294.014,93 340.409,3 317.327,3 324.408,6 339.695,8 344.661,8
0
Table 13: Amount of packaging placed on the market by producers/importers/fillers that chose
to pay the fee instead of achieving the recycling and recovery targets in tonnes (Source: SEPA
annual reports)
Type 2010 2011 2012 2013 2014 2015 2016
Glass 990,19 393,6 203,7 193,6 227,4 3.022,6 830
Plastic 11.070,11 1.288,8 660,9 1.019,1 664,9 1.473,9 928,2
Paper
and
4.199,87 2.118,8 1.482,6 1.715,2 1.462,1 15.463,8 1.273,3
cardboar
d
Metal 3.359,73 522,54 398 97 94,3 128,2 195,7
Wood 6.843,85 1.039,4 1.030,7 1.202,3 863 2.717,5 902
Other 926,9 299,6 60,8 30,3 13,4 13,9 9,7
TOTAL 27.390,65 5.662,7 3.836,7 4.257,5 3.305,1 22.819,9 4.139
The structure by packaging material POM is in average 26 20% glass, 27% plastic, 31% paper
and cardboard, 4% metal, 18% wood and 1% other.
The analysis performed for the Directive Specific Implementation Plan for the Packaging and
Packaging Waste Directive (DSIP on PPWD) has advanced a percentage of 22% free riders for
26
calculated as an average of the percentages reported to SEPA between 2010 and 2015

the 2015 data reported. This calculated value is required by the forecasting process (chapter 4)
and represents:
 Producers do not adequately comply with their obligations. For example, when they do
not finance the collection and recycling of the packaging of their products placed on the
market;
 Producers do not provide accurate data about the quantities of products put on the
market.
From the discussions held with the authorities and stakeholders, this value was considered
realistic.
It can be assumed, that all packaging placed on the market in a given year becomes waste in
the same year but some of materials can be found in the household flow (hereafter: HH) and
industrial/commercial flow (hereafter: IC flow), other materials can only be found in
industrial/commercial flow. The ratio applicable for Serbia was discussed within the process of
preparing the DSIP PPWD and is it shown in Table 14 below:
Table 14: Ratio of packaging material type in household and industrial and commercial flows
[%] (Source: DSIP or packaging waste)
Category Household flow Industrial and commercial flow

Paper and cardboard 60 40
Plastic 70 30
Glass 80 20
Metal 75 25
Wood 0 100
This assumption is required to calculate the packaging quantities by materials to be placed on

the market and so to evaluate when the Directive targets and objectives might be reached.
Following the SEPA’s data the quantities of municipal packaging waste reported as collected
by the collective schemes has increased from approximately 3.000 tonnes in 2010 to
approximately 46.200 tonnes in 2016 (Table 15).
Table 15: Municipal packaging waste separately collected via collective schemes in tonnes
(Source: SEPA annual reports)
Type 2010 2011 2012 2013 2014 2015 2016

Glass 0 4.747 5.672 5.340 4.336 6.103 7.512
Plastic 2.208 5.981 7.958 7.775 8.332 11.835 15.884
Paper/Cardboard 1.067 9.020 10.149 16.938 15.572 16.783 21.231
Metal 0 234 481 327 491 240 430
Wood 0 0 0 215 613 711 1.150
Other 0 0 0 0 0 0 0
Total [t] 3.318 19.983 24.260 30.595 29.344 35.673 46.208

Since the separate collection system of packaging waste from households is at the present not
very well established, the biggest part of packaging waste from households is included in the
mixed municipal waste.
Results obtained in a study performed by the Novi Sad University for the Ministry of
Environment27 showed that packaging waste amounts 20,3% of all municipal waste. The share
of packaging waste is as follows:
 Paper and cardboard – 7.8%;
 Plastic – 7.5%;
 Glass – 3.7%;
 Metal – 1.2%.
Calculation made for the DSIP on Packaging and Packaging Waste Directive concluded that the
total weight of packaging waste generated within municipal flow is about 240.000 tonnes dry
fraction, out of which only tens of thousands are collected separately.
Since packaging waste from commercial and industrial flows is easier to collect (not
contaminated, considerable amounts at a single point), it currently makes the largest part of the
reported data. In this way, the collective schemes were able to achieve the targets, set in the
Directive, for paper and cardboard, plastic and wood. Glass and metal remain problematic and
also overall recycling and recovery targets were not reached. However, in the next period the
increasing recycling and recovery targets shall orient the collective schemes actions to
household packaging waste, being assumed that the share between these two flows is 60% in
household and 40% in commercial.
Following the SEPA’s data the quantities of industrial and commercial packaging waste
reported as collected by collective schemes has increased from approximately 12.000 tonnes in
2010 to approximately 110.000 tonnes in 2016. Here it should be noted that the numbers
reported for paper and cardboard waste are much higher as can be generated within this waste
flow. The inconsistencies can be explained on one hand by the fact that producers that are
placing on the market under 1000 kg are exempt from the reporting, as well as targets
obligations and on the other that is more convenient to report paper packaging waste as
commercial/industrial to demonstrate the overall target achievement.
Table 16: Industrial and commercial packaging waste reported by collective schemes in tonnes
(Source: SEPA annual report)
Type 2010 2011 2012 2013 2014 2015 2016

Glass 1.026 2.118 2.029 3.683 4.612 6.344 7.847
Plastic 3.091 5.816 5.673 5.865 8.402 8.559 11.029
Paper and
7.774 19.938 27.874 38.251 49.627 65.014 72.095
cardboard
Metal 5 676 4.064 3.149 4.293 5.021 5.153
Wood 60 1.234 4.017 6.406 6.381 14.617 13.422
Other 0 0 0 0 14 0 0
TOTAL [t] 11.956 29.782 43.656 57.354 73.328 99.556 109.546
In terms of data reported to the SEPA by collective schemes, approximately 147.000 t
packaging waste was recycled in 2016.
27
Final report on Municipal Solid Waste Information, Environmental Infrastructure Support Programme
for MAEP

Table 17: Packaging waste reported as recycled by collective schemes in tonnes (Source:
SEPA annual report)
Type 2010 2011 2012 2013 2014 2015 2016

Glass 1.069 6.866 7.701 8.947 8.947 12.189 15.381
Plastic 5.300 11.797 12.998 15.022 15.022 15.212 18.212
Paper and
8.841 28.959 37.205 63.735 63.735 80.217 93.221
cardboard
Metal 0 910 4.545 4.785 4.785 5.261 5.496
Wood 60 1.234 4.017 6.994 6.994 15.329 14.593
Other 0 0 0 14 14 0 0
TOTAL [t] 15.269 49.765 66.466 99.497 99.497 128.207 146.903
Further, the same collective schemes reported to SEPA approximately 8.900 t packaging waste
as recovered by processes other than recycling in 2016.
Table 18: Packaging waste recovery reported by collective schemes in tonnes (Source: SEPA
annual report)
Type 2010 2011 2012 2013 2014 2015 2016

glass N/A N/A 0 0 0 0 0
plastic N/A N/A 632,10 1,276,00 1.711,10 5.182,60 8.723,2
paper and
cardboard N/A N/A 817,50 1.860,30 1.464,80 1.580,20 127,9
metal N/A N/A 0 0 0 0 0
wood N/A N/A 0 0 0 0 0
other N/A N/A 0 0 0 0 0
TOTAL [t] 0 0 1.449,60 3.136,30 3.175,90 6.762,.80 8.851,1
Assessment of the current situation - main issues

The reported data are inconsistent (e.g.: to demonstrate the achievement of the overall
recycling target for paper, the recycled quantities of the industrial stream have been reported
more than can be generated from this flow based on studies published at the European level).
 SEPA don’t have enough capacity to evaluate all reported numbers;
 The enforcement is performed only from the point of view of submitting the reports to
SEPA.
Regarding the existing collection system and recycling capacities the– main issues are:
 Insufficient recycling and recovery capacity in Serbia at least for some waste types,
such as glass, wood and aluminium. Producers are using intermediate storage facilities
followed by export;
 Lack of infrastructure for treatment and disposal of hazardous packaging waste.
Companies have to export the waste to the EU MSs and thus, in addition to the
transportation and related costs, bear the administrative burden for the waste shipment
permit;

Marginal separate collection of packaging waste from households by municipal waste

companies, including hazardous packaging waste and no motivation for separate
collection of packaging waste among citizens;
 Lack of stimuli for production of reusable packaging. Insufficient awareness among
citizens on the benefits of multiple use packaging;
 Low involvement of the private and public sector in minimizing packaging waste
generation;
 Low level of sorting and separately collect the waste within the private sector;
 Disregard of the waste hierarchy - significant dependence on landfilling;
 Quality of separate collection is sometimes poor, resulting in ‘polluted’ waste streams
that can’t be recycled and need to be landfilled.
2.5.2 End-of-Life vehicles
In the EU End-of-Live Vehicles are regulated under Directive 2000/53/EC. The directive restricts
the use of specific hazardous materials in vehicles and provides for a separate collection and
recycling based on the principle of extended producer responsibility. The directive also
introduces recycling goals for ELV.
The goals of Directive 2000/53/EC were implemented in Serbia by the LWM and specific by-
laws. Article 55 of the LWM defines End-of-life Vehicles as special waste stream and stipulates
in accordance with the principle of extended producer responsibility obligations of the producer
or importer of road vehicles as well as of the owner of such vehicles.
The producer or importer of a vehicle has to provide the necessary information for dismantling
(including recovery of material) of discarded vehicle.
The recycler provides for the sound dismantling (i.e. removal of hazardous components,
recovery of spare parts, etc.), keeps records of all activities and delivers this information to
SEPA. The recycler shall also issue a confirmation confirming the reception of the vehicle.
The details of the procedure are defined in the Rulebook on the manner and procedure of EoL
vehicle management (“Official Gazette of the Republic of Serbia”, No. 98/10). Furthermore the
rulebook introduces restriction on the use of specific hazardous substances in road vehicles
(Annex 1 of the rulebook). Thus the rulebook applies to vehicles and end-of-life vehicles,
including built-in components and materials regardless of the manner in which the vehicle is
serviced or repaired during its use and whether or not the vehicle is equipped with components
that the manufacturer shipped or other components installed as spare parts.
Regarding the management of hazardous substances it is stipulated that during the
manufacturing of motor vehicles and spare parts or equipment for motor vehicles, measures
shall be taken with the purpose of:
 limiting the use of hazardous substances in vehicles and reducing their amount as
much as possible;
 designing and production of new vehicles, facilitation of dismantling, reuse and
treatment, in particular the recycling of ELV, their components and materials;
 integrating of an increasing quantity of recycled material in vehicles and other
products and developing of the markets for recycled materials.
Motor vehicles and spare parts thereof containing lead, mercury, cadmium or hexavalent
chrome shall not be manufactured or imported, other than the materials and components listed
in Appendix 1 of the rulebook.

The holder of ELV is obliged to submit the ELV to an authorized person who collects and/or
transports and/or disposes of and/or treats ELV. All these persons implicated are obliged to fill
out the document on the movement of hazardous waste.
If the ELV holder is unknown, collection and submission shall be carried out by the local self-
government. Along with the ELV, a copy of the holder’s driver’s license, or municipal inspection
report if the holder is unknown, or a traffic accident report if the ELV was generated as a result
of a traffic accident has to be handed over.
Regarding the storage of ELV it is clarified that no dismantling must take place at the storage
facility. Minimal technical requirements of the storage facility are stipulated.
The transport of ELV has to comply with provisions that regulate transport of dangerous waste
and the permit issued by the competent authority.
Regarding the treatment of ELV detailed stipulations are laid down in the rulebook. This
includes minimum requirements of the treatment facility, provisions regarding the segregation of
hazardous components, provisions regarding the segregation of recyclable parts and provisions
regarding the segregation of special components.
According to Appendix 3 of the rulebook treatment operations shall achieve the following reuse,
treatment and recycling quota:
 Reuse and treatment of at least 85% of the average ELV mass collected throughout the
year and reuse and recycling of at least 80% of the average ELV mass collected
throughout the year, after January 1, 2015;
 Reuse and treatment of at least 95% of the average ELV mass collected throughout the
year and reuse and recycling of at least 85% of the average ELV mass collected
throughout the year, after January 1, 2019.
Finally it is clearly stated that ELV may not be disposed of in landfills and may not be
incinerated.
Other relevant by-law for the collection, transport and treatment of ELV are:
 Rulebook on the form of document on the movement of waste with the filling
instructions (“Official Gazette of the RS”, No. 114/13);
 Rulebook on conditions, the methods and procedure of waste oil management (“Official
Gazette of the RS”, No. 71/10);
 Rulebook on the procedure for management of waste batteries and accumulators
 Rulebook on disposal of waste containing asbestos (“Official Gazette of the Republic of
 Regulation on categories, testing and classification of waste (“Official Gazette of the
 Regulation on products that after use become special waste (“Official Gazette of the
Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14);
 Decree on amounts and conditions for the award of incentive funds; (“Official Gazette of
the RS”, No. 54/10, 86/11, 15/12 , 41/2013 and 3/2014);
 Decree on conditions for granting incentives; (OG of the RS, No. 88/09, 67/10, 101/10,
86/11 and 35/12).
A typical passenger car manufactured in Europe has an average mass of 1.380 kg (International
Council on Clean Transportation, 2015). A passenger car consists of more than 10.000 single
components and approximately 40 different materials. End-of-life vehicles have a high
heterogeneous composition and consist to approximately 55-70% of iron/steel, to 3-8% non-

ferrous metals, to 8-18% of plastics and textiles, to 2-4% of rubber, to 2-5% of glass, to 2-5% of
operating liquids and to 5-10% of other materials.
End-of-life vehicles contain hazardous substances such as fuel, motor oil, oil filter, braking fluid,
coolants, batteries, explosives (air-bags), hazardous electronic components, etc. As a legacy
problem in old cars asbestos (e.g. brake pads) and PCB (e.g. PCB-capacitors) may occur. In
accordance with the Regulation on categories, testing and classification of waste (“Official
Gazette of the RS”, No. 56/10) ELV are classified as hazardous waste under the waste code 16
01 04* end-of-life vehicles. By removing the hazardous components during partial dismantling
the ELV becomes a non-hazardous waste with the code 16 01 06 end-of-life vehicles,
containing neither liquids nor other hazardous components. Only fully depolluted ELVs are
allowed to be classified under the waste code 16 01 06. Any End-of-life vehicle not fully
depolluted of its liquids or hazards component has to be classified as hazardous waste under
the waste code 16 01 04.
According to SEPA (2017), 122.879 and 56.520 tonnes of vehicles were put on the market
in Serbia in 2015 and 2016. These quantities should include the vehicles produced in Serbia
and the vehicles imported to Serbia. They also should include those vehicles produced in
Serbia, which were exported from Serbia abroad. In the light of the data on exports and imports
of motor vehicles an on the statistics about passenger cars produced in Serbia, the quantities
put on the market reported to the SEPA seem to be too low.
According to the Statistical Office of Serbia about 129.200 tonnes of motor cars and other motor
vehicles principally designed for the transport of persons were exported from Serbia and
148.600 tonnes were imported to Serbia in 2016. According to the International Organization of
Motor Vehicle Manufacturers (2017) about 79.360, passenger cars were produced in Serbia in
2016. In 2016, there were approximately 1.8 million registered passenger cars in Serbia (see
Table 19).
Table 19: The number of registered passenger cars (Source: SORS, 2017):
2012 2013 2014 2015 2016

Total number of
registered passenger 1.726.190 1.770.206 1.797.252 1.833.219 1.824.628
cars
Number of first-time
registered passenger 129.169 139.513 105.393 112.615 136.258
cars
According to data published by SEPA (2017) about 2.000 t of End-of-life (waste codes 16 01 04
and 16 01 06) vehicles were generated in the course of business activities in Serbia in 2016.
About 16 % of the end-of-life vehicles were reported as hazardous waste under the waste code
16 01 04*. In Addition, in total 19.890 tonnes of wastes were reported as generated under the
waste codes for wastes from dismantling of end-of-life vehicles and vehicle maintenance
(SEPA, 2017). However this number includes also wastes that were generated partly during
normal maintenance of cars (e.g.10.290 tonnes used tires (16 01 03) or 39 tonnes oil filters (16
01 07)).
An estimation based on the annual numbers of first time registered passenger cars and on the
growth of the fleet of passenger cars suggests that on average between 2013 and 2016 97.063
passenger cars should fall out of the car fleet in Serbia annually. With an average weight of
958 kg per passenger car this would account to a total quantity of 92.986 t. A substantive part of
cars that are taken out of service are exported as used car (not ELV) to a large extent also by

private persons. International comparisons suggest that at least 50% of vehicles that fall out of
the fleet are exported as used cars. Thus an average of maximum 46.493 tonnes ELV per year
can be expected. A comparison with the amount of ELV generated per registered car and year
with selected EU MS (19 kg per passenger car) would lead to an estimation of 34.320 tonnes
per year in the average between 2013 and 2016. The average of both estimations would
account to approximately 40.400 t per year for ELVs. The actual amount of wastes reported
under Chapter 16 01 of the waste list is 21.893 tonnes only and contains also wastes generated
during maintenance operations and not derived from dismantling ELVs. The reason for this
discrepancy can be a lack of compliance with reporting obligation, informal recycling activities
since ELVs contain valuable materials and also informal exports by private persons.

For the time being, no fully reliable data exists in Serbia regarding the treatment of ELV. The
treated quantities reported to SEPA include only approximately 3.400 t of recovery of end-of-life
vehicles (16 01 04* and 16 01 06). One possible reason for the low figures is that some treaters
might not yet properly fulfil their reporting obligations. Moreover, it can be assumed, that ELV
are often collected by informal collection activities, with the aim to sell spare parts and scrap
metal for recycling. End-of-life vehicles might also be shipped abroad informally, or by private
persons. Also according to some private operators in the ELV management only a small amount
of EVL was treated by authorized facilities.
 There is no exact data on the quantities of end-of-life vehicles generated annually;
 The quality of the data on vehicles put on the market seems to be lacking;
 Collection and management of end-of-life vehicles depends mostly on supply and
demand;
 Hazardous substances and components are not extracted before the recycling process
of end-of-life vehicles;
 Only of small part of ELVs is treated in authorized facilities;
 There are operators who have the capacity to recycle end-of-life vehicles in accordance
with regulations but these operators do not seem to receive enough ELVs for treatment;
 Sufficient post shredder technologies and treatment capacities are needed for shredder
residues.
2.5.3 Waste mineral oil
Mineral oil is covered by the Governmental DECREE ON PRODUCTS THAT BECOME SPECIAL WASTE
STREAM UPON US THEREOF (“Official Gazette of the Republic of Serbia”, No 54/10). Therefore the
production or import of mineral oil has to be recorded and reported to SEPA on a yearly basis.
This report is basis for taxation of a specific fee.
The existing legal framework for a separate collection of waste oil is contained in Article 48 of
the LWM and in the GOVERNMENTAL ORDER ON TERMS, MANNER AND PROCEDURE OF WASTE OILS
MANAGEMENT (“Official Gazette of the Republic of Serbia”, No 71/10). In accordance with Article
5 of the governmental order the seller of mineral oil is requested to inform the end-users where
they can deliver their waste oil free of charge. If a reseller takes back waste oil from end-user he
has to sign a contract with an authorized collector. Despite Article 5 of the governmental order
no comprehensive collection scheme for waste oil from households/private persons (and small
enterprises) exist at the moment. However the implementation of a collection system for
hazardous wastes from households either via civic amenity centres or mobile collection or a
strict take back obligation for resellers may increase the collection rate substantially.

Waste mineral oil as defined by Article 48 of the LWM is “all mineral or synthetic oils or
lubricants, which cannot be used for their original purpose, such as hydraulic oils, engine,
turbine oils and other lubricants, marine oils, oils or liquids for insulation or transmission of heat,
other mineral or synthetic oils, as well as oil remains in tanks, oil-water mixtures and emulsions”.
According to Article 21 of the Waste Framework Directive, Member States must ensure that
waste oils are collected separately, where this is technically feasible. In case of generation of
waste oils, they should preferably be re-used incl. material recycling (recovery of base oil
components), i.e. refined. If waste oils, according to national legislation, are subject to
requirements of regeneration, Member States may prescribe that such waste oils shall be
regenerated if technically feasible and, where Articles 11 or 12 of the Waste Shipment
regulation (Regulation (EC) No 1013/2006) apply, restrict the transboundary shipment of waste
oils from their territory to incineration or co-incineration facilities in order to give priority to the
regeneration of waste oils.
Mineral oils are mainly used as lubricants, hydraulic medium, heat transfer and insulation
medium. They are derived from crude petroleum and can be classified as alkanes (with small
amounts of other hydrocarbons). If their molecular structure is modified they are regarded as
synthetic oils. Base oil can be modified by different additives to serve a specific purpose. Oils
with a high content of such additives (other than synthetic hydrocarbons) are classified as highly
alloyed oil. Based on the amount and nature of additives waste mineral oil requires different
technical recycling processes. Thus a material recycling of waste mineral oil (R9) requires a
source separation in the collection. Consequently waste mineral oil is classified in several
chapters of the waste list:
 Emulsions and oils for mechanical shaping and surface treatment are listed in chapter
12 01 of the waste list;
 Hydraulic oil is classified under chapter 13 01;
 Waste engine, gear and lubricating oil is listed in chapter 13 02;
 Insulating and heat transfer oils are classified in chapter 13 03;
 Oil/water mixtures from ships (bilge oils) are classified in chapter 13 04 while oil/water
mixtures from oil/water separators are listed either in chapter 13 05 or in chapter 19 08
and recovered oil from emulsions or oil/water mixtures is listed under waste code 19 02
07*.
All types of waste mineral oils are classified as hazardous waste. The hazard characteristics in
accordance with Annex 5 of the Regulation on categories, testing and classification of waste
(“Official Gazette of the Republic of Serbia”, No.56/10) depend largely on the additives and the
contamination during use of the oil. Thus insulation oil (provided it is not contaminated with PCB
or other halogenated substances) exhibit as a rule only H15 while machining oil and emulsion
may exhibit additionally the hazard characteristics H7, H10, H11, H13 and H14 and engine oil
and oil/water mixtures from oil/water separators may also exhibit H3-B due to a contamination
with gasoline. These different hazards have to be taken into account also during transport
(classification with UN 1993 or UN 3082).
According to data reported to SEPA for 2016 33.700 tonnes (36.093 tonnes in 2014) of mineral
oil, synthetic oil and lubricants were put on the market while an estimation of the total amount in
the draft Hazardous Waste Management Plan 2017 goes up to 50.000 tonnes annually.
However the recorded quantities may not fully cover the quantities of oil put into market since
mineral oil is also imported as part or component of equipment or put into the market by “free
riders”.
In 2016 only 5.527 tonnes of waste oil (including 1.332 tonnes not specified waste oil 13 07 99
and 81 tonnes of PCB contaminated transformer oil) and 3.638 tonnes of emulsions and

oil/water mixtures were reported to the SEPA as collected in Serbia. No oil recovered by PC-
treatment (waste code 19 02 07*) was reported.
It is assumed that much higher quantities of waste oil are collected within the informal
sector. The implementation of a collection system for hazardous wastes from households and/or
a strict take back obligation for resellers could possibly increase the reported quantities
substantially. With an annual consumption of 50.000 tonnes of oils and lubricants in
Serbia the generation potential of waste oil is estimated to account for 25.000 to 37.000
tonnes per year.
According to the data reported to the SEPA, 1.908 tonnes of waste oil was used for energy
recovery (R1), 1.763 tonnes of waste oil were refined (R9) and of oil containing wastes
2.242 tonnes were reported to be processed in a different way (R3, R12) in 2016. According to
SEPA data in 2016 25 companies had a license for the treatment of at least specific types of
waste mineral oil however they have not all processed mineral oil waste in 2016. It is assumed,
that much higher quantities of waste oil are collected within the informal sector.
According to the data of the Chamber of Commerce about 23 tonnes of waste oils containing
PCB/PCT and about 186 tonnes of other waste oils were exported from Serbia in 2016.

Treatment capacities are available for re-refining (R9), energy use (R1) and CP-treatment (R3
or D8). According to SEPA data in 2016 25 companies had a license for the treatment of at least
specific types of mineral oil waste; however they have not all processed mineral oil waste in
2016.
Although material recycling has the highest priority in the waste hierarchy, the preferable
recycling option depends on the type of waste oil. High grade oil with low content of alloying
substances (such as insulation oil) can be recovered by using simple processes such as
cleaning with acids and bleaching clay. The recovery of highly alloyed oils may require a full
refining process similar to the processing of crude oil. Recovered oil from oil/water mixtures
(waste code 19 02 07*) may vary widely in quality and composition and thus for these types of
waste oil energy recovery (e.g. co-incineration in a cement kiln) is the preferred recovery option.
 There is no exact data on the quantities of waste mineral oils generated annually;
 The quality of the data on mineral oils put on the market seems to be lacking;
 Only a small part of waste mineral oils are collected and treated by authorized collectors
and processors;
 The improvement of separate collection of different qualities and types of waste mineral
oil and the increased and improved processing of oil-water mixtures and other oil
containing wastes such as oil containing residues from mechanical processing and
surface treatment are a priority to meet a high recycling rate for waste oil.
2.5.4 Waste tires
Article 49 of the LWM stipulates: “The entity that collects, transports, treats or disposes of waste
tires shall hold appropriate permit, maintain, and keep records on quantities of collected and
treated waste tires and shall submit such data to the Agency. The Minister shall closely
prescribe manner and procedure for waste tires management.” Waste tires are defined as a
non-hazardous waste (waste code 16 01 03) and therefor permits for collection, transport,
treatment, storing, recovery and disposal, export and import are issued by the Ministry and
authorities of Autonomous Provinces, Municipalities or Cities.

Tires are covered by the Regulation on products that after use become special waste streams
upon us thereof (Official Gazette of RS, No. 54/10). Therefore production or importation of tires
has to be recorded and reported to SEPA on a yearly basis. This report is basis for taxation of a
specific fee in line with the principle of extended producer responsibility.
Based on article 49 of the LWM the Rulebook on manner and procedure of waste tires
management ("Official Gazette of the Republic of Serbia", No. 104/2009 and 81/2010) has been
elaborated. Waste tires are defined as motor vehicle tires (cars, buses, trucks, motorbikes etc.),
agricultural and construction machines, trailers, towed machines and so on, after the end of
their life cycle, i.e. which owner rejects due to damage, wear and tear or due to other reasons.
Tires for passenger cars and trucks represent about 85 % of the total number of produced tires.
The rulebook covers the collection, transportation, storage and treatment of waste tires.
Collected waste tires shall be treated in facilities that obtain the requirements established by the
law and other regulations, especially regarding measures for prevention, reducing and
eliminating potential adverse environmental impacts. The treatment options of waste tyres
include recycling of waste tires and use for energy purposes. At least 80 % of the waste tires
should be recycled and not more than 20 % should use for energy purposes of the total quantity
of waste tires collected in the previous year.
In accordance with Article 9 of the Regulation on disposal of waste in landfills (“Official Gazette
of the Republic of Serbia“, No. 92/10) the landfilling of waste tyres is prohibited.
Depending on their utilization and dimension tires vary in design, construction and total weight,
so the weight range of tires is very high. The weight of a used passenger tires about 7.8 kg and
of a long-haul truck is about 53 kg. 80 % of the weight of a car tire is rubber compound. An
average passenger car tire consists of approximately 47 % rubber/elastomers, 21,5 % carbon
black, 15,5 % metal, 6 % textile, 1% zinc oxide, 1 % sulphur and 8 % additives.
There is a substantial production of car tires in Serbia with a high share of export. According to
SEPA (2017) 35.796 tonnes and 49.317 pieces (e.g. tires from tractors, trucks, buses and fork
lifters) of tires were put on the market in Serbia in 2016. This quantity includes the tires
produced in Serbia and the tires imported to Serbia in 2016.
Table 20: Quantity of tires put on the market in 2016 (Source: SEPA 2017)
Total quantity in Total quantity in Total quantity
pieces tonnes (tonnes)28
Imported, produced or retreated
tyres for all types of motor / 34.678,9 34.678,9 t
vehicles
Car trailers 3.884 / 39 t
Vans and delivery vehicles up to
5.727 / 860 t
3.5 tonnes of capacity and tractors
39.706
Trucks, buses and fork lifters 39.706 / pieces3.176 t
Construction operation machines / 232,3 232,3 t

Agricultural machines / 174,8 174,8 t
Cargo trailers and towed machines / 630,9 630,9 t
Other vehicles, transport devices,
/ 75,3 75,3 t
aircrafts
38.867 t
TOTAL 49.317 35.792,2
(estimation!)
28
Conversion rate: https://www.wien.gv.at/umweltschutz/abfall/pdf/umrechnungsfaktoren.pdf

Table 21 shows the amount of tires treated in Serbia in the period 2011 to 2016.
Table 21: Waste tires in Serbia (Source: SEPA 2017)
Disposed waste Treated waste Exported waste Imported waste
Year
in tonnes in tonnes in tonnes in tonnes
2011 / 30.984 / /
2012 / 34.114 / 532
2013 / 30.150 / 496
2014 / 28.766 / 781
2015 / 32.400 / 537
2016 46 42.422 / 247
Waste tires are currently used as RDF in cement industry in Serbia. The amount incinerated
(R1) in two cement plants was about 13.426 tonnes in 2016. About 27,000 t of waste tires were
treated in recycling operations (R5). The installation of civic amenity sites is one tool to reduce
the amount of tires disposed of illegally.

 There is no specific collection scheme for waste tires in place.
 There is no exact data on the generated amount. The treated quantities might include
treatment of stockpiles.
 The quantities put on the market are partly indicated in pieces, partly in tonnes, which
makes the use of this data challenging.
2.5.5 Waste electrical and electronic equipment
The basic legal requirements regarding management of the WEEE as a special waste stream
are given in Article 50 of the LWM. Electronic and electrical equipment is subject to the
REGULATION ON PRODUCTS THAT AFTER USE BECOME SPECIAL WASTE STREAMS (“Official Gazette of
the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14). The regulation prescribes a form of
daily record on quantity and type of produced and imported products and annual report, method
and deadlines for delivering the annual report, entities which need to pay a fee, criteria and
method for billing and payment of fee. Although the waste stream is subject to the principle of
extended producer responsibility (EPR) at the moment the Law on Waste Management (LWM)
does not provide a legal basis for collective or individual recycling schemes. Thus the level of
transposition of the WEEE Directive is rather low with just under half of its provisions being fully
transposed by the Serbian legislation.
Further, the Rulebook on harmonized amounts of incentives for re-use, recycling and recovery
of certain types of waste (MO on incentives) establishes the level on incentives (fees) for re-use,
recycling and recovery of waste electric and electronic equipment without a binding rule on how
to calculate recycling fees. Presently, these recycling fees are not based on real costs for the
management of WEEE, the Government does not base its decision on studies, and instead it
just applies the inflation rate.
Article 15 of the MO on WEEE is setting up the following collection rates, which are still based
on the “old” WEEE-Directive, without establishing the responsible legal entity:

 2 kg/cap/y by 31 December 2015, and;

 4 kg/cap/y by 31 December 2019.
It should be noted that these objectives were defined in Directive 2002/96/EC, but now Directive
2012/19/EU in Article 7 sets-up different collection rates, namely:
 From 2016, the minimum collection rate shall be 45% calculated on the basis of the
total weight of WEEE collected in a given year in the Member State concerned,
expressed as a percentage of the average weight of EEE placed on the market in the
three preceding years in that Member State.
 From 2019, the minimum collection rate to be achieved:
o 65 % of the average weight of EEE placed on the market in the three preceding
years, or alternatively;
o 85 % of WEEE generated on the territory of that Member State.
The inhomogeneous group of electrical and electronic appliances can be classified based on
their purpose; e.g. using the 10 categories as defined by the WEEE-Directive, Annex I, or in the
Serbian MO WEEE, Annex II:
 large household appliances;
 small household appliances;
 IT and telecommunications equipment;
 consumer equipment;
 lighting equipment;
 electrical and electronic tools (except for large-scale stationary industrial tools);
 toys, leisure and sports equipment;
 medical devices (except for implanted and infected products);
 monitoring and control instruments;
 automatic dispensers.
However, from 15 August 2018, all EEE shall be classified within the categories set out in
Annex III, namely:
 Temperature exchange equipment;
 Screens, monitors, and equipment containing screens having a surface greater than
100 cm 2;
 Lamps;
 Large equipment (any external dimension more than 50 cm) including, but not limited to:
o Household appliances; IT and telecommunication equipment; consumer equipment;
luminaires; equipment reproducing sound or images, musical equipment; electrical
and electronic tools; toys, leisure and sports equipment; medical devices;
monitoring and control instruments; automatic dispensers; equipment for the
generation of electric currents. This category does not include equipment included
in categories 1 to 3;
 Small equipment (no external dimension more than 50 cm) including, but not limited to:
o Household appliances; consumer equipment; luminaires; equipment reproducing
sound or images, musical equipment; electrical and electronic tools; toys, leisure
and sports equipment; medical devices; monitoring and control instruments;
automatic dispensers; equipment for the generation of electric currents. This
category does not include equipment included in categories 1 to 3 and 6;
 Small IT and telecommunication equipment (no external dimension more than 50 cm).

In terms of reporting the rules and formats regarding the EEE have been changed several times
in Serbia in recent years; therefore for the purposes of planning estimation of the EEE placed on
the market is based inter alia on interviews with relevant stakeholders and data of neighbouring
countries. The resulting figures on the EEE placed on the market are as follows: 2010 - 58,000,
2013 - 59,000 and 2016 – 60,000 tonnes.
Table 22: Estimation on EEE placed on the market (Source: MEP – DSIP WEEE Directive)
2010 2011 2012 2013 2014 2015 2016
Total EEE placed on the market

57.639 58.446 57.862 59.366 58.298 58.764 60.409
(tonnes)
EEE placed on the market (kilograms
8,02 8,13 8,08 8,31 8,19 8,28 8,54
per capita)
There is a little documentation on the amount of WEEE generated and collected. In addition,
there is no information on hazardous disposal of electronic equipment and there are small
number of companies dealing with WEEE recycling and the procedures of exporting WEEE
types which cannot be recycled in Serbia are perceived to be complicated.
The factors that might determine this situation related with data reporting:
 WEEE is primarily dismantled by a company and the components are passed to other
companies undertaking other dismantling phases and all companies report quantities as
treated, which results in a double counting;
 some equipment is wrongly understood as the WEEE (e.g. control rooms);
 there is a treatment of historic waste (legacy waste).
These situations occur because permits are not issued based on R-codes of operations, so the
operations are not classified correctly according to the Directive.
In the DSIP on WEEE Directive it was assumed that the collected amount was 1 kg
/inhabitant/year based on reported data on treated quantities, no imports and missing collection
system for WEEE from households.

Figure 4: WEEE treated in Serbia in tonnes (Source: SEPA annual report)
The dominant way to treat WEEE is manual dismantling, sorting of components and materials,
drainage of cooling agents and mechanical treatment in a universal cross flow shredder. Metal
fractions derived from treatment of WEEE are traded by numerous scrap metal traders. Serbia
has a steel work, Cu and Al-smelters. Electronic components containing precious metals, such
as printed circuit boards, are partly exported. Several installations for the mechanical treatment
of cables, for recovery of Cu and other metals are available. For some pure plastic fractions
recycling facilities are available in Serbia. Selected waste plastics (e.g. housings) are exported.
Hazardous components, such as CRT-glass or fluorescent dust are currently stored and
exported. Residual non-hazardous fractions are disposed at landfills or co-incinerated in cement
kilns. (MEP 2018, DSIP WEEE-Directive).

The level of transposition of the WEEE Directive is rather low with just under half of its
provisions being fully transposed by the Serbian legislation:
 Presently, the WEEE collection is based on selective collection of profitable WEEE. It is
assumed that WEEE is also collected at relevant amounts by the informal sector with
the aim to recover metals;
 There is no collection system for WEEE from households, except for bulky waste,
containing also WEEE with valuable materials, which is collected by informal waste
collectors directly at households;
 There are no sorting and temporary storage facilities for the WEEE;
 The SEPA does not have comprehensive data on generation/collection of WEEE;
 There are no legal requirements to register the EEE producers and to develop a
National Registry;
 There is a significant disparity between figures on the total amount of the EEE placed
on the market and the total amount of the WEEE treated (recycled);
 Public awareness campaigns are missing.
2.5.6 Waste mercury-containing fluorescent tubes
Although waste mercury-containing fluorescent tubes are a special waste stream in accordance
with Article 51 of the LWM they fall in principle under the definition of WEEE (Article 5 and
Annex 2 of Directive 2012/19/EU).
The specific requirements in the collection and transportation of waste fluorescent tubes
(compared to other WEEEs) are regulated by the Regulation on Manner and procedure for
management of waste mercury-containing fluorescent Tubes (“Official Gazette of the Republic
of Serbia”, No. 97/2010).
The restrictions on mercury content in accordance with Directive 2012/19/EU as well as the
obligation of separate collection are implemented by the Rulebook on the list of electrical and
electronic products, measures of prohibition and restriction of use of electric and electronic
equipment containing hazardous substances, methods and procedures of managing waste from
electric and electronic products (“Official Gazette of the Republic of Serbia”, No. 99/2010).
Fluorescent tubes are also subject to the Regulation on products that after use become special

waste streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14) and
Rulebook on harmonized amounts of incentives for re-use, recycling and recovery of certain
types of waste.
Like for other WEEEs there is neither an organized separate collection nor an implementation of
the EPR scheme for mercury-containing fluorescent tubes yet. Thus the full implementation of
the obligations under the WEEE Directive should be aimed together with the implementation of
a general collection scheme for WEEEs. In accordance with SEPA data about 309 tonnes of
waste code 20 01 21* (fluorescent tubes and other mercury containing wastes) were collected in
2016. Comparable data from EU MS give an indication that can be expected an amount of 2100
tonnes per year. In accordance with the SEPA data base 116 companies had a license for the
collection and 9 companies had a license for the treatment of wastes waste code 20 01 21* in
2016.

 Several requirements of the WEEE Directive (covering also mercury containing
fluorescent tube) have not yet been transposed in Serbia legislation;
 Like for other WEEEs no regular collection system has been established for mercury
containing fluorescent tubes;
 There is a need to improve the procedures for market input data in order to improve the
data quality;
 The major part of mercury containing fluorescent tubes is disposed of with mixed
municipal waste.
2.5.7 Used batteries and accumulators
Based on the LWM, in 2010 detailed provisions for the management of batteries and
accumulators were adopted in the RULEBOOK ON THE PROCEDURE FOR MANAGEMENT OF WASTE
BATTERIES AND ACCUMULATORS (“Official Gazette of the Republic of Serbia“, No. 86/10) and the
Regulation on products that after use become special waste streams.
Also, in 2017, the Minister of Agriculture and Environment adopted the Rulebook on harmonized
amounts of incentives for re-use, recycling and recovery of certain types of waste. The
Regulation on the determination of types of hazardous waste that can be imported as a
secondary raw material (“Official Gazette of the Republic of Serbia“, No. 60/09) designates
types of hazardous waste that may be imported to the Republic of Serbia as secondary raw
materials including lead accumulators. The waste catalogue and the waste classification
procedures are regulated by the By-law on CATEGORIES, TESTING AND CLASSIFICATION OF WASTE
(“Official Gazette of the Republic of Serbia“, No. 56/10). However, the Directive is not fully
transposed.
Batteries and accumulators may be distinguished between ‘battery types’ (portable
batteries/accumulators, automotive batteries/accumulators, industrial batteries/accumulators,
battery packs, button cells) and ‘battery technologies’ differentiating between non rechargeable
and rechargeable batteries, also called ‘accumulators’. Within the battery technologies it is also
possible to distinguish ‘battery chemistries’ giving information about the main content of the
batteries and accumulators.
For batteries/accumulators coming from collection from final users the codes of chapter 20 of
the European List of Waste should be used. For batteries and accumulators from sorting or
professional activities (e.g. car maintenance) waste codes of chapter 16 should be used. Lead-
acid, Nickel-Cadmium and all kinds of Mercury (Hg) containing batteries and mixtures of
batteries and accumulators possibly containing them are classified as hazardous waste.

Table 23: Waste codes for waste batteries and accumulators
Waste waste code

batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and
20 01 33*
unsorted batteries and accumulators containing these batteries
batteries and accumulators other than those mentioned in 20 01 33 20 01 34
Lead batteries 16 06 01*
Ni-Cd batteries 16 06 02*
Mercury- containing batteries 16 06 03*
Alkaline batteries (except 16 06 03) 16 06 04
other batteries and accumulators 16 06 05
separately collected electrolyte from batteries and accumulators 16 06 06*
*...hazardous
Figure 5: Batteries and accumulators placed on the market in Serbia (tonnes)

According to data reported to the SEPA indicate that 12.000 – 14.000 tonnes of batteries and
accumulators were placed on the market annually during last 3 years. Bearing in mind that all
importers do not report imported quantities of batteries and accumulators to the SEPA, it can be
assumed that total quantity of batteries and accumulators placed on the marker reach approx.
15.000 tonnes per year.
The SEPA does not have comprehensive data on generation and collection of batteries and
accumulators.
Due to their economic value, almost all waste automotive batteries are collected. One main
company carries out recycling in Serbia, including recycling of imported waste lead-acid

batteries). According to the report of the SEPA on products that after use become special waste
in the Republic of Serbia, 9.407 t of batteries and accumulators were recycled in 2016 of which
163 t were imported from abroad. In 2016, 5.249 tonnes of batteries and accumulators were
exported from Serbia.
Assessment of the current situation - main issues:
 Several requirements of the Batteries Directive have not yet been transposed in Serbia
legislation;
 No regular collection system has been established for industrial batteries and
accumulators. Information about collection facilities and/or collected amounts of
industrial batteries and accumulators is not available;
 There is no regular collection system for portable batteries and accumulators in place.
 There are no sorting and temporary storage facilities;
 There is a need to improve the procedures for market input data in order to improve the
data quality;
 The SEPA does not have comprehensive data on generation/collection of WBA.
2.5.8 PCB waste
Legal basis for the management of PCB waste in Serbia

The Republic of Serbia ratified the Convention in 2009 and since becoming a party, the
Government has taken on the mandatory obligations to implement the Convention and control
measures identified in its guidance text. The first step towards meeting the obligations was the
development and formulation of the National Implementation Plan (NIP) for the Stockholm
Convention. The NIP was prepared and transmitted to the Stockholm Convention Secretariat in
2010 and was up-dated for the period 2014/2015. Serbia submitted to the depositary for the NIP
update 2016 (deadline 26 November 2016) and update 2018 (deadline 15 December 2018)
notifications of non-acceptance, in accordance with paragraph 3 of Article 22 of the Stockholm
Convention. As at 27 December 2016 Serbia had not withdrawn its notification of non-
acceptance.
In Serbia, PCB waste management is regulated by Article 52 of the Waste Management Act and
the “Rulebook on treatment of devices and waste containing PCB (“Official Gazette of the
Republic of Serbia“, No. 37/11).
According to Article 52 of the Waste Management Act, PCB waste shall be collected separately.
It is foreseen that in Serbia equipment containing more than 5 dm 3 of PCB is disposed of or
decontaminated until 2019/20 at the latest. Equipment containing between 0.005% and 0.05%
by weight (equivalent to 500 ppm or 500 mg/kg) of PCBs shall be decontaminated or disposed
of when it is out of use. According to the proposal for a recast of EC-Regulation 850/2004
(COM(2018) 144 final from 22.03.2018), the identification and remove from use of PCB-
containing devices > 50 mg/kg and > 0,05 dm³ up to latest 31 December 2025 29 shall be
required. If this legislation comes into force, the Waste Management Law and the Rulebook on
management of PCB containing equipment and waste shall be amended to this new
requirement.
The Serbian Waste Management Act defines obligations concerning the management of PCB
waste or PCB-containing equipment for the waste owners:
29
Derogating from Art. 9 of Directive 96/59/EC which allows the use of transformers with PCB-content between 0,05 %
and 0,005 % up to the end of their useful lives and requires a disposal only after their phasing out

 the owner of PCB and PCB waste is obliged to organize its disposal, i.e.
decontamination;
 the owner of PCB-containing equipment in use or an equipment possibly contaminated
with PCB, is obliged to examine the PCB content using the services of accredited
laboratory authorized to conduct such waste analysis;
 the owner of equipment containing more than 5 dm 3 of PCB is obliged to report to the
MEMSP and to propose a replacement plan, i.e. a plan of its disposal and
decontamination, to ensure its disposal and decontamination, as well as to report to the
MEMSP any change of data related to equipment, not later 3 three months from the
date when the change has occurred.
Definition and qualitative characterisation

Polychlorinated biphenyls (PCBs) are chlorinated derivatives of organic compound biphenyl with
general formula C12H10‐xClx. PCBs were once widely deployed as dielectric and cooling fluids in
electrical equipment, in carbonless copy paper, in coatings and in heat transfer fluids. Such
wide application of the material was the results of its inherent stability and longevity. As a result
of material’s proven toxicity to humans and the environment the production of PCBs was
banned. The classification of PCBs as Persistent Organic Pollutants was confirmed by the
Stockholm Convention on Persistent Organic Pollutants in 2001.
PCB containing equipment in use

According to the up-dated NIP, in 2015 623 tonnes of PCB fluids in 3.469 transformers were
reported to be in use by the owners of transformers (see details in Table 24). The corresponding
total mass of transformers30 in use in Serbia is approximately 3 300 tonnes. Until 2017, 230
tonnes of low PCB contaminated oil 31 and thereby 919 tonnes of PCB transformers have been
decontaminated to PCB concentrations below 50 ppm using PEG de-chlorination technology.
Thus, in 2017, the stockpiles of PCB fluids in transformers are about 393 tonnes.
Table 24: Transformers with PCB-based fluids in use in Serbia in 2015 (Source: Draft SWSP
for wastes containing POPs, 2018)
number of fluid mass
District/owner remarks
transformers [kg]
23 17,000 High PCB concentration or neat PCB
Company "Elektroprivreda Low PCB concentration (50 – 2000 ppm);
Srbije" 116 428,100 Data from Inventory on voltage level ≥ 35 kV;
Inventory on lower voltage levels in progress
Company „Elektroprivreda
Around 1500 transformers tested;
Srbije“ – Branch 225 80,305
Further inventory on low voltage grid is in progress
„ElektroVojvodina“
Company „Elektroprivreda
Srbije“ – Branches „ED Estimate on population of ca 50,000 transformers on
Beograd“, „Centar“, low voltage grid, 6% contaminated, on average 400 kg
3000 1,200,000
„Elektro-Srbija“ and PCB contaminated oil per transformer, > 95% low PCB
„Jugoistok“; con-centration
low voltage < 35 kV grid
Non-energy sector inventory by
56 56,300 307 transformers tested
UNIDO
Company „PTT Srbije” 1 300
30
consisting of the device itself and the PCB-fluid
31
149.5 tonnes from “Elektroprivreda Srbije and 80.3 tonnes from “ElektroVojvodina”

number of fluid mass

District/owner remarks
transformers [kg]
Company „Železnice Srbije” 17 2,894 473 transformers already tested
South Banat District 6 15,560 transformers declared as waste
no data for 2 transformers; most likely neat PCB or
Ministry of Defence 25 21,996
high PCB concentration
Mačva District, Morava District,
Nišava District, Pčinja District,
Most likely or already included in
Pirot District, Podunavlje
“Elektroprivreda Srbije”
District, Company „Đerdap”,
Toplica District, Zlatibor District
622,455 kg confirmed
Total 3,469 1,822,455 1,200,000 kg estimated to be confirmed upon
extension of the inventory
In 2015, a total number of 4,394 capacitors corresponding to a mass of 173 tonnes could be
identified in Serbia. For 833 capacitors a corresponding quantity of 22.1 tonnes of PCB fluid has
been estimated. For the remaining 3.561 capacitors no information on the share of the PCB fluid
is available.
Furthermore in 2015 41 rotor resistors containing PCB fluids with a total mass of approximately
3.25 tonnes were in use in Serbia.
All kinds of PCB-containing wastes are hazardous wastes and can be attributed to the waste
codes of the ELW as listed in Table 25 summarizes amounts of PCB waste generated and
exported out of Serbia in recent years.
Table 25: Generation and export of PCB-wastes (Source: NIP under Stockholm Convention
(up-date 2014/2015), SEPA database on waste generation and export for the reference year
2016)
amount of wastes containing PCB [t]
waste code description generated exported

2010 -
2016 2003-07 2013 2016
2013
13 01 01* Hydraulic oils containing PCB 0.4 - - -

Insulation and heat transfer oils 10.5
13 03 01* 4.97 81.2 79.92 23
containing PCB
16 01 09* Components containing PCB - 0.04 - - -
Transformers and PCB-containing
16 02 09* 106.77 71.7 267.2 277.85 113
capacitors
Disposed equipment containing or
16 02 10* contaminated with PCB, other than - - - 4.97
these listed in 16 02 09*
Waste generated from construction
17 09 02* - 2.7 206 2.08
and demolition which contains PCB
total 112.14 155.64 483.7 364.82 136

The NIP 2014/15 provides information about PCB containing equipment out-of-use, which can
be seen as waste awaiting treatment/disposal. In total, 27 transformers with a total mass 90
tonnes including fluids, 4,003 capacitors with a total mass of approximately 121 tonnes including
fluids. Furthermore, the inventory of PCB waste includes 50 tonnes of wastes including
contaminated construction material, barrels containing oil contaminated with PCB and other
materials.
Small PCB-devices are expected in large electric household appliances in a concentration
of about 0.1%. In 2016 37,000 tonnes of WEEE were treated in Serbia32. Assuming a share of
generated by proper WEEE treatment would result in approximately 3.4 to 4.4 tonnes per year.
In addition to information on generation of PCB containing oils reported to SEPA (see Table
25), estimates on the potential generation of PCB containing waste oil can be made based on
potential waste oil generation. According to the Serbian SWSP on Waste Oils (up-date 2016)
the potential annual generation of waste oils is estimated to be 25,000 to 37,000 tonnes. In
Germany, for example, less than 0.5 % of the total waste oil quantities contain PCBs. Assuming
the same share for Serbia the potential generation of PCB-containing waste oils can be
estimated with a maximum of 125 to 185 tonnes per year.
Treatment of PCB containing waste

Treatment options for PCB wastes, i.e. oils containing PCB and equipment containing PCB, are
not sufficient in Serbia. Thus, the currently ongoing UNIDO-project “Environmentally Sound
Management and Final Disposal of PCBs” shall establish the basis for the decision whether to
develop installations for the treatment of PCB waste in Serbia and for choosing the best solution
for disposal of Serbian PCB waste.
The only treatment of PCB-containing waste in the year 2016 reflected in the SEPA database 33
are 200 tonnes of insulation and heat transfer oils containing PCB (13 03 01*), which were
treated using PEG dechlorination technology in a mobile treatment plant operated in Belgrade.

 The Serbian legislation obliges the owner to report all PCB devices > 5 dm³ to the
Ministry in order to get a replacement, decontamination and disposal according to the
legal requirements. This database does not include PCB containing wastes from other
sources, e.g. mineral construction and demolition wastes, so the database shall be
widened.
 Concerning the PCB devices, the intended new obligation of EC-Regulation 850/2004
(drafted recast) shall be considered which intends to identify and to phase out all PCB
device > 50 mg/kg and > 0.05 dm³ up to latest end of 2025.
 At present, there are no facilities for permanent storage of PCB-wastes in Serbia and
there is one mobile unit for decontamination of equipment containing insulating fluids
contaminated by low concentrations of PCBs. Currently, PCB containing waste is often
stored in intermediate storage facilities prior to export 34 for incineration in hazardous
waste incineration plants.
 Intermediate storage is permitted for up to 12 months according to Serbian Landfills
Regulation. However, some of these storage facilities are inadequate (“factory-
storage”).
32
SEPA database for the reference year 2016
33
SEPA Database on waste generation and treatment
34
According to the SEPA database on exported waste 23 tonnes of insulation and heat transfer oils containing PCB
were exported to Switzerland in 2016. 113 tonnes of transformers and PCB-containing capacitors were exported to
Romania.

 Treatment options for PCB wastes, i.e. oils containing PCB and equipment containing
PCB, are not sufficient in Serbia. Thus, the currently ongoing UNIDO-project
“Environmentally Sound Management and Final Disposal of PCBs” shall establish the
basis for the decision whether to develop installations for the treatment of PCB waste in
Serbia and for choosing the best solution for disposal of Serbian PCB waste.
2.5.9 Other POPs waste
Persistent Organic Pollutants (POPs) are organic chemicals halogenated with Chlorine,
Bromine or Fluorine. Once released into the environment, POPs are able to:
 remain intact for exceptionally long time period of many years;
 become widely distributed throughout the environment as a result of especially human
activities as well as natural processes involving mainly air but also soil and water (POPs
can be found in living organisms even in regions far away from any major POPs
source);
 accumulate in the fat tissue of living organisms including humans, and are found at
higher concentrations at higher levels in the food chain and;
 be toxic in a wider sense to both humans and wildlife 35
Three categories of POPs are usually distinguished: pesticides, industrial chemicals and
unintentional by-products from industrial processes.
In 2001 the Stockholm Convention aiming in protecting human health and the environment from
persistent organic pollutants was adopted. Initially twelve POPs – the so called “Dirty Dozen”
-were covered by the Convention. Meanwhile (last amendment with decision from COP.8 in
2017) 18 new POPs have been added36
Among others, the provisions of the Convention require the parties to:
 Prohibit and/or eliminate the production and use, as well as the import and export, of
the intentionally produced POPs that are listed in Annex A to the Convention;
 Restrict the production and use, as well as the import and export, of the intentionally
produced POPs that are listed in Annex B to the Convention;
 Reduce or eliminate releases from unintentionally produced POPs that are listed in
Annex C to the Convention;
 Ensure that stockpiles and wastes consisting of, containing or contaminated with POPs
are managed safely and in an environmentally sound manner.
The Republic of Serbia ratified the Stockholm Convention in 2009 and since becoming a party
the Government has taken on the mandatory obligations to implement the Convention and
control measures identified in its guidance text.
The first step towards meeting the obligations was the development and formulation of the
National Implementation Plan (NIP) for the Stockholm Convention. The NIP was prepared
initially in 2010 and was up-dated for the period 2014/2015 (for detailed information compare
para. 1 in chapter 2.5.8).
In the EU, for the enforcement of the POPs relevant legislation, the EU Regulation on POPs
(EC) No. 850/2004 has to be considered. This Regulation is directly applicable in all MS.
35
Specific effects of POPs can include cancer, allergies and hypersensitivity, damage to the central and peripheral
nervous systems, reproductive disorders, disruption of the immune system and hormone balance and damage of
various organs, such as the liver and kidneys
36
http://chm.pops.int/

Pentachlorophenol and its salts and esters (PCP) and Decabromobiphenylether (Deca-BDE)
are part of the Stockholm convention but not yet implemented into the EU Regulation on POPs.
In Serbia, POPs waste management is regulated by Article 53 of the Waste Management Act
and the Rulebook on the list of POPs substances, the manner and procedure for the
management of POPs waste and limit values for concentrations of POPs substances related to
the disposal of wastes containing or contaminated with POPs substances (“Official Gazette of
the Republic of Serbia“, No. 65/11, 17/2017). Article 53 of the LWM stipulates, that anybody
treating POPs waste shall ensure that the residues of the treatment process are not POPs
waste. This refers especially to the formation of unintentional produced POPs (e.g.
PCDD/PCDF) during the treatment process. Furthermore, waste holders are obliged to notify
the type and quantity of the relevant POPs waste to the Ministry of Environmental Protection.
Generation of wastes containing POPs pesticides

Pesticides are the biggest group of POPs and include 14 substances, which were used as
biocides and plant protection chemicals, herbicides and fungicides.
POPs pesticides were produced in several industrial plants in Serbia. The production of POPs
pesticides, their placement on the market and use in Serbia are not allowed since 2007 latest 37.
Thus, it can be assumed that since then these pesticides can be found only in stockpiles of
agriculture and forestry. If stockpiles of prohibited chemicals are found, they are to be treated as
waste and handled in accordance with provisions of the LWM and the Rulebook on the list of
POPs substances, the manner and procedure for the management of POPs waste and limit
values for concentrations of POPs substances related to the disposal of wastes containing or
contaminated with POPs substances. The Serbian legislation does not require the development
of a stockpile and waste identification strategy, as defined in Article 6 of the Stockholm
Convention. Smaller amount of obsolete pesticides may be stockpiled in private households.
Thus the introduction of a separate collection of hazardous waste from households is also a
priority for the comprehensive implementation of the Convention.
Another source of wastes containing POPs pesticides is packaging material (original and
temporarily used) and all devices in contact with POPs pesticides such as tanks, pipes, spraying
devices, transport containers and devices in decontamination and treatment facilities. This
includes also building compartments contaminated with spills from pesticides (walls, floor) as
well as unintentionally contaminated soil.
Generation of wastes containing pesticides is shown in Table 26. However, information about
the share of POPs pesticides in these wastes is not available
Table 26: Amount of wastes containing pesticides (Sources: SEPA-database on waste

generation for several reference years)
amount of generated wastes containing POPs
pesticides [t]
waste code Description
2010 2011 2012 2013 2016
Agrochemical waste containing hazardous

02 01 08* - - - - -
substances
15 01 10* Packaging containing residues of or 15.0 78.2 - 40.9 5.033
37
Included in the List of banned POPs substances which is included in the RULEBOOK ON LIMITATIONS AND BANS OF
PRODUCTION, PLACEMENT ON THE MARKET AND USE OF CHEMICALS , Official Gazette of the Republic of Serbia“, No. 65/11,
17/2017

contaminated by hazardous substances

20 01 19* Pesticides contained in municipal waste - 59.5 - - -
The Serbian National Implementation Plan under the Stockholm Convention (update 2014/15)
contains information about amounts of POPs pesticides in stockpiles in 2007 and 2014 38. In total
more than 6 tonnes of lindane and DDT were identified in 2014 and 1.35 tonnes in 2017 (see
details in Table 27 ). There is, however, no sufficient information about the whereabouts of the
resulting difference. Thus the information is considered unreliable. Further, it is expected, that
these figures are not complete and still un-identified stockpiles and plants may exist. Also, it is
expected, that some outdated pesticides were buried and illegally dumped. Currently there are,
however, no hints about where such sites could be. Thus it is assumed, that the total amount of
historical POPs pesticides, which have to be disposed of by means of destruction, is still higher
than 1.35 tonnes.
Table 27: POPs pesticides inventory according to the NIP (update 2014/15)
POPs pesticides
39
Organisation inventory [kg] remarks concerning the current state
total 2007 total 2014
Lindane
Forest Estate (FE) "Timočke
80 0 The total pesticide waste amount generated by Public
šume" Boljevac
Enterprise “Srbijašume” (Forest Estates Boljevac,
FE Bor Rasadnik-Selište 8 0 Rasadnik-Selište, Kruševac and Kraljevo) was stored in the
FE "Rasina" Kruševac 564 1,110 temporary storage facility in Forest Estate “Rasina” in
Kruševac
FE "Stolovi" Kraljevo 47 0
All lindane-based preparations from Forest Estate

FE "Banat" Pančevo 3,200 0
“Banat” in Pančevo were hand out to other legal entities
Quantities of lindane-based preparations were recorded

FE "Kozara" Bački Monoštor - 200
during the inventory update.
bankruptcy of the entity; pesticide storage unit was torn

ZZ "Fruška Gora" 1,500 0 down; assumption that there are no lindane-based
preparations left on this location
PAD "Nova Budućnost" 200 0 broken in and lindane-based preparation were stolen
total quantity leaked onto the floor; afterwards stabilised

PIK "Južni Banat" a.d. 166 remarks
with sand and stored in containers
bankruptcy of the entity; pesticide storage facility (poor

"Seme Sombor" a.d. 17 17
condition) was locked/secured with barb wire
total quantity stored in a secured storage building

A.D. "Agrounija" Inđija 16 16
dedicated for storage of expired products
38
The main reasons for the differences between 2007 and 2014 of the elevated total amounts of POPs pesticides in
Serbian stockpiles are the closure of plants including the movement of stockpiles to central storage units, the burglary
of pesticides from storage units, leakages of pesticides and, surely, the intermediate use of pesticides for their
intended purposes.
39
this figures include all liquid substances, too, which were converted with a density of 1 kg/l

DP PK "Krajina Holding" company has shut down; no available data on lindane-

2 -
Negotin based pesticide waste
Hibrid doo. Belgrade - 7
Additionally, the amounts of leaked and sand-bond

subtotal 5,800 1,350
Lindane have to be taken into account.
POPs pesticides
40
Organisation inventory [kg] remarks concerning the current state
total 2007 total 2014
DDT
"Zorka-Plant Protection" a.d. bankruptcy of the entity; taken over by another legal entity;
250 0
Šabac no previously identified amounts of DDT/ POPs
Stefanović Saša. Svrljig. 200 -
subtotal 450 0
total POPs pesticides 6,250 1,350
Generation of wastes containing PBDE

Polybromodiphenyl ether congeners including Tetra-BDE, Penta-BDE, Hexa-BDE, Hepta-BDE
and Deca-BDE are/were used as additive flame retardants. In Serbia, industrial production of
PBDE was not performed at any time. However, there were plants, which used PBDE in the
production of goods like PUR foam, coatings, rubber or electrical devices. There may still be
imports of devices/equipment/products from countries where the use of PBDE is not prohibited.
A main source of PBDE-containing waste is the waste management and recycling industry,
especially treatment plants for:
 dismantling of electric and electronic equipment;
 dismantling of end-of-life vehicles (coated textiles, construction foam);
 shredder plants for vehicles, WEEE and bulky wastes from households (PBDE are
found in the fluff and plastic parts);
 rubber and plastics recycling;
 treatment and sorting of mineral and mixed construction and demolition material.
Furthermore, PBDE is found in sewage sludge, although the concentration is two orders of
magnitude below the limit defined as “low POPs content” in the rulebook (for PBDE
1.000 mg/kg). PBDE concentrations in sewage sludge are not only caused by industrial waste
water but by waste water from households and small business enterprises 41. Releases from
washing processes of coated textiles are supposed to be the major source of PBDE in waste
water and sewage sludge, respectively. Although these low concentration don’t trigger POPs
waste the possible content should be considered and tested when sewer sludge is used as a
fertilizer or is composted.
40
this figures include all liquid substances, too, which were converted with a density of 1 kg/l
41
Umweltbundesamt: Emissionen organischer und anorganischer Stoffe aus kommunalen Kläranlagen; Wien, 2009;
http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0247.pdf

The Draft Serbian Waste Management Plan for wastes containing POPs (2016) estimates a
yearly amount of 15,000 tonnes of PBDE containing parts in end-of life vehicles. Furthermore,
an annual quantity of 10,000 tonnes PBDE containing parts in WEEE is estimated. These
quantities are expected to be transferred to fluff and plastics fraction when WEEE and ELV are
processed in shredder plants.
Generation of wastes containing Perfluorooctanesulfonic acid and salts (PFOS)

The current intentional use of PFOS is widespread and includes: electric and electronic parts,
fire-fighting foam, photo imaging and paper industry, hydraulic fluids and textiles. There is no
intentional use reported for Serbia but it cannot be excluded that PFOS containing products
were used and therefore PFOS can be found in end-of-life-products and in remediated sites.
Besides the paper and textile industry, the galvanic industry is the main source of PFOS
contaminated wastes. PFOS can especially be expected when chromium plating, anodising and
acid pickling processes are applied. Furthermore, the photographic industry is an important
source of PFOS emissions because of paper and film production, developers, printing plates.
The aviation industry uses hydraulic fluids containing PFOS. Possibly, PFOS can still be found
in foam of fire-fighting devices or in stockpiles of outdated or maintained fire-fighting devices.
PFOS can also be found in waste water caused by industrial and private textile cleaning. Waste
water cleaning plants do not degrade or destroy PFOS, so they can be found in the sewage
sludge and as well in the cleaned water.
Estimates on PFOS containing products/wastes in Serbia are available from the draft Serbian
Waste Management Plan for wastes containing POPs (2016):
 3.8 to 45.6 tonnes of fire-fighting foam (corresponding to 0.228 tonnes PFOS);
 44 to 2,200 tonnes coated paper (corresponding to 2,2 tonnes PFOS);
 323 to 3,230 tonnes in coated articles (corresponding to 3,23 t PFOS);
 2 to 2,000 tonnes hydraulic fluids and other products (corresponding to 1 t PFOS).
In total 375 to 7,470 tonnes of PFOS containing products can be expected in Serbia. Assuming
an average life-time of the relevant products of about 20 years an average yearly generation of
250 tonnes PFOS containing waste is estimated for Serbia.
Generation of wastes containing Hexabromocyclododecane (HBCD)

The predominant use of HBCD was as a flame retardant in polystyrene insulation material.
Thus, the main source of HBCD containing wastes is the construction sector. According to the
draft Serbian Waste Management Plan for wastes containing POPs (2016) the generation of
HBCD containing insulation material from demolition activities is expected to be approximately
3,800 tonnes per year. The use of HBCD in polystyrene foams has been phased out meanwhile.
Generation of wastes containing PCDD/PCDF

The main sources of residues containing PCDD/PCDF are metallurgical processes, power
plants and waste disposal sites. According to data presented in the Serbian NIP under the
Stockholm Convention the yearly amount of unintentionally produced PCDD/PCDF in residues
corresponds to 17.6 to 27.2 g TEQ.
POPs contaminated soils

Currently there is no comprehensive data base identifying sites polluted by specific POPs
chemicals available for Serbia. There is a large number of sites contaminated with various types
of pollutants. According to SEPA (2012) in total 384 (potentially) contaminated sites were

identified, including also 2% remediated sites. About one quarter thereof are sites where
industrial waste was disposed of and where industrial and commercial activities were
performed42. Sites where chlorinated organic pesticides were produced or stored, sites of
industrial processes generating PCDD/PCDF and PAH releases (e.g. non-ferrous pyro
metallurgy), chlor-alkali facilities, facilities having used vinyl chloride monomers and chlorinated
phenols (wood protection, leather tanning) stand the risk of contamination.
Treatment of other POPs wastes in Serbia

According to SEPA43, in 2016, 933 tonnes of packaging containing residues of or contaminated
by hazardous substances were treated in nine different treatment plants. However, it is
expected that these quantities refer to non-POPs pesticides only.

