NEW WASTE MANAGEMENT ACT

The National Assembly of the Republic of Serbia adopted the new Waste Management Act on 3 December 2025.¹

The Act entered into force on 12 December 2025, except for certain provisions whose application has been deferred until 1 January 2027.

The Act aims to improve the regulatory framework for waste management in Serbia and to further harmonize domestic legislation with EU regulations and international standards.

In addition to providing more precise definitions of terms already contained in the previous law (such as waste collection, waste storage, solidification, stabilization), the new Act introduces new concepts, including landfilling, material recovery, and food waste.

The list of measures for waste prevention, which was previously regulated exclusively by secondary legislation, is - for the first time - introduced at the statutory level. The focus is placed on sustainable production and consumption models, the development of durable and repairable products, and strengthening systems for reuse and repair. Special attention is devoted to reducing food waste at all stages of the supply chain, responsible management of products containing critical raw materials and hazardous substances, and identifying products that represent the largest sources of waste. The Act also emphasizes the importance of public awareness and education on waste prevention.

The new Act introduces a specific Waste Management Plan for Primary Waste Producers and prescribes its content. This document must be prepared and adopted by all primary waste producers who annually generate more than 100 tonnes of non-hazardous waste and/or more than 200 kilograms of hazardous waste, and who, under the previous law, were required to prepare a waste management plan applicable to facilities subject to an integrated permit.

One of the most significant novelties is the obligation for the holder and recipient of waste to submit to the Environmental Protection Agency a Document on the Movement of Non-Hazardous Waste. This document shall be submitted exclusively in electronic form, by entering data into the information system of the National Pollutant Source Register. The holder must submit the document no later than the day the waste movement begins, while the recipient must do so no later than seven days after the completion of the waste movement. These provisions shall apply as of 1 January 2027.

The Act also defines the obligations of waste collectors, further regulates the management of certain types of specific waste streams, and expands the powers of inspectors.

Furthermore, the new Act establishes an exception to the general ban on waste imports for energy recovery, allowing the import of certain types of non-hazardous waste, provided that a facility for energy recovery of waste in the Republic of Serbia holds a valid operating permit. The Government shall adopt an act prescribing the list of non-hazardous waste eligible for import, as well as the conditions for import and treatment, thereby creating a regulatory framework aimed at reducing reliance on fossil fuels and facilitating the transition from coal and other high-emission fuels.

Finally, a transitional period of one year is provided for the adoption of secondary legislation and for the alignment of business operations of legal and natural persons with the new rules.

Disclaimer: This text is for informational purposes only and does not constitute legal advice.