Waste management mobile plants in Serbia

Environmental threats and the state of the planet Earth are the topics that people talk more and more about at the moment. Excessive use of plastic and the consequences this bad human habit has left for the world around us, especially for water species, is just one of the topics that should be addressed as soon as possible. And while we feel the consequences of our bad habits more and more in many different forms, in the form of ice cover melting, the sea level raising, the average temperatures increasing and water species dying because of plastic consumption, we begin slowly to work on ourselves in order to reduce the consequences we are leaving behind. The proof that we as humans are not just capable of destruction but creation as well is, among other things, human idea of recycling. Recycling represents the separation of waste material and its reuse. In this way, material used once does not have to “retire” after the “working life”, it is undergoing reincarnation and is thus used for the same or some other purposes. Unfortunately, Serbia is not one of the countries with a developed recycling culture, and generally speaking it is not a country that takes too much care about its environment, especially about the nature which is Serbia’s natural treasures. Therefore, just a short distance away from urban communities wild garbage dumps can be found, where often waste classified as hazardous is stored. For this reason, it is beneficial to talk more about the different aspects of waste, the consequences it is leaving on our planet and the way it can be managed.


What is waste management mobile plant?

According to the applicable Law on waste management (“the Law”)1, a waste management mobile plant is a plant for takeover, preparing for re-use, recovery, or other R or D list waste treatment operation (R2 to R13, D8, and D9), the construction of which is such that it is not connected with the ground or building, and may be relocated from one site to another. The Law also considers as waste management mobile plants those facilities used for the rehabilitation of a contaminated site, as a rule, on a waste production site, and/or on a waste producer’s site, or some other site owned by a waste producer for which the plant operator has the waste storage permit.2 In mobile plants, several R-waste management operations may be undertaken which, among other things include recycling, processing of organic material, processing of metals, processing of other materials, restoration of components used to reduce pollution, exposure to processes in land beneficial for agriculture or ecological progress3, while the waste treatment from the D list includes biological treatments and physicochemical treatments the product of which is a mixture or compound obtained from other disposal operations.4

First and foremost, waste management plants as well as waste management equipment can be fixed or mobile.

The reason why waste management mobile plants are significant is because they allow for waste created by one activity not to lie at the garbage dumps for hundred, thousand or even more years in order to freely disintegrate and be an unnecessary burden on the environment, but for waste to be disposed in a safe way or be transformed into something useful.

One of the characteristics of the law, in general, is that it is prone to changes, and the good side of that is that it is not that difficult to change it. This particular characteristic, in this case, proved to be significant because the original definition of waste management mobile plant adopted as the provision of the Law in 2009 was significantly different. The old definition of waste management mobile plants meant only the treatment of waste at the site where the waste was generated. With the Law amendments in 2016 the waste management mobile plants were enabled to also transport waste to another place for the purpose of its treatment, in situations where it is necessary. The main aim of the change was to avoid discrimination against certain existing operators. What has also been achieved is that the waste management mobile plants operators are not limited to the area where the waste was generated. In this way waste producers who are unable to install waste management mobile plants due to technical shortcomings, are able to administrate their waste to operators who will treat it safely at another location, in accordance with the permit of the competent authority. In this way the advantage of the waste management mobile plants is fully utilized, which is their ability to manage waste without being bound to only one location.

Purpose, operation and waste management mobile plants operating permit:

Waste management Mobile plants can simply be explained as waste treatment facility in a situation where the waste producer has no technical capacity or when waste producer never intended to independently perform waste treatment. Waste treatment mobile plants thus enable manufacturers to solve the waste generating problem by performing the activity in a lawful, safe and environmentally sound manner. In such case where the waste producer has a waste storage permit the waste management mobile plant can perform waste treatment at its location. In cases where the manufacturer does not have the capacity or when there is no waste storage permit, then the operator takes over the waste and transports it to another location to later conducts waste treatment. The waste operator is obliged to inform the competent authority about any change in the location of the waste treatment, as well as about the moment of starting and finishing the waste treatment activity.5 By preparing several ways to manage waste the legislator has avoided for waste to lie in garbage dumps and freely decompose for more years than the planet Earth can handle.

Waste management cannot be done by anyone, under their own terms, to performs activities in waste management mobile plants it is necessary to obtain the permit beforehand. The permit is issued by the Ministry of Environmental Protection (“Ministry“)6, while the minister responsible for environmental protection should closely determine which types of waste can be treated in mobile plants.7 An integrated permit can be issued for waste management, if the operator performs a number of activities, but the permit can also be issued only for waste collection, waste transport; waste treatment, which includes waste storage permit, waste recovery permit and waste disposal permit. The license is issued for a period of 10 years.

Prior to obtaining the license in order to fulfil the competences for permit, it is necessary to obtain a positive opinion of the inspection authority. When submitting a license application, the operator submits data on the technical and technological competences for waste treatment, methods used in performing activities, information about the capacity of the plant, as well as the qualifications of responsible persons and qualifications of the employees.8 Based on these data, the permit for waste treatment is issued by the Ministry.