 Treatment options for other POPs wastes are not sufficient in Serbia, neither for the
original 12 POPs nor for the new POPs.
 The identification of POPs wastes (especially the new POPs) is a challenge and needs
a broader data base about relevant products which contain possibly POPs and which
become wastes after their use. Typical waste codes shall be considered – on the basis
of SWSP on POPs - for this purpose according to precaution reasons and to be
examined continuously by analytical means.
 Currently POPs containing waste is often stored in intermediate storage facilities prior to
export44 for incineration in hazardous waste incineration plants. This especially refers to
POPs waste, whose owner is not always known. The intermediate storage is permitted
for up to 12 months according to Serbian Landfills Regulation. However, some of these
storage facilities are inadequate (“factory-storage”).
 The knowledge of affected enterprises and of public about POPs is very weak because
POPs represent a special kind of chemicals which are not in a general focus.
Nevertheless, the possible impacts of POPs and POPs containing wastes shall not be
underestimated because of their behaviour for ubiquitous distribution, persistence,
bioaccumulation and intoxication, So, educational informing about the possible
endangers and the right handling of POPs containing wastes shall be improved.
 Producers and treatment plants of possibly POPs containing wastes shall be sensitised
about the endangers and be supported in checking the real POPs content in certain
waste streams like shredder wastes, coated parts from electric and electronic devices
and from cars. In the same way, the government and the competent authorities shall be
aware of the potentially capability that contaminated sites shall contain POPs.
 Because of the wide range of use of potentially POP containing products in the private
sphere, POPs can be peel off by washing and cleaning processes from clothes, carpets
and furniture surfaces and therefore be ubiquitous spread with sewage sludge. On the
same reason, POPs are expected in typical household wastes like bulky wastes as well.
2.5.10 Medical waste
The competences for medical wastes are split between the Ministry of Environment and the
Ministry of Health. Article 56 of the LWM defines medical waste as special waste stream,
42
NIP under the Stockholm Convention (up-date 2014/2015)
43
SEPA Database on waste generation and treatment
44
According to SEPA, in 2016, packaging containing residues of or contaminated by hazardous substances was
exported to Austria (57 tonnes), to Poland (29 tonnes) and to Switzerland (0.08 tonnes). Also 0,07 tonnes of
pesticides were exported to Austria

stipulates obligations of the producer of such wastes and lays down the basic legal
requirements regarding management of medical waste. The main requirements of Article 56 of
the LWM are related to the reduction, collection, transport, export and treatment of medical
wastes. Furthermore, Article 56 stipulates that medical waste management plans shall be
adopted by the Ministries responsible for healthcare and veterinary matters. It also obliges the
producer of medical waste to submit data about quantities of waste broken down as per types
and manner of treatment to the SEPA.
According to Article 56B of the LWM, costs related to medical waste management, including
pharmaceutical waste management shall be borne by the producer of waste, except for costs
related to management of pharmaceutical waste collected from citizens.
In accordance with Article 56 (16) of the Waste Management Act (RS 36/09, 88/10 and 14/16),
the Minister for Health and the Minister for Environmental Protection agreed to draw up the
Waste Management Regulation related medical waste. In December 2018 the legal procedure
was completed and the document is expected to be published in Official Gazette.
The Ministry of Health develops health policies and budgets, monitors the work of state-owned
health institutions and approves plans for purchases of medical equipment. On veterinary policy,
annual programmes of animal health protection measures and monitoring of pharmacologically
active substances for 2016 were adopted or notified to the European Commission. (Commission
Staff Working Serbia 2016 Report45)
The waste from human or animal health care and/or related research (except kitchen and
restaurant wastes not arising from immediate health care) are classify (according to List of
Waste) in group 18.
Wastes (hazardous (*) and non-hazardous) are included in two subcategories:
 18 01 - waste from natal care, diagnosis, treatment or prevention of disease in sanitary
units.
 18 02 - waste from research, diagnosis, treatment or prevention of disease involving
animals.
Healthcare waste can be hazardous either due to its infectious properties or due to a content of
hazardous chemicals and pharmaceuticals. Thus, proper source separation (and pre-
treatment/sterilisation) is a prerequisite to reduce the amount of hazardous waste generated in
healthcare.
According to data reported to the SEPA, approximately 2.430 – 2.830 tonnes of medical wastes
of the subcategory 18 01 (waste from natal care, diagnosis, treatment or prevention of disease
in sanitary units) have annually been generated in Serbia.
Table 28: Medical waste generated 2011- 2016 in tonnes (Source: SEPA, 2017)
Waste
Waste type 2011 2012 2013 2014 2015 2016
code
Sharp instruments
18 01 01 172,02 165,54 106,87 149,06 167,15 170,32
(except 18 01 03)
body parts and organs
including blood bags and
18 01 02 57,26 48,43 37,65 44,30 50,22 45,70
blood preserves (except 18 01
03)
45
http://www.mei.gov.rs/upload/documents/eu_dokumenta/godisnji_izvestaji_ek_o_napretku/godisnji_izvestaj_
16_eng(1).pdf

Waste
Waste type 2011 2012 2013 2014 2015 2016
code
wastes whose collection and
disposal is subject to special
2.465,43 2.053,12 2.199,08 2.583,18 2.470,33 2.491,97
18 01 03* requirements in order to
prevent infection
wastes whose collection and
disposal is not subject to special
requirements in order to
18 01 04 57,3 136,04 40,85 36,48 52,19 33,71
prevent infection (for example
dressings, plaster casts, linen,
disposable clothing, diapers)
chemicals consisting of or
18 01 06* containing hazardous 23,18 28,63 11,69 6,27 22,86 18,07
substances
chemicals other than those
18 01 07 21,11 5,02 2,53 1,00 0,00 0,00
mentioned in 18 01 06
cytotoxic and cytostatic
18 01 08* 4,82 5,25 5,011 6,27 15,09 19,48
medicines
medicines other than those
18 01 09 30,08 53,97 22,03 6,49 4,94 6,58
mentioned in 18 01 08
18 01 10* amalgam waste from dental care 0,20 0,02 0,01 0,00 0,00 1,03
TOTAL 18 01 2 .831,20 2.495,99 2.425,71 2.833,05 2.782,79 2.785,82
The largest share are waste with code 18 01 03*, waste whose collection and disposal are
subject to special measures to prevent infections and the largest amount of 18 01 waste was in
2011, 2014 and 2016.
Data reported to SEPA indicate that additionally approximately 22 – 40 tonnes veterinary
wastes of the subcategory 18 02 (waste from research, diagnosis, treatment or prevention of
disease involving animals) have annually been generated in Serbia
Table 29: Veterinary waste generated 2011-2016 in tonnes (Source: Waste management in
Republic of Serbia, SEPA 2017)
Waste
Waste type 2011 2012 2013 2014 2015 2016
code
18 02 01 sharps (except 18 02 02) 0,01 1,80 0,16 0,23 0,08 2,01
wastes whose collection and disposal is
18 02 02* subject to special requirements in order 7,42 5,84 15,53 27,33 33,57 33,06
to prevent infection
wastes whose collection and disposal is
18 02 03 not subject to special requirements in 12,88 14,48 8,93 2,59 2,10 2,34
order to prevent infection
chemicals consisting of or containing
18 02 05* 0,35 0,35 0,00 0,11 0,11 0,00
hazardous substances
chemicals other than those mentioned in
18 02 06 0,00 0,00 0,00 5,00 0,00 0,00
18 02 05
18 02 07* Cytotoxic and cytostatic medicines 0,6 0,4 0,43 0 0 0,03
medicines other than those mentioned in
18 02 08 0,36 0,41 4,58 4,40 3,35 0,92
18 02 07
TOTAL 18 02 21,62 23,29 29,64 39,66 39,20 38,36

Infectious wastes (18 01 03*, 18 02 02*) must not be landfilled according to EU Regulation
1999/31/EC as well as according to the Regulation on waste landfilling ("Official Gazette of RS
", No. 92/2010)For the treatment of infectious medical wastes, at least 47 permitted facilities
existed in Serbia by the end of the year 2015.
Through the projects funded by the European Union, 2007-2009, (“Technical Assistance for
Healthcare Waste Management46“ and “Technical Assistance for Treatment of Healthcare
Waste47”), in Republic of Serbia some of state-owned hospitals were equipped with autoclaves
for the sterilization of the infectious medical waste 48. However, there is still lack of the capacity
for the management of a pharmaceutical, cytostatic and chemical waste from hospitals in Serbia
and these streams are handed over to private hazardous waste operators.(Jovanović et al,
2016)49) In 2016 about 4 tonnes were exported for disposal by incineration.
The existing health care waste management system in Serbia is focused on the treatment of
infectious waste and consists of a network of Central Treatment Points and Local Treatment
Points. The Central Treatment Points have been established in general hospitals typically in the
main town or city within a District, while Local Treatment Points have been established in the
more remote healthcare institutions as well as in the largest healthcare institutions, including the
four clinical centres, generating large amounts of infectious waste that warrant to have a self-
sufficient system in place. The Central Treatment Points have been provided with vehicles in
order to collect and treat infectious waste from a number of other health care institutions which
do not have their own treatment equipment while Local Treatment Points typically treat, in
addition to their own waste, waste from only a few other health care institutions which deliver
their waste for treatment. (COWI & Euro Health Group 2013)50.
Table 30: Quantities of medical waste treated 2016 in tonnes (Source: SEPA, 2018)
Waste code Waste type 2016

Sharp instruments
18 01 01 166,05
(except 18 01 03)
body parts and organs including blood bags and blood
18 01 02 3,6
preserves (except 18 01 03)
wastes whose collection and disposal is subject to special
18 01 03* 2.292,7
requirements in order to prevent infection
wastes whose collection and disposal is not subject to special
18 01 04 requirements in order to prevent infection (for example 80
dressings, plaster casts, linen, disposable clothing, diapers)
18 01 06* chemicals consisting of or containing hazardous substances 0,15
Total 2.542,5
46
http://etlog-health.de/projects/europe/serbia/54-ser-01-01.html
47
https://ec.europa.eu/neighbourhood-enlargement/sites/near/files/pdf/serbia/ipa/2008/31-
medical_waste_en.pdf
48
Autoclaving is a thermal process at low temperatures where waste is subjected to pressurized saturated steam for a
sufficient length of time to be disinfected. Not only is the waste sterilised by the provision of autoclave technology but
it is thereafter shredded to reduce the risk posed by sharps and other light metal-type wastes.
49
“The influence of healthcare factors on medical waste management in Serbia hospital facilities“, Verica Jovanović,
Dragomir Jovanović, Branislava Matic, Nela Donović, 2016.
50
COWI & EURO HEALTH GROUP (2013): Technical Assistance for the Treatment of Healthcare Waste in Serbia.
National Plan for the Management of Waste Originating from Healthcare Facilities and Pharmaceutical Waste.
Planning Report Contract N°: 08SER01/31/12/001. February 2013.

Table 31: Quantities of medical waste (including veterinary waste) exported 2016 in tonnes
(Source: SEPA, 2018)

Sharp instruments
18 01 01 4,14
(except 18 01 03)
18 01 06* chemicals consisting of or containing hazardous substances 0,42
18 01 08* 4,11
medicines
18 02 07* 0,19
medicines
Total 8,86
Table 32: Quantities of veterinary waste treated in 2016 in tonnes (Source: Waste management
in Republic of Serbia, SEPA 2017)

wastes whose collection and disposal is subject to special
18 02 02* 0,42
requirements in order to prevent infection
medicines other than those mentioned in
18 02 08 4,11
18 02 07*
Total 4,53

 Inappropriate medical waste management is a significant problem due to lack of waste
separation in health institutions. In 2007, Ministry of Health initiated specific activities related
to introduction of uniformed system of medical waste management in Serbia, particularly
with the category of infectious medical waste. Vehicles for medical waste transport have
been procured, and training of medical staff for separation of waste in healthcare institutions
has been conducted. Separation of infectious medical waste from other waste has started in
public and private healthcare institutions and veterinary organizations.
Although a sound and country-wide basis for infectious waste treatment is in place, the
system is not yet fully developed and is functioning with varying levels of success. However,
various operational and financial problems prevent the system for be fully utilized. (COWI &
Euro Health Group 2013). Chemical waste is, more often than not, disposed of into the
sewer while pharmaceutical waste is generally stored in healthcare institutions often for
many years in row. (COWI & Euro Health Group 2013).
 There are not enough economic incentives to move away from disposal.
 There are several issues that need to be pursued in the future, regarding application of the
legal provisions by the generators and operators of medical and veterinary waste,
 No detailed information is available about the number of environmental inspections and
their results. It is difficult to determine the degree of compliance with the legal prevision in
force, related with medical and veterinary waste regime.
2.5.11 Pharmaceutical waste

Article 56 of the LWM defines medical wastes, including pharmaceutical wastes, as special
waste stream and stipulates obligations of the producer of such wastes and lays down the basic
legal requirements regarding management of medical waste. Article 56A stipulates specific
obligations of pharmacies that were founded as healthcare institutions i.e. veterinary
organisations, as well as pharmacies established within private practice.
Pharmacies that have been established as a medical institution or a veterinary organization, as
well as pharmacies established as private practice are obliged to:
 Take over pharmaceutical waste produced by citizens and submit the waste to persons
in charge of the collection, transport, treatment, and storage, recovery and disposal or
export of pharmaceutical waste;
 Keep separate records on their own pharmaceutical waste and submit data to the
Agency
 Provide separate space for the container for free collection of unusable medicines from
the public;
 Sign a contract with a person referred to in point 1) above on the rights, obligations and
responsibilities in the field of pharmaceutical waste from citizens;
 Display a notice that the pharmacy collects unusable medicines from the public, as well
as information that for returning unusable medicines citizens do not pay fee.
According to Article 56b of the LWM, costs related to medical waste management, including
pharmaceutical waste management shall be borne by the producer of waste, except for costs
related to management of pharmaceutical waste collected from citizens. Costs for management
of waste generated from medications for which the Republic of Serbia did not issue permit for
placement on the market, shall be borne by the importer of such medications. Costs related to
management, i.e. export of pharmaceutical waste collected from citizens shall be borne by the
producer and/or importer who places pharmaceutical products on the market of the Republic of
Serbia, in the proportion equivalent to their share in the mass of placed products on the market
of the Republic of Serbia, in compliance with these laws based on the records maintained by the
medicines and medical devices Agency of Serbia.
Pursuant to Article 56а, paragraph 5 of the Law on Waste Management (Official Gazette of RS,
no. 36/09, 88/10 and 14/16), The Minister of environmental protection, Minister of agriculture,
forestry and water management and Minister of health have jointly draft the Rulebook on the
manner and procedures for pharmaceutical waste management. In December 2018 the legal
procedure was completed and the document is expected to be published in the Official Gazette
(not published yet).
The European List of Wastes following codes, which can be used for pharmaceutical wastes:
 18 01 08* cytotoxic and cytostatic medicines;
 18 01 09 medicines other than those mentioned in 18 01 08;
 18 02 08 medicines other than those mentioned in 18 02 07;
 20 01 32 medicines other than those mentioned in 20 01 31.

The Serbian pharmaceutical market is split between domestic production and imports 51 of
pharmaceuticals from foreign multinationals (about 70 foreign companies have representative
offices in the country, with the majority being members of the Association of Foreign
Pharmaceutical Manufacturers in Serbia). Serbia has some of the highest rates in Europe for
cardiovascular disease, cancer, liver disease, and cirrhosis because of poor diets, high smoking
rates, and other unhealthy habits. Pharmaceuticals that address these conditions, as well as
their precursors (e.g., hypertension, high cholesterol, etc.) are in demand. In 2016, the highest
demand was for cardiovascular drugs, followed by antibiotics and medications for the nervous
system52.
According to the Ministry of Health, the number of companies that deal with trade in drugs and
medical devices is 204.
In Serbia there are 35 public healthcare institutions with approximately 950 individual
pharmacies in total (according with Chamber of Commerce and Industry of Serbia, there is no
registry with a precise number of pharmacies). Regarding privately owned pharmacies, the most
valid information is based on the Insurance Policy and certain types of devices signed in 2017
with the Republic Fund for Health Insurance. There are 2.391 private pharmacies.
According to data from the Republic Fund for Health Insurance, the number of the doctors which
prescribing medication was 9.350 (December 2017).
According to World Health Organization (WHO), more than half of all medications is
inappropriately prescribed, prescribed and sold, which causes unnecessary storage and creates
environmental threat53. Therefore, it is usual that, families and patients are in possession of
unused or expired medications and its risks must be in consideration.
According to the National Plan for the Management of Waste Originating from Healthcare
Facilities and Pharmaceutical Waste, the annual generation rate of cytostatic and cytotoxic
waste (18 01 08*) can be estimated to be in the order of 70 to 75 tonnes of which 15 tonnes
vials contaminated with undiluted cytotoxic and cytostatic substances. The remaining 55 to 60
tonnes comprises sharps, plastic tubing and glass and plastic bottles contaminated with diluted
cytotoxic and cytostatic substances (typically a solution of 1% medication in physiologic infusion
liquid). (COWI & EURO HEALTH GROUP 201354)
Other Pharmaceutical Waste (18 01 09 – non-hazardous) is generated in healthcare facilities,
pharmacies as well as in households. The total pharmaceutical waste generation in all public
HCIs and public pharmacies in Serbia has been estimated to be in the order of seven tonnes
51
"Out of all pharmaceuticals sold in Serbia in 2015, 64% are produced in the country, while 38% are imported from other
countries. Top 20 companies in pharmaceutical sector are holding almost 55% of sales volume in Serbia. The biggest share by far is
reserved for Hemofarm Vršac with 14.53% of market in terms of value of drugs sold and more than 30% share in number of boxes.
Other 3 big producers from Serbia (Pharmaswiss, Galenika and Actavis) are also positioned within top 5 companies, totalling close
to €210 million in value of drugs sold in the country." Chemical and Pharmaceutical Industry in Serbia, Development Agency of
Serbia (RAS), 2017.
52
53
54
COWI & EURO HEALTH GROUP (2013): Technical Assistance for the Treatment of Healthcare Waste in
Serbia. National Plan for the Management of Waste Originating from Healthcare Facilities and
Pharmaceutical Waste. Planning Report Contract N°: 08SER01/31/12/001. February 2013.

per year. Waste generation in the private sector is expected to be in the order of one to three
tonnes per year. For pharmaceutical waste generation by households, basic data are lacking
and only an educated guess can be made based on sparse data from trials and data reported
by other European countries. For planning purposes a waste generation rate of 50 tonnes per
year is assumed bringing the total pharmaceutical waste generation rate to an estimated
60 tonnes per year. (COWI & EURO HEALTH GROUP 2013)
Some public pharmacies accept pharmaceutical waste from households but only a few
institutions actively promote the service.
Pharmaceutical waste from households often either accumulates in household or it is disposed
of into the sewer or communal waste containers. Without treatment capacity in place in Serbia
and without arrangements for the funding of collection, transport and export destruction abroad,
the pharmaceutical institutions that do accept pharmaceutical waste from households store the
waste in a variety of places and circumstances. (COWI & Euro Health Group 2013).
The medicines that remained in the laboratory after testing (not cytostatic and narcotics) are
disposed in red bags marked “hazard pharmaceutical waste-ordinary medicines" and they are
recorded on a special form "List of samples for destruction." Biological products are autoclaved
before disposal. When bags are full, samples of medicines are stored in metal barrels capacity
which are labelled with the same label.
The pharmaceutical waste (consists of samples of expired medicines which are stored in the
warehouse of samples and samples of medicines that remained in the laboratory after
conducting tests) is classified into four groups: cytostatic, narcotics, biological products and
other medicines. (Source: Medicines and Medical Devices Agency, 2017).
In 201255, 300 tonnes of accumulated pharmaceutical waste from health-care facilities for
primary, secondary and tertiary care as well as from veterinary institutes and faculties was
removal from Serbia in order to ensure the safe destruction and disposal in accordance with all
applicable EU legislation, Serbian legislation and the legislation of the recipient country.

 Pharmacies should take over pharmaceutical waste produced by citizens, but in
practice only few pharmacies promote the service. Pharmaceutical waste from
households often either accumulates in household or it is disposed of into the sewer or
communal waste containers.
 Public engagement in separate collection is very low.
 The Waste Management Law foresees that the costs related to the management of
pharmaceutical waste collected from citizens shall be borne by the producer and/or
importer who places pharmaceutical products on the market.
2.5.12 Waste generated in Titanium Dioxide production
There is no current production of Titanium Dioxide in Serbia. However a potential production

would be regulated under Article 57 of the LWM. In accordance with these provisions a specific
license from the Minister for Environment or the Competent Authority of the autonomous
province is requested. The manners for the handling of all wastes generated during the
production shall be prescribed by the Minister for Environment.
55
https://webgate.ec.europa.eu/europeaid/online-services/index.cfm?
ADSSChck=1517984530713&do=publi.welcome&searchtype=RS&aofr=131768&orderby=upd&orderbyad=Desc&nbP
ubliList=15&userlanguage=en

The producer, owner and/or other holder of waste has to keep records on quantities of this type
of waste collected, stored, treated or disposed, and shall submit such to SEPA.
Producer, owner and/or other holder of waste titanium dioxide and titanium dioxide waste is
requested to implement measures of supervision over the disposal operations and shall control
soil, waste and air at the location where titanium dioxide waste has been used, kept or disposed
of. Chapter 3 of the BREF Document “Large Volume Inorganic Chemicals - Solids and Others
Industry (2007)”56 is to be applied in the licensing process.
2.6 Types and quantities of waste imported / exported
The Republic of Serbia has ratified the Basel Convention, which is an international treaty aiming
at eliminating the risks arising from the transboundary movements of hazardous and other
wastes. Its provisions are based on the following main principals: 1) The reduction of hazardous
waste generation and the promotion of environmentally sound management of hazardous
wastes, wherever the place of disposal, 2) The restriction of transboundary movements of
hazardous wastes except where it is perceived to be in accordance with the principles of
environmentally sound management and 3) a regulatory system applying to cases where
transboundary movements are permissible.
In the Serbian legislation, the provisions related to the transboundary shipments of waste have
been set in the following laws and by-laws:
 The Law on Confirmation of Basel Convention (“Official Gazette FRY, International
Agreements”, No.2/99) – Articles 71-73);
 The Law on Waste Management “(Official Gazette of the Republic of Serbia”, RS, No.
36/09, 88/10, 14/16)
 The Law on Environmental Protection of Republic of Serbia “Official Gazette of the
Republic of Serbia”, RS, No. 135/04, 36/09, 72/09 (state law), 43/11 (CC), 14/16) –
Article 57;
 Rulebook on the content of documentation submitted in support of the application for
the permit for import, export and transit of waste “(Official Gazette of the Republic of
Serbia”, RS, No. 60/09 and 101/10);
 Regulation on the waste lists for transboundary shipments, on the content and layout of
documentation that accompanies transboundary movement of waste with instructions
for their completion “(Official Gazette of the Republic of Serbia”, RS, No. 60/09);
 Regulation on designating the types of hazardous wastes that may be imported as
secondary raw materials (Official Gazette of RS, No. 60/09);
 Regulations of List of non-hazardous waste which is on exemption of permit obtaining
obligation, with documentation accompanying transboundary movement of waste
“(Official Gazette of the Republic of Serbia”, RS, No. 102/10).
In accordance with the Law on Waste Management, the import of hazardous waste generally
and the import of other waste for the purpose of disposal or energy recovery is forbidden. Non-
hazardous waste may be imported for the purposes of recovery provided that there is a facility
for the treatment of such waste.
By way of exception, certain hazardous wastes which the refining industry in the Republic of
Serbia uses as secondary raw materials, in compliance with the national goals for the treatment
of such wastes, may be imported based on the permit issued by the Ministry. The Government
determines which types of hazardous waste may be imported as secondary raw materials.
56
http://eippcb.jrc.ec.europa.eu/reference/BREF/lvic-s_bref_0907.pdf

Non-hazardous waste may be imported for the purposes of treatment provided that there is a
facility for the treatment of such waste. Waste that cannot be treated or disposed of in
environmentally friendly and efficient manner due to lack of technical options and facilities in the
Republic of Serbia shall be exported.
According to the statistics of SEPA, 307.400 tonnes of wastes were exported from Serbia in
2016, out of which16.700 tonnes were hazardous wastes. Table 33 shows that the annual
quantity of waste exported from Serbia has decreased approximately 55% between 2012 and
2016.
Table 33: Exports of waste from Serbia in 2012-2016 (Source: SEPA).

2012 2013 2014 2015 2016
(t) (t) (t) (t) (t)
Hazardous waste 6.500 10.700 25.000 23.900 16.700
Non-hazardous waste 668.500 406.200 477.800 281.200 290.700
Total 674.900 416.800 502.800 305.000 307.400
Metal wastes made up the most important fraction of exported wastes in 2016. In addition,
significant quantities of paper and cardboard waste as well as glass waste were exported in
2016. Table 34 presents the quantities of the most important waste types exported from Serbia
in 2016.
Table 34: Wastes exported from Serbia in 2016. The most important waste types in terms of
quantity (Source: SEPA 2017).
Waste Waste Quantity (t)
code
19 12 02 Ferrous metal 56.800
15 01 01 Paper and cardboard packaging 56.500
19 10 01 Iron and steel waste 46.000
17 04 05 Iron and steel 42.200
20 01 01 Paper and cardboard 23.500
15 01 07 Glass packaging 14.100
12 01 01 Ferrous metal filings and turnings 6.900
10 03 16 Skimming other than those mentioned in 10 03 15 6.700
Other wastes (including mixtures of materials) from
19 12 11* mechanical treatment of waste containing dangerous 6.600
substances
15 01 02 Plastic packaging 6.100
16 06 01* Lead batteries 5.200
TOTAL 307.400
According to the statistics of SEPA, 221.000 tonnes of wastes were imported to Serbia in 2016.
Only 163 tonnes of this quantity was hazardous wastes. These hazardous wastes were lead-
acid batteries imported form Montenegro to recycling in battery industry. Table 35 shows the
annual quantities of waste imported to Serbia between 2012 and 2016.
Table 35: Imports of waste to Serbia in 2012-2016 (Source: SEPA).

2012 2013 2014 2015 2016

(t) (t) (t) (t) (t)
Hazardous waste 3.700 300 / / 200
Non-hazardous waste 218.800 221.500 243.100 216.900 220.900
Total 222.500 221.800 243.100 216.900 221.100
More than the half of the imported wastes in 2016 were paper and cardboard wastes. In
addition, relevant quantities of saw dust, metal wastes and plastic wastes were imported to
Serbia in 2016 presents the quantities of the most important waste types imported to Serbia in
2016.
Table 36: Wastes imported to Serbia in 2016. The most important waste types in terms of
quantity (Source: SEPA 2017).
Waste Waste Quantity (t)
code
15 01 01 Paper and cardboard packaging 93.900
Sawdust, shavings, cuttings, wood, particle board
03 01 05 47.400
and veneer other than those mentioned in 03 01 04
19 12 03 Non-ferrous metal 13.100
17 04 05 Iron and steel 12.000
19 12 02 Ferrous metal 9.100
15 01 02 Plastic packaging 8.700
12 01 01 Ferrous metal filings and turnings 2.800
17 04 02 Aluminium 2.400
10 02 10 Mill scales 1.700
15 01 07 Glass packaging 1.400
19 08 99* Wastes not otherwise specified 1.300
TOTAL 221.100
compares the exported quantities of certain recyclables with the imported quantities of these
fractions. The table shows, that a remarkable quantity of wood waste was imported to Serbia in
2016, while wood wastes were not exported from Serbia. The exported quantities of metal
wastes and glass wastes clearly exceeded the imported quantities of these fractions. However,
the imported quantity of metal wastes is remarkable. For plastic wastes and paper/cardboard
wastes the exported quantities are very similar to the imported quantities. These figures lead to
the interpretation that remarkable quantities of recyclables are imported to Serbia, although at
the same time recyclables generated in Serbia would be available. Thus, the supply and
demand of the recyclables do not seem to always match.
Table 37: Exports and imports of certain recyclables in 2016 (Source: SEPA)
Type of waste Export (t) Import (t)

Metal wastes 164.600 40.400
Plastic wastes 9.300 9.300
Glass wastes 14.100 1.400
Wood waste 0 49.400
Paper and cardboard wastes 84.700 83.800
Textile wastes 600 500

Total 0 0
Main issues related to the import and export of wastes:

Large quantities of recyclables, for which Serbia has processing capacities are being exported.
Thus, the supply and demand of the recyclables do not seem to always match.
2.7 Summary of the assessment of current waste management status
According to the data reported to SEPA, in total 9.2 million tonnes of waste were generated
in Serbia in 2016, out of which 74.000 tonnes were hazardous waste. The Statistics of SORS,
which also include waste form mining and quarrying not covered by the Waste Framework
Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC), show for the reference
year 2016 a total waste generation of 47.2 million tonnes, out of which 17.2 tonnes were
hazardous.
The generated quantities reported to SEPA include 6.7 million tonnes of industrial waste
(Chapter 02 – 14 of the List of Waste). With a generated quantity of 6.5 million tonnes, wastes
from thermal processes comprise the lion share of the generated industrial waste. About
550.000 tonnes of the industrial wastes were treated in recycling operations, 330.000 tonnes
were landfilled, 20.000 were used for energy recovery and 20.000 t exported. Large quantities
of industrial wastes, particularly ash from the incineration of coal are being temporary stored.
The energy sector is currently exploring possibilities to recycle ash in the construction sector.
In 2016, 1.89 million tonnes of municipal waste were generated in Serbia. This corresponds
to an average annual quantity of 270 kg/inhabitant, while the EU average in 2016 was 483
kg/inhabitant. It is estimated that the municipal waste collection currently covers approximately
82 % of the Serbian population. Public utility companies (PUCs) collected and deposited 1.49
tonnes of municipal waste in 2016. Most of the municipal waste is landfilled without pre-
treatment. Approximately 550,000 tonnes of municipal waste were landfilled on compliant
sanitary landfills. The total quantity of recyclables separately collected by PUCs amounted only
to about 5.000 t in 2016. In addition, private companies collected some packaging waste types
on behalf of local authorities. Relevant quantities of recyclables are also collected by the
informal sector. In total about 46.000 t municipal packaging waste were separately collected via
collective schemes.
According to the statistics of SORS, the total waste generation in construction sector
amounted in 2016 to about 547.000 tonnes out of which about 53 % were uncontaminated soils
and about 44 % mineral wastes from construction and demolition. The generated quantities
reported to SEPA include only 108.000 tonnes of construction and demolition waste (Chapter 17
of the List of Waste) for the reference year 2016, out of which almost the half (47%) was metal
waste. Apart from metal wastes, construction and demolition wastes are not recycled in Serbia.
For the time being, construction and demolition wastes are either disposed of in landfills or used
as inert material to cover landfills.
Under the Serbian waste legislation packaging waste, ELV, waste mineral oil, waste tires,
WEEE, waste mercury-containing fluorescent tubes, used batteries and accumulators, PCB and
other POPs waste, medical and pharmaceutical waste as well as waste from titanium dioxide
industry are considered as special waste streams. These special waste streams are partly
postconsumer wastes for which the principle of extended producer responsibility is applicable,
partly they are generated mainly during industrial and professional activities so that the polluter
pays principle shall prevail. Some of the waste streams are generated in both areas and
therefor there is a split responsibility.

According to the annual reports of SEPA, on average 350.000 tonnes of packaging were
annually placed on the market in Serbia in recent years. The structure of the packaging
material was on average 20% glass, 27% plastic, 31% paper and cardboard, 4% metal, 18%
wood and 1% other. It can be assumed that all packaging placed on the market in a given year
becomes waste in the same year. It is estimated that household flows make up about 40 % of
the packaging waste flows, while the share of commercial and industrial flows is estimated to be
60%. The collection of packaging waste has in Serbia been focused on packaging waste from
industrial and commercial flows.
In 2016, collective schemes reported 110.000 tonnes of industrial and commercial packaging
while the quantity of separately collected municipal packaging waste amounted to 46.000 t. The
biggest part of packaging waste from households is included in the mixed municipal waste.
According to estimations, the total quantity of packaging waste within municipal flow is about
240.000 tonnes dry fraction. According to the data reported to SEPA; approximately 147.000
tonnes of packaging waste were recycled in 2016.
In recent years, on average 120.000 tonnes of vehicles were annually put on the market in
Serbia. It is estimated, that approximately 40.000 t of end-of-life vehicles are annually
generated in Serbia. The reported quantity of generated ELV, including wastes from
dismantling and from vehicle maintenance, amounted to 22.000 tonnes. Only 3.400 tonnes were
reported as treated in recovery operations. Reasons for the discrepancies may include lack of
compliance with reporting obligations, informal recycling activities and also informal exports by
private persons.
According to the annual reports of SEPA, on average 37.000 tonnes of mineral oils were
annually placed on the market in Serbia in recent years. According to estimations, the annual
quantity put on the market could in reality amount up to 50.000 tonnes. The reported quantity of
oil wastes and wastes of liquid fuels generated was about 10.200 t. However, it is estimated that
the generation potential of waste oils accounts for 25.000 to 37.000 t per year. According to the
data reported to SEPA, 1.900 tonnes of waste oil were used for energy recovery and 1.800 t
were refined. It is assumed that relevant quantities of waste oils are collected within the informal
sector.
Car tires are produced in Serbia with a high share of exports. According to the data reported to
SEPA, about 38.000 tonnes (36.000 t and 49.000 pieces) of different types of tires were put on
the Serbian market 2016. In total 42.000 tonnes of waste tires were reported to have been
treated in Serbia, out of which about 13.000 t were used for energy recovery in cement plants,
while about 27.000 t treated in recycling operations (R5). The treated quantities include about
10.000 tonnes of waste tires from the dismantling of end-of-life vehicles.
Estimations of EEE put on the market, which have been made based inter alia on interviews
with relevant stakeholders and on data of other countries, show that approximately 60.000 t
EEE have been put on the market in Serbia in recent years. According to the data of SEPA
about 37.000 t of WEEE were treated in Serbia in 2016. Fluorescent tubes and other mercury
containing wastes made up about 300 t of the treated quantity. Data analyses have however
shown, that the treated quantity cannot be regarded as the quantity generated / collected in
Serbia. It has been estimated, that the collected quantity of WEEE currently amounts to
about 1 kg / inhabitant/year which equals to 7.000 t annually, actually coming from
businesses. Collection of WEEE from households has not been established yet.
Serbia has ratified the Stockholm Convention on Persistent Organic Pollutants and has
developed a National Implementation Plan in order to meet the requirements of the Convention
regarding the systematic elimination of a particular substances (included in Annex A) and
restrictions on their production and use (included in Annex B). The decontamination of PCB-
fluids in transformers is progressing well.

According to the data reported to SEPA, approximately 2.800 tonnes of medical and
pharmaceutical waste were generated in 2016, the biggest part of it being “waste whose
collection and disposal are subject to special measure to prevent infections (List of Waste code
18 01 03*). However, for planning purposes a generated quantity of 5.000 tonnes per year has
been assumed.
It is estimated that in total approximately 15.000 tonnes of batteries and accumulators are
annually placed on the market in Serbia. This quantity includes automotive batteries,
industrial batteries as well as portable batteries and accumulators. Comprehensive data on
generation and collection of batteries and accumulators is not available. Automotive batteries
are effectively collected due to their economic value. The data reported to SEPA indicates that
9,400 tonnes of batteries and accumulators were recycled in Serbia in 2016, while 5.200 t were
exported.
Currently, the sewage collection system is still developing in Serbia. About 11.000 tonnes dry
matter of sewage sludge are annually generated. This sludge are disposed of at landfills.
The statistics of SORS indicate, that the mining and quarrying sector generated in 2016 in
total 38.8 Million tonnes of waste, making up the lion share of the total waste generation
recorded in the waste statistics of SORS. About 44% of these mining wastes were hazardous.
Mining waste were mostly disposed of at landfills not covered by waste legislation.
The agriculture sector contributes for about 10% of the GDP in Serbia and generates substantial
quantities of animal by-products and vegetal residues. However, a large part of these
streams is directly reused in the agricultural sector and is therefore not regarded as waste. The
statistics of SORS include about 78.000 tonnes of manure and about 13.000 tonnes of vegetal
wastes. In addition, it is estimated that slaughterhouses generated approximately 196.000
tonnes of animal by-products in 2016.
The quantities of secondary wastes, which are generated in the course of waste treatment
operations, depend strongly on the level of the waste treatment infrastructure. For the time
being, the quantities of secondary waste in Serbia remain quite moderate. The data reported to
SEPA indicate that between 264.000 and 273.000 tonnes of secondary wastes were
generated in Serbia in 2016.
According to the statistics of SEPA, approximately 307.000 tonnes of wastes were exported
from Serbia in 2016, out of which approximately 17.000 tonnes were hazardous waste. Metal
wastes were the most imported fraction exported, followed by paper and cardboard wastes. The
quantity imported to Serbia in 2016 accounted to 221.000 tonnes. Only a small amount
(163 t) of hazardous waste, namely lead-acid batteries, were imported. More than the half of the
imported wastes in 2016 were paper and cardboard wastes.

3 NATIONAL WASTE MANAGEMENT GOALS
The overall goal is to develop a sustainable waste management system in order to reduce
environmental pollution and spatial degradation. In order to achieve this overall goal, the legal
framework shall be fully harmonized with EU legislation, the institutional set-up needs to be
further improved, key principles of waste management must be implemented and a network of
waste management installations needs to be established and operated. Waste management
must be geared towards defined waste management objectives which are laid down in the
strategy. Financial measures need be implemented to direct waste streams to the appropriate
treatment options.
3.1 Key principles in waste management
The key principles that must be taken in consideration when establishing and implementing the
waste management plan are as follows:
 The sustainable development principle;
 The precautionary principle;
 The principle of selection of the most favourable option for the environment;
 The principle of self-sufficiency;
 Principle of vicinity and regional approach in waste management;
 The principle of waste management hierarchy;
 The principle of extended producer responsibility;
 The “polluter pays” principle.
These principles shall in general guide the waste management in Serbia (see section 12.4):
Sustainable development principle
The principle of sustainable development postulates the fulfilment of needs of today’s
generation without threatening the opportunity of future generations to meet their needs.
Sustainable development seeks to achieve, in a balanced manner, economic development, social
development and environmental protection, ensuring
 the reduction of poverty;

 fair distribution of wealth;
 improvement of quality of life and;
 reducing the level of pollution to the level of capacities of the environment;
 prevention of future pollution and;
 biodiversity conservation.
Thus sustainable waste management means to implement all necessary measures for the most
efficient use of resources, reduction of quantity of generated waste, and once the waste has
been generated, handling thereof in such a manner to contribute to the objectives of a
sustainable development including re-introducing resources by recycling.
Precautionary principle
The precautionary principle means that “in case there is a possibility of a serious and
irreversible damage, absence of full scientific reliability may not be the reason for not taking
measures for preventing the degradation of environment”. Each activity must be planned and
implemented in such a manner so as to cause the least possible change of the environment. In

case of potential and significant impacts on environment, preventive activities should be taken,
while application of environmental impact assessment instruments should be particularly
supported.
Principle of selection of the most favourable option for the environment
The selection of the most favourable option for the environment is a systematic approach. The
assessment of the environmental impact of the different options allows to determine the option,
or the combination of options, which comprises the highest benefit and/or the least harm for the
environment as a whole, with acceptable costs and profitability, both in long and short term. In
case of a conflict between the principle of vicinity and the application of the waste hierarchy with
the principle of selection of the most favourable option for the environment, the later one may
precede.
The principle of self-sufficiency

The application of the self-sufficiency principle means the establishment of an integrated and
suitable network of plants for the recovery and disposal of mixed municipal household waste
including the collection of this type of waste produced by other waste producers, taking into
account the best available techniques.
The network shall be designed to enable the Republic of Serbia to become self-sufficient in
waste disposal and in waste recovery, taking into account geographical characteristics of the
region and a need for separate plants for specific types of waste.
This network should enable disposal or recovery of waste in one of the nearest appropriate
plants, with the application of the most appropriate methods and technologies in order to ensure
a high level of environment and public health protection.
Principle of vicinity and regional approach in waste management

Waste shall be treated or disposed of as near as possible to its place of origin, i.e. in the region
where it has been generated, in order to avoid unwanted environmental impacts of its
transportation. The selection of a location for a plant for waste treatment and/or recovery and/or
disposal shall depend on local conditions and circumstances, type of waste, its volume, manner
of transportation and disposal, economic viability, as well as the possible environmental impact.
Regional waste management shall be ensured through the development and application of
regional strategic plans in line with the overall national strategy, based on the European
legislation and national policy.
The hierarchy of measures in waste management

The hierarchy in waste management means the following order of priorities in the waste
management practice:
 Prevention: Measures taken before a substance, material or product has become
waste, that reduce: the quantity of waste, including through the re-use of products or the
extension of the life span of products; the adverse impacts of the generated waste on
the environment and human health; the content of harmful substances in materials and;
 Preparing for Re-use: Operations related to re-use of waste which include cleaning
(e.g. used clothes), functional testing (e.g. of electrical and electronic devices or
components thereof), or repair and refurbishment of discarded equipment, by which
products or components of products that have become waste are prepared so that they
can be re-used without any other pre-processing;

 Recycling: reprocessing of waste materials into products, materials or substances

whether for the original or other purposes (“bottle to bottle”, “metal to metal”,
composting)
 Other Recovery: Utilisation of waste values for other useful purposes by replacing
other materials which would otherwise have been used to fulfil a particular function, or
waste being prepared to fulfil that function, in the plant or in the wider economy (e.g.
backfilling, recultivation, energy recovery, other energetic or chemical utilisation);
 Disposal: Any operation which is not recovery of waste, even when substances are
reclaimed or when energy is produced as a secondary effect of such an operation (e.g.
incineration without energy recovery, landfilling).
However the waste hierarchy is not an absolute principle. Measures are to be implemented to
achieve solutions which will generate best possible overall result for the environment. General
environmental principles must also be taken into account, such as precautionary and
sustainability principle, technical feasibility and economic viability, protection of resources, as
well as general impact on environment, human health, economy and social aspect. In specific
cases it may be necessary do depart from the strict hierarchy in order to comply with the other
key principles. E.g. for POPs wastes (POP content above the “low level” as defined in the
guidelines of the Stockholm Convention or pertinent legislation), other treatment which destroys
or transforms the POPs content (e.g. incineration) takes precedence over recycling.
Extended producer responsibility

The scheme of extended producer responsibility is a strategy to internalize the environmental
cost of production and consumption of a specific product. The producer of products bears
responsibility for the impact of the produced goods over the whole live cycle including the
disposal ("from cradle to grave”). The producer bears the greatest responsibility because he
influences the composition and the characteristics of a product and its packaging material. The
producer shall take care of minimising waste generation, development of recyclable products
and development of markets for re-use and recycling of their products. The producers or, failing
that, the importers and sellers may fulfil their obligations either individually or collectively
(inclusion into a collective scheme) depending on specific implementing legislation.
“Polluter pays” principle

To ensure also financially sustainable activity in waste management the “polluter pays” principle
shall be applied. The polluters must bear full costs of the consequences of their activities. Thus
the costs of collection, treatment and disposal of waste must be included in the price of a
product. The principle of full costs recovery for the services of collection and disposing of waste
should be applied, as well as the introduction of financial stimulation instruments for re-use and
recycling of waste.
3.2 Legal framework in harmonization with EU legislation
Pertinent gaps between Serbian legislation and the EU acquis are listed in Chapter 2.2.4 of the
strategy. However the ongoing development of the Circular Economy in the Union may require
additional measures in the process of approximation to the EU acquis.
The LWM as the basic legal framework for waste management in Serbia is also the main
instrument for the harmonization with the EU acquis in the field of waste management. In order
to streamline already implemented provisions and implement new provisions of the Waste
Framework Directive 98/2008/EC (WFD) the LWM was amended in 2016 (“Official Gazette of
the Republic of Serbia”, 14/2016).

These amendments concern especially:

 The scope (Article 2 of the WFD/Article 4 of the LWM);
 Definitions (Article 2 of the LWM);
 The waste hierarchy as key principle of waste management (Article 4 of the WFD/Article
6 of the LWM);
 The definition of by-products (Article 5 of the WFD/Articles 8a and 8b of the LWM)
 The definition of an End-of-waste status (Article 6 of the WFFD/Articles 8v and 8g of the
LWM);
 The implementation of waste prevention programs (Article 29 of the WFD/Article 11a of
the LWM);
 The separate collection and treatment of bio-waste (Article 22 of the WFD/Article 35 of
the LWM).
New by-law will be necessary to make several of these new provisions (e.g. end-of waste
status, by-product status) operative.
Furthermore several relevant new provisions of the WFD have not been transposed into Serbian
legislation yet. This concerns especially the amendments of Annex 3 of Directive 2008/98/EG
(Regulation (EU) 1357/2014 and Regulation (EU) 997/2017)) that are essential for the correct
classification of wastes as hazardous or non-hazardous waste.
Thus further implementation steps will be necessary to reach the goal of full approximation of
Serbian legislation with the EU acquis.
This requires especially:
 the amendment of existing by-laws (e.g. the Rulebook on categories, testing and
classification of waste (“Official Gazette of the Republic of Serbia“, No. 56/10);
 the development of new by-laws for treatment and recovery of specific waste streams
(e.g. mineral C&D wastes; biodegradable wastes; etc.);
 the development of new by-laws to make specific provisions of the LWM operative (e.g.
by-laws on the End-of-waste status and on by-products).
To fully comply with the relevant provisions of the Packaging Waste Directive an amendment of
the Law on Packaging and Packaging Waste Management (“Official Gazette of the Republic
of Serbia“, No. 36/09) and the subsequent by-laws.
Furthermore to meet recycling and reduction targets set out in Chapter 3.3 it is inevitable to
strengthen the extended producer responsibility, inter alia by obliging producers to set up
collective collection schemes for specific wastes, as well as the polluter pays principle obliging
waste generators to fully bear the internal cost of waste management even in the long time
range. This will include financial incentives on recycling as well as additional fees for disposal,
namely dumping.
Additional law has to be developed to guide the remediation of contaminated sites. This
legislation should be based in general on the “polluter pays” principle but also provide a
mechanism for cases where the polluter cannot be identify or is no longer existing or not
capable to comply with his obligations. Such a legal framework has to include financing
mechanism. Such a mechanism shall also set incentives for choosing disposal measures which
have the least negative impact on the environment. E.g. a landfill tax can use not only the
amount and quality of the waste landfilled but also the quality of the landfill site as tax base.
Furthermore to avoid market distortions any mechanism should be robust against free raiders
which mean the tax base has to be transparent and easily accountable.

3.3 Improvement of institutional set-up
To meet the recycling targets as well as reduction targets (e.g. of the share of biodegradable
wastes sent to landfill) a strengthening of the institutional set-up for waste collection is a
necessary pre-requisite. Therefore the following steps for the improvement of the institutional
set-up seem to be necessary:
 Strengthening of the Local Self Government Units, municipalities and cities in order to
achieve full implementation of the local waste management services;
 Develop and implement a Programme of training and technical assistance to
municipalities;
 Review of the effectiveness of existing waste management regions and establishment
of waste management regions in the area where it doesn’t exist including the
establishment of responsible institutions (legal entities);
 Establishment of regional waste management companies providing separate collection
of recyclables. Oblige the private sector to establish collective schemes for specific
waste streams (as to be stipulated in amended legislation – see Chapter 3.2.1);
 Strengthening of the “Green Fund” as a complementary instrument to the EPR
schemes.
 Strengthening of environmental inspections to gain full compliance of stakeholders with
their legal obligation.
3.4 Establishment of a network of waste management facilities
Environmentally sound waste management always needs a comprehensive approach and a

chain of consecutive steps of collection – transport – treatment – use of recovered material and
save disposal of unrecoverable residues. Thus, a suitable collection system for specific waste
streams (municipal waste, packaging wastes, WEEEs, etc.) with collection points, transfer
stations and storages is a relevant part of a network of waste management facilities.
Furthermore specific waste streams require specific treatment and consecutive disposal
options. To comply with the key principles of sustainable waste management an integrated
network of waste management facilities (including collection systems) covering all the
undertakings in a chain of treatment steps is necessary. In assessing these needs export or
even import of specific wastes, if a treatment cannot be provided in line with the economic scale
necessary, is also an option to be taken into account. Different waste streams however require
different solutions.
The integrated network of treatment installations should be in operation until 2024 obligatory for
the waste management regions of Subotica; Vranje; Kruševac; Užice; Pančevo; Pirot; Sremska
Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin; Valjevo; Belgrade and voluntary of all
other waste management regions and shall cover:
 Source separation at household level should be organised via bin/bag-system (including
vehicles) at least for following waste streams:
o recyclables including specific special waste streams such as packaging waste
(metals, plastics, glass, paper and cardboard, wood);
o bio-degradable waste; (food and
garden green waste);
o non-hazardous residual mixed municipal solid waste.
 Public amenity sites to be established at municipality level (covering waste streams
such as bulky waste, green park waste (e.g. from cuttings in gardens), packaging
waste (including waste from special waste streams such as metals, glass plastics,

paper and cardboard, wood), hazardous waste from households (including waste from
special waste streams such as WEEE, used batteries and accumulators, waste oil,
medical and pharmaceutical waste), asbestos containing waste (small scale storage
possibility);
 Home-composting in rural areas at household level (covering waste streams such as
biodegradable-waste including green waste);
 Composting facilities at municipal level (covering waste streams such as biodegradable-
waste including green waste);
 Transfer stations / storage areas for interim storage at regional level (covering waste
streams such as C&D waste, hazardous waste, municipal waste);
 Secondary separation and mechanical sorting of recyclables (at least eight facilities in
the dedicated regions);
 Mechanical-biological treatment of mixed municipal solid waste (at least one facility in
the indicated regions);
 Mobile treatment facilities for mineral construction and demolition waste at regional
level;
 Incinerator dedicated for thermal waste treatment of municipal waste (at least one
facility in Serbia);
 Incinerator dedicated for organic industrial and medical waste (at least one facility in
Serbia);
 Physical-chemical treatment for hazardous waste (at least one facility in Central
Serbia).
 Regional sanitary landfills for residues and pre-treated municipal waste at regional level
(also covering selected hazardous waste such as asbestos containing waste);
3.5 Waste management objectives
Environmentally safe landfilling is an indispensable part of an integrated environmentally sound

waste management system. The quality of the waste landfilled is part of the long term safety
concept of the landfill. Biological reactions in the body of the landfill may lead to an acidic
leachate, with the potential to mobilize inorganic pollutants, and gaseous emissions. Thus the
amount of biodegradable waste going to landfills has to be restricted. The implementation plan
for this reduction is set out in chapter 7 of this document.
The reduction of biodegradable waste going to landfills (or dump sites) is a complex issue
requesting improvement of collection (full coverage of public collection service), introduction of
source separation for recyclable biodegradable wastes (above all bio-waste and paper), specific
treatment of bio-waste (e.g. composting) and adequate treatment of collected municipal waste
(MBT treatment, incineration). The timeframe for e.g. planning and construction of an
incineration plant exceeds several years. Thus, the reduction plan covers both short-term and
long-term objectives.
Beside the reduction of biodegradable waste specific targets for the recycling and the recovery
of specific waste streams have to be met. This concern:
 recycling and recovery targets for municipal waste;
 recycling and recovery targets for packaging waste;
 collection recycling and recovery targets for WEEEs;
 collection and recycling targets for batteries and accumulators;
 recycling and recovery targets for ELVs;
 recycling targets for C&D waste (excluding excavated soil).

