Waste management requirements in Serbia, energy and industrial construction projects 

In Serbia, waste management for energy and industrial construction projects is governed by national laws that align with European Union standards. Effective waste management is essential for legal compliance, environmental sustainability, and securing project financing. Here’s a detailed look at the waste management requirements specific to these projects.

Legal Framework

1. Law on waste management
   • Established through the “Official Gazette of the Republic of Serbia” (No. 36/2009, 88/2010, 14/2016, 95/2018, 35/2019), this law outlines the framework for waste management, emphasizing prevention, reuse, recycling and safe disposal. Key principles include:
     • Waste hierarchy: Prioritizes waste prevention, reuse, recycling, energy recovery and safe disposal as a last option.
     • Extended Producer Responsibility (EPR): Obligates producers to manage waste from their products, encouraging recycling and recovery.
2. Law on Environmental Protection
   • This law (No. 135/2004, 36/2009, 72/2009, 43/2011, 14/2016) provides a broad framework for environmental protection, including regulations on waste management and environmental impact assessments.
3. Specific Regulations
   • Several by-laws detail waste management requirements for energy and industrial projects, including:
     • Regulation on waste categories: Defines waste categories and classification criteria.
     • Regulation on waste storage and labeling: Establishes rules for safe waste storage and labeling.
     • Regulation on construction waste management: Specifies requirements for handling construction and demolition waste.

Waste Management Requirements

1. Waste Management Plan (WMP)
   • Mandatory WMP: All energy and industrial projects must develop a WMP as part of their Environmental Impact Assessment (EIA) or Environmental Permit application.
   • Contents: The WMP should detail waste types, quantities, collection, storage, transport, disposal, and recycling methods, along with measures to minimize waste and mitigate environmental impacts.
2. Waste classification and categorization
   • Classification: Waste is classified into hazardous and non-hazardous categories. Hazardous waste requires special handling and disposal.
   • European Waste Catalogue (EWC): Waste categorization must adhere to EWC codes for compliance with Serbian and EU standards.
3. Hazardous waste management
   • Permit requirement: Facilities handling hazardous waste must obtain a permit from the Ministry of Environmental Protection.
   • Storage and transport: Hazardous waste must be stored separately with appropriate containment, and transporters must be licensed.
4. Construction and Demolition Waste (CDW)
   • Recycling & reuse: Projects are encouraged to recycle and reuse CDW to minimize landfill use.
   • Documentation: Accurate records of waste generated and disposal or recycling routes must be maintained.
5. Waste storage and transport
   • Storage requirements: Waste should be stored in designated areas to prevent leaks, with clear labeling and compliance with safety standards.
   • Transport documentation: A waste manifest must document the waste transport process.
6. Licensing and permitting
   • Waste management companies must hold valid licenses issued by the Ministry of Environmental Protection. Facilities treating, storing, or disposing of waste require operational permits.
7. Reporting and record-keeping
   • Project developers must submit regular waste management reports to relevant authorities, detailing waste types and management practices. Annual reports on waste management activities are also mandatory.

Financing preconditions

Compliance with waste management regulations is crucial for securing project financing, particularly from international financial institutions like the EBRD, which adhere to the Equator Principles and IFC Performance Standards. Financial institutions typically require:

• Proof of compliance: Documentation showing adherence to waste management laws.
• Environmental permits: All necessary permits for waste handling and disposal must be obtained.
• Environmental and Social Management System (ESMS): A robust ESMS to monitor waste management performance.

Meeting these requirements ensures environmental protection, project sustainability, and alignment with national and international best practices, enhancing the attractiveness of projects to potential financiers.