The important thing to know is that the waste management mobile plant permit contains in particular the data on:

  • The origins of waste, destination of the location and waste treatment;
  • Technical and technological requirements for waste treatment plant;
  • Methods used for each individual operation;
  • Procedures for plant operation control and environmental monitoring;
  • Measures for protection against accidents, including accident prevention and accident impact alleviation requirements, measures for protection against fire, and procedures for plant closing.9

In this way it is secured that the operator always has clear and unambiguous data on the way in which it performs its business, and that it can always perform control of its own work without excuses.

Serbian Environmental Protection Agency keeps records of all legal entities who have been granted a permit for the waste storage, waste transport or waste treatment. By searching the agency’s registry, it is possible to obtain the records about legal entities that has obtained permit, and the waste activity for which the permit has been issued. Where the registry is lacking in is that it is not clearly stated when the license has been issued, and additional useful information would also be whether the control of the operator was performed by inspection authority and if so when it was performed. In addition to the register of the waste management permits, the Ministry, according to its legal obligation, regularly publishes data on submitted requests for permits issuing, as well as decisions for revoking of waste treatment permits on its website.

When it comes to the waste treatment, it is important to mention the responsibility when performing the treatment. For the waste treatment only responsible party is operator. In the case the treatment is executed on the location of the waste owner if the waste treatment is carried out in violation of the Law, and the issued permit the only responsible party is operator. The operator is obliged, during each waste treatment operation, to comply with the requirements stated in the permit issued by the Ministry. This very clear obligation removes the possibility of irresponsible performance of waste treatment.


Waste management mobile plant control:

Inspectors of the Ministry control the activity of the operators. Inspectors, inter alia, have the right to monitor the methods of treatment and take precautionary measures in accordance with the requirements defined in the permit.10 Inspectors also control fulfillment of the requirements for the activity of the holder of the waste treatment permit.11 In administration of its duties, the inspector is authorized to prohibit the waste treatment contrary to the requirements of the issued permit,12 as well as to prohibit the operation of the plant and the use of waste treatment equipment that is not used in accordance with the technical instructions of the permit.13 It would be better if the results of the control performed by the inspectors were available to the public, not just as the authorized notices, but as more detailed reports. It would secure more responsible performance of the operators and it would create a habit for the public to be more interested in its surroundings, but also to be engaged in conversation on a topic that is so important for the world as we know it.



In spite of the multiple amendments to the Law that were supposed to ensure its full implementation, such application has not yet been achieved, as there is still a gap in terms of Article 37, paragraph 5, which stipulates that The Minister shall prescribe in more detail the types of waste which may be treated in mobile plants and the types of mobile plants for which the waste treatment permit shall be issued. However, to the date, no regulations have been adopted to determine the type of waste that can be treated in mobile plants and the type of mobile plant for which waste treatment permits can be issued. With this omission, the Ministry jeopardized one of the basic objectives of the Law, which is waste management in a way that does not endanger human health and the environment.

Even thou temporarily there are shortcomings of the Law, it also prescribes positive solutions especially with regulation of illegal waste treatment. Positive solution of the Law certainly are its offences provisions. In addition to fines, which can definitely be useful, a more important is a protective measure that can be imposed on a company or other legal entity in the form of a prohibition of a certain business activity for a period of 10 years.14 This measure is accompanied with the measure for the responsible person in the legal entity which consists of prohibition of performing a certain duty for a duration of 10 years. When it comes to provisions regarding the Law offender whose offence can have broad and long-lasting consequences, perhaps even irreversible damage for people and the environment, in addition to fines, it is certainly important to have a protective measure that will prevent the Law offender from committing the same offense in the foreseeable future.

In the cases of revocation of the permit, the public should have an insight and understanding of the specific reasons for which a certain permit is taken away. It is important not to just formulate it in the general manner, because of the failure to comply with the requirements of the issued permit or failure to comply with the regulations of the Law, since that does not contribute to the achievement of the Law objectives. It is much more useful when it is explained to the public why the permit is revoked than when the public is only notified. If the fact that only in a few centuries (if we are lucky enough) the world as we know it won’t look the way it looks today is not enough listing the reasons of permit revocation and by explaining the reasons we need to create a greater connection between the problem and people, and thus achieve a greater interest in the topic.

  • 1. Law on waste management („Official Gazette RS“ No. 36/2009, 88/2010, 14/2016 and 95/2018-other law)
  • 2. Idem
  • 3. http://www.sepa.gov.rs/download/Otpad/5DiRLista.pdf
  • 4. http://www.sepa.gov.rs/download/Otpad/5DiRLista.pdf
  • 5. Article 64. paragraf 5. of the Law
  • 6. Article 60. paragraf 1 of the Law
  • 7. Article 57. paragraf 5 of the Law
  • 8. Article 62. paragraf 2 of the Law
  • 9. Article 64. paragraf 2. item 2) 3) 4) 6) and 7) of the Law
  • 10. Article 85. Paragraph 1. Item 5) of the Law
  • 11. Article 85. Paragraph 1. item 9) of the Law
  • 12. Article 86. paragraf 1. item 11) of the Law
  • 13. Article 86. paragraf 1. item 12) of the Law
  • 14. Article 89. paragraf 1.

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