Dump sites and contaminated sites pose a permanent danger to human health and the
environment. The stepwise rehabilitation is a short term as well as long term objective. A first
step is the identification and prioritization of such sites is a short term objective while
safeguarding or rehabilitation of identified sites will be a short term as well as a long term
objective.
The following objectives are set in order to establish an environmentally sound waste
management system. They can be achieved considering the described measures in this
strategy:
3.5.1 Short term objectives
As short term objectives the relevant targets for separate collection, recycling and reduction for
2025 as described in the DSIPs should be reached. These objectives are
 Collecting WEEE from citizens through retail network in “one to one basis”, free of
charge by 2022;
 Collecting portable batteries through retail network, educational and public buildings by
2025;
 Increase the recycling rate of wastes from households to overall 30% by weight by
2025;
 Increase the level of diversion as percentage of totally generated paper and cardboard
in Serbia should to 25%;
 increase the level of diversion as percentage of totally generated bio-waste in Serbia
should to 20%;
 Reduce biodegradable waste going to landfills to 75% of the total amount of
biodegradable waste generated in 2008 (maximum amount to be landfilled);
 Increase the recycling rate of C&D waste to 40 % by weight by 2029;
 By 2024, increase the separate collection of WEEE to 20% of EEE placed on the
market in the three years preceding 2024;
To create the premises for targets achievement the Government and Parliament should
complete the transposition of the EU Directives into law.
3.5.2 Long term objectives
Although the full compliance with the relevant targets for separate collection, recycling and
reduction will be reached far beyond the timeframe of the WMS the following long-term
objectives can be defined:
 by end of 2030, increase the recycling rate of wastes from households will be
increased to overall 40 % by weight; respectively 50% by end of 2035;
 by end of 2034, increase the recycling rate of C&D waste to 70 % by weight;
 by end of 2029, increase the level of diversion as percentage of totally generated paper
and cardboard in Serbia to 35%; respectively 50% by end of 2034;
 by end of 2029, increase the level of diversion as percentage of totally generated bio-
waste in Serbia should to 40%; respectively 60% by end of 2034;
 by end of 2029, reduce the biodegradable waste going to landfills to 50% of the total
amount of biodegradable waste generated in 2008 (maximum amount to be landfilled);
respectively 35% by end of 2034;
 by 2027, increase the separate collection of WEEE to 27% of EEE placed on the market
in the three years preceding 2027; respectively by 2031 increase the separate collection
of WEEE to 45% of EEE placed on the market in the three preceding years;

 by 2028 comply with the collection and recycling targets of Directive 94/62/EC;
 by 2035 comply with the collection and recycling targets of Directive (EU) 2018/852.
3.5.3 Targets for recycling and reduction
The targets for reduction and recycling in accordance with the directive specific implementation
plan (DSIP) for the WFD 2008/98/EC, the PWD 94/62/EC and the WEEED 2012/19/EC are
listed in Table. In the DSIP for packaging waste it is assumed, that Serbia will reach the targets
in accordance with Directive 94/62/EC by 2028. Thus the new targets introduced by Directive
(EU) 2018/852 for 2025 should be reached at least by 2035(applying the implementation period
of seven years as provided by the directive in general).
Table 38: Recycling and reduction targets to be implemented from 2024 to 2035
Target 2024 2025 2027 2028 2029 2030 2031 2034 2035
Recycling of household waste 30% 40% 50%
Recycling of paper and cardboard 25% 35% 50%
Recycling of bio-waste 20% 40% 60%
Recycling of C&D waste 40% 70%
Collection rate of WEEE 20% 27% 45%
Reduction of biodegradable waste on by by by
landfill (reference year 2008) 25% 50% 65%
Coverage of separate collection of
50% 55% 85% 100%
packaging waste
Recycling/recovery of packaging waste 59% 65%
Glass 43% 49% 66% 77% 70%
Plastic 24% 27% 31% 36% 55%
Paper 55% 54% 63% 72% 75%
Metal 46% 52% 68% 78% 70/50%*
Wood 50% 50% 50% 50% 30%
* 70% for iron, 50% for aluminium

THE NATIONAL WASTE MANAGEMENT PLAN
In accordance with Article 10 of the LWM the national waste management plan as part of the
national waste management strategy shall provide the necessary information for the planning of
the waste management in Serbia. This includes a description of the expected types, qualities
and origin of specific waste streams, the assessment of existing waste collection systems and
network of treatment facilities as well as the need of additional waste management
infrastructure to comply with the waste management goals set out in the national waste
management strategy. Thus the plan shall provide guidelines for site identification and
necessary capacities of waste treatment installations.
The plan shall include an implementation plan for the reduction of biodegradable waste
landfilled including defined reduction goals and guidelines for the best use of this waste as a
resource.
Furthermore the plan shall address the organization of waste management and the respective
responsibilities of the public and the private sector. It shall include possible mechanism of
funding and providing financial incentives for the development of the Serbian waste
management system.
Although the plan is not an enforceable legal instrument it shall contain measures and
guidelines as well as deadlines for the implementation.

4 EXPECTED TYPES, QUANTITIES, AND ORIGIN OF WASTE,

INCLUDING ESTIMATIONS RELATED TO GENERATION OF
SPECIFIC WASTE STREAMS
4.1 Expected generation of relevant waste streams
Municipal waste is a complex waste stream (see Figure 3). The amount of municipal waste
generated in the future therefore will depend very much on the efficiency of separate collection
of recyclables. Also the statistics on the amount of municipal waste generated may change in
the future, depending on future waste control measures and a more coherent measurement of
waste by weighing them after they are delivered to waste treatment facilities (Landfill, MBT,
etc.).
There are several key factors behind the fact that the information gathered at national level on
generated municipal waste quantities and composition can be not accurate and which must be
taken into account when assessing the estimated waste streams in the future:
 Not all municipalities or PUC equally assess the amount and composition of municipal
waste;
 Majority of municipalities (especially smaller) doesn’t have practice to identify and
analyse the characteristics of the waste they generate;
 A relevant part of municipal waste is dumped into uncontrolled landfills outside control
of the public utility companies;
 Waste collection service is not available to a large part of the population of the Serbia.
Having considered the above-mentioned reason, the actual amount of municipal waste from
official statistics may vary by about 20-30 %.
In 2014, an assessment on municipal waste quantities and composition was carried out, taking
into account the data available at that time and evaluating parameters such as the average net
income in the municipality, number of total population, the share of urban population (%). This
assessment also looked into the potential flow and composition of the future. Since the data
based on measurement and composition analysis did not existed for the whole country,
extrapolation of existing data to whole country has been done.
Table 39: Projected amount of generated municipal waste for Serbia from 2014 to 2030 57
Generated waste amount

Year
kg/cap/day kg/cap/year t/year
2014 0,93 340,7 2.448.566
2015 0,94 343,5 2.468.363
2016 0,95 347,6 2.498.382
2017 0,96 352,1 2.530.283
2018 0,98 357 2.566.067
2019 0,99 362,3 2.603.892
2020 1,01 367,9 2.644.308
57
Municipal Solid Waste Information Republic of Serbia 2014 Bojan Batinić

Generated waste amount

Year
kg/cap/day kg/cap/year t/year
2021 1,02 373,2 2.682.116
2022 1,04 378,7 2.721.803
2023 1,05 384,5 2.763.469
2024 1,07 390,6 2.807.218
2025 1,09 397 2.853.162
2026 1,11 403,7 2.901.416
2027 1,13 410,8 2.952.104
2028 1,15 418,2 3.005.355
2029 1,17 426 3.061.308
2030 1,19 434,1 3.120.105
In EU countries for 2016, municipal waste generation totals vary considerably, ranging from 777
kg per capita in Denmark to 261 kg per capita in Romania. The variations reflect differences in
consumption patterns and economic wealth, but also depend on how municipal waste is
collected and managed.
Regarding projected values for the composition of municipal waste, it was assumed that the
only faction (in terms of the mass share) which will be reduced in the future is the biodegradable
(garden and food) fraction, while for all other waste categories model predicted certain increase.
Biodegradable fraction which includes garden and food waste are projected to be reduced by
21.9%, and with a share of 48.8% in 2014, decline to 40.0% in 2030. This assumptions can be
made taking into account the expected biodegradable waste management activities as
individual composting containers for individual holdings, as well as green waste composting
sites where green waste can be taken from residents, city parks and etc. The amount of
biodegradable waste reduced by individual composting containers will not be accounted for as
municipal waste.
Composition
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
Other (textiles, diapers, leather, fine fraction and other) Glass Metal Plastic Paper & Cardoard
0
Bodegradable (garden and food)
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Figure 6: Predicted composition of generated MSW in Serbia for 2014 - 2030 (kg/cap/year)
Calculation for expected quantities of biodegradable municipal waste in Serbia is based on
results from measurements and waste composition analysis performed in Serbian

municipalities. 58 Following sources of biodegradable municipal waste are taken into account:
garden and food waste (100%), paper and cardboard (90%) and other (35%) consisted of
biodegradable categories such are textiles, wood, leather, fine fraction etc. It also includes
amount of biodegradable waste that comes from the parks and public areas (assumed average
value of 3% for all Serbian municipalities). Amount of biodegradable waste planned for Republic
of Serbia during period until 2030 is presented in the Table 40.
Table 40: Projected amount of generated biodegradable municipal waste for Serbia from 2014
to 2030
Different sources of biodegradable municipal solid waste (t/year)
Households Paper & Other Green Total % of

biodegradabl Cardboar (textile, waste BMW total
Year TOTAL e (garden- d wood, (parks amoun
MSW food) leather, and t
fine public
fraction areas)
etc.)
Reference year
2.374.375 1.024.543 355.536 151.165 71.231 1.602.475 67,5%
2008 *
2014 2.448.566 1.193.779 212.404 203.379 73.457 1.683.019 68,7%
2015 2.468.363 1.189.739 216.334 205.487 74.051 1.685.611 68,3%
2016 2.498.382 1.190.351 221.200 208.439 74.951 1.694.941 67,8%
2017 2.530.283 1.191.521 226.281 211.540 75.909 1.705.251 67,4%
2018 2.566.067 1.194.153 231.763 214.959 76.982 1.717.857 66,9%
2019 2.603.892 1.197.342 237.486 218.539 78.117 1.731.484 66,5%
2020 2.644.308 1.201.308 243.504 222.328 79.329 1.746.469 66,0%
2021 2.682.116 1.203.683 249.340 225.885 80.463 1.759.371 65,6%
2022 2.721.803 1.206.503 255.406 229.586 81.654 1.773.149 65,1%
2023 2.763.469 1.209.790 261.716 233.440 82.904 1.787.850 64,7%
2024 2.807.218 1.213.561 268.282 237.452 84.217 1.803.512 64,2%
2025 2.853.162 1.217.838 275.118 241.631 85.595 1.820.182 63,8%
2026 2.901.416 1.222.640 282.240 245.984 87.042 1.837.906 63,3%
2027 2.952.104 1.227.991 289.663 250.522 88.563 1.856.739 62,9%
2028 3.005.355 1.233.911 297.405 255.252 90.161 1.876.729 62,4%
2029 3.061.308 1.240.424 305.484 260.185 91.839 1.897.932 62,0%
2030 3.120.105 1.247.553 313.917 265.330 93.603 1.920.403 61,5%
The official statistics on municipal waste generated at national level are different from the
estimated data for 2016, therefore, it is necessary to ensure that, when planning the installation
of a specific infrastructure, an assessment would be carried out both on the amount and
composition of the waste generated on regional and/or local level. This is especially important in
cases where the efficiency of the equipment depends on the resulting quantity and composition
(e.g. mechanical biological treatment or incineration plants).
4.1.2 Construction and demolition waste including excavated soils
58
Municipal Solid Waste Information Republic of Serbia 2014

The available statistics and data do not reflect the real potentially generated C&D waste, as
illegal activities are not covered, also an estimation of the totally potentially generated C&D
waste is of interest. To estimate the real potential of C&D-waste a comparison with the average
European generation of C&D-waste can be used. In EC 2011 it is estimated that the European
generation of C&D waste (excavated soil excluded) varies from 0.63 to 1.42 tonnes per capita
per year (EU 27 covered). Considering 7.04 Million inhabitants in Serbia (2017) the potentially
generation of C&D waste may vary from 4.43 Mio tonnes to 10 Mio tonnes of waste. However,
taking into account the gross national product of Serbia an amount of 1.6 Million tonnes seems
to be the most likely potential (and 3.6 Million tonnes an upper limit).
Following national indicators have been analysed to estimate the generation of C&D waste in
the future:
 The total turnover in construction sector [Mio. RSD];
 The total construction investments of buildings [Mio. RSD];
 GDP of the construction sector [Mio. RSD];
 Construction activity of the Serbian contractors at the territory of Serbia [Mio. RSD];
 Demolished dwellings and floor space [m²];
If taking into account those 5 indicators and their development in the past years an average of a
yearly increase of about 4.8 % can be calculated. Taking into account that the total GDP in
Serbia increases with higher yearly average than 4.8 % in the past years, for the calculation of a
forecast with data based on 2014 a yearly average increase of 5% has been assumed.
Furthermore it has to be taken into account that the production of the construction sector
dramatically dropped in 2013 and has recovered by 2015. Thus 2014 data reflect the valley
bottom.
Table 41: Economic data [SOSR, 2017]
Indices: previous year = 100

2012 2013 2014 2015 2016
Gross domestic product at constant
99,0 102,6 98,2 100,8 102,7
prices
Physical production volume of
101,2 79,4 102,5 120,4 106
construction sector
A minimum amount of at least 376.300 t of non-hazardous C&D waste (without soil) can be
expected for 2020 and 451.600 t for 2024. These amounts have been calculated based on
assumption considering the total turnover in construction, the total construction investments of
buildings, the GDP of the construction sector, the construction activity of the Serbian contractors
at the territory of Serbia and the demolished dwellings and floor space.

4.1.3 Secondary waste from waste treatment
The quantities of secondary wastes strongly depend on the complexity of waste management
systems. The introduction of new preparatory treatment steps or new waste incineration
capacities leads to increased quantities of secondary wastes. Since secondary wastes need to
be further treated in recovery or disposal facilities, it is necessary to take them into account in
the planning of integrated waste management system.
For the description of the expected quantities of secondary wastes in this chapter, only the
secondary wastes in a narrower sense of residues needing further treatment are taken into
account. Output streams of preliminary treatment consisting of recyclables den are not
described here.
The realisation of the new installations/operations proposed in Chapter 6 of this document
would lead to increased quantities of secondary wastes. Relevant operations leading to
secondary waste generation and selected secondary wastes expected to be generated in the
future would be:
 Mechanical-biological treatment: MBT facilities consisting of mechanical splitting of
high calorific waste / metal separation combined with aerobic biological processes
typically produce approximately 500-600 kg RDF and approximately 100 - 200 kg reject
fraction to landfilling per 1000 kg input. Thus, at least 150.000 t of RDF are expected to
be generated annually by the three mid-scale MBT facilities, which should be in
operation until 2034. The quantities of the output fractions of the biological treatment
are expected to amount approximately to 30.000 – 60.000 t / year;
 Waste incineration59: Waste incineration typically produces 200 – 300 kg of
incinerators bottom as and 20 – 50 kg of fly ash and flue gas cleaning residues per
1.000 kg input. With the capacity of 300.000 t / year at minimum, the proposed waste
incineration facility would produce 60.000 – 90.000 t of bottom ash and 6.000 – 15.000 t
of fly ash and flue gas cleaning residues annually. Bottom ash could potentially be used
as aggregate if standards are applicable and market exists, or otherwise be landfilled.
Fly ash and flue gas cleaning residues need to be exported to underground landfilling;
 Physical-chemical treatment: There is a vast variety of different physical-chemical
treatment operations and the secondary wastes generated depend strongly on the type
of treatment and on the type of wastes treated. The output streams of physical-chemical
treatment may include organic residues to incineration (e.g. oily sludge) or solid sludge
to landfilling. With the proposed final capacity of 50.000 t / year, physical-chemical
treatment is expected to produce approximately 2.000 t of organic residues for thermal
treatment and 10.000 t of solid sludge to landfilling;
 Mechanical sorting: The proposed mechanical sorting of recyclables, which shall be
conducted at regional and municipal level, is expected to produce up to 150.000 t of
RDF annually, when fully implemented;
 ELV-treatment: Automotive shredding residues are generated in the course of the
treatment of end-of-life vehicles. Assuming, that parts and materials removed in the
course of dismantling account in average to approximately 20% of the vehicle weight,
the quantity of ELV that will be treated in shredders would account to approximately
40.000 t with the expected total quantity of ELVs of 50.000 t. Automotive shredding
residues typically represent 20-25% of the output streams of the ELV-shredding. Thus
the total expected quantity of ARS would amount approximately to 8.000 – 10.000 t
annually;
59
Residues from co-incineration are not regarded as secondary wastes, but primary wastes.

 Shredding of other metal wastes including fractions of WEEE: In addition to the

ASR, further shredder residues will be generated as a residual fraction from mechanical
treatment of metal containing scrap;
 Anaerobic digestion: If facilities for anaerobic digestion will be established, digestate
rich in organic matter, nutrients and nitrogen will be generated. Digestate is commonly
used as fertilizer in agriculture.
4.1.4 Mining wastes
Mining has always been an important part of the Serbian economy. There are approx. 200
active mines in Serbia. The annual volume of mining waste generated in the country is around
150 million m3 of solid mining waste (not subject to the LWM), about 15.5 million metric tonnes
of waste from flotation, and around 35,000 metric tonnes of oil mud (at least partly covered by
the LWM). Improved management of mining wastes under the control of the 2015 Law on
Mining and Geological Exploration are likely to increase the amount of hazardous wastes from
mining operation to be treated in dedicated waste management facilities (mainly hazardous
sludge. Thus an amount of at least 35.000 tonnes of wastes for P/C-treatment and/or thermal
treatment can be estimated.
4.1.5 Sewage sludge
It is estimated that sludge production may reach about 135.190 tonnes of dry material per year
after the Urban Waste Water Treatment Directive will be fully implemented by 2041 (see Table
42). It is estimated that sludge production capacity from the Waste water treatment plants which
currently are in planning or construction stages for the period of 2018 – 2029 is approximately
22.852 tonnes of dry material per year, but the sludge production capacity should increase
rapidly from 2028 or 2029 depending on Serbia's integration processes.
Table 42: The expected total annual sludge production for the ultimate design horizon 2041 per
region for the Republic of Serbia
Region WWTP Capacity 85 % - Percentile 50 %
2041 [t/DS/y]* -Percentile
[t/DS/y]**
Subdivisions of Belgrade 2,170,000 37,300 32,550
Šumadija and Western Serbia 1,884,300 35,630 30,330
Southern and Eastern Serbia 1,362,900 26,890 22,370

Autonomous Province of 1,890,100 35,370 30,140
Vojvodina
Total Design Capacity and 7,307,300 135,190 115,390
Sludge Production
The sludge handling, sludge treatment and sludge dewatering facilities shall be designed based
on the 85 %-percentile. The quantities of the 50 %-percentile shall be applied for definition of
the sludge management and disposal routes.
The total annual sludge production is expressed per (t) dry solids (DS) after sludge stabilization.
The transportation and final disposal volumes depend on the final moisture content and specific

weight of the final product. Dewatering and drying are options to reduce the amount of sludge in
respect to wet weight.
At the ultimate design horizon in 2041 the finally expected sludge quantity in the Republic of
Serbia will be about 0.5 – 0.6 M t-vol/yr of stabilised and dewatered sludge, depending on the
utilization of the individual WWTP’s. Further treatment (drying, incineration) and reuse
(application to land, etc.) of the expected quantities will be subject to sludge management. 60
4.1.6 Vegetal wastes, animal by-products
Meat production is an essential part of the Serbian agriculture sector. The total meat production
increased between 2012 and 2016 from 450.000 tons to 500.000 tonnes 61 . Thus animal by-
products from slaughterhouses can be estimated on basis of literature data 62 to be between
174.000 tonnes in 2012 and 194.000 tonnes in 2016. A slight increase up to 200.000 t can be
estimated within the next few years. New veterinarian regulations will increase the amount of
animal by-products treated in rendering plants. However a small amount of category 1 material
(in accordance with Regulation (EC) 1069/2009) may compete with other wastes for capacities
in co-incineration plants.
The future waste quantities depend on several demographic, economic and social factors. The
developments in the waste management sector, e.g. the improvements in the separate
collection of waste types, also have a high influence on the future waste quantities and waste
composition. Forecasting future quantities of hazardous waste thus requires predicting a
number of uncertain factors. The accuracy of the prognoses depends, of course, also strongly
on the accuracy of the data on the current waste quantities and qualities.
The forecast presented here is based inter alia on the data on current waste quantities, on
assumptions on the developments of separate waste collection, on prognosis of the
development of the economy and population and, in some cases, also on the data of selected
other countries on the generation of specific hazardous waste streams. The objectives of the
estimation were 1) to get a full picture of the hazardous wastes generated in Serbia and 2) to
make prognosis of future quantities. The prognoses of hazardous special wastes have been
taken into account. Detailed descriptions of the prognoses related to the special waste streams
can be found in Chapter 4.2.
The forecasts presented below are based on the following methods and data sources:
 Hazardous WEEE: Based on the collection target of the WEEE-Directive (See also
Chapter 4.2.5.). The biggest part of these quantities are hazardous. However, also non-
hazardous fractions are included here, since projections are not available for hazardous
fractions alone.
 ELV: Prognosis based on the estimated current quantities and on the assumption, that
the number of passenger cars will continue to increase about 1.4 % annually in the near
future and that the quantities of ELV will increase similarly (See also Chapter 4.2.2).
60
National sludge management Strategy and implementation Plan – final draft 2018 December
61
Source: http://publikacije.stat.gov.rs/G2018/PdfE/G201817011.pdf
62
Jedrejek, Dariusz & Levic, J & Wallace, John & Oleszek, Wieslaw. (2016). Animal by-products for feed:
Characteristics, European regulatory framework, and potential impacts on human and animal health and the
environment. Journal of Animal and Feed Sciences. 25. 189-202. 10.22358/jafs/65548/2016

 Waste oils: Based on the estimation on the annual quantities put on the market and on
the average collection rates from other countries (See also Chapter 4.2.3)
 Batteries and accumulators: Prognosis based on the current quantities and on the
assumption, that the number of passenger cars will continue to increase about 1.4 %
annually in the near future and that the quantities of lead acid batteries will increase
similarly. (See also Chapter 4.2.7)
 Medical Wastes: Estimation taken from the National Plan for the Management of
Waste Originating from Healthcare Facilities and Pharmaceutical Waste (See also
Chapter 4.2.11)
 Construction and demolition wastes: Based on the current quantities of hazardous
wastes from construction sector and on the development of the GDP of the
constructions sector as well as on the prognosis of the quantities of asbestos wastes.
(See also Chapter 4.1.2)
 Chemical wastes and sludge from industry and commerce: Extrapolations based
on waste statistics of selected other countries (see also the IHWMP). This waste group
includes among others spent solvents, acid, alkaline and saline wastes, other non-
organic chemical wastes, oil-water emulsions and sludge and other industrial sludge.
 Combustion wastes: Assumption that the quantities remain similar like in 2016.
 Secondary wastes from waste treatment: Estimation based on waste statistics of
selected other countries.
 Hazardous wastes from households: Estimation based on data from other countries.
 Contaminated soils: Current generated/treated quantities and extrapolation based on
waste statistics of selected other countries.
 Hazardous wastes from mining and quarrying: Wastes from mining sector are
completely excluded from the statistics of SEPA. However, in 2016 about 18.000 t of
hazardous wastes from mining and quarrying were treated in facilities which require
permitting in accordance with the Waste Framework. It is assumed that at least 35.000 t
will need treatment in waste management facilities in the future (see also 4.1.4)
Table 43: Expected types and quantities of hazardous wastes in Serbia in 2020 and in 2024.
2020 2024
Waste
from [t] to [t] from [t] to [t]
Hazardous WEEE 8.000 9.000 11.000 16.000
End-of-life vehicles 42.000 49.000 45.000 52.000
Waste oils 25.000 37.000 25.000 37.000
Batteries and accumulators 15.000 18.500 15.000 18.500
Medical waste 4.500 5.000 4.500 5.000
Construction and demolition wastes including asbestos 11.000 11.000 11.000 45.000
Chemical wastes and sludge from industry and commerce 15.000 30.000 20.000 39.000
Combustions wastes 30.000 30.000 30.000 30.000
Secondary wastes from waste treatment 10.000 15.000 15.000 30.000
Hazardous wastes from households 2.000 4.000 4.000 6.000
Contaminated soil 2.000 40.000 2.000 40.000
Hazardous wastes from mining and quarrying 20.000 35.000 20.000 35.000
Total 184.500 283.500 202.700 353.500

4.2 Expected generation of special waste streams
The DSIP on PPWD includes a concise and clear description of the prognosis methodology
used. However, in order to summarize the mechanism of calculating the forecast for placing on
the market packaging were used the GDP growth 63, the forecast population64 and the
percentage of "free riders"65. This percentage resulted by taking into account as inputs a series
of statistical indicators that led to a calculated value of the packaging placed on the market,
which was then compared to the SEPA reported value and the difference actually expresses the
data that was not included in the national reports for objective reasons (e.g.: the difficulty of
fitting certain items into packaging definition, exclusion from reporting and targets achievements
of producers that placed on the market below 1000 kg of packaging).
In this context, the total amounts of packaging placed on the market will be as shown in the
below table (Table 44), where the reference year used was 2016 and the structure by packaging
material was kept constant as an average of the figures reported by SEPA during 2010 – 2015
(Table 45). It can be assumed, that all packaging placed on the market in a given year becomes
waste in the same year.
Table 44: Forecast of the packaging placed on the market, tonnes (Source: DSIP on PPWD)
201766 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028
Glass 86.846 89.885 93.031 96.752 100.623 104.647 108.833 113.187 117.714 117.714 117.714 117.714
Plastic 114.517 118.525 122.673 127.580 132.683 137.991 143.510 149.251 155.221 155.221 155.221 155.221
Paper/
Cardboar 134.181 138.877 143.738 149.487 155.467 161.685 168.153 174.879 181.874 181.874 181.874 181.874
d
Metal 16.061 16.623 17.205 17.893 18.609 19.353 20.127 20.932 21.769 21.769 21.769 21.769
Wood 77.068 79.765 82.557 85.859 89.294 92.865 96.580 100.443 104.461 104.461 104.461 104.461
Other 2.446 2.532 2.621 2.725 2.834 2.948 3.066 3.188 3.316 3.316 3.316 3.316
446.20 480.29 519.48 561.88 584.35
Total 431.118
7
461.824
7
499.509
9
540.269
0
584.355 584.355
5
584.355
Table 45: Structure of packaging material types, % (Source: SEPA)

Type/Percentage 2010 2011 2012 2013 2014 2015 Average value
Glass 20 25 23 19 17 17 20
Plastic 30 25 26 27 27 26 27
paper and 29 30 31 32 33 32 31
cardboard
metal 4 3 4 4 4 4 4
Wood 17 16 17 17 19 21 18
63
Source: International Monetary Fund forecast
64
Source: National Statistical Institute
65
The applied free-riders percent for 2017 data was 20% which is in the range of the recorded values in countries at
the beginning of the implementation period of the Directive
66
The percentage of free-riders applied = 20%

Other 1 1 1 0 0 0 1
Based on the annual numbers of first time registered passenger cars and on the growth of the
fleet of passenger cars and on extrapolations from data of other countries the average quantity
of ELV generated annually in Serbia in 2016 was estimated to be between 40,400 and
46.500 tonnes.
Over the last years, the number of registered passenger cars in Serbia has increased on
average 1.4 % annually. Assuming, that the car fleet will continue to increase 1.4 % annually,
the quantity of ELV will amount to 42,000 – 49,000 in 2020 and to 45,000 – 52,000 t in 2024.
The assumption, that the car fleet will continue to grow despite of the fact, that according to the
prognosis the population of Serbia is going to decrease, is realistic since it can be expected that
the number of passenger cars per person will increase in the future. The current rate of 0.26
cars per inhabitant is relatively low compared to the average in the EU countries. The annual
increase of 1.4 % of registered passenger cars, presuming the same pattern as in the past
years, would mean that in 2020 there would be 0.28 passenger cars per inhabitant in Serbia.
In 2016 the market input of mineral oil which was reported to SEPA was about 33,700 tonnes.
Although this data shows a significant increase compared to the quantities reporting for the
reference year 2010 (22,000 t), it seems not to be complete and it can be assumed that a
significant percentage of importers/producers still do not report on the quantities put on the
market. It is estimated that the real total quantity of mineral oils put on the market in Serbia is in
the range of 50,000 tonnes annually.
According to information available for several European countries approximately 50% to 70% of
oils and lubricants market input are collected as waste oil (EC, 2003; VALORLUB, 201267). The
remaining part is either consumed, lost in any oil containing wastes (e.g. interceptor sludge, oil
filters, etc.) or has been dissipated in the environment. It should be noted here, that “collected
waste oil” in that context means the quantity of waste oil collected by the official waste
management sector being treated/used in licensed treatment plants subsequently.
It is assumed, that during the coming years the overall use of mineral oils/lubricants (currently
about 50.000 t/a) in Serbia will not increase remarkably. With an annual consumption of 50.000
tonnes of oils and lubricants in Serbia the generation potential of waste oil is estimated to
account for 25.000 to 37.000 tonnes per year.
4.2.4 Waste tires
The generation of waste tires closely reflects the development of the car fleet. Based on the
waste generation in 2016 in relation to the amount of cars in use in Serbia and the predicted
development of the car fleet (approx. 1,4% increase per year) a rise of waste generation from
42.175 tonnes in 2016 to 48.500 tonnes can be expected in 2024 (to be checked with SWSP on
tires). The quantities of waste tires include also wastes from stockpiles, the development of
which is hard to predict.
67
VALORLUB is a collective scheme for waste oil in Belgium; http://valorlub.be/en/info/about-valorlub

For the purposes of the DSIP WEEE-Directive (MEP 2018) estimations of the EEE placed on
the market were made considering GDP growth, changes in number of population and other
indicators. The estimations shows that the EEE placement on the market in 2020 will make 9.8
kg/inhabitant and in 2025 - 12.1 kg/inhabitant (Figure 7).
Figure 7: Forecast of amount of EEE placed on the market – total (tonne) and per capita
(kg/capita) (Source: MEP – DSIP WEEE Directive)
The WEEE collection system needs to be planned in a realistic way, because Serbia is
belonging to the group of countries where there is a strong culture of “reuse” within the same
family or closer relatives/friends, without any reporting (such as Poland, Slovakia, Romania,
Malta and Greece) and the quantity of EEE have not been “absorbed”, therefore the life-cycle of
products is generally longer, especially of household appliances and ICT equipment, because
the owners of EEE, instead of discarding the unnecessary devices gives them to others, e.g.
families, ICT to schools.
As regard the WEEE generated, Serbia will need further study to develop a WEEE calculation
tool as was produced by European Commission for each Member State
(http://ec.europa.eu/environment/waste/weee/data_en.htm). Also, it needs to be highlighted that
within this tool for each type of product, it was considered the historical sales date by weight
starting with 1980 and the lifespan distribution per product type (Study on "collection rates of
waste electrical and electronic equipment (WEEE)). Based on these reasons respecting the
article 7 from Directive 2012/19/EC Serbia chose to achieve in the following years the collection
target (see chapter 3.5.3) instead of target based on the generated amounts.
The intermediate collection targets, calculated on the basis of the total weight of the WEEE
collected, expressed as a percentage of the average weight of EEE placed on the market in the
three preceding years, will be achieved until 2031 as follows:
 the collection of 8,451 tons of WEEE in 2020 will represent 13% of EEE placed on the

In Serbia there is no regular collection system for mercury-containing fluorescent tubes and
other lamps from households as well as industry and commerce, as part of the WEEE waste
stream collection and recycling targets apply to mercury-containing fluorescent tubes. The
amount of reported waste generation is about 308 tonnes per year only (SEPA, 2016), while the
potential can be assumed to be in the range of 2.000 tonnes per year. Introduction of separate
collection of hazardous waste from households and a strengthening of the EPR schemes can
therefore increase the amount of separated collected fluorescent tubes enormously. However
based on the technological change (LED lightening devices) it is not assumed that the potential
of waste generation will increase during the next five years.
For the purposes of the DSIP Batteries-Directive (MEP 2018) estimations of the batteries and
accumulators placed on the market were made considering GDP growth, changes in number of
population and other indicators. The estimations shows that the placement of batteries and
accumulators on the market in 2020 will make 2.11 kg/inhabitant and in 2024 – 2.51
kg/inhabitant.
Figure 8 and Figure 9 present the forecasts both for the total batteries and accumulators placed
on the market and for the portable batteries and accumulators placed on the market.
3 25000
2.51 2.61
2.5 2.31 2.41
2.22 20000
2.03 2.11
1.96
21.9 17494 18193
16174 16821 15000
14954 15552
1.5 13892 14378
13422
10000
1
0.5 5000
0 0
2017 2018 2019 2020 2021 2022 2023 2024 2025
Axis Title
POM/cap, kg POM total, tonne

Figure 8: Forecast of the total amount of batteries and accumulators placed on the market – in
tonnes and in kg/capita (Source: MEP – DSIP Batteries Directive).

Figure 9: Forecast of the amount of portable batteries and accumulators placed on the market
– total, in tonnes (Source: MEP – DSIP Batteries Directive).
Based on the current quantities collected and treated and based on the expected development
of the quantities put on the market, it is expected, that the quantity of automotive batteries
generated and collected in Serbia will furthermore be between 15,000 and 18,000 tonnes per
year in the coming years.
In the DSIP for the Batteries Directive (MEP 2018), it is estimated that the collection of portable
batteries will increase as follows: 0.02 kg/cap in 2021, 0.04 kg/cap in 2025, 0.05 kg/cap in 202 7
and 0.06 kg/cap in 2031.
The prognosis of the generated quantities of portable batteries in tonnes is based on the
expectations regarding the target achievements described above. With the forecasted
population of approximately 7.000.000, the expected total quantity of portable batteries would in
2020 be approximately 140 tonnes and in 2024 approximately 280 tonnes.
4.2.8 PCB waste
The total future generation of PCB-containing waste can be estimated using:

 the Serbian PCB-inventory established under the National Implementation Plan under
the Stockholm Convention;
 results of a currently ongoing project “Environmentally Sound Management and Final
Disposal of PCBs in the Republic of Serbia” aiming in - inter alia - identifying the
number of PCB polluted sites in Serbia including the PCB concentrations in the soil.
According to the latest available up-date of the PCB-inventory, in 2015, a total quantity of
1,822.5 tonnes of PCB oils, corresponding to 7,290 tonnes of equipment, is in use. These
quantities are expected to become waste to a large extent by 2020, since the Serbian Law on
Waste Management foresees, that equipment containing more than 5 dm 3 of PCB is disposed of
or decontaminated until 2019/20 at the latest. This would result in an average yearly quantity of
360 tonnes of PCB oils and 1,450 tonnes of PCB containing equipment, respectively. However,
when using such estimates an error margin of up to 30 % can be expected.
The drafted recast of EC-Regulation 850/2004 (by Commission) intends to identify and to phase
out all PCB device > 50 mg/kg and > 0.05 dm³ up to latest end of 2025. Therefore, the inventory
shall be amended. And therefore, the amount of PCB-devices which have to be phased out

before end of their lives and to be disposed is expected to be increase to a level which cannot
be estimated in advance.
PCB containing small devices (capacitors) resulting from proper treatment of WEEE, in
particular large household appliances, are expected to remain a few, maximum 10 tonnes per
year until 2024.
Also, the potential yearly generation of PCB-containing oils by 2024 is expected to remain at the
same order of magnitude as estimated for today, i.e. 125 to 185 tonnes per year.
The following estimates related to generation of the most relevant types of other POPs
containing wastes in the near future (2024) can be made:
Regarding pesticides it is expected that the currently known amount of 1.35 tonnes of lindane
and DDT in stockpiles has been destroyed or exported for destruction before 2024. The future
amounts of pesticides waste to be treated/disposed of depend on whether additional storages
turn up.
Currently 15,000 tonnes of PBDE (already including Deca-BDE) containing parts are expected
in end-of life vehicles and 10,000 tonnes of PBDE containing parts are expected in WEEE. They
are found most likely in shredder fluff and plastics fractions from shredder plants. The biggest
amount of PBDE was used in cars between 1970 and 2005. Assuming an average life time of
cars of 18 years, PBDE streams are expected to decrease from 2023 onwards. Also for WEEE
a decline of the PBDE containing parts is expected. However, in electrical and electronic
equipment, further PBDE congeners are used as substitutes of the restricted congeners. It is
possible that such substitutes will be classified as POPs too. If so, materials from WEEE will
contain considerable amounts of PBDE POPs even in 2024.
The estimated annual generation of PFOS containing wastes is expected to decline from
250 tonnes currently to zero by the end of the 2030ies. However, these wastes – mainly coated
paper and textiles - can hardly be collected separately. Other potentially PFOS containing
wastes like fire-fighting foams and hydraulic products are expected in an amount of annual up to
2 tonnes (foam) and up to 75 tonnes (hydraulics) out of the total 250 tonnes.
The predominant use of HBCD was as a flame retardant in polystyrene insulation material.
Thus, the main source of HBCD containing wastes is the construction sector. According to the
draft Serbian Waste Management Plan for wastes containing POPs (2016) the generation of
HBCD containing insulation material from construction and demolition activities is expected to
be approximately 3,800 tonnes per year.
The main sources of residues containing PCDD/PCDF are metallurgical processes, power
plants and waste disposal sites. According to data presented in the Serbian NIP under the
Stockholm Convention the yearly amount of unintentionally produced PCDD/PCDF in residues
of industrial processes corresponds to 17.6 to 27.2 gTEQ. Thus, the future development of
PCDD/PCDF containing residues strongly depends on the production capacities and on
potential new industrial plant (metal works, power plants etc.).
4.2.10 Asbestos containing waste
Since the use of asbestos in new applications was finally banned by the 2016 amendment of the
RULEBOOK ON BANS AND RESTRICTIONS FOR MANUFACTURING, PLACING ON THE MARKET AND USE

OF CHEMICALS (“Official Gazette of the Republic of Serbia”, No. 36/09, 88/10, 92/11, 93/12 and
2/16) asbestos containing waste is mainly a legacy problem.
Based on the estimated stockpile of 2.1 million tonnes (estimated by the historical consumption
of asbestos; the stockpile consists mainly of asbestos cement and to a smaller extent asbestos
insulation material and asbestos PVC flooring) an amount of up to 45.000 tonnes per year was
estimated, depending of the rate of refurbishment and re-construction of existing buildings. This
amount is the upper limit given a replacement rate of 1/50 per year.
However the following points should be taken into account:
Asbestos cement pipes (widely used in sewer systems and in fresh water supply) are a
substantive part of the stockpile. If these applications are taken out of operation the asbestos
containing material is not necessarily removed as waste immediately. Furthermore the turnover
of the construction sector in Serbia is lower than in most European countries (see also expected
generation of C&D waste). Adjusting the expected amount of asbestos waste (from the
construction sector) with the expected amount of C&D waste a potential of about 10.000 tonnes
per year is the most likely expectation.
Recycling and/or recovery are not an option for asbestos wastes. Although minimisation of the
generation of hazardous waste is in general seen as an indicator for good environmental
performance in case of asbestos containing waste an increase of the separate collected and
disposed amount is a benchmark for the environmental performance of the construction sector.
The increasing number of new and well equipped sanitary landfills provides sufficient disposal
capacity for the potential amount of separate collected asbestos containing waste.
The amount of separate collected asbestos waste will be influenced by the rate of recycling of
mineral C&D waste and to a small extent of separate collected WEEEs. Based on the economic
situation in Serbia not only the professional sector but also the informal sector (“do it yourself”)
is a potential significant generator of asbestos wastes. To increase the separate collection and
safe disposal of asbestos containing waste the following activities are most relevant:
 mandatory recycling of mineral C&D waste (with source separation of hazardous
substances);
 public awareness raising;
 separate collection of hazardous wastes generated by private persons via public
collection centres.
According to SEPA 2.824,18 tonnes of “Wastes from human or animal health care and/or
related research” (Group 18 of the List of Wastes) was generated in Serbia in 2016, of which
about 2.563,64 tonnes were hazardous. However, it seems that not all medical waste are
currently covered by the data reported to SEPA.
In the National Plan for the Management of Waste Originating from Healthcare Facilities and
Pharmaceutical Waste (Ministry of Health 2013):
 the total annual generation rate of infectious waste (18 01 03*) in Serbia has been
estimated to be in the order of 4.500 to 5.000 tonnes per year;
 the annual generation rate of cytostatic and cytotoxic waste (18 01 08*) can be
estimated to be in the order of 70 to 75 tonnes of which 15 tonnes vials contaminated
with undiluted cytotoxic and cytostatic substances. The remaining 55 to 60 tonnes
comprises sharps, plastic tubing and glass and plastic bottles contaminated with diluted
cytotoxic and cytostatic substances (typically a solution of 1% medication in physiologic
infusion liquid). (COWI & EURO HEALTH GROUP 2013).

For planning purposes a generated and collected quantity of 5.000 tonnes per year is assumed
to remain constant for the planning period.
The new infrastructure for hazardous waste management (including medical and veterinary
waste) shall meet existing regulatory requirements, including those of the revised Waste
Framework Directive and the Landfill Directive. This will help to secure environmentally sound
management of hazardous waste. The Integrated Hazardous Waste Management Plan
(IHWMP) includes the priority facilities required. Facilities for treatment should be procured with
support from central government.
According to the European Waste Statistics Regulation, pharmaceutical wastes (18 01 08* and
18 01 09) are allocated to the EWC-Stat-category “Chemical Wastes”.
The total pharmaceutical waste generation in all public HCIs and public pharmacies in Serbia
has been estimated to be in the order of seven tonnes per year. Waste generation in the private
sector is expected to be in the order of 1 to 3 tonnes per year. For planning purposes a waste
generation rate of 50 tonnes per year is assumed bringing the total pharmaceutical waste
generation rate to an estimated 60 tonnes per year. (COWI & EURO HEALTH GROUP 2013)
The generation of pharmaceutical waste is assumed to remain constant for the planning period.
The Integrated Hazardous Waste Management Plan (IHWMP) includes the priority facilities
required. Facilities for treatment should be procured with support from central government.
No generation of this waste stream is expected.
4.3 Expected types and quantities of waste to be imported / exported
The international agreements and the implementation of the obligations of the Waste Shipment
Regulation (Regulation (EC) No. 1013/2006) guarantee a transparent and universal
administrative procedure for Serbian waste owners and a worldwide network of available and
appropriate treatment plants for wastes which cannot be treated in the own territory. Waste
generators can use these capacities if available and if authorized by competent authorities of all
countries concerned (country of origin of waste, country of transfer and country of treatment and
disposal).
Self-sufficiency is a central principle of EU legislation and the Member States are required to
move towards developing their own waste disposal facilities wherever practical. In
accordance with the principle of proximity wastes should be disposed of as close to the source
as possible. Wastes that can be reused or recycled are not included under the principles of
proximity and self-sufficiency.
However, due to economic reasons, the principles of proximity and regional self-sufficiency
cannot always be rigidly applied. Under certain circumstances these principles thus need to be
set aside and Member States which do not have suitable disposal capacities, may make use of
facilities available in other Member States which have excess capacities.
The economic integration and rapprochement of Serbia with the European Union is likely to
increase the exports as well as the imports of recyclable wastes like metal wastes, paper
wastes and plastic wastes. Due to the improvement of source separation and separate

collection in the future, the available quantities of recyclables is expected to increase. For
specific waste streams, like glass wastes, for which the currently available recycling capacities
in Serbia are limited, exported quantities might thus increase if new recycling capacities cannot
be created.
Exports of some hazardous wastes which request a specific treatment that cannot be provided
in an economical feasible manner for the generated quantities in Serbia are expected to
continue and eventually increase in the future. Such wastes include inter alia:
 Residues from steel industry (e.g. dust from flue gas cleaning) and residues from
chemical surface treatment;
 Particular WEEE types, such as gas discharge lamps and hazardous components
removed from discarded equipment;
 Specific asbestos containing wastes which cannot be landfilled, e.g. 15 01 11* (the
quantities are however expected to be small);
 Packaging waste polluted with hazardous substances;
 Pharmaceutical wastes;
 Portable batteries and accumulators;
 Residues from flue gas cleaning from waste incineration 68
 Specific PCB-wastes69, further wastes containing POPs;
4.4 Summary of the expected types and quantities of wastes
The total quantity of waste that will be generated in Serbia and treated in facilities with permits
under waste legislation will in the future strongly depend on the quantities generated by
industrial activities, and especially by the energy sector. It is assumed, that the quantities of
wastes from thermal processes (6.5 million tonnes in 2016) will remain similar or slightly
increase. Based on the current status and on the prognoses made, it can be expected that at
least 10 million tonnes of waste will be generated in Serbia in the near future. It is estimated,
that up to 350,000 tonnes of hazardous waste will be generated in 2024 in Serbia.
The projected quantity of municipal waste that will be generated in Serbia in 2024 accounts
for 2.81 million tonnes. This corresponds to an average annual quantity of 391 kg/inhabitant,
while the EU average in 2016 was 483 kg/inhabitant. It is expected, that the municipal waste
collection will cover 100% of the Serbian population in 2027 at the latest. The separate
collection will be improved in the near future, and the projected quantities of separately collected
fractions of municipal waste amount up to 800,000 tonnes in 2024.
Based on the current generation and selected economic indicators, it is expected that at least
450,000 tonnes of construction and demolition waste will be generated in Serbia in 2024.
However, these quantities do not reflect the real potential, since informal activities are not
covered be the current data on construction and demolition waste. Based on the data of EU-
countries, the potential generation of construction and demolition waste is estimated to amount
up to 3.6 million tonnes.
According to forecasts, approximately 560.000 tonnes of packaging are expected to be
annually placed on the market in Serbia in 2024. It can be assumed that all packaging placed
68
This waste stream will become relevant as soon as capacities for waste incineration will be available in Serbia.
69
The currently ongoing UNIDO-project “Environmentally Sound Management and Final Disposal of PCBs” shall
establish the basis for the decision whether to develop installations for the treatment of PCB waste in Serbia

on the market in a given year becomes waste in the same year. The structure of the packaging
material is expected to remain on average 20% glass, 27% plastic, 31% paper and cardboard,
4% metal, 18% wood and 1% other.
Based on the intermediate collection target of 20% of the EEE placed on the market in the
preceding three years, it can be expected that approximately 15.000 tonnes of WEEE will be
separately collected in Serbia in 2024. Comparable data from other European countries give an
indication that an amount of 2.100 tonnes per year of waste mercury-containing fluorescent
tubes can be expected.
Based on the estimations regarding the current quantities of end-of-life vehicles and of waste
tires and on the predicted development of the Serbian car fleet, it is estimated that up to 52.000
tonnes of end-of-life vehicles and up to 47.000 tonnes of waste tires will be generated in
2024. The quantities of waste tires include also wastes from stockpiles, the development of
which is hard to predict.
Based on the estimations regarding the current quantities put on the market and on information
on oil waste collection in selected other European countries, it is estimated that between 25.000
and 37.000 tonnes of waste oil will be annually generated in the near future.
It is predicted that 2.51 kg / inhabitant of batteries and accumulators will be put on the market in
Serbia in 2024. Based on the current quantities collected and treated as well as on the
projections regarding the quantities put on the market, it is assumed that between 15.000 and
18.000 tonnes of batteries and accumulators waste will be generated in the coming years. It
is estimated that the collection of portable will increase to 0.04 kg / inhabitant until 2025. This
means that approximately 300 t of portable batteries can be expected to be separately collected
in 2024.
The generated quantity of medical waste of 5.000 tonnes per year, which has been
assumed for planning purposes is expected to remain constant for the planning period.
The biggest part of wastes from mining and quarrying are not covered by the Waste Framework
Directive (2008/98/EC) but by the Mining Waste Directive (2006/21/EC). However, it is
estimated that at least 35.000 tonnes of hazardous mining wastes will need to be treated in
physical-chemical treatment facilities or in facilities for thermal treatment. Forecasts on the total
quantities of animal by-products and vegetal residues were not made since these streams
are for a large part not regarded as wastes. As regards animal by-products, a slight increase of
the quantities generated by slaughterhouses is expected resulting in an expected quantity of
about 200.000 tonnes for this waste stream.
It is estimated that sludge production capacity from the waste water treatment plants which
currently are in planning or construction stages for the period of 2015-2020 is approximately
12.000 tonnes of dry material per year, but the sludge production capacity should increase
rapidly from 2028 or 2029 depending on Serbia's integration processes.
The quantities of secondary wastes, which are generated in the course of waste treatment
operations, depend strongly on the level of the waste treatment infrastructure. Secondary waste
fractions, that will be generated in the future (if the proposed infrastructure will be realized)
could among others include: RDF from mechanical treatment (up to 300.000 t/a), output
fractions of the biological part of MBT (up to 60.000 t/a), organic residues and sludge from
physical-chemical treatment (up to 12.000 t/a), ARS from the treatment of ELV and WEEE (at
least 10.000 t/a) and digestate form anaerobic digestion.
The economic integration and rapprochement of Serbia with the European Union is likely to
increase the exports as well as the imports of recyclable wastes like metal wastes, paper
wastes and plastic wastes. Exports of some hazardous wastes which request a specific

treatment that cannot be provided in an economical feasible manner for the generated
quantities in Serbia are expected to continue and eventually increase in the future.

5 EXISTING WASTE COLLECTION SYSTEM AND NETWORK

OF LARGE WASTE RECOVERY AND DISPOSAL FACILITIES
INCLUDING ANY TREATMENT OF WASTE OILS,
HAZARDOUS WASTE AND SPECIAL WASTE STREAMS
5.1 Existing waste collection systems of relevant waste streams
In Serbia, the coverage of waste collection service ranges from only 25% to 100% in some
municipalities. Based on data from SEPA (reports from PUCs) the collection rate of organized
municipal waste collection amounts to ~82% in the Republic of Serbia. Collection is organized
primarily in urban areas, whereas rural areas are significantly less covered.
In urban areas, for municipal waste, the most common type of container used is a 1.1 m3
container, while in some urban areas there are underground containers of 3 m3 and 5 m3. In
semi-urban areas the most common types of container used are 1.1 m3 and 240 litre bins (each
household has its own waste bin). In rural areas, where there are not flats, waste is collected
from each household using plastic sacks or 240 / 140 / 80 litre bins 70.
The provision of municipal waste collection and disposal services is typically undertaken by the
local public utility company (PUC), owned and directed by the local self-government. These
services may also be conducted under agreement with a private provider. Organization of
transport and distribution of containers mostly rely on free assessment and earlier practice,
rather than on appropriate analyses based on changing number of population, frequency of
filling and emptying of containers and capacity of vehicles.
Currently, the main problems associated with the collection system for municipal waste are:
 Inadequate number and structure of containers for waste collection;
 Inadequate distribution of containers;
 Lack of appropriate vehicles for transport of waste;
 Inadequate frequency of transport of waste;
 Inadequate routes of vehicle moving.
For the collection of municipal wastes (household waste and similar commercial, industrial and
institutional wastes) including separately collected fractions (waste category 20) following
permits were issued to companies by end of 2017: 666 permits for collection; 710 permits for
transport and 479 permits for storage activities (register of SEPA on issued waste management
licences). However, only from 80% of the territory of Serbia has carried out organized collection
of municipal waste, which indicates that the companies in Serbia that have permission for
collection, transport and storage of waste are directed towards the collection of waste which
give added value on a commercial basis namely recyclable waste (metal, plastic, paper, rubber,
waste vehicles).
There is no systematically organized separate collection, sorting and recycling of municipal
waste in the Republic of Serbia. Although, the primary recycling in Serbia has been set forth
under the law and envisages separation of paper, glass and metal in specially labelled
containers, separate collection is not functioning in practice.
70
”A comprehensive assessment of the current waste management situation in south east Europe and future
perspectives for the sector including options for regional co-operation in recycling of electric and electronic waste” –
Report prepared by EUNOMIA for DG Environment of the European Commission, January 2017

Separate collection of recyclables other than packaging waste from households is not yet
implemented adequately. In 2013 PUCs, responsible for the collection, reported separate
collection of recyclables for the first time. However, since then the officially reported amounts
collected decreased, due to increasing collection of recyclables by informal sector.
Hazardous waste from households is not collected separately from the mixed municipal waste
stream.
For the collection of waste, various types of special vehicles are used. Rotopress vehicles are
used for the collection of garbage, garbage trucks with a push plate, skip-loading trucks,
ordinary trucks, and tractors with trailers.
The collection frequency varies from municipality to municipality. In Belgrade, according to data
from the Local Waste Management Plan of Belgrade 2011 – 2020 (Off. Gazette of the City
Belgrade, no 28/2011), the collection frequency is as follows:
 Underground containers are emptied twice a week;
 Containers of 1.1 m3 in the inner urban zone are emptied daily and up to three times a
day;
 Containers in the wider city zone are emptied three times a week, and in some parts,
four times a week; and
 Service users (in sub-urban and rural areas of the city) who use the waste disposal bins
are serviced once a week.
In urban areas of other cities and municipalities, the most common collection frequencies are
once per day or twice a week. In rural areas and in areas where each household has its own
waste bin, the most common frequency is once per week. Where there are no transfer stations
for municipal waste, the waste is disposed of directly to dumpsites.
5.1.2 Construction and demolition waste including soil
Recycling of C&D waste depends on good source separation. The following classification
(based on the recycling potential) can be applied for this purpose:
 Mineral C&D wastes: building rubble (17 01 07), bricks (17 01 02), concrete (17 01 01),
mortar (17 01 01), plaster (17 09 04), gypsum based construction material (17 08 02),
glass (17 02 029), excavated soil (17 05 04), etc.;
 Mineral C&D waste with organic binders: bitumen bound road surface 17 03 02), etc.;
 Organic C&D wastes: wood (17 02 01), plastics (17 02 03) including window frames,
organic insulating material (17 06 04), etc.;
 Metal C&D wastes: pipes (17 04 03), ferrous metals (17 04 05), cables (17 04 11),
gutters (17 04 07), metal roofing (17 04 07, 17 04 01), reinforcing rods and clamps (17
04 05), etc.
The collection and disposal of C&D waste is subject to the polluter pays principle which means,
that the waste generator is solely responsible for the lawful and safe disposal (final disposal or
recycling) of the wastes generated. There is no organized collection of C&D waste. Mineral C&D
waste as well as mixed C&D waste is predominantly landfilled on inadequate local dump sites.
Only metal C&D wastes are recovered to a larger extend. At the moment there is no sufficient
separation of hazardous and non-hazardous C&D waste. Namely asbestos containing C&D
waste is landfilled without the necessary precaution.
Although source separation during de- and reconstruction is essential to enable recycling of
C&D waste it is performed to very low extend in Serbia. Even when it is requested to separate
hazardous components (e.g. insulation materials; asbestos-containing construction materials;
bituminous mixtures containing coal tar; tarred products) as well as recyclable parts (e.g. wood,

glass, plastics and metals) from the mineral C&D waste during de- and reconstruction activities
the amounts on these source separated fractions are low.
For the C&D wastes (construction and demolition wastes) including excavated soil from
contaminated (waste category 17) following permits were issued to companies by end of 2017
(Source: register of SEPA on issued waste management licences):
 590 permits for collection;
 658 permits for transport;
 411 permits for storage activities.
As the responsibility to manage the generated waste during de- and reconstruction activities lies
at the building owner and generated waste of those activities are strongly depending on the
location and type of building, collection needs to be organized by the waste owner e.g. by
contracting companies with valid permits to handle and manage the respective waste stream.
5.1.3 Sewage sludge
The following table (Table 46) presents an overview providing the available information’s about
the actual occupation (loading) and the operational status of the existing WWTP’s, incl. an
estimate of the sludge production.
Table 46: Operational status of existing WWTP’s
No. Location of WWTP Design Current Operational Estimated Sludge
capacity loading Production
85 %-per. 50 %-per.
[P.E.] [P.E.] [Y/N] [t/DS/yr.] [t/ DS/yr.]
1 Сомбор/Sombor 180,000 25,451 Y 513 373
2 Вршац/Vršac 90,000 41,866 Y 845 614
3 Вршац/Vršac 2,000 43,393 N n/a n/a
4 Бач/Bač 10,000 2,539 Y 51 37
5 Бачки Петровац/B.Petrovac 4,000 2,894 Y 58 42
6 Маглић/Maglić (B.Petrovac) 2,000 1,240 Y 25 18
7 Бечеј/Bečej 40,000 15,889 Y 320 233
8 Ада/Ada, Mol 7,150 2,963 Y 59 43
9 Кањижа/Kanjiža 8,000 13,218 Y 266 194
10 Кикинда/Kikinda 40,000 29,547 Y 596 433
11 Сента/Senta 17,000 20,346 Y 410 298
12 Суботица/Subotica 150,000 94,389 Y 1905 1385
13 Стара Моравица/Stara 5,000 1,636 Y 33 24
Moravica
(B.Topola)
14 Нови Бечеј/N.Bečej 2,000 5,650 N n/a n/a
15 Пећинци/Pećinci 4,400 3,002 Y 60 44

16 Мачванска Митровица/M. 4,500 1,900 Y 38 27

Mitrovica
17 Рума/Ruma 40,000 n/a N n/a n/a
18 Ваљево/Valjevo 50,000 76,895 Y 1552 1128
19 Лајковац/Lajkovac 7,500 n/a N n/a n/a
20 Шабац/Šabac 84,000 63,942 Y 1290 938
21 Горњи 50,000 30,749 Y 620 451
Милановац/G.Milanovac
22 Деспотовац/Despotovac 5,000 15,166 Y 306 222
23 Параћин/Paraćin 29,000 31,627 Y 638 464
24 Рековац/Rekovac 2,000 n/a N n/a n/a
25 Јагодина/Jagodina 89,000 45,589 Y 920 669
26 Аранђеловац 1/Aranđelovac 25,000 26,442 Y 533 388
1
27 Аранђеловац 2/Aranđelovac 8,000 600 N n/a n/a
2 (Darosava)
28 Крагујевац/Kragujevac 250,000 166,163 Y 3353 2439
29 Топола/Topola 8,000 4,852 Y 97 71
30 Кладово/Kladovo 10,000 n/a N n/a n/a
31 Неготин/Negotin n/a n/a N n/a n/a
32 Сокобања/Sokobanja 5,000 8,233 Y 166 120
33 Власотинце/Vlasotince 10,000 14,198 Y 286 208
34 Бела Паланка/Bela Palanka 20,000 n/a N n/a n/a
35 Димитровград/Dimitrovgrad 9,500 8,929 N n/a n/a
36 Велика Плана/V.Plana 21,000 11,480 Y 231 168

37 Сурдулица/Surdulica 15,000 14,571 N n/a n/a
38 Трговиште/Trgovište 1,800 3,266 N n/a n/a
39 Медвеђа/Medveđa 6,000 4,037 Y 81 59
Total 1,311,850 832,662 15,252 11,090
The sludge production from new WWTP’s can be estimated in a range of 6.600 - 7.600 t/DS/yr.
wet sludge under design load.

