According to the European Commission progress reports on Montenegro, waste management is one of Montenegro’s priority issues:

an integrated waste management system [in Montenegro] is still considered at a very early stage of development. Moreover, cooperation among state and local authorities needs to be strengthened and new investments in this area are needed (with focus more on waste separation and recycling). […] Main efforts needs to be concentrated solely on the implementation and enforcement of the National Waste Management Master Plan. Current extremely low achievement rate of goals previously set (from 2011) is strong indicator of such need.”

In the National Strategy with Action plan for transposition implementation and enforcement of the EU acquis on Environment and Climate change 2016-2020, has been announced that:

“Waste is considered a sector that will pose particular challenge for the candidate countries in this regard because of the extent of the EU environmental requirements and the need for significant investment in environmental infrastructure in order to achieve compliance.
Therefore, waste management represents one of the key challenges in the process of alignment and special efforts will be focused on resolving all the problems in this area.
Basic principles of waste management that EU waste management is based on, even though integrated in the National Waste Management Strategy and National Plan for Waste Management, are still not fully applied in the system of waste management in Montenegro, particularly when it comes to the hierarchy principle which ensures compliance with the order of priorities in waste management (prevention of waste creation, preparation for re-use, recycling and other recovery operations (use of energy) and waste disposal). Systems for separate collection of municipal waste are not still established at a satisfactory level.
A centralised data collection system for the types and quantities of waste has not been on satisfactory level yet.”

 

 

The largest economic activity generating waste in Montenegro is construction and demolition with 37% of the total waste generated. (according to the EuroStats).

Municipal waste (also known as solid domestic waste or household waste) which accounts for about 13 % of total waste generated in Montenegro has a very high political profile because of its complex character, due to its composition, its distribution among many sources of waste, and its link to consumption patterns.

Zero Waste Montenegro has chosen to focus on Municipal Waste due toits limited capacity. As our NGO grows, we plan to expand our scope of work to construction and demolition waste as well.


 

  • Municipal waste production: It is difficult to give exact numbers as not all municipalities know exactly how much waste is produced in their municipality, as not all of it is collected.
    • According to extrapolation of official data provided by the Ministry of SD&T, there would be about 160.000 tons produced per year so about 250 kg per person per year (data: 2017). But those data don’t usually include waste dumped illegally.
    • According to MONSAT, the statistical office, there was in 2013 approximately 230 000 tons of municipal waste generated annually in Montenegro (so 370 kg generated per person) – and approximately 145 000 tons of biodegradable waste.
    • According to EuroStat 508 kg per person were generated in 2013 in Montenegro, among which 451 kg are treated.

 

So as an average of existing data, we could estimate the domestic waste production per inhabitant in Montenegro (data: 2013) to 400-440 kg.

 

In comparison, according to EuroStat, each person in the EU generated 475 kg of municipal waste in 2014 (and 483 kg of municipal waste in 2016).


 

  • Waste collection: Montenegro is a small country (650.000 people) with 23 municipalities divided in 3 main regions. There are 155 small unregulated landfills/dumpsites (under 100 m3) 68 medium unregulated dump sites (under 100-1000 m3) and 50 bigger than 1000 m3 across the country. Approximately 60% of total waste collected in the country end up in those unregulated landfills.
  • According to data provided by the Ministry of SD&T, national targets of waste collection for 2017 are between 65% to 95% depending on the municipalities.
  • The municipalities (LSGU’s) are responsible to manage/run the entire process of collection and disposal of waste including levy of a fee to cover all costs. To do this they usually set up an entity (PUC = Public Utility Company). The issues that most are facing, is that they lack administration skills (how to determine the fee to charge households and companies), efficiency (how to optimize resources), they also lack enforcement resources and they lack the ability to chase debt (in fact this is a major issue). There also does not appear to be any collaboration between LSGU’s, not even resource sharing (it appears some councils have extra unused capacity while others lack it….hence in some areas empty bins are collected and in other areas bins overflow).

