Podgorica, 22.02.2019


Your Excellency,


Zero Waste Montenegro congratulates you on having opened chapter 27 and reiterates its offer to support your work related to its contents.


Below are brief recommendations related to a plastic bag ban and the new waste management law. They were previously sent to your institution but were, regrettably, not taken on board for a number of reasons explained on the website of your Ministry.


We wish to bring your attention that chapter 27 will soon include specific legislation on oxo-degradable plastics. Contrary to previous claims, ‘oxo-degradable’ do not bring the promised benefits (oxo-degradable bags are not to be mixed up with bio-based or biodegradable bags). This has consequences on Montenegro’s future legislation such as the need to establish a precise definition for single use plastic bags. Our previous recommendations included this need and it is for that reason, as well as others, that we allow ourselves to re-send them, as they continue to be relevant.


ZWMNE reiterates its intention and mission to support your work in turning Montenegro into an ecological state and advance negotiations on chapter 27.  As such, we remain at your entire disposal should you wish to have your teams discuss the technicalities of our recommendations.



Plastic bags ban


Your announcement in Niksic in December 2018 that plastic bags will be banned in Montenegro was widely spread not just through National TV, radio and newspapers but reached international media and is now even listed in Wikipedia on the page of global movement towards the phase-out of lightweight plastic bags.


As you can see there, governments all over the world are taking action every day to ban the sale and the use of lightweight bags. As of 1 February 2019, such bans have been introduced in 55 countries, and 31 countries are imposing a charge per bag. Bans and charges have also been enacted by many local jurisdictions and cities. Our neighbours Albania and Macedonia already banned plastic bags and Croatia is on its way.


When we brought a Petition to MORT to ban plastic bags in 2017 you enthusiastically supported it (see appendix A). When we met with you in May 2018, you asked us to ‘help ban plastic bags in Montenegro’. However, in your interview with Vjesti in January 2019 you gave a different impression by putting forward data that minimize the impact of plastic bags: the percentage of plastic bags in overall domestic waste by weight. We all know that lightweight plastic bags are light per definition, and what matters is their impact that can’t be measured by their weight.


0.4% seems negligible indeed, so does the percentage for Austria (0,02%) that you brought up. We used 2016 EUROSTAT waste data to convert this relative value into an absolute one: the number of plastic bags used per year in Montenegro (see table 1). 0.4% is equivalent to almost 460 million plastic bags per year!



Population in million Total waste in tonnes Yearly waste per citizen in kilogramme Percentage plastic bags, % Plastic bags per citizen per year, kg Plastic bags per citizen per year, number of pieces mixed ordinary waste, kg (%) recyclable waste, kg (%)
Austria 8,773 4,268,278 486 0,02 0,097 48 1683308 (39%) 1463464 (34%)
Montenegro 0.622 227,055 365 0,4 1,460 730 193023 (85%) 10052 (4%)

Comparative analysis of plastic bags amount in total waste in Austria and Montenegro (2016)


We fully understand that your Ministry has many priorities to progress on Chapter 27. But plastic bags (and Single Use Plastics in general) are not to be taken lightly. Globally and in the EU, plastic bag legislations are gaining traction and Montenegro should be a frontrunner there too.



We often hear from the Waste Management Directorate that EU does not demand a complete ban on plastic bags, so why should Montenegro do it? ZWMNE disagrees with this assessment and here is why:


Most EU countries may actually not need a full ban, because 1. They already have reduced their consumption of plastic bags to a fairly low level, through voluntary initiatives and high consumer awareness (see the example of Austria with 48 bags/year/person). And 2. because they have a developed recycling system and extremely low littering rate that makes it possible for those 48 bags not to leak in the environment. This is far from being the case in Montenegro. That is why we need to ban plastic bags soon and mitigate the costs of the following issues:


  • Clogged sewers with its consequences (risks of floods, high clean-up costs to municipalities)
  • Littered nature and its negative impact on the growing tourism industry.
  • Long-term damages to the Montenegrin pristine biodiversity
  • Micro-plastics entering our food chain (especially though the wide use of oxo-degradable bags (the European Chemical Agency has recently submitted a restriction proposal on micro-plastics)


Common landscape seen around Montenegro – Niksic in this picture



Recommendations for the waste management law


A – oxo-degradable bags:


Previous response from MORT: “No definition in the proposal for this regulation for “oxo-degradable plastic carrying bags” because Montenegro currently doesn’t have the obligation to define it.”


The European Parliament and the Council agreed to slash single-use plastics in the EU (18 December 2018). The measures to be adopted include:

  • A EU-wide ban of single-use plastic cotton buds, straws, plates, cutlery, beverage stirrers, balloon sticks, oxo-degradable plastics, and expanded polystyrene food containers and beverage cup,
  • Extended Producer Responsibility schemes meaning manufacturers will have to pay for the costs of waste management, clean up and awareness-raising measures for certain single-use plastics.
  • The new SUP Directive is expected in the coming months, but many Member States are already working on its implementation


Furthermore, it is important to note that:

  • The ECHA (European chemical agency) has assessed the health and environmental risks and submitted a restriction proposal on Microplastics (oxo bags are a major source of microplastics)
  • More than 3500 citizen have signed a petition to ban plastic bags in Montenegro in 2017



In the proposed waste management law in Montenegro:

The following restrictions from the Directive are included:

Chapter 56 «Privredno društvo koje upravlja sistemom preuzimanja, sakupljanjai obrade otpadne ambalaže, dužnoje da preduzme mjere za smanjivanje upotrebe plastičnih kesa, tako da:

– se lagane plastične kese za nošenje debljine zida manje od 50 mikrona od 31. januara 2020 ne daju besplatno na prodajnome mjestu robe ili proizvoda, i

– nivogodišnje potrošnje od 31. januara 2025. godine ne premaši 40 laganih plastičnih kesa debljine zida manje od 50 mikrona za nošenje po osobi.»


No information on oxo degradable plastic bags is included. Our recommendations about definitions and ban of this type of bags in accordance with new SUP Directive were deniedConsidering the policy change, ZWMNE reiterates its recommendation:


ZWMNE recommends one of the following definitions for new Waste law (Article 3):


  • ‘ oxo-degradable plastic’ means plastic materials that include additives which through oxidation lead to the fragmentation of the plastic material into micro-fragments or to chemical decomposition (new SUP Directive);


  • “oxo-degradable plastic carrier bags” shall mean plastic carrier bags made of plastic materials that include additives which catalyses the fragmentation of the plastic material into micro-fragments;“ (DIRECTIVE (EU) 2015/720)


It is also important to distinguish between “oxo-degradable” plastics, which fragment but do not biodegrade, except over a very long time, and “oxo-biodegradable” plastics which degrade and then biodegrade. The majority of oxo plastic bags in Montenegro are oxo-degradable.



Biodegradable bags:


Response from MORT says: The comment is not accepted, this definition is not necessary because the meaning of the word “biodegradable” is commonly known.


There is lots of confusion being made between bio-based plastic bags, bio-plastics, biodegradable bags, vegetable based plastics, oxo-biodegradable bags and also oxo-degradable bags. We therefore think defining biodegradable bags in the law is not superfluous.


Furthermore, the new updated draft of Single-Use Plastics Directive proposes the following definition:


  • ‘biodegradable plastic’ means a plastic capable of undergoing physical, biological decomposition, such that it ultimately decomposes into carbon dioxide (CO2), biomass and water and in accordance with European standards for packaging recoverable through composting and anaerobic digestion (new SUP Directive)


We previously recommended their use and inclusion of their definition in the law. To-date, there is still no standard on compostability in households; however the EU Commission is working on it.