Waste treatment, especially recycling, includes in many cases consecutive steps of treatment.
Wastes generated during these consecutive steps are defined as secondary wastes. They are
typically generated during waste treatment operations such as physico-chemical treatment or
waste incineration (both waste category 19), or during dismantling of ELV / WEEE (waste
category 16) and they are specific to the respective treatment operation. Collection needs to be
organized by the waste owner / treatment operator e.g. by contracting companies with valid
permits to handle and manage the respective waste stream.
There is no regular full-scale waste collection system for hazardous wastes introduced on the
territory of Serbia at present. Currently the collection system for hazardous wastes is primarily
based on the economic value of the waste. E.g. oil wastes of a certain quality (high calorific
value) or lead acid-batteries, which can be sold to users within the formal or informal waste
management sector, are collected in any case. Insufficient information is available about the
collection of many hazardous wastes without a positive economic value (acids, chemical waste,
oil-contaminated waste, sludge, etc.).
There is no specific legislation on separate collection and management of hazardous household
wastes in Serbia yet. Certain hazardous wastes from households like WEEE and batteries are
collected under the control of municipalities and in the context of special waste streams. For
other hazardous wastes from households, e.g. waste oil, discarded pharmaceutical and
chemical waste or varnishes, no regular collection system has been established in Serbia until
now.
Table 47 shows the number of valid waste management licenses for collection, transport and
storage of hazardous wastes in Serbia according to the register of SEPA on issued waste
management licenses on the territory of the Republic of Serbia.
Table 47: Number of licenses for collection, transport, storage, treatment and disposal of
hazardous waste (SEPA 06.11.2017).
AP
License issued for Ministry Vojvodina
Secretariat
Collection 191 22
Transport 184 22
Storage 100 51
Treatment 81 28
Disposal 3 3
Total 559 126
5.2 Existing collection systems for special waste streams

The packaging waste from household flow is collected by waste management companies
(public utility companies) mingled with municipal waste, while for buy-back of some packaging
waste types (usually PET and cardboard, waste with a high market value) private companies
get contracts from the local authorities. Also, in accordance with Article 43 of the LWM,
municipalities must organize the separate collection of waste and set up the frequency for waste
collection for recyclables (paper, metal, plastic and glass).At present, the separate collection
system of packaging waste from household flow is not extended to the entire country. The
population connected to sanitation services through sanitation operators represents 60 % of the
population in urban area, while rural areas are not enough covered by organized waste
collection.
The most common types of containers used for packaging waste are 1.1 m 3, 5 m3 and 3 m3,
while in some urban areas, 240 litre bins, and sometimes sacks/bags, are provided to
households for the collection of recyclable waste. In the rural areas where recyclable are
collected separately from mix municipal waste PUCs are providing bags. Drop-off centres are
established in several large cities, either by PUCs or by private enterprises.
The packaging waste from industrial and commercial flow is collected by private companies and
reported to the collective schemes and accounted for as part of producer’s responsibility.
However, some material types of packaging waste (e.g. paper and PET with a high market
value) are collected and recycled out of producer’s responsibility scheme (Source: DSIP on
PPDW)
Beside the quantities reported by the collective scheme system, which involve a certain number
of collectors and recyclers, there are also companies which have a permit for collection and
might collect packaging waste from industrial and commercial flow who do not cooperate with
the collective schemes. There is no information available about such companies and the
amount of waste collected by them. (Source: DSIP on PPDW)
In 2016, the licensed collective schemes carry out activities for 1,771 legal entities or
entrepreneurs.
The valuable packaging waste are also collected for decades by the informal sector. In legal
terms, the informal sector is not regulated by the legislation of Serbia. According to some
estimates, the informal waste collection sector in Serbia is comprised of 30,000 to 50,000
individual collectors– mainly members of the Roma population – working in the informal
economy71.
The collection and handling of vehicles declared ELV usually comprises the transfer of the car
to a designated treatment facility where the actual depollution, dismantling and recycling
processes take place.
Through the Law on Waste Management and the subsequent Rulebook on ELV management,
Serbia took the necessary measures to ensure that economic operators – in most cases the
producers and/or importers of vehicles – set up systems for the collection of end-of-life vehicles
and (as far as technically feasible) of used parts removed when passenger cars are repaired,
and to ensure the adequate availability of collection facilities within their territory. The delivery of
an end-of-life vehicle is not free of charge if it does not contain the essential components or if it
contains waste that had been added to it.
71
Lic, 2013

The dismantling facilities have to issue immediately a certificate of destruction, when they
receive an ELV. Collection facilities only take back the vehicles and forward them to a
dismantling facility. Collection, dismantling facilities and shredder facilities has to obtain a permit
from the MAEP. These actors have to submit report to SEPA.
Moreover, the Government introduced a system of incentives to stimulate the recycling market
of specific element (namely waste accumulators, waste oils) and replacement of old cars with
new ones with preformat environmental protection systems (e.g. domestic car manufacturer
FIAT granted an incentive for scrappage of old cars).
The take-back system for end-of life vehicles is explicitly required to be cost free for the
consumers.
According to SEPA database, there are 63 operators who received permits for the collection of
hazardous End-of-life vehicles (for waste code 16 01 04*) by June 2016 (16/06/2016).
Furthermore, 264 operators received a permit for collection of non-hazardous end-of-life
vehicles (for waste code 16 01 06). 63 operators have a permit for the transport and 17
operators for the storage of hazardous End-of-life vehicles (for waste code 16 01 04*). 268
operators received permits for transport and 164 operators for the storage of non-hazardous
End-of-life vehicles (for waste code 16 01 06).
The collection and treatment of ELV is regulated under Article 55 of the LWM and the Rulebook
on the procedure for end of life vehicle management (“Official Gazette of the Republic of
Serbia“, No. 98/10). The waste stream is subject to the principle of extended producer
responsibility. Thus producers and/or importers of vehicles are required to provide for the
collection of ELV and (as far as technically feasible) of used parts removed when passenger
cars are repaired, and have to ensure the adequate availability of collection facilities. The take-
back system for ELV is cost free for the consumers, provided the ELV still contains the essential
components and no waste that had been added to it. The dismantling and shredder facilities
finance their operation via revenues for recovered scrap, spare parts and materials removed for
recycling (like batteries, catalytic converters). The dismantling facilities have to issue
immediately a certificate of destruction, when they receive an ELV. Collection facilities only take
back the vehicles and forward them to a dismantling facility.
Collectors, dismantling facilities and shredder facilities have to obtain a permit from the MEP
and submit a yearly report to SEPA. A system of incentives to stimulate the recycling market of
specific element (namely waste accumulators, waste oils) and replacement of old cars with new
ones with preformat environmental protection systems was introduced. Also, for several years
(until 2016) FIAT (domestic car manufacturer) granted an incentive for scrappage of old cars.
Although waste mineral oil is regulated by the Regulation on products that after use become
special waste streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12,
3/14) and therefore is subject to the extended producer responsibility principle there is no
comprehensive collection system implemented yet.
The collection of waste oil is regulated by the Rulebook on terms, manner and procedure of
waste oil management ("Official Gazette of the Republic of Serbia", No. 71/2010). Manufacturer
and/or importer of mineral oil products are obliged to notify the seller/retailer in written form of
the places the collection of waste oil in the Republic of Serbia. Professional waste generators
producing less than 500 l waste oil per year are obliged to deliver their waste oil to an
authorized person (collector) while waste generators producing more than 500 l per year are
requested either to provide for a transfer station or deliver directly to a collector.

Seller of mineral oils shall notify the end-users of the places where the end-users can deliver
their used oil free of charge or take back waste mineral oil in the original packaging.
Professional users whose activity generates waste oil (e.g. workshops for the repair of
machinery and equipment, car mechanics, services, etc.) shall store waste oil in containers in a
way that doesn’t endanger human health or environment.
The retailers who take waste oil from the end-users and professional generators have to sign a
contract with a licensed collector of waste oils.
Despite Article 5 of the governmental order no comprehensive collection scheme for waste oil
from households/private persons (and small enterprises) exist at the moment.
97 companies have a permit to collect at least one type of waste mineral oil (without PCB oil) in
accordance with the waste list (chapters 13 01 to 13 01 and 20 01). Furthermore 62 companies
have a permit to collect oil/water mixtures bilge-oil, content of oil/water separators and oil
concentrates from PC-treatment.
5.2.4 Waste tires
Although tires are regulated by the Regulation on products that after use become special waste
streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14) and are
therefore subject to the extended producer responsibility scheme there is no specific collection
system implemented yet. The collection of waste tires is regulated by the Rulebook on manner
and procedure of waste tires management ("Official Gazette of the Republic of Serbia", No.
104/2009 and 81/2010). In accordance with Articles 5 and 6 of the rulebook the generator shall
hand over waste tires to a licensed collector without compensation. 528 companies have a
permit to collect used tires. 132 companies have a license for treatment of used tires. Two
companies use tires as secondary fuel (recovery operation R1) regularly.
The waste stream is subject to the Regulation on products that after use become special waste
streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14) and are
therefore subject to the extended producer responsibility scheme. However, no comprehensive
separate collection system has been introduced so far. Currently, the separate collection of
WEEE from businesses in Serbia is predominantly conducted by the operators of WEEE
treatment plants themselves. 10 companies have a license to treat hazardous WEEEs (16 02
15*). 7 companies have a license for the treatment of CFC-containing equipment (16 02 11*), 7
companies a permitted to treat asbestos containing WEEEs (16 02 12*, e.g. boilers), 5
companies a permitted for the treatment of PCB-containing equipment (16 02 10*) and 89
companies have a permit to treat non-hazardous WEEEs (16 02 14).
As well as packaging recycling, there is a significant informal WEEE collection network in
Serbia. One authorised operator recently estimated that there are between 5,000 and 8,000
informal collectors of WEEE72. These figures are not represented in official statistics. Informal
collectors engaged with WEEE are mainly interested in recovering any type of metal-containing
waste. Therefore, some WEEE is sold at existing scrap metal markets, which often operate
informally. In addition, collectors often supply local repair and second hand shops with spare
parts extracted from WEEE.
Beside that the “informal sector” contributes to some extent to a separate collection as well as
dismantling. Presently, the WEEE collection is based on “Cherry picking” (selective collection of
72

profitable WEEE). “Cherry picking” is selective collecting of the whole or component parts of the
WEEE that generate higher revenues.
Systematically separate collection of WEEE by the official waste management sector is more or
less restricted to collection from businesses and is predominantly conducted by the operators of
WEEE treatment plants themselves. Approximately 500 companies have a permit for collection
of WEEE from business sources (B2B collection).
IT&T appliances - including screens - are collected by the official WEEE-collection system
(companies applying for incentives for treatment of WEEE). It is assumed that other WEEE
types, in particular large household appliances and cooling and freezing appliances are also
collected at relevant amounts by the informal sector with the aim to recover metals.
There is no collection system for WEEE from households, except for bulky waste, containing
also WEEE with valuable materials, which is collected by informal waste collectors directly at
households. Actually, no dedicated collection sites for WEEE have been installed. Hand-over of
WEEE might take place at future civic amenity centres organized for various waste streams
from households (hazardous, bulky etc.). Furthermore, were reported several collection
campaigns organized by the recycling companies and producers.
Even though retailers are obliged by the MO on WEEE to take back WEEE on a one-to-one
basis, the end-users are hardly using this system.
Fluorescent tubes are not referred to explicitly in the Regulation on products that after use
become special waste streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11,
15/12, 3/14), however they are covered since they comply with the definition of WEEEs. Thus
this waste stream is subject to the extended producer responsibility. However, at the moment
there is no organized collection and/or recycling in Serbia. There is no company licensed to
collect explicitly mercury containing fluorescent tubes (waste code 20 01 21*), however these
wastes might be collected under waste code 16 02 15* too. 8 companies have a license to treat
fluorescent tubes.
In Serbia there is no regular collection system for mercury-containing fluorescent tubes and
other lamps from households as well as industry and commerce.
The waste stream is subject to the principle of extended producer responsibility. The produce or
importer has to pay a specific fee for the amount of batteries and accumulators placed on the
market under the REGULATION ON PRODUCTS THAT AFTER USE BECOME SPECIAL WASTE (“Official
Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14).
The collection is regulated under the RULEBOOK ON THE PROCEDURE FOR MANAGEMENT OF WASTE
BATTERIES AND ACCUMULATORS (“Official Gazette of the Republic of Serbia“, No. 86/10). Importer,
producer and seller of batteries and accumulators are responsible for the collection. Importers
and producers are obliged to provide the consumer with information on the obligation of
separate collection (see Article 7). The seller of batteries shall take back used batteries and
accumulators from the consumer at the point of sale (see Article 9). The seller shall hand over
collected batteries to an authorized collector.
Despite these legal obligations collection of WBA is at the moment widely restricted to
automotive batteries since they present an economic value. This collection is performed by

recyclers, the informal sector and NGOs. Thus the amount of waste LAB reported as generated
was only 1,014 tonnes in 2016 while an amount of 9,352 tonnes was reported as recovered by a
secondary smelter.
For consumer batteries no sufficient points of collection are provided, neither is there awareness
raising activity from industry. The amount reported as generated in 2016 was insignificant
(about 22 tonnes of all types of batteries, other than LABs).
According to SEPA data base 259 companies have a permit to collect several or all types of
used batteries (126 collect lead acid batteries, 100 collect NiCd-accumulators, 80 collect
mercury containing batteries (round cells) and 205 collect mixed consumer batteries).
5.2.8 PCB waste
For PCB waste the extended producer responsibility cannot be imposed, since this material is
no longer produced and PCB waste arising is a legacy problem. Based on the polluter pays
principle the waste generator is liable for the save collection and treatment of PCB containing
devices when they become waste. PCB waste referred to in Article 52 of the LWM is mainly
generated during maintenance and shut-down of electrical equipment in the professional sector.
The handling of these wastes is regulated by the RULEBOOK ON TREATMENT OF DEVICES AND
WASTE CONTAINING PCB (“Official Gazette of the Republic of Serbia“, No. 37/11). A second
source of PCB waste is PCB containing hydraulic fluid. Furthermore an increasing amount of
PCB contaminated waste, i.e. waste material containing more the 50 ppm on PCB (mainly
contaminated soil and contaminated C&D waste), will result from clean-up procedures and
demolition activities in the future.
There is no specific collection system introduced for PCB waste, nor deems this necessary. The
collection is regulated in accordance with the rules applicable for hazardous waste in general.
Each waste generator is obliged to transfer these hazardous wastes to an authorized collector
or disposer.
Table 48Table 48 below provides an overview on the number of companies with an
authorization for collection, transport and storage for particular PCB-containing.
Table 48: Number of permits issued for collection, transport and storage for PCB waste
relevant waste codes (Source: SEPA Database on plant permits, status September 2018)
waste management activity

waste code description
collection transport storage
13 01 01* Hydraulic oils containing PCB 42 40 15
Insulation and heat transfer oils
13 03 01* 43 42 13
containing PCB
16 01 09* Components containing PCB 40 40 10
Transformers and PCB-containing
16 02 09* 43 37 20
capacitors
Disposed equipment containing or
16 02 10* contaminated with PCB, other than 46 40 22
these listed in 16 02 09*
Waste generated from construction
17 09 02* 28 27 11
and demolition which contains PCB

Treatment options for PCB wastes, i.e. oils containing PCB and equipment containing PCB, are
currently not sufficient in Serbia. Only one facility with the treatment capacity 140 tonnes/year is
available for treatment of PCB containing waste oils. One company in Belgrade operates a
mobile treatment plant where the PEG de-chlorination technology is applied (this technology
can be used to de-contaminate PCB-transformer with a low concentration on PCB and thus
extend the service life of the equipment).
Thirteen further companies, including one of the 3 Serbian cement factories have a permit to
treat certain of the above mentioned PCB containing wastes 73. However, actual treatment of
PCB containing waste has not yet been reported by these companies.
Thus, the currently ongoing project “Environmentally Sound Management and Final Disposal of
PCBs” shall establish the basis for the decision whether to develop installations for the
treatment of PCB waste in Serbia and to choose the best solution for disposal of Serbian PCB
waste.
POPs wastes others than PCB arise mainly from

 The disposal of stockpiles (namely of outdated pesticides, also other POPs used in
production of goods;
 The maintenance of electrical equipment and dismantling of WEEE (especially plastics
containing brominated flame retardants);
 The maintenance of vehicles and dismantling of ELV (especially plastics, textiles and
foam containing brominated flame retardants);
 Other waste treatment measures than dismantling like shredding of WEEE and ELV;
 Construction, maintenance and demolition works (C&D-waste, e.g. insulation material
and foams containing flame retardants);
 Clean up procedures of contaminated sites;
 Thermal processes (PCDD/PCDF).
For most of POPs waste the extended producer responsibility cannot be imposed, since the
POP substance is no longer (legally) produced or put into the market. Based on the polluter
pays principle the waste generator is liable for the save collection and treatment of POPs
wastes. The legal obligation for the waste generator is to hand over such wastes to an
authorized collector.
Small amounts of these wastes are generated outside the professional sector by private
households (e.g. small stockpiles of pesticides, bulky wastes, sewage sludge). These amounts
can be classified as separate collected (hazardous) fractions of waste from households (chapter
20 01 of the waste list). There is no specific and comprehensive separate collection system for
such wastes at the moment.
Table 49 provides an overview on the number of permits for collection, transport and storage of
certain waste types relevant for pesticides issued in the Republic of Serbia by September 2018.
Furthermore, the SEPA Database lists 18 plants for the treatment of certain of these pesticides,
but it is not clarified if these plants actually treat POPs containing pesticides as well.
Treatment options for POPs pesticides are not sufficient in Serbia. Currently POPs containing
waste is often stored in intermediate storage facilities prior to export. This especially refers to
73
SEPA database on plant permits, status September 2018

POPs waste, whose owner is not always known. The intermediate storage is permitted for up to
12 months according to Serbian Landfills Regulation. However, some of these storage facilities
are inadequate (“factory-storage”).
Table 49: Number of permits issued for waste management activities for POPs waste relevant
waste codes (Source: SEPA Database on plant permits, status June 2018)
waste management activity

waste code description
collection transport storage
Agrochemical waste containing
02 01 08* 26 24 13
hazardous substances
Packaging containing residues of or
15 01 10* 92 84 32
contaminated by hazardous substances
20 01 19* pesticides 37 37 14
POPs containing plastic waste are generated typically already in the waste treatment sector
(secondary wastes) either during dismantling of WEEEs and ELV or during shredding of such
wastes (producing shredding fractions 19 10 03*/04 and 19 10 05*/06). Therefore there is no
need of a specific separate collection scheme. Such wastes may be processed directly into a
RDF (19 02 09*/10 and rather 19 12 10) to be used as secondary fuel in the cement industry. 46
companies have a license to collect wastes with the waste code 19 10 03*/04, 19 10 05*/06
and/or 19 12 10. In addition, 29 companies are licensed for the pre-treatment and recovery of
RDF at the moment.
Asbestos was regulated by the Regulation on products that after use become special waste
streams (“Official Gazette of the Republic of Serbia“, No. 54/10, 86/11, 15/12, 3/14; note
asbestos is no longer listed in the amendments “Official Gazette of the Republic of Serbia” No.
45/2018 and 67/2018) and therefore in principle subject to the extended producer responsibility.
However since the production of asbestos was phased out under the Law on Chemicals
asbestos containing waste is a legacy problem.
Asbestos waste will be generated for a long period during maintenance and demolition of
buildings and infrastructure (water pipes and sewer pipes) since there is an estimated stockpiles
of between 1.6 and 2.2 million tonnes (see chapter 2.5.10). The removal of asbestos waste
during maintenance and demolition activities is subject to control of the labour inspectorate in
accordance with pertinent legislation on occupational health and workplace safety while the
consecutive treatment of the asbestos containing material is regulated by the Rulebook on
Procedures of Asbestos Containing Waste (“Official Gazette of the Republic of Serbia“, No.
75/10). A small amount of asbestos wastes will be generated during dismantling of specific
WEEEs (e.g. boilers).
There is no specific collection system but the general rules for the collection of hazardous waste
apply.
About 70 companies have a license to collect asbestos containing electrical equipment, while 57
have a license to collect asbestos containing insulation material and 54 have a license to collect
asbestos cement. Since most of asbestos waste is generated during professional activities there
is no need of a specific collection system in general. However the collection of small amounts of

asbestos containing waste (especially asbestos cement) from households (do-it-yourself

activities) via civic amenity sites seems appropriate in the future.
5.2.11 Medical and pharmaceutical waste
Medical wastes and pharmaceutical wastes can be divided in those arising from human
healthcare (classified in chapter 18 01 of the waste list) those from veterinary activities
(classified in chapter 18 02 of the waste list). Major sources of medical waste are medical
offices, operation rooms, laboratories, radiology and chemotherapy, ambulance services,
vaccination campaigns, cleaning and maintenance services. Minor amounts are generated by
medical and dental offices, as well as home care.
Hazardous medical and healthcare wastes can be classified as infectious wastes (exhibiting
hazard characteristic H9) and other hazardous wastes, containing hazardous substances (e.g.
chemicals from diagnostic laboratories). Proper source separation of infectious material and
hazardous substances at the place of generation is essential to reduce the amount of
hazardous medical waste. Separated infectious wastes (hazardous) shall be converted into non-
hazardous waste by proper sterilisation (e.g. autoclaving) preferable at the place of generation
(hospital). Other hazardous medical waste mainly comprises from hazardous chemicals, such
as disinfectants, laboratory chemicals, etc. Non-hazardous healthcare waste can be divided in
mixed wastes without hazardous properties (similar to MSW) and in wastes exhibiting the risk of
injuries (sharps, etc.), requiring special care (e.g. packaging in small dense containers).
Healthcare waste from home care is regarded as non-hazardous waste in general.
Pharmaceuticals waste (others than from production) are included in this waste (waste codes 18
01 08*, 18 01 09, 18 02 07*, 18 02 08), while wastes and residues from pharmaceutical
production are classified as a waste stream of the chemical industry (group 07 05 of the waste
list) and medicals collected from end-users under waste code 20 01 31* and 20 01 32.
The Generator (healthcare institutions) is responsible for management of the medical waste.
Medical waste and pharmaceutical waste is not subject of specific separate collection system.
The generators are required either to treat the waste themselves in accordance with the
applicable legal requirements or to enter into a contract with a licensed collector. Furthermore
the generator is obliged to separate hazardous from non-hazardous waste and prepare the
waste in a proper packaging for collection and disposal. A generation of 100 t/a non-hazardous
medical waste and/or a generation of 200 kg/a hazardous medical waste triggers the obligation
to develop a medical waste management plan.
In case the generation of hazardous medical waste exceeds 500 kg/a, the waste management
plan has to be approved by the Ministry responsible for healthcare (Ministry of health) on basis
of an opinion obtained from the Public Healthcare Institute. Waste management plans from
veterinary organisations and facilities are under the competence of the Ministry of Agriculture,
Forestry and Water Economy.
Pharmaceutical waste and, where practical, chemical waste shall be collected from healthcare
institutions, pharmacies and medical laboratories by private transport operators. These few
private operators have been issued with permits to collect, transport and temporary store
pharmaceutical and hazardous waste. They have also the experience and capacity to organize
the export and treatment and disposal abroad while there is no adequate treatment option
(D10/R1) in Serbia available. (COWI & EURO HEALTH GROUP 2013).

There is no recent generation of this waste in Serbia.
5.3 Existing network of large waste recovery and disposal facilities
5.3.1 Waste incineration and co-incineration
At present, there are no dedicated waste incineration plants in Serbia.

Currently, three cement plants are operation in the Republic of Serbia:
 LAFARGE Serbia Ltd. (Member of Lafarge-Holcim Group), Beočin
 CRH Serbia Ltd. Popovac, Paraćin
 TITAN Cementara Kosjerić Ltd., Kosjerić
Two cement factories in Serbia have permits for the thermal treatment of hazardous and non-
hazardous WASTE, while the third factory is in the procedure of obtaining the permit.
The processes where waste is used as raw material and/or as a source of energy, and where
waste substitutes natural mineral resources (material recycling) and fossil fuels (energy
recovery) used in the cement manufacturing, are called co-processing. In the Serbian cement
factories, co-processing took place for the first time in 2006. Between 2006 and 2014 nearly
210,000 tonnes of non-hazardous and hazardous waste were used as an alternative fuel (RDF)
in the Serbian cement factories.
In addition, for the purpose of cement production, this industry in Serbia uses annually more
than 300,000 tonnes of non-hazardous and hazardous waste (primarily fly ash and granulated
blast furnace slag) as alternative raw materials.
5.3.2 Landfills
There are about 130 landfill sites not in compliance with the Regulation on disposal of waste
in landfills (“Official Gazette of the Republic of Serbia“, No. 92/10). Furthermore there are about
3.400 unsecured dump-sites. Thereof, 182 large landfills and dumpsites with the capacity over
10 000 m³ contain 93.5% of the total deposited waste quantity and are most prominently to be
issued by environmental remediation.
Sanitary landfills are used for disposal of non-hazardous waste and they represent sanitary and
technically regulated area for disposal of waste material from public areas, households,
production and work process, turnover and use, which does not have qualities of hazardous
matters and cannot be processed, i.e. used rationally as industrial raw material or fuel.
10 sanitary landfills have been operative so far, as shown in Table 5074.
Table 50: Regional and local sanitary landfills (2017)
Name Location Operator
RSL “Duboko” Uzice Zlatibor 31000 Duboko bb

RSL “Vrbak” Lapovo Lapovo 34220 FCC ECO d.o.o.
RSL Kikinda Kikinda 23300 FCC Kikinda d.o.o.
74
The landfill in Subotica has been constructed, but is not operational yet (status 2017).

RSL “Gigoš” Jagodina Jagodina 35000 PWW Deponija doo Jagodina

RSL “Zeljkovac -D2” Leskovac 16000 PWW Deponija Dva d.o.o. Leskovac
Leskovac
RSL “Muntina padina“ Pirot 18300
Pirot
RSL “Jarak” Sremska Sremska Mitrovica JKP Regionalna Deponija Srem-
Mitrovica 22000 Mačva
RSL Pančevo Pančevo 26000 PUC "HIGIJENA" PANCEVO
SL “Meteris” Vranje Vranje 17500
SL “Vujan” Gornji Gornji Milanovac
Milanovac 32300
Four landfills in the Republic of Serbia have licenses for disposal of specific hazardous waste.
One of the 4 landfills is managed by the steel company “HESTEEL Serbia Iron” which is used to
dispose of hazardous waste generated internally. The additional three locations are in the
private ownership and operate primarily as regional sanitary landfills for non-hazardous waste.
These facilities have separate cells and associated permits for hazardous component of
construction and demolition waste, asbestos and for solidified hazardous waste. Hence the only
site which has a permit to accept non-treated hazardous waste is the “HESTEEL Serbia Iron”
landfill. The four above-mentioned landfills are operating according to EU requirements and no
additional measures are foreseen for their compliance.
Table 51: Landfills that have cells for hazardous waste in the Republic of Serbia
Capacity
Operator Location Waste types landfilled in 2014 in accordance with the waste permits 75
[m³]
FCC EKO Lapovo 12,876 - Construction materials containing asbestos
D.O.O. - Other insulation materials consisting of or containing hazardous
Regionalna substances
deponija - Other construction and demolition wastes (including mixed wastes)
Vrbak containing hazardous substances
Lapovo
- Insulation materials containing asbestos
FCC Kikinda Kikinda 38,285 - Construction materials containing asbestos
doo Kikinda - Other insulation materials consisting of or containing hazardous
substances
PWW
DEPONIJA
Leskovac 1,600
- Waste marked as hazardous, solidified
DVA D.O.O - Construction materials containing asbestos
LESKOVAC
- Sludge and filter cakes from gas treatment containing hazardous
substances
- Sludge from physical/chemical treatment containing hazardous
HESTEEL Smederev substances
240,000
Serbia Iron o - Sludge containing hazardous substances from other - treatment of
industrial waste water
- Machining emulsions and solutions free of halogens
- Spent waxes and fats
According to latest data from SEPA 76, in 2016 474.018 tonnes of waste was landfilled into
compliant sanitary landfills (25 % of reported generated municipal solid waste in 2016).
75
Source: Information provided by SEPA on landfilled amounts of hazardous waste in 2014.
76
Waste Management in the Republic of Serbia 2011 – 2016. Serbian EPA, 2017.

5.3.3 Physico-chemical treatment and treatment of waste oils
At least 10 facilities which had a permit for the treatment of hazardous waste at the end of 2017,
can be classified as physico-chemical treatment plants (including treatment of waste oils). Table
52 give an overview on these plants and their locations.
Table 52: Examples for operators carrying out physico-chemical treatment activities
Operator (name) Municipality Treatment WEB / Operator

Re-refining of waste
RAFINERIJA NAFTE Beograd-Palilula http://www.rnbg.rs/
oil
Mobile installation,
hand-mechanical
cleaning, water
Beograd-Novi washing, chemical
MODEKOLO http://modekolo.co.rs/
Beograd treatment,
decantation,
centrifugation and
solidification
Mechanical cleaning,
CLEANING SISTEMS Šabac dry ice cleaning (CO2 http://css.rs/
in solid state)
oil and physical
treatment (filtration,
EKOSEKUND Beograd-Palilula http://ekosekund.rs/
gravity separation,
centrifugation and
mixing)
Purification,
solidification,
Beograd-Stari
YUNIRISK ultrafiltration and http://www.yunirisk.com/
Grad
MID-MIX technology
for inertisation
Chemical treatment
EKO METAL Irig of waste photo- http://www.ekometal.com/
chemicals
Beograd- Mobile installation,
BREM GROUP http://www.bremgroup.com/
Rakovica bio-remediation
Physical treatment
OPTIMA FORMA Trstenik (filtration, decanting),
recycling
BIODIZEL CO Beograd-Grocka Biodiesel production http://www.biodizelco.com
BIO-OIL Nova Varoš Fuel production
antifreeze, filtration,
Beograd-Stari
ALTIS CHEMICALS adsorption, https://www.altis.co.rs/
Grad
coagulation and
regeneration
5.3.4 Dismantling/pre-treatment of WEEE and ELV
Treatment of WEEE
The dominant way to treat WEEE is by manual dismantling, sorting of components and
materials, drainage of cooling agents and mechanical treatment in a universal cross flow
shredder. However, it can be assumed that the informal sector plays a relevant role in the

collection and treatment (including preparation for re-use) in Serbia. Operators carrying out
following treatment activities:
 Manual dismantling
 CRT-tube splitting (hot-wire)
 Treatment of cooling & freezing appliances
 Treatment and dismantling of cables
 Drainage of cooling & freezing appliances
 Treatment of gas discharge lamps
End of 2017, in Serbia there are about five major recycling companies receiving WEEE waste of
about 35,000 tonnes per anno. Furthermore, approximately 129 companies had a permit to treat
WEEE (EWC 20 01 21*; 20 01 23*; 20 01 35*; 20 01 36; 16 02 09*; 16 02 10*; 16 02 11*; 16 02
12*; 16 02 13*; 16 02 14; 16 02 15*).
Metal fractions derived from treatment of WEEE are traded by numerous scrap metal traders in
Serbia. Selected waste plastics from WEEE may undergo recycling activities (see also Chapter
on further treatment/recycling installations in the following). Hazardous components, such as
batteries, capacitors, CRT-glass or fluorescent dust are currently stored. Residual fractions are
disposed of at landfills.
Treatment of ELV
In the Republic of Serbia 21 operators had a valid permit in 2017 for the treatment of hazardous
End-of-life vehicles (EWC 16 01 04*). Out of which 13 are issued by the Ministry, 7 by the AP
Vojvodina and 1 by a municipality. Further 180 companies had a permit for the treatment of non-
hazardous end-of-life vehicles (EWC 16 01 06) in 2017. Beside this licensed operators informal
activities at various stages (from garages without a license for waste management to private
persons) can be assumed given the discrepancies between estimated and registered amount of
ELV per year (see chapter 2.5.2)
The recycling process of an ELV starts at the dismantling or treatment facility where it is first
depolluted and then dismantled (sometimes these two steps are summarised as “dismantling”).
Depollution includes removing hazardous components and substances such as the battery, fuel,
other fluids, airbags and any parts containing mercury.
Once the vehicle has been depolluted it needs to be dismantled. This process involves
segregating and collecting recyclable and reusable components, including engines, tires,
bumpers, and other parts. The recovered components and fluids are sold for reuse in other
vehicles (motor parts, batteries, fuel, etc.) or for further recycling (tires, valuable metals, carpets,
etc.).
5.3.5 Recycling of mineral construction and demolition waste
69 companies had a valid permit in 2016 for treatment of mineral non-hazardous C&D waste
(one or more EWC 17 01 01; 17 01 02; 17 01 03; 17 01 07; 17 05 04; 17 05 08). However, only
3 companies reported to receive non-hazardous mineral construction and demolition waste for
further recovery operations with a total amount of lower than 1,000 tonnes in 2016.
Treatment of C&D waste to substitute primary resources for construction activities is very low
developed in Serbia. If generated during re- or deconstruction, mineral C&D waste is re-filled for
the purpose of correction of specific areas. To some extent bituminous road material is
recovered/re-used at the construction site during road maintenance operations.

5.3.6 Further treatment/recycling installations
The most recycled waste materials in Serbia are metal waste and packaging waste
(paper/board, plastic/PET, wood and glass).
According to information on waste treatment and permits issued by the competent authorities
(provided in the SEPA database) existing treatment facilities are identified in the following.
Plastic and rubber recycling

There are numerous types of plastic processors in Serbia that utilise recycled plastic. There are
PET processors - large companies processing from 60 to 5,000 t/month, also large non-PET
processors, producing the LDPE folio hose and piping or granulate.
In 2016, about 30 companies carried out operations on the recycling of plastics and rubber. Two
third thereof having received waste lower than 1,000 tonnes a year in amount. Ten companies
received waste in total of more than 50,000 tonnes for recycling activities (R2-R13). About 300
companies had a permit in 2016 for treatment of one or more EWC considered (EWC 02 01 04;
07 02 13; 12 01 05; 15 01 02; 16 01 03; 16 01 19; 17 02 03; 17 02 04; 19 12 04; 20 01 39).
Thereof, 67 companies reported to receive one or more EWC considered for treatment
(including storage) in 2016.
Metal recycling
Metals, both ferrous and nonferrous, are recycled quite efficiently in Serbia through a vast
network of collectors and buyers covering virtually every city, town and village. The steel waste
collected in Serbia is processed by foundries and also further treated for processing in the steel
industry.
In 2016, minimum of 15 companies carried out operations on the recycling of metals. Six
companies received waste in total of more than 300,000 tonnes for recycling activities (R2-R13,
included in table above). About 350 companies had a permit in 2016 for treatment of one or
more EWC considered (EWC 02 01 10; 15 01 04; 16 01 17; 16 01 18; 17 04 01; 17 04 02; 17 04
03; 17 04 04; 17 04 05; 17 04 06; 17 04 07; 17 04 08; 17 04 09; 17 04 10; 17 04 11; 19 10 01;
19 10 02; 19 12 02; 19 12 03; 20 01 40). 51 companies reported to receive one or more EWC
considered for treatment (including storage) in 2016.
Paper and cardboard recycling

Currently waste paper, especially cardboard waste, is recycled mostly in Serbia. A substantive
amount of waste paper is imported for recycling. In 2016, minimum of 3 companies carried out
operations on the recycling of paper/cardboard. They received waste in total of more than
200,000 tonnes for recycling activities (R2-R13. About 200 companies had a permit in 2016 for
treatment of one or more EWC considered (EWC 15 01 01; 19 12 01; 20 01 01). 18 companies
reported to receive one or more EWC considered for treatment (including storage) in 2016.
Glass recycling
Glass recycling in Serbia is uncommon: demand and prices are low, waste is heavy, so
transport costs are an important factor and enable only low margins.
One operator recycles glass packaging waste. The capacity of the factory is 30,000 tonnes per
year.
Treatment of asbestos containing waste

About 20 companies had valid permit in 2017 to treat asbestos containing waste, comprising
one or more EWC considered (EWC 06 07 01*; 06 13 04*; 10 13 09*; 15 01 11*; 16 01 11*; 16
02 12*; 17 06 01*; 17 04 09*; 17 06 05*; 20 01 35*). 9 companies received asbestos containing
waste in 2016 for recovery/storage activities. The three landfills were hazardous waste can be
disposed of (one additional landfill with valid permit but not technically suitable up to now, see
also Chapter on landfill sites) received waste for disposal of about 1,000 tonnes in 2016 (EWC
17 06 01*; 17 06 05*).
Used batteries and accumulators

In Serbia treatment of waste lead-acid batteries and the production of lead alloys thereof is
carried out by one operator. The treatment capacity is 22,000 tonnes annually for treatment of
waste lead-acid batteries. By the end of 2017, no treatment capacities have been established in
Serbia for the treatment of portable batteries and accumulators.
5.4 Summarizing illustration of the existing waste treatment capacities

and of the current status of waste treatment in Serbia
The table below shows a summary of the main waste treatment facilities established on the
territory of Serbia up to now. The number of the respective treatment installations reflect
minimum numbers according to the assessment based which are on company data from SEPA.
Table 53: Main existing infrastructure for management of waste in Serbia
Minimum Capacities
Type of treatment Number (No.)
(tons/anno)
Industrial installations1 with permit for co-incineration 2 ~ 300,000

Compliant regional sanitary landfills 2 10 n. a.
3
Non-compliant landfill sites 180 n. a.
Physico-chemical treatment and treatment of waste oils 13 n. a.
Dismantling/pre-treatment of WEEE and ELV min. 5 n. a.
Recycling of mineral construction and demolition waste min. 3 n. a.
Plastic and rubber recycling min. 30 min. 50.000
Metal recycling min. 15 n. a.
Paper and cardboard recycling min. 18 n. a.
Glass recycling 1 30,000
Used batteries and accumulators treatment 1 ~ 22,000
min… Minimum; ~… Approximately
1… No incinerator for waste treatment has been installed up to now
2… Four out of them having licence for disposal of hazardous waste with a capacity for hazardous waste of more than 290,000 t/a.
3… In addition, approximately 3,400 unsecured dump-sites are known on the whole territory of Serbia

Assessment National Waste Management Plan
6 ASSESSMENT OF NEEDS FOR NEW COLLECTION SYSTEM,

ADDITIONAL INFRASTRUCTURE IN WASTE MANAGEMENT
FACILITIES IN COMPLIANCE WITH SELF- SUFFICIENCY
AND PROXIMITY PRINCIPLES, AND AS NECESSARY,
INVESTMENTS INTO THE CONSTRUCTION OF SUCH
INFRASTRUCTURE
6.1 Assessment for relevant waste streams
Based on the description of the municipal waste management related aspects in previous
chapters the following gaps, important for the implementation of the sustainable municipal waste
management system in Serbia:
 Not all municipalities have guaranteed the conditions for the use of public waste
management services by waste holders located in their territory. Currently the coverage
of waste collection in Serbia is about 82%;
 Separate collection of recyclables and bio-waste is not yet implemented adequately;
 Hazardous waste from households is not collected separately from the mixed municipal
waste stream
 Most of the municipal waste goes to landfills untreated, as well as a significant
proportion of municipal waste is still being disposed of in non-sanitary landfills;
 Recycling targets for the municipal waste (50 %) are not yet achieved. Currently the
recycling rate for the municipal waste is about 3%;
In assessing the need for the necessary infrastructure, it should be borne in mind that, when
implementing waste management infrastructure projects coherent administrative action will be
required. Therefor the National waste management strategy takes a regional approach to
municipal waste management. The Law on Waste Management stipulates that regions will have
a minimum size of 250.000 population. This approach is intended to provide economies of
scale for the development of more effective treatment technologies. The decentralised decision-
making allows local authorities some flexibility to join the regional waste management company
which provides the best value for money service for their particular needs. The regional
structures should be founded through inter-municipal cooperation agreements between the local
authorities (see Chapter 9).

Figure 10: Principal municipal waste management scheme
As shown in the Figure 10 the management of municipal waste consists essentially of two parts:
 Separate collection then processing and marketing of recycled products;
 Management of residual waste what remains after a separate collection.
These two parts are highly interrelated. Waste management alternatives strongly depend on to
which part of the system priority is given (including funding), and how successfully it works. It is
important to ensure interoperability between these two parts so that they do not become
competing with one another. To maximize the benefits and to evaluate not only the investment
costs but also the costs incurred after the implementation, specific technical solution should be
selected after completion of detailed cost-benefit analysis.
To ensure that municipal waste management system is functional, also the polluter pays and
cost recovery principles, it is necessary to ensure sufficient availability of waste collection
services. The objective is to provide waste collection services to municipal waste holders up to
100 percent. Also it is important that waste disposal in non-compliant landfills would be stopped
after the construction of regional non-hazardous waste landfills.
Source separated waste streams such as bio-waste needs to be directed to biological
treatment, other recyclables such as metals, plastics, glass, paper, cardboard and wood should
be directed to material recovery operations predominantly in industrial processes.
Hazardous waste from households such as batteries and accumulators, WEEE and others need
to be source separated and finally directed to suitable pre-treatment and recovery/disposal
operations (such as manual dismantling, physico-chemical treatment or others, thermal
treatment).

Mixed municipal solid waste, remaining after source separation and sorting, can be treated
thermally. Mechanical-biological treatment comprises a pre-treatment step in addition to final
disposal and thermal treatment.
An assessment of the basic infrastructure required for implementation of integrated regional
systems and implementation of the Landfill Directive was performed during the Environmental
Infrastructure Support Programme (funded by Sweden) where inter alia an "Investment
Planning Tool" was developed. According to this assessment specific numbers on the needed
vehicles, amenity sites and containers for separate collection have been calculated for the
single waste management regions in Serbia.
Table 54: Infrastructure required for municipal waste management 77
Territory of Amenity 1.1 m3 600 l Composting

Vehicles 120 l bins
Serbia sites containers composters plants
TOTAL 479 151 46.399 3.140.806 1.024.380 160
As seen in Table 58 in this assessment also has been taken into consideration the
implementation of other waste management requirements and having in mind the targets set by
the Waste Framework Directive and the Packaging and Packaging Waste Directive. Through
facilities like municipal amenity sites the regional systems separate out special waste streams
like recyclables, WEEE, batteries, household generated hazardous waste, tyres and similar.
The development of the municipal waste management system is planned to be carried out in
three stages.
Table 55: Infrastructure plan for municipal waste management
Regions with large

High density urban
conurbations – Novi Sad, Other Regions
Region – Belgrade
Niš, Kragujevac
 100% collection coverage(connected to the services)
 Vehicles for waste collection and transport
 Transfer stations
 Home-composting and public awareness raising
 Source separation – bin/bag system, with separate collection of recyclables and
bio-waste
First Phase  Secondary separation of recyclables – sorting plant
 Amenity sites (e.g. recyclables, bulky waste, WEEE, hazardous)
 Fully engineered sanitary landfill with compaction
 Composting of green waste and source separated bio-waste (e.g. parks, streets,
garden, vegetable kitchen waste, etc.)
 Closure of existing landfills (cease of operations, gate and fence)
 Land acquisition (landfill body, transfers stations and amenity sites)
Simple MBTs prior
landfilling, Upgrading /
Waste-to-Energy Advanced MBT
Second Phase additional BT for source
separated bio-waste
Third Phase Recultivation of all old landfills and dumpsites selecting appropriate recultivation
77
Source: “Investment Planning Tool”, Environmental Infrastructure Support Programme

option
Source: Based on Draft Implementation Plan for Council Directive 1999/31/EC of 26 APRIL
1999 on the Landfill of Waste, Belgrade, March 2018
The first phase foresees the implementation of the same measures in all regions of Serbia. In
this phase priority is given to the availability of the service, thus ensuring the “polluter pays”
principle and to create preconditions for full covering of operating costs.
These shall ensure in particular: the full collection coverage, the separate collection of
recyclables including biodegradable waste, and secondary separation of recyclables. These
measures will be necessary in order to achieve recycling targets for municipal solid waste as
well as the landfill targets concerning diversion of biodegradable waste.
The second phase foresees different measures in specific regions to manage mixed residual
waste and source separated waste at national level. In particular, in high-density regions
incineration facilities for Waste –to-Energy combined with district heating shall be implemented,
while in regions with large conurbation mechanical biological treatment or composting and
anaerobic digestion facilities shall be installed. In remaining regions, the focus should be on the
first phase measures and other low-cost measures such as composting of source separated
bio-waste.
Bio-waste
Source separation – this is actively encouraged in EU and in many EU countries. From 2023 on
separate collection must be implemented by Member States and from 2027 only source
separated bio-waste sent to composting or anaerobic digestion can be accounted for recycling.
It includes separation of the putrescible organic fraction (bio-waste). It is generally accepted that
source separation provides the best quality feedstock for both anaerobic digestion and
composting, offering both a maximum organic content and minimum contamination with heavy
metals, glass and plastics. After digestion of this source-separated waste in a reliable process,
the end result will be the formation of a quality digestate and a high volume of biogas.
Green waste from municipality activities and green waste received at public amenity sites as
well as source separated bio-waste shall be directed to the composting facilities at municipality
level.
In terms of increasing amounts of source separated bio-waste capacities for advanced
biological treatment plants (composting/ingestion plants) shall be established in the second
phase of implementation following the period of 2025.
Hazardous components in mixed municipal waste

Although municipal waste (waste code 20 03 01) is defined as non-hazardous waste mixed
municipal waste contains hazardous components which cause a threat to human health and
environment at all stages of waste management. Although the amount of hazardous waste in
municipal solid waste is typically below 1% especially under the conditions of Serbia where
municipal waste is landfilled only today this small amount causes a permanent threat to soil and
groundwater78. Typical hazardous wastes included in municipal solid wastes are mercury
containing wastes like fluorescent tubes and thermometers, batteries, discarded medicines,
78
Slack, Rebecca & Gronow, J.R. & Voulvoulis, Nikolaos. (2005). Household Hazardous Waste in Municipal Landfills:
Contaminants in Leachate. Science of The Total Environment Volume 337, Issues 1–3, 20 January 2005, Pages 119-
137.

waste paint and lacquer, residues from pesticides. To cope with this problem a separate
collection of hazardous waste from households via civic amenity sites should be introduced.
Furthermore public awareness raising campagnas and permanent education are essential.
6.1.2 Construction and demolition waste including excavated soil
The actual recovery and recycling rate of mineral C&D-waste is very low. In 2016 only
909 tonnes (less than 1%) of mineral C&D waste (without excavated soil) was reported as
recycled (R12), while the total amount is considered 238.982 tonnes.
For separate collected metals, wood and plastics a recycling rate near 100% can be calculated
by using statistical data on waste generation and reported data from recycling facilities.
However, only about 3% of C&D wastes are reported as metals (ferrous, non-ferrous and mixed
metals) and less than 1% was reported as plastics and wood waste. Thus to reach the objective
of at least 70% recovery for non-hazardous C&D waste the focus of measures is on mineral
C&D waste (group 17 01 and 17 03).
It seems inappropriate to introduce a specific collection system for mineral C&D wastes to
increase the recycling rate bearing in mind that C&D waste are generated at a specific site only
for a short time period and in a clear predictable amount.
The technical infrastructure for recovering mineral C&D waste is very similar to the technical
equipment of quarries (crusher, sieves). Also larger construction companies often have access
to such mobile equipment. Additional necessary equipment can be a metal separator, a wind
shifter device and a sorting device. The need of such additional equipment depends widely on
the quality of source separation at the construction site.
Due to the population shift in Serbia construction activities are concentrated especially in larger
urban areas. Thus a nationwide network of stationary C&D recycling installations is not the
adequate solution. Large transport distances on the other hand may jeopardize the
environmental benefit of the recovery operation. To serve the needs best a combination of
stationary facilities and mobile facilities that can process C&D waste at or near the place of
generation (where recovered material may be used directly in many cases) is the adequate
solution.
Given the situation that at least in the beginning investment costs will be rather moderate since
construction companies and stone quarry industry may use existing equipment the introduction
of a recycling schemes is more a question of introducing a stable and clear legal environment
for the recycling of C&D waste and the use of recycled material and providing incentives and
deter dumping of C&D waste at inadequate dumpsites.
The following steps could be taken in parallel to start an increase C&D waste recycling:
 A specific by-law on C&D waste regulating the recycling, the quality assurance and use
of recovered material. There should be the possibility included to license a mobile
facility that may operate at or near by a construction site for a clearly limited time to
avoid long transport distances;
 An obligation to recycle the mineral C&D waste can be introduced fixed on the amount
of waste generated at construction site. The trigger value for applying the recycling
obligation could be lowered stepwise so that in the beginning only large construction
activities are covered;
 To ease the application for a mobile installation a guidance document for the licensing
should be provided to the local authorities;

 To promote the use of recovered material a fixed rate of recycling material to be used
can be introduced in public procurement procedures (either by guidelines for public
procurement procedures or by applicable law);
 The dumping of C&D waste at inadequate dump sites should be stopped by
strengthening the inspection schemes.
C&D waste containing asbestos is covered by chapter 6.2.10. Non-hazardous waste like
organic waste, metals, cardboard, plastics, packaging generated during construction work but
not resulting from demolition/de-construction need to be collected and stored in separate
containers and need to be attached to existing collection schemes already established in
Serbia.
Non-hazardous mixed C&D waste which is suitable for recycling should be stored separately
and be transported to a suitable recycling facility. Low quality mixed C&D waste not suitable for
recycling needs to be transported to a registered landfill.
Since secondary wastes are generated during professional waste recycling and disposal
operations at various stages no specific collection system is necessary. However based on the
type of waste treatment operations consecutive further treatment options are required. Although
there exist a large number of licensed waste collectors and disposers
No profound data of secondary waste from waste treatment is available up to now which also is
related to the shortly introduced starting phase of waste treatment operations in Serbia.
For future time and following the implementation of measures defined for the period 2020-205
waste from waste treatment operations will be more prominent and may cover:
- Slags and ashes from waste incineration;
- Sorting residues from secondary mechanical sorting facilities;
- Sorting residues from biological treatment processes (MBT and composting);
- Digestate from anaerobic waste treatment;
- Recyclables from sorting and MBT for further material recovery operations;
- Output from MBT to be landfilled;
- Output from MBT to be further treated in incineration processes (incl. industrial
processes).
As those wastes are produced at waste treatment operators’ sites, the responsibility for
treatment ad handling is staying at the operator or may be forwarded to other licensed
operators.
Taking into account the waste quantity estimations for 2020/2024 and comparing these
quantities with the currently available infrastructure, the following conclusions concerning new
installations for hazardous waste management in Serbia can be deduced:
1. Establishment of separate collection and storage of hazardous household waste within

municipalities, operated mainly by municipalities in the context of “public amenity sites”;
regular evacuation to regional storage facilities.

2. Construction of regional storage facilities for hazardous waste in 5 regions of Serbia,

operated mainly by private operators of the waste management sector, often in the context
of treatment facilities; transfer to treatment facilities or to export.
3. Construction of a facility for physical-chemical treatment of inorganic and organic liquid
hazardous waste and sludge combined with storage units for liquid and pasty industrial
special waste streams like solvents, acids, bases etc. on the one hand and oily wastes and
solvents on the other; evacuation of residues to further treatment (RDF preparation), to
landfilling facilities or to export.
4. Establishment of capacities for incineration of organic industrial and medical waste,
eventually combined with capacities for the preparation of residues derived fuels (RDF)
from organic hazardous waste streams.
5. Establishment of capacities for landfilling of inorganic industrial hazardous waste eventually
combined with capacities for the solidification of pasty hazardous waste streams.
Establishment of separate collection and storage of hazardous household waste and

regular transfer to regional storage facilities
Hazardous and non-hazardous municipal waste should be collected in the same collection sites.
Citizens must be allowed to bring both types of waste to such collection points free of charge. In
the cities, it shall be necessary to determine accessible locations for the separate collection
schemes und to manage opening hours in a citizen friendly manner. Due to the small amounts
of collected hazardous waste quantities within these general municipal collection points and due
to the regular evacuation of such hazardous waste to intermediate regional collection centres it
should be possible to find such locations without complications.
The units within public amenity sites for the collection of hazardous household waste will be
equipped with containers for the collection of batteries, accumulators, small quantities of
pharmaceutical waste, stained packaging from paints and varnishes, detergents, pesticides,
waste oil, WEEE, tires etc. These units are integrated into the centres for separated collection of
recyclable waste and need especially well trained staff.
The bring-system can be supported by mobile collection units. This means that in remote areas
or in favour of less mobile citizens once or twice per year a truck collects such hazardous
household waste. This truck must be appropriately equipped and driven by trained staff. In this
case the citizens would be informed about location and opening hours of the mobile collection
unit.
Construction of regional storage facilities for hazardous waste in 5 regions of Serbia

In addition to the local municipal collection points for hazardous and recyclable waste at public
amenity sites, it shall be necessary to establish regional storages for hazardous waste,
intended for safe storage and preparation of such waste for further treatment or export. Such
facilities fulfil all requirements necessary for safe handling and storage of hazardous waste like
underground sealing, in-house storage, labelling and packaging rules, explosion and fire
abatement technology, ventilation etc.
Such hazardous waste storage facilities should be operated by private enterprises, experienced
in collection, transport, packaging, handling and/or treatment of hazardous waste and are driven
according to the rules of the market. Therefore such regional storage facilities might be part of
hazardous waste treatment facilities or work independently. Experience from other countries tell
us that such storage facilities often are accompanied by basic pre-treatment processes for the

collected waste streams like gravity separation of liquids in the tanks, filtering, conditioning of
liquids to meet certain calorific values, ventilation and collection of emanating gases etc.
Therefore such regional storage facilities have the function of transfer stations equipped for
temporary storage, repackaging, reassembling to larger transport units, preparation for transport
and further treatment and reload on bigger trucks for distance transport or even export .
The transfer station shall also be the place where the hazardous household waste from
municipal collection units is unloaded from the vehicles, inspected with optional separation of
inconvenient waste types, reloaded into bigger vehicles and transported for further treatment.
Transport of waste by a higher-capacity vehicle significantly reduces the long-distance transfer
costs.
Potential locations for regional waste management centres, criteria and guidelines for their
foundation shall be planned through spatial plans of authorities, while the definite locations will
be selected by the future operator after the investigation works and carrying out the procedure
of environmental impact assessment. In order to define potential locations for the construction of
the mentioned storages and to give certain security for the private investment, it shall be
necessary to analyse the regional needs in terms of origin, type and quantities of hazardous
waste to be stored.
The final decision is depending on more detailed planning steps concerning regional needs and
willingness of private operators. Extension of the source separation of hazardous waste in
commerce and industry is necessary in order to improve the efficiency of all other waste
management steps that follow. In other words, without source separation waste management
options get much more expensive and technically much more sophisticated because such
difficult mixtures are difficult to separate in a later stage of evacuation. Therefore activities must
focus first of all to the:
 Development of a set of economic instruments to support source separation and
recycling in industry and commerce; and the
 Development of technical solutions and specifications for the equipment for source
separation within the collection and storage sites.
Construction of a facility for physical- chemical treatment of liquid hazardous waste and
sludge combined with storage units for liquid and pasty industrial special waste streams
like solvents, acids, bases
Having in mind the data concerning type and quantity of generated hazardous waste in Serbia
and considering the future changes in the industrial sectors of the Republic of Serbia, the need
for the construction and operation of a physical-chemical treatment facility for hazardous waste
is obvious. As a part of the project “Technical assistance in preparation of documentation for the
construction of the facility for physical-chemical treatment of hazardous waste”, funded from the
EU pre-accession funds – 2009 program cycle, a feasibility study had been develop to take into
consideration several locations for construction of such a facility for physical-chemical treatment
in Central Serbia the need was focused on the region that convers Moravički, Šumadijski,
Pomoravski, Raški and Rasinski administrative county. Private investment should be stimulated
by public securities in order to overcome economic uncertainties that usually accompany such
investments in comparable situation.
Capacity should be developed stepwise and in a modular way. Finally, the capacity of the
facility for physical-chemical treatment of hazardous waste should cover the need of
approximately 50.000 tonnes per year based on the overall quantity of appropriate hazardous

waste types generated in the Republic of Serbia annually. The facility should comprise all
necessary (and commonly established) elements for the treatment of organic and inorganic
hazardous waste. An appropriate laboratory is an integral part of such installations.
It is up to the private investor to decide if other elements like solvents distillation facilities or
silver electrolysis (for photographic liquid residues) should be added and if this centre includes a
landfill with cassettes for hazardous and non-hazardous waste.
Technical documents needed for the authorization and construction of this facility shall define
for all units within the facility the appropriate technology and capacity needed, as well as
organizational and operational characteristics of the facility, all this in compliance with the
international standards and the state-of-the-art like defined in the BAT reference documents for
waste treatment.
Establishment of capacities for incineration of organic industrial and medical waste

(2022) eventually combined with capacities for the preparation of residues derived fuels
(RDF) from pasty hazardous waste streams
Incineration plants for hazardous industrial waste, including medical waste shall be considered
in the forthcoming period in accordance with the needs and capacities of the existing facilities
(cement plants, thermal power plants, heating plants, etc.). Needed capacities for RDF re-use
from waste oil amounts to approx. 22.000 tonnes per year and additional capacities for RDF
valorisation resorting from sorting, dismantling and physical-chemical treatment facilities will
amount to approximately 10.000 tonnes per year additionally.
Production capacities of the existing facilities with the option of thermal treatment of waste
(cement plants, steel mills, thermal power plants), may be used for co-incineration of certain
types of waste, if they meet all the requirements prescribed by legal regulation. But due to the
urgent need of additional capacities for quite a number of organic hazardous waste, the
possibilities and conditions for using the existing plants and installations should be promoted
actively by the competent authorities. It must be a concern for the whole Serbian industry to find
a way how and where to find opportunities for such energetic use of hazardous waste in
industrial processes. The preparation of permits should begin at once in close cooperation
between competent authorities and industry defining the requirements that must be met for the
energetic use of such waste.
Related ad-hoc measures to be accomplished are:
1. Public and industry awareness campaign regarding the benefits of using waste as an
alternative fuel and as an alternative raw material;
2. Feasibility study for the use of waste as an alternative fuel (oil waste and oil sludge,
tires, solvents, other organic waste etc.);
3. To draft technical standards for the use of waste as fuel;
4. To develop existing production facilities and technology (BAT application) for the
usage of waste as an alternative fuel.
In the long-term period and with more data available about the related need, Serbia could focus
on the establishment of a central plant for hazardous and medical waste incineration. Residues
like packaging waste polluted with hazardous substances (e.g. packaging waste polluted with
pesticides, chemical substances, PCBs etc.) that must not be burnt in cement plants will need
such incineration otherwise these wastes have to be exported for a long time.