 

  • Waste infrastructure: The waste management infrastructure in Montenegro is still under developed. Its development is part of the new National Solid Waste Management Plan. There are currently 9 recycling yards (6 in Podgorica, 1 in Herceg Novi and 1 in Kotor), 4 material sorting facilities (in Podgorica, Zabjlak, Kotor and Herceg Novi), and 2 sanitary landfills (in Podgorica (Livade) and Ulcinj Municipality (Mozura).
  • According to the last Strategic Master Plan for Waste Management it was planned to construct regional landfills in Kotor, Niksic, Berane, Bijelo Polje, Pljevlja Herceg Novi (approximately 70 million euros).
  • The government has announced its new plan in May 2018: it will consists of operating 4 waste management centers (Podgorica, Nikšić, Bijelo Polje and Bar) giving them the choice of having a Recycling Center (MRF Plant) and/or a waste treatment plant for separate and controlled disposal of construction waste, and/or a waste heat treatment plant and/or a sanitary landfill. The choice is being left to each waste management center to select the most appropriate solution depending on their needs and their budget.

 

  • Waste recycling: Currently less than 2-3% of Montenegro’s waste are recycled. The goal set in the National Solid Waste Management Plan for 2017 was 25% and for 2020 is 50%. The current objective is to increase recycling in all municipalities as much as possible, regardless of the set goal. Municipalities have set their target for 2017 between 0.8% and 8% of waste recycled/waste produced, with more than half with only 0.8%.
  • According to EuroStat, only 1% of municipal waste was recycled and 0% was composted in 2013 in Montenegro.

In comparison, according to EuroStat in 2016, municipal waste were in the EU treated as follow:

Recycled 28%         (+188% in the peri0d from 1995 to 2016)

Composted 16%     (+184% in the peri0d from 1995 to 2016)

Incinerated 27%     (+112% in the peri0d from 1995 to 2016)

Landfilled 28%       (-59% in the peri0d from 1995 to 2016)

44% of municipal waste in 2014 was recycled or composted. In 2016, 29 % was recycled.


  • Municipal waste composition in Montenegro:
Composition of municipal waste in Montenegro - 2017 [RETech Germany]

Composition of municipal waste in Montenegro – 2017 [RETech Germany]


 

  • Challenges of waste management in Montenegro:
    • the key constraints in the improvement of waste collection and recycling in Montenegro are:
    • The topography of Montenegro (mountainous country)
    • The sparse and poor rural population
    • The lack of current adequate waste management infrastructure
    • The low budget of municipalities allocated to waste management
    • The lack of channels to sell recyclables
    • The lack of awareness regarding the impact of unregulated waste land-filling
    • The local practices of outdoor waste incineration
    • The lack of (human and financial) resources at national level

 


 

  • The Waste Management institutional framework consists of:

– Ministry of Sustainable Development and Tourism:

  • Five staff is employed in MSDT.

– Local governments and 23 municipalities

– Environmental Protection Agency:

  • Four job positions have been systematized in EPA for instituting administrative procedures for the issuance of permits, collection and updating of data on all types of waste and reporting to national and European institutions

– Environmental inspectors and communal inspectors:

  • 6 ecological inspectors are employed in AIA. Their competences cover all the issues relating to environmental protection in all sub-sectors, including sub-sector of waste management. Inspection supervision for certain types of waste could include market, mining, veterinary, phytosanitary, forestry, electricity and traffic inspection.