Establishment of capacities for landfilling of inorganic industrial hazardous waste

eventually combined with capacities for the solidification of pasty hazardous waste
streams
The mechanisms for resolving historical pollution, and/or removal of damage to environment
due to inadequate waste management should be developed. It is necessary that the sites
polluted with hazardous waste should be identified, risk assessment should be made and the
priorities for rehabilitation identified. It is also necessary that the obligations of all participants
should be identified (Republic, province, local self-government, operator, owner) for carrying out
the rehabilitation process.
The regional waste management plans will precisely define waste management needs in
conformity with the EU Directives and with guidelines from the National Waste Management
Strategy. It is of particular importance to establish these guidelines on the basis of the very
stringent requirements of the EU Directive 99/31/ЕС on landfills and to follow the new criteria for
evaluation and choice of landfill locations in conformity with these regulations. The design
studies on waste type, waste quantities and landfill technology must be harmonized with the EU
Directive on landfills. Other basic objectives in the development of the regional concepts shall
be rational use of space as a resource and reduction in costs of waste management.
Present estimations based on prognostic numbers of waste generation amount to 30.000 to
40.000 tonnes per year to be landfilled in hazardous waste landfill units. The quantity is highly
influenced by mineral residues deriving from mining activities, which apparently generate waste
with hazardous properties; they are not included in above mentioned capacity need. The
quantity will also be influenced by wastes related to removal of historical pollution and
remediation of contaminated sites. Experience from other EU MS shows that the expected
quantity of mineral hazardous residues generated by multiple industrial and commercial
activities could be even higher than above mentioned prognostics implicate. Asbestos arising
from C&D waste is not added in this amount, because such waste can landfilled in lower
classes of landfills e.g. in separate cells of municipal landfills.
It is out of question that a hazardous landfill is needed for the multiple types of mineral and
mineralized hazardous wastes: The more the hazardous and non-hazardous waste
management infrastructure proceeds, the more increases the amount of residues from waste
treatment processes that need an appropriate further disposal. The more the rehabilitation of
contaminated sites proceeds, the more increases the amount of treatment residues that need
hazardous landfilling. It has been identified that urgent hot spots contaminated by hazardous
waste to be rehabilitated are in Bor and Pančevo, primarily. It could be wise to combine such
rehabilitation works with the installation of a hazardous waste landfill. Other possibility – in a
more regional approach - could be to integrate hazardous waste landfill cells in other (municipal
or industrial) landfills.
6.1.5 Sewage sludge
The following table (Table 56) provides an overview about the required transportation capacities
for different final sludge qualities.
Table 56: Transportation capacities
Sludge Quantity and
85 %-Percentile 50 %-Percentile
Transportation Volume
Total Annual Sludge
135.190 t/DS/yr 115.390 t/DS/yr
Production Stabilized

Dewatered
540.800 m3 461.600 m3
Sludge (average) 25 % DS-
595.000 t-vol. 508.000 t-vol.
conc. 1.100 kg/m3
Dry Sludge 30% VDS 112.884 t/DS/yr 96.351 t/DS/yr
decomp. 70 % DS-conc. 161.300 m3 137.600 m3
1.500 kg/m3 242.000 t-vol. 206.000 t-vol.
Sludge Ash
79.357 t/DS/yr 67.735 t/DS/yr
(mono-incineration) 99%
82.700 m3 70.600 m3
VDS decomp. 96 % DS-conc.
149.000 t-vol. 127.000 t-vol.
1.800 kg/m3
The aforementioned transportation capacities might require approx. 35.000 truckloads (3- axle
tipper, max 15 t) for dewatered sludge, equal to approx. 15.000 transports of dry sludge and
less than 10.000 transports for sludge ash which demonstrates the environmental impact and
carbon footprint of sludge transportation, depending on the final product quality and quantity.
However the transport distances differ depending on the location of the treatment plant (Mono-
incineration plant, co-incineration, composting plant) and the final destination of the sludge
(ashes from mono- or co-incineration to landfill; compost e.g. to agricultural field, direct
application of sludge in agriculture, etc.) and therefore influence the environmental impact. In
case of drying the sludge also the technology of drying (only solar drying, thermal drying, use of
waste heat e.g. from biogas plants, etc.) modifies the total impact as e.g. thermal drying
requires relevant amounts of energy.
Table 57: Expected annual sludge production on administrative district level

WWTP 85 % - 50 % -
No. Region Capacity Percentile Percentile
2041
0 Subdivisions of Belgrade 2,170,000 37,300 32,550
Šumadija and Western Serbia
1 Kolubara District 144,200 2,840 2,320
2 Mačva District 239,700 4,600 3,900
3 Moravica District 199,500 3,780 3,270
4 Pomoravlje District 176,500 3,500 2,840
5 Rasina District 223,800 4,240 3,690
6 Raška District 314,000 5,860 5,160
7 Šumadija District 356,100 6,210 5,390
8 Zlatibor District 230,500 4,600 3,760
Southern and Eastern Serbia
9 Bor District 97,200 1,950 1,590
10 Braničevo District 139,300 2,840 2,360
11 Jablanica District 205,300 3,860 3,390

12 Nišava District 316,100 6,240 5,060

13 Pčinja District 186,200 3,710 3,020
14 Pirot District 68,900 1,430 1,180
15 Podunavlje District 187,100 3,550 3,070
16 Toplica District 70,300 1,430 1,170
17 Zaječar District 92,500 1,880 1,530
Autonomous Province of Vojvodina
18 Central Banat District 177,600 3,350 2,950
19 North Bačka District 186,500 3,490 3,080
20 North Banat District 114,800 2,330 1,910
21 South Bačka District 725,000 12,820 11,070
22 South Banat District 266,100 5,110 4,420
23 Srem District 264,500 5,210 4,230

24 West Bačka District 155,600 3,060 2,480
Total Design Capacity and Sludge 7,307,300 135,190 115,390
Production
District No. 21 (Novi Sad) and the Belgrade Metropolitan Area will require the highest sludge
disposal capacities. With the exemption of districts No. 6, 7 and district No. 12 (Nis) which
require sludge disposal capacities > 6.000 t DS/yr. the majority of districts requires capacities in
a range of 2.000 - 4.000 t DS/yr. Four districts, No. 9, 14, 16 and 17 will require lower sludge
disposal capacities and might be subject to intercommunal cooperation.
It should be noted that the aforementioned quantities refer to the sludge quality of stabilized
sludge usually produced on the WWTP. Further sludge treatment such as composting, long-
term storage in reed beds as well as additional thermal treatment, e.g. sludge drying and sludge
incineration, will significantly reduce the final content of organic matter which consequently will
reduce the ultimate sludge quantities.
To ensure that sewage sludge is managed in accordance with the waste management
principles and waste management hierarchy (Waste Directive 2008/98/EC, Art. 4.1) the
consequent approach is summarized hereinafter:
Table 58: Sludge treatment principles

Prevention Reduce sludge Advanced wastewater treatment process.
quantity.
Preparing for Reduce sludge quantity, Sludge stabilisation and dewatering, sludge drying and
reuse combustion (thermal use) under consideration of P-
improve quality.
recovery options. Consider disinfection for land
application.
Recycling COD* and nutrient Anaerobic digestion with biogas (COD) production, of

recovery. Recovery options.

Recovery Extract Phosphorous Heat/power recovery from biogas,
and/or reuse of energy
P-extraction from liquid or dry phase,
(COD).
Nutrient recovery by alternative processes (sludge to
coal, etc.).
Use in Agricultural (direct application, use as compost)
Disposal Final deposition of Mono-landfill of dry granules and ash to allow for future
residual matter (sludge
urban mining (P-recovery.
residue).
* Chemical Oxygen Demand
A national sludge management strategy has been developed to assess possible ways of
treating sewage sludge.79 Applicable sludge treatment options are summarized by the following
table.
How to read the following table: does it mean that for each category only the stabilisation methods
and sludge treatment are applicable or is the intention to give examples how it could be (e.g. use of
CHP or CCHP, or sludge disintegration)?
Table 59: Sludge treatment options

Cat. Capacit Sludge Stabilisation Sludge STC/SMC Final Remarks
y Treatment Disposal Disposal
[P.E.]
A ≤ 2.000 Cold anaerobic Long-term storage Humus after Land
of 10 application,
(psychrophilic) digestion
transport to
digested & yrs.
& thickening. STC.
thickened
sludge in reed
beds for
sludge
humidification;
Storage for liquid
transport or
service
dewatering.
B a≤ Extended aeration Reed beds Humus after Land
(humidification); 10 application
10.000 or separate aerobic
Storage for yrs. to STC
digestion.
service-
Sludge cake
dewatering.
79
National sludge management Strategy and implementation Plan – final draft 2018 December

C b≤ Single stage anaerobic Solar sludge Transport of Mono-landfill Avoid aerobic

drying;
50.000 digestion granules or to STC stabilization.
Sludge
wherever possible Sludge cake
dewatering.
with CHP.
d c≤ Single stage anaerobic Solar or thermal Transport of Mono-landfill Extra capacity
STC
100.000 digestion with sludge drying; granules or to STC for co-
treatment
CHP. Sludge Sludge cake
from cat. a-e
dewatering.
required.
e d≤ Single stage anaerobic Solar or thermal Transport of Mono-landfill
STC or
150.000 digestion with sludge drying; granules or
SMS for
sludge disintegration, Sludge Sludge cake.
incineration.
dewatering.
CCHP.
to SMS.
f e≤ High-rate anaerobic Thermal sludge Transport of Mono-landfill
SM drying. or
250.000 digestion granules
C
SMS for
(CCHP) with sludge
incineration.
disintegration.
g ≥ High-rate anaerobic Mono- Transport of Mono-landfill. Final capacity
SM 250.000 incineration.
digestion ash. for cat. a-g
C
incineration.
(CCHP) with sludge
disintegration.
Option MAP extraction Co- Transport Solid waste P-recovery
(Recovery incineration. of landfill. during
from liquid ash. sludge
phase) treatment.
It should be noted that these targets are on the ultimate sludge treatment and disposal options
for the projection horizon (2041). Temporary and short-term solution must be defined prior to
completion of sufficient regional mono-landfill capacities and the completion of a certain number
of regional sludge incinerators. In addition to its use on agricultural land, sewage sludge has
been employed successfully for forestry and in land reclamation operations, such as for disused
mines or closed landfills. These alternatives should be considered before considering
installation of mono-landfills. Furthermore, ways for application or treatment or disposal of
sewage sludge in other contexts (e.g. landscaping, incineration, temporary landfill with the
purpose of future mining) may be foreseen. For the purpose of the future estimations an
average final sludge production rate of stabilized sludge shall be set to 45 g DS/(P.E./d) on the
50 %-percentile basis.
Table 60: Expected sludge production rate per P.E./day

Annual mean specific sludge Design Capacity Digested Sludge

quantity for different [P.E.] [g/(P.E.xd)]
WWTP Categories
DS 85% DS 50%
Small WWTP's 2.000 - 10.000 55 45
Middle Sized WWTP's 10.000 - 100.000 52,5 42,5
Main/Big Sized WWTP's ≥ 100000 45 40
Mean average digested sludge production 51 42,5
Adopted average digested sludge production 55 45
Overestimation of the final sludge quantities should be avoided as it would lead to expensive
and unused overcapacities of the facilities. Therefore, it is recommended to apply the 50 %-
percentile value for the determination of sludge drying and sludge incineration facilities as well
as for the ultimate disposal capacities. The 85 %-percentile should be applied for the design of
the sludge handling and processing facilities at the WWTP, only.
6.2 Assessment for special waste streams
Separate collection is one of the most important pre-requisites for an efficient management and
recycling/recovery of packaging waste management.
Separate collection at source is implemented only by several municipalities and even not carried
out on all their administrative territory. By that it is essential to go toward and adopt the
necessary legal and technical measures to ensure that all packaging waste materials are
collected selectively and have the requested quality for further recycling and recovery.
The local authorities should be allowed to deviate from the general obligation to separately
collect recyclable waste by type and nature in other duly justified cases, for instance where the
separate collection of specific waste streams in remote and scarcely populated areas causes
negative environmental impacts that outweigh its overall environmental benefits or entails
disproportionate economic costs. These authorities when deciding by regional waste
management plans, should asses if the economic costs between separately and co-mingled
recyclables80 collection might be disproportionate by considering the overall economic benefits
of separate collection, including in terms of avoided direct costs and costs of adverse
environmental and health impacts associated with the collection and treatment of mixed waste,
revenues from sales of secondary raw materials and the possibility to develop markets for such
materials, as well as contributions by waste producers and producers of products, which could
further improve the cost- efficiency of waste management systems.
Considering the reported quantities of metal or plastic waste from the existing recycling/recovery
capacities do not need to be extended. For other packaging waste the need for additional
capacities might be assessed due to implementation of source separation and collection. E.g.
80
Plastic packaging waste might be collected together with cans because by mechanical separation can easily separate
them. On the other hand glass packaging waste and paper and cardboard waste if are mixed are becoming improper
for further recycling.

packaging glass recycling is performed in just one facility which is confronted with difficulties.
Wood waste is used in heating processes (as briquettes & pellets) or cement kilns to limited
extend. Generally, wood packaging, particularly pallets, are reused (repaired) as often as
possible during their use phase. When cannot be used anymore the most common recycling is
the production of panel boards.
From the limited data availability, however, it seems that the door-to-door separate collection is
the most expensive system in terms of running costs but all other systems being approximately
at the same level. It also seems, though, that establishing a door-to-door separate collection
system is cheaper than the bring points system. Overall, civic amenity sites bring the lowest
costs, although the capture rates for the five analysed materials are small for this system. It
should be reminded that civic amenity sites are primarily established for the collection of other
materials, such as bulky waste, WEEE etc.
EU capitals use various sources of funding for the separate collection, primarily waste fees from
the citizens, but also producer responsibility schemes, sales of the collected materials or Pay-
as-you-throw (PAYT) schemes. These sources of funding differentiate according to fraction
collected: usually more valuable materials such as metal are cheaper to the consumer than
others. Some cities (e.g. Ljubljana and Budapest), in order to incentivise separate collection use
fees from the residual waste collection to fund separate collection activities: fees are set only on
residual waste and providing the service of collection of recyclables without user charges.
In order to increase the collection of end-of-life vehicles, an adequate number of authorized

collection/take back points shall be made available for the citizens and covering all the country’s
territory. The take-back system for end-of life vehicles is explicitly required to be cost free for the
consumers.
Extended Producer Responsibility (EPR) schemes need to be established in order that the
manufacturers/importers of the vehicles on the national market take the full responsibilities for
the collection, storage, treatment, and recycling/recovery of ELV.
Collected ELV should be depolluted and dismantled by garages and dismantled by authorized
waste treatment operators. Shredder processes will process the depolluted/dismantled.
While the potential of collectable waste oil can be estimated in the range of 25.000 to 37.000
tonnes per year the amount of collected waste oil reported in 2016 was 3.507 tonnes (about
14% of the potential only. Additionally another 4.974 tonnes of emulsions and other oil/water
mixtures were reported to SEPA. Regarding the treatment of mineral oil 2.875 tonnes were re-
ported as recovered/recycled (R9) and while 1.531 tonnes were incinerated (R1) as secondary
fuel in the cement industry. Since illegal disposal of mineral oil poses a serious threat to the
environment the main focus shall be to increase the collection rate from professional uses as
well as from private persons.
The collection of waste oil from professional uses as well as the intermediate storage at the
point of generation is well regulated in the Rulebook on terms, manner and procedure of waste
oil management. However there is the need to enhance compliance with the existing legal
requirements by strengthening inspections of companies potentially generating and collecting
waste oil.

A relevant amount of waste oil is generated by private persons (“do it yourself” activities in car
maintenance). According to the Rulebook the seller is obligated to provide the end user with
information where he can return waste oil free of charge. This scheme is not sufficient consumer
friendly at the moment. To increase the amount collected from private persons a collection via
the civic amenity sites to be installed at municipality level combined with awareness raising
activities are requested.
The existing treatment capacity (thermal treatment as well recycling) exceeds the amount
collected at the moment widely. According to available data the potential treatment capacity can
be estimated in the range of 25.000 t for recycling/recovery and 16.000 t for energy recovery.
Although these theoretical capacities are based on older data on licenses and are not in use at
the moment within the planning period of the WMS the available treatment capacities are
sufficient and the focus of the activities related to waste oil is to increase the collection rate by
the measures described above.
6.2.4 Waste tires
Waste statistics (see chapter 2.5.3) show that in 2016 there was a good balance between the
amounts of tires placed on the market and collected and treated wastes tires, while in previous
years the amount of collected/treated waste tires was lower. However collection of used tires
also via civic amenity sites may slightly increase the amount of collected waste tires and reduce
the risk of illegal disposal (e.g. at dump sites).
The Rulebook on manner and procedure of waste tires management (“Official Gazette of the
Republic of Serbia“, No. 104/09, 81/10) request 80% recycling and only 20% energy recovery.
However in 2016 a share of 31% of treated waste tires was not recycled but used for energy
production (R1). To reach the goal of 80% recycling additional capacities for material recycling
(i.e. retreading or mechanical separation in secondary rubber, steel and textiles) may be
required. The installation of these additional capacities should be market driven.
Whether WEEE will be recycled at end of life (or simply disposed of as part of residual waste)
depends on the nature of the infrastructure made available for recycling. The appropriate nature
of the infrastructure for dropping off products for recycling also depends on the nature of the
WEEE concerned. For large WEEE from municipal waste, many EU Member States are reliant
on a network of local recycling centres (amenity sites). In case of Serbia the DSIP on landfilling
is planning 169 such centres which will be operational until the end of 2031.
Therefore, until they are, such materials are likely to be of interest to scrap dealers, and may be
picked up through other routes, or when new products are purchased by households. The
development of recycling centres is a matter which local governments should consider as part of
their waste management plans.
Fluorescent tubes are a part of the WEEE waste stream. Although these are specific technical
requirements for the save collection (to avoid breaking and thus mercury emissions) there is no
need of a separate collection scheme.

For batteries, similar comments apply as for small WEEE (and pan-regional systems). The
main, and most efficient, mechanism for return of portable batteries is likely to be a return-to-
retail system. As such, the system should be oriented towards such an approach, though there
may be circumstances and collection configurations that suggest, and allow for, door-to-door
collection of batteries.
As soon as relevant amounts of waste portable batteries and accumulators are collected the
establishment of a sorting facility for mixed portable batteries might be feasible.
6.2.8 PCB waste
PCB waste as defined by THE RULEBOOK ON TREATMENT OF DEVICES AND WASTE CONTAINING PCB
is generated during professional activities such as maintenance operations of electrical
installations, etc. The LWM as well as the applicable rulebook defines very well the obligations
of the waste generator. Thus no specific collection system is requested for the collection of PCB
waste as defined in the rulebook. According to SEPA six companies have a license for the
treatment of PCB-containing transformers and capacitors. The amount generated per year is in
the range of 200 tonnes at the moment. Since there is no disposal option for the PCB contains
material/residues available in Serbia at the moment export of these wastes for final disposal is
the adequate option.
The option of constructing a hazardous waste incinerator in Serbia (see chapter 6.2.4) within the
next six years would gain self-sufficiency for the final disposal of PCB waste.
According to SORS about 23 t of PCB containing waste were generated in the building and
construction sector in 2016. These amount may include also PCB contaminated soil and
construction material. For even possible increasing amounts of such wastes from clean up
procedures export to specialised treatment installations may stay the preferred option even if a
hazardous waste incinerator is available in Serbia in the future.
POPs wastes are not a homogenous waste stream. Therefor no specific collection system is
appropriate for these wastes. A relevant part of POPs wastes are stockpiles of outdated
pesticides. In accordance with the LWM there is the obligation of the waste generator to hand
over such wastes to a licensed collector. For amounts in store at private households the
collection system for hazardous waste from households via the civic amenity sites to be
constructed in accordance with this strategy at the level of municipalities is an adequate and
sufficient collection scheme. At the moment export of the not significant amounts of collected
(POPs) pesticides for thermal treatment is the adequate treatment option while in the mid-term
self-sufficiency may be gained by installing an incinerator for hazardous waste.
From the new POPs wastes plastics containing brominated flame retardants (BFRs) are the
most relevant part. These wastes are generated in professional activities (during dismantling
and treatment of WEEEs and ELV) mainly. Thus no specific collection system is requested.
Since in the majority the POPs content of plastic with BFRs doesn’t trigger a hazard
characteristic in accordance disposal via co-incineration in industrial plants is a feasible disposal
option in Serbia.

Asbestos containing wastes are generated during professional activities (maintenance and
demolition work) as well as by private activities (“do it yourself” refurbishment). There is no need
of a separate collection system for asbestos wastes from professional activities. Nevertheless
supervision of these activities is necessary to enhance the compliance with the already existing
legal obligation of separate collection and safe disposal. Furthermore it is necessary to focus
the public on the risks and problems associated with unsound management of asbestos and
provide a separate collection for small amounts of asbestos wastes from private activities (e.g.
asbestos heat shields, electrical equipment containing asbestos, asbestos cement products).
Such a collection is not specific for asbestos waste but should be part of a general collection
system (bring-in system at recycling yards) for hazardous wastes from households.
For the sound management of asbestos waste an adequate infrastructure is essential. In this
sense infrastructure means both, adequate technical equipment and installations for the save
handling of asbestos as well as a trained staff. The personnel involved in the disposal of
asbestos containing wastes need to be trained in both, identification and safe handling of
asbestos wastes. Beside the persons authorized to remove asbestos and asbestos containing
wastes also other professionals who may come into contact with asbestos/asbestos containing
products during their activities need to be trained to identify asbestos/asbestos containing
products.
6.2.11 Medical waste and pharmaceutical waste
Considering those presented in Chapter 2 - The current state of the main problems identified
(assessment of the existing situation) and Chapter 4 "Types, quantities and origin of waste,
including estimation on the generation of medical (including veterinary) and pharmaceutical
waste", the main needs (the measures correspondent was detailed in Chapter 12) refers to:
- an sustainable management system (with related infrastructure, pre-treatment where is
necessary , cost control, monitoring and reporting system);
- an integrated data bases with access to all relevant Serbia ministries;
- national collection network points for pharmaceutical waste (expired or inappropriate for
human or veterinary use), to ensure a proper separate collection system (including their
packaging) ;
- economic incentives to move away from disposal etc.;
- Extended Producer Responsibility (EPR) scheme in order that the
manufacturers/importers of the pharmaceutical products on the national market, to fulfil
the responsibilities for collection, temporary storage, treatment;
- training of medical staff for separate collection in healthcare institutions (including
veterinary institutions);
- awareness campaigns, with a clear message related to environment and health for
improving citizens' involvement in the process of separate col-lection of pharmaceutical
waste;
- environmental inspection in link with the management of medical and pharmaceutical
waste, in order to achieve the legal requirements and avoid the negative impact on
environment or the risk on the population health.

There is no recent generation of this waste in Serbia.
6.3 Assessment of the needs on specific infrastructure and treatment

options
Waste management of municipal waste is considered as an “activity of general interest” and can
be conducted by either public enterprises under the Law on Public Enterprises (2016) or
privately-owned companies and in that case the delegation of activities is performed in
accordance with the Law on Public Private Partnership and Concessions (2011).
In the majority of cases the waste management operators are either Public Enterprises/Public
Utility Companies (PUCs) or publicly owned Limited Liability Companies (DOOs). These
companies are managing assets that remain in the ownership either of individual municipalities
or shared between founder municipalities based on inter-municipal cooperation agreements (IM-
CAs).
The responsibility for establishing the proposed management system for municipal waste
(including the system for collection and treatment and providing the public amenity sites) lies at
the level of individual municipalities or IMCAs.
Waste other than municipal waste needs to be managed under the responsibility of the waste
owner. The waste owner may entrust an operator with valid waste collection/storage/treatment
permit to further manage the respective waste. Producer responsibility is applied to some waste
streams and also influences the way waste is managed.
In 2017, Serbia had 6 cities with city municipalities (Novi Sad, Beograd, Požarevac, Niš, Vranje,
Užice) comprising 30 urban municipalities. In addition, 21 cities with only one urban municipality
each and 147 rural municipalities are located on the territory of Serbia. Summarized, this results
in 198 municipalities in total (divided in 51 urban and 147 rural) (Statistical Pocketbook Serbia
2018, SORS).
6.3.1 Source separation and collection system for households
The collection of municipal waste can in principle be carried out in two ways, the waste is
presented to collection points by the inhabitants themselves or the waste collection is carried
out by a detour. The preferred method should be chosen in accordance with the local situation,
taking into account the population density, the population structure, the amount of separate
collected fractions, etc. Depending on a geographical region (whether there are more villages
with less population or urban agglomerations with block apartments or separate houses etc.),
are combined. The decision whether to implement one or another scheme, or a combined
solution, depends on local public authorities.
 „PICK – UP “collection directly from holdings (mixed municipal waste, packaging waste,
hazardous household generated waste);
 „BRING“ residents bring waste;
o Collective used container sites (mixed municipal waste, paper, plastic, glass, metal,
textile, separately collected food waste);
o Amenity sites (all types of waste, including bulky and hazardous waste);
o Green waste sites (green waste from gardens, city parks and etc.);
o Deposit (reusable and disposable beverage packaging);
 Other collecting systems (e.g. single or multiple social events).
The separate collection may be conducted using a:

 Door to door bin/bag collection system from single houses and buildings with multiple
flats;
 Bring-systems:
o Near entry bring
 Flats with communal (i.e. shared) bins;
 Bins are very close to building entrance, or within communal areas within
the building, or in attached bin stores (collection points);
o On-street bring;
 Communal containers serving multiple buildings in parking areas / on the
side of the street
Experience shows, as a matter of convenience, the closer the collection bin is located to the
point of its origin, i.e. the individual household the better the quality and the higher the capture
rates of the recyclables. At first instance this is the case for bio-waste.
To force recycling and source separation for households and similar establishments an
appropriate collection system for collection needs to be established. Source separation at
household level should be organised via bin/bag system at least for following waste streams:
 recyclables including specific special waste streams such as packaging waste (metals,
plastics, glass, paper and cardboard, wood);
o Covering glass and glass packaging waste
 bio-waste (food and garden green waste);
 Non-hazardous residual mixed municipal solid waste.
In order to enable further material recovery the separated recyclables and packaging waste
shall not be contaminated e.g. with hazardous substances and/or food residues. Source
separated bio-waste shall not be contaminated e.g. with packaging or non-organic materials.
Table 61: Examples of source separated municipal waste collected either by door-to-door
collection or by bring systems
Packaging and non-packaging glass waste
Packaging: Glass bottles of all sizes and colours (without caps); Jars (without lids); other glass packs
and breakdown.
Non-packaging: Glassware, vases and other glass products.
Packaging and non-packaging paper and cardboard waste
Packaging: Cardboard of all kinds, its sheets, corrugated cardboard boxes and carton boxes;
Paper bags, bags, packing paper; other cardboard and paper packaging.
Non-packaging: Newspapers, magazines, envelopes, leaflets, flyers and other printed matter
Notebooks and books (no hard cover); other printed and writing paper.
Packaging and non-packaging plastic waste
Packaging: PET (polyethylene terephthalate) packaging: plastic bottles, bowls, boxes and other
containers for beverages and other foodstuffs, animal feeds, household appliances; plastic lids and
caps
plastic bags and films; PET and PP fastening strips; other plastic packaging (with stamped PET, HDPE,
PE, LPPE, PP, PS labels).
Non-packaging: Polyethylene film, plastic utensils.
Packaging and non-packaging metal waste
Packaging: Cans from beverages and other food products, animal feeds, household appliances;
Cans and other metal boxes; Metal lids and caps; Metal fastening strips.
Non-packaging: Metal utensils and tools, baking tins and other metal waste.

Packaging and non-packaging wood waste

Packaging: Wooden crates and boxes; Wood packaging and components for fastening and
transportation of goods.
Non-packaging: furniture, Ice-cream sticks, Wooden utensils and products.
Combined packaging waste (predominant material - paper and paperboard)
Cardboard beverage packaging for juices and dairy products (Tetra Pak, Pure-Pak, etc.).
Bio-waste and green waste
Food residues and former food stuff; Cut offs from food preparation and kitchen activities; Green
waste from gardens and parks; Grass/leaves from plants.
Bulky waste
Waste consisting out of a mixtures of different materials (glass, wood, plastics) or one single material,
being too large to be accepted by the regular waste collection.
Hazardous household waste
Batteries, accumulators, small quantities of pharmaceutical waste, stained packaging from paints and
varnishes, detergents, pesticides, waste oil, WEEE etc.
In a fully developed EPR-scheme producers and importers are responsible for collecting and
managing packaging waste and the local authorities are responsible for the management of
other municipal waste. The development of separate municipal waste collection systems
requires co-operation between municipalities and organizations managing packaging waste
(see Chapter 9). The decision to introduce the appropriate collection system is upon the
municipalities involved in the establishment of the waste management system for municipal
waste.
 Up to 2025 in minimum in all municipalities of the following thirteen waste management
regions the collection system from households and similar establishments should be in
operation (Subotica; Vranje; Kruševac; Užice; Pančevo; Pirot; Sremska Mitrovica; Nova
Varoš; Novi Sad; Kragujevac; Zrenjanin; Valjevo; Beograd).
Therefore, targeted information campaigns on separate collection to enable active participation
of the public and citizens will be carried out. This may comprise an initial letter to the
households to inform the people on the materials/waste which can be thrown into provided
bins/bags each, and especially to raise awareness that hazardous materials/waste are
prohibited from the bin/bag collection and needs to be actively separated and brought to the
public amenity sites via bring system.
The establishment of the collection system should be based on a feasibility study in terms of
which bins/bags are needed to collect different waste streams from households separately
taking into account the different necessities for rural and urban regions. The collection system
might differ in the way of practically implementation (e.g. in terms of the numbers, types and
volumes of provided bins/bags for specific numbers of households as well as minimum
frequency of collection).
 All municipalities of the territory of Serbia should be provided with the collection system
from households and similar establishments until 2035.
While the obligation to separately collect waste requires that waste be kept separate by type
and nature, it should be possible to collect certain recyclables waste types together provided
that this does not impede high-quality recycling in line with the waste hierarchy in accordance
with the provisions in Article 10(2) and (3) of Directive 2008/98/EC (e.g. plastics and metals
together in a bin/bag). Others, such as paper or glass should be considered to be collected in a
separate “paper” bin/bag with a view to purity and the needs of high quality recycling.

Waste transportation is one of the essential elements of waste collection systems, it is one part
to consider for waste management pricing. The number of trucks has to be estimated based on
the specific features of each region, including the planned amount of waste collected per shift,
the daily amount of waste generated in the municipality, the annual amount of generated waste,
waste collection frequency, the number of households, etc. When defining the needs for further
vehicles the age and capacity of existing collection fleets infrastructure has to be taken into
account. In addition separate vehicles or compartments within one truck are needed for specific
waste fractions (such as bio-waste, paper or glass).
6.3.2 Public amenity sites (bring-system)
In addition to the bin/bag collection system, a network of public amenity sites needs to be
established on the territory of Serbia at municipality level. Each municipality should provide in
minimum one public amenity site to which defined waste streams including hazardous waste
from households can be brought to without charging citizens for the waste received at the
amenity site. The takeover should be free of charge if the amount of waste is typical and
comparable to the amount generated by households. Following waste streams are covered to
be received at public amenity sites:
 Bulky waste;
 Green waste (e.g. from cuttings in gardens and parks including grass and leaves);
 Packaging waste (including waste from special waste streams such as metals, glass
plastics, paper and cardboard, wood);
 Hazardous waste from households (including waste from special waste streams such
as WEEE, used batteries and accumulators, waste oil, medical and pharmaceutical
waste);
 Proper packed small amounts of asbestos containing waste (small scale storage
possibility).
The collection system of hazardous household waste at public amenity sites will be equipped
with containers for the collection of waste such as batteries, accumulators, small quantities of
pharmaceutical waste, stained packaging from paints and varnishes, detergents, pesticides,
waste oil, WEEE, tires etc. The public amenity sites will be operated by trained staff. It needs to
be ensured that all the waste collected at amenity sites is handed over only to registered and
licensed operators with valid permit to transport/treat the respective waste.
 Public amenity sites are established to a very low extend in 2017 and up to 2025 in all
municipalities of minimum thirteen waste management regions public amenity sites should
be established operated by the local municipality (Subotica; Vranje; Kruševac; Užice;
Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin; Valjevo;
Beograd). All municipalities of the territory of Serbia should be provided with amenity sites
until 2035. Table 62 provides criteria to select a location for public amenity site.
Table 62: Amenity site place selection criteria

Factors to be evaluated Criteria
Access road Length, condition, maintenance conditions (other road users)
Accessibility for the residents Simplicity of the route, walking distance
Access to the main road Does the route go through the city; distance to main road
Electricity Accessibility

Factors to be evaluated Criteria
Water and sewage system Accessibility
Size Depends on the number of people connected; Not less than 50 x 50 m
Form Similar to the square
Sanitary zone Must be evaluated according to national requirements
Ownership It is preferred that the territory belong to the municipality
Public amenity sites shall be located on closed and fenced areas and equipped with containers
for non-hazardous and hazardous household wastes (incl. WEEE, batteries and accumulators).
Ideally all containers, at minimum those for hazardous wastes needs to be placed under shed
roof in a lockable container or room.
In assessing the location and site capacity, it is recommended to evaluate the possibility of
installing waste exchange points on the site i.e. an infrastructure for preparation of waste for re-
use and storage of them.
Asbestos containing wastes are generated during professional activities (maintenance and
demolition work) as well as by private activities (“do it yourself” refurbishment). There is no need
of a separate collection system for asbestos wastes from professional activities. Nevertheless
supervision of these activities is necessary to enhance the compliance with the already existing
legal obligation of separate collection and safe disposal. Furthermore it is necessary to focus
the public on the risks and problems associated with unsound management of asbestos and
provide a separate collection for small amounts of asbestos containing wastes from the private
sector (e.g. asbestos heat shields, electrical equipment containing asbestos, asbestos cement
products) as part of a general bring-system for hazardous household waste. Awareness raising
campaigns shall inform the public on the risk associated with the removal of asbestos wastes
others than moveable items that could be proper packed and delivered to an amenity site. No
unsafe removal shall be promoted by the opportunity to dispose of asbestos at civic amenity
sites. Public amenity sites shall be equipped with containers for interim storage of small
amounts of asbestos containing waste from households.
Taking into consideration the effectiveness of the introduced system for the collection and the
“bring-system” for household waste it has to be decided if additional larger storage facilities for
hazardous waste from households are needed (e.g. at the level of each waste management
region/county). This should be decided in a subsequent step via more detailed planning step at
regional level and is also discussed in Chapter 6.3.5.
6.3.3 Home-composting in rural and semi-urban households
In rural and semi-urban areas of dedicated waste management regions citizens and households
shall be provided with knowledge for home-composting.
Therefore, targeted information campaigns to enable active participation of the public and
citizens in rural and semi-urban areas shall be carried out. This may comprise an initial letter to
the households with a leaflet and short description how to establish and run a garden compost /
equipment for home-composting and should be followed with training workshops in the
neighbourhoods including training on smart, biological gardening. Equipment for home-
composting including a brochure with description about suitable materials/wastes and process

steps to produce their own compost shall be given to citizens who participated in the training
workshop for free. For 1 household (2 inhabitants, 0.06 - 0.1 ha) a composting container with a
capacity of more than 700 litres is recommended. Trained compost masters from the
municipalities or regional waste management companies/regions will offer advice to interested
citizens. The introduced system shall be based on targeted information campaigns followed by
detailed advice for interested citizens only. This will ensure that related costs are expended
most efficiently.
 Home-composting shall be introduced in rural and semi-urban areas in all municipalities of
minimum thirteen waste management regions covering the regions Subotica; Vranje;
Kruševac; Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac;
Zrenjanin; Valjevo; Belgrade until 2025; in all waste management regions until 2035.
6.3.4 Composting
6.3.4.1 Small scale composting facilities at municipal level
Composting as a separate process is mainly understood as aerobic biological treatment for

separate collected bio-waste waste from households and similar establishments, green waste
(garden and park) and sludge from wastewater treatment plants. The compost can be used as a
soil improver.
For an optimal decomposition input materials must be a mixture of easily degradable, wet
organic substances and structure-improving organic matter. Structure improving materials are
needed to create structure with adequate air-filled porosity and a high number of pores in the
pile when air conductivity is low. Moisture content is important to maintain microorganism
activity; low moisture content can lead to microorganisms becoming dormant. If the moisture
content becomes too high the porosity of materials is reduced and anaerobic conditions can
flourish within the composting material. An optimum moisture content in the range of 40–65 %
has been reported in several studies and surveys.
The minimum moisture content is 30–45 % (wet basis). C:N ratios between 20:1 and 35:1 and a
C:S ratio of 100:1 are considered favourable to supply microorganisms with nutrients. Bulk
density is an indicator of the quality of the input material's structure.
Process description
A basic design for composting plants involves four main steps:
 Reception: Weighing and monitoring the waste input as an initial step the characteristics
and quantity of the waste input are recorded in the reception area or by the supplier by
means of above-ground or flush-mounted floor scales, or by flow-rate meters.
Acceptance checks consist of visual inspections or also, e.g. in the event of missing
information about the received waste or possible contamination posing a risk to the
treatment process, of reference samples analysis. The design of the reception area (e.g.
way of discharging the feedstock, encapsulation of the reception area) depends on the
type of substrate, on air pollution control, and on hygiene requirements. Flat or recessed
bunkers and tanks provide a buffer.
 Preparation and manual sorting: If necessary, unwanted non-biodegradable materials
are removed by hand. Furthermore large pieces of wood could be removed by sorting or
conditioned by shredding. The purpose of shredding is to better prepare the organic
waste input for biological treatment and homogenising the feedstock, etc. Shredders are
fed by wheel loader, crane and other conveying systems, or by means of belt and auger

conveyors. Depending on the feedstock, the shredding can take place either before or
after the sorting step.
 Automatic sorting and homogenising: Drum screens are frequently used to classify
and homogenise material. When necessary, metals, plastic, and other non-
biodegradable materials are removed, by means of magnetic and eddy current
separators and air classifiers respectively;
 Composting – Intensive decomposition: Intensive decomposition occurs during the
first two to three weeks of the process, when the degradation curve is very steep. Most
of the emissions are linked to this phase: aerobic degradation releases carbon dioxide,
water, ammonia and heat. The temperature of the rotting material climbs to up 70 °C in
the pile, giving rise to a greater release of odorous compounds like volatile fatty acids,
ammonia and other nitrogen-containing compounds, ketones, aromatics, and inorganic
and organic sulphur compounds. This stage is commonly referred to as the sanitisation
phase. It is followed by a less intense maturation stage, where breakdown continues, but
with different types of organism proliferating, and temperatures gradually reducing.
Water content, aeration and temperature are the key composting process control
parameters.
In rural municipalities the location of the composting facility may be situated near or next to the
municipal amenity site or even at a suitable location in one of the parks. Only in city
municipalities combined simple composting facilities for more than one municipality may be
operated taking into consideration shortage and suitability of space. Hence, each municipality
needs to decide to establish and operate an own composting plant on a suitable location or
contract a partner for the service of composting. Produced compost may be used by the
municipality administration and provided for the citizens at special prices.
Depending on local climate, site conditions and total quantity treated, simple composting
facilities may fulfil specific technical minimum requirements such as sealed composting platform
with controlled collection of surface and process water. The type of technique chosen for
composting (open/closed system, with or without active ventilation) needs to be decided
considering the location (near housing areas), the type and amount of wastes treated. Minimum
machinery includes a wheel loader as well as a turning device for frequent turning and mixing of
the waste as well as a possibility to add water in order to guarantee optimised rotting conditions
during the treatment as well for storage and transport of raw materials and compost.
 The municipality administrations themselves generate significant amount of organic waste.
This comprises inter alia green waste from public garden and parks. To manage those
waste streams together with source separated bio-waste, simple composting facilities for
garden and park waste and bio-waste should be established in all municipalities of
minimum thirteen waste management regions/counties until 2025 (Subotica; Vranje;
Zrenjanin; Valjevo; Beograd).
The capacities of the composting facilities at municipal level shall be in the range of 500 to
5.000 t/year (small scale biological treatment plants).
6.3.4.2 Large scale biological treatment facilities for source separated bio-waste
Establishing the bin/bag collection system for bio-waste requires additional aerobic composting
facilities and/or anaerobic digestion facilities for the recovery of source separated bio-waste
coming from households and similar establishments. The assessment should take into account
the quantitative impact of home-composting as well as possible sources of garden and park

waste that are not processed at municipality level considering the scale, coverage (catchment
area) and the vicinity principle.
In order to manage source separated bio-waste an accurate capacity for biological treatment
needs to be established considering the whole territory of Serbia. Near large urban
aggregations facilities with high capacities are required.
 For the period 2020-2025 one large scale advanced biological treatment plant for the
region of Belgrade and two more facilities in high populated urban areas need to be built
until the end of the timeframe in order to manage source separated bio-waste from
households.
The capacities of the large scale composting facilities shall be in the range of 50.000 to 100.000
t/year (large scale biological treatment plants).
6.3.5 Transfer stations / storage areas for interim storage
In order to strengthen the management of waste streams which are not treated on-site or which
are treated in centralized facilities with long transport distances, additional storage areas /
transfer stations needs to be established.
Operations carried out in waste transfer stations include: transferring from small collection
vehicles to big volume transport trucks, reception, bulking, sorting, transferring pending, and
prior to submission to a disposal/recovery/recycling operation. In some cases, blending and
mixing may also be carried out in these installations. Waste transfer stations may involve
individual operations or may be an integrated part of a treatment process. All sites typically
undertake some kind of bulking operation to agglomerate the solids, where liquids are decanted
from one container to another. The liquid transfer can be from a tanker to a holding tank, or from
fractions of litre up to a more than 200 litre drum. Operations typically carried out are inspection,
sampling, physical sorting and packaging, decanting, blending, drum emptying, storage and in
some cases disposal of wiping cloths, solidification and the crushing of oil filters. Waste transfer
stations tend to fall into two categories according to the objective of the installation:
 Focus on the output stream. This corresponds to sites that act as a feeder for other
processes: e.g. solvent regeneration, incineration, chemical treatment;
 Focus on the input waste. These sites are independent transfer stations and generally
accept a full range of materials from the neighbouring area. Typically, they also bulk and
blend materials to produce a range of waste streams suitable for disposal through
different treatment, recovery and disposal processes, but they do not usually target any
specific waste group.
The majority of operations linked to waste preparation may be distinguished under two groups:
 Regrouping/Reconditioning. Here the aim is to group together wastes in small or
medium quantities, when they have the same nature and when they are compatible. The
resulting waste though still has to be treated. The purpose of regrouping is to obtain
larger and more homogeneous volumes for waste treatment, to improve safety (e.g.
facilitation of handling) and to rationalise the logistics cost. The combination of
processes used in waste preparation and in pre-treatment operations depends on the
specifications of final treatment;
 Pre-treatment. Here the aim is to adapt the waste to the type of recovery and/or
disposal of the final treatment available. Pre-treatment covers several aspects. It can be
defined as those operations that lead to homogenisation of the chemical composition
and/or physical characteristics of the wastes. Pre-treatment produces a waste, which

may be very different from the initial waste, although not from a regulatory point of view.
This pre-treated waste still has to be treated in a recovery and/or disposal plant.
Where economically feasible, transfer stations may be established to reduce transport costs
and, in some cases, the number of vehicles passing inhabited settlements. Transfer stations are
considered more as a possibility than a necessary element of the system. The number of
transfer stations in each region must be defined during the technical assessment of the future
regional systems primarily as a function of the distances to landfill and the quantities of waste to
be transported. Additional transfer stations may be developed in later phases if there is a
change in circumstances.
 For construction and demolition waste, storage areas / transfer stations where mobile
facilities may be operated are proposed to be established at regional level, for minimum
thirteen waste management regions/counties until 2025 (Subotica; Vranje; Kruševac;
Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin;
Valjevo; Beograd).
 For hazardous waste, storage sites / transfer stations where minimum requirements to
ensure environmental safe handling of those waste is ensured, are proposed to be
established at national level, for two regions until 2025.
 For non-hazardous waste, it needs to be assessed within the period 2020-2025 if storage
areas / transfer stations are needed e.g. for packaging and municipal solid waste. The
assessment has to take into consideration the enforcement activities on introducing
collection schemes and treatment capacities as proposed in this Waste Management
Strategy.
Storage areas / transfer stations may cover several different waste streams to be stored /
transferred taking into account the technical minimum requirements and shall be equipped with
suitable containers which are located on impermeable surfaces. Taking into account the
potential of the stored waste type to damage the environment, the storage area should be
equipped with a roof (at minimum for hazardous waste types) and the whole area should be
closed and safe against unauthorized access.
6.3.6 Mobile treatment facilities for mineral construction and demolition

waste
To treat mineral construction and demolition waste, mobile facilities are appropriate to ensure
the de-centralized management of mineral C&D waste. Available storage areas / transfer
stations at regional level should be frequently operated by the mobile facilities.
 Until 2025 mobile facilities for treatment of construction and demolition waste shall be
available in minimum thirteen waste management regions/counties until 2025 (Subotica;
Vranje; Kruševac; Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Novi Sad;
Kragujevac; Zrenjanin; Valjevo; Beograd) operating on storage areas at regional level
according to the demand requested. (Remark: Reference to the shared responsibilities
between the public sector and the private sector can be found in Chapter 9).
6.3.7 Secondary separation and mechanical sorting of recyclables
Recyclables collected separately by the bin/bag collection system (comprising metals, plastics,
glass, paper and cardboard) need to be sorted to be further recycled/recovered. Therefore,
simple sorting facilities are proposed to be established on regional level.

 Until 2025 at minimum ten simple sorting facilities with manual and/or automatically
mechanical sorting will be build and manage the sorting from municipalities where bin/big
collection system has been established. The decision which regions should establish such
facilities shall be taken considering the functioning (collected amounts) of the established
collection schemes for recyclables, coverage (catchment area) and the vicinity principle.
The sorting and separation steps of recyclables may be carried out by simple sorting lines
comprising technologies such as hand/manual sorting, ferrous metal/non-ferrous metal
separator and/or air separator.
Capacities shall be in the range of 20.000 to 30.000 t/year. They need to be assessed taking
into account the efficiency of the bin/bag collection system. Sorting lines may be technically
expanded stepwise according to needs.
 Up to 2035 a network of simple sorting facilities for recyclables should be installed on the
whole territory of Serbia.
6.3.8 Mechanical-biological treatment
6.3.8.1 Pre-treatment of mixed municipal solid waste before landfilling (simple

MBTs)
Additional simple biological treatment installations (simple MBTs) for the pre-treatment of non-
hazardous residual mixed municipal solid waste prior to landfilling shall be established in
regions with sanitary landfills to minimize greenhouse gas emissions and waste water emissions
at landfill sites. This will foster the implementation of the strategy to reduce bio-degradable
waste at landfills and ensure compliance with the Landfill Directive (see Chapter 7). The
capacities shall be related to the landfilled waste at the specific region.
Simple MBTs may comprise mechanical separation steps and may be equipped with open
rotting systems and sucking air ventilation to be connected to bio-filters systems to minimize
odour and other air emissions. Waste water generated by rotting processes shall be
recirculated.
 Until 2025 minimum 10 simple MBTs in regions with operated sanitary landfills shall be
established.
The assessment to quantify needs for additional capacities should be done following the results
and experiences gained in the implementation period 2020-2025.
6.3.8.2 Mechanical-biological treatment of residual municipal solid waste
Mechanical biological treatment (MBT) is usually designed to mechanically separate materials

suitable for further recovery/recycling and to stabilise the organic fraction of the residual waste
via biological treatment or bio-drying.
Non-hazardous residual mixed municipal solid collected from households via bin collection
system serves for input in mechanical-biological treatment. There, splitting of high calorific
waste and metal separation will be carried out to separate waste streams for energy recovery
and recycling. If appropriate, further mechanical sorting/separation will be carried out to
separate specific recyclables from the mixed waste. The process may comprise shredding and
sieving.

The remaining waste with high organic content will be treated with aerobic biological processes
to fulfil specific degradation for further landfilling. The biological treatment may be carried out in
closed tunnel systems, capturing the exhaust air for treatment in bio-filters to reduce odour
emissions. Output of the biological treatment facilities may be used for cover issues of
remediated and closed landfills.
Depending on the used technology the organic fraction be treated aerobic or anaerobic (to
generate additional energy output), or via combination thereof. The practical advantages of MBT
plants are:
 Sorting output of recyclable materials (e.g. metals, other packaging waste (low efficacy)
and/or materials for further processing (e.g. preparation of solid waste fuels, SRF);
 Reducing volume, water content, organic matter content and/or biological reactivity of
the waste which is sent to final treatment (landfilling or incineration).
MBT plants significantly reduce humidity via the exothermic biological stabilisation of the organic
content in the waste. In principle, many types of waste materials can be treated at a MBT plant.
Generally, only mixed, unsorted waste with considerably content of organic matter enters the
plant. The mixed materials comprised all types of waste such as paper and cardboard, plastics,
green/kitchen organic waste. Also sewage sludge is a possibly input for the biological treatment
step within a MBT plant. However, some European MS legislation and guidance for MBT
treatment processes exclude or restrict some types of waste. Examples are hazardous waste,
waste for which a special treatment is obligatory because of EC legislation (e.g. Regulation (EC)
No. 1069/2009 of the European Parliament and of the Council of 21 October 2009 laying down
health rules as regards animal by-products and derived products not intended for human
consumption and repealing Regulation (EC) No. 1774/2002 (Animal by-products Regulation)),
waste for which a biological treatment is not appropriate and waste causing inhibition of
biological activity. The moisture content of waste intake is extremely variable, for mixed
municipal solid waste from households a moisture content of at least 40–50 % is expected.
The output from biological treatment step may be recovered or used as landfill cover if
contamination is low enough, or it may be landfilled. The quality of the output is generally not
acceptable for widespread use because of the contaminants related to both the inert content
(glass, plastic, etc.) and also to the heavy metals content arising from other wastes entering the
input stream (batteries, etc.). Other outputs mainly from mechanical treatment are combustible
fractions (RDF) and recyclable materials (e.g. metals, plastic).
MBT plants are very flexible and can be built on a modular basis, thus can be implemented also
for lower capacities from 20.000 to 30.000 tonnes. For example, the mechanical treatment may
be carried out before or after the biological treatment. Mechanical biological treatment is a tool
for pre-treating wastes for recovery, for preparing solid wastes (typically residual municipal solid
waste) to be used as fuels, or prior to landfilling.
Biological treatment uses living microorganisms to decompose organic waste into either water,
CO2 and simple inorganics or into simpler organics such as aldehydes and acids. Organic
substances are transformed into humidified mineral-organic complexes. Generally, biological
treatment is successful only when the waste is not harmful to the biocenosis, within the
relatively narrow pH range of pH 4–8, and with a C:N:P ratio of around 100:3–5:1 81. There are
several other important conditions like oxygen content, trace elements, temperature and mixing.
Biological treatment is, if well prepared, able to be adapted to a great variety of organic
materials or substances which can be found in wastes or contaminated ground.
A common characteristic of biological treatments of wastes is that heavy metals and other non-
biodegradable or volatile components on the one hand accumulate as a result of the
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mineralisation of the organic matter and on the other hand are subjected to dilution by mixing,
and dissolution in the aqueous phase, and therefore become part of the body of the
microorganisms. In general, heavy metal compounds are not selectively separated from the
waste and not selectively concentrated in a target output material. The most commonly used
practice for bio-treatment of mixed municipal waste in Europe is related to aerobic treatment
(including bio-drying, bio-stabilisation and wet rotting processes) and anaerobic treatment or
anaerobic digestion after mechanical treatment. The mechanical processing configuration must
be chosen depending on the intended flow and composition of municipal waste, therefore,
depends largely on whether biodegradable waste is collected separately or not. Volatile
chemical constituents are the most likely to result in fugitive emissions to air, together with
ammonia (odour problem). If anaerobic treatment or anaerobic digestion is carried out
centralised separation of the organic fraction included in mixed municipal waste is the common
route for obtaining a digestible fraction from residual waste. The techniques involved include
mechanical processing, optical processing and hand-picking. The digestible fraction obtained
tends to be more contaminated than source-separated bio-waste, with inevitable consequences
for the ultimate utilisation of the compost-like output or digestate (there is some evidence that,
where pulping is used as a pre-process sorting phase, liquid separation can lead to the removal
of some of the more hazardous elements). One of the main constraints is the high level of
impurities such as particles from plastics, metals and glass that would restrict the use as
component for the reclamation layers in landfills. There is also the risk of larger, non-separated
components of the waste being carried over and causing physical damage to treatment plants
further downstream (by abrasion, blockages or tangling). This gives reason that outputs coming
from biological treatment of mixed residual municipal waste is not suitable for specific
applications such as agriculture use and gardening.
 It is planned to build two mechanical-biological treatment plants until 2025 in Novi Sad and
Kragujevac (or another large region namely Niš). The capacity of those MBT facilities
should be in the range of mid-scale plants (about 75.000 t/year total waste input).
 Until 2035 in three regions (Niš, Novi Sad and Kragujevac) MBTs should be in operation.
6.3.9 Waste incineration and co-incineration
Incineration is used as a treatment for a very wide range of wastes. Incineration itself is
commonly only one part of a complex waste treatment system that altogether, provides for the
overall management of the broad range of wastes that arise in society. The objective of waste
incineration, in common with most waste treatments, is to treat waste so as to reduce its volume
and hazard, whilst capturing (and thus concentrating) or destroying potentially harmful
substances. Incineration processes can also provide a means to enable recovery of the energy,
heat, mineral and/or chemical content from waste.
The technologies applied are mainly grate firing, fluidised bed incinerator and rotary kiln
incinerator. Grate firing is commonly used for untreated or only minimal treated municipal solid
waste. The burning chamber of the kiln is applied with a (moving) grate, where the waste is fed
and the combustion air is fed from below the grate. The process can be controlled by the
amount of waste on the grate and the regulation of the combustion air. The incineration process
is sensitive to fluctuations of the calorific value of the waste. To avoid changes in the
incineration temperature which may lead to increased emissions a steady feed of waste with
constant calorific value is important. This is achieved by mixing the waste in a bunker before it is
fed into the combustion chamber. Residues from the process are bottom ash (slag), fly ash and
gas cleaning residues.

Fluidised bed incinerators are used for a wide range of solid and semi-solid (sludge) fuels. Fuel
particles are suspended in a hot, bubbling fluidity bed of ash and other particulate materials
(sand, limestone etc.) through which jets of air are blown to provide the oxygen required for
combustion. Due to the high thermal capacity of the fluidised bed the combustion is insensitive
to fluctuations of the calorific value. To apply this technology for municipal solid waste at least a
mechanical pre-treatment is necessary. Sewer sludge can be fed into the combustion chamber
without pre-treatment. Residues generated is a fine bed-ash (mixture of non-combustible waste
residues and the fluidised bed), fly ash and gas cleaning residues.
While both technologies, grate incinerator and fluidised bed incinerator have a high energy
efficiency since radiation loss of energy can be minimized by insulating the combustion
chamber. The third technology applied in waste incineration commonly is the rotary kiln
incinerator. Solid waste is fed into a rotating cylinder with a small incline to the horizontal.
Additional energy is fed in with burners, using oil, solvents, gas or pre-treated high calorific
waste like plastic. The solid waste (even with low calorific value) is slowly moving through this
cylinder and thus a high thermal destruction is reached. Therefore this technology is used
mainly for hazardous wastes which can be fed into the kiln e.g. in drums. Energy is recovered
only from the combustion gas after the kiln. The kiln itself has a high loss of energy by radiation.
Thus the energy efficiency is significant below the other described technologies. Provided the
incineration temperature is high enough the slag from the rotary kiln is partly vitrified. Beside this
slag again fly ash and gas cleaning residues are generated.
Based on these different technologies the incineration sector may approximately be divided into
the following main sub-sectors:
 Mixed municipal waste incineration – treating typically mixed and largely untreated
household and domestic wastes but may sometimes including certain industrial and
commercial wastes (industrial and commercial wastes are also separately incinerated in
dedicated industrial or commercial non-hazardous waste incinerators);
 Pre-treated municipal or other pre-treated waste incineration – installations that treat
wastes that have been selectively collected, pre-treated, or prepared in some way, such
that the characteristics of the waste differ from mixed waste. Specifically prepared refuse
derived fuel incinerators fall in this sub-sector;
 Hazardous waste incineration - this includes incineration on industrial sites and
incineration at merchant plants (that usually receive a very wide variety of wastes);
 Sewage sludge incineration – in some locations sewage sludge are incinerated
separately from other wastes in dedicated installations, in others such waste is combined
with other wastes (e.g. municipal wastes) for its incineration;
 Medical waste incineration – dedicated installations for the treatment of medical wastes,
typically those arising at hospitals and other healthcare institutions, exist as centralised
facilities or on the site of individual hospital etc. In some cases certain clinical wastes are
treated in other installations, for example with mixed municipal or hazardous wastes.
Main outputs from thermal waste incineration processes:
 Electrical energy – requires connection to grid
 Heat energy – if market available, e.g. district heating, co-located industrial demand
 Incinerator bottom ash and slags (20% - 30%) – potential use as a replacement for
aggregate if standards applicable and market exists, otherwise landfill
 Emissions cleaning residues (2 - 5%) – fly ash and gas cleaning residues – hazardous
waste to be finally landfilled
 Emissions to atmosphere (70%).
From bottom ash from ferrous and non-ferrous metals may be separated before further recovery
or disposal.

It is important to recognise that the local collection and pre-treatment applied to municipal solid
waste will strongly influence the nature of the material received at the incineration plant. The
pre-treatments and other operations carried out at the incinerator should therefore be consistent
with the collection system in place.
The degree to which separate collection and similar schemes affect the final waste delivered to
the installation depends on the effectiveness of the separation and pre-treatment systems
employed (Table 63). This varies greatly. Some residual fractions are always likely to remain in
the delivered waste. Reject materials from recycling plants, mono fractions of waste,
commercial and industrial wastes, and some hazardous wastes may also be part of the
delivered waste.
Table 63: Impact of separate collection on treatment quality
Fraction removed Main impacts on remaining waste

Increase in calorific value;
Glass and metals
Decrease in quantity of recoverable metals in slag.
Decrease in calorific value;
Paper, cardboard and plastic Possible reduction in chlorine loads if PVC
common.
Reduction in moisture loads (particularly of peak
Organic wastes, e.g. food and garden wastes loads);
Increase in net calorific value.
Reduced need for removal/shredding of such
Bulky wastes
wastes.
Reduction in hazardous metal loading;
Hazardous wastes such as batteries, WEEE,
pharmaceutical waste, etc. Reduction in some other substances, e.g. Cl, Br,
Hg.
Currently, in Serbia three companies from the cement industry have permits to treat waste to
substitute primary resources. In this context, mainly waste tires and other combustible waste
such as mixed packaging waste are treated thermally.
In addition, waste is also recovered in a few further companies to substitute primary resources
like fly ashes from the coal industry which is used in the brick production industry.
Introducing the bin/bag collection system from households should facilitate a boost to direct
waste to pre-treatment. The pre-treatment proposed includes the sorting of recyclables for
further recovery, the sorting out of high-calorific wastes for thermal recovery and the production
of RDF.
 It is expected that combustible waste will increase significantly and one centralized
incineration plant in the region of Belgrade needs to be built within the period of the Waste
Management Strategy 2020-2025.
Currently, the project in Belgrade is being implemented, which is planned to be built new
Energy-from-Waste (EfW) facility with single independent waste incineration line, with a nominal
capacity of 43.6 t/h equivalent to a total annual capacity of 340,000 tons/year of residual
municipal waste at a calorific value of 8.5 MJ/kg, Capacity to produce a minimum heat off -take
volume of 175 GWh and power delivery of 168 GWh per year. It is planned that the waste
incineration plant will be operational in 2021. This capacity is sufficient to cover at least the
potential produced non-hazardous high calorific waste from three mid-scale MBT facilities plus
sorted residues from other pre-treatment activities conducted at regional and municipality level,
as well as remaining mixed municipal solid waste.

The waste incinerator needs to be equipped with a state-of-the art off-gas-cleaning system and
should also be able to deal with high calorific value residual waste from packaging and other
sorting activities.
If produced and generated high calorific non-hazardous waste exceeds the capacities of the
waste incinerator the existing co-incineration possibilities predominantly in the cement industry
need to be established and used to balance needs and demand.
In addition, capacities for thermal treatment of hazardous industrial waste, including medical
waste shall be considered in the forthcoming period in accordance with the needs and
capacities of the existing facilities (cement plants, thermal power plants, heating plants, etc.).
Yearly approx. 22,000 tonnes waste oil and approx. 10,000 tonnes RDF from sorting,
dismantling and physical-chemical treatment facilities give reason to make available existing
capacities for co-incineration in the industrial sector. For certain types of organic hazardous
waste (such as oil waste, oil sludge, solvents, other organic waste) possibilities for co-
incineration in the industrial sector need to be evaluated.
 In the long-term period until 2035 and with more data available about the related needs,
Serbia may focus on the establishment of capacities for incineration of hazardous and
medical waste incineration in small-scale incinerators for that type of waste. Residues like
hazardous packaging waste (e.g. packaging waste polluted with pesticides, chemical
substances, PCBs, etc.) that must not be burnt in cement plants will need such
incineration, otherwise these wastes have to be exported. Two facilities on a small scale
level shall be established until 2025.
6.3.10 Capacities for WEEE and batteries and accumulators treatment
A review of the literature was undertaken to identify the key elements and examples of best
practices for an effective management of WEEE in a country as Serbia which is in the early
stages of legislation development. An effective WEEE management system should cover all
flows of EEE and WEEE through the economy. EPR legislation should address the entire
system, stretching from product design, and monitor when a product is prepared for reuse,
recycled, or disposed of at the end of its life.
The Serbian current legislative status might be seen as an opportunity to develop a regional
West Balkans WEEE treatment infrastructure which might absorb, also, the amounts generated
in respective countries and thus become cost-effective. An argument to sustain this approach is
that Serbia has already a dismantling capacity and a small treatment capacity which can be
extended.
The most suitable approach to reach this is, on medium term, to make use the first stage
manual dismantling processes where this is possible, with the (higher value) materials and
components then reprocessed / sent for treatment accordingly. Such an approach would reduce
the costs of bulk transport. Furthermore, considering that legislation will start to produce effects
and EPR schemes became operational, it’s presumed that the market tendency will be to
increase the level of investments. However, the state should play a strong operational role to
mitigate the monopoly.
The policy to have regional facilities arise in respect of more specialised treatment facilities (e.g.
facilities to sort plastic containing brominated flame retardants from WEEE plastics, or for
degassing of fridges, or for treatment of mercury containing equipment). Such treatment
processes are required under the WEEE Directive, and their nature is such that, given the
evolution of quantities of WEEE which will be collected in future years in the region lead to the
conclusion that is not a commercial case to establish facilities in each country.

Also, it should be said that is no need for governments to become financially involved in
developing such facilities if, under well-designed extended producer responsibility schemes, the
producers are made financially responsible for WEEE management.
Regarding car accumulators Serbia has sufficient treatment capacity and if on the future
quantities will increase then the market will react in supplement the capacity.
However, there is a problem with portable batteries and accumulators where unfortunately
because the separate collection is not providing sufficient amounts what is eventually collected
by targeted campaigns is temporary stored and then exported. Thus, the present situation is
critical because portable batteries and accumulators (which are hazardous waste) generated
are disposed of together with municipal waste. By analysing the best practices until the separate
collection will not be fully operational, considering also the investment & operational costs for a
portable batteries and accumulators treatment facility on medium term is indicated to export the
collected quantities.
Portable batteries collected from end-users need to be sorted into different chemistries (Li-
batteries, AlMn, Nickel-Cadmium and all kinds of Mercury (Hg) containing batteries prior to
recycling.
 Having in mind the current and expected future collection volumes of portable batteries in
Serbia one sorting facility is considered sufficient to be established until 2025.
6.3.11 Recycling capacities for metals, plastics, glass, paper and

cardboard
Paper and cardboard: Separately collected paper and cardboard wastes are effectively recycled
mostly in Serbia. Over then 85.000 tonne of paper and cardboard wastes are annually recycled
by companies from the Kappa Star group (source: DSIP PPDW). Thus, there is no need for
additional capacities.
Glass recycling is still uncommon in Serbia. Only one company (Srpska fabrika za reciklažu),
deals with the recycling of glass packaging waste. The factory has sufficient capacity to be able
to take care of the recycling of the total quantity of separately collected glass packaging waste
in Serbia (about 15.000 tonnes annually)82 but under certain quality standards.
Metals, both ferrous and nonferrous, are recycled quite efficiently in Serbia through a vast
network of collectors and metal traders. The steel waste collected in Serbia is processed by
several steel companies.
Plastics: A relevant share of plastic packaging wastes are recycled by different kinds of plastic
processors in Serbia, e.g. PET processors and non-PET processors producing LDPE folio hose
and piping or granulate. (Source: DSIP PPDW)
There is a PET bottles production in Serbia, but not a relevant amount is coming from recycling
of PET. On the other side the PET waste collected is mostly sorted, washed, baled and then
recycled into flakes, which are exported. There is an option to have a capacity for fibre
production but taking into consideration the current stage of industrial and economic
development, it is likely that such a capacity will be developed when the collected clean
materials will increase sufficiently to proof the cost efficiency.
Existing recycling capacities and industry that could use the secondary raw material in
production need technology development and improvement. In parallel to the establishment of
separate collection the private sector recycling industry will increase in relation to the demand.
82
Source: DSIP PPDW

To receive the benefits of recycling, the recycling needs to take place locally. So supporting
reuse becomes very important for strengthen the national economy.
6.3.12 Recycling of mineral construction and demolition waste
In 2018, the C&D waste was mainly landfilled or dumped. Only small amounts of specific
fractions such as asphalt are recycled (mostly at the place of generation).
It seems inappropriate to introduce a specific collection system for mineral C&D wastes to in-
crease the recycling rate bearing in mind that C&D waste are generated at a specific site only
for a short time period and in a clear predictable amount.
The technical infrastructure for recovering mineral C&D waste is very similar to the technical
equipment of quarries (such as crusher, sieves, etc.). Also larger construction companies often
have access to such mobile equipment. Additional necessary equipment can be a metal
separator, a wind shifter device and a sorting device. The need of such additional equipment
depends widely on the quality of source separation at the construction site.
Due to the population shift in Serbia construction activities are concentrated especially in larger
urban areas. Thus a nationwide network of stationary C&D recycling installations is not the
adequate solution. Large transport distances on the other hand may jeopardize the
environmental benefit of the recovery operation. To serve the needs best a combination of
stationary facilities and mobile facilities that can process C&D waste at or near the place of
generation (where re-covered material may be used directly in many cases) is the adequate
solution.
Given the situation that at least in the beginning investment costs will be rather moderate since
construction companies and stone quarry industry may use existing equipment the introduction
of a recycling schemes is more a question of introducing a stable and clear legal environment
for the recycling of C&D waste and the use of recycled material and providing incentives and
deter dumping of C&D waste at inadequate dumpsites.
Important steps in terms of increasing C&D waste recycling are the enforcement of the legal
framework (see drafted by-law on C&D waste specifying requirements for recycling, the quality
assurance and use of recovered material). On-site source separation at the construction site
(also to separate hazardous wastes) needs to be established to guarantee high quality recycling
materials.
 Up to 2025 in minimum thirteen waste management regions each one mobile installation
for the treatment of non-hazardous waste should be provided (Subotica; Vranje; Kruševac;
Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin;
Valjevo; Beograd).
 All regions of the whole territory of Serbia should be provided with each one mobile
machine until 2035. The system and network for those installations should be
predominantly established by private sector and be supported by clarifying the legal
framework for the management of construction and demolition waste at national level.
6.3.13 Physico-chemical treatment and treatment of waste oils
Having in mind the data concerning type and quantity of generated hazardous waste in Serbia
and considering the future changes in the industrial sectors of the Republic of Serbia, the need
for the construction and operation of a physical-chemical treatment facility for hazardous waste
is obvious. As a part of the project “Technical assistance in preparation of documentation for the

construction of the facility for physical-chemical treatment of hazardous waste”, funded from the
EU Pre-accession funds – 2009 program cycle, a feasibility study had been develop to take into
consideration several locations for construction of such a facility for physical-chemical treatment
in Central Serbia the need was focused on the region that convers Moravički, Šumadijski,
Pomoravski, Raški and Rasinski administrative county. Private investment should be stimulated
by public securities in order to overcome economic uncertainties that usually accompany such
investments in comparable situation.
 Capacity should be developed stepwise and in a modular way. Finally, the capacity of the
facility for physical-chemical treatment of hazardous waste should cover the need of
approximately 50.000 tonnes per year until 2035 based on the overall quantity of
appropriate hazardous waste types generated in the Republic of Serbia annually. The
facility should comprise all necessary (and commonly established) elements for the
treatment of organic and inorganic hazardous waste. An appropriate laboratory is an
integral part of such installations.
It is up to the private investor to decide if other elements like solvents distillation facilities or
silver electrolysis (for photographic liquid residues) should be added and if this centre includes a
landfill with cassettes for hazardous and non-hazardous waste.
Technical documents needed for the authorization and construction of this facility shall define
for all units within the facility the appropriate technology and capacity needed, as well as
organizational and operational characteristics of the facility, all this in compliance with the
international standards and the state-of-the-art like defined in the BAT reference documents for
waste treatment.
6.3.14 Landfills
When solid waste is disposed of on land in open dumps or in improperly designed landfills (e.g.
in low lying areas), it causes the following impact on the environment:
 ground water contamination by the leachate generated by the waste dump;
 surface water contamination by the run-off from the waste dump;
 bad odour, pests, rodents and wind-blown litter in and around the waste dump;
 generation of inflammable gas (e.g. methane) within the waste dump;
 bird menace above the waste dump which affects flight of aircraft;
 fires within the waste dump;
 erosion and stability problems relating to slopes of the waste dump;
 epidemics through stray animals;
 acidity to surrounding soil and release of greenhouse gas.
Disposal is the final functional element in the solid waste management system. Today, the
disposal of wastes by landfilling or uncontrolled dumping is the ultimate fate of all solid wastes,
whether they are house hold wastes collected and transported directly to a landfill site, residual
materials from material recovery facilities (e.g. MBT), residues from the combustion of solid
waste, rejects of composting, or other substances from various solid waste-processing facilities.
A municipal solid waste landfill plant is an engineered facility used for disposing of solid wastes
on land or within the earth’s mantle without creating nuisance or hazard to public health or
safety, such as breeding of rodents and insects and contamination of groundwater. The so
called sanitary landfills are used for a disposal of non-hazardous waste and they represent
sanitary-technically arranged space in which waste generated in public areas, households,
production process, work process, sales or use, that contains no hazardous substances and
that cannot be processed and/or rationally used as industrial raw material or energy fuel, is

disposed. Landfills are necessary in each chosen option of treatment of waste, because there is
always a part of waste that remains and must be finally disposed of.
Sanitary landfills for non-hazardous waste

In Serbia residual waste will be disposed of in regional sanitary landfills established according to
the Landfill Directive requirements. The first step to achieve the greatest environmental benefit
is to plan for 100% of municipal waste to be managed to EU standards as soon as possible
using regional approach and infrastructure shared by cooperating municipalities. As already
mentioned 10 sanitary landfills have been operative so far. 8 of them in Uzice, Lapovo, Kikinda,
Jagodina, Leskovac, Pirot, Sremska Mitrovica, Pančevo are considered regional. Also the
landfill in Subotica has been constructed, but is not operational yet.
Government decision No. 353-5076/2018 from 7 th of June 2018 on joint provision and
implementation of waste management defined sanitary regional landfills that will receive waste
from local self-governments, in case that they had not entered into agreements on joint
provision and organisation of waste management.
Given that national regulations do not clearly define regional waste management systems, it is
assumed that infrastructure for each regional system shall include a compliant landfill unless
there will be some inter-regional agreements to cooperate regarding disposal of waste into the
same landfill. National legislation also does not specify that all municipalities must participate in
a regional waste management system, therefore, first of all, ensuring that all municipalities
participate in the regional system will be possible to evaluate the technical solutions for the
implementation of regional projects. The choice of technical solutions and infrastructure
investments for each regional project should be clarified in feasibility studies. Technical
solutions need to take into account national policy and institutional and economic measures.
 It is planned to install 4 more regional landfills for the period until 2025 in Subotica (has
been constructed, but is not operational yet), Belgrade, Vranje and Novi Sad. It is planned
that the Republic of Serbia will ensure gradual reduction of waste landfilled in the existing
non-compliant landfills by 2031.83
Landfills for hazardous waste

The need for hazardous waste landfilling in Serbia will depend on actual system for hazardous
waste treatment that Serbia establishes (e.g. incineration, dismantling and recycling facilities).
The latest studies84 indicate that Serbia generates between 50,000 and 70,000 tonnes of
hazardous waste per year that may need to be landfilled in the medium-term. These figures do
not include asbestos from construction and demolition waste, since this fraction can be
disposed of in separate cells of regional sanitary landfills. The investment costs of a new
hazardous waste landfill in Serbia are approximately 5-10 million EURO.
Currently there are no approved locations for a new hazardous waste landfill in the Republic of
Serbia or for the construction of hazardous waste treatment facilities. When they are identified
and approved, the new facilities will be constructed in compliance with EU requirements.
Requirements for hazardous waste treatment compliant with Landfill and other EU directives will
be enforced through IPPC permits. However, an additional option is the preparation of specific
83
Directive specific implementation plan for Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.
March 2018
84
Serbian integrated hazardous waste management plan. Improvement of hazardous waste management
in the Republic of Serbia – IHWMS. April 2017.

cassettes for the disposal of non-reactive hazardous wastes at landfills for non-hazardous
wastes in accordance with article 13 of the Regulation on disposal of waste in landfills
(“Official Gazette of the Republic of Serbia“, No. 92/10). In such cassettes no biodegradable
waste may be landfilled and the hazardous waste is restricted to granular waste complying with
the criteria defined in annex 8 table 3 of the Regulation on categories, testing and classification
of waste (Official Gazette of the RoS, No. 56/10). Most hazardous wastes principally suitable for
landfilling will comply at least after P/C-treatment (stabilisation, solidification) with these
conditions.
Inert waste landfills
The practice of uncontrolled disposal of C&D-waste in Serbia needs to be stopped as soon as
possible, including any permanent disposal in the place of generation in non-compliant
locations. The owner of the construction waste should be responsible for C&D-waste
management costs and has an obligation to establish separate collection and temporary
disposal. Each municipality is obligated (through planning documents) to ensure an appropriate
location for disposal of C&D-waste. This location must be fenced and controlled. Financing and
maintaining of these locations shall be provided through fees for transport and disposal of C&D-
waste by the waste generators. In the city/municipality where a regional sanitary landfill and
waste management centre exists or it is planned, a separate part of the facility can be dedicated
to C&D-waste disposal. Storage areas and mobile treatment installations for C&D waste will
support the appropriate management of this waste stream (see Chapter 6.3.5 and Chapter
6.3.6).
Landfill operators shall not accept C&D-waste when it is mixed with other type of waste or does
not fulfil waste disposal special conditions defined in the permit (Article 30 of the Law on WM
and Article 22 of the Regulation on disposal of waste on landfills).
6.4 Estimated investment and operational cost of the proposed waste

management options
The following results are mainly based on an assessment carried out in 2017 during the
Environmental Infrastructure Support Programme (supported by Sweden). The investments
predominantly shall start in minimum thirteen waste management regions (Subotica; Vranje;
Zrenjanin; Valjevo; Beograd).
In parallel, other additional municipalities may start with implementation but not finalizing until
2025. Up to 2035 all investments shall be taken to implement the proposed management
options and to be in line with the approximation to European waste legislation.
For introduction of a significant change of waste management several steps in preparation of
investments need to be taken. In this context feasibility studies are the starting point, followed
by further steps until realization of a project. Following table shows main steps to be considered.
Table 64: Transaction cost structure in the project preparation phase (ISWA, Financial Aspects
of Solid Waste Management, 2014)

6.4.1 Municipal Solid Waste Management – Investment costs
For implementation of the municipal solid waste management system at the whole territory of
Serbia, following investment costs can be estimated:
 Technical measures for implementing of source separation: 56,981,531 EUR;
 Technical measures for implementing of secondary separation: 60,487,014 EUR;
 Technical measures for establishing green waste composting lines: 31,370,000 EUR;
 Technical measures for implementing home composting: 46,586,940 EUR;
 Information campaigns related to separate collection at source and home composting:
5,300,000 EUR.
Up to 2025 investments shall be taken totally for minimum thirteen waste management
regions(Subotica; Vranje; Kruševac; Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš;
Novi Sad; Kragujevac; Zrenjanin; Valjevo; Beograd).
Table 65: Main infrastructure for management of municipal solid waste in Serbia
Green and park Secondary

Public amenity Waste transfer
Region waste composting separation
sites (No.) stations (No.)
(No.) facilities (No.)
Subotica 7 3 7 -
Vranje 6 4 6 1
Kruševac 6 1 6 -
Užice 9 2 9 -
Pančevo 2 - 2 1
Pirot 4 1 4 1
Sremska Mitrovica 2 1 2 --
Nova Varoš 4 1 4 1

Green and park Secondary

Public amenity Waste transfer
Region waste composting separation
sites (No.) stations (No.)
(No.) facilities (No.)
Novi Sad 12 2 8 1
Kragujevac 7 2 5 1
Zrenjanin 6 1 5 -
Valjevo 11 3 11 1
Beograd 15 2 14 1
Sub-Total for
91 23 83 8
13 regions until 2025
Other regions for
78 30 78 to be assessed
upcoming period
Total
169 52 161 to be assessed
implementation
Table 66: Investment costs for municipal waste management in Serbia

Green Informati
Waste Source Secondary Home
Waste on
Region quantity Separation Separation Composting
Composting campaign
(t/y) (EUR) (EUR/Located) (EUR)
(EUR) s (EUR)
Subotica 98.362 0 - 0 1.736.351 X
Vranje 47.604 1.170.396 X 1.230.000 1.005.879 X
Kruševac 76.803 2.377.565 - 1.230.000 2.035.361 X
Užice 117.838 3.358.704 - 1.845.000 2.562.249 X
Pančevo 54.128 1.360.000 X 410.000 776.325 X
Pirot 28.772 997.979 X 820.000 685.159 X
Sremska Mitrovica 66.894 962.800 - 210.000 1.430.954 X
Nova Varoš 34.160 1.090.572 X 820.000 811.830 X
Novi Sad 221.943 4.827.325 X 1.640.000 2.891.325 X
Kragujevac 86.118 1.950.000 X 1.025.000 1.359.657 X
Zrenjanin 65.209 2.419.593 - 1.025.000 1.689.351 X
Valjevo 123.257 1.296.152 X 2.255.000 3.296.378 X
Beograd 652.019 8.625.000 X 2.870.000 4.753.446 X
Sub-Total for
13 regions until 1.673.107 30.436.086 36.152.017 15.380.000 25.034.265 2,650,000
2025
Other regions for
933.676 26.545.445 24.334.996 15.990.000 21.552.674 2,650,000
upcoming period
Total
2.606.783 56.981.531 60.487.013 31.370.000 46.586.939 5,300,000
implementation
According to JASPERS Solid Waste and Energy Division, Staff Working Papers, Jonas
Byström, March 2010 (Revised August 2010) the specific investment cost for an MBT with RDF
separation ranges from 250 €/t capacity to 450 €/t capacity; those for a waste-to-energy plant
ranges from 500 €/t capacity to 900 €/t capacity.
Calculating with the specific investment costs of 350 €/t capacity and having in mind a mid-scale
MBT plant (about 75.000 t/a total waste input) the investment per plant is approximately 26.25
Mio EUR.
Calculating with the specific investment costs of 700 €/t capacity and having in mind a waste-to-
energy plant with approximately 300.000 t/a total waste input, the investment per plant is
approximately 210 Mio. EUR.

Table 67: Investment costs on plants for MBT and Waste-to-Energy in Serbia
Waste-to-energy Waste-to-energy
Region MBT sites (No.) MBT sites (EUR)
(No.) (EUR)
Novi Sad 1 26,250,000 - -

Kragujevac 1 26,250,000
Beograd - - 1 210,000,000
Sub-Total for 52,500,000
2 1 210,000,000
Other regions for 1 26,250,000
- -
upcoming period
Total
3 78,750,000 1 210,000,000
implementation
Costs for Simple MBTs?
Costs for Composting Plants
6.4.2 Construction and demolition waste management – Investment

costs
Table 68: Investment costs on plants for C&D waste in Serbia
Region Mobile installations (No.) Mobile installations (EUR)
13 regions 13 3,900,000
Sub-Total for
13 3,900,000
Other regions for upcoming period 14 4,200,000
Total
27 8,100,000
implementation
6.4.3 Hazardous waste management – Investment costs
Table 69: Investment costs on plants specifically treating hazardous waste in Serbia
Mobile Mobile
units for units for
Physico Physico Landfill for
Landfill for hazardous hazardous
chemical chemical hazardous
Region hazardous household household
treatment treatment waste
waste (No.) waste waste
plant (No.) plant (EUR) (EUR)
collection collection
(No.) (EUR)
Sub-Total until 2025 1 8,000,000 1 10.000.000 13 ?
Others for upcoming
1 8,000,000 14 ?
period
Total
2 16,000,000 1 10,000,000 27 ?
implementation

Regional Small scale

Regional Small scale
storage incinerator
storage incinerator
facilities for for
Region facilities for for
hazardous hazardous
hazardous hazardous
waste waste
waste (No.) waste (No.)
(EUR) (EUR)
Sub-Total until 2025 2 1,600,000 2 1,200,000
Others for upcoming
3 2,400,000 3 1,800,000
period
Total
5 4,000,000 5 3,000,000
implementation
6.4.4 Transfer stations / Storage areas for interim storage – Investment

costs
To be calculated!
Further Chapters to be calculated.
6.4.5 Operational costs
In order to ensure the implementation of EU directives, it is necessary to assess not only the
necessary investments but also the costs of maintaining the system. Since waste management
is based on a fee and on the principle of „polluter pays“, fees for waste collection, treatment and
disposal paid by users should ideally cover all investment and operating and maintenance
costs. Under the assumption that in future investment costs will be covered by external financial
sources (bank loans, grants etc.), the challenge will be to ensure long-term financial
sustainability of the future waste collection systems and to introduce a cost recovery tariff for
end users (households, industries, institutions). One of the limiting factors in deciding what
technological solutions will be implemented should be sustainability of the proposed investment
plans.
There is no generally agreed international criterion for the affordability of waste services that
would fit the specific local circumstances of individual countries, but it is noteworthy that
international financial institutions (IFIs), such as the World Bank and the European Bank for
Reconstruction and Development (EBRD), often take as a benchmark that waste and water
charges combined should not exceed 4 per cent of the average household income (usually 1%
for solid waste service).
During the process of investment planning85, an affordability study86 was conducted in order to
assess the sustainability of the proposed investment plan. The study shows that the current
investment plan will increase the burden on households more intensively in the initial period and
then remain on similar level until the end of planning period. The assessment estimates that
approx. 2.461 million euro of operational costs, during the period 2018 – 2034, will need to be
covered through waste management tariffs and that, though tariffs grow significantly, the overall
burden remains below affordability levels.
In the future, waste management fees will be calculated separately for each region and will be
used as a component in the calculation of the waste collection fee determined by self-
85
Directive specific implementation plan for Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.
March 2018
86
The maximum affordability of households necessary to cover OPEX costs in waste sub-sector is defined
at 1.5% threshold of average household income.

government institutions and paid by citizens. This will require a detailed analysis. It is
recommended that, when preparing regional investment plans or by adding new infrastructure,
financial sustainability of the projects is ensured within the limits of 1% household income limits.
That means the affordability of waste management services must be ensured, i.e. the cost of
services after the implementation of the project must not exceed 1% from the average family
income, evaluating all costs / revenues of the waste management system, including the cost of
disposing / disposing of products or waste generated during waste treatment.
Another important aspect of maintaining the system is ensuring a high collection rate for bills
and improving the overall efficiency of service provision.
In order to assess the overall costs of the system of municipal waste management necessary to
create formal methodology for waste management services that aims at ensuring cost-reflective
tariff setting. Municipal waste management fee must be such that the collected funds would
cover the costs of the treatment of municipal waste arising from the activities of the municipal
waste holder.
The waste management costs of products and packaging for which is the responsible producers
and importers, cannot be included in the overall costs of the management of municipal waste.
Depending on the waste management plan, regional waste management plans and local waste
management plans, the following municipal waste management activities can be identified:
1. Collection and transportation of unsorted municipal waste;
2. Separate collection and transportation of secondary raw materials in municipal waste;
3. Hazardous household waste, large waste, domestic electricity and separate collection and
transportation of electronic waste from household;
4. Operation of municipal waste reception facilities (if any);
5. Exploitation of secondary raw materials sorting lines;
6. Exploitation of composting sites;
7. Operation of a regional landfill, including closure, rehabilitation and maintenance after
closure;
8. Operation of unsorted municipal waste reloading points (transferring stations);
9. The operation of other waste management facilities if these facilities are necessary for the
implementation of the objectives for municipal waste in waste management plans;
10. The closure, rehabilitation and maintenance of non-compliant landfills after closure;
11. Management and administration of municipal waste management system:
11.1. The organization of the collection and the administration of collected waste fee;
11.2. Preparation of regional and local waste management plans, organization and
control of implementation;
11.3. Preparation of feasibility studies, technical projects, competitions and other
documentation;
11.4. Organization of tenders for waste collection and operation of equipment;
11.5. Administration and control of contracts;
11.6. Public awareness and other activities for municipal waste provided in waste
management plans.

7 PLAN FOR IMPLEMENTATION OF REDUCTION OF

QUANTITIES OF BIODEGRADABLE WASTE DISPOSED ON
LANDFILLS, MEASURES FOR THE ACHIEVEMENT OF
GOALS FOR DISPOSAL OF THIS TYPE OF WASTE,
ESPECIALLY, FOR RECYCLING, COMPOSTING,
PRODUCTION OF BIOGAS OR RE-USE OF
MATERIALS/ENERGY RECOVERY
Biodegradable waste comprises bio-waste as well as other biodegradable waste such as paper
and cardboard waste. According to the European Waste Framework Directive it covers any
waste that is capable of undergoing anaerobic or aerobic decomposition. As defined in the
Serbian Law on Waste Management bio-waste includes organic garden and park waste, food
and kitchen waste from households, restaurants, caterers and retail facilities and comparable
waste from food production. It does not include forestry or agricultural residues, manure, or
other biodegradable waste such as natural textiles.
Disposal of biodegradable waste at landfills, even carried out under regulated conditions, leads
to significant emissions to air and water by mainly anaerobic degradation processes. By that,
source separation and recycling on the one hand and appropriate pre-treatment of the
remaining biodegradable fraction in residual mixed waste is necessary to reduce emissions from
landfills and to prevent negative impact on the environment. Furthermore, it enables the
recovery of the material resources (including nutrients, organic matter for soil improvement and
peat substitution as well as secondary raw material for the production of paper) or the energy
potential of this waste type via applying anaerobic digestion processes in biogas plants or
biomass incineration of wood chips from tree cuttings.
Whereas paper and cardboard packaging waste is collected separately (93.221 tonnes in 2016
reported as recycled by collective schemes) specifically bio-waste is not source separated in
Serbia, neither from households nor from restaurants, catering or food production facilities.
Composting activities at agriculture facilities, farmers’ sites and home-composting in households
is apparently applied to very low extend.
In 2008, the bio-degradable waste accounts for approximately 67% of total municipal waste
generated in Serbia. This corresponds to 1.6 million tonnes of generated bio-degradable waste
or 214 kg per capita and year covering biodegradable waste from households including paper
and cardboard as well as green waste from parks and public areas.
Besides the need to implement a specific separate collection scheme for packaging paper and
cardboard waste inter alia to support the fulfilment of targets for packaging waste (e.g. defined
in the European Packaging Directive), above all, food waste and green waste with a potential of
841.000 t corresponding to 43% or 119 kg per capita constitute the most important fraction with
regard to its quantitative diversion potential as well as its environmental impact (i.e. gas
potential) when disposed of at landfills.
In line with the requirements of the European Landfill Directive following targets are stipulated in
terms of reducing bio-degradable waste disposed of at landfills:
 by 31 December 2025, the share of biodegradable municipal waste disposed of in
landfills will be reduced to 75% of the total amount (by weight) of biodegradable
municipal waste produced in 2008;
 by 31 December 2029, the share of biodegradable municipal waste disposed of
in landfills will be reduced to 50% of the total amount (by weight) of biodegradable
municipal waste produced in 2008;

 by 31 December 2034, the share of biodegradable municipal waste disposed of

in landfills will be reduced to 35% of the total amount (by weight) of biodegradable
municipal waste produced in 2008.
Stages for implementation
The measures to implement the strategy for reducing bio-degradable waste at landfills focuses
on the following main waste streams:
- paper and cardboard waste,
- bio-waste from households and
- the organic fraction in residual mixed municipal waste respectively.
Following those measures, the diversion of biodegradable waste via implementation of
separation and recycling following the Serbian National Policies and the European Waste
Framework Directive will increase. Source separation and appropriate collection systems
(including door to door as well as bring-systems) have to be introduced to achieve the defined
targets. In addition the measures contribute to
- the reduction of the production of greenhouse gases at landfills,
- the reduction of the use of landfill void space,
- the increased quality of separated paper and cardboard waste for material recovery,
- the increase of bio-waste recovery to produce compost or to use energy potentials.
In the following, an overview on the most relevant waste streams and needed infrastructure is
given with the aim to set the pathway to reduce biodegradable waste to be landfilled to 35% of
the total amount generated in 2008.
The defined levels of diversion may only be achieved taking into consideration the
implementation of all related further measures established in this Waste Management Strategy.
Paper and cardboard

Specific measures:

 Introduce separate collection of packaging and non-packaging paper and cardboard

waste from households (see Chapter 6.3.1 and Chapter 6.3.2);
 Introduce source separation of packaging and non-packaging paper and cardboard
waste from the commercial sector by companies;
 Separation of packaging and non-packaging paper and cardboard waste by sorting in
secondary separation and mechanical sorting facilities (see Chapter 6.3.7).
 Ensure material recovery (recycling) of separated packaging and non-packaging paper
and cardboard waste by industry (see Chapter 6.3.11).
The following level of diversion as percentage of the total amount of paper and cardboard
generated in Serbia should be achieved:
 Until 2025 (stage 1): 25% by obligatory implementation of the defined measures for the
waste management regions of Subotica; Vranje; Kruševac; Užice; Pančevo; Pirot;
Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin; Valjevo; Belgrade
and voluntary of all other waste management regions;
waste management regions of Kraljevo; Niš; Inđija; Vršac; Sombor and voluntary for the
remaining management regions which are not under the obligation of stage 1 and 2;
 Until 2034 (stage 3): 50% by obligatory implementation of the defined measures also for
the waste management regions of Lapovo; Kikinda; Jagodina; Leskovac; Loznica;
Požarevac; Smederevo; Zaječar.
Bio-waste
Specific measures:
 Promote, support, educate home-composting and on-site composting to garden owners,
schools, kindergartens and similar institutions (see Chapter 6.3.3);
 Introduce separate collection and composting of green waste from public gardens and
parks (see Chapter 6.3.4);
 Introduce source separation by a bin collection system for bio-waste; for food waste and
fine garden waste (grass, leaves etc.) from households and composting in municipal or
private composting facilities (see Chapter 6.3.1 and Chapter 6.3.4.2);
 Introduce source separation, collection and biological treatment (composting and/or
anaerobic digestion) of food waste and former foodstuff from central kitchens
(restaurants, hotels etc.) and retailers and open markets (see Chapter 6.3.4.2);
 Introduce separate collection and biological treatment (composting and/or anaerobic
digestion) of organic residues from food processing industries (see Chapter 6.3.4.2).
With the listed measures or a combination thereof, the following diversion targets as percentage
of total bio-waste generated in Serbia should be achieved:
 Until 2025 (stage 1): 20 by obligatory implementation of the defined measures for the
waste management regions of Subotica; Vranje; Kruševac; Užice; Pančevo; Pirot;
Sremska Mitrovica; Nova Varoš; Novi Sad; Kragujevac; Zrenjanin; Valjevo; Belgrade
and voluntary of all other waste management regions;

waste management regions of Kraljevo; Niš; Inđija; Vršac; Sombor and voluntary for the
remaining management regions which are not under the obligation of stage 1 and 2;
 Until 2034 (stage 3): 60%by obligatory implementation of the defined measures also for
the waste management regions of Lapovo; Kikinda; Jagodina; Leskovac; Loznica;
Požarevac; Smederevo; Zaječar.
Organic fraction in residual mixed municipal solid waste

The implementation of the measures on cardboard and paper waste and bio-waste defined
above directly influences the remaining share of bio-degradable waste in the residual mixed
municipal waste.
Specific measures:
 Establish capacities for mechanical biological treatment of mixed municipal solid waste
to further degree the greenhouse gas potential of waste to be landfilled (see Chapter
6.3.8 and Chapter 6.3.8.1);
 Establish thermal treatment capacities to treat residual municipal solid waste (see
Chapter 6.3.9).
The listed measures shall contribute to the achievement of the overall diversion targets of
untreated biodegradable waste from being landfilled.
 Until 2025 (stage 1):
o Construction of two advanced MBT facilities (see Chapter 6.3.8) in the waste
management regions of Novi Sad and Kragujevac with biological stabilisation of the
biodegradable fraction in residual mixed municipal solid waste.
o Simple MBT (see Chapter 6.3.8.1): Integration of biological stabilisation of residual
mixed waste or a fraction thereof rich in organic matter by means of an aerobic
rotting process in order to reduce bio-degradability (gas potential), volume and
humidity when landfilled to be realised in simple mechanical biological treatment
plants to be realised in the waste management regions Subotica; Vranje; Kruševac;
Užice; Pančevo; Pirot; Sremska Mitrovica; Nova Varoš; Zrenjanin; Valjevo;
o Construction of one waste-to-energy facility in Belgrade in addition to the existing
capacities in the cement industry (see Chapter 6.3.9).
o Simple MBT (see Chapter 6.3.8.1): to be realised in the waste management regions
Kraljevo; Inđija; Vršac; Sombor;
o Construction of a third advanced MBT facility (see Chapter 6.3.8) in the waste
management region of Nis with biological stabilisation of the biodegradable fraction
in residual waste.
o Simple MBT (see Chapter 6.3.8.1): to be realised in the waste management regions
Lapovo; Kikinda; Jagodina; Leskovac; Loznica; Požarevac; Smederevo; Zaječar.
Fully implementation of these measures with the announced levels of diversion for bio-
degradable waste gives the pathway for 2034 for fulfilling the reduction of the share of
biodegradable municipal waste disposed of at landfills to 35% of the total amount (by weight) of

biodegradable municipal waste produced in 2008 (calculated for specific measures in DSIP on
Landfills; Serbian Government, Chapter 27 Environment; Implementation Plan for Council
Directive 1999/31/EC of 26 April 1999 on the Landfill of Waste; Belgrade, March 2018).
7.1 Monitoring success of the measures taken
Monitoring the success of measures taken should rely as much as possible on different national
and international reporting obligations. However, in respect to the challenges for Serbia
(installation of separate collection systems, establishing home composting to a greater extent,
etc.) and the targets to be reached stipulated in the landfill directive, the WFD and the
packaging ordinance within a relatively small time span additional activities/investigations will be
required to monitor target achievement. This monitoring should start as early as possible in
order to adjust measures if necessary.
The following monitoring and documentation activities for assessing the successful
implementation of the measures shall be performed:
 Monitoring of quantities of waste streams which have relevant bio-degradable share
(generated by households, and commercial entities such as restaurants, retailers,
markets and food processing industries). Information should be provided on the
following waste flows. Partly the waste flows just can be calculated by summing up
specific waste streams.
o separately collected packaging and non-packaging cardboard and paper waste
(provided by schemes, if applicable);
o collected bio-waste via separately collection system;
o separately collected green waste from gardens and parks;
o residual municipal solid waste;
o composted waste in municipality composting facilities;
o mechanical-biological treated waste in simple MBTs;
o mechanical-biological treated waste in advanced MBTs;
o incinerated waste in thermal treatment plants for municipal waste.
 Representative morphological waste analysis for residual municipal solid waste shall
be carried out in regular intervals in order to enable evaluation of the key measures
such as introducing home-composting and separate collection of the biodegradable
waste fractions. In order to guarantee comparability of achieved data,
national/international standards for morphological waste composition analysis should be
applied;
 Key calculations on the amount of biodegradable waste finally disposed of at landfills,
recovered by home-composting and other biological treatment, thermally treated in
waste incinerators shall be carried out on a yearly basis based on the gathered
information on the amounts of waste.
 Documentation of all information and educational measures taken including lectures,
workshops on home composting and bio-waste management, such as mailings,
information provided via paper and electronic media.

7.2 Legislative instruments to implement the proposed measures
This Strategy, the Serbian Law on Waste Management and the Serbian Landfill Regulation are
the main strategic and legislative documents to establish the defined measures. Upcoming
Amendments should take the proposed roadmap and timeline into account. Exemplified by
following Articles, the Serbian Law on Waste Management specifically lays down requirements
in main areas the measures are defined: Article 20: Responsibilities Local Self-Government
Units; Article 21: Responsibilities for Joint Waste Management in Local Self-Government Units;
Article 35: Requirements for Collection and Transport of Waste; Article 37: Requirements for
Waste Treatment; Article 38: Requirements for Re-use and recovery; Article 40: Requirements
for Biological Treatment; Article 43: Requirements for Municipal Waste Management.
In addition, legislation on Special Waste Streams such as Packaging Waste (covering paper
and cardboard waste) is important in terms of introducing new obligations to enforce the defined
measures.
To enforce the implementation of the strategy on biodegradable waste a roadmap or feasibility
study shall be established
- to enable involvement of administrative levels and key stakeholders, and
- to specifically plan and facilitate all necessary steps in technical, administrative and
legislative terms.
The success of the implementation and achievement of defined targets highly depends on the
enforcement of institutional, administrative and technical infrastructure addressing the
municipality level, the self-governmental unit level, the provincial level as well as the ministry
level.
Single measures and related responsibilities are defined in Chapter 12.

Financial aspects National Waste Management Plan
8 NECESSARY CAPACITIES OF NEW ESTABLISHMENTS FOR

RECOVERY AND/OR DISPOSAL OF WASTE
8.1 Conclusion on the needs for new collection systems and additional
installations as well as on closing down of existing facilities
8.1.1 New collection systems and installations proposed
Based on the assessment of the actual status of waste management of different waste streams
and considering the future treatment options the following list with needs for new collection
systems and additional installations was established.
Table 70: Technical infrastructure to be established until 2025 [until 2035]
Level of
Measures for new Implementation status
implementation for Waste covered
infrastructure until 2025 [until 2035]
final stage
Establish door to door
bin/bag collection
system from
households including
vehicles for transport Municipal waste from
for: households (incl.
Household level 13 regions
- Mixed (residual) packaging waste, bio-
Municipality level [all 27 regions]
waste waste), mixed
- Source separated bio- municipal waste
waste
- Source separated
packaging waste and
recyclables
Establish a bring- Household waste (incl.
91 sites
system for citizens and packaging waste, WEEE,
Municipality level [Total territory, 169
construct public batteries, garden green
sites]
amenity sites waste, etc.)
Establish home
Households of rural
composting for citizens
municipalities of 13
in rural and semi-urban Household level Bio-degradable waste
regions
areas and give advice Municipality level from households
[all households of all
and support for
rural municipalities]
interested citizens
Establish secondary
13 regions, 10 facilities Municipal waste from
waste separation and
[Total territory, to be households (incl.
construct sorting
Regional Level assessed to have an packaging waste, WEEE,
facilities for recyclables
appropriate network batteries, hazardous
- regional waste
available] waste)
centres
Construct small scale
Green and park waste,
composting facilities
83 facilities source separated bio-
(lines) including turning
Municipality level [Total territory, 161 waste (garden and
machines and wheel
facilities] vegetable kitchen
loaders and vehicles
waste)
for transport
Construct large scale 4 facilities Green and park waste,
National Level
facilities for biological [Total territory, 11 source separated bio-

Level of
final stage
treatment of source waste (garden an
facilities]
separated bio-waste kitchen waste)
13 regions, 13 storage
areas / transfer stations
for non-hazardous
Construct storage areas
waste and 2 for
/ transfer stations to Mainly construction and
hazardous waste
enable sub-sequent Regional level demolition waste,
[27 storage areas /
storage before further hazardous waste
transfer stations for
treatment
non-hazardous waste
and 5 for hazardous
waste]
Establish mobile
13 regions, 13 facilities
treatment facilities for Mineral construction
Regional level [Total territory, 27
mineral construction and demolition waste
facilities]
and demolition waste
Construct physical 1 facility
-chemical treatment [Total territory,
plant to treat to be assessed to have Hazardous waste, waste
National level
hazardous waste an appropriate network oils
or a set of modules
available]
Construct advanced
mechanical-biological
2 facilities Residual mixed
treatment facilities
National level [Total territory, municipal (residual)
mainly for mixed
3 facilities] waste, sewage sludge,
municipal waste from
households
Construct simple
mechanical-biological 10 regions with sanitary
treatment facilities landfills, 10 facilities
Residual mixed
mainly for pre- [Total territory, to be
Regional level municipal (residual)
treatment of mixed assessed to have an
waste, sewage sludge,
municipal waste from appropriate network
households before available]
landfilling
Construct a waste
incineration plant for
1 facility Residual mixed
non-hazardous waste
National level [Total territory, municipal (residual)
to treat mainly high
1 facility] waste
calorific waste from
other pre-treatment
Construct small scale
2 facilities
waste incineration
[Total territory, Hazardous waste,
plants for hazardous
National level to be assessed to have medical waste,
waste to treat mainly
an appropriate network pharmaceutical waste
medical and
available]
pharmaceutical waste
Construct and start Regional level 4 facilities Non-hazardous waste,
operation of regional [Total territory, residual municipal solid
sanitary landfills for to be assessed to have waste

Level of
final stage
disposal of non- an appropriate network
hazardous waste available]
Construct a landfill National level 1 facility Hazardous waste,
site/cell for disposal of [Total territory, asbestos-containing
hazardous waste 1 facility] waste, medical waste,
pharmaceutical waste
In addition, the needs of infrastructure to be established in the period 2025-2035 for the
following waste streams shall be assessed in detail via feasibility studies in the time period
2020-2025:
 Large scale biological treatment facilities for source separated bio-waste;
 Secondary waste separation and sorting facilities for recyclables;
 Small scale incinerators for hazardous waste (including medical/pharmaceutical waste);
 Comprehensive network of regional sanitary landfills for non-hazardous waste;
 Simple pre-treatment of mixed municipal solid waste before landfilling (simple MBTs).
8.1.2 Proposed schemes for management of waste streams
In the following, management schemes for selected waste streams are presented. Those
schemes have been derived from the assessment conducted in previous chapters and should
give an overview of relevant infrastructure proposed to be established.

Figure 11: Waste management infrastructure for municipal solid waste (MSW)
Figure 12: Waste management infrastructure for packaging waste

Figure 13: Waste management infrastructure for WEEEs, batteries and accumulators
Figure 14: Waste management infrastructure for construction and demolition waste
Relevant waste stream:
C&D waste
Incl. special waste streams,
if hazardous, especially
mentioned:
Construction and - Asbestos containing
demolition waste waste
Mineral C&D waste

(incl. separated gypsum)
Transfer station /
interim storage and
possible treatment by
mobile installations
Asbestos Metals, plastics, Separated Hazardous

containing glass, paper and Mineral C&D waste C&D waste
waste cardboard, wood
Recycling/Recovery
Landfills Hazardous Export
facilities for metals, Recycling facilities
(dedicated cells for C&D waste or P/C-
plastics, glass, paper C&D waste
hazardous waste) Treat.
and cardboard, wood
Municipality Level (198 municipalities)

Regional Level (29 Districts)
National Level (Territory of Serbia)

Figure 15: Waste management infrastructure for hazardous waste

8.1.3 Closing down of existing facilities
Old landfills and identified dumpsites

The four new sanitary landfills were established according to the requirements of the EU
Directive on landfills. As stated in a preliminary assessment upgrading existing old landfill sites
and dumpsites to meet EU requirements is not a cost-efficient solution. Therefore, modern
regional waste management systems will be established and the operations of all non-compliant
sites will be discontinued through landfill closure, covering or waste removal. The suitable
process to overcome this issue needs to be supported by specific feasibility studies and
planning has to be done based on a risk assessment of all major landfills.
At the beginning of the closure procedure a risk assessment should be carried out covering the
following aspects: Volume or surface of landfill; Height of landfilled waste; Distance from
residential areas; Distance from surface water; Distance from arable land; Periodicity of landfill
covering; Number of gas wells; Groundwater elevation; Existence of landfill fence; Accessibility
to landfill; Measured/theoretical potential of methane production; Quality of leachate; types of
waste disposed of; geological conditions of the landfill area.
An assessment carried in 2017 out for 214 estimated landfills (it includes all municipal landfills
as well as dumpsites larger than 10,000 m3) show following results:
Table 71: Ranking of landfills according to the risk potentially posed to the environment
High risk Medium risk Low risk Total
Landfills and main
141 71 2 214
dumpsites
Each of the sites classified as a high-risk site has to be investigated in more detail, including
field activities in order to obtain the necessary information. Assessment of data shall be done
performing a comparison with established threshold values and deciding on actual risks posed
by a particular site. This stage of risk assessment shall be completed during the feasibility study
stage.
In general, the closure procedure shall comprise the following steps. In a first phase closure
includes the cessation of operations and the prevention of waste disposal at the non-compliant
landfills and dumpsites (include low cost measures as blocking access roads, fencing territory,
providing signs with information and other actions to be selected as most efficient in each
particular case). The second phase closure includes the re-cultivation of old sites and includes
undertaking environmental protection measures, landfill covering and provision of conditions for
vegetation growth in harmony with the surrounding nature. Re-cultivation also includes removal
of waste from smaller dumpsites and landfills to larger landfills under re-cultivation. After re-
cultivation, the former landfill location may be used for other purposes.
The closure of non-compliant landfills and dumpsites shall be planned in the described two
phases at regional level:
 First phase closure will include closure of all landfills immediately after new sanitary
landfills are opened and operational. This phase is already being implemented and will
continue until all planned regional landfills are established;
 Second phase closure will include re-cultivation of all landfills and will start after all new
regional sanitary landfills are established.

Until 2031 all non-compliant landfills and dumpsites at the territory of Serbia shall be closed
(see also Directive Specific Implementation Plan developed in 2018 for the Council Directive
1999/31/EC of 26 April 1999 on the Landfill of Waste). Up to 2024 following regions shall finalize
the second phase closure: Belgrade, Novi Sad, Kolubara, Užice, Subotica, Kragujevac,
Sremska Mitrovica, Kruševac, Zrenjanin, Pančevo, Vranje, Nova Varoš, and Pirot.
It is foreseen, that regions under PPP will be supported for the second phase closure – re-
cultivation, but not for the first phase closure. In addition, it is expected that only main landfills
will be eligible for central level support for financing, namely 141 official municipal landfills as
well as dumpsites larger than 10,000 m3, which pose risk for environment or human health. The
rest shall be taken care by municipalities using local resources.

8.2 Necessary capacities of new establishments needed for relevant

and special waste streams
The assessment of new/additional capacities needed is based on the current status (described
in chapters 2 and 5), the predicted development of waste generation (described in chapter 4)
and the assessment of future needs in chapter 6. This chapter shall provide only an abstract of
the information, based on the assumption that the implementation of municipal waste collection
and the stepwise implementation of targets defined in chapter 3 have started. Further details on
the necessary capacities can be found in the chapters quoted.
Municipal solid waste (Amount generated in 2025: 2.853.162 tonnes)

- Needs for collection/storage until 2025 [until 2035]
o Amenity sites: 91 sites [Total territory, 169 sites]
o Source separation in minimum thirteen regions [all 27 regions]
- Needs for treatment until 2025 [until 2035]
o Establish home composting for citizens in rural and semi-urban areas in minimum
thirteen region [all 27 regions]
o Large scale facilities for biological treatment of source separated bio-waste
: 4 facilities with total capacity of 200.000 tonnes/year [Total territory, 11
facilities]
o Advanced mechanical-biological treatment facilities mainly for mixed municipal
waste from households: 2 facilities with total capacity of 150.000
tonnes/year [Total territory, 3 facilities]
o Waste incineration plant for non-hazardous municipal waste: 1 facility with
total capacity of 340.000 tonnes/year [Total territory, 1 facility]
o Small scale composting facilities: 83 facilities with total capacity of 83.000
tonnes/year [Total territory, 161 facilities]
o Secondary waste separation and sorting facilities for recyclables: 13 regions, 10
facilities with total capacity of 250.000 tonnes/year [Total territory, to be
assessed to have an appropriate network available]
o Simple mechanical-biological treatment facilities mainly for pre-treatment of
mixed municipal waste from households before landfilling : 10 regions
with sanitary landfills, 10 facilities with total capacity of 600.000 tonnes/year
[Total territory, to be assessed to have an appropriate network available]
o Regional sanitary landfills for disposal of non-hazardous waste: 4 facilities
[Total territory, to be assessed to have an appropriate network available] 87
Construction & demolition waste

Secondary waste from waste treatment
Hazardous waste
Sewage sludge
87
Those facilities are necessary to comply with the EC Landfill Directive and Serbian national legislation that no
untreated Municipal Waste can be landfilled. Alternatively to MBT treatment two to three MSW incinerators can be
installed.

8.2.1 Municipal solid waste
Municipal solid waste (MSW), including postconsumer waste subject to specific obligations for
separate collection and recycling/recovery, is the most prominent waste stream for the future
development of the waste management infrastructure. There is a discrepancy in the data
provided in chapter 2.3.1. and in chapter 4.1.1 for the basis years (2014 to 2016). This
discrepancy is due to different ways of data collection and aggregation and a change in
assessment by SEPA in 2015.
The following objectives shall be reached by 2024/2025:
 Coverage of 100% for organized collection of MSW.
 Coverage of at least 55% for the (source separated) collection of packaging waste.
 By 2024 the collection rate of WEEEs (including postconsumer waste from households)
shall reach at least 20% of the EEE amount put into the market between 2021 and
2023.
The predicted amount of MSW (including separate collected fractions) in 2025 is about
2.850.000 tonnes for which a recycling target of 30%, i.e. 855.000 tonnes, should be achieved.
The amount of biodegradable waste landfilled has to be reduced to approx. 1.202.000 tonnes
based on the reference year 2008.
An assessment of the basic infrastructure (amenity sites, containers/bins, composters,
composting sites) required for of these targets was performed during the Environmental
Infrastructure Support Programme. According to this assessment (see Table 54) in total 151
amenity sites and 160 composting sites are required by 2025.
The number of compliant sanitary landfills should be increased to 24 by 2025 while non-
compliant dump-sites shall be closed down consequently. Thus the average capacity to be
provided by each landfill is in the range of 80.000 tonnes per year.
In order to reach the reduction goal for biodegradable waste going to landfills and the recycling
goals a combination of
 Source separation (green waste, paper and cardboard, etc.) based on an at least two
bin system,
 Secondary sorting (including MBT) and
 Waste incineration (waste-to-energy) is envisaged.
To reach these goals in the first implementation phase (2024) at least eight sorting facilities for
separate collected recyclables (“dry bin”) are required.
For secondary sorting and biological pre-treatment one MBT with a capacity of 75.000 tonnes
per year is foreseen. Since a relevant part of the output of a MBT-plant is RDF the
implementation of MBT has to be adjusted to co-incineration capacities available.
By 2025 a waste-to-energy facility at Belgrade with a total capacity of 340.000 tonnes per year
is assumed to be operative.
Although packaging material is listed in chapter 15 01 of the waste list postconsumer packaging
waste is regarded as part of the MSW.
In 2018 only 6% of Serbia is covered by a collection scheme for packaging waste from
households. By 2024 this number should increase to at least 50% and further increase to 55%

in 2025. Separate collection will be introduced as door-to-door collection (at least on separate
bin for packaging or recyclables) or as drop-off-system (via amenity sites and collection points -
separate collection of plastics, glass, metals, etc.) or as combination (different collection system
in dense populated and remote area). Since postconsumer packaging is regarded as part of
MSW collection relevant infrastructure (amenity sites, etc.) is already included in chapter 8.2.1.
8.2.3 WEEEs (including fluorescent tubes)
Collection of WEEEs from consumers shall be organized in accordance with the DSIP for
Directive 2012/19/EU
 Via retailers (1:1 take back) and
 Civic amenity sites.
Thus the number of collection point at amenity sites is already covered in chapter 8.2.1.
The envisaged collection rate for WEEEs is 20% in 2024 from EEE placed on the market in
three preceding years. Based on the forecast amount of EEE placed on the market 2020 to
2023 this would be in the range of 15.000 tonnes in 2024 while the existing
recycling/dismantling capacity is already in the range of 20.000 tonnes per year. Therefore,
there is not necessary to make investments on short term into new infrastructure for
dismantling/recovery of WEEEs However the quality of the recycling/treatment of WEEEs has to
be upgraded to comply with the requests of Directive 2012/19/EU.
The assessment made in chapter 6.3.13 concluded that there is an opportunity to have
investments in regional Western Balkan WEEE treatment based on the fact that such
installations need to be cost effective and the amounts which might be collected in Serbia on
medium/long term near don’t sustain such an investment. Regarding the financing aspects it is
expected that the EPR schemes will ensure a proper funding.
Investments in upgrading will be market driven, provided the EPR schemes for WEEE are
required to prove the quality of recycling. Specific attention require the treatment/recycling of
mercury-containing fluorescent tubes and CFC-containing equipment. For both types of waste
specialised treatment facilities are required (confirming with the WEEEBALEX standards). For a
transition period (as long as the collection rate is low) export to qualified treatment and recycling
facilities are an option. With increasing amount collected at least one specialised facility for
CFC-containing equipment and one for mercury containing florescent tubes are required.
For the assessment of necessary (additional) infrastructure hazardous waste can be divided
based origin into the following types:
 Hazardous waste from households
 Hazardous secondary wastes (from professional waste disposal)
 Hazardous waste from production
Furthermore hazardous secondary wastes and hazardous production wastes can be divided
into:
 Recyclables/secondary raw material and
 Waste for disposal (incineration, landfilling, physical-chemical treatment)
The separate collection of hazardous wastes from households is essential to reduce the risk to
the environment associated with landfilling/dumping of MSW. Infrastructure to provide a

separate collection of hazardous wastes from households is included in chapter 8.2.1.

Hazardous wastes from households compromise of two different waste streams:
 Waste that are subject to EPR schemes and recycling targets (waste batteries,
hazardous WEEEs including fluorescent tubes, etc.). Separate collected amounts of
these wastes will be fed in to the recycling system directly.
 Residues of consumer products like paint and lacquers, pesticides, chemicals used in
households (e.g. drain cleaner), etc.
The later wastes are normally to be excluded from landfilling (even at a landfill for hazardous
waste). Depending on their chemical composition, they should be disposed of in a physical-
chemical treatment plant or incinerated. The total amount in 2024 can be estimated in the range
of 2.000 tonnes to 6.000 tonnes. Depending on the investment into hazardous waste
incineration, these wastes may be incinerated in Serbia or exported for disposal D10.
To a small amount asbestos containing wastes (especially asbestos cement products) may be
collected via civic amenity sites. Such wastes should be proper packed and landfilled in specific
designated areas of sanitary landfills.
Hazardous wastes from waste treatment (secondary wastes) can be either recyclables (e.g.
waste oil derived from treatment of oil/water mixtures; metal bearing fractions from WEEE
treatment; etc.), which will be fed into the recycling circle, or wastes requiring thermal treatment
(e.g. mixed shredding residues; solvent/water mixtures; etc.), or (eventually stabilized by a
physical-chemical pre-treatment) wastes for landfilling (e.g. residues from waste incineration;
stabilized sludge from physical-chemical treatment). Depending on the investment into
hazardous waste incineration, wastes requiring a thermal treatment may be incinerated in
Serbia or exported for disposal D10. Stabilized hazardous wastes may be co-disposed in
specific cells of sanitary landfills.
The total amount of hazardous wastes for landfilling can be assumed in the range of 76.200
tonnes to 165.000 tonnes (including contaminated soil and mineral waste from C&D activities)
for 2024. Given that a part of these wastes has a higher density as MSW a volume at specific
volume of sanitary landfills of about 40.000 m³ to 87.000 m³ will be required (i.e. an average of
about 3.625 m³ per landfill, compared to 80.000 m³ for (pre-treated) MSW (less than 5% of
volume to be provided per year)).
8.3 Site selection criteria
8.3.1 General site selection
While the minimum site selection criteria for landfill sites are well defined specifically in Annex I
of the REGULATION ON WASTE LANDFILLING they are not so strictly defined for other types of
waste management installations. Minimum requirements for the site selection therefore are
based on a case by case decision, taking into account the type of installation, general spatial
planning and exclusion criteria provided by applicable law.
To define the specific site selection criteria the possible impact of the installation to the
environment (e.g. emissions to air and water, smell, noise, generated traffic), the specific
requirements of the installation (e.g. energy supply, water supply, demand of space), the supply
with waste (e.g. location near to waste producers), the disposal or use of processed material
(e.g. distance to sanitary landfill, distance to co-incineration plant) have to be taken into
account.