– MONSAT:

  • One staff is in charge of waste statistics in MONSTAT (the institution competent for the collection and statistical processing of data on certain types and amount of waste, as well for EUROSTAT reporting)

 

  • Law on Waste Management (Official Gazette of Montenegro 64/11 and 39/16)
  • Law on Environment (Official Gazette of Montenegro 48/08, 40/10 and 40/11)
  • Law on Nature Protection (Official Gazette of Montenegro br. 51/08, 21/09 and 40/11)
  • Law on Environmental Impact Assessment (Official Gazette of Montenegro 80/05 and 27/13)
  • Law on Strategic Environment Impact Assessment (Official Gazette of Montenegro 80/05, 73/10, 40/11 and 59/11)
  • Law on Local Self-Government (Official Gazette of Montenegro 42/03, 28/04, 75/05 and 13/06 and Official Gazette of Montenegro 88/09, 03/10 and 38/12)
  • Law on Utility Services (Official Gazette of Montenegro 55/16)
  • Law on Spatial Development and Construction of Structures (Official Gazette of Montenegro 33/14)
  • Rulebook on detailed conditions to be fulfilled by municipal sewage sludge, quantities, volume, frequency and methods of analysis of municipal sewage sludge for permissible purposes and conditions to be fulfilled by the land planned for its implementation (Official Gazette of Montenegro 89/09)
  • Regulation on the manner and procedure for the establishment of the system of taking, collecting and treating end-of-life vehicles and on its operation (Official Gazette of Montenegro 28/12)
  • Regulation on the manner and procedure for the establishment of the system of taking, collecting and treating waste from electrical and electronic products and on its operation (Official Gazette of Montenegro 24/12)
  • Rulebook on waste classification and waste catalogue (Official Gazette of Montenegro 35/12)
  • Regulation on the manner and procedure for the establishment of the system of taking, collecting and treating waste tyres and on its operation (Official Gazette of Montenegro 39/12)
  • Regulation on the manner and procedure for the establishment of the system for taking, collecting and treating waste batteries and accumulators and on its operation (Official Gazette of Montenegro 39/12)
  • Regulation on detailed criteria, amount and method of payment of a special waste management fee (Official Gazette of Montenegro 39/12)
  • Regulation on the manner and procedure for the establishment of the system for taking, collecting and treating packaging waste and on its operation (Official Gazette of Montenegro 42/12)
  • Rulebook on waste oil treatment (Official Gazette of Montenegro 48/12)
  • Rulebook on the treatment of equipment and waste containing PCBs (Official Gazette of Montenegro 48/12)
  • Rulebook on criteria, method and treatment of medical waste (Official Gazette of Montenegro 49/12)
  • Rulebook on construction waste treatment, method and procedure of construction waste processing, conditions and manner of disposal of cement asbestos construction waste (Official Gazette of Montenegro 50/12)
  • Rulebook on the manner of keeping records of waste and the content of a form on waste transport (Official Gazette of Montenegro 50/12)
  • Rulebook on conditions to be met by a company or entrepreneur for waste treatment and/or disposal of waste (Official Gazette of Montenegro 53/12)
  • Rulebook on the detailed content and manner of submission of annual reports on the implementation of waste management plans (Official Gazette of Montenegro 53/12)
  • Rulebook on the detailed content and manner of drawing up a waste management plan of a waste producer (Official Gazette of Montenegro 05/13)
  • Rulebook on the conditions to be met by a company or entrepreneur for waste collection and transport (Official Gazette of Montenegro 16/13)
  • Rulebook on the method of packaging and disposal of asbestos-containing waste (“Official Gazette of Montenegro 11/13)
  • Rulebook on the manner of keeping and the content of the application for entry into the register of exporters of non-hazardous waste (Official Gazette of Montenegro 27/13)
  • Rulebook on detailed characteristics of the site, building conditions, sanitary and technical conditions, mode of operation and closure of landfills (Official Gazette of Montenegro 31/13 and 25/16)
  • Regulation on the manner and conditions of waste storage (Official Gazette of Montenegro 33/13 and 65/15)
  • Rulebook on incineration and/or co-incineration of waste (Official Gazette of Montenegro 33/13)
  • Rulebook on keeping the register of issued permits for the treatment and/or disposal of waste, the register of waste collectors, carriers, traders and intermediaries (Official Gazette of Montenegro 47/13)
  • Rulebook on the collection and delivery of end-of-use vehicles whose owner is unknown (Official Gazette of Montenegro 47/13)
  • Rulebook on conditions for bio-waste treatment and criteria for the determination of quality of products of bio-waste organic recycling (Official Gazette of Montenegro 59/13)
  • Rulebook on detailed conditions for entry into the register of waste intermediaries and traders (Official Gazette of Montenegro 46/13 and 21/14)
  • Rulebook on the methods of testing hazardous properties of waste and detailed conditions to be fulfilled by an accredited laboratory for testing the hazardous properties of waste (Official Gazette of Montenegro 21/14)
  • Regulation on detailed conditions to be met by substances or objects resulting from the production process for by-products (Official Gazette of Montenegro 30/15)
  • Rulebook on the method of calculating the minimum insurance sums in case of damage incurred to third parties or their property (Official Gazette of Montenegro 40/15)
  • Regulation on the manner and conditions of waste storage (Official Gazette of Montenegro 33/13 and 65/15)
  • Rulebook on the content of the application and documentation for the issuance of permit for treatment and/or disposal of mining waste (Official Gazette of Montenegro 78/16)
  • Rulebook on the detailed content of the documentation submitted with the application for the issuance of permit for import, export and transit of waste, as well as the lists of waste classification (Official Gazette of Montenegro 83/16)
  • Regulation on the criteria for the cessation of the status of iron, steel, aluminium, copper and glass waste (Official Gazette of Montenegro 26/17).