Based on these general criteria the site selection in a designated commercial or industrial zone
is in most cases the preferred option. It has to be noted, that specific waste treatment
installations may be covered by (upcoming) legislation implementing Directive 2012/18/EU on
the control of major-accident hazards involving dangerous substances. In such case, also other
relevant installations nearby have to be taken into account (avoidance of domino effects in the
event of an accident).
Based on these deliberations site selection shall follow the following step-by-step approach:
 Define the specific exclusion criteria and minimum requirements of the specific
installation Exclusion criteria shall include all applicable law.
 Define additional selection criteria (criteria for a favourable site).
 On the basis of the results of large scale exclusion criteria, small scale exclusion criteria
and evaluative criteria are applied to the searching areas. (GIS can be used as a tool,
provided the necessary information on sites is available in the system.)
To identified sites the additional selection criteria for a favourable site are applied in a system of
graded assessment (++/+/ 0/ -/--) and – by superposing these criteria - areas of graded aptitude
are determined. This is a highly iterative and evaluative process. Such evaluative criteria of
importance inter alia are:
 Distance to settlements;
 Position within or in proximity of important water bodies;
 Proximity to important biotope or areas of national heritage;
 Proximity to areas of special public interest (military areas, airports etc.);
 Favourable conditions for water and electricity supplement;
 Favourable conditions concerning availability of the ground;
 Favourable conditions concerning technical suitability of the building ground;
 Favourable distance to railway, waterway and/or highway;
 Proximity to other waste and wastewater activities (e.g. waste water treatment);
 Favourable conditions concerning main direction of wind;
 Favourable conditions concerning potential work places.
As a result of the searching procedure, a number of alternative sites should be safeguarded by

legally prescribed administrative planning processes, i.e. by introduction of the selected site(s)
in the Regional Planning documents to safeguard this space for waste management purposes
for a long time and independent of the duration and result of the political struggle which is
common within Regional Planning processes with its competitive interests.
8.3.1.1 Specific site selection criteria for civic amenity sites

In accordance with the assessment of necessary infrastructure for MSW the installation of 151
civic amenity sites is envisaged. These sites can be quite different in size and differ in the types
of waste for which they provide collection. Thus the minimum requirements and the absolute
and relative exclusion criteria have to adapt on a case by case basis.
While in general an adequate distance to residential areas is a minimum criterion for site
assessment for a waste management site (“the farer the better”) in case of civic amenity sites
there is often the need for a compromise between favourable distance to housing areas and
accessibility to the public.
Thus not only the absolute distance to the next settlement or residential area should be taken
into account, but also e.g. the main wind direction. As a compromise in some cases (especially
in urban areas), the collection centre can be installed within a closed yard or the types of waste

collected can be restricted (excluding e.g. wastes that may lead to smell, like bio-waste/kitchen-
waste).
As absolute exclusion criteria can be defined close distance (< 300 m) to vulnerable
communities like hospitals, schools, kindergarten and day-care institutions. Also potential flood
areas have to be excluded. Minimum requirement on the other hand are sufficient infrastructure
support (electricity, water supply, sewer), accessibility (waste collection trucks and container
vessels) and sufficient parking space for clients.88
8.3.1.2 Specific site selection criteria for composting sites

Composting is a biological process producing also volatile and odour intensive substances.
Beside the odour-intensive substances produced in the process specific types of waste (kitchen-
waste, separate collected bio-waste containing kitchen waste, sewer sludge) are liable to
generate odour-intensive emissions themselves. Thus the types of waste to be composted, the
total amount and the frequency of waste delivery have to be taken into account. Furthermore,
the way type of composting facility (open heap, indoor) is relevant and the intensity of odour is
influenced by the way the process is performed. Also the local climate (rainfall, main wind
direction, etc.) have to be taken into account.
In case the minimum criteria for the distance to housing areas from technical guidelines cannot
be complied with an assessment in accordance with the Standard SRPS EN 13725:2010 Air
quality - Determination of odour concentration by dynamic olfactometry can be made.
In specific technical guidelines the following minimum distance criteria for open composting
sites are requested:89
Open heap composting
Capacity ≤ 1.000 t 1.001 – 5.000 t 5.001-10.000 t 10.001-20.000 t
Minimum
< 300m < 300m < 300 m 300 - 500 m < 500 m 500 -1.000 m
distance
Only green
√ EN 13725 EN 13725 √ EN 13725 √
waste
Bio-waste and
EN 13725
sewer sludge
EN 13725: an opinion in accordance with SRPS EN 13725:2010 is required
Table 72: Minimum distance of composting facilities to housing areas
Closed waste acceptance area and closed composting area

1.001 – 5.000
Capacity ≤ 1.000 t 5.001-10.000 t 10.001-20.000 t
t
Minimum
< 300m < 300m < 300 m 300 - 500 m < 500 m 500 -1.000 m
distance
Only green
√ √ √ √ √ √
waste
Bio-waste and
EN 13725
sewer sludge
EN 13725: an opinion in accordance with SRPS EN 13725:2010 is required
Table 73: minimum distance of indoor composting facilities to housing areas
However the minimum distance to specific vulnerable persons/sites (e.g. hospitals, day-care
centres, schools, etc.) should be at least 1.000 m. In these cases not only the odour but also
other emissions (e.g. fungal spores) are relevant.
88
http://www.hazardouswasteserbia.info/fileadmin/inhalte/haz_waste/pdf/Deliverables/Hazardous_waste_guide_
SRB_for_web.pdf; Hazardous Waste Guide for municipal experts
89
Stand der Technik der Kompostierung, BMLFUW 2005

Further criteria to be taken into account in site selection are

 Local climate (average/maximum rainfall expected, wind);
 Distance to groundwater (note: Only small installations for treatment of < 500 m³/year of
green waste only don’t need a sealed surface with collection of the leachate;
rainfall/surface water that did not come into contact with the waste can be drained.);
 Traffic
Composting plants with a capacity exceeding 50 tonnes per day (i.e. 18.250 tonnes) are
subject to the IE-Directive and therefore the BAT document for waste treatment 90 is applicable.
The BAT-conclusions (chapter 5 of the BAT document) have to be applied mandatory in the
European Union (Commission implementing Decision (EU) 2018/1147).
8.3.1.3 Specific site selection criteria for sorting plants

The specific requirements for sorting plants need take into account the type of waste processed.
 Dry bin waste;
 Other recyclables like separate collected metal, glass, paper, plastics, textiles;
 Wet bin waste (MSW; secondary sorting plant).
Minimum distance of sorting plants for dry bin waste/ packaging material to housing areas
should be at least 300 m, while other sorting plants (secondary sorting) should have a distance
to settlements of at least 500 – 700 m (Note: it can be preferable to install sorting plant at/near a
landfill site using synergies in the installation). Microclimate has to be taken into account
(average/maximum rainfall, wind and main wind direction).
Sorting installations with a capacity of more than 50 tonnes per day (18.000 tonnes per year)
should apply the BAT document for waste treatment.
8.3.2 Landfill sites
The Directive 1999/31/EC (in Serbia transposed by the REGULATION ON WASTE LANDFILLING
("Official Gazette of the Republic of Serbia ", No. 92/2010) in combination with the REGULATION
ON CATEGORIES, TESTING AND CLASSIFICATION OF WASTE (“Official Gazette of the Republic of
Serbia“, No. 56/10) is based on a multi-barrier concept to secure the long-time stability and
security of a landfill site. This concept is based on
 the site (the geological barrier);
 the bottom liner system and the surface liner system (the technical barrier);
 The landfill body - type of waste (the inner barrier).
Following this concept, the site-selection becomes the most important step for the long-time
safety of landfills. The geological situation has to be in line with waste intended to be landfilled
(type of landfill). Furthermore during the active phase of the landfill a strict input control has to
secure that all wastes landfilled comply with the concept of the inner barrier.
8.3.2.1 General requirements

The general requirements of Annex I of Directive 1999/31/EC are transposed by Annex I of the
REGULATION ON WASTE LANDFILLING. The requirements include an assessment of
 Minimum distance to settlements (500 – 700 m)
 Distance to surface water body and groundwater body;
90
http://eippcb.jrc.ec.europa.eu/reference/

 Topographic situation (e.g. slope; etc.);

 Climate (rainfall, maximum rainfall, wind, etc.);
 Geological situation (e.g. minimum natural barrier – depending on the type of landfill).
Areas to be excluded are
 Areas with protected water body (including thermal water);
 Flood area;
 Special protected areas (e.g. health care facility; natural spas);
 Natural conservation areas;
 Areas of national heritage;
 Technical infrastructure protection zones.
Beside these criteria, the following points have to be considered
 Available area (the active period of the landfill shall last at least 20 years)
 Traffic infrastructure (access road)
 Spatial planning
8.3.2.2 GIS as searching tool
To identify suitable areas the Geographical Information System (GIS) is an important tool. GIS
has the capacity to process large amounts of spatial data provided that the data is available.
GIS can be used for data visualisation and map preparation but also for modelling and analysis
within catchment areas. Input data of a GIS can cover spatial information on various different
fields including:
 Hydrogeology;
 Geology (natural barrier & construction material availability);
 Hydrology (Wetlands, Surface waters, inundation areas, ground water aquifers;
 Elevation data (Digital elevation model) and Slope;
 Land (use, cost, availability);
 Settlement areas (areas of waste generation);
 Roads, Railways, Airports;
 Network infrastructure (Pipelines, power lines).
It is important to realize that GIS analysis is not a substitute for field analysis; however, it does
identify areas that are potentially suitable for a new landfill and such that can be excluded from
the decision process due to the defined criteria. The exclusion process can be processed in an
economical way by using GIS and allows the graphical presentation of the decision process
(Sener et al. 200691; Boško et al. 201292).
8.3.2.3 Public participation
Public participation is very important to gain acceptance of decisions, which have impact on
people´s life. Therefore, it is important to involve all relevant stakeholders from an early stage of
the project. The Environmental Impact Assessment (EIA) is an important instrument to balance
the diverging interests the protection of the environment and the growth of the economy
(Schönherr, 201393).
91
Şener, B., Süzen, M.L. & Doyuran V. (2006) Landfill site selection by using geographic information systems. Environ
Geol 49: 376. https://doi.org/10.1007/s00254-005-0075-2
92
Boško Josimović and Igor Marić (August 1st 2012). Methodology for the Regional Landfill Site Selection, Sustainable
Development Sime Curkovic, IntechOpen, DOI: 10.5772/45926.
93
Schönherr (2013): Slovakia: Public Participation in Environmental Impact Assessment Procedures – a Blessing and a
Curse? http://roadmap2013.schoenherr.eu/public-participation-in-eia-procedures/

8.3.2.4 Environment impact assessment (EIA)
In accordance with the Law on Environmental Impact Assessment (“Official Gazette of the
Republic of Serbia“, No. 135/04 and 36/09) and the Regulation on the establishment of the List
of projects for which the impact assessment is mandatory and the List of projects for which the
environmental impact assessment may be required (“Official Gazette of the Republic of Serbia“,
No.114/08) the establishment of
 Landfills for hazardous waste, and
 Communal waste landfills for over 200,000 population equivalent
Always require an EIA procedure, while the construction of a
 Communal waste landfills with a capacity of up to 10 tonnes per day or
 A total capacity of up to 25,000 tonnes
may require an EIA.
8.3.2.5 Stepwise approach to identify suitable landfill sites
In the guidance note94 of the European Commission on how to prepare a waste management
plan a planning horizon for immediate action is three to five years, whereas longer planning
horizons might be necessary for long-term perspectives.
“The reason for the long-term perspective part of the plan is that considerable difficulties can be
expected in identifying suitable sites for waste treatment facilities or landfills within, or close to,
urban areas. Furthermore, it will be necessary to put considerable effort into site selection,
environmental impact assessment, and public consultation in order to obtain permission for new
sites. Finally, waste treatment facilities represent large investments that need to be recovered
over a longer period.”
This perception of the European Commission, the knowledge about environmental risks of
landfills as well as the multi-barrier-concept makes the importance of the site selection for new
landfills clear. The selection of the site of for a landfill can be considered the most important task
in the design phase of a landfill. Adequate site selection minimizes risks of groundwater
pollution and the negative effects on the environment areas.
Thus to select a landfill site in a defined procedure, the criteria have to be structured and
ordinated, corresponding to the strictness of criteria in:
 Exclusion criteria and minimum requirements (in line with the proposed type of landfill –
inert waste – non-hazardous waste – hazardous waste), whose fulfilment is compulsory,
otherwise the site is excluded from further search procedure;
 Evaluative criteria (or selection criteria) with graded importance within the searching
procedure, and;
 Supplementary criteria, whose fulfilment is a useful addition for the decision making
process.
While the exclusion criteria and minimum requirements are defined by the law, the evaluation
criteria and the supplementary criteria have to be taken into account and addressed in the final
selection process to gain the best overall decision.
The evaluative criteria are applied to the residual areas and enter into competition with other
planning purposes. The criteria are put into a system of graded assessment (++/+/ 0/ -/--) and –
94
http://ec.europa.eu/environment/waste/plans/index.htm

by superposing these criteria - areas of graded aptitude are determined. This is a highly iterative
and evaluative process. Such evaluative criteria of importance are:
 Distance to settlements;
 Position within or in proximity of important water bodies;
 Proximity to important biotope, archaeological monuments and natural testimonies;
 Proximity to areas of special public interest (military areas, airports etc.);
 Proximity of and accessibility to important traffic infrastructure (railway, waterway,
highway).
Note that these evaluation criteria are also exclusion criteria, if the minimum requirements
defined in law are not met.
The supplementary criteria should also enter into the site selection and evaluation process
because they describe circumstances marking the social, technical or economic feasibility of the
resulting site. Such criteria can be:
 Favourable conditions for water and electricity supplement;
 Favourable conditions concerning availability of the ground;
 Proximity to other waste and wastewater activities (e.g. waste water treatment -
leachate treatment);
 Safe and nearby disposal of effluents;
 Favourable conditions concerning main direction of wind;
 Favourable conditions concerning potential work places.

9. ORGANISATION OF WASTE MANAGEMENT,

INCLUDING DIVISION OF RESPONSIBILITIES
BETWEEN PUBLIC AND PRIVATE SECTOR IN THE
AREA OF WASTE MANAGEMENT
Waste management systems should be developed to cover the management of all waste except
emissions into the air, waste water, radioactive waste, fallen stock and agricultural waste
(natural, non-hazardous, used in agriculture) as other substances that are listed in the Law on
Waste management Article 4. Essentially waste management systems can be divided into two
parts:
 Management of municipal waste (post-consumer waste);
 Management of production waste and wastes from other economic activities.
The function of organizing municipal waste management is attributable to public sector

responsibility, according to Low on waste article 20 it is responsibility of local self-government
unit. While management of production waste and wastes from other economic activities is
responsibility of producers and entities engaged in economic activities. Public authorities shall
establish the essential requirements ensuring the safety of workers, the protection of the
environment and human health from pollution by waste. Each economic entity and public
authority, in accordance with these requirements, can choose the most appropriate ways or
means of waste management.
One of the most important aspects of these two groups is the principle of the producer’s
responsibility for the environmental impact of the product, as the producer has the greatest
influence on the formation of this effect when taking important decisions at the stages of product
design and production process design and production. However, consumers play a major role in
the waste management systems. It is important to analyse the entire life cycle of a product and
understand both the main players, both the producer and the consumer, when developing waste
management systems for individual waste types.
Another important aspect is to ensure the financial viability of systems. The costs of waste
management in accordance with the polluter-pays principle shall be borne by the holder of the
waste and/or by the producer or importer of the materials and articles for which the waste is
generated. To fully implement the polluter pays principle, Rulebook on adjusted amounts for the
environmental pollution tax (“Official Gazette of the Republic of Serbia “, No. 43/17) establishes
a tax for environmental pollution by waste products.
9.1 Public sector
In the field of waste management, the public sector generally carries out regulatory and service
control functions. However, local self-government units also have to ensure the organization
and implementation of municipal waste management that is to create a system of municipal
waste management in the territory.
Municipal waste management system is a set of organizational, technical and legal measures
related to the implementation of municipal functions in the field of waste management. It should
cover household waste, as well as other waste which is similar to household waste due to its
nature or composition and other waste generated in the territory of municipalities that are not
included in the production waste and wastes from other economic activities management
systems.

Local self-government units are the main link that organizes the management of municipal
waste generated in the respective territory. They are responsible for the regulation,
development and administration of municipal waste management systems in their territories.
Local self-government approve the local waste management plan and other municipal waste
management regulations governing the system of municipal waste management. The rules are
binding on all natural and legal persons located in the territory of the municipality. The
implementation of the provisions and requirements of the rules must ensure the rational
management of the management of municipal waste, the proper fulfilment of public waste
management tasks and financial obligations. All waste holders must pay for waste management
costs and comply with established waste management requirements. Household waste that
forms a high proportion of municipal waste must be managed in accordance with the
requirements of waste management legislation, all their handling costs should not exceed 1.5 95
percent of the average family income. Social policy must be implemented through social
programs, not by means of waste management companies.
The main task of local self-government units is to offer a public service for the management
(collection, use and disposal) of municipal waste to all residents and economic entities
(enterprises, institutions and organizations), to ensure that the service meets environmental,
technical-economic and hygienic requirements, is convenient and available to users.
For the implementation of the measures provided in this plan each level of institutions need to
establish general skills in areas like: strategic planning, financial management, procurement,
project implementation, monitoring and control. For development of local waste treatment
services and for implementing large-scale projects, the local authorities shall be obliged to
upgrade their skills to deliver modern standards in the collection and reporting of data, analysis
of waste composition and generation, modelling future changes, specification of necessary
equipment, provision of monitoring, evaluation and auditing of internal and outsourced
contracts.
In order to help self-government institutions is promoted the so-called regional approach in
overall waste management. This approach involves the establishment of cooperation and
grouping of local governments into regions in order to establish a sustainable waste
management system and rationalize costs of implementation. If the regional approach is to be
promoted, the existing policy, legal and administrative framework governing local government
bodies needs to ensure that there is an adequate basis for inter-municipal co-operation, as well
as sufficient capacities for development and implementation of waste management policy. The
state supports the development of regional waste management systems.
To date, the regional waste management system in Serbia is not fully functional for the following
reasons:
 Not all municipalities have concluded agreements for the development of regional
systems;
 There are differences between regions, in some regions private companies are involved
in municipal waste management (including collection, treatment and etc.) in others
public enterprises whose owners are municipalities is established. In this way there is
no equal opportunity to control the organization and development of municipal waste
management;
 There is no clear regulation of the rights and obligations of participants in the regional
municipal waste management (e.g. there is no clear definition of regional waste
management centres);
95
The maximum affordability of households necessary to cover OPEX costs in waste sub-sector
is defined at 1.5% threshold of average household income.

 Municipalities do not have enough human resources to deal with all waste management
issues. Most of the functions related to waste management tasks could be delegated to
regional inter-municipal companies established by the municipalities;
 Regional entities are not created and are not being developed as centres of
competence in the field of waste management. A great attention must be paid to the
company’s staff training.
The regional waste management systems will function properly only if, together with the inter-
municipal agreements, the organization – municipal waste management administrator, which
could be responsible for the implementation of municipal functions at the regional level, is
established. These self-government functions could be transferred to a municipal waste
management administrator:
 To organize a tenders for the selection of the waste managers who provides the municipal
waste management services;
 To develop local and regional waste management plans;
 To submit proposals to the local self-government units for the improvement and
development of the system of municipal waste management;
 To collect, analyse information on the management of municipal waste in the territory of
the municipality and /or waste management in the region;
 The implementation of measures of local and regional waste management plans (project
implementation) ensuring the implementation of the tasks specified in the National waste
management plan;
 To control waste collection and treatment services, signing and control of agreements;
 To conclude contracts with municipal waste holders, to collect and administer of waste
management related fees;
 To implement public information, education and training measures in the field of municipal
waste management;
 Overtaking other responsibilities of local authorities in the field of municipal waste
management.
It should be noted that in order not to violate the principles of competition, it is recommended to
transfer only municipal functions, i.e. administrative functions. That means that such regional
company could perform municipal waste management (collection, treatment, and disposal)
functions only in cases where it would not be possible to ensure the continuity and availability of
waste management services in other ways when there are no other active participants in the
market. State and local self-government institutions must take organizational action if the
existing technological capacity does not ensure the necessary level of waste management, and
the business entities themselves do not develop new technological capacities and/or provide the
necessary waste management services.
Given that municipal waste management services are services of general economic interest the
provision of municipal waste management services without a tender may be entrusted to an
established company if these requirements are satisfied 96:
 the recipient undertaking must have public service obligations and the obligations must be
clearly defined;
 the parameters for calculating the compensation must be objective, transparent and
established in advance;
 the compensation cannot exceed what is necessary to cover all or part of the costs
incurred in the discharge of the public service obligations, taking into account the relevant
receipts and a reasonable profit;
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 Where the undertaking which is to discharge public service obligations is not chosen
pursuant to a public procurement procedure which would allow for the selection of the
tenderer capable of providing those services at the least cost to the community, the level
of compensation needed must be determined on the basis of an analysis of the costs of a
typical well-run company.
By ensuring these criteria will be ensured that public service compensation does not constitute
State aid when Serbia will join European Union97.
9.2 Private sector
As mentioned above the responsibility for the management of production waste and waste from
other economic activities lies with the private sector.
The management of waste from production and other economic activities includes
organizational and technical measures implemented by operators who have integrated pollution
prevention and control permits or emission allowances that are prepared and issued in
accordance with the procedure established by legal acts for the management of waste and/or
the waste generated by the operation is not a municipal waste, therefore this waste is not
necessarily managed in the municipal waste management systems organized by the local
authorities.
Production waste and wastes from other economic activities include industrial waste, including
hazardous and biodegradable waste, construction and demolition, medical and pharmaceutical
waste, sewage sludge and other waste. The management of production waste and wastes from
other economic activities at the state level is regulated by environmental and other normative
documents, regulations on the management of specific waste flows, permits issued for the
operation of facilities. Ensuring that waste from production and other economic activities is
managed is a duty of economic operators, performed in accordance with the requirements and
principles of the general waste management system and in co-operation with the operating
waste managers.
The collection and sorting, packaging, labelling, accounting, storage and transfer of waste from
production and other economic activities shall be the responsibility of the waste handlers and/or
holders who, in accordance with the polluter-pays principle, must cover all waste management
costs.
Management of the waste of production and other economic activities should be organized by
the enterprises in accordance with the procedure established in the permits issued for the
operation of the installations in accordance with the priorities of waste prevention and
management, as well as taking all possible and economically justifiable measures for waste
reduction, preparing environmental action plans, introducing cleaner production principles and
low waste technologies.
Undertakings which are not required to obtain permits for economic activity carried out by them
or for operation of equipment organize management of production and other economic activity
waste according to the priority order of waste prevention and management (as appropriate) in
compliance with the requirements of the environmental protection and other legal acts and in
cooperation with operating waste managers.
97
When financing public infrastructure from EU support, it is important to align the support provided with EU state aid
rules. In any case, the European Commission asks for a transparent, non-discriminatory tender to ensure fair
competition between the private partners. On the other hand, in the project, both in the public and in the private
sector, different levels of EU support can be envisaged.

IMPLEMENTATION OF PRODUCER RESPONSIBILITY PRINCIPLE
For applying the producer responsibility principle, producers and importers are responsible for
products and packaging placed by them on the internal market over the whole life cycle from
production to safe waste management, including the organization and/or financing of the system
of collection, shipment, recycling, recovery and disposal, achievement of targets set for
management of product and packaging waste, provision of information on products, packaging
and management of their waste to users of such products and waste management operators,
acceptance and management of returned products and waste resulting from their use, and
financial responsibility for such activities.
The producer responsibility principle is applied in management of waste of packaging, tires,
accumulators, batteries, internal combustion engine fuels, oils, air intake filters, and hydraulic
(oil) shock absorbers of vehicles, electrical and electronic equipment, motor vehicles and oils.
The product and packaging waste management system based on the producer responsibility
principle is organized by applying:
 economic measures;
 administrative measures;
 information measures.
Producers and importers may carry out the obligations established for them either individually or
collectively, except for packaging producers and importers who can fulfil their obligations only
collectively (except for packaging used for their own needs).
For the purpose of collective organization of product and packaging waste management which
is subject to the producer responsibility principle, in order to fulfil the established obligations and
targets, on the initiative of producers and importers and licensed organizations of producers and
importers, non-profit public legal entities are being set up.
Private sector (producers) responsibility for managing different waste streams:
1. Producers and importers of electrical and electronic equipment, batteries and
accumulators are responsible for the organization of collection, shipment, preparing for
recovery, and recovery of waste of electrical and electronic equipment, batteries and
accumulators placed by them on the internal market and for bearing the costs, as well
as for the organization of education and awareness-raising of the public and for bearing
the costs;
2. Producers and importers of industrial, automotive or portable batteries and
accumulators are responsible for the establishment of a waste collection system which
would enable consumers to return such waste free of charge;
3. Producers and importers of packaging are responsible for the organization of sorted
collection, shipment, preparing for recovery, recovery and bearing the costs of all
packaging waste resulting from the use of packed products placed by them on the
market, as well as for the organization of education and awareness-raising of the public
and for payment of costs;
4. Producers and importers of transport vehicles are responsible for the establishment of a
convenient management system of the end-of-life vehicles, organization and payment
of costs of collection, shipment, preparing for recovery and recovery of the end-of-life
vehicles, as well as for the organization and payment of costs of education and
awareness-raising of the public;

5. Producers and importers of motor vehicle parts, including tyres, internal combustion
engine fuel and oil filters, internal combustion engine air intake filters and hydraulic (oil)
shock absorbers, are responsible for the organisation and payment of costs of
collection, shipment, preparing for recovery and recovery of waste generated during
operation of vehicles, as well as for the organisation and payment of costs of education
and awareness raising of the public, organisation of the system in a manner which
enables the owner of a vehicle to deliver such waste free of charge to undertakings
providing motor vehicle technical maintenance and repair services;
6. Producers and importers of oils are responsible for the reimbursement of the costs of
collection of waste oils of negative value or of no value and for their shipment for
management to undertakings providing motor vehicle technical maintenance and repair
services and to waste management operators.
9.3 Conclusions on the division of responsibilities
In order to operate efficient waste management systems, the private and public sectors must
seek ways of cooperating in managing different waste streams:
1. Producers and importers of electrical and electronic equipment should participate in the
organization of electrical and electronic equipment waste management in municipal
waste management systems organized by local self-government units or municipal
waste management administrators, in which they should co-finance the costs of
operation of bulk waste collection sites and of collection of waste electrical and
electronic equipment of households delivered to such sites;
2. Packaging producers and importers should participate in the organization of
management of packaging waste in municipal waste management systems organized
by local self-government units or municipal waste management administrators in which
they pay the costs of development of the infrastructure of the system of collection of
packaging waste generated in the flow of municipal waste and the costs of sorted
collection, shipment, preparing for recovery and recovery of packaging waste;
3. Producers and importers of transport vehicles and licensed organizations of producers
and importers and undertakings should engaged in management of the end-of-life
vehicles cooperate with local self-government units or municipal waste management
administrators in order to clean yards and other areas from abandoned end-of-life
vehicles;
4. Producers and importers of packaging, electrical and electronic equipment, batteries
and accumulators, and taxable products, in order to achieve the targets set for them
and to organise the management of all generated waste of packaging, electrical and
electronic equipment, batteries and accumulators, and taxable products (excl. tires),
may implement systems that supplement the municipal waste management systems of
municipalities.
To ensure proper management of municipal waste, local self-government must decide whether to
develop the necessary infrastructure or to provide services:
1. directly, based on internal organizational resources, i.e. administration (e.g.: management
of certain infrastructure through municipal administration specialists);
2. through a separate institution and enterprise (e.g. municipal waste management
administrator) established and fully controlled by a public entity;
3. full transfer of responsibility to the private sector (rare cases, i.e. completely abandoning
the public function by privatization of communal infrastructure).

When looking for opportunities to cooperate with the private sector (in cases where its own
resources or experience and expertise are lacking), but is not intended to completely abandon
public sector control of the services provided, the public sector has two additional alternatives
for organizing waste management:
4. contractual public private partnership - to obtain the necessary resources from the
private sector based on a contract (directly or through an entity controlled by a local
self-government), e.g. concession and other contracts;
5. institutional public private partnership - to set up a joint venture, jointly with a private
investor, directly or through an entity controlled by the local-self-government.
As mentioned above, it is recommended that self-governing institutions for managing municipal

waste set up regional enterprises, transfer their self-government functions in the field of waste
management, but ensuring constant control over the functions performed through the
management bodies. The provision of municipal waste management services and the
construction and operation of the necessary infrastructure should be ensured through public
procurement procedures, contractual or institutional public private partnership.

10. SOURCES AND AMOUNTS OF FINANCIAL FUNDS

FOR REALISATION OF ALL WASTE MANAGEMENT
MEASURES
10.1 Currently available sources and financial funds dedicated to financing the
waste measures
Several donors and funders are active in the region and have funds available on various terms.
Keeping in view the EU policy which is oriented on following waste hierarchy (prevention, Re-
Use and recycling are on the first positions) on medium term the Government will start the
dialog with funders to shift their focus from large, capital waste treatment facilities towards
projects aimed at increasing recycling rates.
The main types of funding for long-term infrastructure include:
a) State budget – projects may be financed (or co-financed) directly from central or local
government budgets.
The state budget is represented mainly by Environmental Fund which is collecting fees
on products that become special waste streams after use, other pollution fees ( SO2,
NO2, Ozone, plastic bags) and penalties for not achieving the packaging recycling
targets.
The overall flow of the amounts of pollution fee paid by all producers/importers is shown
in Figure 19. These amounts make from approx. 0.10% (2012) to 0.18% (2016) of the
Serbian GDP in the particular year.
70,000,000
60,000,000
50,000,000
40,000,000
30,000,000
20,000,000
10,000,000
0
2010 2011 2012 2013 2014 2015 2016
Figure 16 Amounts of all pollution fees collected in 2010-2016, EUR

Source: MAEP (current MEP)
Error: Reference source not found67 shows the pollution fees paid by producers / importers of
packaging and packaging waste during the period 2014-2016.
Table 74 Revenues from pollution fees for packaging waste

No of companies Pollution fee Pollution fee

Year
paying fee payments, RSD payments, EUR
2014 205 15 119 240 125 000
2015 172 22 639 000 187 520
2016 150 11 432 570 92 900
Source: MAEP (current MEP)
In the observed period (2014-2016), fees collected for packaging waste amount to approx. less
than 0.5% of the total amount of collected pollution fees.
Table 75 EEE- total amount of fee calculated and collected, RSD

Fees Fees
Year Fees collected Collection rate
calculated Uncollected
2013 1 143 000 000 970 198 000 172 802 000 85%
2014 1 950 000 000 1 555 000 000 395 000 000 80%
Source: MEP
‘Fees calculated’ refer to the total amount of fees based on Payment Decision issued by a
relevant state authority. ‘Fees collected’ indicate the total amount of calculated fee paid by
importer/producer. As presented above, total amount of calculated and collected fee for EEE
sharply increased in 2014 compared to 2013 (70%) which correlates with increase of total
quantity of EEE placed on the market in the same period (34%). Despite the significant increase
in the quantity of EEE placed on the market and the total fee calculated, the collection rate was
not changed much, showing a relatively small decrease from 85% to 80%.
Based on the official data received from the former MAEP, in 2015 and 2016 there were six
companies receiving incentives for the WEEE recycling.
Table 76 WEEE - Incentives to recycling companies
Year Incentives amount (RSD) Incentives amount (EUR)

2015 1 441 115 251 11 910 043
2016 1 602 677 316 13 029 897
Source: MAEP (currently MEP)
The table below shows incentives paid to recycling companies only for treatment of automotive
batteries and accumulators in 2015-2016. Feasibility of provision of such kind of incentives is
questionable and will be assessed during the development of the ERP scheme.
Incentives paid to recycling companies for automotive BA
Amount of incentives paid
Year
RSD EUR
2015 78 556 000 649 220
2016 50 646 000 412 000
To conclude during 2014 – 2017 were paid incentives to recycling companies on value of
66,743,378 euro.
Incentives to recycling companies

Year Amount of Amount of % of GDP

incentives, incentives,
RSD EUR
2014 1,900,000,000 16,196,402 0,05
2015 1,886,891,497 15,594,145 0,05
2016 2,072,999,888 16,853,658 0,05
2017 2,190,000,000 18,099,173
Total 8,049,891,385 66,743,378
b) Loans – provided by commercial banks, bi-lateral (e.g. KfW) and/or multilateral

development finance institutions (e.g. EBRD). Loans can take different forms and a
development loan will be tailored, specifically, to the nature of the particular project, the
characteristics of the borrower.
c) Guarantees – provided by bi-lateral and/or multilateral financing institutions. A
guarantee effectively implies that the guarantor will take responsibility for an
organization’s financial obligations if it cannot meet them for any particular reason.
Guarantees may be of an ‘all risk’ nature, or ‘partial risk’, the terms referring to the
extent to which responsibility is taken on by the guarantor.
d) Grants – in-kind funding that does do not require repayment. Grants are awarded by
central government to regional or local bodies, and by national donor agencies (e.g.
JICA, GIZ, USAID, SIDA), international organizations (e.g. Europe Aid, EU), and, to a
lesser extent, international financial institutions (IFIs). Some IFIs will offer grants as part
of a loan to help ensure that the necessary structures can put but in place to ensure that
the loan can to be repaid;
e) Funds coming from the application of economic instruments: such as taxes,
Extended Producer Responsibility Schemes, waste tariffs
Economic instruments currently in place:
a. Extended producer responsibility schemes for PPW –, etc.
b. Taxes for product put on the market;
c. Environmental pollution fees;
d. Waste tariffs (source Eunomia study)
10.2 Options for the financing of waste management measures
Extended producer responsibility schemes, for additional waste streams – as

indicated above, producers who place products on the market are required to finance the
management of their products at the end of their lives (e.g. collection costs and
treatment/disposal costs). Producers’ funds can be used – directly, or indirectly – to invest in
improved waste management in order to achieve the recycling targets. This is the key source of
funding used to cover the costs of collection and treatment infrastructure for a number of waste
streams. Currently, only EPR schemes for packaging and packaging waste have been
implemented in Serbia.

Pay-as-you-through tariff system for municipal waste
The “Pay-as-you-throw” scheme, PAYT, is an economic instrument of waste management that

implements the “polluter pays” principle by charging inhabitants of municipalities according to
the amount of residual, organic and bulky waste they send for waste management.
The PAYT approach means that a substantial part of the overall fee is allocated to the amount
of waste generated in order to stimulate waste prevention and recovery. Against this back-
ground, the PAYT approach can be implemented in different ways depending on the waste ac-
counting method:
 Per user identifier:

o Volume-based accounting;
o Weight-based accounting.
 Per bin identifier (individually or collectively assigned bins):

o Volume-based accounting (identification system);
o Weight-based accounting.
 Pre-paid systems:
o Pre-paid sack.
 Tag, sticker or token.
The pre-paid sack system is commonly considered to belong to the volume-based systems, but
its differentiation lays on the fact that the volume of a sack directly correlates with its weight and
the fee has to be paid for each sack, while common volume-based schemes are based on the
container size for which the citizens pay. In this case, containers can be collected partially filled
and hence volume may not correlate to weight.
Reduced tariff for separate collected recyclables can provide an incentive for source separation
by the households.
Landfill tax
The landfill tax is a widely used economic instrument in the EU 98 to reduce the amount of waste
disposed of in landfills. Studies show that when the total landfill charge (gate fee and landfill tax)
is high, the rate of landfill disposal is low. However, one has to bear in mind that landfill taxes
are integrated in an environment with other economic or non-economic instruments applied (e.g.
ban of the disposal of untreated waste on landfills, compulsory collection of bio-waste,
packaging ordinances, etc.).
Decisive for the incentive effect is the total landfill charge which consists of a gate fee (charged
by landfill operators to cover operating costs, cost for aftercare and profit) and a landfill tax
(used e.g. to improve the (financial) attractiveness of other waste management options which
are of higher priority according the EU waste hierarchy).
Moreover, the incentive to divert waste from landfill is most effective when coupled with user
charges based on the PAYT principle and convenient separate collection systems for recyclable
materials and bio-waste are available.
98
in 2012 18 of the 27 Member States used it

Good experience was made with introducing the landfill tax at a low level initially to avoid price
shocks for waste producers and in case of a PAYT approach with a high share of the variable
part to minimise the illegal disposal. However, a steady increase to a higher level is necessary
and in parallel increasing offers of other waste management option (incineration, MBT, separate
collection) to achieve the desired results. A clear commitment in the law to gradually increase
the tax is necessary, so that industry and municipalities have time to take the appropriate
measures (e.g. adjusting the infrastructure for separate collection of recyclables, increase the
capacities of installations for pre-treatment of waste prior to landfilling such as MBT to separate
high-calorific fractions for energy recovery and to reduce the biodegradables in the remaining
land-fill fraction).
Applying lower landfill taxes for fully compliant landfills which have higher investments and
operational costs compared to not fully compliant landfills will contribute to establishing fair
market conditions.
Polluters pay principle
10.3 Conclusions on financing of the proposed waste management

options
A key challenge to be overcome will be to ensure that costs are fully recovered as waste
management becomes more expensive. It is important for waste management to be on a sound
financial basis, so that it does not lead to a build-up of public sector deficits.
Thus, the following steps need to be considered:
 Should be established a clear basis for accounting for waste management services in
line with the objective of the National Strategy of Environmental Approximation to
achieve full cost recovery by no later than 2022. On short-term to review the waste
management financing systems in accordance with the Post Screening Document.
 The mechanisms for collection of fees to cover the costs of the waste management
service should not be one where public utility companies collect user fees.
 A clear method for tariff setting to ensure cost recovery should be made available for
those municipalities where services are not contracted out as envisaged under a new
Article 25 of the Law on Public Utility Companies.
 In the short- to medium-term, local government should recover costs through: a) local
fees collected by municipalities / taxation and joint revenues; and b) transfers from
central government.
The implementation of producer responsibility should ensure that producers fund the services
which municipalities provide, and which are used to support the delivery of producers’
obligations.

11. ASSESSMENT OF USEFUL EFFECTS AND

SUSTAINABILITY OF APPLICATION OF ECONOMIC
AND OTHER INSTRUMENTS IN WASTE
MANAGEMENT, WITH UNDISTURBED FUNCTIONING
OF INTERNAL MARKET
Will be developed after the cost assessment part will be finalised (from the WMS and DSIPs)

Implementation National Waste Management Plan
12. MEASURES AND GUIDELINES FOR

IMPLEMENTATION OF THE NATIONAL PLAN
12.1 General waste management measures
12.1.1 Harmonizing the legal framework with EU waste legislation
Pertinent gaps between Serbian waste legislation and the EU acquis are listed in Chapter 2.2.4
of this Strategy. Also, the ongoing development of a legal framework to support a Circular
Economy in the EU requires additional adaptation of Serbian waste legislation in the process of
approximation to the EU.
The following table summarizes the most relevant amendments of Serbian legislation required
for full transposition of EU-waste legislation:
Table 77: Necessary amendments of legislation
Piece of EU legislation Provisions to be transposed
- Achieving the gradually increasing recycling targets for

municipal waste taking into account the necessary
transition periods (currently envisaged 30% recycling in
2025, 40% in 2030, 50% in 2035 99) and the related
provisions for implementing measures, monitoring,
reporting and enforcement (Article 11 from WFD);
Waste Framework - Achieving the recycling targets for construction &
Directive (2008/98/EC as demolition waste taking into account the necessary
last amended by transition periods (currently envisaged 40% recycling in
851/2018/EC) 2029, 70% in 2034 ) (Article 11 from WFD);
- Provisions related to Permits and Registrations (Chapter
IV from WFD);
- Definition of properties of waste which render it hazardous
(Annex III from WFD);
Transposition in the Law on Waste Management)

- Provisions for achieving further increasing recycling
targets for municipal waste.
(A further increase of the recycling rate was prescribed by
Directive 851/2018/EC revising WFD. The new targets according
Directive 851/2018/EC,
to the mentioned Directive are: 55% in 2025, 60% in 2030 and
amending the WFD
65% in 2035. The most adequate transition periods for Serbia will
have to be defined and agreed with EC.).
- Make obligatory the use of the rules on the calculation of
the attainment of the targets;
99
Taking into account agreements for the achievement of the recycling targets of Directive 2008/98/EC, the following
transition periods as specified periods are proposed for Serbia in the Specific Implementation Plan for this Directive
for Serbia: 30% in 2025, 40% in 2030, and 50% in 2035.


- Provision to separately collect bio-waste by 2023 (Article
22);
- Setting general minimum requirements for extended
producer responsibility schemes (Article 8a);
Transposition in the Law on Waste Management)

- Amending the List of Waste and the assessment and
Commission Decision classification of waste by transposing the Commission
2000/532/EC on a List of Decision 2014/955/EC.
Waste, as amended
Transposition in the Regulation on Categories, Testing and

Classification of Waste
- Fully align the definitions and scope of the Law on
Packaging and Packaging Waste with PPW Directive;
- Transposing the provisions of Directive 2015/720/EU as
regards reducing the consumption of lightweight plastic
carrier bags;
- Transposing the provisions of Directive
2018/852/EU amending the Directive 94/62/EC on
Directive 94/62/EC on Packaging and Packaging Waste.
Packaging and (A further increase of the overall recycling rate of packaging
Packaging Waste, as waste was prescribed by Directive 2018/852/EU revising PPWD.
amended The new targets according to the mentioned Directive are: 65% in
2025, 70% in 2030. The most adequate transition periods for
Serbia will have to be defined and agreed with EC. Furthermore
the use of the rules on the calculation of the attainment of the
targets shall be mandatory);
Transposition in the Law on Packaging and Packaging Waste

Directive 1999/31/EC on
- Directive 1999/31/EC on the landfill of waste is largely
Landfills
transposed by the national legislation.
Transposed in the LWM and/or Regulation on waste landfilling

- Provisions for reducing the landfilling of municipal waste
amending Directive
1999/31/EC on Landfills (The Directive 850/2018/EU requires the Member States to take
the necessary measures to ensure that by 2035 the amount of
municipal waste landfilled is reduced to 10 % or less of the total
amount of municipal waste generated (by weight). The most
adequate transition periods for Serbia will have to be defined and
agreed with EC. Furthermore the use of the rules on the
calculation of the attainment of the targets shall be mandatory);
Transposition in the LWM and/or Regulation on waste landfilling

Directive 2010/75/EU on - Full transposition into Serbian legislation is

Industrial emissions required
(In particular additional waste treatment activities are now under
the scope of the Directive, such as treatment of metal wastes in
shredder, production of refuse-derived fuel and biological
treatments).
Transposition in the Law on Integrated Pollution Prevention and

Control
- The sunset clause for the use of PCB-containing electrical

equipment in accordance with Article 3 of the directive
(disposal or decontamination of PCB-containing
Directive 96/59/EC on equipment) has to be transposed;
PCB/PCT - A date of expire for the use of PCB-containing equipment
has to be defined.
Transposition in the Law on Waste Management in connection
with the Rulebook on treatment of devices and waste
containing PCB.
Directive 2012/19/EU on
- Full transposition into Serbian legislation is required (from
WEEE
248 separate Directive provisions, 103 are not yet
transposed);

with the Rulebook on the List of Electric and Electronic Products,
Measures of Prohibition and Restriction of Use of Electric and
Electronic Equipment Containing Hazardous Substances,
Methods and Procedures of Managing Waste from Electric and
Electronic Products
- Full transposition into Serbian legislation is
waste batteries and
required (from 135 separate Directive provisions, 39 are
accumulators, as
not yet transposed).
amended
with Rulebook on manners and procedures of used batteries and
accumulators management
- Fully transposed by national legislation
End-of-Life Vehicles

with the Rulebook on the manner of ELV management
- The provisions of Directive 2018/849/EU amending the
Directives 2000/53/EC on end-of-life vehicles, 2006/66/EC

on batteries and accumulators and waste batteries and

accumulators, and 2012/19/EU on waste electrical and
electronic equipment need to be transposed into national
legislation.
12.1.2 Establish an integrated systems for municipal waste management

throughout Serbia
The integrated system for municipal waste management will be constitute by the following
elements:
 Separate collection of recyclables by establishing an (at least) two bin/bags collection
system - one for mixed municipal solid waste and the other for recyclable waste -
covering 100 % of the Serbian population;
 Introduce secondary separation of recyclables by establishment of regional waste
centres with appropriate separation lines for recyclable waste separation – in each
waste management region;
 Establishment of separate collection of municipal Bio-waste (third bin) and green waste;
 Establish a network of amenity sites across the country: Depending on the population
density one or several such sites in each municipality will be established. These sites
will be operated as ‘bring centres’ for citizens to dispose of waste that should not be
disposed of in the household bins, including e.g.: bulky waste, special waste streams,
green waste, household hazardous waste, waste electrical and electronic equipment.
 Construction of small composting lines for composting of organic municipal waste
including provision of appropriate vehicles for transport;
 Establish home composting in rural regions, in order to recycle organic waste from
households;
 Construction of Mechanical-Biological Treatment plant for municipal waste in three
waste management regions;
 Establishment of a municipal waste incineration plant for residual municipal waste in
Belgrade. The project has already been launched: In 2017 the City of Belgrade and two
private companies entered into a Public-Private Partnership (PPP) for financing,
construction and 25-years-operation of a waste incineration plant with an incineration
capacity of 340,000 tonnes, an installed power production capacity of 25 MW and a
heat production capacity of 56 MW. Completion of construction is foreseen in 2021;
 Establishment of a sanitary landfill in each waste management region, where it does not
yet exist;
 Closure of non-compliant landfills and dumpsites.

12.1.3 Conduct information campaigns related to waste management for

citizens (including municipal waste).
When the collection infrastructure for municipal waste is available in a region or municipality, the
following information will be provided to the citizens:
 Information about the separate collection system (bin/bag collection system) and how
to use;
 Information about amenity sites (which fractions, opening hours etc.) and how to be
used;
 Information about other take-back possibilities for certain hazardous and non-hazardous
wastes from households, including packaging waste, WEEE, waste oil, pharmaceutical
waste, batteries etc.;
 Information about the benefits of home composting and practical guidance for home
composting;
 Information about take-back possibilities for end-of-life vehicles and tires;
 Information about collection of C&D waste including asbestos containing waste.
In the preparation of all information campaigns the target groups and appropriate messages will
be defined in advance.
12.1.4 Ensuring environmentally sound waste treatment in Serbia
Adapt existing plant permits and issue new permits for installations now falling in the
IPPC regime
The existing plant permits issued under the Serbian Law on Integrated Prevention and Control
of Pollution will be adapted taking into account the (to be transposed) provisions of the Industrial
Emissions Directive and the revised Best Available Technologies (BAT) Reference document
for Waste Treatment including the respective BAT-conclusions. This includes for example
stricter limits on water emissions from waste treatment. In the IED additional waste treatment
activities were added to the scope of the Directive, such as treatment of metal wastes in
shredders, production of refuse-derived fuel and biological treatments. Thus, waste treatment
installations, currently not having a permit according to the provisions of the Serbian Law on
Integrated Prevention and Control of Pollution will be identified and IPPC permits will be issued.
Laying down minimum treatment standards for certain waste streams going beyond the
provisions of the current Serbian legislation
For certain waste treatment activities, which do not fall under the scope of the Law on Integrated
Prevention and Control of Pollution, minimum treatment standards going beyond those specified
currently in the Serbian legislation will be laid down. This includes at least:
 Treatment standards for WEEE including standards for cooling and freezing equipment,
for lamps, for screens, etc.;
 Treatment and recycling requirements for waste batteries and accumulators;
 Technical guideline for the treatment of partly worn tyres, waste tyres and
scrapped/shredded tyres. For achieving the national recovery targets, the landfilling of
tyres shall be banned.

Strengthen the environmental inspection

Article 34(1) to (3) EU Waste Framework Directive sets obligations for inspections. Following
this provision, establishments or undertakings which carry out waste treatment operations,
establishments or undertakings which collect or transport waste on a professional basis, brokers
and dealers, and establishments or undertakings which produce hazardous waste shall be
subject to appropriate periodic inspections by the competent authorities, Article 34(1) WFD.
Article 34(2) WFD stipulates that inspections concerning collection and transport operations
shall cover the origin, nature, quantity and destination of the waste collected and transported.
 Strengthen the administrative capacity by sufficient staffing and providing

supplementary training, at state level (Ministry of Environmental Protection, the
respective departments), at provincial level (Secretariat for Urban Planning and
Environmental Protection in the Autonomous Province of Vojvodina, the respective
departments) and at local level (Local Self Government Units) Sector for Inspection,
Waste Department) for monitoring and inspection of waste generators as well as of
waste management facilities;
 Require that the Manual100 on Waste Control which provides concise guidance for waste
inspections, is followed when waste management facilities are inspected by the
competent authorities.
 Strengthening the inter-institutional cooperation in inspection activities, between
environmental inspectors, the labour inspectorate (among other to ensure the safe
removal of asbestos), the veterinary inspection (among other in case of co-treatment of
animal by-products in waste treatment installations) and the traffic inspectorate (on the
road control of waste transport, application of ADR in waste transport).
12.1.5 Measures for financing the waste management and for steering waste
streams
Tariff reform for the municipal waste

The tariff reform for municipal waste management shall respect the principles of Pay-as-You-
Throw and Cost-Recovery, taking into account affordability. This means that a substantial part
of the overall fee shall be allocated to the amount of waste generated in order to stimulate waste
prevention and recovery. Reduced tariffs may be introduced for the separately collected
recyclables to provide an incentive for source separation by the citizens.
Implementation of a landfill tax
Implementation of a landfill tax in Serbia shall be prepared by the following measures:

 Conducting a feasibility study
The study shall inter alia determine the most appropriate tax rates (possibly different tariffs for
fully compliant and non-compliant landfills, different landfill classes and different waste types)
100
elaborated within the Twinning project SR10-IB-EN-01

and the manner of practically implementation (e.g. transitional periods, gradual increase of the
tax rate to the final level determined to be appropriate for steering the waste streams).
 Setting up the legal basis for a landfill tax in Serbia.
Setting up EPR schemes for at least WEEE and Waste batteries and accumulators
and ensuring that producers bear financial responsibility for the management of the
waste stage of a product’s life cycle including separate collection, sorting and treatment
operations.
That obligation can also include organisational responsibility and a responsibility to contribute to
waste prevention and to the reusability and recyclability of products.
12.1.6 Improve the monitoring and reporting of the waste management
In order to determine whether the waste management goals and objectives for Serbia are met
waste monitoring and reporting shall be improved by the following measures:
 • Strengthen the administrative capacity of SEPA by sufficient staffing and
providing supplementary training;
 Conduct statistically representative composition analysis of municipal waste and
subsequent reconciliation between the datasets on municipal waste and packaging
waste.
 To adapt the national reporting methodology according to the requirements of EU waste
legislation, as amended by the circular economy package;
 To implement the measures for quality control of data and reports according to quality
requirements of respective EU legislation;
12.2 Hazardous waste management measures
Below, measures of highest relevance for meeting the waste management goals and objectives
specified in this Strategy are summarized. Additional measures and more details about
hazardous waste management are provided in the Integrated Hazardous Waste Management
Plan.
12.2.1 Establish an adequate network for collection of hazardous wastes from

households
As described under measure 12.1.2 at least one amenity site per municipality is foreseen.
Besides providing for the separate collection of recyclables and special waste streams from
households, these amenity sites will be equipped and staffed adequately to receive hazardous
waste from households and store it intermediately. The collected wastes will be regularly
evacuated to regional storage facilities for hazardous waste.

12.2.2 Establish an adequate network of treatment installations for hazardous

waste
In order to fulfil the requirements of the Waste Framework Directive by 2034 a treatment
network for hazardous waste consisting of the following elements will be established:
 Construction of 5 regional storage facilities for hazardous waste including POPs waste
in five regions of Serbia. It is expected that these storage facilities will be operated
mainly by private operators, often in the context of treatment facilities. Hazardous waste
will then be transferred to treatment facilities or exported out of Serbia;
 Construction of at least one facility for physical- chemical treatment of inorganic and
organic liquid hazardous waste and sludge combined with storage units for liquid and
pasty industrial special waste streams like solvents, acids, bases etc. on the one hand
and oily wastes and solvents on the other. The minimum capacity needed is ~50,000
t/a, to be developed in a modular way. Residues need be subjected to further treatment
(e.g. RDF preparation), to compliant landfills or to shipment out of Serbia;
 Establishment of capacities for the incineration of organic industrial and medical waste,
eventually combined with capacities for the preparation of residues derived fuels (RDF)
from organic hazardous waste streams. The total capacity needed is ~ 30,000 t/a and
can partly be realised by co-incineration in industrial plants;
 Establishment of one landfill for inorganic industrial hazardous waste eventually
combined with capacities for the solidification of pasty hazardous waste streams. The
needed capacity is between 28.000 and 38.000 t/a;
 Establishment of a sorting facility for mixed portable batteries as soon as relevant
collection amounts are available.
12.3 Special waste streams management measures
Below, measures of highest relevance for meeting the waste management goals and objectives
specified in this Strategy are summarized. For all special waste streams additional measures
and more details are provided in the Specific Waste Stream Plans for these waste streams.
12.3.1 Establish extended producer responsibility (EPR) schemes according to

the provisions of the Article 8a of the Directive 852/2018 amending
Directive 2008/98/EC on waste
 Define for which waste streams EPR schemes according to the provisions of the
revised Waste Framework Directive will be established:
It will be laid down in the Serbian Waste Management Act, that for packaging waste, end-of-life
vehicles, waste electrical and electronic equipment (WEEE) and used batteries and
accumulators such EPR schemes shall be established.
It will be assessed whether additional waste streams such as waste oil, pharmaceutical waste,
and waste tyres shall be covered by the EPR principles.
 Establish the legal framework for EPR schemes for individual waste streams
 Establish the legal basis for a National register of producers/importers of EEE, Batteries
and accumulators and other waste flows for which an EPR will be introduced
Producers and importers of all products for which EPR will be introduced will be obliged to
register in a National electronic database. SEPA already maintains the database on waste
management as part of the environmental information system, including data on

producers/importers of products which become waste after their use. Therefore, it is considered
that the National register will be operated by SEPA.
12.3.2 C&D waste
Establish a nation-wide network for pre-treatment of C&D waste prior to recycling [MO9]
In order to achieve the recycling target of 70% according to Waste Framework Directive for C&D
waste in 2034101, the needed infrastructure for the pre-treatment of C&D waste at regional level
prior to recycling will be established by designation of special areas for the treatment and the
operation of one mobile treatment machine per region.
The following approach will be followed: Appropriate locations for mobile C&D waste treatment
and for storage of the processed C&D waste will be designated by all municipalities. A central
location for C&D waste treatment and for storage of the processed C&D waste and for operation
of one mobile treatment installation per region will be established. In order to meet this objective
on average every year approximately 2 regions will install such locations.
Make the demolition/renovation plan mandatory in the procedures of issuing a

demolition/de-construction permit [MR7]
In order to realize source separation of hazardous, non-hazardous (including recyclables) and
inert components from C&D waste, and the further management of the waste streams, a
demolition/renovation the plan needs to consider an environmental sound management of all
these fractions and will be made mandatory in the procedures for issuing a demolition/de-
construction permit. Respective legal provisions will be laid down.
Strengthening the market for secondary aggregates in Serbia

Available data on C&D waste show, that the use of recycled C&D waste in Serbia is quite low
compared to the use of natural resources. To strengthen the market for secondary aggregates
in Serbia the following sub-measures are foreseen:
 Introduce quality standards for secondary aggregates considering technical and
environmental aspects and quality assurance schemes will be elaborated under the
lead of Serbia´s Institute for Standardization [MM2];
 Lay down the legal basis for obligatory use of secondary aggregates up to a specific
share (e.g. 10%) for public tendered projects (green public procurement rules). This will
provide an important impulse to encourage the industry to make the recycling of
construction and demolition waste economically feasible [MR8];
 Lay down provisions related to recovered C&D waste (including an end-of-waste
clause), in a by-law on C&D waste [MR9]
Establish a nation-wide network for compliant disposal of non-hazardous C&D waste

[MO10]
Landfills for municipal solid waste (compare section12.1.2) shall have a separate compartment
for non-hazardous C&D waste.
The network will include sites for backfilling and inert landfills for appropriate C&D fractions.
101
Compare also Serbian Directive Specific Implementation Plan for the Waste Framework Directive (Eptisa, 2018)

Improve the Extended Producer Responsibility system (PROs) for packaging in line with
the general minimum requirements from the revised Waste Framework Directive
 specifically ensure better cost coverage by the producers, including the cost of
dealing with the non- recycled packaging disposed of by households as residual waste.
 specifying in detail a minimum level of collection service that producers are
required to fund for the local self-government units (LSGUs) so that there is a focus on
quality collection services, including door-to-door collection wherever appropriate;
 increase the fees paid by producers or PROs to ensure that they cover the full
costs of the collection service.
 systematic audits on companies that provide data on the amount of packaging
placed on the market.
 clear distribution of responsibilities for the management of packaging waste
between municipalities and producer responsibility organizations (PROs). The
contractual arrangements between them should allow the municipalities to influence
decisions regarding the packaging collection systems’ performance (which is the
responsibility of the PROs).
 strengthen the regulator’s capacity to enable better enforcement of producer
registration and fee collection.
Extend the current separate waste collection networks in all municipalities, for at least
glass, plastic and metal, as well as paper and card-board
 Assess the current fee levels (to be paid by citizens, business, PROs) to consider if
these are high enough to serve as an incentive to introduce the effective separate
collection systems. Depending on the results a review of fees may need to be
considered.
 Conduct a major audit of collection performance to identify system inefficiencies
preventing higher yields of recyclables.
 Develop national minimum service standards for waste collection to specify, for
example, the type and volume of containers, frequency of collection and type of vehicle
used, taking into account the type of housing stock, how rural the area is, typical
climate, etc.
 Introduce minimum performance indicators for separate collection.
 Implement a mechanism that would require municipalities to rectify their schemes if the
minimum performance indicators are not met, and apply penalties/consequences for
failing to meet the standards.
Technical support for local authorities

Development of a system at national level that provides technical support for municipalities,
specifically in the following areas:
 choosing collection services;
 service procurement;
 service management;
 communication campaigns;
Coupled with active sharing of good ideas and practices that can improve efficiency in terms of
cost reduction and improvement in performance. The support will also be about how authorities
will achieve targets, it will also aim to support the active sharing of good ideas and practices that

can improve efficiency in terms of cost reduction and improvement in performance. The Ministry
of Environmental Protection will continue to carry out projects and research studies into best
practice systems, set up a monitoring system (survey etc.) to understand the level of
implementation of the sorting obligation across the municipalities and gain feedback from them
on challenges and barriers, develop support tools for municipalities.
12.3.4 End-of-life vehicles (ELV)
Establish an extended producer responsibility (EPR) according to the

provisions of the revised Waste Framework Directive for end-of-life vehicles
[corresponds to MR6]
To improve the management of ELV in Serbia102 EPR according to the provisions of the
revised Waste Framework Directive103 will be introduced. The respective legal provisions
will be introduced into Serbian ELV legislation
Establish a nation-wide network for collection and treatment of end-of-life

vehicles [MO11]
In order to achieve environmental sound treatment of end-of-life vehicles throughout Serbia it is
necessary to establish a collection network. As a minimum 3 authorized collection facilities for
take-back of ELV will be established in bigger cities (Užice, Kraljevo, Novi Sad, Valjevo and
Nis), 5 authorized collection facilities for take-back of ELV will be established in Belgrade and 2
facilities will be established in each of the remaining regions.
Organize information on take-back of end-of-life vehicles for citizens [MI3]

Citizens will be informed about authorized collection facilities for take-back of end-of-life
vehicles in their vicinity.
12.3.5 Waste Oil
Establish an extended producer responsibility (EPR) scheme according to the provisions

of the revised Waste Framework Directive for waste oil [corresponds to MR6]
To improve the management of waste oil in Serbia EPR according to the provisions of the
revised Waste Framework Directive104 will be introduced. The respective legal provisions will be
introduced into Serbian waste legislation. .
Oblige retailers of mineral oil to take back waste oil [MR10]

It will be laid down in the Serbian waste legislation, that retailers are obliged to take-back waste
oil from end-users free of charge.
12.3.6 Waste tires
102
The report of the project “Development of Guidance on Extended Producer Responsibility (EPR)” commissioned by
the EC, a better performance in ELVs management can be observed in those countries where the EPR schemes are
introduced
103
104


of the revised Waste Framework Directive for tires [corresponds to MR5]
The provisions for EPR schemes laid down mainly in Article 8 of the revised Waste Framework
Directive will be considered in the Serbian legislation for used tires.
Prepare technical guidance for collection of used tires and for treatment of waste tires
including preparation for reuse [MO12]
Technical guidance will be prepared addressed to those taking back/collecting used tires (tire
dealers, garages for car repairing, car service stations, towing service and petrol stations). This
shall include clear definitions for used tires, part worn tires and waste tires and the requirement
to collect those types of used tires separately at the take-back/collection site. In addition,
guidance on appropriate treatment options for waste tires (incineration in cement kilns or
mechanical treatment and sorting into metal, rubber and other fractions) including information
on admissible final uses will be given. This includes also quality criteria for the resulting rubber
granules and powders subject to the intended final use (e.g. use in the production of floorings,
artificial turfs, roofing materials etc. or use in the production of asphalt) 105. Also, requirements for
retreading part-worn tires shall be included.
Adapt the recycling/energy recovery target for waste tires [MR11]

The recycling target of 80% and the energy recovery target of 20% of the collected waste tires
will be adapted. This will be based on an analysis of the treatment infrastructure for waste tyres
(co-incineration capacities in cement factories, treatment plants producing rubber granules or
powder) and of the market for use of such secondary rubber granules or powder (including in
asphalt production, in production plants for floorings, roofing materials etc. and the demand for
such items) also considering future developments and ecological impacts of energy recovery
and particular uses of secondary rubber mixtures and future development.
12.3.7 Waste electrical and electronic equipment (WEEE) - including

fluorescent lamps

of the Directive for WEEE (2012/19) and Directive 2018/852 on waste management
[corresponds to MR6]
The national legal framework needs to be adapted to the new European provisions by:
 Introduce EPR schemes in line with the general minimum requirements in the revised
Waste Framework Directive.
 Involve all relevant levels of government (municipal, regional, national)
 Introduce (or intensify) controls at all stages of the management chain, and organize
inspections targeting illegal or non-compliant activities.
Improve data quality, including through quality checks and by reinforcing traceability
procedures to account for all waste equipment. […..]
 Develop and maintain a producer national Register as specified by Directive.
Extend the collection network [….]
 Improve collection by:
105
The revised Waste

o expanding collection infrastructure. Entry into operation of the amenity sites

network across the country (one in each municipality), where citizens can also
dispose of their WEEE (see Section 12.1.2);
o improving consumer awareness; (see Section 12.1.3)
o establishing the transfer of ownership of waste equipment in the management
chain; and
o requiring all collectors to cooperate with an EPR scheme.
 Enforce the proper treatment requirements set out in the Directive - adopt minimum
quality standards for the treatment of WEEE. (see section Error: Reference source not
found)
 Implement/develop mechanisms for exchanging product-related information relevant for
recycling and preparation for re-use between producers and recyclers
 Establish a ‘preparation for re-use’ network of registered and authorized/certified
operators at national level.
 Evaluate the necessity of adopting a separate ‘preparation for re-use’ target at national
level.
12.3.8 Waste Batteries and Accumulators

of the Directive 2018/852 on waste management […..]
The national legal framework needs to be adapted to the new European provisions by:
 Introduce EPR schemes in line with the general minimum requirements in the revised
Waste Framework Directive.
 Involve all relevant levels of government (municipal, regional, national)
 Introduce (or intensify) controls at all stages of the management chain, and organize
inspections targeting illegal or non-compliant activities.
Improve data quality, including through quality checks and by reinforcing traceability
procedures to account for all waste equipment. […..]
 Develop and maintain a producer national Register as specified by Directive.
Extend the collection network [….]
 Establishment of a network of amenity sites across the country (one in each municipality),
where citizens can also dispose of their portable batteries (see section 12.1.2);
 Conduction of information campaigns related to municipal waste management for citizens
(see section 12.1.3);
 Improve the control and enforcement system for the implementation of the legislation on
batteries and accumulators and waste batteries and accumulators;
 Establishment of an adequate network of treatment installations for hazardous waste (one
sorting facility for mixed portable batteries) (see section 12.2.2).
12.3.9 PCB and POPs waste
For PCB and other POPs containing wastes, the relevant SWSMP lists suited measures and
activities to reach the objectives. According to this, the following measures will be taken:

Create inventories for new POPs [MI5]

In order to improve the currently very weak data basis especially on new POPs, these data shall
be compiled and consolidated within an inventory connected to the amended NIP according to
the Stockholm Convention.
Perform information and awareness raising campaigns concerning POPs [MI6]

Information about negative effects of POPs shall raise the awareness within the public,
enterprises and authorities:
 There is an additional need to be able to identify new POPs in articles and products that
are produced or imported as well as for wastes resulting from these products after spent
life time. Therefore, an electronic register for producers and importers – and
subsequently for the future owners – shall be legally established and shall cover these
POPs items as well;
 POPs in products and articles shall be considered as part of the extended producer’s
responsibility. The market control by authorities to check the duties and responsibilities
of producers, importers and dealers to place certain products (e.g. EEE) on the market
including the labelling and the proof of conformity shall be established as a legal
requirement;
 The data basis on POPs in environmental media, especially soil, water, foods and
animal feedstuff, shall be established and amended continuously by monitoring
activities particularly nearby landfills/dumpsites, relevant emitting plants, contaminated
sites and similar hot spots [see MO16];
 To provide common information about the presence of POPs in articles and exposure
routes to these substances throughout the life-cycle of such articles [MM3]. This shall
include information in general about the health risks resulting from POPs in products
and in wastes (particularly to protect workers of the waste disposal and recycling
industry);
Establish regular monitoring measure related to POPs in the environment [MO16]

The presence and the amount of POPs shall regularly be monitored in soil, water, foods and
animal feedstuff (possibly to be extended). In particular the surrounding areas of
landfills/dumpsites, relevant emitting plants, contaminated sites and similar hot spots shall be
monitored.
Lay down the legal basis for a control and supervision system for POPs containing
wastes [MR12]
Define the limit values or restrictions for POPs wastes generated or to be disposed of in
certain waste management facilities [MR13]
The limit values defined by the EC-Regulation 850/2004 shall be specified for certain waste
management activities and shall be compared with the relevant limit values for hazardous
wastes. This includes relevant measures to create supervision and control instruments:
 POPs concentration in wastes below the limit values in Annex IV of EC-Regulation
850/2004 allow any waste management activity including their recovery without any
restriction. But for some waste streams (e.g. use of sewage sludge as fertiliser,
recycling of plastics for reprocessing…), the limit values of POPs in these waste
streams shall be more stringent – considering the limit values in Annex I of Regulation

850/2004 and other relevant regulations (e.g. soil protection) – in order to avoid their
further accumulation in the biosphere and the circular management;
 POPs concentration in wastes above the limit values in Annex IV of EC-Regulation
850/2004 require the treatment of POPs wastes by means of – in general – destruction.
These limit values are more less than the relevant limit values for the classification of
POPs wastes as hazardous106. Therefore, a control system similar to the control system
for hazardous wastes is needed to enable the authorities to supervise the POPs wastes
requirements for all non-hazardous classified POPs wastes.
Provide competent authorities with easily practicable test methods to detect POPs and
chemical elements which are relevant for the classification of wastes as hazardous
[MO14]
Easily practicable test methods shall be available in order to detect POPs and chemical
elements which are relevant for the classification of wastes as hazardous, e.g. fast testing
methods with XRF-spectroscopy as well as laboratory devices like GC-MS, LC-MS, or
alternatively HPLC-MS according to the estimated needs. Alternatively, such testing methods
can be contracted with private laboratories
Strengthen the administrative control and supervision related to POPs waste [MO15]
 All competent authorities which are affected with POPs waste management will be
sensitized with the special aspects of POPs and their handling
 Create a special administrative unit to manage the decontamination and the remediation
and recreation of the initial state of contaminated sites. This is recommended due to the
special aspects of such sites (considering soil and water protection legislation
concerning former dumpsites and illegal deposits of wastes, certain industrial sites
which are out of operation, former mining areas)
Several waste management measures described in the preceding sections are contributing to
environmental sound management of POPs waste in Serbia
The waste management infrastructure in Serbia has to be adjusted in general to the actual
needs and the legal requirements on the integrated pollution prevention and control. The
possibilities to manage POPs wastes in particular shall be adjusted in this connection, too,
considering the following measures:
 The strategic measures to establish an adequate network for the interim storage, the
treatment and the disposal of hazardous wastes shall consider the management of
POPs wastes generated in Serbia, too, to realize a self-sufficient POPs wastes
management in mid-term period (see sections Error: Reference source not found and
Error: Reference source not found);
 Existing plants shall be adjusted to the requirements on industrial emission and on
landfills according to the state of the art. Non-compliant plants, especially landfills, shall
be closed in mid-term period. Simultaneously, the waste management shall be adjusted
and supervised considering the minimum standards; uncontrolled incineration
106
According to the European List of Wastes as amended by Commission Decision 2014/955/EU, only wastes
containing PCDD/PCDF, DDT, chlordane, HCH, dieldrin, endrin, heptachlor, HCB, chlordecone, aldrine, PeCB, mirex,
toxaphene HBB and/or PCB exceeding the relevant concentration limits shall be classified as hazardous. For all new
POPs, this definition is not applicable, so the respective limit values of CLP-Regulation shall be considered for the
classification of new POPs containing wastes as hazardous.

processes have to be avoided (see sections Error: Reference source not found and
Error: Reference source not found)
 The management of POPs wastes shall be especially considered in terms of the
required remediation of contaminated sites;
 To initiate and to speed up all above mentioned measures for improvement of POPs
waste management infrastructure, governmental funds shall be established to grant
benefits to private operators and municipalities. These funds shall enable to use existing
European funds (see section Error: Reference source not found).
12.3.10 Asbestos
Conduct information campaigns related to asbestos and asbestos cement for citizens
[MI4]
Information about risks of handling asbestos containing materials and take back possibilities will
be communicated.
In addition, several waste management measures described in the preceding sections will
contribute to an improved management of asbestos waste in Serbia:
 Establishment of a network of amenity sites across the country (one in each municipality),
where citizens can also dispose small amounts of asbestos wastes (asbestos cement
products, asbestos shields, etc.; see Section 12.1.2);
 Introduce separate designated areas for the disposal of asbestos waste on sanitary landfills
(see Section 12.1.2).
According to SEPA, 2.824,18 tonnes of “Wastes from human or animal health care and/or
related research” (Group 18 of the List of Wastes) was generated in Serbia in 2016.
Measures proposed in order to improve the performance of medical waste management:
No. Measures to improve performance
Waste management plan
1. Update the waste management plans for healthcare institutions following
the adoption of the National Waste Management Plan.
Separate collection
2.
Implementing the separate collection of hazardous waste from
medical and veterinary activities.107
3. Guidelines for the acceptance criteria and procedures to be followed for the
received wastes (the checking of the waste upon receipt in order to verify
the correctness of the description of the waste given on the official reporting
form) must be elaborated/ issued by the environmental authority.
4.
Developing the national service standards for medical waste
collection (hazardous and non-hazardous) to specify the type and
107
Separate collection of recyclables, non-hazardous wastes, infectious wastes and other hazardous wastes shall be
introduced via the medical waste management plan for healthcare institutions, based on proper source separation.

volume of containers, minimum and maximum frequency of collection

and type of vehicles used, having in view protected areas,
geographical condition, typical climate etc...
5.
Setting up a minimum technical requirements for pre-treatment of
medical waste, within public sanitary facilities. 108
6. Implementing of collection service requirements for all sanitary units, for a

proper waste streams.
Economic incentives
7. Setting up a mechanism to sanction local authorities in case of un-
compliance with legal requirements in waste field.
EU Funds
8. Accessing the EU funds for the new infrastructure, setting collection service
standard and standard for storage facilities etc...
According to the European Waste Statistics Regulation, pharmaceutical wastes (18 01 08* and
18 01 09) are allocated to the EWC-Stat-category “Chemical Wastes”.
The total pharmaceutical waste generation in all public HCIs and public pharmacies in Serbia
has been estimated to be in the order of seven tonnes per year. Waste generation in the private
sector is expected to be in the order of 1 to 3 tonnes per year.
Measures proposed in order to improve the performance of pharmaceutical waste
management:
No Measures to improve performance

Extended producer responsibility (EPR) scheme
1. Introducing of a legal basis for creating an EPR for pharmaceutical waste in the
relevant legislation.
Clear definition of EPR scheme in the relevant legislation.
Elaborating a methodology for establishing and managing the financial
contributions which will be paid by producers to cover the costs of all of the
aspects of pharmaceutical waste management.
Prevention
Serbian Government should limit prescription medication by dispensing
medication according to the exact number needed for treatment. 109
108
Pre-treatment (shredding/autoclaving) of (potential) infectious wastes must be up-grade and regulated for full
compliance with environmental legal requirements (including waste law) on entire national territory
109
Analysis of expired medication In Serbia household, published online 2016 May 10,
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5031069

Separate collection
Establishing the national collection network points for pharmaceutical waste
(expired or inappropriate for human or veterinary use), to ensure a proper
separate collection system (including their packaging).
Developing the national service standards for pharmaceutical waste collection

(hazardous and non-hazardous) to specify the type and volume of containers,
minimum and maximum frequency of collection and type of vehicles used.
Implementation the collection service requirements for commercial premises
(pharmacies), as this may help to ensure separate collection of different
pharmaceutical products/packaging of the pharmaceutical products.
Communication and awareness-raising
Extending awareness campaigns (developed already by the public health
authority or the Institute of Public Health of Serbia/network of regional public
health institutes)110.
Developing111 awareness guidelines / public awareness campaigns 112 regarding
collection of unused/expired medication for human use from households.
Introducing measures to encourage households to sort waste, including
pharmaceutical waste.
Measures for improvement the environmental compliance and governance in medical

and pharmaceutical waste field are summarise in the table below:
No Measures
1. Reflecting the mixing ban of medical and pharmaceutical waste in national
legislation and also the permit conditions and ensure their enforcement.
2. Identifying the necessary professional needs for training environmental
inspectors and improve cooperation with practitioners and other bodies in the
field of medical and pharmaceutical waste.
3. Facilitate the sharing of good practice, background and reference material,
promote funding opportunities for assurance the waste compliance.
4. Creating an environmental and health informational system, essential tool to
support policy-making, allowing priorities to be set on the basis of evidence,
As a general rules, the pharmaceutical industry warns costumers only with instructions for use inside the package and
of
course warning about contraindications, expire date etc., but doesn’t made indications about how the citizens must to
collect unused/expired medication when be-coming waste.
110
http://www.hpi.sk/en/2014/01/serbia-brief-health-system-review/
111
Ministry of Environmental Protection, Ministry of Health, Health Fund of the Republic of Serbia, Association of
Pharmaceuticals of Serbia, Medicines and Medical Devices Agency of Serbia, The Innovative Drug Manufacturers’
Fund-INOVIA, Institute of Public Health of Serbia, Agency for accreditation of Health Care Institutions of Serbia,
industrial laboratories that introduce medicinal products on the national market and representative organizations of the
pharmacists.
112
To raise awareness on how to collect /dispose of unused or expired medicines appropriately, bringing information
from "meds disposal" http://medsdisposal.eu/about-us/

enhancing access to information and facilitating communication with the

public.113
5. Creating and integrated data base for all projects related to medical and
pharmaceutical waste management field.
6. Developing guidance referring to management/good practices.
7. Preparing technical guidelines for inspection of medical waste facilities.
8. Building up the capacity and use of geospatial intelligence for compliance

assurance and promote good practice projects.
9. Assessing national waste compliance assurance system as part of an

environmental governance assessment framework.
10. Improving monitoring and reporting, including by ensuring that data is captured
at municipal level.
11. Using EU funds to develop medical and pharmaceutical waste infrastructure.
12. Crating and use clear guidance on waste classification and management,
including on waste.114
12.3.13 Waste from titan dioxide industry
Since there is no TiO2-production in Serbia this special waste stream is of no relevance at the
moment. In case of an application for a license the BAT/BREF for titanium dioxide industry can
be applied directly in the licensing process.
12.4 General guidelines (policies) for waste management, planned

technologies and waste management methods, including waste with
specific management difficulties
To achieve the national waste management goals the following general principles shall be
followed:
Municipal solid waste shall be separated at source and collected separately and/or shall be
subject to separation of recyclable fractions before any further treatment. Wet fractions and
Hazardous waste from households shall be separated at source in any case. This is necessary
to achieve the (European) recycling targets for municipal waste, to reduce the amounts of
biodegradable waste going to landfill and to recover as much as possible energy from waste
fractions that are not recyclable. The establishment of an integrated management system for
municipal solid waste includes the establishment of adequate separation at source logistics and
appropriate collection systems including bring and pick-up systems, construction of separation
lines for recyclable fractions, composting facilities the construction of waste incineration plants
and of plants for the mechanical-biological treatment of waste before landfilling. Also, facilities
113
Based on the experience of earlier projects and involving a wide range of stakeholders, the Ministry of Environmental
Protection must address the current priority policies, including those related to environment and health, assuring their
synergy and reducing duplication.
114
Use of the Commission`s technical guidance on the classification of waste
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018XC0409(01)&from=EN

for treatment of slags from municipal waste incineration and appropriate opportunities for
landfilling the (hazardous) residues resulting from municipal waste incineration.
Hazardous waste shall be separated at source in all commercial and industrial facilities. This is
necessary to facilitate or even enable recycling of non-hazardous waste fractions and to
safeguard the Serbian environment from unintended pollution through unappropriated or even
illegal hazardous waste disposal. Such forced hazardous waste separation facilitates as well
economic sustainability of private hazardous waste collection schemes. Separate collection of
hazardous waste needs storage facilities and appropriate final treatment and disposal
capacities. The establishment of an integrated system for hazardous waste management
includes the establishment of adequate separation at source logistics, appropriate collection
and transportation of hazardous waste, construction of regional storage capacities, the
construction of facilities for physical-chemical treatment, the establishment of incineration
infrastructure for hazardous waste as well as opportunities for hazardous waste landfilling.
Export of hazardous waste fractions which do not find appropriate treatment within Serbia may
be an intermediate or even a long-lasting solution, e.g. for low-volume waste streams where
operating dedicated treatment plants in Serbia would not be economically viable.
For special waste streams dedicated management systems are needed. Below general
guidelines for planned technologies and waste management methods are listed.
Table 78: General guidelines for planned technologies and waste management methods
Special waste stream Guidelines for the management and planned technologies
C&D waste and asbestos waste  Source separation – mandatory demolition plan
 A close network of amenity sites for delivery of small
amounts of asbestos waste by citizens
 Pre-treatment of source separated mineral C&D waste
by mobile crushers
 Construction of treatment facilities for the production of
secondary aggregates
 Appropriate landfills for hazardous (asbestos containing
wastes) and non-hazardous C&D waste
Packaging waste  Simona please add
End-of-live vehicles  Take back opportunities free of charge for end-users
 Appropriate facilities for de-pollution, dismantling and
shredding
 Appropriate treatment/disposal opportunities for
hazardous components
Waste tires  Take back opportunities free of charge for end-users
 Facilities for recycling an energy recovery
Used batteries and accumulators  Separation at source of portable batteries
 Take back opportunities free of charge for end-users
 Facilities for separation of mixed potable batteries
 Treatment opportunities (including export) of sorted
portable batteries, car batteries and industry batteries

Special waste stream Guidelines for the management and planned technologies
Waste from electric and electronic  Separate collection of different categories of WEEE
devices (WEEE)
 Take back opportunities free of charge for end-users
 Appropriate facilities for de-pollution, dismantling and
shredding
 Appropriate treatment/disposal opportunities for
hazardous components
Waste mineral oil  Take back opportunities free of charge for end-users
 C/P treatment plants for pre-treatment of waste oil and
waste oil containing wastes
 Facilities for re-refining of waste mineral oil and
provision of sufficient amounts of waste oil for a
domestic recycling facility (TBD, BK)
 Facilities for thermal treatment of waste oil qualities
that are not suitable for re-refining
PCB and POPs waste  Appropriate treatment, incineration and landfill facilities
Medical waste  Separate collection of hazardous (in particular infectious
waste) and non-hazardous medical waste
 Sufficient capacities for hazardous waste incineration
Pharmaceutical waste  Take back opportunities free of charge for citizens
 Sufficient capacities for hazardous waste incineration
For waste streams containing relevant resources, for whose recovery no treatment
technologies are available at the moment, storage in mono-landfills might be an option. One
example is landfilling of ashes from mono-incineration from municipal sewage sludge for future
recovery of phosphorous.
12.5 Guidelines for recovery and disposal of waste, taking into account
national goals for reduction of packaging waste and reduction of
waste generation of which cannot be avoided, especially reduction of
biodegradable waste disposal on landfills
The key guideline to be taken into consideration for recovery and disposal of waste is the
hierarchy of measures in waste management. This means the following order of priorities:
 Prevention: Qualitative waste prevention (reduction of hazardous characteristics of waste,
pollutant elimination, pollutant substitution), quantitative waste prevention (reduction of waste
generation), Re-use (“Second Hand”, reusable packaging), Reduction of the harmful effects
of waste on health and environment;
 Preparing for Re-use: Cleaning of for example used clothing, Functional testing of for
example electrical and electronic equipment or components thereof;
 Recycling: Reprocessing of waste materials into products, materials or substances whether
for the original or other purposes (“bottle to bottle”, “metal to metal”, composting…)
 Other Recovery: Utilisation of waste values for other purposes (backfilling, recultivation,
energy recovery, other energetic or chemical utilisation)
 Disposal: Incineration without energy recovery, landfilling.

However, according to the provisions of the Waste Framework Directive the waste hierarchy is
not to be applied strictly in any case, but the option that delivers the best overall outcome shall
be chosen. The general environmental protection principles of precaution and sustainability,
technical feasibility and economic viability, protection of resources as well as the overall
environmental, human health, economic and social impacts need to be taken into account.
Departing from the waste hierarchy may be admissible for specific waste streams when justified
for the mentioned reasons.
Considering the precautionary principle it is of particular relevance to determine the acceptable
pollutant concentration of any secondary raw material. The pollutant concentrations shall not
exceed the concentrations in the primary resources that are substituted. High quality secondary
raw materials are also a means to increase acceptance by the industry using them.
For pollutant enriched residual fractions resulting from waste treatment disposal opportunities in
save sinks (landfills for hazardous waste or underground storage) are needed.
The key guideline to be taken into consideration for reduction of biodegradable waste
disposal on landfills is to implement separation at source and high-quality recycling of the
biodegradable fraction, i.e. production of high quality compost from green waste to be used as a
fertilizer, use of high quality waste wood for substituting wood in the production of wood based
panels and of paper in the production of paper and cardboard. For separately collected bio-
waste including kitchen waste composting shall be envisaged, whereby the resulting compost
should not be used as a fertilizer due to high contents of pollutants but can be used for
applications where lower compost qualities are sufficient, e.g. as a substrate for re-cultivation of
old dump-sites.
The guiding principles to be considered in the reduction of waste generation of which cannot
be avoided are discussed in detailed in the Serbian Waste Prevention Programme for the
period 2019-2024.
12.6 Guidelines for ensuring most favourable technical, production and

other measures for the achievement of waste management goals
The most favourable technical, production and other measures for the achievement of waste
management goals can be assured by means of applying the integrated approach. The
integrated approach means that in the planning and permitting of new waste management
installations, the whole environmental performance of the installation are taken into account.
This covers e.g. emissions to air, water and land, generation of waste, use of raw materials,
energy efficiency, and noise, prevention of accidents and restoration of the site upon closure.
The planning of installations and the permit conditions including emission limit values shall be
based on the Best Available Techniques (BAT). In specific cases, some flexibility, e.g.
regarding emission limit values, should be allowed if an assessment shows that achieving the
emission levels associated with BAT would lead to disproportionately higher costs compared to
the environmental benefits due to the geographical location or the local environmental
conditions or the technical characteristics of the installation.

12.7 Criteria for technical and economic viability for hazardous waste
management
Before implementing a waste management project, e.g. building a new installation for
hazardous waste treatment, the technical feasibility and economic viability of the project concept
needs to be evaluated. A project is technically feasible, if it can be implemented using available
technologies, without unreasonable technical risks. A project is economically viable if the
economic advantages of it are greater than its economic costs – taking into account externalities
and environmental impact.
The assessment of the technical feasibility and economic viability of a waste management
project should be based on / should cover at least the following:
 The estimation of the quantities and composition of the relevant waste types generated
during the expected lifetime of the planned installation, in the area / region concerned;
 Efficient and safe ways of collecting and transporting wastes concerned;
 The preliminary design and technical properties of the planned installation;
 Selection of available sites and technical feasibility of these sites, including geological
assessment;
 The existing environmental situation;
 Environmental benefits, which can be achieved by the project and environmental risks
related to the project;
 Legal framework;
 Public opinions and awareness;
 The estimation of the required initial investment and of the annual operating costs;
 Options for financing the project.
12.8 Measures for implementation of public awareness campaigns

and provision of information to wider public or target group of
interested consumers
When setting up public awareness and information campaigns best-practice115 examples shall
be considered. Particular emphasis shall be placed on reaching all stakeholders, including non-
native speakers via multilingual or pictorial communication and via school activities. Additionally,
awareness-raising activities/campaigns/meetings will integrate the aspect of collecting feedback
and possibly complaints from residents on the waste management system in place. Waste
advisers could be useful to this aim, since they can directly answer the comment by citizens or
report the issue to the local authority/public utility company.
The following elements of effective awareness-raising will be embedded in all awareness-raising

campaigns:
 ensure continuity, consistency, complementarity and clarity of all communications with
well-defined aims and objectives;
 create clear messages appropriate to, and directed at, well-defined target audiences;
115
Dri M., Canfora P., Antonopoulos I. S., Gaudillat P., (2018): Best Environmental Management Practice for the Waste
Management Sector, JRC Science for Policy Report,

 ensure efficient delivery through the integration of activities and clear lines of
responsibility.
The guideline to submit the right message and get a positive result is to use a wide range of
communication methods via appropriate communication channels tailored to the target audience
and to the message to be delivered, in particular:
 Advertising: radio, printed press, TV, outdoor billboards, mobile, online, cinema spots
 Public relations: media relations via radio, press, TV and online.
 Direct marketing: door-to-door canvassing, leaflet/information distribution, exhibitions
and events.
 Community engagement: outreach to schools, support for local community groups,
collaboration with third-sector organizations, roadshows, seminars and door-to-door
campaigns.
 Online engagement: local authority, waste management organization, public agency or
third-sector websites, interactive activities and videos, and apps, e.g. providing
information on nearest collection points.
Social media: social media is an effective way for citizens to access real-time or
location-specific information, and provides a convenient and flexible form of
communication. Channels include YouTube, Facebook, and Twitter.
No two towns or regions are identical but all have to face similar challenges. That is why an
exchange of information and experiences on local, regional and national level is particularly
useful in order to improve awareness raising throughout Serbia. It has be considered also, that
parallel initiatives related to waste prevention will enhance their effectiveness.
12.9 Data about disposal sites contaminated historical waste and

measures for rehabilitation thereof
(It will be added in a further mission)
12.10 Other measures relevant for waste management
Informal collectors of secondary raw materials have been the base of the recycling pyramid in
Serbia for decades. According to a report prepared by GIZ in 2018 116 still informal collectors 117
are responsible for collection of most secondary raw materials collected and processed in
Serbia. Data processed by the Association of Packaging Waste Recyclers indicates that out of
the total amount of packaging waste collected for recycling, as much as 87% originates from the
informal sector, while only 13% is collected by public utility companies, or the packaging
schemes directly.
Recommendations to establish a programmatic framework for the structural integration of the
informal sector in Serbia are described in detail in the mentioned GIZ report.
116
GIZ - Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH (2018):
Inclusion of informal collectors into the evolving waste management system
117
In all of Serbia, according to most estimates, between 6,000 and 10,000 families, or
35,000 – 55,000 persons are working as full-time collectors who earn (close to) 100% of
family income from collecting. Some sources claim that an additional 100,000 persons
participate in waste picking on a part-time basis or alternate it with other economic activities
(Data from the Eco service cooperative) (GIZ, 2018).


13. MANNER AND DEADLINES FOR IMPLEMENTATION OF THE NATIONAL PLAN
13.1 Measures
13.1.1 Regulatory measures / instrument
Main
Measure P Manner/Action In co-operation with Until when
Responsibility
Harmonize Serbian Important provisions to be
waste legislation transposed into Serbian Ministry of Environment in
Relevant institutions and 2020 and
MR1 with EU waste H legislation are listed in cooperation with respective
stakeholders ongoing
legislation Section competent Ministries
Develop treatment standards

for WEEE including
standards for cooling and
freezing equipment, lamps,
screens
Ban landfilling the shredder
Lay down minimum residues from end-of-life
treatment standards vehicles in order to achieve Relevant institutions and
MR2 for certain waste H the recovery rates set for Ministry of Environment 2020
stakeholders
streams ELV
Laying down minimum
treatment standards for tyres
and scraped/shredded tyres
including a landfill ban
Specify technical
requirements for CP-

treatment of waste oil

including the determination of
appropriate treatment
technology.
Lay down the legal Ongoing

basis for offences Offences and penalties will during
and respective be laid down in the law on Ministry of Environment transpositio
MR3 H
penalties Serbian waste management. Ministry for Justice n of the
waste legislation relevant EU
legislation
Lay down the legal
basis for a landfill Ministry of Environmental
MR4 M Ministry of Finance 2025
tax Pollution
Introduce new
national? Reporting
obligations, and Ministry of Environmental
MR5 adapt existing H SEPA 2022
Pollution
national? reporting
obligations
Lay down that for WEEE,
ELV, waste tires, packaging,
Lay down the legal batteries, waste oil and
basis for pharmaceutical waste EPR
establishing schemes according to the
extended producer provisions of the revised Relevant producer
responsibility (EPR) Waste Framework Directive organisations, municipalities,
schemes according will be established Ministry of Environmental
MR6 H legal entities representing the 2022
to the provisions of Pollution
Elaborate the legal waste management regions,
the revised Waste SEPA
framework for EPR schemes
Framework
for individual waste streams
Directive for special
according to the provisions of
waste streams
the revised Waste
Framework Directive
including in particular the

obligatory registration of
producers/importers of all
products that become waste
after their use for which an
EPR will be introduced
(specification of which
information has be submitted,
which institution is enacted
and responsible for
establishing and running the
electronic database for these
producers/importers;
Provide the legal basis for a
Make the
mandatory demolition plan
demolition /
also specifying the obligatory
renovation plan
information that has to be Ministry of Construction,
mandatory in the
MR7 H contained related to the Transport and Infrastructure / Ministry of Environment 2020
approval
removal and/or separate Local Authority
procedures for a
collection of hazardous
demolition/de-
components and
construction permit
contaminated fractions
Lay down the legal
basis for obligatory Specific mandatory shares
use of secondary (e.g. 10%) of secondary
aggregates for aggregates to be used in new Ministry of Construction, Ministry of Environmental
MR8 publicly tendered H public tendered projects will Transport and Infrastructure / 2020
Pollution
projects in green be laid down, also Local Authority
public procurement considering quality aspects
rules)
Lay down
provisions related Ministry of Construction,
Provisions should include an Ministry of Environmental
MR9 to recovered C&D M Transport and Infrastructure / 2025
end-of-waste clause, Pollution
waste e.g. in a by- Local Authority
law on C&D waste

Simona, insert here

packaging if any
Oblige retailers of Lay down, that retailers are
MR10 mineral oil to take M obliged to take-back waste oil Ministry of Environmental 2022
back waste oil from end-users free of charge Pollution
The recycling/energy
recovery target of 80%/20%
Adapt the
of the collected waste tires
recycling/energy Ministry of Environmental
MR11 recovery target for H will be adapted according to 2020
plant infrastructure and Pollution
waste tires
analysis of environmental
impacts
The general POPs
destruction in wastes is
needed in accordance with
limit values which are less
Lay down the legal than the relevant limit values
basis for a control for the classification of POPs
MR12 and supervision wastes as hazardous. Ministry of Environment 2021
system for POPs Therefore, a control system
containing wastes similar to the control system
for hazardous wastes is
needed to enable the
authorities to supervise the
POPs wastes requirements.
MR13 Define the limit In general, wastes with POPs Ministry of Environment Chamber of Commerce 2020
values or content below the limit values Operators
restrictions for can be managed without any
POPs wastes restriction. But, e.g. use of
generated or to be sewage sludge as fertiliser,
disposed of in recycling of plastics for
certain waste reprocessing, the limit values
management of POPs in these waste
streams shall be more

stringent in order to avoid

accumulation in the
biosphere and the circular
management
It should be checked if the
operated cement kilns can be
empowered for the input of
small amounts of POPs-
containing wastes (defined
POPs content and dispensed
input). In the same way, other
thermal treatment facilities
facilities (power plants, metallurgical
operations in accordance
with Directive 2000/76/EC)
could be enabled to dispose
of certain POPs-containing
wastes.
Requirements or restrictions
for the landfill of POPs
wastes – if allowed according
to European legislation –
shall be established,
including the option of bans
or more stringent limit values
Assessing national waste Minister of Health
compliance assurance
system as part of an Minister of agriculture,
Update the legal environmental governance Ministry of Environmental
forestry and water
framework assessment framework. Protection
management 2020
Reflecting the mixing ban of
medical and pharmaceutical Minister of Finance
waste in national legislation
and also the permit Minister of Economy

conditions and ensure their

enforcement.
Elaborating clear guidance
on waste classification.118
Introducing of a legal basis
for creating an EPR for
pharmaceutical waste in the
relevant legislation. Clear
definition of EPR scheme in
the relevant legislation.
Elaborating a methodology
for establishing and
managing the financial
contributions which will be
paid by producers to cover
the costs of all of the aspects
of pharmaceutical waste
management.
Setting up a minimum
technical requirements for
pre-treatment of medical
waste, within public sanitary
facilities.
Creating an Strengthening the Minister of Health Minister of Education,
environmental and cooperation between Ministry Science and Technological
health informational of Environmental Protection Ministry of Environmental Development
system, essential Protection 2021
and Ministry of Health and Minister without portfolio
tool to support
policy-making, Minister of agriculture, Minister of agriculture, responsible for innovation
allowing priorities to forestry and water forestry and water and technological
118
Use of the Commission`s technical guidance on the classification of waste
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018XC0409(01)&from=EN

management (an Official

Agreement between parties
involving), in order to achieve
a good medical and
pharmaceutical management
in Serbia
Based on the experience of

earlier projects and involving
a wide range of stakeholders,
the Ministry of Environmental
be set on the basis Protection must address the
of evidence, current priority policies,
enhancing access including those related to development
to information and
environment and health, management
facilitating
communication with assuring their synergy and
the public reducing duplication. Through
active involvement of the
national authorities, the
environment and health
information system will
contribute to the development
of sustainable health
information and knowledge
system related to waste
management.
Creating and For each project, will be links Minister of Health

integrated data to further information Ministry of Environmental
base for all projects Minister of agriculture, 2020
(layman's report, project Protection forestry and water
related to medical
and pharmaceutical website and project management

summary), where they exist.

The "Read More" section of
some project summaries
shall include links to
publications or videos
specific to the project in
question.
Ministry of Environmental
Protection must take in
consideration also all Ministry of Mining and Energy
agreements (in future period)
in medical and Minister of Public
pharmaceutical waste Administration and Local
Self-government
management field, closed for
waste management the projects which will be Minister of Education,
constructed under the Serbia Science and Technological
territory. Development
All the local producers and all Minister without portfolio

manufacturers that market responsible for innovation
medical and pharmaceutical and technological
products (for human and development
veterinary use) must be also
known by the Ministry of
Environmental Protection. In
this sense, a better
collaboration with the actors
involved in their registration is
essential to know their
numbers/activities on Serbia.
Improving Improving monitoring and Ministry of Environmental Minister of Public 2020

Administration and Local

Self-government
reporting, including by
monitoring and Minister of Health
ensuring that data is captured Protection
reporting system
at municipal level. Minister of agriculture,
forestry and water
management
Minister of Health
Minister of agriculture,
forestry and water
management
Accessing the EU funds for Minister of Public

the new infrastructure, setting Administration and Local
Using EU funds collection service standard Ministry of Environmental Self-government
2024
and standard for storage Protection
Minister of Education,
facilities etc...
Science and Technological
Development
Minister of Finance
Minister of Economy

13.1.2 Operative measures / instruments
Main Until
Measure P Manner/Actions In co-operation with
Responsibility when
Establish a bin/bag collection system for
H separate collection of municipal waste Municipalities private sector 2029119
covering 100 % of the Serbian population
Establish a network of amenity sites
across the country for various municipal
H Municipalities private sector 202988
wastes including hazardous household
wastes (at least one in each municipality)
Establish waste centres with appropriate
Establish an integrated separation lines for recyclable waste
H Regions private sector 202988
system for municipal separation - in each waste management
MO1
waste management region
throughout Serbia Establish a waste-to-energy plant in Private companies, City
H Ministry of Environment 2021
Belgrade of Belgrade
Establish a sanitary landfill in each Serbian
H Regions Private sector 2031
waste management region
Construct small composting capacities
H (composting lines) for composting organic Regions private sector 203288
municipal waste
Introduce home composting in rural
M Municipalities private sector 203288
regions
119
For details of the implementation by individual regions refer to DSIP Landfill Directive (Eptisa, 2018)

Ceasing of landfill operation of all non- ongoing,

H
compliant landfills and dump-sites to be
Close non-compliant
MO2 Landfill operators Municipalities complete
landfills and dump-sites Re-cultivation of the closed landfills and
M d by
dump-sites 2031
Ministry of
Adapt existing plant Adapt plant permits taking into account the Environment,
permits and issue new
Industrial Emissions Directive and revised Secretariat for
MO3 permits for installations H 2023
now falling in the IPPC BAT Reference document for Waste urbanism and
regime Treatment including the BAT-conclusions environment protection
Vojvodina
Ministry of Environmental
Provide sufficient trained staff at state level
Protection (MEP),
(Ministry of Environmental Protection
Government Secretariat for urbanism 2020
(MEP), Secretariat for urbanism and
and environment
environment protection Vojvodina)
protection Vojvodina
Provide sufficient trained staff at local level Local Self Government
Intensify enforcement of (Local Self Government Units, Units, municipalities and 2020
MO4 environmental H municipalities and cities) cities
legislation
Apply the “Manual on waste control” 120, in Environmental
the in routine inspections of waste inspectors on state and ongoing
management facilities local level
Environmental Labour inspectorate,
Intensify inter-institutional cooperation in
inspection on state veterinary inspectorate, ongoing
enforcement activities
level traffic inspectorate
MO5 Conduct a feasibility H Ministry of Environment Ministry of Finance 2021
120
The Manual on waste control was elaborated within the Twinning project SR10-IB-EN-01 to provide guidance for routine inspections at waste
management facilities. It describes details how inspectors should verify if operators are respecting the conditions required by the legislation and by their
permit in the course of site inspections. It also it describes how – in case of incompliance – additional measures and enforcement actions shall be
assessed in the light of timing, effectiveness and cost-efficiency.

study for introduction of

a landfill tax in Serbia
Common rules to grant benefits to private Ministry of Chamber of Commerce,
operators and municipalities will be Environment, Ministry Municipalities
established. Measures that can be funded of Finances, Ministry of
Establish governmental shall involve all measures for closing of Economics
funds for the installation non-compliant plants, especially landfills
MO6 of new and amendment H and dumpsites, and their recultivation. 2020
of existing waste Also, the remediation of contaminated
management plants sites, the ad-hoc cleaning of stockpiles
and the closure of inappropriate landfills
shall be subject to governmental benefits
in single cases.
Strengthen the capacities of SEPA (human Ministry of Environmental
H Government 2020
resources) Protection
Improve collection of
Improve national waste statistics by
waste data and waste
MO7 M inclusion of estimates for the activities of SEPA Relevant stakeholders 2023
reporting
the informal sector.
Improve the administrative data collection
H xx 2023
system
MO8 Establish an adequate H Construction of 5 regional storage facilities Private sector Ministry of Environmental 2035
network of treatment for hazardous and POPs waste in five Protection, waste
installations for regions of Serbia. It is expected that these management regions
hazardous waste
storage facilities will be operated mainly by
private operators, often in the context of
treatment facilities. Hazardous waste will
then be transferred to treatment facilities
or exported out of Serbia.
Construction of at least two facilities for
physical- chemical treatment of inorganic
and organic liquid hazardous waste and
sludge combined with storage units for
liquid and pasty industrial special waste

streams like solvents, acids, bases etc. on

the one hand and oily wastes and solvents
on the other. Capacity needed is min.
50,000 t/a.
Establishment of 5 regional incineration
plants for organic industrial, medical and
POPs waste, eventually combined with
capacities for the preparation of residues
derived fuels (RDF) from organic
hazardous waste streams. The total
capacity needed is ~ 30,000 t/a, and can
partly be realised by co-incineration in
industrial plants.
Establishment of one landfill for inorganic
industrial hazardous waste eventually
combined with capacities for the
solidification of pasty hazardous waste
streams and POPs waste. The needed
capacity is between 28.000 and 38.000 t/a
Establish a sorting facility for mixed
portable batteries as soon as relevant
collection amounts are available
Identify appropriate locations for mobile
C&D waste treatment and for storage of
Establish a nation-wide the processed C&D waste by minimum 84
network for pre-
municipalities and of a central location for Municipalities, regions,
MO9 treatment of C&D waste H 2024
prior to recycling mobile C&D waste treatment and for private sector
storage of the processed C&D waste and
operation of one mobile treatment machine
in minimum 15 regions
MO10 Establish a nation-wide M All sanitary landfills for municipal solid Regions Private sector 2031
network for compliant waste will be featured with a separate

landfilling of non- compartment for non-hazardous C&D

hazardous C&D waste waste.
Extend the current
separate waste
collection networks in Special containers/bags for packaging
Municipalities, public
SIMONA
all municipalities, for at waste materials will be installed in all x
utility companies
least glass, plastic and municipalities in Serbia
metal, as well as paper
and card-board
Voluntary agreements
Reduce the annual Fees
SIMONA
consumption of plastic
bags Ban light plastic bags
Citizen awareness-raising campaigns
Provision of:
Private sector
- at least 2 authorized take-back facilities
(automotive producers
for ELV in Užice, Kraljevo, Novi Sad, Ministry of Environment,
and recycler
Valjevo and Nis, at least 3 take-back local authorities
& recovery
facilities in Belgrade and at least 1 take
operators)
Establish a nation-wide back facility in all of the remaining regions
MO11 network of collection Provision of:
facilities for ELV - at least a third authorized take-back Private sector
facilities for ELV in Užice, Kraljevo, Novi (automotive producers
Ministry of Environment,
Sad, Valjevo and Nis, at least 2 additional and recycler
local authorities
take-back facilities in Belgrade and at least & recovery
1 additional take back facility in all of the operators)
remaining regions
Prepare technical
This shall in particular include clear
guidance for collection
definitions for used tires, part worn tires
of used tires and for
MO12 M and waste tires and the requirement to Ministry of Environment Relevant stakeholders 2023
treatment of waste tires
collect those types of used tires separately
including preparation for
at the take-back/collection site.
reuse
Implement WEEE pilot
MO13 The expert shall further develop/specify
project

Competent authorities shall be equipped Ministry of Chamber of Commerce

with suited fast testing methods Environment, concerning private
Provide competent (qualitative check), e.g. XRF-spectroscopy laboratories
authorities with easily devices according to the estimated needs SEPA
practicable test in Serbia. This shall be used for the waste
methods to detect stream control as well the market control.
MO14 POPs and chemical H For quantitative waste checks, laboratory 2020
elements which are devices are needed like GC-MS, LC-MS,
relevant for the or alternatively HPLC-MS. Legislatively
classification of wastes required standard test methods shall be
as hazardous. established within the authorities or
alternatively shall be contracted with
private laboratories.
Sensitise the competent authorities for Ministry of Environment
L aspects of POPs wastes and other ongoing
hazardous wastes
Strengthen the Create a special administrative unit to Ministry of Environment
administrative manage the decontamination, remediation
MO15 Further Ministries
supervision related to and recreation of the initial state of these
POPs waste M contaminated sites, especially former responsible for 2030
dumpsites and illegal deposits of wastes, Financing and for the
certain industrial sites which are out of general structure of
operation, former mining areas. authorities
The data basis on POPs in environmental Ministry of
media shall be created and to be amended Environment, Continuo
continuously. Relevant sectors to monitor
SEPA usly
Establish regular the presence and the amount of POPs are
accordin
monitoring measures especially soil, water, foods and animal
MO16 g to the
related to POPs in the feedstuff (possibly to be extended).
financial
environment Particularly the surrounding areas of
possibiliti
landfills/dumpsites, relevant emitting
es
plants, contaminated sites and similar hot
spots shall be monitored.

Main Until
Measure P Manner/Activity In co-operation with
Responsibility when
Implementing of collection service Ministry of
requirements for all sanitary units, for a Environmental Minister of Public
proper waste streams. Protection Administration and Local
Self-government
Developing the national service
standards Minister of Health
Implementing the separate
M
collection of hazardous For medical waste collection
O 2020
waste from medical and
17 (hazardous and non-hazardous) to Minister of agriculture,
veterinary activities.
specify the forestry and water
management
type and volume of containers, minimum
and maximum frequency of collection and
type of vehicles used, having in view
protected areas, geographical condition,
typical climate etc...
Establishing/implementing the national Ministry of Minister of Public
collection network points for Environmental Administration and Local
pharmaceutical waste (expired or Protection Self-government
inappropriate for human or veterinary use),
Developing the national service standards

for pharmaceutical waste collection Minister of Health
Ensure a proper separate
(hazardous and non-hazardous) to specify
M collection system for
pharmaceutical waste the type and volume of containers,
O Minister of agriculture, 2020
minimum and maximum frequency of
18 (including their packaging). forestry and water
collection and type of vehicles used.
management
Implementing the collection service
requirements for commercial premises
(pharmacies), as this may help to ensure
separate collection of different
pharmaceutical products/packaging of the
pharmaceutical products.
Update the waste management plans for Municipalities Private sector

13.1.3 Informative measures / instruments
Main Until
Measure P Manner/Activity In co-operation with
Responsibility when
Information campaigns related to

collection of municipal waste:
Inform citizens about wastes to be
H collected separately, about functioning of
Conduct information the bin/bag collections system, about
Regions, Ministry of
campaigns related to amenity sites (opening hours, waste 2020,
MI1 Municipalities environment, EPR
municipal waste fractions etc…) etc. ongoing
schemes
management for citizens
Information campaigns related to
prevention of municipal waste covering
H at least the following elements: organic
waste, paper waste, packaging and bulky
items
Implement yearly education and Ministry of Finance
information campaigns targeting Ministry of 2022 and
Develop a national consumers. Environment ongoing
awareness strategy for Chamber of Commerce
MI2 packaging waste and a Prepare campaign materials needed to
plan targeting consumers help educate and inform households and
businesses regarding collection and
recycling schemes.
Apply for European Funds
Establishment a data-base of authorized Producers/importers of Municipalities, waste
Organize information on 2024
take-back facilities for end-of-life vehicles ELV, details to be management regions,
MI3 take-back of end-of-life M
Information of citizens about authorized defined in legal public utility companies, continuo
vehicles for citizens
collection facilities for take back of end-of- framework for EPR Ministry of Environmental usly

life vehicles available in their vicinity e.g.

via internet, municipality newspaper … ELV Pollution
Conduct information
campaigns related to Public Utility companies,
Continuo
MI4 asbestos and asbestos M Ministry of Environment,
usly
cement for citizens regions
Further inventories for POPs shall be

Create inventories for new established to identify new POPs in Ministry of from
MI5 POPs articles and products that are imported Environment, 2020
(connected to measures No 8 (chapter SEPA onwards
13.1.1) and No 10 (chapter 13.1.2)).
Information sharing and transfer at the
regional level for techniques to identify
new POPs and their presence in articles
provide common information and
Perform information and
awareness raising about the presence of Ministry of
awareness raising POPs in articles and exposure routes to Environment,
MI6 campaigns concerning Municipalities ongoing
these substances throughout the life‐cycle Ministry for Health and
POPs Inform in general about the health risks social affairs
resulting from POPs in products and in
wastes. Increase the protection of
workers of the waste disposal and
recycling industry.
7 Developing121 awareness H Instruments to promote the guidance are: 2019
guidelines/public  workshops Ministry of
awareness campaigns122  internet Environmental Minister of Public
Administration and Local
regarding collection of  (websites) Protection
Self-government
unused/expired medication  folders, brochures
for human use from
households. Minister of Health
121
Ministry of Environmental Protection, Ministry of Health, Health Fund of the Republic of Serbia, Association of Pharmaceuticals of Serbia, Medicines and Medical Devices Agency of Serbia,
The Innovative Drug Manufacturers’ Fund-INOVIA, Institute of Public Health of Serbia, Agency for accreditation of Health Care Institutions of Serbia, industrial laboratories that introduce
medicinal products on the national market and representative organizations of the pharmacists.
122
To raise awareness on how to collect /dispose of unused or expired medicines appropriately, bringing information from "meds disposal" http://medsdisposal.eu/about-us/

Developing guidance referring to separate Minister of agriculture,

collection/good practice for forestry and water
pharmaceutical waste. management
Ministry of
Environment Protection
Develop a national
Extending awareness campaigns
awareness campaign Minister of Health Minister of Public
(developed already by the public health
related to medical and Administration and Local
authority or the Institute of Public Health 2020
pharmaceutical waste Self-government
of Serbia/network of regional public health
Minister of agriculture,
management institutes)123.
forestry and water
management
13.1.4 Market based measures / instruments
123
http://www.hpi.sk/en/2014/01/serbia-brief-health-system-review/

Main Until
Measure P Manner/Action In co-operation with
Responsibility when
Introduce of a pay as All municipalities will introduce a pay as
you through tariff you through tariff system
Regions, Ministry of
MM1 system for municipal H Municipalities 2020
Environment
waste by all
municipalities
Introduce quality Elaborate quality standards considering Institute for MEP, Ministry of
MM2 standards for secondary H technical and environmental aspects and Standardization of Construction, Transport 2019
aggregates quality assurance schemes Serbia (ISS) and Infrastructure
here packaging if any
Companies shall facilitate the
identification of new POPs in articles and
the way in which these products should
Identification of POPs
be disposed of after their useful lives. Ministry of
MM3 containing articles and H 2020
Regulations should be introduced to Environment
products
require the labelling of articles for their
POPs content and for their
environmentally sound disposal
13.2 Assignment of responsibilities for implementation of measures
The institutions/bodies responsible for implementation of the measures of the current Waste Management Strategy assigned in the tables of the
preceding chapters.

TABLES
Table 1: Targets defined in EU legislation for recovery of specific waste streams.....................31

Table 2: Selected EU regulation on hazardous substances.......................................................33
Table 3: Quantities of waste generated in Serbia in 2016 broken down by the 2-digit chapter
codes of the List-of-Waste (Source: Waste management in the Republic of Serbia for the
period 2011-2016; SEPA 2017)..........................................................................................50
Table 4: Quantity of waste from category 20 th of the Waste list in tonnes/year (Source: Waste
management in the Republic of Serbia for the period 2011-2016; SEPA 2017)..................52
Table 5: Quantities of utility waste (Source: Waste management in the Republic of Serbia for
the period 2011-2016; SEPA 2017).....................................................................................52
Table 6: Waste management regions (Source: Investment Planning Tool (Solid Waste
Management in Serbia) and Implementation plan for council directive 1999/31/EC On the
landfill of waste).................................................................................................................. 54
Table 7: Quantity of waste disposed on sanitary landfills in tonnes per year (Source: Waste
management in the Republic of Serbia for the period 2011-2016; SEPA 2018)..................56
Table 8: Waste generation in construction sector (data from SORS, 2017)...............................59
Table 9: Hazardous industrial and commercial waste in Serbia in 2016. The most important
waste types in terms of quantity (SEPA 2017)....................................................................66
Table 10: The quantities of hazardous wastes treated in Serbia in 2016 by recovery/disposal
operation.(Source: SEPA 2017).......................................................................................... 67
Table 11: Generation and treatment of hazardous wastes in Serbia broken down according to
the 2- digit groups of the European List of Waste (SEPA 2017)..........................................68
Table 12: Packaging quantities placed on the market by producers/importers/fillers organised in
a collective/individual scheme in tonnes (Source: SEPA annual reports)............................71
Table 13: Amount of packaging placed on the market by producers/importers/fillers that chose
to pay the fee instead of achieving the recycling and recovery targets in tonnes (Source:
SEPA annual reports).......................................................................................................... 71
Table 14: Ratio of packaging material type in household and industrial and commercial flows
[%] (Source: DSIP or packaging waste)..............................................................................72
Table 15: Municipal packaging waste separately collected via collective schemes in tonnes
(Source: SEPA annual reports)........................................................................................... 72
Table 16: Industrial and commercial packaging waste reported by collective schemes in tonnes
(Source: SEPA annual report)............................................................................................. 73
Table 17: Packaging waste reported as recycled by collective schemes in tonnes (Source:
SEPA annual report)........................................................................................................... 74
Table 18: Packaging waste recovery reported by collective schemes in tonnes (Source: SEPA
annual report)...................................................................................................................... 75
Table 19: The number of registered passenger cars (Source: SORS, 2017):...........................78
Table 20: Quantity of tires put on the market in 2016 (Source: SEPA 2017)..............................82
Table 21: Waste tires in Serbia (Source: SEPA 2017)...............................................................82

Table 22: Estimation on EEE placed on the market (Source: MEP – DSIP WEEE Directive)....84
Table 23: Waste codes for waste batteries and accumulators...................................................87
Table 24: Transformers with PCB-based fluids in use in Serbia in 2015 (Source: Draft SWSP for
wastes containing POPs, 2018).......................................................................................... 90
Table 25: Generation and export of PCB-wastes (Source: NIP under Stockholm Convention
(up-date 2014/2015), SEPA database on waste generation and export for the reference
year 2016)........................................................................................................................... 91
Table 26: Amount of wastes containing pesticides (Sources: SEPA-database on waste
generation for several reference years)...............................................................................94
Table 27: POPs pesticides inventory according to the NIP (update 2014/15)............................95
Table 28: Medical waste generated 2011- 2016 in tonnes (Source: SEPA, 2017)...................100
Table 29: Veterinary waste generated 2011-2016 in tonnes (Source: Waste management in
Republic of Serbia, SEPA 2017).......................................................................................101
Table 30: Quantities of medical waste treated 2016 in tonnes (Source: SEPA, 2018).............102
Table 31: Quantities of medical waste (including veterinary waste) exported 2016 in tonnes
(Source: SEPA, 2018)....................................................................................................... 102
Table 32: Quantities of veterinary waste treated in 2016 in tonnes (Source: Waste management
in Republic of Serbia, SEPA 2017)....................................................................................103
Table 33: Exports of waste from Serbia in 2012-2016 (Source: SEPA)...................................107
Table 34: Wastes exported from Serbia in 2016. The most important waste types in terms of
quantity (Source: SEPA 2017).......................................................................................... 108
Table 35: Imports of waste to Serbia in 2012-2016 (Source:SEPA).........................................108
Table 36: Wastes imported to Serbia in 2016. The most important waste types in terms of
quantity (Source: SEPA 2017).......................................................................................... 108
Table 37: Exports and imports of certain recyclables in 2016 (Source: SEPA)........................109
Table 38: Receycling and reduction targets to be implemented from 2024 to 2035.................116
Table 39: Projected amount of generated municipal waste for Serbia from 2014 to 2030........118
Table 40: Projected amount of generated biodegradable municipal waste for Serbia from 2014
to 2030.............................................................................................................................. 120
Table 41: Economic data [SOSR, 2017]...................................................................................121
Table 42: Expected types and quantities of hazardous wastes in Serbia in 2020 and in 2024.
.......................................................................................................................................... 125
Table 43: Forecast of the packaging placed on the market, tonnes (Source: DSIP on PPWD)126
Table 44: Structure of packaging material types, % (Source: SEPA).......................................126
Table 45: Number of licenses for collection, transport, storage, treatment and disposal of
hazardous waste (SEPA 06.11.2017)...............................................................................136
Table 46: Number of permits issued for collection, transport and storage for PCB waste relevant
waste codes (Source: SEPA Database on plant permits, status September 2018)...........141
Table 47: Number of permits issued for waste management activities for POPs waste relevant
waste codes (Source: SEPA Database on plant permits, status June 2018)....................142

Table 48: Regional and local sanitary landfills (2017)..............................................................145

Table 49: Landfills that have cells for hazardous waste in the Republic of Serbia...................145
Table 50: Examples for operators carrying out physico-chemical treatment activities..............146
Table 51: Examples for operators carrying out treatment activities for WEEE.........................147
Table 52: Main existing infrastructure for management of waste in Serbia..............................151
Table 53: Infrastucture plan for municipal waste management................................................155
Table 54: Examples of source separated municipal waste collected either by door-to-door
collection or by bring systems........................................................................................... 166
Table 55: Amenity site place selection criteria..........................................................................168
Table 56: Impact of separate collection on treatment quality....................................................177
Table 57: Technical infrastructure to be established until 2025 [until 2035]............................181
Table 58: Ranking of landfills according to the risk potentially posed to the environment........187
Table 59: Transaction cost structure in the project preparation phase (ISWA, Financial Aspects
of Solid Waste Management, 2014)..................................................................................189
Table 60: Main infrastructure for management of municipal solid waste in Serbia...................189
Table 61: Investment costs for municipal waste management in Serbia..................................190
Table 62: Investment costs on plants for MBT and Waste-to-Energy in Serbia........................190
Table 63: Investment costs on plants for C&D waste in Serbia................................................191
Table 64: Investment costs on plants specifically treating hazardous waste in Serbia.............191
Table 65: Minimum distance of composting facilities to housing areas....................................198
Table 66: minimum distance of indoor compostin facilities to housing areas...........................198
Table 67 Revenues from pollution fees for packaging waste...................................................206
Table 68 EEE- total amount of fee calculated and collected, RSD...........................................206
Table 69 WEEE - Incentives to recycling companies...............................................................206
Table 70: Necessary amendments of legislation .....................................................................208
Table 71: General guidelines for planned technologies and waste management methods......225

FIGURESY
Figure 1: Relevant stakeholders for issues on waste management planning.............................19

Figure 2: Share of generated waste in the Republic of Serbia by sectors in 2016 (Source:
SORS, Statistical Release ZS60)........................................................................................ 50
Figure 3: Average morphological composition of mixed municipal waste in Serbia....................52
Figure 4: WEEE treated in Serbia in tonnes (Source: SEPA annual report)...............................84
Figure 5: Batteries and accumulators placed on the market in Serbia (tonnes).........................87
Figure 6: Medical waste generated 2011-2016..........................................................................99
Figure 7: Predicted composition of generated MSW in Serbia for 2014 - 2030 (kg/cap/year). .118
Figure 8: Forecast of amount of EEE placed on the market – total (tonne) and per capita
(kg/capita) (Source: MEP – DSIP WEEE Directive)..........................................................126
Figure 9: Forecast of the total amount of batteries and accumulators placed on the market – in
tonnes and in kg/capita (Source: MEP – DSIP Batteries Directive)..................................128
Figure 10: Forecast of the amount of portable batteries and accumulators placed on the market
– total, in tonnes (Source: MEP – DSIP Batteries Directive).............................................128
Figure 11: Principal municipal waste management scheme.....................................................152
Figure 13: Waste management infrastructure for municipal solid waste (MSW)......................183
Figure 14: Waste management infrastructure for packaging waste..........................................183
Figure 15: Waste management infrastructure for WEEEs, batteries and accumulators...........184
Figure 16: Waste management infrastructure for construction and demolition waste..............184
Figure 17: Waste management infrastructure for hazardous waste.........................................185
Figure 18 Amounts of all pollution fees collected in 2010-2016, EUR......................................205

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Twinning Project

Support to Waste Management Policy

National Waste Management Strategy

NWMS including NWMP 2019-2024 version from

Approved by MS Project Leader Brigitte Karigl

Approval by BC Project Leader Aleksandar Vesić

Project title Support to Waste Management Policy

Project number SR13/IPA/EN/04 16

Lietuvos Respublikos aplinkos ministerija,

WASTE MANAGEMENT STRATEGY

THE NATIONAL WASTE MANAGEMENT STRATEGY.......................10

2 ANALYSIS AND ASSESSMENT OF CURRENT

Support to Waste Management Policy

2.5.11 Pharmaceutical waste........................................................................102

3 NATIONAL WASTE MANAGEMENT GOALS.......................112

THE NATIONAL WASTE MANAGEMENT PLAN..............................120

4 EXPECTED TYPES, QUANTITIES, AND ORIGIN

Support to Waste Management Policy

4.3 Expected types and quantities of waste to be

5 EXISTING WASTE COLLECTION SYSTEM AND

6 ASSESSMENT OF NEEDS FOR NEW

Support to Waste Management Policy

THE CONSTRUCTION OF SUCH

Support to Waste Management Policy

6.3.13 Physico-chemical treatment and treatment of waste oils...................188

7 PLAN FOR IMPLEMENTATION OF REDUCTION

8 NECESSARY CAPACITIES OF NEW

9. ORGANISATION OF WASTE MANAGEMENT,

Support to Waste Management Policy

9.1 Public sector.....................................................................................222

10. SOURCES AND AMOUNTS OF FINANCIAL

11. ASSESSMENT OF USEFUL EFFECTS AND

12. MEASURES AND GUIDELINES FOR

Support to Waste Management Policy

12.3.5 Waste Oil........................................................................................... 245

13. MANNER AND DEADLINES FOR

Support to Waste Management Policy

BAT Best Available Technology

Support to Waste Management Policy

WBA Waste Batteries and Accumulators

Support to Waste Management Policy

THE NATIONAL WASTE MANAGEMENT STRATEGY

Support to Waste Management Policy

Sustainable waste management is an essential element of a comprehensive strategy for

Support to Waste Management Policy

1.1 Role of the Waste Management Strategy and Waste Management

Sustainable waste management is an essential part of sustainable development. Environmental

1.2 Special waste streams and other relevant waste streams

Special waste streams as defined by Articles 47 to 58 of the LWM are:

Support to Waste Management Policy

 Construction and demolition waste;

Support to Waste Management Policy

Support to Waste Management Policy

Support to Waste Management Policy

Support to Waste Management Policy

Waste electric and electronic equipment (WEEE) –means electrical or electronic

Support to Waste Management Policy

operations resulting in a change in the nature or composition of this

Support to Waste Management Policy

2 ANALYSIS AND ASSESSMENT OF CURRENT WASTE

2.1 Current institutional framework for waste management

Support to Waste Management Policy

Support to Waste Management Policy