Other:

  • Montenegro Waste Management Strategy until 2030 (2015)
  • National Waste Management Plan of Montenegro 2015-2020 (2015)
  • National strategy with the action plan for transposition, implementation and enforcement of EU acquis on environment and climate change 2016-2020 (2016)
  • Draft Negotiating Position of Montenegro for Chapter 27 – Environment and Climate Change – area of Waste Management, for intergovernmental conference on Montenegro’s accession to EU (the Negotiating Position of Montenegro)
  • Spatial Plan of Montenegro (from 2008).

 

According to the EU, in order to achieve alignment with the EU acquis Montenegro intends to:

Strengthen human capacities within MSDT- Directorate for Waste Management, by employing legal officers, among other staff – this will happen by the end of this year, and no later than the first quarter of 2017
Strengthen human capacities within EPA for conducting administrative procedures for issuance of permits, collection and updating of data on all types of waste and for reporting  to national and European institutions
Ensure planning and implementation of special training for the staff of MSDT- Directorate for Waste Management and EPA
Prepare and perform internal reorganization of AIA in order to clear division of competencies and achieve greater synergy in the work of inspection bodies
Fully establish a centralised data collection system for types and amounts of waste through the already established cooperation between EPA and MONSTAT

 

Update January 2017: Montenegro is currently waiting for the decision of the Ministry of Tourism and Sustainable Development regarding the 3 proposed options presented in the National Waste Management Plan: all 3 options have in common a vast majority of waste management infrastructures around the country (5 transfer stations, 3 MRF, 4 composting facilities, 5 sorting centers).

  • Option 1 proposes the constructions of 2 new sanitized landfills (Niksic, B. Polije)
  • Option 2 proposes the construction of a sanitized landfills (B. Polije) and a transfer station in Niksic
  • Option 3 proposes the construction of a waste incineration plant (Niksic) and 3 transfer stations (B. Polije, Bar, Heceg Novi)

 

Update October 2017: Decision on which option will be chosen by Montenegrin Government which should have been announced in June 2017 is still unknown. A feasibility study for option 3 is still ongoing at the Ministry of Sustainable Development.

 

Update May 2018: The government has finally announced its decision: it will consists of operating 4 waste management centers (Podgorica, Nikšić, Bijelo Polje and Bar) giving them the choice of having a Recycling Center (MRF Plant) and/or a waste treatment plant for separate and controlled disposal of construction waste, and/or a waste heat treatment plant and/or a sanitary landfill. The choice is being left to each waste management center to select the most appropriate solution depending on their needs and their budget.